A-9914, DECEMBER 14, 1925, 5 COMP. GEN. 428

A-9914: Dec 14, 1925

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1925: I HAVE YOUR LETTER OF SEPTEMBER 5. WAS PROMPTLY REPORTED TO THE CHIEF OF FINANCE. SINCE A TIME SHORTLY AFTER IT WAS OPENED. HAVE NOT RELATED TO ANY AUTHORITY TO CARRY AND USE SUCH AN ACCOUNT FOR SUCH A PURPOSE. HAVE RELATED MERELY TO THE HANDLING OF THE ACCOUNT. OR ANY LAW REQUIRING THAT SUCH TRANSACTIONS SHALL BE COVERED BY FORMAL ACCOUNTS SUBJECT TO THE ORDINARY AUDIT OF THE GENERAL ACCOUNTING OFFICE IT WILL PROBABLY BE NECESSARY TO DISCONTINUE THE RENDERING OF THIS SERVICE. BECAUSE TO DO SO UNDER SUCH RESTRICTIONS WILL IMPOSE ADDITIONAL ADMINISTRATIVE LABOR WHICH CAN NOT BE PERFORMED WITHOUT ADDITIONAL EXPENSE TO THE UNITED STATES FOR WHICH THERE IS NO ADEQUATE APPROPRIATION AVAILABLE.

A-9914, DECEMBER 14, 1925, 5 COMP. GEN. 428

ACCOUNTING - SPECIAL DEPOSIT ACCOUNTS GOOD ACCOUNTING REQUIRES THAT ALL MONEYS RECEIVED BY GOVERNMENT OFFICERS AS SUCH MUST BE ACCOUNTED FOR IN ACCOUNTS SUBMITTED FOR AUDIT TO THE GENERAL ACCOUNTING OFFICE, WHETHER THE FUNDS INVOLVED BE STRICTLY PUBLIC MONEYS OR MONEYS OF A PRIVATE CHARACTER OBTAINED AND HELD FOR SOME PARTICULAR PURPOSE SANCTIONED BY LAW. FUNDS CONTRIBUTED BY PRIVATE INDIVIDUALS FOR THE PURPOSE OF DECORATING THE GRAVES OF AMERICAN SOLDIERS BURIED IN FRANCE AND HELD IN A SPECIAL DEPOSIT ACCOUNT BY A FINANCE OFFICER OF THE ARMY FOR SUCH PURPOSE MUST BE ACCOUNTED FOR TO THE GENERAL ACCOUNTING OFFICE, AND THE ACCOUNTS SUBMITTED SHOULD BE SUPPORTED BY SCHEDULES SHOWING THE AMOUNT AND SOURCE OF EACH CONTRIBUTION AND TO WHOM AND FOR WHAT PURPOSE EXPENDED.

COMPTROLLER GENERAL MCCARL TO THE SECRETARY OF WAR, DECEMBER 14, 1925:

I HAVE YOUR LETTER OF SEPTEMBER 5, 1925, RELATIVE TO THE ACCOUNT CARRIED BY CAPT. E. J. HELLER, FINANCE OFFICER, UNITED STATES ARMY, WITH THE PARIS BRANCH OF THE BANKERS TRUST CO. OF NEW YORK FOR THE CUSTODY AND DISBURSEMENT OF MONEYS CONTRIBUTED BY PRIVATE INDIVIDUALS FOR THE PURPOSE OF DECORATING GRAVES OF AMERICAN SOLDIERS BURIED IN FRANCE, WHEREIN YOU FURNISH CERTAIN INFORMATION REQUESTED IN MY LETTER TO YOU DATED JULY 16, 1925, WITH RESPECT THERETO. YOUR LETTER STATES:

