posted on: Friday, December 23, 2005

According to the LA Times (see Robin Fields’ December 21, 2005 article “Nonprofit Panel Puts Getty on Probation”), it seems like the Council on Foundations is getting a lesson in the limits of self-regulation.

In the wake of widespread media reports of corruption at the Los Angeles-based J. Paul Getty Trust (Council member), the Council demanded a wide range of documents from the Trust. The Council requested the materials in June 2005, and when the Trust failed to deliver the documents this month, the Council placed the Trust on probation. This case is apparently the first time the Council has taken such actions.

It’s not clear what next steps the Council might take with Getty. The Council (or any other self-regulatory body) has no power to impose fines on its members or terminate a member’s tax-exempt status. At worst, the Council could terminate Getty’s membership with the Council, which would mean…well…um…what would it mean?

Getty will still benefit from the Council’s lobbying work on the Hill, as any of the approximately 64,000 foundations that aren’t members of the Council can attest to. Perhaps it might have to pay a slightly higher fee to attend Council meetings and conferences as a non-member, but considering that the Trust has nearly $10 billion in assets, that shouldn’t be too big of a hardship. Plus, those costs would be offset by the several thousand dollars that Getty saves in annual Council membership fees.

Hmmmm...maybe other foundations should try for probation and eventual disbarment?

posted on: Monday, December 19, 2005

The slime oozing from disgraced and indicted lobbyist Jack Abramoff has seeped into some of the nation’s most prominent conservative think tanks, including the Cato Institute and the Institute for Policy Innovation. Collectively, those two organizations brought in $5.1 million from foundations over the past several years.

Eamon James covers the latest dimension to the Abramoff scandal in “Op-Eds for Sale,” which appears in the December 16, 2005 edition of BusinessWeek. In this article, James describes the relationship between Abramoff and Doug Bandow, who writes a column for the Copley News Service and was (until last week) a senior fellow at the Cato Institute. Over the past decade, Abramoff paid Bandow around $2,000 each for “12 to 24” columns that cast Abramoff’s lobbying clients and their policy positions in a favorable light. Bandow resigned from Cato last week, and claims that the think tank had no knowledge of his arrangement with Abramoff. Copley has suspended Bandow, pending its own investigation of the matter.

In the Institute for Policy Innovation case, Peter Ferrara, a senior policy adviser at the Institute, admits that he also received money from Abramoff to write op-eds that are favorable to Abramoff’s clients. According to James, Ferrara stated, "I do that all the time. I've done that in the past, and I'll do it in the future." Tom Giovanetti, the Institute’s president, agrees with Ferrara, stating this practice is not wrong or unethical. Hmmmm…what’s that saying about “absolute power...”?

While the leaders of so-called self-regulating national nonprofit infrastructure organizations ducked their heads in the sand in 2004, NCRP took on Senate Majority Leader Bill Frist’s “World of Hope” fundraiser and condemned it as an exercise in the misuse of charity and philanthropy.

In truth, we erred because we didn’t do enough. With limited resources to deploy, we issued a stinging critique and left it at that when we should have probably taken apart Frist’s increasingly stellar imitation of his House counterpart, Congressman Tom DeLay. We simply never imagined that Dr. Bill Frist’s creation of a nonprofit to raise money—at the Republican National Convention—for AIDS charities, some of a highly dubious nature, could approach the disgraceful depths established and honed by Tom DeLay and his DeLay Foundation for Kids and proposed Celebrations for Children.

Under the guise of providing housing for foster children, DeLay was raising money through his foundation from power players without having to reveal, per 501(c)(3) regulations, who the donors might be, what benefits might be given to sitting members of Congress and their families, or just about anything else for that matter. In addition, Celebrations for Children was to be staffed by DeLay’s daughter and others who were all staff members of his political campaign or the various DeLay-related Political Action Committees. NCRP even went as far as calling for the Internal Revenue Service to deny Celebrations for Children nonprofit tax status.

Maybe we simply couldn’t believe that Bill Frist could function much like someone of the increasingly visible corruption of Tom DeLay, recently an indicted visitor in Texas state courts and likely to be caught up, like his colleague, Ohio’s Bob Ney, in the rapidly unfolding scandal around Jack Abramoff’s Capital Athletic Foundation. Maybe we were deterred by Frist’s promise, notwithstanding the 501(c)(3) status of World of Hope, to reveal the names of the donors to the organization.

