AUDITOR CONTROLLER I N T E R N A L A U D I T
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1 Orange County Auditor-Controller Internal Audit Compliance Monitoring of the Treasurer s Investment Portfolio for the Quarter Ended December 31, 2017 Audit Number 1721 Report Date: March 27, 2018
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 Eric H. Woolery, CPA Orange County Auditor Controller Scott Suzuki, CPA, CIA, CISA Lily Chin, CPA, CGMA Michael Steinhaus, CPA, CGMA Nancy Ramos Director of Internal Audit Audit Manager II Audit Manager I Auditor I 12 Civic Center Plaza, Room 200 Santa Ana, CA Auditor Controller Website
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4 Table of Contents Compliance Monitoring of the Treasurer s Investment Portfolio Audit No Transmittal Letter i Internal Auditor s Report 1
5 Internal Auditor s Report Audit No March 27, 2018 Richard Rohm, CPA, Chair, Public Member Treasury Oversight Committee 625 North Ross Street, Building 11 Santa Ana, California We have completed the compliance monitoring of the Treasurer s Investment Portfolio for the quarter ended December 31, The purpose of our engagement was to determine whether the Orange County Investment Pool (OCIP), Orange County Educational Investment Pool (OCEIP), and various other non-pooled investments managed by the Treasurer, such as John Wayne Airport Investment Fund, were in compliance with the applicable provisions of its Investment Policy Statement (IPS) and that instances of noncompliance, including technical incidents, were properly reported in the Treasurer s Monthly Investment Report. It is important to note that the Treasurer further invests pooled funds from the OCIP and OCEIP into three funds: the Orange County Money Market Fund (OCMMF) and the Orange County Educational Money Market Fund (OCEMMF) (collectively referred to as Money Market Funds), and the Extended Fund. We perform the compliance monitoring of the Treasurer s investment portfolio at the request of the Treasury Oversight Committee. The monitoring is designed to provide limited assurance to the Treasury Oversight Committee and the Office of the Treasurer-Tax Collector that the Treasurer s investment portfolio is in compliance with specific provisions of the IPS, and that instances of noncompliance, technical incidents and required disclosures are properly reported. Our compliance procedures included judgmentally selecting five (5) 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, to perform calculations and determine whether investment purchases were in compliance with the IPS. Based on the procedures performed, no instances of noncompliance were identified. When applicable, our report also includes information regarding the Treasurer s reporting of technical incidents in the Treasurer s Monthly Investment Reports. 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. Compliance Monitoring of the Treasurer s Investment Portfolio Audit No Page 1
6 Internal Auditor s Report The following lists the procedures performed and results achieved: 1. Authorized Investments (IPS Section VI, VII, VIII, IX, XI): We judgmentally selected a sample of 15 investments purchased during the quarter (one investment for each of the 15 business days selected for testing). For the samples selected, we confirmed that the investments conform to authorized investment requirements in accordance with the IPS. We also confirmed that the investments were purchased from issuers or brokers on the Treasurer s authorized lists. 2. 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, and that the John Wayne Airport Investment Fund met those diversification limits as well. 3. Weighted Average Maturity (WAM) Limitations (IPS Section VIII.2): We performed calculations to determine that WAM did not exceed 60 days for the Money Market Funds in accordance with the IPS and that WAM did not exceed 90 days for the John Wayne Airport Investment Fund. 4. Maximum Maturity Limitations (IPS Section VIII.2): We confirmed that the maximum maturity of any portfolio instrument purchased did not exceed 397 days for the Money Market Funds, 5 years for US treasury, government sponsored enterprise, and municipal debt securities, and 3 years for medium-term notes and negotiable certificates of deposits for the Extended Fund, in accordance with the IPS and that the maximum maturity did not exceed 15 months for the John Wayne Airport Investment Fund. 5. Investment Type Maximum Maturity Limitations (IPS Section VIII.1): We confirmed that the maximum maturity of investments purchased for commercial paper, bankers acceptances, and repurchase agreements did not exceed 270 days for commercial paper, 180 days for bankers acceptances, or one year for repurchase agreements in accordance with the IPS. 6. Issuer Limitations (IPS Section VIII.1): 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, and that the John Wayne Airport Investment Fund did not exceed those investment limits. Compliance Monitoring of the Treasurer s Investment Portfolio Audit No Page 2
7 Internal Auditor s Report 7. Financial Reporting (IPS Section XXI): We reviewed the investment portfolio for a sample of 15 business days to determine that any instances of non-compliance or technical incidents were properly reported in the Treasurer s Monthly Investment Report in accordance with the IPS. This report is intended solely for the information and use of the Treasury Oversight Committee and the Office of the Treasurer-Tax Collector; however, this report is a matter of public record and its distribution is not limited. Compliance Monitoring of the Treasurer s Investment Portfolio Audit No Page 3
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