Financial Management & Controls

No decision has been made yet — this document exists to force one before any money moves. CPD requires a PAC that solicits or receives funds to hold either its own qualifying federal tax-exempt status or use an approved third-party fiscal sponsor. Two real paths, with real tradeoffs:

Path A — Own 501(c)(3). File IRS Form 1023-EZ (if eligible; roughly $275 filing fee, weeks-to-months processing) or the full Form 1023 (higher fee, longer review, needed if projected revenue or complexity exceeds 1023-EZ thresholds) after Illinois incorporation and EIN (Phase 1). Gives the Council full control over its own funds, its own bank account, and its own annual Form 990 filing obligation — but requires sustained compliance capacity (a Treasurer willing to own annual filings) and a delay between incorporation and actually being able to accept tax-deductible gifts.

Path B — Fiscal Sponsorship. A qualified 501(c)(3) holds funds on the Council's behalf under a written agreement (4-02), typically charging a fee (often 5–10% of funds processed) in exchange for immediate tax-deductible giving capacity, its own accounting/990 filing, and reduced Council-side administrative burden — at the cost of the sponsor retaining legal control over the funds and some approval authority over spending. CPD's own current PAC Guidelines name a concrete example of what it considers acceptable here: "the Chicago Parks Foundation, or another organization offering fiscal sponsorship services."

Decision criteria the Board should actually weigh, not just the two paths in the abstract: (1) Capacity — does the Council have, or can it realistically recruit, a Treasurer willing to own annual 990 filings and IRS correspondence indefinitely, or would that responsibility be more reliably absorbed by a sponsor's back office in year one while the Council is still finding its footing? (2) Timeline — Path A's exemption-application lag (weeks for 1023-EZ, months for full 1023) means any near-term fundraising or grant application effectively requires Path B first, even if Path A is the eventual destination. (3) Control — Path B means real donor funds sit outside the Council's direct signatory authority (Article 17) until the sponsor releases them; the Fiscal Sponsorship Agreement (4-02) is where that tension gets negotiated, not assumed away. (4) Reversibility — a Council that starts under Path B is not locked in; converting to Path A later (once capacity and a filing history exist) is a normal, common transition, and this memo should be revisited whenever circumstances materially change, not just once at formation.

This memo is where the Board records which path it selects, why, and when, along with the vote and date — and until it's completed, the Council should not represent to any donor, sponsor, or grantor that either path is settled, and should not accept funds through either path until the corresponding downstream documents (4-02 for Path B; 4-03/4-04 for Path A) are actually in place.

Triggered only if 4-01 selects Path B. A real fiscal sponsorship agreement — not a handshake — needs to specify, in writing, before any solicitation begins under this structure:

Ownership and control. Who legally owns and controls the funds while held (ordinarily the sponsor, until disbursed to the Council) — this matters because it means the Council's own Financial Policies Manual (4-10) governs the Council's spending of released funds, but the sponsor's own controls govern the funds while they're still in the sponsor's custody.

Fees. The sponsor's fee structure (commonly 5–10% of funds processed) and exactly when and how it's deducted — before or after restricted-purpose accounting, a distinction that affects how much of a restricted gift actually reaches its stated purpose.

Restricted gifts. How the sponsor tracks and honors donor restrictions the Council has accepted (4-30), and what happens if the sponsor's own records and the Council's Restricted Funds Ledger (4-46) ever disagree.

Disbursement approval. What expenditures the sponsor will and won't pre-approve, the sponsor's turnaround time for releasing funds, and any expense categories the sponsor won't fund at all.

Reporting. The sponsor's own reporting to the Council — statements at minimum monthly, reconciled against the Council's own records.

Termination. A clear clause describing what happens to any remaining funds, especially restricted funds, if the sponsorship relationship ends — including the scenario where the Council later transitions to Path A (its own 501(c)(3)) and needs the remaining balance transferred cleanly.

Executed by an authorized Council officer (per the Contract Review & Signature Authority Policy, Phase 5) and the sponsor's authorized representative.

Selecting a sponsor. The Board evaluates at least one, ideally more, candidate fiscal sponsors before committing — comparing fee structure, disbursement turnaround, and any prior track record with similarly sized community organizations — rather than defaulting to the first organization that offers. A sponsor named as an acceptable example in CPD's own current PAC Guidelines (such as the Chicago Parks Foundation) is a reasonable starting point for outreach, not an automatic selection that skips this comparison.

If the relationship breaks down. A disagreement over a specific disbursement, a restricted-fund discrepancy, or a fee dispute is first raised in writing to the sponsor's program contact, with the Treasurer and President both informed; if it isn't resolved at that level within a reasonable time, the Board decides whether to escalate, renegotiate the agreement's terms, or invoke the termination clause. The Council does not simply stop routing funds through an active sponsorship mid-dispute without a documented Board decision to do so, since donors' funds are involved.

Liability during sponsorship. A fiscal sponsorship does not transfer responsibility for the Council's own program conduct, volunteer supervision, or event safety to the sponsor — those remain governed entirely by this Council's own policies (Phase 5, Phase 6, Phase 8). The sponsorship agreement should say so explicitly, so neither side later assumes the other was responsible for something it wasn't.

Only relevant if 4-01 selects Path A. This file holds the completed application, all supporting narrative (mission, programs, projected budget for the next three years), the EIN confirmation (1-26), the filed Illinois Articles (1-23), and the Bylaws (2-02) as submitted. 1023-EZ eligibility itself has dollar and asset thresholds set by the IRS that should be re-verified at filing time — do not assume eligibility without checking the current instructions. Retained permanently once filed, alongside the eventual determination letter (4-04).

The single most important piece of paper this Council will ever receive if it takes Path A — the IRS's own written confirmation of 501(c)(3) status, the exemption "effective date," and the public-charity classification. Retained permanently (physical and digital copies), cited in every grant application and every donor's own tax documentation, and produced to CPD as evidence of the fiscal structure decided in 4-01.

A single completed, signed IRS Form W-9 (legal name, EIN, tax classification) kept on hand and sent promptly to any grantor, sponsor, or vendor that requests one before issuing a check — a request the Council should expect from day one of receiving any outside funds, and one that's embarrassing to scramble for if it isn't already prepared.

