ramapo

Document Sample
ramapo Powered By Docstoc
					OFFICE   OF THE   NEW YORK STATE COMPTROLLER
                  D IVISION OF LOCAL GOVERNMENT
                      & SCHOOL ACCOUNTABILITY




   Town of Ramapo
   Internal Controls Over
Selected Financial Activities

           Report of Examination
                    Period Covered:
         January 1, 2009 — November 17, 2010
                       2011M-143




               Thomas P. DiNapoli
                              Table of Contents
                                                                               Page

AUTHORITY LETTER                                                                3


EXECUTIVE SUMMARY                                                               4


INTRODUCTION                                                                    6
           Background                                                           6
           Objective                                                            6
           Scope and Methodology                                                7
           Comments of Town Officials and Corrective Action                      7


BOARD OVERSIGHT                                                                 8
           Recommendations                                                      9


BASEBALL STADIUM CAPITAL PROJECT                                               10
            Stadium Financing                                                  10
            Feasibility Analysis                                               13
            Recommendations                                                    14


FINANCIAL CONDITION                                                            15
            Budget Estimates                                                   15
            Operating Deficits and Fund Balance                                 16
            Exceeding Appropriations                                           18
            Inter-Fund Advances                                                19
            Recommendations                                                    20


INFORMATION TECHNOLOGY                                                         21
            Breach Notification                                                 21
            Disaster Recovery                                                  22
            Auto Complete Setting                                              22
            User Accounts                                                      23
            Inappropriate Computer Use                                         24
            Information Security Awareness Training                            24
            Banking Policy                                                     25
            Recommendations                                                    25


                      DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY          11
APPENDIX   A   Response From Town Officials                     26
APPENDIX   B   OSC Comments on the Town Officials’ Response     50
APPENDIX   C   Audit Methodology and Standards                 58
APPENDIX   D   How to Obtain Additional Copies of the Report   60
APPENDIX   E   Local Regional Office Listing                    61




 2     OFFICE OF THE NEW YORK STATE COMPTROLLER
                                              State of New York
                                 Office of the State Comptroller


Division of Local Government
and School Accountability

February 2012

Dear Town Officials:

A top priority of the Office of the State Comptroller is to help local government officials manage
government resources efficiently and effectively and, by so doing, provide accountability for
tax dollars spent to support government operations. The Comptroller oversees the fiscal affairs of
local governments statewide, as well as compliance with relevant statutes and observance of good
business practices. This fiscal oversight is accomplished, in part, through our audits, which identify
opportunities for improving operations and Town of Ramapo governance. Audits also can identify
strategies to reduce costs and to strengthen controls intended to safeguard local government assets.

Following is a report of our audit of Town of Ramapo, entitled Internal Controls Over Selected
Financial Activities. This audit was conducted pursuant to Article V, Section 1 of the State
Constitution and the State Comptroller’s authority as set forth in Article 3 of the General Municipal
Law.

This audit’s results and recommendations are resources for local government officials to use in
effectively managing operations and in meeting the expectations of their constituents. If you have
questions about this report, please feel free to contact the local regional office for your county, as listed
at the end of this report.

Respectfully submitted,


Office of the State Comptroller
Division of Local Government
and School Accountability




                            DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                     33
                                                                 State of New York
                                                    Office of the State Comptroller
                                                      EXECUTIVE SUMMARY


The Town of Ramapo (Town) is located in Rockland County and has 12 villages, including Airmont,
Chestnut Ridge, Hillburn, Kaser, Montebello, New Hempstead, New Square, Pomona, Sloatsburg,
Spring Valley, Suffern and Wesley Hills. The Town Board (Board) is the governing and legislative
body of the Town. It determines policy and appropriates funds for various governmental functions and
services. The Board has the rights to adopt and manage the budget, control and have custody of Town
property, and oversee the Town’s various Departments.

The Town provides various services to its residents, including maintaining and improving Town
roads, snow removal, public improvements, recreation and cultural activities, water, and general
governmental support. Budgeted appropriations for the fiscal years 2009 and 2010 were $71.4 million
and $74.9 million, respectively.

Scope and Objective

The objective of our audit was to assess the Town’s internal controls over selected financial activities
for the period January 1, 2009, to November 17, 2010. We expanded the scope of our audit to include
January 1, 2008, to May 18, 2011, to review the trends associated with the Town’s finances and to
include the Town’s actions related to the baseball stadium construction project. Our audit addressed
the following related questions:

   •   Did Town officials properly oversee and monitor the planning and construction of the baseball
       stadium?

   •   Are internal controls over the Town’s finances appropriately designed to safeguard Town
       assets?

   •   Are internal controls over the Town’s information technology (IT) system appropriately
       designed to protect electronic data?

Audit Results

Town officials have inappropriately mingled the activities of the Town and the Ramapo Local
Development Corporation (RLDC) in the construction of a minor league baseball stadium. These
actions allowed Town officials to circumvent laws the Town is required to abide by for the
approval and construction of such projects, and has resulted in the Town paying over $35.4 million in
improvement costs and being liable for at least $25 million in bonds issued for debt on property that

  4         OFFICE OF THE NEW YORK STATE COMPTROLLER
the Town no longer owns. In addition, there is little likelihood that the project will generate sufficient
revenue to help the Town pay for this outstanding liability.

The Town will pay approximately $27.5 million1 in principal and interest payments on these bonds
over the next five years. This is significantly more than the approximately $7 million a feasibility
consultant projected the baseball stadium would generate in net revenues available for debt service
during the same time frame. The Town does not have a written agreement with the RLDC outlining
how the RLDC will reimburse the Town for the principal and interest on these bonds. Supposedly,
the RLDC is relying on revenues that will be generated from the sale of affordable housing units to
reimburse the Town. However, the RLDC obtained loans of approximately $29.9 million that were
also guaranteed by the Town to build these units. These loans must be repaid before any revenues
generated from the sale of the units can be made available to reimburse the Town for payments related
to the $25 million bonds. As a result, it is unlikely that the RLDC will be able to reimburse the Town
for the full principal and interest payments made on the $25 million bonds.

We found that the Board has not exercised effective oversight of the Town. Board members told us that
they received no financial reports, such as detailed project cost reports for Town projects (including
the baseball stadium), budget versus actual reports, and generally did not receive or review contracts.
Additionally, Board members told us that they did not know how much the baseball stadium would
cost the taxpayers or how it would be paid for.

We also found that, in 2010, the Town had depleted its fund balances in three major operating funds
because of unrealistic revenue estimates and the Board’s failure to monitor and adjust the budget
when it became clear that the Town would not achieve anticipated results. During 2009 and 2010, the
Town advanced approximately $3.3 million and $3.9 million, respectively, among funds with differing
tax bases, but failed to pay back those funds by the close of the fiscal year as required by law. The
advancing funds lost $17,243 in interest because they were not paid back with a comparable rate of
interest.

The Board did not establish adequate information technology policies, including a breach notification
policy, online banking policy or policies for assigning or deactivating user accounts. Further, the
Board has not adopted an entity-wide disaster recovery plan; therefore, in the event of a disaster, Town
personnel have no guidelines or plan to follow to resume mission-critical functions. In addition, the
auto-complete setting was enabled on the online banking computer. We also found multiple instances
of non-work-related computer usage. As a result, the Town’s computer system and electronic data may
be susceptible to loss, unauthorized use, or improper disclosure.

Comments of Town Officials

The results of our audit and recommendations have been discussed with Town officials and their
comments, which appear in Appendix A, have been considered in preparing this report. Town officials
disagreed with our findings. Appendix B includes our comments on issues that Town officials raised
in their response letter.




1
    This includes $25 million in principal + $2.5 million in interest.
                                  DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY            55
                                    Introduction

Background                  The Town of Ramapo (Town) is located in Rockland County and
                            has 12 villages, including Airmont, Chestnut Ridge, Hillburn, Kaser,
                            Montebello, New Hempstead, New Square, Pomona, Sloatsburg,
                            Spring Valley, Suffern and Wesley Hills. The Town provides various
                            services to its residents, including maintaining and improving Town
                            roads, snow removal, public improvements, recreation and cultural
                            activities, water, and general governmental support.

                            The Town Board (Board) is the governing and legislative body of
                            the Town. It determines policy and appropriates funds for various
                            governmental functions and services. The Board comprises the Town
                            Supervisor (Supervisor) and four councilpersons. Councilpersons
                            are elected at large in odd-numbered years for four-year terms; these
                            terms are staggered so that two councilpersons are elected each
                            biennial session.

                            The Supervisor is the chief executive officer of the Town and is
                            responsible, along with other administrative staff, for the day-to-
                            day management of the Town under the direction of the Board. The
                            Supervisor, who also is a voting member of the Board and Director
                            of Finance, is responsible for oversight of the Town’s ongoing capital
                            projects and general Town finances. Budgeted appropriations for the
                            fiscal years 2009 and 2010 were $71.4 million and $74.9 million,
                            respectively.

                            The Director of Automated Systems (Director) is responsible for
                            the day-to-day operations of the Information Technology (IT)
                            Department, which is overseen by the Supervisor and the Board. The
                            Department comprises two IT personnel who report to the Director.
                            The IT Department is responsible for the Town’s 41 laptops, 179
                            desktop computers, and 26 servers. The Town contracts with various
                            outside vendors for IT-related services.

