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




   Village of Catskill
Fiscal Oversight and Internal
   Controls Over Selected
     Financial Activities
           Report of Examination
                    Period Covered:
            June 1, 2007 — June 12, 2008
                       2009M-53




              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 Local Officials and Corrective Action                     6


FISCAL OVERSIGHT                                                                7
            Operating Deficits and Fund Balances                                 8
            Interfund Advances                                                  9
            Accounting Records                                                 10
            Accounting for Capital Projects                                    12
            Financial Reports                                                  13
            Annual Audit                                                       14
            Recommendations                                                    14


CASH RECEIPTS AND DISBURSEMENTS                                                16
            Policies and Procedures                                            16
            Deposit of Cash Receipts                                           17
            Claims Audit and Payment                                           17
            Recommendations                                                    18


INFORMATION TECHNOLOGY                                                         20
            Recommendations                                                    21


APPENDIX   A   Response From Local Officials                                    22
APPENDIX   B   OSC Comments on the Village’s Response                          27
APPENDIX   C   Audit Methodology and Standards                                 28
APPENDIX   D   How to Obtain Additional Copies of the Report                   30
APPENDIX   E   Local Regional Office Listing                                    31


                      DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY          11
                                              State of New York
                                 Office of the State Comptroller


Division of Local Government
and School Accountability

September 2009

Dear Village 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 Village Board 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 the Village of Catskill, entitled Fiscal Oversight and 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




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


The Village of Catskill (Village) has a population of approximately 4,400 and is located in Greene
County. Its elected five-member Board of Trustees (Board) is responsible for the general management
and control of the Village’s finances and operations. The Board’s President (President) serves as the
Village’s chief executive officer. A Board-appointed Clerk-Treasurer serves as chief fiscal officer, and
is responsible for the custody of all Village moneys, maintaining accounting records, filing required
financial reports, signing checks, and keeping a record of the Board’s proceedings.

The Village provides services to its residents including street maintenance and improvements, water
distribution and sewage treatment, public safety, and general government support. The Village collects
revenue mainly from real property taxes and water and sewer user fees. For the fiscal year ending May
2007, the Village reported expenditures of $3,986,817 in its general fund, $955,015 in its water fund,
and $687,451 in its sewer fund.

Scope and Objective

The objective of our audit was to review the Village’s internal controls over selected financial operations
for the period June 1, 2007 to June 12, 2008.1 Our audit addressed the following related questions:

    •   Has the Board effectively monitored the financial condition of the Village?

    •   Has the Village established adequate controls over cash receipts and disbursements and are
        those controls operating effectively?

    •   Are internal controls over information technology (IT) appropriately designed?

Audit Results

The Board and President have not provided effective oversight of the Village’s financial operations
and have failed to address significant weaknesses, identified in our previous audit,2 in budgeting,
accounting, reporting, cash management, and claims processing. These inadequate management
practices have contributed to the deteriorating financial condition of the Village’s primary operating
funds, perpetuated a reliance on interfund transfers to maintain cash flow, and placed the Village at risk
of fiscal stress that could jeopardize its ability to operate effectively.


____________________
1
  We also reviewed selected financial statement information for fiscal years 2004-05 and 2005-06 to provide historical
perspective regarding the Village’s fund balance, interfund advances, and accounting records.
2
  Report No. 2004M-11, Village of Catskill: Financial Condition and Fiscal Oversight (issued August 2005)

                              DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                          33
Due to poor planning and unrealistic budgeting, the total fund balances of the Village’s main operating
funds (general, water, and sewer) decreased by $933,727 (58 percent) over the three fiscal years 2004-
05 to 2006-07. At the end of 2006-07, these three funds had a combined operating deficit of $574,876,
or 36 percent of their total fund balance at the beginning of the 2004-05 fiscal year. The Village made
expenditures without ensuring sufficient funds were appropriated, which violates Village law, and
relied on interfund transfers to maintain sufficient cash flow. Unless Village officials develop and
follow budgets that match revenues to expenses, the Village is at an ongoing risk of deteriorating fund
balances and insufficient cash.

The Board also failed to ensure that the Clerk-Treasurer fulfilled her accounting and reporting
responsibilities. The Village’s independent accountant was required to make millions of dollars in
adjustments, both additions and subtractions, to the Clerk-Treasurer’s records in order to produce
an accurate 2006-07 annual financial report. The Clerk-Treasurer’s failure to properly record all
transactions also resulted in discrepancies between the Village’s bank accounts and general ledger
cash balances; for example, while the bank statement showed $88,045 in the sewer fund account at
July 31, 2007, Village records showed a balance of $224,711. Due to the deficient accounting records,
the payroll clerk was unable to effectively perform bank reconciliations.

The Board did not ensure that capital projects were properly accounted for, and the Village’s delayed
application for a $460,000 bond anticipation note to finance a water meter capital project that had
been substantially completed resulted in a severe depletion of operating cash.3 The Board also did not
perform an annual audit of the Clerk-Treasurer’s records. The Board’s lack of proper oversight of the
accounting and financial reporting functions diminishes its ability to control and monitor the budget
and compromises the transparency of the Village’s financial operations.

The Board also did not establish proper controls over cash receipts and disbursements. Cash handling
duties were not segregated, and 15 of the 30 deposits we tested, totaling $92,544, were deposited up to
46 days after receipt. Of 44 claims tested, 35 (80 percent) totaling $392,995 had deficiencies in proper
approvals, required bids or quotes, and/or supporting documentation. These control deficiencies place
the Village at a significant risk of the mismanagement, loss, or theft of Village moneys.