THE OPENING OF THIS ACCOUNT BY CAPTAIN HELLER, WHICH ALTHOUGH HIS OWN ACTION IN THE FIRST INSTANCE, WAS PROMPTLY REPORTED TO THE CHIEF OF FINANCE, MET WITH HIS APPROVAL AND MINE, AND THE ACCOUNT HAS BEEN THE SUBJECT OF CORRESPONDENCE BETWEEN THIS DEPARTMENT AND THE SECRETARY OF THE TREASURY, AS WELL AS OF INFORMAL COMMUNICATIONS BETWEEN THE OFFICE OF THE CHIEF OF FINANCE AND YOUR OFFICE, SINCE A TIME SHORTLY AFTER IT WAS OPENED. SUCH CORRESPONDENCE AND COMMUNICATIONS, HOWEVER, HAVE NOT RELATED TO ANY AUTHORITY TO CARRY AND USE SUCH AN ACCOUNT FOR SUCH A PURPOSE, BUT HAVE RELATED MERELY TO THE HANDLING OF THE ACCOUNT, THE PROPRIETY OF WHICH HAS NOT HERETOFORE BEEN QUESTIONED.

WHILE I AM NOT AWARE OF THE EXISTENCE, OR THE NEED, OF ANY EXPRESS AUTHORITY OF LAW FOR THE OPENING AND USE OF SUCH AN ACCOUNT FOR SUCH PURPOSE, I AM NOT AWARE OF THE EXISTENCE OF ANY LAW FORBIDDING IT. IF THERE BE ANY SUCH LAW, OR ANY LAW REQUIRING THAT SUCH TRANSACTIONS SHALL BE COVERED BY FORMAL ACCOUNTS SUBJECT TO THE ORDINARY AUDIT OF THE GENERAL ACCOUNTING OFFICE IT WILL PROBABLY BE NECESSARY TO DISCONTINUE THE RENDERING OF THIS SERVICE, BECAUSE TO DO SO UNDER SUCH RESTRICTIONS WILL IMPOSE ADDITIONAL ADMINISTRATIVE LABOR WHICH CAN NOT BE PERFORMED WITHOUT ADDITIONAL EXPENSE TO THE UNITED STATES FOR WHICH THERE IS NO ADEQUATE APPROPRIATION AVAILABLE.

IT IS PROPER TO STATE IN THIS CONNECTION THAT THE UNITED STATES DOES NOT ASSUME OR INCUR ANY LIABILITY IN CONNECTION WITH THE DECORATING OF THESE GRAVES IN THIS MANNER. THE WAR DEPARTMENT, THROUGH THE OFFICERS OF THE GRAVES REGISTRATION SERVICE IN FRANCE, SIMPLY UNDERTAKES TO APPLY THE FUNDS THUS PRIVATELY CONTRIBUTED TO THE PURPOSES DESIGNATED BY THE CONTRIBUTORS. THE FUNDS IN QUESTION HAVE COME INTO THE CUSTODY OF CAPTAIN HELLER AS ADJUTANT OF THE GRAVES REGISTRATION SERVICE IN THE FOLLOWING MANNER:

A. FROM RELATIVES IN THE UNITED STATES BY CHECKS AND CURRENCY, IN DOLLARS, APPROXIMATELY 10 PERCENT.

B. FROM RELATIVES IN THE UNITED STATES BY INTERNATIONAL MONEY ORDERSAND BANK DRAFTS, IN FRANCS, APPROXIMATELY 25 PERCENT.

C. FROM RELATIVES, ETC., WHILE VISITING THE VARIOUS CEMETERIES AND THE HEADQUARTERS, A.G.R.S., QUARTERMASTER CORPS IN EUROPE, PARIS, IN FRENCH CURRENCY AND CHECKS FOR FRANCS, APPROXIMATELY 65 PERCENT.