At the time, NCRP alone among the national nonprofits challenged Frist, though we hadn’t had even a peep of support from the supposed nonprofit leadership groups when we took on DeLay, Senator Blanche Lincoln, Senator Saxby Chambliss, or even Jack Abramoff for that matter. We suggested that Frist’s fundraiser, whether he intended it or not, would serve as a venue for donors to buy invaluable “face time” with senior Republican lawmakers, some 10 or so from the Senate to be the featured attractions at the World of Hope fundraiser. We criticized Frist’s pledge not to accept lobbyists’ donations as meaningless, since the corporations that hired lobbyists would be able to make the donations directly to buy access. We raised questions about the AIDS charities that Frist had preselected for support, noting one’s leadership by a pastor known for his high-profile support of President Bush’s faith-based initiatives, another run by the son of Rev. Billy Graham. And we noted that the Senator’s charity was run not by AIDS services professionals, but by Frist campaign operatives.

An Associated Press wire story (http://www.cbsnews.com/stories/2005/12/17/politics/main1134721.shtml)
lays out the case against Frist. Here are the facts from the AP story, with some extra information from NCRP:

World of Hope finally filed its Form 990 information with the IRS, nine months late, revealing that despite Frist’s earlier revelation that 96 named donors contributed to World of Hope, the “lion’s share” came from 18 donors. Which of the 96 were actually the 18 whose donations ranged from $97,950 to $267,735 was not revealed in the 990—that’s confidential. One can guess that the big donors might include 3M, Eli Lilly, and Goldman Sachs, listed among World’s financial sources, but whether and how much, no one will say. All the AP report revealed, probably from the identity-redacted 990 information, is that 11 of the charity's 18 biggest donors gave $97,950 each, that one gave $100,000 and that the rest gave more than $245,000 each.

The fundraiser generated $4.4 million in contributions, but only $3 million went to the AIDS charities. The remaining $1.4 million went to overhead, including more than $450,000 in consulting fees to two companies run by Linus Catignani, Frist’s chief campaign fundraiser. The AP story revealed that one of the Catignani’s firms was co-run by Linda Bond, the wife of Missouri Republican senator Kit Bond.

Doing the compensated legal work for the charity was the law firm of Jill Holtzman Vogel, a Republican candidate for the state senate in Tennessee who, according to the AP, has received substantial political contributions from Catignani & Bond. It probably shouldn’t be a surprise that Frist’s spokesman is Jill’s husband Alex Vogel, co-founder of Mehlman Vogel Castagnetti, formerly chief counsel to Senator Frist and counsel to both Frist’s PAC (Volunteer PAC) and, of course, World of Hope.

World of Hope gave money to six charities, not five. One of them, as noted, was Franklin Graham’s Samaritan’s Purse, receiving $490,000. Senate records reveal, however, that not long before the World of Hope fundraiser, Senator Frist went to Chad, Sudan, and Kenya on a junket paid for by Samaritan’s Purse.

NCRP of course has done its own additional research on the World of Hope connections and would add the following to the AP story:

We found at least three Frist trips sponsored by Samaritan’s Purse, one shortly before the Republican convention between 8/06/04 and 8/11/04 to Chad, Sudan, and Kenya costing $1,594, a one day trip on 9/19/03 to Nashville, TN (with Mrs. Frist) costing $1,524, and a third from 8/27/03 to 9/01/03 to Namibia and Kenya (costs undetermined). Since the Convention fundraiser, Samaritan’s Purse has continued its subsidization of Frist’s trips, including a one-day trip on 9/04/05 for the Senator and his son to Mobile, AL costing $3,311 and a trip on 10/07/05 to 10/08/05, again for the Senator and Mrs. Frist to Asheville, NC for $2,130. (see Political Money Line at www.fecinfo.com for a complete database on the sponsors and costs of trips for members of Congress)

This isn’t the first time that Samaritan’s Purse has appeared on NCRP’s radar screen. NCRP’s study of conservative foundations’ support for evangelical religious organizations in the political “culture wars” shows conservative foundations funneling $6.6 million into Samaritan’s Purse between 1999 and 2002. Samaritan’s leader, Rev. Franklin Graham, has received substantial publicity for delivering the sermon at President Bush’s first inauguration and, more recently, for denouncing Islam as an “evil” religion. Less well known is Samaritan’s Purse scoring a $5.6 million grant from the U.S. Agency for International Development in 2004 to work on abstinence programs to stop the spread of AIDS in Africa, a grant received despite the agency’s previous censuring of Rev. Franklin’s charity for engaging in proselytizing while working with federal money providing assistance in earthquake-ravaged El Salvador.

