REDACTED VERSION nbsp;·nbsp; Payee identities have been redacted pending formal proceedings. An unredacted version is available to authorized parties on request.
Companion document: RCA Financial Review Narrative v6 — interpretive layer (pattern narrative, governance analysis, regulatory framework, recommendations).
This document: Specific transactions, vendor detail, amounts, dates, and anomaly data only. No interpretive sentences. Every entry is a citable fact.
Section A · Tiered Findings Index
Findings in descending severity. Tier classification reflects evidentiary confidence and immediacy of action required.
Tier 4 · Escalation Required
T4-01 · Unlicensed Community Management
Evidence: NRED license records; NRS 116A.400; NRED Case 2025-610
Risk: Every management action, disbursement authorization, and contractual execution during the review period was performed without legal authority. All vendor payments approved by Haldeman are potentially void ab initio.
Recommended Action: Regulatory referral — NRED; supplement NRED Case 2025-610; refer to Nevada AG for civil enforcement; criminal referral for review pending further legal assessment
T4-02 · Reserve Account Control Vested in Management Company
Evidence: Reserve account May 2025 statement — account titled in name of Nevada Community Management LLC as agent; NRS 116.3103
Risk: Signatory authority over association reserve funds rests with the management company, not the board. Every reserve disbursement during the review period was authorized by a party with no legal authority to do so.
Recommended Action: Engage association counsel for immediate account retitling; freeze reserve account pending board resolution; refer to NRED as element of T4-01 complaint
T4-03 · 107xx Secondary Check Series — Unidentified Payee, No Authorization
Evidence: Bank transaction records; 43 checks; $61,685.81 total; May 2025 – March 2026; no payee identified; no board authorization in any meeting minutes
Risk: A parallel disbursement channel operating outside the primary AvidPay tracking system, with no identified recipient, constitutes an unaccounted outflow of association funds across the full review period.
Recommended Action: Obtain all check images for series; ADP payroll register reconciliation; attorney referral; criminal referral for review
T4-04 · Reserve Draw — No Prior Authorization; Ratification Mismatch
Evidence: Reserve account Sep 2025 statement; AvidPay reference; September 22, 2025 minutes; March 9, 2026 minutes; NRS 116.31083
Risk: $41,108.35 disbursed September 11, 2025, eleven days before the next board meeting, with no authorization appearing in those minutes. March 9, 2026 ratification of $164,000 does not match the amount drawn.
Recommended Action: Obtain contract, scope of work, and invoices; attorney referral; document $122,891.65 differential for potential civil recovery
T4-05 · CHECK 10004 — $185,079.26 Circular Reserve Transfer; Payee Unidentified
Evidence: Reserve account — November 10, 2025 web transfer out ($185,079.26); December 2, 2025 web transfer in ($185,079.26); December 4, 2025 CHECK 10004 ($185,079.26); no payee identified on statement; no board authorization in any meeting minutes; NRS 116.31083
Transfer Sequence: (1) November 10, 2025 — Reserve → Operating via web transfer, $185,079.26; (2) December 2, 2025 — Operating → Reserve via web transfer, $185,079.26 (returned); (3) December 4, 2025 — Reserve → CHECK 10004, $185,079.26, payee unidentified
Risk: Largest single disbursement in the review period. The two-day return of funds to the reserve account before the check cleared is consistent with staging to obscure the ultimate recipient. No board authorization documented for any step in this sequence. October and November 2025 — the months with no clean board financial approval — make this disbursement window one with zero governance oversight.
Recommended Action: Obtain CHECK 10004 image and payee identification; attorney referral; regulatory referral. If the Nevada Real Estate Division or Commission orders production, Nevada Community Management can be compelled to submit the check image and payee records.
Tier 3 · Potential Findings
T3-01 · Reserve Draws — Consecutive Identical Amounts, No Authorization
Evidence: Reserve account July 2025 and August 2025 statements; July 2025 minutes — not produced; August 2025 minutes — not produced
Confidence: Two consecutive $17,300 reserve draws to same payee with no meeting documentation for either month; no reserve study line item identified for
T3-02 · Board Minutes Systematic Period Misdating
Evidence: September 22, 2025 minutes — agenda period "February – June 2025"; recorded motion approves "November 2024 – January 2025 financials." March 9, 2026 minutes — agenda period "July – November 2025"; recorded motion approves "July – September 2025 financials" only. Source-verified against both documents.
