The School Support The School Support Organization Financial Organization Financial

Accountability Act of 2007Accountability Act of 2007((as amended 2008as amended 2008))

Presented byPresented by

Chadwick W. Jackson, JDChadwick W. Jackson, JD

Staff AttorneyStaff Attorney

Office of the Comptroller of the Office of the Comptroller of the TreasuryTreasury

Division of Municipal AuditDivision of Municipal Audit

What is this law about?What is this law about?

This legislation governs groups or This legislation governs groups or organizations that raise money in the organizations that raise money in the name of a school to support the name of a school to support the school and its students.school and its students.

Who does this law affect?Who does this law affect?

If money is raised by a If money is raised by a nongovernmental group in the name nongovernmental group in the name of a school and for the benefit of a of a school and for the benefit of a school or its students…that group is school or its students…that group is a school support organization (SSO) a school support organization (SSO) and must comply with this law.and must comply with this law.

What is the law intended What is the law intended to do?to do?

Promote accountability for school support Promote accountability for school support organizations;organizations;

Protect the school support organization Protect the school support organization members from certain personal civil members from certain personal civil liability through incorporation;liability through incorporation;

Promote consumer and donor confidence Promote consumer and donor confidence in the school fundraising process by in the school fundraising process by outside support organizations; andoutside support organizations; and

Provide legitimacy to school support Provide legitimacy to school support organizations.organizations.

What is a School Support What is a School Support Organization?Organization?

Booster Club,Booster Club, Foundation,Foundation, PTA,PTA, PTO,PTO, PTSA, orPTSA, or Any nongovernmental organization or group Any nongovernmental organization or group

of persons whose primary purpose is to of persons whose primary purpose is to support a:support a: School,School, School district,School district, School club, orSchool club, or Academic, arts, athletic or social activities Academic, arts, athletic or social activities

related to a school.related to a school.

School Support Organizations School Support Organizations are the only organizations or are the only organizations or groups that can raise money groups that can raise money in the name of a school or in the name of a school or school district.school district.

Why are they the only Why are they the only groups?groups?

TCA TCA § § 49-2-604: “A group or 49-2-604: “A group or organization organization may notmay not use a school use a school district’s or school’s name, mascot, or district’s or school’s name, mascot, or logos, property, or facilities logos, property, or facilities for the for the raising of money, materials, property, or raising of money, materials, property, or securitiessecurities until a policy has been until a policy has been adopted by the local board of adopted by the local board of educationeducation concerning cooperative concerning cooperative agreements, school support agreements, school support organizations, and the use of school organizations, and the use of school facilities for fundraising purposes.”facilities for fundraising purposes.”

Therefore…Therefore…

The Board Policy MUST require the The Board Policy MUST require the group or organization to be a group or organization to be a nonprofit entity.nonprofit entity.

That nonprofit entity MUST be a That nonprofit entity MUST be a school support organization.school support organization.

The primary purpose of the nonprofit The primary purpose of the nonprofit entity MUST be to support the school entity MUST be to support the school system, school or its athletics, clubs system, school or its athletics, clubs or social activities.or social activities.

Who or What is Who or What is NOTNOT a School a School Support Organization?Support Organization?

……aa group of persons who merely group of persons who merely request that students, parents, request that students, parents, or members of the general public or members of the general public make donations to a school make donations to a school district, school, school club, or district, school, school club, or academic, arts, athletic, or social academic, arts, athletic, or social activity related to a schoolactivity related to a school… OR… OR

Who or What is Who or What is NOTNOT a School a School Support Organization?Support Organization?

……who assist in the raising of who assist in the raising of funds for a specified purpose funds for a specified purpose under the sponsorship of a under the sponsorship of a school employee where the school employee where the funds are turned over to the funds are turned over to the school to be used for the specific school to be used for the specific purpose for which the funds purpose for which the funds were raisedwere raised……

A Fork in the A Fork in the Road…Road…

Two Paths From Which Two Paths From Which To Choose…To Choose…

I.I. Run the fundraiser Run the fundraiser through the school.through the school.

