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HomeMy WebLinkAboutOTHER-2026-037-North Carolina Local Government Commission Audit Contract with Mauldin & Jenkins LLC �i�fz - a0ac� � 37� i j 5 /5�aco LGCw205 Form A CONTRACT TO AUDIT ACCOUNTS Rev. 02/2026 The Governing Board Board of County Commissioners of Primary Government Unit Orange County and Discretely Presented Component Unit ( DPCU ) (if applicable ) N/A Primary Government Unit, together with DPCU (if applicable), hereinafter referred to as Governmental Units) and Auditor Name Mauldin & Jenkins, PLLC Auditor Address 3301 Benson Drive , Suite 102, Raleigh, NC Hereinafter referred to as Auditor for Fiscal Year Ending Date Audit Will Be Submitted to LGC 06/30/26 12/31 /26 Must be within six months of FYE hereby agree as follows : 1 . The Auditor shall audit all statements and disclosures required by " U . S . Auditing Standards — AICPA (Clarified ) , " referred to as generally accepted auditing standards ( GAAS ) and additional required legal statements and disclosures of all funds and/or divisions of the Governmental Unit(s ) . The non -major combining , and individual fund statements and schedules shall be subjected to the auditing procedures applied in the audit of the basic financial statements and an opinion shall be rendered in relation to (as applicable ) the governmental activities , the business -type activities , the aggregate DPCUs , each major governmental and enterprise fund , and the aggregate remaining fund information (non - major government and enterprise funds , the internal service fund type , and the fiduciary fund types ) . Budgetary comparison information shall be prepared in accordance with applicable GASB standards . Budget-to-actual comparisons at the level of the legally adopted budget ordinance shall be presented as required supplementary information and shall not be included in the basic financial statements . Any other budgetary comparison information shall be presented only as supplementary information for funds required to be budgeted under NCGS Chapter 159 , Article 3 . 2 _ At a minimum , the Auditor shall conduct the audit and render the report in accordance with GAAS . If the Governmental Unit expended $ 100 , 000 or more in combined Federal and State financial assistance during the reporting period , the Auditor shall perform the audit in accordance with Generally Accepted Government Auditing Standards (GAGAS ) . The Governmental Unit is subject to federal single audit requirements in accordance with Title 2 US Code of Federal Regulations Part 200 Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F ( Uniform Guidance) and the State Single Audit Implementation Act . Currently the threshold is $ 1 , 000 , 000 for federal and state single audits , or such other threshold as applicable for the fiscal year under audit . This audit and all associated audit documentation may be subject to review by federal and State agencies in accordance with federal and State laws , including the staff of the Office of State Auditor (OSA) and the Local Government Commission ( LGC) . If the audit requires a federal single audit in accordance with the Uniform Guidance (§ 200 . 501 ) the Auditor and Governmental Unit(s ) should discuss , in advance of the execution of this contract , the responsibility for submission of the audit and the accompanying data collection form (form SF- FAC) to the Federal Audit Clearinghouse as required under the Uniform Guidance (§ 200 . 512 ) to ensure proper submission . If the audit and Auditor communication are found in this review to be substandard , the results of the review may be forwarded to the North Carolina State Board of CPA Examiners ( NC State Board ) . Page 1 LGC-205 Form A CONTRACT TO AUDIT ACCOUNTS Rev. 02/2026 3 . If an entity is determined to be a component of another government as defined by the group audit standards , the entity' s auditor shall make a good faith effort to comply in a timely manner with the requests of the group auditor in accordance with AU -6 §600441 - § 600AZ 4 . This contract contemplates an unmodified opinion being rendered . If during the process of conducting the audit , the Auditor determines that it will not be possible to render an unmodified opinion on the financial statements of the unit , the Auditor shall contact the LGC Staff to discuss the circumstances leading to that conclusion as soon as is practical and before the final report is issued . The audit shall include such tests of the accounting records and such other auditing procedures as are considered by the Auditor to be necessary in the circumstances . Any limitations or restrictions in scope which would lead to a qualification should be fully explained in an attachment to this contract . 