B-7247, FEBRUARY 3, 1940, 19 COMP. GEN. 696

B-7247: Feb 3, 1940

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- HAVE BEEN APPLIED TO THE WRONG LOAN INDEBTEDNESS OF THE INDIVIDUAL. THERE IS NO OBJECTION TO SUCH ADJUSTMENTS AS MAY BE REQUIRED IN THE INTEREST OF THE GOVERNMENT. IS NOT AUTHORIZED. 1940: REFERENCE IS MADE TO YOUR LETTER OF NOVEMBER 18. AS FOLLOWS: YOUR ATTENTION IS INVITED TO A PROBLEM WHICH ARISES OUT OF COLLECTIONS OF LOANS AND WHICH IS SHARED BY THE FARM CREDIT ADMINISTRATION AND THE FARM SECURITY ADMINISTRATION OF THIS DEPARTMENT. MANY FARMERS ARE INDEBTED BOTH TO THE FARM CREDIT ADMINISTRATION AND THE FARM SECURITY ADMINISTRATION. CASES HAVE ARISEN WHERE SUCH FARMERS HAVE DISPOSED OF PROPERTY SUBJECT TO A LIEN IN FAVOR OF ONE OF THE TWO AGENCIES AND THE PROCEEDS OF SUCH SALE HAVE BEEN APPLIED TOWARD THE LIQUIDATION OF THE DEBT OWING TO THE OTHER AGENCY.

B-7247, FEBRUARY 3, 1940, 19 COMP. GEN. 696

FUNDS - PUBLIC - LOANS - REPAYMENTS CREDITED TO LOAN ACCOUNT WITH ANOTHER GOVERNMENT AGENCY - ADJUSTMENTS WHERE REPAYMENTS ON LOANS MADE BY THE FARM CREDIT ADMINISTRATION AND THE FARM SECURITY ADMINISTRATION--- BOTH AGENCIES NOW UNDER THE DEPARTMENT OF AGRICULTURE--- HAVE BEEN APPLIED TO THE WRONG LOAN INDEBTEDNESS OF THE INDIVIDUAL, THERE IS NO OBJECTION TO SUCH ADJUSTMENTS AS MAY BE REQUIRED IN THE INTEREST OF THE GOVERNMENT, BUT THE MAKING OF SUCH ADJUSTMENTS THROUGH THE MEDIUM OF SUBSEQUENT COLLECTIONS OF THE SAME KIND, RATHER THAN THROUGH THE SUBMISSION OF A REQUEST THEREFOR TO THE GENERAL ACCOUNTING OFFICE, IS NOT AUTHORIZED.

ACTING COMPTROLLER GENERAL ELLIOTT TO THE SECRETARY OF AGRICULTURE FEBRUARY 3, 1940:

REFERENCE IS MADE TO YOUR LETTER OF NOVEMBER 18, 1939, AS FOLLOWS:

YOUR ATTENTION IS INVITED TO A PROBLEM WHICH ARISES OUT OF COLLECTIONS OF LOANS AND WHICH IS SHARED BY THE FARM CREDIT ADMINISTRATION AND THE FARM SECURITY ADMINISTRATION OF THIS DEPARTMENT.

