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Nonprofit Fraud: What
                              You Need to Know

                              Part I: The Fraud
                         Lawrence J. Hoffman, CPA/CFF, CVA, CFE
                         Senior Partner, & Director of Forensic Consulting Services

                         April 4, 2013




Thrive. Grow. Achieve.
OBJECTIVES
     NONPROFIT FRAUD: THREE-PART SERIES

PART I: THE FRAUD
•   Why it is important that you are educated in fraud
•   The magnitude of fraud in nonprofits
•   The types of frauds in nonprofits
•   Why does fraud occur in nonprofits
•   Some important fraud prevention measures

PART II: THE DETECTION
•   Who are the fraud perpetrators?
•   Why do people commit fraud?
•   How is fraud detected?
•   What are fraud red flags?
•   Fraud detection techniques
•   What do you do when you uncover fraud?

PART III: THE PREVENTION
•   What are the primary factors contributing to fraud in nonprofits?
•   Detective versus preventative controls
•   What are the best preventative measures?
•   The five critical takeaways!
                                                    Part I: The Fraud * Page 2
AGENDA

• Why you need to be educated about fraud
• What you need to know about the impact of fraud
• Common types of fraud in nonprofits
• Case study # 1
• Case study # 2
• More case studies
• Summary – the important takeaways!
• How can Raffa assist you in preventing and detecting fraud?
• Resources and suggested reading
• Questions and answers




                                                 Part I: The Fraud * Page 3
WHY YOU NEED TO KNOW ABOUT FRAUD

                                THE TOP TEN REASONS!
1. Nonprofit organizations are very susceptible
   to fraud and abuse

1. Don’t count on your outside auditor to uncover the fraud

2. Fraud increases when the “pressure / incentive” increases,
   which increases in a poor economy1 and layoffs (fewer
   employees doing more)

3. You probably have some sort of fraud in your organization
   going on and you don’t know it

4. A fraud in your organization could bring unwanted outcomes,
   such as adverse publicity, loss of support, lower employee
   morale, and disruption of your operations



1
    See article, “In Tough Economy, Employee Theft Climbs to Epidemic Proportions, Expert Says,”
    Statesman.com, November 2011.

                                                                               Part I: The Fraud * Page 4
WHY YOU NEED TO KNOW ABOUT FRAUD

           THE TOP TEN REASONS! (CONTINUED)
6. The IRS requires you to disclose instances of fraud – Form 990
   – more transparent to donors

7. You cannot afford the loss, cost of the investigation, and
   disruption to your operations

8. Asset (cash ) misappropriations are by far the most prevalent
   frauds committed against nonprofits and the most important
   resource

9. The fraud perpetrator is not easily known to the organization.
   In many cases, the perpetrator is “someone you know and
   trust”

10. You could find yourself personally liable for damages




                                                  Part I: The Fraud * Page 5
WHY YOU NEED TO KNOW ABOUT FRAUD

FORM 990 RETURN OF ORGANIZATION EXEMPT FROM
                 INCOME TAX




                                Part I: The Fraud * Page 6
WHAT YOU NEED TO KNOW ABOUT FRAUD




Go to http://www.acfe.com/rttn.aspx to download the report.


                                                 Part I: The Fraud * Page 7
WHAT YOU NEED TO KNOW ABOUT FRAUD
                     ACFE REPORT TO THE NATIONS
                        SUMMARY OF FINDINGS
• Typical organization loses 5% of its annual revenue to fraud (applied to
  2011Gross World Product = $3.5 trillion)
• Median loss is $140,000
• Fraud lasted 18 months before being detected
• 87% are asset misappropriation schemes
• Most likely detected by a tip than any other means
• Small organizations are disproportionately victimized
• Most occupational fraudsters are first-time offenders with clean
  employment histories. Approximately 87% of occupational fraudsters had never
  been charged or convicted of a fraud-related offense, and 84% had never been
  punished or terminated by an employer for fraud-related conduct
• In 81% of cases, the fraudster displayed one or more behavioral red flags
  that are often associated with fraudulent conduct.
  – Living beyond their means (36%)
  – Experiencing financial difficulties (27%)
  – Unusually close association with vendors or customers (19%)
  – Excessive control issues (18%)

                                                                  Part I: The Fraud * Page 8
WHAT YOU NEED TO KNOW ABOUT FRAUD

              ACFE REPORT TO THE NATIONS
            SUMMARY OF FINDINGS (CONTINUED)
• Perpetrators with higher levels of authority tend to cause much
  larger losses. The median loss among frauds committed by owners /
  executives was $573,000, the median loss caused by managers was
  $180,000, and the median loss caused by employees was $60,000
• The longer a perpetrator has worked for an organization, the
  higher fraud losses tend to be. Perpetrators with more than 10
  years of experience at the victim organization caused a median loss of
  $229,000. By comparison, the median loss caused by perpetrators
  who committed fraud in their first year on the job was only $25,000
• 77% of all frauds in the study were committed by individuals
  working in one of six departments: accounting, operations, sales,
  executive / upper management, customer service, and publishing
• Nearly half of victim organizations do not recover any losses that
  they suffer due to fraud. 49% of victims had not recovered any of
  the perpetrator’s takings; this finding is consistent with previous
  research, which indicates that 40-50% of victim organizations do not
  recover any of their fraud-related losses
                                                     Part I: The Fraud * Page 9
WHAT YOU NEED TO KNOW ABOUT FRAUD
             ACFE REPORT TO THE NATIONS
           SUMMARY OF FINDINGS (CONTINUED)
• Not-for-profit organizations made up the smallest portion of the
  ACFE’s dataset, accounting for more slightly more than 10% of
  reported cases




                                                   Part I: The Fraud * Page 10
WHAT YOU NEED TO KNOW ABOUT FRAUD
       ACFE REPORT TO THE NATIONS
     SUMMARY OF FINDINGS (CONTINUED)




                               Part I: The Fraud * Page 11
WHAT YOU NEED TO KNOW ABOUT FRAUD
             ACFE REPORT TO THE NATIONS
           SUMMARY OF FINDINGS (CONTINUED)
• Small organizations (those with fewer than 100 employees)
  continue to be the most common victims in fraud




                                                Part I: The Fraud * Page 12
WHAT YOU NEED TO KNOW ABOUT FRAUD
       ACFE REPORT TO THE NATIONS
     SUMMARY OF FINDINGS (CONTINUED)




