KOI Financial Policies and Procedures: Difference between revisions

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Adopted by Board of Directors of KOI on: TBD

Review cadence: Semi-~~annually~~

Review cadence: Semi-

== Purpose, scope, and definitions ==

=== Purpose ===

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* To ensure the fiscal health and safety of the organization

* For compliance with grants

* For compliance with ~~gudits~~

* For compliance with audits

* For reference by KOI ~~volunteers~~

* For reference by KOI

=== Recognition of Capitalism and Harm ===

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Headings should be used to create a table of contents and easy navigation of the reader. Any images should have alt text with them. Headings should be nested appropriately for the ease of navigation of the user.

Each section should ideally come with a dedicated section for the policy of the financial operation and with the procedure of the financial operation. A Policy is a malleable set of guidelines to ensure any procedure properly follows sound and compliant decisions by KOI. A procedure is the steps to enact the policy.

Each section should ideally come with a dedicated section for the policy of the financial operation and with the procedure of the financial operation. A Policy is a malleable set of guidelines to ensure any procedure properly follows sound and compliant decisions by KOI. A procedure is the steps to enact the policy. Policy should be drafted before procedures, and should (ideally) change very little. Procedures are expected to change often due to systems changing, and the evolving nature of the non-profit space.

== Definitions ==

=== Actors ===

'''Volunteer''' - An individual who has been onboarded into KOI, including alias and chat platform access, and who donates labor toward the furtherance of KOI’s goals and programs

'''Active KOI Volunteer''' - An individual volunteer who has contributed no fewer than 10 hours the previous calendar month

'''Director''' - A director is a volunteer who, for purposes of governmental and inter-organizational interfacing, holds a titled position within the organization but does not have authority for governance - which remains restricted only to the board of directors (e.g. chair, secretary, treasurer).

'''Governing Board Director''' - A volunteer who has a titled governance position within the organization as laid out in the organization’s bylaws and is registered as such by government entities (secretary of state, Internal Revenue Service, etc.)

* '''Volunteer''' - An individual who has been onboarded into KOI, including alias and chat platform access, and who donates labor toward the furtherance of KOI’s goals and programs

'''Board Treasurer''' - The volunteer board member who is listed as the treasurer to the Internal Revenue Service and the secretary of state of Washington State.

* '''Active KOI Volunteer''' - An individual volunteer who has contributed no fewer than 10 hours the previous calendar month

* '''Director''' - A director is a volunteer who, for purposes of governmental and inter-organizational interfacing, holds a titled position within the organization but does not have authority for governance - which remains restricted only to the board of directors (e.g. chair, secretary, treasurer).

'''Finance Comrade''' - A finance comrade is a KOI volunteer who has explicit, and approved, access to our accounting system and/or our bank portal. They are also tasked to record financial transactions and to compose budgets.

* '''Governing Board Director''' - A volunteer who has a titled governance position within the organization as laid out in the organization’s bylaws and is registered as such by government entities (secretary of state, Internal Revenue Service, etc.)

* '''Board Treasurer''' - The volunteer board member who is listed as the treasurer to the Internal Revenue Service and the secretary of state of Washington State.

'''Evacuee''' - A member of the trans community that is being advocated for by KOI to acquire freedom of movement, self-determination and autonomy to create a new life in Washington State.

* '''Finance Comrade''' - A finance comrade is a KOI volunteer who has explicit, and approved, access to our accounting system and/or our bank portal. They are also tasked to record financial transactions and to compose budgets.

* '''Evacuee''' - A member of the trans community that is being advocated for by KOI to acquire freedom of movement, self-determination and autonomy to create a new life in Washington State.

'''Authorizer''' - A volunteer who holds the power to initiate a transaction of funds from, and to, KOI.

* '''Authorizer''' - A volunteer who holds the power to initiate a transaction of funds from, and to, KOI.

* '''Signatory''' - A signatory is a KOI volunteer who has authorization powers, and can sign checks for the bank account.

'''Signatory''' - A signatory is a KOI volunteer who has authorization powers, and can sign checks for the bank account.

=== Accounting/Finance Definitions ===

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'''Accounts Payable''' - A GL account that holds all of the expenses owed by the organization, yet not paid. Accounts payable is also a collection of processes to track expenses and disburse funds for expenses.

'''Going Concern''' - A going concern means the organization can meet all of its liabilities, and is no danger of losing liquidity. Despite its ~~description~~, it is a good thing.

'''Going Concern''' - A going concern means the organization can meet all of its liabilities, and is no danger of losing liquidity. Despite its name, it is a good thing to have a going concern.

'''Liabilities''' - Liabilities are legal obligations for future disbursements, or services. The most common of these are loans, accounts payable, and unearned revenue.

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Internal controls prevent fraud and ensure proper spending of the funds of KOI.

=== Separation of ~~Powers~~ ===

=== Separation of Duties ===

Separation of ~~powers~~ (sometimes called segregation of ~~powers~~) is an internal control that prevents misuse of funds by ensuring every transaction has at least two eyes on it. Ideally, each transaction would have at least three KOI volunteers involved with it.

Separation of Duites (sometimes called segregation of duties) is an internal control that prevents misuse of funds by ensuring every transaction has at least two eyes on it. Ideally, each transaction would have at least three KOI volunteers involved with it.

KOI recognizes the following three ~~powers~~ in a transaction process:

KOI recognizes the following three duties in a transaction process:

* '''Authorization''' – Authorization is the power to approve a transaction. These can include expense approvals, check signatory powers, contract signatory powers, payroll initiation, etc.

* '''Custody –''' Custody is the physical holding of the funds of KOI. This can include physical checks, P2P transaction app access, credit cards, and cash

* '''Record Keeping''' - Record keeping is the logging, and documentation of transactions. Examples include paper files, journal entries, employee records, billing, and payables, financial statement preparation, etc.

* '''Materiality~~'''~~

The most dangerous duty to have combined with another is authorization.

** Materiality for evacuee expenses

** Materiality for non-evacuee expenses

Finance Comrades forbidden from holding authorization duties. Bank Signatories are forbidden from holding record-keeping duties.

=== Materiality ===

==== Materiality for evacuee expenses ====

Materiality will determine the amount of scrutiny an evacuee expense incurs. A set amount will be determined and referable by the Finance Committee. There can be multiple scales of materiality for an evacuee expense.

The lowest on the materiality threshhold will involve the following:

* The least amount of authorizers needed.