MANY FARMERS ARE INDEBTED BOTH TO THE FARM CREDIT ADMINISTRATION AND THE FARM SECURITY ADMINISTRATION. CASES HAVE ARISEN WHERE SUCH FARMERS HAVE DISPOSED OF PROPERTY SUBJECT TO A LIEN IN FAVOR OF ONE OF THE TWO AGENCIES AND THE PROCEEDS OF SUCH SALE HAVE BEEN APPLIED TOWARD THE LIQUIDATION OF THE DEBT OWING TO THE OTHER AGENCY. SUCH ERRORS ARE USUALLY DUE TO A MISUNDERSTANDING ON THE PART OF THE BORROWER AS TO HIS OBLIGATIONS; TO CONFUSION IN THE BORROWER'S MIND BETWEEN THE TWO FEDERAL AGENCIES; OR TO THE FACT THAT, AT THE TIME THE COLLECTION WAS MADE, THE COLLECTING OFFICER DID NOT KNOW THE SOURCE OF THE FUNDS AND DID NOT HAVE ACTUAL KNOWLEDGE THAT THE PROPERTY SOLD WAS SUBJECT TO A LIEN IN FAVOR OF THE OTHER AGENCY. IN CASES OF THIS KIND, WHERE THE ERRONEOUS COLLECTION IS DISCOVERED BEFORE THE FUNDS HAVE BEEN COVERED INTO THE TREASURY OF THE UNITED STATES, AN ADJUSTMENT TO ACCOMPLISH THE PROPER CREDIT TO THE SECURED INDEBTEDNESS MAY BE ACCOMPLISHED QUICKLY AND EFFECTIVELY BY THE TRANSFER OF THE COLLECTIONS TO THE AGENCY HOLDING THE LIEN. HOWEVER, WHERE THE COLLECTION HAS BEEN COVERED INTO THE TREASURY OF THE UNITED STATES BY THE COLLECTING AGENCY AND ADJUSTMENT IS SOUGHT THROUGH THE GENERAL ACCOUNTING OFFICE TO TRANSFER THE CREDIT TO THE FUND, OR APPROPRIATION, OR RECEIPT TITLE ACCOUNT OF THE AGENCY HOLDING THE SECURED LOAN, IT IS FOUND THAT, IN CERTAIN CASES, THESE ADJUSTMENTS ARE EFFECTED BY THE GENERAL ACCOUNTING OFFICE BY TRANSFER AND COUNTER WARRANT, AND THAT IN OTHER CASES, THE DECISION HAS BEEN REACHED THAT NO ADJUSTMENT WILL BE PERMITTED, AS ILLUSTRATED BY THE FOLLOWING:

(A) LETTER TO THE GENERAL ACCOUNTING OFFICE FROM THE FARM CREDIT ADMINISTRATION, DATED AUGUST 10, 1938, REQUESTED THAT AN ADJUSTMENT IN THE AMOUNT OF $80 BE MADE BECAUSE A COLLECTION IN THAT AMOUNT, IDENTIFIED AS HAVING BEEN DERIVED FROM THE SALE OF PROPERTY MORTGAGED TO SECURE A LOAN FROM THE FARM SECURITY ADMINISTRATION, HAD BEEN COVERED INTO THE TREASURY AND APPLIED TOWARD THE LIQUIDATION OF AN UNSECURED LOAN INDEBTEDNESS DUE THE FARM CREDIT ADMINISTRATION FROM GUST HALLVIN OF WAUSA, NEBRASKA. THE REMITTANCE OF $80 REACHED THE FARM CREDIT ADMINISTRATION IN THE FORM OF A BANK DRAFT, AND IT DEVELOPED THAT THE FARM CREDIT ADMINISTRATION WAS NAMED AS THE PAYEE OF THE DRAFT BY MISTAKE OF THE BANK AND CONTRARY TO THE INSTRUCTIONS OF MR. HALLVIN THAT THE AMOUNT BE REMITTED TO THE FARM SECURITY ADMINISTRATION. ADJUSTMENT WAS MADE BY TRANSFER AND COUNTER WARRANT NO. 2583, TREASURY WARRANT NO. 16313, DATED FEBRUARY 20, 1939.

(B) LETTER TO THE GENERAL ACCOUNTING OFFICE FROM THE FARM CREDIT ADMINISTRATION, DATED OCTOBER 4, 1938, REQUESTED THAT AN ADJUSTMENT IN THE AMOUNT OF $55 BE MADE BECAUSE A COLLECTION IN THAT AMOUNT, IDENTIFIED AS HAVING BEEN DERIVED FROM THE SALE OF PROPERTY MORTGAGED TO SECURE A LOAN FROM THE FARM SECURITY ADMINISTRATION, HAD BEEN COVERED INTO THE TREASURY AND APPLIED TOWARD THE LIQUIDATION OF AN UNSECURED LOAN INDEBTEDNESS DUE THE FARM CREDIT ADMINISTRATION FROM ALVIN YOUNG, NESS CITY, KANSAS. THE REMITTANCE OF $55 REACHED THE FARM CREDIT ADMINISTRATION IN THE FORM OF A CASHIER'S DRAFT, WHICH WAS DELIVERED BY THE BORROWER IN THE BELIEF THAT THE AMOUNT WOULD BE REMITTED TO THE TREASURY DEPARTMENT AND THERE CREDITED TO HIS ACCOUNT DUE THE FARM SECURITY ADMINISTRATION. HOWEVER, THE FARM CREDIT ADMINISTRATION COLLECTOR KNEW, AT THE TIME, THE SOURCE OF THE FUNDS AND THAT THE PROPERTY SOLD WAS MORTGAGED TO THE FARM SECURITY ADMINISTRATION. THE DESIRED ADJUSTMENT WAS MADE BY TRANSFER AND COUNTER WARRANT NO. 618, DATED JULY 21, 1939.

