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HomeMy WebLinkAbout09-30-1997 1 ki l 'j r r h I r r 1 I 1i I Report to Management FY ending September 30, 1997 I r 32 a Deloi##e & Tcuche LLP City of Denton, Texas Report to Management Year Ended September 30, 1997 lA 1 t t~ DelaitteTouche { Tohmatsu Internatlonal , y i 32 X o 4 I i Deloitte & Touche «P CityConter Tower II Telephone: 181 71 34 7-3300 Suite 2950 301 Commerce Sireot Fort Worth.. Texas 76102 I January 9, 1998 The Honorable Mayor and City Council and City Manager City of Denton 215 E. McKinney Denton, Texas 76201 Dear Mayor, Council Members and City Manager: In planning and performing our audit of the general purpose financial statements of the City of Denton, Texas ("City"), for the year ended September 30, 1997 (on which we issued our report dated January 9, 1998), we considered its internal control structure in order to determine our auditing I procedures for the purpose of expressing an opinion on the general purpose financial statements and not to provide assurance on the internal control structure, Our consideration of the internal control structure would not necessarily disclose all matters in the internal control structure that might be material weaknesses under standards established by the American Institute of Certified Public ACCOlmtam5. A description of the responsibility of management for establishing and maintaining the internal control structure, and the objectives of the inherent limitations in such a structure is set forth in the attached Appendix and should be read in conjunction with this letter. A material weakness is a condition in which the design or operation of the specific internal control structure elements does not reduce to a relatively low level the risk that errors or irregularities in amounts that would be material in relation to the general purpose financial statements being audited may occur and not be detected within a timely period by employees in the normal course of performing their assigned functions. We noted no matters involving the internal control structure and its operation that we consider to be material weaknesses as defined above. We did note other matters related to the intemal control structure and certain administrative and operating matters. 'these recommendations resulted from our observations made In connection with f our audit of the City's general purpose financial statements for the year ended September 30, 1997, This report is intended solely for the use of the City Council and management and should not be used j for any other purpose. We will be pleased to discuss these recommendations with you further and to assist you in implementing them, Yours truly, DeloltteTouche Tohmatsu f Ir~ernailonal -vu. U ' p i TABLE OF CONTENTS CONTINUING PREPARATION FOR THE YEAR 2000 3 GASB 31 IMPLEMENTATION 5 DEFERRED COMPENSATION 5 APPENDIX I' i r I i 1 i f b i y O i , 32xl I i 1 f CONTINUING PREPARATION FOR THE YEAR 2000 Observation: The approach of the year 2000 presents significant issues for many financial, information, and operational systems. Many systems in use today may not be able to interpret dates after December 31, 1999 appropriately, because such systems allow only two digits to indicate the year in a date. As a result, such systems are unable to distinguish January I, 2000, from January I, 1900, which could have adverse consequences on the operations of the entity and the integrity of information processing, causing safety, operational, and financial issues. Lefl uncorrected, many basic functions of computer systems could fail. For example: • All calculations and processes based on two-digit year data (e.g., years 1900 and 2000 are both represented as "00") could fail completely or produce incorrect results. • Age calculations for routine tasks (e,g., payment of benefits) could be incorrect. • Sorting routines may not work correctly (e.g., year 2000 could be sorted as earliest data- -00, 97, 98, 99) • Validation routines (eg., based on "dale within range," "permitted time to reply") could fail a Automatically generated date based information (e.g., timestamps, reference numbers, receipt dates) could fai. or resel to a past date (e.g., 1900), • Interfaces between systems (e.g,, links between personal computers and networks, links between clients, vendors, and customers) could fail or transfer ambiguous data. The year 2000 issue may Impact accounting and information systems, and it may also impact many of the systems used by an entity to operate on a daily basis, Many operational systems have . ales "embedded" in their programming. It is also possible that the failure of operational systems could create safety issues, such as the operations of elevators, building heating and cooling, and security. It has been estimated that