A-51082, NOVEMBER 29, 1933, 13 COMP. GEN. 154

A-51082: Nov 29, 1933

Additional Materials:

Contact:

Edda Emmanuelli Perez
(202) 512-2853
EmmanuelliPerezE@gao.gov

 

Office of Public Affairs
(202) 512-4800
youngc1@gao.gov

THE COUNTERSIGNING HEREAFTER WILL BE BY THE GENERAL ACCOUNTING OFFICE INSTEAD OF BY THE COMPTROLLER. THERE IS NO STATUTORY REQUIREMENT FOR THE COUNTERSIGNING OF POSTMASTER GENERAL'S DRAFTS OR CHECKS TRANSFERRING POSTAL REVENUES TO MONEY-ORDER FUNDS (SEC. 4042. 1933: THERE HAVE BEEN RECEIVED YOUR LETTERS OF SEPTEMBER 14. WILL YOU KINDLY INFORM ME. THIS COUNTERSIGNATURE BY THE COMPTROLLER OF THE POST OFFICE DEPARTMENT IS AN APPROVAL OF THE TRANSACTIONS REPRESENTED BY THESE CHECKS? ALSO IS THIS COUNTERSIGNATURE A CERTIFICATION THAT THE AMOUNTS ARE CORRECT AND PAYABLE? IN REGARD TO THE LIABILITY UNDER WHICH THE COMPTROLLER OF THE POST OFFICE DEPARTMENT IS COUNTERSIGNING CHECKS OF THE POSTMASTER GENERAL.

A-51082, NOVEMBER 29, 1933, 13 COMP. GEN. 154

COUNTERSIGNING OF CHECKS OR WARRANTS ISSUED BY THE POST OFFICE DEPARTMENT AS THE COUNTERSIGNING REQUIRED BY STATUTE ON CHECKS OR WARRANTS ISSUED BY THE POSTMASTER GENERAL INVOLVES AN AUDIT ACTION, THE COUNTERSIGNING HEREAFTER WILL BE BY THE GENERAL ACCOUNTING OFFICE INSTEAD OF BY THE COMPTROLLER, BUREAU OF ACCOUNTS, POST OFFICE DEPARTMENT. THERE IS NO STATUTORY REQUIREMENT FOR THE COUNTERSIGNING OF POSTMASTER GENERAL'S DRAFTS OR CHECKS TRANSFERRING POSTAL REVENUES TO MONEY-ORDER FUNDS (SEC. 4042, REV.STAT.), OR FOR THE COUNTERSIGNATURE OF BILLS OF EXCHANGE, DRAFTS, OR CHECKS RECEIVED BY THE GENERAL ACCOUNTING OFFICE AND TURNED OVER TO THE SUPERINTENDENT, DIVISION OF FINANCE, POST OFFICE DEPARTMENT.

COMPTROLLER GENERAL MCCARL TO THE POSTMASTER GENERAL, NOVEMBER 29, 1933:

THERE HAVE BEEN RECEIVED YOUR LETTERS OF SEPTEMBER 14, OCTOBER 12, AND NOVEMBER 1, 1933, AS FOLLOWS:

A QUESTION HAS ARISEN AS TO THE RESPONSIBILITY OF THE COMPTROLLER OF THE POST OFFICE DEPARTMENT, FOR HIS COUNTERSIGNATURE ON CHECKS OF THE POSTMASTER GENERAL, SIGNED BY THE THIRD ASSISTANT POSTMASTER GENERAL, DRAWN ON THE TREASURER OF THE UNITED STATES, FOR THE FOLLOWING PURPOSES:

IN PAYMENT TO FOREIGN COUNTRIES FOR INTERIM BALANCES AND FOR AUDITED BALANCES, ON MONEY-ORDER ACCOUNT. ALSO THE COUNTERSIGNATURE ON THE ACCOMPANYING FORM 6071.

IN PAYMENT OF POSTMASTER'S CHECKS DRAWN ON, AND PAID BY THE TREASURER OF THE UNITED STATES. ALSO THE COUNTERSIGNATURE ON THE ACCOMPANYING FORM 6075.

FOR THE TRANSFER OF POSTAL FUNDS TO MONEY-ORDER FUNDS. ALSO THE COUNTERSIGNATURE ON THE ACCOMPANYING FORM 6077.

