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					 OFFICE   OF THE   NEW YORK STATE COMPTROLLER
                   D IVISION OF LOCAL GOVERNMENT
                       & SCHOOL ACCOUNTABILITY




           Beacon
     City School District
Internal Controls Over Selected
     Financial Operations
            Report of Examination
                    Period Covered:
            July 1, 2007 — March 24, 2009
                       2009M-161




               Thomas P. DiNapoli
                                Table of Contents



                                                                                Page

AUTHORITY LETTER                                                                 2


EXECUTIVE SUMMARY                                                                3


INTRODUCTION                                                                     5
           Background                                                            5
           Objective                                                             5
           Scope and Methodology                                                 5
           Comments of District Officials and Corrective Action                   6


PROFESSIONAL SERVICES                                                            7
            Recommendations                                                      8


WIRE TRANSFERS                                                                   9
            Recommendation                                                      10


INFORMATION TECHNOLOGY                                                          11
            Recommendation                                                      12



APPENDIX    A   Response From District Officials                                 13
APPENDIX    B   OSC Comment on the District’s Response                          16
APPENDIX    C   Audit Methodology and Standards                                 17
APPENDIX    D   How to Obtain Additional Copies of the Report                   18
APPENDIX    E   Local Regional Office Listing                                    19




                       DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY          1
                                                                                       1
                                                 State of New York
                                    Office of the State Comptroller


Division of Local Government
and School Accountability

October 2009

Dear School District Officials:

A top priority of the Office of the State Comptroller is to help school district officials manage their
districts efficiently and effectively and, by so doing, provide accountability for tax dollars spent to
support district operations. The Comptroller oversees the fiscal affairs of districts statewide, as well
as districts’ 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
district operations and Board of Education governance. Audits also can identify strategies to reduce
district costs and to strengthen controls intended to safeguard district assets.

Following is a report of our audit of the Beacon City School District, entitled Internal Controls Over
Selected Financial Operations. 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 district 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




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


The Beacon City School District (District) is governed by the Board of Education (Board) which
comprises nine elected members. The Board is responsible for the general management and control of
the District’s financial and educational affairs. The Superintendent of Schools (Superintendent) is the
chief executive officer of the District and is responsible, along with other administrative staff, for the
day-to-day management of the District under the direction of the Board.

Responsibilities relating to the District’s finances and accounting records and reports are largely
those of the Assistant Superintendent for Business and the Treasurer. The Assistant Superintendent
for Business oversees the day-to-day financial operations of the District, supervises Business Office
personnel, and serves as the District’s purchasing agent. The Assistant Superintendent for Media and
Operations oversees the District’s network system.

Scope and Objective

The objective of our audit was to examine the District’s internal controls over selected financial
operations for the period July 1, 2007, to March 24, 2009. Our audit addressed the following related
questions:

   •   Are internal controls over professional service expenditures appropriately designed and
       operating effectively to safeguard District assets?

   •   Are internal controls over wire transfers appropriately designed and operating effectively to
       safeguard District assets?

   •   Are internal controls over information technology appropriately designed to protect the
       District’s electronic data?

Audit Results

We found instances where the Board had not established critical controls, or controls that had been
established were not implemented or operating effectively. As a result the District is vulnerable to
errors and/or irregularities occurring and not being detected. For example, we found the District has
not developed adequate procedures to effectively procure quality professional services at reasonable
prices. We reviewed 21 payments totaling approximately $549,000 that were made to seven vendors
for professional services and found that District officials did not solicit competitive proposals or
quotes for four vendors. We reviewed additional payments made to the four vendors and found that,
during the audit period, the District paid over $840,000 to three firms for architectural and engineering

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services and over $120,000 to a firm for legal services. As a result, the District may have paid more
than necessary when obtaining those services. We also found the District did not have written
contracts with two of these vendors, totaling over $344,000. When no written contract exists that
would help to clarify the District’s needs and expectations, there is an increased risk that the District
will not receive the level or quality of service that was paid for.

We also found that the Board has not adopted formal policies related to wire transfers. The Treasurer
routinely disburses millions of dollars of District moneys through wire transfer. In doing so, the
Treasurer initiates each wire transfer, receives the confirmation, records the transaction into the
general ledger and then reconciles the bank accounts. Except for bond payment transfers approved by
the Assistant Superintendent for Business, wire transfers initiated by the Treasurer are not authorized,
reviewed, or approved by another individual. Because these incompatible duties are not adequately
segregated, there is an increased risk that moneys may be transferred improperly, or that the transfer
will not be properly recorded and documented.

