Fiscal Control Policy
ARTICLE I - PURPOSE
1. Purpose. The purpose of this Fiscal Control Policy ("Policy") is to ensure that Wikimedia District of Columbia ("Wikimedia DC") conducts financial affairs in a manner consistent with applicable laws and best practices for nonprofit organizations.
ARTICLE II - BUDGETING
1. Drafting and Initial Approval. No later than the last day of each fiscal year, the Board of Directors ("Board") shall review and approve an Annual Budget for the next fiscal year, and shall recommend it for approval by the members of Wikimedia DC.
2. Budgetary Gaps. In the event that a new fiscal year begins and no Annual Budget has been approved by the members of Wikimedia DC, spending shall continue at the levels authorized by the Annual Budget for the prior fiscal year. Best efforts shall be made to reconcile such expenditures with the Annual Budget for the new fiscal year once one is approved.
ARTICLE III – FUNDS
1. Bank Accounts. Wikimedia DC shall maintain a checking account at Wells Fargo Bank, constituting the general treasury of Wikimedia DC. The President and the Treasurer may open or cause to be opened such additional accounts as may be necessary to comply with any grant agreement into which Wikimedia DC may enter, provided that any such accounts are reported to the Board. All bank accounts shall be held in the name of Wikimedia DC, shall use Wikimedia DC's Employer Identification Number, and shall list only the President and the Treasurer as account signers.
2. Payment Instruments. The President and the Treasurer shall each be granted a debit card and access to Wikimedia DC's online banking and merchant services. The Treasurer shall additionally receive access to Wikimedia DC's check stock. The President and the Treasurer shall keep payment instruments secure and prevent their misuse. Cash or other payment instruments shall not be used without the prior authorization of the Board.
3. Cash. Precise records shall be kept of any cash received or disbursed in the course of operations. Cash received shall be promptly deposited into Wikimedia DC's bank account.
ARTICLE IV - EXPENDITURES AND DISBURSEMENTS
1. Authorization of Expenditures. Expenditures shall only be authorized through a resolution of the Board, or by the President pursuant to the Delegation of Authority Policy. When determining whether to authorize a proposed expenditure, the person or persons responsible for authorizing it shall consider whether it is reasonable and whether it is consistent with the Charitable Purpose as defined in Article II of the Bylaws.
2. Disbursement of Funds. Following the authorization of an expenditure, disbursement of funds shall take place through one of the following methods:
- (a) Small Disbursements. The President may make disbursements of sums under $250 without the prior approval of the Treasurer, provided that such expenditures are authorized by the Annual Budget. All disbursements made directly by the President shall be reported promptly to the Treasurer with appropriate documentation.
- (b) Disbursement by Treasurer. For disbursements of $250 or greater, the Treasurer shall carry out the disbursement, provide written or oral authorization to the President to carry out the disbursement, or object to the disbursement within seven business days of an expenditure having been authorized. The Treasurer may object to a disbursement if it would constitute an improper use of funds or would jeopardize the financial well-being of Wikimedia DC; review of disbursements in accordance with these criteria shall satisfy the Treasurer's duty of due diligence.
- (c) Disbursement in the Absence of the Treasurer. Should the Treasurer fail to take any action on a requested disbursement within seven business days of the request, the President shall be authorized to make the disbursement at their own discretion. All disbursements made pursuant to this provision shall be promptly reported to the Board with appropriate documentation, and the Treasurer shall be notified that such action was taken. If the Treasurer anticipates that they will be unavailable to render decisions regarding disbursements for an extended period of time, they is expected to inform the Board of such absence and to allow for the appointment of a temporary replacement by the Board.
3. Receipts. Receipts shall be collected and retained for any expenditure of $5 or more. All receipts must include the name of the vendor, the location, the date, and the dollar amount. Acceptable forms of receipts shall be original receipts completed by vendors and copies of credit or debit card slips; credit or debit card billing statements shall only be acceptable when used for requesting expense reimbursement under Article V of this Policy. Should a receipt not be available, the person responsible for the expenditure shall provide a full explanation of the expenditure and an explanation as to why the receipt is unavailable.
4. Payroll. The Treasurer, or their designee, shall maintain a payroll for any persons employed by Wikimedia DC, and shall withhold taxes from said payroll as required by law. Payments to employees shall be disbursed on a bi-weekly basis.
ARTICLE V – EXPENSE REIMBURSEMENT
1. Reimbursement. Wikimedia DC shall reimburse expenses incurred by individuals or organizations other than Wikimedia DC in the course of conducting official Wikimedia DC business, provided that such expenses comply with all requirements set forth by this Policy. No claimed expense shall be reimbursed unless and until it has been approved by Wikimedia DC.
2. Unallowed Expenses. The following expenses shall not be approved:
- (a) Any expense incurred in the course of carrying out any activity not permitted to be carried on by a corporation exempt from federal income tax under Section 501(c)(3) of the Internal Revenue Code; or not permitted to be carried on by a corporation, contributions to which are deductible under Sections 170(c)(2), 2055(a)(2) and 2522(a)(2) of the Internal Revenue Code.
- (b) Any expense claimed on the basis of a transaction in which the person claiming or approving said expense has a financial interest, as defined in the Conflict of Interest Policy.
3. Authority. Any person or persons authorized to make expenditures under this Policy shall have authority to approve expense claims. The claim must be approved by a different person from the one submitting it. In the event of a claim by the President, the Treasurer shall have the authority to approve the claim.