approximately 85% of all local govemment programs are affected by the year 2000 issue. .File cost of resolving year 2000 programming issues is estimated to be very substantial and may, place some entities, particularly smaller entities, in financial diffrorllies. Actual experiences have indicated that $1.00 to $2.00 per line of code is not unusual, and certain types of code are significantly higher. In { extreme cases, code cannot be fixed and must be replaced with new systems. Recommendation: Management should continue to consider the risks associated with the year 2000 issue and take immediate steps to address these risks. A dialog should continue among management personnel and between management and the board or council to help mitigate these risks, Some of the questions that may be addressed on a continuing basis up through the year 2000 are as follows: d a. Has a written high-level plan that outlines the procedures for the year 2000 issue been developed? Has the plan been reviewed by senior management? Was a copy (or appropriate summary) provided to the audiUflnance committee? Does the plan include an estimate of the total costs of the year 2000 project? When was the Iasi time that estimate was updated7 b. Has management identified and scheduled a sufficient number of personnel and processing ~r resources to address the year 2000 issue and to accomplish at] of the objectives set forth In the year 2000 plan? Does the plan describe the resources that are needed? Have the costs ofthese resources f, been included in the operating budgets? .u; •3• 44, 0 e i 1 c. Does the plan include a timetable of expected completion dater for various phases of the projects i (i.e., key milestones)? Are the year 2000 activities on schedule? f d. Does the plan include a process for preparing (or updating) a comprehensive inventory of financial, informational, and operational systems? Has this inventory been completed? If not, when will it be completed? e. When will all of the systems that are critical to the operations be identified? Has this date been included within the written plan? f. What procedures are in place to identify those critical systems that are negatively impacted by the year 20007 Are these procedures documented in the plan? What percentage of the critical systems has been subject to these procedures? What were the results of those procedures? When will these procedures be completed for all of the critical systems? ' g. What is the plan for fixing critical systems that are negatively impacted by the year 2000 (e.g., code renovation, replacement, upgrade, development of "work•arounds")? Has this been documented in the year 2000 plan? h. When do you expect all critical systems to be year 2000 compliant? Has this date been documented in the plan? What percentage of the critical systems is now year 2000 compliant? Are there critical or noncritical systems that may not be completed by the required completion date? For every critical system with year 2000 problems, is there a detailed project plan for resolving the problems or for replacing the system; have required personnel and processing resources been estimated; and have experienced project managers and technical staff been assigned? For every critical system with year 2000 problems, is there a detailed schedule for problem resolution or system replacement; does the schedule include the required and expected completion dates, measurable milestones, and expected performance metrics; and does project progress, as measured by achieved milestones and aJual metrics, suggest that the project will be completed on time? i. What procedures are in place to test those critical systems that are considered to be year 2000 compliant? Are these procedures documented in the plan? Have the processing resources required for renovations and testing been estimated, and has a testing environment with adequate capacity been established? What percentage of the critical systems have been subject to these procedures? What were the results of those procedures? When will these procedures be completed for all critical systems? Has this completion date been documented in the plan? j. What procedures are in place to determine that the systems of your key vendors, service providers, ® customers, and component units and joint ventures in which you have a material investment are year 2000 compliant? Are these procedures documented in the plan? What percentage of your key vendors, service providers, customers, and component units and joint ventures in which you have a material investment has been subject to these procedures? What were the results of those procedures? When will these procedures be completed for all of your key vendors, service providers, customers, and component units and joint ventures in which you have a material ® investment? Has (his completion dale been documented in the plan? 4 k. What procedures are in place to mitigate risk of litigation and noncompliance with federal and state regulations as a result of year 2000 operating problems? Have these procedures been documented in the plan? Has general counsel reviewed the plan? .4. Fri ra .e & -ate .r , &A J I V I 4 1. What contingency plans are in place, or planned, if systems fail to function properly? Have these plans been tested or challenged for feasibility? Are there critical and unique high-volumt systems I for which a contingency plan may not be possible? m. Who has oversight responsibility for this year 2000 project? How, do they fulfill this responsibility " (c.g„ interim status reports, exception reports that identify departures from schedules early enough for corrective action)? Who verifies the accuracy of the reporting to this oversight body (individual)? 1 n. Are senior management and the audit committee kept up to 4ate on your year 2000 activities and the results of those activities? When was the last communication to senior management? When was the last communication to the audit committee? o. Has the year 2000 impacted current or prior-year operations? Has the year 2000 impacted current or prior-year management or financial reporting? GASB STATEMENT NO. 31 Observation: 'rhe Governmental Accounting Standards Board ("GASB") has Issued Statement 31, "Accounting and Financial Reporting for Certain Investments and for External Investment Pools." GASB Statement 31 will become effective for the City for the period beginning after June 15, 1997. It requires that most investments be recorded at fair value, in most cases, market value, Fair value is defined as the amount at which a financial instrument could be exchanged in a current transaction between willing parties. This method of accounting will cause fluctuations in reported investment values based on fluctuations in the investment market. Fluctuations in the fair value of investments will be recorded in the operating statements, in accordance with GASB Statement 31. Reported investment income will be affected as amounts formerly excluded from operating statements as "unrealized," or non-cash gains and losses will now, be included. I t E Recommendation: Evaluate the impact of GASB Statement 31 on the City's investment policy and strategies, Management will need to estubliah and implement procedures to ensure that all information f required to monitor the fair value of investments is available and can be recorded appropriately. Users of the City's financial statements will need to be educated on the effects on the financial statements of this j change in accounting for investments. i DEFERRED COMPENSATION Observation: Section 457 of the Internal Revenue Code regarding deferred compensation has changed as follows: "A plan shall not be treated as an eligible deferred compensation plan unless all assets and income of the plan are held in trust for the exclusive benefit of participants and their beneficiaries. ..,]it the case of a plan in existence on the date of the enactment of this Act, a trust need not be established by reason of the amendments made by this section before January 1, 1999." As a result, the assets and liabilities of the deferred compensation plan will no longer be shover, as a separate fund in the general purpose financlal statements. However, the change to the general purpose t financial statements can only be made once the deferred compensation plan has been amended to reflect -5 y 4. - ~z s~~€3:`y`i.:•+.:.ititYiffi~ $L~:`~. 1 e._ j ff r~_ Ir the change in the law, For plans to be In compliance with the law and remain as eligible for tax-exempt statn., an amendment reflecting the change needs to be made by January 1, 1994. Recommendation: Review the change in internal Revenue Code Section 457 and draft appropriate amendments to the deferred compensation plan reflecting the changes required by the low to ensure that the plan is 'it compliance. Once the change has been made, remove the deferred compensation plan from the agency fund of the general purpose financial statements. f' I ;t i I I .6- 32 x 8 , APPENDIX I I MANAGEMENT'S RESPONSIBILITY FOR, AND THE OBJECTIVES ~ AND LIMITATIONS OF, THE INTERNAL CONTROL STRUCTURE The following comments concerning management's responsibility for the internal control structure and the objectives of, and the inherent limitations in, the internal control structure are adapted from the Statements on Audition Standards of the American Institute of Certified Public Accountants. Management's Responsibility Management is responsible for establishing and maintaining an internal control structure, In fulfilling this responsibility, estimates andjudgments by management are required to assess