2023-05-12T14:21:56-05:00 2022-06-30 420714325 RSM US LLP 7351 OFFICE PARK PLACE MELBOURNE FL 329408229 990 2021-07-01 590192430 THE CHILDREN'S HOME SOCIETY OF FLORIDA CHIL 3213973000 5766 S SEMORAN BLVD ORLANDO FL 328224818 BARBARA MCDONALD CHIEF FINANCIAL OFFICER 3213973000 2023-05-10 1 BARBARA MCDONALD 999009999 JULIANA KREUL P01204534 3217516200 2023-05-07 3 AAL1 IAL1 2021 2023-04-26 12:10:37Z ANDRY SWEET 5766 S SEMORAN BLVD ORLANDO FL 328224818 111218232 0 X WWW.CHSFL.ORG X 1964 FL CHS BUILDS BRIDGES TO SUCCESS FOR CHILDREN, OFFERING SOLUTIONS IN FOUR (4) KEY SERVICE AREAS: CHILD WELFARE, BEHAVIORAL HEALTH, EARLY CHILDHOOD AND COMMUNITY SOLUTIONS. 21 21 1847 1415 0 0 83804854 82489020 9767742 6946330 7762217 6999267 1004941 1131925 102339754 97566542 3552079 4246029 0 0 69750842 76315272 0 0 3117586 18835068 18507053 92137989 99068354 10201765 -1501812 89249590 76657795 21500758 17487727 67748832 59170068 X CHILDREN'S HOME SOCIETY OF FLORIDA MISSION STATEMENT:BUILDING BRIDGES TO SUCCESS FOR CHILDREN 0 0 38381233 1868664 177745 CHILD WELFARE SOLUTIONS: EMPOWERING CHILDREN AND FAMILIES IN THE CHILD WELFARE SYSTEM - OR AT RISK OF ENTERING THE SYSTEM - TO SUCCEED: CHS SERVES FAMILIES AT RISK OF ENTERING THE FOSTER CARE SYSTEM AS WELL AS CHILDREN WHO HAVE BEEN REMOVED FROM THEIR HOMES; THE GOAL IS TO FIND A PERMANENT SOLUTION (REUNIFICATION, ADOPTION OR A PERMANENT LIVING SITUATION WITH A RELATIVE), SO THE CHILD LIVES IN A SAFE, NURTURING ENVIRONMENT. SERVICES INCLUDE CASE MANAGEMENT, SHELTER, FOSTER/ADOPTIVE HOME RECRUITMENT AND RETENTION, IN-HOME SUPPORT SERVICES, FAMILY PRESERVATION SERVICES, CHILD PROTECTION TEAMS, CINS/FINS SERVICES FOR RUNAWAY AND HOMELESS YOUTH, FAMILY AND SIBLING VISITATION SERVICES, GROUP HOME SERVICES, REUNIFICATION, ADOPTION AND TRANSITIONAL LIVING SERVICES. CHS HAS DEVELOPED AND IMPLEMENTED INNOVATIVE SOLUTIONS (E.G.: CASEAIM) TO REDUCE LENGTHS OF STAY FOR CHILDREN IN CARE, IMPROVE THE QUALITY OF CARE, AND IMPROVE CHILD OUTCOMES FOR SAFETY, PERMANENCY AND WELL-BEING.CLIENTS = 15,244 CLIENTS / DAYS OF SERVICE = 837,896 12532094 484444 6440832 BEHAVIORAL HEALTH SOLUTIONS: IMPROVING HEALTH AND WELL-BEING OF CHILDREN AND FAMILIES: CHS SERVES CHILDREN, FAMILIES AND ADULTS WHO ARE DIAGNOSED WITH BEHAVIORAL HEALTH DISORDERS AND ARE IN NEED OF COUNSELING, PSYCHIATRIC CARE AND CASE MANAGEMENT SERVICES. CHS PROVIDES TRAUMA-FOCUSED THERAPY TO IMPROVE THE RESILIENCY OF CHILDREN AND ADULTS EXPOSED TO TRAUMA. CHS BEHAVIORAL HEALTH SOLUTIONS PROMOTE ACCESS, QUALITY AND OUTCOMES. SERVICES ARE ACCESSIBLE AT THE CONVENIENCE OF OUR CLIENTS (IN HOMES, SCHOOLS, COMMUNITY SETTINGS AND VIA