Nonprofit Board Service: Shake Rag Alley

Controls, Assurance, and the Compliance Calendar

Internal control for a small staff: separating authorization, custody, recording, reconciliation, and review, walking donations, registrations, purchases, and payroll, compensating controls, compilation versus review versus audit, the Wisconsin and federal compliance calendar, and fraud response.

  • 5 min
  • 9 steps
  • 3 questions
  • Lesson 16 of 36

In this lesson

  1. Five control functions
  2. Walk the transactions
  3. Small-staff compensating controls
  4. Assurance levels
  5. Compliance is a matrix, not one deadline
  6. Wisconsin distinctions
  7. Federal watch items
  8. Fraud-response plan
  9. Quarterly finance assurance

Open alongside this lesson

Internal control is not mistrust. It is a system that protects people from error, temptation, accusation, and impossible concentration of authority.

Five control functions

For each money flow separate where feasible:

  1. authorization — permission;
  2. custody — access to cash/assets;
  3. recording — accounting entry;
  4. reconciliation — comparison to independent source;
  5. review — investigation and follow-up.

National Council of Nonprofits emphasizes clear authority, segregation, documentation, and monitoring 1.

Walk the transactions

Donation

mail/portal receipt → gift/restriction record → deposit → accounting → donor acknowledgment → bank reconciliation → development/accounting reconciliation → board reporting

Check:

  • two-person mail/cash process;
  • payment platform access and MFA;
  • donor restriction captured exactly;
  • donor database equals ledger;
  • acknowledgments do not overstate deductibility;
  • refund/reversal authority;
  • no donor payment instructions changed from email alone.

Registration/refund

enrollment → payment/deferred revenue → roster → attendance → earned revenue → refund/cancellation → reconciliation

Check approval for complimentary seats, scholarships, refunds, transfers, chargebacks, and instructor payment.

Purchase/payment

need → budget/authority → conflict/procurement → receipt of goods → invoice approval → payment → recording → bank reconciliation

No person should independently create a vendor, approve the purchase, change bank details, release payment, record it, and reconcile.

Payroll

Separate hire/pay authorization, time/changes, payroll processing, bank release, reconciliation, and tax filing review. Directors should receive exception evidence, not employee detail without need.

Small-staff compensating controls

When full segregation is impossible:

  • unopened bank statements/read-only bank access to an independent reviewer;
  • monthly review of bank reconciliations, cleared images, new vendors, payroll changes, refunds, journals, and card detail;
  • dual approval above thresholds;
  • automated audit logs;
  • mandatory vacation/cross-training;
  • direct complaint route;
  • rotating spot checks;
  • finance committee exception reporting.

Signatures without review are theater.

Assurance levels

Understand the engagement:

  • internal management statements: prepared by organization;
  • compilation: accountant presents information, generally no assurance;
  • review: limited assurance through inquiry/analytics;
  • audit: reasonable—not absolute—assurance that statements lack material misstatement;
  • agreed-upon procedures: findings on specified procedures.

Ask the CPA what was in scope, materiality, adjustments, control deficiencies, estimates, going-concern issues, restrictions/grants, and management letter. An audit does not guarantee no fraud.

Quick check

Which engagement gives the highest level of assurance on financial statements?

Compliance is a matrix, not one deadline

Maintain:

Obligation Regulator/funder Due rule Owner Reviewer Evidence Escalation
Form 990 IRS current federal due/extension finance committee/board process accepted filing
corporate annual report WI DFI corporate current entity due secretary/executive governance confirmation
charitable report/renewal WI DFI charity current form/due finance committee confirmation
payroll/tax federal/state filing calendar processor/finance independent review receipts
grants each award agreement dates grant owner finance/program accepted reports
raffle WI DOA license/report terms event owner finance license/report
sales/use tax WI DOR activity-specific finance CPA returns/workpapers
insurance carriers renewal/claim deadlines executive board/risk binder

Verify current requirements every year.