the expected benefits f and related costs of Internal control structure policies and procedures, Objectives f The objectives of an intemal control structure are to provide management with reasonable, but not absolute, assurance that assets are safeguarded against loss from unauthorized use or disposition, and that transactions are executed in accordance with management's authorization and recorded properly to permit the preparation of financial statements in accordance with generally accepted accounting principles. Limitations Because of Inherent limitations in any Internal control structure, errors or irregularities may occur and not be detected. Also, projection of any evaluation of the structure to future periods is subject to the risk that procedures may become Inadequate because of changes in candillons or that the degree of compliance with the procedures may deteriorate. I I I j m 3 I ' , wI F , f j f 1 1 41. _ s 32X S t t 1 r Deloitte & I Touche UP City Centei Tower II Telephone !8171347.3300 Suito 2950 301 Commerce Street Foil Worlh, Texas 78102 January 9, 1998 City of Denton Municipal Building 215 E. McKinney Denton, Texas 76201 i Dear Honorable Mayor and Members of the City Council: We have audited the general purpose financial statements of the City of Denton (the "City") as of and for the year ended September 30, 1997, and have issued our repoll thereon dated January 9, 1998, our professional standards require that we communicate with you concerning certain matters that may be of interest to you in fulfilling your obligation to oversee the financial reporting and disclosure process for which management of the City is responsible. We have prepared the following comments to assist the Mayor and members of the City Council in fulfilling that obligation. OUR RESPONSIBILITY UNDER GENERALLY ACCEPTED AUDITING STANDARDS AND j' GOVERNMENT AUDITING STANDARDS ISSUED BY THE COMPTROLLER GENERAL OF THE UNITED STATES I We conducted our audit of the 1997 general-purpose financial statements of the City In accordance f with generally accepted auditing standards and Government Auditing Standards, Those standards require that we plan and perform the audit to obtain reasonable, rather than absolute, assurance about whether the financial statements are free of material misstatement. When performing as audit in accordance with those standards, we are only required to obtain an understanding of the City's internal control structure sufficient to enable us to properly plan our audit not to provide assurance on the internal control structure, Based, in part, on our understanding of the control environment, we design our audit to provide reasonable assurance of detecting errors and irregularities that are material to the financial statements. However, because of the characteristics of irregularities, particularly those involving forgery and collusion, a properly designed and executed audit may not detect such items. We have issued a separate report to you, also dated January 9, 1998, containing our comments on the internal control structure. Neither our audit of the City's general purpose financial statements for the year ended September 30, E 1997, nor any reviews or other services provided pursuant to that audit, provide any assurances that IE is a the City's systems or any other systems, such as those of the City's vendors, service providers, customers, component units or joint ventures In which the City has an investment, or other third DoUttebuche Tohmatsu lntermtloM 1 1 s parties, are year 2000 compliant, nor does our audit, any reviews or other services provide any other assurances regarding the year 2000. In addition, we are not engaged to perform, nor did we perform, any procedures to test whether the City's systems or any other systems are year 2000 compliant or whether the r plans and activities of the City are sufficient to address and correct system or any other problems that might ! arise because of the year 2000. Accordingly, have not expressed any opinion or provided any other assurances regarding the year 2000. t SIGNIFICANT ACCOUNTING POLICIES During the year ended September 30, 1997, there were no significant changes in previously adopted accounting policies or their application. f MANAGEMENT JUDGMENTS AND ACCOUNTING ESTIMATES Accounting estimates are an integral part of the general-purpose financial statements prepared by management and are based upon management's current judgments. 