5 . If this audit engagement is subject to the standards for audit as defined in Government Auditing Standards (2018 revision or subsequent revisions , as applicable ) issued by the Comptroller General of the United States , then by accepting this engagement , the Auditor warrants that he or she has met the requirements for a peer review and continuing education as specified in Government Auditing Standards . The Auditor agrees to provide a copy of the most recent peer review report to the Governmental Unit (s ) and to the Secretary of the LGC prior to the execution of an audit contract . Subsequent submissions of the report are required only upon report expiration or upon the Auditor' s receipt of an updated peer review report . If the audit firm receives a peer review rating other than pass , the Auditor shall not contract with the Governmental Unit(s ) without first contacting the Secretary of the LGC for a peer review analysis that may result in additional contractual requirements . If the audit engagement is not subject to Government Auditing Standards or if financial statements are not prepared in accordance with U . S . generally accepted accounting principles (GAAP ) and fail to include all disclosures required by GAAP , the Auditor shall provide an explanation as to why in an attachment to this contract or in an amendment . 6 . It is agreed that time is of the essence in this contract . All audits are to be performed , and the report of audit submitted to LGC Staff, within six months of fiscal year end . At the time of the execution of this contract , if the parties know that the anticipated submission date of the audit exceeds six months after fiscal year end , a written explanation shall be provided to the Secretary of the LGC on this contract form (see the space provided on Page 7) . If it becomes necessary to amend the audit fee or the date that the audit report will be submitted to the LGC , an amended contract along with a written explanation of the change shall be submitted to the Secretary of the LGC for approval . 7 . It is agreed that GAAS include a review of the Governmental Unit' s ( Units ' ) systems of internal control and accounting as they relate to accountability of funds and adherence to budget and law requirements applicable thereto ; that the Auditor shall make a written report , which may or may not be a part of the written report of audit , to the Governing Board setting forth the Auditor' s findings , together with his or her recommendations for improvement . That written report shall include all matters determined to be " significant deficiencies and material weaknesses" in accordance with AU -C § 265 " Communicating Internal Control Related Matters Identified in an Audit" of GAAS . The Auditor shall file a copy of that report with the Secretary of the LGC . For GAAS or Government Auditing Standards audits , if an Auditor issues an AU -C §260 report , "Auditor's Communication With Those Charged With Governance , " commonly referred to as a " Governance Letter , " LGC staff does not require the report to be submitted unless the Auditor cites significant findings or issues from the audit , as defined in AU -C § 260 paragraphs 12 - 14 . This would include issues such as difficulties encountered during the audit , significant or unusual transactions , uncorrected misstatements , matters that are difficult or contentious for which the Auditor consulted outside the engagement team and , in the Auditor' s judgment , are significant and relevant to those charged with governance , and other findings or issues that the Auditor believes are significant and relevant . If matters identified during the audit were required to be reported as described in AU -C § 260 paragraphs 12 - 14 and were communicated in a method other than an AU -C §260 letter, the written documentation must be submitted . Page 2 LGC-205 Form A CONTRACT TO AUDIT ACCOUNTS Rev. 02/2026 8 . All local government and public authority contracts for audit or audit-related work require the approval of the Secretary of the LGC . This includes annual or special audits , agreed upon procedures related to internal controls , bookkeeping or other assistance necessary to prepare the Governmental Unit' s records for audit , financial statement preparation , any finance-related investigations , or any other audit- related work in the State of North Carolina . Approval is also required for the Alternative Compliance Examination Engagement for auditing the Coronavirus State and Local Fiscal Recovery Funds expenditures as allowed by US Treasury . Approval is not required on audit contracts and invoices for system improvements and similar services of a non -auditing nature . 9 . Invoices for services rendered under these contracts shall not be paid by the Governmental Unit(s) until the invoice has been approved by the Secretary of the LGC . This also includes any progress billings [G . S . 159-34 and 115C-447] . All invoices for audit work shall be submitted in PDF format to the Secretary of the LGC for approval . The invoice marked ' approved ' with approval date shall be returned to the Auditor to present to the Governmental Unit (s) for payment . This paragraph is not applicable to contracts for audits of hospitals . 