A formal Board resolution — recorded in minutes, not just discussed — authorizing the opening of a Council bank account, naming the institution, and naming which officers may be authorized signers (per Bylaws Article 17, no single officer should be a sole signer on disbursements above the Expense Approval Threshold Matrix's lowest tier, 4-21). Superseded and re-adopted any time signatories change, referencing the updated Authorized Signer Register (4-08).

The complete packet actually taken to the bank: EIN confirmation (1-26), filed Illinois Articles (1-23), the Banking Resolution (4-06), government ID for each proposed signer, and the account terms/disclosures the bank provides in return. Kept together so a future Treasurer inherits the full account history in one place rather than reconstructing it from memory.

Updated the same day an officer transition (Phase 3, 3-28) removes or adds bank authority — a departed officer who's still an active bank signatory is exactly the kind of control gap this register exists to prevent.

A starter structure, refined once real transaction volume exists:

Every account maps cleanly to a line on the Annual Operating Budget (4-12) so budget-to-actual comparisons (4-13) are meaningful rather than approximate.

The master reference that everything else in this phase implements piece by piece — the document a new Treasurer should read cover to cover before touching the checkbook. Core principle: segregation of duties — no single person should be able to both authorize and record a transaction unsupervised.

1. Receipts. All incoming funds — cash, check, or electronic — are logged the same day received in the Cash Receipts / Deposit Log (4-17) before deposit. Cash is always counted by two people (4-19), never by the person who will later deposit it alone. Checks are endorsed "for deposit only" immediately on receipt.

2. Disbursements. The Treasurer records transactions, but no disbursement above the lowest tier of the Expense Approval Threshold Matrix (4-21) is authorized by the Treasurer acting alone. Every payment requires a completed Disbursement / Payment Authorization Form (4-20) with supporting documentation attached before the check is cut or the card is used — not after.

3. Reconciliation. Bank statements are reconciled monthly against the General Ledger (4-15), and every reconciliation is reviewed and signed by someone other than the person who made the deposits or wrote the checks (4-16). An unreconciled month is a red flag on its own, regardless of whether anything else looks wrong.

4. Reporting. A Treasurer's Report (4-14) is presented at every regular meeting without exception, and a Budget-to-Actual comparison (4-13) at least monthly. Required financial records are available for public inspection consistent with Bylaws Article 17 and the Financial Records Public-Access Procedure (4-61).

5. Absolute prohibitions. No Council funds may be loaned to any person, officer or otherwise, under any circumstance. No officer may approve their own reimbursement or a disbursement to an entity in which they've disclosed a conflict (3-12) regardless of dollar amount. No account may operate with a single authorized signer.

6. Retention and fraud response. Financial records follow the Records Retention Schedule (Phase 5, 5-10) and, if fraud or misuse is ever suspected, the response defined in the Fraud Prevention & Response Policy (4-51) governs — not an informal, ad hoc conversation among officers.

This Manual is reviewed by the Finance Committee at least annually per the Policy Sunset / Periodic Review Schedule (Phase 6, 6-36) and amended through the Policy Adoption / Amendment Procedure (Phase 2, 2-38), not informally.

Sets the annual rhythm so budgeting is a predictable cycle, not a scramble every fall. Timeline: the Treasurer and Finance Committee prepare a draft budget at least two months before the new fiscal year begins, built from the prior year's Budget-to-Actual history (4-13) and the Annual Work Plan (Phase 10) — every program goal in the Work Plan should have a matching budget line, and every budget line should trace back to a Work Plan goal or a recurring compliance obligation (insurance, filings). The draft circulates to the full membership, not just the Board, for comment at a regular meeting, consistent with the public-access spirit of Bylaws Article 17, before final adoption at the threshold the Bylaws set for budget approval.

Amendments. A material change to an adopted budget line during the year — reallocating funds between programs, adding an unbudgeted expense — requires the same approval level as the original line item under the Expense Approval Threshold Matrix (4-21); it is not something the Treasurer adjusts unilaterally just because the money happens to be available.

Monitoring. The Treasurer reviews budget-to-actual variance at least monthly (4-13) and flags any line running materially over or under expectation at the next regular meeting, rather than waiting for year-end to discover it.

The actual approved dollar plan for the year, structured by the Chart of Accounts (4-09) and tied line-by-line to the Annual Work Plan (Phase 10) — a stewardship-day budget with no matching Chart of Accounts line, or a work-plan goal with no funding behind it, is exactly the mismatch this document is meant to surface before the year starts, not after.

A simple three-column report (Budgeted / Actual / Variance) by Chart of Accounts line, prepared monthly at minimum and presented at every regular meeting alongside the Treasurer's Report (4-14). A variance beyond a threshold the Finance Committee sets (e.g. 15% over on any expense line) triggers a one-line written explanation, not just a number — the point is early warning, not a retrospective audit finding.

Current CPD guidance expects a financial report at PAC meetings and expects the Council's financial records to be available for public review — this is that report, in standing form: current bank balance, month's receipts and disbursements in summary, budget-to-actual highlights (4-13), and any restricted-fund or grant-compliance notes. Attached to the minutes and retained in the PAC Binder (Phase 6) as the primary evidence CPD's requirement is being met continuously, not just at year-end.

The complete, continuous accounting record — every receipt and disbursement, dated, coded to the Chart of Accounts (4-09), with a running balance. Whether kept in dedicated nonprofit accounting software or a well-controlled spreadsheet, this is the single source of truth every other financial report in this phase (4-13, 4-14, 4-16) is drawn from, and the record Illinois corporate law and CPD's public-access expectation both ultimately point back to.

Every month, without exception, the bank statement is reconciled against the General Ledger (4-15) — and a second person (an officer other than the Treasurer, or, once one exists, the Finance Committee chair) reviews and signs off on the reconciliation. This second-set-of-eyes step is the single cheapest fraud/error control available and should never be skipped even in a "quiet" month with few transactions.

Every batch of cash or checks received is logged here before it's deposited, creating an unbroken chain from "money received" to "money in the bank" that the Monthly Bank Reconciliation (4-16) can be checked against.

Adopted before the first cash-handling event (a bake sale table, a beach cleanup donation jar, a merchandise table) — retrofitting cash controls after money has already changed hands defeats the purpose.

