FAC Explorer

Audit 308212

FY End
2022-12-31
Total Expended
$1.58M
Findings
6
Programs
3
Organization: Boys & Girls Clubs of Central Nh INC (NH)
Year: 2022 Accepted: 2024-06-06
Auditor: Nathan Wechsler & Company P A

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
400096 2022-002 Significant Deficiency Yes A
400097 2022-003 Material Weakness Yes L
400098 2022-001 Material Weakness Yes P
976538 2022-002 Significant Deficiency Yes A
976539 2022-003 Material Weakness Yes L
976540 2022-001 Material Weakness Yes P

Programs

ALN Program Spent Major Findings
93.575 Child Care and Development Block Grant $1.44M Yes 3
10.555 National School Lunch Program $138,516 - 0
94.021 Volunteer Generation Fund $9,458 - 0

Contacts

Name Title Type
J77GVP4BPRP2 Wendy Behling Auditee
6032241061 Callie Chase Auditor
No contacts on file

Notes to SEFA

Title: Note 1. Basis of Presentation Accounting Policies: Note 1. Basis of Presentation The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal grant activity of Boys and Girls Clubs of Central New Hampshire, Inc. under the programs of the federal government for the year ended December 31, 2022. The information in this schedule is presented in accordance with the requirements of the Office of Management and Budget (OMB) Uniform Guidance. Because the Schedule presents only a selected portion of the operations of Boys and Girls Clubs of Central New Hampshire, Inc., it is not intended to and does not present the financial position, results of operations or cash flows of Boys and Girls Clubs of Central New Hampshire, Inc. Note 2. Basis of Accounting Expenditures reported on the Schedule are presented on the same basis of accounting as Boys and Girls Clubs of Central New Hampshire, Inc.’s financial statements. Boys and Girls Clubs of Central New Hampshire, Inc. uses the accrual basis of accounting. Expenditures represent only the federally funded portions of the program. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Note 3. Program Costs The amounts shown as current year expenditures represent only the federal grant portion of the program costs. Entire program costs could be more than shown. Such expenditures are recognized following, as applicable, the cost principles in the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements, wherein certain types of expenditures are not allowable or are limited to reimbursement. Note 4. Major Programs In accordance with the OMB Uniform Guidance, major programs are determined using a risk-based approach. Programs in the accompanying Schedule are determined by the independent auditor to be a major program. Note 5. Indirect Cost Rate The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. Note 6. Subrecipients No amounts expended and reported with in the Schedule of Federal Awards were passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal grant activity of Boys and Girls Clubs of Central New Hampshire, Inc. under the programs of the federal government for the year ended December 31, 2022. The information in this schedule is presented in accordance with the requirements of the Office of Management and Budget (OMB) Uniform Guidance. Because the Schedule presents only a selected portion of the operations of Boys and Girls Clubs of Central New Hampshire, Inc., it is not intended to and does not present the financial position, results of operations or cash flows of Boys and Girls Clubs of Central New Hampshire, Inc.
Title: Note 2. Basis of Accounting Accounting Policies: Note 1. Basis of Presentation The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal grant activity of Boys and Girls Clubs of Central New Hampshire, Inc. under the programs of the federal government for the year ended December 31, 2022. The information in this schedule is presented in accordance with the requirements of the Office of Management and Budget (OMB) Uniform Guidance. Because the Schedule presents only a selected portion of the operations of Boys and Girls Clubs of Central New Hampshire, Inc., it is not intended to and does not present the financial position, results of operations or cash flows of Boys and Girls Clubs of Central New Hampshire, Inc. Note 2. Basis of Accounting Expenditures reported on the Schedule are presented on the same basis of accounting as Boys and Girls Clubs of Central New Hampshire, Inc.’s financial statements. Boys and Girls Clubs of Central New Hampshire, Inc. uses the accrual basis of accounting. Expenditures represent only the federally funded portions of the program. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Note 3. Program Costs The amounts shown as current year expenditures represent only the federal grant portion of the program costs. Entire program costs could be more than shown. Such expenditures are recognized following, as applicable, the cost principles in the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements, wherein certain types of expenditures are not allowable or are limited to reimbursement. Note 4. Major Programs In accordance with the OMB Uniform Guidance, major programs are determined using a risk-based approach. Programs in the accompanying Schedule are determined by the independent auditor to be a major program. Note 5. Indirect Cost Rate The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. Note 6. Subrecipients No amounts expended and reported with in the Schedule of Federal Awards were passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. Expenditures reported on the Schedule are presented on the same basis of accounting as Boys and Girls Clubs of Central New Hampshire, Inc.’s financial statements. Boys and Girls Clubs of Central New Hampshire, Inc. uses the accrual basis of accounting. Expenditures represent only the federally funded portions of the program. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements.
Title: Note 3. Program Costs Accounting Policies: Note 1. Basis of Presentation The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal grant activity of Boys and Girls Clubs of Central New Hampshire, Inc. under the programs of the federal government for the year ended December 31, 2022. The information in this schedule is presented in accordance with the requirements of the Office of Management and Budget (OMB) Uniform Guidance. Because the Schedule presents only a selected portion of the operations of Boys and Girls Clubs of Central New Hampshire, Inc., it is not intended to and does not present the financial position, results of operations or cash flows of Boys and Girls Clubs of Central New Hampshire, Inc. Note 2. Basis of Accounting Expenditures reported on the Schedule are presented on the same basis of accounting as Boys and Girls Clubs of Central New Hampshire, Inc.’s financial statements. Boys and Girls Clubs of Central New Hampshire, Inc. uses the accrual basis of accounting. Expenditures represent only the federally funded portions of the program. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Note 3. Program Costs The amounts shown as current year expenditures represent only the federal grant portion of the program costs. Entire program costs could be more than shown. Such expenditures are recognized following, as applicable, the cost principles in the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements, wherein certain types of expenditures are not allowable or are limited to reimbursement. Note 4. Major Programs In accordance with the OMB Uniform Guidance, major programs are determined using a risk-based approach. Programs in the accompanying Schedule are determined by the independent auditor to be a major program. Note 5. Indirect Cost Rate The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. Note 6. Subrecipients No amounts expended and reported with in the Schedule of Federal Awards were passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. The amounts shown as current year expenditures represent only the federal grant portion of the program costs. Entire program costs could be more than shown. Such expenditures are recognized following, as applicable, the cost principles in the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements, wherein certain types of expenditures are not allowable or are limited to reimbursement.
Title: Note 4. Major Programs Accounting Policies: Note 1. Basis of Presentation The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal grant activity of Boys and Girls Clubs of Central New Hampshire, Inc. under the programs of the federal government for the year ended December 31, 2022. The information in this schedule is presented in accordance with the requirements of the Office of Management and Budget (OMB) Uniform Guidance. Because the Schedule presents only a selected portion of the operations of Boys and Girls Clubs of Central New Hampshire, Inc., it is not intended to and does not present the financial position, results of operations or cash flows of Boys and Girls Clubs of Central New Hampshire, Inc. Note 2. Basis of Accounting Expenditures reported on the Schedule are presented on the same basis of accounting as Boys and Girls Clubs of Central New Hampshire, Inc.’s financial statements. Boys and Girls Clubs of Central New Hampshire, Inc. uses the accrual basis of accounting. Expenditures represent only the federally funded portions of the program. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Note 3. Program Costs The amounts shown as current year expenditures represent only the federal grant portion of the program costs. Entire program costs could be more than shown. Such expenditures are recognized following, as applicable, the cost principles in the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements, wherein certain types of expenditures are not allowable or are limited to reimbursement. Note 4. Major Programs In accordance with the OMB Uniform Guidance, major programs are determined using a risk-based approach. Programs in the accompanying Schedule are determined by the independent auditor to be a major program. Note 5. Indirect Cost Rate The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. Note 6. Subrecipients No amounts expended and reported with in the Schedule of Federal Awards were passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. In accordance with the OMB Uniform Guidance, major programs are determined using a risk-based approach. Programs in the accompanying Schedule are determined by the independent auditor to be a major program.
