Not-for-Profit Organizations: Thinking Outside the Box

Transcription

1 Institute of Chartered Accountants of British Columbia Professional Development Course Not-for-Profit Organizations: Thinking Outside the Box Presented by: Bill Cox, CPA, CA David Geertz Brendan Burns, LL.B Rosanne Walters, CPA, CA, CBC COPYRIGHT All rights reserved. No part of this publication/course material may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means (photocopying, electronic, mechanical, recording or otherwise) without the prior written permission of the copyright holder and publisher. DISCLAIMER This course material deals with complex matters and may not apply to particular facts and circumstances. As well, the course material and references contained therein reflect laws and practices which are subject to change. For these reasons, the course material should not be relied upon as a substitute for specialized professional advice in connection with any particular matter. Although the course material has been carefully prepared, neither the Institute of Chartered Accountants of British Columbia, the course author and/or firm, nor any persons involved in the preparation and/or instruction of the material accepts legal responsibility for its contents or for any consequence arising from its use. Winter 2014

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3 CPA British Columbia Not for Profit Organizations Thinking Outside the Box! Bill Cox, CPA, CA Partner, BDO Canada LLP January 2014 Schedule and Speakers for the morning Bill Cox, BDO What s new with the CRA Outsourcing financial functions David Geertz, SoKap Social capital/fundraising Brendan Burns, Miller Thomson Community Contribution Companies Rosanne Wlt Walters Terhart, t BDO Fraud and Board governance Short wrap up out by 10:00am 1

4 NOT FOR PROFITS Canada Revenue Agency What s New? CRA Non Profit Organization Risk Identification Project...not much new 2

5 CRA Non Profit Organization Risk Identification Project Audit of 1440 NPOs Believed to be concern over profit in a nonprofit May lead to a need to use other structures Also concern over non profits that do not meet the definition of an NPO Higher level of revocation in recent years Need to be squeaky clean Other new issues with CRA and tax courts Mergers, amalgamations and consolidations Endowments, 10 year gifts, perpetual trusts Giving a gift back 3

6 Mergers, Amalgamations and Consolidation of charities New version of CRA publication CSP A21 which discusses mergers, amalgamations and consolidations Most important consideration: MUST INFORM CRA IN ADVANCE AND RECEIVE APPROVAL Endowments, 10 year gifts, Perpetual Trusts Real confusion over these terms Not really any such thing as 10 year gifts Lawyers and accountants that don t specialize in this area will have difficulty If you spend out of an endowment or trust this can be a breach of trust Your own words and actions can influence legal view if not good documentation Be careful, terms matter, check wording of all donation/gift/sponsorship agreements 4

7 Giving a gift back Prior to 2011, a gift with a string attached probably should not have been receipted until the condition satisfied 2011 CRA administrative changes allow for issue of tax receipt and return of gift in certain circumstances (but still should not be a planned event) Requires filing of information return (see next slide) Giving a gift back CRA Explanation A qualified donee that issued an official donation receipt and later returns donated property must file an information return with the CRA if the fair value of the property is greater than $50. The Information Return must be filed within 90 days after the property is returned. A copy of the Return must also be given to the donor. This provision applies whether the property is: The same property as donated Property that was identical to the donated property Or a substitute for the donated property 5

8 Giving a gift back Caution Always better to err on side of caution Could be adverse tax impact to donor Return of gifts can be viewed as a gift to a nonqualified donee if not handled 100% properly Best bet: add a clause that if project does not go ahead the funds will be used for...(other good cause/project at NPO). Better not to offer funds back. Notes 6

9 NOT FOR PROFITS TO IN HOUSE HOUSE OR OUT HOUSE HOUSE? That is the question! Bill Cox, CPA, CA January 2014 IN HOUSE OR OUT HOUSE? That is the question! Not for profits face many challenges: Maintainingvision purpose andhigh level focus Maintaining vision, purpose and high level focus Operating in an efficient and socially responsible manner Meeting all legal requirements and ethical standards Raising capital and spending revenues in responsible manner The in house vs. Out house question: When should functions be carried out in house and when is it better to outsource? No definitive answers or solutions. Just thoughts and ideas to keep in mind as you lead your organization to success 7

