K9 Partners for Patriots, Inc.

EIN: 471871810

UEI: LKY7DGJ9F218

Data as of August 23, 2026

K9 Partners for Patriots, Inc.5 audit years7 findings2 repeat
5
Audit Years
7
Total Findings
2
Repeat Findings

FY 2020-08-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on December 1, 2021. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 1, 2022 (1545 days ago).

What is a management decision? →
2020-002
Cost Allowability
MATERIAL WEAKNESSREPEAT

Finding Reference # 2020-002 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Allowable Costs Type of Finding Material Weakness in Internal Control Questioned Costs $0 Criteria. The Organization is required to comply with Cost Principles of Uniform Guidance, Subpart E. Conditions. ? The Organization?s chart of accounts was modified subsequent to receipt of the previous audit report; however, not all costs of fundraising were reclassified to fundraising account codes. ? The Organization reported certain fundraising costs as allowable for its major program. ? Job descriptions for certain employees include unallowable and overhead activities; however, the Organization does not have a process for allocation of payroll costs. Most payroll costs are reported as direct costs of the major federal program. ? The Organization?s chart of accounts does not identify indirect costs and the Organization does not employ a process of allocation of indirect costs to allowable and unallowable activities. Perspectives. ? The Organization is relatively small, the majority of the Organization?s expenses are allowable, and the majority of indirect costs would be allocable to the grant. ? Although we noted fundraising costs that were included in costs reported to the major program, we also noticed costs that could have been reported to the major program that were not. The amounts netted to an under-reporting of allowable costs. This amount was trivial to the major program and no questioned costs are reported. Cause. The Organization is not familiar with the processes of allocation of indirect costs among direct cost pools. Recommendations. ? The Organization?s chart of accounts should provide for mutually exclusive identification of indirect costs and direct costs. Direct costs should include costs reimbursable from the Organization?s major program, other programmatic costs, fundraising and any other unallowable costs. ? The Organization should consider time reporting systems for its employees that comply with Standards for Documentation of Personnel Expenses found in Section 200.430, Uniform Guidance. ? The Organization should develop a method for allocation of indirect costs to direct cost activities. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

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Full finding narrative

Finding Reference # 2020-002 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Allowable Costs Type of Finding Material Weakness in Internal Control Questioned Costs $0 Criteria. The Organization is required to comply with Cost Principles of Uniform Guidance, Subpart E. Conditions. ? The Organization?s chart of accounts was modified subsequent to receipt of the previous audit report; however, not all costs of fundraising were reclassified to fundraising account codes. ? The Organization reported certain fundraising costs as allowable for its major program. ? Job descriptions for certain employees include unallowable and overhead activities; however, the Organization does not have a process for allocation of payroll costs. Most payroll costs are reported as direct costs of the major federal program. ? The Organization?s chart of accounts does not identify indirect costs and the Organization does not employ a process of allocation of indirect costs to allowable and unallowable activities. Perspectives. ? The Organization is relatively small, the majority of the Organization?s expenses are allowable, and the majority of indirect costs would be allocable to the grant. ? Although we noted fundraising costs that were included in costs reported to the major program, we also noticed costs that could have been reported to the major program that were not. The amounts netted to an under-reporting of allowable costs. This amount was trivial to the major program and no questioned costs are reported. Cause. The Organization is not familiar with the processes of allocation of indirect costs among direct cost pools. Recommendations. ? The Organization?s chart of accounts should provide for mutually exclusive identification of indirect costs and direct costs. Direct costs should include costs reimbursable from the Organization?s major program, other programmatic costs, fundraising and any other unallowable costs. ? The Organization should consider time reporting systems for its employees that comply with Standards for Documentation of Personnel Expenses found in Section 200.430, Uniform Guidance. ? The Organization should develop a method for allocation of indirect costs to direct cost activities. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

Corrective Action Plan

As noted above, subsequent to year end the Organization hired a Financial Operations Director. As part of his review of transactions, the Financial Operations Director will be reviewing transactions to ensure that allowable and unallowable costs are properly identified and coded to the proper general ledger accounts. In addition, the Organization has instituted a timekeeping system, Clicktime, to document employee's hours in order to track percentage of time worked on grant awards and programs. Finally, as part of the year-end closing process, the Finance Director will review all overhead costs to determine what percentage of costs should be allocated to grant awards and programs in accordance with the respective grant agreements. This review and allocation will be documented in excel, and the documentation will be maintained in order to support the amounts charged to the grant awards and programs.

