Co-Founder

N atiorlal Legal and Ken Boehm 1g4g-2018

Board of Directors
Peter Flaherty Chairman

Policy Cente Ku rt,Christensen, Vice-Chai rman

Michael Falcone
Richard F. LaMountain
David Wilkinson
"promoting e*ttcs in pwblic lrfr"
Since 1991

J une 7 ,2A19

The Honorable Charles P. Rettig

Commissioner
Internal Revenue Service
I I I I Constitution Ave., NW
Washington, l)C 20224

RE: Center for Global Policy Solutions, EIN 45-48 56194

Global Policy Solutioni, tLC, EIN 56-2521323

Dear Commissioner Rettig:

By this letter, National Legaland Policy Center (NLPC) amends our May 20,2}lg
Complaint.

Additional information published on June 5',2)lg in the Daily Caller in an article by

Andrew Kbrr titled "Elijah Cummings's Wife Used Her Charity to Pay For-Profit
Company, Documents Show" increases the imperatiy?.fot 1n immelillt^I:lTut
Revenue-service (lRS) investigation. Go to: https://dailycaller'coml2019l}6/05/elfjah-
cummi n gss-w ife-charity/

The article contains links to documents that purport to be independent auditors reports,
including financial statements, foq the Center for Global Policy Solutions (CGPS) for the
years2b:t4and 2015. The Daily Caller does not state how it came into possession of
ihese documents, attached as Exhibits A & B'

If authentic, the statements provide additional evidence of the Internal Revenue Code
(lRC) violations cited in our original Complaint.

The auditoris note titled "Related Parties" in the 2015 report states:

managing programs and operations. At December 3I , 20t 5 and 2014', the

its
Centi hi, orrrurd expenses of $78,178 aryd $99,245, respectively,for
mana7enxent fees.

107 Park Washington Court . Falls Church, VA . 22040

703-237-1970 . fax 703-237-2ogQ o www.nlpc.org
The Honorable Charles P. Rettig
June7,2Ol9
Page Two

According to Part VII, Section A of the IRS Form 9f! IGPS annual tax
rsturns for 2015,
worked an aYerage'
tutuyu RoJkeymoore Cummings was paid a salary of $152,155,
and.
for
|,o|i,; prr *.Lf 'ot 40. The sa,ie Section also requires the filer to. "list any hours
related organizations below the dotted line." A "0" appears in this space'

Maya Rockeymoore cummings was paid a substaltial fuJl;tim3 t?l.uy ,:

h....91ht
,orproiit CdpS . At the ,u*, iir. , the for-profit GIS , LLC , of which 'she, is the sole
:its programs
principal, received "a fee of 5 percent of the lenter's expenses for managing
to have been paid twice
and oierations. " Thus, Maya i.ockeymoore Cummings ap;pqars
for the same sefvices.

The 2015 report contains a Schedule of Functional Expenses. The total for salaries
is
Th-at be.long: to.
$470,151, but it is not the highest line item on the Schedule'
"Professional Fees," which toials 9534,ilg. Nowhere on the schedule ol
in.the.report'

Was Maya
Was Maya Rockeym6ore Cummings also the recipient of Professional Fees?
Xolf,.V*oore Cummings paid threi (or more) times for the same work? The IRS. has an
obligation to find out.

A similar fact pattern appears to exist far 2014.The auditor's note titled '(Related Parties"
in the 2014 riport states:
.

The Center also pays GPS afee of 5 percentof the.Center's expenses {9r
managing its progiams qnd operations. At December 3l , 2014 and 2013, the
Center has a.icried expenses'of $51 ,213 and $75,672, rispectively for
manaSement fees.

and.her
The IRS should examine the income derived by Maya Rockeymoore cummings
family from CGPS and GPS';LLC from 2013 to the present

Filing a False Tax Return.

On ZO1S Form 990, CGPS answered "no" to question 28c of Part IV that
asks "Was the
' org*irution a party to a business transaction with one of the following parties? An entity
of whiqh a current or former officer, director, trustee, or key employee (or a family
member thereof) was an officer, director, trustee or key employee or direct or indirect
owner? lf "Yes," complete Schedule L, Part IV'"
The Honorable Charles P. Rettig
June7,2Ol9
Page Three

was the sole

As a Director, officer and Key Employee of GGPS at the same time'she o'yes"
have answefed to
C"urrnor of GpS, LLC, tvtaya Rocleymoore Cummings should
question 28a. The false entry appears to be willful. Form 990 was signed by Maya
Rockeymoore Cummings "under penalties of perjury''

(Of course, self-dealing, private benefit and inurnment do not become tawfuljust because
it.y ur. diiclosed on Fu-im 990. Maya Rockeymoore Cumming: tig CGPS violated the
Internal RevenUe Code whether question2Sc was answered truthfully or not;)

continued Failure to Allow Public Inspection of Form 990.

