B-40060, MARCH 15, 1944, 23 COMP. GEN. 668

B-40060: Mar 15, 1944

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THERE IS NO AUTHORITY TO EFFECT SUCH ADVANCES BY TRANSFER AND COUNTER WARRANT INSTEAD OF BY MEANS OF A CHECK. AS FOLLOWS: REFERENCE IS MADE TO PUBLIC LAW 653. WHICH IS NOT PROPERLY CHARGEABLE TO AVAILABLE FUNDS UNDER THE (A) NAVAL APPROPRIATION. A FEW ADVANCE PAYMENTS TO THE NAVAL PROCUREMENT FUND HAVE BEEN MADE FROM BOTH ANNUAL AND CONTINUING APPROPRIATIONS. HAVE BEEN MADE TO COVER MATERIALS AND SERVICES FOR A SINGLE PROJECT. THE NEED FOR EXPANDING THE OPERATIONS UNDER THE NAVAL PROCUREMENT FUND IS BECOMING MORE AND MORE URGENT. WORK UNDER THESE CONTRACTS IS PERFORMED IN PRIVATE YARDS ON THE AUTHORITY OF JOB ORDERS ISSUED FOR SPECIFIC ITEMS OF WORK. THIS IS SO BECAUSE OF THE FACT THAT THE APPROPRIATION CHARGEABLE IS DETERMINED NOT ONLY FROM THE TYPE AND CATEGORY OF THE VESSEL CONCERNED.

B-40060, MARCH 15, 1944, 23 COMP. GEN. 668

NAVAL PROCUREMENT FUND - ADVANCES FROM NAVAL APPROPRIATIONS THE PROVISIONS IN THE ACT OF JULY 3, 1942, AUTHORIZING THE ESTABLISHMENT OF THE NAVAL PROCUREMENT FUND AND THE MAKING OF ADVANCE CHECK PAYMENTS THERETO FROM NAVAL APPROPRIATIONS, MAY NOT BE CONSIDERED AS HAVING THE EFFECT OF REMOVING THE RESTRICTION OF THE LIMITED PERIOD OF AVAILABILITY OF NAVAL APPROPRIATIONS PLACED THEREON BY THE CONGRESS AT THE TIME OF APPROPRIATION AND MAKING SUCH APPROPRIATIONS AVAILABLE UNTIL EXPENDED UPON BEING ADVANCED TO THE NAVAL PROCUREMENT FUND--- A REVOLVING FUND NOT SUBJECT TO FISCAL YEAR LIMITATIONS. IN VIEW OF THE SPECIFIC PROVISION IN THE ACT OF JULY 3, 1942, THAT ADVANCES OF FUNDS FROM NAVAL APPROPRIATIONS TO THE NAVAL PROCUREMENT FUND SHALL BE ACCOMPLISHED BY ADVANCE CHECK PAYMENTS MADE TO THE FUND, THERE IS NO AUTHORITY TO EFFECT SUCH ADVANCES BY TRANSFER AND COUNTER WARRANT INSTEAD OF BY MEANS OF A CHECK.

COMPTROLLER GENERAL WARREN TO THE SECRETARY OF THE NAVY, MARCH 15, 1944:

THERE HAS BEEN CONSIDERED YOUR LETTER OF FEBRUARY 9, 1944, AS FOLLOWS:

REFERENCE IS MADE TO PUBLIC LAW 653, 77TH CONGRESS, APPROVED 3 JULY 1942, ESTABLISHING A NAVAL PROCUREMENT FUND UNDER THE BUREAU OF SUPPLIES AND ACCOUNTS WHICH PROVIDES, INTER ALIA, THAT:

