Purchase Card Users' Guide
 Revision Narrative
12/01/98
Contents:
Introduction  Program Overview 
Customer Cardholder
Approving Official (AO)  Agency Program Coordinator (APC) 
Dispute Office Contact (DOC)  Comptroller Organization 
Procurement Cardholder Representative  Logistics
Chief Information Officer (CIO)  Technical Implementation Panel (TIP) 
Purchase Card Account  Customer Request 
Screening  Shopping and Ordering 
Placing the Purchase Card Order:  Receipt
Reconciliation  Disbursement 
Reporting AuditCompliance
Records Retention and Disposition  Leaving NASA or Turning in Card 
Penalties for Abuse of Procedures  Appendix
Revision Narrative (12/01/98)  * NationsBank  (link to info. and forms)
Operating Policy and Procedures for the use of the
Government Purchase Card for Micro-Purchases
at John F. Kennedy Space Center
Revision 8.0
December 01, 1998
Purchase Card Users' Guide
Operating Policy and Procedures for the use of the
Government Purchase Card for Micro-Purchases
at John F. Kennedy Space Center
APPROVAL PAGE
 
 

APPROVAL:
 
 

________________________

Marlo Krisberg

Chief, Operation Support Office
 

Purchase Card Users' Guide
Operating Policy and Procedures for the use of the
Government Purchase Card for Micro-Purchases
at John F. Kennedy Space Center
 
 
 
 
 

Introduction Back to Contents

The establishment of the KSC Purchase Card Program is welcomed by many, especially customers who will receive their micro-purchases (purchases valued at $2,500 or less. In record time -- from hours to a few business days. But in order for this program to succeed, it must be built on cooperation, coordination, and widely-communicated internal controls to ensure its integrity and accountability.

The Cardholder will play the key role in maintaining the program's integrity and success. Coupled with the Approving Official, the Cardholder will embark on providing a new benchmark for quality service and flexibility of micro-purchases.

The following operating policies and guidelines will introduce the purchase card user, and program participants to the seven process steps of the Purchase Card program at KSC. Also, these policies will detail responsibilities, identify ownership, and introduce various customer and program tools to ensure a smooth running and successful program.

Program Overview Back to Contents

The Purchase Card Program can be divided into seven distinct functions. Each sequential function contains specific guidelines, that if not met, the process will not proceed to the next function. Also, it is the program's intent to ensure internal control without compromising customer satisfaction. Finally, two additional steps are included for Reporting and Audit Compliance.

Each function contains various participants who facilitate the process. Each participant has clear and distinct responsibilities: the Customer, Cardholder, Approving Official (AO), Agency Program Coordinator (APC), Dispute Office Contact (DOC), the Comptroller Organization, Procurement Cardholder Representative (PCR), Logistics, and Technology Implementation Panel (TIP).

Customer Back to Contents  * Revision 12/01/98

The Customer is the individual within the Cardholder's directorate that expresses a need for an item. The Customer is responsible for:

· Complying with the following Chief Information Officer's (CIO) Directives: Latest version all Executive Notices.

See below for pertinent Executive Notices.

01-95 "Conditional Freeze On Purchase Of Information Technology", Latest version EN 01-95

NASA STD-2804  "Minimum Office Automation Software Suite Interface Standards and Product

Standards. Latest version in Word.

NASA STD-2805  "Minimum Hardware Configuration" Latest version in Word.

· Seeking Chief Information Officer (CIO) Approval for Information Technology Purchases.

· Seeking Technical Implementation Panel (TIP) Approval for Information Technology (IT) purchases utilizing ROS funding for organizations such as AC, CC, EO, HM, IM, OP, etc.

Cardholder Back to Contents * Revision 12/01/98

The Cardholder is the individual to whom a Government Purchase Card is issued. Cardholders are issued a delegation of authority from the Procurement Officer. The Cardholder is responsible for:

· Maintaining control/custody of the purchase card; only the Cardholder may utilize the card.

· Purchasing only authorized items in compliance with established KSC procedures, pertinent regulations/guidance as listed in this document and other regulating controlling polices and funding procedures. Please note that all data under the purchasecard program (including the Cardholder's name and items purchased) is releasable under the Freedom of Information Act with the exception of the Cardholder account number and Approving Official account number.

· Ensuring that adequate funds are available and certified prior to placing an order.