Subsequent to Maya Rockeymoore Cummings' refusal on April 29,7019

to provide
the
Nl-pC'with u .opy of the laiest CGPS Form 990, two news organizations -
Washington n*iiire, and the Daily Caller have also been rebuffed'
-
Go to:

https:l/dailycaller.co m/2019 /05 /37 /cumrnings-wife-nonprofit-disclosure forms/

https://www.washingtonexaminer.com/news/scrutiny-deepens-of-charity-run-by-wife-of-

This Amendment to.our Complaint is being sent to the Exempt Organizations

Classification office in Dallas but we again request that the Commissioner take steps to
given the
ensure a prompt and fair investigation that is insulated from political influence,
spousal rllationship between MiyaRockey'moore Cummings and Rep. Cummings,
a

powerful member of Congress'

Thank you agai.n for your attention to this important matter. Please contact me if I can
provide additional information or be of firrther assistance.

Sincerely,

Tom Anderson
Director, Government Integrity Project
EXHIBIT A
CEI{TER FOR GLOBAT POLICY SOLUTIONS, Ilt{C.

Financial Statements
And
Independent Auditor's Report

Years Ended December 31, 2015 and 2011

 TABTE OF CONTENTS

Pnge

Independent Auditor's Report 1

Financial Statements
Statements of Financial Position 3
Statements of Activities and Changes in ltlet Assets 4
Statements of Cash Flows 5

Notes to Financial Statements 6

$ up p !_q Ur. entarlr J.Ufo rUpt i p n

Schedule of Functional Expense (with Comparable Totals) 1l

 s\*srt*$^ux$

$tq)'$flffir"

Nqs$ffi &,

W$$$$sr$'Hw$ $$.A-

INDEPE]\DENT AT]DITOR' S REPORT

Board of Directors
Center for Global Policy Solutions, Inc
Washington, DC

Report on the Financial Statements

We have audited the accompanying financial statements of Center for Global Policy Solutions,
Inc. (the Center) which comprise the statements of financial position as of December 31,2015
and 2014 and the related statements of activities and changes in net assets, cash flows for the
years then ended and the related notes to the financial statements.

Management's Responsibility for the Financial Statements

Management is responsible for the preparation and fair presentation of these financial statements
in accordance with accounting principles generally accepted in the United States of America; this
includes the design, implementation, and maintenance of internal control relevant to the
preparation and fair presentation of financial statements that are free from material misstatement,
whether due to fraud or error.

Auditor's Responsibility

Our responsibility is to express an opinion on these financial statements based on our audits. We
conducted our audits in accordance with auditing standards generally accepted in the United
States of America. Those standards require that we plan and perform the audit to obtain
reasonable assurance about whether the financial statements are free from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and
disclosures in the financial statements. The procedures selected depend on the auditor's
judgment, including the assessment of the risks of material misstatement of the financial
statements, whether due to fraud or error. ln making those risk assessments, the auditor
considers internal control relevant to the Center's preparation and fair presentation of the
financial statements in order to design audit procedures that are appropriate in the circumstances,
but not for the purpose of expressing an opinion on the effectiveness of the Center's internal
control. Accordingly, we express no such opinion. An audit also includes evaluating the
appropriateness of accounting policies used and the reasonableness of significant accounting
estimates made by management, as well as evaluating the overall presentation of the financial
statements.

il*rr$.$f***$ $utskv$*t: s\r"T*)$$"t$r$;t$v)$r( -,S' N$r$$$$rss* -&q$vr$sq*rs

I $ t*r*x$l [dr$, .rlsrt\r "?.i i

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a
basis for our audit opinion.

0pinion

In our opinion, the financial statements referred to above present fairly, in all material respects, the
financial position of Center for Global Policy Solutions, Inc, as of December3l,2015 and2014,
and the changes in its net assets and cash flows for the years then ended in accordance with
accounting principles generally accepted in the United States of America.

Other Matter

Our audit was conducted for the purpose of forming an opinion on the financial statements as a
whole. The schedule of functional expenses for the year ended December 31, 2015 (with
Comparable Totals for 2014) on page I I is presented for purposes of additional analysis and is not a
required part of the financial statements. Such information is the responsibility of management and
was derived from and relates directly to the underlying accounting and other records used to prepare
the financial statements. The information has been subjected to the auditing procedures applied in
the audit of the financial statements and certain additional procedures, including comparing and
reconciling such information directly to the underlying accounting and other records used to prepare
the financial statements or to the financial statements themselves, and other additional procedures in
accordance with auditing standards generally accepted in the United States of America, In our
opinion, the information is fairly stated in all material respects in relation to the financial statements
as a whole.

