Grant management training for non-profit applicants and recipients,leadership strategies,coaching professional body uk - PDF Books

30.04.2015, admin  
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EPA is committed to ensuring that its grants programs meet the highest management and fiduciary standards, and further the agency's mission of protecting human health and the environment. This web-based training is designed to help non-profit recipients of EPA grants and cooperative agreements (grants or grant agreements) manage their grants in a manner that assures EPA meets this vision. EPA’s regulation that applies to grants is found in Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-profit Organizations, (see 40 CFR Part 30). The training is organized generally consistent with EPA’s grant making process from before EPA awards a grant through the closeout of the grant. You will apply for an EPA grant either in response to a competitive request for grant applications or proposals or by submitting an unsolicited proposal.
If you are awarded an EPA grant you will then manage the grant activities to completion, including requesting payments, purchasing goods and services, keeping records, submitting reports, and closing the grant when it is complete. While this is a training course, it may also be used as guidance for various activities as your organization manages an EPA grant project. It is EPA policy to promote competition in the award of grants to the maximum extent practicable and to assure the competitive process is fair and open and that no applicant has an unfair competitive advantage.
If EPA changes the requirements of a solicitation before the application deadline, EPA will notify all potential applicants in the same manner that the original announcement was announced. Each full solicitation contains the programmatic description of the funding opportunity and sufficient information to help you make an informed decision about whether to submit a proposal. Evaluation Criteria: The solicitation will include the evaluation criteria and process EPA will use in selecting among applicants.
If you determine your organization is eligible to compete for an award and has a project consistent with EPA’s needs, you must develop a detailed proposal describing the nature of your proposed project. The proposal must include a proposed budget and you should assure the scope of your project is consistent with the budget and the applicable Office of Management and Budget (OMB) Cost Principle Circulars  (see peparing a buget and part 2 - demonstrating management system capability for further information). EPA will consider all information in your proposal, along with information EPA may have from other sources concerning your past performance, your management capability, and your responsiveness to the requirements of the solicitation in evaluating whether EPA will select your proposal for an EPA grant. An outcome is the result, effect, or consequence that will occur as a result of an environmental activity under your grant.
Your grant proposal must make clear the outputs and outcomes you expect to achieve from your grant project and how you will measure progress towards achieving them (see Section I in the sample solicitation). The grant solicitation will include ranking criteria for evaluating your plan for tracking and measuring progress toward achieving the expected outputs and outcomes. In addition, the grant solicitation will include ranking criteria for evaluating your past performance in reporting on outputs and outcomes. In developing the budget, you should consider the amount EPA has stated is available in the particular solicitation to which you are responding and you must base your budget on financial information from your accounting system.
You must now make the package final by adding the required information and moving the attached documents to the completed side. If you submit the application electronically,  will notify EPA that your application is available for review. The panel will review and rank or prepare a list of qualified and unqualified proposals or applications based on the evaluation criteria and relative weights included in the solicitation. Each solicitation describes the process that will be used to rank responding applications and applicants. EPA will notify you in writing or by e-mail, if your organization’s application was not selected for funding. Not selected for award based on their ranking after evaluation against the ranking and selection criteria in the solicitation.
After a debriefing, under the circumstances discussed below, you may file a dispute under Appendix A to EPA’s Policy for Competition of Assistance Agreement, EPA Order 5700.A1 with the Grants Competition Disputes Decision Official (GCDDO). You do not agree with the determination that your organization is not eligible for award consideration because your application or project did not meet the threshold eligibility requirements contained in the announcement. Generally, the Grants Competition Disputes Decision Official (GCDDO) will deny, without review, disputes based on scoring issues. The Grants Competition Disputes Decision Official (GCDDO) will consult with the Program Office, the Office of General Counsel, and the grants competition advocate and will then determine whether it is in the agency’s best interest to delay grant awards pending resolution of the dispute. The Grants Competition Disputes Decision Official (GCDDO) will establish the process and schedule for resolving your dispute and advise you and the affected EPA Program Office.
After reviewing all of the information relevant to the dispute, the Grants Competition Disputes Decision Official (GCDDO), after consultation with the grants competition advocate and concurrence of the Office of General Counsel, will timely issue a final written decision regarding the dispute.
