{
  "question_id": "CG-P1B-FULL-043",
  "slug": "what-belongs-on-a-church-financial-review-checklist",
  "display_title": "What documents and steps belong on a checklist for a church's financial review of its records?",
  "format": "article-v2",
  "applies_to": {
    "countries": [
      "US"
    ],
    "frameworks": [],
    "tax_year": null,
    "platforms": []
  },
  "general_concept": false,
  "summary": "Request only the documents a named step uses; the Documents column of the checklist below lists them step by step. Trace offerings from the count, test gifts and payments against their terms and authority, and report procedures and findings in writing. The result is not a financial statement audit or CPA review.",
  "body": "## What can a review of the records conclude, and what can it not?\n\nThe Journal of Accountancy's article on agreed-upon procedures describes three kinds of engagement under the AICPA's attestation standards. In an examination, the practitioner obtains reasonable assurance to support an opinion; in a review, limited assurance to express a conclusion; in an agreed-upon procedures engagement, the practitioner performs specific procedures and reports findings without an opinion or conclusion.\n\nA checklist run by church members also reports procedures and findings, but no practitioner performs it, so it is none of the three. It can say which records were examined, what they showed and what exceptions were found. It cannot say the books are free of error or fraud, speak for items it did not test, or be described as a financial statement audit or a CPA review.\n\nThe level you run it at sets the depth and the wording:\n\n| Who runs it | Depth | How the result is described |\n|---|---|---|\n| Church members or officers | Every step below | Procedures and findings, naming who did each step and any step not independently tested |\n| An independent CPA | Set by the engagement terms and the CPA's standards | The CPA's own report; the checklist becomes the church's request list |\n| Preparation for an audit by someone else | Requests, reconciliations and known gaps | Readiness notes, never a conclusion on the books |\n\nClear no step on someone's word that an area is in order: each result names the record examined. A general business checklist has no step for offerings with no outside record, gifts for a stated purpose, benevolence payments or ministerial pay. GCFA, an agency of The United Methodist Church, writes its guidance for that denomination: where a step compares a church with GCFA's practice, the church's own policy governs, and a departure is reported as a recommendation, not a breach.\n\n## What goes on the request list, and who can clear each step?\n\nFix the review period, then request documents step by step so each one has a user; a document requested for one step serves every other step that uses it. The Documents column is the request list; the last two columns show an invented church's results.\n\nNo step should be cleared by anyone who recorded, counted, carried, deposited, approved, signed or received the money or records it tests, or by that person's relative or household member. GCFA's Local Church Audit Guide lets a very small church (its example: 10 to 20 members with minimal funding and asset balances) use an independent qualified member or a volunteer from another church. If no independent person is available, someone who is not independent may perform the step. Record who performed it and in what role, mark it not independently tested rather than cleared, and list it in the report.\n\n| Step | Documents to request | Evidence examined | Result (example) | Disposition |\n|---|---|---|---|---|\n| 1. Scope | Bylaws or constitution; financial policies; governing-body and committee minutes; prior review report | Who sets pay and approves spending; prior findings | One prior finding open | Reported again |\n| 2. Reports | Financial reports the governing body received; general ledger | Report amounts to ledger | March omits building fund | Finding |\n| 3. Accounts | Account and signer list, including pastor-controlled accounts in the church's name; declarations from the pastor and ministry leaders; bank and investment confirmations; card, processor and petty cash accounts | One complete list | Youth account off the books | Finding |\n| 4. Reconciliations | Statements for every account, for the period and the next month, obtained directly from the bank; bank confirmations; monthly reconciliations | Reperformed reconciliation; bank balance to confirmation; outstanding checks to next month's statement; preparer and reviewer | March unreviewed | Finding |\n| 5. Offerings | Service and event calendar; bulletins or announcements of special offerings; counting policy; count sheets; custody log; deposit slips; processor reports | Count, custody, deposit, recorded total | 8 collections agree | None |\n| 6. Purpose gifts | Gift letters; endowment and memorial fund terms; designated-envelope records; appeals; written designations; fund roll-forwards; fund invoices | Balances, purpose, conditions, perpetual gifts | Mission payment unsupported | Finding: support or restore |\n| 7. Acknowledgments | Giving records; copies of acknowledgments and disclosure statements; event and ticket sale records | Issued where due; giving records to total | 400.00 gift unacknowledged | Finding |\n| 8. Disbursements | Paid invoices; approvals; approved budget; card statements; vendor change records | Invoice, approver, authority, signers | 2 of 25 approved by the payer | Finding |\n| 9. Benevolence | Policy; request, assessment and approval files; payment records; substantial-contributor list from the giving records | Documentation, recipient, relationships | Approver's relative paid, undisclosed | Escalated |\n| 10. Compensation | Pay-setting minutes or contracts; pay schedules; housing allowance designations; comparability data; payroll registers | Pay to approval; designation before payment | Agree | None |\n| 11. Duties | Duty map; software access lists | Who records, holds, approves, reconciles | Treasurer records and reconciles | Outside member receives statements directly and initials reconciliations: tested |\n| 12. Insiders | Insider list; conflict disclosures; payee list; loan, lease and property transfer records | Matches, disclosure, approval | None found | None |\n| 13. Filings | List of returns and registrations; filed copies; proof of filing or payment | Copy and proof for each | One quarter's proof missing | Finding |\n| 14. Assets | Property list; deeds and titles; investment statements; loan agreements and statements; insurance policies | Owned, owed and insured to records | Agree | None |\n\n## How do you trace an offering from the count to the recorded total?\n\nStart at the count, not the deposit: the time between collection and deposit has no outside record. GCFA's Good Internal Controls for Ministries page says counters should be two or more people who are neither the treasurer nor the financial secretary and are not related to or part of a household with each other, the treasurer or the financial secretary, and that offerings are deposited the same or next business day. Test counters and timing against the church's own counting policy, or GCFA's practice where it has none.\n\nFor offerings collected in person, first list every collection that the calendar and the bulletins or announcements show for the period, confirm each has a count sheet and a deposit, and record any collection without both as an exception. Select collections from that list across the period, including special and midweek ones, and run these steps in order:\n\n1. Read the count sheet: date, cash and checks, the counters' signatures, and whether the counters met the church's counting policy.\n2. Follow custody: who carried the offering, where it was held and when it was deposited.\n3. Agree the count total to the deposit slip and the bank credit, and note the deposit date.\n4. Agree the deposit to the recorded contribution entry, and the identified gifts to the giving records.\n5. Work backward from selected contribution entries to their deposits, giving records and count sheets.\n\nFor electronic gifts, the processor's report is the outside record: agree its gifts, fees and refunds to its payouts, the payouts to bank credits, and the gifts to the ledger and giving records.\n\nOne invented Sunday, traced:\n\n| Handoff | Evidence examined | Amount | What an exception looks like |\n|---|---|---|---|\n| Count | Count sheet signed by two counters: cash 745.00, checks 2,630.00 | 3,375.00 | One signature, or counters outside the church's counting policy |\n| Custody | Night-deposit bag logged Sunday; bank receipt Monday | 3,375.00 | Offering kept at someone's home for days |\n| Deposit | Deposit slip and bank credit Monday | 3,375.00 | Bank credit of 3,275.00 |\n| Recorded total | Ledger: general offering 2,925.00, building fund 450.00 | 3,375.00 | Building fund gifts posted as general offering |\n| Giving records | Identified gifts 3,070.00 (checks 2,630.00, envelope cash 440.00); loose plate cash 305.00 | 3,375.00 | Identified gifts below the checks and envelopes counted |\n\n## How do you test gifts given for a stated purpose?\n\nFASB's definition of a donor-imposed restriction, reproduced for context in ASU 2018-08, covers a donor stipulation specifying a use narrower than the broad limits set by the organization's nature, environment and governing documents. Restrictions are temporary, such as use after a specified date, for particular programs or services, or to acquire buildings or equipment, or perpetual, such as keeping resources in perpetuity; laws may extend those limits to investment returns. ASU 2016-14 defines board-designated net assets as net assets without donor restrictions limited by governing-board action, and says boards may delegate designation decisions to management. Test donor gifts against the donor's terms, including any gift the donor marked for a purpose, such as a designated envelope. Test only the governing body's or its delegate's earmarks against the minutes or, where delegated, against the delegation and management's written designation.\n\nRun these steps in order:\n\n1. List every purpose fund from gift letters, endowment and memorial fund terms, designated envelopes, appeals, bequests and minutes.\n2. Roll each fund forward: opening balance, plus gifts, plus or minus investment returns (earnings, gains and losses), plus or minus transfers with each one's approval, minus spending, equals the closing balance, agreed to the ledger.\n3. Test spending against the stated purpose using invoices and payment records; money leaving the fund does not pass unless the evidence shows the purpose.\n4. For a gift the donor required to be kept in perpetuity, confirm the original gift is still held, whatever any spending was for, and record what terms or authority the church relied on to spend its earnings.