Limited USA policy and Student Life guidelines leave club leaders confused; donated funds mishandled by CAC

Policies detailed under USA Budget Guidelines (2018-19) and USA Spending Requirements (2018-19) do not detail a step-by-step process of how to handle fundraised money, and this is causing confusion for clubs. A Griffin investigation has found that the regulations in place, in some instances, were not followed by Colleges Against Cancer (CAC). CAC expressed in an email interview with The Griffin that the regulations were not made clear nor well written to their club leaders.

“Myself, as well as the rest of the E-Board, were unaware of these policies and therefore have not followed them the entire year,” CAC President Samuel Viggiani, stated in an email to The Griffin after being sent specific policies following an in-person interview. “I will also add that, after being made aware of these policies by you, I can confidently state that these policies are not well-written and would make the fundraising process a much larger hassle for clubs than it already is and needs to be.”

CAC is known on campus for their large scale fundraising events held to support the American Cancer Society (ACS), a national 501(c)(3) nonprofit organization whose mission is to “free the world from cancer.” CAC is a college chapter program of ACS that traditionally runs Relay for Life. However, Canisius’ chapter recently restructured to accommodate holding additional events, such as Paint the Campus Pink Week. CAC’s procedures of handling donations throughout this year appear to have violated USA Budget Regulations Article 4 Section III, and USA Spending Requirements Article 3 Section III, regarding the handling of profits of fundraisers and the submission of donations.

Thus far, it is estimated CAC has fundraised $11,421.50 for ACS, at the time of this article’s publishing, based on an estimate of Paint the Campus Pink Week given by Viggiani and ACS’s online Relay for Life tracker. It does not include their smaller fundraisers, nor what they may fundraise tonight at the 2019 Relay for Life. Over the year, CAC has been allocated an approximate $16,150.41 by the Undergraduate Student Association (USA), based on Senate finance documents provided to The Griffin by USA. Viggiani and CAC Vice President Nick Guay were both sophomore senators for the 2018-19 year.

CAC and the current USA regulations

“All the cash that we fundraise throughout the year we keep in the locked club room in a locked lockbox. Only a few E-Board members have access to the club room and only one member has access to the box,” Viggiani stated in an earlier email to The Griffin. “As far as how the money will be given to ACS at the end of the year goes, we will simply give the cash to ACS and write a check for the money that is in the club’s Venmo and Cash App accounts. The check for the money that is in the club’s Venmo and Cash App accounts will be written by the club’s Treasure[r], as both accounts are tied to his personal checking account.”

Policies only details regulations for parts of the process of holding a fundraiser, such as to where to store donations, how to submit donations for processing, specifics of check-based donations, and specifics of how allocated budgets can be spent.

USA Budget Regulations Article 4 Section III, focuses on profits, stating: “No profits gathered from fundraising efforts are to be pocketed by members of a club. Rather, profits are to be secured in an envelope or safe-deposit box and stored in the office of Student Life (unless otherwise permitted) until withdrawn for their intended purpose.”

USA Spending Requirements Article 3 Section III focuses on the submission of profits, stating “Submit any donations, checks, and/or cash from fundraising to Elaine Mrugala in the office of Student Life. She will prepare a deposit slip and submit it for further processing for the budget of each specific club.”

Rich Kennedy, advisor to Senate and Assistant Director of Student Life, explained in an interview with The Griffin that there is a process for clubs who want to fundraise. Club leaders should fill out a fundraising event form, found in Student Life, then submit it back to Student Life 30 days in advance of their event. Then, they will check out a lock box that comes with one key, and keep the cash in there, and return the cash in the lock box as soon as possible to Student Life.

When they return the box, if Venmo, CashApp, or PayPal is used, money fundraised through money transfer applications must also be submitted with a transaction log from the application. Then, Elaine Mrugala, Student Life’s administrative associate, will send Public Safety with the money raised to the business office to have the money deposited to the club’s account, and then a check order will be submitted to have the exact amount raised written as check from Canisius College to the organization receiving the donation.

In a previous interview with The Griffin, Viggiani stated that CAC held onto money from the year’s several fundraising events as change for other fundraisers, as they “did not realize how much change we would need” at the start of the year. However, according to the process described by Kennedy to The Griffin, clubs should typically be returning lockboxes to Student Life following an event, and Budget Regulations Article 4 Section iii stipulates that the safe-deposit box should be kept in Student Life until withdrawn from for its intended purpose, although Spending Requirements Article 3 section III does not give any time frame for submitting donations to Student Life.

“We’re at the end of the year now, so it’s a pretty substantial amount of money—cash, just cash. We also do like Venmo and CashApp and there’s a bit of money as well in those accounts,” Viggiani added in an in-person interview.

CAC has, however, not followed either of these specific policies. They have described that money fundraised not only in cash, but through money transfer applications, is handled by students, including up until the students submit a donation to ACS themselves rather than through the college. This means that donations would not go into the club account, which is what the Student Life office uses to track fundraising, through banner reports.

Banner reports track club account transactions throughout a given year. Additionally, a difference that comes between a 501(c)(3), such as Canisius College, making a donation to another 501(c)(3), and a student writing a donation to a 501(c)(3) is the potential for it to be recorded as a tax-deductible donation. Canisius could not receive the same tax-deduction since they do not pay taxes. Kennedy added in an interview that, “I just don’t want students to have to worry about their write-offs,” in respect to students submitting donations.