* The least amount of documnetation

* The least amount of natural consequences in cases of misappropriation.

The highest amount of materiality will involve the following:

* Clearest enforcement of Internal Controls

* Concise recording of authorization, and authorizors.

* Contracts if needed.

* The clearest understanding of natural consequences when it comes to misappropriation and fraud.

If there is a prohibited transaction for an evacuee, there will be no materiality threshold and scrutiny will be in place.

==== Materiality for non-evacuee expenses ====

Materiality will determine the amount of scrutiny an non-expense incurs. A set amount will be determined and referable by the Finance Committee. There can be multiple scales of materiality for an evacuee expense.

The lowest on the materiality threshhold will involve the following:

* The least amount of authorizers needed.

* The least amount of documnetation

* The detail in a Journal Entry Workpaper

* The least amount of natural consequences in cases of misappropriation.

The highest amount of materiality will involve the following:

* Clearest enforcement of Internal Controls

* Concise recording of authorization, and authorizors.

* Contracts if needed.

* Highest detail required for a Journal Entry workpaper.

* The clearest understanding of natural consequences when it comes to misappropriation and fraud.

=== General Ledger Account Control ===

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* Using appropriated funds for an evacuee for another documented expense purpose than initially reported

* Using appropriated funds for one evacuee than initially stated

* Using more appropriated funds for one evacuee than initially stated

* Unauthorized transactions for sundries for KOI

* Using funds from a restricted fund for expenses not allowed by said restricted fund.

Accountability involves all sides knowing where errors and harm has been done. Acknowledgement of the misappropriation will be communicated by the Finance Committee to the KOI Volunteer. If the misappropriate was initiated by and Evacuee, the Finance Committee will notify the Evacuee's Care Coordinator.

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* Removal from the transaction process entirely for the person who misappropriated funds.

* Redelegation of tasks for a volunteer who misappropriated funds.

* Using funds from a restricted fund for expenses not allowed by said restricted fund.

The priority for deciding which consequence to enact upon the person who misappropriated funds should always be based upon the internal controls, and sustainability, of KOI. Never should shame/guilt be used when deciding next steps after misappropriation of funds.

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=== Accounting System - Xero ===

The accounting system used by KOI must contain the following functionalities:

* User and Audit Logs of Logins, and transaction modifications.

* Transaction Recording

* Financial Statement Reporting

*Journal Entry Logging

*Bank Reconciliation

*User Management

The Accounting system should only be completely accessible by KOI Volunteers who have record keeping privileges (Finance Comrades and the Board Treasurer). No one with signatory powers should be able to reconcile bank statements and record transactions in the accounting software. Read only accounts are highly suggested for those on the board and those with signatory powers.

Xero is the Accounting System used by KOI.

=== Fundraising Systems ===

Fundraising systems should be utilized to log the donor transactions for KOI. They should:

* Log the donor who donated

* Log the donation date

* Log the fund donated to.

Ideally, such systems should also accept donations easily and electronically.

Donation systems might contain donor information such as bank information and credit card numbers. It is important to protect this data and ensure only folks with need to know privileges have access to said systems.

Donations need to curated when received to ensure no fund restrictions are in place.

==== Zeffy ====

Zeffy is the primary donation platform for KOI. Individuals who wish to donate directly to KOI are referred to our Zeffy link.

Zeffy donations include the following, and more:

* The donor name

* The restriction of the donation (if any)

*The donation method

*The cadence of the donation

*The date of the donation

*The donation referral

*The date deposited in KOI's bank account

Exports of donations can be done via the zeffy web portal. Such exports should be kept with KOI as backup documentation of the purpose of the donation,and the donor.

Finance Comrades, the Board Treasurer, and anyone with development tasks are allowed to use the Zeffy system and see exports. However, due to the confidential nature of the donations, only those with a completed background check can access zeffy. This requirement will always supersede general KOI policies.

==== Benevity ====

Benevity is KOI's main workplace donation platform. Employees can ask their employer to have paycheck deductions

=== Office Applications - Google ~~Docs~~ ===

Benevity donations can include the following, and more:

*The donor name

* The restriction of the donation (if any)

*The date of the donation

*The donation referral

*The date deposited in KOI's bank account

In addition, Benevity can also collect corporate matches for their employee's donations.

The matching donations can include:

*The matching organization

* The restriction of the donation (if any)

*The date of the donation

*The employee the donation is matching

*The date deposited in KOI's bank account

It is important to record such information for record keeping purposes.

Finance Comrades, the Board Treasurer, and anyone with development tasks are allowed to use the Benevity system and see exports. However, due to the confidential nature of the donations, only those with a completed background check can access zeffy. This requirement will always supersede general KOI policies.

To access Benevity, the account must have a Mutli-Factor Authentication feature turned on. Currently, that MFA feature is SMS only.

=== Office Applications - Google Drive ===

Google Drive, sometimes called Google Docs, is a cloud based application that features the following office applications:

* Rich Text Editing (Sometimes called Word)

* Multi-cell spreadsheet (Called Sheets)

* Presentation Slides (Called Slides)

In addition, the google drive can host pdfs and other documents in a cloud based environment. Documents can be shared with anybody who wants access, and they can be shared with only a few KOI members.

The Finance Committee will use Google Drive for primary document retention, budgeting, and other finance tasks that are required.

Due to the current political climate, and the possible capitulation of Google with a hostile government, it is recommended only primary documents that do not contain volunteer/evacuee names be stored on Google Drive.

=== Office Applications - Cryptpad ===

Cryptpad is a cloud based application environment that features the following office applications:

* Rich Text Editing (Sometimes called Word)

* Multi-cell spreadsheet (Called Sheets)

In addition, cryptpad can host pdfs and other documents in a cloud based environment. Documents can be shared with anybody who wants access, and they can be shared with only a few KOI members.

The Finance Committee will use Google Drive for retention of documents that contain sensitive information such as Bank Statements, Evacuee names, payroll records, etc.

=== Communication - Element/Matrix ===

The Finance Committee communicates needs, issues, task delegations, meeting times, etc. via the KOI Matrix Server with the Client Element. There is a Finance Committee channel where all of the Finance Comrades and the Board Treasurer communicate. The channel is also open to any other KOI volunteer, and it is encouraged other KOI volunteers join to provide oversight on the KOI Finance Committee.