Before EPA awards a grant to your organization, whether you are selected competitively, non-competitively, or based on your unsolicited proposal, the EPA Policy on Assessing Capabilities of Non-Profit Applicants for Managing Assistance Agreements, see EPA Policy on assessing Capabilities of Non-Profit Applicants for Managing Assistance Agreements EPA 5700.8 requires the EPA Grants Management Office (GMO) to assure your organization can be expected to meet certain management system requirements of EPA’s regulations. Basic requirements for Financial Management Systems are found in Section 30.21 of the Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-profit Organizations. Generally, you will have an accounting system that was developed with the assistance of a firm or person with accounting system development and management expertise or by obtaining any one of several excellent off-the-shelf software programs, and many times both. This training will help assure your answers on the EPA administrative capability questionnaire are complete and accurate. EPA’s regulation (40 CFR 30.21(a)) require that your financial management system be able to relate financial data to performance data and to develop unit cost information.
Comparing your financial data to your performance data allows you to compare estimated costs for various activities to the actual cost of carrying out the work.
Section 40 CFR 30.21(b)(1) of EPA’s regulations requires that your financial management system provide accurate, current, and complete disclosure of the financial results of your grant. In accordance with the principle of consistency, transactions related to your EPA project must be treated the same as for your other project’s transactions. Income that you must consider with respect to your EPA grant includes any income your organization earns as a result of the EPA grant project.
Also, many non-profit organizations use volunteer services to accomplish much of their work. To ensure the estimated cost of volunteer services is allowable, your organization must account for them.
Your financial management system must provide records that adequately identify the source and application of funds for EPA grant supported activities. Your financial management system must provide for effective control over and accountability for all funds, property and other assets.
All assets related to your EPA supported project must be recorded in your financial management system.
Your financial management system must provide for a comparison of outlays with budget amounts for each award, including, where appropriate, information related to performance and unit cost (40 CFR 30.21(b)(4)). In order to ensure you do not overspend on a particular activity at the expense of others so that organization is fully reimbursed for the federal share of your project costs, it is important that your accounting system provide information that is reliable for estimating costs.
Your financial management system must include written procedures to ensure there is a minimum of time between payments from the U.S. When you receive an EPA grant, you will be enrolled in an electronic funds transfer process (discussed later). Your financial management system must provide written procedures for determining the reasonableness, allocability and allowability of costs in accordance with the Cost Principles for Non-Profit Organizations, OMB Circular A-122 (2 CFR 230) (see 40 CFR 30.21(b)(6). Allocability – A cost is allocable to your grant if the goods or services involved are chargeable or assignable to such cost objective in accordance with relative benefits the grant receives or other equitable relationship. If a cost is direct and is incurred for the work of more than one grant or activity, you must allocate the amount among the affected grants and activities based on the extent the work benefits each grant or activity. Allowability – Certain costs, while legitimate business expenses, are not allowable under EPA grants.
It is treated consistently with policies and procedures that apply uniformly to both EPA grant activities and other activities of your organization.
It is recorded in accordance with your accounting system and generally accepted accounting principles (GAAP). Your financial management system must assure that cost accounting records are supported by source documentation (40 CFR 30.21(b)(7).
Your financial management system must provide procedures for conducting an audit in accordance with Audits of States, Local Governments, and Non-profit Organizations, OMB Circular A-133, if required. If your organization expends more than $500,000 in federal funds (the total from all federal agencies) in any of your fiscal years, you are subject to the Single Audit Act and you must conduct a single audit.
Also, regardless of whether your organization is subject to the Act, EPA’s Office of Inspector General may audit your EPA grants. Your financial management system must provide for and describe existing or planned indirect cost rate charges and systems Cost Principles for Non-Profit Organizations, OMB Circular A-122, Attachment A, Sections C and D. In order to substantiate a claim for the reimbursement of indirect costs your organization must develop an indirect cost rate proposal in accordance with the procedures in Cost Principles for Non-Profit Organizations, OMB Circular A-122, Attachment A, Sections C and D.
EPA has developed a Sample Indirect Cost Proposal Format for Non-profit Organization to assist you in developing an indirect cost rate proposal if you do not have one. You must submit your indirect cost rate proposal to your organization’s cognizant federal agency for review and approval.