NCRP’s research reveals that Pacto de Esperanza, run by Rev. Luis Cortes, was quite connected to the Bush Administration, with Cortes playing a leading role in organizing the National Hispanic Prayer Breakfast, featuring President Bush, in 2002, 2003, and 2004. Cortes’s Philadelphia-based community development arm, Nueva Esperanza, not surprisingly in 2002 scored a $2.5 million grant in the first round of President Bush’s Compassion Capital Fund grants for faith-based organizations, plus in 2004 another $2.76 million as the first installment of $11 million over three years in 2004 from the Bush Administration’s Department of Labor. While close to Bush, Frist, and other conservative Republicans, and identified by Time magazine in 2005 as one of the nation’s 25 most influential evangelicals, Cortes is politically ambidextrous, only last month having met with Howard Dean “at the Democratic National Committee headquarters to discuss the shared values and priorities between the Democratic Party and the Hispanic and faith based communities”, according to a DNC press release (http://www.democrats.org/a/2005/11/dnc_chairman_de_3.php). The DNC announcement didn’t mention Esperanza’s AIDS program which appears to focus on ministering to people with AIDS to save their souls while on their death beds.

Senator Dr. Frist cares about AIDS, but not without other considerations seeping in. When questioned on national TV in late 2004 by an incredulous George Stephanopoulos, Frist said he didn’t know whether or not tears and sweat could transmit HIV and AIDS, a canard propagated by far right evangelists. Of course Frist knows the truth (he finally acknowledged to Stephanopoulos that it would be “very hard” to contract AIDS from tears and sweat), but he played dumb to maintain this foothold with the religious right. With World of Hope, he may have cared about funneling some money to AIDS charities, but he was also thinking about his image. A Linda Bond memo to lobbyists before the fundraiser underscored that the fundraiser’s success is “hugely important to Senator Frist”. No wonder, since his campaign staff for a potential 2008 run for President has been waiting, honing its skills, and getting paid behind the camouflage of his World of Hope charity.

posted on: Thursday, December 08, 2005

New York University, which as of August 2003 had a $2.2 billion endowment and annual revenues approaching the same amount, is circulating a letter to donors, urging them to give to the University before the end of the year so they can take advantage of the charitable giving tax incentives that were passed into law in the wake of Hurricane Katrina and the resulting relief effort.

If that’s not bad enough, NYU’s George H. Heyman’s Center for Philanthropy and Fundraising is forwarding the letter to its nonprofit contacts, encouraging them to use a similar gimmick to attract donations.

Apparently, at NYU, now is a time to reap and reap and then reap some more.

The text of the email is below:


SPECIAL NEWSLETTER

Of all the letters to donors on the Katrina tax incentive, I believe the one below, sent by Debra A. LaMorte, Senior Vice President, Development and Alumni Relations here at NYU is the best. Perhaps this can help you.--Naomi Levine

Dear [Recipient]:

As the holiday season approaches, we want to take a moment to tell you once more that we are deeply grateful for your ongoing commitment and leadership, and offer our warmest wishes to you and your family for the season.

Because you are currently fulfilling a leadership pledge to The Campaign for NYU, we thought you would be interested to learn more about a new charitable giving opportunity that may make it easier for you to satisfy your generous pledge to NYU.

In the wake of Katrina, Congress has provided additional incentives for charitable giving. Donors who make cash gifts to a charity such as NYU can claim an income tax charitable deduction for up to 100% of adjusted gross income – as opposed to the usual limitation of 50% of adjusted gross income. If you have run up against the limitation on the tax deductibility of your cash charitable gifts in the past, this change in the law effectively suspends that limitation until December 31. So this year you have a unique opportunity to make substantial cash gifts and claim larger charitable deductions immediately.

For example, since you have an outstanding pledge, you may want to consider prepaying future installments, in order to take advantage of the increased charitable deduction available this year.

This temporary change in the law may also make it attractive for you to withdraw funds from your IRA or similar retirement plan in order to make a charitable gift – and deduct the entire amount this year.