Expenses are brought to the entire KOI volunteer organization for review. Emoji reacts do not count as approval or veto'ing of an expense. Approval via Matrix does not count as approval of expenses for legal reasons.

== Cash Management ==

=== Cash Management Policy ===

==== Managing Cash Flow ====

The cash in and out is an important factor for the sustainability of the organization. In order for KOI to continue on as an organization, the organization needs to be able to meet the following obligations (by priority):

# Budgeted Monthly Evacuee Expenses

# Budgeted Monthly Payroll Expenses (if it exists)

# Budgeted Monthly Rent Expenses (if renting a building)

If there is ever a low cash balance for the organization, the Finance Committee must create a cash report listing:

* End of Month Bank Account Balances

* End of Month Credit Card Balances

* End of Month Line of Credit Balances

* Budgeted Evacuee Expenses for the Month

* Budgeted Payroll Expenses for the Month (If Any)

* Budgeted Payables for the month.

* Budgeted Receivables (if any) for the month

Ideally, this should be a spreadsheet allowing the Finance Committee to easily determine and report the next steps the organization can take.

If expenses, and operations, are large enough, then the Finance Committee must issue this report monthly regardless to provide transparent status of the finances to the organization.

==== Bank Account Balances ====

Bank Account Balances should have set minimum balances. At the beginning of the month, the main checking account should be replenished to the the budgeted amount of expenses for evacuees for the month. The Bank account should never be below a set amount to ensure there are funds to be spent on the evacuees. The bank account shouldn't be above the replenish balance to ensure only a certain amount of funds would be vulnerable to a rogue actor who would wish to empty the bank account.

Any funds not currently in the checking account should be in the savings account.

Only those with authorization powers can transfer funds between bank accounts. Those with record keeping powers must have access to bank information in some channel, including a read-only method of the bank accounts.

==== Petty Cash Handling ====

The organization will not work with cash as much as possible. Cash will not be disbursed to evacuees. Cash will not be a mode of payment with vendors. Cash donations will be immediately deposited and not held by the organization outside of a depository institute.

If there ever is a petty cash fund within the organization outside of a depository institute, there a few requirements.

* Cash has to be counted on a periodic basis.

* The Petty Cash account will have to go through reconciliation on a set periodic basis.

* Separation of controls will be held (Authorizor, vs. Record Keeper vs. Custodian) with no exceptions.

* Withdraws from the Petty Cash account will need two signatories.

== Organization Budgeting ==

To have a functioning Non-profit, a composed budget is required every year for KOI. A budget must be composed also for Grant applications, and to strengthen the internal controls of the organization.

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If the budget is not approved by the organization, then there is no operational budget. The budget has to be recomposed, and re-submitted.

The draft budget should be available on an accessible platform where changes can be tracked, and ~~colloborated~~

The draft budget should be available on an accessible platform where changes can be tracked, and collaborated.

The following committees are responsible for:

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In the scenario where KOI secures the funds to hire paid staff, the Wage Schedule will be composed by the Finance Committee based upon the inputs of the Board.

If there is a new expenditure/program that materially effects the organization, then either:

* The budget must be amended, or

* An entire re-forecast of the budget must occur.

A Re-forecasted budget, or budget amendment, must be approved by majority vote in the Finance Committee. The Finance Committee must alert the rest of the organization about the changes in the budget.

=== Budgeting Procedure ===

== Fund Management ==

=== Fund Policy ===

As a 501(c)(3), KOI is responsible in dividing the net assets into dedicated funds. The IRS ~~required~~ KOI to track expenses by funds, and to report expenses per funds in a statement of functional expenses on the tax return document the 990. The spending of expenses per fund is made transparent to the public on the 990 and on Washington State's Secretary of State's website.

As a 501(c)(3), KOI is responsible in dividing the net assets (equity) into dedicated funds. The IRS requires KOI to track expenses by funds, and to report expenses per funds in a statement of functional expenses on the tax return document the 990. The spending of expenses per fund is made transparent to the public on the 990 and on Washington State's Secretary of State's website.

KOI is required to keep track of only three Funds: Management, Fundraising, and Programs. However, to properly operate KOI keeps track of additional funds as need be.

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===== Programs (undesignated) Fund =====

Programs is ~~our~~ general fund that allows KOI to do the work for the mission. Unless otherwise stated, these funds are unrestricted. There can be restricted funds that are sub-funds of the Programs Fund.

Programs is the general fund that allows KOI to do the work for the mission. Unless otherwise stated, these funds are unrestricted. There can be restricted funds that are sub-funds of the Programs Fund.

All Evacuee Expenses come from the programs fund. Any other expense that is for the mission of KOI also comes from the Programs Fund.

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If such expenses were to occur, then a misappropriation of funds (at the minimum) is considered to have occurred.

==== Evacuee Expense Authorization ====

Expenses that require authorization must have:

* The name of the KOI volunteer that approved the expense.

* The name of the KOI Volunteer that proposed the expense

* The date of the approval

A KOI Volunteer cannot approve their own expense.

Expenses that do not require authorization are either budgeted to include documentation only, or are a re-occurring expense that has pre-authorization to occur.

Those with record-keeping, or custody, powers cannot authorize an expense.

=== Evacuee Expenses Procedures ===

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If a card is approaching the spending limit, the card holder may request a signatory to complete an early payment. The board treasurer can confirm if there are cash reserves available for such a payment.

Credit card holders may attach the credit card to a peer-to-peer (P2P) monetary ~~option~~ such as Venmo, Cash App, Paypal, etc.

Credit card holders may attach the credit card to a peer-to-peer (P2P) monetary service such as Venmo, Cash App, Paypal, etc.

Credit card holders may use the credit card for recurring expenses, ~~and may~~ ~~only ask for approval once due to the consistent nature of the expense.~~

Credit card holders may use the credit card for recurring expenses. These expenses need approval for the first instance. Afterwards, no further authorization is needed barring changes in the purpose of the transaction, amount, or timing.<!-- Recommend "only need approval for the first instance" or similar. Also perhaps add something about needing re-authorization if the cost of the recurring expense changes beyond a set percentage of the primary amount.

Josh - Good point. I rephrased it. -->

If there is an unknown, and/or unauthorized, transaction on the card, the card holder must notify the signatories within 24 hours of the posting date.