Objective                   The objective of our audit was to assess the internal controls over
                            selected financial activities including the construction of a baseball
                            stadium, financial condition and information technology. Our audit
                            addressed the following related questions:

                                •   Did Town officials properly oversee and monitor the planning
                                    and construction of the baseball stadium?

                                •   Are internal controls over the Town’s finances appropriately
                                    designed to safeguard Town assets?

  6         OFFICE OF THE NEW YORK STATE COMPTROLLER
                            •   Are internal controls over the Town’s IT system appropriately
                                designed to protect electronic data?

Scope and                We examined the Town’s internal controls over selected financial
Methodology              activities, including the baseball stadium, financial condition and IT
                         for the period January 1, 2009, to November 17, 2010. We expanded
                         the scope of our audit to include January 1, 2008, to May 18, 2011, to
                         review the trends associated with the Town’s finances and to include
                         the Town’s actions related to the baseball stadium.

                         Our audit disclosed areas in need of improvement concerning some
                         IT controls. Because of the sensitivity of this information, certain
                         vulnerabilities relating to passwords are not discussed in this report
                         but have been communicated confidentially to Town officials so they
                         could take corrective action.

                         We conducted our audit in accordance with generally accepted
                         government auditing standards (GAGAS). More information on
                         such standards and the methodology used in performing this audit is
                         included in Appendix C of this report.

Comments of              The results of our audit and recommendations have been discussed
Town Officials and        with Town officials and their comments, which appear in Appendix
Corrective Action        A, have been considered in preparing this report. Town officials
                         disagreed with our findings. Appendix B includes our comments on
                         issues that Town officials raised in their response letter.

                         The Board has the responsibility to initiate corrective action. A
                         written corrective action plan (CAP) that addresses the findings and
                         recommendations in this report should be prepared and forwarded
                         to our office within 90 days, pursuant to Section 35 of the General
                         Municipal Law. For more information on preparing and filing your
                         CAP, please refer to our brochure, Responding to an OSC Audit
                         Report, which you received with the draft audit report. We encourage
                         the Board to make this plan available for public review in the Clerk’s
                         office.




                    DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                77
                        Board Oversight

                    The Board has a fiduciary responsibility for Town assets and finances,
                    and an obligation to serve the community, protect taxpayers’
                    interests, and exercise good faith and due diligence. The Board, along
                    with Town officials, is responsible for managing and overseeing
                    the Town’s overall fiscal affairs and safeguarding its resources.
                    This responsibility includes establishing a sound internal control
                    environment.

                    An important component of any system of internal controls is the
                    control environment or “the tone at the top.” The control environment
                    is the foundation of a good internal control system, providing
                    discipline and structure upon which the other components are
                    based. It reflects management’s attitude about internal controls and
                    includes the integrity, ethical values, and competence of the entity’s
                    personnel, and management’s philosophy and operating style. When
                    this foundation is not strong or the control environment is not positive,
                    the overall system of internal controls will not be as effective as it
                    should be. The Board and Town officials must act with the highest
                    ethical standards and carry out their oversight responsibilities in
                    conformance with applicable laws, rules and guidelines that they
                    expect their employees to follow. The Board and Town officials must
                    be leaders in diligently protecting Town resources that are entrusted
                    to them.

                    As the legislative body, the Board should establish and oversee much
                    of the policy, financial, and ethical framework within which the Town
                    operates. Through its actions and policies, the Board should chart
                    the course for the Town’s activities. The Board is responsible for
                    monitoring the results of operations. Local governments routinely
                    participate in construction projects that span several years and cost
                    millions of dollars. It is important that the Board monitor the status of
                    these substantial projects. The most common disclosures are project-
                    based financial statements providing selected details of each project,
                    such as total cost-to-date compared to budget or authorization.

                    The Board has not exercised effective oversight of the Town. The
                    Board neither established policies nor oversaw the Town’s financial
                    operations. Board members told us that they received no financial
                    reports, such as detailed project cost reports for Town projects
                    (including the baseball stadium discussed in the next section),
                    budget versus actual reports, and generally did not receive or review
                    contracts. The Board made its decisions based upon representations
                    from the Town Attorney and Supervisor. Additionally, although Board

8   OFFICE OF THE NEW YORK STATE COMPTROLLER
                       members should ensure they receive all necessary information, for
                       the most part, they have not requested the information or ensured that
                       they received requested information. In fact, Board members told us
                       that they did not know how much the baseball stadium would cost the
                       taxpayers or how it would be paid for. Without proper information,
                       there is a risk that inappropriate decisions may be made which could
                       result in further costs to taxpayers.

Recommendations        1. The Board should establish and maintain a control environment
                          that fosters a commitment to compliance with relevant laws and
                          Town policies. The Board also should routinely monitor the
                          implementation and effectiveness of the internal control system.

                       2. The Board should ensure that financial decisions are based upon
                          competent information.

                       3. The Board should require the Supervisor to provide project-based
                          cost reports.




                  DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                99
                    Baseball Stadium Capital Project

                          Capital projects are usually long-term projects which require
                          relatively large sums of money to acquire, develop, improve, or
                          maintain. The Board is responsible for oversight and management of
                          the Town’s capital projects, including establishing internal controls to
                          help ensure that capital projects are properly and adequately planned
                          and managed. Effective controls help ensure that projects are
                          properly planned, funding is authorized, and project costs are kept
                          within their approved budget.

                          Local Development Corporations (LDCs) are private, not-for-profit
                          corporations often created by, or for the benefit of, local governments
                          for economic development or other public purposes. Although created
                          by, or for the benefit of a local government, an LDC is a separate
                          private corporation, distinct from the local government, having its
                          own set of powers under the governing statutes. In exercising these
                          powers, LDCs generally are not subject to the same requirements
                          and procedures as local governments with respect to borrowing,
                          procurements and certain other matters that relate to implementing
                          a capital project. These requirements and procedures applicable to
                          local governments are intended for the protection of taxpayers.

                          In September 2008, the Board formed the Ramapo Local
                          Development Corporation (RLDC). According to the RLDC’s
                          Certificate of Incorporation, the RLDC’s mission and objective is to
                          "lessen the burdens of government by undertaking and promoting
                          urban redevelopment initiatives in the Town…that will include
                          real estate acquisition, development and management, real estate
                          project finance, and other [permissible] community-based economic
                          development activities…” The Supervisor, who is a voting member
                          of the Board, serves as the President and a voting member of the
                          RLDC.

Stadium Financing         In June 2009, the Board purchased approximately 61 acres of property
                          located at Fireman’s Memorial Drive and Pomona Road for a cost
                          of $8.4 million for general municipal purposes. Subsequent to the
                          purchase, the Board decided to build a baseball stadium, as part of an
                          urban renewal plan, which would serve as the home field for a minor
                          league baseball team with approximate seating capacity of 3,500 and
                          parking for 900 vehicles. In February 2010, the Board entered into an
                          agreement with the RLDC to assist the Town with the development
                          of the baseball stadium.




 10       OFFICE OF THE NEW YORK STATE COMPTROLLER
     Board members indicated that they believed that the RLDC could
     build the stadium at a lesser cost because the RLDC does not have
     to comply with the Wicks Law. The Wicks Law generally requires
     multiple prime contracts for public works projects for the construction
     of buildings. When the Wicks Law applies, municipalities must
     award separate prime contracts for three major components of the
     work: electrical, plumbing, and HVAC (heating, ventilating and air
     conditioning). One or more contracts generally are awarded to general
     contractors for the remainder of the project scope. Furthermore,
     General Municipal Law (GML) requires that local governments
     competitively bid contracts for public work that involve expenditures
     in excess of $35,000. By using the RLDC to construct the stadium,
     the Board, in effect, circumvented the procurement laws that would
     have applied if the Town directly pursued the project.

     In May 2010, the Board, by resolution, agreed to guarantee $16.5
     million in financing to be obtained by the RLDC. Generally, with
     several exceptions, the State’s Constitution (article VIII, §1) prohibits
     a town from loaning its credit (e.g., guaranteeing loans) to or in aid of
     any public or private corporation or association.

     Town taxpayers filed a petition for a special election on the
     resolution. The petition sought to directly protest the Board’s
     resolution which authorized and agreed to provide a financial
     guarantee of the financing to be obtained by the RLDC for the
     development of the baseball stadium. In August 2010, the Board’s
     resolution was defeated, with 71 percent of the votes cast against it.
     According to published reports, the Supervisor subsequently stated
     that the stadium would be built with private and not taxpayer funding.

     Following the vote, the Board continued to expend Town funds on
     improvements to the property. In November 2010, with knowledge
     that the RLDC was unable to obtain or generate the necessary
     funds to complete the project, the Board, by resolution, transferred
     the property to the RLDC. Although the Town transferred the
     property, it retained responsibility to pay for the $8.4 million in debt
     associated with the original purchase of the property and subsequent
     improvements, which are estimated to be an additional $27 million.
     As a result of this decision, Town taxpayers have liability, or potential
     liability, for as much as $35.4 million2 in costs associated with a
     property the Town no longer owns.