Prior Finding References

2019-005

About Allowable Costs / Cost Principles →
2020-003
Reporting
REPEAT

Finding Reference # 2020-003 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Reporting Type of Finding Significant Deficiency in Internal Control Questioned Costs $0 Criteria. The Organization is required to comply with the Performance and Financial Monitoring and Reporting section of Uniform Guidance, Sections 200.327 and 200.328. Condition. We tested whether the amounts reported on Standard Form 425, Federal Financial Report, agreed to underlying accounting records. The table below displays the results of that testing: Grant # Grant Period Reporting Period End Amount Reported Amounts from Accounting Worksheets Differences HU0001-18-1-0048 9/24/2018 to 9/23/2019 3/24/2019 $ 431,132 $440,234 ($9,102) HU0001-18-1-0048 9/24/2018 to 9/23/2019 9/23/2019 $ 885,830 $ 885,830 -- HU0001-91-0023 8/1/2019 to 7/31/2020 1/31/2020 $ 442,875 $437,266 $ 5,609 HU0001-91-0023 8/1/2019 to 7/31/2020 7/31/20 $ 1,022,996 $ 1,022,996 -- We were able to agree amounts reported at the end of each grant period to the underlying accounting records. However, we were not able to agree the amounts reported in the mid-year reports. When we totaled amounts reported during the interim period from the annual reports, we noted the above differences. Perspectives. The amounts reported at the end of each grant period were supported by underlying documentation and were in excess of the total grant amounts. Therefore, we have reported no questioned costs. Cause. The cause of this deficiency is unknown. Recommendations. The Organization should retain records of amounts reported to Uniformed Services University. In addition, the Organization should retain documentation of its review process whereby one individual prepares the report and another performs a quality review. Such documentation could include an email from the reviewer to the preparer. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

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Full finding narrative

Finding Reference # 2020-003 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Reporting Type of Finding Significant Deficiency in Internal Control Questioned Costs $0 Criteria. The Organization is required to comply with the Performance and Financial Monitoring and Reporting section of Uniform Guidance, Sections 200.327 and 200.328. Condition. We tested whether the amounts reported on Standard Form 425, Federal Financial Report, agreed to underlying accounting records. The table below displays the results of that testing: Grant # Grant Period Reporting Period End Amount Reported Amounts from Accounting Worksheets Differences HU0001-18-1-0048 9/24/2018 to 9/23/2019 3/24/2019 $ 431,132 $440,234 ($9,102) HU0001-18-1-0048 9/24/2018 to 9/23/2019 9/23/2019 $ 885,830 $ 885,830 -- HU0001-91-0023 8/1/2019 to 7/31/2020 1/31/2020 $ 442,875 $437,266 $ 5,609 HU0001-91-0023 8/1/2019 to 7/31/2020 7/31/20 $ 1,022,996 $ 1,022,996 -- We were able to agree amounts reported at the end of each grant period to the underlying accounting records. However, we were not able to agree the amounts reported in the mid-year reports. When we totaled amounts reported during the interim period from the annual reports, we noted the above differences. Perspectives. The amounts reported at the end of each grant period were supported by underlying documentation and were in excess of the total grant amounts. Therefore, we have reported no questioned costs. Cause. The cause of this deficiency is unknown. Recommendations. The Organization should retain records of amounts reported to Uniformed Services University. In addition, the Organization should retain documentation of its review process whereby one individual prepares the report and another performs a quality review. Such documentation could include an email from the reviewer to the preparer. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

Corrective Action Plan

The Organization erroneously copied over previous versions of the SF-425. The organization has since initiated a procedure whereby the Organization keeps the electronic records of reported amounts for the SF-425 for both mid-year and final reports. This procedure includes proper annotation of either "mid-year" or "final" on the documents, along with the date of the period that the report relates to. In addition, the Organization has instituted a review process for one individual to prepare the report, and another individual to review the report for accuracy before report submission.

Prior Finding References

2019-007

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FY 2019-08-31

FAC accepted this audit on July 15, 2020 — management decision was due January 15, 2021.