(C) LETTER TO THE GENERAL ACCOUNTING OFFICE FROM THE FARM CREDIT ADMINISTRATION, DATED MAY 23, 1939, REQUESTED THAT AN ADJUSTMENT IN THE AMOUNT OF $100 BE MADE BECAUSE A COLLECTION IN THAT AMOUNT, IDENTIFIED AS HAVING BEEN DERIVED FROM THE SALE OF PROPERTY MORTGAGED TO SECURE A LOAN FROM THE FARM SECURITY ADMINISTRATION, HAD BEEN COVERED INTO THE TREASURY AND APPLIED TOWARD THE LIQUIDATION OF AN UNSECURED LOAN INDEBTEDNESS DUE TO THE FARM CREDIT ADMINISTRATION FROM W. A. WOOLEDGE OF GANN VALLEY, SOUTH DAKOTA. THE REMITTANCE OF $100 REACHED THE FARM CREDIT ADMINISTRATION IN THE FORM OF A BANK DRAFT. THE BORROWER EXPLAINED THAT HE HAD SENT THE DRAFT TO THE FARM CREDIT ADMINISTRATION THROUGH A CONFUSION IN HIS MIND BETWEEN THE FARM CREDIT ADMINISTRATION AND THE FARM SECURITY ADMINISTRATION. THE DRAFT BORE A NOTATION INDICATING THAT IT WAS TO BE APPLIED TOWARD THE LIQUIDATION OF A 1936 FEED LOAN. THE FARM CREDIT ADMINISTRATION LOAN WAS MADE IN 1934, AND THE FARM SECURITY ADMINISTRATION LOAN WAS MADE IN 1936. GENERAL ACCOUNTING OFFICE CERTIFICATE OF SETTLEMENT, DATED AUGUST 29, 1939, CLAIM NO. 10109054 (12), ADDRESSED TO THE FARM SECURITY ADMINISTRATION STATES THAT NO ADJUSTMENT WILL BE MADE BECAUSE THE FARM CREDIT ADMINISTRATION, AT THE TIME THE COLLECTION WAS RECEIVED, HAD NO NOTICE THAT THE FUNDS WERE DERIVED FROM THE SALE OF MORTGAGED PROPERTY.

(D) LETTER TO THE GENERAL ACCOUNTING OFFICE FROM THE FARM CREDIT ADMINISTRATION, DATED JULY 26, 1938, REQUESTED THAT AN ADJUSTMENT IN THE AMOUNT OF $105.95 BE MADE BECAUSE A COLLECTION IN THAT AMOUNT, IDENTIFIED AS HAVING BEEN DERIVED FROM THE SALE OF PROPERTY MORTGAGED TO SECURE A LOAN FROM THE FARM SECURITY ADMINISTRATION, HAD BEEN COVERED INTO THE TREASURY AND APPLIED TOWARD THE LIQUIDATION OF A 1937 CROP PRODUCTION LOAN INDEBTEDNESS DUE THE FARM CREDIT ADMINISTRATION FROM AUGUST ASBJORNSON, OF WINIFRED, MONTANA. THE REMITTANCE OF $105.95 REACHED THE FARM CREDIT ADMINISTRATION IN THE FORM OF A CHECK ISSUED BY THE CONKLIN BROS. LIVESTOCK COMMISSION COMPANY OF CHICAGO, THE PURCHASERS OF THE MORTGAGED PROPERTY. MR. ASBJORNSON LATER REQUESTED THAT AN ADJUSTMENT BE MADE TO APPLY THE AMOUNT TOWARD THE LIQUIDATION OF HIS SECURED INDEBTEDNESS TO THE FARM SECURITY ADMINISTRATION, AND EXPLAINED THAT THE REMITTANCE WAS MADE BY HIM TO THE FARM CREDIT ADMINISTRATION BY MISTAKE, BUT IN ACCORDANCE WITH INSTRUCTIONS GIVEN BY THE FIELD REPRESENTATIVE OF THE FARM CREDIT ADMINISTRATION AT THE TIME THE MORTGAGED PROPERTY (CATTLE) WAS SHIPPED TO THE COMMISSION COMPANY. GENERAL ACCOUNTING OFFICE CERTIFICATE OF SETTLEMENT NO. 10753016 (2), ISSUED TO THE FARM SECURITY ADMINISTRATION ON SEPTEMBER 17, 1938, STATES THAT NO ADJUSTMENT WILL BE MADE BECAUSE THE FARM CREDIT ADMINISTRATION EMPLOYEE, WHO MADE THE COLLECTION, DID NOT HAVE ACTUAL NOTICE AT THE TIME THAT THE CATTLE SOLD WERE SUBJECT TO A LIEN IN FAVOR OF THE FARM SECURITY ADMINISTRATION.

