Special Investigation Finds More Than $122,000 in Improper or Unsupported Disbursements by Guttenberg Chamber of Commerce

We're here to cover the moments that matter. Help us keep showing up. GUTTENBERG, Iowa — A special investigation of the Guttenberg Chamber of Commerce found $5,086.85 in improper disbursements and another $116,995.61 in disbursements that could not be adequately supported with documentation, according to a report released Wednesday by Iowa Auditor of State Rob Sand. The investigation examined Chamber financial activity from Oct. 1, 2020, through Oct. 31, 2024, after Chamber officials raised concerns about financial transactions processed by former Chamber Director Brandie Tomkins and requested the state auditor's review. The report identified $122,082.46 in improper and unsupported disbursements. After accounting for $2,700 in Chamber cash turned over to the Guttenberg Police Department, the report lists a net amount of $119,382.46. The auditor's office cautioned that the findings may not represent the full extent of questionable financial activity. Because the Chamber did not adequately maintain supporting records, investigators could not determine whether additional transactions were improperly recorded, additional funds were improperly disbursed or additional collections were not deposited. "This special investigation identified several internal control weaknesses," the report said. The report was filed with the Clayton County Sheriff's Office, the Iowa Division of Criminal Investigation, the Clayton County Attorney's Office and the Iowa Attorney General's Office. Former Director Handled Broad Range of Financial Duties Tomkins was hired as Chamber director Oct. 12, 2020. Her responsibilities included collecting receipts, making bank deposits, preparing and signing checks, handling payroll, reconciling bank accounts and preparing financial reports. Auditors identified the concentration of duties as a significant internal-control weakness. The Chamber Board was responsible for financial oversight, with disbursements generally expected to be supported by invoices or other documentation and approved by the board. After approval, Tomkins prepared and signed checks, which were supposed to be countersigned by a board member. Auditors found those safeguards were not consistently followed. Chamber officials told investigators that bank reconciliations were not performed during Tomkins' tenure, and the board did not regularly review monthly bank statements. Cash Withdrawals Raised Questions One $4,900 cash withdrawal dated Feb. 29, 2024, included a memo referencing the German Market, Smoke Off, Ghouls Night Out and Celebrate Guttenberg. The withdrawal occurred months before the events, and Chamber officials could not explain it. Auditors classified the withdrawal as improper. When asked about the withdrawal, Tomkins said she was "just doing what I was told." She said a former board president wanted money withdrawn early in the year while funds were available, describing it as similar to a security deposit. The auditor did not consider the explanation sufficient. Nine additional cash withdrawals totaling $30,269.76 lacked supporting documentation. Those transactions were classified as unsupported rather than improper because auditors could not determine whether they were legitimate. Those withdrawals were classified as unsupported rather than improper because investigators could not determine from the available records whether they were legitimate Chamber expenses. Debit Card Purchases Included Unsupported Transactions The Chamber's debit card, which was in Tomkins' possession, was used for 433 transactions totaling $45,980.69. Auditors classified $67.69 as improper and $15,827.79 as unsupported. Among the transactions was a $50 DraftKings charge that lacked supporting documentation and was not considered reasonable for Chamber operations. Tomkins told auditors she did not have a DraftKings account and would not know how to use it. A $25.63 purchase at Bender Foods included powdered sugar and three individual cold-cut sandwiches. Auditors determined the powdered sugar was a reasonable Chamber expense for a Valentine's Day cookie fundraiser but classified the $7.69 spent on sandwiches as improper because Chamber officials said the food was for staff or officials and was not served to the public. Auditors also identified seven unsupported Amazon purchases totaling $230.70. Auditors obtained detailed transaction information from Amazon, including item descriptions, shipping addresses and customer email information. The report said some vinyl purchased through Amazon may have been used to make shirts for Chamber events, but investigators could not determine whether the purchases were for Chamber operations or personal use. The report noted that Tomkins owns a clothing boutique in Guttenberg, making it impossible for auditors to establish the purpose of those purchases from the available records. Payments to Former Director Could Not be Fully Verified The Chamber issued 80 checks totaling $68,224.22 to Tomkins, including $53,090.08 in payroll and payroll-related checks and $15,134.14 in non-payroll payments. For much of the period, the Chamber could not provide records establishing Tomkins' approved