Finally, District officials do not store back-up copies of computer data in a secure off-site location
and the data on the copies is not routinely restored to verify its integrity. Our audit also disclosed
other areas in need of improvement concerning access controls. Because of the sensitivity of this
information, these vulnerabilities are not discussed in this report but have been communicated to
District officials confidentially so they could take corrective action. As a result, the District’s critical
financial data may be subject to an increased risk of loss.

Comments of District Officials

The results of our audit and recommendations have been discussed with District officials and their
comments, which appear in Appendix A, have been considered in preparing this report. The District
generally agreed with our recommendations and planned to initiate corrective action. OSC’s comment
on the District’s response can be found in Appendix B.




   4         OFFICE OF THE NEW YORK STATE COMPTROLLER
                           Introduction
Background         The Beacon City School District (District) is located in the City of
                   Beacon and parts of the Towns of Fishkill and Wappingers, Dutchess
                   County. The District is governed by the Board of Education (Board)
                   which comprises nine elected members. The Board is responsible for
                   the general management and control of the District’s financial and
                   educational affairs. The Superintendent of Schools (Superintendent)
                   is the chief executive officer of the District and is responsible, along
                   with other administrative staff, for the day-to-day management of the
                   District under the direction of the Board.

                   There are six schools in operation within the District, with
                   approximately 3,300 students and 600 employees. The District’s
                   budgeted expenditures for the 2009-10 fiscal year were $56.7 million,
                   which were funded primarily with State aid and real property taxes.

                   Responsibilities relating to the District’s finances and accounting
                   records and reports are largely those of the Assistant Superintendent
                   for Business and the Treasurer. The Assistant Superintendent for
                   Business oversees the day-to-day financial operations of the District,
                   supervises Business Office personnel, and serves as the District’s
                   purchasing agent. The Assistant Superintendent for Media and
                   Operations oversees the District’s network system.

Objective          The objective of our audit was to examine the District’s internal
                   controls over selected financial activities. Our audit addressed the
                   following related questions:

                      •   Are internal controls over professional service expenditures
                          appropriately designed and operating effectively to safeguard
                          District assets?

                      •   Are internal controls over wire transfers appropriately
                          designed and operating effectively to safeguard District
                          assets?

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

Scope and          We examined the District’s internal controls over purchasing, wire
Methodology        transfers, and the IT system for the period July 1, 2007 to March 24,
                   2009.


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                           Our audit disclosed areas in need of improvement concerning
                           information technology controls. Because of the sensitivity of this
                           information, certain vulnerabilities are not discussed in this report but
                           have been communicated to District officials confidentially 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 District       The results of our audit and recommendations have been discussed
Officials and Corrective    with District officials and their comments, which appear in Appendix
Action                     A, have been considered in preparing this report. The District
                           generally agreed with our recommendations and planned to initiate
                           corrective action. OSC’s comment on the District’s response can be
                           found in Appendix B.

                           The Board has the responsibility to initiate corrective action.
                           Pursuant to Section 35 of the GML, Section 2116-a (3)(c) of the
                           Education Law, and Section 170.12 of the Regulations of the
                           Commissioner of Education, a written corrective action plan (CAP)
                           that addresses the findings and recommendations in this report
                           must be prepared and provided to our office within 90 days, with
                           a copy forwarded to the Commissioner of Education. To the extent
                           practicable, implementation of the CAP must begin by the end of
                           the next fiscal year. 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. The Board
                           should make the CAP available for public review in the District
                           Clerk’s office.




  6        OFFICE OF THE NEW YORK STATE COMPTROLLER
      Professional Services

     An important part of the Board’s responsibility is to establish
     procurement policies and procedures to help ensure that the District
     obtains goods and services of the required quantity and quality at
     competitive prices and to protect against favoritism, extravagance,
     fraud, and corruption. Professional service expenditures often
     represent a significant outlay of school district funds. Because
     of the cost and complexities associated with these specialized
     services, procurement policies and procedures must ensure that the
     district receives quality services at reasonable prices. To ensure that
     reasonable prices are obtained, competition should be sought when
     procuring professional services. To ensure that quality professional
     services are obtained, detailed contracts need to be in effect that fully
     define the nature and extent of the service to be provided and the
     methods by which the receipt of the service will be confirmed.