                               Part I: The Fraud * Page 13
WHAT YOU NEED TO KNOW ABOUT FRAUD
       ACFE REPORT TO THE NATIONS
     SUMMARY OF FINDINGS (CONTINUED)




                               Part I: The Fraud * Page 14
WHAT YOU NEED TO KNOW ABOUT FRAUD
       ACFE REPORT TO THE NATIONS
     SUMMARY OF FINDINGS (CONTINUED)




                               Part I: The Fraud * Page 15
WHAT YOU NEED TO KNOW ABOUT FRAUD

          CONCLUSIONS AND RECOMMENDATIONS
• Occupational fraud is a global problem
• Fraud reporting mechanisms (hotlines) are a critical component
  of an effective fraud prevention and detection system
• Organizations tend to over-rely on audits
• Employee education is the foundation of preventing and detecting
  fraud
• Surprise audits are an effective, yet underutilized tool
• Small businesses are particularly vulnerable to fraud
• Internal controls alone are insufficient to fully prevent fraud
• Fraudsters exhibit behavioral warning signs of their misdeeds
• Effective fraud prevention measures are critical




                                                     Part I: The Fraud * Page 16
WHAT YOU NEED TO KNOW ABOUT FRAUD

 JP SIMS CONSULTING – CASES REPORTED IN LAST SIX
         MONTHS IN THE NONPROFIT SECTOR
• “Brooklyn Woman Sentenced in Manhattan Federal Court to Two
  Years in Prison for Participating in $57.3 Million Fraud on
  Organization that Makes Reparations to Victims of Nazi
  Persecution”
• “Former President and Executive Director of Vanguard Public
  Foundation Sentenced to 40 Months in Prison for Fraud and
  Money Laundering”
• “Monroeton Woman Sentenced for Embezzling Money from
  Martha Lloyd Community Services”
• “A.G. Schneiderman Announces $2.3 Million Settlement with St.
  Luke’s-Roosevelt Hospital for Overbilling Medicaid and Medicare”
• “Miami-Area Therapist Sentenced to Prison in Florida in $205
  Million Community Mental Health Fraud Scheme”


          www.jpsimsconsulting.com

                                                 Part I: The Fraud * Page 17
WHAT YOU NEED TO KNOW ABOUT FRAUD

                            NONPROFIT FRAUD
• Why nonprofits face a disproportionate level of fraud:
  – Lack of internal controls / segregation of duties

  – Lack of tone at the top / oversight – “volunteers” vs. “the store owner

  – Lack of hiring – due diligence

  – Lack of anti-fraud programs

  – Too much reliance on audits to catch fraud

  – More “mission” driven versus “profit” driven

  – Greater culture of “trust”




                                                               Part I: The Fraud * Page 18
WHAT YOU NEED TO KNOW ABOUT FRAUD
                          THE SIZE OF THE NONPROFIT SECTOR2
      • 1,551,705 tax-exempt organizations composed of:
          – 963,255 public charities
          – 97,941 private foundations
          – 490,509 other types of organizations (e.g., chambers of commerce, fraternal
            organizations, and civic leagues)

      • Nonprofits’ share of the U.S. GDP was 5.5% in 2012
      • In 2010 (the most recent date in which these figures were
        aggregated), public charities accounted for:
          – $1.51 trillion in revenue
                 • Of the revenue, 22% came from contributions, gifts, and government grants; 73%
                   came from program services revenues, which include government fees and contracts;
                   and 5% came from “other” sources, including dues, rental income, special event
                   income, and gains or losses from goods sold

      • In 2011(the most recent date in which these figures were
        aggregated), private charitable contributions, which include
        giving to public charities and religious congregations, totalled
        $298.4 billion


2
    National Center for Charitable Statistics, “Quick Facts about Nonprofits,” http://nccs.urban.org/statistics/quickfacts.cfm.
                                                                                                Part I: The Fraud * Page 19
WHAT YOU NEED TO KNOW ABOUT FRAUD

  THE MOST IMPORTANT POINTS YOU WILL TAKE AWAY
            FROM THIS SEMINAR SERIES

• Design your systems and procedures so you do not have to rely
  on trust as a control!
• Any person is capable of committing fraud!
• TRUST IS NOT AN INTERNAL CONTROL!




                                                Part I: The Fraud * Page 20
FAMOUS QUOTES




                         “Trust, but verify.”
• 40th President of the United States Ronald W. Reagan (1911-2004)




                   “Verify, then verify some more.”
• Senior Partner, Raffa, P.C., Lawrence J. Hoffman, CPA/CFF, CVA,
  CFE (1954-?)

                                                  Part I: The Fraud * Page 21
MY BOOK!

EXPECTED RELEASE
       THIS FALL!

       STAY TUNED!




    Part I: The Fraud * Page 22
WHAT YOU NEED TO KNOW ABOUT FRAUD

           THE FIVE MOST IMPORTANT TAKEAWAYS
1. Trust is not an internal control!
  – Establish, to the extent possible, controls and procedures that eliminate the
    element of trust
  – Always segregate the custody of the asset with the recordkeeping for the asset

2. Set the tone from the top!
  – “If you are stealing, your employees are stealing!”
  – E.g., office supplies, expense reports, etc.

3. Know your employees!
  – Background investigations and public records checks before hiring
  – Meet and establish a baseline relationship

4. Institute a fraud policy
  – No tolerance
  – Will prosecute

5. Establish a hotline for tips
  – Number one method for detecting fraud!
  – Can outsource

                                                            Part I: The Fraud * Page 23
TYPES OF FRAUD

          THREE BROAD CATEGORIES OF FRAUD
• Fraudulent statements

• Corruption

• Misappropriation of assets




                                    Part I: The Fraud * Page 24
TYPES OF FRAUD




    Part I: The Fraud * Page 25
TYPES OF FRAUD

                       FRAUDULENT STATEMENTS
• Fraudulent financial reporting (“cooking the books”). Intentional
  misstatement or omissions of amounts or disclosers in financial
  statements designed to deceive financial users when the effect
  causes the financial statements not to be presented , in all
  material respects, in conformity with GAAP
  – Examples:
      • Falsification of accounting records
      • Omissions of transactions or disclosers

