POLICES: FISCAL SERVICES

ABOUT

The Archdiocesan policies present on this site are the norms and directives of the Archdiocese of Baltimore and are designed to be consistent with its mission. All internal operating procedures practices, rules and guidelines of individual schools, parishes and agencies must be consistent with these policies and may not contradict them.

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SACRAMENTS


100 INTERNAL CONTROL PROCEDURES


The following Internal Control Policies apply to all parishes and schools, including Archdiocesan, Collaborative (ACS), and Inter-parish/Regional schools.


101 BUDGETING


The following policy explains the budget preparation and review process for parishes and schools.

101.1 Annual Budget Required:

All parishes and schools shall prepare and submit an annual “line-by-line” budget to Fiscal Services.

Procedure:

A) The budget should describe in financial terms how the parish or school plans to allocate its resources during the coming fiscal year (July 1 to June 30).

B) The budget should be submitted to Fiscal Services of the Archdiocese of Baltimore as part of the annual financial report due August 15th of each year.

C) Both the final accounting for the year ended and the current budget shall be submitted via the Archdiocesan financial reporting website.

D) In creating the budget, the parish/school should review previous years’ financial records to determine its financial status and to identify income and expense trends.

101.2 Collaborative Process:

The budget should be prepared in a collaborative process.

Procedure:

A) The budget should be prepared by some combination of the pastor/PLD, principal (in the case of a school), appropriate staff, and the parish or school finance committee.

B) The individuals in charge of different programs or ministries at a parish/school should submit a projection of their expenses and a careful estimate of possible revenues to assist in creation of the parish/school budget.

101.3 Budget Approval:

In the case of a parish or parish school, the budget is approved by the pastor. In the case of an incorporated school, the budget is approved by the Board of Directors (School Board).

Procedure:

A) After initial preparation, the finance committee should present the budget to the pastoral council for review.

B) In the case of a parish or parish school, the parish council should review and, if acceptable, recommend the budget to the pastor. The budget should then be reviewed and given final approval by the pastor.

C) In the case of an incorporated school, the School Board should review and, if acceptable, approve the budget.

101.4 Comparison – Budgeted to Actual:

On a monthly basis, the budget should be compared to actual results.

Procedure:

A) Actual results should be compared to the budget monthly and reviewed with the finance committee, the pastor/pld and/or principal at least quarterly.

B) Variations between the budget and actual results should be researched, documented and communicated to those responsible for the variations.

C) Quarterly budget reports shall also be made via the Archdiocesan financial reporting website.


102 GENERAL LEDGER & FINANCIAL REPORTING


The following section explains various accounting and internal control procedures as they relate to parishes and schools within the Archdiocese of Baltimore. More explanation and information on the components of internal control is available here.

If a parish or school suffers a loss and did not follow the required internal controls, the parish/school will be assessed a higher deductible and risks denial of its insurance claim.

102.1 General Ledger:

All parishes and schools shall maintain a computerized general ledger.

Procedure:

A) The general ledger should contain a complete and accurate accounting of all activity and holdings at the parish/school.

B) The general ledger should contain a detailed listing of transactions for every account classification used by the organization.

C) All transactions, activities, assets and liabilities of a parish or school must be accounted for/maintained in the general ledger.

102.2 No Netting of Income and Expenses:

Income and expenses shall never be netted against one another because netting understates both income and expenses and violates a basic accounting principle.

Note: The only exception to the principle of no-netting of income and expenses is in the case of school fundraisers. For more information, please contact the Department of Fiscal Services.

102.3 Exchange Account:

Exchange accounts are not used for parish/school revenue and expenditures. The exchange account (#1290) should be used only to record receipts and expenditures connected with actual exchanges, where funds are collected and disbursed, such as for a bus trip.

Procedure:

A) The exchange account should never be used to net or record income and expenses.

B) The account should be recorded on the general ledger and should be clearly marked or otherwise analyzed to show the offsetting receipts and expenditures.

C) The exchange account must net to zero at fiscal year-end.

D) Exchange accounts should not be sued for miscellaneous changes that are not true exchanges.

102.4 Trial Balance:

A trial balance – typically, a report found in the general ledger system providing the number, name and balance on each account in the general ledger — shall be maintained on a monthly and annual basis.

Procedure:

A) Accounts with debit balances should be listed in one column, while accounts with credit balances are listed in an adjacent column.

B) The total of the accounts with debit balance must equal the total of the accounts with credit balances.

C) All asset and liability accounts on the general ledger should be reconciled monthly and quarterly to supporting documentation (e.g., invoices, receipts, etc.)

102.5 Notes Receivable/Payable:

All notes receivable, notes payable, debenture payable, mortgage payable, etc. shall be set up in the general ledger as their own individual accounts.

Procedure:
Each asset or liability must have appropriate documentation to support its current balance.

102.6 Liabilities (Debt):

When the mortgage payable or notes payable (liability) is set up in the general ledger, payments on the mortgage or loan must be applied to reduce this payable.

102.7 Recording of Special Collections Funds:

Monies received from Special Parish Collections such as drives to defray the cost of repairing or repainting the church or rectory, decorations for holidays, or other festive occasions, school collections, fuel collections, etc., shall be recorded in account #4050 – Special Collection Funds for Operating Needs. Note, special collections to reduce a mortgage balance must receive written exemption from the Archbishop in order to be tax-exempt.

102.8 Recording of Special Approved Campaign Funds:

Proceeds from a special campaign for new construction or major renovations shall be recorded in account #4150 – Special Approved Campaign Funds. A special campaign must be limited to a definite period of time and dollar goal, and must have prior written approval of the Archbishop.

102.9 Recording of Capital Campaign Funds – Parish Share & Grants:

The parish share from Capital Campaigns and any Grants shall be recorded in account #4151 – Archdiocesan Capital Campaigns – Parish Share & Grants Received. Parishes that are self-administering the Capital Campaign should show their net parish share in this account.

102.10 Recording of Lenten Appeal Rebates & Grants:

The rebate to the parish of 25% of the Lenten Appeal funds raised as well as Lenten Appeal Grants must be recorded in account #4160 – Lenten Appeal Rebates & Grants.

102.11 Recording of Donations and Gifts:

Donations, gifts, and bequests received shall be recorded in the general ledger and posted according to the following procedures.

Procedure:

A) General donations, gifts, and bequests lacking a specific purpose or use of the funds should be posted to account #4220.

B) Donations, gifts, and bequests received that specifically state the donor’s intended use of the funds should be posted to #4720 – Specific Bequests under a Will, or #4370 Specific Gifts/Grants Restricted for Non-Operating Use.

C) Gifts in Kind (in lieu of cash) should not go unrecorded. The Donation Income and Other Expense (depending on the church expense paid) accounts should be increased. The books should reflect every church expense paid by the parish or for it, and every donation as income, whether received in actual dollars or in-kind, such as fixed assets, supplies, or repairs.

102.12 Property, Plant, and Equipment (Fixed Assets):

Fixed assets shall be posted according to the following procedures.

Procedure:

A) Fixed Assets, such as furniture, fixtures, machinery, equipment, building, and building improvements and extensions are recorded in account #5930 – Capital Expenditures in the Church, account #5500 – Capital Expenditures and New Non-Instructional Equipment in the School, or account #5080 – New Instructional Equipment in the School.

B) Supporting records should be kept for each capital expenditure category of fixed assets, such as Furniture & Fixtures, Machinery & Equipment, Building, Land, and Building Improvements. These supporting records should reflect the date of expenditure, vendor name, asset description and cost of each fixed asset item purchased



103 RECEIPTS


103.1 Supervision of Collected Offertory Funds:

No person shall be left unsupervised with collected offertory funds at any time.

Procedure:

A) Prior to Mass, the individuals responsible for collecting offertory funds shall obtain tamper evident bags and complete the tamper evident bag log.

B) When offertory funds are collected, an usher should place the collection in a basket and bring the collection to the altar. The basket should be placed away from doors or entrances to the church. The funds shall then be placed in a tamper evident bag.

C) When Mass is over, two unrelated persons (ushers, priest, religious, PLD, or corporator) should place the funds in a locked safe immediately.

103.2 Use of Safes:

Offertory funds and other receipts should be kept in a locked safe at all times, from the time that they are collected until the time that they are counted and deposited.

Procedure:

A) With the exception of petty cash funds, no other funds should ever be stored in a locked desk or cabinet.

B) All funds received into the parish should be deposited as soon as possible.

C) Individuals with the ability to input transactions into accounting records should not receive, count, transport, or take custody of funds and should not have access or knowledge of the combination to the safe.

D) Safe combinations should be known and/or safe keys should be held only by clergy/religious, PLDs, and/or corporators.

E) Safe combinations and/or keys should be changed periodically and any time there is a change in an individual with the ability to access the safe (for instance, a change in pastor or corporator).

103.3 Counting Procedures:

Each parish shall create and adhere at all times to written counting procedures for offertory funds, which shall incorporate the following procedures.

Procedure:

A) Counting shall be done as soon as possible after collection, preferably immediately after the last Mass of the week.

B) At least three counting teams should be used to count funds. Counting teams should consist of at least three unrelated individuals, and count teams should be rotated weekly.

C) Under no circumstances should the same team of people be allowed to count funds together week after week.

D) The members of each counting team should be assigned specific tasks (e.g., removing money from envelopes, noting amounts on envelope face, counting notes and coins, recounting, examining and marking checks for deposit only, recording amounts received by check, recording cash count, and preparing deposit slips).

E) A count sheet should be used to record totals for each type of collection.