     District officials have not developed adequate procedures to
     effectively procure quality professional services at reasonable prices.
     District officials did not solicit competitive proposals or quotes for
     four of seven professional service providers. District officials did
     not have written agreements with two of these vendors who were
     paid over $344,000. As a result, the District may have paid more
     than necessary when obtaining those services. In addition, the failure
     to adequately document the understanding of the services to be
     provided and the compensation to be paid can result in the District
     paying more for these services than the Board intended.

     Price Competition – The appropriate use of price competition
     provides taxpayers with the greatest assurance that professional
     services are procured in the most prudent and economical manner
     without favoritism. General Municipal Law requires districts to
     take measures to ensure the prudent and economical use of public
     moneys. The District’s procurement process should include Requests
     for Proposals (RFPs), written or verbal quotes, or other appropriate
     competition when procuring professional services. The District’s
     purchasing policy requires District officials to encourage such
     competition when procuring services that will be paid for with public
     funds. However, the policy does not provide specific guidance for
     District officials, such as when it is appropriate to use an RFP or
     solicit quotes for professional services.

     We reviewed 21 payments totaling approximately $549,000 that were
     made to seven professional service providers during our audit period.
     District officials did not solicit competitive proposals or quotes for

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                   7
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                         four of the providers, including the District’s architects and attorney.
                         We reviewed additional payments made to the four vendors and found
                         the District paid over $840,000 to three firms for architectural and
                         engineering services and over $120,000 to a firm for legal services.
                         District officials used an RFP when obtaining the services of the
                         external and internal auditing firms and used a State contract to obtain
                         the services of an IT consultant.

                         Contracts – Comprehensive written agreements between the
                         District and professional service providers should give all parties
                         a clear understanding of the nature and extent of the services to be
                         provided, provide for a means to measure/monitor service quality,
                         and establish the level of compensation for those services. To protect
                         the District and taxpayer interests, it is important for the Board to
                         enter into written agreements with all professional service providers.

                         The District did not have a signed contract detailing the nature of
                         the services procured with two of the seven vendors who were paid
                         over $344,000 for IT and engineering services. We also found that
                         the District’s contract for internal audit services was not sufficiently
                         detailed and did not include a breakdown of fees for the services to
                         be performed.

                         By awarding professional service contracts without the benefit of
                         RFPs or quotes, District officials cannot assure taxpayers that they
                         are procuring such services in the most economically beneficial
                         manner. The lack of written contracts with professional service
                         providers deprives the District of legal protection in the event that
                         the services provided are not adequate. A written agreement for
                         professional services also provides the District and the individual or
                         firm furnishing services with a clearly defined and mutually agreed-
                         upon basis for the entitlement to payments.

Recommendations          1. The Board should amend the District’s procurement policy
                            to provide specific guidance on the required competition for
                            procuring professional services.

                         2. District officials should develop procedures relating to the
                            procurement of professional services. These procedures should
                            include guidance that employees must follow when procuring
                            professional services.

                         3. The Board should enter into written contracts with all current and
                            future professional service providers that fully detail the services
                            to be provided, provide service performance measures and/or
                            monitoring, and clearly delineate the compensation for those
                            services.

  8      OFFICE OF THE NEW YORK STATE COMPTROLLER
           Wire Transfers

     A structured and effective internal control framework regulating
     wire transfers is critical to the safeguarding of District moneys.
     A framework of comprehensive wire transfer controls must be
     established and approved by the Board. One fundamental element
     of such control is an adequate segregation of incompatible duties.
     The duties of authorizing, initiating and recordkeeping need to be
     performed by different individuals. Also, it is essential that wire
     transfer confirmations and/or bank reconciliations are not performed
     by the same individual who initiates the transfers.

     The Treasurer, as custodian of District moneys, can initiate wire
     transfers. However, wire transfers should be made by the Treasurer
     only upon written authorization. Independently approved, itemized
     documentation is necessary to support the purpose, source,
     destination, timing and amount of the wire transfers to be made. To
     further segregate incompatible duties, the Treasurer should not be the
     only individual receiving wire transfer confirmations and should not
     be the one to reconcile District bank accounts.

     The Board has not adopted formal control policies related to wire
     transfers. The Treasurer routinely disburses millions of dollars of
     District moneys through wire transfer. In doing so, the Treasurer
     initiates each wire transfer, receives the confirmation, records the
     transaction into the general ledger and then reconciles the bank
     accounts. Except for bond payment transfers approved by the
     Assistant Superintendent for Business, wire transfers initiated by
     the Treasurer are not authorized, reviewed, or approved by another
     individual. Because these incompatible duties are not adequately
     segregated, there is an increased risk that moneys may be transferred
     improperly, or that the transfer will not be properly recorded and
     documented.