Finally, we found weaknesses in the Village’s controls over server room access, disaster recovery
planning, and data backup procedures which increase the risk of unauthorized access and/or modification
to Village data as well as potentially costly disruptions to Village operations. Due to the sensitivity
of the issue, certain vulnerabilities are not discussed in this report and have been communicated
confidentially to Village officials so they could take corrective action.

Comments of Local Officials

The results of our audit and recommendations have been discussed with Village officials and their
comments, which appear in Appendix A, have been considered in preparing this report. Village
officials disagreed with certain findings and recommendations contained in this report. Our comments
on the Village’s response can be found in Appendix B.


____________________
3
    The combined available cash in the general, water, and sewer funds in February 2008 was $56,706.


      4          OFFICE OF THE NEW YORK STATE COMPTROLLER
                           Introduction

Background         The Village of Catskill (Village), incorporated in 1806, has a
                   population of approximately 4,400 and is located in Greene County.
                   Its five-member Board of Trustees (Board) is the elected legislative
                   body responsible for the general management and control of the
                   Village’s finances and operations. The Board’s President (President)
                   serves as the Village’s chief executive officer. A Board-appointed
                   Clerk-Treasurer serves as chief fiscal officer and is responsible for
                   the custody of all Village moneys, maintaining accounting records,
                   filing required financial reports, signing checks, and keeping a record
                   of Board proceedings. The Village uses the services of an information
                   technology consultant to maintain its computer resources and assist
                   staff in the use of the Village’s financial software.

                   The Village provides services to its residents including street
                   maintenance and improvements, water distribution and sewage
                   treatment, public safety, and general government support. The Village
                   collects revenue mainly from real property taxes and water and sewer
                   user fees. For the fiscal year ending May 2007, the Village reported
                   expenditures of $3,986,817 in its general fund, $955,015 in its water
                   fund, and $687,451 in its sewer fund.
Objective          The objective of our audit was to review the Village’s internal controls
                   over selected financial operations. We addressed the following related
                   questions:

                      •   Has the Board effectively monitored the financial condition of
                          the Village?

                      •   Has the Village established adequate controls over cash
                          receipts and disbursements and are those controls operating
                          effectively?

                      •   Are internal controls over information technology (IT)
                          appropriately designed?
Scope and          We examined the monitoring of financial condition and internal
Methodology        controls over cash receipts and disbursements of the Village of Catskill
                   for the period June 1, 2007 to June 12, 2008. We also reviewed
                   selected financial statement information for fiscal years 2004-05 and
                   2005-06 to provide historical perspective regarding the Village’s fund
                   balance, interfund advances, and accounting records.

                   Our audit identified areas in need of improvement concerning
                   information technology controls. Because of the sensitivity of this

              DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                  55
                           information, certain vulnerabilities related to user access are not
                           discussed in this report and have been communicated confidentially
                           to Village officials so that 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 are
                           included in Appendix C of this report.

Comments of                The results of our audit and recommendations have been discussed
Local Officials and         with Village officials and their comments, which appear in Appendix
Corrective Action          A, have been considered in preparing this report. Village officials
                           disagreed with certain findings and recommendations contained in
                           this report. Our comments on the Village’s response can be found in
                           Appendix B.

                           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-
                           Treasurer’s office.




  6        OFFICE OF THE NEW YORK STATE COMPTROLLER
          Fiscal Oversight

     The responsibility for effective financial planning and management
     (fiscal oversight) of the Village rests with the Board and President,
     who must receive timely and accurate financial information from
     the Clerk-Treasurer. Such information includes monthly bank
     reconciliations, monthly budget-to-actual expenditure reports, and
     annual financial statements. The Board must have this information
     for preparing the annual budget, monitoring the budget throughout
     the year, ensuring compliance with relevant laws and policies, and
     ensuring that sufficient financial resources are available to maintain
     Village operations at an acceptable level.

     According to Village Law and the Village’s charter, the Clerk-
     Treasurer is responsible for maintaining accurate and timely
     accounting records, performing monthly bank reconciliations,
     providing monthly budget reports to the Board, and preparing and
     submitting annual financial statements to the Board and the State
     Comptroller. To assist the Clerk-Treasurer in her duties, the Village
     contracts with an independent certified public accounting firm
     to perform certain consulting and accounting services, including
     monthly reconciliations of the general ledger to bank statements and
     the preparation and filing of the Village’s annual financial report.

     Our previous report of examination4 cited significant weaknesses in the
     maintenance of accounting records and reports and Board oversight.
     Our current audit found that the Board has not taken action to address
     many of these weaknesses, and that the Board and President have
     not provided effective oversight of the Village’s financial operations.
     These insufficient Village management practices contributed to the
     deteriorating financial condition of the main operating funds – whose
     combined fund balances declined by $933,727 from fiscal years
     2004-05 to 2006-07 – and a continued reliance on interfund transfers
     for cash to support Village operations. Further, the Clerk-Treasurer’s
     accounting records and reports were not complete, accurate, or up-
     to-date, making them unreliable for monitoring Village financial
     operations and causing significant delays in statutory financial
     reporting. Finally, the Board has not audited the Clerk-Treasurer’s
     financial records to verify that public moneys are properly handled
     and to review the Village’s financial condition. If the Board does not
     address the significant control deficiencies identified in this report,
     the Village’s essential operations and ability to provide services to its
     residents may be jeopardized.
     ____________________
     4
      Report No. 2004M-11, Village of Catskill: Financial Condition and Fiscal
     Oversight (issued August 2005)