F) Separate totals must be obtained for loose and envelope monies for each type of collection.

G) All counters should sign and date the weekly count sheet.

H) The signed count sheet should be turned over to the pastor who should review the document, initial and file the form.

103.4 Bank Deposits:

The following procedures shall be used for making bank deposits.

Procedure:

A) A counter from each count team should prepare the deposit slip for the deposit of offertory funds.

B) All funds received through the offertory collection should be deposited.

C) Funds should be transported to the bank using a bag containing the funds, deposit slips and adding machine tapes.

D) Funds should be transported to the bank for deposit by at least two, unrelated individuals immediately following the count and placed in the night depository (if Sunday) or deposited.

E) In instances where an armored carrier is used, the funds should be placed in locked bags and returned to the safe by two individuals and then turned over to the armored carrier on Monday.

F) Remote deposits may be made provided the depositor complies with all bank remote deposit procedures.

103.5 Recording Receipts and Deposits:

All receipts shall be entered immediately in a Receipts (Deposits) Journal.

Procedure:

A) All receipts should reflect the date received and the source.

B) Funds received throughout the week not included in the offertory process should be recorded on a daily receipts listing.

C) All receipts in the form of a check should be immediately stamped “For Deposit Only.”

D) All receipt and daily receipt listing forms should be given to the bookkeeper for entry into the accounting system on a daily basis.

E) All Parishes and schools should properly classify income amounts using the account names listed in the Charts of Accounts. A copy of the uniform chart of accounts is available from the ADDITIONAL RESOURCES section to the right.

F) When deposit slips are returned by the bank, they should be turned over to the bookkeeper with a copy of the signed weekly count sheet. The amounts on the deposit slips and count sheet should be compared to confirm agreement.

G) The amounts per the count sheet should then be recorded in the general ledger.

H) Once the amounts are entered a report should be printed out and tied to the count sheet and general ledger. Any differences should be investigated, documented, and corrected.

I) The envelope amounts should be entered into the Parish’s census data system. Reconciliations between the census data system and count sheet should occur monthly/quarterly.


104 SPECIAL CONTROL PROCEDURES FOR SCHOOLS


104.1 Receipt Slips for Schools:

Every time money is received for tuition or fees, by cash or check, schools shall issue a pre-numbered receipt slip and retain a carbon copy.

Procedure:

A) The original receipt should be given to the student or parent and the copy retained for the school’s records.

B) The receipt slips should indicate the reason for payment, the amount paid, and the method of payment.

C) Receipt slips should be totaled and included with the deposit slip.

104.2 Daily Cash Listing for Schools:

All school cash receipts of tuition and fees shall be reflected on a daily cash listing in the order of receipt.

Procedure:

A) The listing should include the date, grade, name of payer, amount, and description of reason for payment (e.g., tuition, fees, etc.) of each receipt.

B) The listing should be totaled each time a deposit is made and at the end of each page.

C) If FACTS is used by a school, the remittance report should be printed and maintained to support each FACTS deposit.

104.3 Tuition Receivable for Schools:

A monthly listing of unpaid/overdue tuition receivables shall be maintained by each school.

Procedure:

A) The listing should contain the school year dates, name of student, grade and amount owed.

B) The amounts due should be reviewed as to their collectability. If an amount is deemed “uncollectible,” this should be noted on the receivable listing.

C) The listing of uncollectible fees should be approved by the person authorized to write off receivables as “uncollectible.”

D) Items that are still deemed receivable should be actively pursued by the school (if consistent with school policy, official records should be withheld until collection is made).

E) On or before June 30 each year, a comprehensive listing of delinquent tuition should be reconciled to the general ledger. All differences should be investigated and reconciled and unpaid amounts should be pursued for collection in accordance with Archdiocesan collection policies.

104.4 Documenting Reduced Tuition:

Reduced or forgiven tuition shall always be supported by an adjustment in FACTS.

Procedure:

A) Records should be kept of all reduced or forgiven tuition, reflecting the school year, the student’s name and grade, the amount of reduced tuition, and the signature of the pastor or principal.

B) Tuition payments should be expected from every student on the class lists other than those for whom adjustments have been approved in FACTS or those who are exempt due to a family tuition plan.

C) All records and class lists detailing reduced or forgiven tuition should be retained as supporting records and should be made available for review.

104.5 Additional Tuition Records:

Adequate records should be maintained to enable someone, other than the person who records tuition records or deposits, to calculate the tuition and fees that should have been collected and deposited.

Procedure:

A) The following records should be kept by each school:

A class listing as of the beginning of the year, including all students and the tuition rates to be paid. Family rates, reduced or forgiven tuition should be clearly marked on the class list. If FACTS is used, print and maintain the agreements and finalization report.
The names of students withdrawn during the year and the balance of the tuition that was left unpaid by each of them.

The names of students added during the year and the reduced rate charged to each.
A schedule showing computation of the tuition for the school year to be collected, reduced by the withdrawn students, increased by additional students and reduced by unpaid tuitions and reduced and forgiven tuitions. If the school would like to compare this calculation from year to year, the school must distinguish in their records between current and past years’ tuitions collected and deposited

B) Explanations for the variance between the actual recorded and deposited tuition, and the amount of tuition that should have been collected should be provided when the difference is substantial.

C) On a routine basis, tuition revenue should be compared with enrollment data by an individual other than the person(s) responsible for maintaining tuition records and receiving tuition payments. Any discrepancies found should be resolved.



105 DISBURSEMENTS


105.1 Disbursements:

All expenditures should be made by check or secured payment transfer and should be recorded in the general ledger.

Procedure:

A) All expenditures must be approved by the pastor or other authorized personnel prior to payment.

B) All expenditures should indicate the date of the payment, to whom the payment was made, the purpose of the payment, and the check number.

C) Checks should always be issued and posted in sequential order.

D) Checks should be simultaneously posted to the general ledger through the check creation process.

E) The Chart of Accounts for parishes and schools should be used for the proper classification of check disbursements. A copy of the uniform chart of accounts is available from the ADDITIONAL RESOURCES section to the right.

F) The check signer should always be a different person than the check preparer.

G) The check preparer should be a different person than the person who reconciles the general ledger with the bank records.

H) Supporting documentation shall be maintained for every disbursement, including original receipts or invoices (items should only be p[aid after receipt of approved invoices).

I) Checks shall not be made payable to cash or signed in advance.

105.2 Invoices and Documentation:

Invoices or other supporting documents shall be obtained for every expenditure, with the exception of salaries to employees, payroll tax payments, clergy fees, Cathedraticum payments, Diocesan Collections remitted, and school subsidies.

Procedure:

A) Paid checks and credit card statements alone are not sufficient support for expenditures.

B) Receipts and/or invoices must be attached. The business purpose for an expenditure should be clearly indicated in the supporting documentation. A memo explaining the reason for the expenditure should be included if the reason for the expenditure is not provided in the other supporting documentation.

C) All invoices should be reviewed and approved by the pastor, pld, principal or applicable department head prior to payment. This approval should be indicated in writing.

D) Invoices and other supporting documents are part of the required records and must not be destroyed, but retained as support for the cash disbursements. These documents may only be destroyed in accordance with the Archdiocesan Record Retention Policy, available here.

E) After payment, invoices should be marked to reflect the check number and date paid.

F) Invoices should be kept alphabetically in files by vendor for the fiscal year July 1 through June 30. Files should be kept separately for each fiscal year.


106 PAYROLL RECORDS


106.1 Use of UltiPro Required:

All Archdiocesan locations must use UltiPro for payroll processing. All new employees must be added to the Ulti-Pro system before issuance of payroll may occur.

106.2 Payroll Records:

Complete payroll records shall be maintained confidentially by the parish or school for all employees.

Procedure:

A) A detailed payroll register shall be maintained through UltiPro and shall be the source document for posting payroll into the general ledger.

B) Every payroll processed shall be recorded as an individual journal entry.

C) State and Federal quarterly withholding tax returns and year-end Employee Earnings Statements (W-2s) shall be filed accurately and on-time through UltiPro.

D) Timely deposits of withheld taxes shall be made through UltiPro.

E) Current signed payroll tax withholding authorizations (W-4s) and applicable state withholding forms, which show the number of claimed exemptions for employees who claim to be exempt from taxes, should be obtained yearly and maintained in the employee file. Current W-4s and state withholding forms for other employees should also be maintained, however, they are not required to be obtained annually.

F) For all changes in compensation and benefits, including new hires, terminations, or wage rate or benefits changes for current employees, a personnel action form must be completed and maintained in the employee’s personnel file.

G) If employees are paid on an hourly basis, time sheets indicating the dates and hours worked, and signed by the employee and approved by the pastor or supervisor should be maintained to support the wages. Salaried employees should also complete and sign timesheets for each pay period indicating any holiday, sick or vacation time used.

H) Direct deposit is recommended as a safer and more cost effective payroll method. Payments to employees who choose to receive checks shall be processed through UltiPro, and such payments may be made through a separate payroll account.

106.3 Employee vs. Non-Employee:

School/parish personnel shall be treated as employees unless approval is received from Archdiocesan legal counsel to treat the personnel as non-employees (independent contractors or volunteers).

Procedure:

A) All persons determined to be employees must be included in the payroll records, have taxes withheld from their pay according to the tax tables, and receive W-2 withholding tax statements at calendar year-end.

B) If an independent contractor does work for a school or parish, he/she/it must issue an invoice for the work done. IRS regulations require reporting of all payments of $600 or more in a calendar year to independent contractors on IRS Form 1099s.


