Board of Inquiry, Andy Dietz vs. Helen Trapp
Findings and Recommendations
Re: Complaint by Andy Deitz Against Helen Trapp, Former Treasurer of AWMA Date: 4/17/2025
Background
A formal complaint was submitted by Andy Deitz alleging Dereliction of Duty by Helen Trapp, former Treasurer of AWMA. The complaint centered on Ms. Trapp’s failure to provide the AWMA Auditing Committee with access credentials to AWMA’s bank accounts and/or complete accounting information, thereby allegedly impeding the committee’s ability to perform its oversight duties. The complaint also expressed concern that this lack of access could jeopardize AWMA’s tax-exempt status by interfering with financial transparency and timely reporting. In her response, Ms. Trapp noted that treasury practices within AWMA are largely undocumented and typically defined by the serving Treasurer. She stated that she adhered to practices handed down by her predecessor, including the historical norm of having a single signatory on bank accounts and not sharing access credentials. She further cited security and regulatory reasons for not sharing credentials, referencing guidance from the Federal Trade Commission (FTC) and Federal Deposit Insurance Corporation (FDIC).
Ms. Trapp also emphasized that:
• There were no objections or concerns raised by Mr. Deitz or any other Board member during the 2024 AWMA General Board Meeting, which occurred prior to the filing of the complaint.
• All required tax documentation and filings for AWMA were submitted to the IRS in a timely and accurate manner, thereby maintaining compliance with tax-exempt status requirements.
Findings
After reviewing documentation and responses, the Board finds the following:
1. Absence of Formalized Procedures: AWMA currently operates without formal documentation outlining treasury procedures or audit-related access protocols. This gap contributes to differing expectations among leadership roles.
2. Adherence to Precedent: Ms. Trapp followed inherited practices, including not utilizing a second signatory and not distributing online banking credentials. These actions were consistent with past practice, even if not ideal from a governance perspective.
3. Compliance with Security Norms: Ms. Trapp’s rationale for withholding credentials aligns with widely accepted banking security standards and federal guidance discouraging the sharing of user IDs and passwords. “While the FDIC doesn’t explicitly prohibit sharing logins and passwords, it strongly advises against it due to significant security risks and potential violations of privacy and security regulations. The FTCs guidance stresses that sharing login credentials is a significant security risks and encourages businesses and individuals to take steps to protect their information.”
4. No Evidence of Obstruction or Negligence: There is no indication that Ms. Trapp acted with intent to impede the auditing process. The absence of prior concerns raised at the 2024 General Board Meeting, and the timely filing of IRS documents, support her assertion that she maintained AWMA’s financial compliance during her tenure.
5. No Risk to Tax-Exempt Status Identified: Based on the information reviewed, AWMA’s tax-exempt status was not placed at risk due to Ms. Trapp’s actions. The required filings were completed appropriately and on time.
Conclusions
The Board concludes that the charge of Dereliction of Duty is not substantiated. The perceived lack of cooperation with the Auditing Committee stemmed from structural and procedural ambiguities, not misconduct or dereliction on the part of Ms. Trapp. Additionally, there is no evidence that her actions had or could have had a material impact on AWMA’s tax-exempt standing.
Respectfully Submitted,
AWMA Board of Inquiry
Kim Yeager, Jill Lyden, and Laura Swanson