Sixteen months ago, Nicholas Confessore and Amy Chozick wrote in The New York Times about the loose governance and financial performance of the Bill, Hillary, and Chelsea Clinton Foundation. For example, after more than 10 years in operation, the Foundation had internal controls that were only just coming into play, while financial disclosures seemed sloppy and even misleading.

In addition, two months have elapsed since Eric Braverman– the talented executive recruited in July 2013 to put the Clinton Foundation back into order– resigned unexpectedly several weeks following renewal of his long-term management contract by the Board of Directors.

Actually accounting for financial impact?

Media reports suggest Braverman lost out fighting the melange of Clinton loyalists who behave as Bill and Hillary have done throughout their adult lives: acting as if rules are for other people and noble ends justify transgressions, even egregious ones.

Judging from a review of publicly available information, Braverman made improvements toward bringing the Clinton Foundation into compliance with the nest of laws and regulations that apply inside the United States and around the world, where employees and volunteers attempt to fulfill lofty goals.

Among other things, these laws and regulations serve to motivate those who carry out charitable works to be truthful about how they spend contributions and grants they receive to fulfill their missions.

One special focus is on how much donor money reaches intended charitable beneficiaries. A second is on whether and how those working inside and with a charity may benefit personally in ways that fall outside the notice of donors, tax authorities, other regulators, and the general public.

In the corporate world, businesses operating with lax internal controls in numerous countries that change their top executives and chief financial officers frequently; that submit and amend financial statements and IRS tax filings which still appear confusing and incomplete; and that repeatedly issue contradictory releases to the public attract intense focus by a raft of state, federal, and international regulators.

Moreover, just because the Clinton Foundation claims that it actually addresses lightning-rod issues that affect billions of people does not mean that it, and parties related to it, should be given blanket immunity from onerous obligations that other charities do shoulder to maintain compliance with domestic and international laws.

Three days after the August 2013 New York Times story, the Clinton Foundation published what it characterized as an “Executive Summary” of work that law firm Simpson, Thacher & Bartlett conducted to “review the organization’s operations to implement more robust governance and operating procedures.”

This document, which has a date stamp of August 16, 2013, concentrates on a period from October 27, 2011 through November 23, 2011 when President Clinton and other senior Foundation personnel met to discuss the Simpson Thacher Report. It does not describe any further steps considered or taken between November 23, 2011 and August 16, 2013.

Considering the Clinton Foundation’s record over a multi-year period, questions remain, including whether the “consolidated” financial statements and tax filings are prepared on a consistent basis, and whether they are free from material misstatements.

From a donor’s perspective, a further consideration is whether the management and the Board of Directors exercised proper, informed control over the far-flung operations of the Foundation and of its component parts.

Ongoing review of Clinton Foundation filings suggest that revenues and expenses were substantially overstated for the Clinton Health Access Initiative in audits and IRS tax forms held out as being “consolidated” for the group of charitable entities that work together under the Clinton name.

As will be shown in follow-on articles in detail, one consequence of these overstatements was to mask the degree to which overheads and group expenses ate into donations intended to go for program expenses.

A second consequence was to obscure the poor state of financial controls and the possibility of substantial conflicts of interests involving Bill and Hillary Clinton, and key Foundation personnel.

Obama Administration targets some tax-exempt groups aggressively

When it comes to hassling and auditing tax-exempt organizations, evidence suggests that the IRS can be relentless and intrusive, particularly when an entity addresses conservative causes and has conservative donors.

It is well past time for the IRS to examine information already in its files concerning all of the Clinton entities engaged in charitable activity and then motivate these entities to make full, fair, and consistent disclosures to relevant authorities and to the public.