107 BANK ACCOUNT AND PETTY CASH REGULATIONS


The following section explains regulations for use of bank accounts by parishes and schools.

107.1 One Checking Account Limit:

Only one checking account shall be used to deposit income and pay expenses.

Procedure:

A) Each parish and school should have only one checking account into which every cash receipt is deposited and from which every cash disbursement is made.

B) A separate payroll checking account used exclusively for payroll is permitted. This type of account operates through transfers from the regular checking account.

C) Additional sets of books, bank reconciliations and the consolidation of the activity of the accounts are all complications of having more than one checking account.

D) Savings accounts can be used to receive transfers of funds from the regular checking account when a parish or school wishes to separate certain funds.

107.2 Savings Accounts:

There is no limit to the number of savings accounts that a parish or school can have.

Procedure:

A) Savings account balances should be recorded in the General Ledger and adequate documentation to support the current balances should be maintained.

B) Cash receipt deposits should never be made directly into savings accounts, and disbursements for expenses should never be made directly from savings accounts.

C) Activity in savings accounts should be entered as transfers to or from the regular checking account.

D) The interest on savings accounts should be recorded monthly.

107.3 Titling of Accounts:

All financial and investment accounts must be registered only in the name of the parish or school corporation and at its legal address.

Procedure:

A) For parishes, the Archbishop, the Vicar Bishop, the parish pastor/ PLD, the associate pastor and/or corporators should be named as an authorized signer on all parish financial and investment accounts.

B) For parish schools, the Archbishop, the Vicar Bishop, the pastor, associate pastor, principal, assistant principal, and/or the school board president should be named as authorized signers on every school financial and investment account.

C) For incorporated schools, the Archbishop, the Vicar Bishop, the principal, assistant principal, school board chair, and/or finance committee chair should be named as authorized signers on every school financial and investment account.

D) Facsimile signature stamps should not be used at parishes or schools.

E) Dual signatures should be required on checks over a predetermined amount.

107.4 Reporting Bank Accounts:

All financial and investment accounts must be reported to the Archdiocese of Baltimore as part of the Annual Financial Report, which is due by August 15th of each year.

Procedure:
When reporting accounts as part of the Annual Financial Report, all parishes and schools must include the name of the financial institution, type of account, what the account is used for, the account number and the balance in the account at year-end.

107.5 Bank Reconciliation:

Written bank reconciliations must be prepared and maintained monthly.

Procedure:

A) The bank balance of cash at month-end must be reconciled to both the checkbook balance and the general ledger cash balance on the same date.

B) Discrepancies should be investigated, documented and properly corrected.

C) A copy of the completed reconciliation, along with the outstanding check listing and the deposit in transit listing, should be maintained and should be dated and initialed by the person completing it. Additionally, a copy of the balance sheet should be attached as of the date of the bank statement.

D) The completed reconciliation, signed and dated by the preparer, should then be forwarded to the pastor or other appropriate member of the parish or school (i.e., a finance committee member or corporators) for their review.

E) The reconciliation should also be initialed by the person that reviews it.

F) The parish or school shall obtain copies of all cancelled checks and maintain them in accordance with the record retention policy, available here.

107.6 Petty Cash Fund:

A parish or school may use a petty cash fund for small purchases subject to the following procedures.

Procedure:

A) Only one person, the designated custodian, shall be responsible for and have sole access to the petty cash fund.

B) To establish the fund, a check to the custodian of the fund must be drawn in an amount adequate to maintain the fund. Ordinarily, the amount of the petty cash fund will not exceed $500.

C) An imprest system – whereby a set amount is maintained by replenishing only amounts spent – should be used for all petty cash funds.

D) Petty cash funds should be stored in a secure location, ideally a small lock box or locked cabinet or drawer.

E) As money is used, invoices/receipts are attached to a petty cash voucher slip which is completed in ink and signed by the person receiving the money. The voucher slip shall indicate the amount withdrawn, the date, the reason for the expenditure, and an account number.

F) All petty cash expenditures should be supported by invoices and vouchers.

G) At the end of the month, or sooner if the fund is low, the voucher slips are collected, reviewed, and expenditures are approved and totaled.

H) A check made payable to the custodian of the fund, equal to the total of all voucher slips, is drawn. The check is then cashed into bills and coins and the petty cash container is replenished.


108 CHARITABLE CONTRIBUTIONS


The following section summarizes the tax implications and recording procedures for charitable contributions. For additional information, see here.

108.1 Contributions of Clothing and Household Items

Contributions of clothing and household items are subject to the following procedures.

Procedure:

A) Parishes and schools must file IRS Form 8282, Donee Information Return, if they sell or dispose of donated items valued at more than $500 within three years after they received the donation, unless the item was consumed or distributed for charitable purposes (except for donations of jewelry and gems, collections, paintings, antiques, and other objects of fine arts). See IRS publication 561, Determining the Value of Donated Property, available here, for more information on such donations.

B) Parishes and Schools should not accept donations that cannot be sold or used by the organization in its charitable programs.

C) Parishes and schools that accept donations of clothing, household items, and other tangible property should advise donors that they may wish to seek advice from a tax advisor regarding the deductibility of such donations.

D) Donors who contribute a single piece of clothing or household item that is not in good used condition or better for which a deduction of more than $500 is claimed must file a qualified appraisal of the donated item with their tax returns.

E) Taxpayers who claim deductions for non-cash contributions totaling more than $500 must submit a copy of IRS Form 8283, Noncash Charitable Contributions, with their tax returns.

F) Parishes and schools should monitor and be aware of requirements issued by the Treasury Department regarding procedures for accepting donated household and clothing items and the receipts that parishes and schools must provide to donors for such items.

108.2 Substantiation of Cash Contributions:

Parishes and Schools should be aware of the following tax procedures and requirements for cash contributions.

Procedure:

A) Donors who itemize deductions on their annual income tax returns must have a bank record (e.g., a canceled check or credit card statement) or a receipt or other written communication from the parish or school to substantiate any cash contributions. The parish or school’s communication, such as a receipt or a letter, must indicate the name of the parish or school, the date of the contribution, and the amount of the contribution.

B) A donor can deduct a contribution of $250 or more only if the donor has a written acknowledgement from the parish or school.

C) Parishes and schools are required by law to provide documentation to donors for gifts of $75 or more if they provide a return benefit to the donor (such as a meal or token gift). These types of donations, referred to as “quid pro quo” donations, represent payments to a qualified organization made partly as a charitable contribution and partly as compensation for goods or services received.

D) Quid pro quo donations are potentially tax deductible to the donor only to the extent by which the contribution exceeds the fair market value of goods or services received. Quid pro quo disclosure statements must:

Indicate the amount of the donation that is deductible for federal income tax purposes, noting that the deduction is limited to the excess of any money (and the value of any property other than money) contributed by the donor over the value of goods or services provided by the parish or school.

Provide the donor with a description and good faith estimate of the value of the goods or services that the donor received.

Disclosure statements do not need to be provided when goods or services provided to a donor have “insubstantial value” or represent an “intangible religious benefit.”
The parish or school may be subject to a penalty for the failure to make the required disclosure of a quid pro quo contribution.

108.3 Appraisal for Valuations of Certain Donated Property:

Parishes and Schools should be aware of the following tax requirements for valuations of certain donated property.

Procedure:

A) Taxpayers who claim deductions for certain property (including works of art) valued at $5,000 or more are subject to more stringent appraisal requirements to substantiate the value of the property.

B) While these rules do not directly affect charitable organizations that receive such gifts, parishes and schools may wish to advise their donors of these rules and encourage them to consult their own tax and legal advisors to determine the appropriate actions required to substantiate a claim for tax deductions.

108.4 Contributions of Services:

Donations of services (e.g., legal, accounting, general contracting services) are not deductible, except for unreimbursed out-of-pocket expenses related to such services (e.g., materials, supplies), as long as the donor maintains adequate records to substantiate the amounts paid and, for expenses totaling in excess of $250, receives an acknowledgment from the parish or school similar to the one provided for other contributions, but with a description of the services provided.

108.5 Communications to Parishioners/Donors:

Parishioners and other donors should be generally apprised of these charitable giving regulations and urged to contact their tax and/or legal professionals regarding the tax implications and reporting obligations of specific donations. Under no circumstances should the parish or school represent that it is providing tax or legal advice regarding a charitable contribution.


109 INTERNAL CONTROL POLICIES FOR RELATED ORGANIZATIONS


The following section explains the internal control procedures that apply to parish and school organizations, which benefit from the tax-exempt status of the parish. All major parish/school organizations and programs such as the religious education program, fund raising groups, the choir, and youth groups should be accounted for through the parish/school’s general ledger. Specific accounts have been included in the Archdiocesan parish and school chart of accounts. Note, certain groups such as Home and School Associations and sponsored Scout groups are subject to the full range of internal controls required at each parish and school.

109.1 General Internal Control Policy for Related Organizations:

All related organizations must follow all internal control procedures of their respective parish or school. Additionally, related organizations are subject to the following procedures.

Procedure:

A) Financial records of the organization must be maintained at the parish or school office.

B) The organization must use the address of the parish or school office for business purposes.

C) The organization must maintain cash collection procedures consistent with the internal control procedures applicable to parishes and schools.

D) The organization must maintain a written system to track and record the sources of funds received and expended. Checking account balances of the organization must be reported to the parish or school for tracking as an asset/liability on the general ledger.

E) The organization must prepare and submit for review and approval by the school/parish an annual budget.

