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Home My WebLink AboutDWR Audit Training for DMS_6-2024v vml-e�eoase��u�aa�Q�S��oq\�. � �o�e �QSuma\oSa�a�e�a�Fus�e �Sev.�aa�s�Q\aee�a�sag Qee°`" e�a�� Doaeeq Sas��Q�Qasoe�e. .,,�mQ �s q�am\area, \Fusee M \ti��e�eSSaQ . ��i�1:�_ntilii�i�il�iT•'iiiTi� To train specific DMS staff (Kelly Williams, Beth Harmon) how to perform an un- official audit of mitigation banks' buffer & nutrient offset credit sales This training is only to assist DMS in auditing bank where DMS intends to purchase mitigation bank credits through an IFB. A Credit Transfer Certificate (CTC) will be signed by DMS after they have conducted a compliant audit A CTC will be signed by DWR once DMS informs DWR that there is a compliant audit All ledgers that have been audited by DMS for purchasing credits from that specific bank, will still be audited by DWR during their formal annual audit review. Ledger layouts & what to focus on in an audit Mitigation Credit Transfer Certificate (Receipt) layouts & what to focus on in an audit Review the Supporting Documentation types for buffer & nutrient offset credit sales Checklist for auditing buffer credit sales Checklist for auditing nutrient offset credit sales What do you need for an audit? Ledgers dated NO EARLIER Stormwater Approval than the date they submit Mitigation Credit Transfer Letters (or the like) w/supporting Nutrient their Credit Transfer ® Certificates (MCTC) Certificate request to DMS Reporting Forms (in most ft scenarios) Most recent Audit Any conversion approval Compliance Letter from 4D Buffer Authorization Letters ® documentation from DWR ® DWR that shows when the (if applicable) last audit was completed for a specific time period. WiAInWs Black Ort i Rownvw d umb,Vla Mil g4fi n Bana.ny IrMU ent IUMBJI wca Owe 4YtyNlm BrN Pr[M mmum mw Baer Nuc m2wol fertvdr of n. FeF6 Aw"I MQmVn Credit TedWm Oat. t,m upd,i.d 5,3 pM4 OWR P,wcl ■ M2l4MZv2 WILDLANDS DLDINGS • • • 170001 MIN • WA bi * • F M OeRe I hnlieTw w • Uedk MWme ft"Od mww I Gmdu "�Iw "ekht trrn sm P w "Wom Gok 4Rp /Ma ftwm-g Ponds of yq. FT, 'Oe+OaM I �. FT, /nsnuli d Sn• H Sale date comes AFTER Approval letter date Credit Releases match their release letter, including the correct decimal places. Project Name matches the Approval Letter or the Reporting Form exactly. If a Buffer Authorization, then there needs to be a project number included w/ the name If a SW letter, then there needs to be a project number, specific Phase, and/or a street #/address. Something to differentiate that project from a similar project. We see this necessary when the project is a well-known store (Walmart, gas station, grocery store, retai store, Hardware store, etc). If for a DMS purchase, the IFB# needs to be included Debits must match Approval letter, including the correct decimal places Always check the credit balance to make sure everything adds up at the end Government Requiring means who issued the approval letter that required the credits ► If a credit sale was only "partial" of what the need was, then the ledger must say "Partial" in the "Project Name" column. This is supported by the MCTC ► All Debits, Credits and Balances should be checked for accuracy (not everyone uses Excel) If the credits being released are out to 2 decimal places, then all the other columns should be out to 2 decimal places. If the credits released are out to 3 decimal places (all banks approved after November 2019), then all the other columns should be out to 3 decimal places. ► All credit sale dates should match the MCTC date. The MCTC date is the official date to use. The purchaser column The acres columns Templates: Buffer MCTC, Nutrient Offset Permanent Credit MCTC, Nutrient Offset MCTC (not permanent) There must be 1 MCTC for each Bank used to make a permit requirement. Even if multiple banks by the same Provider were used to satisfy the same permit, each Bank must have its own MCTC. i.e. 4 banks = 4 MCTC There must be 1 MCTC for each Credit Type sold. By credit type, we mean "RBC" or "NOC". Nitrogen & Phosphorus are sold for same permit = 1 MCTC Buffer Restoration & Buffer Preservation are sold for same permit = 1 MCTC Nitrogen & Buffer are sold for the same project = 2 MCTC (1 for Nutrient, 1 for Buffer) Date of the MCTC cannot predate the Approval Letter Date of the MCTC does not match the Ledger. In 99% of cases, the MCTC date is the date of the sell