     In February 2011, the Board passed a resolution agreeing to serve as
     “guarantor” of $25 million in short term obligations to be issued

     2
       The cost shown above represents unaudited amounts as of June 8, 2011, and is not
     the total cost, as the project was ongoing as of this date.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                           11
                                                                                11
                     by the RLDC with a maturity date not to exceed five years.
                     Taxpayers had previously indicated that they were opposed to the
                     guarantee of 30-year bonds; in an apparent attempt to avoid the
                     voters’ opposition and guarantee the RLDC bonds, bonds with five-
                     year terms were agreed upon. Under the “guarantee,” the Town has
                     agreed to be obligated to pay the principal and interest payments
                     directly, with reimbursement from the RLDC. The Town agreed
                     to a risky guarantee whereby revenues were pledged to pay these
                     liabilities before any other Town payments were made. This could
                     affect payments such as salaries and could impact essential services
                     provided by the Town. Further, this may give RLDC bondholders a
                     prior right to be paid over those holding obligations issued directly
                     by the Town.3

                     The Town does not have a written agreement with the RLDC
                     outlining how the RLDC will reimburse the Town for the principal
                     and interest on the $25 million bonds that the Town is obligated
                     to pay. To demonstrate the RLDC’s ability to reimburse the Town,
                     the bond prospectus indicates that the RLDC is relying on revenues
                     that will be generated from the sale of affordable housing units
                     to reimburse the Town for the principal and interest payments.
                     However, the RLDC obtained loans of approximately $29.9 million
                     that were guaranteed by the Town to build the affordable housing
                     units. These loans must be repaid before any revenues generated
                     from the sale of the units are made available to reimburse the Town
                     for payments related to the $25 million bonds. Further, due to the
                     economic downturn in the housing market, the sale of the housing
                     units may not occur within the anticipated timeframe and estimated
                     sales revenues may not be realized by the RLDC. As a result, the
                     RLDC may be unable to reimburse the Town for the principal and
                     interest payments made on the $25 million bonds.



                     3
                        We understand that several issues related to the stadium’s financing remain in
                     litigation. Therefore, we have not made findings on underlying legal issues relating
                     to the financing. Nonetheless, we find that the transaction raises significant legal
                     issues, including: 1) The New York State (NYS) Constitution generally prohibits
                     towns from loaning their credit (e.g., guaranteeing loans) to or in aid of any
                     private or public corporation or association; 2) A local government may not submit
                     a proposition to referendum, even upon petition of the voters, unless expressly
                     authorized or required by statute. It is not clear under what statute the resolution
                     was made subject to permissive referendum; 3) The NYS Constitution prohibits
                     towns from making gifts or loans of property to or in aid of private entities.
                     Although characterized by the Town and the RLDC as a “Purchase and Sale,” the
                     Town received no cash consideration for transfer of property. The “purchase price”
                     under the transfer agreement was stated as “RLDC’s development and construction
                     of the Project…and the resulting community benefits to be derived therefrom…” It
                     is unclear whether the purchase and sale is for adequate consideration so as not to
                     constitute an unconstitutional gift by the Town.

12   OFFICE OF THE NEW YORK STATE COMPTROLLER
                            While there is no written agreement, the RLDC has committed to
                            provide the revenues generated from the sale of affordable housing
                            units to reimburse the Town for the principal and interest payments
                            on the short term obligations issued in connection with the baseball
                            stadium. These excess funds could have been used to fund other
                            RLDC initiatives. This commitment will significantly impact the
                            ability of the RLDC to further its mission and achieve its stated goals
                            of lessening the burdens of government by undertaking and promoting
                            urban redevelopment initiatives in the Town.

                            As a result of the decisions the Board made, Town taxpayers are
                            now potentially responsible for approximately $35.4 million in
                            expenditures for a property not owned by the Town. Furthermore, the
                            Town has agreed to guarantee an additional $25 million in short-term,
                            five-year bonds issued by the RLDC, after taxpayers had previously
                            voted against a resolution that guaranteed financing of 30-year bonds
                            that were to be issued by the RLDC.

Feasibility Analysis        When implementing a capital project, Board members should ensure
                            that there is a well-defined plan, which evaluates the cost of a project
                            and the potential costs to taxpayers.

                            In an effort to determine the feasibility of the baseball stadium, the
                            RLDC contracted with an outside vendor to perform a feasibility
                            analysis. We reviewed this analysis and found that it was inadequate.
                            We found that the consultant only considered the costs of the structure
                            to be built; it did not consider the total cost of the project. Specifically,
                            we found the following:

                            •   The consultant did not incorporate the cost of the land or necessary
                                property improvements to erect the structure.

                            •   The consultant chose facilities that were built in 2002 and prior,
                                which resulted in a cost per capacity4 of $3,581.

                            •   We found projects from 2005 to 2010 with cost per capacity
                                ranging from $3,900 to $6,788.

                            •   The figures used within the report were not consistent from one
                                section to the next, and figures such as cost per capacity could not
                                be recomputed based upon the information provided.




                            4
                              Capacity is the total amount of seating available; therefore, the cost per capacity
                            represents the amount of money it costs per seat. It is calculated by taking the total
                            cost to build and dividing it by the number of seats.

                       DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                                13
                                                                                                            13
                         The consultant’s report also included revenue estimates from the
                         operation of the baseball stadium. The consultant estimated that the
                         baseball stadium would generate approximately $1.2 million in its
                         first year of operation that would be available to pay debt service.
                         The consultant projected this amount would increase gradually to
                         approximately $1.7 million in year 10.

                         The consultant concluded that $20 million for vertical construction
                         was the maximum amount that could be supported by the projected
                         revenues. In making this assumption, the consultant anticipated that
                         the RLDC would issue 32-year bonds to finance the project.

                         Further, only one of the four Board members stated that he received
                         and reviewed the report; the remaining members did not receive the
                         report at all. The Supervisor, who is also the President of the RLDC,
                         relied upon this analysis to support his decision to construct and
                         operate a baseball stadium. The analysis did not contain sufficient
                         information to substantiate the decision to build the baseball stadium.

                         When the RLDC was unable to obtain financing consistent with the
                         terms used in the consultant’s feasibility analysis, the Board chose
                         to move forward with the $25 million bonds described above. The
                         feasibility analysis was not updated to reflect the change in financing.
                         The Town will pay approximately $27.5 million5 in principal and
                         interest payments for these bonds over the next five years. This is
                         significantly more than the approximately $7 million the consultant
                         determined the baseball stadium would generate in revenues available
                         for debt service during the same time frame. Therefore, it appears
                         that the RLDC has placed more financial burden on the Town and
                         taxpayers via these financial transactions, and the Board moved
                         forward with the project, whose feasibility is questionable.

Recommendations          4. The Board should not use the RLDC to, in effect, circumvent
                            procurement and financing laws that would have applied if the
                            Town directly pursued a capital project.

                         5. The Board should perform feasibility analyses for future capital
                            projects to determine all costs that will be associated with them.
                            The Board should review these analyses prior to committing to
                            capital projects.




                         5
                             This includes $25 million in principal and $2.5 million in interest.


 14      OFFICE OF THE NEW YORK STATE COMPTROLLER
                          Financial Condition

                        A local government’s financial condition reflects its ability to provide
                        and finance services on a continuing basis. A local government is
                        considered to have sound financial health when it can consistently
                        generate sufficient revenues to finance anticipated expenditures, and
                        maintain sufficient cash flow to pay bills and other obligations when
                        due, without relying on short-term borrowings. Conversely, local
                        governments in poor financial condition often experience recurring
                        unplanned operating deficits. Persistent unplanned operating deficits
                        are usually indicative of poor budgeting and can result in cash flow
                        problems and/or deficit fund balances. Cash flow problems often
                        result in the need to borrow monies to finance day-to-day operations.

                        The Town has experienced a series of unplanned operating deficits
                        in its general, town-outside village, and part-town highway funds
                        over the last several years. These deficits were caused by inaccurate
                        budget estimates and the Board’s insufficient monitoring of financial
                        operations throughout the year. The resulting decline in fund balances
                        has, in turn, caused the Town to experience cash flow problems. The
                        Town has addressed its need for cash in the short-term by using inter-
                        fund advances. However, the Board has not adequately monitored the
                        funds, which resulted in funds not being paid back prior to the end of
                        the fiscal year at a comparable interest rate. Unless these budgetary
                        and cash flow problems are addressed, future Town operations could
                        be adversely impacted.

Budget Estimates        Board members must ensure that there is an adequate process in place
                        to prepare, adopt and amend budgets based upon reasonably accurate
                        assessments of resources that can be used to fund appropriations.
                        When estimating budgeted revenues, the Board and Town officials
                        must have current and accurate information. They also should use
                        historical data, such as prior years’ actual results of operations, to
                        guide them in determining whether revenues and expenditures are
                        reasonable.

                        As illustrated in the table below, the Town has experienced revenue
                        shortfalls in the general fund during fiscal years 2009 and 2010.
                        While we found that actual expenditures were within budget, Town
                        officials overestimated revenues for the past two years.




