Audit Subcommittee Questions Why Incomplete FY2025 Draft Was Posted to Bond Market

Members of the Board of Finance‘s new Audit Remediation and Financial Reporting Subcommittee prepared another round of questions for Wilton’s Finance Department on Wednesday, Sept. 23, after learning that an unfinished and, in places, inaccurate draft of Wilton’s FY2025 financial statements had been posted publicly on the municipal bond market’s disclosure system.

Specifically, subcommittee members want to know exactly why the draft was posted publicly Sept. 1 on EMMA (Electronic Municipal Market Access), the internet database that serves as the municipal bond market’s disclosure system, rather than sent directly to Moody’s, the rating agency the Town was reportedly trying to accommodate. They also questioned why the Town’s elected financial oversight boards were not formally notified or provided with the document.

“We need to follow up on that,” BOF member and Subcommittee Chair Kim Healy said about the posting, as well as why FY24 figures apparently show a $9.58 million restatement.

During Tuesday evening’s Board of Selectmen meeting, written responses from CFO Dawn Savo to questions BOS members had submitted were read aloud, and several touched on the EMMA filing and related issues. Savo wrote that the draft had been posted to EMMA “per disclosure rules by our bond advisor.”

Tuesday night, at least two BOS members were surprised they hadn’t been notified about the posting, as they’ve been told for several months that the audit was still in process. Now nine months overdue and close to three months past the filing extension deadline, the audit is said to be on track for completion by Sept. 30, according to Savo.

Savo did not identify the bond adviser by name but BOF audit subcommittee members said Wednesday that the advice appeared to have come from the Town’s municipal adviser Barry Bernabe of Phoenix Advisors, but they had not seen the instruction or received an explanation directly from him.

The subcommittee — Healy, joined by BOF Vice Chair Rudy Escalante and member Kari Roberts — agreed that more information was needed about why the report was posted in that form, why Sept. 1 was significant and what review occurred before it became publicly available.

Why EMMA Instead of Moody’s?

The document placed on EMMA was an unsigned, watermarked draft that contained incomplete sections, outdated material and contradictory financial figures.

GOOD Morning Wilton obtained an email written by Savo that said the document was posted to EMMA on advice of the Town’s bond advisor “to accommodate Moody’s,” which issues an annual credit rating to the town.

Roberts said posting it on EMMA made it publicly available not only to Moody’s but also to investors, financial institutions and others who follow Wilton’s outstanding debt.

“If you want to accommodate Moody’s, you can send Moody’s a draft of it… ” Roberts said. “But when you post it to EMMA, EMMA is a public information source.”

“It does seem odd that if it was so incomplete and so unlike anybody else’s, why did we post it there and not just send it to Moody’s?” she said. “I’m really not sure, but they’re saying [Bernabe] asked us to do that.”

Roberts said subcommittee members had not received an explanation directly from the bond advisor.

“That’s quite possible, I guess, [but] we’re not allowed to talk to him,” Roberts said, “so we wouldn’t know.”

Escalante also questioned the process and called the posting of what he described as “kind of a half-baked report” on EMMA “unusual.” Likewise, he wants to know why it happened. 

“What is the process for posting to EMMA?” he asked. “What are you supposed to do?”

He also asked why the document was filed when it was.

“Why was Sept. 1 significant?” Escalante asked.

$9.58 Million Restatement Raises More Questions

The original FY2025 document posted on EMMA on Sept. 1 disclosed that the Town’s previously issued FY2024 financial statements understated governmental capital assets by $9,577,619.

That understatement does not indicate money or property is missing. Rather, it means the government-wide financial statements issued for FY2024 did not include the full value of assets the Town owned.

The original draft also contained contradictory figures explaining the correction. The narrative said the assets had been understated by $9.58 million, while the table beneath it showed a negative adjustment of more than $19 million. Another section showed a positive $9.58 million adjustment.

“In the original report that was put into EMMA, the numbers didn’t even add up,” Healy said. “They didn’t agree with prior years. They now at least agree to prior year.”

The Town provided the full BOF with a revised FY2025 draft on Wednesday morning, hours before the subcommittee meeting. The revised document corrected the contradictory restatement table, although members said it still contained unfinished material and raised additional questions.

Healy said the note describing the correction did not give the reader enough information to understand what happened.