F) The organization must report to the pastor and/or principal at least quarterly on the activities to-date and budget versus actual. A year-end report must also be prepared and presented.

G) Dual signatures are required for all checks written from an organization account. One signature shall be from the pastor or principal.

H) The foregoing procedures must be followed by all members of the organization, including volunteers.

109.2 Charitable Contributions to Related Organizations:

Related organizations are not permitted to solicit, raise or accept charitable contributions except as approved by the pastor or principal.


110 FUNDRAISER CONTROLS


Regardless of whether a fundraiser is held by a parish, school, or related organization, the following controls should be implemented.

110.1 General Control Procedures:

The same internal control procedures that are applicable to general parish/school operations apply to operation of a fundraiser.

Procedure:

A) Parishes and schools should consider creating a special events committee to oversee fundraisers. This committee should report to the pastor and principal on a routine basis.

B) Written policies/procedures should be provided to every volunteer/worker to explain the operations of the fundraiser.

C) To avoid conflicts of interest, individual employees/volunteers are not permitted to receive incentives from fundraiser vendors. Donations are acceptable from such vendors provided they benefit the parish or school as a whole, not certain individuals.

D) All financial records must be kept on parish or school premises.

E) From receipt to deposit, all monies, whether cash or checks, should be handled by two people. No one person should ever be left alone with funds collected. All funds should be deposited on at least a weekly basis. Except when making a deposit, fundraising monies must never be taken off-site or home by anyone. Funds collected must be placed in a tamper-evident bag and stored in the parish/school safe until deposit. Counting of funds should never occur at someone’s home. Drop safes should be considered to allow money to be placed into a safe, without the person having knowledge of the combination.

F) All funds received should be recorded according to their source and supported by accompanying documentation. Supporting documentation may vary by type of event and may include, for example, a log of ticket sales or a summary of amounts paid for individually identified auction items.

G) Documentation from fundraising events shall be retained in accordance with the Archdiocesan record retention policy.

H) Raffles, bingo, and other “gaming” events may be subject to Maryland laws regulating gaming and may require obtaining a permit from the local county or city government. For more information regarding county regulations for various fundraisers, parishes and schools should contact Archdiocesan Legal Counsel. See also Maryland annotated code, http://www.lawlib.state.md.us, Maryland Code – Criminal Law Article, titles 12 & 13.

110.2 Ticket Sales:

Tickets should be used for all cash events. The number of tickets sold should then be reconciled to the amount of cash received. Any tickets, etc. distributed without receiving payment must be carefully tracked to ensure money is received before the event.

110.3 Startup Cash:

Start-up cash should not be treated as an expense, but rather a receivable. Income and expenses should be recorded gross.

110.4 Specific Procedures for Auctions/Raffles:

The following procedures should be followed for any auction/raffle, in addition to the general control, cash receipt, and expense procedures for fundraisers.

Procedure:

A) If tickets are used, the tickets should be inventoried according to the serial numbers on the tickets. The number of tickets sold should match the money collected.

B) Raffle winners that receive at least $600, but not more than $5,000, must complete a Form W-2G, if the prize is at least 300 times the amount of the wager, not reduced by the wager. (Example: If a raffle winner wins $4,000 and bought a $5 ticket, 300 x $5= $1,500, therefore, the winner should be issued a Form W-2G, since he/she won over $1,500. The winner must furnish the game operator proper identification, and their name, social security number, and address. If the winner does not provide this information, then the game operator must withhold tax at the rate of 31%.) A single prize, less the wager, exceeding $5,000 requires the completion of Form W-2G and regular gambling withholding of 28% of the net winnings as required by the IRS. A copy of the Form W-2G is available here.

C) Items made available for auction should be listed and identified individually so that they may be tracked to the winner.

D) Supporting documentation of the winning bidder shall be maintained for each auction item, including the name, address, and amount of the bid of the winning bidder.

E) Specific rules for silent auctions must be provided, including the opening and closing time of the auction, the minimum bid, etc. and strictly adhered to.

F) Payments for auction items should be received immediately and before the conclusion of the auction. In no event should an item be given to a bidder before the funds are received.

G) Winning raffle numbers must not be based on the Maryland lottery.

110.5 Specific Procedures for Bingo:

The following procedures should be followed for bingo games, in addition to the general control, cash receipt, and expense procedures for fundraisers.

Procedure:

A) Paper bingo cards and other game cards (tear offs) should be adequately secured and properly inventoried. The inventory form should also reflect the start-up cash for the bingo. A sample inventory form is available here.

B) Income and expense should be tracked gross- not net of each other.

C) No expenses of bingo to vendors should be paid in cash, except to the winners.

D) A “winning sheet” listing the games, winners, and amount of winnings should be maintained. A sample winnings sheet is available here. A blank winnings sheet reflecting the amount at stake in each game should be handed out to the bingo players at the beginning of the night. Players should understand the amount the winners will receive receiving at the start of the game. When winners are paid, they should initial the winnings sheet. The winnings should be clearly announced to winners for all games, including if a pot is split.

F) All funds should be deposited immediately and intact either at the bank or in the safe and should not be removed from parish/school grounds. A reconciliation should be done at the end of the night to verify income received. The reconciliation should include income received from kitchen sales. A sample reconciliation form is available here.

G) A final count of income earned and paid out for the various games played at bingo should be done and verified by two people. A sample final count form is available here. The outcome of each game should be tracked via a “Report of Games Played, Lost, or Destroyed.” Sample reports are available here.

H) An IRS Form W-2G must be issued to anyone paid $1,200 or more in bingo winnings, not reduced by the wager. A copy of the Form W-2G is available here.

110.6 Specific Procedures for Runs/Walks:

The following procedures should be followed for runs/walks, in addition to the general control, cash receipt, and expense procedures for fundraisers.

Procedure:

A) Participants must sign a waiver and release of liability that has been approved by the Division of Risk Management.

B) If a participant sponsorship system is used, participants should be provided with a detailed form explaining the sponsorship process and that allows them to track sponsors.

C) Checks should be submitted for all sponsorships. No cash should be turned in by participants for sponsorships. If a participant receives cash from a sponsor, the participant should cut a check for the amount to the parish/school.

D) The parish/school should provide each participant a certificate that verifies participation and the funds donated by the participant’s sponsors. Participants should also be provided with a thank you letter to each sponsor, stating the amount donated.

E) A daily income receipt log should be kept and verified against the bank deposit slip.

110.7 Specific Procedures for Carnivals/Fairs:

The following procedures shall be followed for carnivals/fairs, in addition to the general control, cash receipt, and expense procedures for fundraisers.

Procedure:

A) Segregation of duties is essential for carnival/fair operations. For instance, the same person should not be responsible for tracking income and paying expenses.

B) Income should be tracked per event, per day and all ticket and food sales should be reconciled to the cash received (for all tickets, rides, games, and food sales).

C) Counting should occur at the close of each day and two people should always count income. Income should be deposited immediately, or placed in a tamper evident bag and put in the parish/school drop-safe until a deposit is made. Count logs should be forwarded to the parish/school bookkeeper for comparison to the validated deposit slip once returned from the bank and for entry in the accounting system.

D) All checks should be made out to the parish/school. Checks should not be made out to individuals.

E) Written rules and guidelines for carnival operation should be given to all volunteers.

F) A carnival budget should be created in advance to avoid losses.

G) No expenses to vendors/workers should be paid out of cash generated at the carnival. All payments should be made by check request with supporting documentation attached to the request. All transactions should be properly recorded gross. Payments to workers may require issuance of tax forms.

110.8 Specific Procedures for Scrip Sales:

Specific, detailed procedures have been developed for Scrip sales. These procedures, available here, should be followed in addition to the general control, cash receipt, and expense procedures for fundraisers.

110.9 Compliance with Local Gaming and Alcohol Laws, Permitting, and Insurance:

The parish or school must comply with all local gaming and alcohol laws in holding a fundraising event and must obtain any necessary permits and insurance in accordance with the Office of Risk Management.

110.10 Staffing by Volunteers:

Fundraising events should be staffed by volunteers (not employees). Volunteers may not receive financial benefits in exchange for their efforts. For example, organizations should not offer a cash prize to the person selling the most tickets, or a tuition credit or discount if a student’s parents help with a raffle.


200 ETHICS/WHISTLEBLOWER POLICY


The Archdiocese of Baltimore is dedicated to managing the resources of the Church as faithful stewards. To fulfill the mission of the Church, Archdiocesan employees must perform work in an ethical and accountable manner. The Archdiocese expects all employees to work within established Archdiocesan policies and procedures and the guidelines set forth in the Code of Conduct for Church Personnel.

The Archdiocese has developed the following method for reporting fraud and other ethics concerns, investigating incidents reported, and recommending actions to be taken where violations are found. The Archdiocese encourages individuals to report to the Ethics Hotline, in accordance with the procedures below, any conduct or activity which they perceive to be contrary to the policies and ethics of the Archdiocese.

This policy applies to any fraud or dishonest act involving Archdiocesan personnel. The Archdiocese is defined as: Central Services, parishes, and Archdiocesan, ACS, parish, and Interparish/Regional schools. Archdiocesan personnel includes: clergy, religious and lay ministers, employees and volunteers of the Archdiocese.


201 REPORTING SUSPECTED FRAUD OR DISHONEST CONDUCT


Policy:

Archdiocesan personnel who detect or suspect fraud, dishonest conduct, or other ethics violations should report their concerns immediately to the Ethics Hotline.