                   DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                15
                                                                                        15
                                     Table 1: General Fund Revenue Shortfalls
                               Description             2009                2010
                           Budgeted Revenues                $28,501,877              $32,394,657
                           Actual Revenue                   $27,999,302              $28,867,620
                           Revenue Above/                    ($502,575)             ($3,527,037)
                           (Below) Budgeted
                           Revenue

                          In particular, Town officials adopted an unrealistic budget for 2010
                          that resulted in $3.5 million in revenue shortfalls. For example, Town
                          officials overestimated mortgage taxes by $1.4 million, overestimated
                          golf fees by $342,207 and overestimated sales of real property by
                          $586,000. Town officials continued to budget unrealistically when
                          adopting the 2011 budget. We reviewed the 76 budgeted revenue
                          lines in the general fund and found that 34 appeared unreasonable
                          based upon historical trend data. For example, the Town budgeted
                          for $510,000 in tennis revenue although it had only received actual
                          revenue of $18,000 in 2010. Town officials budgeted for $1,850,000
                          in golf fees although the Town received only $1,507,793 in 2010.
                          Further, Town officials continued to overestimate mortgage taxes; the
                          2011 budget includes $2,200,000 for this revenue even though 2010
                          actual revenue was $1,321,126. Estimating a 67 percent growth in
                          mortgage tax revenue is unrealistic.

                          Town officials indicated that they review historical data when
                          preparing the budget; however, they did not estimate revenues to
                          reasonably respond to a clear and obvious downward trend or adjust
                          estimates in accordance with the revenue shortfalls in prior years.
                          In addition, we found no indication that the Board monitored actual
                          results compared to the budget during the year. Further, the Supervisor
                          could not provide any explanations for the budget estimates for
                          2011. Without realistic estimates, there is a risk that the Town will
                          experience further revenue shortfalls and therefore, operating deficits.

Operating Deficits and     Budgets are meant to balance revenues and expenditures, so that
Fund Balance              the local government is able to provide needed services with the
                          resources available. However, the reality is that budgets will rarely
                          work out precisely as planned, which can lead to operating deficits
                          if expenditures exceed revenues. An operating deficit can be planned
                          for and financed by appropriating fund balance. An unplanned
                          operating deficit results from over-expending appropriations, not
                          receiving budgeted revenues, or a combination of the two. Although
                          operating deficits can be planned as a means of prudently using
                          excess accumulated fund balance to finance operations, persistent
                          and recurring operating deficits are usually indicative of structurally
                          imbalanced budgets and financial stress.


 16       OFFICE OF THE NEW YORK STATE COMPTROLLER
     Fund balance is the difference between revenues and expenditures
     accumulated over a period of time. The unreserved, unappropriated
     amount is the portion of fund balance that can be used to manage
     unexpected occurrences such as emergency repairs, cost and
     demand fluctuations in commodities such as utilities and gasoline,
     and unanticipated shortfalls in estimated revenues. Inadequate
     unreserved, unappropriated fund balance limits Town officials’
     ability to manage emergencies and other unanticipated occurrences.

     The Town incurred unplanned operating deficits in the general,
     town-outside village, and part-town highway funds for the fiscal
     year ending December 31, 2010. The deficits occurred because of
     unrealistic revenue estimates and Town officials’ failure to monitor
     and adjust the budget when it became clear that anticipated results
     would not be achieved. A three-year history of the operating surplus
     or deficit for each of the operating funds is shown in the tables below.

                         Table 2: General Fund Balance
       Description            2008           2009               2010
      Operating                 $45,941        ($391,081)     ($2,103,899)
      Surplus/(Deficit)
      Ending Fund            $4,501,665       $4,110,584        $2,006,685
      Balance

     The general fund had operating deficits of $391,081 and $2,103,899
     in 2009 and 2010. The deficits occurred because of the Board’s
     unrealistic budgeting practices, as previously discussed, which
     created revenue shortfalls and decreased fund balance. As a result of
     the operating deficits incurred, the fund balance has declined from
     $4.5 million to $2.0 million.

              Table 3: Town-Outside-Village Fund Balance
       Description        2008           2009          2010
      Operating              ($109,385)       ($503,027)        ($107,606)
      Surplus/(Deficit)
      Ending Fund              $676,651         $173,624           $66,018
      Balance

     The town-outside-village fund’s operating deficits stemmed from
     revenue shortfalls caused by overestimating revenues. For example,
     in 2010 Town officials had revenue shortfalls for building permits
     totaling $240,807 and for for departmental income totaling $316,374.




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                  17
                                                                       17
                                     Table 4: Part-Town Highway Fund Balance
                             Description        2008          2009           2010
                           Operating                ($169,168)      ($110,450)       ($215,068)
                           Surplus/(Deficit)
                           Ending Fund               $371,553        $261,103           $46,035
                           Balance

                           For the part-town highway fund, Town officials caused these deficits
                           by overestimating revenues and by over-expending budget line items.
                           For example, Town officials over-expended the salaries budget line
                           item by $223,305 in 2010. In addition, Town officials did not realize
                           revenue totaling $97,674 in the transportation services to other
                           government budget line item.

                           The Town has depleted its fund balances and has limited financial
                           cushions in the event of an emergency. Further, if the Town continues
                           to experience operating deficits, there is a risk that it may need
                           to borrow funds to finance the deficit and to finance day-to-day
                           operations.

Exceeding Appropriations   Formal budgetary accounting is a management control technique used
                           to assist in controlling expenditures. Budgetary accounting techniques
                           are important because the annual budget is a legal compliance standard
                           against which the Town’s operations are evaluated. The law requires
                           the Town to maintain separate accounts for each appropriation. The
                           law does not permit the Town to overdraw an appropriation or use
                           a fund or appropriation to pay a claim chargeable to another fund
                           or appropriation. Town officials must obtain Board approval before
                           exceeding any appropriation. In fiscal year 2010, the Town over-
                           expended $6.8 million in individual accounts in the Town's five
                           major funds. While total expenditures were within the budget, many
                           individual account lines were exceeded, as shown below.

            Table 5: Over-Expended Appropriations as of December 31, 2010
                                                      Percentage of
                                     Total Over-                      Dollar Amount
        Fund         Total Accounts                  Accounts Over-
                                      Expended                        Over-Expended
                                                        Expended
 General Fund              684                314                     46%            $3,716,581
 Police Fund               116                 58                     50%            $2,252,264
 Town Outside Village       59                 28                     47%              $102,529
 Highway Town-Wide          34                 21                     62%              $414,328
 Highway Part Town          42                 15                     36%              $332,145
                Totals     935                436                     47%            $6,817,847




 18       OFFICE OF THE NEW YORK STATE COMPTROLLER
                           These over-expenditures occurred for several reasons. First, the
                           finance software used by the Town has settings that would prohibit
                           the creation of requisitions if funds are unavailable; however,
                           these settings are currently disabled, which allows users to create
                           requisitions against funds that are not available. In addition, during
                           the purchasing process, when requisitions become formal purchase
                           orders, there is no control in place to identify requisitions that do not
                           have sufficient funds available. Further, Town officials do not provide
                           the Board with regular budget reports for monitoring purposes.
                           However, the Board does approve a year end budget transfer to
                           rectify the over-expenditures and, therefore, should be aware of the
                           issue. Without proper controls, there is a risk that the Town’s already
                           declining financial position may worsen.

Inter-Fund Advances        General Municipal Law (GML) allows municipalities to temporarily
                           advance monies from one fund to another (with certain restrictions).
                           Towns generally are not authorized to make budgetary transfers
                           between funds that have different tax bases. When Town officials
                           advance monies between funds that have different tax bases, they
                           must repay the advance, with a comparable amount of interest, by the
                           end of the fiscal year in which the advance was made.

                           As a result of the Town’s declining financial position, the Town has
                           depended on inter-fund advances from the other Town operating
                           funds to help finance operations. At fiscal years ended December 31,
                           2009 and December 31, 2010, the Town advanced approximately
                           $3.3 million and $3.9 million, respectively, between funds with
                           differing tax bases. Town officials did not pay back these funds prior
                           to the end of the fiscal year. Town officials were not aware that the
                           advanced funds were required to be paid back by the end of the fiscal
                           year.

                           Further, Town officials did not repay these interfund advances with a
                           comparable amount of interest. For example, in 2009, the police fund
                           loaned $3.3 million to the general fund. These funds were originally
                           invested in CDs earning 1.45 percent; if these funds had remained
                           in the CDs, they would have earned interest totaling $19,973. Town
                           officials only paid the police fund $2,730 in interest. Therefore, the
                           police fund lost $17,243 in interest because it was not paid back with
                           a comparable rate of interest.

                           The Board is responsible for approving all inter-fund advances, and
                           must ensure that all temporary inter-fund advances are repaid by
                           fiscal year end with interest at a comparable rate to what the fund
                           would have earned if the monies had not been advanced. If repayment
                           does not occur at a comparable interest rate, taxpayer inequities will
                           occur.

                      DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                   19
                                                                                              19
Recommendations          6. The Supervisor should develop reasonable budget estimates.

                         7. The Board should monitor its budget continuously and make
                            necessary adjustments to avoid operating deficits and continued
                            decline in fund balance.

                         8. The Board should activate the control feature in the financial
                            system that prevents requisitions from being created without
                            proper funding.

                         9. The Board should ensure that funds advanced are paid back in a
                            timely manner and with a comparable rate of interest.




