As part of our examination, we made a study and evaluation of the Board's
system of internal accounting control to the extent we considered neces-
sary to evaluate the system as required by generally accepted auditing
standards. The purpose of our study and evaluation was to determine the
nature, timing and extent of the auditing procedures necessary for ex-
pressing an opinion on the Board's financial statements. Our study and
evaluation was more limited than would be necessary to express an opinion
on the system of internal accounting control taken as a whole.
The management of the Board is responsible for establishing and maintaining
a system of internal accounting control. In fulfilling this responsibility,
estimates and judgements by management are required to assess the expected
benefits and related costs of control procedures. The objectives of a
system are to provide management with reasonable, but not absolute, assur-
ance that assets are safeguarded against loss from unauthorized use or
disposition and that transactions are executed in accordance with manage-
ment's authorization and recorded properly to permit the preparation of
financial statements in accordance with generally accepted accounting
principles.
Because of inherent limitations in any system of internal accounting con-
trol, errors or irregularities may nevertheless occur and not be detected.
Also, projection of any evaluation of the system to future periods is sub-
ject to the risk that procedures may become inadequate because of changes
in conditions or that the degree of compliance with the procedures may
deteriorate.
Our study and evaluation made for the limited purpose described in the
first paragraph would not necessarily disclose all material weaknesses
in the system. Accordingly, we do not express an opinion on the system
of internal accounting control of the Board, taken as a whole. However,
our study and evaluation disclosed no condition that we believed to be
a material weakness. We do include in the following memorandum comments
and suggestions which we do not consider to be material internal control
weaknesses; however, they came to our attention during the course of our
examination of the financial statements. These comments are offered as
-25-
constructive suggestions for the consideration of management as part of
the ongoing process of improving accounting control and other financial
and administrative practices and procedures.
This report is intended solely for the use of management and the legis-
lature and should not be used for any other purpose. This restriction
as to use is not intended to limit the distribution of this document
which, upon acceptance by the Legislative Audit Committee, is a matter
of public record.
Giblin, Riggs & Associates
Certified Public Accountants
."tJ^ ^ . *i_.J^<j jC, voC^ "
Colorado Springs, Colorado
September 12, 1984
-26-
iJtll'EKRAL OF BOND SWAP (;A I NSVl-pSSjiS
Bond swaps involve trading fixed income securities, such as bonds, deljeu-
tures and mortgages, for other fixed income securities having the same par
value for the purpose of enhancing portfolio content, but primarily to im-
prove yield. Because of increasing interest rates in current years, the
market value of older securities has declined. As a result of this current
market condition, this exchange of securities often gives rise to a loss on
disposal of the older security.
There are currently two ways of accounting for gains and losses on ex-
changes of debt securities. One method is known as the completed transac-
tion method which recognizes the gain or loss on a sale of a security at
the time of the sale. The other method is the deferral and amortization
method which recognizes a deferred gain or loss at the time of the sale and
amortizes the deferral over the remaining life of the new (or old) bond.
The Board uses the deferral method and amortizes gains and losses over the
shorter of either the remaining life of the bonds sold or the replacement
bonds purchased. The Board uses the deferral method on bond swaps because
it is their belief that the recording of these losses in the financial
statements of the participating funds would seriously affect these funds'
ability to distribute their income and provide benefits and service. The
Board also feels no sale should be recognized since the affect of the sale
and repurchase of securities leaves the fund in essentially the same position
as before. Individuals who support the deferral method argue that, should
the completed transaction method of accounting be required under all circum-
stances, including those meeting the exchange criteria, many investment
managers would be deterred from making exchanges which would otherwise
improve investment yields.
At this time, the deferral method of recording gains and losses on bond
swaps is not in accordance with generally accepted accounting principles
except for use by entities such as public employees' retirement systems,
where these gains and losses may be deferred if they meet the exchange
criteria. Other state and local government entities are required to use
the completed transaction method if they wish to comply with generally
accepted accounting principles.