'those judgments are normally based on knowledge and experience about past and current events and assumptions about future events, Significant accounting estimates reflected in the City's 1997 general-purpose financial statements include the liabilities for general liability claims payable and workers compensation claims payable and allowances for uncollectible accounts. SIGNIFICANT AUDIT ADJUSTMENTS There were no significant audit adjustments. DISAGREEMENTS WITH MANAGEMENT There were no disagreements with management, I CONSULTATION '.VITH OTHER ACCOUNTANTS We are not aware of any consultations with other independent public accountants regarding accounting or auditing matters. MAJOR ISSUES DISCUSSED WITH MANAGEMENT PRIOR TO RETENTION There were no major issues discussed with management DIFFICULTIES ENCOUNTERED IN PERFORMING THE AUDIT There were no difficulties encountered. OTHER INFORMATION IN THE COMPREHENSIVE ANNUAL FINANCIAL, REPORT When audited financial statements are Included in documents containing other information, such as the City's Comprehensive Annual Financial Report, generally accepted auditing standards require that we read 1 such other information and consider whether it, or the manner of Its presentation, is materially inconsistent with the information, or the manner of Its presentation, in the financial statements audited by us. We have Q 9 read the other Information In the City's Comprehensive Annual Financial Report for the year ended 4 September 30, 1997, and have inquired as to the methods of measurement and presentation of such Information. If we had noted a material inconsistency, or if we had obtained any knowledge of a material 2 - r' i ~I CITY OF DENTON_TEXA$ Finance Department ' 215E. McKinney* Denton, Texas 76201 Telephone (940) 349-8288 • DF"' illetro (972) 434.2529 • FAX (940) 349.7789 February 6, 1998 Honorable Mayor, Council Members and City Manager: After review and discussion of the auditor's management letter, staff has prepared the following responses to the recommendations presented. 1. CONTINUING PREPARATION FOR THE, YEAR 2000 Observalion: the approach of the year 2000 presents significant issues for many financial, information, and operational systems. Many systems in use today may not be able to interpret dates after December 31, 1999 appropriately, because such systems allow only twa digits to indicate the year in a date. As a result, such systems rue unable to distinguish January I, 2000, from January I, 1900, which could have advet, conscyuences on the operations of the entity and the integrily of information processing, causing safely, operational, and financial issues, Lefl uncorrected, many basic functions of computer systcros could fail, For example: • All calculatlons and processes based on two-digit year data (e.g., years 1900 and 2000 are both represented as "00") could fail completely or produce incorrect results. • Age calculations for routine tnsks (e.g., payntent of benefits) could be incorrect. • Sorling routines may not work correctly (e.g., year 2000 could be sorted as earliest data 00,97,98,99). • Validation mulines based on "date within range," "permitted time to reply") could rail • Automatically generated date-based information (e.g., limestamps, reference numbers, receipt doles) could fail or reset to a past dale 1900). • Interfaces bct%vicen systems (e.g., links between personal computers and networks, links between clients, vendors, and customers) could fail or oansfet ambiguous data. The year 2000 issue may impact accounting and information systems, and it may also impact many of the systems used by an entity to operate on a daily basis. Many operational systems have dates "embedded" in their programming. II is also possible that the failure of operational systems could create safety issues, such as the operations of elevators, building heating and cooling, and sccurity, It has been estimated that approximately 85;'0 of all local government programs are affected by the year 2000 issue. Q The cost of resolving year 2000 programming issues is estimated to be very substtmtlal and may place some entities, particularly smaller entities, in financial difficulties. Actual experiences have indicated that $1.00 to $2A0 per line of codo is not unusual, and certain types of code are sigoiftcanlly higher. In extreme r+ cases, code cannot he fixed and roust be replaced with new systems. 'Wedtroled to (huria)-No ee" s Management Letter Responses February -1,199g page 2 of 4 Recommendation: Management should continue to consider the risks associated with the year 2000 issue and take irmnediate steps to address these risks. A dialog should continue among management petsouncl and betvvccn management and the board or council to help mitigate these risks. Some ofthe questions that may be addressed on a continuing basis tip through the year 2000 are as follows: a, I las a written high-level plan that outlaw the procedures for the year 2000 issue been developed? YES Lis the plan been reviewed by senior management? YES Was a cup), (or appropriate summary) provided to the audit/lImancc committee? YES Does the plan include an estimate of the total