\n\nSome gifts carry conditions. ASU 2018-08 amended the glossary so that a donor-imposed condition is a stipulation representing a barrier the recipient must overcome before it is entitled to the assets; failing to overcome it gives the contributor a right of return of assets transferred, or the promisor a right of release from its obligation. The update treats a barrier plus such a right as what makes a gift conditional, and gives a matching requirement as an example of a barrier. For each such gift, list every condition in the gift document, obtain evidence that each was met before the money was used, and record any unmet condition as an exception naming the gift, the condition and the amount used.\n\n## How do you check acknowledgments and giving records?\n\nPublication 1828, the IRS tax guide for churches, says a donor cannot claim a tax deduction for any single contribution of $250 or more without a contemporaneous written acknowledgment from the church, and that separate contributions are not added together to reach $250. Obtaining it is the donor's responsibility, and a church that does not acknowledge a contribution incurs no penalty, but the church can assist with a timely written statement. That statement gives the church's name, the date, the amount of any cash contribution and a description (but not the value) of non-cash contributions, plus one of three statements: that no goods or services were provided, that any provided were entirely intangible religious benefits, or a description and good-faith estimate of the value of other goods or services provided. The full content rules are a separate question.\n\nPublication 1828 also says the church must give a written statement to a donor who makes a payment exceeding $75 partly as a contribution and partly for goods or services, unless the goods or services have insubstantial value or the only benefit is an intangible religious benefit.\n\nThen run these checks:\n\n- From the giving records, select donors with any single gift of $250 or more, confirm an acknowledgment covering it was issued and a copy kept, and record a gap as a finding against the church's acknowledgment practice.\n- From event and ticket sale records, list payments over $75 made partly for goods or services, and confirm a disclosure statement was given as Publication 1828 requires, with the solicitation or the receipt and in a manner likely to come to the donor's attention, unless an exception applies. Record a late or inconspicuous disclosure as an exception.\n- Compare a sample of acknowledgments with the giving records and the elements above.\n- Agree total giving records plus unidentified receipts, such as loose plate cash, to the recorded contributions.\n\n## How do you test disbursements and benevolence payments?\n\nGCFA's Good Internal Controls for Ministries page says invoices must be required for all payments and approved by someone other than the financial secretary or treasurer, designated by the finance committee; that checks are cut only after approval; and that someone other than the person entering invoices or cutting checks sets up vendors. Read those roles against the church's own policy and minutes.\n\nSelect payments from bank and card statements as well as the ledger, so unrecorded payments surface. For each, examine the invoice, the approval, the budget line or governing-body action that authorized it, and the signers against signing authority. Where a payee's bank details were added or changed during the period, look for a record that someone other than the person who entered them confirmed them through a channel independent of the request, such as a phone number the church held before the request arrived, never one taken from the invoice, the request or any message.\n\nTest benevolence payments to individuals separately. Publication 3833, the IRS guide to providing assistance through charitable organizations, is written for aid to disaster victims and people in emergency hardship, such as a sudden illness or death. It says an organization must keep adequate records showing that its payments further its charitable purposes and that the victims served are needy or distressed, and that distributions followed needs assessments based on recipients' financial resources and physical, mental and emotional well-being. It says documentation should generally include a description of the assistance, its costs and purpose, the objective criteria, how recipients were selected, each recipient's name, address and amount, any relationship between a recipient and officers, directors, key employees or substantial contributors, and the selection committee's composition. For other benevolence payments, apply the same list as the church's own standard.\n\nFor short-term emergency aid, such as handing out blankets, hot meals, electric fans or coats, Publication 3833 expects only the type of assistance, criteria, date, place, estimated number assisted (names are not required), purpose and cost; it says longer-term aid needs the fuller records. Test longer-term assistance against the fuller list, including a check of each recipient's relationships against the insider list and the church's substantial contributors (Publication 3833's term), listed from the giving records. Apply the same list to any short-term emergency payment made to a named person; that is stricter than Publication 3833 expects, so where such a payment carries the short list but not the fuller one, record a recommendation, not a departure from the publication.