     To address the possibility of improper transfers, we reviewed 10 wire
     transfers from one month of activity, totaling $4.6 million, and verified
     the propriety of each transaction. We confirmed the wire transfer
     destination, the amount transferred, and the timing of the payment
     and receipt. Our testing did not identify any improprieties. All wire
     transfers were made to other District bank accounts or were routine
     payroll remittances to governmental tax authorities, semi-annual
     debt payments, or investments in certificates of deposit. Although we
     found no improprieties, the Board and District officials still need to
     improve controls over wire transfers to adequately safeguard District
     funds.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                  9
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Recommendation           4. The Board should establish a written policy regarding wire
                            transfers that ensures the duties of authorizing, initiating and
                            recording wire transfer transactions are adequately segregated.
                            The policy should also require that transfer confirmations and
                            bank reconciliations be performed by someone other than the
                            Treasurer.




 10      OFFICE OF THE NEW YORK STATE COMPTROLLER
    Information Technology

     Computer data is a valuable District resource. The District relies
     on computer data in its day-to-day operations, for making financial
     decisions, and for reporting to State and Federal agencies. If the
     system on which this data is stored fails or the data is lost or altered
     either intentionally or unintentionally, the results could range from
     inconvenient to catastrophic. Even small disruptions in electronic
     data systems can require extensive effort to evaluate and repair. For
     this reason, an adequate data back-up system and a formal disaster
     recovery plan are necessary to help ensure that mission-critical data is
     adequately safeguarded from loss.

     District officials do not store back-up copies of computer data in a
     secure off-site location and the data on the copies is not routinely
     restored to verify its integrity. Our audit also disclosed other areas
     in need of improvement concerning access controls. Because of the
     sensitivity of this information, these vulnerabilities are not discussed
     in this report but have been communicated to District officials
     confidentially so they could take corrective action. As a result, the
     District’s critical financial data is subject to an increased risk of loss
     or misuse.

     Data Back-up – It is important for District officials to back up (i.e.,
     create a copy) computer processed data on a routine basis, and the
     copy must be stored at an environmentally and physically secure off-
     site location for retrieval in case of an emergency. The back-up data
     needs to be periodically tested to ensure that the data could actually be
     restored in the event of a problem.

     Although the District performs daily, weekly, and monthly data
     backups of its financial systems, it does not store the data back-up tapes
     in a secure off-site location. Instead, a District employee performs the
     data backup and maintains custody of the tapes. This practice exposes
     the District’s sensitive and confidential data to an increased risk of
     loss or theft.

     We also noted that the District does not have a formal process to
     periodically restore system data from the back-up copies. Therefore,
     there is no assurance that the back-up data is complete, accurate and
     reliable and that the restoration will be successful. The District risks
     losing valuable computer-processed data if its system were to become
     compromised and back-up files were not able to restore it to normal
     operations.


DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                  11
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Recommendation            5. District officials should establish procedures to ensure that data
                             back-up tapes are stored at a secured off-site location. District
                             officials should periodically restore system data from the back-up
                             copies to assure that the back-up data is complete, accurate and
                             reliable and that the restoration will be successful.




 12      OFFICE OF THE NEW YORK STATE COMPTROLLER
                                          APPENDIX A

                      RESPONSE FROM DISTRICT OFFICIALS

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




                          DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY     13
                                                                                     13
                                                See
                                                Note 1
                                                Page 16




14   OFFICE OF THE NEW YORK STATE COMPTROLLER
DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY   15
                                                         15
                                           APPENDIX B

                 OSC COMMENT ON THE DISTRICT’S RESPONSE

Note 1

During our audit tests and inquiries of District officials we did not find any indication that the District
prepared RFPs for the asbestos testing service, and District officials did not provide us with copies of
RFP documentation subsequent to our on-site fieldwork.




  16        OFFICE OF THE NEW YORK STATE COMPTROLLER
                                          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 District assets. 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. Our initial assessment
included evaluations of the following areas: financial oversight, cash receipts and disbursements,
purchasing, payroll and personal services and information technology.