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==== Cessation of Credit Card use ====

Credit card cessation is required when:

Credit card use cessation is required when:

* Violation, or violations, of policy threaten KOI’s sustainability and going concern

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The immediate next step is to close the credit card. No further credit card can be issued to the credit card holder unless it was determined there was an error in the decision of cessation.

Only the board treasurer, the board chair, ~~and~~ the executive director can make the decision to cease use of a credit card for a credit card holder. No vote is required out of the three, but disclosure must be made. No veto regarding such a decision can be made.

Only the board treasurer, the board chair, or the executive director can make the decision to cease use of a credit card for a credit card holder. No vote is required out of the three, but disclosure must be made. No veto regarding such a decision can be made.

Once there is a decision to remove the credit card from the credit card holder, the decision must be disclosed to the credit card holder, the evacuees depending on the credit card, the finance committee, and to the bank. A bank signatory will then close ~~the account~~.

Once there is a decision to remove the credit card from the credit card holder, the decision must be disclosed to the credit card holder, the evacuees depending on the credit card, the finance committee, and to the bank. A bank signatory will then close the card.

Further consequences can include:

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=== Payroll Procedures ===

== Compliance, Audits, and Government Filings ==

KOI will retain copies of every compliant, audit, and/or government filing and keep it organized in case there are any need to refer to past filings.

=== Federal – Internal Revenue Service ===

==== Annual Filings - 990 ====

The 990 is the annual filing with the IRS as a non-profit. The deadline for such filings is May 15th, or October 15th (if an extension was filed).

To file a 990, the prior year's financials must be completed and closed (meaning, no modifications allowed). Ideally, the financial statements would be audited if required for a grant.

To file a 990, the following pieces of information is required:

* List of Board of Directors

* Compensated Directors

* Major Donors

* An end of year Income Statement for the prior year.

* A end of year Balance sheet statement for the prior year.

* A list of expenses per Management, Programs, and Fundraising.

The 990-N is the annual filing KOI can file in place of the 990 if certain requirements are met. KOI currently doesn't meet those requirements, and it will unlikely be able to due to the financial obligations of supporting evacuees.

==== Payroll Filings 940 and 941 ====

If KOI were to ever have payroll, regular payroll filings would need to be filed. During payroll, employee deductions for Unemployment Insurance (UI or FUTA) would be held in a liability account. The 940 report would need to be filed before the end of the month following the end of the prior quarter.

During payroll, employee deductions for federal withholding, social security, and medicare would be held in a liability account. At the same time, employer contributions to social security and medicare will be expensed and held in a liability account. At the end of the month after the quarter ends KOI will pay the aggregate totals reported in a 941 form to the IRS.

If it works better for KOI, a deposit system can be used to keep on top of the payroll liabilities through the quarter.

==== Annual W-2's and W-3s ====

If there were payroll in a calendar year, the W-2s and W-3s are due at the end of January of the following year. The W-3 will contain the aggregate information for all of the boxes of the W-2s filed for the year. Ideally, this is filed electronically.

==== Annual 1099's and 1096's ====

If there are payments to Non-employee contractors (individuals, sole proprietorship) or Single member LLC's, KOI must collect a W-9 from said vendor if the aggregate amounts paid for the year meet, exceed, or will exceed $600.00. KOI will then file the 1099's by the end of January following the year, along with a 1096 that will consolidate all of the payments of the 1099s.

=== Washington State – Secretary of State ===

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=== Washington State – Department of Revenue B&O ===

Every Year, KOI will file the annual Excise tax by April 15th 2026 electronically via dor.wa.gov and the Secure Access Washington (SAW) Account.

=== Washington State – Payroll ===

==== ESD Filing ====

After payroll is calculated and Unemployment withholdings are withheld, KOI will file an electronic return with ESD via the SAW account for the fiscal quarter. Funds will be sent to ESD electronically, or by paper check. The due date for the filings is the last day after the last fiscal quarter. It is recommended a csv is prepared well before the filing to make the filing easier. Instructions can be found on esd.wa.gov.

==== LnI Filing ====

==== LnI (Labor and Industries) Filing ====

Before KOI begins withholding LnI withholdings, a Business Type Class must be designated for all workers, and the appropriate rate written down. These rates can be found on lni.wa.gov (Most likely 5308 - Community Action). The rate is multiplied by the amount of hours worked in a payroll period, and withheld from pay to be allocated in a payroll liability account. At the end of the quarter, the LnI return is filed by multiplying the total amount of payroll hours for the prior fiscal quarter by the LnI rate chosen. The return is due by the last day of the month following the fiscal quarter. The return is filed on lni.wa.gov, and it is recommended a CSV of the hours of the prior quarter be prepared ahead of time.

==== PFMLA Filing ====

KOI will need to determine what amount of the premiums will be paid by KOI, and what amount will be paid by the employee. Once those rates have been decided, the employer withholdings are expensed and put into a payroll tax liability, and the employee deductions are put into a payroll tax liability. At the end of the month following the end of a fiscal quarter, a summary of hours, payroll wages, and PFMLA withholdings is submitted to ESD electronically through a SAW account. A payment is sent to ESD by check or ACH option on the SAW Account.

==== WA Cares Filing ====

KOI will need to request if any employee wants to exempt themselves from WA Cares. The employee deductions are put into a payroll tax liability during every payroll. At the end of the month following the end of a fiscal quarter, a summary of hours, payroll wages, and WA Cares withholdings is submitted to ESD electronically through a SAW account. A payment is sent to ESD by check or ACH option on the SAW Account.

=== King County ===

No report currently required by King County.

=== City of Seattle ===

To remain compliant with the City of Seattle, KOI will file a business tax return with the City digitally via [https://www.filelocal-wa.gov/ File Local] .This report is due at the end of April of every year.