4. Submission of Claims. All claims for reimbursement of expenses shall be submitted to the President no later than thirty (30) calendar days following the date on which the associated expense was incurred. In the event that reimbursement for multiple expenses is requested in one submission, the deadline shall be calculated based on the earliest of the included expenses.
5. Form of Claim. An expense claim shall consist of a completed expense claim form or grant report form, together with such supporting documentation as necessary to verify the claimed expenses. Expense claims shall be submitted in writing. The President may, at their discretion, accept an electronic copy of of an expense claim in lieu of a physical copy, in which case such electronic copy shall be considered equivalent to the corresponding physical copy.
6. Incomplete Claims. All expense claims shall include all the details necessary to process the reimbursement and to comply with this Policy. Any expense claim that is incorrect, incomplete, or lacks acceptable supporting documentation shall be rejected and returned to the person submitting such claim, who may resubmit it.
7. Processed Claims. If a claim for reimbursement is approved, reimbursement shall be issued within thirty (30) calendar days of approval. If a claim for reimbursement is not approved, the President shall return the claim to the person submitting it, together with an explanation for why approval was not granted, within thirty (30) calendar days of submission.
ARTICLE VI - DONATIONS
1. Processing Receipts. The Treasurer shall be responsible for receiving cash and other payments, for depositing payments into the appropriate bank account, and for providing receipts for donations. Officers other than the Treasurer who receive payments on behalf of Wikimedia DC shall remit such payments to the Treasurer for processing.
2. Recognition of Donations. For donations in the amount of $25 or greater, the Treasurer shall prepare a letter acknowledging the donation as well as any restrictions or conditions placed on the donation. The letter may be sent electronically, at the discretion of the Treasurer.
3. Restrictions. Any restrictions or conditions placed on a donation shall be noted in Wikimedia DC's financial records. In the event that Wikimedia DC cannot adhere to a stipulated restriction, the donation shall be returned. In the event the donor's intent is unclear or communicated orally, the Treasurer shall request written confirmation regarding the donor's intent. The nature of the restriction, including its being lifted altogether, shall be altered only with the written permission of the donor.
4. Solicitations. All solicitation documents shall accurately report the 501(c)(3) status of Wikimedia DC. Should a specific program of Wikimedia DC be mentioned in such solicitations, donations resulting from these solicitations shall be restricted toward the use of the mentioned program unless the donor agrees to waive such restriction or if the solicitation includes an explicit disclaimer that donations will not be restricted.
ARTICLE VII - ACCOUNTING
1. Accounting Standards. The Treasurer shall maintain financial records that enable the preparation of financial statements which are consistent with United States Generally Accepted Accounting Principles (US GAAP) sections FAS 116 ("Accounting for Contributions Received and Contributions Made") and FAS 117 ("Financial Statements of Nonprofit Organizations").
2. Chart of Accounts. The Treasurer shall maintain a chart of accounts consistent with the line items designated in the Annual Budget.
3. Accrual Basis. The Treasurer shall recognize revenues upon their being pledged, regardless of the timing of the receipt of cash. The Treasurer shall recognize expenses upon their being incurred, regardless of the timing of the expenditure of cash. Invoices and similar documents shall be sufficient to demonstrate the accrual of revenues and expenses under this Policy.
4. Asset Register. The Treasurer shall keep a register of all valuable property owned by Wikimedia DC.
5. Reporting. The Treasurer shall provide up-to-date financial statements, including at minimum a statement of income and expenses and a current balance sheet, to the Executive Committee no later than seven days prior to each regular meeting of the Board.
6. Capital Depreciation. At the end of each fiscal year, the Treasurer shall calculate depreciation for Wikimedia DC's fixed assets. Depreciation for a fixed asset shall accrue over a five-year period and shall be calculated using the straight-line depreciation method unless the Treasurer determines in their discretion that an alternative period or calculation method is appropriate for a specific asset or category of assets. All depreciation calculations shall be documented in the Annual Financial Report of Wikimedia DC.
7. Closing of Books. The Treasurer shall close Wikimedia DC's books on the last day of each fiscal year, and shall report the revenue and expenses for the fiscal year to to Board within 30 days thereof.
8. Documentation. The Treasurer shall be responsible for retaining and storing financial records in accordance with the Record Retention Policy, and shall make such records accessible to the Board and to the Audit Committee as necessary.
9. External Accounting Services. The Treasurer may delegate tasks to an external accounting service retained by Wikimedia DC, provided that such delegation shall not relieve the Treasurer of their duty of care.
ARTICLE VIII - AUDIT
1. Audit Committee. The Audit Committee shall be a standing committee of at least three Directors, which shall conduct an annual review of the financial records of Wikimedia DC in accordance with Article VIII, Paragraph 2 of the Bylaws, and which shall carry out such other tasks as may be assigned to it by the Board of Directors.
2. Insubstantial Part Analysis. The Audit Committee shall conduct an annual analysis to verify that no substantial part of Wikimedia DC's activities is dedicated to advocating for or against legislation, in accordance with Section 501(h) of the Internal Revenue Code. The Audit Committee shall report the results of this analysis as part of its report regarding the annual review of Wikimedia DC's financial records, or in such other place as the committee may determine in its discretion.
3. Investigations. The Audit Committee shall investigate reports of illegal activity or improper accounting practices as described in the Whistleblower Policy, and reports of certain violations of the Non-Discrimination Policy described in that Policy. The Audit Committee is authorized to retain legal counsel to address a complaint if it involves the President or the Vice President.