How is your organization different
or similar to the organizations described in Rev. Rul. 63-252?
Our organization is not at all like examples (1), (2), and (3). It is
similar to examples (4) and (5), and most like (5).
The EFEF is a domestic organization, which does charitable work in a
foreign country (Ehume, Imo State, Nigeria, Africa). A foreign organization,
the “Building Committee,” was formed for the purposes of administrative
convenience, and the EFEF controls every facet of its operations. In the
past, the EFEF solicited contributions for the specific purpose of carrying
out its charitable activities in the foreign country, and it will continue
to do so in the future. The EFEF will transmit funds it receives for its
foreign charitable activities directly to the Building Committee only for
purchase of an item, labor, or materials specified by the Board. The
majority of funds expended in the foreign country will be by an EFEF Board
Representative who will be on site where the work is being performed.
Does your organization maintain
control and responsibility over the use of any funds granted to foreign
organizations? If yes, explain in detail how you exercise such control?
Yes, we maintain control and responsibility over the use of all our
funds. We do not grant funds to foreign organizations except to the limited
extent discussed in the response to question a.
Any funds granted to any individual, domestic organization, or
foreign organization must be used within the limits of the corporate
charter, and a record must be kept of their use. All financial records are
available for public inspection and copies are provided upon request.
Will anyone from your organization
make any field investigations to ensure your funds are being used
properly? If yes, how often?
Yes, when funded activities are being performed, a member of our
Board of Directors will go to where the activity is to be performed and
negotiate the labor and materials agreements. Our plan is to have at least
one Board representative in the area throughout the duration of the
activity. The representatives will serve one to two weeks at a time. Funds
from our organization will be in an account at a local bank near Ehume. (The
local bank is affiliated with Citibank in the United States.) Only certain
Board Members will have signature authority to withdraw funds, and any Board
Member withdrawing funds must work within guidelines set by the Board and
file expense reports for all withdrawn funds. No foreign organization will
be given funds except for activities related to the work specified by the
In September 2001, our corporate secretary, Israel Ojimadu, visited
the Ehume Community School, took pictures, videotaped the school, and talked
to teachers and parents. Pictures from this trip are on our web site at
http://ehumefund.tripod.com. Mr. Ojimadu’s report to the Board provided the
basis for our initial planning.
In May 2002, our corporate treasurer, Peter Okeke, visited the Ehume
Community School, took pictures, and appointed a local Building Committee,
members of which are local community leaders willing to volunteer their time
and resources to improve the education of the children of Ehume. The purpose
of the Building Committee is to organize volunteers to help with the work,
to help provide food and water for the workers, and to advise the Board on
procurement of materials and skilled labor. Funds will not be given to the
Building Committee except for a specified activity such as purchasing food
to prepare for the workers. Pictures from his trip and letters of commitment
from community leaders are on our web site.
The planned date for start of repair of Ehume Community School is
January 20, 2003. We anticipate the first phase of work to be completed
within 4 weeks. The second phase will occur about a year later. Our
corporate treasurer, Peter Okeke, will be in Ehume to initiate the work and
will stay for one or two weeks. His time of departure will overlap the
arrival of the next Board Representative from the United States. Mr. Okeke
will put in place the necessary arrangements for procured labor and
materials and give instructions to the Building Committee regarding the work
to be performed.
Does your organization have full
control and discretion over funds donated to you or does the foreign
organization control the funds?
Our organization has full control over funds donated to us. Read our
response to question c for details.
How does your organization ensure
that the funds you donate to Ehume Community School are used for the
purposes that they were intended? Please explain.
All work related to facility construction will be controlled as
described in the response to question c.
Educational supplies and equipment will be purchased from vendors via
agreements between our organization and the vendors.
If, ultimately, we decide to provide financial assistance for
selected impoverished children in the area to attend school, we will
establish guidelines to a local group. The local group will recommend
recipients based on our guidelines, and we will make the selections. We will
require reports on the progress of the recipients, and periodically, a Board
Representative will visit the school to confirm the correct use of the