II.II. Run the fundraiser Run the fundraiser through the not-for-through the not-for-profit incorporated SSO.profit incorporated SSO.

Through the SchoolThrough the School

A school employee is in charge A school employee is in charge of the fundraiser.of the fundraiser.

The school employee is The school employee is responsible for collecting, responsible for collecting, receipting, accounting for, and receipting, accounting for, and safeguarding the money from safeguarding the money from the fundraiser.the fundraiser.

Through the SchoolThrough the School

The school sponsor turns the money The school sponsor turns the money over to the school’s bookkeeper to over to the school’s bookkeeper to be run through the school’s be run through the school’s accounting system.accounting system.

The bookkeeper keeps a separate The bookkeeper keeps a separate account within the overall accounting account within the overall accounting system for the money.system for the money.

The bookkeeper deposits the money The bookkeeper deposits the money into the school’s bank account.into the school’s bank account.

The end result…The end result…

By law, money received through that By law, money received through that fundraising effort must be spent in fundraising effort must be spent in accordance with the purpose for accordance with the purpose for which it was raised.which it was raised.

Therefore, if the school-Therefore, if the school-sponsored fundraiser is for new sponsored fundraiser is for new uniforms for the basketball uniforms for the basketball team…the money can only be team…the money can only be spent for new uniforms for the spent for new uniforms for the basketball team.basketball team.

What becomes of the SSO?What becomes of the SSO?

In order to achieve this type of In order to achieve this type of fundraising activity, the fundraising activity, the members/parents of the traditional members/parents of the traditional booster club act as booster club act as volunteersvolunteers for for the school as part of a the school as part of a collaborative collaborative effort between parents and the effort between parents and the school to raise money for a specific school to raise money for a specific purpose.purpose.

What does all this mean?What does all this mean?

I.I. The “parent volunteers” do not fall The “parent volunteers” do not fall under the definition of a “school support under the definition of a “school support organization” under the SSOFAA.organization” under the SSOFAA.

II.II. The “parent volunteers” assist the The “parent volunteers” assist the school with the fundraising activities school with the fundraising activities and are not responsible for the financial and are not responsible for the financial aspects of the fundraiser…aspects of the fundraiser…

……that becomes the that becomes the responsibility of the school.responsibility of the school.

What does all this mean?What does all this mean?

III.III. The “parent volunteers” can still The “parent volunteers” can still raise money that is needed for raise money that is needed for specific items by the particular specific items by the particular group or groups they support.group or groups they support.

IV.IV. The “parent volunteers” do not The “parent volunteers” do not have to incorporate, elect officers, have to incorporate, elect officers, maintain bylaws, or maintain maintain bylaws, or maintain financial statements.financial statements.

Caveat!!! Caveat!!! There’s one catch…There’s one catch…

The “parent volunteers” can only The “parent volunteers” can only dictate how the money is spent at the dictate how the money is spent at the outset when the fundraiser is planned outset when the fundraiser is planned if it is to be for a “specific item” or if it is to be for a “specific item” or “specific purpose”…“specific purpose”…

……otherwise it falls into the otherwise it falls into the broader category and the coach or broader category and the coach or sponsor must follow school policy and sponsor must follow school policy and decide how the money is spent for their decide how the money is spent for their group.group.

BECAUSE…BECAUSE…

““A group of persons who…assist in A group of persons who…assist in the raising of funds for a specified the raising of funds for a specified purpose under the sponsorship of a purpose under the sponsorship of a school employee where the funds are school employee where the funds are turned over to the school turned over to the school to be used to be used for the specific purpose for which the for the specific purpose for which the funds were raisedfunds were raised, shall not be , shall not be considered a school support considered a school support organization.”organization.”

Behind Door #2!!!Behind Door #2!!!