TELEHEALTH). CHILDREN AND ADULTS SERVED IN BEHAVIORAL HEALTH SERVICES SHOW IMPROVED FUNCTIONING AND ARE AT REDUCED RISK FOR INPATIENT AND CRISIS STABILIZATION SERVICES. CLIENTS = 10,455 CLIENTS / DAYS OF SERVICE= 1,739,637 15862148 1158234 418798 EARLY CHILDHOOD SOLUTIONS: IMPROVING SAFETY, DEVELOPMENTAL WELL-BEING AND ACADEMIC READINESS OF CHILDREN AGES 0-5: CHS SERVES CHILDREN, THEIR CAREGIVERS AND PREGNANT WOMEN THROUGH A VARIETY OF PREVENTION, EARLY INTERVENTION AND EARLY EDUCATION SERVICES: HEALTHY FAMILIES, EARLY STEPS, EARLY HEAD START, HEALTHY START, PERINATAL AND BRIDGES. CHS PROMOTES HEALTHY BONDING, ATTACHMENT AND DEVELOPMENT THROUGH THE IMPLEMENTATION OF EVIDENCED-BASED CURRICULA IN HOME-VISITING AND CENTER-BASED SETTINGS. CHS' PREVENTION AND EARLY INTERVENTION SERVICES SUCCESSFULLY KEEP FAMILIES TOGETHER - AND OUT OF THE FOSTER CARE SYSTEM - AND THE EARLY CHILDHOOD SOLUTIONS ARE EFFECTIVE IN HELPING CHILDREN ACHIEVE SCHOOL READINESS BY AGE 5, A KEY INDICATOR IN THEIR FUTURE ACADEMIC SUCCESS. CLIENTS= 9,437 CLIENTS | DAYS OF SERVICE= 2,425,147 10757083 734687 1018513 COMMUNITY SOLUTIONS: PROMOTING SAFE COMMUNITIES AND SCHOOLS: CHS SERVES COMMUNITIES AND COLLABORATES WITH MULTIPLE PARTNERS TO CREATE SOLUTIONS THAT SUPPORT ENTIRE COMMUNITIES, SUCH AS MENTORING, YOUTH EMPLOYMENT, NEIGHBORHOOD ENGAGEMENT IN EDUCATION (BRIDGES), AND COMMUNITY PARTNERSHIP SCHOOLS. IN THESE SCHOOLS AND SERVICES, CHS AND PARTNERS WORK TO REMOVE BARRIERS TO LEARNING (HUNGER, HOMELESSNESS, ILLNESS), PROMOTE OPPORTUNITIES THROUGH ENRICHMENT ACTIVITIES DURING AND AFTER SCHOOL, PROMOTE YOUTH DEVELOPMENT AND PROVIDE A SOLID FOUNDATION FOR ACADEMIC INSTRUCTION. IN COMMUNITY PARTNERSHIP SCHOOLS, COMMUNITY LEADERS, PARENTS, TEACHERS AND STUDENTS HAVE A VOICE IN A SHARED GOVERNANCE MODEL WITH A SHARED VISION, GOALS AND OUTCOMES FOR THE SCHOOL AND SURROUNDING NEIGHBORHOOD. RESULTS INCLUDE INCREASED GRADUATION RATES, IMPROVED SCHOOL ATTENDANCE, REDUCED DISCIPLINARY ACTIONS IN SCHOOLS, AND INCREASED HEALTH AND SAFETY IN THE SCHOOL AND SURROUNDING NEIGHBORHOODS. CLIENTS = 29,371 CLIENTS / DAYS OF SERVICE= 3,316,835 10757083 734687 1018513 77532558 1 0 0 1 0 0 0 0 0 0 1 0 0 1 1 1 1 0 0 0 0 0 0 0 1 0 0 0 1 1 0 0 0 0 0 0 0 0 1 0 0 0 1 0 0 0 0 1 533 0 1 1847 1 0 0 0 0 0 1 1 0 0 0 0 0 0 X 21 21 0 0 0 0 0 0 0 1 1 0 1 0 0 1 1 1 1 1 1 1 0 FL X BARBARA MCDONALD CFO 3213973000 5766 S SEMORAN BLVD ORLANDO FL 328224818 DALE JACOBS CHAIR 3.00 X X 0 0 0 BRAND MEYER VICE CHAIR 3.00 X X 0 0 0 LAURA KOLKMAN IMMEDIATE PAST CHAIR 3.00 X 0 0 0 MIGUEL A VIYELLA EX-OFFICIO, CHS FOUNDATION CHAIR 3.00 X 0 0 0 ALAN WILLIAMS MEMBER (THRU 12/21) 1.00 X 0 0 0 ANDREW DUFFELL