Abrams, Foster, Nole & Williams, P.A,

Certified Public Accountants
Baltimore, Maryland

April l, 2016
 CEI{TBR TOR GLOBAL POLICY SOLUTIONS, INC.
Statements of Financial Position
December 31, 2015 and 2014

20t5 ?014,
ASSETS

Current Assets
Castr $ 430,517 $ 3 l5 ,725
Grants receivable 357 ,17 5 430,981
Due from affiliate .- ?,?{ 1

Total Assets $ 791,643 s 7 46,706

LIABILITIES AND NET ASSETS

Current Liabilities
Due to affiliate $ $ 43,142
Accrued expenses 28,7 48 51,213
Deferred revenue _ slq,gqT - 4.76,641
Total liabilities - , sQa,Q!"1 _*179,?efr

Net Assets
Unrestricted net assets 4?p,7?S -- I Zl'7 1o
Total Liabilites and Net Assets $ 791,643 $ 7 46,706

"See Accompanying )tlotes"

3
 CENTER FOR GLOBAL POLICY SOLUTIONS, Ih[C.
Statements of Activities and Changes in Net Assets
Years Ended December 31, 2015 and 2014

201 5 2014

Change in Unrestricted Net Assets

Support and Revenue
Grants $ I ,593,449 $ r,847 ,7 62
Contributions 40,000 10,000
Other revenue
Total support and revenue
.__ .??,7s7 .
1,999,?96
U2.1.4
,. 1",qI2,?Z-5-

Expenses
Program services I ,573,81 3 I ,897 ,619
Supporting expenses ." ..fJ,lqs.t,e|7,8!,3 ",79,??.!
, Total expenses *lrqlul_q
Increase (decrease) in unrestricted net assets 51,088 (107 ,s67)
Net assets at beginning of year _*, l7f,7lp, ,,.,?8?;.77
Net Assets at End of Year
ffi $,,.,,,I,Ts',

"See Accompanying Notes"

4
 cEr{TER FOR GLOBAL POLICY SOLUTIONS, rNC.
Statements of Cash Flows
Years Ended l)ecember 3l, 2Al5 and 2014

ag.r5 ?pt4

Cash Flows from Operating Activities

Increase (decrease) in net assets $ 51,088 $ (107,867)
Adjustments to reconcile change in net assets to net cash
provided by operating activities:
(lncrease) decrease in assets
Grants receivable 73,806 (430,98 I )
Due from affiliate (3,95 I ) 74,433
Increase (decrease) in liabilities
Due to affiliate (43,t42) 43,142
Accrued expenses (22,465) (24,459)
Deferred revenue _ _ _ Jp,1s6 .. . ]*2,746
Net cash provided by (used) in operating activities 114,7?2 - Go?.0?q)
Net increase (decrease) in cash I 14,792 (307,026)
Cash at beginning of year 315,725 _ p44,71]
Cash at End of Year $ 430,517 $ 315,725

"See Accompanying Notes"

5
 CENTER FOR GLOBAL POLICY SOLUTIONS, IT{C.
Notes to Financial Statements
December 31, 2015 and 2014

l. BACKGROUND

The Center for Global Policy Solutions, Inc. (the Center) is a non-profit corporation,
incorporated in the District of Columbia in February 2012 and began operations in 2013.
The Center was organized under Section 501(cX3) of the Intemal Revenue Code to
conduct research and develop programs that advance the health, education, financial and
civic well-being of individuals and communities across the United States.

The Center receives funding from contributions, grants, contracts and fees. These funds
are expended primarily on the Center's programs and on its administrative activities,

2. SUMMARY OF SIGNIFICANT ACCOUNTII{G POLICIES

A. Basis of Accounting

The financial statements of the Center are prepared in accordance with Financial
Accounting Standards Board (FASB) Accounting Standards Codification (ASC)
as the sourae of authoritative accounting principles generally accepted in the
United States of America on the accrual basis of accounting with a fiscal year
ending December 31't .

B. Basis of Presentation

The financial statement presentation follows the guidance of FASB 168 ASC-
958-205, Financial Statements of Not-for-Profit Programs. Under ASC-958-205,
the Center is required to report information regarding its financial position and
activities according to three classes of net assets: unrestricted, temporarily
restricted, permanently restricted.

Unrestricted net assets are the net assets that are neither permanently restricted nor
temporarily restricted by donor-imposed stipulations.

Temporarily restricted net assets result from contributions and grants whose use is
limited by donor-imposed stipulations. Net assets may be temporarily restricted for
various purposes, such as use in future periods or use for specifrc purposes.

Permanently restricted net assets are funds subject to donor-imposed stipulations that
they be maintained permanently by the Center.

The Center had no temporarily or permanently restricted net assets as of

December 3 l, 201 5 and 2014,
 CEI{TER FOR GLOBAL POLICY SOLUTIOI{S, IF{C.
f{otes to Financial Statements
December 31, 2015 and 2014

)
A. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued)

C. Cash and Cash Equivalents

The Center considers all highly liquid investments with a maturity of three months
or less at the date of acquisition to be cash equivalents.

D. Propefty end Equipment

Property and equipment in excess of $500 are capitalized at cost and depreciated
on a straight-line basis over the estimated useful lives of the related asset. Asset
lives range from 5 to 7 years for personal property and 27.5 to 39 years for real
property. The cost of maintenance and repairs is recorded as expenses as incurred.