10 IN HOUSE OR OUT HOUSE? That is the question! FRAUD (a teaser Rosanne to expand on later) Drivers of fraud in small organizations Lack enough staff for appropriate segregation of duties Organizational leaders too busy to review their financial records Organizational leaders do not see the warning signs Reasons employees cite for stealing: Job dissatisfaction Need to provide for family Sense of entitlement (e.g. for long hours worked) Perceived unfair compensation IN HOUSE OR OUT HOUSE Management vs. Leadership As CEO Executive Director General Manager orwhatever As CEO, Executive Director, General Manager or whatever leadership title you go by, organizational leadership means: Making decisions that are good for the organization as a whole Being able to evaluate the talent that you have on the team Knowing the right questions to ask Knowing the right metrics to evaluate and recruit Making reasoned decisions based on quality financial information, rather than instinct or gut decisions 8

11 IN HOUSE OR OUT HOUSE The push to operate like a business Same pressures as for profit companies if not more! Economy Social Government And still find ways to fulfill your original mandate IN HOUSE OR OUT HOUSE Limited resources $$ and People Optimizing resources Hire the right people Internal full time, part time, occasional External advisors, consultants, service providers Retain the best people Best / most important asset Legal & government obligations Optimize time and skills (yours & others) How to make the most impact with limited time & attention Delegate internally, externally 9

12 IN HOUSE OR OUT HOUSE Rules of thumb Always remember When hiring outside consultants or service providers Experts are experts in their field But YOU know your business best Experts ADVISE. YOU make the decision. Be clear on expectations Responsibilities / scope of engagement gg Deliverables with associated timelines Costs fixed& variable Extras / Contingencies Reporting IN HOUSE OR OUT HOUSE Limited resources $$ and People When should you consider hiring a service provider? A financial service provider can help you A financial service provider can help you manage day to day accounting needs and financial statements control payables & receivables reconcile bank balances negotiate tax laws Help transform raw financial data into real business information free up time so you can focus on priorities and strategies that are essential to maximizing efficiencies and growing your business 10

13 IN HOUSE OR OUT HOUSE? What s out there in regard to bookkeeping, accounting, payroll and CFO services? Full disclosure there is a BDO cloud service called BDO outsourcing that is one of the options. Many/most of you will be aware of third party payroll providers, but true outsourcing takes it past just the calculations any payments but also the input to the system and the recording of the payments when made. There are packaged CFO services also available from other sources. Suggest compare some alternatives and see what seems right for your organization. Questions? 11

14 SoKap Simple. Social. Enterprise Social Capital aka SoKap The economic outcome resulting from leveraging social networks and accessing their Human, Physical and Financial Capital to provide benefit to a specific community group 12

15 Social Enterprise a business that is set up to drive revenue to community based initiatives 13

16 This is NOT simple! 14

17 Simple. Social. Enterprise SIMPLE fundraising i business management logistics consumer user experience reporting 15

18 Social benefit to community media distribution encourages buy local mentality jobs jobs jobs! Enterprise low cost growth capital for small businesses increases bottom line revenue from lowering outbound marketing costs vested interest from distribution partners who are social entrepreneurs. 16

19 h l d h Let technology do the heavy lifting 17

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22 Methodology crowdfunding, p2p finance, and microfinance crowdsourcing and volunteerism. distributed supply chain systems community value over shareholder value 20

23 David Geertz 21

24 Community Contribution Companies January 23, 2014 Presentation by Brendan Burns Community Contribution Companies Since July 29, 2013 a new category of company called Community Contribution Companies (CCCs or C3s) can be incorporated in B.C. 22

25 What is a C3? New corporate vehicle for social enterprises in B.C. Hybrid social enterprise structure Combines elements of a for-profit business with those of a non-share capital entity Similar to UK model of Community Interest Companies First hybrid social enterprise structure in Canada Unique Features of C3s 1. Must have a Community Purpose Community Purpose is broadly defined Includes the purpose of providing health, social, environmental, cultural, educational or other services Purpose must be beneficial to society at large or to a segment of society broader than the group of persons related to the C3 23

26 Unique Features of C3s (cont d) 1. Community Purpose (cont d) Doesn t need to be charitable Must be primary purpose of C3 Must be set out in the articles Unique Features of C3s (cont d) 2. Directors Must be a minimum of three directors Meant to provide greater accountability Directors must act with a view to the community purposes of the C3 No residency requirements for directors 24