\n\n## What compensation records does the review check?\n\nLearn from the bylaws and minutes which body sets pay, then agree each person's pay rate to what that body approved and recalculate the pay.\n\nFor a minister's housing allowance, Publication 517 says the employing church must officially designate the payment as a housing allowance, in a definite amount, before it makes the payment. It says the designation may be shown in an employment contract, minutes, a budget or any official action taken in advance, that informal discussions do not amount to one, and that for a minister employed and paid by a local congregation, a national church agency's resolution does not designate it: the congregation must. Check that an official designation exists, states an amount and predates the payments; the review judges no one's tax position.\n\nThe IRS page on the rebuttable presumption under the intermediate sanctions rules says payments to a disqualified person under a compensation arrangement are presumed reasonable if an authorized body without conflicted members approved the arrangement in advance, relied on appropriate comparability data obtained before deciding, and documented the basis adequately, timely and concurrently. That documentation should include the terms and date of approval, the members present for the debate and vote, the comparability data, the actions of any conflicted members and the basis for the decision. The IRS page on disqualified persons describes one as any person in a position to exercise substantial influence over the organization's affairs at any time during the lookback period, and says family members of a disqualified person and entities the person controls are also disqualified persons. Check whether the minutes carry those items for the pay of each such person, family member or entity; the review does not decide whether the presumption applies.\n\n## How do you make sure every account is covered?\n\nEstablish the full population before reconciling anything. Build the list from the account and signer list, statements, card and processor accounts, the prior review, minutes, every petty cash fund, and a written declaration from the pastor and each ministry leader of any account or cash they hold. GCFA's Local Church Audit Guide lists all bank and investment accounts with each signer, including special use accounts in the church's name under the pastor's control; covers separate treasuries a group keeps under the church's tax identification number, such as a pastor's discretionary fund; and obtains written confirmation of balances directly from the bank.\n\nThen agree each amount in the financial reports the governing body received to the general ledger. Obtain each account's statements for the period and the next month directly from the bank. For every listed account, reperform the period-end reconciliation: agree the bank balance to the statement and to the balance the bank confirms to you in writing, the book balance to the ledger, and deposits in transit to the next month's statement. As GCFA's Local Church Audit Guide does, agree checks on the next month's statement dated on or before the period end to the reconciliation's outstanding-check list, and report any check outstanding more than six months; record a cleared check missing from the list, or at a different amount, as an exception. GCFA's controls page says accounts are reconciled at least monthly by someone other than the preparer, and that petty cash is counted by surprise; count each fund unannounced.\n\n## Who records, holds, approves and reconciles, and what if one person does several?\n\nMap who records, holds money or signing authority, approves and reconciles for receipts, payments, payroll and bank accounts. GCFA's controls page says the treasurer and financial secretary must not be related or part of the same household. GCFA's Local Church Audit Guide verifies that the person keeping the ledger cannot alter the individual giving records or send donors their giving statements, that the financial secretary cannot record in the accounting records, and that neither counts offerings; test this against the software access lists, not by asking.\n\nWhere one person records and reconciles, or holds money and records it, test that someone outside the process receives the statements directly from the bank and reviews and initials each reconciliation against them. Where one person counts or holds cash, test that someone outside the process counts it unannounced. A compensating step does not count if the person holding the combined duties supplies its evidence. Checks for a one-person setup are covered in the related question on very small businesses.\n\n## How are insider transactions found?\n\nPublication 1828 describes insiders as persons having a personal and private interest in the church's activities, who could include the minister, church board members, officers and, in certain circumstances, employees; its examples of prohibited inurement include unreasonable compensation to insiders and transferring property to them for less than fair market value. List insiders, their relatives and their businesses, collect conflict disclosures, and match them against payees, addresses, benevolence recipients, loans, rentals and property transfers. For each match, look for the disclosure and approval in the minutes.\n\n## How do you confirm required filings were made?