• Non-Financial
  – Employment credentials
  – Internal and external documents




                                                      Part I: The Fraud * Page 26
TYPES OF FRAUD

                            CORRUPTION
• Schemes that involve the employee’s use of his or her influence
  in business transactions in a way that violates their duty to the
  employer and obtains benefit for themselves or others:
  – Conflicts of interest
  – Bribery
  – Illegal gratuities
  – Economic extortion




                                                   Part I: The Fraud * Page 27
TYPES OF FRAUD

                MISAPPROPRIATION OF ASSETS
• The theft of an entity’s assets where the effect of the theft causes
  the financial statements not to be presented in conformity with
  GAAP (sometimes referred to as “defalcation”)
• Misappropriation of assets can be accomplished in various ways,
  including:
  – Embezzling
  – Stealing assets
  – Causing an entity to pay for goods or services that have not been
    received or causing an entity to overpay for goods or services actually
    received




                                                         Part I: The Fraud * Page 28
TYPES OF FRAUD

                MISAPPROPRIATION OF ASSETS
• Revenue and cash receipts (collections) schemes:
  – Cash skimming / unrecorded sales / contributions
  – Cash larceny
  – Lapping schemes
  – Write-off of accounts receivable
  – Unauthorized credits
  – Check tampering (stolen, altered)




                                                       Part I: The Fraud * Page 29
TYPES OF FRAUD

   PURCHASING AND CASH DISBURSEMENT SCHEMES
• Fictitious invoices and vendors (shell company)
• Check tampering
  – Forged maker (check signer)
  – Forged endorsement
  – Altered payee

• Bank wire transfers




                                                    Part I: The Fraud * Page 30
TYPES OF FRAUD

     PAYROLL AND EMPLOYEE EXPENSE REPORTING
                    SCHEMES
• Payroll schemes
  – Ghost employees
  – Falsified hours and wages
  – Overtime abuses

• Expense reimbursement schemes
  – Mischaracterized expenses
  – Overstated expenses (altered receipts)
  – Fictitious expenses (bogus receipts)
  – Multiple reimbursements




                                                 Part I: The Fraud * Page 31
TYPES OF FRAUD

          NONCASH ASSET MISAPPROPRIATIONS
• Misuse of assets for personal use
• Inventory




                                          Part I: The Fraud * Page 32
CASE STUDY # 1




The Washington Post, Wednesday, June 3, 2009.
                                                    Part I: The Fraud * Page 33
CASE STUDY # 1

                       WHAT WENT WRONG?
• Position of perpetrator: Controller
• Length of time employed: 3 years, 11 months
• Length of time fraud lasted: 3 years, 6 months
• Schemes involved in fraud:
  – Fraudulent checks and wire transfers
  – Used electronic signatures and signature stamps
  – Falsified accounting of transactions in books and records
  – Provided forged documents, including bank statements, to independent
    auditors

• How was the fraud discovered?: Executive Director found checks
  written to perpetrator and an unknown bank account statement in his
  office after he was terminated for poor performance




                                                          Part I: The Fraud * Page 34
CASE STUDY # 1

                      HOW MUCH DID IT COST?
• Organization’s annual budget: $2.7 million
• Total fraud loss to the organization: $425,558 (fidelity bond was
  only $30,000 with $5,000 deduction)
• Other losses to the organization: Disruption to operations and legal
  and forensic consulting fees
• Where did all the money go?: New 2006 BMW 325i car, furniture,
  vacations
• What happened to the perpetrator?:
  – Criminal prosecution
  – Conviction
  – 41 months in Allenwood, a low-security correctional institution in White Deer,
    PA
  – Ordered to pay restitution of $470,990.59




                                                              Part I: The Fraud * Page 35
CASE STUDY # 1

                          LESSONS LEARNED
• Lack of segregation of duties – a “one-man show”!
  – Segregate the custody of the asset with the recordkeeping!

• Lack of oversight controls and financial reviews, including review
  of financial statements, reconciliations
• Use of signature stamp
• Inadequate fidelity bond coverage
• Too much trust and not enough verification!




                                                            Part I: The Fraud * Page 36
CASE STUDY # 2

ORGANIZATION CURRENTLY UNDISCLOSED




                          Part I: The Fraud * Page 37
CASE STUDY # 2

                        WHAT WENT WRONG?
• Position of perpetrator: Director of Information Technology
• Length of time employed: 7 years, 7 months – voluntarily left
  employment and left country
• Length of time fraud lasted: 7 years, 5 months
• Schemes involved in fraud:
  – Billing scheme – shell company – billed for IT equipment that was never
    received by the organization

• How was the fraud discovered?:
  – Whistleblower – person who replaced perpetrator notices discrepancies and
    anomalies in past IT inventory and procedures




                                                            Part I: The Fraud * Page 38
CASE STUDY # 2

                    HOW MUCH DID IT COST?
• Total fraud loss to the organization: $3.5 million ($1.3 million
  recovered from insurance)
• Other losses to the organization: Disruption to operations and
  forensic consulting fees
• Where did all the money go?: Amusement park in foreign country
• What happened to the perpetrator?: Fled the country




                                                      Part I: The Fraud * Page 39
CASE STUDY # 2

                          LESSONS LEARNED
• Lack of internal controls / segregation of duties
  – No separation of custody of asset with recordkeeping

• Lack of a packing and receiving reports match
• One person controlled the procurement, receipt, and deployment
  of the assets
• Lack of inventory controls – “The wolf watching over the hen
  house”
• Too much trust and not enough verification!




                                                           Part I: The Fraud * Page 40
MORE CASE STUDIES




The Washington Post, May 31, 1997.
                                     Part I: The Fraud * Page 41
MORE CASE STUDIES




The Washington Post, August 17, 2011.
                                Part I: The Fraud * Page 42
MORE CASE STUDIES




  The Blog of Legal Times, September 26, 2013.
                   Part I: The Fraud * Page 43
MORE CASE STUDIES




The Washington Post, May1, 2010.
                                           Part I: The Fraud * Page 44
MORE CASE STUDIES




The Associated Press, January 14, 2013.
                                                  Part I: The Fraud * Page 45
MORE CASE STUDIES




The National Law Journal, January 14, 2013.
                                              Part I: The Fraud * Page 46
MORE CASE STUDIES




The Associated Press, September 24, 2008
                                                   Part I: The Fraud * Page 47
MORE CASE STUDIES




The Washington Examiner, July 1, 2010.
                                         Part I: The Fraud * Page 48
MORE CASE STUDIES




        Part I: The Fraud * Page 49
WHAT YOU NEED TO KNOW ABOUT FRAUD

    THE FIVE MOST IMPORTANT TAKEAWAYS – AGAIN!
1. Trust is not an internal control!
  – Establish, to the extent possible, controls and procedures that eliminate the
    element of trust
  – Always segregate the custody of the asset with the recordkeeping for the asset

2. Set the tone from the top!
  – “If you are stealing, your employees are stealing!”
  – E.g., office supplies, expense reports, etc.

