$1.8B Conversion Fund

The $1.8B has been fully accounted for and visible in the SCEIS General Ledger.  The $1.8B in SCEIS Fund 30350993 resulted from a decision by three state agencies – Comptroller General’s Office (CGO), Department of Administration (SCEIS) and State Treasurer’s Office (STO) – to net thousands of conversion entries and transactions recorded by the STO, CGO, and SCEIS team as a result of the State’s cash conversion project.

The conversion entries have been audited by the State Auditor (OSA) and its external audit firm CliftonLarsonAllen (CLA).  They found “no exception” in this fund’s existence.  There has never been an audit finding or recommendation regarding this fund.  Everyone was aware of its existence and the funds remaining in it.

Why was it considered missing or lost?

The $1.8B is not missing or recently discovered. These funds have been accounted for and fully visible in SCEIS Fund 30350993 since the “STARS to SCEIS” cash conversion and the CGO, SCEIS, and State Auditor have always been aware of and had access to the fund. 

The $1.8B has always been invested by the STO in accordance with state law, reconciled to the bank, and reported by the STO in its annual cash closing package to the CGO. Since 2014, investment of the $1.8B significantly outperformed benchmark performance and generated more than $225M in investment earnings, which has been applied to the State’s General Fund and appropriated by the General Assembly.

The STO has been fully transparent about the $1.8B conversion entries.

Comparison of $1.8B - 2018 & 2024 (PDF)

Questions related to the $1.8B are a result of the CGO’s independent decision to reclassify the $1.8B as an “ACFR General Fund classification.”  The new CG directed the STO to justify the SCEIS fund classification of the $1.8B by the end of FY2024. However, the recent report provided by external auditor Mauldin Jenkins confirmed that fund classification is beyond the STO's ability without a collaborative effort and additional resources. 

Moving Forward

This is a complex financial matter, and we need to be afforded the time, people and resources to handle this matter in a way that reflects the best interest of our state’s taxpayers.

I support the effort as proposed by the House and Senate via budget proviso to hire an audit firm to study and make a recommendation as to the classification of this fund. I also want to thank Governor McMaster for convening a meeting on April 11, 2024, with all the appropriate agencies that were involved in the state’s SCEIS computer conversion, and we all committed to working collaboratively to resolve this fund classification of the $1.8B.

My top priority is to ensure the STO's statutorily driven responsibilities, including the daily management of nearly $70B in public funds, issuance of the State's debt and administration of other established programs, are executed as efficiently and effectively as possible for the citizens of South Carolina.

SCEIS fund 30350993, which has been the subject of a lot of attention, has a cash balance of $1.8B, not $30B as asserted by the Constitutional Budget Subcommittee of the Senate Finance Committee.

The document shared in the Subcommittee meeting, which shows a $30B cash balance is misleading. The Subcommittee’s document purports to show the cash balance of fund 30350993.

SCEIS fund 30350993 has a net cash balance of $1,852,455,573 as demonstrated in the SCEIS report below. The true and accurate cash balance is reflected in the first report. To suggest that the fund has $30B in cash is patently false.

SCEIS Report of Fund 30350993 & Subcommittee document (PDF)

At no time has the STO influenced the State Auditor’s Office (OSA) or CliftonLarsonAllen (CLA). 

During the April 2, 2024 meeting of the Constitutional Budget Subcommittee of the Senate Finance Committee, the Subcommittee stated the State Treasurer violated the law by exercising undue influence on the OSA and CLA. 

It is common practice for a client to discuss and provide documentation related to proposed management letter comments.  Staff from the STO met with the OSA and CLA on January 17, 2024, and only CLA on January 18, 2024, after which Mr. Omisore, a Principal with CLA, notified the STO via email “After discussion today, we wanted to provide a quick update and let everyone know that we have decided to drop the comment related to “Cash and Investment Reporting.” 

The STO staff members who participated in the above meetings did not exercise undue influence on the OSA or CLA.  In fact, the Treasurer did not participate in either of the meetings referenced above. 

During the April 2, 2024 meeting of the Constitutional Budget Subcommittee of the Senate Finance Committee, the Subcommittee quoted the STO’s average turnover rate at being “nearly 30%.”  While the STO has not been informed of how that rate was determined, the inclusion of separated temporary employees and interns would be required to achieve the inflated rate. The STO uses standard turnover calculation guidelines as established by the Division of State Human Resources (DSHR), which result in an average turnover rate of approximately 19% (7/1/2014 - 6/30/2023*). The STO's average turnover rate is consistent with the state's average turnover rate of 18% for all agencies during this period. A comparison of the STO’s standardized calculation method against the Subcommittee's presumed calculation is shown below:

STO Turnover Analysis (PDF) 

The Constitutional Budget Subcommittee of the Senate Finance Committee alleged the STO had a negative cash balance on June 30, 2023.  The STO did not have a negative cash balance on June 30, 2023, nor were there any sales for liquidity purposes. 

STO Liquidity Report 6.30.2023 (PDF)

My office has complied with all statutory reporting requirements consistent with historical interpretation both during my tenure as Treasurer and during the tenure of my predecessors for many years. 

• 11-5-120: These reports have been made available to the public whether by publication in newspapers or on the internet, to the Comptroller General and to the General Assembly.  No one has ever objected to the adequacy of these disclosures until after the 2022 ACFR restatement. It now appears there may be a new interpretation of these statutes which create new and different disclosure requirements that my office has never before been asked to provide. These new requirements will  require additional staff, resources and modifications to SCEIS.  
  
  
• 11-5-170 and 11-5-180: The information and reports required within sections 11-5-170 and 11-5-180 have been generated through SCEIS for years.  The CGO acknowledges that the obligations of these laws are now “performed by SCEIS” within their annual Accountability Report (p.30).

Legislative Compliance Accountability Report excerpt (PDF)

• The State Treasurer’s Office has complied with Proviso 98.14 by providing information requested by the CGO for the Cash and Investment Closing file, to the best of our ability, and continues to research SCEIS fund 30350993.

The State Treasurer’s Office reconciles its custodied bank and investment accounts to the General Ledger on a regular basis, according to schedule. The reconciliations are performed daily, weekly, and/or monthly, depending on the bank or investment account.