Remember that you must make your gift no later than December 31 to take advantage of these new opportunities and receive an increased deduction for this year. So you will want to speak with your own advisor – or the NYU gift planning office at (212) 998-6960 – to find out how you can benefit.

Once again, many, many thanks for your wonderful generosity. Our best wishes for a wonderful holiday season!

Warmest regards.

A letter like this is a terrific way to provide donors and nonprofits with an opportunity to further their mutual goal of helping others and improving the world. I urge you to be sure your nonprofit and donors are aware of this incentive.

posted on: Wednesday, December 07, 2005

Sometimes it is remarkably difficult to keep up with the pace at which dubious Beltway politicians find their ways into tapping charity and philanthropy for nefarious ends. The teary saga of California Congressman Randall “Duke” Cunningham and his relationship with favor-dispensing defense contractors reached its apogee this past week with the Duke’s indictment and subsequent plea bargain and resignation from Congress.

NCRP wrote about the “Duke’s Demise” in our Summer 2005 issue of Responsive Philanthropy, highlighting Cunningham’s relationship with defense contractor MZM Inc., whose president, one Mitchell Wade, worked some real estate transactions for Cunningham putting 6-figure sums in the Congressman’s pocket on top of giving him a 42-foot yacht to live on in D.C. for the de minimus rent of $500 a month.

We of course focused on the philanthropic angle of Cunningham’s friends and associates and the Duke himself. In order to dodge some of the indictments that eventually ensnared him, Cunningham pledged to sell his new home, that had been purchased with MZM’s inappropriate indulgences, and donate the proceeds to three San Diego area charities, one of them known for its Republican political connections and willingness to engage in charitable repair of felonious politicians’ reputations, and another notable for its virulence against lesbian and gays, a concept not unknown to Cunningham who has made crude and insulting remarks about gays on the floor of the House of Representatives.

We also noted the connection of both Cunningham and Wade to something called the Sure Foundation, a faith-based charity ostensibly addressing victims of civil unrest in Third World nations and, based on a government grant, in the neighborhoods of inner-city Washington, D.C.. Capitalized by MZM contributions, Sure counts Wade and his wife as board officers, and Cunningham’s wife and daughter as members of a four-person advisory council.
The indictment and plea bargain outline a long list of bribes Cunningham took in addition to the real estate transactions in San Diego and Arlington, VA (a $200,000 payment to help Cunningham buy a condo there). Included are items such $140,000 for his “Duke-Stir” yacht, $13,500 toward the purchase of a Rolls-Royce and almost $18,000 for its repairs, $7,200 for an antique French commode, $9,200 for two Laser Shot shooting simulators, and the list goes on and on (http://www.latimes.com/news/local/la-me-duke30nov30,0,2055710.story?coll=la-home-local). All told, Cunningham has admitted to some $2.4 million in bribes, not a bad haul for the guy who was allegedly the model for Tom Cruise’s “Top Gun.” But the bribes weren’t all from Wade and MZM.

The indictment also captured four additional unnamed co-conspirators, and quickly the public learned that “co-conspirator no. 1” was Brent Wilkes, a San Diego businessman, well known in Republican campaign circles for his fundraising for Republican candidates and political groups. In fact, Wilkes is no small donor, but a “Bush Pioneer,” so designated for having raised more than $100,000 for the President’s 2004 reelection campaign. On their own, Wilkes and his wife Regina donated $139,806 to political candidates and PACs in 2001 and 2004 (http://wwww.washingtonpost.com/wp-dyn/content/article/2005/08/17/AR2005081702005_pf.html).

Political contributions aren’t the same as bribes, but apparently Wilkes runs a number of firms, including a defense contractor called ADCS, which received more than $80 million in Defense Department contracts for digitizing Pentagon documents. While Wilkes isn’t in jail yet, the business side of his life looks a bit shaky, as his company’s headquarters is up for sale in order to pay back $40,000 in back taxes owned by the landlord, Al Dust Properties LLC, also own by Wilkes (http://www.nctimes.com/articles/2005/12/01/news/top_storoies/21_53_5011_30_05.txt). This indictment isn’t the first time Cunningham was investigated for pushing Pentagon contracts to ADCS, but he and the company slipped through the Pentagon’s Inspector General’s review in the late 1990s, with the then pugnacious Cunningham telling his critics that they “can go to hell” and declaring, in the ADCS investigation, “I’m on the side of the angels here.” (http://www.dukecunningham.org/bibliography/ut19971215-adcs.html).

