CFC MEMORANDUM 2005-11

September 7, 2005 

The Office of CFC Operations (OCFCO) has received inquiries from Federal Departments/Agencies and donors asking whether 2005 CFC cash/check contributions could be designated to charitable organizations supporting the Hurricane Katrina relief efforts and be disbursed sooner than the standard April (monthly)/June (quarterly) 2006 initial disbursement schedule. The CFC should be viewed, under normal circumstances, as a means for long term assistance with cash/checks and payroll deductions being used to fund organizations providing relief throughout the 2005 CFC. As a result of the unusual exigencies of Hurricane Katrina, the OCFCO requests that Local Federal Coordinating Committees (LFCC) accommodate, to the extent possible, requests from Federal agencies to make cash/check advance disbursements available to designated charities involved in Hurricane Katrina relief efforts.

Contributions received through this process are considered CFC pledges. The contributions will be counted toward the total raised in the local campaign. Donors and Federal agencies should receive credit toward their campaign goals for any cash/check contributions received.

We recommend the following procedures advancing cash/check contributions:

1. Principal Combined Fund Organizations (PCFO) must first discuss their plans and internal controls with their LFCC and obtain LFCC approval to move forward.
2. Because the bulk of cash/check contributions can be expected within the first two months of the campaign period, we recommend that the most cost efficient means of managing any advance disbursements is to distribute cash/check in two allotments to be completed no later than October 17 and November 16, 2005.
3. Campaigns that choose to make these advance disbursements should inform donors of these actions through keyworkers, emails, posters, or other communication methods.
4. Campaigns should check with their pledge processing or accounting vendors for assistance. OPM has been in contact with several major vendors that provide CFC specific pledge/accounting software to let them know of these advance disbursements and these vendors have indicated that they will provide campaigns with tools/resources to assist them.

Instructions for Handling Disbursements

PCFOs should model their plan in accordance with these instructions:

First Advance Cash/Check Disbursements

The first disbursement should include all cash and checks received through October 14, 2005, which have been processed by the PCFO. The PCFO should follow these procedures when processing funds for this first advance disbursement:

1. All cash/check donations must be accompanied by a pledge card.
2. The only cash/check contributions that will be included in this advance disbursement are those to CFC participating organizations identified by the USA Freedom Corps as providing relief services. Note: The list of CFC participating organizations identified by the USA Freedom Corps is updated regularly and can be downloaded from OPM's website at (http://www.opm.gov/cfc/disasters/katrina-relief.asp). PCFOs are required to verify that the 4-digit CFC code matches to one of those on the list provided by OPM). PCFOs should check the OPM list periodically and, at the least, prior to the first advance disbursement. OPM is updating the list as new organizations are added to USA Freedom Corps' list of organizations providing relief services.
3. If a cash/check contribution includes a pledge to an organization that is not on the list, then that portion of the contribution should be processed as normal through the CFC with disbursement occurring as required in April/June of 2006.
4. The PCFO must record the pledge in its pledge processing system or a separate system used to track CFC contributions designated towards Hurricane Katrina relief. At the minimum, the PCFO must record the following:
   a. The Donor's name;
   b. If the Donor is Civilian or Military;
   c. Donor's Unit/Division name;
   d. Donor's work address & zip code;
   e. Donor's work phone number;
   f. Amount of the cash/check contribution;
   g. Four digit CFC charity code;
   h. Date received;
   i. Date processed;
   j. Date disbursed; and
   k. Any other information deemed necessary by the PCFO for accounting and auditing purposes.
5. The PCFO must maintain any records processed through a separate system for a minimum of three campaign periods, and make such records available upon request to OPM, LFCC or to its auditor in accordance with CFC regulations.
6. The PCFO will not withhold any costs from this advance disbursement. Instead, the PCFO will count these cash/check contributions towards the recipient organization's designated CFC contributions and allocate actual incurred campaign expenses, including any incurred for this advance disbursement, proportionately to all CFC participating charities based on their total designations in accordance with CFC regulations. PCFOs may withhold actual, substantiated costs incurred as approved by the LFCC from the organization's regular initial disbursement in April/June of 2006.
7. The PCFO may establish a small reserve based on its history of canceled checks to protect against the possibility that any checks received may be canceled or that the donor's bank account may not have sufficient funds to honor the pledge. Any funds held in reserve should be specifically identified to one or more organizations and distributed as designated with the initial disbursement in April/June of 2006.
8. The PCFO may designate a minimum threshold for aggregate receipts by an organization providing disaster relief. For example, the PCFO may determine that only organizations with cash/check contributions in excess of $100 will receive the advance disbursements.
9. The PCFO should make the first advance disbursement on October 17, 2005. If the organization(s) is a member of a National or International federation, the PCFO should make the disbursement, with the appropriate supporting documentation, to the federation. OPM has confirmed with the National/International federations that they will pass the CFC funds on immediately to their member organizations.

Second Advance Cash/Check Disbursement

The second disbursement should include all cash and checks received between October 15 and November 15, 2005, which have been processed by the PCFO. The PCFO should follow the same procedures identified in #1-9 above when processing funds for this second advance disbursement, except that the PCFO should make the second advance disbursement no later than November 16, 2005.

Any cash/check contributions received and processed after November 15, 2005, even if designated to an identified relief organization, must be processed as normal under the CFC and included in the initial disbursements in April/June of 2006.

If campaigns have any further questions, please contact either Curtis Rumbaugh or Mark Lambert with further questions on 202/606-2564 or on curtis.rumbaugh@opm.gov or mark.lambert@opm.gov

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