costs of the year 2000 project? YES When was the last time that estimate was updated? SEPTEMBER 1995 b. I his nunnngcment identified and scheduled a sufficient number orpersonnel and processing resources to address the year 2000 issue and to accomplish all of the objeclkvcs set forth in the year 2000 plan? YES Does the plan describe the resources that are needed! YES I have the costs of these resources been included in the operating budgets? YES o Does the plan include a timetable of expected completion dates for various phases of the projects (Le., key milestones)? YES Are the year 2000 activities on schedule? YES d, Does the plan include a process for preparing (or updating) a connprehensive inventory of financial, infonnational, and operational systems? YES Has this inventory been completed? YES c. When will all ofthe systems that arc critical to the operations be identified? ACI IIEVF0 Has this date been included within the written plan? YIIS f. What procedures are in place to identify those critical systems that are negatively impacted by the year `E 2000? All applications, hosts, and connectivity components are verified Y2K compliant prior to implementation or have been identified in our Y2K assessment plan Are these procedures documented in the plan? YES What percentage of the critical systems has been subject to these procedures? 100% What were the results of those procedures? Our accounting systent (LOFS), Equipment Management System, Municipal Court System, VSE operating system, NvIWarc J.X and 4.X were all identified as being non-WK compfiant. When will these procedures be completed for all of the critical systems? ACI II EiVED g. What is the plan I'or fixing critical systems that are negatively impacted by the year 2000{e.g., code renovation, replacentent, upgrade, development of"wurk-aroIuIc? hnplententation of vendor e patches, soflware upgrades. I las this beca documented in the year 2000 plan? YF.S It, When do you expect all critical systems to be year 2000 compliant? Janunry 1999 Has This dale been doemllertled in thu plan? YES What percentage or the critical systems is now year 2000 compliant? 4'J% Are there critical or noncritical systems that may not he completed by the required completion date'? NO For every critical system with year 2000 problems, is there a detailed project plan resolving the Q l problems or for replacing the system; have required personnel and proessing tvsnrttrces been 1 estimnated; and have experienced project managers and technical staf7 t cetn assigned'? YES For every critical s) stern with year 21000 problems, is there a detailed schedule for probkni resolution mr system rcplacenicwt does the schedule Include the required and expected completion dates, 0 Management Leticr Responses February 3, 1998 Page 3 of 4 measurable milestones, and expected performance wcrrics; and does project progross, as measured by achieved milestones and actual metrics, suggest that the project will be completed on time? YES i. What procedures are !it place to test those critical systems that are considered to be year 2000 compliant? Detailed in the Y2K Assessment Plan. Are these procedures documented in the plan? YF.S Have [lie processing resources required fo, renovations and testing been estimated, and has a testing errvironment with adequate capacity been established? YES What percentage of the critical systems have been subject to these procedures? 100% What were the results of those procedures? COMPLIANT When will These procedures be completed for all critical systems? ACHIEVED Ilas this completion date been documented in the plan? Y17S j. What procedures are in place to determine that the systems of your key vendors, service providers, customers, and component units and joint ventures in which you have a material investment are year 2000 compliant? To [le Determined Are These procedures doeunicntcd in the plan? To Be lktennined What percentage of your key vendors, service providers, customers, and componenl units mhdjoiw ventures in which you have a material investment has been subject to these procedures? To ❑e Determined What were the results of those procedures? To Ile Ielermined When will these procedures be conipletcd for all of your key vendors, service providers, customers, and component units and joint ventures in which you have a material investment? To lie Determined [fits this completion date been documented in the plan? To lie Determined k. What procedures are in place to mitigate the risk of litigation and noncompliance with federal and state regulations asa result of ycar 2000 operating problems or prnduct/scrvice failures? To He Determined j Have these procedures been documented in the plan? To Ile Determined tins the general counsel reviewed the plan? To Be Determined L What contingency plans are in