10 . In consideration of the satisfactory performance of the provisions of this contract , the Governmental Unit(s) shall pay to the Auditor, upon approval by the Secretary of the LGC if required , the fee , which includes any costs the Auditor may incur from work paper or peer reviews or any other quality assurance program required by third parties (federal and state grantor and oversight agencies or other organizations ) as required under the Federal Single Audit Act and the State Single Audit Act . This does not include fees for any pre-issuance reviews that may be required by the North Carolina Association of Certified Public Accountants ( NCACPA) Peer Review Committee or North Carolina State Board of CPA Examiners (see Paragraph 13 ) . 11 . If the Governmental Unit(s ) has/have outstanding revenue bonds , the Auditor shall submit to LGC Staff, either in the notes to the audited financial statements or as a separate report, a calculation demonstrating compliance with the revenue bond rate covenant . Additionally, the Auditor shall submit to LGC Staff simultaneously with the Governmental Unit's ( Units ' ) audited financial statements any other bond compliance statements or additional reports required by the authorizing bond documents , unless otherwise specified in the bond documents . 12 . After completing the audit, the Auditor shall submit to the Governing Board a written report of audit. This report shall include , but not be limited to , the following information : (a ) Management' s Discussion and Analysis , ( b ) the financial statements and notes of the Governmental Unit(s ) and all of its component units prepared in accordance with GAAP , (c) supplementary information requested by the Governmental Unit(s ) or required for full disclosure under the law , and (d ) the Auditor's opinion on the material presented . The Auditor shall furnish the required number of copies of the report of audit to the Governing Board uponcompletion . 13 . If the audit firm is required by the Secretary of the Local Government Commission to obtain a pre- issuance review or take corrective action as a result of peer review findings or quality control deficiencies , such corrective action shall be consistent with the authority and requirements of the North Carolina State Board of Certified Public Accountant Examiners , the AICPA Peer Review Program , and established Local Government Commission practice , including the use of report addenda or other remedial measures , as appropriate . Page 3 LGCm205 Form A CONTRACT TO AUDIT ACCOUNTS Rev. 02/2026 14 . In accordance with G . S . 159-34 , the Finance Officer of the Unit is responsible for filing the audited financial statements with the Secretary of the Local Government Commission , The Auditor may upload the audit report and related documents through the LGC 's electronic submission system ; however , submission shall not be deemed complete until the Finance Officer has reviewed and certified the submission . The Auditor, Finance Officer, other Unit staff member designated by the Finance Officer, or a third party approved by the Unit may enter all Data Input Report information except the information on the " transmittal doc info" tab . The "transmittal doc info" tab must be completed by the Auditor . The Finance Officer shall review approve , and certify the accuracy and completeness of the Data Input Report ( DIR ) in the LGC ' s LOGOS system prior to LGC review , regardless of whether the DIR is prepared by the Auditor or the Unit . Finance Officer certification is required for any corrected or revised submissions . Finance Officer certification of the DIR shall be completed in a timely manner following notification that the DIR is ready for review and within time frames prescribed by the LGC . Failure to complete certification in a timely manner may result in the audit being considered late due to unit action rather than auditor performance The Auditor shall conduct the audit in accordance with generally accepted auditing standards and shall ensure that the financial statements are prepared in accordance with generally accepted accounting principles as of the fiscal year end . Budget-to -actual comparisons at the level of the legally adopted budget ordinance shall be presented in required supplementary information , separate from the basic financial statements , and shall not be included in the audit opinion . The Auditor shall confirm that such information reconciles to the financial statements and is consistent with applicable accounting guidance and any LGC reporting requirements . The Finance Officer shall certify in a timely manner that all data inputted in LOGOS used for preparation of the financial statements and required supplementary information is complete and accurate . For audits of units other than hospitals , the audit report should be submitted when (or prior to ) submitting the final invoice for services rendered . The report of audit , as filed with the Secretary of the LGC , becomes a matter of public record for inspection , review and copy in the offices of the LGC by any interested parties . Any subsequent revisions to these reports shall be sent to the Secretary of the LGC . These audited financial statements , excluding the Auditors ' opinion , may be used in the preparation of official statements for debt offerings by