As of December 31, 2015 and 2014,the Center had no fixed assets.

E. Revenue Recognition

A major portion of the support for the Center was provided by grants from Ford
Foundation, Kansas Health Foundation, Robert Wood Johnson Foundation and
the Annie E. Casey Foundation. These funds are recognized as revenue when the
purpose for which they were received has been accomplished.

Contributions received by the Center are treated as unrestricted funds, unless

restricted by the donor.

F. Income Taxes

Under the provisions of Section 501(cX3) of the Intemal Revenue Code, the
Center is exempt from Federal and state income taxes, except for unrelated
business income, if any. Accordingly, no provision for income taxes has been
made in the accompanying financial statements. An informational tax return
Form 990 is filed annually.

The Intemal Revenue Service has not examined (audited) the income tax return of
the Center; thus, the first two years are subject to examination. The Center has
not taken any questionable tax positions.
 CENTtrR FOR GLOBAL POLICY SOLUTIONS, I}{C.
Notes to Financial Statements
December 31, 2015 and 2014

7
aa SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued)

G. [Jse of Estimates

The preparation of financial statements in conformity with accounting principles

generally accepted in the United States of America requires management to make
estimates and assumptions that affect the reported amounts of assets and liabilities
and disclosure of contingent assets and liabilities as of the date of the financial
statements and the reported amounts of revenue and expenses during the reporting
period, Actual results could differ from those estimates.

3. GRANTS RECEIVABLE

of amounts earned by or awarded to the Center but not yet

Grants receivable consists
received under reimbursable contracts and amounted to $357,175 and $430,981,
respectively, for the years ended December 31 ,2015 and 2014. Management believes the
grant receivables are fully collectible and, therefore, no allowance for uncollectible
accounts has been recorded.

4. DEFERRED REVENUE

For the year ended December 31,2015, the Center was awarded five cost reimbursable
grants from the Annie E. Casey Foundation, Ford Foundation, Kansas Health Foundation
(KHF) and the Robert Wood Johnson Foundation (RWJF) totaling $1,411,259 and three
reimbursable grants from the Ford Foundation, the Robert Wood Johnson Foundation and
the Kansas Health Foundation for the year ended December 31,2014 totaling $1,559,487,
One of the Annie E. Casey Foundation grant's in the amount of $25,000 is unrestricted
and is used to provide general support for the Center. The Ford grant is used to support
and expand the ongoingwork of "Closingthe Racial Wealth Gap" initiative, The Kansas
Health Foundation grant is used to help five communities in Kansas that are experiencing
elevated concentrations of health risks, while the grant from RWJF is being used to
promote Leadership for Healthy Communities (LHC). As of December 31, 2015 and
2014, the Center had unspent grant funds totaling $536,097 and 5476,641, respectively.

5. CONCENTRATION OF CREDIT RISK

At times during the year, the Center maintains a portion of its cash balances in interest
bearing accounts at financial institutions in excess of the Federal Deposit Insurance
Corporation (FDIC) limit of $250,000 per depositor for each ownership category.
 CENTER FOR GLOBAL POLICY SOLUTIONS, Ili{C.
Notes to Financial Statements
December 31, 2015 and 2014

5, CONCENTRATION OF CREDIT RISK (Continued)

Management has not experienced any losses in such accounts and believes that it is not
exposed to any significant credit risk related to cash.

Approximately 99 percent of the Center's revenue is derived from grant funding. The
current level ofthe Center's operations and program services are contingent on continued
funding from these services. Accordingly, the Center's operation may be significantly
impacted if ftrnding is not renewed.

6, RELATBDPARTIES

During 2013, the Center entered into a cancelable cost sharing agreement with Global
Policy Solutions (GPS), a related party Limited Liability Company, to share certain
mutually beneficial costs incurred in the execution of both organizations' missions.

Under the terms of the agreement, the Center shares equipment, facilities, personnel costs
and sundry other services. The Center reimburses GPS for its share of costs paid directly
by GPS. In addition, the Center may from time to time advance funds to GPS to pay
personnel costs that benefit the Center. These costs/advances are classified as due from
(to) affiliate and were $3,951 and $(43,142), respectively, as of December 31,2015 and
2014.

The Center also pays GPS a fee of 5 percent of the Center's expenses for managing its
programs and operations. At December 31, 2A15 and 2014, the Center has accrued
expenses of $78,178 and$99,245, respectively, for management fees.

nlt FUNCTIONAL ALLOCATION OF EXPENSES

The costs of providing the various programs and other activities have been summarized
on a functional basis in the Statement of Activities and Change in Net Assets.
Accordingly, certain costs have been allocated among the programs and supporting
services benefited.

