Despite vow, Las Vegas fallen-cop charity transparency hasn’t improved

Las Vegas fallen-cop charity

See update at end of story

In my annual look last year at Las Vegas’s Injured Police Officers Fund, its new leadership said the nonprofit agency to aid families of fallen cops in the Las Vegas area would work to add transparency to its operations. So far, I haven’t seen evidence of this.

IPOF, as I will explain below, is a meritorious law-enforcement-themed nonprofit in many ways. But it still does not post its latest annual IRS 990 tax filing, a public record that contains a wealth of information, on its website. This isn’t legally required so long as a charity provides a copy to a requester upon request, but has been highly recommended by the IRS and charity watchdogs for years as a good governance practice for nonprofits.

At my request, IPOF recently sent me its 990 for the year ending December 31, 2021 (there’s always a long lag between the end of the reporting period and when the document becomes available). The filing still didn’t list–or give any hint of–the magnitude of what may have become IPOF’s major function: overseeing the collection of designated donations for specific fallen officers, which are then remitted to the officer or his next-of-kin.

It’s possible these individual campaigns in some years total in the millions of dollars, or at least dwarf the relatively modest numbers shown on the 990. I would suggest that tax-exempt nonprofits acting as the public face for such donations have an obligation to disclose the collective extent of such fundraising to the public. None of this is revealed on IPOF’s 990.

And indeed, this conditional question is posed on the 990 in Schedule D, Part IV at line 1a: “Is the organization an agent, trustee, custodian or other intermediary for contributions or other assets not included” on the 990 balance sheet?  This is followed by a schedule calling for a summary of such receipts and disbursements. The section was left blank on IPOF’s 990 for 2021, and for previous years, too.

But given that IPOF’s website contains language for one fallen officer that “The Injured Police Officers Fund is the only approved donation point,” and references to “the IPOF bank account,” it’s hard to see how IPOF isn’t at least an “intermediary,” and perhaps even an “agent,” even if the funds are held at an independent financial institution like a bank. Also, after a well-publicized event like the tragic death of an officer, local news media accounts often suggest that contributions can be made to IPOF.

I put this query, with others, in a email in early November to IPOF’s president, Chelsea Stuenkel. She’s a lieutenant with the Nevada Department of Public Safety who talked with me last year about more transparency. I haven’t heard back, but will update this post if I do. (See update at end of story) Last year, she cited individual privacy as the reason for not releasing even the total amount of designated contributions not listed on the 990. I think it’s often a big number.

As for IPOF’s 990 for 2021, it showed $180,000 in donations received, plus another $181,000 in revenue, mainly in investment income (the charity had a $2.5 million endowment) for total income of $361,000. It officially handed out $86,000 in cash grants to nine recipients and spent another $18,000 as part of its charitable mission as well as $70,000 in overhead, for total expenditures  of $175,000 (I’m rounding a bit).

I have been writing about charities for nearly a quarter-century, long before becoming New To Las Vegas. One analytical tool I use is calculation of financial efficiencies.

A standard metric is charitable commitment, defined as the percentage of total expenses spent in furtherance of the stated mission. Based on the 990, IPOF’s ratio for 2021 was 60%. This is considerably below the 65% floor set by the Better Business Bureau Wise Giving Alliance, a leading charity watchdog, for reputable nonprofits. But, as I noted, IPOF excludes all those designated contributions from the 990. Were they included, I imagine IPOF’s charitable commitment ratio could be a terrific 90% or even higher.

Another standard metric is fundraising efficiency, the percent of donations received remaining after fundraising expenses. The BBB again sets 65% as the acceptable minimum. Here, IPOF really shines. The nonprofit does no direct mail or telemarketing at all–which can easily absorb most of what comes in–relying on a few large donors, plus several fundraisers and contributions to the IPOF itself that come in the door thanks to those free media plugs. As a result, IPOF’s fundraising efficiency is 100%. It can’t get any higher than that.

At the New To Las Vegas world headquarters, I regularly get telephone pitches seeking funds for law enforcement causes. But every single one has been some kind of a scam, usually because what sounds like a charity is actually a masquerading political action committee spending next to nothing–and often nothing at all–for the betterment of law enforcement. Nor have they complied with a new Nevada law requiring prior state registration before soliciting, either. I call each a faux charity. In this space I have written up many of them. For examples, click here, click here, click here, and click here. Or just put the word “faux” in the nearby search box.

However, IPOF is the real deal.

Founded in 1982, IPOF is run by a volunteer board of sworn officers, with one paid part-time staffer, from more than a dozen law-enforcement agencies in southern Nevada. IPOF is a fully qualified 501(c)(3) and contributions it receives are tax-deductible by the donor. The original idea was to pay for expenses not covered by workers comp and health insurance. Aside from the designated contributions, IPOF pays a death benefit of $25,000 and, for non-fatal cases, a maximum of $10,000.

In past years, there has been some grumbling from spouses of Las Vegas police officers about a lack of transparency in how money was awarded in non-fatal cases. But that seems to have died down.

Still, it’s not often that I encounter a nonprofit that deliberately obscures much of the good it does.

UPDATE ON JANUARY 12, 2023: Lt. Stuenkel responded to my query about why the amount of donations received and disbursed by IPOF for specific individual fallen officers–a sum I suspect is considerable–was not reflected on the organization’s public IRS Form 990 filing. She wrote that such donations and expenditures were indeed recorded on the books of IPOF, but that they are not treated as income and expense but simply a balance sheet liability not required to be publicly disclosed by IPOF unless outstanding on the first or last day of the fiscal year. “On December 31, 2020, and December 31, 2021, there were no balances held for the benefit of others,” she wrote. My problem with this answer is that the Form 990 explicitly asked in part this question:  “Did the organization … serve as a custodian for amounts not listed [on the balance sheet]?” The Form 990 further instructs that if the answer was yes, details of such amounts were to be disclosed on a separate schedule on the return. The IPOF checked the box for ‘No”–even though Stuenkel candidly admitted in her response such designated donations were “recorded on the books and records of” IPOF and not listed on the Form 990. Under these circumstances, “No” does not strike me as the correct answer, especially on a tax form filed under penalty of perjury. Moreover, in my view IPOF is employing a ploy–making sure there are no undistributed sums on the last day of a year–in a bid to avoid required disclosure.

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