\n\nPublication 1828 says churches may be required to report certain payments or information to the IRS. Its list of the returns most frequently required includes Form W-2 for organizations with employees, and it lists churches, as distinct from other religious organizations, among the organizations not required to file Form 990, 990-EZ or 990-N, while saying religious organizations generally must file one of them. The review does not decide which filings reach the church. List the returns and registrations the church makes, from prior filings, payroll records and advisers, including any state filings, which each state's own authority sets. For each, obtain the filed copy and proof of filing or payment for the period, and record anything missing as a finding.\n\n## What records show what the church owns, owes and insures?\n\nAgree the property list and deeds or titles to the ledger, investments to custodian statements, loan statements and the minutes approving each loan to recorded debt, and insurance policies in force to the property list, and report gaps as findings.\n\n## What happens when a step finds a problem?\n\nA records deficiency, such as a missing signature or an unsupported invoice, goes on the findings list with a recommendation. A possible misuse of funds, such as missing money or an undisclosed payment to an insider, does not wait for the report: stop testing that area, keep copies of what you examined, do not confront the person involved, and report it promptly to the chair of the governing body or, if the chair is involved, to another officer the bylaws name. GCFA's Local Church Audit Guide says suspicions should not be discussed in open meetings.\n\n## How is the review closed out and signed off?\n\nFor each step, record the documents examined, the sample and how it was chosen, the result, any exception and its disposition, who performed it and in what role, and the reviewer's initials and date. Steps 1 to 4, the collection list in step 5, the fund list in step 6, the pay test in step 10 and the insider match in step 12 cover every item; offering traces, acknowledgments, disbursements and benevolence can be sampled if the selection is written down.\n\nGCFA's Local Church Audit Guide, which calls a church member's work an audit, says the report should be in writing and should ideally provide, at a minimum, the procedures performed and related results, a balance sheet or listing of all assets and liabilities, a statement of activities or listing of all income and expenses, and comments on any internal control deficiencies. Report to the governing body in writing with those items plus the period, scope, who did the work and their independence, exceptions, recommendations, any step not independently tested, and a statement that the work was not a financial statement audit or a CPA review. Attach the balance sheet and statement of activities as the church prepared them, labelled as not audited or reviewed. The reviewer signs and dates the report, and the governing body minutes its receipt and responses. Keep the completed checklist and workpapers with the church's records, and begin the next period by re-testing each prior finding.",
  "sources": [
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  "related": [
    {
      "question_id": "CG-P1B-FULL-096",
      "slug": "what-a-nonprofit-financial-audit-checklist-should-contain",
      "display_title": "What should a nonprofit organization's financial audit checklist contain?"
    },
    {
      "question_id": "CG-P1B-FULL-032",
      "slug": "what-a-charitable-donation-receipt-must-contain-for-the-irs",
      "display_title": "What must a charitable donation receipt or written acknowledgment contain to satisfy IRS substantiation requirements?"
    },
    {
      "question_id": "CG-MCE-125",
      "slug": "how-to-track-and-document-spending-against-a-restricted-grant",
      "display_title": "How do I track and document spending against a restricted grant or award so I can report back to the funder and survive their review?"
    },
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      "slug": "what-an-internal-financial-audit-checklist-should-contain",
      "display_title": "What should an internal financial audit checklist contain?"
    },
    {
      "question_id": "CG-MCE-023",
      "slug": "what-checks-can-a-very-small-business-put-in-place-when-the-same-person-records",
      "display_title": "What checks can a very small business put in place when the same person records, pays and reconciles?"
    }
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    "review_verdict": "ACCEPT",
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    "editorial_disposition": "ACCEPT",
    "corrections": 1,
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  "offer": "ask",
  "offer_id": null,
  "sample_target_id": null,
  "datePublished": "2026-09-27T21:10:04Z",
  "reviewed_at": "2026-09-27T21:10:04Z",
  "content_sha": "23932b0e9525c8b76c8dd01da8ce9f35edaec97b73c026df88ffb5da5d5e66b1",
  "release": "2.11.0",
  "slug_provenance": "minted at first publication",
  "question_text": "What documents and steps belong on a checklist for a church's financial review of its records?",
  "jsonld_types": [
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  ],
  "related_question_ids": [
    "CG-P1B-FULL-096",
    "CG-P1B-FULL-032",
    "CG-MCE-125",
    "CG-P1B-FULL-053",
    "CG-MCE-023"
  ],
  "aliases": [],
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}