Before the event. The Event Lead designates a two-person cash team in advance; a single volunteer is never left solely responsible for a cash box, even briefly. Sequentially numbered receipts are prepared for any in-person sale over $10.

During the event. Cash is counted by the two-person team at the point of collection and again at any transfer between people (e.g., handing off a cash box between shifts) — every transfer is itself a count, not a handoff on trust.

After the event. A final count using the Cash Count Sheet (4-19) happens immediately, on site, not the next day from memory. Funds are deposited within 2 business days and are never held at an officer's home or vehicle longer than the time it takes to reach a bank or a secure drop.

Absolute rule. Council cash is never commingled with any individual's personal funds, even temporarily "for convenience," and is never used to make change from a personal wallet without an immediate, documented reimbursement the other direction.

Receipts and records. Any pre-printed or sequentially numbered receipt book used at a cash table is itself logged out to the event before use and logged back in afterward with the final receipt number recorded, so a missing receipt book — not just missing cash — is itself detectable. Cash-count sheets (4-19), deposit slips, and any receipt-book stubs are kept together as one event's cash-control file, not filed separately where they'd be hard to reconcile against each other later.

Training. No volunteer works a cash table for the first time without a brief walkthrough of this policy from the Event Lead or Treasurer beforehand — "figure it out at the table" is not an acceptable substitute for the two-person count and receipt-numbering habits this policy depends on.

If a discrepancy appears. A count that doesn't match the receipt total, however small, is noted on the Cash Count Sheet at the time it's discovered, not silently adjusted to make the numbers agree. A discrepancy that can't be explained by an obvious error (a miscount, a receipt not yet recorded) is escalated per the Fraud Prevention & Response Policy (4-51) rather than absorbed quietly into "close enough."

Completed on the spot, immediately after cash handling ends — not the next day from memory — and feeds directly into the Cash Receipts / Deposit Log (4-17).

Required for every non-routine expenditure before a check is cut or a card is used — "routine" is defined by the Expense Approval Threshold Matrix (4-21), below which a simpler process may apply.

Illustrative starting tiers, to be calibrated to real budget size once one exists:

No officer may approve their own reimbursement or a payment to an entity in which they've disclosed a conflict (3-12) regardless of amount.

Eligible expenses are those directly tied to an approved budget line or a specific Board-authorized activity — mileage to a stewardship workday, supplies for an approved event, printing for a required CPD posting. Personal meals, entertainment, and anything not connected to a specific Council purpose are not reimbursable absent a prior, specific Board exception.

Documentation. Every request requires an original itemized receipt (not a card statement line alone, which shows the charge but not what was purchased) and, where the Threshold Matrix (4-21) requires it, pre-approval before the expense is incurred rather than after.

Timing and approval. Reimbursement requests must be submitted within 60 days of the expense using the Expense Reimbursement Form (4-23); requests older than that are presumptively denied absent a documented exception. No officer may approve their own reimbursement — a second officer signs off every time, regardless of amount — and reimbursements are paid within 2 weeks of a complete, approved request.

Routine purchases under the lowest Expense Approval Threshold Matrix (4-21) tier proceed on ordinary judgment, supported by a receipt.

Competitive purchasing. Any purchase above that threshold requires at least two competitive quotes, documented and attached to the Purchase Request / Purchase Order Form (4-25), before a vendor is selected — the lowest quote isn't mandatory, but the reason a higher one was chosen (quality, timeline, prior reliability) should be recorded, not left to memory.

Sole-source exceptions. A single-quote purchase is permitted only with a documented justification: a specialty vendor with no reasonable substitute, a time-sensitive need where competitive bidding isn't practical, or a vendor already vetted and approved for recurring work. The justification is written down at the time, not reconstructed later if questioned.

Conflicts and CPD boundaries. Any purchase from a vendor tied to a disclosed conflict of interest (3-12) requires disinterested-officer approval regardless of amount. Purchases connected to CPD property or CPD-permitted events must stay within whatever CPD approval boundary the relevant event or capital process requires (Phase 8; Phase 4's capital-partnership documents, 4-56 through 4-60) — the Council cannot purchase or install anything on CPD property outside that process just because it has the funds to do so.

Preferred vendors. Where the Council repeatedly buys the same category of goods or services (event supplies, printing, insurance), the Finance Committee may maintain an informal preferred-vendor list built from past competitive quotes — this speeds routine purchasing without re-bidding every time, but the list itself is revisited at least annually so a vendor's pricing or reliability slipping doesn't go unnoticed simply because "we always use them."

Sustainability consideration. Where cost and quality are comparable, purchasing decisions give some weight to environmentally preferable options (recycled or biodegradable event supplies, energy-efficient equipment), consistent with the Environmental Sustainability Policy (Phase 7) — this is a soft preference, not a rule that overrides the competitive-purchasing process above.

Records. Purchase Request/Purchase Order Forms (4-25), quotes, and sole-source justifications are retained per the Records Retention Schedule (Phase 5, 5-10) so a future Finance Committee can see why a particular vendor was chosen, not just that one was.

Completed and approved before, not after, the purchase is made whenever the Purchasing Policy's threshold is triggered.

Default position: the Council does not issue cards until operating volume genuinely justifies one; the Disbursement / Payment Authorization Form (4-20) and check payments cover routine needs. If a card is later issued: it goes to a named individual officer (never a shared or anonymous card), with a Board-set spending limit and a defined list of permitted expense categories tied to the Chart of Accounts (4-09). Every charge is matched to an original receipt within 5 business days and reviewed monthly against the statement by someone other than the cardholder — typically the Treasurer if the card belongs to another officer, or a second officer if it belongs to the Treasurer. Cash advances are prohibited outright, and a card whose statement can't be reconciled to receipts for two consecutive months is suspended pending Board review.

Default position: no petty cash fund. Small purchases go through the Expense Reimbursement Form (4-23) instead. If the Finance Committee later determines an actual on-site cash fund is unavoidable (e.g. for a specific recurring event), any such fund is capped at an explicit dollar limit, held by a single named custodian, and reconciled after every use — never left as a standing, unreconciled float.

Accepted without special review: cash, checks, credit-card gifts, and standard in-kind items under $250 in estimated value that require no special handling, storage, or maintenance commitment.

