District 150 releases audit report, statement on McArdle

District 150 has just released a statement (reprinted below) and a copy of the audit by Clifton Gunderson of the District’s Grade School Activity Funds.

DISTRICT STATEMENT – For Immediate Release – Wednesday, April 29, 2009

  • First, we need to clarify that Julie McArdle was not fired. Her contract was terminated without cause, pursuant to her employment contract.
  • The Board of Education and Administration stand behind their decision to terminate Principal Julie McArdle’s contract without cause. As an employer, we are bound to personnel laws that prohibit us from discussing or outlining reasons behind the decision to terminate her contract.
  • Regarding financial reviews – as part of routine procedures, our district used an outside accounting firm to conduct random, routine financial reviews of school activity funds. These reviews occur on a rotating basis every three-to-four years at all of our schools. We also request a review of these funds each time a new principal is named at a school or a building is closed.
  • On April 24, 2009 – (last Friday) – a police report was filed because 2007-2008 Lindbergh MS financial records are missing. These documents were reviewed in the summer of 2008 by the accounting firm during a routine review of the fund, which found no misuse of the school’s funds.
  • District staff members are diligently working with multiple sources to find documentation, receipts and statements that will assist in the reconstruction of the missing Lindbergh 2007-2008 financial documents. We are also hoping for a rapid conclusion of the Peoria Police Department’s investigation into our two filed reports.
  • Regarding the use of personal credit cards and District issued credit cards:
    • It is routine practice for school or District personnel to use a personal credit card to purchase items for our students, classrooms or other needed supplies, so long as appropriate and detailed documentation is kept.
    • There are currently nine different district-issued credit card accounts. The statements for these accounts are reviewed by the Business Manager and payments are processed by the District.
  • A decision had been made to recommend the termination of Mrs. McArdle’s contract prior to receiving any allegations of misconduct under the Illinois whistleblowers act.

My take: The report from Clifton Gunderson is not exactly a clean bill of health. Notice this statement near the end:

The above procedures were performed at the request of the Controller/Treasurer of the District. We make no representation regarding the sufficiency of the procedures for any purpose. We were not engaged to and did not conduct an examination, the objective of which would be the expression of an opinion of the financial statements of the Student Activity Funds of Lindbergh Middle School. Had we performed additional procedures, matters might have come to our attention that would be reported to the District.

So, if I’m reading this right, they’re not offering an opinion of the financial statements. In fact, given the parameters of what they were asked to do, it’s unlikely that they could have detected any fraud that might have been perpetrated, unless someone had actually written “stolen funds” in the ledger or on the memo line of the check. They pulled 20 disbursements at random and found two that had no supporting documentation. That’s ten percent of a random sampling that were defective. Shouldn’t that have been a tip off to the Controller/Treasurer that the controls in place were deficient?

As for the statement from the District, the last point is the most interesting. According to their statement, the decision had been made to terminate McArdle’s contract “prior to receiving any allegations of misconduct under the Illinois whistleblowers act.” This is pretty shaky. Obviously it’s designed to try to absolve the board of any impropriety; it says, “hey, we didn’t know anything about the charges against Mary Davis before we decided to terminate McArdle, so we should be held harmless.” But they did know about the charges before they voted to terminate the contract. The police reports were made on Friday, and the termination took place on Monday. Once they heard the charges against Davis, they could have held off and investigated the matter first. Instead, they went ahead and terminated the contract for reasons they cannot publicly by law disclose.

Why should they have held off? Because Davis is McArdle’s superior, and it’s most likely that the information on which the board based their termination decision was evaluative information received from Mary Davis and her supporters. If Davis were involved in wrongdoing as alleged, it stands to reason that she would have tried to keep that information from coming to light. One way would be to undermine the potential whistleblower (McArdle) and try to get her discharged. Caution should have been the order of the day.

131 thoughts on “District 150 releases audit report, statement on McArdle”

  1. CAN YOU SPELL S-P-I-N? Were they going to mention that LMS and Davis’ names were on the UNAUTHORIZED credit card? SPIN….I’m getting dizzy…..

  2. They said it wasn’t authorized. They didn’t say it didn’t exist. Why is she still working? This is some serious sh$$ going down.

