Please Read Comments to A660s

Thank you.

 Sue Dietrich

Staten Island Federation of PTAs

 

1 - Several times in the forms in the back of the document, it uses the word "stationary" when you mean "stationery".

 

2 - In the section about auditing the books of a PTA on pages 19 and 20, when you are describing the audit committee, you mention that the auditor can't be a member of the PTA (section L.1.d).   I think that you have put this in the incorrect section and you should have another section on external audit.  In addition, you say the audit must be by April but you don't say what period of time it must cover.  My concern is that much of the expenses of a PTA are done in May and June and that might never be looked at if the audit is in April.

 

3 - You say that if a PTA gets a 501C3, they must have counsel.  Our PTA has a 501C3 (which I believe all non-profits must have - I don't think it is an option), and we don't have counsel and don't see the need for counsel.  I would also encourage your legal department to explain to us how a PTA can raise funds and not be a 501C3.

 

4 – You have several recommendations concerning the person who maintains the PAs books.  You never mention that this person is the treasurer (who must maintain the books), and elsewhere in the document, you say there are no qualifications to be an officer.  This is an inconsistency.

 

5 - Members of a CEC, etc, can’t serve on a school leadership team.  This conflicts with A-655.  In addition, since these regulations are now in effect during the comment period, does that mean there are many SLTs out there out of compliance because they have less than the required number of parents?  We also currently have parents who work in one school in Staten Island (District 31) serving as a PTA officer and SLT member on the school their child attends, also in Staten Island .  This would also not be allowed the way it is described in section 3. on the bottom of page 5.

 

6 – On page 6, section 2.b.i. It says that if a vacancy occurs in a mandatory officer position and it is not filled within 10 calendar days, the PA will cease to function.  This is not enough time!  What if an officer resigns on December 23?  The 10 calendar days would be over before school is back in session.

 

7 – At the top of page 9 you say that candidate statements can be posted on the school website, sent via email or sent via backpack.  If you want to allow this, you should mandate that all candidates have the same options.  Maybe one can make copies and mail them home while another cannot afford to do that.  In addition, how can the candidates have access to the members email accounts?

 

8 – In section c.i. at the bottom of page 11, it mentions the ranking of officers.  I can’t figure out what this means.  If the recording secretary quits, who takes over?

 

9 – In section J.4.b. at the bottom of page 14 it says that distribution of information during instructional hours does not constitute a violation of this provision.  I think this is wonderful.  However, I feel it should also say that collection of envelopes is not a violation of this provision.

 

10 – Attachment 5 is a budget proposal form.  I think that if the PTA has its own form, which includes the necessary information that should suffice.  In the PTAs I have been treasurer, our forms have much more information – I would not want to waste my time trying to simplify the form.

 

11 – On page 16, section 6.c, it says that reimbursement can’t be given until the next regularly scheduled meeting.  This would be a terrible imposition on some PTA members who may not be able to afford to wait for reimbursement.

 

12 – In the section on bank accounts you say it is OK for a PTA to have more than the mandatory checking account.  You also say they can’t use withdrawal slips.  If they open a money market account to get more interest, the only way to get money into our out of that CD would be with deposit or withdrawal slips.  I think this should be an exception to the rule.

 

13 – On page 18, section b, it says that the transfer of records by the treasurer must be made in the presence of the principal.  Why????

 

14 – Going back to page 2, it defines who may be a member of a PTA in section A.1.a.  In page 1 of attachment 8 (Minimum requirements for bylaws) it says that parents of children in a citywide program are automatically members of the PTA in the school their child attends.  This wording should be added to page 2 of A-660.  In addition, if a District 75 program exists in a campus, which school PTA are the parents members of?  Can they choose?

 

15 – There are several problems with Attachment 8, minimum requirements for bylaws.  On page 1 of 4, section II.A. it says that at least one general meeting must be scheduled and held within sixty calendar days of the beginning of the school year.  This should be within 30 days as long as you have a functioning PTA.

         I continue to have problems with all committee meetings being mandated to be held in the school.  Often the school does not have room for all committees to meet.  In addition, certain committees, such as a yearbook committee, may need computers or other supplies, which are not available at the school and may be available at a private residence.  In my opinion, as long as the location of the meetings are known, there should not be this restriction.

         Section II.D. says that members must vote before an outside speaker can come to a meeting.  This means that if a need exists for a speaker, it may take as long as 2 months to first bring it to membership at one meeting and than have them come at the next meeting.  It seems to me that this is a job the executive board of the PTA can do by themselves.  It also says outside observers are prohibited.  I thought we, as PTAs would want to encourage community members to be a part of our school family.

         Section F says that draft minutes must be distributed to the membership prior to the next regularly scheduled meeting along with the meeting notice.  This is particularly onerous in a school without a major budget for copying.  In reality, you are now forcing us to send out maybe 1,000 copies of the minutes when maybe 50 people show up at the meeting.  This is a huge expense for most PTA.

         Quorum is listed in section IV. As the president, three other executive board members (defined as officers in section V.A.) and at ten parent members at large.  This is ridiculous. First, if the president is ill, the vice president should be able to run the meeting – that is what they are there for.  With this rule, this is not possible.  Secondly, some PTAs only have the core officers, so they will never be able to have quorum.  Even requiring 4 out of 6 officers (if your PTA has that many) to attend every meeting does not match the reality of our busy lives.  In small schools especially, requiring a total of 14 members be present would be a good goal but would not always be met.

         In section VI. B. it says a PA may establish class parents as additional officer positions.  I do not know what ‘class parents’ means in this context.

 

16 – Attachment 9 for Presidents councils says elections must be held by September 30 but the term runs through June 30.  That means that there is not Presidents council after June 30.  Is that right?  It also says in section VI.E. that elected representatives term will end with a change in the office of the presidency.  That should not be the case – if the president leaves in the middle of the year, the alternate should maintain their position.  I also feel somewhere in here it must say that a representative to CPAC must be elected if the President of presidents’ council is unable or unwilling to serve in that capacity.

 

Thank you.