(E) LETTER TO THE GENERAL ACCOUNTING OFFICE FROM THE FARM CREDIT ADMINISTRATION, DATED OCTOBER 31, 1938, REQUESTED THAT AN ADJUSTMENT IN THE AMOUNT OF $73.72 BE MADE BECAUSE A COLLECTION IN THAT AMOUNT, IDENTIFIED AS HAVING BEEN DERIVED FROM THE SALE OF PROPERTY MORTGAGED TO SECURE A LOAN FROM THE FARM SECURITY ADMINISTRATION, HAD BEEN COVERED INTO THE TREASURY AND APPLIED TOWARD THE LIQUIDATION OF AN UNSECURED LOAN INDEBTEDNESS DUE THE FARM CREDIT ADMINISTRATION FROM BUD W. HINZMAN, OF OWANKA, SOUTH DAKOTA. MR. HINZMAN EXPLAINED THAT THIS AMOUNT WAS PAID TO THE COLLECTOR FOR THE FARM CREDIT ADMINISTRATION BECAUSE THE LATTER WAS PRESENT AND DEMANDED PAYMENT. THE COLLECTOR STATED THAT HE DID NOT KNOW, AT THE TIME HE ACCEPTED THE REMITTANCE, THAT THE LIVESTOCK SOLD WAS MORTGAGED TO THE FARM SECURITY ADMINISTRATION. GENERAL ACCOUNTING OFFICE CERTIFICATE OF SETTLEMENT NO. 1019054 (12), ISSUED DECEMBER 10, 1938, ADDRESSED TO THE FARM SECURITY ADMINISTRATION, STATES THAT NO ADJUSTMENT WILL BE MADE BECAUSE NEITHER THE FIELD SUPERVISOR WHO MADE THE COLLECTION, NOR THE EMERGENCY CROP AND FEED LOAN OFFICE, KNEW AT THE TIME THAT THE LIVESTOCK WAS MORTGAGED TO THE FARM SECURITY ADMINISTRATION.

IT APPEARS THAT THE BASIS UPON WHICH ADJUSTMENT OF THE CASES CITED ABOVE IN (C) TO (E) WAS DENIED IS THE SAME AS THAT STATED BY THE GENERAL ACCOUNTING OFFICE IN OTHER CLAIMS WHERE A THIRD PARTY LIENHOLDER IS MAKING CLAIM FOR THE PAYMENT TO HIM FROM THE TREASURY OF AN AMOUNT DERIVED FROM THE SALE OF PROPERTY COVERED BY A MORTGAGE IN HIS FAVOR.

THE DEPARTMENT OF AGRICULTURE IS DESIROUS OF EFFECTING ADJUSTMENTS IN ALL CASES SIMILAR TO THOSE CITED HEREIN, WHERE MONIES RECEIVED BY THE UNITED STATES ARE IDENTIFIED AS HAVING BEEN DERIVED FROM THE SALE OF PROPERTY MORTGAGED TO THE UNITED STATES, AND HAVE NOT BEEN APPLIED TOWARD THE LIQUIDATION OF THE SECURED INDEBTEDNESS OR HAVE BEEN APPLIED INCORRECTLY BECAUSE OF A MISTAKE, EITHER ON THE PART OF THE BORROWER OR ON THE PART OF AN EMPLOYEE OF THE UNITED STATES. WE BELIEVE THAT THE QUESTION OF WHETHER THE COLLECTING OFFICIAL IS AWARE OF THE SOURCE OF THE FUNDS SHOULD HAVE NO PLACE IN TRANSACTIONS BETWEEN TWO AGENCIES OF A DEPARTMENT OF THE GOVERNMENT. THE ACCOMPLISHMENT OF THIS RESULT IS DESIRED PRINCIPALLY FOR TWO REASONS: FIRST, JUNIOR LIENHOLDERS, IF THERE BE ANY, WOULD CONTEST THE RIGHT OF THE GOVERNMENT TO MAINTAIN ITS PRIOR POSITION AS TO THE REMAINDER OF THE MORTGAGED PROPERTY IF THE PROCEEDS OF THE SALE OF PART OF THE PROPERTY, RECEIVED BY THE UNITED STATES, ARE NOT APPLIED TO THE MORTGAGE DEBT; AND SECOND, TO MAINTAIN THE INTEGRITY OF THE ACCOUNTS OF THE ADMINISTRATIVE OFFICES CONCERNED AND OF THE TREASURY DEPARTMENT AND THE GENERAL ACCOUNTING OFFICE BY CAUSING THESE ACCOUNTS TO SHOW THE CORRECT IDENTIFICATION OF THESE COLLECTIONS, AND TO MAKE PROPER DISPOSAL OF SUCH COLLECTIONS IN ACCORDANCE WITH PERTINENT STATUTES BY CARRYING THEM TO THE PROPER MISCELLANEOUS RECEIPTS, APPROPRIATIONS, OR FUND ACCOUNTS. IT WOULD APPEAR THAT A FAILURE TO MAKE THESE ADJUSTMENTS WOULD CONSTITUTE, IN SOME CASES, A DIVERSION OF FUNDS CONTRARY TO THE REQUIREMENTS OF THE LAW.