" * * * EXPENDITURES MAY BE MADE FROM THE NAVAL PROCUREMENT FUND FOR MATERIAL (OTHER THAN MATERIAL FOR STOCK) AND FOR PERSONAL AND CONTRACTUAL SERVICES UNDER SUCH REGULATIONS AS THE SECRETARY OF THE NAVY MAY PRESCRIBE: PROVIDED FURTHER, THAT NO EXPENDITURE SHALL BE INCURRED UNDER THE NAVAL PROCUREMENT FUND, WHICH IS NOT PROPERLY CHARGEABLE TO AVAILABLE FUNDS UNDER THE (A) NAVAL APPROPRIATION, AND THE NAVAL PROCUREMENT FUND SHALL BE PROMPTLY REIMBURSED FROM THE APPROPRIATE NAVAL APPROPRIATIONS FOR ALL EXPENDITURES PROPERLY CHARGEABLE THERETO ON THE BASIS OF TRANSFER AND COUNTERWARRANTS PREPARED IN THE NAVY DEPARTMENT AND CERTIFIED TO THE SECRETARY OF THE TREASURY BY A DULY AUTHORIZED REPRESENTATIVE OF THE NAVY.'

THE GENERAL ACCOUNTING OFFICE, IN ACCOUNTS AND PROCEDURES LETTER NO. 4864, DATED 10 JULY 1942 DESIGNATED THE APPROPRIATION ACCOUNT "17X0800 NAVAL PROCUREMENT FUND" WITH A NO YEAR SYMBOL AND PRESCRIBES " LIMITATIONS: NO SUBDIVISION.' THIS ACTION CONFORMS TO THE BUREAU OF SUPPLIES AND ACCOUNTS' UNDERSTANDING AS TO THE PURPOSE AND INTENT OF THE LAW.

THE FOURTH PROVISO IN PUBLIC LAW 653, SUPRA, PROVIDES:

"THAT ADVANCE CHECK PAYMENTS MAY BE MADE TO THE NAVAL PROCUREMENT FUND UPON WRITTEN REQUEST TO THE PAYMASTER GENERAL OF THE NAVY FROM THE APPROPRIATE NAVAL APPROPRIATION FOR ALL OR ANY PART OF THE COSTS ULTIMATELY CHARGEABLE TO SUCH NAVAL APPROPRIATION, SUBJECT TO APPROPRIATE ADJUSTMENTS BEING MADE ON THE BASIS OF THE COMPLETED ACTUAL COST OF THE SUPPLIES, MATERIALS, EQUIPMENT AND SERVICES INVOLVED.'

PURSUANT TO THE AUTHORITY OF PUBLIC LAW 653, A FEW ADVANCE PAYMENTS TO THE NAVAL PROCUREMENT FUND HAVE BEEN MADE FROM BOTH ANNUAL AND CONTINUING APPROPRIATIONS. THESE PAYMENTS, IN GENERAL, HAVE BEEN MADE TO COVER MATERIALS AND SERVICES FOR A SINGLE PROJECT, PROPERLY CHARGEABLE TO TWO OR MORE EQUALLY AVAILABLE APPROPRIATIONS. THIS HAS BEEN DONE FOR THE PURPOSE OF ELIMINATING THE DETAILED ACCOUNTING WHICH WOULD BE REQUIRED IN THE ALLOCATION AND PRORATION OF A SINGLE PAYMENT ON A PUBLIC VOUCHER TO THE TWO, THREE OR MORE APPROPRIATIONS BEING USED TO FINANCE A SINGLE PROJECT.