municipal bond rating services to fulfill secondary market disclosure requirements of the Securities and Exchange Commission and for other lawful purposes of the Governmental Unit (s ) without requiring consent of the Auditor. If the LGC Staff determines that corrections need to be made to the Governmental Unit ' s ( Units ' ) j financial statements and /or the compliance section , those corrections shall be provided within three business days of notification unless another deadline is agreed to by LGC Staff. I Page 4 s 3 i LGCm205 Form A CONTRACT TO AUDIT ACCOUNTS Rev. 02/2026 15 . Should circumstances disclosed by the audit call for a more detailed investigation by the Auditor than necessary under ordinary circumstances , the Auditor shall inform the Governing Board in writing of the need for such additional investigation and the additional compensation required therefore . Upon approval by the Secretary of the LGC , this contract may be modified or amended to include the increased time , compensation , or both as may be agreed upon by the Governing Board and the Auditor . 16 . If an approved contract needs to be modified or amended for any reason , the change shall be made in writing and preaudited if the change includes a change in audit fee ( preaudit requirement does not apply to hospitals ) . This amended contract shall be completed in full , including a written explanation of the change , signed and dated by all original parties to the contract . It shall then be submitted to the Secretary of the LGC for approval . No change to the audit contract shall be effective unless approved by the Secretary of the LGC . 17 . A copy of the engagement letter, issued by the Auditor and signed by both the Auditor and the Governmental Unit(s ) , shall be attached to this contract , and except for fees , work, and terms not related to audit services , shall be incorporated by reference as if fully set forth herein as part of this contract . In case of conflict between the terms of the engagement letter and the terms of this contract , the terms of this contract shall take precedence . Engagement letter terms that conflict with the contract are deemed to be void unless the conflicting terms of this contract are specifically deleted in Paragraph 30 of this contract . Engagement letters containing indemnification clauses shall not be accepted by LGC Staff. 18 . Special provisions should be limited . Please list any special provisions in an attachment . 19 . A separate contract should not be made for each division to be audited or report to be submitted . If a DPCU is subject to the audit requirements detailed in The Local Government Budget and Fiscal Control Act and a separate audit report is issued , a separate audit contract is required . If a separate report is not to be issued and the DPCU is included in the primary government audit , the DPCU shall be named along with the primary government on this audit contract . DPCU Board approval date , signatures from the DPCU Board chairman and Finance Officer also shall be included on this contract . 20 . The contract shall be executed , preaudited ( preaudit requirement does not apply to hospitals ) and physically signed by all parties including Governmental Unit(s ) and the Auditor, then submitted in PDF format to the Secretary of the LGC . 21 . The contract is not valid until it is approved by the Secretary of the LGC . The staff of the LGC shall notify the Governmental Unit and Auditor of contract approval by email . The audit should not be started before the contract is approved . 22 . Retention of Client Records : Auditors are subject to the NC State Board of CPA Examiners ' Retention of Client Records Rule 21 NCAC 08N . 0305 as it relates to the provision of audit and other attest services , as well as non-attest services . Clients and former clients should be familiar with the requirements of this rule prior to requesting the return of records . Page 5 LGC-205 Form A CONTRACT TO AUDIT ACCOUNTS Rev. 02/2026 23 . This contract may be terminated at any time by mutual consent and agreement of the Governmental Unit (s ) and the Auditor, provided that (a ) the consent to terminate is in writing and signed by both parties , (b) the parties have agreed on the fee amount which shall be paid to the Auditor ( if applicable ) , and (c) no termination shall be effective until approved in writing by the Secretary of the LGC . 24 . The Governmental Unit' s ( Units ' ) failure or forbearance to enforce , or waiver of, any right or an event of breach or default on one occasion or instance shall not constitute the waiver of such right , breach or default on any subsequent occasion or instance . 25 . There are no other agreements between the parties hereto and no other agreements relative hereto that shall be enforceable unless entered into in accordance with the procedure set out herein and approved by the Secretary of the LGC . 26 . E4erify . The Auditor shall comply with the requirements of NCGS Chapter 64 Article 2 . Further , if the Auditor utilizes any subcontractor(s ) , Auditor shall require such subcontractor(s ) to comply with the requirements of NCGS Chapter 64 , Article 2 . 