UPON A REVIEW OF THIS MATTER, I TRUST THAT YOU WILL FIND IT POSSIBLE TO ADOPT A RULE PERMITTING ADJUSTMENTS TO BE MADE IN CASES OF THIS KIND SO THAT COLLECTIONS, WHICH HAVE CLEARLY BEEN APPLIED TO THE WRONG ACCOUNT IN ERROR, MAY BE ADJUSTED.

IT IS MOST ESSENTIAL, FROM THE STANDPOINT OF GOOD ADMINISTRATION, TO MAKE THESE ADJUSTMENTS AS QUICKLY AS POSSIBLE. IT IS CLEAR THAT THE ADJUSTMENTS CANNOT BE MADE EXPEDITIOUSLY IF YOUR OFFICE SHOULD REQUIRE THAT THEY BE MADE ONLY BY THE ISSUANCE OF TRANSFER AND COUNTERWARRANTS. I, THEREFORE, SUGGEST, FOR YOUR CONSIDERATION AND APPROVAL, AN ALTERNATE PROCEDURE WHICH WOULD PERMIT THESE ADJUSTMENTS TO BE MADE FROM SUBSEQUENT COLLECTIONS OF THE SAME KIND IN THE HANDS OF COLLECTING AND DISBURSING OFFICERS, WHICH HAVE NOT YET BEEN COVERED INTO THE TREASURY OF THE UNITED STATES. THE NET RESULT UNDER THE LATTER PROCEDURE WOULD BE THE SAME AS IS ACCOMPLISHED THROUGH THE TRANSFER AND COUNTERWARRANT PROCEDURE, EXCEPTING THAT THE ADJUSTMENTS CAN BE ACCOMPLISHED PROMPTLY AND THE LOAN ACCOUNTS OF BOTH AGENCIES THUS MADE TO SHOW THE CORRECT STATUS. SUCH ADJUSTMENTS FROM SUBSEQUENT COLLECTIONS OF THE SAME KIND HAVE BEEN PERMITTED OVER A CONSIDERABLE PERIOD OF TIME, AND PRIOR TO YOUR DECISION OF APRIL 20, 1938 (17 COMP. GEN. 859) REFUNDS PROPERLY DUE THIRD PARTIES ON ACCOUNT OF COLLECTIONS MADE BY MISTAKE AND COVERED INTO THE TREASURY WERE ALSO PERMITTED TO BE MADE FROM SUBSEQUENT COLLECTIONS OF THE SAME KIND (SEE DECISION OF JUNE 15, 1936, 15 COMP. GEN. 1089). IT APPEARS, HOWEVER, THAT THE CHANGE IN THE RULE, DISCONTINUING THE MAKING OF REFUNDS TO THIRD PARTIES FROM SUBSEQUENT COLLECTIONS OF THE SAME KIND, NEED NOT AFFECT, NECESSARILY, THE RULE PERMITTING ADJUSTMENTS BETWEEN LOAN ACCOUNTS TO BE MADE FROM SUBSEQUENT COLLECTIONS OF THE SAME KIND.

