Attachment D I N T E R N A L A U D I T O R A N G E C O U N T Y AUDITOR-CONTROLLER. Page 1 of 6
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1 O R A N G E C O U N T Y AUDITOR-CONTROLLER I N T E R N A L A U D I T REPORT ON CONTINUOUS COMPLIANCE AUDITING OF THE TREASURY INVESTMENT PORTFOLIO FOR THE QUARTER ENDED DECEMBER 31, 2014 Job Number 1153 Report Date: June 26, 2015 Page 1 of 6
2 O R A N G E C O U N T Y AUDITOR-CONTROLLER I N T E R N A L A U D I T Orange County Auditor-Controller Eric H. Woolery, Auditor-Controller Nancy N. Ishida, CPA Scott Kim, CPA Erik Suarez Audit Manager Senior Auditor Intern Hall of Finance and Records 12 Civic Center Plaza, Room 200 Santa Ana, CA Orange County Web Site Page 2 of 6
3 ERIC H. WOOLERY, CPA AUDITOR-CONTROLLER June 26, 2015 Job No TO: SUBJECT: Members, Treasury Oversight Committee Continuous Compliance Auditing of the Treasury Investment Portfolio For the Quarter Ended December 31, 2014 We have completed the continuous compliance auditing of the Treasury investment portfolio for the quarter ended December 31, The purpose of our engagement was to determine whether the Orange County Money Market Fund, Educational Money Market Fund, John Wayne Airport Investment Pool, Extended Fund, and Fund 100-General Fund-Tax Exempt Non AMT (100-GF) investments managed by the Orange County Treasurer s Office were in compliance with certain provisions specified in the Investment Policy Statement (IPS) and Board Resolution We are continuing our continuous compliance auditing of the Treasury investment portfolio at the request of the Treasury Oversight Committee. Our continuous auditing is designed to provide reasonable assurance to the Board of Supervisors, the County Executive Officer, Treasury Oversight Committee, and other stakeholders that the Treasury investment portfolio is in compliance with specific provisions of the IPS and Board Resolution , where applicable, and that non-compliance deficiencies or technical incidents and required disclosures are properly reported in the Treasurer s Monthly Investment Reports for October, November, and December Our compliance procedures included judgmentally selecting 10 business days for testing from each month and importing the selected electronic downloads from the Treasurer s Quantum System into ACL, a computer-assisted audit technique software, for purposes of performing calculations and validating that investment purchases were in compliance with the IPS by reviewing and testing supporting documentation. In conducting our procedures, we examined the following days in October: 1, 3, 6, 8, 14, 20, 24, 28, 29, and 31, November: 3, 6, 10, 13, 14, 17, 19, 21, 24 and 26, and December: 1, 4, 9, 11, 15, 19, 23, 26, 29, and 31. Based on our continuous compliance auditing for the selected dates, no compliance issues were identified. When applicable, our report also includes information regarding the Treasurer s reporting of technical incidents in the monthly investment report. The Treasurer defines a technical incident as an event, other than the purchase of a security, which causes an IPS limit to be exceeded. The most common cause of a technical incident is when the total investment pool holdings decrease causing the relative percentage of holdings to increase. AUDITOR-CONTROLLER 12 CIVIC CENTER PLAZA, ROOM 200 SANTA ANA, CALIFORNIA PHONE (714) FAX (714) eric.woolery@ac.ocgov.com ac.ocgov.com 1 Page 3 of 6
4 Continuous Compliance Auditing of the Treasury Investment Portfolio For the Quarter Ended December 31, 2014 The following lists the procedures performed and results achieved from the compliance continuous auditing procedures: 1. Authorized Investments (IPS Section VI, VII, VIII, and Board of Supervisors Resolution ): We judgmentally selected a sample of 43 investments representing each pool. The sample was selected from investments purchased on the 30 business days selected for review from October through December For the sample selected, we independently confirmed that the investments conform to authorized investment requirements in accordance with the IPS. We also confirmed for the Pooled Funds that the Treasurer used issuers and brokers who were on the Treasurer s authorized lists. Since the 100-GF investments are not pooled funds, we did not verify that the Treasurer used issuers on the Treasurer s authorized lists. However, we did verify that sampled purchases were taxexempt government securities not subject to the Alternative Minimum Tax (AMT) as required by Board of Supervisors Resolution Diversification Compliance (IPS Section VIII.1): We performed calculations to determine that the Money Market and Extended Fund portfolios met the diversification limits for investment types in accordance with the IPS. 3. Weighted Average Maturity (WAM) Limitations (IPS Section VIII.3): We performed calculations to determine that WAM did not exceed 60 days for the Money Market Funds in accordance with the IPS. 4. Maximum Maturity Limitations (IPS Section VIII.3 and Board of Supervisors Resolution ): We confirmed that the maximum maturity of any portfolio instrument purchased did not exceed 13 months (397 days) for the Money Market Fund and 5 years (1,826 days) for the Extended Fund in accordance with the IPS. For 100-GF investments, we verified that the maximum maturity of any investment in this fund did not exceed a year (365 days) as required by Board of Supervisors Resolution Page 4 of 6
5 Continuous Compliance Auditing of the Treasury Investment Portfolio For the Quarter Ended December 31, Investment Type Maximum Maturity Limitations (IPS Section VIII.1): We confirmed that the maximum maturity of commercial paper, banker s acceptances, or repurchase agreements purchased did not exceed 270 days for commercial paper, 180 days for banker s acceptances, or 1 year (365 days) for repurchase agreements in accordance with the IPS. 6. Issuer Limitations (IPS Section VIII.2): We performed calculations to determine that the Money Market and Extended Fund portfolios did not exceed the investment limits for issuers in accordance with the IPS. Results: We found one technical incident that occurred on one of the days selected for testing. Orange County Educational Money Market Fund Technical Incident 1. The percentage of portfolio holdings in Toronto Dominion Bank NY exceeded 5% of the total market value of the portfolio by 0.16%. These investments were fully compliant with issuer limitations at the time of purchase, however, a technical incident occurred on November 10 when a temporary reduction in the total assets resulted in an increased percentage in Toronto Dominion Bank NY holdings. The Treasurer s November 2014 Monthly Investment Report noted technical incidents in the Educational Money Market Fund. 7. Financial Reporting (IPS Section XXI): We confirmed that the October 31, 2014, November 30, 2014, and December 31, 2014 Treasurer s Monthly Investment Reports included all statements of portfolio non-compliance in accordance with the IPS, and any technical incidents were reported consistent with the Treasurer s policy. Results: Review of Investment Policy Compliance Summary" The Treasurer s Monthly Investment Report includes an Investment Policy Compliance Summary to disclose non-compliance issues that occurred during the month. The Treasurer s Investment Policy Compliance Summary for October, November, and December reported no compliance issues. 3 Page 5 of 6
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