What must be done What must be done in order to raise in order to raise

money as an money as an outside support outside support organization or organization or booster club?booster club?

What the law says…What the law says…

TCA TCA § § 49-2-604: “A group or 49-2-604: “A group or organization organization may notmay not use a school use a school district’s or school’s name, mascot, or district’s or school’s name, mascot, or logos, property, or facilities logos, property, or facilities for the for the raising of money, materials, property, raising of money, materials, property, or securitiesor securities until a policy has been until a policy has been adopted by the local board of educationadopted by the local board of education concerning cooperative agreements, concerning cooperative agreements, school support organizations, and the school support organizations, and the use of school facilities for fundraising use of school facilities for fundraising purposes.”purposes.”

The responsibility of The responsibility of the Board of Educationthe Board of Education

I.I. Adopt a policy concerning:Adopt a policy concerning:a. Cooperative Agreementsa. Cooperative Agreementsb. School Support b. School Support

OrganizationsOrganizationsc. The use of school facilities c. The use of school facilities

for for fundraising purposes. fundraising purposes.II.II. Develop a process to certify valid Develop a process to certify valid

school support organizations school support organizations authorized to raise money for local authorized to raise money for local schools.schools.

****These must be done before any ****These must be done before any fundraising will be allowed!!!fundraising will be allowed!!!

The responsibility of The responsibility of the Director of Schools the Director of Schools

or his/her designeeor his/her designee Post or publish a list of Post or publish a list of organizations that have organizations that have complied with the adopted complied with the adopted board of education policy on board of education policy on school support organizations.school support organizations.

Do not allow fundraising Do not allow fundraising activities without approval.activities without approval.

The School Board’s The School Board’s PolicyPolicy

Shall include at a minimum that…Shall include at a minimum that…

i. Prior to soliciting, raising, or collecting i. Prior to soliciting, raising, or collecting money, materials, property, or securities to money, materials, property, or securities to support a school district, school, school support a school district, school, school club, or any academic, arts, athletic, social club, or any academic, arts, athletic, social activity or event related to a school…activity or event related to a school…

……a school support a school support organization shall submit to the organization shall submit to the director of schools or his/her designee director of schools or his/her designee a form that documents certain things.a form that documents certain things.

The form shall include the The form shall include the following:following:

(A)(A) The organization’s status as a The organization’s status as a nonprofit organization, foundation, or nonprofit organization, foundation, or a chartered member of a nonprofit a chartered member of a nonprofit organization or foundation;organization or foundation;

(B)(B) The goals and objectives of the The goals and objectives of the organization; andorganization; and

(C)(C) The telephone number, address, and The telephone number, address, and position of each officer of the position of each officer of the organization.organization.

What does it mean to be a “nonprofit What does it mean to be a “nonprofit organization”?organization”?

The long and the short of it is…The long and the short of it is…

CHARTERCHARTER

How to charter as a nonprofit How to charter as a nonprofit organizationorganization

I.I. Fill out Form SS-Fill out Form SS-4418 (Nonprofit 4418 (Nonprofit Charter Form) Charter Form) from the from the Secretary of Secretary of State.State.

II.II. Fill out Form SS-Fill out Form SS-4520 (Statement 4520 (Statement of Exemption).of Exemption).

Mail those two Mail those two forms to the forms to the Secretary of Secretary of State’s Office, State’s Office, Division of Division of Business Business Services in Services in Nashville.Nashville.

A few notes on filling out theA few notes on filling out the Nonprofit Charter Nonprofit Charter

Anyone can be listed as the nonprofit Anyone can be listed as the nonprofit corporation’s registered agent….so corporation’s registered agent….so long as they have a Tennessee long as they have a Tennessee address.address.

Anyone associated with starting the Anyone associated with starting the nonprofit corporation can be listed as nonprofit corporation can be listed as an “incorporator” on the charter.an “incorporator” on the charter.