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                   77
Operating Deficits         Board members must ensure that budgets are prepared, adopted, and
and Fund Balances         amended based upon reasonably accurate assessments of resources that
                          can be used to fund the cost of Village operations. This responsibility
                          requires Board members to balance the level of services desired and
                          expected by Village residents with the ability and willingness of
                          the residents to pay for such services. Therefore, it is essential that
                          the Board adopt realistic, structurally balanced budgets for all of its
                          operating funds that provide recurring revenues to finance recurring
                          expenditures. The annual budget for each operating fund should
                          provide a reasonable estimate of appropriations, revenues, and other
                          financing sources. In addition, the Board’s monitoring of the actual
                          results and budgeted estimates of each fund regularly throughout the
                          year helps to determine whether revenues will be sufficient to fund
                          services as provided by the annual operating budget. The failure to
                          limit expenditures to available appropriations creates the risk that
                          moneys will not be available. Moreover, Village Law prohibits
                          officials from making any expenditure or entering into a contract if
                          moneys have not first been appropriated and made available in the
                          budget.

                          Village Board members have not received sufficient or timely
                          financial information, have not adopted realistic budgets, and have
                          not sufficiently monitored financial operations or taken appropriate
                          actions to maintain the Village’s financial stability. As a result, the
                          Village’s financial condition has declined over the past three years.
                          The total fund balances of the main operating funds (general, water,
                          and sewer) have decreased by $933,727, or 58 percent, over the three
                          fiscal years 2004-05, 2005-06, and 2006-07. The decline in fund
                          balances resulted from unplanned operating deficits5 in those funds,
                          as shown in the following table:

                                             Operating Surplus / (Deficit)
                                              2004-05     2005-06        2006-07
                                     Fund
                                             Fiscal Year Fiscal Year Fiscal Year
                                     General   $(34,101) $(108,946)      $(410,345)
                                     Water     $(40,084) $(142,757)       $(42,643)
                                     Sewer       $41,485     $46,745     $(121,888)


                          These operating deficits resulted from both revenue shortfalls
                          (overestimates) and overspent appropriations. For example, in the
                          2006-07 fiscal year:


                          ____________________
                          5
                           The deficit total for these three funds incurred during the 2006-07 fiscal year is
                          equal to 36 percent of their combined fund balance at the beginning of the 2004-05
                          fiscal year.

  8       OFFICE OF THE NEW YORK STATE COMPTROLLER
                                •   The general fund incurred $353,339 in expenditures that
                                    were in excess of total appropriations. Individual accounts
                                    that were overspent included personnel ($146,105) and fire
                                    ($149,905).

                                •   The sewer fund’s sewage treatment and disposal accounts
                                    incurred $148,807 in expenditures that were in excess of
                                    available appropriations.

                                •   The water fund’s water meter sales incurred a revenue shortfall
                                    of $105,636 due to the Board’s overbudgeting of metered water
                                    sales for 2006-07, following a previous $190,728 revenue
                                    shortfall in 2005-06. In April 2008, the Board approved a
                                    water meter rate increase; however, the revenue from this
                                    increase may not be sufficient to offset budgeted expenditures
                                    for the 2008-09 fiscal year.

                          User charges constitute the major source of revenue for the water and
                          sewer funds. However, the Board did not budget realistic levels of
                          anticipated revenue from user charges, but instead computed amounts
                          that appeared to match projected expenditures. The Board’s previous
                          resolutions6 to require monthly budget reports and to prevent over-
                          expending appropriation accounts were not effective. Although the
                          Board and other Village officials received monthly reports from the
                          Clerk-Treasurer that compared budget amounts to actual revenues
                          and expenditures, the Board did not effectively use these reports to
                          monitor the budget, limit expenditures to available appropriations, or
                          modify the budget when the need arose.

                          The Village’s repeated over-expending of appropriations violates
                          Village Law and, together with the unrealistic budgeting practices, has
                          placed the Village at an ongoing risk of deteriorating fund balances
                          and fiscal stress.

Interfund Advances        General Municipal Law provides the legal conditions under which
                          interfund cash advances can be made and requires that repayment
                          be made as soon as moneys are available, but no later than the close
                          of the fiscal year in which the advance was made. When an advance
                          is made between funds that are supported by different tax bases,
                          repayment must include an amount reasonably equivalent to the
                          amount of interest that would have been earned on the investment of
                          the moneys that were advanced.

                          Because of the fiscal stress resulting from recurring operating deficits,
                          the Village was in danger of not having sufficient cash resources to
                          ____________________
                          6
                              In May 2004

                     DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                   99
                          finance current operations. To provide cash resources for general
                          fund expenditures, the Village borrowed moneys from other funds
                          (primarily the water fund). Over time this practice created a reported
                          liability that the general fund could not realistically repay. At May
                          31, 2006, the annual financial report filed with the State Comptroller
                          indicated that the general fund owed other funds $1,233,284, yet
                          had only $582,803 in cash. Because the amount remaining in the
                          general fund was insufficient to repay the other funds as required by
                          law, Village officials wrote off the interfund loans among all three
                          operating funds (including the $1.2 million owed from the general
                          fund) during the 2006-07 fiscal year, effectively recognizing the
                          advances as subsidies. While this practice restored a positive balance
                          in the general fund, it did not address the ongoing practice that
                          allows these interfund loans to accumulate. Since the general fund
                          is primarily funded by real property taxes, and the water and sewer
                          funds by user charges, applying revenues generated by water usage
                          charges to support general fund operations and programs creates an
                          inequity among Village residents; such inequity may continue if these
                          interfund borrowings are not repaid in a timely manner and with
                          interest.