 20      OFFICE OF THE NEW YORK STATE COMPTROLLER
                         Information Technology

                          Computerized data is a valuable resource that Town officials rely
                          on to make financial decisions. The Town’s information technology
                          (IT) system is an essential part of operations used for accessing the
                          Internet, email communication, processing and storing data, and
                          reporting to State and Federal agencies. If the IT system fails, or
                          the data is lost or altered, either intentionally or unintentionally, the
                          resulting problems could range from inconvenient to severe; even
                          small disruptions in electronic data systems can require extensive
                          effort to evaluate and repair. An effective system of internal controls
                          to safeguard computerized data includes policies and procedures that
                          address key aspects of computer use and data security, including
                          system security and the protection of data from loss due to threats or
                          accidents (disasters). The Board and Town officials are responsible for
                          establishing, designing, and implementing a comprehensive system
                          of internal controls over the Town’s IT system and data to protect
                          these assets against the risk of loss, misuse, or improper disclosure
                          of sensitive data.

                          The Board has not established policies and procedures related to
                          breach notification, disaster recovery planning, and online banking.
                          We also found weaknesses in the Town’s internal controls relating to
                          the auto complete function, deactivating terminated user accounts,
                          and limiting personal computer use. Further, the Board has not
                          provided Town employees with security awareness training. These
                          control weaknesses increase the risk that the Town’s IT system and
                          electronic data may be susceptible to loss, unauthorized use, or
                          improper disclosure.

Breach Notification        The law requires local governments to establish an information
                          breach notification policy. The policy should detail how employees
                          would notify residents whose personal, private or sensitive
                          information was, or is reasonably believed to have been, acquired
                          by a person without valid authorization. The disclosure should be
                          made in the most expedient time possible and without unreasonable
                          delay, consistent with the legitimate needs of law enforcement or any
                          measures necessary to determine the scope of the breach and restore
                          the reasonable integrity of the data system.

                          Town personnel in several departments collect social security
                          numbers, driver’s license numbers and bank account information
                          for business purposes; however, the Town neither adopted a formal
                          breach notification policy, nor classified its data according to risk.


                     DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                   21
                                                                                             21
                           The Director indicated that the she was unaware of the requirement
                           to establish a breach notification policy. Since we made the Director
                           aware, she has begun to identify what personal, private or sensitive
                           data is collected and stored by Town departments and is creating
                           a breach notification policy. Without a formal breach notification
                           policy, the Town may not be able to fulfill its legal obligation to
                           notify affected individuals in the event that sensitive information is
                           compromised.

Disaster Recovery          Town officials are responsible for developing and documenting a
                           disaster recovery plan. A good disaster recovery plan addresses
                           a range of potential disruptions. These may include relatively
                           minor disruptions, such as temporary power failures, as well as
                           major disasters such as fire or natural disasters that would require
                           reestablishing operations at a remote location. If controls are
                           not adequate, even relatively minor disruptions can result in lost
                           or incorrectly processed data, which can cause financial losses,
                           expensive recovery efforts, and inaccurate or incomplete financial
                           or management information. Further, the plan should set forth
                           procedures to ensure Town personnel can either maintain, or quickly
                           resume, mission-critical functions.

                           Town officials have not developed and documented a formal disaster
                           recovery plan. We discussed this issue with the Director, who has
                           begun to investigate several different approaches to protect the data.
                           When she determines the most cost-effective plan for the Town, she
                           will meet with the disaster preparedness committee. If the Town
                           experiences a major disruption, without a formal disaster recovery
                           plan, Town personnel have no guidelines or plan to follow to resume
                           mission-critical functions.

Auto Complete Setting      The auto complete feature in Internet Explorer can save web
                           addresses, form data, and login information such as usernames and
                           passwords. Typically, web browsers and applications store the login
                           credentials if the auto complete option is enabled. Work stations store
                           the user names and passwords in locations that are easy to access.
                           A user name and password provides access to applications that are
                           solely for that user’s purpose; this information will be automatically
                           entered every time the employee visits the website. The employee’s
                           information also will be automatically entered for anyone else who
                           uses the employee’s computer and accesses the same web sites. When
                           a user’s name and password can be accessed, there is a risk that
                           someone other than the user who gains access to the work station can
                           comprise the login credentials in a matter of seconds.

                           The auto complete setting was enabled on the Town’s online banking
                           computer. This setting automatically populated the user name and

 22        OFFICE OF THE NEW YORK STATE COMPTROLLER
                     password when the first letter of the user’s name and password was
                     entered. As a result, the Town is at risk that unauthorized users can
                     sign on, access banking information, and compromise financial data.
                     When we notified the Director, she immediately disabled the auto
                     complete feature.

User Accounts        Good internal controls include policies and procedures designed to
                     limit access to data. Town employees are assigned user accounts that
                     enable them to access the network. All changes to user accounts,
                     including additions, deletions, and modifications, should be
                     authorized and approved in writing by an appropriate Town official.
                     It also is important for user accounts to be deactivated as soon as
                     employees leave Town service.

                     The Town does not have written policies for deactivating user
                     accounts. The process used by the Town for terminating access to
                     the Town’s network and financial system is inadequate. The Human
                     Resources Department does not formally notify the IT Department
                     when an employee leaves Town service, so the IT Department must
                     contact Human Resources to confirm the employee has left. An IT
                     staff member must disable the account on the day the employee is
                     terminated. In addition, the Director indicated that, once a year, the
                     Department requests a list of all terminations for the year from
                     Human Resources and deactivates terminated employees from the
                     system.

                     We reviewed the list of 496 network user accounts on the Town’s
                     active directory and 66 user accounts on the Town’s financial
                     software to determine if employees who had left Town service were
                     still on the list of active users. We found three users on the active
                     directory and 12 users on the financial software whose accounts had
                     not been disabled after they left Town service. The duration of time
                     these employees have remained active on active directory was 30 to
                     827 days; one employee who left Town service 15 years ago was still
                     active on the financial software. In addition, we found that two users
                     out of 12 who had left Town service remained on the financial system
                     following the Department’s year-end review. Therefore, the yearly
                     review was inadequate, and the Town did not have another procedure
                     in place to periodically evaluate the user accounts on the active
                     directory or the financial system. When we informed the Director of
                     our findings, she immediately deactivated these users.

                     Failure to promptly remove the access rights of inactive employees
                     increases the risk that unauthorized users could inappropriately gain
                     access to a system and change, destroy, or manipulate confidential
                     and/or critical data.


                DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                23
                                                                                     23
Inappropriate Computer     To help protect the Town’s computing environment, the Board
Use                        adopted an acceptable-use policy governing employees’ use of Town
                           computers. This policy restricts the use of the Town’s computer
                           systems to business use only; personal use of the system is
                           prohibited. Generally, Town-owned resources, such as computers,
                           must be used primarily for Town purposes. However, as with the
                           use of a telephone, occasionally it may be necessary for Town
                           personnel to use computers, e-mail or an Internet connection during
                           the business day for personal matters. Sound business practice
                           requires Town personnel to keep the frequency and duration of such
                           occasional personal use to a minimum to avoid interfering with their
                           job performance.

                           The Town owns approximately 220 computers and has Internet
                           content filters on its network servers to block access to certain
                           websites. The Town’s Internet content filtering software logs
                           information relating to users and the domains visited. We selected
                           domains that did not appear to be job-related, which included dating
                           websites, porn websites and social media websites from the usage
                           report. We identified 161 computers that were used to access all or
                           most of these web sites. We selected six of the 161 computers with the
                           most activity for additional testing, and found that these computers
                           were used to access domains such as youtube.com, facebook.com,
                           ebay.com, match.com, hsn.com, turbo tax.com and craiglist.com
                           during work hours. Without proper monitoring and control over
                           Internet content filters, there is an increased risk that Internet usage
                           will be more than incidental or occasional.

                           Based upon our finding, in October 2010, the Director made changes
                           to the Internet content filter to deny access to certain websites.
                           Further, we compared two dates in September 2010 to two dates in
                           November 2010 and found that the percentage of time that the six
                           computers tested spent accessing web sites decreased by 46 percent
                           as a result of the changes implemented by the Director.

Information Security       Security Awareness Training is designed to educate users on the
Awareness Training         appropriate use, protection and security of information, individual
                           user responsibilities, and ongoing maintenance necessary to protect
                           the confidentiality, integrity, and availability of information assets,
                           resources, and systems from unauthorized access, use, misuse,
                           disclosure, destruction, modification, or disruption.

                           The Board has not provided employees with information security
                           awareness training. We interviewed eight of the 13 employees using
                           online banking to determine if they have been provided with security
                           awareness training. All eight employees indicated that the Town had
                           not provided them with training. In addition, users were accessing

 24        OFFICE OF THE NEW YORK STATE COMPTROLLER
                       the online banking with desktop shortcuts and were not cleaning out
                       their temporary Internet files or web browser cache after completing
                       an online banking session, which increases the risk of unauthorized
                       access. By failing to provide security awareness training, there is an
                       increased risk that employees will not understand their responsibilities
                       on how to appropriately protect the computer system. As a result, the
                       data and computer resources they have been entrusted with will be at
                       greater risk for unauthorized access, misuse or abuse.

