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WEATHERING THE FINANCIAL STORM

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Title: WEATHERING THE FINANCIAL STORM


1
WEATHERING THE FINANCIAL STORM
Jeanne H. Yamamura, CPA, MIM, PHD
2
INTRODUCTION
  • Our world at a glance
  • Bolstering the economy
  • Top Ten Tips for Tough Times
  • Resources

3
OUR WORLD AT A GLANCE
  • Global economic challenges and issues
  • U.S. economic growth slowed recession
  • Changing regulatory environment
  • Financial markets turmoil
  • Scandals Madoff, Satyam, etc.
  • Social Security questions
  • Public pensions at risk
  • Shrinking workforce and massive layoffs
  • Sustainability and environmental issues

4
BOLSTERING THE ECONOMY
  • The Economy
  • Stock Market Loss
  • GDP Loss
  • Unemployment
  • Retirement Savings
  • Recovery
  • Financial Stability Plans
  • ARRA 2009
  • Regulatory Restructuring

5
American Recovery and Reinvestment Act of 2009
Where the money is going
6
Overview of Financial Stability Plan
7
LOCAL GOVERNMENTS IN FISCAL DISTRESS
  • Declining revenues
  • Property taxes no longer stable source
  • State governments unable to assist
  • Increasing demand for services

8
WHAT IS HAPPENING IN YOUR GOVERNMENT?
  • Table discussion topic
  • Economic problems occurring in your government
  • Actions taken
  • Actions planned
  • Outlook?
  • Report back to the class on the actions taken
    and/or proposed in response to the economic
    downturn.

9
Top Ten Tips for Tough Times
10
TOP TEN TIPS FOR TOUGH TIMES!
  • Understand and manage your revenue sources
  • Do all you can to control costs.
  • Effectively manage employee costs for the short
    term and the long term.
  • Understand your cash position.
  • Pay attention to financing sources and
    developments.

11
TOP TEN TIPS
  • Look at long-term opportunities for better asset
    utilization.
  • Strengthen controls.
  • Beware of ill-advised actions.
  • Focus on fraud prevention.
  • Keep lines of communication open.

12
TIP NO. 1 UNDERSTAND AND MANAGE REVENUES
  • Understand your revenue sources.
  • Be realistic!

13
REVENUE ESTIMATION
  • Plan scenarios and look at your risk management
    philosophies, risk tolerance and mitigation plans
  • Make conservative estimates of revenues
  • Harder to deal with shortfalls later in the year
  • How far off are we usually?
  • Budgeting less than 100 of a grant

14
REVENUE SOURCES
  • Consider every revenue source
  • Will it continue? Will it decrease? By how much?
  • Can it be increased?
  • What do others charge for the same services?
  • Evaluate reasonableness of fees.
  • Consider if higher fees are driving customers to
    other providers.

15
EXPLORE NEW REVENUE SOURCES
  • Be innovative. Are there opportunities for new
    revenue sources?
  • Establish clear cost-recovery goals
  • How are costs defined? Direct costs only?
    Fully allocated costs?
  • Verify fees are meeting cost-recovery goals

16
AUDIT REVENUES
  • Many revenues based on self-reporting
  • Liability may be understated or misreported
  • Auditing can increase revenues
  • Benefits
  • Fair, payment of rightful share
  • Ensures accuracy and consistency

17
EVALUATE FEES CHARGED - COMMON AREAS FOR
UNDERCHARGING
  • Fees to auto and homeowner insurance companies
    for
  • Fire calls, especially false alarm, jaws of
    life, cleanup of hazardous materials, and
    non-emergency calls
  • Fees for services rendered to non-residents or
    businesses
  • Title searches, permit records, voter
    information, research, extras on road
    construction, tree planting

18
EVALUATE FEES CHARGED
  • Have departments regularly review their fees to
    ensure they are kept updated
  • May need to tie operating budgets to program
    revenues to ensure attention paid to fees

19
IMPROVE BILLING AND COLLECTION PROCEDURES
  • Standardize billing procedures for all
    receivables
  • Insurance claims, damage claims, rebates, fees
    for service
  • Ensure nothing falls through the cracks due to
    lack of communication between departments and
    staff
  • Diagram exceptions procedures
  • Who has authority to approve exceptions and under
    what circumstances?