WHILE AS STATED ABOVE, ONLY LIMITED USE HAS BEEN MADE TO DATE OF THE AUTHORITY CONTAINED IN PUBLIC LAW 653, THE NEED FOR EXPANDING THE OPERATIONS UNDER THE NAVAL PROCUREMENT FUND IS BECOMING MORE AND MORE URGENT. AS AN EXAMPLE, THE NAVY HAS EXECUTED A LARGE NUMBER OF CONTRACTS COVERING THE REPAIR, ALTERATION AND CONVERSION OF MANY TYPES AND CATEGORIES OF NAVAL VESSELS. WORK UNDER THESE CONTRACTS IS PERFORMED IN PRIVATE YARDS ON THE AUTHORITY OF JOB ORDERS ISSUED FOR SPECIFIC ITEMS OF WORK. THE APPROPRIATION OR APPROPRIATIONS CHARGEABLE WITH SUCH WORK CANNOT ALWAYS BE DETERMINED BY THE NAVAL PERSONNEL ON DUTY AT THE PRIVATE YARD. THIS IS SO BECAUSE OF THE FACT THAT THE APPROPRIATION CHARGEABLE IS DETERMINED NOT ONLY FROM THE TYPE AND CATEGORY OF THE VESSEL CONCERNED, BUT OFTEN ON THE DEGREE OF COMPLETION OF WORK PERFORMED IN THE BUILDING YARD OR AT ANOTHER YARD; AND WHETHER THE BUREAU OF SHIPS DETERMINES ADMINISTRATIVELY THAT DEFENSE AID FUNDS ARE TO BE CHARGED. IN ADDITION, FOR MILITARY REASONS THE NAVY CONTROLS AND REQUIRES, AT CERTAIN YARDS, THAT WORK ON ARMY VESSELS BE DONE UNDER THE NAVY CONTRACT. AS A RESULT OF THIS SITUATION, CONFUSION IS CAUSED WHEN PAYMENT FOR WORK DONE UNDER A REPAIR, ALTERATION AND CONVERSION FORM OF CONTRACT IS MADE FROM A SINGLE BUREAU OF SHIPS' APPROPRIATION STATED ON THE CONTRACT, AND ADJUSTMENTS BETWEEN THE PROPER APPROPRIATIONS ARE SUBSEQUENTLY NECESSARY. ELIMINATE THE MULTIPLICITY OF APPROPRIATION ACCOUNTS CHARGEABLE WITH A SINGLE PAYMENT, A DEMAND IS GROWING IN THE NAVY DEPARTMENT FOR BROADER USE OF THE NAVAL PROCUREMENT FUND FOR FINANCING PAYMENTS UNDER THE TYPE OF CONTRACTS REFERRED TO HERETOFORE.

NO APPROPRIATION HAS BEEN MADE TO THE NAVAL PROCUREMENT FUND TO DATE; AND, THEREFORE, IN ORDER TO FINANCE ANY EXPENDITURES FROM THE NAVAL PROCUREMENT FUND ON THE CONTRACTS IN QUESTION ADVANCE PAYMENTS FROM THE SEVERAL APPROPRIATIONS INVOLVED WILL BE REQUIRED, SUBJECT TO PROPER ADJUSTMENTS BETWEEN APPROPRIATIONS, AS LATER DETERMINED FROM ADMINISTRATIVE EXAMINATION OF THE PAYMENT VOUCHERS AND OTHER PERTINENT DATA AVAILABLE IN THE COGNIZANT BUREAUS AND OFFICE OF THE NAVY DEPARTMENT.

IN ADDITION, THE RECENT ENACTMENT INTO LAW OF A LIMITATION ON THE VALUE OF STOCK, AND OBLIGATIONS WHICH MAY BE INCURRED, UNDER THE NAVAL STOCK FUND, HAS CAUSED CONSIDERABLE STUDY TO BE MADE OF WAYS AND MEANS FOR ELIMINATING MANY TYPES OF PAYMENTS WHICH HAVE BEEN FINANCED REGULARLY FROM THAT FUND. IN FACT, IT WAS EXPECTED THAT THE NAVAL PROCUREMENT FUND, IMPLEMENTED BY AN ADEQUATE APPROPRIATION OF WORKING CAPITAL, WOULD RELIEVE THE NAVAL STOCK FUND OF A LARGE VOLUME OF DAY TO DAY PROCUREMENT. THE ABSENCE OF AN APPROPRIATION OF ADEQUATE WORKING CAPITAL TO THE NAVAL PROCUREMENT FUND HAS NECESSARILY RESTRICTED THE USE OF THIS FUND TO ADVANCE PAYMENTS MADE THERETO FROM OTHER NAVAL APPROPRIATIONS.

