WHO IS ACCREDITED?

Private Organization Accreditation

Money Management International is a nationwide nonprofit organization that provides counseling and education related to credit, housing and bankruptcy, and offers debt management assistance if needed. MMI also conducts community education programs in the areas where we have a physical presence.
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VOLUNTEER TESTIMONIAL

Nicole Deprez-Garrity, M.Ed.

Volunteer Roles: Endorser, Lead Endorser

Nicole Deprez-Garrity is a lead After School Endorser based in Germany.
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Purpose

The for-profit organization ensures accountability through effective administration and management, and sound financial management practices that are in accord with legal and regulatory requirements.

FOC
AFM 11: Separate Legal Entities

The organization properly plans for, oversees, and monitors the activities of separate legal entities established on its behalf in accordance with applicable law and regulation. 

Update:

  • Revised Evidence - 02/15/18

Interpretation: The standards in AFM 11 are intended to address foundations, not-for-profit corporations, for-profit subsidiaries, holding companies, and other legal subsidiary entities established on the organization’s behalf. There are a number of reasons organizations choose to form subsidiaries, whether for fundraising or asset management purposes, or to conduct distinct programming. The standards in AFM 11 are not intended to address corporate acquisitions or mergers that result in a singular legal entity.

NA The organization has established no separate legal entities.

Rating Indicators
1
The organization's practices fully meet the standard as indicated by full implementation of the practices outlined in the AFM 11 Practice standards.
2
Practices are basically sound but there is room for improvement as noted in the ratings for the AFM 11 Practice standards.
3
Practice requires significant improvement as noted in the ratings for the AFM 11 Practice standards.
4
Implementation of the standard is minimal or there is no evidence of implementation at all, as noted in the ratings for the AFM 11 Practice standards.

Table of Evidence

Self-Study Evidence On-Site Evidence On-Site Activities
    • See the first AFM Narrative question
    • Feasibility study
    • Business plan
    • Strategic plan (if applicable)
    • Policy regarding the acquisition, use, and distribution of subsidiary revenue
    • Written agreement describing the relationship between the organization's governing body and the separate legal entity
No On-Site Evidence
    • Interview: 
      1. Owner
      2. CEO/Governing Body Chair
      3. Chief Financial Officer
      4. Senior Management

  • AFM 11.01

    Prior to forming a separate legal entity, the organization: 

    1. conducts a feasibility study which includes, but is not limited to, a cost-benefit analysis and an assessment of the legal implications involved;
    2. creates a business plan and, as appropriate, revises its strategic plan highlighting the purpose of the entity and how the relationship fits into the organization’s goals; and
    3. determines whether the proposed venture has sufficient capital, resources, and marketability to ensure success.

    Update:

    • Added NA - 02/15/18

    NA The organization’s legal entities were established prior to the organization’s first application for COA accreditation.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g.,
    • It is unclear how a subsidiary aligns with the organization's long term strategic goals; or
    • One or two of the standard's elements need strengthening.
    3
    Practice requires significant improvement; e.g.,
    • Some aspect of planning for the venture (feasibility study, business plan, or assessment of sufficient capital, etc.) was insufficient and as a result, the organization may be at risk, however the management and the owner are actively working toward a resolution; or
    • One of the standard's elements has not been implemented.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all; e.g.,
    • At least two of the standard's elements have not been implemented; or
    • The organization is at serious risk due to clearly inadequate planning or due diligence related to element (a) (b) (c), and/or (d); or
    • The organization is under legal sanction for misuse of subsidiary revenue, or other legal or tax issue.

  • AFM 11.02

    The organization: 

    1. exercises legally permissible oversight of any entity that raises or holds funds or assets on its behalf;
    2. has a written agreement that clearly describes the relationship between the organization and the separate legal entity;
    3. clearly articulates the corporate structure, the roles, relationships, and responsibilities of all parties; and
    4. adopts a policy regarding the acquisition, use, and distribution of subsidiary revenue consistent with all applicable legal, regulatory, contractual, and funding obligations.

    Update:

    • Revised Standard - 02/15/18
      Element (d) was moved from AFM 11.01 to AFM 11.02.

    Interpretation: With regard to element (b), issues to be addressed within the written agreement include, but are not limited to: policy authority, budgetary authority, compliance and quality oversight, dispute resolution, the authority of the organization to appoint governing body members to a non-profit entity, and the authority of the organization to dissolve the entity. 

    Interpretation: Corporate structure, roles, relationships, and responsibilities should be developed and executed in accord with applicable laws and regulations. 

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g.,
    • Some aspect of the written agreement requires greater specificity or clarity; or
    • One of the standard's elements needs strengthening.
    3
    Practice requires significant improvement; e.g.,
    • Lines of accountability and legal responsibility between the organization and the entity are unclear; or
    • The written agreement does not address one of the standard's elements; or
    • The policy regarding subsidiary revenue was not approved by the owner. 
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all; e.g.,
    • There is no written agreement or the agreement is completely inadequate.

  • AFM 11.03

    Leadership of the organization has regular and ongoing communication with the leadership of separate legal entities.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • Communication is scheduled but could be more frequent; or
    • Documentation of discussions needs improvement.
    3
    Practice requires significant improvement; e.g., 
    • Communication occurs but is infrequent or ad hoc; or
    • Communication records are not maintained.
    4
    Communication between leadership of the organization and the entity is rare or nonexistent.

  • AFM 11.04

    At least annually, the organization reviews its relationship to any separate legal entities to determine whether the relationship(s) continue to serve the best interests of both the parent organization and its external stakeholders, including persons and families served.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • Some aspect of the review process requires clarification.
    3
    Practice requires significant improvement, e.g., 
    • The review has not been conducted within the last eighteen months; or
    • The last review did not include all subsidiaries; or
    • Documentation of the review is minimal or nonexistent; or
    • The review is cursory or does not consider the interests of service recipients.
    4
    The standard has not been implemented; e.g., 
    • The review is not conducted; or
    • Evidence that the relationship no longer serves the best interests of the organization or one of its key stakeholders has been ignored.
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