8. COMMITMENTS AND CONTINGENCIES

Most grants specify the type of expenditures for which the grant funds may be used. The
expenditures made by the Center under these grants are subject to audit and may require
the return of funding if found noncompliant. Management believes that as of
December 31,2015 and2014, the Center is in compliance with all grant terms and no
accrual for potential refunds is required.
 CENTER FOR GLOBAL POLICY SOLUTIONS, INC.
hlotes to Financial Statements
December 3I, 2015 and 2014

8. COMIVIITMENTS AND CONTINGENCIT,S (Contin ued)

The Center is subject to various claims, legal proceedings and investigations covering a
wide range of matters that arise in the ordinary course of business. In the opinion of
management, all such matters are adequately covered by insurance and if not so coyered,
are without merit or are of such kind, or involve such amounts as would not have a
significant offect on the financial position or results of operations of the Center if
disposed of unfavorably.

9. SUBSEQUENT E\TENTS

The Conter has evaluated subsequent events through the date the financial statements
were available to be issued on April l, 2016 and determined there are no material
transactions to or events that require recognition in the financial statements or disclosures
of the Center according to the definitions and requirements of FASB Accounting
Standards Codifrcation ASC 855-1 0-50.

t0
SUPPLE MEI\{TARY II\FORMATION
 CENTER FOR GLOBAL POLICY SOLIJTIOI{S, [IYC.
Schedule of Functional Expenses
Year Ended December 31, 2015
(With Comparable Totals for 2AI4)

Program Services Support Services

2015 2AU
Ford AEC RWJF KHF Total G&A Total Total

Salaries $ 150,697 $ 4,132 $ 180,030 $ 135,292 47 0.151 11.195 $ 481.346 $ 582,453

Fringe Benefits 14.634 246 22,739 I 1,333 48,948 968 49,916 I 20.03 8
Payroll Expenses 3.131 28 6,ggg 1,699 1 1,836 128 lL,964 3,950
Professional Fees 73,844 22,439_ 326,056 112,311 534,649 7,060 541,709 439,082
Program Communicati ons 36,07 4
Profe ssional D evel oprn ent 355 800 5,961 ,116
7 126 7,242 11,323
Dues and Subscriptions 10"405 44 20,094 4,460 34,993 1,31 I 36,304 46,39A
Maintenance and Repairs 5 5 5 6.989
Printing and Reproduction 7.252 2; 2,135 256 9,669 821 10,490 24,731
Meetings and Conferences 97,l3a 3,939 5,61 3 107,181 3,513 110,694 192,695
Travel 39,796 9 4,17 6 29,940 73,921 1,941 75,762 187,807
Office Supplies 2,514 7 4,437 l,l7 4 8,132 8,132 10,280
Postage and Delivery s23 I 588 227 1,339 126 1,465 2,799
Occupancy Costs 28,87 5 1,925 42,350 zl,l7 5 94,325 1,925 96,250 111,1,77
Equipment Rental 44 44 44 10,103
Accounting and Auditing I 1,750 120 26.190 6,437 44,497 1,281 45,779 36,434
Legal 656 z,sos 352 3,516 7,7'38 tt "254 11,944
Cable and Telephone 2,934 3; 10,007 1,637 14,613 177 14,790 16,509
Insurance 1.302 2,357 606 4,265 163 4,429 4,1 g3
Taxes & Licenses 130 294 70 494 9 503 1,933
Storage 758 u 1,694 419 2,872 49 2,921 2,456
Water 287 636 I58 l,0g l l9 1 ,100 950
Bank Charges 292 663 l6t 1,1 l6 16 1,132 707
Management Fee 22,779 , 1,3S; 35,215 16,900 6,179
7 1,999 78,178 99,245
Other costs 4,797 t5 I7,853 216 22,871 840 23,7ll 1 1,306

Total $ 47 5,467 $ 3A,426 $ 7 tL,633 w_ $ 1,573,813 s___41J05. $l,6.uJ_Lq $_lJ6?,843-

11
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EXHIBIT B
CEI\TER FOR GLOBAL POLICY SOLUTIONS, INC.

Financial Statements
And
lndependent Auditor's Report

Years Ended December 31, 2014 and 2013

 TABLE OFCONTENTS

Fase

Independent Auditor's Report

financ ial $latp-rnents

Statements of Financial Position 3
Statements of Activities and Change in Net Assets 4
Statements of Cash Flows 5
Statement of Functional Expense (with Comparable Totals) 6

Notes to Financial Statements

 --\k$x-ffi $,N-\s,

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INDEPENDENT AUDITOR'S REPORT

Board of Directors
Center for Global Policy Solutions, Inc.
Washington, DC

Report on the Financial Statements

We have audited the accompanying financial statements of Center for Global Policy Solutions,
Inc. (the Center) which comprise the statements of financial position as of December 31, 2014
and 2013 and the related statements of activities and changes in net assets, cash flows and
statement of functional expense (with comparable totals for 2013) for the years then ended and
the related notes to the financial statements

Management's Responsibility for the Financial Statements

Management is responsible for the preparation and fair presentation of these financial statements
in accordance with accounting principles generally accepted in the United States of America; this
includes the design, implementation, and maintenance of intemal control relevant to the
preparation and fair presentation of financial statements that are free from material misstatement,
whether due to fraud or error.