20
IMPROVE BILLING AND COLLECTION PROCEDURES
  • Establish consistent and fair collections efforts
  • Cannot ignore debt one year and expect collection
    success in the following year
  • Collections procedures
  • Clearly stated
  • Publicly available
  • Consistently applied

21
IMPROVE BILLING AND COLLECTION PROCEDURES
  • Coordinate collections efforts between agencies
  • Different levels of government have overlapping
    revenue streams, e.g., property and income taxes
  • Reconcile filings with related agencies
  • Local income tax records to state records and IRS
    filings
  • Property tax records to utility bills, other
    agency property tax records, and court records
  • Consider amnesty program

22
TIP NO. 2 CONTROL COSTS
  • Look at incremental cost reductions
  • Small things can add up!
  • For example electronic distribution instead of
    paper?
  • Also more environmentally sound!
  • Explore opportunities to consolidate back office
    operations at smaller agencies
  • With larger agency in same functional area,or
  • In a central service agency

23
REDUCE COSTS
  • Evaluate the possibility of partnering with other
    governments
  • Buying collaboratives
  • Systems
  • Functions
  • Consider contingent-fee based cost avoidance
    audits
  • Vendors find ways to cut costs

24
OTHER COST REDUCTION STRATEGIES
  • Consider revenue maximization
  • Vendors find new sources of revenue
  • Publicize what you are doing for savings
  • Solicit creative ideas
  • Remember public perception is important
  • Be conservative with travel and meeting
    arrangements
  • NO PRIVATE PLANES!!!
  • Look at travel reimbursement policies

25
ENHANCE PURCHASING PRACTICES
  • Identify bulk purchases
  • Identify items that make up bulk of purchasing
  • See if new quotes or suppliers can lower costs
  • Encourage or require joint purchasing of similar
    items by departments (e.g., office, janitorial,
    communications supplies)

26
ENHANCE PURCHASING PRACTICES
  • Standardize
  • Develop standard specifications for commodity
    items
  • Will aid in obtaining better terms from vendors
  • For example standardizing desktop personal
    computers

27
ENHANCE PURCHASING PRACTICES
  • Investigate prompt payment discounts
  • Find out if available
  • Take advantage!!
  • May require contacting suppliers and apologizing
    for past behavior!
  • Institute practices to ensure late payment
    penalties avoided

28
ENHANCE PURCHASING PRACTICES
  • Inspect incoming purchases
  • Hold suppliers accountable for delivering the
    right goods in the right quantity and in good
    quality
  • Long-term contracts
  • Develop multiyear contracts with vendors if they
    will offer and/or guarantee lower prices
  • For example Construction-related activities,
    landscape, printing, mid and heavy equipment

29
ENHANCE PURCHASING PRACTICES
  • Just-in-time purchasing
  • Use JIT purchasing for readily available products
    to reduce or eliminate warehousing and inventory
    costs
  • May be possible to obtain vendor-supplied
    ordering software
  • Maintain competition
  • Evaluate vendors frequently to verify value and
    accuracy
  • Professional services as well as commodities

30
ENHANCE PURCHASING PRACTICES
  • P-cards
  • Significant advancements in individualized
    controls for purchases
  • Will support JIT purchasing environment as well
    as reduce purchasing costs
  • IF PROPERLY CONTROLLED

31
ENHANCE PURCHASING PRACTICES
  • Adopt Winning Compliance strategies
  • Reduce purchasing costs by
  • Simplifying processes
  • Posting simplified procedure manuals on an
    intranet
  • Using technology to speed up the procurement
    process
  • Enables purchasing staff to focus on
  • Honing negotiating skills
  • Working with departments to narrow bid
    specifications
  • Looking for ways to save money and to make it
    easier and faster for departments to get what
    they need

32
TIP NO. 3 MANAGE EMPLOYEE COSTS
  • Effectively manage employee costs for the short
    and long term
  • One of, if not THE, major costs for any government

33
BOTTOM-UP APPROACH
  • Take bottom-up approach to your budget
  • Why are you in a particular program?
  • Is it necessary to the core mission of your
    entity?
  • Careful analysis will enable better FTE
    management

34
NEEDED REFORMS
  • Use crisis as opportunity to propose and pursue
    needed reforms
  • For example Restructuring pensions and
    retirement benefits
  • Important to long-term financial health and
    viability
  • May be best chance for sustainable benefit levels
    going forward

35
UNION AGREEMENTS AND LABOR LAWS
  • Review all union agreements and labor laws
  • What is in negotiated agreements?
  • What is practiced with regard to employee
    benefits?
  • Seek opportunities to make adjustments that will
    benefit present and future

36
VACANT POSITIONS
  • Examine every vacant position before refilling
  • Is it necessary?
  • Can you reorganize to distribute duties
    differently and eliminate any positions?
  • Consider impact on internal control
  • How do layoffs and vacancies affect internal
    controls, especially in areas over assets
    susceptible to misappropriation and fraud?