A few notes on filling out theA few notes on filling out the Nonprofit Charter Nonprofit Charter

If the school board and the principal If the school board and the principal will allow it, mail and other corporate will allow it, mail and other corporate documents can be sent to the school documents can be sent to the school to make things easier on the booster to make things easier on the booster club’s officers who may only be in club’s officers who may only be in office for a year.office for a year.

How to be a booster club How to be a booster club under the SSOFAAunder the SSOFAA

I.I. Comply with the local board policy.Comply with the local board policy.II.II. Maintain bylaws.Maintain bylaws.III.III. Keep minutes of meetings.Keep minutes of meetings.IV.IV. Maintain a copy of your charter.Maintain a copy of your charter.V.V. Retain a copy of what the Sec of State Retain a copy of what the Sec of State

sends back to you when you file your sends back to you when you file your charter.charter.

VI.VI. Maintain detailed statements of receipts Maintain detailed statements of receipts and disbursements.and disbursements.

VII.VII. Adopt and maintain a written accounting Adopt and maintain a written accounting policy for your booster club.policy for your booster club.

Written Written Accounting PolicyAccounting Policy

What the law says:What the law says: “A school “A school support organization’s officers support organization’s officers shall ensure that school support shall ensure that school support organization funds are organization funds are safeguarded and are spent only safeguarded and are spent only for purposes related to the goals for purposes related to the goals and objectives of the and objectives of the organization.”organization.”

Written Written Accounting PolicyAccounting Policy

Specifically, the law states that:Specifically, the law states that: “The organization shall adopt “The organization shall adopt and maintain a written policy and maintain a written policy that specifies reasonable that specifies reasonable procedures for accounting, procedures for accounting, controlling and safeguarding any controlling and safeguarding any money, materials, property or money, materials, property or securities collected or disbursed securities collected or disbursed by it.”by it.”

Model Financial Policy Model Financial Policy ““Procedures ManualProcedures Manual””

The SSOFAA authorizes the Office of The SSOFAA authorizes the Office of the Comptroller to adopt a model the Comptroller to adopt a model financial policy for school support financial policy for school support organizations.organizations.

The “Procedures Manual” can be The “Procedures Manual” can be found on our website at found on our website at http://comptroller.state.tn.us/ma/sso.http://comptroller.state.tn.us/ma/sso.htmhtm

School Support Organizations School Support Organizations Annual RequirementsAnnual Requirements

Before the beginning of the school Before the beginning of the school year, submit a form to the director or year, submit a form to the director or his/her designee...his/her designee...

……verifying your continued verifying your continued existence as a nonprofit organization;existence as a nonprofit organization;

……stating your goals and stating your goals and objectives;objectives;

……current telephone numbers and current telephone numbers and addresses of officers;addresses of officers;

Additional Annual Additional Annual RequirementsRequirements

File a statement of total revenues File a statement of total revenues and disbursements before the end of and disbursements before the end of each school year with the director of each school year with the director of schools or his/her designee.schools or his/her designee.

Return the Annual Report to the Return the Annual Report to the Secretary of State after the close of Secretary of State after the close of each fiscal year.each fiscal year.

What a booster club is not What a booster club is not allowed to do…allowed to do…

A nongovernmental group or organization A nongovernmental group or organization

including all school support organizationsincluding all school support organizations MAY NOT…MAY NOT…

1.1. Use the school or district sales tax Use the school or district sales tax exemption to purchase items;exemption to purchase items;

2.2. Bind the school or school district to any Bind the school or school district to any contracts or financial obligations;contracts or financial obligations;

3.3. Maintain or operate a bank account Maintain or operate a bank account that bears the EIN of a school, school that bears the EIN of a school, school board or district; orboard or district; or

4.4. Use its funds for a purpose other than Use its funds for a purpose other than those related to its goals and those related to its goals and objectives that relate to supporting a objectives that relate to supporting a school district, school, school club, or school district, school, school club, or school academic, arts, athletic or social school academic, arts, athletic or social activity.activity.