Auditor's Responsibility

Our responsibility is to express an opinion on these financial statemehts based on our audits, We
conducted our audits in accordance with auditing standards generally accepted in the United
States of America. Those standards require that we plan and perform the audit to obtain
reasonable assurance about whether the financial statements are free from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and
disclosures in the financial statements. The procedures selected depend on the'auditor's
judgment, including the assessment of the risks of material misstatement of the financial
statements, whether due to fraud or error. In making those risk assessments, the auditor
considers internal control relevant to the Center's preparation and fair presentation of the
financial statements in order to design audit procedures that are appropriate in the circumstances,
but not for the purpose of expressing an opinion on the effectiveness of the Center's internal
control. Accordingly, we express no such opinion. An audit also includes evaluating the
appropriateness of accounting policies used and the reasonableness of significant accounting
estimates made by management, as well as evaluating the overall presentation of the financial
statements.

{-" **r s" $ i $\ tt u$ Nsu [s$ $ $,u\.**: .-\*,$ s\$.s $\ $ti N* $$ vs x$ xtq* xs s\q$v]s{.}$^N,
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a
basis for our audit opinion.

Opinion

In our opinion, the financial statements referred to above present fairly, in all material respects, the
financial position of Center for Global Policy Solutions, Inc. as of December 31,2014 and 2013,
and the changes in its net assets and cash flows for the years then ended in accordance with
accounting principles generally accepted in the United States of America.

Abrams, Foster, Nole & Williams, P.A,

Certified Public Accountants
Baltimore, Maryland

July 17 ,2015
 CBNTER FOR GLOBAL POLICY SOLUTIONS, INC.
Statements of Financial Position
December 310 2014 and 2013

2014 2013
ASSETS

Current Assets
Cash $ 3 l5 ,725 $ 622,7 51

Grant receivable 430,98 I

Due from affiliate 70,433
Total Assets $
!=ffi#
746,706 $
ffi
69iJq4

LIABILITIES AND I\ET ASSETS

Current Liabilities
Due to affiliate $ 43,142 $

Accrued expenses 51,213 7 5,672

Deferred revenue *_!76-,q!l - J33'??s
Total liabilities . s7,9,W9 * .. 4A9}607
Net Assets
Unrestricted net assets . r?[,?,rg -?q?,sZJ
Total Liabilites and Net Assets $ 746,706 $ 693,184

"See Accompanying Notes"

3
 CEI{TER FOR GLOBAT POLICY SOLUTIOI{S,IN[C.
Statements of Activities and Changes in Net Assets
Years Ended December 31, 2014 and 2013

2014 2013

Change in Unrestricted Net Assets

Support and Revenue
Grants $ I ,847 ,762 $ 1,67 4,415
Contributions 10,000 1,97 6
Other revenue 2,214 5A 7

Total support and revenue 1,859 ,97 6 1,6??,141

Expenses
Program services "1 ,897 ,619 I ,392,511,
Supporting expenses . - -,,.7 .0-,2?* . 1.,913
Total expenses 1,967 ,843 1,393 ,564

(Decrease) increase in unrestricted net assets ( 1 07,8 67) 283,577

Net assets at beginning of year ,281,tr.77
Net Assets at End of Year $ 17 5,710 $ 283,577

"See Accompanying Notes"

4
 CENTER FOR GLOBAL POLICY SOLUTIONSOII\C.
Statements of Cash Flows
Years EndedDecember31,ZLl[and2013

2q1,3
?p:,r*

cash Flows from operating Activities $

(Decrease) increase in net assets
$ (107,867) 283,577

to net cash
Adjustments to reconcile change in net assets
provided bY oPerating activities:
(lncrease) decrflase in assets
(430,981)
Grants receivable
70,433 QA,A33)
Due from affiliate
Increase (decrease) in liabilities 43,142 F

Due to affiliate (24,459) 7 5,672

Accrued expenses
Deferred revenue - !+?,1q9
(iq7,p?p)
-, i3lre3{
. f??,1,l
Net cash (used) provided by operating activities
(307 ,026) 622,7 51
Net (decrease) increase in cash
Cash at beginning of Year
*. 6??,7"il,
Cash at End of Year
$ 315 ,725 $,, .,, f3?u7.1 ]

"See AccomPanYing Notes"

5
 CENTER FOR GLOBAL POLICY SOLUTIONIS,IN[C.
Statement of Functional Expenses
Year Ended December 31, 2014
(With Comparable Totals for 2013)