Procedures:

A) Reports can made to the Ethics Hotline through the Archdiocese’s website, www.archbalt.org, by using the EthicsPoint Quick Link, through EthicsPoint’s website www.ethicspoint.com, or through the EthicsPoint’s telephone hotline at 1-888-572-8206.

B) Examples of conduct that should be reported include, but are not limited to:

Complaints related to financial misconduct such as:

  • Fraud and Theft
  • Conflict of interest
  • Embezzlement
  • Falsification of contracts, records, or reports
  • Theft of Gifts and Donations

Complaints related to Human Resources issues such as:

  • Harassment and Inappropriate Behavior
  • Misuse of Resources
  • Threats of Violence
  • Workplace Safety

C) The individual reporting the concern should not:

  • contact the suspected individual in an effort to determine facts or demand restitution; and should not
  • discuss the case, facts, suspicions or allegations with anyone unless directed to do so by Archdiocesan Legal Counsel or the Manager of Internal Audit.

D) The reporting and investigation of suspected improprieties or irregularities should be kept confidential, so as to avoid damaging the reputation of an innocent person or prematurely alerting suspected individuals that an investigation is underway.

E) The Ethics Hotline should not be used to report concerns related to Child and Youth Protection and School Safety issues. For concerns related to these issues, the following reporting guidelines should be followed:

Child and Youth Protection: Anyone who knows of or suspects child abuse by a priest, employee, or volunteer of the Archdiocese should contact the Archdiocesan Office of Child and Youth Protection at (866) 417-7469 immediately.

School Safety: To report issues related to classroom safety, harassment,drugs, alcohol or bullying, please contact the school’s principal. If the issue is not adequately resolved, please contact the Department of Catholic Schools at 410-547-5515.

F) Frequently asked questions regarding the Ethics Hotline are answered here.


202 INVESTIGATION PROCEDURES


202.1 Investigation Conducted Regardless of Wrongdoer’s Position:

Allegations of fraud, dishonest conduct, or other ethics violations will be investigated regardless of the suspected wrongdoer’s length of service, position or title.

202.2 Investigation Conducted by Internal Audit:

The Manager of Internal Audit (the “Manager”) has the primary responsibility for the investigation of all suspected ethics violations. No Archdiocesan entity should conduct its own independent investigation.

202.3 Coordination with Human Resources:

The Manager will coordinate all investigations with Human Resources and other parties as necessary, including Archdiocesan Legal Counsel, and will determine the appropriate members of the investigative team. Investigations of complaints related to violations of Human Resources policies will ordinarily be led by Human Resources.

202.4 Access Provided to Investigative Team:

Individuals involved in the investigation will have free and unrestricted access to all Archdiocesan records and premises and the authority to examine, copy and / or remove all or any portion of the contents of files, desks, cabinets and computer records that are necessary to the investigation.

202.5 Issuance of Audit Report:

If the investigation substantiates that fraudulent activities or other ethics violations have occurred, the Manager of Internal Audit or investigative team will issue an audit report to appropriate personnel and the Audit Committee of the Board of Financial Administration. In addition, the Manager of Internal Audit or investigative team will report the results of the investigation to the complaining party as appropriate.

202.6 Review of Recommendation to Terminate Wrongdoer’s Employment:

If the investigation results in a recommendation to terminate the employment of an Archdiocesan employee, the recommendation shall be reviewed for approval by the employee’s supervisors and designated representatives from Human Resources and, where appropriate, by Archdiocesan Legal Counsel, before any such action is taken. If the investigative team believes that the corrective action taken by the employee’s supervisors and Human resources was insufficient based on the facts uncovered during the investigation, the investigative team will address its concerns to the Vicariate office and Human Resources.

202.7 Report to Law Enforcement Authorities:

It is the practice of the Archdiocese to report all substantiated fraud and other criminal law violations to appropriate law enforcement authorities.


203 ACTIONS CONSTITUTING FRAUD


Policy:

Fraud is the intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her injury. For purposes of this policy, examples of fraud include:

Benefits Fraud – Improper, misleading or deceptive actions, falsification of records, or misrepresentation of physical conditions related to benefits plans including health and supplemental income plans, tuition reimbursement and sick or other paid time off programs.

Conflict of Interest – A conflict of interest is defined as a situation in which a person’s private or personal interests influence the exercise of his or her official duties. The Archdiocese maintains a detailed Conflict of Interest Policy, available here.

Embezzlement – Misappropriating property entrusted in one’s care to one’s own use.

Falsification of Contracts, Reports or Records – Falsification of records consists of altering, fabricating, falsifying, or forging all or any part of a document, contract or record for the purpose of gaining an advantage, or misrepresenting the value of the document, contract or record.
Theft (Larceny, Burglary, Robbery) – Any act of stealing, including: the taking and removing of property with intent to deprive the rightful owner of it.

Time Abuse – Falsifying an employee’s work hours.


204 MAINTAINING CONFIDENTIALITY


Policy:
Fraud and ethics complaints shall be handled with sensitivity, discretion and confidentiality.

Procedure:

A) Concerns will be shared only with those individuals who have a need to know.

B) Disclosure of information related to a fraud or ethics complaint to individuals not involved in the investigation or review of the complaint will be viewed as a serious disciplinary offense and may result in discipline, up to and including ermination of employment.


205 WHISTLEBLOWER PROTECTIONS


205.1 Non-Retaliation:

This Policy is intended to encourage and enable individuals to raise ethics concerns for investigation and appropriate action without fear of retribution. No individual who, in good faith, reports an ethics concern shall be subject to retaliation or, in the case of an employee, adverse employment actions as a result of making such a report. Archdiocesan Personnel who retaliate against someone who has reported a concern in good faith are subject to discipline up to and including dismissal.

205.2 Good-Faith Reporting:

Individuals reporting a concern must act in good faith and have reasonable grounds for believing the information disclosed indicates improper activity. Archdiocesan personnel who make allegations that are proven to have been made maliciously, recklessly or with knowledge that the allegations are false will be subject to disciplinary action up to and including dismissal.


300 CONFLICTS OF INTEREST


A conflict of interest means a conflict, or the appearance of a conflict, between the private interests and official responsibilities of Archdiocesan Personnel, including clergy, religious and lay ministers, employees and volunteers of the Archdiocese. The Archdiocese includes: Central Services, parishes, and Archdiocesan, ACS, parish, and Interparish/Regional schools.

In light of various IRS restrictions and, more importantly, in order to assist the Archdiocese in fulfilling its responsibilities to act as a competent and trustworthy steward of Church goods, the Archdiocese has developed this Conflicts of Interest policy. This policy is intended to supplement but not replace any laws governing conflicts of interest applicable to non-profit and charitable corporations.


301 CONFLICTS OF INTEREST PROHIBITED


Policy:
Archdiocesan Personnel should never knowingly undertake or recommend any financial or business transaction from which they, a family member, a relative or friend have an existing or potential financial interest (as defined below) without first fully disclosing the potential benefit to the appropriate parish, school or Archdiocesan official.

A financial interest exists if the person has, directly or indirectly, through business, investment or family any one of the following:

a. An ownership or investment interest in any entity with which the Archdiocese has a

b. A compensation arrangement (including direct and indirect remuneration) with any entity

c. A potential ownership or investment interest with or compensation arrangement with any entity or individual with whom the Archdiocese is negotiating a transaction or arrangement;

d. Any other material interest that impairs or may impair the person’s independence and objectivity of judgment.


302 ACCEPTANCE OF GIFTS, FAVORS OR ENTERTAINMENT


Policy:
Under no circumstances may a gift or entertainment be solicited or accepted by Archdiocesan Personnel that would influence the individual’s judgment.

Procedure:

Archdiocesan Personnel who receive, or whose family members receive a gift prohibited by this policy should report it to his or her supervisor (for employees) or appropriate parish, school or Archdiocesan Official (for volunteers). The gift should be immediately returned or donated to charity. Gifts, as defined in this policy, do not include:

a. Normal business entertainment items, such as meals and beverages

b. Items of minimal value given in connection with honors, awards, service, etc.

c. Items or services with a total annual value of under $25.00


303 OUTSIDE EMPLOYMENT


Policy:
Archdiocesan Personnel may not be employed outside the Archdiocese in a position that would affect their objectivity in carrying out their Archdiocesan responsibilities.

Procedure:

A) Archdiocesan Personnel should not accept a position as director, officer, employee or consultant to any entity doing business with the Archdiocese unless written approval has been obtained from the appropriate supervisor.

B) Outside employment should not conflict with scheduled work hours.

C) Archdiocesan Personnel must not use Archdiocesan time, materials, information or other assets in connection with any outside employment.


304 CAPITAL PROJECTS


Policy:
To avoid conflicts of interest, parishioners shall not be retained as consultants, contractors or subcontractors.

Procedure:

A) Any firm where a parishioner holds a financial interest as an owner, officer, principal or stockholder shall be automatically disqualified from consideration.

B) Parishioners working at an otherwise qualified firm and who do not hold a financial interest in the firm shall not cause that firm’s disqualification from consideration. However, in the event that such a qualified firm is selected to perform the work, those parishioners that are employees in a management position (project manager or superintendent) shall not be used by that firm to perform the work.

C) Exceptions to this policy may be requested in writing by the location to Vicar Bishop, if it is determined that an exception is in the best interest of the location or Archdiocese. The firm must meet all standard qualification criteria.


305 INVESTMENT/INVESTMENT MANAGEMENT


Policy:
Parishes and schools must avoid any investment or relationship with an investment manager that is, or appears to be, a conflict of interest.