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 Adopted by Board of Directors of KOI on: TBD
-Review cadence: Semi-annually
+Review cadence: Semi-
 == Purpose, scope, and definitions ==
 === Purpose ===
@@ Line 12: / Line 11: @@
 * To ensure the fiscal health and safety of the organization
 * For compliance with grants
-* For compliance with gudits
+* For compliance with audits
-* For reference by KOI volunteers
+* For reference by KOI
 === Recognition of Capitalism and Harm ===
@@ Line 69: / Line 68: @@
 Headings should be used to create a table of contents and easy navigation of the reader. Any images should have alt text with them. Headings should be nested appropriately for the ease of navigation of the user.
-Each section should ideally come with a dedicated section for the policy of the financial operation and with the procedure of the financial operation. A Policy is a malleable set of guidelines to ensure any procedure properly follows sound and compliant decisions by KOI. A procedure is the steps to enact the policy.
+Each section should ideally come with a dedicated section for the policy of the financial operation and with the procedure of the financial operation. A Policy is a malleable set of guidelines to ensure any procedure properly follows sound and compliant decisions by KOI. A procedure is the steps to enact the policy. Policy should be drafted before procedures, and should (ideally) change very little. Procedures are expected to change often due to systems changing, and the evolving nature of the non-profit space.
 == Definitions ==
 === Actors ===
+'''Volunteer''' - An individual who has been onboarded into KOI, including alias and chat platform access, and who donates labor toward the furtherance of KOI’s goals and programs
+'''Active KOI Volunteer''' - An individual volunteer who has contributed no fewer than 10 hours the previous calendar month
+'''Director''' - A director is a volunteer who, for purposes of governmental and inter-organizational interfacing, holds a titled position within the organization but does not have authority for governance - which remains restricted only to the board of directors (e.g. chair, secretary, treasurer).
+'''Governing Board Director''' -  A volunteer who has a titled  governance position within the organization as laid out in the organization’s bylaws and is registered as such by government entities (secretary of state, Internal Revenue Service, etc.)
-* '''Volunteer''' - An individual who has been onboarded into KOI, including alias and chat platform access, and who donates labor toward the furtherance of KOI’s goals and programs
+'''Board Treasurer''' -  The volunteer board member who is listed as the treasurer to the Internal Revenue Service and the secretary of state of Washington State.
-* '''Active KOI Volunteer''' - An individual volunteer who has contributed no fewer than 10 hours the previous calendar month
-* '''Director''' - A director is a volunteer who, for purposes of governmental and inter-organizational interfacing, holds a titled position within the organization but does not have authority for governance - which remains restricted only to the board of directors (e.g. chair, secretary, treasurer).
+'''Finance Comrade''' - A finance comrade is a KOI volunteer who has explicit, and approved, access to our accounting system and/or our bank portal. They are also tasked to record financial transactions and to compose budgets.
-* '''Governing Board Director''' -  A volunteer who has a titled  governance position within the organization as laid out in the organization’s bylaws and is registered as such by government entities (secretary of state, Internal Revenue Service, etc.)
-* '''Board Treasurer''' -  The volunteer board member who is listed as the treasurer to the Internal Revenue Service and the secretary of state of Washington State.
+'''Evacuee''' - A member of the trans community that is being advocated for by KOI to acquire freedom of movement, self-determination and autonomy to create a new life in Washington State.
-* '''Finance Comrade''' - A finance comrade is a KOI volunteer who has explicit, and approved, access to our accounting system and/or our bank portal. They are also tasked to record financial transactions and to compose budgets.
-* '''Evacuee''' - A member of the trans community that is being advocated for by KOI to acquire freedom of movement, self-determination and autonomy to create a new life in Washington State.
+'''Authorizer''' - A volunteer who holds the power to initiate a transaction of funds from, and to, KOI.
-* '''Authorizer''' - A volunteer who holds the power to initiate a transaction of funds from, and to, KOI.
-* '''Signatory''' - A signatory is a KOI volunteer who has authorization powers, and can sign checks for the bank account.
+'''Signatory''' - A signatory is a KOI volunteer who has authorization powers, and can sign checks for the bank account.
 === Accounting/Finance Definitions ===
@@ Line 88: / Line 94: @@
 '''Accounts Payable''' - A GL account that holds all of the expenses owed by the organization, yet not paid. Accounts payable is also a collection of processes to track expenses and disburse funds for expenses.
-'''Going Concern''' - A going concern means the organization can meet all of its liabilities, and is no danger of losing liquidity. Despite its description, it is a good thing.
+'''Going Concern''' - A going concern means the organization can meet all of its liabilities, and is no danger of losing liquidity. Despite its name, it is a good thing to have a going concern.
 '''Liabilities''' - Liabilities are legal obligations for future disbursements, or services. The most common of these are loans, accounts payable, and unearned revenue.
@@ Line 162: / Line 168: @@
 Internal controls prevent fraud and ensure proper spending of the funds of KOI.
-=== Separation of Powers ===
+=== Separation of Duties ===
-Separation of powers (sometimes called segregation of powers) is an internal control that prevents misuse of funds by ensuring every transaction has at least two eyes on it. Ideally, each transaction would have at least three KOI volunteers involved with it.
+Separation of Duites (sometimes called segregation of duties) is an internal control that prevents misuse of funds by ensuring every transaction has at least two eyes on it. Ideally, each transaction would have at least three KOI volunteers involved with it.
-KOI recognizes the following three powers in a transaction process:
+KOI recognizes the following three duties in a transaction process:
 * '''Authorization''' – Authorization is the power to approve a transaction. These can include expense approvals, check signatory powers, contract signatory powers, payroll initiation, etc.
 * '''Custody –'''  Custody is the physical holding of the funds of KOI. This can include physical checks, P2P transaction app access, credit cards, and cash
 * '''Record Keeping''' - Record keeping is the logging, and documentation of transactions. Examples include paper files, journal entries, employee records, billing, and payables, financial statement preparation, etc.
-* '''Materiality'''
+The most dangerous duty to have combined with another is authorization.
-** Materiality for evacuee expenses
-** Materiality for non-evacuee expenses
+Finance Comrades forbidden from holding authorization duties. Bank Signatories are forbidden from holding record-keeping duties.
+=== Materiality ===
+==== Materiality for evacuee expenses ====
+Materiality will determine the amount of scrutiny an evacuee expense incurs. A set amount will be determined and referable by the Finance Committee. There can be multiple scales of materiality for an evacuee expense.
+The lowest on the materiality threshhold will involve the following:
+* The least amount of authorizers needed.
