Amelia Concourse Community Development District

ANNUAL FINANCIAL REPORT

September 30, 2017

Amelia Concourse Community Development District ANNUAL FINANCIAL REPORT
Fiscal Year Ended September 30, 2017 TABLE OF CONTENTS
Page Number
FINANCIAL SECTION

REPORT OF INDEPENDENT AUDITORS	1-2
MANAGEMENT’S DISCUSSION AND ANALYSIS	3-8
BASIC FINANCIAL STATEMENTS:
Government-wide Financial Statements:
Statement of Net Position	9
Statement of Activities	10
Fund Financial Statements:
Balance Sheet – Governmental Funds	11
Reconciliation of Total Governmental Fund Balances
to Net Position of Governmental Activities	12
Statement of Revenues, Expenditures and Changes in Fund
Balances – Governmental Funds	13
Reconciliation of the Statement of Revenues, Expenditures and Changes in Fund Balances of Governmental Funds
to the Statement of Activities	14
Statement of Revenues, Expenditures and Changes in Fund
Balances – Budget and Actual – General Fund	15
Statement of Revenues, Expenditures and Changes in Fund
Balances – Budget and Actual – Special Purpose Entity	16
Notes to Financial Statements	17-30
INDEPENDENT AUDITOR'S REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN
ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS	31-32
MANAGEMENT LETTER	33-36
INDEPENDENT ACCOUNTANT’S REPORT/COMPLIANCE WITH
SECTION 218.415, FLORIDA STATUTES	37

tt Berger, Toombs, Elam,
-OJ  Caines & Frank
Certified Public Accountants	PL
600 Citrus Avenue
Suite 200
Fort Pierce,  Florida 34950
772/461-6120 // 461-1155
FAX: 772/468-9278
REPORT OF INDEPENDENT AUDITORS

To the Board of Supervisors
Amelia Concourse Community Development District Nassau County, Florida

Report on the Financial Statements

We have audited the accompanying financial statements of Amelia Concourse Community Development District as of and for the year ended September 30, 2017, and the related notes to financial statements, which collectively comprise the District's basic financial statements as listed in the table of contents.

Management's Responsibility for the Financial Statements

Management is responsible for the preparation and fair presentation of these financial statements in accordance with accounting principles generally accepted in the United States of America; this includes the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error.

Auditor's Responsibility

Our responsibility is to express an opinion on these financial statements based on our audits. We conducted our audits in accordance with auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Accounting Standards, issued by the Comptroller General of the United States. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor's judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the entity's preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity's internal control. Accordingly, we express no such opinion. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion.

Member AICPA

Fort Pierce / Stuart
- 1 -
Member AICPA Division For CPA Firms
Private Companies Practice Section

Member FICPA

f p Berger, Toombs, Elam,

,t)J Gaines & Frank

To the Board of Supervisors
Amelia Concourse Community Development District

Opinion

In our opinion, the financial statements referred to above present fairly, in all material respects, the respective financial position of the governmental activities and each major fund of Amelia Concourse Community Development District, as of September 30, 2017, and the respective changes in financial position and the budgetary comparison for the General Fund for the year then ended in conformity with accounting principles generally accepted in the United States of America.

Other Matters

Required Supplementary Information

Accounting principles generally accepted in the United States of America require that the Management Discussion and Analysis be presented to supplement the· basic financial statements. Such information, although not a part of the basic financial statements, is required by the Governmental Accounting Standards Board who considers it to be an essential part of financial reporting for placing the basic financial statements in an appropriate operational, economic, or historical context. We have applied certain limited procedures to the required supplementary information in accordance with auditing standards generally accepted in the United States of America, which consisted of inquiries of management about the methods of preparing the information and comparing the information for consistency with management's responses to our inquiries, the basic financial statements, and other knowledge we obtained during our audit of the basic financial statements. We do not express an opinion or provide any assurance on the information because the limited procedures do not provide us with sufficient evidence to express an opinion or provide any assurance.

Other Reporting Required by Government Auditing Standards

:;nJ:;;er¢;t overfinancial reportingand compliance.

In accordance with Government Auditing Standards, we have also issued a report dated June 27, 2018 on our consideration of the District's internal control over financial reporting and on our tests of its compliance with certain provisions of laws, regulations and contracts. The purpose of that report is to describe the scope of our testing of internal control over financial reporting and compliance and the results of that testing, and not to provide an opinion on internal control over financial reporting or on compliance. That report is an integral part of an audit performed in accordance with Government Auditing Standards in considering Amelia Concourse Community

0_>6 4	\//4IU.L,
Berger, Toombs, Elam, Gaines & Frank
Certified Public Accountants PL Fort Pierce, Florida

June 27, 2018

Management’s discussion and analysis of Amelia Concourse Community Development District's (the “District”) financial performance provides an objective and easily readable analysis of the District’s financial activities. The analysis provides summary financial information for the District and should be read in conjunction with the District’s financial statements.