A FEW WORDS ON A FEW WORDS ON

““SCHOOL SCHOOL REPRESENTATIVES”REPRESENTATIVES”

Who is a Who is a “school representative”?“school representative”?

A “school representative” isA “school representative” isI.I. A school board member;A school board member;II.II. The director of Schools;The director of Schools;III.III. A principal;A principal;IV.IV. Any school or school system’s bookkeeper; ORAny school or school system’s bookkeeper; ORV.V. Any individual who works for the school Any individual who works for the school

system who, system who, as a part of their employment by as a part of their employment by the school system is charged with directing or the school system is charged with directing or assisting in directing the related school club or assisting in directing the related school club or activity…activity…

……specifically including but not specifically including but not limited to coaches, assistant coaches, limited to coaches, assistant coaches, band directors, or any other school band directors, or any other school sponsor of a related club or activity.sponsor of a related club or activity.

What is a “school representative” What is a “school representative” not allowed to do?not allowed to do?

““A school representative may not act A school representative may not act as a treasurer or bookkeeper for a as a treasurer or bookkeeper for a school support organization.”school support organization.”

““A school representative may not be A school representative may not be a signatory on the checks of a school a signatory on the checks of a school support organization.”support organization.”

““A majority of the voting members of A majority of the voting members of any school support organization any school support organization board should not be composed of board should not be composed of school representatives.”school representatives.”

What is allowed…What is allowed… The band director can be the The band director can be the

treasurer of the basketball booster treasurer of the basketball booster club.club.

An English teacher can be treasurer An English teacher can be treasurer and sign checks for the football and sign checks for the football booster club.booster club.

Et cetera…et cetera…et cetera…Et cetera…et cetera…et cetera…

BECAUSE…BECAUSE… A school representative for purposes A school representative for purposes

of a school club or activity is the of a school club or activity is the person who is person who is in charge of directing in charge of directing or assisting in directing the club or or assisting in directing the club or activityactivity as part of their as part of their employment by the school employment by the school systemsystem..

AND FINALLY…AND FINALLY… Any teacher, coach, assistant coach, Any teacher, coach, assistant coach,

principal, bookkeeper, director, or principal, bookkeeper, director, or board member can sell items in a board member can sell items in a fundraiser for any group and act as a fundraiser for any group and act as a volunteer to assist with the raising of volunteer to assist with the raising of money for any SSO or club, money for any SSO or club, regardless of what activity it is.regardless of what activity it is.

However…However…

A school’s bookkeeper or a bookkeeper for A school’s bookkeeper or a bookkeeper for the entire school system is not allowed to the entire school system is not allowed to be the bookkeeper for any booster club in be the bookkeeper for any booster club in the district.the district.

TCA 49-2-603(3)(A)(i)(d) and (ii)(d) states TCA 49-2-603(3)(A)(i)(d) and (ii)(d) states that a school representative is that a school representative is “Any “Any individual who is primarily responsible for individual who is primarily responsible for accounting for school system funds or the accounting for school system funds or the funds of an individual school”funds of an individual school”

SPECIAL SPECIAL COMMENTSCOMMENTS

The SSOFAA does not require a school The SSOFAA does not require a school support organization to be designated as a support organization to be designated as a 501(c)(3) under the IRS tax codes.501(c)(3) under the IRS tax codes.

Nothing in the law requires SSOs to Nothing in the law requires SSOs to surrender their funds to the school surrender their funds to the school principal…principal…

……however, the board policy however, the board policy may be more restrictive than the law.may be more restrictive than the law.