place, or planned, if systems fail to function properly? A business continuity plan is in dcvclopment. Have these plans been tested or challenged for feasibility? To 6e Determined i Are there critical and unique hlgh•volunie systems for which a contingency plan may not be possible? To lie Ilclermined in. Who has oversight responsibility for this year 2000 project? Alex Pettit, Director of information Services. E Mow do they fulfill this responsibility (c,g., interim status reports, exception reports That identify departures from schedulcs early enough for coreclive action)? Status reportslprojcet planning. Who verifies the acurncy ofte reporting to this oversight bxxly (individual)? Dave Dickcy and • Angela Kastel, n. Are senior management and the audit committee kept up to date on your year 20(10 activities and the results of those activities? YF'S When was the last communication to senior management? Ikccruber 22, 1997 When was Thu Iasi cumnuntication to the audit committee'! May, 1995 o. Ilas the year 2000 impacted current orprior•year operations? No Iles the year 2000 impacted current or prior•year managentem or frnnncial reporting? No Q p. What year 2000 issues cause you the most concert? Of no current concern. kl' It's . r Q J i - I Mmnagenicnt Leucr Responses February 3, 1998 Page 4 011'4 Response: StaB'agrecs with the recommendation and has had a fbnnal plan n,, effect for the last several years to address these issues, Management's respxmses to the questions raised in the reeommendation appenrabove. IL GASB STATEMENT NO, 31 Observation: The Governnienlal Accounting Standards Board ("GASH") has issued Statement 31, "Accounting and Financial Reporting For Cerlain Investments and for External Investment Pools," GASB Statement 31 will become effective for the City for the period beginning after June 15, 1997. It requires that most investments be recorded at fair value, in most cases, market value. Fair value is defined as the amount at which a financial instrument could be exchanged in a current transaction between willing parties. This method ofaccouralog will cause Ihictuations in reported investment values based on fluctuations in the investment market. Fluctuations in the fair value of investments will be recorded in the operating statements, in accordance with GASB Statement .l 1. Reported investment income will be affected as 0111put115 formerly excluded from operating statements as "unrealized;" or non-cash gains and losses will now be included. i i Recpnmmn latim Vvi lhate the impact of GASB Statement 31 on the City's investnarhl policy and strategics. Management will need to establish and implement procedures to ensure that all information required to nhonitor the flair value of investments is available and can be recorded appropriately. Users of the City's financial statements will need to be educated on the effects on the financial statements of this change io accounting for investments. Res onse_ Staff agrees with the recommendation arid has implenlented procedures to Conform with the reputing requirements of GASB 31, Additionally, the Comprehensive Annual Financial Report for the next fiscal )Car will contain information to assist users in understanding the effects of GASB 31 on the financial statements. Ill. DSPERREDCONIPENSATION Observation: Section 457 of the Internal Revcnue Code regarding deferred compensation has changed as fhl lows: i "A plan...shall not be treated as an eligible deferred compensation plan unless all assets and income of the plan ...arc held in trust for the exclusive benefit of participants and their beneficiaries. ..,In the case of a plan in existence on the date of lh t enactment of this Act, a trust need not he established by reason ofthe amendments nnade by this section before January 1, 1999." As it result, the assets and liabilities of the deferred compensation plan will no longer be shown as a separate fund in the general purpose financial statements, however, the change to the general purpose Iinancinl sutcuhents can rally be made once the deferred compensation plan has been amended to reflect the Change in the law. For plans to be in compliance with the law arid remain as eligible for tax-e.eernpt status, an amendment reflecting the change needs to be made by January I, 1999. )in - Review the change in Internal Rovemic Code Section 457 and draft appropriate amcudnucnts to the dekrrod compensation plan reflecting the changes required by the law io ensure that the plan is in compliance. (nice the change has been made, remove the deferred compensation plan from the agency fund of the goner l purpose financial statements. S I!Kr, w: Stafragrees with the recommendation and will make all cliunges necessary to ensure fill] )si,. compliance with the ucw law, T. 1, 711 17 Fr 1 } S, _r t 9 R 1I,..a~!