and that date goes on the ledger Credit type/s sold are wrong Credit amount doesn't match approval letter, why? If the MCTC shows less than the permit requirement, then it was a Partial sell. MCTC must indicate that it was Partial and the corresponding ledger also say "Partial" under Project Name. Credit amount doesn't match ledger Not signed by the Provider Supporting Documentation Buffer Sales: Buffer Authorization + Compensatory Mitigation Responsibility Transfer Form (CMRT form) + MCTC Sometimes need to see the Statement of Availability letter when we see non- compliance Nutrient Offset Sales: Approval Letter from LG + Reporting Form (if applicable) + MCTC Was the bank used for the credits also listed on the CMRT form? Were the credits sold from the correct service area per the rule? ❑ If no, this will likely trigger a Credit Refund Were the credits sold in the same service area shown on the CMRT form? Was it a partial credit sale? If partial, did the MCTC explain that? Did the Ledger show "Partial" on the line item for that sale? Were the credits sold AFTER the letter was issued? Does the date on the MCTC match the ledger date? Was the DWR Project Number listed on the Ledger under "Project Name" If anything was "no" on previous slide, then write up an email with the items needed to be corrected to bring them into compliance. They should respond back to DMS with a comment response on how they resolved the issues. I suggest that DMS advise them to only respond to the issues when they have all been resolved. If a Credit Refund is triggered, elevate to DV R per Slide 18. DMS does not have to instruct the Provider on how to bring them into compliance. DMS only provides them with the problems they noticed and is up to the Provider to figure out how to fix it. The provider may have to contact DWR to get assistance. ❑ General Notes: Ledger dates should always match MCTC dates (MCTC date is the date payment was received & ledger date must match), any changes to the Credits Debited column may trigger a Credit Refund Was the approval letter issued by a LG? ❑ Were the right credits sold per the letter requirement? ❑ Were Permanent Credits needed? If so, did they use the correct MCTC Template to show the conversion between "pounds" and "pounds per year"? ❑ Were the credits sold in the same service area as the permitted project? ❑ If the service area was not included on the letter, can you prove compliance via other means? (i.e. Nutrient Reporting Form, email, address, etc) ❑ If no, this will likely trigger a Credit Refund ❑ Was it a partial credit sale? ❑ If partial, did the MCTC explain that? 41 Ir ❑ Did the Ledger show "Partial" on the line item for that sale? 'IV ❑ Were the credits sold AFTER the letter was issued? ❑ Does the date on the MCTC match the ledger date? ❑ Was the Project Name on the ledger specific? Have a permit number, address, phase ID, etc? If anything was "no" on previous slide, then write up an email with the items needed to be corrected to bring them into compliance. They should respond back to DMS with a comment response on how they resolved the issues. I suggest that DMS advise them to only respond to the issues when they have all been resolved. If a Credit Refund is triggered, elevate to DWR per Slide 18. DMS does not have to instruct the Provider on how to bring them into compliance. DMS only provides them with the problems they noticed and is up to the Provider to figure out how to fix it. The provider may have to contact DWR to get assistance. ❑ General Notes: Ledger dates should always match MCTC dates (MCTC date is the date payment was received & ledger date must match), any changes to the Credits Debited column may trigger a Credit Refund Sassarixa Swamp Phase II Nitrogen ledger Partial, ID numbers, phases, Grantham Branch Buffer ledger Conversion, non -compliant debit, IFB, multiple banks (partial) If the audit was deemed to be compliant to the best of your ability send Katie an email notifying the audit was completed and appears to be compliant. Include the CTC, signed by all parties, for her signature along with the Bank's corrected ledger/s • A credit refund is almost always necessary when credits are sold in the wrong service area • A credit refund is always necessary when a provider has oversold • A credit refund is almost always necessary when it is determined they sold credits PRIOR to the issuance of an approval letter.