Requires Finance Committee review before acceptance: securities or real property (valuation and liquidity concerns — the Council generally liquidates non-cash financial gifts promptly rather than holding them); gifts with unusual restrictions or strings attached beyond a simple purpose designation (routed to the Restricted Gift Policy, 4-30, for the acceptance decision itself); gifts from a source the Conflict of Interest process (3-12, Phase 5) flags as connected to an officer, director, or their immediate family; in-kind gifts requiring ongoing maintenance, storage, insurance, or a use commitment (screened jointly with the In-Kind Donation Policy, 4-31); and any gift where the donor's own conduct or reputation raises a concern the Board should weigh before accepting the Council's name being associated with it.

Not the Council's to accept at all: any gift genuinely intended for the park itself rather than for Council operations — a bench, a physical improvement, equipment for installation on CPD property — which routes through the Donation Acceptance Policy (4-29) and CPD's own Donation Acceptance Form process (4-55) instead, regardless of how the donor originally framed the offer.

Right to decline. The Board may decline any gift, without needing to state a reason to the donor, if acceptance would be inconsistent with the Council's mission, create an unacceptable liability, or conflict with this policy.

Valuation. A non-cash gift's estimated value for acceptance-review and acknowledgment purposes (4-33) is based on reasonable good-faith documentation — a stated retail value, a comparable-sale estimate, or, for anything material, the donor's own qualified appraisal where one exists. The Council does not appraise gifts itself and does not certify a donor's own tax-deduction value; the acknowledgment states what was received and when, and leaves valuation for the donor's own tax purposes to the donor and their advisor.

Who reviews. The Finance Committee handles routine review; anything reaching the Board-review triggers above (securities, real property, unusual restrictions, a conflict-flagged source) is decided by the full Board, with any officer connected to the gift recused per the Conflict of Interest Policy (Phase 5, 5-22). This policy itself is reviewed at least every two years, or sooner if a gift arrives that doesn't cleanly fit any existing category.

Draws a bright line every donor-facing volunteer needs to understand, because donors themselves rarely draw it correctly: a gift to the Council (funds its operating budget, programming, stewardship supplies) follows the Gift Acceptance Policy (4-28) and lands in the Council's own bank account. A gift intended for the park itself — a bench, a sign, a physical improvement, planting materials for installation — is not the Council's to accept unilaterally, no matter how small, because accepting it implies a commitment to install or maintain something on CPD property that only CPD can actually authorize.

Process for a park-directed gift: (1) the volunteer or officer who receives the offer does not accept on the Council's behalf; (2) the offer is brought to the Park Supervisor or Area Manager for a first read on whether CPD would even want the item; (3) if CPD is receptive, the Park Supervisor or Area Manager completes the actual Donation Acceptance Form (this is CPD's form, completed by CPD staff, not the Council); (4) the completed form and any related correspondence are filed in the CPD Donation Acceptance Form File (4-55); (5) only after CPD's acceptance is documented does the Council communicate a firm "yes" to the donor.

A well-meaning volunteer telling a donor "yes, we'd love that bench" before this process runs its course is the single most common way this line gets blurred — the Volunteer Handbook (Phase 6, 6-24) should flag this explicitly.

Timeline. The Park Supervisor/Area Manager conversation and CPD's own acceptance-form process do not run on a fixed Council-side deadline — CPD's own review pace controls, and the Council does not promise the donor a completion date it can't guarantee. If CPD's initial read is negative or the process stalls, the Council communicates honestly with the donor rather than letting the offer quietly go unanswered.

If CPD declines. A donor whose park-directed gift CPD does not accept is offered, with their consent, the option to redirect the gift to the Council's own general operations or a specific Council program instead (routed through the Gift Acceptance Policy, 4-28) — the gift is never simply kept and spent as if it had been a Council-directed gift all along without the donor's knowledge and agreement to that change in purpose.

A donor-imposed restriction (e.g. "for dune restoration only," "for the youth program") is only accepted if two things are both true: the Council can realistically deliver on it given its current or planned programming, and the restriction is mission-consistent and doesn't conflict with CPD approval requirements for the restricted purpose (a restriction earmarking funds for an unapproved capital project, for instance, isn't accepted until the underlying project itself has CPD approval).

Acceptance and tracking. Every accepted restriction is documented in a Donor Restriction Agreement (4-32) at the time of the gift and tracked as its own line in the Restricted Funds Ledger (4-46) from receipt through full expenditure — restricted funds are never treated as available for general operating use, even temporarily, even if the restricted program is running behind schedule.

If the purpose becomes impossible. Modifying or releasing a restriction after acceptance (because a program was discontinued, or CPD declined the underlying project) requires either the donor's written consent to redirect the funds, or, absent that, a documented Board finding — with counsel input given the legal doctrine involved (courts call this "cy pres") — before the funds are redirected to a related purpose. Funds are never simply absorbed into general operations because honoring the original restriction became inconvenient. In plain terms, cy pres lets a court (or, informally, a good-faith Board process modeled on it) redirect a gift to the closest related purpose still consistent with the donor's original intent, when the exact original purpose is no longer possible — it is not a license to redirect funds to whatever the Board currently finds convenient.

Annual review. Every open restriction in the Restricted Funds Ledger (4-46) is reviewed at least annually by the Finance Committee for two things: is the restricted program still active and on track to use the funds as intended, and is any restriction at risk of becoming impossible to honor (a discontinued program, a CPD-declined project) before it actually happens — catching this early gives more options than discovering it only once a donor or funder asks.

Screening questions before acceptance, in order: (1) Is the item actually useful to a current or clearly planned program — not just "might be useful someday"? (2) Can the Council realistically store, insure, and maintain it, tracked in the Asset Inventory (4-47) if kept? (3) Is it intended for the Council's own operational use, or for installation on CPD property? Question 3 is the critical fork: anything destined for the park itself — a donated bench, signage, planting materials, playground-adjacent equipment — requires the same CPD acceptance process as monetary park gifts (4-29, 4-55) before it is installed or even brought onto CPD property, regardless of who physically delivers it or how informally the offer was made.

Condition and liability. Donated equipment is inspected for safety before use, particularly anything used by volunteers or in youth programming; a donor's generosity does not substitute for a basic safety check, and the Council reserves the right to decline or dispose of an in-kind gift that fails one.