                          Village officials must take steps to develop budgets that match
                          revenues to expenses. If Village officials continue to rely on interfund
                          transfers to compensate for over-expenditures – maintaining cash flow
                          in a reactive manner without addressing the underlying budgeting
                          problems – it is at a significant risk of incurring cash shortages that
                          could jeopardize Village operations and the services provided to its
                          residents.

Accounting Records        The Village’s financial records must be timely, complete, and accurate
                          to be relevant and useful for the Board and other Village officials to
                          manage Village operations properly. The Clerk-Treasurer, as chief
                          fiscal officer, is responsible for maintaining the Village’s financial
                          records.

                          The Village’s accounting records were not complete, accurate, or up-
                          to-date. There were significant discrepancies in the Village’s general
                          fund accounting records maintained by the Clerk-Treasurer and the
                          amounts reported in the annual financial report filed with the State
                          Comptroller by the independent accounting firm for fiscal year ending
                          May 31, 2007,7 as shown in the following table:



                          ____________________
                          7
                           As of May 18, 2009, the Comptroller’s Office had not received the Village’s
                          annual financial statement for the 2007-08 fiscal year, which was due October 1,
                          2008 (following a filing extension).

  10      OFFICE OF THE NEW YORK STATE COMPTROLLER
                      Fiscal Year Ending May 31, 2007
                                         Clerk-      Annual
                    Account          Treasurer’s    Financial
                                        Records      Report
            Cash                          $910,890     $143,115
            Taxes Receivable,
                                      ($8,453,502)    $153,099
            Current
            Due From Other Funds        ($156,566)           $0
            Due From Other
                                          $191,910           $0
            Governments
            Accounts Payable               $84,831      $54,053
            Due To Other Funds            $531,362       $8,182
            Unreserved Fund
                                      ($8,124,485)    $233,979
            Balance Unappropriated
            Real Property Taxes                 $0   $2,790,523

     These discrepancies were the result of inaccurate and incomplete
     recordkeeping by the Clerk-Treasurer during the course of the year,
     and delays in making year-end adjusting entries in the general fund,
     as well as the water and sewer funds.8

     We selected two of the Village’s bank accounts for two months each
     and compared their balances with the Village’s general ledger cash
     balances for the water and sewer funds. We found the following
     discrepancies at July 31, 2007:
          Bank Account         Bank Balance    General Ledger Balance
         Water Fund               $100,597.14             $121,067.39
         Sewer Fund                 $88,045.35            $224,711.04

     The discrepancies occurred because the Clerk-Treasurer did not
     properly record all transactions in the Village’s accounting records.
     For example, $120,000 in interfund transfers between the water and
     sewer funds was recorded in the water fund, but not recorded in the
     sewer fund. These recording deficiencies made it difficult for Village
     staff to perform effective bank reconciliations, which are essential
     for controlling cash. Without accurate recordkeeping throughout the
     course of the year and the timely recognition of any year-end adjusting
     entries submitted by the Village’s accounting firm, the Board’s
     proper oversight of the Village’s financial activity and condition is
     diminished.

     ____________________
     8
       The Village’s accounting firm did not provide the 2006-07 fiscal year adjusting
     journal entries to the Clerk-Treasurer until June 30, 2008, approximately four
     months after the annual financial report for the fiscal year ending May 31, 2007
     was filed.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                        11
                                                                             11
                           Inaccurate records also inhibit proper and necessary reconciliations
                           of the Village’s cash records and bank account balances, and increase
                           the risk that errors and irregularities may occur and go undetected and
                           uncorrected. The reconciliation of bank account balances to general
                           ledger cash balances is essential for maintaining effective control
                           over cash transactions. Bank reconciliations enable Village officials
                           to verify that cash transactions have been properly recorded and
                           accounting records are accurate. When reconciliations are performed
                           in a timely manner, they also ensure that errors and/or irregularities
                           will be detected and corrected in a timely manner.

                           A payroll clerk was performing monthly bank reconciliations by
                           reconciling monthly net bank balances to the checkbook registers. We
                           found these reconciliations to be accurate.9 However, the payroll clerk
                           was not reconciling those bank statement balances to the accounting
                           records and indicated that this was because the Clerk-Treasurer did
                           not maintain accurate general ledger cash accounts. This failure to
                           reconcile bank balances to accounting records prevents the Board
                           from having reasonable assurance that all financial information is
                           properly recorded in the accounting records and reported in financial
                           reports, and increases the risk that errors and irregularities could occur
                           and go undetected and uncorrected.
Accounting for Capital     Complete and accurate accounting records for capital projects are
Projects                   necessary for proper financial reporting and monitoring. Financial
                           records for each capital project serve to document the project’s
                           financial history and establish accountability for resources provided.
                           Individual capital project records assist officials in monitoring the
                           status of each project and provide the Board with the information
                           necessary to ensure that expenditures are within authorized amounts.
                           Village officials are responsible for designing internal controls to
                           ensure that capital project moneys (such as bond proceeds) are
                           properly accounted for and used for the purposes they were intended.
                           In addition, Local Finance Law requires the Village to use bond
                           proceeds for the purpose for which the bonds were issued, and to use
                           any excess proceeds for the repayment of debt principal or interest.