Banking Policy         Effective internal controls over online banking include policies
                       and procedures to properly monitor and control online banking
                       transactions. A comprehensive online banking policy clearly
                       describes the online banking activities the Town will engage in,
                       specifies which employees have the authority to process transactions,
                       establishes a detailed approval process to verify the accuracy and
                       legitimacy of transfer requests, and requires a monthly report of
                       all online banking transactions. It is important that someone
                       independent of the online banking process review this report
                       and reconcile it with the monthly bank statement to verify that all
                       transactions were properly approved and appropriate. The Town has
                       not adopted an online banking policy. Without proper controls over
                       online banking processes, Town funds will be at increased risk of
                       being stolen through cyber fraud activities.

Recommendations        10. The Board should develop and adopt a formal breach notification
                           policy.

                       11. The Board should implement a formal disaster recovery plan to
                           address the possible loss of data in the event of a disaster.

                       12. The Director of Automated Systems should ensure that the auto
                           complete setting is disabled on all computers.

                       13. The Board should establish formal policies and procedures for
                           the addition and deletion of user accounts.

                       14. The Director of Automated Systems should monitor Internet
                           usage for inappropriate content.

                       15. The Board should provide officers and employees with
                           information security awareness training.

                       16. The Board should adopt an online banking policy.




                  DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                  25
                                                                                         25
                                         APPENDIX A

                        RESPONSE FROM TOWN OFFICIALS

The Town officials’ response to this audit can be found on the following pages.




  26        OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                           See
                                                           Note 1
                                                           Page 50




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    27
                                                         27
                                                See
                                                Note 1
                                                Page 50




                                                See
                                                Note 2
                                                Page 50




                                                See
                                                Note 2
                                                Page 50




28   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                               See
                                                               Note 3
                                                               Page 50




                                                               See
                                                               Note 3
                                                               Page 50




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    29
                                                         29
30   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                               See
                                                               Note 4
                                                               Page 50




                                                               See
                                                               Note 5
                                                               Page 50




                                                               See
                                                               Note 6
                                                               Page 51




                                                               See
                                                               Note 7
                                                               Page 51




                                                               See
                                                               Note 8
                                                               Page 51




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    31
                                                         31
                                                See
                                                Note 9
                                                Page 51




                                                See
                                                Note 10
                                                Page 51




                                                See
                                                Note 11
                                                Page 52




32   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                               See
                                                               Note 12
                                                               Page 52




                                                               See
                                                               Note 13
                                                               Page 52




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    33
                                                         33
                                                See
                                                Note 14
                                                Page 52




                                                See
                                                Note 15
                                                Page 52




34   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                               See
                                                               Note 16
                                                               Page 53




                                                               See
                                                               Note 17
                                                               Page 53




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    35
                                                         35
                                                See
                                                Note 18
                                                Page 53




36   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                               See
                                                               Note 19
                                                               Page 54




                                                               See
                                                               Note 20
                                                               Page 54




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    37
                                                         37
                                                See
                                                Note 21
                                                Page 54




                                                See
                                                Note 22
                                                Page 54




                                                See
                                                Note 23
                                                Page 54




38   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                               See
                                                               Note 23
                                                               Page 54




                                                               See
                                                               Note 24
                                                               Page 56




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    39
                                                         39
                                                See
                                                Note 23
                                                Page 54




                                                See
                                                Note 23
                                                Page 54




                                                See
                                                Note 23
                                                Page 54




40   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                               See
                                                               Note 23
                                                               Page 54




                                                               See
                                                               Note 23
                                                               Page 54




                                                               See
                                                               Note 23
                                                               Page 54




                                                               See
                                                               Note 25
                                                               Page 56




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    41
                                                         41
                                                See
                                                Note 23
                                                Page 54




                                                See
                                                Note 26
                                                Page 56




42   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                               See
                                                               Note 27
                                                               Page 56




                                                               See
                                                               Note 28
                                                               Page 56




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    43
                                                         43
                                                See
                                                Note 29
                                                Page 56




44   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                               See
                                                               Note 30
                                                               Page 56




                                                               See
                                                               Note 31
                                                               Page 57




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    45
                                                         45
                                                See
                                                Note 32
                                                Page 57



                                                See
                                                Note 32
                                                Page 57




                                                See
                                                Note 32
                                                Page 57



46   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                               See
                                                               Note 32
                                                               Page 57




                                                               See
                                                               Note 33
                                                               Page 57




                                                               See
                                                               Note 33
                                                               Page 57




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    47
                                                         47
                                                See
                                                Note 34
                                                Page 57




48   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                               See
                                                               Note 35
                                                               Page 57




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    49
                                                         49
                                         APPENDIX B

           OSC COMMENTS ON THE TOWN OFFICALS’ RESPONSE

In response to concerns raised and observations made about our audit in the Town officials’ letter, we
provide the following information.


Note 1

Our transmittal letter does not state that the report may be inaccurate or incomplete, as stated in
the Town’s response. The transmittal letter states, “If you believe anything in the preliminary draft
findings may be inaccurate or incomplete, please feel free to contact me.” Further, in accordance with
our policy, the report was disseminated to only Town officials, not to the general public. The report
provides an accurate representation of the Town’s financial transactions and condition; it does not
contain faulty conclusions and misrepresentations. Appendix C includes our audit methodology and
standards used in determining our audit findings.

Note 2

We removed from the objective “to ensure compliance with taxpayer wishes,” as a result of Judge
Linda S. Jamieson’s September 22, 2011 decision. The remaining notes to the response provide
evidence that our audit results are accurate and properly summarize the findings cited in the report.

Note 3

The Town’s response does not specifically address the Board’s knowledge about the baseball stadium.
When we met with Board members, they indicated that they did not know how much the baseball
stadium would cost the taxpayers or how it would be paid for. Further, Board members stated that
they did not receive the financial information, including contracts necessary to make sound decisions,
even when requested.

Note 4

Town Board Resolution 2010-149 states the Town “has proposed the construction of a ballfield …
known as Project Grand Slam.” It further states that the RLDC “will assist the Town of Ramapo in the
development of Project Grand Slam,” indicating that this is clearly a Town project. Further, comments
in the audit report clearly represent statements made by Board members.

Note 5

By using the RLDC to construct the stadium, the Supervisor and Board, in effect, circumvented the
procurement laws that would have applied if the Town directly pursued the project. The report does
not address whether the RLDC acted in accordance with its own procurement policies.




  50        OFFICE OF THE NEW YORK STATE COMPTROLLER
Note 6

The paragraph does not imply that the Town manipulated the RLDC; it states that, by using the RLDC,
Town officials, in effect, circumvented the procurement laws that would have applied if the Town
directly pursued the project. Moreover, our reference to the Wicks Law was based on statements made
to us by Board members to the effect that the stadium could be built at a lower cost by the RLDC,
which did not have to comply with the Wicks Law. Also, while it is true that the separate specification
requirement of the Wicks Law does not apply to local governments that provide for a project labor
agreement in accordance with the requirements of Labor Law §222, other statutory procurement
requirements would still apply to the local government.

Note 7

Judge Jamieson’s statement on the “broad” powers of LDCs relates to whether the purpose for which
the land was transferred to the RLDC fell within the powers of an LDC under the Not-For-Profit
Corporation Law. It did not relate to the propriety of the procurement process used to construct
the stadium. In fact, the court did not address any such procurement issue. Further, the paragraph
referenced in no way implies that the RLDC acted improperly, but rather is directed at actions of Town
officials.

Note 8

The reference to the State Constitution is merely a generic statement of the general prohibition against
loans of credit by towns. With respect to the exception for urban renewal projects, article 18, §2 of
the State Constitution does not provide a blanket exception for town loans of credit for urban renewal
purposes. Rather, it provides that the State Legislature may authorize towns to guarantee principal
and interest on indebtedness contracted by “public corporations” for urban renewal purposes. The
State Legislature has implemented this grant of authority by authorizing towns, subject to referendum
requirements, to guarantee loans of municipal urban renewal agencies established pursuant to article
15-A of the General Municipal Law, which are public benefit corporations (General Municipal Law
§§ 503-a, 553, 559).

Note 9

Board members indicated that the Town Supervisor did not provide them with evidence that other
financing was available. The Town transferred the property in November 2010, after the taxpayers
voted down the proposal for a 30-year guarantee of the RLDC financing. Given that, in February
2011, the Board once again voted to guarantee the financing with a shortened, more risky term. This
action indicates that more favorable terms were not available, as stated.

Note 10

The statement in the report that “Town taxpayers have liability or potential liability for as much as
$35.4 million in costs associated with property the Town no longer owns” has nothing to do with
the $25 million of bonds issued by the RLDC and “guaranteed” by the Town. The $35.4 million is
comprised of the $8.4 million that the Town spent to acquire the stadium property plus the additional
$27 million of Town moneys that were spent to improve the property.

                           DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                  51
                                                                                                  51
Note 11

The report states that Town taxpayers have a potential liability associated with property the Town does
not currently own, but we did not address whether Town taxpayers may receive a “benefit” from the
property transfer. Moreover, Judge Jamieson’s decision did not address whether taxpayers, in fact,
are receiving tangible benefits from the stadium project. Rather, the context of her decision addressed
whether the project fell within the powers of an LDC under the Not-For-Profit Corporation Law, and
stated that providing for additional employment is one of things that the stadium project “was intended
to do.”