+* The least amount of documnetation
+* The least amount of natural consequences in cases of misappropriation.
+The highest amount of materiality will involve the following:
+* Clearest enforcement of Internal Controls
+* Concise recording of authorization, and authorizors.
+* Contracts if needed.
+* The clearest understanding of natural consequences when it comes to misappropriation and fraud.
+If there is a prohibited transaction for an evacuee, there will be no materiality threshold and scrutiny will be in place.
+==== Materiality for non-evacuee expenses ====
+Materiality will determine the amount of scrutiny an non-expense incurs. A set amount will be determined and referable by the Finance Committee. There can be multiple scales of materiality for an evacuee expense.
+The lowest on the materiality threshhold will involve the following:
+* The least amount of authorizers needed.
+* The least amount of documnetation
+* The detail in a Journal Entry Workpaper
+* The least amount of natural consequences in cases of misappropriation.
+The highest amount of materiality will involve the following:
+* Clearest enforcement of Internal Controls
+* Concise recording of authorization, and authorizors.
+* Contracts if needed.
+* Highest detail required for a Journal Entry workpaper.
+* The clearest understanding of natural consequences when it comes to misappropriation and fraud.
 === General Ledger Account Control ===
@@ Line 269: / Line 313: @@
 * Using appropriated funds for an evacuee for another documented expense purpose than initially reported
-* Using appropriated funds for one evacuee than initially stated
+* Using more appropriated funds for one evacuee than initially stated
 * Unauthorized transactions for sundries for KOI
+* Using funds from a restricted fund for expenses not allowed by said restricted fund.
 Accountability involves all sides knowing where errors and harm has been done. Acknowledgement of the misappropriation will be communicated by the Finance Committee to the KOI Volunteer. If the misappropriate was initiated by and Evacuee, the Finance Committee will notify the Evacuee's Care Coordinator.
@@ Line 284: / Line 329: @@
 * Removal from the transaction process entirely for the person who misappropriated funds.
 * Redelegation of tasks for a volunteer who misappropriated funds.
-* Using funds from a restricted fund for expenses not allowed by said restricted fund.
 The priority for deciding which consequence to enact upon the person who misappropriated funds should always be based upon the internal controls, and sustainability, of KOI. Never should shame/guilt be used when deciding next steps after misappropriation of funds.
@@ Line 337: / Line 382: @@
 === Accounting System - Xero ===
+The accounting system used by KOI must contain the following functionalities:
+* User and Audit Logs of Logins, and transaction modifications.
+* Transaction Recording
+* Financial Statement Reporting
+*Journal Entry Logging
+*Bank Reconciliation
+*User Management
+The Accounting system should only be completely accessible by KOI Volunteers who have record keeping privileges (Finance Comrades and the Board Treasurer). No one with signatory powers should be able to reconcile bank statements and record transactions in the accounting software. Read only accounts are highly suggested for those on the board and those with signatory powers.
+Xero is the Accounting System used by KOI.
 === Fundraising Systems ===
+Fundraising systems should be utilized to log the donor transactions for KOI. They should:
+* Log the donor who donated
+* Log the donation date
+* Log the fund donated to.
+Ideally, such systems should also accept donations easily and electronically.
+Donation systems might contain donor information such as bank information and credit card numbers. It is important to protect this data and ensure only folks with need to know privileges have access to said systems.
+Donations need to curated when received to ensure no fund restrictions are in place.
 ==== Zeffy ====
+Zeffy is the primary donation platform for KOI. Individuals who wish to donate directly to KOI are referred to our Zeffy link.
+Zeffy donations include the following, and more:
+* The donor name
+* The restriction of the donation (if any)
+*The donation method
+*The cadence of the donation
+*The date of the donation
+*The donation referral
+*The date deposited in KOI's bank account
+Exports of donations can be done via the zeffy web portal. Such exports should be kept with KOI as backup documentation of the purpose of the donation,and the donor.
+Finance Comrades, the Board Treasurer, and anyone with development tasks are allowed to use the Zeffy system and see exports. However, due to the confidential nature of the donations, only those with a completed background check can access zeffy. This requirement will always supersede general KOI policies.
 ==== Benevity ====
+Benevity is KOI's main workplace donation platform. Employees can ask their employer to have paycheck deductions
-=== Office Applications - Google Docs ===
+Benevity donations can include the following, and more:
+*The donor name
+* The restriction of the donation (if any)
+*The date of the donation
+*The donation referral
+*The date deposited in KOI's bank account
+In addition, Benevity can also collect corporate matches for their employee's donations.
+The matching donations can include:
+*The matching organization
+* The restriction of the donation (if any)
+*The date of the donation
+*The employee the donation is matching
+*The date deposited in KOI's bank account
+It is important to record such information for record keeping purposes.
+Finance Comrades, the Board Treasurer, and anyone with development tasks are allowed to use the Benevity system and see exports. However, due to the confidential nature of the donations, only those with a completed background check can access zeffy. This requirement will always supersede general KOI policies.
+To access Benevity, the account must have a Mutli-Factor Authentication feature turned on. Currently, that MFA feature is SMS only.
+=== Office Applications - Google Drive ===
+Google Drive, sometimes called Google Docs, is a cloud based application that features the following office applications:
+* Rich Text Editing (Sometimes called Word)
+* Multi-cell spreadsheet (Called Sheets)
+* Presentation Slides (Called Slides)
+In addition, the google drive can host pdfs and other documents in a cloud based environment. Documents can be shared with anybody who wants access, and they can be shared with only a few KOI members.
+The Finance Committee will use Google Drive for primary document retention, budgeting, and other finance tasks that are required.
+Due to the current political climate, and the possible capitulation of Google with a hostile government, it is recommended only primary documents that do not contain volunteer/evacuee names be stored on Google Drive.
 === Office Applications - Cryptpad ===
+Cryptpad is a cloud based application environment that features the following office applications:
+* Rich Text Editing (Sometimes called Word)
+* Multi-cell spreadsheet (Called Sheets)
+In addition, cryptpad can host pdfs and other documents in a cloud based environment. Documents can be shared with anybody who wants access, and they can be shared with only a few KOI members.
+The Finance Committee will use Google Drive for retention of documents that contain sensitive information such as Bank Statements, Evacuee names, payroll records, etc.
 === Communication - Element/Matrix ===
+The Finance Committee communicates needs, issues, task delegations, meeting times, etc. via the KOI Matrix Server with the Client Element. There is a Finance Committee channel where all of the Finance Comrades and the Board Treasurer communicate. The channel is also open to any other KOI volunteer, and it is encouraged other KOI volunteers join to provide oversight on the KOI Finance Committee.