3. Know your employees!
  – Background investigations and public records checks before hiring
  – Meet and establish a baseline relationship

4. Institute a fraud policy
  – No tolerance
  – Will prosecute

5. Establish a hotline for tips
  – Number one method for detecting fraud!
  – Can outsource

                                                            Part I: The Fraud * Page 50
HOW CAN RAFFA ASSIST YOU IN
      PREVENTING AND DETECTING FRAUD?

             FORENSIC CONSULTING SERVICES
• Pre-hire investigations and background checks
• Fraud risk assessment
• Internal control / program review
• Fraud awareness training
• Fraud prevention programs and policies implementation
• Due diligence investigations
• Fraud investigations




                                                  Part I: The Fraud * Page 51
SOME AREAS WE WILL BE GOING OVER IN
                OUR FINAL PRESENTATION

PART II: THE DETECTION – MAY 7, 2013, 12:00-2:00 P.M.
•   Who are these people that commit fraud?
•   Why do they commit fraud?
•   How are most frauds really detected?
•   Specific things you should have in place to help detect fraud
•   What should you do when you uncover fraud?

PART III: THE PREVENTION – JUNE 5, 2013, 12:00-2:00 P.M.
•   What are the primary factors contributing to fraud in nonprofits?
•   Detective versus preventative measures and controls
•   The best preventative controls and practices
•   The critical takeaways and how to implement them




                                                    Part I: The Fraud * Page 52
RESOURCES AND SUGGESTED READING

• 2012 Report to the Nations on Occupational Fraud and Abuse,
  Association of Certified Fraud Examiners,
  http://www.acfe.com/rttn.aspx
• “The American Fraud Report,” www.jpsimsconsulting.com
• The CPA’s Handbook of Fraud and Commercial Crime Prevention,
  AICPA
• Managing the Business Risk of Fraud: A Practical Guide; AICPA,
  ITA, and ACFE; https://na.theiia.org/standards-
  guidance/Public%20Documents/fraud%20paper.pdf




                                                Part I: The Fraud * Page 53
QUESTIONS AND ANSWERS




            Part I: The Fraud * Page 54
BIOGRAPHY
                       •   35 years of consulting, audit, accounting and tax experience in the public and private
                           sectors.
                       •   Started career with a Big-Four international accounting firm in Washington, DC.
                       •   Founded a regional certified public accounting and consulting firm in 1982 and grew it to
LAWRENCE J. HOFFMAN,       on of the Washington, DC’s largest firms in seven years. Merged his practice with Raffa
CPA/CFF, CVA, CFE          P.C. in 2008.
                       •   Managed and conducted audit and accounting engagements ranging from small privately
                           held to large publicly held businesses in various industries, including multi-national
                           businesses, nonprofit organizations, and governmental entities and agencies.
                       •   Performed economic and financial analysis, including projections and forecasts, in support
                           of litigation and claims for lost earnings and profits, business interruption, shareholder
                           disputes, patent and trademark infringements, bankruptcy and restructuring, and structural
                           settlements; assistance with interrogatories, document requests and depositions; and
                           serving as an expert and consulting witness.
                       •   Performed and supervised business valuations for both public and closely held companies
                           in a variety of industries, individuals and estates, family limited partnerships and limited
                           liability companies, including valuations for business combinations (SFAS 141R), mergers,
SENIOR PARTNER
                           acquisitions, and divestitures, estate and gift taxes, marital dissolution proceedings, buy-
RAFFA, P.C.                sell agreements, intangible assets and intellectual property, purchase price allocations,
1899 L STREET, NW
                           goodwill (SFAS 142) and long-lived asset (SFAS 144) impairment, fair value accounting
WASHINGTON, DC 20036
                           (SFAS 157), cheap stock (IRC 409A), stock-based compensation (SFAS 123R), phantom
                           stock and employee stock ownership plans.
TEL. 202-822-5408
FAX 202-822-0669       •   Conducted and led teams of forensic accountants on fraud audits and investigations,
LHOFFMAN@RAFFA.COM         including fraudulent financial statements, misappropriations of assets and embezzlements;
                           money laundering, kickbacks, bribery and conflicts of interest; insurance claims;
                           bankruptcy; financial institutions and loan fraud.        Also has conducted fraud risk
                           assessments, anti-fraud programs, and fraud training and education.

                                                                                            Part I: The Fraud * Page 55
BIOGRAPHY
                       •   Assisted companies and nonprofits with restructuring and turnaround situations, including
                           recapitalizations, reorganizations and liquidations. Advised entities on Chapters 11 and 7,
                           bankruptcy filings and proceedings and non-judicial workouts. Developed and
                           administered crisis management plans, cash flows, liquidation and turnaround analysis,
                           debt restructuring and creditor negotiations, and turnaround plans.
LAWRENCE J. HOFFMAN,
CPA/CFF, CVA, CFE      •   Formulated strategic short- and long-term business and financial planning for various
                           business organizations and served as interim “C” level positions, including for a major
                           North American sports league, European and U.S. aircraft manufacturer, aviation charter
                           airline and travel company, and a multi-chain quick service food chain.
                       •   Formulated syndication strategies and prepared business plans and private placement
                           offerings, including financial forecasts, market research and analysis, due diligence,
                           securities pricing and structuring for various public and private securities offerings,
                           including SEC filing.
                       •   Founded and developed a regional NASD licensed broker dealer investment banking firm.
                           Placed over $150 million in debt and equity and represented over $200 million in merger
                           and acquisition transactions.
                       •   Founded and developed two private equity funds in excess of $10 million, including
SENIOR PARTNER             investments in early stage and mature emerging companies in the form of debt and equity.
                           Portfolio investments included aviation, food and hospitality, software and technology,
                           telecommunications, sports and entertainment, banking and financial institutions,
                           healthcare, and wholesale and retail.
                       •   Co-founded and managed various real estate acquisition, ownership, and operating
                           entities, including commercial office buildings, shopping centers, flex warehouses,
                           residential housing and developed land.
                       •   Performed tax and financial consulting services for individuals and closely held
                           businesses.
                       •   Instructor in audit, accounting, finance, and forensic accounting.