Confidence: Two independently documented instances; October and November 2025 — months of highest-value reserve transfers — have never been cleanly approved in any board action
T3-03 · Missing July 2025 Board Minutes
Evidence: April 21, 2025 minutes — meeting referenced as scheduled for July 2025; no July minutes produced; first $17,300 reserve draw occurred in July 2025
Confidence: Meeting was scheduled per prior minutes; absence cannot be attributed to cancellation without written confirmation
T3-04 · Page Haldeman Direct AvidPay Payments — No Authorization
Evidence: Operating account statements; Sep 2025: $616.29 (3 payments); Oct 2025: $175.00; total: $791.29; payment channel: AvidPay; no contract or board resolution identified
Confidence: Manager receiving payments from the account she oversees; no documented employment agreement or board authorization found
Tier 2 · Red Flags
T2-01 · — Payments Above Ratified Rate; No SOS Record; Bounced First Payment
Observations: Avg monthly payment $7,759; board ratified $7,530/month; first payment ($8,275.88) returned; no NV SOS entity record found; no contract produced
Why flagged: Billing above ratified rate; entity identity unverifiable; no contract supports any amount
Further investigation: SOS search all adjacent states; obtain contract; reconcile all payments against ratified rate
T2-02 · — December Clustering; Reversal; Entity in Default
Observations: 4 payments December 2025, total $10,543; $9,653 reversal January 2026; entity formed January 2025; entity in default status by year-end 2025
Why flagged: Multiple payments in single month; reversal without documented explanation; payment to entity known to be in default
Further investigation: Invoices for all December 2025 payments; reason for reversal; SOS entity status documentation
T2-03 · / — Dual Vendor Codes, Possible Same Entity
Observations: $6,803 combined Q2–Q3 2025; two vendor codes for what may be a single entity; identity unverified; no SOS record confirmed
Why flagged: Dual vendor codes for a single entity can obscure total payment volume and circumvent approval thresholds
Further investigation: Entity resolution; combine totals under single vendor record; contract and invoice review
T2-04 · Benford's Law Non-Conformity — Full Dataset and AvidPay Channel
Observations: Debit MAD 0.0369 (threshold 0.015; classification: HIGH RISK); full dataset MAD 0.0226 (non-conformity); AvidPay channel MAD 0.0323 (HIGH RISK); digit-1 excess +13.3%; digit-3 deficit −6.1%
Why flagged: Debit MAD is more than twice the non-conformity threshold; AvidPay channel shows independent non-conformity; compound signal
Further investigation: Transaction-level review of $10,000–$19,999 debit cluster; all AvidPay disbursements to unidentified vendors
T2-05 · Check Series Gaps — Primary and Secondary Series
Observations: Primary series (10xxx): gaps at 10005 and 10063–10065; Secondary series (100xxx): 10 consecutive checks unaccounted for — 100818 through 100827
Why flagged: Sequential gaps in an otherwise continuous series indicate unproduced checks or out-of-sequence issuance
Further investigation: Check images for all gap positions; check register reconciliation
T2-06 · — Duplicate Same-Authorization-Date Payments
Observations: Two identical $1,125 payments to in August 2025 recorded on the same authorization date
Why flagged: Identical amount, same payee, same authorization date — standard duplicate payment indicator
Further investigation: Obtain invoices; confirm whether services were rendered twice; demand refund if duplicate confirmed
Tier 1 · Anomalies
T1-01 · LV Valley Water — Consecutive Identical Monthly Charges
Observation: LV Valley Water account #0005325401 — $5,285.00 in May 2025 and $5,285.00 in June 2025
Status: Requires explanation; insufficient evidence to elevate — independent meter audit recommended
T1-02 · New Vision Community Management LLC — Relationship Unestablished
Observation: Entity name appears in review context; relationship to Nevada Community Management LLC and to RCA not yet documented
Status: Requires explanation; entity research and payment history review required before assessment
T1-03 · Special Assessment Authorization — Documentation Not Produced
Observation: Reserve study (Complex Solutions, July 2023) references special assessments of $250,000 (2024) and $100,000 (2025); no authorization documentation or owner notice produced
Status: Requires explanation; production demand outstanding; insufficient evidence to classify pending document review
T1-04 · CHECK 10005 and CHECK 10006 — Reserve Account; Payee Unidentified
Observation: CHECK 10005: $33,600, January 2026, reserve account; CHECK 10006: $43,745, March 2026, reserve account; payee unidentified; check images not produced
Status: Requires explanation; check images required; may escalate to Tier 3 or Tier 4 upon payee identification
Section B · Vendor / Payee Analysis
One table per flagged vendor. Tabular format only.