MEMBER 3.00 X 0 0 0 DAVICKA THOMPSON MEMBER 3.00 X 0 0 0 DOUG WILES MEMBER 3.00 X 0 0 0 FRANK J GULISANO MEMBER 3.00 X 0 0 0 GIL ZIFFER MEMBER 3.00 X 0 0 0 JULIE EASON MEMBER 3.00 X 0 0 0 KAREN M BUESING MEMBER 3.00 X 0 0 0 KRISTIE WALLACE MEMBER 3.00 X 0 0 0 RON BRISE MEMBER 3.00 X 0 0 0 RUSSELL JONES MEMBER 3.00 X 0 0 0 SAMUEL P BELL III MEMBER 3.00 X 0 0 0 SUSAN MAIN MEMBER 3.00 X 0 0 0 TERRENANCE FREEMAN MEMBER 3.00 X 0 0 0 VICTORIA WEBER MEMBER 3.00 X 0 0 0 TRACEY B BRACCO MEMBER 3.00 X 0 0 0 ANDRY E SWEET PRESIDENT & CEO 40.00 X 261410 0 43875 KYMBERLY A COOK CHIEF OPERATING OFFICER 40.00 X 173358 0 29136 BARBARA MCDONALD CHIEF FINANCIAL OFFICER 40.00 X 178907 0 4035 FRANCISCO GONZALEZ CHIEF COMPLIANCE OFFICER 40.00 X 151370 0 45332 JAMES S PULLIAM CHIEF INFORMATION OFFICER (THRU 07/21) 40.00 X 97249 0 6294 MARCUS JOHNSON CHIEF INFORMATION OFFICER (AS OF 10/21) 40.00 X 41538 0 0 HEATHER E VOGEL CHIEF TALENT OFFICER 40.00 X 156282 0 13915 ANTHONY SUDLER CHIEF DEVELOPMENT OFFICER 40.00 X 183988 0 18407 TARA G HORMELL SR. VP OF OPERATIONS 40.00 X 135479 0 30234 WADE T LIJEWSKI SR. VP PRACTICE INTEGRATIO 40.00 X 131171 0 31132 NACOLE S GUYTON SR VP OF OPERATIONS (THRU 05/22) 40.00 X 136581 0 11036 LOURDES M PONS REGIONAL EXECUTIVE DIRECTO (THRU 04/22) 40.00 X 127861 0 10203 LINDSEY B CANNON REGIONAL EXECUTIVE DIRECTO 40.00 X 120176 0 4446 1895370 0 248045 25 0 1 0 LAKE WORTH WEST RESIDENT PLANNING INC 4730 MAIN STREET LAKE WORTH FL 33461 PROFESSIONAL FEES 483453 STABILIFY LLC 500 S DIXIE HWY SUITE 303 CORAL GABLES FL 33146 PROFESSIONAL FEES 331401 UNIVERSITY OF FLORIDA PO BOX 103424 GAINESVILLE FL 32610 BEHAVIORAL HEALTH SERVVICES 246763 RSM US LLP 5155 PAYSPHERE CIRCLE CHICAGO IL 60674 PROFESSIONAL FEES 182216 COASTAL BEHAVIORAL THERAPY INC 590 SOLUTIONS WAY ROCKLEDGE FL 32955 BEHAVIORAL HEALTH SERVICES 175331 12 1093360 970278 75176130 5249252 998660 82489020 MEDICARE/MEDICAID PAYMENTS 624100 6618988 6618988 ADOPTIVE & OTHER SVC FEES 624100 327342 327342 6946330 643225 643225 342586 342586 0 6808589 12663611 6050438 7065720 758151 5597891 6356042 6356042 215313 970278 192946 22367 22367 MISCELLANEOUS 624100 1109558 1109558 1109558 97566542 8055888 0 7021634 4246029 4246029 1482274 1271215 158786 52273 54941337 46972796 6063432 1905109 8028889 1242025 6726551 60313 7059381 6068388 720626 270367 4803391 4253366 400123 149902 103568 58072 43423 2073 184881 164866 16719 3296 85882 85882 95080 95080 3082164 2018866 967642 95656 3056114 1705094 1116370 234650 3350947 2701040 614228 35679 2158375 2027917 87379 43079 418311 285612 125962 6737 29456 236 29220 1463903 566499 891632 5772 1681174 1504438 153191 