37
OVERTIME
  • Evaluate overtime use
  • What is the ratio of overtime to regular wages or
    wages and benefits?
  • Can overtime be reduced by different patterns for
    scheduling or expanded use of PT personnel?
  • Make managers manage overtime
  • For example In one county, all OT drawn from a
    central account, shared by all departments.
    Withdrawals require justification.

38
ADDRESS HEALTH CARE COSTS
  • Health care costs large and rapidly growing
  • Reduction tactics
  • Identify cost drivers, especially for health care
    and disability claims
  • Prescriptions? Increase co-pays, switch to
    generic brands
  • Common on-the-job (OTJ) injuries? Increase
    preventive training

39
ADDRESS HEALTH CARE COSTS
  • Seriously consider wellness options
  • Health system promotions
  • Health club memberships at a discount
  • Verify participants
  • Conduct eligibility audit
  • Dependents who no longer qualify?
  • Former employees?
  • Spouses with coverage from another employer plan
    designate other plan as primary

40
TIP NO. 4 UNDERSTAND CASH POSITION
  • Cash is king!!
  • Local governments cannot print money like the
    federal government
  • Borrowing ability may be reduced or very
    expensive
  • Bank reconciliations need to be current!!!

41
FORECAST YOUR CASH
  • Cash flow reporting essential in financial
    crisis.
  • Prepare daily, weekly, monthly, and quarterly
    forecasts
  • Review forecasts annually
  • Compare to actual on day-to-day basis
  • Evaluate risks that might affect your cash
    forecast

42
REVIEW TRUSTS AND OTHER DORMANT ACCOUNTS
  • Consider sweeping cash into the general fund
  • If possible, do it!

43
INTERCEPT CASH
  • For example offset tax refund against amount
    owed on student loan
  • See if possible to join state refund setoff
    programs that allow local government to collect
    on unpaid utility bills or other customer AR by
    filing claims with state tax refund departments

44
ABANDONED PROPERTY AND CREDIT MEMOS
  • Search abandoned property (unclaimed property) at
    least monthly to see what can be reclaimed with
    state tax refund departments
  • Perform vendor credit memo searches. Do not pay
    vendors with whom you have credit until the
    situation is resolved.

45
TIP NO. 5 FINANCING SOURCES
  • Pay attention to financing sources and
    developments
  • Keep abreast of developments in the various
    stimulus packages
  • Pay special attention to expected federal funding
    for infrastructure projects
  • Maximize opportunities to make lasting
    infrastructure improvements

46
CAPITAL MARKETS
  • Be aware of capital market developments and
    structure (or re-structure) major financings
  • To increase access
  • To reduce borrowing costs

47
INVESTMENT MANAGERS AND CUSTODIANS
  • Perform due diligence on financial institutions
    and other fiduciaries that hold your investment
    portfolio
  • If it sounds too good to be true, BEWARE!!
  • Remember Madoff
  • Ponzi schemes are rampant!

48
EARN HIGHER YIELDS SAFELY
  • Look for opportunities to earn higher yields on
    excess cash with relatively low risk investments
  • Governments are usually allowed to invest in
    variable rate municipal securities, issued by
    credit-worthy governments
  • In most cases, these remain safe investments

49
TIP NO. 6 ASSET UTILIZATION
  • Look at long-term opportunities for better asset
    utilization

50
ASSET UTILIZATION STRATEGIES
  • Consider leasing or renting assets like cars and
    trucks for motor pool
  • Look at stranded or little-used assets that could
    be leased to someone else
  • Dont sell!!!
  • Review tax abatement and economic development
    incentives for updating or modification
  • For example Payment In Lieu of Taxes (PILOT)
    agreements

51
TIP NO. 7 STRENGTHEN INTERNAL CONTROLS
  • Internal controls key to effective operations
  • Strong role in preventing fraud
  • Increased risk
  • Employee layoffs increase vulnerability
  • Staff morale low
  • 20 question diagnostic over payment controls
    answer each question YES or NO

52
ARE YOUR INTERNAL CONTROLS GOOD ENOUGH?
  • Do you require all employees who have anything to
    do with the payment process to take at least 5
    consecutive days of vacation?
  • Do you prohibit the ability to both approve
    invoices and enter invoice data?