                                                                                                Part I: The Fraud * Page 56
BIOGRAPHY

                       EDUCATION & CERTIFICATIONS
                        •   Bachelor of Science, Accounting – Mount St. Mary’s University
                        •   Certified Public Accountant (CPA)
LAWRENCE J. HOFFMAN,    •   Certified Fraud Examiner (CFE)
CPA/CFF, CVA, CFE       •   Certified in Financial Forensics (CFF)
                        •   Certified Valuation Analyst (CVA)
                        •   Private Investigator (PI), Virginia
                        •   Series 7 General Securities Representative (not active)
                        •   Series 24 General Securities Principal (not active)
                        •   Series 63 Uniform Securities Agent (not active)


                       PROFESSIONAL ASSOCIATIONS & AFFILIATIONS
                        •   American Institute of Certified Public Accountants, Member
                        •   Virginia Society of Certified Public Accountants
                        •   Association of Certified Fraud Examiners
SENIOR PARTNER          •   National Association of Certified Valuation Analysts
                        •   Institute of Business Appraisers


                       PERSONAL INTERESTS
                        •   Private pilot with instrument, multi-engine, high performance complex and aircraft ratings
                        •   Golf and fishing
                        •   Reading and politics




                                                                                          Part I: The Fraud * Page 57

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Nonprofit Fraud: What You Need to Know (39