306 BOARDS, COUNCILS, AND COMMITTEES


Policy:
Archdiocesan Personnel serving on boards, councils and committees within the Archdiocese, also known as collegial bodies, shall not knowingly take any action or make any statement intended to influence the conduct of the Archdiocese in such a way as to confer any financial benefit on such individual, his or her immediate family member, or on any firm or corporation in which he or she has a financial interest as partner, shareholder, investor, director officer or employee.

Procedure:

A) Archdiocesan Personnel and collegial body members who are aware of a potential conflict of interest with respect to any matter coming before a collegial body shall not vote in connection with the matter.

B) In the event that a matter for consideration or recommendation by the collegial body raises a potential conflict of interest for Archdiocesan personnel, the individual shall disclose the potential conflict of interest as soon as he/she becomes aware of it and the disclosure shall be recorded in the minutes of the meeting.


307 DUTY TO DISCLOSE CONFLICTS OF INTEREST


Policy:
Archdiocesan Personnel and collegial body members have a duty to disclose any conflict of interest as soon as they become aware of it.

Procedure:

A) In connection with any actual or possible conflict of interest, Archdiocesan Personnel must disclose the existence and nature of his or her financial interest and all material facts to the appropriate parish, school or Archdiocesan official, on an annual basis. A sample Annual Declaration of Potential Conflicts of Interest is available here.

B) Early identification and resolution of potential conflict of interest issues is critical to supporting the Archdiocese’s commitment to the highest ethical standards.

C) Nothing in this policy should be construed as preventing or discouraging any Archdiocesan employee or collegial body member from disclosing relevant information with respect to any matter as to which he/she has knowledge or from answering questions or stating his/her position with respect to any such matter.


308 QUESTIONS OR CONCERNS REGARDING CONFLICTS OF INTEREST


Policy:
Any individual who has a question or concern regarding a potential conflict of interest should seek advice from their supervisor or the Manager of Internal Audit or the Director of Human Resources.

Procedure:
Concerns regarding conflicts of interest may be reported to the Ethics Hotline through the Archdiocese’s website, www.archbalt.org, by using the EthicsPoint Quick Link, through EthicsPoint’s website www.ethicspoint.com, or through the EthicsPoint’s telephone hotline at 1-888-572-8206.


400 INTERNAL AUDIT POLICIES AND PROCEDURES


401 MISSION STATEMENT AND OBJECTIVES


401.1 Mission Statement:

The Archdiocese’s Internal Audit office of the Division of Fiscal Services (“Internal Audit”) acts as an independent audit and management advisory service to the Board of Financial Administration and Central Services’ financial and administrative managers, supporting Archdiocesan and parish and school staff to ensure accountability, effectiveness, and completion of their financial responsibilities.

401.2 Statement of Objectives:

To provide an independent appraisal function to examine and evaluate the financial and operational activities of the parishes and schools of the Archdiocese.
To determine whether overall Archdiocesan objectives are accomplished in a manner that is consistent with established policies, procedures and sound business practices, and to report deviations to management.

To evaluate and appraise an entity’s system of internal controls to ensure that information is accurately, completely, and timely processed.

To review and ensure an entity’s compliance with its internal control procedures and related policies, procedures, laws and regulations that could have a significant impact on Archdiocesan operations.
To recommend procedures to help improve an entity’s accounting and internal control procedures in order to safeguard its assets and resources, promote its growth, and to ensure compliance with all public laws and regulations, as well as the adopted policies of the Archdiocese.


402 AUDIT AUTHORITY


402.1 Reporting Structure:

Internal Audit is led by the Manager of Internal Audit (the “Manager”). The Manager reports directly to the Executive Director of Management Services, regarding operational controls and internal coordination, as well as the Audit Committee of the Board of Financial Administration. Internal Audit staff members will report directly to the Manager.

402.2 Periodic Reports/Audit Plan to Audit Committee:

The Manager will provide formal reports not less than annually to the Audit Committee, which shall include an audit plan, as well as a summary of the audit results for the fiscal year.

402.3 Access to Records:

In order to execute the audit plan approved by the Audit Committee, Internal Audit will be provided free and unrestricted access to all company records and personnel files necessary to complete its audits.

402.4 Retention of External Auditors:

The Manager may approve the outsourcing of specific audits to external auditors.

402.5 Review of Completed Audits:

Completed audit work, including the final audit report, will be reviewed by the Manager or his/her designees, whether the audit is performed by a staff member or an external auditor.

402.6 Scope of Authority:

Internal Audit’s audit authority extends to all divisions and related entities of the Archdiocese. The services provided by Internal Audit are advisory in nature, and Internal Audit does not have any authority or responsibility over the activities or the personnel whose work is being reviewed.


403 AUDIT RESPONSIBILITIES


403.1 Statement of Qualifications:

Internal Audit staff members (and any external auditors retained to provide additional assistance) must have sufficient background and experience to audit a broad range of financial and operating environments competently and effectively.

403.2 Statement of Responsibilities:

In accordance with established general audit procedures, Internal Audit has the following responsibilities when performing the audits:

Review records, reports, and activities of the entity under audit to determine compliance with Archdiocesan policies, procedures, laws and regulations.
Be alert to operating controls and activities that might help assess whether the entity’s employees perform their tasks honestly, accurately, efficiently, and with completeness.
Report any deficiencies to the proper level of management and/or the Audit Committee of the Board of Financial Administration.
Maintain the highest level of confidentiality related to any information obtained or reviewed.
To perform special assignments as requested by the Manager.


404 AUDIT PROCESS AND PROCEDURES


404.1 Audit Selection Process:

Entities will be selected for audit in the discretion of the Manager, with the approval of the Executive Director of the Division of Management Services and/or the Audit Committee of the Board of Financial Administration, based on the following factors and criteria.

404.1.1 Periodic Audits:

Archdiocesan guidelines require that parishes and schools be audited on a 3-year cycle if possible.

404.1.2 Selection Criteria:

When developing the audit plan, the Manager considers several criteria (i.e. last audit, audit rating, change in Pastor/Principal, poor financial health/leadership, past-due reporting/receivables, etc.).

404.1.3 Audit Requests:

Audits will also be performed at the request of the Archbishop/Vicar Bishops, Catholic Center Management or entity’s Pastor/Principal.

403.2 Audit Plan:

The audit plan shall include approximately 65 audits to be performed per audit year by internal or external resources, as determined by the Manager. The audit plan shall specifically describe the entities to be audited according to the criterion specified in policy

403.1.

403.3 Staff Assignments:

To ensure complete objectivity and independence of Internal Audit, staff members will not be selected to audit activities that the staff member would ordinarily be expected to oversee or perform in the course of his/her job duties. In situations of suspected fraud, theft, or gross mismanagement, a qualified, independent auditor specializing in forensic accounting will be contracted to investigate and review the case.

403.4 Reporting Procedures:

403.4.1 Exit Conference:

Upon completion of each audit, an exit conference shall be scheduled between the internal auditor that completed the audit and the leadership of the audited entity to review the audit results. The purpose of the exit conference is to provide the entity with an opportunity to provide initial responses to the audit results prior to the auditor drafting a final report.

403.4.2 Preliminary Review of Draft Final Report:

A draft of the final audit report will be sent to the pastor/PLD/principal and appropriate staff of the audited entity for review. The Manager’s comments and the audited entity’s responses to the issues raised in draft will be included in the final audit report.

403.4.3 Distribution of Final Report:

Copies of the final version of the report (and/or an Executive Summary in the case of a lengthy audit report) shall be sent to the Archbishop, Vicar Bishops (including Vicar General), Executive Director of Management Services, Clergy Personnel (if applicable), the School’s Superintendent and Director of Finance (if applicable), the Pastor/Principal, President of the Parish Council/School Board, Chair of the Parish/School Finance committee, and Corporators. A copy of the final report must also be included in the auditor’s work file.

403.4 Reporting Obligations of Manager of Internal Audit:

The Manager is responsible for keeping the Archdiocesan executive staff informed of any unusual financial transactions, or other matters of significance noted in the audit reports. If the Manager believes that these matters are not satisfactorily resolved by management, these matters should be reported to the Audit Committee, Vicar Bishop, and/or Vicar General. If the manager continues to believe that a significant matter has not been satisfactorily resolved, the Manager may report the matter to the Archbishop and Chairman of the Board of Financial Administration.

403.5 Follow-up Audit Procedures:

Depending on the number of and/or severity of issues noted in an audit report, if any, follow-up audit procedures may be performed as long as there are sufficient resources available to complete the follow-up without delaying completion of the audit plan.


500 PARISH & SCHOOL REPORTING CALENDAR


The following calendar of reporting requirements has been established to ensure proper stewardship, to comply with Federal and State regulations, and to ensure that each location can respond timely to requests for information.


501 REPORTING CALENDAR


Policy:
All parishes and Archdiocesan, ACS, parish, and Interparish/Regional schools must comply with the following calendar of Federal and State tax-reporting requirements:

Procedure:

By January 31st:

Furnish employees and independent contractors with form W-2 or 1099.

File 941 & deposit any un-deposited federal payroll withholdings

File MW506 & deposit any un-deposited state payroll withholdings

File Parish Quarterly Report with the Archdiocese

By January 31st:

File forms W-2 & W-3 if filing in paper format.

Note: Do not file these before January 31 as changes can be made up to this date to correct errors.

File forms 1099 & 1096 if in paper format.
File forms MW 508.

By January 31st:

File forms W-2 and 1099 if filing electronically

By February 15th:

Request new W-4 and MW-507 from employees if changes have occurred

By April 15th:

File Maryland Form 1

By April 30th:

File 941 & deposit any un-deposited federal payroll withholdings
File MW506 & deposit any un-deposited state payroll withholdings
File Parish Quarterly Financial Report.

