CLPF #790 · IRS ENROLLED AGENTCERTIFIED SBE / SB · MUNICIPAL FISCAL AGENCY

The SBE Compliance Shield™
for California Cities.

Brown Management is a Certified Small Business Enterprise (SBE) and California's licensed Active Neutral for municipal grant administration. We help cities meet their mandatory 25% SBE participation goals while providing elite fiduciary oversight — every dollar held in a regulated trust account, every vendor verified before payment, every audit finding documented before the auditor arrives.

100%
Grant Retention Rate
$0
Clawback Exposure
10
VULCAN Audit Triggers
Certified SBE
SBE Participation Eligible

THE RISK

The City Manager’s Biggest Risk Is an External Audit Finding.

When a grant is mismanaged — vendor overbilling goes undetected, documents are filed late, or funds are co-mingled — it is the City Manager’s name on the audit finding. The consequences range from state clawbacks to federal debarment.

As your Neutral Compliance Shield, Brown Management stands between the City and every audit risk — before the auditor arrives. We are licensed, bonded, court-supervised, and AI-powered. We represent the fund, not any party with an interest in it.

Vendor overbilling goes undetected
State audit finding + clawback demand
Grant documents filed late
Loss of future award eligibility
Prop 64 funds co-mingled
State Controller investigation
No independent verification
Council liability exposure

HOW IT WORKS

The Fiduciary Buffer Model

Brown Management sits between the City and its vendors — holding funds, verifying delivery, and releasing payment only when every compliance condition is met.

01

Trust Account

Grant and contract funds are held in a regulated fiduciary trust account — the same structure California probate courts rely on to protect estate assets.

02

VULCAN Audit Engine

AXON STEWARD OS™ runs 10 automated audit triggers against every invoice, contract amendment, and disbursement — flagging issues before payment is released.

03

Verified Disbursement

Vendors are paid only after delivery is confirmed and all compliance conditions are satisfied. Every transaction is documented and audit-ready.

The Recovery Bonus Model — Self-Funding Engagement

Our fee structure is designed to be self-funding. Brown Management's 5% fiscal agency fee is recovered through vendor overbilling detection, grant fund preservation, and penalty avoidance. In most engagements, the first audit cycle recovers more than the annual fee — meaning the City pays nothing net.

5%
of contract value

TARGET CITIES

South Bay Municipal Pipeline

FIRST STRIKEContract & Procurement Oversight

Carson — Contract & Procurement Oversight

State Controller audit found 900% contract amendment — documented, public, actionable.

Grant / Fund
General Fund / Vendor Contracts
Contact Point
City Manager's Office
Urgency Signal
Active audit finding

AXON STEWARD OS™ · VULCAN ENGINE

10 Audit Triggers That Find the First $10,000

Before Brown Management is paid a single dollar, VULCAN runs these 10 automated checks against every transaction in the pilot grant cycle.

1
Ghost Milestone Trigger
Flags any invoice where Proof of Work (photo/log) lacks a GPS timestamp or geo-tag matching the project site. No verified location = payment held.
Prevents phantom billing
2
EA Tax Variance Check
As an IRS Enrolled Agent, VULCAN flags vendors charging incorrect Sales & Use tax rates for municipal exemptions — recovering the spread for the City.
Avg. $3K–$12K per cycle
3
Duplicate Fiduciary Gate
Detects split-invoicing — where a vendor breaks a $5,000 limit into two $2,500 charges to bypass City Manager approval thresholds.
Prevents approval bypass
4
Insurance Expiration Lock
Automatically freezes payments 24 hours before a vendor's Certificate of Insurance expires, shielding the City from uninsured liability exposure.
Eliminates liability gap
5
Prevailing Wage Delta
Cross-references payroll reports against CA Department of Industrial Relations (DIR) standards to identify underpayment before it becomes a labor lawsuit.
Prevents DIR penalties
6
Grant-Only Filter
Flags any line item not explicitly allowed under the Prop 64 Grant Handbook. Ineligible expenditures are held before disbursement, preventing state clawbacks.
Preserves 100% of award
7
Early-Pay Discount Capture
Identifies vendors offering 2/10 Net 30 discount terms. By paying within 10 days, the City captures a 2% discount on every qualifying invoice.
2% on every invoice
8
Change Order Loop
Flags any invoice amount exceeding the original Purchase Order by more than 5% without an attached, digitally-signed City Authorization.
Prevents unauthorized overruns
9
Late Filing Credit Memo
When a vendor files their compliance report late, VULCAN calculates the City's administrative processing cost and issues a credit memo against the next invoice.
Recovers administrative cost
10
Secretary of State Active Check
Real-time verification that every vendor is active and in good standing with the CA FTB and SOS. Suspended entity status = payment held immediately.
Prevents payments to suspended entities