· Training customer on proper completion of Section 1 & 2 of the Purchase Record Purchase Record Document

· Maintaining a Purchase Card Records and a Cardholder Purchase Log of all card purchases and retaining all documents (e.g. charge slips, shipping invoices, etc.) pertaining to the purchase.

· Resolving all discrepancies with the vendor(s), and/or purchase card company, and reconciling the monthly statement. Discrepancies that cannot be resolved between the vendor(s) and the purchase card company should be brought to the attention of the Dispute Office Contact (DOC).

· Reporting immediately lost or stolen purchase cards to the Agency Program Coordinator (APC), Approving Official (AO), and the purchase card company.

· Providing in a timely manner to the Comptroller Organization the required documentation and funding/accounting data as detailed in this plan or request.

· Providing in a timely manner to the Chief Information Officer (AI) * any requested information related to IT. 

Approving Official (AO)Back to Contents

The AO is the person who reviews and approves the cardholder's monthly statement of purchases. The AO shall be the cardholder's supervisor or a higher level individual. In order to avoid statement processing delays and late payment penalties, the AO must designate an Alternate Approving Official in his/her absence.

Agency Program Coordinator (APC) Back to Contents

The APC for KSC is appointed by the Procurement Officer to serve as the liaison between purchase card program participants and the purchase card company. The APC is responsible for:

· Coordinating purchase card applications; establishing accounts in accordance with NFS 1813.70; issuing and destroying purchase cards; changing dollar limitations or authorizing amounts in cooperation with the Comptroller Organization; training purchase card program participants; serving as the Dispute Office Contact (DOC); and overseeing the purchase card program.

Dispute Office Contact (DOC) Back to Contents

The DOC is the focal point appointed by the Procurement Officer for coordination of the tracking and resolution of disputed purchases. The DOC shall coordinate, process and monitor resolution of disputed purchases, credits, or billing errors. The DOC should only become involved in a disputed purchases when an impasse has been reached between the cardholder, the vendor, and/or purchase card company.

Comptroller Organization Back to Contents

The Comptroller Resources Project Offices [GG-C1, GG-C2, GG-C3] are responsible for generating and maintaining the financial data on the Purchase Card Register, coordinating with customer organizations on funding levels per purchase card for each fiscal year, and establishing Material Requisitions (MR).

The Financial Management Division is responsible for the disbursement of payments in accordance with the Prompt Payment Act. Also, the Financial Management Division shall maintain only the required disbursement documents such as the reconciled Statement of Account approved by the Cardholder and Approving Official, Statement of Questioned Items (if applicable), and the Multiple Object Class Code/FMC Reconciliation Form (if applicable) involved in the disbursement of funds.

Procurement Cardholder Representative(PCR) Back to Contents

The PCR appointed by the Procurement Officer will assist the Cardholder in obtaining pertinent information regarding a required buying source or any other purchase card questions. The PCR will provide assistance in obtaining the phone number for a particular GSA schedule.

Logistics Back to Contents

The Joint Base Operations And Support Contract (BOSC) logistics personnel will be responsible for the primary screening of proposed purchases, tagging of controlled property, and acting as the central delivery point at KSC. After receiving notification from the cardholder, NASA/LO-N1 will tag the controlled equipment that was picked up in person at the vendor's location by the cardholder.

Chief Information Officer Back to Contents

The CIO is responsible for the approval/disapproval of all purchases of IT equipment and software for all organizations.

Technical Implementation Panel (TIP) Back to Contents

The TIP is responsible for the approval/disapproval of all purchases of IT equipment and software for organizations such as GG, CC, EO, HM, IM, OP, PA, etc. utilizing ROS funding.

Back to Contents

· To establish a purchase card account, the APC shall query the directorates with the support of project RMO Offices to specify the: 1) number of purchase cards required; 2) individuals assigned to each purchase card; 3) Approving Official for each Cardholder; and 4) authorization limits for each card.

· The Comptroller Resources Project Offices will generate and maintain jointly with the APC a Purchase Card Register. The Accounting Classification Number (ACN) line will be established up front and the directorates will commit the entire balance of the MR at the beginning of each fiscal year. Funds not obligated by September 15 of the present fiscal year will be decommitted. It is the Cardholder's responsibility to report to the Financial Management Division all purchases incurred up to September 15 so obligation can properly be made. A new MR will be established at the beginning of the new fiscal year. There will be no rollover of unobligated funds.