27 Unique Features of C3s (cont d) 3. Dividends Must be approved by shareholders holding voting shares Total of all dividends in a year cannot exceed the total of: a) 40% of the C3s annual profits, and b) any unused dividend amounts from previous years. Unique Features of C3s (cont d) 3. Dividends (cont d) Exemption: no limits on dividends declared on classes of shares that can only be issued to qualified entities Qualified entities include: a community service cooperative a registered charity a qualified donee, as defined in section 149.1(1) of the Income Tax Act 25

28 Unique Features of C3s (cont d) 4. Transfer of Assets Prohibition on the transfer of assets, unless: It is for fair market value; It is to a qualified entity; OR It is in furtherance of the C3s purposes Unique Features of C3s (cont d) 5. Asset Lock on Dissolution On dissolution, the liquidator must, q distribute all or 60% of the C3s distributable assets to one or more qualified entities 26

29 Unique Features of C3s (cont d) 6. Reporting Must produce annual financial statements Must file normal annual corporate maintenance documents Must publish a community contribution report annually Unique Features of C3s (cont d) 6. Reporting (cont d) Community Contribution Report must disclose: a) description of how the C3s activities benefited society b) description of assets (including amounts) that were transferred during that year in furtherance of the C3s purposes c) details of any transfers of money or other assets with a fair market value over $10,000, including: i. The identity of transferee ii. The purpose of the transfer iii. The amount transferred 27

30 Unique Features of C3s (cont d) d) the remuneration and position held of each person who made more than $75,000 e) the financial statements f) the amount of dividends declared on each class of shares Community contribution report must be kept at C3s records office and posted on the C3s website (if it has one) Taxation of C3s C3s have no special tax treatment under the Income Tax Act C3s do not qualify as non-profit organizations under the Income Tax Act C3s will be subject to tax in the same manner as a regular company under the Income Tax Act 28

31 Taxation of C3s (cont d) C3s can donate to a registered charity and receive a tax receipt Speculation that provincial government will introduce an investment tax credit for investments in C3s Benefits of C3s Can operate anywhere in Canada by extraprovincial registration Brand recognition Customers Socially responsible investors Depends on uptake and traction 29

32 Potential Uses 1. Stand alone social purpose business Owned by one or more people p who want to do good and make money Can be a new business or could convert an existing business Potential Uses (cont d) 2. Subsidiary of a Charity or NPO Used by a charity to operate an unrelated business CRA has stated that where an NPO incorporates a C3 and holds shares of a taxable subsidiary, this will not, in itself, cause the NPO to lose its tax-exempt t status 30

33 Potential Uses (cont d) 3. Replacement Vehicle for an NPO If an NPO becomes too successful and is making a profit it will lose its tax-exempt status Could convert an NPO into a C3 VANCOUVER CALGARY EDMONTON SASKATOON REGINA LONDON KITCHENER WATERLOO GUELPH TORONTO MARKHAM MONTRÉAL 31

34 Important factors to consider when choosing board members and how to protect your NPO from financial irregularities Rosanne Walters Terhart, CA, CBV, CFE, Senior Manager January 2014 SPEAKER S BIOGRAPHY Rosanne Walters Terhart, CA, CBV, CFE, Senior Manager Rosanne is a Chartered Accountant, t Certified Fraud Examiner and Chartered Business Valuator. She has over 25 years experience in accounting, auditing and forensic investigations. Rosanne s practice focuses on forensic investigations addressing allegations of fraud, quantification of economic damages, business valuations, special purpose audits and financial consulting. rterhartbdo.ca Direct: Cathedral Place 925 West Georgia Street Vancouver, BC V6C 3L2 Tel: Fax: Rosanne has provided expert witness testimony for civil and criminal trials in the Supreme Court of British Columbia. She has also acted as a courtappointed special referee. Roseanne is the President of the Vancouver Chapter, Certified Fraud Examiners. She is also a frequent speaker on topics related to fraud for the Institute of Chartered Accountants of British Columbia, Continuing Legal Education, universities and other organizations. 32

35 NPO - BOD Outline Mandate and challenges of the NPO Board responsibilities Best practices for choosing a board Fraud in the NPO Environment How to protect your NPO Fraudster profile and red flags Types of schemes and prevention Case studies NPO - BOD NPO Mandate - Stayed focused on the organization s mission - Manage funds effectively 33

