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M21-4 · Section 8.A

Fiduciary Accounting Quality Checklist

M21-4 section 8.A. Official source text with a separately reviewed Claim Raven explanation when available.

Claim Raven wrote the explanation that follows. The original VA text appears below it, unchanged.

What this means

This appendix shows the checklist VA uses to review the quality of fiduciary accounting work. It checks whether the records, financial safeguards, follow-up and any misuse actions were handled properly. The blank boxes describe possible review findings, not findings about your account.

How this may help with a claim

A beneficiary or fiduciary can use the sample to identify the accounting record or explanation behind a concern. A missing bank statement, an unexplained balance or an absent approval letter is a more specific question to raise than a general claim that the accounting was mishandled.

What to review in your file

  • Start with the audit and its supporting records. The sample checks oversight dates and tasks, financial-account verification, accounting notices, credit-report authorization, fees, reimbursement of excessive fees, and reconciliation of the starting balance, income, expenses and ending balance. It also checks surety-bond documentation, withdrawal agreements and whether required material was received before accounting approval.

  • Keep accounting decisions separate from fund usage review. The checklist distinguishes disapproval, waiver, suspension, a misuse allegation, an examination to obtain missing information and assistance with completing an accounting. Its later questions examine fund usage review documents, extensions, follow-up contacts and system updates. A question being present does not mean that action is required in every case.

  • For a misuse concern, distinguish the allegation, investigation, determination and reissuance records. The sample checks documentation, signatures, due diligence, referrals, calculation of the misuse amount, the recipient of reissued funds and the amount reissued. Those are separate review points, not proof that misuse occurred.

Important limits

This is a sample internal quality checklist, not an accounting approval, a finding of misuse or a rule granting benefits. Its critical and non-critical labels classify review questions. The original header identifies both NFACQR and NFMISUSEQR and names the checklist NFACQR6/2026. Apply the governing procedure and the facts of the case before treating an error description as a required action.

Search terms when useful

Phrases that may help when searching your claim file or this library.

  • fiduciary accounting quality review
  • accounting balance reconciliation
  • fund usage review follow-up
  • misuse determination and reissuance

Review your own claim records

Start a free Claim Readiness Review to check one claim document for what it supports and what may be missing. Or create a free account to explore Claim Raven.

The review cannot guarantee a VA decision or replace an accredited representative. You decide what to file.

Original VA guidance

The official VA text of this section

Official section title: Accounting Quality Checklist

This page reproduces the VA text. Use the official VA source for any images and linked documents.

Appendix A. Accounting Quality Checklist

Change Date

August 31, 2026

Scroll sideways to see the full table.

Appendix A.a. Accounting Quality Checklist

The following is a sample of the Accounting Quality Checklist.

This is an image of the accounting quality checklist.
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Questions3–5 accounting notification/follow-up, audit, credit-report authorization.
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Continuation of question5 error descriptions, including signed form/version/authorization alternatives.
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Questions6–8 fees, excess-fee reimbursement, account-balance reconciliation.
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Questions9–11 surety bonds, withdrawal agreement, accounting-approval requirements;11 continues.
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Question11 error-description continuation.
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Questions12–14 disposition, accounting/FUR waiver, suspension.
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Questions15–17 misuse allegation and fund-usage field examination/assistance.
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Questions18–20 FUR processes, required elements, system/document updates;20 continues.
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Question20 error-description continuation.
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Questions21–23 FUR follow-up, misuse allegation and investigation;23 continues.
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Question23 investigation error-description continuation.
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Questions24–25 misuse determination and reissuance.
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