· The Procurement Officer will issue a "Delegation of Authority " to the Cardholder. This document authorizes the Cardholder to conduct micro-purchasing on behalf of the U.S. Government.

· The Purchase Card will be issued to the Cardholder once he/she has attended a 4-hour training class on the Purchase Card Program. The APC shall be responsible for distribution of all Purchase Cards and ensuring that all Cardholders attend training prior to the receipt of the Purchase Card.

Back to Contents

At this stage, the cardholder has been trained, an MR established, and the Cardholder is in receipt of a Purchase Card with their name and account number embossed on the front of the card. The following details the Customer Request process:

· The Cardholder is approached by a customer to purchase an item(s) utilizing the Purchase Card:

Þ The customer completes Sections 1 and 2 of PurchaseCard Purchase Record [Appendix A] Purchase Record Document as indicated and forwards a fax or hardcopy to the Cardholder for processing.***

***Section 1: Chief Information Officer (CIO) Approval is required for all Information

Technology purchases for all directorates. CIO Approval is obtained by faxing a copy of the  Purchase Record to 7-1745 Attn: Richard Sharum (Headquarters Room 2537, Mail Code AI). The CIO will return the Purchase Record to the Customer within 24 hours after receipt. Once approved the Customer forwards via fax or hardcopy to the Cardholder for processing. Note: If ROS funded continue to Section 1A.

***Section 1A: Technical Implementation Panel (TIP) Approval is required for all Information Technology purchases for organizations such as GG, CC, EO, HM, IM, OP, etc. utilizing ROS funds. Your organizational TIP representative shall approve via signature the IT purchase prior to submittal to the TIP.

TIP Approval is obtained by faxing a copy of the Purchase Record to 7-8807 ATTN: Bill Caudle (FF-Y, Headquarters Room 2607). The TIP will return the Purchase Record to the Customer within 24 hours after receipt. Once approved the Customer forwards via fax or hardcopy to the Cardholder for processing.

Back to Contents

Screening of the customer request is accomplished by the Cardholder, J-BOSC Cataloging, and the Procurement Cardholder Representative (PCR) as detailed below:

Cardholder Screening: Back to Contents

Upon receipt of the customer's Purchase Record, the Cardholder will screen the requirement as follows and complete Section 3(A) of the Purchase Record Purchase Record Document

· IS FUNDING AVAILABLE? The Cardholder checks the Cardholder Purchase Log's [Appendix B] Cardholder Purchase Log balance column to verify if there is sufficient funding. If funding is not available, the Cardholder informs the customer to issue a purchase request to the Procurement Office.

· AUTHORIZED PURCHASE? The Cardholder refers to the Unauthorized Purchase List [Appendix C] Unauthorized Purchase List to verify whether the item(s) is an authorized purchase. If the answer is NO, the Cardholder informs the Customer to issue a purchase request to the Procurement Office.

Cardholder Screening is now complete. The Cardholder simultaneously forwards the Purchase Record to J-BOSC Cataloging. For additional detail, refer to J-BOSC Cataloging section below.

J-BOSC Cataloging: Back to Contents * Revision 12/01/98

Upon receipt of a Purchase Card Purchase Record from the Cardholder, J-BOSC Cataloging will screen and process the request in accordance with Federal Acquisition Regulation (FAR) Part 8 as follows:

· If the item(s) is available through Kennedy Inventory Management System (KIMS) or Federal Supply Sources (MUFFIN, NIB, NISH, etc.), the Purchase Card Purchase Record will be processed by J-BOSC and the items delivered to the Customer. The Purchase Card process would stop here.

· If the item(s) is not available via KIMS or Federal Supply Sources, J-BOSC cataloging will complete Section 3(B) of the Purchase Card Purchase Record to reflect the GSA Schedule Contract (if applicable), and provide the Federal Supply Code (FSC).

· The J-BOC will determine if item(s) will be controlled property per NHB 4200.1 Paragraph 3.101b and the KSC Sensitive Items List.