“The note is not detailed enough,” she said. “It needs more information. It does leave more questions than answers.”

Subcommittee members questioned what assets were involved, how the omission occurred and when it was discovered.

The draft says the Town identified the error “during fiscal year 2025,” which ended June 30, 2025, but does not provide a date or say who was informed.

Roberts cautioned against speculating about the cause and said the committee should ask Savo for details.

The subcommittee also questioned why neither the BOF nor BOS was formally told about the restatement before it was raised by resident Joshua Kopac during public comment at Tuesday’s BOS meeting.

Roberts Describes ‘Environment of Non-Cooperation’

The subcommittee discussed having to submit their questions through BOF Chair Tim Birch so the Town could obtain and share answers from Savo and Bernabe about the filing.

The discussion prompted Roberts to express her frustration with Town Hall administration and the Finance Department, and her disappointment with what she described as a “dysfunctional” relationship.

“I’ve only been here since December 1st of 2025, but it seems like we have been clawing, begging, struggling for information ever since I started on the Board of Finance,” Roberts said, “and there seems to be an environment of non-cooperation.”

“I think it’s just important, and I’ve said this a billion times, for everybody to understand that we’re all on the same team. We’re all trying to get the same thing done,” she said, describing the Town Hall administration as “hoarding information and not cooperating.”

Roberts referred to comments Boucher made at Tuesday’s BOS meeting about the manner in which questions have been posed to Town employees.

“I think Toni suggested that perhaps people don’t communicate because sometimes the communication they receive back is not to their liking,” Roberts said. “Which is unfortunate, and everybody can work on that, and we’re all professionals.”

But, she added, elected officials were “not going away.”

“I just think… the whole lack of cooperation is very dysfunctional and benefits no one,” Roberts added. “It just makes everything worse.”

Escalante Disputes Savo’s Account

In an email exchange between Savo and Second Selectman Ross Tartell about providing the EMMA document link to the BOS prior to Tuesday’s meeting, Savo wrote that she had discussed distribution of the draft with Birch and Escalante.

“Because the Board of Finance oversees the audit, I discussed this with Tim and Rudy,” Savo wrote. “We agreed that the draft should not be distributed to the boards until the audit is complete.”

Birch disputed that account after Tuesday’s BOS meeting.

“I don’t think this is a completely accurate account,” Birch wrote in an email to Savo, the BOS and BOF, that GMW obtained. “I was asked not to distribute the draft to BOF because it was too incomplete.”

In a separate response to GOOD Morning Wilton, Birch said, “I had no knowledge of the filing with EMMA until after the fact.”

Escalante also disputed Savo’s characterization Wednesday night to Healy and Roberts.

“Not quite what we said,” he responded when the subcommittee discussion turned to Savo’s statement.

Escalante said his conversation with Savo was separate from Birch’s conversation with her and concerned the condition of a separate incomplete financial report, not a decision about whether the draft FY2025 statements should be posted on EMMA or withheld from other BOF members until the audit was complete.

Escalante said he told Savo to complete the missing entries before sending the report or clearly identify which pages and totals remained incorrect.

“That was my response,” Escalante said. “That wasn’t like, ‘Don’t send it ever.’”

He said the concern was that a report containing only part of the necessary information had little value to the BOF.

“But once it’s ready, send it to us,” Escalante said.

He said he believed Birch had made essentially the same point.

BOF Review Could Affect Sept. 30 Target

Birch asked Tuesday night and again Wednesday morning that the revised draft be provided to the BOF. He also said the board would likely schedule a special meeting to review it.

The subcommittee plans to seek answers about the EMMA posting, the $9.58 million restatement, the process for distributing draft financial statements and the BOF’s role in reviewing the audit before it is finalized.

Healy said concerns had been raised that BOF questions or requested changes could delay completion because the audit was already so far along.

“However, I don’t feel like that’s our problem,” she said. “I mean, we should have been given it in advance.”

Savo has said completion “on or around Sept. 30 remains a realistic target,” although she cautioned that CLA’s national review could generate additional questions or requested revisions.

Audit subcommittee members expressed skepticism about that timeline.

Escalante noted that several previous completion dates had passed.

“They have not met any date that they set up till now,” he said. “So why would we believe — kick the football, Charlie Brown?”