EPA defines equipment as tangible nonexpendable personal property charged directly to your EPA assistance project having a useful life of more than one year and an acquisition cost of $5000 or more per unit (40 CFR 30.2(l).
The acquisition cost of equipment is the net invoice price of the equipment, including the cost of modifications, attachments, accessories, or auxiliary apparatus necessary to make it usable for your project. Title to equipment you purchase with grant funds vests in your organization subject to EPA’s interest as stated in grant conditions or as noted below. You may not use equipment purchased under a grant to provide services to non-federal outside organizations for a fee that is less than private companies charge for equivalent services, unless specifically authorized by Federal statute, for as long as EPA retains an interest in the equipment.
When you no longer need equipment for the original project or program, you may use it for other federally-sponsored activities, in the following order of priority: activities sponsored by EPA, then activities sponsored by other federal awarding agencies.
During the time you use the equipment for the EPA project, your organization may make it available for use on other projects or programs if that does not interfere with the work on the EPA project. If it is necessary to acquire replacement equipment during the EPA project or for continuing use on the project after the EPA grant ends and, if EPA approves, you may use the equipment to be replaced as a trade-in or sell the equipment and use the proceeds to offset the costs of the replacement equipment.

You must investigate any differences between quantities determined during the inventory and those shown in the accounting records to determine the reason for the difference.
Your equipment management system must provide controls to insure safeguards against loss, damage or theft of the property (40 CFR 30.34(f)(4).
You must investigate and fully document any loss, damage, or theft of equipment; if EPA owned the equipment, you must promptly notify EPA. Your property management system must provide for adequate maintenance of equipment (40 CFR 30.34(f)(5)).
EPA often calls purchasing under grants procurement, but we will use the term “purchasing” in this training. It is unlikely you will purchase the supplies, equipment, and services you need for your grant at an auction, but EPA’s purchasing guidance and requirements are designed to ensure that what you buy you get at a reasonable price in a fair and openly competitive way. You must settle all contractual and administrative issues arising out of contracts under your grant (40 CFR 30.41). You must ensure you do not purchase unnecessary things under your grant (40 CFR 30.44(a)(1)).
You must have written standards of conduct that apply to employees involved in purchasing (in particular, the award and administration of contracts for supplies, equipment, and services) (40 CFR 30.42). You must, to the maximum extent practicable, ensure open and free competition in your purchasing (40 CFR 30.43).
You must assure the cost or price of your supplies, equipment, and services is reasonable ((40 CFR 30.45). You must make positive efforts to use disadvantaged businesses, including small businesses, minority-owned firms, women's business enterprises, and firms in labor surplus areas, whenever possible (40 CFR 30.44(b)).
You may copyright any software or written material that is subject to copyright and was developed, or for which ownership was purchased, under an award. You must ensure you do not award a contract to any person (organization or individual) debarred or suspended or otherwise excluded from or ineligible for participation in Federal programs (40 CFR 30.13). See also the Purchasing Good and Servicessection of this training related to activities after award of a grant.
Your code of conduct must make clear that no employee, officer, or agent of your organization may participate in the selection, award, or administration of a contract under you EPA grant if a real or apparent conflict of interest would result. Conflicts of interest occur when your employee, officer, or agent, members of immediate families, partners, or organizations which employs or is about to employ any of these persons, has a financial or other interest in the firm selected for an award. Your code of conduct must provide for disciplinary actions for cases where your organization’s officers, employees, or agents violate the code (40 CFR 30.42).
These requirements also apply to labor costs that will be used for the non-federal share of the grant.
Travel costs are the expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business. EPA will notify your organization that it selected your proposal for an award by sending you a grant agreement or a cooperative agreement.
The difference between the two is that EPA will have substantial involvement in a cooperative agreement and EPA’s involvement will be stated in the terms and conditions of the agreement. The grant agreement will include appropriate terms and conditions and it will incorporate by reference your application and supporting information and EPA’s regulations and guidance. The budget or grant amount in your grant agreement may have been changed from those in your application. Your project officer should have negotiated all changes with you, but you should review the EPA amount offered and the revised budget to assure you can carryout the project within the budget and without additional EPA funds.