23545 CONTRIBUTED GOODS 958478 845428 113050 EQUIPMENT RENTAL 516765 414992 89375 12398 PROVISION FOR BAD DEBT/ 457449 774077 -316628 MEMBERSHIP DUES 246689 139649 102868 4172 617817 271953 246349 99515 99068354 77532558 18418210 3117586 144329 150572 6819742 6196699 306554 447154 9893577 10866678 1090201 905985 33473813 18687308 22333278 14786505 18497970 16891387 30163939 26412815 89249590 76657795 16903627 7267835 2362234 1972283 1526899 7202184 707998 1045425 21500758 17487727 X 37630090 33584378 30118742 25585690 67748832 59170068 89249590 76657795 X -1501812 -3578752 -3498200 X X 0 1 X 1 1 1 X 98484722 92866941 90046232 83804854 82489020 447691769 98484722 92866941 90046232 83804854 82489020 447691769 447691769 1106246 1077587 869104 744924 985811 4783672 1307916 1404521 1090791 1103762 1324871 6231861 458707302 47944690 0.97600 0.97670 X 236021 236021 98832333 99068354 1000000 250000 0 0 1000000 1000000 1000000 1000000 4000000 6000000 217316 219231 224465 236021 897033 250000 250000 250000 250000 1000000 1500000 SCHEDULE C, PAGE 2, PART II RELATIVE TO ALL LOBBYING ACTIVITIES: PROPOSED LEGISLATION IS REVIEWED FOR ITS IMPACT ON CHILDREN AND FAMILIES IN FLORIDA. THE REVIEW INCLUDES DISCUSSIONS WITH LEGISLATIVE AIDES, STAFF OF THE FLORIDA DEPARTMENT OF CHILDREN AND FAMILIES AND OTHER RELEVANT SOURCES. AS APPROPRIATE, CONTACT IS MADE WITH LEGISLATORS, LEGISLATIVE AIDES AND STAFF OF THE DEPARTMENT OF CHILDREN AND FAMILIES. THE TOTAL AMOUNT REPORTED IS FOR ALL LOBBYING EXPENSES. 1 1334729 1334729 18036685 7330178 10706507 854404 821183 33221 13247995 10535947 2712048 14786505 BENEFICIAL INTEREST IN THE NET ASSETS OF THE CHS FOUNDATION, INC. 25557013 PENSION ASSET 855802 26412815 HELD IN CUSTODY FOR OTHERS 1045425 1045425 X 97631122 382964 535532 918496 96712626 95080 758836 853916 97566542 93134102 382964 535532 918496 92215606 95080 6757668 6852748 99068354 PART X, LINE 2: MANAGEMENT ASSESSED WHETHER THERE WERE ANY UNCERTAIN TAX POSITIONS WHICH MAY GIVE RISE TO INCOME TAX LIABILITIES AND DETERMINED THAT THERE WERE NO SUCH MATTERS REQUIRING RECOGNITION IN THE ACCOMPANYING CONSOLIDATED FINANCIAL STATEMENTS. CHS FILES TAX RETURNS IN THE U.S. FEDERAL JURISDICTION. GENERALLY, CHS IS NO LONGER SUBJECT TO U.S. FEDERAL INCOME TAX EXAMINATIONS BY TAXING AUTHORITIES FOR YEARS BEFORE JUNE 30, 2019. PART XI, LINE 2D - OTHER ADJUSTMENTS: FUNDRAISING EVENT EXPENSE 192,946. DIRECT RENTAL EXPENSE 342,586. PART XI, LINE 4B - OTHER ADJUSTMENTS: REALIZED GAIN ON SALE OF INVESTMENTS 758,151. INTEREST INCOME GROUPED IN EXPENSES 685. PART XII, LINE 2D - OTHER ADJUSTMENTS: FUNDRAISING EVENT EXPENSE 192,946. DIRECT RENTAL EXPENSE 