By July 31st:

File 941 & deposit any un-deposited federal payroll withholdings
File MW506 & deposit any un-deposited state payroll withholdings

By August 15th:

File Parish Annual Financial Report.
File School Annual Financial Report.
File School Fall Marketing Survey.

By September 30th:

File Parish Annual Consolidated Report.
File School Year End Marketing Survey.

By October 31st:

File 941 & deposit any un-deposited federal payroll withholdings
File MW506 & deposit any un-deposited state payroll withholdings
File Parish Quarterly Financial Report.

By December 1st:

Remind employees to submit a new Form W-4 if their withholding allowances have changed or will change in the next year.


600 SPECIAL ASSESSMENTS OF PARISHES FOR THE SUPPORT OF CATHOLIC SCHOOLS


601 GENERAL PROVISIONS


601.1 Purpose:

To partially fulfill the obligation of the People of God to support Catholic Schools and the unique education they bring to the children within the Archdiocese of Baltimore

601.2 Restrictions:

The funds acquired through this special assessment are specifically restricted to use in parish, interparish, or Archdiocesan schools.

601.3 Definitions:

Archdiocesan School – Any separately incorporated school with respect to which the Archbishop has significant reserved powers including those schools established as Archdiocesan Collaborative Schools (ACS) by the Archbishop.

Parish Offertory – Those funds entered in accounts 4010-4050 of the Uniform Charter of Accounts for the Archdiocese of Baltimore.

Parish School – Any school that is owned and operated by a parish within the Archdiocese of Baltimore.

Interparish/Regional School – Any incorporated school that has been formed to serve two or more parishes in the Archdiocese of Baltimore and has parishes as sponsors and/or as affiliates of the school.

School building – Any building where the primary use is for the instruction of students or for the administration of educational programs.

601.4 Special Assessment Rate:

The Special Assessment called for in this Policy will be assessed at a rate of 1 to 5% of a parish’s annual offertory, depending on the parish’s average offertory for the prior two years, as follows:

Annual Offertory Amount

Contribution %

Less than $100,000 1%

$100,001-$200,000 2.5%

$200,001-$500,000 3.5%

$500,001 and over 5%


602 IMPLEMENTATION


602.1 Notice:

Each parish will be notified of its Special Assessment amount prior to September of each year, in order to allow the parish to plan and incorporate the assessment into its upcoming budget (for the fiscal year beginning the following July).

602.2 Planning:

Each parish will develop its own plan to satisfy the Special Assessment amount and will share this plan with the Vicar General and Division of Fiscal Services by November 1 of each year.

602.3 Due Date:

The parish will pay the Special Assessment amount by March 31 of each year.

602.4 Exceptions:

A parish may petition the Archbishop for a waiver of any one year’s Special Assessment.


603 SATISFACTION OF SPECIAL ASSESSMENT


A parish may satisfy its Special Assessment as follows.

603.1 Direct Payment of Special Assessment:

A parish may satisfy the Special Assessment by making direct payment to the Archdiocese, utilizing the following sources of funds:

Parish overage (or rebate) from Annual Appeal;
General offertory;

Proceeds from the sale or lease of a school building that are over and above any amount used by the parish to pay a debt or obligation to the Archdiocese, as required in the use of Proceeds from Sale and Lease of School Buildings policy, available here.
With approval of the Archbishop, funds from special fund raising activity for this purpose are exempt from Cathedraticum and may include:

Second Collections;

Special Appeals; and

Parish Fund Raising Events.

603.2 Credit for Special Assessment Amount:

A parish may obtain a credit to satisfy or reduce its Special Assessment amount by engaging in the following activities.

603.2.1 Direct Tuition Assistance – Parishes may receive credit for direct tuition assistance of Catholic schools as follows:

A parish with a Catholic school (parish or ACS school) on its property or which is formally an affiliate or sponsor of an interparish/regional school, may provide direct tuition assistance to that school.

A parish may support the Catholic school education of its parishioners at Archdiocesan, interparish or parish schools with direct tuition assistance provided to the Catholic school(s) of its parishioners.

603.2.2 Direct School Subsidy

– Direct subsidies to an Archdiocesan, interparish, or parish school, which includes payments to schools for anything other than tuition assistance, such as documented payment of utility bills, maintenance costs, or other expenses by the parish for the benefit of the school.

Procedure:
A parish with a Catholic school (parish or ACS school) on its property or which is formally an affiliate or sponsor of an interparish/regional school may provide direct subsidies to that school. Other parishes without schools or regional school arrangements are asked to submit payments directly to the Archdiocese.

603.2.3 Endowment

– Contributions to existing parish endowment funds for Catholic schools made through the Catholic Community Foundation may satisfy up to 33% of a parish’s Special Assessment.



700 CATHOLIC COMMUNITY FOUNDATION ENDOWMENTS


The Catholic Community Foundation (CCF) is a separate Archdiocesan Foundation set up specifically to hold endowments created by Archdiocesan faithful, parishes and schools. The endowments, which are assets of the foundation, may also have split-interest type arrangements with Archdiocesan parishes, schools, and entities.

The creation of a CCF endowment must be formally approved and subject to the guidelines established by the Investment Committee of the Archdiocese. The following policy and procedures identify when split-interest arrangements exist between CCF and parishes, schools, or other Archdiocesan entities


701 RECORDING CCF FUNDS


701.1 Transfer of Parish Assets:

When a parish decides to move existing parish assets into the CCF to establish an endowment in which the parish is identified as receiving annual distributions from the fund, the asset will be treated as a “split-interest” type asset and be recorded as an asset on the books of CCF and the parish.

Procedure:

A) The following entry will be made to establish a split-interest CCF asset in which the funds originated from an existing parish asset (cash, savings, or other investment or endowment) recorded on their books:

1501 – CCF Endowment
Existing asset.

B) The purpose of this entry is to record the asset value of the CCF investment and show a resulting decrease in the asset utilized to create the CCF asset.

701.2 Component Fund:

When an Archdiocesan faithful establishes a fund within the CCF and the fund is identified as “component fund” of the parish, the asset will be treated as a “split-interest” type asset and be recorded as an asset on the books of CCF and the parish.

Procedure:

A) The following entry will be made to establish a split-interest CCF asset in which an Archdiocesan faithful establishes a named fund that is considered a “component fund” of the parish:

501- CCF Endowment

4740 or 4750 Parish or Educational Endowment Income.

B) The purpose of this entry is to record donation income related to a “split-interest” fund in which the named fund was identified as a “component fund” of the parish. Note: Accounts 4740 and 4750 are not subject to Cathedraticum tax.

701.3 CCF Not a Parish Asset:

If a named CCF fund is created by an individual and it is not identified as a “component fund” of the parish, it will not be recorded on the parishes accounting records. This treatment will not change even if the parish is named as receiving annual distributions from the fund.

701.4 CCF Distributions:

Each endowment fund established in the CCF sets aside on a monthly basis an allotment of dollars to be distributed at fiscal year-end. Typically the distributions are sent to beneficiaries in September/October following the end of the fiscal year. On a quarterly basis, an estimate of likely distributions is reported to all parties with a significant interest in the fund.

Procedure:

A) Parishes that have a split-interest with a CCF fund should not report any estimated income from the fund at fiscal year-end or at any time during the year based on the quarterly report information. This is because the market value of the CCF fund will be recorded on the parish’s records. Recognizing estimated future proceeds would result in a duplicate recognition of the asset.

B) When the parish actually receives a distribution check from CCF the following entry should be made:

1110 Operating checking (or equivalent)

4440 or 4450 Interest & Dividend Income Restricted or Operations.

C) The purpose of this entry is to record cash received from split-interest CCF investment.

701.5 CCF Market Value and Asset Value:

The value of any CCF fund in which the parish has a split-interest shall be shown on the balance sheet at its current market value.

Procedure:

A) On a quarterly basis, a CCF fund report will be sent to all parties with a significant interest in the fund. This report will indicate any changes to the asset due to additional dollars being added to the fund, interest earned, decreases from disbursements and changes due to market conditions. The parish should utilize this report to compare the asset value of the CCF fund in their accounting system (prior to making any adjustments) to value shown on the quarterly report.

B) If the asset value has increased, the parish will need to make a debit entry to account 1501 for the difference. If the asset value has decreased, the parish will need to make a credit to account 501 for difference. The opposite debit/credit will be recorded to account 4495 Gain or Loss Permanently Restricted Asset:

1501- CCF Endowment (if asset value increased)

1501 – CCF Endowment (if asset value decreased)

4495- Unrealized Gain/Loss Perm. Restricted Asset (if asset value decreased)

4495- Unrealized Gain/Loss Perm. Restricted Asset (if asset value increased).

C) The purpose of this entry is to adjust the CCF Endowment asset to match the market value. Changes in the value of the parishes CCF investment are not subject to Cathedraticum tax.



800 INVESTMENT MANAGEMENT


Archdiocesan parishes and schools are entrusted by parishioners and families to be good stewards of gifts and tuition. A vibrant parish community will save and invest proceeds in excess of ongoing operations for future uses and needs of the parish.

Funds for immediate operating needs are generally held in a local FDIC insured bank. However, funds collected for future uses shall be safeguarded by following the Archdiocesan Investment Management Policy and Procedures that follow.