THE PARTICULAR POINT, OF IMMEDIATE INTEREST TO THE NAVY DEPARTMENT IN THE CONTEMPLATED EXPANSION OF THE USE OF THE NAVAL PROCUREMENT FUND, IS THAT CONCERNING THE ADVANCE PAYMENTS TO THE NAVAL PROCUREMENT FUND WHICH WILL BE MADE FROM BOTH ANNUAL AND CONTINUING APPROPRIATIONS. WHEN THESE PAYMENTS ARE MADE, THE NAVAL PROCUREMENT FUND WILL CONSTITUTE A LUMP SUM, AVAILABLE FOR THE PURPOSES FOR WHICH THE FUNDS ARE ADVANCED. THE IDENTITY OF THE SEVERAL AVAILABLE APPROPRIATIONS, FROM WHICH THE ADVANCES ARE MADE, WILL NOT BE PRESERVED. IN FACT, ANY EFFORT TO DO SO WOULD DEFEAT THE OBJECTIVE OF THE NAVAL PROCUREMENT FUND LAW. ACCORDINGLY, A QUESTION ARISES WHICH REQUIRES AN AUTHORITATIVE DETERMINATION AS TO THE CONTINUED AVAILABILITY OF ADVANCE PAYMENTS INTO THE NAVAL PROCUREMENT FUND, ESPECIALLY WHERE AN ADVANCE FROM AN ANNUAL APPROPRIATION IS INVOLVED. THE BUREAU OF SUPPLIES AND ACCOUNTS, WHICH HAS COGNIZANCE OVER THE NAVAL PROCUREMENT FUND, IS OF THE OPINION THAT FUNDS TRANSFERRED INTO THE NAVAL PROCUREMENT FUND ARE AVAILABLE UNTIL EXPENDED, AND THIS OPINION IS PRECISELY IN POINT WITH THE ACTION OF THE GENERAL ACCOUNTING OFFICE IN THE ACCOUNTS AND PROCEDURES LETTER NO. 4864, SUPRA.

IT IS EXPECTED FEW, IF ANY, ADVANCE PAYMENTS WILL BE MADE INTO THE NAVAL PROCUREMENT FUND, WHICH ARE NOT, IN TURN, CHARGEABLE TO A PROJECT ORDER ISSUED UNDER THE AUTHORITY OF THE ACT OF 1 JULY 1922 (42 STAT. 812; U.S.C. TITLE 41, SEC. 23), WHICH PROVIDES THAT:

"ALL ORDERS OR CONTRACTS FOR WORK OR MATERIAL, UNDER AUTHORIZATION OF LAW, HERETOFORE OR HEREAFTER PLACED WITH GOVERNMENT-OWNED ESTABLISHMENTS, SHALL BE CONSIDERED AS OBLIGATIONS IN THE SAME MANNER AS PROVIDED FOR SIMILAR ORDERS OR CONTRACTS, PLACED WITH PRIVATE CONTRACTORS, AND APPROPRIATIONS FOR SUCH WORK OR MATERIAL SHALL REMAIN AVAILABLE FOR PAYMENT THEREFOR AS IN THE CASE OF ORDERS OR CONTRACTS PLACED WITH PRIVATE CONTRACTORS.'