Even if your review is complete, the fact that EPA approves your grant does not ensure EPA will allow the cost of all activities or purchases you make under the grant, even if the activities and purchases are identified in your application.
If it is not, or if you incurred costs for the project before the beginning of the budget period, you should contact the EPA project officer to discuss an amendment.
Administrative – Administrative terms and conditions involve such things as payment, applicable regulations, statutory requirements and required administrative reports. Programmatic – Programmatic terms and conditions include the timing and content of progress reports, an explanation of substantial involvement for cooperative agreements, and special performance requirements. If you have significant problems with or you find mistakes in the grant agreement, including the terms and conditions, discuss them with your Project Officer as soon as possible.
When you are satisfied with the grant agreement, including the terms and conditions, your organization’s authorized representative should sign it and return a copy to EPA.
If, at some point, it becomes clear that you must change the direction or focus of your project or that it cannot be completed with the funds available, contact you project officer, explain the needed changes, and request an amendment, if necessary. In the case of a cooperative agreement, the terms and conditions may require you to obtain the project officer’s approval after completing a task before you proceed with a subsequent task or that you notify your project officer when you complete a task to allow for the project officer’s input as appropriate. The terms and conditions of your grant agreement will cover requirements relating to such things as reporting, payment, minority and women owned business enterprise use, payments to consultants, and lobbying. These administrative requirements are the nearly identical to those for all other federal agencies, although it is written for EPA.
For example, it provides specific guidance for purchasing goods or services necessary for your project and preparing necessary reports related to your project.
Click on this link to determine whether the funding opportunity you are reviewing is consistent with the expertise, interests, and mission of your organization.
If you are a non-profit organization (,) and non-profit organizations are not listedn among the eligible applicants you may not apply. It must also list expected outputs and outcomes.  (See Section I in the sample solicitation).
To accomplish this EPA’s grant solicitations require that grant proposals discuss environmental results and how they will be measured. Outputs may be quantitative or qualitative, but must be measurable during your grant project period.
For example, salaries must be based on the estimated number of hours each employee will spend on project work considering current salaries and any projected salary increases during the project. Postal Service, hand-delivered, or electronically delivered to the Agency, or include official delivery service documentation indicating EPA acceptance from a delivery service, on or before the deadline date published in the request for applications or request for initial rroposals.
However, panels also include employees of other federal agencies and non-federal personnel, but EPA staff must make final decisions on the relevance of particular proposals to program needs and the selection of recipients. The criteria represent areas of importance and emphasis to be considered in the selection process, and support meaningful and fair comparisons among competing applicants. EPA will conduct oral debriefings (perhaps by telephone) at a mutually agreeable time and place as soon as practicable after you submit your request. The Grants Competition Disputes Decision Official (GCDDO) is an EPA employee who was not involved in the grant competition and is from outside of office that conducted the competition.
At that time, the GMO will assure your organization meets the management capability requirements. The item numbers of the following training sections correspond to the question numbers on the questionnaire. In this way, you are quickly alerted when your costs significantly exceed the estimates on which your grant is based.
For example, if a project involves taking numerous samples of a pollutant and evaluating the components, this repetitive activity may lend itself to unit costing. In other words, your accounting system must be able to separate the transactions for your EPA grant project from the transactions for your other activities.
For example, a cost included in your overhead or indirect cost pool for general transactions must be included in the overhead or indirect cost pool for your EPA project. This means the actual amount of income for the project activities must be recorded when it is received.
All income and costs must be posted in the accounting system at or as near to the time they are incurred as possible. If you use volunteer services for your EPA grant project, a reasonable estimate of the value of those services may be allowable and charged to your project. This means, for example, that volunteers must maintain records of the time they spend on your project and submit the time sheets to you. You should record information on authorizations, obligations, unliquidated obligations, assets, outlays, income, and interest (40 CFR 30.21(b)(2)). To comply with EPA regulations, funds you use for your EPA project must be identified so they can be separated from those you use for other activities both as to source and use.
This means that all project related assets must be identified with an identifier such as an EPA project related account number or the EPA grant number.