AS A GENERAL RULE THE LIEN OF A MORTGAGE DOES NOT ATTACH TO THE PROCEEDS OF AN UNAUTHORIZED SALE OF THE MORTGAGED PROPERTY, BUT THE MORTGAGEE MAY WAIVE THE TORT AND RECOVER THE PROCEEDS OF THE SALE FROM THE MORTGAGOR OR A THIRD PERSON WHO HAD NOTICE OF THE MORTGAGE. BUT IN ORDER TO ENABLE THE MORTGAGEE TO RECOVER FROM A THIRD PARTY THE PROCEEDS FROM THE SALE OF MORTGAGED PROPERTY RATHER THAN TO LOOK TO THE PROPERTY ITSELF, IT IS NECESSARY TO ESTABLISH THAT SUCH THIRD PARTY RECEIVED SUCH PROCEEDS WITH NOTICE OF THE MORTGAGEE'S RIGHTS. WHERE THE PROCEEDS OF A SALE OF MORTGAGED PROPERTY BY THE MORTGAGOR ARE PAID TO A THIRD PARTY AND APPLIED AS A CREDIT ON A PRIOR INDEBTEDNESS, THE MORTGAGEE CANNOT RECOVER SUCH PROCEEDS FROM A PERSON WHO RECEIVED PAYMENT WITHOUT ANY KNOWLEDGE AS TO THE SOURCE OF SUCH FUNDS. COMPARE MINNEAPOLIS NAT. BANK OF MINNEAPOLIS, KAN. V. LIBERTY NAT. BANK OF KANSAS CITY, 72 F./2D) 434, AND SMITH V. SHELLABARGER, 291 F. 144.

THE FOREGOING SETS OUT THE LEGAL PRINCIPLES APPLICABLE IN CASES IN WHICH PRIVATE INDIVIDUALS OR CONCERNS ARE INVOLVED AND THE SAME RULE WAS FOLLOWED BY THIS OFFICE IN THE CASES DESCRIBED IN YOUR LETTER. HOWEVER, AS YOU SUGGEST, WHERE NO OUTSIDE INTERESTS ARE INVOLVED AND THE ONLY QUESTION ARISING IS AS TO AN ADJUSTMENT BETWEEN AGENCIES OF THE GOVERNMENT UNDER THE SAME DEPARTMENT SUCH RULE IS NOT NECESSARILY FOR APPLICATION. FURTHERMORE, WITH RESPECT TO CASES INVOLVING THE FARM CREDIT ADMINISTRATION AND THE FARM SECURITY ADMINISTRATION, SINCE BOTH AGENCIES ARE NOW A PART OF THE DEPARTMENT OF AGRICULTURE, IT IS ASSUMED THAT THE PROPER ADMINISTRATIVE ACTION WILL BE TAKEN TO COORDINATE THE ACTIVITIES OF THE TWO AGENCIES SO AS TO ELIMINATE MANY OF THE ERRORS WHICH HAVE OCCURRED IN SUCH CASES AS YOU DESCRIBE. AS TO CASES WHERE SUCH ERRORS CANNOT BE AVOIDED THIS OFFICE WILL NOT OBJECT HEREAFTER TO SUCH ADJUSTMENTS AS MAY BE REQUIRED WHERE IT APPEARS THAT THE INTERESTS OF THE GOVERNMENT WILL NOT BE ENDANGERED THEREBY.

HOWEVER, I AM UNABLE TO AGREE THAT THE ADJUSTMENT PROCEDURE SHOULD BE AS SUGGESTED IN THE CONCLUDING PARAGRAPH OF YOUR LETTER. THE FORMER PROCEDURE AS PROVIDED IN 6 COMP. GEN. 293 AND A-53655, FEBRUARY 23, 1934, AND FOLLOWED UNDER A-71152, AND A-84380, MARCH 9, 1937, PERMITTING ADJUSTMENTS FROM SUBSEQUENT COLLECTIONS IN THE HANDS OF COLLECTING AND DISBURSING OFFICERS, HAS BEEN DISCONTINUED, 17 COMP. GEN. 859, AND THE FACTS AND CIRCUMSTANCES MENTIONED IN YOUR LETTER ARE NOT DEEMED SUFFICIENT TO AUTHORIZE REVIVING IT. CONSEQUENTLY YOU ARE ADVISED THAT ALL CASES REQUIRING ADJUSTMENT SHOULD BE SUBMITTED TO THIS OFFICE FOR CONSIDERATION AND PROPER ACTION ACCOMPANIED BY A REPORT OF THE FACTS INVOLVED AND A STATEMENT OF THE REASONS WHY THE ADJUSTMENT IS REQUIRED.