Storage capacity check. Before accepting any bulk or large in-kind gift (a pallet of supplies, furniture, a large piece of equipment), the accepting officer confirms an actual place to store it exists — accepting more than the Council can reasonably house or transport just because it was offered for free creates its own liability and clutter problem.

If declined or unusable. A gift that fails the safety check, or that the Council accepted but later finds it can't use, is disposed of responsibly (donated onward to another organization where appropriate, recycled, or discarded) rather than left to accumulate — and the original donor is told honestly what happened to their gift if they ask, rather than left with the impression it's still in active use.

Used for any gift material enough to carry real restrictions — not every $25 donation needs a signed letter, but any gift the Restricted Funds Ledger (4-46) will track does.

Standard thank-you/receipt language sent for every gift, including the tax-substantiation language a donor needs for their own filing once a fiscal structure (4-01) is in place: gift amount or description, date received, a statement of whether goods/services were provided in exchange (and if so, their value), and the Council's (or fiscal sponsor's) tax-exempt status reference. Sent within two weeks of receipt.

Tiers and benefits. Sets illustrative sponsorship tiers (e.g., Community/Friend/Steward-equivalent levels for businesses, distinct from the individual membership tiers on the public website) with defined, non-escalating benefits at each: logo recognition on event materials, an event-day signage placement, a website listing, and — for the highest tier — a designated speaking acknowledgment at the Council's signature event. Benefits are capped and published in advance; they are not negotiated case-by-case in a way that lets a larger check buy more influence.

What a sponsorship is not. No sponsorship benefit implies the sponsor is endorsed by, or has any special standing with, the Chicago Park District — every sponsorship benefit described here is a Council benefit, not a CPD one, and sponsorship materials must say so using the Independent-PAC Public Disclaimer (Phase 9, 9-06) where relevant. A sponsorship never buys naming rights to CPD property (that's the Naming/Recognition Policy's territory, 4-36) and never buys preferential treatment in the Council's advisory positions, event access decisions, or vendor selections (Corporate Sponsorship Standards, 4-35, and the Conflict of Interest Policy, Phase 5, both apply to sponsor relationships too).

Solicitation and term. Only officers or committee members specifically authorized by the Board solicit sponsorships on the Council's behalf — an unauthorized volunteer promising a sponsorship tier to a business creates exactly the kind of commitment the Council may not be positioned to honor. A sponsorship runs for a defined term (typically one event cycle or one year) and is not automatically renewed; the sponsor re-applies and is re-screened against the Corporate Sponsorship Standards (4-35) each term, since a business's reputational fit can change.

Every sponsorship above $500 (or any sponsorship at all from a business the Council hasn't worked with before) goes through Board-level screening before acceptance, using these criteria:

Reputational fit with the Council's community, environmental, and cultural mission — a sponsor whose public conduct or business practices would embarrass the Council or the community it represents is declined regardless of the amount offered. No direct promotion of alcohol, cannabis, or tobacco products in sponsorship materials, given the youth and family programming this Council supports, even where such a sponsor's underlying business is otherwise legal and acceptable. No material environmental-harm conflicts — a sponsor whose business is in active conflict with the dune/habitat stewardship mission (e.g., a demonstrated record of environmental violations) is declined. Deference to CPD's own rules — any sponsorship touching park property, signage, or branding defers entirely to whatever CPD's current sponsorship/branding requirements specify, which control over this policy where they conflict.

A sponsor that fails screening is declined in writing, without necessarily detailing every reason, and the decision is documented for future reference in case the same business approaches the Council again. A sponsor may appeal a declination once, in writing to the Board, if it believes the screening was based on a factual error — the Board is not obligated to reverse its decision, but an honest factual mistake should be correctable.

Ongoing review, not just at acceptance. An existing sponsor whose conduct or public reputation changes materially during the sponsorship term (a controversy, a change in ownership or business practices) is re-screened against these same standards mid-term, not just carried forward on the strength of the original approval — the Board may decline to renew, or in a serious enough case, may decline to continue displaying an active sponsor's recognition for the remainder of the term.

States plainly, for internal and external audiences alike: this Council cannot independently grant naming rights, memorial plaques, dedicated benches, or any permanent recognition installed on Chicago Park District property — 63rd Street Beach, the Beach House, the dunes, or any feature within them — no matter the size of the associated gift. Naming CPD property is CPD's authority alone.

What the Council can offer on its own authority: recognition in Council-owned materials (the website, the Annual Community Report, event programs), a named Council award or scholarship, or sponsor-tier benefits under the Sponsorship Policy (4-34) — none of which touch physical park property.

What requires CPD. Any proposal that would place a donor's or sponsor's name on a physical feature of the park — a bench plaque, a dedicated garden, signage — is routed through the Park Supervisor or Area Manager and CPD's own approval process before the Council makes any commitment to the donor, including an informal verbal assurance that "we'll get your name on something." If a donor is motivated specifically by naming recognition, that expectation is set correctly and in writing before the gift is accepted, not negotiated after the fact when CPD declines.

Council-side approval and permanence. Even a Council-owned recognition (a named award, a listing on the website) that carries any ongoing cost or commitment requires Board approval before it's promised, not just an officer's informal say-so. No recognition — Council-owned or CPD-approved — is promised as permanent unless the underlying agreement (with CPD, for park property; with the Board, for Council-owned recognition) actually says so; absent that, recognition is understood to last for a defined period tied to the gift or sponsorship term.

Revocation. The Board may discontinue a Council-owned recognition if the underlying relationship or circumstances materially change (mirroring the sponsorship re-screening process in 4-35) — a named award is not, by default, an irrevocable grant regardless of how the honoree's conduct or standing later changes.

Requires CPD coordination/approval before any fundraising campaign tied to CPD property or projects (per the CPD Fundraising Pre-Approval / Coordination Record, 4-38) — this is not optional courtesy, it is a current CPD requirement, and skipping it risks the campaign's proceeds being unusable for their stated purpose if CPD later declines the underlying project.

Every campaign, before it launches, needs: a written plan and goal amount (4-39); a defined use of proceeds specific enough that donors know exactly what they're funding; CPD coordination evidence where the campaign touches park property or projects (4-38); and donor-facing communications reviewed against the Independent-PAC Public Disclaimer (Phase 9, 9-06) so nothing overstates the Council's authority over park property or implies CPD has already approved something it hasn't.