342,586. PART XII, LINE 4B - OTHER ADJUSTMENTS: PENSION CONTRIBUTION 6,756,983. INTEREST INCOME GROUPED WITH EXPENSES 685. SCHEDULE D, PART IX, LINE 2 BENEFICIAL INTEREST IN THE NET ASSETS OF THE CHS FOUNDATION, INC. - TOTAL OF $25,557,013 CONSISTS OF: $25,557,013 FOR CHS FOUNDATION SOUTH SIDE SPLENDOR 343273 261540 81733 5580 400 14208 ULTIMATE DINNER PARTY 136151 130387 5764 2987 425 22680 10 706167 578351 127816 853 26535 91765 4727 22786 1185591 970278 215313 853 26535 100332 5552 59674 192946 22367 FL 0 SEE SCHEDULE O 0 0 0 0 0 1 FINANCIAL ASSISTANCE TO CLIENTS 2375 718377 VENDOR BILLS CLIENTS' UTILITIES, ELECTRONIC DEVICES; CELLPHONES, PHONE SERVICES FOOD, CHS FACILITIES 4025 248513 VENDOR BILLS CLIENTS MEALS; GROCERIES; RESIDENTIAL SUPPLIES, CHS FACILITIES 180 18191 VENDOR BILLS LAUNDRY SUPPLIES; CAFETERIA SUPPLIES MEDICAL, PSYCH & DENTAL FEES 2763 1545261 VENDOR BILLS MEDICAL & PSYCH SERVICES; DENTAL SERVICES; COUNSELLING FOSTER CARE BOARD PAYMENTS 34 165568 FOSTER CARE RATES FOSTER SERVICES DAYCARE 1636 387628 VENDOR BILLS TRANSPORTATION 619 38640 VENDOR BILLS RECREATION ACTIVITIES 2653 182919 VENDOR BILLS OUTREACH ACTIVITIES 581 34601 VENDOR BILLS OTHER ASSISTANCE ON BEHALF OF CLIENTS 2345 432682 VENDOR BILLS CLOTHING & PERSONAL NEEDS 139 34250 VENDOR BILLS PROGRAM EDUCATIONAL SUPPLIES 1272 439399 VENDOR BILLS PART I, LINE 2: THE ORGANIZATION USES A COMBINATION OF DESIGNATED COST CENTERS AND NATURAL GRANT ACCOUNTS TO TRACK GRANTS TRANSACTIONS WITHIN THE ACCOUNTING SYSTEM. USE OF GRANT FUNDS ARE MONITORED BY THE PHILANTHROPY DEPARTMENT & GRANTS TEAM TO ENSURE DONOR RELATED INFORMATION & INTENTS ARE TRACKED ACCORDINGLY. PART III, COLUMN B ESTIMATES BASED ON TOTAL EXPENSES INCURRED, RELATIVE TO AVERAGE SPEND PER CLIENT SERVICE RATES BILLED BY VENDORS / THIRD PARTY SERVICE PROVIDERS. X X X X 0 0 0 0 0 0 0 0 0 ANDRY E SWEET PRESIDENT & CEO 261410 0 0 0 0 0 17999 0 26837 0 306246 0 0 0 KYMBERLY A COOK CHIEF OPERATING OFFICER 173358 0 0 0 0 0 6675 0 27885 0 207918 0 0 0 ANTHONY SUDLER CHIEF DEVELOPMENT OFFICER 183988 0 0 0 0 0 8596 0 10848 0 203432 0 0 0 FRANCISCO GONZALEZ CHIEF COMPLIANCE OFFICER 151370 0 0 0 0 0 11443 0 34798 0 197611 0 0 0 BARBARA MCDONALD CHIEF FINANCIAL OFFICER 178907 0 0 0 0 0 4035 0 489 0 183431 0 0 0 HEATHER E VOGEL CHIEF TALENT OFFICER 150763 0 0 0 5519 0 4662 0 10138 0 171082 0 0 0 TARA G HORMELL SR. VP OF OPERATIONS 135479 0 0 0 0 0 10557 0 21394 0 167430 0 0 0 WADE T LIJEWSKI SR. VP PRACTICE INTEGRATIO 131171 0 0 0 0 0 1050 0 30563 0 162784 0 0 0 X 958493 FAIR MARKET VALUE X IT EQUIPMENT 1 40167 FMV 5435 0 1 0 PART I, COLUMN (B): USING A COMBINATION OF THE TWO METHODS ABOVE