                           Although the Village’s accounting firm annually compiled financial
                           data on capital project activity and presented a separate capital
                           projects fund in the annual financial report, this information was not
                           properly recorded in the Village’s books during the course of the
                           year. For example, in March 2008 the Village received and deposited
                           $460,000 in proceeds from a bond anticipation note (BAN) issued
                           for the purpose of funding a water meter capital project. However,
                           ____________________
                           9
                            Our reconciliation of bank statements to Village records, as described in the Fiscal
                           Oversight section under “Accounting Records,” included the reconciliation of the
                           bank statements to the checkbook registers.

  12       OFFICE OF THE NEW YORK STATE COMPTROLLER
                         this project had been started on April 12, 2007 and was substantially
                         completed by August 13, 2007. The proceeds of the BAN and all
                         related expenditures should have been accounted for in the capital
                         projects fund, and the BAN moneys used for the project according
                         to their intended purpose; however, neither the Clerk-Treasurer nor
                         the Village President could provide any records or documentation
                         showing the expenditure of BAN proceeds on the project for which
                         the BAN was issued. Further, records compiled at our request by the
                         Village’s Department of Public Works indicated that the project cost
                         totaled $447,428 ($12,572 less than the BAN amount), which makes
                         the Village legally obligated to apply the excess moneys toward
                         repayment of the BAN debt.

                         The Village had Board approval to apply for the BAN in March 2007,
                         but did not apply for the BAN until February 2008, after the project
                         was substantially completed. Because the Village used operating
                         cash to finance the project, at the end of February 2008 the Village
                         had only $56,706 in unrestricted operating cash remaining. By not
                         applying for the BAN in a timely manner, the Village demonstrated
                         a lack of planning which resulted in a cash shortage that could have
                         impaired its ability to continue operations.

                         Failure to properly account for capital activity and any related long-
                         term financing results in the presentation of incorrect information in
                         internal Village financial reports, distortion of actual general fund
                         financial transactions, and the inability of the Board to adequately
                         oversee and manage Village operations. Without properly accounting
                         for capital project funds, Village officials do not have assurance
                         that the Village’s debt issue proceeds are being properly used in
                         compliance with legal and contractual requirements.

Financial Reports        The Clerk-Treasurer must provide annual financial reports to the
                         Board and the State Comptroller within 60 days following the close
                         of each fiscal year as required by law. An additional 60-day filing
                         extension may be granted by the State Comptroller if a written request
                         is received from the Clerk-Treasurer before the original 60-day filing
                         period expires. The annual financial report is an important document
                         that allows management and the general public to assess the financial
                         operations and financial condition of the Village.

                         The Clerk-Treasurer has not filed the Village’s annual financial reports
                         with the State Comptroller in a timely manner. As of May 18, 2009,
                         the Village had not yet filed its annual financial report for the fiscal
                         year ending May 31, 2008 (after requesting and receiving a filing
                         extension from August 1, 2008 to October 1, 2008). Similarly, for the
                         previous three fiscal years, the Village did not file its annual financial
                         reports until eight to 18 months past the end of the fiscal year.

                    DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                 13
                                                                                          13
                          The lack of timely submission of annual financial reports diminishes
                          the Board’s ability to monitor and manage the Village’s financial
                          resources properly and increases the risk that errors and irregularities
                          may occur and go undetected and uncorrected. In addition, the
                          transparency of Village operations is compromised because the
                          public does not have the opportunity to review the Village’s financial
                          operations and financial condition.

Annual Audit              The Board is responsible for auditing or contracting for the audit of
                          the Clerk-Treasurer’s books and records. An annual audit provides
                          independent verification that the financial records have been properly
                          maintained, transactions have been properly recorded and reported,
                          and cash has been properly accounted for. Such an audit not only
                          ensures that public moneys are properly handled, but also identifies
                          conditions that need improvement and provides a review of the
                          Village’s financial condition.

                          There was no indication that the Board had audited the Clerk-
                          Treasurer’s financial records and reports for fiscal year 2006-07.
                          Although the Village engages a CPA firm to provide various accounting
                          services and prepare the Village’s annual financial report, this does
                          not serve as an audit of the Clerk-Treasurer’s books and records. A
                          similar finding was included in our previous report of examination.

                          The Board’s failure to ensure that the Clerk-Treasurer’s financial
                          records were audited in a timely manner diminishes the Board’s
                          management oversight authority, and puts the Village at risk of
                          mishandling public moneys and failing to detect and correct errors
                          and irregularities in a timely manner.

Recommendations           1. The Board should adopt realistic, structurally balanced budgets to
                             finance recurring expenditures and maintain sufficient cash flow
                             for operations.

                          2. The Board should closely monitor budget-to-actual reports to
                             ensure that expenditures are limited to available appropriations,
                             and revise the annual budget as needed to reflect realistic revenues
                             and expenditures.

                          3. Board members should ensure that interfund advances are repaid,
                             with interest where applicable, by the end of the fiscal year in
                             which they are made.