During and after the campaign: funds are deposited per the Cash Handling Policy (4-18) and tracked toward the stated goal in the Fundraising Campaign File (4-39); if the campaign falls short or overshoots the stated purpose's actual cost, the Board decides the disposition of the difference consistent with any donor restrictions (4-30) before spending it on anything else.

Council-only fundraising. Not every fundraiser touches CPD property or requires CPD coordination — a membership drive, merchandise sales, or an online giving campaign for general operating support can proceed under this policy without 4-38 if it genuinely doesn't implicate park property or a CPD-approved project. The Treasurer or Finance Committee makes that threshold call before the campaign launches, in writing, so it's not assumed casually and later found wrong.

Paid fundraisers. The Council does not engage a commission-based professional fundraiser (someone paid a percentage of what they raise) without Board approval and, if applicable, compliance with any Illinois professional-fundraiser disclosure requirements — a percentage-based arrangement creates an incentive misalignment the Board should weigh deliberately, not accept by default.

Donor transparency. Campaign materials state honestly what portion of proceeds goes to the stated purpose versus covering the campaign's own costs, where that split is material — donors give more freely, and more repeatedly, when they aren't later surprised by how their gift was actually used.

Created and completed before the campaign launches, not retroactively — written CPD coordination evidence for every campaign touching park improvements is what the Annual PAC Fundraising Report (4-40) will need to point back to.

One complete file per campaign, opened at the planning stage and closed out afterward — not a scattered collection of emails reconstructed after the fact. Contents: the campaign plan and goal amount; the CPD coordination record where the campaign touches park property (4-38); a budget for the campaign's own costs (printing, event expenses) netted against gross proceeds; every solicitation piece actually used — emails, flyers, social posts — kept on file so any claim made to a donor is auditable later if a dispute arises; donor restrictions accepted during the campaign, cross-referenced to the Donor Restriction Agreement (4-32) and Restricted Funds Ledger (4-46); deposit records tying receipts back to the Cash Receipts Log (4-17); and a short final report once the campaign closes — amount raised against goal, how proceeds were spent, and one or two honest lessons for next time, filed where the next campaign lead will actually find it.

Current CPD conduct/guidance calls for an annual report on PAC funds and fundraising activity whenever the Council handles money, including the bank evidence CPD requests — this is not optional for a PAC that has accepted even modest donations during the year. Assembled from the year's twelve Treasurer's Reports (4-14), the Annual Operating Budget compared against actual results (4-12/4-13), a summary of any fundraising campaigns run (4-39), and copies of the relevant bank statements demonstrating the funds are actually where the Council's records say they are. Submitted alongside, or as part of, the broader Annual CPD PAC Report (Phase 10, 10-03) on whatever schedule CPD's current Annual Report cycle requires — the Treasurer should not treat this as a separate, forgettable filing distinct from the main annual report.

Illinois charitable-solicitation registration applies once solicitation/receipt activity crosses the state's current threshold — CPD guidance specifically flags checking this. Per the Illinois Solicitation for Charity Act (225 ILCS 460) as cited in CPD's current PAC Guidelines: PACs that intend to solicit and receive more than $15,000 for charitable purposes during any 12-month period ending December 31 must register with the Illinois Attorney General's Office as a charitable organization prior to any solicitation of funds. This file exists to hold the applicability determination itself (with the date it was checked and the running 12-month total against this $15,000 threshold) and, if registration is required, the completed CO-1/CO-2 or current-successor filing. Re-checked annually regardless of the prior year's conclusion, since activity levels change.

Filed annually only if 4-41 determines charitable registration applies. Tracked on the same compliance calendar (Phase 1, 1-34; Phase 10) as every other recurring filing, with the prior year's filing kept on hand as the template for what evidence the next one will need.

Before applying. No grant application is submitted without internal sign-off using the Grant Application Approval Form (4-45), confirming: genuine mission fit (not just "any funding is good funding"); any required matching funds the Council can actually cover from its own budget, not hoped-for future fundraising; the reporting burden and deadlines the grant will impose; and a named person — not "the Grants Committee" generically — accountable for meeting them.

After award. Every awarded grant's restrictions are tracked from day one in the Restricted Funds Ledger (4-46) and logged in the Grant Register & Compliance Calendar (4-44), reviewed at every Finance Committee meeting so a reporting deadline is never discovered by missing it. Grant funds are spent strictly consistent with the funder's stated purpose; spending grant funds on anything the application didn't describe is a funder-relations problem even if the Council's own mission would otherwise justify it.

Closeout. Every grant has a defined end: a final report to the funder, a reconciliation of spent-versus-awarded amounts, and an explicit disposition decision for any unspent funds (return to funder, request to extend/reallocate, or absorption per the grant agreement's own terms) — a grant does not simply go dormant once the initial excitement of the award fades.

Prioritization before pursuit. Not every available grant is worth pursuing. Before drafting an application, the Grants Committee weighs the size of the potential award against the realistic staff/volunteer time the application and eventual reporting will consume — a small grant with a heavy reporting burden can be a net loss of volunteer capacity even when the check itself is welcome.

Multi-year grants. A grant spanning more than one fiscal year is tracked with its own multi-year timeline in the Grant Register (4-44) rather than treated as fully closed at the end of year one — renewal requirements, interim reports, and the cumulative match obligation across all years are tracked from the start, not rediscovered each renewal cycle.

No re-granting without disclosure. The Council does not pass grant funds through to another organization or individual as a sub-grant unless the original grant agreement explicitly permits it and the Grants Committee documents the arrangement — funders generally expect their funds spent by the organization they awarded them to, not redirected without their knowledge.

One row per grant, reviewed at every Finance Committee meeting so a reporting deadline is never discovered by missing it.

Signed off before submission — an application submitted without confirming the Council can actually deliver on the match requirement or reporting burden creates a problem the day it's awarded, not before.

Every donor- or grant-restricted dollar is tracked here separately from the unrestricted operating balance — running balance by restriction, spend-down history matched to actual expenditures, and a flag if a restriction is at risk of not being usable as intended (triggering the release/modification process in the Restricted Gift Policy, 4-30).

Draws a clean line between what the Council itself owns (tents, signage, tools — tracked here) and what's been donated to and installed on CPD property (never Council-owned, tracked instead as a note in the CPD Donation Acceptance Form File, 4-55) — a distinction that matters the moment anything needs repair, replacement, or insurance.