That means that EPA will allow only actual (not budgeted) costs incurred for managing your grant project activities. As required in item 2 above, you can use the unit costs information for repetitive activities that will ensure future cost estimates for similar work are reliable. Details for determining whether a particular cost is reasonable can be found in the Cost Principles for Non-Profit Organizations, OMB Circular A-12, Attachment A, A.3.
If you determine a cost is not reasonable, you must adjust it to a reasonable amount before charging it to your grant project in your accounting system.
A primary source for determining whether a particular cost is allowable is the Cost Principles for Non-Profit Organizations, OMB Circular A-122 (2 CFR 230).
Attachment B lists many types of cost and explains whether they are allowable under grants.
Those records must be identified by the use of appropriate account numbers to ensure the EPA grant costs are charged to the EPA grant.
For example, you must have time sheets that support payroll charges and contracts and contractors’ bills that support contract costs.
Currently, audits are required for recipients expending $500,000 or more in federal funds during their fiscal year (40 CFR 30.26(a)).

If you conduct an audit in accordance with the Single Audit Act, EPA’s Office of Inspector General may still audit your EPA grants, but it will, to the extent practicable, build on the results of your single audit. Therefore, the costs cannot be readily and specifically identified with a particular project (your EPA grant project, for example) or activity. EPA also has a second, more detailed guidance document called the EPA Guide on How to Prepare an Indirect Cost Rate Proposal for a Non-Profit Organization. The results of each negotiation will be a written agreement between your organization and that agency. You must use the equipment for the EPA project as long as needed, whether or not the project or program continues to be supported by federal funds. During the inventory you must also verify the existence, current use, and continued need for the equipment.
Detailed guidance for such purchasing can be found in purchasing supplies, equipment, and services under EPA grants.
You must submit reports that indicate your compliance with this requirement on EPA Form 5700.52A.
You must also ensure your contractor does not award a subcontract to any person debarred or suspended or otherwise excluded from or ineligible for participation in federal assistance programs.
For purchases which exceed $100,000, these records must include the rationale for the method of procurement, the reason you selected the contract type, your justification for lack of competition when competitive bids or offers are not obtained, the reasons for contractor selection or rejection, and the basis for the contract price, including documentation of required price and cost analyses.
Fixed price contracts are used when effective competition based on a complete product description and clear plans and specifications is likely. Percentage of construction cost and cost plus a percentage cost contracts provide an incentive for the contractor to increase costs in order to increase profit. The standards must provide for disciplinary actions in the case of misconduct (40 CFR 30.42). Your officers, employees, and agents must neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, or others involved in your contracts.
In general, this means salaries and wages paid for work on the EPA grant must be the same as your organization pays for other work. Costs may be charged on an actual cost basis, on a per diem or mileage basis in lieu of actual costs incurred, or on a combination of the two, provided the method used is applied to an entire trip and not to selected days of the trip.
When you sign the grant agreement, you are agreeing to abide by all of its requirements and terms and conditions, so you should review it carefully before signing. As stated in the section on complete, current, and accurate cost data, the requirements for valuing donations are complex and are explained in OMB Circular A-122, Attachment B, 12.
Generally, it will be the same as the one you included in your application, but there the project officer may have negotiated a change with you or the grant award may have been delayed. You should mark out any terms and conditions with which you do not agree, sign the agreement and return it to EPA. Assure you understand and can comply with the terms and conditions before accepting the grant.
The project officer will give advice and assist you where possible, but the project is yours to pursue.
There are several steps for you to complete, however, before you are ready to submit the application. It should clearly address the evaluation criteria and explain how your proposed project meets the criteria in the solicitation. In response, grant applicants must ensure that their work plans contain defined outputs and, to the maximum extent practicable, defined outcomes. EPA will assure that individual reviewers do not have a conflict of interest with regard to a particular applicant or application.
EPA will rank the initial proposals and only those applicants whose proposals are selected for possible funding will be asked to submit final proposals and applications. For headquarters competitions, the Director, Office of Grants and Debarment (OGD), will select the Grants Competition Disputes Decision Official (GCDDO). Disputes may only be filed after a debriefing; the Grants Competition Disputes Decision Official (GCDDO) will dismiss disputes filed before, or in the absence of, a debriefing.