When told about CAC’s process of writing checks to ACS for Venmo transactions, Kennedy also responded, “They should be sending it to Canisius first.”

Venmo is vague

Venmo’s use by clubs, however, is a largely vague territory. As of this year, there are no policies in USA Budget Regulations or in Spending Requirements regarding the use of Venmo, CashApp, or PayPal for fundraising. The only guidelines given to clubs are done so verbally by Student Life when planning an event, and these guidelines are just to submit a transaction list when submitting cash transfer application-based donations. These guidelines are not included on the fundraiser form (called “Canisius College Fund Raiser Policy”) that clubs submit when planning fundraisers. CAC however, developed their own policies as to the use of money transfer applications for fundraisers in order to prevent any potential for abuse. However, according to Senate Finance, clubs are not required to keep a log of (or submit) cash transactions.

“One of our e-board members, we had people Venmo that person directly, he made sure he had nothing in there so that anything that came in would then all be taken out. After the event, all of it taken out, a check written,” Guay, the vice president, said in an interview with The Griffin. Guay detailed that, in addition to the individual who is handling Venmo for that event clearing out their balance prior to the event, that individual also would not use their Venmo account for personal reasons while accepting transactions for the event, and a specific term was asked to be used in transactions to make clear what it is for. While these safeguards were created and are used by CAC, it is not apparent that USA or Student Life asks for these safeguards.

Additionally, Cameron Rosenecker, the outgoing executive vice president for business and finance (VPBF) of Senate, who helped edit this year’s USA regulations and guidelines, added about Venmo via email: “We have discussed a Venmo policy, and so has Student Life. Usually it is a club’s prerogative if it chooses to use Venmo, but at this time, the legal and professional aspects of creating a Venmo account for each club on campus are too risky and costly, and they remove the current risk-mitigating controls that Student Life has in place regarding using club cards and collection cash/payment from students. That being said, we do need to discuss this topic further and you can expect to see there being a new list of Budget Regulations next year around Venmo transactions.”

Fundraising audits are not conducted

Club fundraising is kept track of through the banner reports, according to Kennedy. Clubs are not asked or audited at the end of the year of their fundraising, even if part of their club’s mission is fundraising.

While CAC greatly focuses on education and awareness of cancer, a large part of their mission is to fundraise for ACS. CAC has stated that their goal has been to fundraise back 50% of what they spent on any event, and so far, they have succeeded on this in their two largest events: Paint the Campus Pink Week and Relay for Life (which is only in preregistration stages). Paint the Campus Pink Week was funded primarily by CAC’s initial allocation of $7,000, which was spent in full on the week that consisted of several different events. According to Viggiani, a rough estimate of the amount fundraised in that week was $5,300, of which he estimates was 65% from Athletics’ sponsored event, and 35% from donations/money CAC received throughout the week. For Athletics-sponsored events, Athletics handled the donation of that money to ACS, according to Viggiani. CAC’s Relay for Life appeal totaled $7,986.91, and so far for pre-registration and donations, Relay for Life has raised $6,121.50, according to, Relay for Life’s official website.

“I think I developed a bit of a reputation with Senate, I’m very hard on other clubs and I can be hard on other senators at times, you know, ’cause I hold myself to such a high standard, and I hold everyone else to the same standard. So yeah sure, like our goal, like I said earlier, is to fundraise half of what we spend, and that’s a very reasonable and achievable goal. That’s a good goal to have,” Viggiani said, “If a club’s sole purpose or joint purpose is to fundraise, such as ours, sure, Senate should keep track. Cause, if that’s the goal, to fundraise half of what you spend, and the club isn’t doing that, then again, that’s just another way for Senate to you know have a bit more control of what’s going on.”

When asked why Senate does not audit or ask for a fundraising report from clubs, Rosenecker responded via email, “Because it is a club’s decision whether or not they want to fundraise. If clubs wish to share that information with Senate at any meeting they are welcome to, and if clubs wish to plea for additional initial allocation funding at a Senate meeting or Finance Board meeting, they are always welcome to as well. All Senate meetings are open as you know. That being said, we can, and the VPBF does, check to see all of the inflows of money into a clubs account throughout the year and is able to easily trace what the purpose of that inflow is, so if I, or now James, wishes to take fundraising into account, it would not be hard to find it within all clubs’ Banner Printouts.”

Comment from USA

Rosenecker additionally provided the following comment to The Griffin regarding CAC’s apparent failure to abide by policy:

“The regulations do need to be rewritten, and club leaders need to take a greater initiative to follow them. That being said, Sam Viggiani deserves as much of our trust as any other club leader because he has demonstrated an intent to fundraiser for the betterment of his club and those with cancer. Many clubs collect cash throughout the year, and although they may not find it easier to deposit the cash and then take out a club card to spend the cash, that’s probably the direction that we will be headed. That way there is more traceability of spending. I cannot speak for the new and current VPBF, but having now completed the role, I will be working with VPBF Garvey to refinish some of these regulations so they are easier to follow and enforce.”

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