Title: Note 5. Indirect Cost Rate Accounting Policies: Note 1. Basis of Presentation The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal grant activity of Boys and Girls Clubs of Central New Hampshire, Inc. under the programs of the federal government for the year ended December 31, 2022. The information in this schedule is presented in accordance with the requirements of the Office of Management and Budget (OMB) Uniform Guidance. Because the Schedule presents only a selected portion of the operations of Boys and Girls Clubs of Central New Hampshire, Inc., it is not intended to and does not present the financial position, results of operations or cash flows of Boys and Girls Clubs of Central New Hampshire, Inc. Note 2. Basis of Accounting Expenditures reported on the Schedule are presented on the same basis of accounting as Boys and Girls Clubs of Central New Hampshire, Inc.’s financial statements. Boys and Girls Clubs of Central New Hampshire, Inc. uses the accrual basis of accounting. Expenditures represent only the federally funded portions of the program. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Note 3. Program Costs The amounts shown as current year expenditures represent only the federal grant portion of the program costs. Entire program costs could be more than shown. Such expenditures are recognized following, as applicable, the cost principles in the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements, wherein certain types of expenditures are not allowable or are limited to reimbursement. Note 4. Major Programs In accordance with the OMB Uniform Guidance, major programs are determined using a risk-based approach. Programs in the accompanying Schedule are determined by the independent auditor to be a major program. Note 5. Indirect Cost Rate The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. Note 6. Subrecipients No amounts expended and reported with in the Schedule of Federal Awards were passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414.
Title: Note 6. Subrecipients Accounting Policies: Note 1. Basis of Presentation The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal grant activity of Boys and Girls Clubs of Central New Hampshire, Inc. under the programs of the federal government for the year ended December 31, 2022. The information in this schedule is presented in accordance with the requirements of the Office of Management and Budget (OMB) Uniform Guidance. Because the Schedule presents only a selected portion of the operations of Boys and Girls Clubs of Central New Hampshire, Inc., it is not intended to and does not present the financial position, results of operations or cash flows of Boys and Girls Clubs of Central New Hampshire, Inc. Note 2. Basis of Accounting Expenditures reported on the Schedule are presented on the same basis of accounting as Boys and Girls Clubs of Central New Hampshire, Inc.’s financial statements. Boys and Girls Clubs of Central New Hampshire, Inc. uses the accrual basis of accounting. Expenditures represent only the federally funded portions of the program. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Note 3. Program Costs The amounts shown as current year expenditures represent only the federal grant portion of the program costs. Entire program costs could be more than shown. Such expenditures are recognized following, as applicable, the cost principles in the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, Audit Requirements, wherein certain types of expenditures are not allowable or are limited to reimbursement. Note 4. Major Programs In accordance with the OMB Uniform Guidance, major programs are determined using a risk-based approach. Programs in the accompanying Schedule are determined by the independent auditor to be a major program. Note 5. Indirect Cost Rate The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. Note 6. Subrecipients No amounts expended and reported with in the Schedule of Federal Awards were passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The amount expended does not include any indirect costs. Boys and Girls Clubs of Central New Hampshire, Inc. did not elect to use the 10% de minimis indirect cost rate as allowed in the Uniform Guidance, section 414. No amounts expended and reported with in the Schedule of Federal Awards were passed through to subrecipients.