  3. The use of personal credit cards to buy materials for reimbursement seems to be very, very bad practice–again the district needs to be proactive–once again they are forced to be reactive. Evidently, the long detailed documentation of purchases was not provided in this case. And why wouldn’t that documentation be expected with each purchase–not as a lump payment of $4000 to Sam’s Club maybe weeks or months after the original purchase–especially when none of the items on the charge card were even charged to Sam’s Club (it was just a Sam’s Club Discover Card–big difference).
    Well, evidently we now know that the missing records were in the hands of district personnel in the summer of 2008. Now we just need to know which hands misplaced them. Are other records missing or is this the only piece of paper that is missing? Why would there be only one–no copies???
    It’s really a shame that these two events (the termination of a contract and the misuse of funds) have to be defended in the same document. There should be no relationship in the two events–they shoud be two very separate issues. The money issue should have been handled before the termination was carried out.

  4. An angle I failed to consider: If as a teacher I would have bought something for which I should be reimbursed, I could have charged it to my own charge account and then turned the receipt in to the school treasurer to get my money back. The problem here is that the principal may have written the check from the Activity Fund to pay her own charge card back. Or did some other person write the check–if so, that person should have asked for receipts and should be coming to Davis’ defense right now? The purchaser to be reimbursed and the person who writes the check should not be the same person.

  5. I just turned TV on to hear McArdle’s attorney make the same argument about Davis writing her own check to pay for accumulated purchases–he said it more succinctly than I did.

  6. On April 24, 2009 – (last Friday) – a police report was filed because 2007-2008 Lindbergh MS financial records are missing. These documents were reviewed in the summer of 2008 by the accounting firm during a routine review of the fund, which found no misuse of the school’s funds.

    Wrong, wrong, wrong, there is nothing in that agreed upon procedures letter that said these documents in question were reviewed. Read the letter it specifically says “We make no representation regarding the sufficiency of the procedures for any purpose. We were not engaged to and did not conduct an examination,” etc. A. audits don’t catch all fraud. B. this isn’t even an actual audit.

  7. The timing of the $4002.05 on July 4, 2008 does coincide with the end of Ms. Davis’ tenure at Lindbergh. All expenses for the year would have come through by this time. So it is not unreasonable to see a sizable reimbursement at this time.

    “Well, evidently we now know that the missing records were in the hands of district personnel in the summer of 2008. Now we just need to know which hands misplaced them.”

    Yes, that is a very interesting question… Who stands to gain the most by having no documentation for a $4000 school activity fund payment to Ms. Davis?

    None of this is clear right now. Many are basing their opinions on the complaint filed by Ms. McArdle’s lawyer. Hardly a disinterested party.

  8. CJ: Any idea what would be on the previous pages 1-29 to the page 30 statement released by D150? Thx.

  9. “The purchaser to be reimbursed and the person who writes the check should not be the same person.”

    I agree. The school organization I was involved with required two signatures on a check. It was a pain. I wonder if this account was set up like that?

    “We make no representation regarding the sufficiency of the procedures for any purpose.”

    Another way of saying take all of our work with a grain of salt?

    I also agree it is time for some new auditors and auditors don’t catch all fraud. Anyone who has watched the news since Enron has seen that over and over these last few years.

  10. Karrie: It’s not a page number. It’s just a traditional symbol for the end of the press release. I don’t know the origin of it. The press release was only one page.

  11. CJ: Thanks. You learn something new everyday. 🙂

    Some ideas …..

    The most plausible explanation is from this website and dates back to
    the Civil War: http://www.thereporter.com/Current/Forum/forum072802_1.html

    “According to Webster’s New World Dictionary of Media and
    Communications, the symbol may have come from the use by telegraphers
    of three X’s, also the Roman numeral for 30, to signify the end of a
    dispatch. Or it may have started as an indication of the number of
    words in a dispatch. The first press dispatches from Civil War
    battlefields ended with 30, by then the standard signoff. The symbol
    also may have stood for the amount of time during which reporters were
    allowed to use the military-controlled telegraph lines during the
    Civil War. The “30” at the end of the dispatch told telegraphers at
    the receiving end that the dispatch was completed and that time was
    up.”

    **********
    This website lists a variety of origins for -30- as they were passed
    down in newspaper lore. Pick your favorite here:
    http://web.utk.edu/~gwilson1/30.html

  12. Here’s the amusing part: “We are also hoping for a rapid conclusion of the Peoria Police Department’s investigation into our two filed reports.”

