Letter Report on the Cash Controls over Fees Collected by the Lobbying Bureau of the Office of the City Clerk and Clerk of the Council
Executive Summary
The objective of this audit was to determine whether the City Clerk’s Lobbying Bureau complied with Comptroller’s Directive #11, Cash Accountability and Control, the New York City Administrative Code, and the Rules of the City of New York when calculating and collecting fees.
The City Clerk serves as both the Clerk of the City of New York and the Clerk of the City Council and provides a range of services to the public. In particular, the City Clerk attests to laws enacted by the City Council; keeps transcripts of City Council proceedings; and attests to leases and deeds of City property, grants, agreements, bonds, tax notes, and other forms of obligations of the City. The City Clerk also operates the Lobbying Bureau and the Marriage Bureau.
The City Clerk’s Lobbying Bureau, officially established in 2006, works with lobbyists and clients to ensure compliance with the NYC Administrative Code and the Rules of the City of New York and to promote transparency in government. Lobbying in the City of New York is governed by NYC Administrative Code §§ 3-211 through 3-223 (the “Lobbying Law”) and Chapter 1 of Title 51 of the Rules of the City of New York. The Lobbying Bureau’s responsibilities also include the registration of lobbyists and clients, the receipt of periodic reports from lobbyists on their lobbying activities, and the audit of those reports.
According to the Comptroller’s Comprehensive Annual Financial Report (Annual Report) for Fiscal Year 2018, the City Clerk reported revenues of $6,226,182, composed of $3,198,740 for administrative services, $2,763,903 in marriage licensing fees, and $263,539 in fines.
Results
Our audit found based on our review of a sample of transactions that the City Clerk’s Lobbying Bureau adequately complied with certain cash control procedures set forth in Comptroller’s Directive #11 in that it: (1) charged correct registration and administration fees to the persons and organizations required to file; and (2) enforced the filing requirements by imposing fees for lateness and noncompliance as provided by the Lobbying Law and the related rules. The Lobbying Bureau also used a log to monitor and record daily the fees it received through the mail and those paid in-person. In addition, the Lobbying Bureau created registration and late-fee logs to track lobbyists’ and clients’ registrations and reporting activities. Moreover, the fees collected and entered into the City Clerk’s Venus system were reconciled to the amounts recorded in the City’s Financial Management System (FMS), and late filing fees were calculated accurately in accordance with the Lobbying Law. However, our audit found that the Lobbying Bureau did not deposit the fees it collected on a daily basis. Specifically, the Lobbying Bureau held on to the deposits for periods that ranged from 7 to 18 days.
Recommendations
Based on the audit, we make the following two recommendations:
The City Clerk’s Lobbying Bureau should:
- Deposit fees on a daily basis in accordance with Comptroller’s Directive #11.
- Consider using a Remote Deposit device to facilitate and ensure daily bank deposits of fees collected.
City Clerk’s Response
In its response, the City Clerk agreed with both recommendations and stated that its staff was greatly impressed the professionalism, diligence, and hard work of our staff during this audit.