Finding Details

Finding 2022-002
Federal Agency: U.S. Department of Health and Human Services Cluster Name: Child Care and Development Fund Cluster Program Year: 2022 Assistance Listing Number: 93.575 Compliance: Activities Allowed and Unallowed and Allowable Costs/Cost Principles Finding Type: Significant deficiency in internal controls over compliance Criteria: Management is responsible for maintaining adequate records for salaries charged to federal awards that accurately reflect the work performed. These records must also support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award or on a Federal award and non-Federal award. Condition: During compliance testing, it was noted that no adequate time and effort documentation was maintained for salaried employees being charged to the Federal awards. Context: Of a statical sample of payroll, it was noted that salaried employees who do work within more than one department did not have a distribution of their hours and pay allocated to the different departments included on their timecards. For employees who work solely in one department also lacked appropriate time and effort documentation. Cause of condition: The Club’s current controls in place were not appropriate to address the compliance requirement. Effect of Condition: As a result of this condition, the Club’s expenditures charged to the federal grant for salaries lacked adequate compliance documentation. Recommendation: It is recommended that the Club maintain adequate records for salaries charged to federal awards, such as signed timesheets with allocation amounts included or semi-annual certification for employees working solely on one federal program. View of Responsible Officials and Planned Corrective Action: The nature of this funding was general operating support with no specified concrete deliverable per the grantor (State of New Hampshire). In accordance with prior year guidance on grant compliance and the grantor’s guidance to the Club stating personnel costs were an allowable use of funds, the Club received quarterly approvals from management and/or supervisors for the allocation of expense to the grant. Employees and supervisors approve weekly timecards and total hours paid without specification as the source of funds. The Club will provide an employee/supervisor certification in FY2023. Planned Implementation Date of Corrective Action: Fiscal year 2023 and ongoing Person Responsible for Corrective Action: Kathy Woodfin, Finance Director
Finding 2022-003
Federal Agency: U.S. Department of Health and Human Services Cluster Name: Child Care and Development Fund Cluster Program Year: 2022 Assistance Listing Number: 93.575 Compliance: Reporting Finding Type: Material weakness in internal controls over compliance Criteria: Management is responsible for submitting timely, accurate reporting based on the terms of the grant agreement. Condition: During compliance testing it was noted that final reporting was not accurate. Context: One final report for the federal award did not match supporting documentation. Cause of condition: Grant reporting was prepared by a new employee who was unaware of prior year expenditure categories. Effect of Condition: As of a resulted of this condition, the Club’s required reporting was misstated. Recommendation: It is recommended that a more thorough review of the prepared final reports is done prior to submission. View of Responsible Officials and Planned Corrective Action: A new employee prepared the final grant reporting to the grantor (State of NH) who had no knowledge or participation in the FY21 audit. In FY21 the auditors had tested the multi-year grant, and the Club did not clearly label the most up-to-date and final audited files, and incomplete information was used for preparation of the final report. The Club has engaged an IT consultant to improve its technology. Additionally, the finance team will also institute best practices for digital file management. Planned Implementation Date of Corrective Action: Ongoing Person Responsible for Corrective Action: Kathy Woodfin, Finance Director
Finding 2022-001
Finding Type: Material weakness in internal controls over financial reporting. Criteria: The Club is required to prepare financial statements in accordance with generally accepted accounting principles (GAAP). This the responsibility of the Club’s management. The preparation of the financial statements in accordance with GAAP requires internal controls over both maintaining internal books and records and reporting the external financial statements and the related footnotes. Conditions and context: The current staffing of the Club does not allow the Club to have an internal control system in place designed to provide for the preparation of the financials and related footnotes being audited. The Club requested that the external auditors draft the financial statements and accompanying notes as a result. Cause of condition: Due to the cost and other considerations, the Club has requested that their auditor’s draft the financial statement and related footnotes. Effect of Condition: As a result of this condition, the Club lacks internal controls over the preparation of the financial statements in accordance with GAAP, and instead relied, in part, on its external auditors for assistance with this task. Recommendation: It is recommended that the Club ensures that members of management responsible for the accounting and reporting function receive appropriate training to ensure they are able to apply generally accepted accounting principals in review and taking responsibility over the financial statement and footnotes prepared by the external auditors. We also recommend hiring additional experienced staff to oversee the accounting and reporting function. View of Responsible Officials and Planned Corrective Action: The Club has evaluated the cost vs. benefit of establishing internal controls over the preparation of financials statements in accordance with GAAP and determined that it is in the best interest of the Club to outsource this task to its external auditors, and to carefully review the draft financial statements and notes prior to approving them and accepting responsibility for their content and presentation. Planned Implementation Date of Corrective Action: On-going. The Club will continue to evaluate the cost vs. benefit of having someone in management capable of preparation and/or of the financial statements in accordance with GAAP. Person Responsible for Corrective Action: Chris Emond, Chief Executive Officer