IN EVERY CASE, WHERE FUNDS ARE TRANSFERRED INTO THE NAVAL PROCUREMENT FUND FOR THE PROCUREMENT OF MATERIAL AND SERVICES ULTIMATELY CHARGEABLE TO A PROJECT ORDER ISSUED PURSUANT TO THE ACT OF 1 JULY 1922, IT IS UNDERSTOOD THE FUNDS WILL REMAIN AVAILABLE FOR EXPENDITURE THROUGHOUT THE LIFE OF THE PROJECT ORDER, I.E., TWO YEARS FOLLOWING THE YEAR FOR WHICH AN ANNUAL APPROPRIATION IS MADE, AND INDEFINITE PERIOD WHERE A CONTINUING APPROPRIATION IS INVOLVED. FOR THESE REASONS, THERE SEEMS TO BE NO ADMINISTRATIVE NEED NOR LEGAL REQUIREMENT FOR CREATING A DETAILED AND SEPARATE ACCOUNTABILITY FOR EACH ADVANCE PAYMENT MADE TO THE NAVAL PROCUREMENT FUND FROM ANY ONE OF THE SEVERAL NAVAL APPROPRIATIONS.

THE NAVY DEPARTMENT WOULD APPRECIATE INFORMATION AND CONFIRMATION OF THE INTERPRETATION OF THE NAVAL PROCUREMENT FUND LAW, AS SUPPORTED BY THE GENERAL ACCOUNTING OFFICE, ACCOUNTS AND PROCEDURES LETTER NO. 4864, I.E., THAT ADVANCE PAYMENTS MADE TO THE NAVAL PROCUREMENT FUND MAY BE OBLIGATED UNDER THAT FUND WITHOUT LIMITATION, PROVIDED OF COURSE, THAT ADJUSTMENT IS MADE BY THE PROPER APPROPRIATIONS ON THE BASIS OF COMPLETED ACTUAL COST OF THE SUPPLIES, MATERIALS, EQUIPMENT AND SERVICES INVOLVED.

FROM AN EXAMINATION OF THE LEGISLATIVE HISTORY OF S. 1957--- WHICH SUBSEQUENTLY BECAME THE ACT OF JULY 3, 1942, 56 STAT. 645--- THERE IS NO DOUBT BUT THAT IT WAS THE INTENT OF THE CONGRESS TO ESTABLISH THE NAVAL PROCUREMENT FUND (HEREINAFTER REFERRED TO AS THE FUND) AS A REVOLVING FUND NOT SUBJECT TO FISCAL YEAR LIMITATIONS; ALSO, THAT IT WAS INTENDED THAT THE FUND WAS TO BE COMPOSED OF FUNDS APPROPRIATED FROM TIME TO TIME IN ACCORDANCE WITH THE AUTHORITY CONTAINED THEREIN. EXPENDITURES ARE AUTHORIZED TO BE MADE FROM THE FUND FOR MATERIAL (OTHER THAN MATERIAL FOR STOCK) AND FOR PERSONAL AND CONTRACTUAL SERVICES UNDER REGULATIONS PRESCRIBED BY THE SECRETARY OF THE AVY; AND REIMBURSEMENT THEREFOR IS DIRECTED TO BE MADE FROM THE APPROPRIATE NAVAL APPROPRIATIONS BY MEANS OF TRANSFER AND COUNTER WARRANTS.

IN ORDER TO PROVIDE AN ACCOUNT IN WHICH TO RECORD TRANSACTIONS AUTHORIZED UNDER THE FUND, THERE WAS PRESCRIBED BY ACCOUNTS AND PROCEDURES LETTER NO. 4864, DATED JULY 10, 1942, THE ACCOUNT ,17X0800 NAVAL PROCUREMENT FUND," BEARING A "NO YEAR" SYMBOL AND WITH NO LIMITATIONS.

WHILE THE ACT ESTABLISHING THE FUND AUTHORIZES AN APPROPRIATION FROM TIME TO TIME OF SUCH FUNDS AS MAY BE NECESSARY TO ACCOMPLISH THE PURPOSES OF THE FUND, NO APPROPRIATIONS THEREFOR HAVE BEEN MADE TO DATE. HOWEVER, YOU STATE THAT USE OF THE FUND HAS BEEN AVAILED OF BY MAKING "A FEW ADVANCE PAYMENTS" TO THE FUND FROM BOTH ANNUAL AND CONTINUING APPROPRIATIONS UNDER THE AUTHORITY OF THE PROVISO:

THAT ADVANCE CHECK PAYMENTS MAY BE MADE TO THE NAVAL PROCUREMENT FUND UPON WRITTEN REQUEST TO THE PAYMASTER GENERAL OF THE NAVY FROM THE APPROPRIATE NAVAL APPROPRIATION FOR ALL OR ANY PART OF THE COSTS ULTIMATELY CHARGEABLE TO SUCH NAVAL APPROPRIATION, SUBJECT TO APPROPRIATE ADJUSTMENTS BEING MADE ON THE BASIS OF THE COMPLETED ACTUAL COST OF THE SUPPLIES, MATERIALS, EQUIPMENT, AND SERVICES INVOLVED. AND IT IS STATED FURTHER THAT IN VIEW OF THE NEED FOR EXPANDING OPERATIONS UNDER THE FUND AND SINCE NO FUNDS HAVE BEEN APPROPRIATED TO DATE, THE PURPOSES OF THE FUND ARE PROPOSED TO BE ACCOMPLISHED THROUGH THE INCREASED USE OF ADVANCE PAYMENTS.

THE BOOKS OF THIS OFFICE DO NOT REFLECT THE "ADVANCE PAYMENTS" REFERRED TO IN THE FOURTH PARAGRAPH OF YOUR LETTER, SUPRA, BUT THE RECORDS DO DISCLOSE THAT A NUMBER OF CREDITS TO THE FUND WERE ACCOMPLISHED BY MEANS OF TRANSFER AND COUNTER WARRANTS. THE REFERRED TO ADVANCES MAY BE PART OR ALL OF ONE OR MORE OF THE AMOUNTS COVERED BY THE TRANSFER AND COUNTER WARRANTS. IF THAT BE THE CASE, IT SHOULD BE POINTED OUT HERE THAT THE PROVISO AUTHORIZING ADVANCES FROM APPROPRIATE NAVAL APPROPRIATIONS PROVIDES THAT SUCH ADVANCES SHALL BE ACCOMPLISHED BY ADVANCE CHECK PAYMENTS MADE TO THE FUND.

THERE HAS BEEN NOTED THE OPINION OF THE BUREAU OF SUPPLIES AND ACCOUNTS-- - WHICH BUREAU HAS ADMINISTRATIVE CONTROL OVER THE FUND--- THAT ADVANCE PAYMENTS MADE TO THE FUND, WHETHER FROM ANNUAL OR CONTINUING APPROPRIATIONS, ARE AVAILABLE UNTIL EXPENDED. THERE IS NOTHING IN THE REFERRED-TO PROVISO (EITHER EXPRESSED OR IMPLIED) WHICH MAY BE CONSIDERED AS HAVING THE EFFECT OF REMOVING THE RESTRICTION OF THE LIMITED PERIOD OF AVAILABILITY OF NAVAL APPROPRIATIONS PLACED THEREON BY THE CONGRESS AT THE TIME OF APPROPRIATION AND MAKING THEM AVAILABLE UNTIL EXPENDED UPON BEING ADVANCED TO THE FUND. THE MERE FACT THAT ADVANCEMENTS FROM THE VARIOUS NAVAL APPROPRIATIONS TO THE FUND ARE AUTHORIZED TO BE MADE DOES NOT OPERATE IPSO FACTO TO EFFECT SUCH A RESULT. IF SUCH WERE THE CASE, THE ACTION OF THE CONGRESS IN MAKING ANNUAL APPROPRIATIONS FOR A PARTICULAR FISCAL YEAR COULD BE NULLIFIED COMPLETELY BY THE DRAWING OF A CHECK IN THE AMOUNT OF THE ENTIRE ANNUAL APPROPRIATION AND MAKING PAYMENT TO THE FUND, NOT SUBJECT TO FISCAL YEAR LIMITATION. THAT SUCH A RESULT WAS CONTEMPLATED BY THE CONGRESS CANNOT SERIOUSLY BE CONTENDED.