Note 12

The word “guarantor” is a direct quote from the Board resolution itself. The role of a guarantor typically
is to become liable only in the event of a default by the principal. To the extent the use of quotation
marks around the word “guarantor” could be construed to imply that the Town is the party principally
liable to bondholders, as we understand the Town Guaranty, the Town has agreed to pay debt service
in the first instance. The official bond statement specifies that the interest payment due September 15,
2011 will be paid with interest from the bond proceeds. Therefore, we question whether actual RLDC
funds were used to make the first payment as indicated. With no agreement between the Town and
RLDC outlining how the RLDC will reimburse the Town for the principal and interest payments it
will make on behalf of the RLDC, the short-term nature of the bonds, and questionable revenue stream
slated to make the payments, it seems to us that the Town effectively is principally liable.

Note 13

The report does not make findings on the underlying legal issues relating to the guarantee. However,
the Town has agreed to guarantee $25 million in short-term, five-year bonds issued by the RLDC. We
view this as an apparent attempt to avoid the voters’ opposition to the guaranteed financing of 30-year
bonds that were to be issued by the RLDC by reconfiguring the transaction as a five-year guarantee,
which the Town believed was not subject to voter approval.

Note 14

The footnote merely sets forth several legal issues raised by the transaction. Judge Jamieson’s April
4, 2011 and September 22, 2011 decisions addressed specific causes of action brought by petitioners
and, as we read these decisions, they did not address on the merits the issues raised in the footnote,
including whether there was underlying authority for the permissive referendum. In the context of a
post-audit, mentioning that these issues are raised by the transaction is appropriate.

Note 15

As shown in the table below, taken from the Official Statement for the RLDC Bonds (Appendix H,
Anticipated Redemption of the Bonds), none of the revenues from the housing project have been
pledged to the bonds. Further, as shown below, the payment of the $29.9 million in Town-guaranteed
debt will occur during 2012 and 2013. As illustrated, the Town-guaranteed debt is deducted from
revenues to arrive at the net amount available to reimburse the Town for the payments of principal and
interest. Further, the revenues illustrated are estimates and may not be realized as anticipated.

  52         OFFICE OF THE NEW YORK STATE COMPTROLLER
Note 16

The audit report represents an audit of the Town, not the RLDC. Therefore, there is no guarantee as
to whether the revenues anticipated will be realized. The Town had the opportunity during the audit
and accompanying this response to provide actual documentation of such sales, and failed to do so.

Note 17

The report is factual. If the funds were not being used to pay for the stadium, they would be available
for other RLDC initiatives. Therefore, the commitment of these funds to pay for principal and interest
payments on the bonds issued for the baseball stadium impacts the RLDC’s ability to further its
mission. Further, the paragraph properly represents the results of the actions taken by Town officials.

Note 18

The report states that Town taxpayers are “potentially” responsible for approximately $35.4 million
in expenditures on the stadium property and that Town also guaranteed $25 million in bonds issued
by the RLDC. The $35.4 million is comprised of the $8.4 million that the Town spent to acquire
the stadium property plus an additional $27 million of Town moneys that were spent to improve the
property. By “guaranteeing” the RLDC’s bonds, the Town is as least “potentially” liable for another
$25 million in stadium costs. Therefore, based just on these facts, Town taxpayers are responsible, or
potentially responsible, for a minimum of $60.4 million in connection with the stadium. Moreover,
whether the RLDC has the intent or the means to pay the debt service on its bonds relates to the
likelihood that the Town will have to honor its “guarantee,” not to the existence of the Town’s
“potential” liability on those bonds.


                          DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                  53
                                                                                                 53
Note 19

Only one of the four Board members stated that he received and reviewed the consultant’s report;
the remaining members did not receive the report at all. Further, Town officials did not provide us
with any evidence, such as plans, analysis or other documentation that further review or analysis was
performed.

Note 20

As stated in the Official Statement on the RLDC bonds, none of the revenues from the housing
project have been pledged to the bonds. In addition, there is no agreement between the Town and
RLDC outlining how the RLDC will reimburse the Town. Further, revenues may not be realized as
anticipated. Appendix H of the Official Statement, which sets forth the anticipated redemption of the
bonds, expressly states that “[t]here is no assurance that the schedule of Anticipated Redemption will
occur as expected” and, in fact, shows a shortfall in RLDC revenues to reimburse the Town for 2016.
Therefore, it does appear that the RLDC has placed a financial burden or, at the very least, a potential
financial burden, on the Town and taxpayers, greater than that initially envisioned in the feasibility
study.

Note 21

As stated in the report, the Town has experienced a series of unplanned operating deficits in its
general, town-outside-village, and part-town highway funds over the last several years. An operating
deficit results when expenditures exceed revenues during the fiscal year, and is different than a fund
balance deficit. Fund balance is the difference between revenues and expenditures accumulated over
a period of time. When an operating deficit exceeds available fund balance, a fund balance deficit
occurs. Further, inter-fund transfers were not repaid at a comparable interest rate. For example, as
stated in the report, in 2009, the police fund lost $17,243 in interest because it was not paid back with
a comparable rate of interest for its inter-fund transfer to the general fund.

Note 22

The Town’s required pension contributions are a factor of the national economic recession and
individual Town decisions, such as salary levels, staffing levels, and specific pension options it has
chosen.

Note 23

The 2010 amounts referred to in the draft report were based on unaudited amounts obtained from the
Town’s financial system. These amounts represented the most current information available to us and
Town officials at the time of our fieldwork, and were the information that Town officials had available
to them upon which they based decisions. The independent audit of the Town's financial statements for
the year ended December 31, 2010 referred to in the Town's response were not received by the Town
until after we had completed our fieldwork. Town officials subsequently provided us with the audited
financial statements that they referred to in their response. The financial statements report that the
Town depleted its fund balance in 2010, resulting in a net change of ($15,544,380) in fund balance.
We reviewed the statements and included the audited numbers in the final report. Following is our
response to the Town’s comments:

  54        OFFICE OF THE NEW YORK STATE COMPTROLLER
Town Comments 2 and 3 in the Financial Condition Section:
The audited financial statements (page 60) report a shortfall of $3,527,037, not $1,226,687. We
changed the report to reflect the audited numbers.

Town Comment 3 in the Financial Condition Section:
The draft report indicated that $1.85 million was budgeted for golf revenues and only $1.5 million was
received. We revised the report to reflect the difference of $342,207.

The audited financial statements indicate a sale of real property of $314,000; therefore, we changed the
$900,000 reported in the draft report to $586,000.

Town Comment 5 in the Financial Condition Section:
The Town incurred operating deficits in these three funds. Page 19 of the audited financial statements
reports that the general and town-outside village funds had operating deficits in 2010, and page 73
reports the part-town highway fund had a deficit. Prior year fund balance was applied to render
positive fund balance in these funds in 2010. We deleted the statement that “these funds now have
deficit fund balances” from the report.

Town Comments 6 and 7 in the Financial Condition Section:
Page 60 of the audited financial statements reports revenues, not fund balance. Page 16 of the financial
statements reports a negative change in fund balance of $2,103,899. Therefore, the fund balance was
reduced from over $4 million to $2 million in 2010. The report is changed to reflect the $2 million
fund balance amount.

Town Comment 8 in the Financial Condition Section:
Page 19 of the audited financial statements reports a deficit of $107,606, not a surplus. The deficit of
$107,606 was applied to the $173,624 fund balance. Therefore, the fund balance was reduced to only
$66,018 in 2010. These numbers are incorporated into the report.

Town Comment 9 in the Financial Condition Section:
We revised the building permit figures in the final report to reflect the figures reported in the audited
financial statements. We also deleted our discussion of the sales tax figures from the final report.
However, while the audited financial statements report that the sales tax figures exceeded the budget,
the Town had a revenue shortfall for departmental revenue totaling $316,374. We included this
departmental revenue shortfall in the final report.

Town Comment 10 in the Financial Condition Section:
Page 73 of the audited financial statements reports a net negative change in fund balance of $215,068,
not $251,068. Therefore, the fund balance was decreased from $261,103 in 2009 to only $46,035 in
2010. We revised the report to reflect these numbers.

Town Comment 12 in the Financial Condition Section:
The Town has depleted its fund balance, as illustrated in the audited financial statement. The word
“negative” is removed from the report.




                          DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                  55
                                                                                                 55
Note 24

We emailed the Supervisor on April 19, 2011 and requested that he provide explanations for the
2011 budget estimates in question. Neither the Supervisor nor the Finance Department provided any
explanations.

Note 25
The numbers in the report were not changed, as this number was not supported by the audited financial
statements. In addition, the $97,674 in revenue that was not realized is listed in the Town’s financial
system as account 2221003, transportation services to other governments, specifically the Village of
Monsey.

Note 26

The significance of the budget lines being over budget is that the law does not permit the Town to
overdraw an appropriation or use a fund or appropriation to pay a claim chargeable to another fund
or appropriation. Town officials must obtain Board approval before exceeding any appropriation.
This demonstrates the Supervisor’s failure to obtain Board approval prior to overspending individual
budget appropriations.

Note 27

There is no “effective review process in place,” as depicted in the report. In addition, the fact that
the Town over-expended $6.8 million in 935 individual accounts in the Town's five major funds
demonstrates a lack of controls over the Town’s finances.