53
ARE YOUR INTERNAL CONTROLS GOOD ENOUGH?
  • Do you prevent one or more of your
    managers/executives from having access to all
    phases of the payment process, even though it
    might make training and managing more difficult?
  • Do you have a strong policy prohibiting the
    return of checks to requisitioners?

54
ARE YOUR INTERNAL CONTROLS GOOD ENOUGH?
  • Are all changes made to the master vendor file
    periodically checked, no less frequently than
    once a month, but ideally every week?
  • Do you periodically (at least once a year)
    deactivate inactive accounts in your master
    vendor file?

55
ARE YOUR INTERNAL CONTROLS GOOD ENOUGH?
  • Do you have an anonymous tip hotline?
  • Do you periodically check that your processors
    are not writing their passwords down where anyone
    can see them?

56
ARE YOUR INTERNAL CONTROLS GOOD ENOUGH?
  • If you have a petty cash box, do you make sure
    that the location of the key is not common
    knowledge?
  • Do you wait until the end of the day to deliver
    checks to the mailroom for mailing?

57
ARE YOUR INTERNAL CONTROLS GOOD ENOUGH?
  • Are unsigned checks always left in a secure
    location while waiting for signature and not on
    someones desk in an empty office?
  • Is the positive pay file uploaded only when
    checks are mailed?

58
ARE YOUR INTERNAL CONTROLS GOOD ENOUGH?
  • Are checks only printed only when they are going
    to be mailed not earlier so they will reflect a
    date that matches your payment terms?
  • Are open receivers and POs always extinguished
    when an invoice is paid even if the invoice is
    paid outside accounts payable?

59
ARE YOUR INTERNAL CONTROLS GOOD ENOUGH?
  • Is access to the master vendor file for entering
    vendor changes or changing vendor information
    severely limited?
  • When an employee making electronic payment
    transfers is terminated or leaves voluntarily, is
    the bank and procurement card administrator
    immediately notified and passwords changed?

60
ARE YOUR INTERNAL CONTROLS GOOD ENOUGH?
  • When a new vendor is to be entered into the
    master vendor file, do you require at least two
    signatures or approvals before adding them?
  • When a new vendor is to be entered into the
    master vendor file, do you do some checking to
    make sure the vendor is legitimate before adding
    them?

61
ARE YOUR INTERNAL CONTROLS GOOD ENOUGH?
  • If you have a petty cash box, do you hold
    surprise audits and does everyone know you do
    that?
  • Do you have a written fraud policy, signed by a
    top-level executive, indicating zero tolerance
    for employee fraud?

62
ARE YOUR INTERNAL CONTROLS GOOD ENOUGH?
  • Preferred response YES!
  • No perfect organization
  • NO indicates vulnerability
  • Look into NOs and determine if possible to
    tighten controls
  • If cannot tighten, plan to regularly audit
    problem areas

63
TIP NO. 8 ILL-ADVISED ACTIONS
  • Beware of taking ill-advised actions in a rush
    to just do something!

64
UNDERFUNDING
  • Dont underfund accrued liabilities like pensions
  • Sticks tomorrows generations with todays bills
  • Can negatively impact bond ratings, public
    perception, and employee relations

65
COST-SHIFTING
  • Dont shift operational costs into capital
    budgets.
  • Distorts true cost of capital investments
  • Usually not allowable!