FOR PAYMENT TO THE SUPERINTENDENT, DIVISION OF FINANCE, POST OFFICE DEPARTMENT, FOR BILLS IN FOREIGN MONIES RECEIVED BY THE GENERAL ACCOUNTING OFFICE IN PAYMENT OF POSTAL SERVICES OTHER THAN MONEY ORDER.

WILL YOU KINDLY INFORM ME, IF, IN YOUR OPINION, THIS COUNTERSIGNATURE BY THE COMPTROLLER OF THE POST OFFICE DEPARTMENT IS AN APPROVAL OF THE TRANSACTIONS REPRESENTED BY THESE CHECKS? ALSO IS THIS COUNTERSIGNATURE A CERTIFICATION THAT THE AMOUNTS ARE CORRECT AND PAYABLE?

I WOULD BE PLEASED TO RECEIVE ANY FURTHER REMARKS YOU MAY CARE TO MAKE ON THIS SUBJECT.

FURTHER TO MY LETTER OF SEPTEMBER 14, 1933, IN REGARD TO THE LIABILITY UNDER WHICH THE COMPTROLLER OF THE POST OFFICE DEPARTMENT IS COUNTERSIGNING CHECKS OF THE POSTMASTER GENERAL, THERE IS NOW TO BE ADDED THE FOLLOWING INSTANCE:

CHECKS IN FAVOR OF THE DIRECTOR, DIVISION OF POSTAL SAVINGS, TO REIMBURSE THE POSTAL SAVINGS FUNDS FOR MONEY WITHDRAWN FROM THOSE FUNDS AND USED IN THE PAYMENT OF MONEY ORDERS BY POSTMASTERS.

IN THIS INSTANCE THE METHOD OF ADJUSTMENT AND THE AMOUNT OF THE ADJUSTMENT IS FURNISHED BY THE GENERAL ACCOUNTING OFFICE.

THERE IS FURTHER TO MY LETTERS OF SEPTEMBER 14TH AND OCTOBER 12TH, WHICH REMAIN UNANSWERED, ON THE SUBJECT OF COUNTERSIGNATURE BY THE COMPTROLLER OF THE POST OFFICE DEPARTMENT ON CHECKS DRAWN BY THE POSTMASTER GENERAL ON THE TREASURER OF THE UNITED STATES.

THERE IS ALSO THE INSTANCE OF CHECKS DRAWN TO DEPOSIT THE PROCEEDS OF DOMESTIC AND INTERNATIONAL MONEY-ORDER BUSINESS FOR EACH OF THE FOUR QUARTERS OF THE YEAR, THE AMOUNT BEING THE BALANCE AUDITED BY YOUR OFFICE CALLED "REVENUE FROM MONEY ORDER BUSINESS," AND WHICH CONTAINS ITEMS NOT WITHIN THE CONTROL OF THIS DEPARTMENT.