Finding 2022-002
Federal Agency: U.S. Department of Health and Human Services Cluster Name: Child Care and Development Fund Cluster Program Year: 2022 Assistance Listing Number: 93.575 Compliance: Activities Allowed and Unallowed and Allowable Costs/Cost Principles Finding Type: Significant deficiency in internal controls over compliance Criteria: Management is responsible for maintaining adequate records for salaries charged to federal awards that accurately reflect the work performed. These records must also support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award or on a Federal award and non-Federal award. Condition: During compliance testing, it was noted that no adequate time and effort documentation was maintained for salaried employees being charged to the Federal awards. Context: Of a statical sample of payroll, it was noted that salaried employees who do work within more than one department did not have a distribution of their hours and pay allocated to the different departments included on their timecards. For employees who work solely in one department also lacked appropriate time and effort documentation. Cause of condition: The Club’s current controls in place were not appropriate to address the compliance requirement. Effect of Condition: As a result of this condition, the Club’s expenditures charged to the federal grant for salaries lacked adequate compliance documentation. Recommendation: It is recommended that the Club maintain adequate records for salaries charged to federal awards, such as signed timesheets with allocation amounts included or semi-annual certification for employees working solely on one federal program. View of Responsible Officials and Planned Corrective Action: The nature of this funding was general operating support with no specified concrete deliverable per the grantor (State of New Hampshire). In accordance with prior year guidance on grant compliance and the grantor’s guidance to the Club stating personnel costs were an allowable use of funds, the Club received quarterly approvals from management and/or supervisors for the allocation of expense to the grant. Employees and supervisors approve weekly timecards and total hours paid without specification as the source of funds. The Club will provide an employee/supervisor certification in FY2023. Planned Implementation Date of Corrective Action: Fiscal year 2023 and ongoing Person Responsible for Corrective Action: Kathy Woodfin, Finance Director
Finding 2022-003
Federal Agency: U.S. Department of Health and Human Services Cluster Name: Child Care and Development Fund Cluster Program Year: 2022 Assistance Listing Number: 93.575 Compliance: Reporting Finding Type: Material weakness in internal controls over compliance Criteria: Management is responsible for submitting timely, accurate reporting based on the terms of the grant agreement. Condition: During compliance testing it was noted that final reporting was not accurate. Context: One final report for the federal award did not match supporting documentation. Cause of condition: Grant reporting was prepared by a new employee who was unaware of prior year expenditure categories. Effect of Condition: As of a resulted of this condition, the Club’s required reporting was misstated. Recommendation: It is recommended that a more thorough review of the prepared final reports is done prior to submission. View of Responsible Officials and Planned Corrective Action: A new employee prepared the final grant reporting to the grantor (State of NH) who had no knowledge or participation in the FY21 audit. In FY21 the auditors had tested the multi-year grant, and the Club did not clearly label the most up-to-date and final audited files, and incomplete information was used for preparation of the final report. The Club has engaged an IT consultant to improve its technology. Additionally, the finance team will also institute best practices for digital file management. Planned Implementation Date of Corrective Action: Ongoing Person Responsible for Corrective Action: Kathy Woodfin, Finance Director
Finding 2022-001
Finding Type: Material weakness in internal controls over financial reporting. Criteria: The Club is required to prepare financial statements in accordance with generally accepted accounting principles (GAAP). This the responsibility of the Club’s management. The preparation of the financial statements in accordance with GAAP requires internal controls over both maintaining internal books and records and reporting the external financial statements and the related footnotes. Conditions and context: The current staffing of the Club does not allow the Club to have an internal control system in place designed to provide for the preparation of the financials and related footnotes being audited. The Club requested that the external auditors draft the financial statements and accompanying notes as a result. Cause of condition: Due to the cost and other considerations, the Club has requested that their auditor’s draft the financial statement and related footnotes. Effect of Condition: As a result of this condition, the Club lacks internal controls over the preparation of the financial statements in accordance with GAAP, and instead relied, in part, on its external auditors for assistance with this task. Recommendation: It is recommended that the Club ensures that members of management responsible for the accounting and reporting function receive appropriate training to ensure they are able to apply generally accepted accounting principals in review and taking responsibility over the financial statement and footnotes prepared by the external auditors. We also recommend hiring additional experienced staff to oversee the accounting and reporting function. View of Responsible Officials and Planned Corrective Action: The Club has evaluated the cost vs. benefit of establishing internal controls over the preparation of financials statements in accordance with GAAP and determined that it is in the best interest of the Club to outsource this task to its external auditors, and to carefully review the draft financial statements and notes prior to approving them and accepting responsibility for their content and presentation. Planned Implementation Date of Corrective Action: On-going. The Club will continue to evaluate the cost vs. benefit of having someone in management capable of preparation and/or of the financial statements in accordance with GAAP. Person Responsible for Corrective Action: Chris Emond, Chief Executive Officer