    I’ll bet they’re hoping for a quick whitewash. This investigation must be turned over to the state police, the FBI (federal funds, No Child Left Behind violations) or the Illinois Attorney General’s office for a thorough investigation of all aspects of this bizarre situation.

  13. An important point that is being overlooked in regards to the credit card is that Davis had said the account was CLOSED, when in fact it wasn’t. I believe that would be referred to as “consciousness of guilt.”

  14. …and why did the Clifton Gunderson audit not address the honking $4,000 debit? I don’t see how they can possibly think this letter exonerates them.

  15. I still wonder why the Activity Fund states the check was made to Sam’s Club–does anyone see that as deceptiive? In fact, if I read the Exhibits correctly, wasn’t Davis talking about a Sam’s Club membership–as to whether or not McArdle wanted to keep it open. Davis may have cancelled the Sam’s Club membership, but it appears that she kept the Discover charge card. It just seems strange and/or confusing to me.

  16. If I’m going to jump to conclusions, I think it’s wise that I look at arguments on the other side. Looking at the types of charges on the whole card, many of them do seem possibly to be more school-related than personal. The thing that strikes me the most is that the charges most mentioned–Toyota and the Pottery Barn–were for purchases made after the $4,000 payment–so school funds may not have been used to pay for those more obvious personal items. All the other suspicious factors still apply–no receipts, missing financial records. Also, we don’t know whether or not previous payments to this card (before the $4,000) were paid through the Activity Fund.

  17. “If I’m going to jump to conclusions, I think it’s wise that I look at arguments on the other side.”

    Or, simply don’t.

  18. Did anyone notice the interest rates on that credit card billing statement…? 27% for purchases and 33% (I think) for cash advances…

    Who (any person that makes over $40,000 a year) would hold that card….

  19. Julie McArdle was terminated “without cause”, however, in the fourth paragraph it states that Ms. McArdle made a “police report” against the school district. Something smells fishy here.

  20. CJ I concur…that last statement from the administration is really shaky. In my opinion it is only an out for the board members who voted for the firing. Unless someone can talk me down….Julie McArdle was fired!!! I continue to believe there is no precedent. Many principals have had shaky beginnings and yet not been fired in an eight month period….”She just wasn’t a good fit” is the one statement I have heard. By the way there are many parents supporting Julie….

  21. Nontime… I don’t know that any of us are really jumping to conclusions–there are plenty of unanswered questions to be asked. It is the administration’s job to clear up these questions ASAP–not wait for a lawsuit–in their own interest to help them with an already shaky public perception. Their news release doesn’t answer our questions. If there were good answers to any of the questions (including the non-LMS area students in attendance, the paid student teacher), then Julie McArdle should have had those explained to her quite some time ago–and the administration should be giving dates and times and explanations as to when they provided this information to Julie.
    Kcdad: Yes, I noticed the high finance charges. That’s why I tend to believe this is a personal credit card; certainly, the school wouldn’t use a card with such large balances and such a high interest rate. Even if these are school-related expenses (the Ecove LLC is some sort of Edison software), why would the Activity Fund be paying for them and why would Davis pay for them herself and keep them on a card with such high interest rates and with late payments and charges? Add to the questions: Who authorized any of the school-related expenses and why didn’t “they” pay for them? Why purchase items before and if there is no money available to pay for them?

  22. Sharon: Is not this some indication of financial/management impotence? An Administrator earning over $100,000 a year with lousy credit? My goodness, I earn a lot less than that and I hold a 7% credit card.
    “Certainly the school wouldn’t…” are you sure?

  23. Clifton didn’t address the 4,000 because it wasn’t part of the sample. They pulled 20 disbursements, 2 of the disbursements were “exceptions.” 10% of the sample was jacked up. This isn’t an audit. It is an agreed upon procedures engagement. Clifton was never going to do anything about the results. They just agreed to perform the samples and inquries. The form letter wouldn’t have read much differently if all 20 items sampled had been exections. It was up to the dirstrict to do the follow up. The district’s own accounting department should have come back in and pulled another 50 and if they found 5 more exceptions, time for a serious come to Jesus meeting, 10% is unacceptable. Internal controls don’t work if people don’t follow them.