Note 28

When Town officials advance monies between funds that have different tax bases, they must repay the
advance, with a comparable amount of interest, by the end of the fiscal year in which the advance was
made. Repayments of advances were made in February of the following year, which is not within the
fiscal year the advances were made. With regard to the interest, the funds were taken from a CD to be
made available for use by the other funds; therefore, the advancing fund should have been repaid with
the rate of interest of the CD.

Note 29

Town officials did not comply with the law and pay back the funds prior to the end of the fiscal year
with a comparable amount of interest.

Note 30

Town officials have not developed and documented a formal disaster recovery plan pertaining to
information technology. The plan mentioned in the Town’s response does not address information
technology.



  56        OFFICE OF THE NEW YORK STATE COMPTROLLER
Note 31

During the audit, we observed that the room where the designated computer was located was left open
and unlocked. Further, while observing the wire transfers being performed, we observed that the
online banking password automatically populated; therefore, there is a risk that unauthorized users can
sign on, access banking information and compromise financial data.

Note 32

The Town does not have written policies for deactivating user accounts, and the process used by
the Town for terminating access is inadequate, as evidenced by the excessive number of active user
accounts left remaining after Town officials’ year-end review. Further, failure to promptly remove the
access rights of inactive employees increases the risk that unauthorized users could inappropriately
gain access to a system and change, destroy, or manipulate confidential and/or critical data.

Note 33

During the audit, we obtained the Town’s user activity report, which listed all the websites visited by
Town employees. We advised Town officials of inappropriate computer use by Town employees and
recommended that the web content filter be further restricted. After Town officials implemented our
recommendation, we found a decrease in the employees visits to these sites. We acknowledge that web
filters can exaggerate time spent on sites; therefore, we did not report the total time spent visiting these
sites. In addition, the pornographic sites visited were not limited to Town police; Town employees also
visited these sites.

Note 34

Town employees were not provided security awareness training; therefore, the data and computer
resources they have been entrusted with will be at greater risk for unauthorized access, misuse or
abuse.

Note 35

The Town should adopt policies and procedures to guide staff in areas of operations (such as online
banking) where there is high inherent risk of fraud, waste or abuse, or where staff would benefit from
specific guidance to perform their duties. This helps to ensure that public funds are used prudently and
in the best interest of the taxpayers.




                           DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                     57
                                                                                                     57
                                         APPENDIX C

                     AUDIT METHODOLOGY AND STANDARDS

Our overall goal was to assess the adequacy of the internal controls put in place by officials to
safeguard Town assets and monitor financial activities. To accomplish this, we performed an initial
assessment of the internal controls so that we could design our audit to focus on those areas most at
risk.

During the initial assessment, we interviewed Town officials, performed limited tests of transactions,
and reviewed pertinent documents such as Town policies, Board minutes, and financial records and
reports. After reviewing the information gathered during our initial risk assessment, we determined
where weaknesses existed, and evaluated those weaknesses for the risk of potential fraud, theft and/or
professional misconduct. We focused our audit testing on those areas most at risk, which included the
ball stadium, financial condition and information technology.

To accomplish our audit objective and obtain relevant audit evidence, our procedures included the
following:

   •   We reviewed Board minutes to determine the timing and nature of events.

   •   We reviewed all contracts associated with the initial purchase of the ball stadium and
       subsequent transfer to the RLDC, RLDC articles of incorporation and by-laws, memorandum
       of understanding between RLDC and Bottom 9 baseball, feasibility analysis provided to the
       RLDC, pertinent Board resolutions, lawsuit filed by taxpayers and corresponding decision and
       order, RLDC official bond statement.

   •   We interviewed the Town Supervisor, Town Attorney and Town Board members.

   •   We obtained and reviewed information pertaining to the expenditures made by the RLDC and
       the Town.

   •   We obtained revenue and expenditure comparison reports for the fiscal years ending 2008
       through 2011 and analyzed the budgets when compared to actual, operating surplus/deficits,
       and 2011 budget estimates and trend for those years.

   •   We analyzed fund balance for the fiscal years ending 2008 through 2010.

   •   We examined the inter-fund advances and reviewed Board resolutions authorizing them. We
       further examined bank statements for affected funds.

   •   We interviewed the Director of Automated Systems and other appropriate Town officials. We
       interviewed and observed employees who use online banking.

   •   We obtained and reviewed Town policies and procedures related to information technology.


  58        OFFICE OF THE NEW YORK STATE COMPTROLLER
   •   We reviewed the configuration of the Town’s Internet content filter and obtained reports
       summarizing usage. We further reviewed additional logs related to usage, as well as, the
       Town’s default domain policy and other applicable computer policies setup. We reviewed a
       usage report produced by the filtering program.

   •   We compared Internet content filter configuration from risk assessment to current settings of
       Internet content filter.

   •   We obtained the list of user accounts setup in the active directory and compared them to the
       current staff list.

   •   We audited multiple computers, consisting of running win audit software, examining
       temporary Internet files, cookies, and Internet history.

We conducted this performance audit in accordance with generally accepted government auditing
standards (GAGAS). Those standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.




                          DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                59
                                                                                               59
                                           APPENDIX D

           HOW TO OBTAIN ADDITIONAL COPIES OF THE REPORT

To obtain copies of this report, write or visit our web page:




                            Office of the State Comptroller
                            Public Information Office
                            110 State Street, 15th Floor
                            Albany, New York 12236
                            (518) 474-4015
                            http://www.osc.state.ny.us/localgov/




  60        OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                        APPENDIX E
                             OFFICE OF THE STATE COMPTROLLER
                              DIVISION OF LOCAL GOVERNMENT
                               AND SCHOOL ACCOUNTABILITY
                                           Steven J. Hancox, Deputy Comptroller
                                          Nathaalie N. Carey, Assistant Comptroller

                                       LOCAL REGIONAL OFFICE LISTING

BINGHAMTON REGIONAL OFFICE                                   NEWBURGH REGIONAL OFFICE
H. Todd Eames, Chief Examiner                                Christopher Ellis, Chief Examiner
Office of the State Comptroller                               Office of the State Comptroller
State Office Building - Suite 1702                            33 Airport Center Drive, Suite 103
44 Hawley Street                                             New Windsor, New York 12553-4725
Binghamton, New York 13901-4417                              (845) 567-0858 Fax (845) 567-0080
(607) 721-8306 Fax (607) 721-8313                            Email: Muni-Newburgh@osc.state.ny.us
Email: Muni-Binghamton@osc.state.ny.us
                                                             Serving: Columbia, Dutchess, Greene, Orange,
Serving: Broome, Chenango, Cortland, Delaware,               Putnam, Rockland, Ulster, Westchester Counties
Otsego, Schoharie, Sullivan, Tioga, Tompkins Counties

                                                             ROCHESTER REGIONAL OFFICE
BUFFALO REGIONAL OFFICE                                      Edward V. Grant, Jr., Chief Examiner
Robert Meller, Chief Examiner                                Office of the State Comptroller
Office of the State Comptroller                               The Powers Building
295 Main Street, Suite 1032                                  16 West Main Street – Suite 522
Buffalo, New York 14203-2510                                 Rochester, New York 14614-1608
(716) 847-3647 Fax (716) 847-3643                            (585) 454-2460 Fax (585) 454-3545
Email: Muni-Buffalo@osc.state.ny.us                          Email: Muni-Rochester@osc.state.ny.us

Serving: Allegany, Cattaraugus, Chautauqua, Erie,            Serving: Cayuga, Chemung, Livingston, Monroe,
Genesee, Niagara, Orleans, Wyoming Counties                  Ontario, Schuyler, Seneca, Steuben, Wayne, Yates Counties


GLENS FALLS REGIONAL OFFICE                                  SYRACUSE REGIONAL OFFICE
Jeffrey P. Leonard, Chief Examiner                           Rebecca Wilcox, Chief Examiner
Office of the State Comptroller                               Office of the State Comptroller
One Broad Street Plaza                                       State Office Building, Room 409
Glens Falls, New York 12801-4396                             333 E. Washington Street
(518) 793-0057 Fax (518) 793-5797                            Syracuse, New York 13202-1428
Email: Muni-GlensFalls@osc.state.ny.us                       (315) 428-4192 Fax (315) 426-2119
                                                             Email: Muni-Syracuse@osc.state.ny.us
Serving: Albany, Clinton, Essex, Franklin,
Fulton, Hamilton, Montgomery, Rensselaer,                    Serving: Herkimer, Jefferson, Lewis, Madison,
Saratoga, Schenectady, Warren, Washington Counties           Oneida, Onondaga, Oswego, St. Lawrence Counties


HAUPPAUGE REGIONAL OFFICE                                    STATEWIDE AND REGIONAL PROJECTS
Ira McCracken, Chief Examiner                                Ann C. Singer, Chief Examiner
Office of the State Comptroller                               State Office Building - Suite 1702
NYS Office Building, Room 3A10                                44 Hawley Street
Veterans Memorial Highway                                    Binghamton, New York 13901-4417
Hauppauge, New York 11788-5533                               (607) 721-8306 Fax (607) 721-8313
(631) 952-6534 Fax (631) 952-6530
Email: Muni-Hauppauge@osc.state.ny.us

Serving: Nassau and Suffolk Counties



                                  DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                                  61
                                                                                                                         61

				
DOCUMENT INFO
Shared By:
Categories:
Tags:
Stats:
views:1
posted:2/12/2012
language:
pages:62