RECOMMEND ATIONS
The Board should use generally accepted accounting principles in relation
to the accounting of bond swap gains and losses. We realize that the
Board wants to maintain consistent accounting records and that they have
been using the deferral method for over ten years. Although this desire
to maintain consistency is extremely important, in this case, the deferral
method is not in agreement with generally accepted accounting principles
-27-
RECOmiENDATiqNS (CONTINUED)
and its continued use may Lund to future c|ualified opinions if the deferred
gains or losses are material to the financial statements taken as a
whole. In this regard, the Board may wish to continue the use of the
deferral method at least long enough to see if the new Government Accounting
Standards Board will study the deferral method as it relates to entities
such as the Board of Investments.
We also recommend that the Board provide information with respect to bond
swap gains and losses to the various agencies and the Legislative Auditor,
if requested. This would enable the various agencies to adjust their
financial statements so that they would be in accordance with generally
accepted accounting principles.
MANAGEMENT COMMENTS
Since the majority of the long-term funds are retirement funds and to
provide consistent accounting, we believe the deferral method is
justified.
Also, all information with respect to bond swaps is available to each
respective agency.
PHYSICAL EXAMINATION OF MORTGAGES
Our examination of mortgages consisted of a review of all mortgage loan
files and the related supporting documentation which were held by servicing
agencies for the Board of Investments. This examination was conducted at
the servicing agencies indicated by the State Legislative Auditors 1984
rotation schedule. This year we reviewed loan files and the supporting
documentation for approximately $22,700,000 of the $99,754,418 of mortgage
loans.
Details of all exceptions noted were furnished to the Board at the end of
our examination. The exceptions which had not been cleared at that time
consisted of the following:
- 6 original assignments to the proper fund of the State of
Montana could not be located
- 1 loan file had no evidence of current insurance
RECOMMENDATIONS
We recomniend that the Board and the servicing agencies continue to follow
up on the above noted exceptions to complete their mortgage loan files.
MANAGEMENT COMMENTS
All of the exceptions have been corrected.
-28-
MORTGAGE LOAN FILES
The servicers of mortgage loan files are required to hold the loan files
in their bank. During our examination of mortgage loan files wc found 20
files that were held in a different city than the servicing bank.
RECOMMENDATION
We recommend that if the servicing of loans is transferred to a different
bank, that the loan files also be transferred. This would allow the new
servicing bank to have all of the information needed to properly service
the loan.
MANAGEMENT COMMENTS
We concur.
SECU RITIES IN SAFEKEEPING
The physical custody of most of the securities are held in custodial accounts
at a bank in New York. Securities listed in the Portfolio Management
System (PMS) are to be reconciled monthly to the Statement of Assets
provided by the bank each month.
We received a confirmation from the bank and compared it to the securities
listed in the PMS as of June 30, 1984. Although we did not note any
significant differences, we did note some items which had to be reconciled
as of June 30, 1984 which dated back several months.
RECOMMENDATIONS
We recommend that any differences be reconciled by the Treasurers' Office
tliroughout the year between the Portfolio Management System (PMS) and the
Statement of Assets provided by the Bank in New York.
MANAGEMENT COMMENTS
The recommendation should be directed to the Treasurers' Office.
NEW ACCOUNTING SYSTEM
The Board will be converting to a different computerized accounting system
during the current year. As the Board is already aware, it almost always
takes a considerable amount of start up time before the new system becomes
fully operational and reliable.
-29-
RECOMMENDATIONS
The Board plans to continue to operate this current system as a parallel
system until such time as the new computer system is fully operational
and working without errors. We want to emphasize the importance of
doing the above.
MANAGEMENT COMMENTS
We concur.
-30-
STATE OF MONTANA
BOARD OF INVESTMENTS
PRIOR YEAR RECOMMENDATIONS
The State of Montana Board of Investments is in substantial compliance
with the recommendations discussed in the 1983 audit report with the
exception of the deferral of gains and losses on bond swaps, which
is further discussed under the current year recommendation.
-31-
STATE OF MONTANA
BOARD OF INVESTMENTS
AGENCY REPLIES
DEPARTMENT OF ADMINISTRATION
BOARD OF INVESTMENTS
TED SCHWINDEN. GOVERNOR
CAPITOL STATION
STATE OF MONTANA'
(406) 444 2656
HELENA. MONTANA b9H^O
October 5, 1984
Giblin, Riggs & Associates
Certified Public Accountants
2502 E. Pikes Peak Avenue
Colorado Springs, CO 80909
Dear Sirs:
The following is our response to your recommendations in regards to our
financial audit:
DEFERRAL OF BOND SWAP GAINS/LOSSES
Since the majority of the long-term funds are retirement funds and to provide
consistent accounting, we believe the deferral method is justified.