FORM 990, PART VI, SECTION B, LINE 10B CHS REGIONAL (LOCAL) BOARDS ARE PRIMARILY FOCUSED ON PHILANTHROPIC & COMMUNITY AWARENESS SUPPORTS FOR CHS PROGRAMS. LOCAL BOARDS ALSO INCLUDE MEMBERS OF CHS EXECUTIVES AND SENIOR LEADERSHIP PERSONNEL WHO ENSURES LOCAL UNITS' ACTIVITIES ARE CONSISTENT WITH THE ORGANIZATION'S TAX-EXEMPT PURPOSES AND STRATEGIC MISSION. FORM 990, PART VI, SECTION B, LINE 11B ONCE A DRAFT RETURN IS RECEIVED BY CHS, THE CONTROLLER REVIEWS THE RETURN FOR ACCURACY AGAINST BOTH THE AUDITED FINANCIALS AND THE GENERAL LEDGER. IF NO DISCREPANCIES ARE FOUND, THE DRAFT IS THEN REVIEWED BY THE CFO AND SUBMITTED TO BOTH THE CEO & COO FOR FUTHER REVIEW. DUE TO TIME CONSTRAINTS, THE CFO WILL SUBMIT THE 2021 FORM 990 TO THE BOARD OF DIRECTORS AND THE AUDIT COMMITTEE FOR RATIFICATION, SUBSEQUENT TO FINALIZATION OF THE RETURN. MANAGEMENT WILL HOWEVER REVERT TO THE STANDARD PROCESS OF SUBMITTING ALL FUTURE DRAFT RETURNS FOR REVIEW BY THE BOARD OF DIRECTORS AND AUDIT COMMITTEE, PRIOR TO FINALIZING RETURNS FOR FILING WITH THE IRS. FORM 990, PART VI, SECTION B, LINE 12C NEW BOARD MEMBERS ARE PROVIDED A CONFLICT OF INTEREST POLICY STATEMENT TO READ, DISCLOSE ANY CONFLICTING ITEMS AND SIGN. IF THERE ARE ITEMS THAT RESULT IN A CONFLICT OF INTEREST DURING THE COURSE OF THEIR BOARD MEMBERSHIP, BOARD MEMBERS RECUSE THEMSELVES FROM THAT DISCUSSION AND VOTE. EACH MEMBER IS GIVEN A CONFLICT OF INTEREST POLICY STATEMENT ANNUALLY TO READ, DISCLOSE ANY CONFLICTING ITEMS AND SIGN. FORM 990, PART VI, SECTION B, LINE 15 SALARIES ARE REVIEWED BY THE CHS COMPENSATION COMMITTEE WHICH INCLUDES THE DIRECTOR OF TOTAL REWARDS AND THE CHIEF TALENT OFFICER. EACH YEAR THE COMPENSATION COMMITTEE COMMISSIONS AN INDEPENDENT SALARY SURVEY AND THE RESULTS ARE PRESENTED TO THE BOARD FOR REVIEW & APPROVAL. THE COMPENSATION FOR CEO IS APPROVED BY THE BOARD. FORM 990, PART VI, SECTION C, LINE 18 THE ORGANIZATION'S 990 & 990-T ARE MADE AVAILABLE TO FEDERAL/STATE & PRIVATE FUNDING SOURCES DURING ROUTINE GRANTS APPLICATION PROCESS. FORM 990, PART VI, SECTION C, LINE 19 GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS ARE AVAILABLE TO THE PUBLIC ON REQUEST FOR THE SAME PERIOD OF DISCLOSURE AS SET FORTH IN SECTION 6104(D). FORM 990, PART XI, LINE 9: CHANGE IN BENEFICIAL INTEREST IN THE NET ASSETS OF CHS FOUNDATION, INC. -3,498,200. FORM 990, PART XII, LINE 2C THIS PROCESS HAS NOT CHANGED FROM PRIOR YEAR. FORM 990, SCHEDULE G, PART III, LINE 9B THE ORGANIZATION HELD RAFFLE GAMES WHICH WERE CONDUCTED WITHIN FLORIDA CODE. THE CASINO EVENTS HELD WAS NOT A REAL CASINO BUT A FUNNY MONEY GAME. 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