  • 1. Nonprofit Fraud: What You Need to Know Part I: The Fraud Lawrence J. Hoffman, CPA/CFF, CVA, CFE Senior Partner, & Director of Forensic Consulting Services April 4, 2013 Thrive. Grow. Achieve.
  • 2. OBJECTIVES NONPROFIT FRAUD: THREE-PART SERIES PART I: THE FRAUD • Why it is important that you are educated in fraud • The magnitude of fraud in nonprofits • The types of frauds in nonprofits • Why does fraud occur in nonprofits • Some important fraud prevention measures PART II: THE DETECTION • Who are the fraud perpetrators? • Why do people commit fraud? • How is fraud detected? • What are fraud red flags? • Fraud detection techniques • What do you do when you uncover fraud? PART III: THE PREVENTION • What are the primary factors contributing to fraud in nonprofits? • Detective versus preventative controls • What are the best preventative measures? • The five critical takeaways! Part I: The Fraud * Page 2
  • 3. AGENDA • Why you need to be educated about fraud • What you need to know about the impact of fraud • Common types of fraud in nonprofits • Case study # 1 • Case study # 2 • More case studies • Summary – the important takeaways! • How can Raffa assist you in preventing and detecting fraud? • Resources and suggested reading • Questions and answers Part I: The Fraud * Page 3
  • 4. WHY YOU NEED TO KNOW ABOUT FRAUD THE TOP TEN REASONS! 1. Nonprofit organizations are very susceptible to fraud and abuse 1. Don’t count on your outside auditor to uncover the fraud 2. Fraud increases when the “pressure / incentive” increases, which increases in a poor economy1 and layoffs (fewer employees doing more) 3. You probably have some sort of fraud in your organization going on and you don’t know it 4. A fraud in your organization could bring unwanted outcomes, such as adverse publicity, loss of support, lower employee morale, and disruption of your operations 1 See article, “In Tough Economy, Employee Theft Climbs to Epidemic Proportions, Expert Says,” Statesman.com, November 2011. Part I: The Fraud * Page 4
  • 5. WHY YOU NEED TO KNOW ABOUT FRAUD THE TOP TEN REASONS! (CONTINUED) 6. The IRS requires you to disclose instances of fraud – Form 990 – more transparent to donors 7. You cannot afford the loss, cost of the investigation, and disruption to your operations 8. Asset (cash ) misappropriations are by far the most prevalent frauds committed against nonprofits and the most important resource 9. The fraud perpetrator is not easily known to the organization. In many cases, the perpetrator is “someone you know and trust” 10. You could find yourself personally liable for damages Part I: The Fraud * Page 5
  • 6. WHY YOU NEED TO KNOW ABOUT FRAUD FORM 990 RETURN OF ORGANIZATION EXEMPT FROM INCOME TAX Part I: The Fraud * Page 6
  • 7. WHAT YOU NEED TO KNOW ABOUT FRAUD Go to http://www.acfe.com/rttn.aspx to download the report. Part I: The Fraud * Page 7
  • 8. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS • Typical organization loses 5% of its annual revenue to fraud (applied to 2011Gross World Product = $3.5 trillion) • Median loss is $140,000 • Fraud lasted 18 months before being detected • 87% are asset misappropriation schemes • Most likely detected by a tip than any other means • Small organizations are disproportionately victimized • Most occupational fraudsters are first-time offenders with clean employment histories. Approximately 87% of occupational fraudsters had never been charged or convicted of a fraud-related offense, and 84% had never been punished or terminated by an employer for fraud-related conduct • In 81% of cases, the fraudster displayed one or more behavioral red flags that are often associated with fraudulent conduct. – Living beyond their means (36%) – Experiencing financial difficulties (27%) – Unusually close association with vendors or customers (19%) – Excessive control issues (18%) Part I: The Fraud * Page 8
  • 9. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED) • Perpetrators with higher levels of authority tend to cause much larger losses. The median loss among frauds committed by owners / executives was $573,000, the median loss caused by managers was $180,000, and the median loss caused by employees was $60,000 • The longer a perpetrator has worked for an organization, the higher fraud losses tend to be. Perpetrators with more than 10 years of experience at the victim organization caused a median loss of $229,000. By comparison, the median loss caused by perpetrators who committed fraud in their first year on the job was only $25,000 • 77% of all frauds in the study were committed by individuals working in one of six departments: accounting, operations, sales, executive / upper management, customer service, and publishing • Nearly half of victim organizations do not recover any losses that they suffer due to fraud. 49% of victims had not recovered any of the perpetrator’s takings; this finding is consistent with previous research, which indicates that 40-50% of victim organizations do not recover any of their fraud-related losses Part I: The Fraud * Page 9
  • 10. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED) • Not-for-profit organizations made up the smallest portion of the ACFE’s dataset, accounting for more slightly more than 10% of reported cases Part I: The Fraud * Page 10
  • 11. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED) Part I: The Fraud * Page 11
  • 12. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED) • Small organizations (those with fewer than 100 employees) continue to be the most common victims in fraud Part I: The Fraud * Page 12
  • 13. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED) Part I: The Fraud * Page 13
  • 14. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED) Part I: The Fraud * Page 14
  • 15. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED) Part I: The Fraud * Page 15
  • 16. WHAT YOU NEED TO KNOW ABOUT FRAUD CONCLUSIONS AND RECOMMENDATIONS • Occupational fraud is a global problem • Fraud reporting mechanisms (hotlines) are a critical component of an effective fraud prevention and detection system • Organizations tend to over-rely on audits • Employee education is the foundation of preventing and detecting fraud • Surprise audits are an effective, yet underutilized tool • Small businesses are particularly vulnerable to fraud • Internal controls alone are insufficient to fully prevent fraud • Fraudsters exhibit behavioral warning signs of their misdeeds • Effective fraud prevention measures are critical Part I: The Fraud * Page 16
  • 17. WHAT YOU NEED TO KNOW ABOUT FRAUD JP SIMS CONSULTING – CASES REPORTED IN LAST SIX MONTHS IN THE NONPROFIT SECTOR • “Brooklyn Woman Sentenced in Manhattan Federal Court to Two Years in Prison for Participating in $57.3 Million Fraud on Organization that Makes Reparations to Victims of Nazi Persecution” • “Former President and Executive Director of Vanguard Public Foundation Sentenced to 40 Months in Prison for Fraud and Money Laundering” • “Monroeton Woman Sentenced for Embezzling Money from Martha Lloyd Community Services” • “A.G. Schneiderman Announces $2.3 Million Settlement with St. Luke’s-Roosevelt Hospital for Overbilling Medicaid and Medicare” • “Miami-Area Therapist Sentenced to Prison in Florida in $205 Million Community Mental Health Fraud Scheme” www.jpsimsconsulting.com Part I: The Fraud * Page 17
  • 18. WHAT YOU NEED TO KNOW ABOUT FRAUD NONPROFIT FRAUD • Why nonprofits face a disproportionate level of fraud: – Lack of internal controls / segregation of duties – Lack of tone at the top / oversight – “volunteers” vs. “the store owner – Lack of hiring – due diligence – Lack of anti-fraud programs – Too much reliance on audits to catch fraud – More “mission” driven versus “profit” driven – Greater culture of “trust” Part I: The Fraud * Page 18