Tracks every policy or CPD-provided coverage benefit the Council relies on (general liability, event-specific coverage, D&O if obtained per 3-31, cyber) with limits, exclusions, and renewal dates — and, critically, confirms in writing what CPD's own volunteer/PAC framework does not cover, so the Council isn't discovering a coverage gap after an incident. Reviewed at least annually and before any material event or contract.

Not adopted until recurring, reasonably predictable revenue actually justifies it — a Council with only sporadic, one-time gifts has nothing meaningful to reserve and shouldn't pretend otherwise. Once annual revenue is predictable enough to plan around:

Target. The Board sets a reserve target, illustratively 3–6 months of average operating expense, reviewed annually against actual budget size (4-12) — the target is a range the Finance Committee recalibrates, not a number set once and forgotten.

Building the reserve. Unrestricted funds remaining at year-end beyond immediate needs are allocated toward the reserve target by Board vote as part of the year-end close, rather than left in the general operating balance where they might get spent on an unplanned opportunity.

Appropriate draw-down. Reserve funds are used for a genuine funding gap (a delayed grant payment, an unexpected compliance cost like a required filing fee) — never for routine budget shortfalls caused by poor planning, which the Annual Budget Policy (4-11) exists to prevent in the first place. Any use of reserve funds requires Board approval outside the ordinary budget process, documented with the reason and a plan to replenish.

Custody. Reserve funds are held in a separate, clearly labeled sub-account or savings account distinct from the general operating checking account — commingled in the same account with no internal tracking, a reserve is too easy to spend down informally without anyone noticing until it's gone.

Replenishment. A draw-down below the reserve target triggers a written replenishment plan at the next regular Board meeting — a target timeline and funding source, not an open-ended intention to "build it back up eventually." The Treasurer reports the reserve balance against target at every Board meeting alongside the Budget-to-Actual Report (4-13), so a shrinking reserve is visible well before it's empty.

Conditional — adopted only if and when cash balances (most likely the Reserve Fund, 4-49) become large enough that leaving everything in a non-interest checking account is a real, material opportunity cost. For a Council this size, that threshold is likely years away, and this policy stays unadopted until the Finance Committee affirmatively recommends otherwise.

If and when adopted: investments are restricted to principal-safe, liquid instruments — FDIC- or NCUA-insured savings accounts, money-market accounts, short-term CDs — consistent with a nonprofit's prudent-investor obligations under Illinois law. Speculative investments (individual stocks, cryptocurrency, anything without insured principal protection) are explicitly prohibited regardless of potential return. Investment decisions require Board-level approval, never sole Treasurer discretion, and are reviewed at least annually alongside the Insurance Register (4-48).

Insurance-limit awareness. If reserve balances ever approach the standard FDIC/NCUA per-depositor, per-institution insurance limit, the Finance Committee considers spreading funds across more than one insured institution rather than leaving an uninsured balance sitting at a single bank — this is a monitoring responsibility even before this policy is formally adopted, since the Reserve Fund itself (4-49) could reach that scale first.

Monitoring. Once adopted, the Treasurer reports the status and performance of any invested funds at the same cadence as the Reserve Fund balance, and the Finance Committee confirms at least annually that actual holdings still match this policy's principal-safe restriction — an instrument's terms can change at renewal in ways that drift outside what was originally approved.

Red flags every officer should recognize: unreconciled cash or repeated "small" discrepancies dismissed without explanation; a signer pressuring for exceptions to the Expense Approval Threshold Matrix (4-21) or resisting the two-person cash-count rule (4-19); reluctance or delay in providing receipts for reimbursement; personal financial distress in an officer with signing authority; and any transaction that doesn't match a legitimate budget line or approved purpose.

If fraud or misuse is suspected: (1) notify the President and the Governance Committee immediately — not the person suspected, and not a general announcement to the full membership before the facts are established; (2) preserve all relevant records under a Legal Hold (Phase 5, 5-12) so nothing is altered or destroyed while the matter is reviewed; (3) the Board (excluding anyone implicated, who recuses per the Conflict of Interest Policy) determines next steps, which may include an independent financial review (4-52), restricting the individual's access pending review, and, where warranted, cooperation with law enforcement or CPD's own oversight channels; (4) the outcome and any corrective action are documented in the Compliance Exception / Corrective Action Log (Phase 5, 5-49).

The goal of writing this down now is that a documented process already exists the one time it's actually needed — improvising a response in the moment, under stress, with an officer's reputation and the Council's funds both at stake, is exactly what this policy prevents.

External reporting. Confirmed fraud or misappropriation involving Council funds is reported to CPD through the Park Supervisor/Area Manager and, where the amount or circumstances warrant, to law enforcement — the Council does not treat a confirmed incident as a purely internal matter to quietly absorb, even when the amount involved is modest and the person involved is well-liked or long-serving.

Insurer notification. If the Council holds any relevant coverage (D&O, crime/fidelity bond) per the Insurance Register (4-48), the Treasurer or President notifies the insurer promptly once a suspected loss is identified — insurance policies commonly set notice deadlines, and a late notification can jeopardize coverage that would otherwise apply.

After the incident. Once resolved, the Finance Committee reviews whether an internal-controls gap allowed the incident to happen (a threshold set too high, a reconciliation skipped) and proposes a specific fix to the Financial Policies & Internal Controls Manual (4-10) — a fraud incident that doesn't change any control going forward has been only half-addressed.

Scales the level of independent review to actual activity, rather than defaulting to either extreme:

Modest budget (illustratively, under $25,000 in annual activity, no grants): an internal review by an officer or Board member outside the Treasurer's normal approval chain, checking the General Ledger (4-15) against bank statements and the Annual Operating Budget (4-12), documented in a brief written report.

Larger budget, grants, or a first fiscal-structure change: an external CPA review (a lighter-touch, lower-cost alternative to a full audit) or compiled financial statements, engaged with Board approval and reviewed for scope before the engagement begins.

Triggering events regardless of size: a suspected fraud incident (4-51), a material and unexplained variance in the Budget-to-Actual Report (4-13), or a funder's own audit requirement as a condition of a grant.