36 NPO - BOD NPO Challenges - Environment of trust - Failure to include individuals with financial oversight expertise on the board - Failure to devote adequate resource to financial management - Lack of proper controls - Existence of nonreciprocal transactions (contributions) that are much easier to steal than other forms of income - Public perception is so important for continuity of organization NPO - BOD Board Responsibilities Carry out the mission - Policy: Set organizational policies and ensure compliance - Planning: Establish and implement short time and long term plans - Public relations: Concern for public image by composition of board and communication to the community 34

37 NPO - BOD Board Responsibilities Manage funds effectively - Budgeting and financial planning - Monitoring revenue and expenses in light of the budget - Ensuring adequate cash flow and other resources for the organization s programs - Safeguarding the organization s resources - Management of financial risk - Building appropriate reserves - Compliance with requirement imposed by funding sources NPO - BOD Choosing board members Step 1 Understanding of mission Ensure the potential candidate has an understanding of the needs of the NPO s clients and the resources to provide for those needs. Have they done their research? 35

38 NPO - BOD Choosing board members Step 2 Share the passion The candidate must believe in this mandate and be committed to effectively carry out the mandate of the organization. How have they shown a passion for the organization? ation? NPO - BOD Choosing board members Step 3 Willing to serve Ensure the candidate is interested in serving the organization and not for other reasons. Other reasons could be fear to disappoint if being asked, prestige or other personal benefits. Why do they want to serve? 36

39 NPO - BOD Choosing board members Step 4 Know the expectations Select individuals who know what is expected of them and are prepared for the time commitment required. Time commitments can include attendance at meeting, preparation for meetings, NPO activities ities and committee meetings. Ask candidate to estimate the time they can dedicate and assess if this is sufficient. NPO - BOD Choosing board members Step 5 Community Involvement Ensure the potential candidate is willing to go out into the community and actively persuade others to support the work of your organization. In what ways has the board member demonstrated community involvement in other ways? 37

40 NPO - BOD Choosing board members Step 6 Skills and diversity Consider the skills and experience each potential member can bring to the organization. Ensure the board members compliment each other and are willing to support each other on a common mission. Team players. Consider mix of age and experience and transitioning of responsibilities. Ask candidate to describe skills and experience that they are bringing to the organization. NPO - BOD Choosing board members Step 7 Service individuals Consider selecting individuals who are service professionals. They bring knowledge and experience to the board. But remember that they are their to assist in the governance of the organization and not to provide services for free. 38

41 NPO - BOD Choosing board members Step 8 Conflict of interest Consider potential director s relationship with management. Ensure they do not have a conflict of interest concerning management and key personnel. Consider potential director s relationship with customers and suppliers Must be willing to act prudently and in the best interests of the organization while fulfilling their responsibilities. Ask what relationship exist. NPO - BOD Choosing board members Step 9 Due diligence Perform proper due diligence to ensure the potential candidate has strong values and personal integrity. These values help members make decisions that are best for the organization ation and not for the financial gain of themselves or others. 39

42 NPO - BOD Choosing board members Step 10 Financial skill or commitment Ensure at least one individual on the board has some financial experience and/or knowledge. Ensure the board as a whole is willing to take on this responsibility Ensure the candidate understands their financial responsibilities NPO - BOD Is fraud happening in the NPO environment? - Statistics, ACFE 2012 Report to the Nation - Yes, estimate is that 5% of revenues are lost due to fraud - Frequency, estimate 7/10 organizations - Median fraud scheme is $150,000 - Schemes lasts on average 18 months or longer - Over 50% of case of no recovery of losses 40

43 NPO - BOD Is fraud happening in the NPO environment? - Frequently organizations believe they are protected by a few good controls Two signatures on cheques Review of supporting documentation before signing cheques Financial statement audit or review - Not enough NPO - BOD Preventative Measures What can the BOD do Choose right director who will be watchful and aware Take financial responsibility Do budgets and compare to actual results on a timely basis Do zero based budgets Look at actual bank statements and see where money went Restrict access to bank accounts and cheques Do not rely on the financial summaries prepared internally Be aware and involved 41

44 NPO - BOD Victim Organizations Small organizations are vulnerable (fewer than 100 employees) All sort of industries and types of organizations Fraud can occur is all departments of the organization NPO - BOD Who commits fraud against organizations? - Variety of perpetrators including: - Inside: employees/volunteers, management, officers and directors - Outside: outsourced functions, vendors, donors, members or program participants, competitors. 42