  • 19. WHAT YOU NEED TO KNOW ABOUT FRAUD THE SIZE OF THE NONPROFIT SECTOR2 • 1,551,705 tax-exempt organizations composed of: – 963,255 public charities – 97,941 private foundations – 490,509 other types of organizations (e.g., chambers of commerce, fraternal organizations, and civic leagues) • Nonprofits’ share of the U.S. GDP was 5.5% in 2012 • In 2010 (the most recent date in which these figures were aggregated), public charities accounted for: – $1.51 trillion in revenue • Of the revenue, 22% came from contributions, gifts, and government grants; 73% came from program services revenues, which include government fees and contracts; and 5% came from “other” sources, including dues, rental income, special event income, and gains or losses from goods sold • In 2011(the most recent date in which these figures were aggregated), private charitable contributions, which include giving to public charities and religious congregations, totalled $298.4 billion 2 National Center for Charitable Statistics, “Quick Facts about Nonprofits,” http://nccs.urban.org/statistics/quickfacts.cfm. Part I: The Fraud * Page 19
  • 20. WHAT YOU NEED TO KNOW ABOUT FRAUD THE MOST IMPORTANT POINTS YOU WILL TAKE AWAY FROM THIS SEMINAR SERIES • Design your systems and procedures so you do not have to rely on trust as a control! • Any person is capable of committing fraud! • TRUST IS NOT AN INTERNAL CONTROL! Part I: The Fraud * Page 20
  • 21. FAMOUS QUOTES “Trust, but verify.” • 40th President of the United States Ronald W. Reagan (1911-2004) “Verify, then verify some more.” • Senior Partner, Raffa, P.C., Lawrence J. Hoffman, CPA/CFF, CVA, CFE (1954-?) Part I: The Fraud * Page 21
  • 22. MY BOOK! EXPECTED RELEASE THIS FALL! STAY TUNED! Part I: The Fraud * Page 22
  • 23. WHAT YOU NEED TO KNOW ABOUT FRAUD THE FIVE MOST IMPORTANT TAKEAWAYS 1. Trust is not an internal control! – Establish, to the extent possible, controls and procedures that eliminate the element of trust – Always segregate the custody of the asset with the recordkeeping for the asset 2. Set the tone from the top! – “If you are stealing, your employees are stealing!” – E.g., office supplies, expense reports, etc. 3. Know your employees! – Background investigations and public records checks before hiring – Meet and establish a baseline relationship 4. Institute a fraud policy – No tolerance – Will prosecute 5. Establish a hotline for tips – Number one method for detecting fraud! – Can outsource Part I: The Fraud * Page 23
  • 24. TYPES OF FRAUD THREE BROAD CATEGORIES OF FRAUD • Fraudulent statements • Corruption • Misappropriation of assets Part I: The Fraud * Page 24
  • 25. TYPES OF FRAUD Part I: The Fraud * Page 25
  • 26. TYPES OF FRAUD FRAUDULENT STATEMENTS • Fraudulent financial reporting (“cooking the books”). Intentional misstatement or omissions of amounts or disclosers in financial statements designed to deceive financial users when the effect causes the financial statements not to be presented , in all material respects, in conformity with GAAP – Examples: • Falsification of accounting records • Omissions of transactions or disclosers • Non-Financial – Employment credentials – Internal and external documents Part I: The Fraud * Page 26
  • 27. TYPES OF FRAUD CORRUPTION • Schemes that involve the employee’s use of his or her influence in business transactions in a way that violates their duty to the employer and obtains benefit for themselves or others: – Conflicts of interest – Bribery – Illegal gratuities – Economic extortion Part I: The Fraud * Page 27
  • 28. TYPES OF FRAUD MISAPPROPRIATION OF ASSETS • The theft of an entity’s assets where the effect of the theft causes the financial statements not to be presented in conformity with GAAP (sometimes referred to as “defalcation”) • Misappropriation of assets can be accomplished in various ways, including: – Embezzling – Stealing assets – Causing an entity to pay for goods or services that have not been received or causing an entity to overpay for goods or services actually received Part I: The Fraud * Page 28
  • 29. TYPES OF FRAUD MISAPPROPRIATION OF ASSETS • Revenue and cash receipts (collections) schemes: – Cash skimming / unrecorded sales / contributions – Cash larceny – Lapping schemes – Write-off of accounts receivable – Unauthorized credits – Check tampering (stolen, altered) Part I: The Fraud * Page 29
  • 30. TYPES OF FRAUD PURCHASING AND CASH DISBURSEMENT SCHEMES • Fictitious invoices and vendors (shell company) • Check tampering – Forged maker (check signer) – Forged endorsement – Altered payee • Bank wire transfers Part I: The Fraud * Page 30
  • 31. TYPES OF FRAUD PAYROLL AND EMPLOYEE EXPENSE REPORTING SCHEMES • Payroll schemes – Ghost employees – Falsified hours and wages – Overtime abuses • Expense reimbursement schemes – Mischaracterized expenses – Overstated expenses (altered receipts) – Fictitious expenses (bogus receipts) – Multiple reimbursements Part I: The Fraud * Page 31
  • 32. TYPES OF FRAUD NONCASH ASSET MISAPPROPRIATIONS • Misuse of assets for personal use • Inventory Part I: The Fraud * Page 32
  • 33. CASE STUDY # 1 The Washington Post, Wednesday, June 3, 2009. Part I: The Fraud * Page 33
  • 34. CASE STUDY # 1 WHAT WENT WRONG? • Position of perpetrator: Controller • Length of time employed: 3 years, 11 months • Length of time fraud lasted: 3 years, 6 months • Schemes involved in fraud: – Fraudulent checks and wire transfers – Used electronic signatures and signature stamps – Falsified accounting of transactions in books and records – Provided forged documents, including bank statements, to independent auditors • How was the fraud discovered?: Executive Director found checks written to perpetrator and an unknown bank account statement in his office after he was terminated for poor performance Part I: The Fraud * Page 34
  • 35. CASE STUDY # 1 HOW MUCH DID IT COST? • Organization’s annual budget: $2.7 million • Total fraud loss to the organization: $425,558 (fidelity bond was only $30,000 with $5,000 deduction) • Other losses to the organization: Disruption to operations and legal and forensic consulting fees • Where did all the money go?: New 2006 BMW 325i car, furniture, vacations • What happened to the perpetrator?: – Criminal prosecution – Conviction – 41 months in Allenwood, a low-security correctional institution in White Deer, PA – Ordered to pay restitution of $470,990.59 Part I: The Fraud * Page 35
  • 36. CASE STUDY # 1 LESSONS LEARNED • Lack of segregation of duties – a “one-man show”! – Segregate the custody of the asset with the recordkeeping! • Lack of oversight controls and financial reviews, including review of financial statements, reconciliations • Use of signature stamp • Inadequate fidelity bond coverage • Too much trust and not enough verification! Part I: The Fraud * Page 36
  • 37. CASE STUDY # 2 ORGANIZATION CURRENTLY UNDISCLOSED Part I: The Fraud * Page 37
  • 38. CASE STUDY # 2 WHAT WENT WRONG? • Position of perpetrator: Director of Information Technology • Length of time employed: 7 years, 7 months – voluntarily left employment and left country • Length of time fraud lasted: 7 years, 5 months • Schemes involved in fraud: – Billing scheme – shell company – billed for IT equipment that was never received by the organization • How was the fraud discovered?: – Whistleblower – person who replaced perpetrator notices discrepancies and anomalies in past IT inventory and procedures Part I: The Fraud * Page 38
  • 39. CASE STUDY # 2 HOW MUCH DID IT COST? • Total fraud loss to the organization: $3.5 million ($1.3 million recovered from insurance) • Other losses to the organization: Disruption to operations and forensic consulting fees • Where did all the money go?: Amusement park in foreign country • What happened to the perpetrator?: Fled the country Part I: The Fraud * Page 39
  • 40. CASE STUDY # 2 LESSONS LEARNED • Lack of internal controls / segregation of duties – No separation of custody of asset with recordkeeping • Lack of a packing and receiving reports match • One person controlled the procurement, receipt, and deployment of the assets • Lack of inventory controls – “The wolf watching over the hen house” • Too much trust and not enough verification! Part I: The Fraud * Page 40
  • 41. MORE CASE STUDIES The Washington Post, May 31, 1997. Part I: The Fraud * Page 41
  • 42. MORE CASE STUDIES The Washington Post, August 17, 2011. Part I: The Fraud * Page 42
  • 43. MORE CASE STUDIES The Blog of Legal Times, September 26, 2013. Part I: The Fraud * Page 43