The Grants Competition Disputes Decision Official (GCDDO) will assure that you have reasonable access to relevant EPA records consistent with the standards contained in the Freedom of Information Act. If the GMO has not reviewed your organization’s management capability within four years and the proposed grant amount is for $200,000 or more, the GMO will request you to fill out an EPA administrative capability questionnaire in appendix A of the EPA Order. Even if EPA will not be reviewing your management systems, this training will refresh your understanding of applicable EPA requirements. In such an event, you should notify your project officer requesting an increase in the grant to cover your revised estimate based on the more accurate information. If your accounting system is based on when income accrues and when costs are incurred, you should assure all income and accrued costs are posted before reports covering the accounting period are prepared. Unallowable costs, of course, must be identified as such and must not be charged to the EPA award. For example, if, during your project, you produce and sell a book, the proceeds from the sale is program income. Generally, a specific identifier such as an account number or the grant number must be attached to accounting entries of funds related to your EPA project.
For example, your organization may have borrowed money to carry out some activities or buy equipment. The supporting information must be cross-referenced to the accounting entries and maintained in your filing system. The audit requirements under the Single Audit Act are complex, and this training does not cover the details of these audits.
In order to be allowable under your EPA grant, these costs must be grouped into common pools and distributed to the grant and all other benefiting activities by a cost allocation process. If your organization has not previously established an indirect cost rate with a federal agency, you should submit to the agency that awards you the most funds an initial indirect cost rate proposal immediately after you are advised that an EPA or other federal grant will be made and, in no event, later than three months after the grant’s effective date. If a dispute arises in a negotiation of an indirect cost rate between the cognizant agency and your organization, the dispute will be resolved in accordance with the dispute resolution process of the cognizant agency.
This equipment is still owned by EPA and your property management system must reflect EPA’s ownership. Your organization may establish lower limits in your definition of acquisition cost if that would be consistent with your existing equipment management system. You can find the list of debarred, suspended, and excluded persons at: System for Award Management.
If your organization has only federally supported work, salaries and wages must be comparable to that paid for similar work in the labor markets in which you compete for the kind of employees involved. The grant agreement and cooperative agreement forms are the same, except that a grant will say grant agreement at the top and a cooperative agreement will say cooperative agreement at the top.
You cannot use funds spent under another grant to cost share or match your EPA grant, unless a law specifically authorizes you to. This authorizes EPA to disallow the cost of a contractor, for example, even if EPA approved your grant application that indicated you would be using the services of a contractor, if, for example, EPA subsequently determined you did not obtain the contractor’s services in accordance with EPA’s minimum standards. Be certain the time indicated is adequate to cover the time you expect to work on the project and that it includes the time during which you may have incurred costs before EPA awarded the grant.
In such cases, the EPA Grants Management Office will revise the grant agreement and send the revision to you before you accept the grant. While the administrative requirements are important, the outcome of your project is the most important aspect of your grant. It should clearly explain what you expect your project to accomplish and it should make clear why your proposal is worthy of funding. For regional competitions, the Regional Award Official will generally designate the Grants Competition Disputes Decision Official (GCDDO). Your accounting system must track program income and ensure it is accounted for in the EPA project account.
Examples of such costs may be utilities, senior organization management and their support, and rent.
The contractor must furnish the goods or services for the fixed price, and so assumes significant risk. Often, the contractor must satisfactorily complete only the amount of work equivalent to the estimated cost to qualify for the negotiated profit; the contractor may not be able to complete the entire project for the amount established. In other cases, the project officer will ask you to sign and return the grant agreement and then request an amendment. EPA has developed a document that provides Tips on Writing a Grant Proposal, which may help assure your proposal is complete.
Allowable and unallowable costs are identified in Cost Principles for Non-Profit Organizations, OMB Circular A-122 (2 CFR 230). EPA should have included a term and condition in your grant agreement stating how you may use program income.
In the case of volunteer personnel, the documentation should be similar to your organization’s time sheets and should not be only estimates of time spent.
If your grant does not include a term and condition as to the use of program income but you earn income as a result of the grant, you should contact the project officer to obtain approval for one of the accepted program income uses.

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