Findings. Whatever level of review is performed, findings are tracked to resolution via the Compliance Exception / Corrective Action Log (Phase 5, 5-49) with a named owner and a deadline — not filed in the Annual Financial Review Report (4-53) and never revisited.

Independence. Whoever performs the review — internal officer or external CPA — is not the same person who maintains the General Ledger, approves disbursements, or reconciles the bank account in the ordinary course; a "review" performed by the Treasurer of the Treasurer's own books tests nothing. The Board sets the scope of any external engagement before it begins (what's covered, what isn't, and what level of assurance — a full audit, a review, or compiled statements — is actually being purchased) so there's no confusion afterward about what was or wasn't checked.

If deferred. A Board that decides a given year's review can be deferred (budget too small, no unusual activity) documents that decision and the reasoning in the Board minutes rather than simply letting the year pass with no review and no explanation — a funder or CPD asking "was last year reviewed?" deserves a documented answer either way.

The written output of 4-52 — findings, any control weaknesses identified, and management's response/remediation plan. Presented to the full Board, not just the Treasurer, and retained permanently as the year's financial-integrity record.

Applicable only under Path A (own 501(c)(3), 4-01/4-04). Which variant applies (990-N e-Postcard, 990-EZ, or full 990) depends on gross receipts and assets as of the filing year — checked annually, not assumed to stay the same as the Council's activity grows. Filed by the deadline tied to the Council's fiscal year-end, and the filed copy is itself a public document CPD and any donor can reasonably expect to see.

Holds CPD's own completed acceptance documentation (obtained through the Park Supervisor/Area Manager) for every monetary or in-kind gift actually intended for the park itself rather than for the Council's own operations — the file that proves a park-directed gift went through CPD's process rather than being installed or spent on the Council's say-so alone.

The first formal step for any capital project (a Beach House repair, an accessibility improvement, a habitat structure) that involves the Council raising or committing funds toward CPD property: a letter to CPD describing the project concept and the Council's intent to help fund it, submitted before any fundraising begins or dollars are pledged, so CPD's own planning process can weigh in from the start rather than after commitments are already made. Per current CPD guidance, the real routing is: discuss the project first with the Park Supervisor or Area Manager to confirm it fits CPD's plans for the park, then submit this letter of intent to CPD's Department of Legislative and Community Affairs (LCA).

CPD's own formal capital-partnership documentation, provided by CPD's Planning Department once its review of the Letter of Intent (4-56) is complete — records the specific project, the Council's committed funding amount, and CPD's construction/installation responsibilities and timeline.

Bank evidence provided to CPD on request, confirming the Council's pledged capital contribution (4-57) is actually on hand and set aside — not merely projected from future fundraising — before CPD commits its own spending authority to the joint project.

The final, signed agreement between the Council and CPD authorizing the capital project to proceed — signed on the Council's side only by officers with actual signature authority under the Contract Review & Signature Authority Policy (Phase 5), and on CPD's side, per current CPD guidance, by the General Superintendent or their designee — only after proof of funds (4-58) is confirmed. CPD does not issue spending authority until it has both the executed agreement and the bank statement in hand.

Every invoice, payment record, and final reconciliation tied to a specific capital project, retained together so the project's actual cost versus pledge (4-57) is auditable, and closed out with a short report confirming the funds were spent as CPD-approved.

What's available on request. Consistent with current CPD guidance and Bylaws Article 17, the Treasurer's Meeting Reports (4-14), the Annual Operating Budget (4-12), and the Annual Financial Review Report (4-53) once completed are available to any member of the public who asks, typically within 5 business days.

What's redacted or withheld. Bank account numbers, routing numbers, and other account-security details are redacted from any record before release. Individual donors' personal information (home addresses, exact gift amounts tied to identifiable individuals below a level the Board sets as genuinely public-interest) is withheld absent the donor's consent, consistent with the Data Privacy Policy (Phase 5, 5-34) — the requirement to be financially transparent as an organization does not require disclosing individual donors' private giving.

Process. Requests are handled through the same intake channel as the general Public Information / Records Request Procedure (Phase 5, 5-18), logged in the Public Records Request Log (Phase 5, 5-19), and any denial or redaction is explained in writing.

Format. A requester may inspect records in person by appointment or receive copies; the Council may charge a modest, cost-based copying fee (capped by the Board, not set ad hoc) for a large paper request, but does not charge simply to view or copy a small, routine request like a single Treasurer's Report.

If a request is denied. A requester who believes a denial or redaction was made in error may ask the President or Board to reconsider, in writing, stating why — the Council does not require a requester to hire counsel or file a formal legal challenge just to get a second, good-faith look at a records decision.

Kept as a ready template, activated only if the Council ever disbands or is suspended. Per current CPD guidance, upon suspension or disbanding the Council's permission to raise or spend funds solicited on CPD's behalf is suspended immediately, and its fiscal agent (if any) is notified to safeguard the funds; if the Council is not reinstated or a new PAC is not formed within 12 months, individual donors whose unspent restricted contributions in the preceding 12 months total $2,000 or more may either have those donations returned or redirect them, with the remaining balance going to CPD.

The worksheet walks through, in sequence: (1) a Board vote to dissolve, meeting whatever threshold Bylaws Article 30 sets for that vote; (2) notifying CPD immediately, and notifying the bank or fiscal sponsor (4-02) to freeze further activity pending wind-down; (3) an inventory of every open restricted-fund line in the Restricted Funds Ledger (4-46) and every outstanding grant obligation in the Grant Register (4-44), so nothing owed to a donor or funder is overlooked; (4) applying the $2,000 donor-refund rule above to any qualifying restricted contributions from the preceding 12 months; (5) distributing any remaining unrestricted funds consistent with Illinois not-for-profit dissolution requirements — typically to another 501(c)(3) with a related mission, never to individuals; and (6) filing Illinois Articles of Dissolution once funds are fully disposed of.

If under a fiscal sponsorship (Path B). The Fiscal Sponsorship Agreement's own termination clause (4-02) governs how remaining sponsor-held funds are handled and controls over any conflicting instruction in this worksheet — the Council reads that clause first, rather than assuming this worksheet's sequence applies unmodified to sponsor-held funds.

Cross-referenced to the broader Disbanding / Dissolution Compliance Packet in Phase 5 (5-50), which sequences this financial wind-down alongside the parallel governance and CPD-notice steps.