  • 44. MORE CASE STUDIES The Washington Post, May1, 2010. Part I: The Fraud * Page 44
  • 45. MORE CASE STUDIES The Associated Press, January 14, 2013. Part I: The Fraud * Page 45
  • 46. MORE CASE STUDIES The National Law Journal, January 14, 2013. Part I: The Fraud * Page 46
  • 47. MORE CASE STUDIES The Associated Press, September 24, 2008 Part I: The Fraud * Page 47
  • 48. MORE CASE STUDIES The Washington Examiner, July 1, 2010. Part I: The Fraud * Page 48
  • 49. MORE CASE STUDIES Part I: The Fraud * Page 49
  • 50. WHAT YOU NEED TO KNOW ABOUT FRAUD THE FIVE MOST IMPORTANT TAKEAWAYS – AGAIN! 1. Trust is not an internal control! – Establish, to the extent possible, controls and procedures that eliminate the element of trust – Always segregate the custody of the asset with the recordkeeping for the asset 2. Set the tone from the top! – “If you are stealing, your employees are stealing!” – E.g., office supplies, expense reports, etc. 3. Know your employees! – Background investigations and public records checks before hiring – Meet and establish a baseline relationship 4. Institute a fraud policy – No tolerance – Will prosecute 5. Establish a hotline for tips – Number one method for detecting fraud! – Can outsource Part I: The Fraud * Page 50
  • 51. HOW CAN RAFFA ASSIST YOU IN PREVENTING AND DETECTING FRAUD? FORENSIC CONSULTING SERVICES • Pre-hire investigations and background checks • Fraud risk assessment • Internal control / program review • Fraud awareness training • Fraud prevention programs and policies implementation • Due diligence investigations • Fraud investigations Part I: The Fraud * Page 51
  • 52. SOME AREAS WE WILL BE GOING OVER IN OUR FINAL PRESENTATION PART II: THE DETECTION – MAY 7, 2013, 12:00-2:00 P.M. • Who are these people that commit fraud? • Why do they commit fraud? • How are most frauds really detected? • Specific things you should have in place to help detect fraud • What should you do when you uncover fraud? PART III: THE PREVENTION – JUNE 5, 2013, 12:00-2:00 P.M. • What are the primary factors contributing to fraud in nonprofits? • Detective versus preventative measures and controls • The best preventative controls and practices • The critical takeaways and how to implement them Part I: The Fraud * Page 52
  • 53. RESOURCES AND SUGGESTED READING • 2012 Report to the Nations on Occupational Fraud and Abuse, Association of Certified Fraud Examiners, http://www.acfe.com/rttn.aspx • “The American Fraud Report,” www.jpsimsconsulting.com • The CPA’s Handbook of Fraud and Commercial Crime Prevention, AICPA • Managing the Business Risk of Fraud: A Practical Guide; AICPA, ITA, and ACFE; https://na.theiia.org/standards- guidance/Public%20Documents/fraud%20paper.pdf Part I: The Fraud * Page 53
  • 54. QUESTIONS AND ANSWERS Part I: The Fraud * Page 54
  • 55. BIOGRAPHY • 35 years of consulting, audit, accounting and tax experience in the public and private sectors. • Started career with a Big-Four international accounting firm in Washington, DC. • Founded a regional certified public accounting and consulting firm in 1982 and grew it to LAWRENCE J. HOFFMAN, on of the Washington, DC’s largest firms in seven years. Merged his practice with Raffa CPA/CFF, CVA, CFE P.C. in 2008. • Managed and conducted audit and accounting engagements ranging from small privately held to large publicly held businesses in various industries, including multi-national businesses, nonprofit organizations, and governmental entities and agencies. • Performed economic and financial analysis, including projections and forecasts, in support of litigation and claims for lost earnings and profits, business interruption, shareholder disputes, patent and trademark infringements, bankruptcy and restructuring, and structural settlements; assistance with interrogatories, document requests and depositions; and serving as an expert and consulting witness. • Performed and supervised business valuations for both public and closely held companies in a variety of industries, individuals and estates, family limited partnerships and limited liability companies, including valuations for business combinations (SFAS 141R), mergers, SENIOR PARTNER acquisitions, and divestitures, estate and gift taxes, marital dissolution proceedings, buy- RAFFA, P.C. sell agreements, intangible assets and intellectual property, purchase price allocations, 1899 L STREET, NW goodwill (SFAS 142) and long-lived asset (SFAS 144) impairment, fair value accounting WASHINGTON, DC 20036 (SFAS 157), cheap stock (IRC 409A), stock-based compensation (SFAS 123R), phantom stock and employee stock ownership plans. TEL. 202-822-5408 FAX 202-822-0669 • Conducted and led teams of forensic accountants on fraud audits and investigations, LHOFFMAN@RAFFA.COM including fraudulent financial statements, misappropriations of assets and embezzlements; money laundering, kickbacks, bribery and conflicts of interest; insurance claims; bankruptcy; financial institutions and loan fraud. Also has conducted fraud risk assessments, anti-fraud programs, and fraud training and education. Part I: The Fraud * Page 55
  • 56. BIOGRAPHY • Assisted companies and nonprofits with restructuring and turnaround situations, including recapitalizations, reorganizations and liquidations. Advised entities on Chapters 11 and 7, bankruptcy filings and proceedings and non-judicial workouts. Developed and administered crisis management plans, cash flows, liquidation and turnaround analysis, debt restructuring and creditor negotiations, and turnaround plans. LAWRENCE J. HOFFMAN, CPA/CFF, CVA, CFE • Formulated strategic short- and long-term business and financial planning for various business organizations and served as interim “C” level positions, including for a major North American sports league, European and U.S. aircraft manufacturer, aviation charter airline and travel company, and a multi-chain quick service food chain. • Formulated syndication strategies and prepared business plans and private placement offerings, including financial forecasts, market research and analysis, due diligence, securities pricing and structuring for various public and private securities offerings, including SEC filing. • Founded and developed a regional NASD licensed broker dealer investment banking firm. Placed over $150 million in debt and equity and represented over $200 million in merger and acquisition transactions. • Founded and developed two private equity funds in excess of $10 million, including SENIOR PARTNER investments in early stage and mature emerging companies in the form of debt and equity. Portfolio investments included aviation, food and hospitality, software and technology, telecommunications, sports and entertainment, banking and financial institutions, healthcare, and wholesale and retail. • Co-founded and managed various real estate acquisition, ownership, and operating entities, including commercial office buildings, shopping centers, flex warehouses, residential housing and developed land. • Performed tax and financial consulting services for individuals and closely held businesses. • Instructor in audit, accounting, finance, and forensic accounting. Part I: The Fraud * Page 56
  • 57. BIOGRAPHY EDUCATION & CERTIFICATIONS • Bachelor of Science, Accounting – Mount St. Mary’s University • Certified Public Accountant (CPA) LAWRENCE J. HOFFMAN, • Certified Fraud Examiner (CFE) CPA/CFF, CVA, CFE • Certified in Financial Forensics (CFF) • Certified Valuation Analyst (CVA) • Private Investigator (PI), Virginia • Series 7 General Securities Representative (not active) • Series 24 General Securities Principal (not active) • Series 63 Uniform Securities Agent (not active) PROFESSIONAL ASSOCIATIONS & AFFILIATIONS • American Institute of Certified Public Accountants, Member • Virginia Society of Certified Public Accountants • Association of Certified Fraud Examiners SENIOR PARTNER • National Association of Certified Valuation Analysts • Institute of Business Appraisers PERSONAL INTERESTS • Private pilot with instrument, multi-engine, high performance complex and aircraft ratings • Golf and fishing • Reading and politics Part I: The Fraud * Page 57