REFERRING TO YOUR LETTER OF SEPTEMBER 14, SUPRA, THE CHECKS MENTIONED IN THE SECOND PARAGRAPH ARE THOSE ISSUED TO FOREIGN COUNTRIES DURING A QUARTER AND AT THE END THEREOF IN SETTLEMENT OF MONEY-ORDER ACCOUNTS WITH FOREIGN POSTAL ADMINISTRATIONS, PURSUANT TO THE TERMS OF POSTAL CONVENTIONS. ONLY THE FINAL CHECK IN SETTLEMENT FOR A QUARTER HERETOFORE HAS BEEN BASED ON A CERTIFICATION BY THIS OFFICE TO THE OFFICE OF THE POSTMASTER GENERAL, OFFICE OF THE THIRD ASSISTANT POSTMASTER GENERAL. THE CHECKS REFERRED TO IN YOUR THIRD PARAGRAPH ARE THOSE ISSUED TO THE TREASURER OF THE UNITED STATES IN PAYMENT FOR WITHDRAWALS MADE BY POSTMASTERS WHEN NECESSARY FOR THE SATISFACTORY TRANSACTION OF MONEY-ORDER BUSINESS PURSUANT TO SECTION 1501, POSTAL LAWS AND REGULATIONS, 1932. IS UNDERSTOOD THAT THE TREASURER OF THE UNITED STATES TRANSMITS EACH DAY TO THE POST OFFICE DEPARTMENT THE POSTMASTERS' CHECKS CASHED BY HIM AND RECEIVES IN RETURN ONE CHECK FROM THE POSTMASTER GENERAL, COUNTERSIGNED AS INDICATED, FOR THE TOTAL SUM THUS THEREIN, FOR THE PURPOSE OF TRANSFERRING POSTAL FUNDS TO THE MONEY-ORDER ACCOUNT. FORM 6077 IS NOT COUNTERSIGNED BY THE COMPTROLLER, BUREAU OF ACCOUNTS, POST OFFICE DEPARTMENT, AS STATED. REFERRING TO YOUR FIFTH PARAGRAPH, SAID CHECKS ARE ISSUED FOR THE PURCHASE BY THE MONEY-ORDER DIVISION, POST OFFICE DEPARTMENT, OF FOREIGN BILLS OF EXCHANGE RECEIVED BY THIS OFFICE AND TURNED OVER TO THE SUPERINTENDENT, DIVISION OF FINANCE, POST OFFICE DEPARTMENT, WHOSE RECEIPT IS TAKEN, IN PAYMENT OF BALANCES DUE THIS COUNTRY FROM FOREIGN POSTAL ADMINISTRATIONS. DESCRIPTIONS OF THE TWO ADDITIONAL CLASSES OF CHECKS ARE SUFFICIENTLY SET FORTH IN YOUR LETTERS OF OCTOBER 12 AND NOVEMBER 1.

IT WOULD NOT APPEAR NECESSARY TO SET FORTH THE COMPLETE ADMINISTRATIVE AND ACCOUNTING PROCEDURE INVOLVED IN THE ISSUANCE OF THE SIX CLASSES OF CHECKS IN QUESTION. IT IS UNDERSTOOD, HOWEVER, THAT NO ADMINISTRATIVE EXAMINATION OF ACCOUNTS OR OTHER ADMINISTRATIVE ACTION HERETOFORE HAS BEEN TAKEN BY THE COMPTROLLER, BUREAU OF ACCOUNTS, POST OFFICE DEPARTMENT, PRIOR TO HIS COUNTERSIGNATURE, TO DETERMINE THE CORRECTNESS OR LEGALITY OF TRANSACTIONS INVOLVED, BUT THAT HIS COUNTERSIGNATURE HAS BEEN ENTIRELY A MATTER OF FORM, APPARENTLY HAVING BEEN ASSUMED BY THE FIRST COMPTROLLER, BUREAU OF ACCOUNTS, POST OFFICE DEPARTMENT, IN 1921, AS A FUNCTION OF THE ADMINISTRATIVE EXAMINATION OF ACCOUNTS VESTED IN HIM BY THE BUDGET AND ACCOUNTING ACT. IT IS UNDERSTOOD, FURTHER, THAT, PURSUANT TO THE ADMINISTRATIVE DISTRIBUTION OF DUTIES TO THE VARIOUS BRANCHES OF THE POST OFFICE DEPARTMENT, THE ADMINISTRATIVE RESPONSIBILITY FOR THE CORRECTNESS AND LEGALITY OF THE TRANSACTIONS INVOLVED IN THE ISSUANCE OF THE CHECKS HAS BEEN VESTED IN THE OFFICE OF THE THIRD ASSISTANT POSTMASTER GENERAL, AND NOT IN THE BUREAU OF ACCOUNTS. SECTIONS 8 TO 15 OF THE POSTAL LAWS AND REGULATIONS, 1932.

SECTION 277, REVISED STATUTES, PROVIDES IN PART AS FOLLOWS:

THE SIXTH AUDITOR SHALL RECEIVE ALL ACCOUNTS ARISING IN THE POST OFFICE DEPARTMENT, OR RELATIVE THERETO, WITH THE VOUCHERS NECESSARY TO A CORRECT ADJUSTMENT THEREOF, AND SHALL AUDIT AND SETTLE THE SAME AND CERTIFY THE BALANCES THEREON TO THE POSTMASTER GENERAL. * * * HE SHALL REGISTER, CHARGE, AND COUNTERSIGN ALL WARRANTS UPON THE TREASURY FOR RECEIPTS OR PAYMENTS ISSUED BY THE POSTMASTER GENERAL WHEN WARRANTED BY LAW. * * *