+Expenses are brought to the entire KOI volunteer organization for review. Emoji reacts do not count as approval or veto'ing of an expense. Approval via Matrix does not count as approval of expenses for legal reasons.
 == Cash Management ==
+=== Cash Management Policy ===
+==== Managing Cash Flow ====
+The cash in and out is an important factor for the sustainability of the organization. In order for KOI to continue on as an organization, the organization needs to be able to meet the following obligations (by priority):
+# Budgeted Monthly Evacuee Expenses
+# Budgeted Monthly Payroll Expenses (if it exists)
+# Budgeted Monthly Rent Expenses (if renting a building)
+If there is ever a low cash balance for the organization, the Finance Committee must create a cash report listing:
+* End of Month Bank Account Balances
+* End of Month Credit Card Balances
+* End of Month Line of Credit Balances
+* Budgeted Evacuee Expenses for the Month
+* Budgeted Payroll Expenses for the Month (If Any)
+* Budgeted Payables for the month.
+* Budgeted Receivables (if any) for the month
+Ideally, this should be a spreadsheet allowing the Finance Committee to easily determine and report the next steps the organization can take.
+If expenses, and operations, are large enough, then the Finance Committee must issue this report monthly regardless to provide transparent status of the finances to the organization.
+==== Bank Account Balances ====
+Bank Account Balances should have set minimum balances. At the beginning of the month, the main checking account should be replenished to the the budgeted amount of expenses for evacuees for the month. The Bank account should never be below a set amount to ensure there are funds to be spent on the evacuees. The bank account shouldn't be above the replenish balance to ensure only a certain amount of funds would be vulnerable to a rogue actor who would wish to empty the bank account.
+Any funds not currently in the checking account should be in the savings account.
+Only those with authorization powers can transfer funds between bank accounts. Those with record keeping powers must have access to bank information in some channel, including a read-only method of the bank accounts.
+==== Petty Cash Handling ====
+The organization will not work with cash as much as possible. Cash will not be disbursed to evacuees. Cash will not be a mode of payment with vendors. Cash donations will be immediately deposited and not held by the organization outside of a depository institute.
+If there ever is a petty cash fund within the organization outside of a depository institute, there a few requirements.
+* Cash has to be counted on a periodic basis.
+* The Petty Cash account will have to go through reconciliation on a set periodic basis.
+* Separation of controls will be held (Authorizor, vs. Record Keeper vs. Custodian) with no exceptions.
+* Withdraws from the Petty Cash account will need two signatories.
 == Organization Budgeting ==
 To have a functioning Non-profit, a composed budget is required every year for KOI. A budget must be composed also for Grant applications, and to strengthen the internal controls of the organization.
@@ Line 365: / Line 534: @@
 If the budget is not approved by the organization, then there is no operational budget. The budget has to be recomposed, and re-submitted.
-The draft budget should be available on an accessible platform where changes can be tracked, and colloborated
+The draft budget should be available on an accessible platform where changes can be tracked, and collaborated.
 The following committees are responsible for:
@@ Line 376: / Line 545: @@
 In the scenario where KOI secures the funds to hire paid staff, the Wage Schedule will be composed by the Finance Committee based upon the inputs of the Board.
+If there is a new expenditure/program that materially effects the organization, then either:
+* The budget must be amended, or
+* An entire re-forecast of the budget must occur.
+A Re-forecasted budget, or budget amendment, must be approved by majority vote in the Finance Committee. The Finance Committee must alert the rest of the organization about the changes in the budget.
 === Budgeting Procedure ===
 == Fund Management ==
 === Fund Policy ===
-As a 501(c)(3), KOI is responsible in dividing the net assets into dedicated funds. The IRS required KOI to track expenses by funds, and to report expenses per funds in a statement of functional expenses on the tax return document the 990. The spending of expenses per fund is made transparent to the public on the 990 and on Washington State's Secretary of State's website.
+As a 501(c)(3), KOI is responsible in dividing the net assets (equity) into dedicated funds. The IRS requires KOI to track expenses by funds, and to report expenses per funds in a statement of functional expenses on the tax return document the 990. The spending of expenses per fund is made transparent to the public on the 990 and on Washington State's Secretary of State's website.
 KOI is required to keep track of only three Funds: Management, Fundraising, and Programs. However, to properly operate KOI keeps track of additional funds as need be.
@@ Line 417: / Line 593: @@
 ===== Programs (undesignated) Fund =====
-Programs is our general fund that allows KOI to do the work for the mission. Unless otherwise stated, these funds are unrestricted. There can be restricted funds that are sub-funds of the Programs Fund.
+Programs is the general fund that allows KOI to do the work for the mission. Unless otherwise stated, these funds are unrestricted. There can be restricted funds that are sub-funds of the Programs Fund.
 All Evacuee Expenses come from the programs fund. Any other expense that is for the mission of KOI also comes from the Programs Fund.
@@ Line 587: / Line 763: @@
 If such expenses were to occur, then a misappropriation of funds (at the minimum) is considered to have occurred.
+==== Evacuee Expense Authorization ====
+Expenses that require authorization must have:
+* The name of the KOI volunteer that approved the expense.
+* The name of the KOI Volunteer that proposed the expense
+* The date of the approval
+A KOI Volunteer cannot approve their own expense.
+Expenses that do not require authorization are either budgeted to include documentation only, or are a re-occurring expense that has pre-authorization to occur.
+Those with record-keeping, or custody, powers cannot authorize an expense.
 === Evacuee Expenses Procedures ===
@@ Line 657: / Line 846: @@
 If a card is approaching the spending limit, the card holder may request a signatory to complete an early payment. The board treasurer can confirm if there are cash reserves available for such a payment.
-Credit card holders may attach the credit card to a peer-to-peer (P2P) monetary option<!-- recommend "service" --> such as Venmo, Cash App, Paypal, etc.
+Credit card holders may attach the credit card to a peer-to-peer (P2P) monetary service such as Venmo, Cash App, Paypal, etc.
-Credit card holders may use the credit card for recurring expenses, and may<!-- Recommend "only need approval for the first instance" or similar. Also perhaps add something about needing re-authorization if the cost of the recurring expense changes beyond a set percentage of the primary amount. --> only ask for approval once due to the consistent nature of the expense.
+Credit card holders may use the credit card for recurring expenses. These expenses need approval for the first instance. Afterwards, no further authorization is needed barring changes in the purpose of the transaction, amount, or timing.<!-- Recommend "only need approval for the first instance" or similar. Also perhaps add something about needing re-authorization if the cost of the recurring expense changes beyond a set percentage of the primary amount.
