ARCHIVED - Audit of Trust Accounts - Follow-up Report Status Update as of September 30, 2011

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Action Plan Implementation Status Update Report to the Audit Committee - As of September 30, 2011

Resolution and Individual Affairs & CFO

Audit of Trust Accounts
Approval Date: 24/09/10

Project
Recommendations
Action Plan Expected
Completion Date
Program
Response
1. The ADM, RIA should develop and communicate a framework for the ongoing monitoring and clearing of suspense accounts within the regions. This should include the clarification of roles and responsibilities for the monitoring and creation of suspense accounts in the Indian Moneys Manual and the Lands Management Manual. There is an opportunity to coordinate the oversight of this monitoring activity with the CFO, through incorporating the status of suspense accounts as part of the regional monthly certification process.
  • Individual Affairs Branch (IAB) in collaboration with Lands Branch (LED) to develop a lands related suspense account monitoring framework. This work will include the modernization of appropriate tools such as a national checklist, categorization of transactions criteria, and clarifying the criteria/conditions in which the department will deposit receipts.
Mars 2011 Status: Request to close (completed)

Update/Rationale:
As of 31/03/2011:

  • Transaction criteria categorized and clarified for monitoring procedure.

  • Standard Operating Procedures (SOP) steps developed

  • National NetLands Directive developed



  • assessment of Netlands completed, corrections to the system have been made, corresponding recommendations awaiting DG, LED approval

  • training on Netlands has been conducted in the regions

  • IM/IT and a Netlands redevelopment plan is currently with DG, LED for approval



  • assessment of Netlands completed, corrections to the system have been made, corresponding recommendations are under review

  • Transaction criteria categorized and clarified for monitoring procedure

  • training on Netlands has been conducted in the regions

  • IM/IT and a Netlands redevelopment plan is currently under review
Status: Request to Close (Completed)

Update/Rationale:
As of 30/09/2011:

  • updated SOP table for Land Management activities and related tools: new reports

  • New procedure: data quality review for maintaining data integrity with NetLands & IRLS (Indian Lands Registry System.)

  • New appendix B which summarizes tools users require to access help with NetLands Directive

  • Training strategy developed

  • A draft process has been completed. Waiting for regions comments. Work on a handbook for managers.

AES: Underway

Review of recommendations resulting from assessment of Netlands.
  • Consistent monitoring procedures will be developed to deal with transactional issues and part of this solution is a national directive to be issued in 2010 making the use of the Netlands tracking system.


  • The monthly certification process will incorporate the requirements for justification of the status of suspense accounts and define consequences for not providing adequate justification and documentation.
October 2011
2. The ADM, RIA, in collaboration with the Senior ADM, RO, should develop a policy, guidelines and associated processes to address long-term suspense accounts.
  • IAB (RIA) in collaboration with Lands (LED) will develop a comprehensive strategy to address long-term lands related suspense accounts which will include the modernization of associated policies, guidelines, processes and procedures as well as to support a monitoring framework.
March 2011 Status: Request to close (completed)

Update/Rationale:
As of 31/03/2011:

  • suspense accounts have been categorized and release procedures for each categories have been recommended and awaiting DG review. A number of categories (such as where lessee or band no longer exists and other historical categories) will require further analysis and review.

  • a chapter in the lands management manual will be drafted to include payment management

  • collection policies and a strategy to address the arrears will be developed.
Status : Request to Close (Closed)

Update/Rationale:
As of 30/09/2011:

  • National NetLands Directive communicated out to regional partners

  • RIA recommended language for updating the Indian Moneys Manual (IMM), Part 5 Suspense Accounts provided.

AES: Underway
  • Collection Policy is under development.

  • Lands Management Manual is being reviewed.

  • Indian Moneys Manual is being updated.
3. The CFO should formally communicate with all regional offices to highlight INAC's cash deposit requirements as outlined in the FMM. This requires that regional offices deposit all cash receipts totalling $500 on a daily basis. There may be opportunities for Program Officers within the regional offices to educate remitters on the documentation requirements to support a cash receipt.
  • CAMM (CFO) in collaboration with Lands (LED) to integrate the Receipt and Deposit of Public Money Policy into the Indian Moneys Manual and the Lands Management Manual. An appropriate procedure will be created to ensure the immediate clearing of suspense accounts which are created to accommodate the lag time between activation and registration of land instruments.
March 2011 Status : Request to Close (Completed)

Update/Rationale:
As of 31/03/2011:

  • National NetLands Directive communicated out to regional partners.

  • RIA recommended language for updating the Indian Moneys Manual (IMM), Part 5 Suspense Accounts provided.

  • User Guide updated.

Status : Request to Close (Completed)

Update/Rationale:
As of 30/09/2011:

  • CFO and LED to integrate the Receipt and Deposit of Public Money Policyonce finalized (by the end of 3rd quarter) into the Indian Moneys Manual and the Lands Management Manual. An appropriate procedure will be created to ensure the clearing of suspense accounts which are created to accommodate the lag time between activation and registration of land instruments.