SECTIONS 293, 294, 406, 407, 408, 3617, 3641, 3674, 4042, 4043, 4045, AND 4055, REVISED STATUTES, PROVIDE AS FOLLOWS:

SEC. 293. THE SIXTH AUDITOR SHALL KEEP THE ACCOUNTS OF THE MONEY ORDER BUSINESS SEPARATELY, AND IN SUCH MANNER AS TO SHOW THE NUMBER AND AMOUNT OF MONEY ORDERS ISSUED AT EACH OFFICE, THE NUMBER AND AMOUNT PAID, THE AMOUNTS OF FEES RECEIVED, AND ALL THE EXPENSES OF THE MONEY-ORDER BUSINESS.

SEC. 294. THE SIXTH AUDITOR SHALL STATE AND CERTIFY QUARTERLY TO THE POSTMASTER GENERAL AN ACCOUNT OF THE MONEY PAID BY POSTMASTERS OUT OF THE RECEIPTS OF THEIR OFFICES, AND PURSUANT TO APPROPRIATIONS, ON ACCOUNT OF THE EXPENSES OF THE POSTAL SERVICE; DESIGNATING THE HEADS UNDER WHICH SUCH PAYMENTS WERE MADE.

SEC. 406. UPON THE CERTIFIED QUARTERLY STATEMENT BY THE SIXTH AUDITOR OF THE PAYMENTS BY POSTMASTERS ON ACCOUNT OF THE POSTAL SERVICE, THE POSTMASTER GENERAL SHALL ISSUE HIS WARRANT TO THE TREASURER TO CARRY THE AMOUNT TO THE CREDIT OF THE POSTAL REVENUES AND TO THE DEBIT OF THE PROPER APPROPRIATIONS UPON THE BOOKS OF THE AUDITOR.

SEC. 407. THE POSTAL REVENUES AND ALL DEBTS DUE THE POST OFFICE DEPARTMENT SHALL, WHEN COLLECTED, BE PAID INTO THE TREASURY OF THE UNITED STATES, UNDER THE DIRECTION OF THE POSTMASTER GENERAL; AND THE TREASURER, ASSISTANT TREASURER, OR DESIGNATED DEPOSITORY RECEIVING SUCH PAYMENT, SHALL GIVE THE DEPOSITOR DUPLICATE RECEIPTS THEREFOR.

SEC. 408. ALL DEPOSITS ON ACCOUNT OF THE POSTAL SERVICE SHALL BE BROUGHT INTO THE TREASURY BY WARRANTS OF THE POSTMASTER GENERAL, COUNTERSIGNED BY THE AUDITOR; AND NO CREDIT SHALL BE ALLOWED FOR ANY DEPOSIT UNTIL SUCH WARRANT HAS BEEN ISSUED.

SEC. 3617. THE GROSS AMOUNT OF ALL MONEYS RECEIVED FROM WHATEVER SOURCE FOR THE USE OF THE UNITED STATES, EXCEPT AS OTHERWISE PROVIDED IN THE NEXT SECTION, SHALL BE PAID BY THE OFFICER OR AGENT RECEIVING THE SAME INTO THE TREASURY, AT AS EARLY A DAY AS PRACTICABLE, WITHOUT ANY ABATEMENT OR DEDUCTION ON ACCOUNT OF SALARY, FEES, COSTS, CHARGES, EXPENSES, OR CLAIM OF ANY DESCRIPTION WHATEVER. BUT NOTHING HEREIN SHALL AFFECT ANY PROVISION RELATING TO THE REVENUES OF THE POST OFFICE DEPARTMENT.

SEC. 3641. THE POSTMASTER GENERAL MAY TRANSFER MONEY BELONGING TO THE POSTAL SERVICE BETWEEN THE TREASURER, ASSISTANT TREASURERS, AND DESIGNATED DEPOSITARIES, AT HIS DISCRETION, AND AS THE SAFETY OF THE PUBLIC MONEY AND THE CONVENIENCE OF THE SERVICE MAY REQUIRE.