66
ACCOUNTING MANIPULATIONS
  • Dont be tempted to use accounting manipulations
    to improve your results
  • For example
  • Delaying deliveries, payrolls, and payments to
    next fiscal year
  • Manipulating or distorting estimations or
    forecasts
  • Recognizing anticipated (or worse, speculative)
    savings or revenues

67
TIP NO. 9 FRAUD PREVENTION
  • In best of times, fraud expensive
  • In worst of times, fraud could be disastrous!
  • A few questions to check your knowledge of fraud
    prevention, detection, and investigation

68
WHATS YOUR FRAUD IQ?
  • Under the concept of ______________,
    corporations can be held criminally responsible
    for the acts of their employees if those acts
    were done in the course and scope of their
    employment and for the apparent benefit of the
    corporation.
  • Connected accountability
  • Civil responsibility
  • Imputed liability

69
WHATS YOUR FRAUD IQ?
  • Imputed liability
  • Corporations can be held legally responsible for
    the criminal acts of their employees in certain
    circumstances
  • For example company could be criminally liable
    for controller committing financial statement
    fraud
  • Even if supervisors unaware of his actions!

70
WHATS YOUR FRAUD IQ?
  • Stephen Latimer is the lead auditor for Island
    Power, a component unit providing energy. With
    the economic downturn, company management has
    been under increased pressure for profitable
    operations, and the company is in danger of
    violating its loan covenants.

71
WHATS YOUR FRAUD IQ?
  • Stephen is concerned that management may be
    fraudulently concealing liabilities and expenses
    to improve the companys financial statements.
    He performs his preliminary analytical procedures
    with these factors in mind. Which of the
    following is a red flag that might reaffirm
    Stephens suspicions?

72
WHATS YOUR FRAUD IQ?
  • The companys gross margin is significantly lower
    than industry average.
  • The company has experienced an unusual increase
    in the number of days purchases in accounts
    payable.
  • The financial statements reflect an unusual
    change in the relationship between fixed assets
    and depreciation.
  • The company shows a significant reduction in
    accounts payable, even though its competitors are
    stretching out payments to vendors.

73
WHATS YOUR FRAUD IQ?
  • Concealing operating expenses and related
    payables reduces AP
  • - Unusual given other companies in industry

74
WHATS YOUR FRAUD IQ?
  • Which of the following is considered a fraud
    preventive control?
  • Employee support programs
  • Segregation of duties
  • Employee background checks
  • All of the above

75
WHATS YOUR FRAUD IQ?
  • ALL, if properly implemented, will help prevent
    fraud
  • - Employee support programs
  • - Financial, drug, and family counseling
  • - Assist employees in dealing with
  • pressures
  • - Segregating incompatible duties
  • - Eliminates opportunity
  • - Background checks
  • - Prevents hiring mistakes

76
WHATS YOUR FRAUD IQ?
  • The concept of the fraud triangle states that,
    for a fraud to occur, three factors generally are
    present. Which of the following is NOT one of
    the three sides of the fraud triangle?
  • Criminal predisposition
  • Incentive or pressure
  • Perceived opportunity
  • Rationalization

77
FRAUD TRIANGLE
Correct answer A
Pressure (Motive)
FRAUD TRIANGLE
Opportunity
Rationalization
78
WHATS YOUR FRAUD IQ?
  • In general, the best way to prevent fraud is to
  • Implement harsh penalties for perpetrators.
  • Outsource all possible functions.
  • Increase the perception of detection.
  • Conduct covert audits.

79
WHATS YOUR FRAUD IQ?
  • Most fraud perpetrators commit fraud ONLY when
    they perceive an opportunity to be present.
  • So increasing in employees minds the perception
    that illegal acts will be detected can
    significantly deter fraud

80
WHATS YOUR FRAUD IQ?
  • __________ is defined as the totality of
    circumstances that would lead a reasonable,
    professionally trained, and prudent individual to
    believe a fraud has occurred, is occurring,
    and/or will occur.
  • Proof
  • Evidence
  • Suspicion
  • Predication

81
WHATS YOUR FRAUD IQ?
  • Predication is the basis for a fraud examination.
    It is the set of circumstances that leads a
    reasonable professional to believe that a fraud
    has, is or will occur.
  • Example While conducting an audit, an auditor
    overhears purchasing agent bragging about
    substantial discount on new car from companys
    supplier of fleet cars. Predication for fraud
    examination.
  • If auditor only witnessed purchasing agent in
    expensive car, would only have suspicion
    (insufficient for fraud examination)

82
WHATS YOUR FRAUD IQ?
  • Which of the following is NOT an element
    generally included as part of a fraud risk
    assessment?
  • Risk identification
  • Formal fraud policy development
  • Assessment of likelihood and significance of
    risks
  • Risk response

