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.TAN-31-89 TUE 15:28 VTR <br />P.O3 <br />Donald Paulcy <br />401 January 31, 1989 <br />Page 2 <br />The first four areas listed above were already routinely audited during the <br />course of the City's audit. The conflicts of interest area is more difficult to <br />address from an auditor's perspective. We recognized this limitation and <br />rccommendcd that the City take action to establish irtemal compliance <br />procedures. The City of Mounds View took prompt action to rotsiu evidence of <br />compliance on file at the City. <br />The City now requires each public official to annually sign a letter of <br />representation which: 1) documents each public official's awareness of it; <br />applicable statutes; and, 2) allows the officer to certify that he/she is in <br />compliance with various applicable statutes, <br />We have aot read the proposed legislation (Senate File 0S). We have, however, <br />read the League of bifaulesota Cities summary dated :aauary 20, 1989, The <br />amount of time and effort both by the individual public officcr: And by the <br />designated control agency will be considerable, The potontial for lack of <br />confidentiality of data will cause apprehension among those filling. This <br />crca:cs a situation whereby good and honest citizens who value the <br />confidentiality of their p,:fsonai finances may not sock public office. Under <br />this circumstance, we would all lose. <br />1f the purpose is to prohibit conflicts, in our opinion, statute, already exist to <br />render such acts illegal, If the purpose of the legislation Is to monitor <br />compliar,:o or detect illegal acts, we believe the statute will be ineffective. If <br />An official has au illegal conflict, it is doubtful that this procedure will <br />uncover such improprieties: A relational data base to match financial <br />interests with City transactions to detect such conflicts would be, in our <br />opinion, unworkable. <br />Enclosed please find: <br />1. Excerpts of the 1984 Management Report and Recommendations <br />relative to this topic, <br />2. Legal compliance audit program excerpts. <br />3. Sample representation letter form. <br />if you have any quostions or mnnire ±dditinrol irf0rrnwiun, plw--. .a.-:.. <br />Sinccroly, <br />VOTO, TAU IDES, REDPATA & CO., LTD, <br />Robert G, T�CPA <br />