AES: Underway

Indian Moneys and Lands Management Manuals are under review
4. The ADM, RIA, in conjunction with the CFO, should strengthen due diligence to ensure Indian Moneys are approved in accordance with the relevant BCR and the Indian Act.

If reliance is to be placed on the "Statement of Receipts and Disposal of Indian Moneys" submitted as part of the audited financial statements, they should be audited.
  • Following consultations with DLSU regarding the reporting requirements for the expenditure of Indian moneys, the Indian Moneys, Estates and Treaty Annuities Directorate will oversee rigorous due diligence prior to the release of Indian Moneys. In addition, for future requests a First Nation will be required to provide assurance that any previously released amounts were properly expended according to the approved BCR.
September 2011 Status: Underway

Update/Rationale:
As of 30/09/2011:

  • Phase 1 Policy and process review and update complete.

  • IMETA policy compliance report developed and implemented.

  • Expenditure risk assessment tools developed.

  • Regional consultation on new requirements.

  • Phase 2 moneys management modernization Implementation Framework developed and underway.

Status : Underway

Update/Rationale:
As of 30/09/2011:

  • In consultation with CFO and regions, RIA has developed a mandatory expenditure release electronic process within the Trust Funds Management System. Whereas, previously paper checklists could be ignored, by requiring completion of the electronic checklist before Indian moneys may be released we can ensure national compliance with specific requirements for release.

  • Procedures have been updated to include review of former BCRs and the management of the funds as part of the upfront due diligence review process.

AES: Underway

Pending the launch of this mandatory expenditure electronic checklist.
5. The ADM, RIA should establish tools and communicate detailed guidance to regions on the level of support required to accompany requests for access to Indian Moneys (band and individual) and on the level of analysis required by the Program Officers prior to the recommendation, approval and release of trust account moneys.
  • In collaboration with the CFO the policies, procedures, manuals, training modules and quality assurance processes to ensure national consistency will be reviewed for adequacy.
September 2011 Status : Underway

Update/Rationale:
As of 30/09/2011:

  • draft interim Directive and Phase 2 Implementation Framework developed to be communicated out to RDGs via ROS and Indian Moneys managers first week of April 2011.

Status: Underway

Update/Rationale:
As of 30/09/2011:

  • A draft revised version of the Manual for the Administration of Band Moneys (MABM) reflecting the audit recommendation to strengthen due diligence at the outset and national consistency in implementation is currently under review. Regional training needs will be assessed and training modules developed following completion and publication and distribution of the MABM.

AES: Underway

MABM is still under review.
6. The ADM, RIA, in conjunction with the ADM, LED, should develop a mechanism within existing system capabilities that would allow Program Officers to set up expectations of future cash receipts once an instrument is executed. Once established, the mechanism could notify Program Officers when the receipt of Indian Moneys is expected, which in turn, would trigger a follow-up action if the receipt does not arrive within an acceptable period of time. Depending on the nature of this tracking mechanism, resource requirements to support it should be evaluated.
  • IAB (RIA) in collaboration with Lands (LED) to assess the current Netlands software and deploy patches improving the reporting functionality of the current system as well as the revenue tracking and notification functions. These fixes will be deployed in 2010 along with a directive making the use of the system mandatory for all revenue generating instruments. A complete system rebuild will include full integration with the Lands Registry and Trust Fund Management system. This will be contingent on funding.
March 2011 Status: Request to Close (Completed)

Update /Rationale
As of 31/03/2011:

  • Patches deployed improving the reporting functionality of the current system.

  • National NetLands Directive developed and communicated out to regional partners.

  • System rebuild for integration with TFMS is pending available resources.

AES: Based on rational provided, the recommendation has been closed.
7. The CFO should update the FMM to reflect the expectations of segregation of duties over cash receipts within Finance at the regional office. More specifically, in circumstances where resource limitations only allow for one Finance resource to handle cash receipts, the monthly cash reconciliation should be performed by a separate Finance representative and should be reconciled back to the cash blotter prepared by the mail room.
  • CAMM (CFO) will update the Financial Management Manual (Policy on Receipt and Deposit of Public Money) to better reflect the expectations of segregation of duties over cash receipts within Finance at the regional offices.
March 2011 Status : Underway

Update/Rationale:
As of 30/09/2011:

  • A draft policy has been completed and sent for comments to the Regional Manager of Accounting Operation (REGMAO). A final draft is planned to be completed by the end of April.
Status : Underway

Update/Rationale:
As of 30/09/2011:

  • Recommendation 7 will be addressed as soon as the Receipt and Deposit of Public Money Policy is implemented.

  • Segregation duties will be reviewed to provide specific guidance at the working level through classification of roles and responsibilities linked with identified positions.

  • Consideration will be given to conduct reconciliation in advance of the approved policy.

AES: Underway

Pending review of Segregation and Implementation of Receipt and Deposit of Public Money Policy.
 
 
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