801 ORGANIZATIONS ESTABLISHED FOR INVESTMENT MANAGEMENT


801.1 The Inter Parish Loan Fund, Inc.:

The “IPLF” was incorporated in the State of Maryland specifically for the purpose of providing depository, investment, and financing services to parishes, schools and other institutions affiliated with the Roman Catholic Archbishop of Baltimore. The Inter Parish Loan Fund, Inc. currently offers two financial services products:

Deposit and Loan Program – accepts demand deposits, on which it pays interest at short-term rates, and provides loans for approved capital projects.
Investment Program – makes available, under an investment management agreement with a financial institution acting as custodian, a range of investments for longer term goals.
The Board of the IPLF has adopted Operating Guidelines for the administration of each Program offered by the IPLF which are provided to, and, by its participation in such program are agreed to by, each parish, school and other institution utilizing such Program.

801.2 The Catholic Community Foundation of the Archdiocese of Baltimore, Inc.:

The “CCF” has been established to manage endowment for parishes, schools and other Archdiocesan organizations. Endowments are created for the purpose of providing a permanent source of funding for particular operating needs of such organizations. Within CCF there are four major types of endowments: Field of Interests, Organizational, Individuals, and Donor Advised.

801.3 Goals of the IPLF and CCF:

The Boards of Inter Parish Loan Fund, Inc. and The Catholic Community Foundation of the Archdiocese of Baltimore, Inc., as well as the Archdiocese, are all committed to educating pastors and parish/school leadership about the Archdiocesan Investment policy and procedure and to encouraging parishes and schools to establish and maintain an appropriate level of savings and operating fund and to develop endowments and utilize investment opportunities to meet their investment objectives


802 INVESTMENT OPTIONS


Parishes and schools of the Archdiocese of Baltimore have three main investment options based upon the investment objectives as determined by the parish or school in accordance with Archdiocesan Investment Management Policy:

802.1 Highly Liquid Short Term Investments:

802.1.1 Objective:

The investment objective for this category is the preservation of cash so it is available when needed, utilizing very low risk vehicles with modest and predictable interest income. This “rainy day” fund is vital and necessary before an organization should consider more risky but potentially higher return investment opportunities.

802.1.2 Deposit and Loan Program Minimum Investment:

The Deposit and Loan Program of the IPLF was established to hold funds in excess of operating needs and is a required savings option for each parish and school. Before a parish or school may invest in other types of investments it must first establish a deposit balance with the IPLF equal to at least four months of operating needs.

802.1.3 Other Short-Term Investments:

Other possible short-term investments include Certificates of Deposit and other short-term investments offered by private banks (such as money market mutual funds), US Treasury bills, and other short term options that are offered as part of the Investment Program of the IPLF.

802.2 Longer-Term Investments

802.2.1 Objective:

The investment objective for this category is the growth of funds invested and achievement of higher returns in excess of that which is usually possible with short-term investments; however, the investor will have a greater chance of losing principal. Depending on investment options chosen there may be a reduction in liquidity, due to restrictions on when funds can be withdrawn.

802.2.2 IPLF Investment Program:

PNC Bank is the custodian and administrator of the Investment Program offered by the IPLF. The IPLF Investment Program is intended to:

a. Provide a vehicle for the investment of those funds which are separate and in excess of those funds held for operating needs.

b. Provide parishes and schools with multiple investment options.

c. Provide investment options that will be part of the fiduciary oversight function of the IPLF Board.

d. Offer investment diversification, both in the number and type of investment managers and investment strategies.

e. Provide investment options that are cost-effective.

f. Provide reporting of investment activity on a monthly basis

802.3 Endowments

802.3.1 Objective:

The investment objective for this category is to create a fund with principal that may never be used by the organization, but that generates income sufficient to create a revenue stream in perpetuity that can be applied towards certain operating needs.

802.3.2 CCF Endowment Program: CCF holds all endowments within the Archdiocese of Baltimore. Funds should only be established in this category when the requirements for operating stability, savings, and investment have been comfortably achieved. Endowments are vital to a parish or school especially when there are operating needs that may continue when the parish or school may no longer be operating, such as a cemetery.


803 INVESTMENT PROCEDURES


803.1 Deposits and Withdrawals under the IPLF Deposit and Loan Program:

The IPLF Board has made the Division of Fiscal Services responsible for all administrative duties related to the IPLF Deposit and Loan Program, including all deposit and withdrawal requests.

Procedure:

A) All deposits should be sent to the Division of Fiscal Services with appropriate instructions.

B) Withdrawal requests should be sent directly to Division of Fiscal Services. Only withdrawals approved by the pastor may be processed by the Division of Fiscal Services.

C) Refer to Facilities Policy 100 for further detail on the IPLF and loan requirements.

803.2 Use of IPLF Investment Program:

The IPLF Board has made PNC Bank responsible for all administrative duties related to the IPLF investment Program.

Procedure:

A) All correspondence should be made directly to PNC Bank utilizing the standard Investment Program Form, available here.

B) Parishes and schools must have minimum reserves on deposit with the IPLF under the Deposit and Loan Program before any other investment options may be considered.

C) Parishes and schools, with their leadership, boards, and finance councils, must identify and document investment policies and objectives for these funds that are appropriate to the risk profile and financial demands of the location.

D) The IPLF Investment Program may not be used for endowments. All endowments shall be in the Catholic Community Foundation of the Archdiocese of Baltimore, Inc.

E) The standard IPLF Investment Program Form has two sections related to investment choices:

Option A – Provides fund options which are designed to always have a mixture of fixed income assets and equity assets as part of their portfolio. Investments may be made in one or more of the actively managed balanced funds by indicating the percentage to be invested on the Form that is sent to PNC Bank administrative team.

Option B – Provides a listing of funds offered by type of asset category. Asset categories included are Money Markets, Fixed Income, Large Cap Equities and Other Equity Strategies. Investments may be made in one or up to six different funds in this category. However, investment in equity (stock) funds is limited to 70% of the portfolio.

F) Choices may be made from either Option A or Option B but should not be made from both. An exception is the money market fund listed under Option B.

G) After initial selection of investments, selections may be changed, but changes are limited to twice per year.

803.3 Oversight of Investment Options:

803.3.1 Fiduciary Status:

In the performance of its oversight of the investment options offered under the Investment Program, the IPLF is a fiduciary, responsible for acting solely in the interest of the parishes and schools that make investments under the Investment Program.

803.3.2 Annual Reporting:

The IPLF will provide, at least annually, information on the investment options, which information may include prospectuses, historical return information (net of fees), and fees. Changes to investment options offered may be made by the IPLF and the reasons for such changes will be provided.

803.3.3 Social Responsibility:

It is the intent of the IPLF to make available socially responsible investment options, consistent with the USCCB guidelines, where available and appropriate.

803.4 Restrictions on Investments Outside of the IPLF Investment Program:

803.4.1 Individual Stocks and Bonds:

Parish and schools may not invest in individual stocks and bonds. If securities are received from a donor as a gift, the donor should be provided the “Instructions for Gifts of Securities,” available here.

803.4.2 Minimum Investment in IPLF Deposit and Loan Program: Unless restricted by a donor, Archdiocesan parishes and schools may not participate in the IPLF Investment Program or establish an endowment unless adequate funds are maintained in deposits held as part of the IPLF Deposit and Loan Program.

803.4.3 Approval of Other Outside Investments:

If a parish, school or other organization desires to have investments in fixed income and equity funds outside of the options provided in the IPLF Investment Program, approval must be requested from the Archbishop of Baltimore.

Procedure:

A) To help ensure diligent oversight and competitive fees, the investment of any funds outside of the IPLF Investment Program should be at a minimum of $5 million before justification can be made to create investments outside of the IPLF Investment Program.

B) If this minimum criterion is met the following information should be provided to the Archbishop along with the request, to aid his decision making process:
Source of funds
Donor restrictions, if any, and documentation of such
Amount of initial investment

Purpose of the investment

Period of time before the funds will be used

Support at the local level (pastor, finance chair, school board etc.)

Proposed investment vehicle(s)/methods(s)

Investment Policy Statement of the fund (required if approval is granted).

C) If outside investments are approved, the investments and investment account must be “titled” in the name of the Inter Parish Loan Fund, Inc. for the benefit of the specific parish or school.

D) The IPLF c/o the Division of Fiscal Services should receive quarterly reports from the investment managers showing investment performance and asset allocations. Socially Responsible Investing guidelines by the USCCB must always be followed for any outside investments.

803.5 Creating an Endowment in the CCF:

Endowments differ from traditional investments because endowments are intended to serve as a permanently restricted asset whereby the organization no longer has any access to the investment corpus. Only the income generated by the investment may be used pursuant to a methodology that ensures the permanent status of the investment. The Catholic Community Foundations of the Archdiocese of Baltimore, Inc. was created specifically to meet these needs. Parishes and schools should take great care before establishing an endowment from excess operating or reserve funds, acknowledging the long term permanently restricted nature of the endowment structure.

Procedure:

A) The CCF Board has outsourced administrative responsibility to Central Services of the Archdiocese of Baltimore. The Department of Development in particular helps establish new funds within CCF.

B) Investments in and distributions from funds established in the CCF are governed by the fund documentation, the CCF Board and its advisory committees.

C) Parishes and schools need to contact CCF directly to establish an organizational fund.

D) If a parishioner would like to create an individual named endowment for a specific purpose(s) they should be directed to the CCF.

E) All annual payments from the fund will be per the spending formula established by the Board of the Catholic Community Foundation. The CCF Board has fiduciary responsibility and ownership over the funds.

F) For further details regarding CCF, see Fiscal Services Policy 700, available here.