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• <br />VIII. MANAGEMENT AND INTERNAL CONTROLS <br />The Director of Finance shall establish a system of internal controls which shall <br />be reviewed by an independent auditor. The controls shall be designed to <br />prevent losses of public funds arising from fraud, employee error, <br />misrepresentation by third parties, unanticipated changes in financial markets, <br />or imprudent actions by employees or Investment Officers of the City. <br />Controls and managerial emphasis deemed most important that shall be <br />employed where practical are: <br />A. Control of collusion. <br />B. Separation of duties. <br />C. Separation of transaction authority from accounting and record keeping. <br />D. Custodian safekeeping receipts records management. <br />E. Avoidance of bearer-form securities. <br />F. Clear delegation of authority. <br />G. Documentation on investment bidding events. <br />H. Written conformation of telephone transactions. <br />I. Reconcilement and comparisons of security receipts with the investment <br />subsidiary records. <br />J. Compliance with investment policies. <br />K. Accurate and timely reports. <br />L. Validation of investment maturity decisions with supporting cash flow <br />data. <br />M. Adequate training and development of Investment Officials. <br />N. Verification of all interest income and security purchase as sell <br />computations. <br />O. Review of financial condition of all brokers, dealers and depository <br />institutions. <br />P. Staying informed about market conditions, changes, and trends that <br />require adjustments in investment strategies. <br />7 <br />