Program Services Support Services

2AM 2013
Ford RWJF' KHF Total G&A Total Total

Salaries $ t47,358 $ 412,053 $ 15,828 $ 575,239 $ 7.214 $ 582,453 $ 447 ,531

frrir-rge Beneflts 35,381 I9 ,334 4,17 8 119,493 545 1 20,03 g 75,001
Payroll Expenses 1,406 2,202 266 3,87 4 76 3,950 5,444
Profbssional Fees 162,898 213,593 30,27 8 406,7 69 32,313 439,082 133,312
Program Comm unications 18,217 14,329 32,545 ? s2g
r)ru, 36,07 4
Professional Development 2,602 7,905 64 10,571 752 1l ,323 10,02 I
Dues and Subscriptions 12,372 32,432 363 45,167 1,623 46,794 32,379
Maintenance and Repairs 2,158 4,827 4 6,989 6,ggg 6,906
Printing and Reproduction 9,953 9,494 6 19,353 1,379 20;7 31 10,085
Meetings and Confbrenoes 7 4,494 | 14,196 2,061 190,7 5l 1,g44 192,695 165,553
J'rave I 43,697 121,690 20,623 1 96,010 1,797 187,807 232,345
Office Supplies 2,57 7 6,420 837 9,834 446 10,290 7,671
Postage and Delivery 983 1,329 139 2,450 338 2,7 gg 3,395
Occupancy Costs 23,890 80,461 6,826 111,177 1l1,177 90,597
Equipment Rental 2,720 6,054 t99 8,973 1,130 10,103 36,968
Accounting and Aurditing I 0,3 g7 23,256 2,17 g 35,821 609 36,430 12,3 1 g
[-egal s68 1,280 96 1,944 10,000 I I ,944 976
Clable and I'elephone 4,67 3 10,543 1 ,0_7 2 16,288 221 I 6,509 8,043
Insurance 1,262 2,9 1g 4,091 102 4,1 83 1,393
Taxes & Licenses 563 1,27 0 1,933 1,933 130
Storage 690 1,545 170 2,445 5l 2,456 1,937
Water 281 630 39 950 950 888
Bank Charges 198 450 57 705 2 707 2,005
Management Fee 26,945 58,417 7,858 93,220 6,025 99,245 7 4,164
Other costs . 1,746 q,614 _ 77? l1;177
- t?9 _ - I l,?06 3+,7 62
Total g-:f,,e12 $t*J:l?? $ 94,521 $ 1,897 ,619 $ 7 A,224 $_]f6i,91 $ I ,393,564

"See Accompanying Notes"

6
 CENTER FOR GLOBAL POLICY SOLUTIONS,INC.
Notes to Financial Statements
December 31,2014 and 2013

1. BACKGROUND

The Center for Global Policy Solutions, Inc. (the Center) is a non-profit corporation,
incorporated in the District of Columbia in February 2012 and began operations in 2013.
The Center was organized under Section 501(c)(3) of the Internal Revenue Code to
conduct research and develop programs that advance the health, education, financial and
civic well-being of individuals and communities across the United States.

The Center receives funding from contributions, grants and contracts and fees. These
funds are expended primarily on the Center's programs and on its administrative
activ ities.

)
r. SUMMARY OF SIGI{IFICANT ACCOUI\TING POLICIES

A. Basis of Accounting

The financial statements of the Center are prepared in accordance with FASB
Accounting Standards codification (ASC) as the source of authoritative
accounting principles generally accepted in the United States of America on the
accrual basis of accounting with a fiscalyear ending December 3lst.

B. Basis of Presentation

The financial statement presentation follows the guidance of FASB 168

Accounting Standards Codification (ASC); ASC-958-205, Financial statements
of Not-for-Profit Prograns. Under ASC-958-205, the Center is required to report
information regarding its financial position and activities according to three
classes of net assets: unrestricted, temporarily restricted, permanently restricted.

Unrestricted net assets are the net assets that are neither permanently restricted nor
temporarily restricted by donor-imposed stipulations.

Temporarily restricted net assets result from contributions and grants whose use is
limited by donor=imposed stipulations, Net assets may be temporarily restricted for
various purposes, such as use in future periods or use for specific purposes.

Permanently restricted net assets are funds subject to donor-imposed stipulations that
they be maintained permanently by the Center.

The center had no temporarily or permanently restricted net assets as of

December 3l ,2014 and 2Al3.
 CENTER FOR GLOBAL POLICY SOLUTIONS,INC.
Notes to Financial Statements
December 31, 2014 and 2013

,,
2t SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued)

C. Cash and Cash Equivalents

The Center considers all highly liquid investments with amaturity of three months
or less at the date of acquisition to be cash equivalents.

D. ProperlI and Equipment

Properfy and equipment in excess of $500 are capitalized at cost and depreciated
on a straight-line basis over the estimated useful lives of the related asset. Asset
lives range from 5 to 7 years for personal proper{y and 27,5 to 39 years for real
property. The cost of maintenance and repairs is recorded as expenses as incurred,

As of December 3I, 2014 and 2013, the Center had no fixed assets.