 Check supply before you start the Buying processJ-BOSC Supply

Mandatory GSA Schedules

There is no requirement for mandatory GSA schedules for purchases 2,500 or less [Federal Acquisition Regulation Part 8.404 (b)]. Based upon this screening, the Cardholder will determine whether this purchase may be on an optional GSA Schedule. If so, the cardholder may contact their Procurement Cardholder Representative [Appendix E] Procurement CardHolder Representative List for assistance in obtaining specific contract details. However, the Cardholder shall comply with FAR Part 8.001 Priorities for use of Government supply sources. Read the required priorities in FAR Part 8 . The Cardholder should screen the purchase through GSA Advantage. GSA Advantage!(TM) offers on-line shopping that enables the cardholder to place orders for items on an optional Federal Supply Schedule (FSS). The Cardholder may find it is cost advantageous to purchase on an optional FSS.

Procurement Cardholder Representative (PCR):

The PCR appointed by the Procurement Officer will assist the Cardholder in obtaining pertinent information regarding a required buying source or any other purchase card questions. Procurement reserves the right to screen all proposed purchases for adherence to regulations established in this Users' Guide.

Back to Contents

General Information:

· Micro-purchases of $2,500 or less are not set-aside for small business and do not have to be placed competitively. Buy American Act is not applicable.

· Splitting of a requirement to fall within the $2,500 limit is prohibited. According to the Federal Acquisition Regulation (FAR) Part 13.003 (d), "Requirements aggregating more than the simplified acquisition threshold or the micro-purchase threshold shall not be broken down into several purchases that are less than the applicable threshold merely to permit use of simplified acquisition procedures, or to avoid any requirements that apply to purchases exceeding the micro-purchase threshold." The total of a single purchase to be paid for using the card may be comprised of multiple items and cannot exceed the authorized single purchase limit. Purchases will be denied if the authorized single purchase limit is exceeded. Payment for purchases may not be split in order to stay within the single purchase limit.

Examples of split awards include a procurement with three line items that totals $3,000. You may not split the procurement and order two of the line items one day for $2,400 and then turn around and order the other line item the next day for $600. An organizational split award constitutes establishment of a large requirement at the beginning of the fiscal year and purchasing the items individually over the year to avoid the regular procurement process. Splitting of a requirement to fall within the $2,500 limit is prohibited.

· Distribute purchases equitably among qualified vendors to avoid the appearance of favoritism.

· By placing a Purchase Card purchase, the Cardholder is stating the purchase price of items is fair and reasonable.

· If the vendor will not accept a Government Purchase Card, a purchase request must be forwarded to the procurement office for processing.

· Partial deliveries and back-ordering of item(s) is discouraged.

· COD shipments are not allowed.

· If assistance is needed in locating a vendor, the Central Industry Assistance Office at 867-7353 will provide help.

Placing the Purchase Card Order: Back to Contents

· The cardholder may place the order via phone or in person. When placing the order, the Cardholder should provide and confirm the following information (if applicable):

a. Notify vendor of tax exempt status (Certificate Number 15 00 052729 51C). If the vendor requests a copy contact Barbara Hickle (OP-AMO) at 7-7345.

b. Confirm with vendor the total cost of the purchase. This cost should include the cost of item(s) as well as the associated shipping and handling charge.

c. If purchasing IT items (computers, monitors, or printers)**, verify with the vendor that these items are Energy Star compliant and annotate the PurchaseCard Purchase Record.

Purchasing of non-compliant equipment requires prior approval from the Chief Information

Officer. **Servers are exempted.

d. Verify that the vendor agrees to charge the purchase card only after shipment.

e. Notify vendor that no partial deliveries are authorized.

f. If the item IS A CONTROLLED ITEM as indicated by BOC screening, obtain from the vendor WARRANTY information (length, number, and company responsible) and annotate in Section 4 of the Purchase Record. The cardholder shall forward to your property custodian this information to be input in NEMS Control (LO-N1).

g. If the item IS A CONTROLLED ITEM and is being shipped, instruct the vendor to mark the box as follows:

NASA, J-BOSC Receiving, M6-744

Property Management

[Cardholder Name, Building, Room Number]

Kennedy Space Center, FL 32899

h. If the item IS A NON-CONTROLLED ITEM and is being shipped, instruct the vendor to mark the box as follows:

NASA, J-BOSC Receiving, M6-744

[Cardholder Name, Building, Room Number]

Kennedy Space Center, FL 32899

i. To document order placement, the Cardholder will complete the applicable items in

Section 4 of the Purchase Record and annotate the Cardholder Purchase Log.