                          4. The Board should ensure that the Clerk-Treasurer properly
                             maintains the Village’s financial recordkeeping system to provide
                             for the timely and accurate recording of all financial transactions
                             and any year-end adjusting entries.

 14       OFFICE OF THE NEW YORK STATE COMPTROLLER
     5. The Board should ensure that capital projects are properly
        accounted for during the course of the year, and that any debt
        proceeds are used in accordance with legal requirements.

     6. The Clerk-Treasurer should file the Village’s annual financial
        report with the Office of the State Comptroller in a timely manner,
        as required by law.

     7. The Board should perform, or contract for the performance of,
        the annual audit of the Clerk-Treasurer’s financial records and
        reports.




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY               15
                                                                    15
                     Cash Receipts and Disbursements

                           The Board is responsible for establishing adequate internal controls
                           to properly safeguard the Village’s cash assets. An effective system
                           of internal control over cash receipts ensures that all moneys received
                           are properly recorded, deposited, and accounted for. The Board must
                           ensure that all cash is disbursed only upon proper authorization.
                           Disbursements must be supported by appropriate documentation,
                           properly recorded, and for valid business purposes. Other components
                           of internal control include establishing policies and procedures over
                           cash receipts and disbursements and proper segregation of duties to
                           ensure that no one individual controls all phases of a transaction.

                           The Board has not established policies and procedures over cash
                           receipts and disbursements. As a result, we found internal control
                           weaknesses relative to bank reconciliations, the deposit of cash
                           receipts, the payment of vendor claims, and the segregation of duties
                           in the Clerk-Treasurer’s office. These deficiencies place the Village
                           at an increased risk of errors or irregularities in the handling of cash
                           receipts and/or inappropriate payments being made for goods or
                           services that may not be received or may not be obtained at the best
                           price.

Policies and Procedures    An effective system of internal controls consists of policies,
                           practices, and procedures that enable local government officials to
                           provide reasonable assurance that they are properly safeguarding and
                           accounting for public resources. An important component to good
                           internal controls is the development of written policies and procedures
                           for cash receipts and disbursements. Key aspects of good policies and
                           procedures include timely supervision of those charged with handling
                           public moneys. Good internal controls provide assurance that cash
                           receipts and disbursements are recorded and reported in a timely and
                           accurate manner and that all disbursements are properly supported.

                           The Board has not established written procedures governing the
                           receipt and disbursement of cash. As addressed in the subsequent
                           sections of this report, internal controls over cash receipts in the Clerk-
                           Treasurer’s office were inadequate, and cash disbursements were
                           made without proper support. The Board did not provide sufficient
                           oversight over these financial activities.

                           The lack of written policies and procedures over cash receipts and
                           disbursements creates an increased risk that cash transactions are not
                           adequately controlled. As a result, the Village is vulnerable to the
                           possibility of loss, misuse, errors and/or irregularities occurring and
                           not being detected in a timely manner.

  16       OFFICE OF THE NEW YORK STATE COMPTROLLER
Deposit of Cash Receipts    A good system of internal controls over cash receipts provides for
                            a proper segregation of duties so that no one individual controls all
                            phases of a transaction, and that all moneys received by the Clerk-
                            Treasurer’s office are properly accounted for. In addition, Village
                            Law requires the Clerk-Treasurer to deposit all moneys received
                            within 10 days of receipt. Daily cash receipts should be reconciled to
                            cash reports and deposits to detect potential errors and irregularities.

                            There is a lack of segregation of duties in the Clerk-Treasurer’s
                            office. All four employees in the Clerk-Treasurer’s office collect
                            cash, prepare bank deposits, and deposit moneys in the bank. There
                            is no documentation supporting which employee has prepared or
                            deposited the moneys, and no reconciliation of deposits to the cash
                            journal. When cash receipt duties are not properly segregated and
                            cash receipts are not reconciled periodically to daily deposits on a
                            timely basis, accountability for cash receipts is compromised.

                            We tested 30 deposits totaling $168,075 made during the audit period
                            and found that 15 (50 percent), totaling $92,544, were deposited
                            between 11 and 46 days after receipt. The failure to deposit money
                            in a timely manner increases the risk that cash can be lost or misused
                            and, combined with inadequate segregation of duties in the processing
                            of cash receipts, undermines the protection of Village cash assets.

Claims Audit and Payment    An objective of internal controls over cash disbursements for the
                            payment of claims is to ensure that cash is disbursed only for vendor
                            claims that are legal and proper. Village Law requires the Board to
                            audit and approve the claims prior to authorizing the Clerk-Treasurer
                            to prepare and disburse checks for the payment of the claims. To
                            properly approve claims for payment, the Board should require that
                            the claims are properly itemized and contain sufficient documentation
                            to determine the nature of the purchase, that the amounts represent
                            actual and necessary Village expenses, and that the purchase complies
                            with statutory requirements and Village policies. In addition, Village
                            Law requires that the claims be signed by the department head who
                            placed the order, and sound business practices use a purchase order
                            or other acceptable document, signed by a Village employee and
                            included with the claim, to confirm actual receipt of the goods or
                            services.