SEC. 3674. PAYMENTS OF MONEY OUT OF THE TREASURY ON ACCOUNT OF THE POSTAL SERVICE SHALL BE IN PURSUANCE OF APPROPRIATIONS MADE BY LAW, BY WARRANTS OF THE POSTMASTER GENERAL, REGISTERED AND COUNTERSIGNED BY THE AUDITOR OF THE POST OFFICE DEPARTMENT, AND EXPRESSING ON THEIR FACE THE APPROPRIATION TO WHICH THEY SHOULD BE CHARGED.

SEC. 4042. ALL PAYMENTS AND TRANSFERS TO AND FROM MONEY-ORDER OFFICES SHALL BE UNDER THE DIRECTION OF THE POSTMASTER GENERAL. HE MAY TRANSFER MONEY-ORDER FUNDS FROM ONE POSTMASTER TO ANOTHER, AND FROM THE POSTAL REVENUE TO THE MONEY-ORDER FUNDS; AND HE MAY TRANSFER MONEY-ORDER FUNDS TO CREDITORS OF THE DEPARTMENT, TO BE REPLACED BY EQUIVALENT TRANSFERS FROM THE POSTAL REVENUES.

SEC. 4043. THE POSTMASTER GENERAL MAY TRANSFER TO THE POSTMASTER AT ANY MONEY-ORDER OFFICE, BY WARRANT ON THE TREASURY, COUNTERSIGNED BY THE SIXTH AUDITOR, AND PAYABLE OUT OF THE POSTAL REVENUES, SUCH SUM AS MAY BE REQUIRED OVER AND ABOVE THE CURRENT REVENUES AT HIS OFFICE TO PAY THE MONEY ORDERS DRAWN UPON HIM.

SEC. 4045. ALL MONEY RECEIVED FOR THE SALE OF MONEY ORDERS, INCLUDING ALL FEES THEREON, ALL MONEY TRANSFERRED FROM THE POSTAL REVENUES TO THE MONEY-ORDER FUNDS, ALL MONEY TRANSFERRED OR PAID FROM THE MONEY-ORDER FUNDS TO THE SERVICE OF THE POST OFFICE DEPARTMENT, AND ALL MONEY-ORDER FUNDS TRANSFERRED FROM ONE POSTMASTER TO ANOTHER, SHALL BE DEEMED AND TAKEN TO BE MONEY-ORDER FUNDS AND MONEY IN THE TREASURY OF THE UNITED STATES. AND IT SHALL BE THE DUTY OF THE ASSISTANT TREASURER OF THE UNITED STATES TO OPEN, AT THE REQUEST OF THE POSTMASTER GENERAL, AN ACCOUNT OF ,MONEY-ORDER FUNDS" DEPOSITED BY POSTMASTER TO THE CREDIT OF THE POSTMASTER GENERAL, AND OF DRAFTS AGAINST THE AMOUNT SO DEPOSITED, DRAWN BY HIM AND COUNTERSIGNED BY THE SIXTH AUDITOR.

SEC. 4055. ALL PAYMENTS ON ACCOUNT OF THE POSTAL SERVICE SHALL BE MADE TO PERSONS TO WHOM THE SAME SHALL BE CERTIFIED TO BE DUE BY THE SIXTH AUDITOR; BUT ADVANCES OF NECESSARY SUMS TO DEFRAY EXPENSES MAY BE MADE BY THE POSTMASTER GENERAL TO AGENTS EMPLOYED TO INVESTIGATE MAIL DEPREDATIONS, EXAMINE POST ROUTES AND OFFICES, AND ON OTHER LIKE SERVICES, TO BE CHARGED TO THEM BY THE AUDITOR, AND TO BE ACCOUNTED FOR IN THE SETTLEMENT OF THEIR ACCOUNTS.

THE ACT OF MAY 29, 1920, 41 STAT. 654, ABOLISHED THE OFFICES OF ASSISTANT TREASURER AND TRANSFERRED THEIR FUNCTIONS TO THE OFFICE OF THE TREASURER OF THE UNITED STATES.