  24. The $4,000 charge was not used for Sams wholesale club purchases, but rather the Sam’s Discover Charge. It would appear that that entry was deliberately made to mislead the evaluator into thinking it was made to Sam’s Wholesale.

  25. I am wondering why Hinton, et al don’t just put up a cross on a hill someplace, flog (or waterboard) McArdle for awhile and if she doesn’t recant, nail her up there for all to see? It’s worked in the past…

    How dare she question them?

  26. Diane: That certainly is the observation I have made–the difference between Sam’s Club and Sam’s Club Discover Card is a big difference.
    Kcdad: No. I ‘m not sure that such carelessness doesn’t exist in District 150.
    An aside comment: Have any of you ever been in a principal’s office and noticed the furnishings? I’ve seen solid wood desks and plush desk chairs, expensive bookshelves and storage cabinets, decorative plants, office gadgets, and desk accouterments. Compare all of that to the furnishings in the average classroom. Who pays for all of this–certainly, I’ve asked this question often? My point is that school-related items can be purchased–but they can still be for personal use within the building. As a teacher could I have made these kinds of purchases for my classroom and expected school or district funds to pay for them? Of course, not.

  27. We should nominate Hinton, Walvoord, Davis, Wolfmeyer, Spangler, Dennis Bailey, and Broderick as contestants for next season’s “Dancing with the Stars.” Heck, now we all know how well they can dance!

  28. “I’ll bet they’re hoping for a quick whitewash.”

    Didn’t the city council just eliminate overtime for the police department?

  29. Prairie Celt Thanks for keeping the names in the forefront…I still question that Vince Wieland was in on the investigation. Anyone know where that has gone!!!

  30. I thought District 150 could stay out of the news for one day. But–did you hear about the 22-year-old bus driver on the Charter Oak route? He put masking tape over the mouth of one kid and tape on the neck of another (not sure what that would accomplish). I think I heard something about possible legal action against the driver.

  31. AWESOME! There will be a lot more complaints made public over the next few weeks…

    How about a 7th grader of Arab descent, natural born American citizen, being told by the District SPED Director to take behavior control drugs for a speech and hearing disorder?

    How about a Principal telling a mixed race child that the principal would only speak with the parent of the same race as the Principal?

    How about a a Principal refusing to intercede in an ongoing bullying situation becasue the bullying child is a “honors” student (and happens to be the same race as the principal)?

    How about a Principal colluding with the coaching staff to “recruit” students from out of the District to play sports?

    As Terrance Mann says to Ray Kinsella in Field of Dreams… It reminds of us of all that once was good and it could be again. Oh, people will come Ray. People will most definitely come.

  32. Sharon – you can bet that driver won’t be an employee for long! That’s child abuse and results in automatic termination. Wonder if the parents will sue the district?

  33. PrairieCelt: I just heard the news on WMBD radio–wasn’t paying much attention until I realized 150 was once again in the news. I think I heard the word “abuse.”
    Kcdad: If any of that can be verified, etc., I don’t suppose any action will be taken to terminate a principal’s contract. I certainly that no other first-year principals are having trouble adjusting. 🙂

  34. Regarding the high interest rates on the credit card, it is my understanding that if a person (or school) is not making payments in a timely manner (late payments and/or non-payments are shown on the credit card statements) interest rates jump to very high levels. There are also fees and penalties levied that add to the card balance.
    After a certain point a maximum interest level is reached so further increases will not be made. And there is usually a different rate for a cash advance than a purchase.

    There are several statements that indicated past due or late payments. Who paid the penalties for those? And, for any legitimate school-related charges on those cards that incurred interest, who paid the excess interest? The student activity fund should not pay when payments are not made in a timely manner. As long as the card holder is willing to accept those high rates and does not exceed the available balance, the account will remain open. This account remained open until until early in 2009. There has been no explanation given for 1)why the account remained open after Ms. Davis said it had been closed, or 2) why it was finally closed.

    BTW, it seems unusual to me that, if Ms. Davis truly believed the account had been closed, why there was still a balance of almost $9000 on the card in October and, more importantly, WHY would she not close the account after she became aware that Ms. McArdle was aware of it? She obviously didn’t offer to turn it over to Ms. McArdle, which would seem logical if it were solely for LMS purchases and Ms. Davis was no longer principal there. JDLR.