2019-003
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

Finding Reference # 2019-003 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Procurement Type of Finding Compliance and Material Weakness in Internal Control Questioned Costs Not required to be reported Criteria. The Organization is required to comply with Procurement Standards of Uniform Guidance, Sections 200.317 to 200.326. Conditions. ? The Organization had not adopted a procurement policy. ? The Organization did not always enter into written contracts for the procurement of personal services. Cause. The Organization was not aware that professional services should be subjected to procurement policies. Perspective. The number of agreements to purchase goods or services that exceed the small dollar threshold of $10,000 are generally limited. In addition, the Organization has been working with many of its contracted service providers for several years. Recommendations. The Organization should adopt and implement a procurement policy that complies with the relevant provisions of Uniform Guidance. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

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Full finding narrative

Finding Reference # 2019-003 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Procurement Type of Finding Compliance and Material Weakness in Internal Control Questioned Costs Not required to be reported Criteria. The Organization is required to comply with Procurement Standards of Uniform Guidance, Sections 200.317 to 200.326. Conditions. ? The Organization had not adopted a procurement policy. ? The Organization did not always enter into written contracts for the procurement of personal services. Cause. The Organization was not aware that professional services should be subjected to procurement policies. Perspective. The number of agreements to purchase goods or services that exceed the small dollar threshold of $10,000 are generally limited. In addition, the Organization has been working with many of its contracted service providers for several years. Recommendations. The Organization should adopt and implement a procurement policy that complies with the relevant provisions of Uniform Guidance. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

Corrective Action Plan

Planned Corrective Action: Management agrees with the above finding. The Company is in the process of developing a procurement policy as required by the Procurement Standards of the Uniform Guidance. This policy will include guidance for micropurchases, small purchases, sealed bids, competitive proposals, and sole source contracts. This policy will be reviewed and approved by the Organization's Board of Directors, and will be in effect prior to the end of the Organizations 2020 fiscal year end. Management agrees that during 2019, the Organizations purchases were mainly micro purchases that would not require bids or quotes. Anticipated Completion: August 31, 2020 Responsible Contact Person: Ron Flaville, Chief Executive Officer

About Procurement and Suspension and Debarment →
2019-004
Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS

2019-004 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Allowable Costs Type of Finding Compliance and Material Weakness in Internal Control Questioned Costs $138,603 Criteria. The Organization is required to comply with Cost Principles of Uniform Guidance, Subpart E. Conditions. 1. Invoices for services did not contain sufficient detailed descriptions to determine what portion of services were for allowable vs. unallowable activities. 2. The Organization did not always utilize written agreements for professional services. In the cases where written contracts were utilized, the contracts did not contain sufficient detail to determine whether or how much of the services performed are allowable. 3. The Organization reported the costs of professional services that may include fundraising activities as expenditures of the federal award. Payments for these professional services were $138,603, the amount of the questioned costs reported above. Perspective. It is clear that at least some portion of the payments represent allowable grant administration costs. Cause. We were not able to identify a cause. Recommendations. The Organization should enter into written agreements for the purchase of professional services. The agreements should contain sufficient detail to determine the services provided and amounts paid for those services. Specifically, any services that represent unallowable activities and costs, such as fundraising, should be clearly identified. In accordance with the Organization?s procurement policies, the Organization should have these agreements approved by the Board of Directors. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

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Full finding narrative

2019-004 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Allowable Costs Type of Finding Compliance and Material Weakness in Internal Control Questioned Costs $138,603 Criteria. The Organization is required to comply with Cost Principles of Uniform Guidance, Subpart E. Conditions. 1. Invoices for services did not contain sufficient detailed descriptions to determine what portion of services were for allowable vs. unallowable activities. 2. The Organization did not always utilize written agreements for professional services. In the cases where written contracts were utilized, the contracts did not contain sufficient detail to determine whether or how much of the services performed are allowable. 3. The Organization reported the costs of professional services that may include fundraising activities as expenditures of the federal award. Payments for these professional services were $138,603, the amount of the questioned costs reported above. Perspective. It is clear that at least some portion of the payments represent allowable grant administration costs. Cause. We were not able to identify a cause. Recommendations. The Organization should enter into written agreements for the purchase of professional services. The agreements should contain sufficient detail to determine the services provided and amounts paid for those services. Specifically, any services that represent unallowable activities and costs, such as fundraising, should be clearly identified. In accordance with the Organization?s procurement policies, the Organization should have these agreements approved by the Board of Directors. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

Corrective Action Plan

Planned Corrective Action: Management had a contract with the individual engaged in the initial acquisition of the Grant under discussion. That contractor had one SME that spent over 90% of their time solely devoted to the USG Grant being audited. Therefore, we feel that the amount of questioned costs are not accurate. Management also discussed the concerns raised regarding fundraising costs with the Acquisitions Directorate for the related grant. Based on these discussions, Management received written authorization to use their own discretion. In addition, Management was under the assumption that since they only had one program, and that all fundraising ultimately related to development of the one program, that these costs would be allowable under the grant (the grant allowed for $145,000 of marketing/advertising/PR/and Media costs). This information was provided to the Organization's auditor. However, to help ensure clarity and compliance going forward, during fiscal 2020, the Organization hired a consultant with significant experience related to federal grants. The consultant is in the process of helping the Organization to develop policies and procedures surrounding documentation and approval of goods and services related to all expenditures, including those associated with federal awards. These procedures will include ensuring adequate documentation exists to support the expense, ensuring proper allocation between allowable and unallowable costs, and ensuring that the organization is following required procurement policies as approved by the Board of Directors (see response to Finding 2019-003 regarding procurement policies). Anticipated Completion: August 31, 2020 Responsible Contact Person: Ron Flaville, Chief Executive Officer