Also, all information with respect to bond swaps is available to each respective
agency.
PHYSICAL EXAMINATION OF MORTGAGES
All of the exceptions have been corrected.
MORTGAGE LOAN FILES
We concur
SECURITIES IN SAFEKEEPING
The recommendation should be directed to the Treasurers' Office.
NEW ACCOUNTING SYSTEM
We concur
Sincerely,
//James R. Howeth
^ Investment Officer
JRH/mmw
-32-
pj^tutun h ^oft^i
AN BOUAL OPPORTUNITY EMPLOYER
.f
STATE OF MONTANA
BOARD OF INVESTMENTS
SUMMARY OF PORTFOLIO
STATE OF MONTANA
SUMMARY OF PORTFOLIO
FOR THE YEAR ENDED JUNE 30,
1984
Long-Term
Stated at Book Value
STIP MX Comp.
Total
Willaim Murphy Bequest $
Highway Comp. HDQ Building
Deaf & Blind Bequest
Police Retirement
Sheriffs' Retirement
Educational Trust Fund
Coal Tax Park Acq.
1983 LRBP Bonded Program
1983 FW & P Bonded Program
Volunteer Firemans' Comp.
Permanent Coal Trust
Crime Victims Comp.
Lease Participation Cert.
Highway Rev. Bond Const.
Highway Rev. Bond Cap. Int.
MT Tech. PE Building
MSU Trust
DNRC Water Development
EMC Trust
Common School I & I
Long Range Bldg. BPICF
Airport Loans Spec. Rev.
Trust & Legacy
Public Employees Retirement
Game Wardens' Retirement
Social Security
Teachers' Retirement
Judges' Retirement
Hail Insurance
Workers' Compensation
Subsequent Injury
Highway Patrol Retirement
Treasurers' Accountability
Group Benefits
Firefighters' Unified Ret.
Highway Rev. Bond Proc.
Agency Insurance
Highway Rev. Bond Debt Ser.
Resource Indemnity
Uninsured Employers
Peter Potter Trust
TRS Minnie Fullam Trust
STIP Units Only
MT Comp. Units Only
-0- $
19,354 $
283,
017 $
302,371
600,560
-0-
-0-
600,560
-0-
-0-
-0-
-0-
12,991,178
337,211
399,
487
13,727,876
10,905,114
886,403
699,
034
12,490,551
58,208,768
1,458,893
-0-
59,667,661
9,738,571
1,769,050
-0-
11,507,621
28,108,538
3,985,327
-0-
32,093,865
2,391,154
565,221
-0-
2,956,375
2,964,453
365,369
-0-
3,329,822
182,171,916
10,076,805
-0-
192,248,721
497,941
188,677
-0-
686,618
86,595
-0-
-0-
86,595
25,845,587
6,975,297
-0-
32,820,884
3,597,583
515,318
-0-
4,112,901
161,448
-0-
-0-
161,448
349,891
-0-
-0-
349,891
680,936
163,985
-0-
844,921
1,694,681
-0-
-0-
1,694,681
16,853,062
4,285,393
-0-
21,138,455
7,041,883
11,083,686
-0-
18,125,569
1,266,300
-0-
-0-
1,266,300
161,365,669
-0-
-0-
161,365,669
352,067,971
-0-
51,769,
,756
403,837,727
4,499,394
109,177
299,
.472
4,908,043
12,048,203
-0-
-0-
12,048,203
264,841,122
-0-
43,751,
.557
308,592,679
4,732,436
106,990
448,
,981
5,288,407
549,889
3,048,990
-0-
3,598,879
63,405,989
-0-
-0-
63,405,989
2,332,947
164,288
-0-
2,497,235
9,811,343
194,347
799,
,427
10,805,117
102,200,453
128,542,153
-0-
230,742,606
4,598,110
5,391,083
-0-
9,989,193
8,548,468
2,630,606
198
.711
11,377,785
33,391,567
5,227,365
-0-
38,618,932
7,223,121
770,663
-0-
7,993,784
12,663,275
491,388
-0-
13,154,663
41,846,845
428,882
-0-
42,275,727
200,000
293,652
-0-
493,652
-0-
20,149
42
,014
62,163
-0-
31,617
22
,064
53,681
-0-
45,924,252
-0-
45,924,252
-0-
-0-
117
,831
117,831
$1,452,482,961 $ 236,051,591 $ 98,831,351 $1,787,365,90 3
-33-
STATE OF MONTANA
SUMMARY OF PORTFOLIO
FOR THE YEAR ENDED JUNE 30, 1984
Stated at Market Value
Name of Fund
William Murphy Bequest
Highway Comp. HDQ Building
Deaf & Blind Bequest
Police Retirement
Sheriffs' Retirement
Educational Trust Fund
Coal Tax Park Acq.