B.1 ·
| Field | Detail |
|---|
| Vendor Code | |
| Payment Channel | AvidPay |
| Avg Monthly Payment | $7,759 |
| Board Ratified Rate | $7,530/month |
| First Payment | $8,275.88 — returned (bounced) |
| Period | May 2025 – March 2026 |
| Tier | Tier 2 — Red Flag |
| Contract Status | Not produced |
| NV SOS Entity Record | Not found |
| Evidence Gap | Contract; SOS entity status; monthly invoices; explanation for billing above ratified rate |
B.2 ·
| Field | Detail |
|---|
| Vendor Code | |
| Account(s) | Reserve account + Operating account |
| Reserve Draw — July 2025 | $17,300.00 — no authorization; no July board minutes |
| Reserve Draw — August 2025 | $17,300.00 — identical amount; no authorization; no August board minutes |
| Total Reserve Draws | $34,600.00 |
| Operating Duplicate | $5,640.00 — July 10, 2025; $5,640.00 — July 21, 2025 (9-day interval; different check numbers) |
| Tier | Tier 3 (reserve draws) · Tier 2 (operating duplicate) |
| Contract Status | Not produced |
| NV SOS Entity Record | Not found |
| Reserve Study Basis | No line item identified in Complex Solutions July 2023 study |
| Board Mention | No mention in any minutes for the review period |
| Evidence Gap | Entity identity; contract; purpose of reserve draws; reconciliation of operating duplicate |
B.3 ·
| Field | Detail |
|---|
| Vendor Code | |
| Disbursement Date | September 11, 2025 |
| Amount Drawn | $41,108.35 |
| Payment Channel | AvidPay — reserve account |
| Authorization at Disbursement | None — next board meeting September 22, 2025; no authorization in those minutes |
| Subsequent Ratification | March 9, 2026 — "the ATI proposal for $164,000"; Director Dougherty objected; motion carried over objection |
| Ratification Gap | Six months |
| Amount Differential | Ratified: $164,000.00 | Drawn: $41,108.35 | Differential: $122,891.65 — unexplained |
| Tier | Tier 4 — Escalation Required |
| Evidence Gap | Contract; scope of work; invoices; documentation for $122,891.65 differential; licensing records |
B.4 ·
| Field | Detail |
|---|
| Vendor Code | |
| December 2025 Payments | 4 payments; total $10,543.00 |
| January 2026 Reversal | $9,653.00 reversed — reason not documented |
| Net Amount | $890.00 after reversal |
| Entity Formation Date | January 2025 |
| Entity Status at Payment Date | In default |
| Tier | Tier 2 — Red Flag |
| Evidence Gap | Invoices for all 4 December payments; reason for reversal; SOS status documentation; contract |
B.5 · /
| Field | Detail |
|---|
| Vendor Codes | and — possible same entity |
| Total Combined | $6,803.00 — Q2–Q3 2025 |
| NV SOS Entity Record | Unverified — identity resolution pending |
| Tier | Tier 2 — Red Flag |
| Evidence Gap | Entity resolution; confirm single or two distinct vendors; contract; invoices; board authorization |
B.6 · Page Haldeman (Direct AvidPay Payments)
| Field | Detail |
|---|
| Payee | Page Haldeman — community manager of record |
| September 2025 | 3 payments; total $616.29 |
| October 2025 | 1 payment; $175.00 |
| Total | $791.29 |
| Payment Channel | AvidPay — operating account she oversees |
| Authorization | Not identified — no employment contract, personal services agreement, or board resolution located |
| Tier | Tier 3 — Potential Finding |
| Evidence Gap | Any contract, board authorization, or expense reimbursement documentation |
B.7 · 107xx Secondary Check Series
| Field | Detail |
|---|
| Series Prefix | 107xx |
| Check Count | 43 checks |
| Total Amount | $61,685.81 |
| Period | May 2025 – March 2026 (full review period) |
| Payee | Not identified on bank statements |
| Dominant Amount | $1,610.03 — 20 of 43 occurrences |
| Top 5 Amounts | $1,610.03 (×20) · $1,262.81 (×7) · $1,166.39 (×5) · $1,268.71 (×5) · $1,359.23 (×3) = 40 of 43 checks |
| Board Authorization | None — not mentioned in any meeting minutes for the review period |
| Tier | Tier 4 — Escalation Required |