Of course there’s a philanthropy angle here. Wilkes also runs the eponymous Wilkes Foundation which has also done favors for the now former, bribe-sullied Congressman. In 2002, for example, the foundation organized a black tie “Tribute to Heroes” gala honoring Cunningham and awarding him a trophy for being a hero. That same year, MZM’s Wade contributed money to the Wilkes Foundation, during which Wilkes honored the congressman.

The Wilkes Foundation has a one-page website consisting of a cover page with the foundation’s mission statement: “The Wilkes Foundation is committed to improving the lives of our children and to the people who have served our country” (www.wilkesfoundation.org). If there was ever more content, it seems to have been pulled down, reminiscent of the rapidly disappearing website of Jack Abramoff’s Capital Athletic Foundation after that investigation started.

Started with $100,000 from ADCS in 2000, the Wilkes Foundation grew to $150,000 in 2001 with a gift from David Stecher, a compensation and benefits consultant who, like Wilkes was big in the local United Way’s deTocqueville Society program for major donors and eventually served as a board member for the Tribute to Heroes program. But the only grant made by the foundation in those years was one $500 contribution to a food program in Washington, D.C.

2002 saw the foundation jump with plans for the Salute to Heroes and contributions from the likes of MZM’s Wade ($29,500), adding $300,000 to the institution’s assets. It spent $35,946 on the Tribute to Heroes even that honored Cunningham—plus another $340,000 that went to the United Way. That grant certainly helped solidify Wilkes’ own standing as a United Way deTocqueville donor.

The Foundation added another $340,000 in gifts and income in 2003, but grants fell to $53,500, the majority going to the Marshall Faulk Foundation in Indianapolis. Expenses included $77,000 for yet another Heroes fundraising event, this one honoring Republican Congressman Duncan Hunter. Apparently, the Foundation went ahead with a 2004 heroes celebration, though at this writing, it is unclear which hero from the Republican Congressional delegation got the trophy.

It all comes full circle. NCRP’s investigations of Jack Abramoff’s philanthropic activities led us to look at the presence of another Congressman who went on a Capital Athletic Foundation golf junket to Scotland that led to a contract for one of Abramoff’s corporate clients that also contributed to his foundation. That Congressman was Ohio’s Bob Ney. It’s touching to see that in 2002, Ney got the House of Representatives to approve a proclamation honoring the Tribute to Heroes event that lauded the now disgraced Cunningham. Based on news reports, the subpoenaed Ney may soon be joining Cunningham in reading the particulars of an indictment.

When some of Cunningham’s dealings with Wade were first revealed in the summer of 2005, Cunningham’s response was a dare: “If I’ve done anything wrong, come and get me” (http://nctimes.com/articles/2005/11/06/news/top_stories/22_37_5011_5_05.prt). At the end of November, Cunningham was meekly and tearfully answering, “Yes, Your Honor,” to charges of accepting bribes (http://www.sandiego.com/localnews_fullstory.jsp?ItemId=story.29493.html). But his unindicted misbehavior, along with Wade’s and Wilkes’s, also includes the misuse and corruption of charity and philanthropy for political and personal benefit. It may seem inconsequential compared to the hundreds of thousands of dollars that Cunningham apparently pocketed in direct bribes, but every chip at the edifice of philanthropic accountability reverberates through the halls of Congress and with the American public.

posted on: Thursday, December 01, 2005

The Washington Post’s excellent recent series on the proclivity of the District of Columbia municipal government to award no-bid contracts willy-nilly to politically connected players has captured a nonprofit miscreant. In “Lavish Spending, Little Reward” (http://www.washingtonpost.com/wp-dyn/content/article/2005/11/27/AR2005112701055.html), the Post’s David Fallis and Dan Keating describe the work of the Foundation for Educational Innovation (FEI), run by one Archie Prioleau.

Alice Rivlin, a former member of the Congressionally-appointed board overseeing the District’s finances, described Prioleau as “a wonderfully motivated, well-intentioned, marvelous guy, but…his vision was bigger than his capacity to deliver.” Actually, his nonprofit did deliver, but for Archie rather than for the District or for the young people he was supposed to be training for technology employment.