1983 LRBP Bonded Program
1983 FW & P Bonded Program
Volunteer Firemans' Comp.
Permanent Coal Trust
Crime Victims Comp.
Lease Participation Cert.
Highway Rev. Bond Const.
Highway Rev, Bond Cap. Int.
MT Tech PE Building
MSU Trust
DNRC Water Development
EMC Trust
Common School I & I
Long Range Bldg. BPICF
Airport Loans Spec. Rev.
Trust & Legacy
Public Employees' Ret.
Game Wardens' Ret.
Social Security
Teachers' Retirement
Judges' Retirement
Hail Insurance
Workers' Compensation
Subsequent Injury
Highway Patrol Ret.
Treasurers Accountability
Group Benefits
Firefighters' Unified Ret.
Highway Rev. Bond Proc.
Agency Insurance
Highway Rev. Bond Debt Ser.
Resource Indemnity
Uninsured Employers
Peter Potter Trust
TRS Minnie Fullam Trust
STIP Units Only
MT Comp. Units Only
Dixon Endowment
Long-Term
8,440 $
562,490
-0-
10,881,446
9,259,984
52,208,749
8,718,760
28,824,795
2,462,220
2,435,744
166,937,376
487,658
85,914
25,596,514
3,659,392
138,143
347,550
680,123
1,697,960
16,978,354
7,492,852
1,313,791
135,686,556
297,624,018
3,585,460
11,786,232
226,490,934
3,776,553
361,257
51,204,954
2,060,625
7,681,022
102,400,561
4,509,096
7,809,912
32,868,936
7,481,565
11,612,979
36,488,882
197,312
-0-
-0-
-0-
-0-
25,600
STIP
MT Comp
Total
17,530 $
-0-
-0-
329,379
870,963
1,451,297
1,785,289
3,869,510
548,042
364,439
9,889,671
182,681
-0-
6,781,331
500,988
-0-
-0-
159,614
-0-
4,140,764
10,731,110
-0-
-0-
-0-
109,793
-0-
-0-
107,025
2,888,754
-0-
159,615
193,752
118,530,276
5,446,285
2,380,385
5,080,924
810,992
474,232
417,951
294,319
19,375
30,447
44,441,242
-0-
-0-
327,114 $
; 353,084
-0-
562,490
-0-
-0-
452,338
11,663,163
798,619
10,929,566
-0-
53,660,046
-0-
10,504,049
-0-
32,694,305
-0-
3,010,262
-0-
2,800,183
-0-
176,827,047
-0-
670,339
-0-
85,914
-0-
32,377,845
-0-
4,160,380
-0-
138,143
-0-
347,550
-0-
839,737
-0-
1,697,960
-0-
21,119,118
-0-
18,223,962
-0-
1,313,791
-0-
135,686,556
67,643,647
365,267,665
333,503
4,028,756
-0-
11,786,232
58,167,557
284,658,491
504,727
4,388,305
-0-
3,250,011
-0-
51,204,954
-0-
2,220,240
917,453
8,792,227
-0-
220,930,837
-0-
9,955,381
182,724
10,373,021
-0-
37,949,860
-0-
8,292,557
-0-
12,087,211
-0-
36,906,833
-0-
491,631
49,834
69,209
25,556
56,003
-0-
44,441,242
150,779
150,779
-0-
25,600
$1,284,430,709 $ 223,007,975 $ 129,553,851 $ 1,636,9 92,535
-34-
STATE OF MONTANA
BOARD OF INVESTMENTS
APPENDIX A
PORTFOLIO OF INVESTMENTS
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