THE SEVERAL CLASSES OF CHECKS MENTIONED ARE "WARRANTS" WITHIN THE MEANING OF THE ABOVE-QUOTED STATUTES. (4 COMP. GEN. 1059, 1061.) ANNUAL REPORT OF THIS OFFICE, 1927, PAGE 46. THERE IS, HOWEVER, NO REQUIREMENT UNDER ANY OF THE CITED STATUTES OR OTHERWISE FOR THE COUNTERSIGNATURE OF THE POSTMASTER GENERAL'S DRAFTS OR CHECKS TRANSFERRING POSTAL REVENUES TO MONEY ORDER FUNDS (SEC. 4042, REV.STATS.), OR FOR THE COUNTERSIGNATURE OF BILLS OF EXCHANGE, DRAFTS, OR CHECKS RECEIVED BY THIS OFFICE AND TURNED OVER TO THE SUPERINTENDENT, DIVISION OF FINANCE, POST OFFICE DEPARTMENT, MENTIONED IN THE FOURTH AND FIFTH PARAGRAPHS OF YOUR LETTER OF SEPTEMBER 14. ACCORDINGLY, COUNTERSIGNING OF THESE TWO CLASSES OF CHECKS OR DRAFTS MAY BE DISCONTINUED.

IN SECTION 7 OF THE ACT OF JULY 31, 1894, 28 STAT. 207, IT IS PROVIDED AS FOLLOWS:

SIXTH. THE AUDITOR FOR THE POST OFFICE DEPARTMENT SHALL RECEIVE AND EXAMINE ALL ACCOUNTS OF SALARIES AND INCIDENTAL EXPENSES OF THE OFFICE OF THE POSTMASTER GENERAL AND OF ALL BUREAUS AND OFFICES UNDER HIS DIRECTION, ALL POSTAL AND MONEY-ORDER ACCOUNTS OF POSTMASTERS, ALL ACCOUNTS RELATING TO THE TRANSPORTATION OF THE MAILS, AND TO ALL OTHER BUSINESSES WITHIN THE JURISDICTION OF THE POST OFFICE DEPARTMENT, AND CERTIFY THE BALANCES ARISING THEREON TO THE POSTMASTER GENERAL FOR ACCOUNTS OF THE POSTAL REVENUE AND EXPENDITURES THEREFROM, AND TO THE DIVISION OF BOOKKEEPING AND WARRANTS FOR OTHER ACCOUNTS, AND SEND FORTHWITH COPIES OF THE CERTIFICATES IN THE LATTER CASES TO THE POSTMASTER GENERAL. THE FURTHER DUTIES OF THIS AUDITOR SHALL CONTINUE AS NOW DEFINED BY LAW, EXCEPT AS THE SAME ARE MODIFIED BY THE PROVISIONS OF THIS ACT.

IN SECTIONS 304 AND 309 OF THE BUDGET AND ACCOUNTING ACT OF JUNE 10, 1921, 42 STAT. 24, 25, IT IS PROVIDED:

SEC. 304. ALL POWERS AND DUTIES NOW CONFERRED OR IMPOSED BY LAW UPON * * * THE SIX AUDITORS OF THE TREASURY DEPARTMENT * * * SHALL, SO FAR AS NOT INCONSISTENT WITH THIS ACT, BE VESTED IN AND IMPOSED UPON THE GENERAL ACCOUNTING OFFICE AND BE EXERCISED WITHOUT DIRECTION FROM ANY OTHER OFFICER. THE BALANCE CERTIFIED BY THE COMPTROLLER GENERAL SHALL BE FINAL AND CONCLUSIVE UPON THE EXECUTIVE BRANCH OF THE GOVERNMENT. * * *

THE ADMINISTRATIVE EXAMINATION OF THE ACCOUNTS AND VOUCHERS OF THE POSTAL SERVICE NOW IMPOSED BY LAW UPON THE AUDITOR FOR THE POST OFFICE DEPARTMENT SHALL BE PERFORMED ON AND AFTER JULY 1, 1921, BY A BUREAU IN THE POST OFFICE DEPARTMENT TO BE KNOWN AS THE BUREAU OF ACCOUNTS, WHICH IS HEREBY ESTABLISHED FOR THAT PURPOSE. THE BUREAU OF ACCOUNTS SHALL BE UNDER THE DIRECTION OF A COMPTROLLER. * * * THE COMPTROLLER SHALL PERFORM THE ADMINISTRATIVE DUTIES NOW PERFORMED BY THE AUDITOR FOR THE POST OFFICE DEPARTMENT AND SUCH OTHER DUTIES IN RELATION THERETO AS THE POSTMASTER GENERAL MAY DIRECT. * * *

SEC. 309. THE COMPTROLLER GENERAL SHALL PRESCRIBE THE FORMS, SYSTEMS, AND PROCEDURE FOR ADMINISTRATIVE APPROPRIATIONS AND FUND ACCOUNTING IN THE SEVERAL DEPARTMENTS AND ESTABLISHMENTS, AND FOR THE ADMINISTRATIVE EXAMINATION OF FISCAL OFFICERS' ACCOUNTS AND CLAIMS AGAINST THE UNITED STATES.