45 NPO - BOD Perpetrators - Statistics Insiders Position Frequency Median Losses Employee 41.6% $ 60,000 Manager 37.5% $182,000 Owner / Executive 17.6% $573,000 Losses rise with level of responsibility and authority within the organization NPO - BOD Perpetrator profile Equal chance of male or female More than 50% have tenure over 6 years Educated, most frequently has bachelors degrees No criminal history 43

46 NPO- BOD The Fraud Triangle OPPORTUNITY Weak internal controls or ability to override controls FRAUD NEED / PRESSURE Employee needs funds for lifestyle or habits RATIONALIZATION Employee feels funds are deserved for various reasons NPO - BOD Who is the fraudster? Rule 10% of employees will never steal, no matter what 10% of employees will steal at any opportunity 80% of employees will go either way depending on how they rationalize a particular opportunity Where do you fit in? 44

47 NPO - BOD Behaviour Red Flags Living beyond means 35.6% Financial difficulties 27.1% Unusually close relationship with vendor or customer 19.2% Control issues (unwillingness to share duties) 18.2% Wheeler-dealer attitude 14.8% Divorce/family problems 14.8% Defensive behaviour 12.6% NPO- BOD Types of Fraud Three Major Classifications i Scheme Type Frequency Median Losses Asset Misappropriation 87% $ 120,000 Corruption 33% $ 250,000 Financial Statement Fraud 8% $1,000,000 45

48 NPO - BOD Asset Misappropriation Schemes 87% of cases, $120,000 losses % of Cases Median Loss ($) Fraudulent Billing ,000 Stealing Non-Cash Assets 17 58,000 Cash Skimming 15 58,000 Expense Account Abuse 13 26,000 Cheque Tampering ,000 Stealing Cash on Hand 12 20,000 Payroll Schemes 9 50,000 NPO - BOD Most Frequent Scheme Corruption and billing schemes posed the greatest risk, more than 50% of the cases of fraud in Canada 46

49 NPO - BOD Asset Misappropriation Billing Schemes Organization pays for services or items that it does not need Accomplished by: - Setting up sham company - Purchasing unnecessary items or services - Purchasing items of personal nature NPO - BOD Asset Misappropriation Billing Schemes Prevention Zero-based budgeting Regular scrutiny of budget vs. actual Consider source of the actual results presented Check actual expenditures to source documents Review of bank statement and cancelled cheques Periodic review of how expenditures are generally used in the organization Randomly pick an expenditure and see how it is used 47

50 NPO - BOD Corruption Corruption occurs in 33% of cases; losses $250,000 Employees use their influence in a way that violates their duty to employers in order to obtain a benefit - Receive or offer bribes - Accept or extort illegal payments - Engage in conflicts of interest Transactions may not be on the books, so internal controls not effective NPO - BOD Corruption Prevention Establish code of conduct with specific expectations, state consequences Annual sign off for employees Be aware of relationships with customers and suppliers Occasional confirmation with customers / suppliers Question why certain suppliers are used Know who the suppliers are Perform proper due diligence of suppliers 48

51 NPO - BOD Asset Misappropriation Cheque Tampering Forged maker Forged endorsements Altered payee or amounts after cheque is signed NPO - BOD Asset Misappropriation Cheque Tampering Prevention Proper security over unused cheques Proper security of mail procedures after cheques are signed Segregation of duties, handling cheques should not enter accounting entries Bank reconciliation procedure to scrutinize all cheques periodically Review cheques after they have cleared the bank for payees, amounts and signatures 49

52 EMPLOYEE FRAUD Asset Misappropriation Cash Skimming Involves the taking of cash before it is entered in books Occurs in organizations where cash is used for payment EMPLOYEE FRAUD Asset Misappropriation Cash Skimming Prevention Generally will be detected if proper cash and transaction reconciliation procedures are performed Have more that one person involved with handling cash Receipt giving separate from cash handling Skimming prevented by deterrent controls like video surveillance Surprise audits Be aware of results of fund-raising activities Compare to budget Compare to statistics and expectation 50