During the initial assessment, we interviewed appropriate District officials, performed limited tests
of transactions and reviewed pertinent documents, such as District policies and procedures manuals,
Board minutes, and financial records and reports. In addition, we obtained information directly from
the computerized financial databases and then analyzed it electronically using computer-assisted
techniques. This approach provided us with additional information about the District’s financial
transactions as recorded in its databases. Further, we reviewed the District’s internal controls and
procedures over the computerized financial databases to help ensure that the information produced by
such systems was reliable.

After reviewing the information gathered during our initial assessment, we determined where
weaknesses existed, and evaluated those weaknesses for the risk of potential fraud, theft and/or
professional misconduct. We then decided on the reported objectives and scope by selecting for audit
those areas most at risk. We selected professional services, wire transfers, and information technology
for further audit testing.

To accomplish the objectives of our audit during the period July 1, 2007 to March 24, 2009, our
procedures included the following steps:

   •   We reviewed requests for proposals, written contracts, and claims for professional service
       expenditures.

   •   We reviewed 10 wire transfers and performed analytical reviews on the wire transfers prepared
       during the audit period.

   •   We interviewed District staff concerning the data back-up.

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
objective. We believe that the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objective.




                          DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                 17
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                                           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/




  18        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
                                            John C. Traylor, Assistant Comptroller

                                      LOCAL REGIONAL OFFICE LISTING
BUFFALO REGIONAL OFFICE                                      GLENS FALLS REGIONAL OFFICE
Robert Meller, Chief Examiner                                Karl Smoczynski, Chief Examiner
Office of the State Comptroller                               Office of the State Comptroller
295 Main Street, Suite 1032                                  One Broad Street Plaza
Buffalo, New York 14203-2510                                 Glens Falls, New York 12801-4396
(716) 847-3647 Fax (716) 847-3643                            (518) 793-0057 Fax (518) 793-5797
Email: Muni-Buffalo@osc.state.ny.us                          Email: Muni-GlensFalls@osc.state.ny.us

Serving: Allegany, Cattaraugus, Chautauqua, Erie,            Serving: Clinton, Essex, Franklin, Fulton, Hamilton,
Genesee, Niagara, Orleans, Wyoming counties                  Montgomery, Rensselaer, Saratoga, Warren, Washington
                                                             counties

ROCHESTER REGIONAL OFFICE                                    ALBANY REGIONAL OFFICE
Edward V. Grant, Jr., Chief Examiner                         Kenneth Madej, Chief Examiner
Office of the State Comptroller                               Office of the State Comptroller
The Powers Building                                          22 Computer Drive West
16 West Main Street – Suite 522                              Albany, New York 12205-1695
Rochester, New York 14614-1608                               (518) 438-0093 Fax (518) 438-0367
(585) 454-2460 Fax (585) 454-3545                            Email: Muni-Albany@osc.state.ny.us
Email: Muni-Rochester@osc.state.ny.us
                                                             Serving: Albany, Columbia, Dutchess, Greene,
Serving: Cayuga, Chemung, Livingston, Monroe,                Schenectady, Ulster counties
Ontario, Schuyler, Seneca, Steuben, Wayne, Yates
counties

SYRACUSE REGIONAL OFFICE                                     HAUPPAUGE REGIONAL OFFICE
Eugene A. Camp, Chief Examiner                               Jeffrey P. Leonard, Chief Examiner
Office of the State Comptroller                               Office of the State Comptroller
State Office Building, Room 409                               NYS Office Building, Room 3A10
333 E. Washington Street                                     Veterans Memorial Highway
Syracuse, New York 13202-1428                                Hauppauge, New York 11788-5533
(315) 428-4192 Fax (315) 426-2119                            (631) 952-6534 Fax (631) 952-6530
Email: Muni-Syracuse@osc.state.ny.us                         Email: Muni-Hauppauge@osc.state.ny.us

Serving: Herkimer, Jefferson, Lewis, Madison,                Serving: Nassau, Suffolk counties
Oneida, Onondaga, Oswego, St. Lawrence counties

BINGHAMTON REGIONAL OFFICE                                   NEWBURGH REGIONAL OFFICE
Patrick Carbone, Chief Examiner                              Christopher Ellis, Chief Examiner
Office of the State Comptroller                               Office of the State Comptroller
State Office Building, Room 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: Orange, Putnam, Rockland, Westchester
Serving: Broome, Chenango, Cortland, Delaware,               counties
Otsego, Schoharie, Sullivan, Tioga, Tompkins
counties



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