| Evidence Gap | Check images for all 43 checks; payee identification; ADP payroll register; purpose inventory |
B.8 · CHECK 10004 / Unknown Payee — $185,079.26 Circular Reserve Transfer
| Field | Detail |
|---|
| Reference | CHECK 10004 — Reserve Account |
| Amount | $185,079.26 |
| Date Disbursed | December 4, 2025 |
| Payee | UNIDENTIFIED — not shown on bank statement |
| Payment Channel | Physical check — reserve account |
| Preceding Transfer (Nov 10) | $185,079.26 web transfer from Reserve → Operating |
| Return Transfer (Dec 2) | $185,079.26 web transfer from Operating → Reserve (two days before check) |
| Board Authorization | None — not mentioned in any meeting minutes for the review period |
| Governance Context | October and November 2025 financials were never cleanly approved per T3-02; this disbursement falls within that unapproved window |
| Tier | Tier 4 — Escalation Required |
| Evidence Gap | CHECK 10004 image; payee identification; purpose of transfer; board authorization documentation. State production order may compel Nevada Community Management to submit. |
Section C · Check Series & Disbursement Detail
C.1 · Primary Check Series (10xxx) — Reserve Account
| Check Number | Amount | Date | Payee | Status |
|---|
| 10001 | $17,300.00 | July 14, 2025 | (confirmed per CSV) | Amount and date confirmed from bank data; check image not produced |
| 10004 | $185,079.26 | December 4, 2025 | UNIDENTIFIED | Amount and date confirmed from bank data; payee unidentified — check image required; see T4-05. Note: separate CHECK 10004 exists in operating account (July 10, 2025, $880.60) — non-overlapping series on distinct accounts. |
| 10005 | $33,600.00 | January 2026 | UNIDENTIFIED | Gap position — check image required |
| 10006 | $43,745.00 | March 2026 | UNIDENTIFIED | Gap position — check image required |
| 10063–10065 | Unknown | Unknown | Unknown | Gap in operating series — unaccounted; check register entry required |
C.2 · Secondary Check Series (100xxx) — Gap and Outstanding Positions
| Check Range | Count | Status |
|---|
| 100818 – 100827 | 10 consecutive | Unaccounted — not reflected in statements reviewed; check images and register entries required |
| 100840 – 100843 | 4 | Identified in records; check images not produced |
| 100027 | 1 | $8,900.00 — cleared May 20, 2025; sole transaction in May 2025 reserve statement; payee unidentified on statement |
Section D · Reserve Account Transactions
| Date | Amount | Payee | Reference | Authorization Status |
|---|
| May 20, 2025 | $8,900.00 | Unidentified | CHECK 100027 | Unknown — no authorization document produced |
| July 2025 | $17,300.00 | | To be confirmed | NONE — no July 2025 board minutes exist |
| August 2025 | $17,300.00 | | To be confirmed | NONE — no August 2025 board minutes exist |
| September 11, 2025 | $41,108.35 | | AvidPay | NONE at disbursement — partial ratification March 9, 2026 ($164,000 ≠ $41,108.35) |
| November 10, 2025 | $185,079.26 | Operating account (internal transfer) | WEB TFR Reserve→Operating | NONE — reserve funds transferred to operating with no board authorization; returned December 2, 2025 |
| December 4, 2025 | $185,079.26 | UNIDENTIFIED | CHECK 10004 | NONE — largest single reserve disbursement in review period; funds returned to reserve two days prior then immediately drawn by check; payee unknown; check image required. State production order may compel NevCM disclosure. See T4-05. |
| January 2026 | $33,600.00 | UNIDENTIFIED | CHECK 10005 | Unknown — check image required |
| March 2026 | $43,745.00 | UNIDENTIFIED | CHECK 10006 | Unknown — check image required |
All amounts sourced from RCA_Bank_Transactions.csv (895 rows) and FCB monthly statements, May 2025 – March 2026. CHECK 10001 and CHECK 10004 amounts confirmed from CSV data; check images not produced. Payees marked UNIDENTIFIED require check image production for confirmation.