53 NPO - BOD Detection - Statistics Tips 43.3% Good oversight 14.6% Internal audit 14.4% By accident 7.0% Account reconciliation 4.8% Document examination 4.1% External audit 3.3% NPO - BOD General Preventative Measures Internal and external audit functions Maintain proper internal controls Implement good accounting system Effective management review of reports Surprise audits Reporting hotlines Be aware and ask questions 51

54 NPO - BOD Preventative Measures Internal Controls Separate functions no employee should have control over an entire financial transaction Where segregation isn t possible, use compensating controls Look at bank statements and all cancelled cheques, wire transfers and debits for anything unusual More effective controls needed at the senior levels who can override controls NPO - BOD Preventative Measures - Employees Code of conduct Proper employee screening Proper supervision and review is critical Job rotation / mandatory vacations Employee support programs Video surveillance, perception of detection Fraud training Consider insuring against dishonesty - fidelity insurance 52

55 EMPLOYEE FRAUD Case Studies How was fraud detected? What was scheme? How were transactions booked to cover fraud? Were there any red flags? Could it have been prevented? What did organization i do once it was detected? d? What was resolution? EMPLOYEE FRAUD Case Study #1 Best Friends Jailed Organization Non-Profit Organization Finance Manager in charge of office and administration Fraud Finance Manager embezzled $300,000 per year for two years Internal Controls Good controls, all cheques signed by two designated board members Organization was audited 53

56 EMPLOYEE FRAUD Case Study #1 Best Friends Jailed How was it detected? Management review/by accident, director looking up information in general ledger and noticed unusual payments Type of Scheme? Fraudulent Disbursement - Finance Manager created weakness in internal controls - Given authorization to electronically transfer funds between bank accounts - Instead wired funds to friend s bank account EMPLOYEE FRAUD Case Study #1 Best Friends Jailed How booked? Consulting expenses Red Flags? Friend frequently hanging around organization Fi Friend was only person paid as consultant Friend s invoices lacked detail Journal entries booked at year end 54

57 EMPLOYEE FRAUD Case Study #1 Best Friends Jailed Prevention? Give employee opportunity to report - Finance Manager living beyond means - employees concerned about friends relationship with Finance Manager Board of directors did not question consulting expenses (i.e. who was being paid and for what?) EMPLOYEE FRAUD Case Study #1 Best Friends Jailed What did organization do? Contacted police Police seized Finance Manager s computer and documents Police recommended charges Crown Counsel hired forensic accountant No chance of civil il recovery money gone Both individuals pleaded guilty after forensic report prepared 55

58 EMPLOYEE FRAUD Case Study #2 Bookkeeper Steals from the Vulnerable Organization Non-Profit Organization for Elderly Fraud Bookkeeper embezzles $200,000 over three years Internal Controls Two directors sign each cheque Organization reviewed, not audited EMPLOYEE FRAUD Case Study # 2 Bookkeeper Steals from the Vulnerable How was fraud detected? Tip from outside organization - bank manager contacted president to inform him that all trust and general funds were gone Fraud scheme? Cheque Tampering - Bookkeeper added $1,000 to each paycheque Fraudulent Disbursements - Bookkeeper forged signatures of directors, wrote cheques to herself 56

59 EMPLOYEE FRAUD Case Study #2 Bookkeeper Steals from the Vulnerable How were transactions booked? Amounts spread to various expense accounts Red flags? Expenses kept increasing but organization activities did not change Reviewer commented that bank reconciliations and supplier reconciliations were not performed on a timely basis Accounts payable showed large unpaid balances Amounts of cheques written to bookkeeper were round amounts and cheque numbers were out of sequence EMPLOYEE FRAUD Case Study #2 Bookkeeper Steals from the Vulnerable Prevention? BOD did not question increase in expenses and why organization was facing hardship BOD did not consider compensating controls like occasional review of bank statement and cancelled cheques directly from bank BOD placed much trust and reliance in bookkeeper 57

60 EMPLOYEE FRAUD Case Study #2 Bookkeeper Steals from the Vulnerable What did organization do? Bookkeeper was let go Hired local accountant to put together evidence Civil proceedings thrown out because evidence did not meet court standards Forensic accountant became involved Re-submitted for civil proceedings, civil judgement, no recovery Proceeded to criminal proceedings Bookkeeper received 18 months jail time Organization lost historic building as a result of the embezzlement QUESTIONS? 58