E. Revenue Recognition

A major portion of the support for the Center was provided by grants from Ford
Foundation, Kansas Health Foundation and the Robert Wood Johnson
Foundation. These funds are recognized as revenue when the purpose for which
they were received has been accomplished.

Contributions received by the Center are treated as unrestricted funds, unless

restricted by the donor.

F. Income Taxes

Under the provisions of Section 501(c)(3) of the Intemal Revenue Code, the
center is exempt from Federal and state income taxes, except for unrelated
business income, if any. Accordingly, no provision for income taxes has been
made in the accompanying financial statements. An informational tax retum
Form 990 is filed annually.

The Internal Revenue Service has not examined (audited) the income tax return of
the Center thus the first year is subject to examination. The Center has not taken
any questionable tax positions.
 CENTER FOR GLOBAL POLICY SOLUTIONS,INC.
Notes to Financial Statements
December 31.,2014 and 2013

,,
2t SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued)

G. Use of Estimates

The preparation of financial statements in conformity with accounting principles

generally accepted in the United States of America requires management to make
estimates and assumptions that affect the reported amounts of assets and liabilities
and disclosure of contingent assets and liabilities as of the date of the financial
statements and the reported amounts of revenue and expenses during the reporting
period. Actual results oould differ from those estimates.

3. DEFERRED REVENUE

For the year ended December 31,2014, the Center received three cost reimbursable grants
from the Ford Foundation, the Kansas Health Foundation (KHF) and the Robert Wood
Johnson Foundation (RWJF) totaling 91,559,487 and two reimbursable grants from the
Ford Foundation and the Robert Wood Johnson Foundation for the year ended
December 31,2013 totaling $2,008,350. The Ford grant is used to support and expand
the ongoing work of 'oClosing the Racial Wealth Gap" initiative. The Kansas Health
Foundation grant is used to help five communities in Kansas that are experiencing
elevated concentrations of health risks, while the grant from RWJF is being used to
promote Leadership for Healthy Communities (LHC). As of December 31, 2014 and
2013, the Center had unspent grant funds totaling $476,641and $333,935, respectively.

1. CONCENTRATION OF CREDIT RISK

At times during the year, the Center maintains a portion of its cash balances in interest
bearing accounts at financial institutions in excess of the Federal Deposit Insurance
Corporation (FDIC) limit of $250,000 per depositor for each ownership category,
Management has not experienced any losses in such accounts and believes that it is not
exposed to any significant credit risk related to cash.

Approximately 99 percent of the Center's revenue is derived from grant funding. The
current level ofthe Center's operations and program services are contingent on continued
funding from these services, Accordingly, the Center's operation may be significantly
impacted if funding is not renewed.

5. RELATED PARTIES

During 2013, the Center entered into a cancelable cost sharing agreement with Global
Policy Solutions (GPS), a related party Limited Liability Company, to share certain
mutually beneficial costs incurred in the execution of both organizations' missions.
 CENTER FOR GLOBAL POLICY SOLUTIONS,INC.
Notes to Financial Statements
December 31,2014 and 2013

\-
va RELATED PARTIES (Continued)

Under the terms of the agreement, the Center shares equipment, facilities, personnel costs
and sundry other services. The Center reimburses GPS for its share of costs paid directly
by GPS, In addition, the Center may from time to time advance funds to GPS to pay
personnel costs that benefit the Center. These costs/advances are classified as due from
(to) affiliate and were $(43,142) and $70,433, respectively, as of December 31,2014 and
2013.

The Center also pays GPS a fee of 5 percent of the Center's expenses for managing its
programs and operations. At December 31, 2014 and 2013, the Center has accrued
expenses of $5 I ,2 I 3 and $7 5,672, respectively for management fees.

6, FUNCTIONAL ALLOCATION{ OF EXPE]\SES

The costs of providing the various programs and other activities have been summarized
on a functional basis in the Statement of Activities and Change in Net Assets.
Accordingly, certain costs have been allocated among the programs and supporting
services benefited.

7. COMMITMENTS AND CONTINGENCIES

Most grants specify the type of expenditures for which the grant funds may be used. The
expenditures made by the Center under these grants are subject to audit and may require
the retum of funding if found noncompliant. Management believes that as of
December 31,2014 and2013, the Center is in compliance with all grant terms and no
accrual for potential refunds is required.

The Center is subject to various claims, legal proceedings and investigations covering a
wide range of matters that arise in the ordinary course of business. In the opinion of
management, all such matters are adequately covered by insurance and if not so covered,
are without merit or are of such kind, or involve such amounts as would not have a
significant effect on the financial position or results of operations of the Center if
disposed of unfavorably.

8, SUBSEQUENT EYENTS

The Center has evaluated subsequent events through the date the financial statements
were available to be issued on July 17, 2015 and determined there are no material
transactions to or events that require recognition in the financial statements or disclosures
of the Center according to the definitions and requirements of FASB Accounting
Standards Codification ASC 855- 1 0-50.

10