The investment officer is responsible for establishing and maintaining an internal control structure designed to ensure that the assets of the City of Moraine are protected from loss, theft, or misuse. Details of the internal controls system shall documented in an investment procedures manual and shall be reviewed updated annually. The internal control structure shall be designed to provide reasonable assurance that these objectives are met. The concept of reasonable assurance recognizes that (1) the cost of a control should not exceed the benefits likely to be derived and (2) the valuation of costs and benefits requires estimates and judgments by management.
The internal control structure shall address the following points:
• Control of collusion
• Separation of transaction authority from accounting and recordkeeping
• Custodial safekeeping
• Avoidance of physical delivery securities
• Clear delegation of authority to subordinate staff members
• Written confirmation of transaction for investments and wire transfers
• Dual authorizations of wire transfers
• Development of a wire transfer agreement with the lead bank and third party custodian
Accordingly, the investment officer shall establish a person for an annual independent review by external auditor to assure compliance with policies and procedures or alternatively, compliance should be assured through the City of Moraine's annual independent audit.
(Ord. 1776-10. Passed 9-23-10.)
(Ord. 1776-10. Passed 9-23-10.)