                            To determine whether the Village’s claims were properly authorized
                            and supported, we tested 30 cash disbursements, representing
                            payments of 44 claims totaling $605,472, for the period June 1, 2007
                            to June 12, 2008. Only nine claims were supported with complete
                            documentation. The remaining 35 claims (80 percent) totaling
                            $392,995 were approved for payment even though one or more items
                            of required documentation were incomplete or missing, as follows:

                       DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                  17
                                                                                              17
                             •   Seven claims contained purchases required by statute to be
                                 competitively bid. Four of these claims were related to a
                                 water meter project that was properly bid, but there was no
                                 documentation attached to the claims as evidence that the
                                 purchases had been bid or showing the awarded bid prices.
                                 For the remaining three claims, totaling $116,482, we found
                                 no evidence on the claim or elsewhere that the purchases
                                 shown had been bid as required. These purchases included
                                 $70,300 for dam equipment and $35,000 for sewer cleaning
                                 machinery.

                             •   Thirty-one claims lacked documentation of Board approval
                                 prior to the purchase, as required by the Village’s procurement
                                 policy for all purchases over $250.

                             •   Nine claims lacked a department head’s signed approval.

                             •   Twenty of the 44 claims required receiving documentation.
                                 Of these 20 claims, 10 did not have signed receiving
                                 documentation attached acknowledging the Village’s receipt
                                 of the goods.

                             •   Seven claims, whose purchases were required by the Village’s
                                 procurement policy to have verbal or written quotations, did
                                 not have evidence of the required quotes.

                         When the Board does not properly audit and approve claims prior
                         to payment, the Village is at risk of making incorrect payments
                         to ineligible parties, paying for items that are not necessary or
                         appropriate, or paying for goods or services that were not received
                         as ordered. Further, without the consistent use and documentation of
                         required bids or quotes, Village officials cannot be sure of procuring
                         goods and services in the most economical manner and in the best
                         interest of the taxpayers.

Recommendations          8. The Board should adopt policies and Village officials should
                            implement written procedures that govern the receipt and
                            disbursement of cash.

                         9. Village officials should ensure that the payroll clerk reconciles
                            all bank balances to the accounting record’s general ledger cash
                            balances, as well as to the Village’s checkbook registers, on a
                            monthly basis.

                         10. The Board and Village officials should ensure that the cash
                             handling duties performed by employees in the Clerk-Treasurer’s
                             office are adequately segregated and documented, that deposits

 18      OFFICE OF THE NEW YORK STATE COMPTROLLER
        are reconciled to cash journals, and that all moneys are deposited
        in a timely manner.

     11. The Board should ensure that all claims are properly audited prior
         to approving them for payment. The claims audit should verify
         that all applicable claims contain evidence that the purchases
         were properly bid or quoted, as required by law and/or policy;
         that they are properly approved by department heads and the
         Board, as applicable; and that they have evidence of receipt.




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                19
                                                                     19
                    Information Technology

                     The Village relies on an information technology (IT) system for
                     correspondence; preparation, issuance and posting of collected user
                     charges billings; collection of taxpayer billings; Internet access;
                     e-mail communication; preparation of payroll; issuance of checks;
                     maintenance of financial records; and reporting to State and Federal
                     agencies. Therefore, the IT system and the data it holds are a valuable
                     Village resource. If the IT system fails, or is damaged or destroyed,
                     the resulting problems could range from inconvenient to severe. Even
                     small disruptions in electronic data systems can require extensive
                     time and effort to evaluate and repair.

                     An effective system of internal controls to safeguard computerized
                     data includes policies and procedures to protect vital computer
                     equipment, software, and data, and to provide guidance to Village
                     personnel in restoring lost data and resuming operations in the event
                     of a disaster. These essential controls must limit unauthorized access
                     to data, include a disaster recovery plan, and provide for routine
                     backups and secure, off-site storage of computer data. The proper use
                     of passwords and unique user identifiers is also an essential element
                     of data security.

                     We found weaknesses in the Village’s controls relating to server room
                     access, disaster recovery planning, and data backup procedures. These
                     weaknesses increase the risk of unauthorized access to Village data
                     and/or system failure that could result in potentially costly disruptions
                     to the Village’s operations or the loss or misuse of its critical data.

                     Access to the Server Room — Policies and procedures relating to
                     physical security over IT assets (i.e., computer hardware, servers, and
                     wiring closets) are a key component of an internal control structure.
                     Such policies and procedures help to ensure that computer assets are
                     protected by limiting access to those items and securing them from
                     fire and water damage.

                     The Village did not establish adequate policies and procedures over
                     the physical security of its server room, resulting in various security
                     deficiencies. In addition to the IT consultant, the Village President
                     and the Clerk-Treasurer’s staff of four all had access to the server
                     room which is not tracked or monitored. In addition, there is no
                     protection from fire and water damage. In the absence of protection
                     of IT equipment from fire, water, or other accidental damage, Village
                     officials have not ensured that the Village’s IT resources are adequately
                     safeguarded, and the Village could incur the loss of critical data and/
                     or interruptions to its computerized operations.

20   OFFICE OF THE NEW YORK STATE COMPTROLLER
                       Disaster Recovery — A disaster recovery plan is intended to identify
                       and describe how the Village plans to deal with potential disasters.
                       Such disasters may include any sudden, catastrophic event (e.g., fire,
                       computer virus, power outage, or inadvertent employee action) that
                       compromises the integrity of the IT system and data. An effective
                       plan includes precautions, including the routine backup of critical
                       data, to minimize the effects of a disaster and to enable the Village to
                       either maintain or quickly resume its critical functions.