27 . For all non -attest services , the Auditor shall adhere to the independence rules of the AICPA Professional Code of Conduct and Government Auditing Standards, 2018 or 2024 Revision (as applicable ) . Preparing financial statements in their entirety shall be deemed a "significant threat" requiring the Auditor to apply safeguards sufficient to reduce the threat to an acceptable level . If the Auditor cannot reduce the threats to an acceptable level , the Auditor cannot complete the audit . If the Auditor is able to reduce the threats to an acceptable level , the documentation of this determination , including the safeguards applied , must be included in the audit workpapers . I All non -attest service (s ) being performed by the Auditor that are necessary to perform the audit must be identified and included in this contract . The Governmental Unit shall designate an individual with the suitable skills , knowledge , and/or experience (SKE ) necessary to oversee the services and accept responsibility for the results of the services performed . If the Auditor is able to identify an individual with the appropriate SKE , the Auditor must document and include in the audit workpapers how the Auditor reached that conclusion . If the Auditor determines that an individual with the appropriate SKE cannot be identified , the Auditor cannot perform both the non -attest service (s ) and the audit . See " Fees for Audit Services " page of this contract to disclose the person identified as having the appropriate SKE for the Governmental Unit , 28 . Applicable to audits with fiscal year ends of June 30 , 2021 and later. The Auditor shall present the audited financial statements including any compliance reports to the Government Unit ' s Governing Board or audit committee in an official meeting in open session as soon as the audited financial statements are available but not later than 45 days after the submission of the audit report to the Secretary of the LGC . The Auditor' s presentation to the Governing Board or audit committee shall include : a ) the description of each finding , including all material weaknesses and significant deficiencies , as found by the Auditor , and any other issues related to the internal controls or fiscal health of the Government Unit as disclosed in the management letter, the Single Audit or Yellow Book reports , or any other communications from the Auditor regarding internal controls as required by current auditing standards ; b) the status of the prior year audit findings ; c) the values of Financial Performance Indicators based on information presented in the audited financial statements ; and d) notification to the Governing Board that the Governing Board shall develop a " Response to the Auditor's Findings , Recommendations , and Fiscal Matters , " if required under Rule 20 NCAC 03 . 0508 . Page 6 B LGC-205 Form A CONTRACT TO AUDIT ACCOUNTS Rev. 02/2026 29 . Information based on the audited financial statements shall be submitted to the Secretary of the LGC through the LGC's LOGOS system , including completion of the Data Input Report ( DIR) . Submission is not complete and shall not be accepted by the LGC until the Finance Officer has reviewed and certified the DIR in accordance with Paragraph 14 of this contract . 30 . All of the above paragraphs are understood and shall apply to this contract , except the following numbered paragraphs shall be deleted (See Paragraph 17 for clarification) . 31 . The process for submitting contracts , audit reports and invoices is subject to change . Auditors and Units should use the submission process and instructions in effect at the time of submission . Refer to the N . C . Department of State Treasurer website at https : //www , nctreasurer. com/state-and -local- government-finance-division/local -government- commission/submitting-your-audit . 32 . All communications regarding audit contract requests for modification or official approvals will be sent to the email addresses provided on the signature pages that follow . 33 . Applicable to audits with fiscal year ends of June 30 , 2025 , and later. The Unit authorizes the LGC to grant access to the LGC ' s LOGOS system , including the Data Input Report ( DIR) , to employees of the contracted audit firm who are associated with and acting on behalf of the firm for purposes of performing audit and reporting services under this contract . Such access shall be limited to the scope necessary to perform contracted services and shall not relieve the Auditor or the Unit of their respective responsibilities under this contract . 34 . Changes or edits to the text of this contract form are not permitted , except for the Secretary' s authority to revise or update this contract form pursuant to LGC Rule 20 NCAC 03 . 0502 . For contracts with an anticipated audit submission date exceeding six months after fiscal year end , please use this space to explain the reason for the late submission , as required by Paragraph 6 of this contract form : N /A Page 7 LGC -205 Form B CONTRACT TO AUDIT ACCOUNTS Rev . 