SECURITY OF NON PUBLIC FUNDS

 

INTRODUCTION

 

1. Except as indicated in this chapter, orders in relation to the security of Public funds, and in particular QR&O 202.03, CFAO 202-2, and National Defence Security Policy (NDSP) Chapter 8, apply equally to Non-Public Funds.  Public support for security of NPF is covered under A-PS-110-001/AG-002.

 

PHYSICAL SECURITY

 

2. NPF cash, negotiable instruments and cash vouchers shall be secured in accordance with CFAO 202-2, paragraph 14, and NDSP Chapter 8, article 8.48.

 

3. Public and Non-Public Funds shall not normally be kept in the same safe and in circumstances where it is impractical or separate facilities do not exist, storage of Public and Non-Public Funds in the same safe requires written Commanding Officer (CO) authorization.  If authorized the Public and Non-Public Funds shall be kept segregated.  At no time will funds be transported to a private residence for safekeeping.  Funds must be maintained at all times within a secure location.  The NPPAM shall notify annually the Military Police in writing of the location of each office where Non-Public Funds are stored; the notification shall also state whether the office is open to public view.

 

DEPOSITING OF CASH RECEIPTS

 

4. Without exception, all cash receipts must be deposited on or before the first banking day following the last day of each accounting period.  Cash receipts for days not immediately followed by a banking day may:

a. be kept at the outlet if appropriate secure facilities are available;

b. be deposited with the military police; or

c. be deposited in a suitable night depository.

5. CANEX, messes and other entities whose daily sales normally exceed $1,000, must deposit all cash receipts, including any overage, daily in accordance with Non-Public Property Accounting Manager (NPPAM) direction.  On the occasion that daily sales do not exceed $1,000 and the facility is equipped with an appropriate safe or approved filing cabinet with built-in hasp or equipped with an approved locking bar set and secured with an approved padlock rated S2/83, deposits may be held on site but must be deposited when cumulative daily sales exceed $1,000.00 and at a minimum, weekly and at the end of the accounting period. If secure facilities are unavailable, deposits must be made daily. This does not preclude the entity’s responsibility to submit Daily Sales Reports (DSR’s).
When the amount of cash, negotiable instruments and cash vouchers exceeds $50K on a consistent basis additional security measures such as intrusion alarms and more frequent security checks during silent hours should be provided.

 

6.  For other trading entities whose daily sales routinely are less than $1,000 may, if an approved filing cabinet with built-in hasp or equipped with an approved locking bar set and secured with an approved padlock rated S2/83, may hold deposits on site but cash receipts must be deposited when cumulative daily sales exceed $1,000.00 and at a minimum, weekly.  If secure facilities are unavailable, deposits must be made daily.  This does not preclude the entity’s responsibility to submit DSR’s.
 
7. Persons appointed in accordance with Chapter 18 (Cash and Other Disbursements) to collect funds not classified as sales, (for example: mess subscriptions, membership dues) shall make deposits when the cumulative amount at close of business exceeds $1,000.00 and at a minimum weekly.  If secure facilities such as an approved filing cabinet with built-in hasp or equipped with an approved locking bar set and secured with an approved padlock rated S2/83 are unavailable, deposits must be made daily.  All cash deposited must be supported by the duplicate copies of form CF 602, Non-Public Funds Receipt, or equivalent Point of Sale or other cash control systems receipt issued.

 

8. If the NPPAM acts as a central cashier, they shall deposit funds daily with the local financial institution on each banking day. Where the distance to the nearest banking facility makes daily depositing impracticable and, if appropriate secure facilities exist, the Regional Accounting Manager (RAM) may authorize weekly deposits.  Delay of deposits in excess of one week must be authorized by the Chief Financial Officer (CFO).

 

MILITARY POLICE SERVICES

 

9. In circumstances where Military Police Escort Services, as required by QR&O 202.03 sub paragraph (b) are not provided for all deposits to the bank, the RAM shall advise the applicable BComd accordingly, giving full particulars of the possible implications should these services not be made available/utilized.  While the safeguarding of Non-Public Funds is imperative, the safety of personnel is paramount and each circumstance must be assessed on a case-by-case basis.  If Military Police Escort Services are considered necessary and cannot be provided, the BComd shall advise the chain of command of the problem in writing to seek direction on the appropriate action to be taken. The RAM will also notify CFO of the situation.

Note:  A military armed guard is not normally required for the transport of endorsed negotiable instruments intended for bank deposit.  If a military guard is considered necessary in the circumstances, a request for such services shall be submitted to the Base Security Officer.

 

10. Notwithstanding the requirement for daily deposits when sales are in excess of $1,000.00, when Military Police Escort Services are not available and when personal safety is jeopardized with late night deposits, outlets may secure funds within the outlet as long as appropriate secure facilities are utilized.

 

MILITARY POLICE REPORTS

 

11. All incidents involving the loss of non-public funds, regardless of amount, shall be reported to the responsible RAM.  This may be done directly or through the local NPPAM.  This requirement is in support of identifying internal control shortcomings and initiating the appropriate corrective action.  Write-off, reporting, and loss/damage of NPP procedures are outlined in Chapter 30 (Write-off, Reporting, and Loss/Damage of NPP).

12. It is incumbent upon RAMs to liaise with the local Military Police authorities to explain where they fit in the chain of command and how reports should be distributed – directly to RAM or filtered up through the local NPPAM.  RAMs are to report all non-public funds Military Police investigations to the CFO.

 

SAFE COMBINATIONS AND LOCKING DEVICES

 

13. As per CFAO 202-2 and NDSP persons to whom a safe has been provided for the safekeeping of Non-Public Funds in their charge shall change the combination:

a. immediately on assuming the responsibility as a Non-Public Funds holder;

b. whenever it is suspected that compromise may have occurred;

c. at least once every six months; and

d. on changeover of secondary personnel hold the combination.

Note: an individual provided with a safe shall not attempt to change a combination without having been advised of the proper method.

 

14. The use of sequential series of numbers (eg. 20-40-60, 9-18-27) or dates readily associated with the safe holder (eg birthdate, enrolment, etc) shall be avoided when setting a combination.

 

15. In addition to these policies, the combination (and/or duplicate of the key) under which the funds are secured shall be placed in a sealed (with a highly adhesive tape) envelope and deposited with the following:

a. CANEX Outlets with the NPPAM;

b. other NPP entities/activities with the NPPAM; and

c. NPPAM with the RAM

16. The sealed envelopes shall be annotated on the front with the following information:

Unit: _______________________________

Fund Holder: ________________________

Location of Fund: Bldg # ________

Office # ________

Date Combination
Changed: ___________________

In Case of Emergency, this envelope may be surrendered to:

__________________________________

And opened by:

__________________________________