                       The Village does not have a formal disaster recovery plan.
                       Consequently, in the event of a disaster, Village personnel have no
                       guidelines or plan to follow to help minimize or prevent the loss of
                       equipment and data, or guidance on how to implement data recovery
                       and resume operations as efficiently as possible.

                       Data Backup — Sound business practices require that the Village
                       back up (make a duplicate copy of) the data stored on its computers
                       and servers on a routine basis so that it can be restored in the event
                       of loss. Backup data should be kept at a secure alternate location to
                       protect it from loss in the event of a disaster at the server location.
                       It is also important that the Village routinely test the backup data to
                       ensure its integrity.

                       Village staff perform a daily backup of data files and store the backup
                       media on Village premises, with the exception of the Court Clerk
                       who takes the backups home. Storing the backup media on-site or
                       taking them to an unsecure location still subjects them to many of
                       the same risks (disasters) as the original data and defeats the purpose
                       of the backup control procedure. Further, the Village does not have
                       a formal process for testing the backup data by routinely restoring it
                       to the system. As a result of these control deficiencies, the Village’s
                       financial information and other critical data are at an increased risk of
                       loss in the event of a disaster.

Recommendations        12. The Board should adopt formal policies and procedures that
                           restrict physical access to areas where servers and other IT
                           components are located.

                       13. The Board should develop a formal disaster recovery plan that
                           addresses the range of potential threats to the Village’s IT system
                           and provides procedural guidance for employees to follow if the
                           Village’s computer operations are interrupted or its IT systems
                           or data incur loss or damage. The disaster recovery plan should
                           include procedures for backing up and restoring critical data.

                       14. Village officials should ensure that backup copies of data are
                           stored at a secure off-site location, and that the backup data is
                           periodically tested to verify its integrity.

                  DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                  21
                                                                                         21
                                          APPENDIX A

                        RESPONSE FROM LOCAL OFFICIALS

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




  22        OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                          See
                                                          Note 1
                                                          Page 27




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    23
                                                         23
                                                See
                                                Note 2
                                                Page 27




24   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                                          See
                                                          Note 3
                                                          Page 27




                                                           See
                                                           Note 4
                                                           Page 27




DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    25
                                                         25
26   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                          APPENDIX B

                OSC COMMENTS ON THE VILLAGE’S RESPONSE

Note 1

The ultimate responsibility for timely filing of the Village’s annual financial report rests with the
Clerk-Treasurer. This responsibility and the requirement for timely filing are stipulated in General
Municipal Law.

Note 2

Village Law requires the Board of Trustees to annually audit the Clerk-Treasurer’s reports and
supporting records. Alternatively, the Board could have the audit of the Clerk-Treasurer’s records
and reports performed by a public accountant engaged specifically for that purpose. This audit is
especially important, given the lack of adequate controls and the extent of recording and reporting
deficiencies noted in this and prior reports.

Note 3

General Municipal Law requires that interfund advances (loans) among funds be repaid no later than
the end of the fiscal year in which they were made. This was not done by Village officials. Rather,
they allowed these loans to grow over a number of years and remain unpaid. As we noted in our report,
applying revenues generated by water and sewer usage charges to support general fund operations and
programs creates an inequity among Village residents.

Note 4

We acknowledge the need for several individuals to have access to the server. However, such access
should be tracked and routinely monitored to ensure that it is reasonable and to provide accountability.
In addition, the server is not adequately protected from fire and water damage.




                           DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                  27
                                                                                                  27
                                           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
Village assets. In order to accomplish this, we performed an initial assessment of 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 Village officials and employees, performed limited tests
of transactions, and reviewed pertinent documents such as adopted policies and procedures, Board
minutes, and financial records and reports. After reviewing the information gathered during our initial
assessment, we determined where weaknesses existed, and evaluated those weaknesses for inherent
control risks. We then decided upon the reported objectives and scope by selecting for audit those
areas most at risk. We selected monitoring of financial condition, cash receipts and disbursements, and
information technology for further audit testing.

To assess the effectiveness of the Board’s fiscal oversight, we interviewed Village officials and
performed the following audit procedures:

   •   We analyzed revenue and expenditure trends and changes in the fund balances of the general,
       water, and sewer funds for the fiscal years ended May 31, 2005 through May 31, 2008.

   •   We verified amounts reported in the annual update document to the Village’s manual accounting
       ledgers.

   •   We reviewed the process used by the Village to develop and monitor its budget and analyzed
       material variances between budgeted amounts and actual results.

   •   We reviewed minutes of Board proceedings to verify that the required reports were submitted
       and to determine whether interfund advances and transfers were authorized.

   •   We inspected the general and subsidiary ledgers, bank reconciliations, and abstracts (lists of
       approved claims) to determine if internal controls had been established over the maintenance
       of the accounting records.

Within the cash receipts and disbursements area, we interviewed appropriate Village officials and
employees to gain an understanding of the procedures used to control cash assets and record receipts
and disbursements in the Clerk-Treasurer’s office. We examined the following records to determine
the effectiveness of the internal controls:

   •   Bank statements

   •   Bank reconciliations


  28         OFFICE OF THE NEW YORK STATE COMPTROLLER
   •   Wire transfers

   •   Cancelled checks

   •   Abstracts

   •   Deposit slips

   •   Cash receipts journal

   •   Duplicate receipts

   •   Payroll reports

   •   Vouchers

   •   Water and sewer billings.

We conducted our 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              29
                                                                                               29
                                           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/




  30        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


                                  DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                             31
                                                                                                                    31