02/2026 FEES FOR AUDIT SERVICES 1 . For all non -attest services , the Auditor shall adhere to the independence rules of the AICPA Professional Code of Conduct (as applicable ) and Government Auditing Standards, 2018 Revision . Refer to Paragraph 27 of this contract for specific requirements . The following information must be provided by the Auditor ; contracts presented to the LGC without this information will be not be approved . Financial statements were prepared by: E✓ Auditor ❑ Governmental Unit [] Third Party If applicable : The individual at the Governmental Unit designated to have the suitable skills , knowledge , and/or experience (SKE ) necessary to oversee the non-attest services and accept responsibility for the results of these services : Name: Title and Unit / Company: Email Address: Gary Donaldson CFO , Orange County gdonaldson@orangecountync. gov OR Not Applicable ❑ (Identification of SKE Individual on the LGC-205 Contract is not applicable for GAAS-only audits or audits with FYEs prior to June 30, 2020.) 2 . Fees may not be included in this contract for work performed on Annual Financial Information Reports (AFIRs ) , Form 990s , or other services not associated with audit fees and costs . Such fees may be included in the engagement letter but may not be included in this contract or in any invoices requiring approval of the LGC . See Paragraphs 8 and 13 for details on other allowable and excluded fees . 3 . The audit fee information included in the table below for both the Primary Government Fees and the DPCU Fees ( if applicable ) should be reported as a specific dollar amount of audit fees for the year under this contract . If any language other than an amount is included here , the contract will be returned to the audit firm for correction . j 4 . Prior to the submission of the completed audited financial report and applicable compliance reports subject to this contract , or to an amendment to this contract ( if required ) the Auditor may submit interim invoices for approval for services rendered under this contract to the Secretary of the LGC , not to exceed 75 % of the billings for the Unit' s last annual audit that was submitted to the Secretary of the LGC . All invoices for services rendered in an audit engagement as defined in Rule 20 NCAC . 0503 shall be submitted to the Secretary of the LGC for approval before any payment is made . Payment before approval is a violation of law . (This paragraph not applicable to contracts and invoices associated with audits of hospitals ) . j Primary Government Unit Orange County Audit Fee (financial and compliance if applicable ) $ 150 ,000 Fee per Major Program ( if not included above ) $ - Additional Fees Not Included Above (if applicable ) : Financial Statement Preparation (Ind . notes and RSI) $ All Other Non-Attest Services $ - TOTAL AMOUNT NOT TO EXCEED $ 150, 000 Discretely Presented Component Unit N/A Audit Fee ( financial and compliance if applicable ) $ Fee per Major Program ( if not included above) $ Additional Fees Not Included Above ( if applicable ) . Financial Statement Preparation (incl . notes and RSI) $ All Other Non -Attest Services $ TOTAL AMOUNT NOT TO EXCEED $ Page 8 LGC-205 Form B CONTRACT TO AUDIT ACCOUNTS Rev. 02/2026 SIGNATURE PAGE AUDIT FIRM Audit Firm * Mauldin & Jenkins , PLLC Authorized Firm Representative (typed or printed ) * Signature Timothy M . Lyons Date* Email Address* 61 04/ 14/26 tlyons@mjcpa . com GOVERNMENTAL UNIT Governmental Unit* Orange County Date Governing Board Approved Audit Contract* ( Enter date in box to right) Mayor/Chair erson (typed or printed )* Signat e* Date Email A dress* j i vbocc. Chair of Audit Committee (typed or printed , or " NA" ) Signature Date Email Address GOVERNMENTAL UNIT — PREAUDIT CERTIFICATE Required by G . S . 159 -28 (a1 ) or G . S . 115C441 (al ) . Not applicable to hospital contracts . This instrument has been preaudited in the manner required by The Local Government Budget and Fiscal Control Act or by The School Budget and Fiscal Control Act. Sum Obligated by This Transaction : $ 1505000 Primary Governmental Unit Finance Officer* (lypedorpHnled Signature* Date of Preaudit Certificate* Email Address* Page 9 LGCm205 Form B CONTRACT TO AUDIT ACCOUNTS Rev. 02/2026 SIGNATURE PAGE — DPCU ( complete only if applicable) DISCRETELY PRESENTED COMPONENT UNIT DPCU * N/A Date DPCU Governing Board Approved Audit Contract* ( Enter date in box to right) DPCU Chairperson (typed or printed )* Signature* Date* Email Address * Chair of Audit Committee (typed or printed , or " NA' ) Signature Date Email Address DPCU — PREAUDIT CERTIFICATE Required by G . S . 159-28 ( a1 ) or G . S . 115C441 (a1 ) . Not applicable to hospital contracts . This instrument has been preaudited in the manner required by The Local Govemment Budget and Fiscal Control Act or by The School Budget and Fiscal Control Act, i i Sum Obligated by this Transaction : $ DPCU Finance Officer (typed or printed ) * Signature* Date of Preaudit Certificate* Email Address* Remember to print this form , and obtain all required signatures prior to submission . PRINT i I i i I Page 10 I