Back to Contents

General Receipt Information:

· If the item(s) is a controlled item and picked up at the vendor's location by the Cardholder in lieu of being shipped, the Cardholder is to notify NASA LO-N1 (1-1452) for tagging.

· Upon receipt of the item(s) at KSC, visual inspection of the shipping container will be accomplished by J-BOSC Receiving. All controlled items will be tagged, the appropriate data will be transmitted to NEMS Control (LO-N1), and the items will be delivered to the Cardholder. All non-controlled items received will be delivered to the Cardholder.

· Once the item(s) has been delivered, the Cardholder should check for damage, verify contents, and quantity order against the relevant Purchase Record as follows:

Þ IF THE ITEM(s) IS UNDAMAGED AND CORRESPONDS TO THE ORDER, the Cardholder contacts the Customer to arrange for pick-up. Please keep all of the shipping documents, and attach the documents/receipt to the Purchase Record.

Þ IF THE ITEM(s) IS DAMAGED, the Cardholder retains the item(s) with all packaging,

contacts the vendor for resolution and Freight Traffic (7-3501) to process a freight claim

for damages.

Þ IF THE ITEM(s) DOES NOT CORRESPOND TO THE ORDER, the Cardholder retains the item(s) with all packaging, contacts the vendor to correct the discrepancy, completes KSC Form 7-248 to ship the item(s) back, and informs J-BOSC Shipping (7-7998) when item(s) is ready for pick-up. The vendor will be responsible for the associated shipping cost. J-BOSC Shipping will assist the Cardholder in this matter.

Back to Contents

Each month, the Cardholder will receive a Statement of Account from the Purchase Card Company. The statement will detail transaction date, vendor, and purchase cost. The Cardholder has a total of 5 working days after receipt of statement to reconcile. At this point, the Cardholder should:

· Verify each charge on the Statement of Account against the Cardholder Purchase Log.

Þ IF THE STATEMENT IS CORRECT, the Cardholder signs and dates - on the reverse side- and then forwards it to the Approving Official.

Þ IF THERE IS A DISCREPANCY, the Cardholder first contacts the vendor for corrective action, and completes a dispute form available at  NationsBank  The original form is submitted to NationsBank and a copy with the Statement of Account is forwarded to the Approving Official. Keep a copy of the completed form in your file.

· Verify the Object Class Code [Appendix I] Objects Class Codes and Functional Management Code (FMC) [Appendix J] Functional Management Codes of the items purchased.

Þ IF THE OBJECT CLASS CODE AND THE FMC ARE THE SAME AS DESIGNATED ON THE AUTHORIZING MR, the Cardholder does nothing.

Þ IF THE OBJECT CLASS CODE AND/OR THE FMC IS DIFFERENT FROM WHAT IS DESIGNATED ON THE AUTHORIZING MR, the Cardholder summarizes the variation on the Multiple Object Class Code/FMC Reconciliation Form [Appendix K] Class Codes Reconciliation Form . This form along with the Statement of Account is forwarded to the Approving Official. Keep a copy of the form in your file.

· The Approving Official has a total of 5 working days to review, sign and date the Statement of Account. Upon completion, the Approving Official forwards the original reconciled Statement of Account, a copy of the Statement of Questioned Items (if applicable) and the Multiple Object Class Code/FMC Reconciliation Form (if applicable) to GG-B-B1 for payment.

· If the Approving Official determines any of the purchases were improper, the APC is notified to take action. Please note: The Cardholder will be held personally liable for unauthorized purchases [Appendix C] - which may result in restitution, disciplinary action and/or dismissal.

Back to Contents

Financial Management Division:

· Upon receipt of the reconciled Statement of Account, Dispute Form (if applicable) and Multiple Object Class Code/FMC Reconciliation Form (if applicable), Accounts Payable will obligate, cost and disburse funds.

· Accounts Payable will ensure payments are made in accordance with the Prompt Payment Act and will submit proper documentation to the purchase card company for invoice adjustments.

· Accounts Payable will only disburse funds for authorized and approved purchases as indicated by the Approving Official. If discrepancies do exist, payment will be made in future months once the purchase has been approved.

Back to Contents  * Revision 12/01/98

By September 15, the Cardholder shall report to the Financial Management Division all purchases incurred up to September 15 so obligation can be properly made. Additionally, the cardholder shall report to Chief Information Officer (AI) any requested information related to IT items (computers, monitors, and printers) purchased for the fiscal year.