THE PILOT PROGRAM

The Prop 64 Pilot — One Grant Cycle. Zero Risk.

We propose a single Prop 64 cannabis tax grant cycle as a proof-of-concept engagement. Brown Management manages the fund administration, runs all 10 VULCAN audit triggers, and delivers a full compliance report at the end of the cycle.

The fee structure is designed to align incentives: a $2,500/month base covers fiduciary oversight and compliance monitoring, a 2% success fee is applied to grant funds administered, and a 15% Recovery Bonus on identified overbilling is self-funding in most engagements. The total 90-day pilot engagement stays under $25K — executable at the City Manager level without Council agenda placement.

One grant cycle — 90-day engagement
Full VULCAN audit trigger suite deployed
Audit-ready compliance report delivered
Recovery Bonus model — self-funding structure
Engagement Letter — no Council approval required under $25K

Pilot Engagement Structure

Engagement TypeFiscal Agent — Fiduciary Trust Account
Term90-Day Pilot Cycle
Base Fee$2,500/month — fiduciary oversight & compliance monitoring
Success Fee2% of grant funds administered
Recovery Bonus15% of overbilling recovered — self-funding
ExecutionEngagement Letter — City Manager Level (under $25K)
DeliverableFull audit-ready compliance report
Risk to CityRecovery Bonus offsets base fee in most engagements

CREDENTIAL STACK

What No Other Bidder Has

CLPF #790
California Licensed Professional Fiduciary
Verified
IRS Enrolled Agent
Federal Tax Authority — EA Credential
Verified
Fiduciary Bond
Personally bonded — public funds protected
Verified
Court-Supervised Standard
Same framework California courts rely on
Verified
AXON STEWARD OS™
AI-powered audit trigger engine
Verified
Recovery Bonus Model
Self-funding via recovered overbilling
Verified

The CLPF + EA combination is unique in the South Bay municipal market. No other fiduciary vendor holds both a California Licensed Professional Fiduciary credential and an IRS Enrolled Agent designation — giving Brown Management authority over both the trust account and the tax compliance layer simultaneously.

NOT READY FOR THE PILOT?

The Shadow Audit — Find Lost Money First. Free.

Not ready to hand over a full grant cycle? We understand. Instead, let us run the last 12 months of your vendor invoices through the VULCAN engine at no charge. We show you exactly what we would have caught — and what it cost the City. If we find nothing, you owe nothing and lose nothing. If we find something, you have the evidence to justify the full engagement.

12 months of invoices analyzed at no cost
Full VULCAN 10-trigger audit run on historical data
Written findings report delivered within 10 business days
No contract, no commitment, no Council approval required

SHADOW AUDIT — SAMPLE FINDING

Duplicate Fiduciary Gate
3 invoices split below $5K threshold
$14,200 recovered
EA Tax Variance Check
Municipal exemption not applied on 7 invoices
$3,840 recovered
Change Order Loop
2 invoices exceeded PO by >5% without authorization
$8,500 flagged
SOS Active Check
1 vendor suspended by FTB during contract period
$22,000 held
Total Found$48,540

Illustrative example based on typical municipal invoice patterns.

REQUEST THE PILOT

Ready to Protect Your Grant Funds?

We built the Prop 64 compliance framework around your city's specific obligations. Let us show you the draft reporting structure before you sign anything.

No RFP required. Engagement Letter executed at City Manager level under $25K.