SPECIAL SPECIAL COMMENTSCOMMENTS

A local board of education may grant the A local board of education may grant the principal of a school the authority to enter principal of a school the authority to enter into an agreement with a school support into an agreement with a school support organization to operate and collect money organization to operate and collect money for a concession stand or parking at a for a concession stand or parking at a school event…school event…

……where any money it collects or where any money it collects or any portion designated by the any portion designated by the agreement shall be considered as agreement shall be considered as school support organization funds school support organization funds and not as student activity funds…and not as student activity funds…

Provided that…Provided that…

Booster clubs and Booster clubs and concessionsconcessions

I.I. The board has adopted a policy The board has adopted a policy concerning school support concerning school support organizations; organizations; andand

II.II. The SSO provides the school with The SSO provides the school with the relevant collection the relevant collection documentation that would have documentation that would have been required pursuant to the been required pursuant to the provisions of the TISUAPM (the provisions of the TISUAPM (the “Manual”) for student activity funds.“Manual”) for student activity funds.

Booster clubs and Booster clubs and bookstoresbookstores

““A local board of education may grant A local board of education may grant the principal of a school the authority to the principal of a school the authority to enter into an agreement with a school enter into an agreement with a school support organization to operate a support organization to operate a bookstore located on school grounds…bookstore located on school grounds…where any money the school support where any money the school support organization collects or any portion organization collects or any portion designated by the agreement shall be…designated by the agreement shall be…school support organization funds; school support organization funds; providedprovided,,

Booster clubs and Booster clubs and bookstoresbookstores

I.I. The board has adopted a policy;The board has adopted a policy;

II.II. 100% of the profits of the 100% of the profits of the operation of the bookstore are operation of the bookstore are used for support of the school; and used for support of the school; and

III.III. The SSO provides the school with The SSO provides the school with the relevant collection the relevant collection documentation that would have documentation that would have been required by the “Manual” for been required by the “Manual” for student activity funds.student activity funds.

The Envelope The Envelope RuleRule

A principal may allow a school A principal may allow a school support organization to turn in its support organization to turn in its fundraising money during school and fundraising money during school and it may be collected by teachers and it may be collected by teachers and turned into a designated school turned into a designated school support organization member…support organization member…HOWEVER, the money must be HOWEVER, the money must be turned in using sealed envelopes.turned in using sealed envelopes.

The Envelope Rule conflicts The Envelope Rule conflicts with the “Manual”with the “Manual”

The Internal School Uniform The Internal School Uniform Accounting Policy Manual provides Accounting Policy Manual provides that once a teacher, in his or her that once a teacher, in his or her official capacity, receives money…official capacity, receives money…

……that money automatically that money automatically belongs to the school and must be belongs to the school and must be run through the school’s accounting run through the school’s accounting system.system.

So, to keep teachers from inadvertently So, to keep teachers from inadvertently violating either the “Manual” or the violating either the “Manual” or the SSOFAA, the Envelope Rule was created. SSOFAA, the Envelope Rule was created.

Thus…Thus… If the money is in a If the money is in a sealed sealed

envelopeenvelope and the teacher does and the teacher does not actually “receive”, “receipt”, not actually “receive”, “receipt”, or “handle” the money directly…or “handle” the money directly…it can continue to be school it can continue to be school support organization funds and support organization funds and therefore turned in at school.therefore turned in at school.

In a Nutshell…In a Nutshell…A school support organization A school support organization

mustmustI.I. File a charter and exemption form with File a charter and exemption form with

the Secretary of State.the Secretary of State.

II.II. Maintain organizational structure Maintain organizational structure through bylaws and officers.through bylaws and officers.

III.III. Adopt an accounting and financial Adopt an accounting and financial policy.policy.

IV.IV. Get permission from the director of Get permission from the director of schools or his/her designee before schools or his/her designee before conducting a fundraiser.conducting a fundraiser.

V.V. Keep up with records for 4 years.Keep up with records for 4 years.

A school support organization A school support organization must also…must also…

VI.VI. Document and maintain a detailed list of Document and maintain a detailed list of receipts and disbursements.receipts and disbursements.

VII.VII. Annually file a statement of total Annually file a statement of total revenues and disbursements with the revenues and disbursements with the director of schools or his/her designee director of schools or his/her designee before the end of the school year.before the end of the school year.

