BCC: Developer Credits Policies and Procedures- Dated July 30, 2024

Summary

8 findings

1. Finding 1mediumpolicy

   Developer Credit Reconciliation Process Not Fully Followed

   During process observations, two procedures were not performed in accordance with the Developer Credits Reconciliation SOP (Version No. 1.3). Specifically, the Additional Information tab on the Trust Account Balance spreadsheet did not include required columns titled Comments and Long String. Additionally, the monthly developer credit reconciliation was not emailed to all recipients listed in the SOP.

   Recommendation: Since compliance with policies and procedures is required, no additional recommendation was provided beyond requiring adherence.
   Management response: Acknowledged. Fiscal will update the SOP to reflect the recipients in receipt of the monthly reconciliation and provide the data stated in the SOP. Management will inform all parties and train accordingly. Target implementation: September 2024.
2. Finding 2mediumpolicy

   Trust Account Balance Not Updated in Accela Timely

   A trust account balance was not updated in Accela in a timely manner. A trust account balance was reduced in Accela on December 12, 2023 for a credit reimbursement that had been issued on September 8, 2023 — a lag of over three months. The update process was manual, relying on flagged check request emails as reminders to reduce the balance once payment was issued by the Clerk & Comptroller's Finance Department.

   Recommendation: Develop a more effective system for tracking check requests submitted to the Clerk & Comptroller's Finance Department to ensure trust account balances are updated in Accela in a timely manner.
   Management response: Acknowledged. Management recognizes the need for a more effective tracking system. The process will be changed and updated with additional formal procedures to reflect trust account balances in a timely manner. Target implementation: September 2024.
3. Finding 3lowpolicy

   Developer Credit Transmittal Summary Checkbox Options Ambiguous

   Responses to certain questions on the Developer Credit Transmittal Summary were ambiguous because only Yes or No checkboxes were available. Some answers required a Not Applicable response, which was not an option, causing staff to check No instead, creating potential for misinterpretation of the record.

   Recommendation: Update applicable questions on the Developer Credit Transmittal Summary to remove the No box and replace it with N/A.
   Management response: Acknowledged. Fiscal revised the Developer Credit Transmittal Summary removing the No box and replacing it with N/A. Completed June 2024.
4. Finding 4mediumpolicy

   SOP for Developer Credit Transmittal Summary Contains Multiple Gaps

   The Developer Credit Transmittal Summary SOP (Version No. 2.0) lacked detailed guidance across numerous areas, including: procedures for researching and correcting errors; timing requirements for submitting the summary to the Accountant II; guidance for answering the question about whether credits can be sold outside the development; criteria for mobility fee automation in Accela; defined roles for completing the summary; signature requirements; retention requirements; processing timeframes; secondary review requirements before submission to Fiscal; cross-references to related SOPs covering general ledger and trust account setup; detailed procedures for Accela automation setup; and detailed criteria for the Fiscal review step.

   Recommendation: Update the SOP, Developer Credit Transmittal Summary to include detailed procedures and internal controls addressing all identified gaps.
   Management response: Acknowledged. Management recognizes the need to update the SOP. Fiscal will conduct further discussions and revisions with input from all parties involved. Target implementation: September 2024.
5. Finding 5mediumpolicy

   Developer Credits Reconciliation SOP Lacks Key Controls and Procedures

   The Developer Credits Reconciliation SOP (Version No. 1.3) contained limited guidance and omitted several key controls: it did not require the preparer to sign and date the completed reconciliation; did not define roles for performing the reconciliation; lacked a contingency plan for alternate reconcilers; did not specify retention requirements; provided insufficient guidance for researching and correcting discrepancies; did not require a secondary review before submission to the Clerk's Finance Department; did not include controls for segregation of duties (the same individual processed trust account activity and performed the monthly reconciliation); and used individual names rather than position titles for email distribution, without identifying all required recipients.

   Recommendation: Update the SOP, Developer Credits Reconciliation to include detailed procedures and internal controls as described, including a second management review and separation of duties.
   Management response: Acknowledged. Management recognizes the need to frequently update SOPs. The process will be updated with additional formal procedures, including a second management review and separation of duties. Target implementation: September 2024.
6. Finding 6mediumpolicy

   Credit Loads and Transfers SOP Missing Multiple Procedural Controls

   The Developer Credits – Credit Loads and Transfers SOP (Version No. 1.3) omitted key controls and guidance, including: defined roles for performing credit loads, transfers, and refunds/reimbursements; a requirement to verify trust account balances before processing refunds to confirm sufficient credit; defined timeframes for processing; guidance for ineligible requests; defined retention requirements; a specific citation to the applicable section of the Pasco County Land Development Code; and guidance for check requests and timely trust account balance updates upon refund/reimbursement.

   Recommendation: Update the SOP, Developer Credits Loads and Transfers to include detailed procedures and internal controls as described above.
   Management response: Acknowledged. Management recognizes added controls are needed. Fiscal will implement a schedule to review and update procedures to ensure essential tasks are performed with consistency, accuracy, and efficiency. Target implementation: September 2024.
7. Finding 7mediumpolicy

   Trust Account/Credit Letter Processing SOP Lacks Key Controls

   The Trust Account/Credit Letter Processing SOP (Version No. 3.0) did not require management approval before the Accounting Clerk deletes impact fees in Accela; did not provide standardized memo criteria or documentation requirements when credit letters and payments are returned for correction; did not include directives for storing original credit letters; and did not provide guidance for handling lost original credit letters.

   Recommendation: Update the SOP, Trust Account/Credit Letter Processing to include detailed procedures and internal controls as described above.
   Management response: Acknowledged. Management recognizes the need to update the SOP. Fiscal will add procedures for essential tasks and include time-stamped signature verifications to fulfill internal controls. Target implementation: June 2025.
8. Finding 8lowother

   Developer Credit Reconciliation Process Relies on Manual Procedures

   The monthly reconciliation of trust account balances between Munis and Accela was largely a manual process with no independent source data for verification. Due to integration limitations between Accela and Munis, trust account activity did not automatically upload into Munis, and Fiscal did not enter journal entries in Munis for trust account adjustments. As a result, General Ledger staff manually maintained trust account balances in Excel spreadsheets outside of Munis and compared them to Fiscal's spreadsheet, creating operational inefficiency and data reliability risk.

   Recommendation: If feasible, Fiscal should enter journal entries in Munis for trust account adjustments to reduce manual data entry, improve operational efficiency, and enhance data reliability.
   Management response: Acknowledged. Fiscal will continue working with all parties to improve efficiencies and is inquiring with various entities about automating and centralizing the data. Target implementation: August 2026.