About Allowable Costs / Cost Principles →
2019-005
Cost Allowability

Finding Reference # 2019-005 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Allowable Costs Type of Finding Significant Deficiency in Internal Control Questioned Costs $0 Criteria. The Organization is required to comply with Cost Principles of Uniform Guidance, Subpart E. Conditions. The Organization?s chart of accounts does not identify fundraising and other unallowable costs. In addition, the Organization?s chart of accounts does not identify indirect costs. Finally, the Organization does not employ a process of allocation of indirect costs to allowable and unallowable activities. Perspective. The Organization is relatively small, the majority of the Organization?s expenses are allowable, and the majority of indirect costs would be allocated to the grant. However, as the Organization grows, a chart of accounts and accounting process will need to be utilized to properly identify indirect and unallowable costs. Cause. We were unable to identify a cause. Recommendations. The Organization?s chart of accounts should provide for identification of fundraising and indirect costs and for allocation of indirect costs to allowable and unallowable activities. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

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Full finding narrative

Finding Reference # 2019-005 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Allowable Costs Type of Finding Significant Deficiency in Internal Control Questioned Costs $0 Criteria. The Organization is required to comply with Cost Principles of Uniform Guidance, Subpart E. Conditions. The Organization?s chart of accounts does not identify fundraising and other unallowable costs. In addition, the Organization?s chart of accounts does not identify indirect costs. Finally, the Organization does not employ a process of allocation of indirect costs to allowable and unallowable activities. Perspective. The Organization is relatively small, the majority of the Organization?s expenses are allowable, and the majority of indirect costs would be allocated to the grant. However, as the Organization grows, a chart of accounts and accounting process will need to be utilized to properly identify indirect and unallowable costs. Cause. We were unable to identify a cause. Recommendations. The Organization?s chart of accounts should provide for identification of fundraising and indirect costs and for allocation of indirect costs to allowable and unallowable activities. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

Corrective Action Plan

Planned Corrective Action: Management agrees that the Organization is required to comply with the Cost Principles of the Uniform Guidance. Historically, the Organization has been relatively small, and the allocation of costs between direct and indirect costs has been done using an excel spreadsheet. Management agrees that going forward, compliance with the Guidance will be more manageable if the chart of accounts is further expanded. Management has hired a consultant that is knowledgeable with grant reporting to assist management in expanding the chart of accounts. Anticipated Completion: August 31, 2020 Responsible Contact Person: Ron Flaville, Chief Executive Officer

About Allowable Costs / Cost Principles →
2019-006
Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS

Finding Reference # 2019-006 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Allowable Costs Type of Finding Compliance and Material Weakness in Internal Control Questioned Costs $2,146 Criteria. The Organization is required to comply with Cost Principles of Uniform Guidance, Subpart E. Those cost principles require that expenditures support allowable activities and be adequately documented. Conditions. ? The Organization was unable to provide supporting documentation for two out of a sample of sixty disbursements. In addition, documentation did not always include notations explaining the purpose of the purchase. ? Two out of the sample of sixty disbursements were in support of fundraising activities. ? One out of the sample of sixty disbursements was for an amount in excess of the supporting documentation. Perspective. ? We requested other documentation as part of our audit that was not part of the sample and all of those documents were available. ? Our sample was non-statistical. Cause. We were unable to identify a cause. Recommendations. ? All expenditures should be documented with written receipts or invoices which include sufficient detail to determine what was purchased and for what purpose. ? When the purpose is not obvious from the documentation obtained from external sources, notations should be included by management of the Organization. ? The amount due to vendors should be verified to ensure that the vendor invoices are for proper amounts. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