Section E · Statistical Screening Results
E.1 · Benford's Law Analysis
Dataset: 895 rows · both accounts · May 2025 – March 2026 | Debit subset: 484 transactions; $1,733,249.53 | Full dataset: 892 non-zero transactions; $3,235,652.88
Conformity thresholds: <0.006 = Close conformity · 0.006–0.012 = Acceptable · 0.012–0.015 = Marginally acceptable · >0.015 = Non-conformity
| First Digit | Expected % | Debits Observed | Obs % | Deviation | Flag |
|---|
| 1 | 30.1% | 210 | 43.4% | +13.3% | FLAGGED |
| 2 | 17.6% | 79 | 16.3% | −1.3% | — |
| 3 | 12.5% | 31 | 6.4% | −6.1% | FLAGGED |
| 4 | 9.7% | 39 | 8.1% | −1.6% | — |
| 5 | 7.9% | 48 | 9.9% | +2.0% | — |
| 6 | 6.7% | 17 | 3.5% | −3.2% | — |
| 7 | 5.8% | 18 | 3.7% | −2.1% | — |
| 8 | 5.1% | 31 | 6.4% | +1.3% | — |
| 9 | 4.6% | 11 | 2.3% | −2.3% | — |
| Subset | N | MAD | Classification |
|---|
| Debit transactions (primary) | 484 | 0.0369 | High Risk / Non-Conformity |
| Full dataset (all transaction types) | 892 | 0.0226 | Non-Conformity |
| AvidPay channel only | 118 | 0.0323 | High Risk / Non-Conformity |
| Operating account (debits) | — | 0.0368 | High Risk / Non-Conformity |
| Reserve account | 22 | N/A | Excluded — below 100-transaction threshold |
Digit-1 Excess: 210 observed vs. 146 expected. Two concentration bands: 114 transactions ($100–$199); 18 transactions ($10,000–$19,999 — includes and related payments clustering near $17,300–$17,504).
Digit-3 Deficit: 31 observed vs. 60 expected. Suppression of $300–$399 and $3,000–$3,999 amounts.
AvidPay Channel: $400,003.66 total processed; digit-1 at 39.8% (expected 30.1%); primary conduit for , , , .
107xx Series: Dominant fixed-amount clustering ($1,610.03 × 20 occurrences) produces digit-frequency pattern inconsistent with organic payroll variation.
Limitations: Benford's is a screening tool, not a fraud finding. Recurring fixed payments contribute to digit skew independent of manipulation. The $100–$199 band excess is partly attributable to legitimate recurring payments. The $10,000–$19,999 cluster and AvidPay channel deviation are not explained by routine fixed-payment patterns.
Tier Classification: Tier 2 — Red Flag; warrants transaction-level review of $10,000–$19,999 debit cluster and all AvidPay disbursements to unidentified vendors.
E.2 · Pattern Screening Summary
| Pattern Type | Finding | Tier |
|---|
| Consecutive identical amounts — same payee | reserve: $17,300 × 2 (Jul/Aug 2025); : $1,125 × 2 (same auth date, Aug 2025) | T3 / T2 |
| Near-duplicate — same payee, short interval | operating: $5,640 × 2 (Jul 10 and Jul 21, 2025; 9 days apart; different check numbers) | T2 |
| Parallel disbursement channel — no payee | 107xx series — 43 checks, $61,685.81, full review period | T4 |
| Manager self-payment from managed account | Page Haldeman — $791.29 AvidPay from operating account | T3 |
| Payment to entity in default | — 4 payments December 2025; entity in default status | T2 |
| Above-ratified-rate billing | — avg $7,759/month vs. ratified $7,530/month | T2 |
Section F · Transaction Evidence Appendices
- Appendix A: Monthly balance verification tables — Operating and Reserve, May 2025 – March 2026 (opening balance, total credits, total debits, closing balance, statement source)
- Appendix B: Vendor ledger — all AvidPay disbursements by vendor code, full period (date, amount, check/reference, running total)
- Appendix C: Check sequence map — all series, full period (all check numbers, amounts, dates, gaps flagged)
- Appendix D: Minutes cross-reference matrix — disbursement vs. authorization by meeting date (authorization status: Y / N / Unknown for each reserve draw)
- Appendix E: Reserve draw chronology vs. reserve study line items (each reserve disbursement matched against Complex Solutions July 2023 study components; basis: confirmed / not found)
- Appendix F: Benford's Law full analysis — digit-by-digit tables, MAD calculations, flagged bucket detail (all subsets per Section E.1)
- Appendix G: SOS entity status documentation — verified filings for all vendor codes, May 9, 2026
- Appendix H: Page Haldeman NRED license history (Salesperson S.0042769 — Inactive Involuntary; Property Manager PM.0142769 — Inactive Normal; CAM certificate — never held)
Chain of Custody Notation — Template
Document Reference
Source: [Document name, date, page/line reference]
Provided by: [Who provided this document and when]
Analysis date: [Date of review]
Analyst: Designee — Draft Pending Patrick's Review & Approval