+Josh - Good point. I rephrased it. -->
 If there is an unknown, and/or unauthorized, transaction on the card, the card holder must notify the signatories within 24 hours of the posting date.
@@ Line 681: / Line 872: @@
 ==== Cessation of Credit Card use ====
-Credit card cessation is required when:
+Credit card use cessation is required when:
 * Violation, or violations, of policy threaten KOI’s sustainability and going concern
@@ Line 692: / Line 883: @@
 The immediate next step is to close the credit card. No further credit card can be issued to the credit card holder unless it was determined there was an error in the decision of cessation.
-Only the board treasurer, the board chair, and the executive director<!-- Recommend noting more explicitly that all three are required. --> can make the decision to cease use of a credit card for a credit card holder. No vote is required out of the three, but disclosure must be made. No veto regarding such a decision can be made.
+Only the board treasurer, the board chair, or the executive director<!-- Recommend noting more explicitly that all three are required. - Clarifying that only one is needed to deny CC usage. --> can make the decision to cease use of a credit card for a credit card holder. No vote is required out of the three, but disclosure must be made. No veto regarding such a decision can be made.
-Once there is a decision to remove the credit card from the credit card holder, the decision must be disclosed to the credit card holder, the evacuees depending on the credit card, the finance committee, and to the bank. A bank signatory will then close the account<!-- Close the account, or just the card? -->.
+Once there is a decision to remove the credit card from the credit card holder, the decision must be disclosed to the credit card holder, the evacuees depending on the credit card, the finance committee, and to the bank. A bank signatory will then close the card.
 Further consequences can include:
@@ Line 878: / Line 1,069: @@
 === Payroll Procedures ===
 == Compliance, Audits, and Government Filings ==
+KOI will retain copies of every compliant, audit, and/or government filing and keep it organized in case there are any need to refer to past filings.
 === Federal – Internal Revenue Service ===
 ==== Annual Filings - 990 ====
+The 990 is the annual filing with the IRS as a non-profit. The deadline for such filings is May 15th, or October 15th (if an extension was filed).
+To file a 990, the prior year's financials must be completed and closed (meaning, no modifications allowed). Ideally, the financial statements would be audited if required for a grant.
+To file a 990, the following pieces of information is required:
+* List of Board of Directors
+* Compensated Directors
+* Major Donors
+* An end of year Income Statement for the prior year.
+* A end of year Balance sheet statement for the prior year.
+* A list of expenses per Management, Programs, and Fundraising.
+The 990-N is the annual filing KOI can file in place of the 990 if certain requirements are met. KOI currently doesn't meet those requirements, and it will unlikely be able to due to the financial obligations of supporting evacuees.
 ==== Payroll Filings 940 and 941 ====
+If KOI were to ever have payroll, regular payroll filings would need to be filed. During payroll, employee deductions for Unemployment Insurance (UI or FUTA) would be held in a liability account. The 940 report would need to be filed before the end of the month following the end of the prior quarter.
+During payroll, employee deductions for federal withholding, social security, and medicare would be held in a liability account. At the same time, employer contributions to social security and medicare will be expensed and held in a liability account. At the end of the month after the quarter ends KOI will pay the aggregate totals reported in a 941 form to the IRS.
+If it works better for KOI, a deposit system can be used to keep on top of the payroll liabilities through the quarter.
+==== Annual W-2's and W-3s ====
+If there were payroll in a calendar year, the W-2s and W-3s are due at the end of January of the following year. The W-3 will contain the aggregate information for all of the boxes of the W-2s filed for the year. Ideally, this is filed electronically.
+==== Annual 1099's and 1096's ====
+If there are payments to Non-employee contractors (individuals, sole proprietorship) or Single member LLC's, KOI must collect a W-9 from said vendor if the aggregate amounts paid for the year meet, exceed, or will exceed $600.00. KOI will then file the 1099's by the end of January following the year, along with a 1096 that will consolidate all of the payments of the 1099s.
 === Washington State – Secretary of State ===
@@ Line 906: / Line 1,126: @@
 === Washington State – Department of Revenue B&O ===
+Every Year, KOI will file the annual Excise tax by April 15th 2026 electronically via dor.wa.gov and the Secure Access Washington (SAW) Account.
 === Washington State – Payroll ===
 ==== ESD Filing ====
+After payroll is calculated and Unemployment withholdings are withheld, KOI will file an electronic return with ESD via the SAW account for the fiscal quarter. Funds will be sent to ESD electronically, or by paper check. The due date for the filings is the last day after the last fiscal quarter. It is recommended a csv is prepared well before the filing to make the filing easier. Instructions can be found on esd.wa.gov.
-==== LnI Filing ====
+==== LnI (Labor and Industries) Filing ====
+Before KOI begins withholding LnI withholdings, a Business Type Class must be designated for all workers, and the appropriate rate written down. These rates can be found on lni.wa.gov (Most likely 5308 - Community Action). The rate is multiplied by the amount of hours worked in a payroll period, and withheld from pay to be allocated in a payroll liability account. At the end of the quarter, the LnI return is filed by multiplying the total amount of payroll hours for the prior fiscal quarter by the LnI rate chosen. The return is due by the last day of the month following the fiscal quarter. The return is filed on lni.wa.gov, and it is recommended a CSV of the hours of the prior quarter be prepared ahead of time.
 ==== PFMLA Filing ====
+KOI will need to determine what amount of the premiums will be paid by KOI, and what amount will be paid by the employee. Once those rates have been decided, the employer withholdings are expensed and put into a payroll tax liability, and the employee deductions are put into a payroll tax liability. At the end of the month following the end of a fiscal quarter, a summary of hours, payroll wages, and PFMLA withholdings is submitted to ESD electronically through a SAW account. A payment is sent to ESD by check or ACH option on the SAW Account.
 ==== WA Cares Filing ====
+KOI will need to request if any employee wants to exempt themselves from WA Cares. The employee deductions are put into a payroll tax liability during every payroll. At the end of the month following the end of a fiscal quarter, a summary of hours, payroll wages, and WA Cares withholdings is submitted to ESD electronically through a SAW account. A payment is sent to ESD by check or ACH option on the SAW Account.
 === King County ===
+No report currently required by King County.
 === City of Seattle ===
+To remain compliant with the City of Seattle, KOI will file a business tax return with the City digitally via [https://www.filelocal-wa.gov/ File Local] .This report is due at the end of April of every year.

KOI Financial Policies and Procedures: Difference between revisions

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