AS INDICATED ABOVE, IT IS OBVIOUS THAT THE ACT UNDER CONSIDERATION HAD FOR ITS MAIN OBJECTIVE THE ESTABLISHMENT OF A REVOLVING FUND BY APPROPRIATIONS AS AND WHEN THE NEED THEREFOR AROSE, THROUGH WHICH FUND THE BULK OF TRANSACTIONS--- FORMERLY CLEARED THROUGH THE NAVAL SUPPLY ACCOUNT FUND--- WOULD BE HANDLED. THAT IS TO SAY, THERE WAS CONTEMPLATED A CONVENIENT FUND FROM WHICH EXPENDITURES, PROPERLY CHARGEABLE TO AVAILABLE FUNDS UNDER NAVAL APPROPRIATIONS, COULD BE MADE FROM FUNDS APPROPRIATED TO THE FUND AND REIMBURSEMENT THEREFOR SUBSEQUENTLY EFFECTED FROM THE APPLICABLE NAVAL APPROPRIATIONS. HOWEVER, AT THE PRESENT TIME THE FUND HAS BEEN ESTABLISHED IN NAME ONLY -- NO APPROPRIATIONS THERETO AS CONTEMPLATED AND AUTHORIZED HAVING BEEN MADE TO DATE. THE PROVISO UNDER CONSIDERATION WAS INSERTED AS AN AMENDMENT TO PERMIT PAYMENTS FOR SUPPLIES, MATERIAL, ETC., TO BE MADE IN ADVANCE, INSTEAD OF BY WAY OF REIMBURSEMENT, IN CASES WHERE WRITTEN REQUEST THEREFOR IS MADE TO THE PAYMASTER GENERAL OF THE NAVY. IN OTHER WORDS, WHILE TRANSACTIONS UNDER THE FUND ARE CONTEMPLATED GENERALLY, ON A REIMBURSEMENT BASIS, PROVISION IS MADE FOR EXCEPTIONAL CASES TO BE HANDLED ON A PAY IN ADVANCE BASIS. HOWEVER, IT IS CLEAR THAT THE CORPUS OF THE FUND IS TO BE CREATED FROM APPROPRIATIONS AND NOT FROM PAYMENTS MADE IN ADVANCE FOR PARTICULAR TRANSACTIONS. IN VIEW OF THE SPECIFIC PROVISION TO THE EFFECT THAT ADVANCES OF FUNDS FROM APPROPRIATE NAVAL APPROPRIATIONS SHALL BE ACCOMPLISHED BY ADVANCE CHECK PAYMENTS MADE TO THE FUND THERE WOULD APPEAR TO BE NO AUTHORITY TO EFFECT SUCH ADVANCES OTHER THAN BY MEANS OF A CHECK- -- THE AMOUNT THEREOF TO BE DEPOSITED DIRECTLY TO THE CREDIT OF THE FUND. AND, IN ORDER THAT A PROPER ACCOUNTING CONTROL MAY BE OBTAINED AND TO INSURE OBSERVANCE OF THE PERIOD OF AVAILABILITY PLACED BY THE CONGRESS UPON THE NAVAL APPROPRIATIONS FROM WHICH SUCH ADVANCES ARE MADE, I AM CONSTRAINED TO HOLD THAT SUCH ADVANCES DO NOT BECOME PART OF THE FUND IN THE SENSE OF NOT BEING SUBJECT TO FISCAL YEAR LIMITATIONS, BUT MUST BE TAKEN UP AND ACCOUNTED FOR AS SEPARATE TRANSACTIONS. THE NECESSARY DETAILS IN RESPECT THERETO SHOULD BE TAKEN UP BY REPRESENTATIVES OF THE NAVY DEPARTMENT WITH REPRESENTATIVES OF THE TREASURY DEPARTMENT AND THE GENERAL ACCOUNTING OFFICE.