Five control functions for a donation (authorize, custody, record, reconcile, review) held by different people, and a compliance matrix of federal and Wisconsin filings with their due rules.
Split the duties, and calendar every filing. Credit: StudyCorner diagram · CC BY 4.0 · Source

Wisconsin distinctions

  • Corporate annual report: maintains corporation information through Wisconsin DFI 2.
  • Charitable solicitation registration/reporting: separate DFI charitable-organization stream 3.
  • Financial statement attachment: current Form 1952 instructions use contribution thresholds for reviewed/audited statements and a waiver process; the March 2024 form identifies review above $500,000 through $999,999 and audit at $1,000,000 or more in contributions 4. Recheck the form in the filing year and obtain accounting advice.
  • Raffles: Wisconsin requires a raffle license; Class A and B rules differ 5. An auction, door prize, sweepstakes, and raffle are not interchangeable labels.
  • Sales/use tax: exemption from income tax does not make every purchase or sale exempt; Publication 206 explains Wisconsin nonprofit rules 6.

Federal watch items

  • Form 990 is generally due the 15th day of the fifth month after year-end, subject to current rules/extensions 7.
  • Unrelated business income generally has three elements: trade/business, regularly carried on, and not substantially related to exempt purpose; exceptions and modifications apply. Form 990-T filing is generally triggered when gross unrelated business income is $1,000 or more 8.
  • Public support, payroll, contractor reporting, donor acknowledgments, lobbying/election rules, and grant conditions have separate tests.

For Shake Rag, assess—not assume—the treatment of rentals, lodging, merchandise, food, sponsorship benefits, advertising, raffles, and asset use with a nonprofit CPA or counsel.

Fraud-response plan

Before suspicion:

  • reporting channels and non-retaliation;
  • authorized response team;
  • insurer/counsel/forensic contacts;
  • evidence preservation;
  • limits on access changes and interviews;
  • authority to notify bank, processor, law enforcement, funder;
  • communications and recovery.

If concern arises, do not confront casually, alter files, promise outcomes, or let a potentially implicated person control the inquiry.

Quarterly finance assurance

The board receives:

  • statements and forecast;
  • restriction/grant compliance;
  • bank/reconciliation confirmation;
  • control exceptions and corrective actions;
  • filing calendar status;
  • suspected fraud/material error incidents;
  • external accountant findings;
  • decisions required.

The useful question is not “Did someone file everything?” It is: What evidence shows each obligation and control is owned, reviewed, and corrected?

Practice

Which is an effective control when staff is small?

Practice

Is charitable registration the same as the corporate annual report?

Lesson complete

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Board Giving and Fundraising Expectations

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Sources for this lesson
  1. 1
    Internal Controls for Nonprofits. National Council of Nonprofits. verifiedPractical checks and balances for cash, banks, spending authority, vendors, and segregation of duties. Cited at: internal controls.
  2. 2
    Annual Report Instructions for Nonstock Corporations. Wisconsin Department of Financial Institutions. verifiedCurrent business-entity annual-report requirement, separate from charitable solicitation reporting. Cited at: corporate report.
  3. 3
    Charitable and Professional Organization Forms. Wisconsin Department of Financial Institutions. verifiedCurrent Wisconsin charitable registration and annual financial-report forms. Cited at: charity forms.
  4. 4
    Wisconsin Supplement to Financial Report — Form 1952. Wisconsin Department of Financial Institutions. verifiedState charitable-report form showing current review and audit triggers; always recheck the current form before filing. Cited at: threshold instructions.
  5. 5
    Applying for a New Raffle License. Wisconsin Department of Administration. verifiedCurrent Wisconsin raffle-license eligibility and Class A/Class B overview. Cited at: raffle licensing.
  6. 6
    Sales Tax Exemptions for Nonprofit Organizations. Wisconsin Department of Revenue. verifiedOfficial state guidance on nonprofit purchases, sales, occasional sales, admissions, and fundraising events. Cited at: Publication 206.
  7. 7
    About Form 990. Internal Revenue Service. verifiedOfficial Form 990 purpose and schedule index. Cited at: filing.
  8. 8
    Unrelated Business Income Tax. Internal Revenue Service. verifiedOfficial three-part UBIT concept and Form 990-T gross-income filing threshold. Cited at: UBIT.