pay rate and expected hours. Officials also gave conflicting descriptions of her expected workload, ranging from 15 to 20 hours per week to full time. No timesheets were located for that period. As a result, auditors classified $51,055.08 in payroll disbursements as unsupported. Tomkins told auditors she completed timesheets and presented them with payroll, while a board member said they signed paychecks but never saw the timesheets. Tomkins also received monthly cell phone and insurance stipends. Auditors considered those payments reasonable. After the Chamber and city entered into a 28E agreement in September 2022, the director became a shared employee and the city processed payroll. Auditors found that the later payroll records documented the approved rate, expected hours and number of checks. Of the $15,134.14 in non-payroll checks issued to Tomkins, $9,061.14 in reimbursements was classified as unsupported because receipts, invoices or other documentation were unavailable. Reimbursements Lacked Receipts and Other Records The 30 non-payroll checks issued to Tomkins totaled $15,134.14 and represented reimbursements for purchases of supplies and other expenses. Auditors said the Chamber's records generally contained only the notation written on the check memo line. Receipts, invoices or evidence of board approval were not available for 32 reimbursements identified in the report. The $9,061.14 represented by those reimbursements was classified as unsupported. Tomkins told investigators that she purchased items for Chamber events and was reimbursed for those purchases. She also said she was reimbursed for mileage only once or twice. When asked about the lack of documentation, Tomkins said records had remained at the Chamber office after she left. The report said a Chamber board member and the board member's spouse told auditors there were records in the office after Tomkins' departure, but the records were disorganized and they could not determine what was Chamber-related and what was personal. Cash From Events Also Could Not be Fully Tracked The investigation found broader problems with the Chamber's ability to document revenue. The Chamber received money from membership dues, donations and fundraisers, but auditors said officials could not provide sufficient documentation showing the number of memberships, donations received or amounts raised through fundraisers. The Chamber also lacked sufficient documentation showing the dates and amounts expected to be collected. As a result, auditors said they could not verify that all collections were properly received and deposited. The report described one event in early September 2024 at which cash was collected but, based on the Chamber's review, no corresponding deposits were made into Chamber bank accounts. Winners of the event had donated their prizes back to the Chamber, totaling $600. After reviewing the Chamber's records, officials filed a police report Oct. 17, 2024. Three sealed envelopes were turned over to the Guttenberg Police Department. The envelopes were marked "ghouls" and "$600," "smoke out" and "600," and "German market" and "$1,500." According to police officials cited in the report, the amounts written on the envelopes matched the cash inside. The three envelopes contained $2,700 in total. Because the cash was in law enforcement possession, auditors classified the $2,700 as a repayment. Accounting Records Contained Discrepancies Auditors also found discrepancies between the Chamber's accounting records and deposits into its bank accounts. For calendar year 2022, three receipts were entered twice in the accounting system, overstating reported revenue by $3,616. In 2023, one receipt totaling $1,666.66 was deposited into a Chamber bank account but was not entered into the accounting system, resulting in an understatement of recorded revenue by that amount. In 2024, four receipts were entered twice, overstating revenue in the accounting system by $7,303.85. The auditor's office concluded that the amounts reported as receipts in the Chamber's accounting system did not agree with the amounts deposited in its bank accounts. The problems extended to board records. The Chamber could not provide minutes for 34 of 49 meetings during the period reviewed, according to the report. The report cited Iowa law requiring the meetings to be documented and said the missing minutes made it more difficult to establish what actions the board had approved. Auditor Recommends Tighter Controls The auditor's recommendations focused largely on separating financial duties so one employee does not control receipts, disbursements, payroll, cash, bank accounts and financial reporting. The report also recommended regular bank reconciliations and independent reviews, adequate documentation for disbursements and payroll, and better tracking of membership dues, donations and fundraiser proceeds. The investigation was conducted at the request of Chamber officials with assistance from city officials. The auditor's report said the procedures performed were not a financial statement audit under generally accepted auditing standards and that additional procedures could have identified other matters. Know what's happening, without having to look for it. Sign up for our free newsletter.