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Full finding narrative

Finding Reference # 2019-006 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Allowable Costs Type of Finding Compliance and Material Weakness in Internal Control Questioned Costs $2,146 Criteria. The Organization is required to comply with Cost Principles of Uniform Guidance, Subpart E. Those cost principles require that expenditures support allowable activities and be adequately documented. Conditions. ? The Organization was unable to provide supporting documentation for two out of a sample of sixty disbursements. In addition, documentation did not always include notations explaining the purpose of the purchase. ? Two out of the sample of sixty disbursements were in support of fundraising activities. ? One out of the sample of sixty disbursements was for an amount in excess of the supporting documentation. Perspective. ? We requested other documentation as part of our audit that was not part of the sample and all of those documents were available. ? Our sample was non-statistical. Cause. We were unable to identify a cause. Recommendations. ? All expenditures should be documented with written receipts or invoices which include sufficient detail to determine what was purchased and for what purpose. ? When the purpose is not obvious from the documentation obtained from external sources, notations should be included by management of the Organization. ? The amount due to vendors should be verified to ensure that the vendor invoices are for proper amounts. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

Corrective Action Plan

Planned Corrective Action: Management had a contract with the individual engaged in the initial acquisition of the Grant under discussion. That contractor had one SME that spent over 90% of their time solely devoted to the USG Grant being audited. Therefore, we feel that the amount of questioned costs are not accurate. Management also discussed the concerns raised regarding fundraising costs with the Acquisitions Directorate for the related grant. Based on these discussions, Management received written authorization to use their own discretion. In addition, Management was under the assumption that since they only had one program, and that all fundraising ultimately related to development of the one program, that these costs would be allowable under the grant (the grant allowed for $145,000 of marketing/advertising/PR/and Media costs). This information was provided to the Organization's auditor. However, to help ensure clarity and compliance going forward, during fiscal 2020, the Organization hired a consultant with significant experience related to federal grants. The consultant is in the process of helping the Organization to develop policies and procedures surrounding documentation and approval of goods and services related to all expenditures, including those associated with federal awards. These procedures will include ensuring adequate documentation exists to support the expense, ensuring proper allocation between allowable and unallowable costs, and ensuring that the organization is following required procurement policies as approved by the Board of Directors (see response to Finding 2019-003 regarding procurement policies). Anticipated Completion: August 31, 2020 Responsible Contact Person: Ron Flaville, Chief Executive Officer

About Allowable Costs / Cost Principles →
2019-007
Reporting

Finding Reference # 2019-007 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Reporting Type of Finding Significant Deficiency in Internal Control Questioned Costs $0 Criteria. The Organization is required to comply with the Performance and Financial Monitoring and Reporting section of Uniform Guidance, Sections 200.327 and 200.328. Condition. During the year under audit, the Organization provided Standard Form 425, Federal Financial Report, for the reporting period ended September 30, 2018. However, the Organization was unable to provide supporting documentation that agreed to the amounts reported. Perspectives. The amounts reported and the amounts that were supported by underlying documentation were well in excess of the total grant amount. Therefore, we have reported no questioned costs. Cause. The cause of this deficiency is unknown. Recommendations. The Organization should retain records of amounts reported to Uniformed Services University. In addition, the Organization should implement a review process whereby one individual prepares the report and another performs a quality review. These control procedures should be documented. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

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Full finding narrative

Finding Reference # 2019-007 Federal Program Uniformed Services University CFDA No. 12.750 Compliance Requirement Reporting Type of Finding Significant Deficiency in Internal Control Questioned Costs $0 Criteria. The Organization is required to comply with the Performance and Financial Monitoring and Reporting section of Uniform Guidance, Sections 200.327 and 200.328. Condition. During the year under audit, the Organization provided Standard Form 425, Federal Financial Report, for the reporting period ended September 30, 2018. However, the Organization was unable to provide supporting documentation that agreed to the amounts reported. Perspectives. The amounts reported and the amounts that were supported by underlying documentation were well in excess of the total grant amount. Therefore, we have reported no questioned costs. Cause. The cause of this deficiency is unknown. Recommendations. The Organization should retain records of amounts reported to Uniformed Services University. In addition, the Organization should implement a review process whereby one individual prepares the report and another performs a quality review. These control procedures should be documented. Views of Responsible Officials. Views of responsible officials are included in the attached corrective action plan.

Corrective Action Plan

Planned Corrective Action: Management agrees with the finding noted above. As noted, the Organization did file the FFR on time. However, subsequent to filing the report, the supporting documentation was misplaced. Going forward, as part of our policies and procedures, documentation surrounding all grant reporting will be required to be maintained in a secure location for a period of 7 years. In addition, the procedures will require that someone independent of the person that prepared the report be responsible for review and approval of the final submission. Anticipated Completion: August 31, 2020 Responsible Contact Person: Ron Flaville, Chief Executive Officer

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