83
WHATS YOUR FRAUD IQ?
  • Formal fraud policy not one of steps in fraud
    risk assessment
  • Fraud risk assessment involves
  • Identifying fraud risks inherent to the
    organization
  • Assessing the likelihood and significance of the
    fraud risks identified
  • Deciding on the appropriate responses to the
    identified risks

84
WHATS YOUR FRAUD IQ?
  • The three primary categories of occupational
    fraud are
  • Corruption, financial statement fraud, and asset
    misappropriation
  • Skimming, money laundering, and bid rigging
  • Asset misappropriation, identity theft, and
    fictitious revenues
  • Financial statement fraud, inventory theft, and
    cash larceny

85
WHATS YOUR FRAUD IQ?
  • Occupational fraud fraud committed by an
    employee against an employer
  • Three primary categories of occupational fraud
  • Corruption Use of influence for self-benefit,
    e.g., bribes
  • Financial statement fraud Intentional
    misstatement or omission of material information
    from FS
  • Asset misappropriation Theft or misuse of
    company resources

86
WHATS YOUR FRAUD IQ?
  • Jason Aubuchon is conducting an investigation
    into a possible accounts receivable lapping
    scheme at Micronesian Visitors Bureau. If Jason
    plans to interview all of the following parties,
    whom should he interview first?

87
WHATS YOUR FRAUD IQ?
  • Frank, the primary suspect.
  • Martha, an accounts payable clerk who filled in
    for Frank when he was on vacation
  • Evan, a regular customer of the company whose
    complaint about his account balance prompted the
    investigation
  • Sarah, Franks supervisor, who is suspected of
    helping Frank cover the fraud in exchange for a
    portion of the proceeds

88
WHATS YOUR FRAUD IQ?
  • Collection of evidence should progress from
    general to specific
  • Investigator proceeds in order from witnesses
    least likely to be involved to those most
    culpable
  • Neutral third-party witnesses (Evan)
  • Corroborative witnesses (Martha)
  • Co-conspirators (Sarah)
  • Suspect (Frank)

89
WHATS YOUR FRAUD IQ?
  • Most employees who commit fraud have a history of
    fraudulent misconduct.
  • A. True
  • B. False

90
WHATS YOUR FRAUD IQ?
  • FALSE
  • 2008 Report to the Nation on Occupational Fraud
    and Abuse
  • 87 first-time fraud offenders
  • 83 never punished or terminated for fraudulent
    behavior

91
TIP NO. 10 OPEN COMMUNICATION LINES
  • A difficult problem in the best of times
  • Solution will be a group effort
  • Employees
  • Constituencies
  • Managers
  • Vendors
  • All affected parties

92
COMMUNICATION
  • Build credibility with frequent, clear, and
    honest communication
  • Manage perceptions
  • Speak up frame the situation for others
  • Be honest about what is achievable

93
COMMUNICATION
  • Sharing information can help
  • To avoid rigid reactions
  • May keep everyone open to different options for
    solutions
  • Employees take their cues from the leaders

94
CULTURE OF THRIFT
  • Establish a culture of thrift
  • Every dollar counts!
  • Terminate temporary help and redeploy existing
    staff to fill gaps
  • Cutback sharply on office equipment
  • Delay replacement of vehicles
  • Control travel and expenses
  • Engage employees in auditing small expenditures
  • Take action on very big items or very visible
    issues such as management vehicles and other perks

95
CULTURE OF THRIFT
  • Management must set an example for everyone to
    follow. Remember the tone at the top.

96
OPPORTUNITIES
  • Recognize opportunities within crisis
  • Organizations often do not change until a major
    event occurs
  • This may be a game-changing time that can be
    used to break free of constraining past practices
    and habits
  • May have to spend money to save money

97
EMPLOYEES ASSISTANCE
  • Employees will respond with creativity and
    ingenuity IF
  • They believe that their suggestions will be heard
    and valued

98
RESOURCES
  • AICPA
  • Government Accountability Brief January 2009
    March 2009
  • Navigating the Current Economic Crisis What It
    Means for Businesses March 2009
  • GFOA
  • Fiscal First Aid
  • Andi McNeal, Whats Your Fraud IQ?
  • Mary Schaeffer, Are Your Internal Controls Good
    Enough?

99
QUESTIONS?
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