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Report on special investigation of Guttenberg Chamber released
City of Guttenberg

By Audrey Posten

The Iowa State Auditor’s Office last week released a report on a special investigation of the Guttenberg Chamber of Commerce, citing about $122,000 in unsupported and improper disbursements by former Guttenberg Chamber of Commerce Director Brandie Tomkins from October 2020 through October 2024.

Tomkins was employed at the chamber from mid-October 2020 through mid-September 2024, during which time her duties included receipts, disbursements, payroll, bank accounts and reporting. In 2022, the city of Guttenberg and Guttenberg Chamber of Commerce started a 28E agreement sharing the position between the two. The director’s payroll was processed by the city from then until the city discontinued that agreement in September 2024, after which Tomkins left the chamber.

The auditor’s office said the special investigation was requested by chamber officials, with the assistance of city officials, as a result of concerns regarding certain financial transactions processed by Tomkins.

“Upon her leaving, chamber officials began reviewing financial records and discovered what they called a mess,” State Auditor Rob Sand said during a news conference on Sept. 2. “Many disbursements issued to her without supporting documentation, missing time sheets for her, missing receipts for items she had purchased and no evidence that cash, which had been collected at chamber events, had ever been deposited.”

During its investigation, the state auditor’s office said it examined chamber policies and procedures, finding the chamber did not properly maintain chamber board minutes, payroll resolutions or time sheets identifying pay rates and expected hours for Tomkins for the period of review. Monthly bank statements and related images of redeemed checks were also not periodically reviewed by the members of the board while Tomkins was the director, and the board stated bank reconciliations were not performed.

In the report, the state auditor’s office said it examined bank records and activity, with comparison to the chamber’s accounting system, and payroll disbursements and reimbursements. The office also reviewed activity in chamber and city council meeting minutes, in addition to interviewing Tomkins and city and chamber officials.

The state auditor’s office reported the special investigation identified $5,086.85 of improper disbursements, $116,995.61 of unsupported disbursements and $2,700 of chamber cash in the possession of the Guttenberg Police Department.

“However, because chamber records were not sufficiently maintained, it was not possible to determine if additional transactions were improperly recorded or if additional amounts were improperly disbursed,” the report said.

The $5,086.85 of improper disbursements includes $4,900 of improper cash withdrawals from the chamber’s bank accounts, $117.69 of improper disbursements to vendors and $69.16 of improper purchases using the chamber’s debit card, according to the report.

The report further stated the $116,995.61 of unsupported disbursements identified includes $51,055.05 in payroll issued to Tomkins, $30,269.76 of cash withdrawals from the chamber’s bank account, $16,211.74 of purchases on the chamber’s debit card, $10,397.89 of disbursements from the chamber’s bank accounts to vendors and $9,061.14 of reimbursements to Tomkins.

According to the state auditor’s office, disbursements were classified as improper if they were personal in nature or not necessary or reasonable for operations of the chamber. Disbursements were classified as unsupported if appropriate documentation was not available or it was not possible to determine if the disbursement was related to chamber operations or was personal in nature. Other disbursements were classified as reasonable if it appeared they were for chamber operations based on available supporting documentation, the vendor, frequency and amount of the payments and/or discussions with chamber officials.

Of the total, “most of that was payable checks to [Tomkins] that were issued without proper documentation, like time sheets or board approval,” Sand said at the news conference. “She also had about $30,000 in unsupported cash withdrawals from the chamber’s bank account with its debit card. In one improper withdrawal for $4,800, she later said was for an event, but that event had been held months after. When we interviewed her about it, she called it a security deposit.”

“We also found about $16,000 worth of debit card transactions that were not supported by documentation, and some of them were plainly improper, including a purchase for the online gambling site DraftKings,” Sand continued.

When informed by the state auditor’s office there were not records for a large number of chamber activities, the report stated Tomkins “alleged that when she left employment all records were maintained in the chamber’s office.”

The report noted the chamber’s primary revenue sources include membership/sponsorship dues, hotel/motel tax funds provided annually by the city of Guttenberg and proceeds from fund raising events.

When asked about the funds in question, Sand said he would characterize them as “government funds.”

“It’s taxpayer money at the end of the day. It’s money that’s collected from room taxes. It’s provided by the city, by taxpayers, and the 28E itself is always a public act,” he said.

Moving forward, the Iowa State Auditor’s Office recommends chamber officials implement procedures to ensure the chamber’s internal controls are strengthened, including segregation of duties, performing collections reconciliations, performing independent review of bank statements and ensuring all disbursements are properly supported, approved and paid in a timely manner.

“In addition, chamber officials should ensure all actions taken by the board are properly documented in the minutes of board meetings such as staff’s hourly rate and expected hours,” the state auditor’s office continued.

“We had our standard recommendations that we made to the Guttenberg Chamber regarding oversight and checks and balances. The constant issue is always segregation of duties. If you have one person who has the keys to the kingdom, you’re giving that person an awful big opportunity to misspend taxpayer dollars. That’s a real problem,” Sand said. “Another piece of this: If you’re responsible for oversight, asking for the bank records every month. You should want to see the bank account statements. It doesn’t mean you have to ask questions about every single one of them. That’s good. But even just the person knowing that you’re asking and knowing you have the statements in your hand is going to help them behave themselves.”

Copies of the report have been 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. A copy of the report is available for review on the Auditor of State’s website at Special Interest Reports.