VIII.VIII. Maintain adequate separation of duties Maintain adequate separation of duties between SSO officers and the school between SSO officers and the school representative related to the school representative related to the school group or organization (i.e. football coach, group or organization (i.e. football coach, assistant coaches…band director…choir assistant coaches…band director…choir director…etc)director…etc)

CAUTION!!!CAUTION!!!

I.R.S. IMPLICATIONSI.R.S. IMPLICATIONS

If your booster club is not a 501(c) If your booster club is not a 501(c) corporation under the Internal corporation under the Internal Revenue Code, the booster club Revenue Code, the booster club MAYMAY HAVE TO PAY FEDERAL INCOME HAVE TO PAY FEDERAL INCOME TAXTAX on the money you raise!!! on the money you raise!!!

The booster club may be required to The booster club may be required to file a form 1120 corporate tax return file a form 1120 corporate tax return annually with the IRS.annually with the IRS.

Credits against Credits against extracurricular activity feesextracurricular activity fees

If parents receive monetary If parents receive monetary deductions on fees for extracurricular deductions on fees for extracurricular activities … the IRS may require activities … the IRS may require those parents to account for those those parents to account for those fee-credits as income.fee-credits as income.

Services performed in exchange for a Services performed in exchange for a benefit benefit == Income Income

Kentucky booster parents hit with Kentucky booster parents hit with $30,000 personal IRS bill.$30,000 personal IRS bill.

Credits against Credits against extracurricular activity feesextracurricular activity fees

NOTENOTE:: This office does not condone the use of This office does not condone the use of

“credits” given to individual students or “credits” given to individual students or their parents or “accounts” maintained their parents or “accounts” maintained on behalf of individual students.on behalf of individual students.

It appears that the SSOFAA does not It appears that the SSOFAA does not provide for nor allow the disbursement provide for nor allow the disbursement of booster club funds for the benefit of of booster club funds for the benefit of individual students. individual students.

Credits against Credits against extracurricular activity feesextracurricular activity fees

Since a “school support organization” Since a “school support organization” may not use its funds for a purpose may not use its funds for a purpose other than those related to its goals other than those related to its goals and objectives that relate to supporting and objectives that relate to supporting a school district, school, school club, or a school district, school, school club, or school academic, arts, athletic or social school academic, arts, athletic or social activity…TCA 49-2-608(3)activity…TCA 49-2-608(3)

……it would appear that credits to it would appear that credits to individual accounts are not allowed individual accounts are not allowed under the law other than those credits under the law other than those credits which are applied to which are applied to all studentsall students who who participate in the club or activity.participate in the club or activity.

Comptroller AuditsComptroller Audits

The Comptroller has the authority to The Comptroller has the authority to audit an SSO.audit an SSO.

These audits are not performed These audits are not performed annually.annually.

An SSO does not have to submit an An SSO does not have to submit an annual financial report or audit to annual financial report or audit to the Comptroller.the Comptroller.

Audits will occur on a case-by-case Audits will occur on a case-by-case basis in the event of corporate basis in the event of corporate mismanagement, theft, or a failure mismanagement, theft, or a failure to comply with the SSOFAA.to comply with the SSOFAA.

School Support School Support Organization Organization

Financial Financial Accountability Act Accountability Act

of 2007of 2007Passed May 21, 2007.Passed May 21, 2007. Amended June 13, 2008.Amended June 13, 2008.

Effective July 1Effective July 1stst, 2008., 2008.

Contact Contact InformationInformationComptroller of the TreasuryComptroller of the Treasury

Division of Municipal AuditDivision of Municipal Audit

Bank of America Plaza, Suite 1100Bank of America Plaza, Suite 1100

414 Union Street414 Union Street

Nashville, Tennessee 37243-0271Nashville, Tennessee 37243-0271

615-532-4475615-532-4475http://comptroller.state.tn.us/cpdivma.htm