IN AN OPINION OF THE ATTORNEY GENERAL DATED JANUARY 20, 1922, 33 OP.ATTY.GEN. 80, IT WAS HELD, QUOTING FROM THE SYLLABUS:

THE PROVISION OF TITLE III OF THE BUDGET ACT OF JUNE 10, 1921, AND SPECIALLY THE PROVISIONS OF SECTION 309 THEREOF, LIMIT THE EXTENT OF THE ADMINISTRATIVE EXAMINATION OF THE ACCOUNTS AND VOUCHERS OF THE POSTAL SERVICE WHICH THE POSTMASTER GENERAL MAY DIRECT, UNDER SECTION 304 OF SAID ACT, TO BE PERFORMED BY THE COMPTROLLER OF THE POST OFFICE DEPARTMENT.

UNDER AUTHORITY OF SECTIONS 304 AND 309 OF THE BUDGET AND ACCOUNTING ACT, SUPRA, THIS OFFICE UNDER DATE OF APRIL 12, 1922, PROMULGATED THE RULES FOR THE ADMINISTRATIVE EXAMINATION OF POSTAL ACCOUNTS BY THE BUREAU OF ACCOUNTS, POST OFFICE DEPARTMENT, WHEREIN THE FUNCTIONS OF THE BUREAU WERE SUMMARIZED, AS FOLLOWS:

THE ADMINISTRATIVE EXAMINATION OF ACCOUNTS BY THE POST OFFICE DEPARTMENT, BUREAU OF ACCOUNTS, IS INTENDED TO COMPREHEND THE RECEIPT OF THE ACCOUNTS AND THEIR EXAMINATION AS TO FORM AND PROPER RENDITION,AND SHALL IN NO WISE AUTHORIZE EXAMINATION CUSTOMARILY FORMING THE BASIS OF STATING SETTLEMENTS OF THE ACCOUNTS.

UNDER THE QUOTED STATUTES IT IS CLEAR THAT THE COUNTERSIGNING OF THE CLASSES OF CHECKS MENTIONED IN YOUR LETTERS REQUIRING A COUNTERSIGNATURE IS NOT PROPERLY A FUNCTION OF THE ADMINISTRATIVE EXAMINATION OF ACCOUNTS FOR PERFORMANCE BY THE COMPTROLLER, BUREAU OF ACCOUNTS, POST OFFICE DEPARTMENT, BUT INVOLVES AN AUDIT ACTION FOR THIS OFFICE.

ACCORDINGLY, AS TO THE CLASSES OF CHECKS OR "WARRANTS" REQUIRING A COUNTERSIGNATURE, BOTH OF YOUR QUESTIONS IN LETTER OF SEPTEMBER 14, ARE ANSWERED IN THE NEGATIVE, AND YOU ARE ADVISED THAT WITH THE EXCEPTION OF THE TWO CLASSES MENTIONED IN THE FOURTH AND FIFTH PARAGRAPHS OF YOUR LETTER OF SEPTEMBER 14, WHICH ARE NOT REQUIRED TO BE COUNTERSIGNED, ALL CHECKS OR WARRANTS OF THE CLASSES MENTIONED TO BE ISSUED AFTER THE EXAMINATION AND, IF PROPER, FOR COUNTERSIGNATURE. THE NECESSARY CHANGES IN THE WORDING OF THE CHECKS OR WARRANTS AND FORMS MAY BE TYPED OR STAMPED ON THE EXISTING SUPPLY OF BLANK CHECKS AND FORMS, AND FURTHER CONSIDERATION WILL BE GIVEN TO THE NECESSARY CHANGES TO BE MADE IN SUCH FORMS.