    Regardless of the legitimacy of the card itself, the person responsible for reporting/paying/reimbursing should be held accountable for the extra fees incurred. If that person was MS Davis, as a matter of fiduciary responsibility should she not have to account for/offer proof that the school did not pay for extra charges incurred due to lack of timely payment.

  35. kcdad – unfortunately, things like that do happen within the halls of #150 – really sad, isn’t it, that prejudice and bigotry are allowed to continue unchecked?

  36. Oh… what is Illinois High School graduation rate?
    Look at Richwoods:
    Dropout rate: 4.2%
    High School graduation rate: 93.3%… there is a statistic anomaly.. only 4% drop out so where are the other 3%?

    Then there is this STAT:
    School District:
    School District Name Peoria 150 School District

    This School’s Agency

    Number of Schools Managed 43
    Number of Students Managed 15,278 students
    District Total Revenue $147,597,000
    District Expenditure $159,044,000
    District Revenue / Student $9,661
    District Expenditure / Student $10,410
    District Graduation Rates 60%

    60 %!!!!!
    http://www.publicschoolreview.com/school_ov/school_id/26266

    What about some REAL numbers….
    Let’s look at Manual and Woodruff enrollment numbers
    Class of 2008
    Manual Freshman year (2005) …… 184
    Manual Sophmore year (2006)…….178
    Manual Junior year (2007)…………..132
    Manual Senior year (2008)………….101

    Looks like they lost 45% of their class in those four years… I don’t know how many actually graduated…..

    Woodruff
    2005….. 305
    2006….. 248
    2007….. 222
    2008….. 214

    Looks like they lost 29% of their class of 2008 in four years… again, I don’t know how many may have graduated.

    District 150… It’s Better Here!

    BTW @ Richwoods, Class of 2008 only lost 5% of their students and Class of 2007 lost 11%… not including those who didn’t graduate.

    So the question is… Why is Richwoods (and Kellar and Lindbergh… all schools I attended, btw) so much better than the other schools? What is it … the water on the north end? What good is the District Administration if the only schools performing as expected are the same ones that were doing well before they entered the District?

  37. Not unchecked… disregarded. Complaints were made in each of those cases (except the athlete … who complains when the team is winning?) to the school board, my wife involved in helping the parents make two of those complaints.

  38. Kcdad: Lost enrollment at Manual (between 9th and 12th grades) doesn’t necessarily mean the difference is due to dropouts. Manual administrators were in the habit of “blaming” suspension, expulsions, and dropouts for Manual’s loss in enrollment. Never once did I hear a principal mention that the “dropouts” were actually “dropins” at other schools. In many cases Manual’s loss was gain for some other school.
    Hot in the City: I’ve lost track of all the details–where do we learn that the account was closed in early 2009? Will the auditors, lawyers, or whoever is checking on this story be able to get a copy of the check (and who signed it) that paid off the account–which always seems to carry a hefty balance.

  39. Could the “innocence” of this former principal be affected by a legal situation that occurred about 5-6? years ago?

  40. I understand… but they were probably not drop ins at any 150 school.. every school lost students each year.

    angelwithorns… good thinking

  41. Sharon, I know how you feel. I am on information overload. There are always so many details and red herrings that I have to constantly backtrack.

    Regarding the CC, I went back and looked at the statements more closely. It seems that the majority of the charges made after July 2008 were for things that weren’t school-related (like car repairs.) Who made CC payments after the last large one of $4000+ on June 30 when Ms. Davis was no longer principal? That should be easy to uncover if she paid personally. There should be personal records.

    As I looked at the statements, they reminded me of my husband’s CC bills. He used to put business and personal charges on the same card, paid the card out of our personal account and was reimbursed for business expenses. He had to present receipts or he didn’t get paid. On the surface, some of the business charges looked like personal charges (meals, etc.) and if the card had been paid directly by the business it could have looked suspicious. BUT the card payments were not paid by his business.
    He has since gotten a card he uses only for business expenses, but the payment format is the same. The bill comes to our house, he pays it in full every month and is reimbursed for the payments. If he incurred late payments, etc., he would have to pay them, not his employer. And he is management, but he doesn’t sign the checks for these payments.