THE FUNDS IN DOLLARS ARE CONVERTED INTO FRANCS IMMEDIATELY UPON THEIR RECEIPT AT THE RATE OF EXCHANGE PREVAILING AT THE TIME OF CONVERSION. ALL PURCHASES MADE FROM THESE FUNDS MUST NECESSARILY BE PAID IN FRANCS AND THE FORM IN WHICH THE REMITTANCES ARE RECEIVED MAKES THE ACCOUNTING THEREFOR IN DOLLARS IMPRACTICABLE. AS THESE REMITTANCES ARE RECEIVED ALMOST DAILY, IT CAN READILY BE SEEN THAT THE RATES OF EXCHANGE WOULD BE NUMEROUS DEPENDENT UPON THE RISE AND FALL OF THE FRENCH FRANC. THE NECESSARY ROUTINE OF ADMINISTRATION IS THEREFORE VASTLY SIMPLER BY ACCOUNTING IN FRANCS THAN IT WOULD BE IF IT WERE NECESSARY TO CARRY THE FUNDS IN AN OFFICIAL ACCOUNT IN DOLLARS. THE AMOUNT IN THE ACCOUNT AT ANY ONE TIME IS COMPARATIVELY SMALL, VARYING ACCORDING TO TIME OF YEAR AND AVERAGING APPROXIMATELY $500 IN VALUE, AND THE ADMINISTRATION OF IT IS COVERED BY INFORMAL ACCOUNTS RENDERED TO THE CHIEF OF FINANCE.

THERE APPEARS TO BE NO REASON FROM THE FOREGOING QUOTATION WHY AN ACCOUNTING SHOULD NOT BE RENDERED COVERING ALL TRANSACTIONS INVOLVING THE RECEIPT AND DISBURSEMENT OF MONEYS THUS RECEIVED AND HANDLED BY THIS OFFICER. THE INTERESTS OF THE GOVERNMENT REQUIRE THAT ALL MONEYS RECEIVED BY GOVERNMENT OFFICERS AS SUCH BE ACCOUNTED FOR TO THE GENERAL ACCOUNTING OFFICE IRRESPECTIVE OF WHETHER THEY BE STRICTLY PUBLIC MONEYS OR MONEYS OF A PRIVATE CHARACTER OBTAINED AND HELD FOR SOME PARTICULAR PURPOSE SANCTIONED BY LAW. 19 COMP. DEC. 442; 21 ID. 374.

THE FUNDS HERE IN QUESTION ARE ENTRUSTED TO CAPTAIN HELLER, NOT AS AN INDIVIDUAL, BUT AS AN OFFICER OF THE GOVERNMENT, AND THE GOVERNMENT WOULD BE HELD AT LEAST MORALLY RESPONSIBLE FOR ANY IRREGULARITIES IN THE HANDLING OF SUCH FUNDS. IT FOLLOWS, THEREFORE, THAT IN THE INTERESTS OF THE GOVERNMENT, A PROPER ACCOUNTING OF SUCH MONEYS SHOULD BE MADE TO THIS OFFICE TO BECOME A PART OF THE PERMANENT RECORDS OF THE GOVERNMENT.

CONSIDERING THE CIRCUMSTANCES UNDER WHICH THESE FUNDS ARE RECEIVED, HELD, AND DISBURSED, HOWEVER, AND THE FACT THAT NO PART THEREOF BELONGS TO THE GOVERNMENT, THERE APPEARS TO BE NO LEGAL OBJECTION TO PERMITTING THE ACCOUNT TO BE KEPT AND RENDERED IN TERMS OF FRANCS AS A SPECIAL DEPOSIT ACCOUNT IN THE BANK IN PARIS. AN ACCOUNT THUS RENDERED SHOULD NOT IMPOSE ADDITIONAL LABOR INVOLVING ADDITIONAL EXPENSE TO THE UNITED STATES AS APPEARS TO BE FEARED FROM THE TENOR OF YOUR LETTER.

IT IS ACCORDINGLY REQUESTED THAT THE OFFICER BE INSTRUCTED TO SUBMIT TO THIS OFFICE FOR PROPER AUDIT ACCOUNTS SUPPORTED BY ITEMIZED SCHEDULES SHOWING AMOUNT AND SOURCE OF EACH CONTRIBUTION AND TO WHOM AND FOR WHAT OBJECT THE FUNDS WERE EXPENDED WITH RESPECT TO ALL MONEYS IN HIS POSSESSION UNDER THIS SPECIAL DEPOSIT ACCOUNT, ONE ACCOUNT TO COVER FROM THE DATE THE SAME WAS ESTABLISHED UNTIL DECEMBER 31, 1925, AND MONTHLY ACCOUNTS THEREAFTER UNTIL CLOSED.