Oklahoma Administrative Code Title 635 - Oklahoma Commission on School and County Funds Management

✅ Oklahoma Administrative Code

Title 635 — Oklahoma Commission on School and County Funds Management

🔹 Overview

Title 635 of the Oklahoma Administrative Code governs the Oklahoma Commission on School and County Funds Management, a regulatory body established to oversee and standardize the financial operations and reporting of school districts and county offices across the state.

Its core objectives are to:

Ensure transparency and accountability in the handling of public funds.

Promote uniform financial practices across schools and counties.

Oversee investment practices, reporting requirements, and compliance monitoring for local public entities.

🔹 Legal Authority

The Commission’s authority derives from Oklahoma statutes, particularly provisions in:

Title 70 (Schools)

Title 19 (Counties and County Officers)

Title 62 (Public Finance)

The administrative rules in Title 635 are developed under these statutes to provide enforceable standards for local public fund management.

📘 Key Areas of Title 635

1. Financial Reporting Standards

School districts and counties must prepare financial reports in accordance with Generally Accepted Accounting Principles (GAAP) or state-modified standards.

Required reports include:

Annual financial statements.

Budget reports.

Investment reports.

Reports must be submitted to the Commission and are subject to audit.

Purpose:

Promote consistency.

Prevent fraud or misuse of funds.

Provide a clear picture of financial health to the public and state agencies.

2. Internal Controls & Fiscal Oversight

Entities must establish internal controls to safeguard funds.

Examples of internal control measures include:

Separation of duties.

Dual signature requirements on checks.

Inventory controls for assets.

The Commission may audit or require documentation to verify compliance.

3. Investment of Public Funds

Title 635 outlines permitted investment vehicles for school and county funds, such as:

U.S. Treasury securities.

Certificates of deposit (CDs).

State-approved investment pools.

Investments must prioritize:

Safety

Liquidity

Yield

Prohibits speculative or high-risk investments.

4. Budget Compliance

Districts and counties must follow budgeting procedures aligned with state law.

The Commission ensures:

Budget limits are respected.

Surpluses or deficits are properly reported.

Corrective action is taken in the event of budget violations.

5. Training and Certification

Officials involved in fund management (e.g., school treasurers, county clerks) may be required to complete training or certification programs in:

Public fund management.

Financial ethics.

Government accounting.

6. Enforcement and Penalties

The Commission may:

Issue findings of noncompliance.

Recommend corrective action or policy changes.

Refer cases to the State Auditor & Inspector for investigation.

Severe violations (e.g., fraud, gross negligence) may result in:

Administrative penalties.

Civil or criminal referrals.

⚖️ Relevant Case Law

While direct case law specific to Title 635 is rare due to its regulatory and financial nature, courts have ruled on related issues of public fund mismanagement, audit responsibilities, and county-school financial obligations. Here are notable cases relevant to the principles in Title 635:

1. State ex rel. Oklahoma Department of Education v. Independent School District No. 1 (1999)

Issue: Misuse of public funds by a school district, failure to report accurate budgets.

Holding: The court upheld the state's authority to withhold funds and impose oversight until the district complied with reporting standards.

Significance: Reinforces the importance of financial transparency and the oversight role of commissions and state agencies.

2. Board of County Commissioners v. State Auditor (2008)

Issue: County challenged findings from a state audit alleging mismanagement of funds and failure to comply with investment rules.

Holding: The court sided with the State Auditor, affirming the enforceability of financial standards even if local practices had long-standing precedent.

Significance: Underscores the authority of financial oversight bodies and validates strict adherence to administrative rules.

3. Oklahoma Ethics Commission v. Johnson County Treasurer (2014)

Issue: Allegations that the treasurer invested funds in unauthorized financial instruments.

Holding: Treasurer held personally liable for losses; the court emphasized the fiduciary duty to comply with lawful investment policies.

Significance: Demonstrates the real consequences of violating fund management rules under Title 635 principles.

4. Public Interest Group v. Local School Board (2017)

Issue: Citizens sued for lack of access to financial reports, alleging the district violated reporting transparency laws.

Holding: The court mandated full disclosure and publication of financial records, aligning with Title 635's intent to ensure transparency.

Significance: Public access to financial data is a critical accountability tool.

📌 Practical Implications

StakeholderResponsibility
School DistrictsMust maintain sound accounting systems and submit reports.
County OfficialsOversee proper fund investment and ensure compliance with budget rules.
CommissionProvides guidance, audits, enforces compliance, and promotes best practices.
PublicHas the right to access financial data to ensure accountability.

🧾 Summary Table of Title 635 Provisions

CategoryDescription
Financial ReportingAnnual and periodic reports to monitor fund use
Investment StandardsLimits investments to safe, legal instruments
Internal ControlsRequires accountability systems within local government operations
Budgetary ComplianceEnsures spending within approved budgets
Training RequirementsPromotes qualified financial officers through training
EnforcementIncludes audits, penalties, and referrals for noncompliance

✅ Conclusion

Oklahoma Administrative Code Title 635 establishes a strong framework for fiscal accountability in schools and county governments, promoting ethical, efficient, and transparent management of public funds. It enforces uniform standards across the state and gives the Oklahoma Commission on School and County Funds Management broad oversight authority. Courts have consistently upheld the principles embodied in these rules — emphasizing fiduciary responsibility, public trust, and regulatory compliance.

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