According to the Post reporters, “for two years, Prioleau hired a…company he runs, paying it about $213,000 for consulting work to his nonprofit organization. The company, FEI Enterprises Inc., had a similar name and shared offices with his nonprofit organization. Prioleau headed both and, at times, his wife and his brother were officers in both firms.”

The rather obvious possibility of self-dealing at FEI didn’t seem to bother District officials, but his failure to deliver on grants passed through the District from the Department of Labor, HUD, and the Department of Commerce and scandals concerning his work with training young people through DC’s Division of Employment Services and the DC Public Schools mounted until FEI, that is FEI-the-nonprofit, collapsed. HUD is seeking restitution from the District, not Prioleau, for $1.7 million in training funding it advanced, though it’s not clear that Commerce and Labor will seek to get back their funding.

The HUD money takes us back to more possible instances of nonprofit conflict of interest and self-dealing. One of Prioleau’s allies was former DC councilmember and Southeastern University president Charlene Drew Jarvis, who got Prioleau named to the university’s board of trustees, rapidly followed by the university awarding FEI $50,000 for space it could use at one of Prioleau’s training facilities. Jarvis also happened to be the city official who signed for the disputed $1.7 HUD grant on behalf of the Council, subsequently given a clean bill of health by the Rivlin-chaired financial control board.

What makes the Post series, focused on the District’s contracting problems, not on nonprofit accountability, of interest to NCRP? It’s what wasn’t contained in the article that bears of the accountability issues that should concern all nonprofits.

Apparently, neither the Post nor NCRP could find evidence of 990s filed for Prioleau’s Foundation for Educational Innovation after 1997, yet FEI was pulling in government contracts despite lacking this core document that every nonprofit worth its salt (and taking in or spending more than $25,000 annually) files with the Internal Revenue Service.

Maybe the District of Columbia’s contracting officials weren’t motivated to look for a 990, but certainly foundations should have been, right? It’s part of their due diligence process to know that a nonprofit is on the up-and-up at least in terms of filing competently prepared IRS form 990s, attesting to their consumption of public and tax exempt revenues.

Apparently, some foundations were asleep at the switch with Prioleau’s nonprofit. A quick tour of the Foundation Center database reveals that FEI scored grants between 2000 and 2003 from philanthropic grantmakers such as the Sprint Foundation ($80,000 in 2000), the Kansas City Community Foundation ($100,000 in 2001), the Freddie Mac Foundation ($30,000 in 2003), and the Fannie Mae Foundation ($35,000 in 2000, $35,000 in 2001, and $65,000 in 2003). The Utah-based Novell Corporation reportedly made donations to FEI, and the Community Foundation grant might have been additional money from the then Kansas-based Sprint. A 2000 press release from Microsoft claims that it gave FEI a cash grant of $14,000 plus $300,000 in software for one of Prioleau’s ill-fated technology programs. And the Meyer Foundation in DC gave FEI a $75,000 cash flow loan to bridge money from the District’s Housing and Community Development department, likely the funds that the U.S. Department of Housing and Urban Development is demanding the District repay.

One nonprofit executive reading the “Lavish Spending” article gasped at the enumerated FEI misdeeds, indicating that there’s no way her organization would ever imagine treading the path that FEI did. And that’s what NCRP said in the Post about FEI’s potential self-dealing: “if it looks like self-dealing, it should not be done. Most nonprofits would not even contemplate anything like this.”

But something is wrong when so many major corporate and foundation donors seemed to be willing to hand over a check to a guy whose nonprofit hadn’t filed a 990 since 1997 and had a track record littered with accountability problems. DC School Board president Peggy Cooper Cafritz repeatedly warned her public sector colleagues about Prioleau to no avail. Maybe DC contracting officials couldn’t be motivated to act, maybe the foundation program officers at Fannie Mae and Freddie Mac, located within shouting distance of FEI’s purported technology training centers, might not have known the Prioleau story, it’s all possible. Former Federal Reserve vice-chair and founding director of Congressional Budget Office Rivlin obviously didn’t see through the guy. But for all those nonprofits dutifully filing timely 990s, hiring tough-minded firms to do their audits, and watching every P and Q of charitable accountability in order to meet the due diligence requirements of foundations, something appears to have been seriously amiss in the foundation sector’s acceptance of Prioleau’s dubious charitable operations.