    So… I was starting to think maybe this could be a similar situation when some things caught my attention:
    1. The card had Lindbergh MS on it underneath Ms Davis’ name.
    2. The billing address was the school’s, not Ms. Davis’. That means statements went to the school.
    3. The email from Ms. Davis about the Discover card account is vague and contradictory (if you can be both, she was in this case!) “Also, I received that Discover bill. Very interesting. At one time we had a card and always paid it in full but I closed it. There was some confusion and hopefully I have it straightened it out. If you receive another one please let me know. I the name of the supervisor and name (sic). Very interesting. Talk to you soon.” This is an email, not a personal or phone conversation that could be “misremembered.”

    QUESTIONS I would like answered:
    If it was a personal card that she used for school expenses, why would she not say so and ask for the statements back?–and change the billing address when she left the school? The only reason the call was made to LMS and statements were sent to LMS is because that name and address were on the statement. The CC company doesn’t care who makes the payments. Wouldn’t a simple, “I used that card for school and business purchases and just forgot to pay the bill last month. Sorry, I’ll take the school’s name off and you shouldn’t be bothered anymore”, or something similar, should have taken care of the issue.

    Conversely, if it was a school card and she used it for personal expenses but either repaid the school (and can prove it) or paid for those herself (not likely, as there was only one payment per month, but possible if she reimbursed herself and then paid with a personal check (and can prove it.) The fact that at least one large payment was from the activity fund with no receipts or documentation is problematic.

    Why would it be “very interesting” and what was “very interesting” about what happened? It was either a school card that had personal charges or a personal card that had school charges.

    The “very interesting”, “at one time we had a card”, “there was some confusion” and “I have it straightened out” are what make the whole thing smell. That and the lack of documentation (missing records). I believe Ms. Davis should be put on leave immediately until the myriad questions are answered, discrepancies are explained and facts are revealed, whether she is completely guilty, completely innocent or somewhere in between. This is a matter for the police (AND the administration AND the School Board) to unravel. Whether any or all of this is related to Ms McArdle’s termination is now a matter for the courts.

    Just trying to make some sense out of non-sense.

    Gosh, I’m catching up to Sharon in lengthiness. Sorry all! Guess I need my own blog.

  42. ummm, and I see that any ledger entries from before 6/30 are not part of the exhibits. Where are they? Those ledgers are activity fund property and should be housed at the school. Those would show if other CC payments were made from that fund.
    Was a new ledger started on 6/30? What happened to earlier pages?
    And, the entries in the “deposits” section shown are actually checks, it appears. (See continous enumeration.)
    Looks like my college checkbook, which I constantly overdrew b/c I never really kept track of $$!

  43. hot in the city: Yes, a lot of information. The email is cryptic — is there any possibility that there was more than one authorized user on the cc account? Is is possible that Mary Davis was the primary cardholder and other users on the account? Just posing questions … no answers….

  44. I just reread Exhibit 1–missed this before, “I didn’t try to leave you with no money–we just spent a lot, but always for our children.” Something about Freud may be appropriate here.
    Hot in the City: Since the Activity Fund check records aren’t available except for the $4,000, I also wonder if all the payments on the credit card were paid by the Activity fund. Yes, earlier I was questioning the use of a personal credit card for school business. But then I realized the problem, and McArdle’s lawyer, also, pointed out what you just stated about your husband’s habits. It’s fine to use a personal credit card, if receipts are submitted for reimbursement. The problem is that Davis appears to be both the purchaser who charges on her own card and then the person who writes the checks from the Activity Fund to pay herself back.
    Also, in Exhibit 1, there is no confusion about the charge card–she just doesn’t mention it at all. She tells McArdle she may want to keep the Sam’s Club membership; “But that’s up to you.” As Diane and I have stated before, those are two very different kinds of cards. Accordingly, I find it a bit interesting but not important that none of the charges on the credit card statement were purchases from Sam’s Club.

  45. Hot in the City: Sorry, you were referring to Exhibit 4 about the Discover Card. Wow! What does this mean? “We had a credit card and always paid it in full but I closed it. I the name of the supervisor and name.” If this were a personal card, why would Davis say “we” had a card (Karrie’s question) and what about “I the supervisor.” Also, the records in Exhibit 3 show that for at least a year, the credit card balance was never paid in full. Even when the $4,000 was paid, the card still had a large balance.

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.