Back to Contents  * Revision 12/01/98

To ensure the integrity of the Purchase Card Program at KSC, the Procurement Office will establish a cross-directorate team that will include members from the Procurement Office, the Administration Office, the Office of the CIO, the Comptroller Organization, and the Logistics Directorate. The team will be responsible for auditing on a regular basis or as needed a statistically valid sample of the Purchase Cardholders for compliance to the spirit and intent of the preceding policies and procedures. The team will also audit on a regular basis the purchase statements for Approving Official signature and conduct interviews with Approving Officials to verify that proper review is given to the purchases. Problem areas found during the audits will be reviewed more frequently, and on a random basis. Problem areas will result in more direct review of individual purchases, at a minimum, to revocation of the bankcard. The Audit and Compliance Team will issue regular reports to Senior Management on the compliance and status of the Purchase Card Program. The team will also be responsible, for updating and augmenting this plan, and issuing "lessons learned" on a periodic basis. Also, the Audit Compliance team will be responsible for establishing and maintaining metrics to communicate performance.

Records Retention and Disposition   Back to Contents

The retention period is outlined in Federal Acquisition Regulation (FAR) Part 4.805 and NPG 1441.1C, Schedule 5, Code 5100, item 1A.2.

The Cardholder is required to retain all records for each Fiscal Year (FY) in a file or notebook at his/her work site to the end of the next FY. Each FY's records shall be maintained in a separate file.

At the end of the subsequent FY, the Cardholder may turn the prior year's completed file over to their Organizational Records Officer for archiving.

If the Cardholder and/or the Approving Official (AO) leaves NASA:

-The Cardholder may leave all records at the AO's work site or the Cardholder may forward all records to the Organizational Records Officer.

The AO will follow the above procedures.

Leaving NASA Or Turning in Card

The Cardholder is required to notify in writing the APC/Allen J. Miller/OP-OSO that he/she is leaving NASA and will be turning in his purchase card on the appropriate date.

The Cardholder is required to reconcile his records and inform his AO of all pending actions. The AO shall be prepared to sign all future invoices for reconciliation. If no further actions are required the Cardholder shall follow: Records Retention and Disposition. Once all actions have been accomplished The AO shall follow Records Retention and Disposition procedures.

Penalties for Abuse of Procedures

Use of the Purchase Card requires adherence to the general and specific instructions governing the program which are contained in the Purchase Card Users' Guide. You are cautioned that making cumulative expenditures in excess of the funding limit on your authorizing Material Requisition may be a violation of the Anti -Deficiency Act. The act provides for criminal penalties for knowingly and willfully violating this restriction. Splitting of a requirement to fall within the $2500 limit is prohibited. The Cardholder and Approving Official may be held personally liable for unauthorized purchases, which may result in restitution or disciplinary action.

Appendix Back to Contents * Revision 12/01/98

· A. Card Purchase Record Purchase Record Document

· B. Cardholder Purchase Log Cardholder Purchase Log

· C. Unauthorized Purchase List Unauthorized Purchase List

· D. (Reserved)

· E. Procurement Cardholder Representative List Procurement CardHolder Representative List

· F. (Reserved)

· G. (Reserved)

· H. (Reserved)

· I. Object Class Code List Objects Class Codes

· J. Functional Management Code (FMC) Functional Management Codes

· K. Multiple Object Class Code/FMC Reconciliation Form Class Codes Reconciliation Form

* Latest Revisions 12/01/98  Back to Contents

* "Credit Card Users' Guide" is changed to Purchase Card Users' Guide and the terms "credit card" or "credit card purchase" is changed to Purchase Card or Card Purchases -Throughout the entire Guide.

* CIO Directives updated to current on-line version -Page 4..  CIO reserves the right to request information on any IT purchase - Page 5 and 13.

*BOC changed to J-BOSC: Joint Base Operations And Support Contract -Throughout the entire Guide.

* On-line link to  J-BOSC Supply  items. - Page 8.

*Appendix H (Statement of Questioned Item Form) deleted.  Changed to on-line link to general information and on-line Dispute Form available at NationsBank  - Page 1, 10, and Appendix.

*Audit Compliance

Semiannual audits changed to audits on a regular basis or as needed - Page 13.