OVERVIEW OF THE FINANCIAL STATEMENTS

The District’s basic financial statements comprise three components; 1) Government-wide financial statements, 2) Fund financial statements, and 3) Notes to financial statements. The Government-wide financial statements present an overall picture of the District’s financial position and results of operations. The Fund financial statements present financial information for the District’s major funds. The Notes to financial statements provide additional information concerning the District’s finances.

The Government-wide financial statements are the statement of net position and the statement of activities. These statements use accounting methods similar to those used by the private-sector. Emphasis is placed on the net position of governmental activities and the change in net position. Governmental activities are primarily supported by  special assessments.

The statement of net position presents information on all assets and liabilities of the District, with the difference between assets and liabilities reported as net position. Net position are reported in three categories; 1) net investment in capital assets, 2) restricted and 3) unrestricted. Assets, liabilities, and net position are reported for all Governmental activities.

The statement of activities presents information on all revenues and expenses of the District and the change in net position. Expenses are reported by major function and program revenues relating to those functions are reported, providing the net cost of all functions provided by the District. To assist in understanding the District’s operations, expenses have been reported as governmental activities. Governmental activities funded by the District include general government, physical environment, culture and recreation, transportation and interest on long- term debt.

Fund financial statements present financial information for governmental funds. These statements provide financial information for the major funds of the District. Governmental fund financial statements provide information on the current assets and liabilities of the funds, changes in current financial resources (revenues and expenditures), and current available resources.

OVERVIEW OF THE FINANCIAL STATEMENTS (CONTINUED)

Fund financial statements include a balance sheet and a statement of revenues, expenditures and changes in fund balances for all governmental funds. A statement of revenues, expenditures, and changes in fund balances – budget and actual, is provided for the District’s General Fund and SPE Fund. Fund financial statements provide more detailed information about the District’s activities. Individual funds are established by the District to track revenues that are restricted to certain uses or to comply with legal requirements.

Governmental funds are used to account for essentially the same functions reported as governmental activities in the government-wide financial statements. However, unlike the government-wide financial statements, governmental fund financial statements focus on near- term inflows and outflows of spendable resources, as well as balances of spendable resources available at the end of the year. Such information may be useful in evaluating a government's near-term financing requirements.

Because the focus of governmental funds is narrower than that of the government-wide financial statements, it is useful to compare the information presented for governmental funds with similar information presented for governmental activities in the government-wide financial statements. By doing so, readers may better understand the long-term impact of the District's near-term financing decisions. Both the governmental fund balance sheet and the statement of revenues, expenditures, and changes in fund balances provide reconciliations to facilitate this comparison between governmental funds and governmental activities.

Notes to financial statements provide additional detail concerning the financial activities and financial balances of the District. Additional information about the accounting practices of the District, investments of the District, capital assets, and long-term debt are some of the items included in the notes to financial statements.

Financial Highlights:

The following are the highlights of financial activity for the year ended September 30, 2017.

The District’s total assets were exceeded by total liabilities by $(6,757,803) (net position).	Unrestricted  net  position was $(5,993,420).	Restricted net position was
$56,609. Net investment in capital assets was $(820,992).

Governmental activities revenues totaled $461,584 while governmental activities expenses totaled $1,046,901.

OVERVIEW OF THE FINANCIAL STATEMENTS (CONTINUED)

Financial Analysis of the District

The following schedule provides a summary of the assets, liabilities and net position of the District.

Governmental Activities 2017	2016

Current assets	$	345,686	$	453,612
Other non-current assets	54,656	54,656
Restricted assets		1,103,897		3,597,166 Capital assets, net of depreciation	 	4,846,343	 	3,014,942 
Total Assets	 	6,350,582	 	7,120,376 

Current liabilities	3,878,385	3,862,862
Non-current liabilities	 	9,230,000	 	9,430,000 
Total Liabilities	 	13,108,385	 	13,292,862 

Net investment in capital assets	(820,992)	(730,368)
Net position-restricted			56,609			54,184 Net position-unrestricted	 	(5,993,420)	 	(5,496,302) 

Total Net Position	$   (6,757,803)	$   (6,172,486)

The increase in capital assets and decrease in restricted assets is related to the capital asset additions in the current year paid from capital projects funds.

The decrease in net position is the result of the lack of funding for the debt service payments due in the current year.

OVERVIEW OF THE FINANCIAL STATEMENTS (CONTINUED)

Financial Analysis of the District (Continued)

The following schedule provides a summary of the changes in net position of the District.

Governmental Activities

 	2017		 	2016	

Charges for services	$	303,342	$	326,385	
Operating grants and contributions	130,210	75,326	
Investments earnings	5,312		1,547	
Other revenues	 	22,720 		760,652	
Total Revenues	 	461,584 		1,163,910	

Expenses
General government	

124,146		

338,762	
Physical environment	208,682		212,986	
Interest on long-term debt	 	714,073 		650,125	
Total Expenses	 	1,046,901 		1,201,873	

Change in Net Position	
(585,317)		
(37,963)	
Net Position - Beginning of Year	 	(6,172,486)		(6,134,523)	

Net Position - End of year	
$ (6,757,803)		
$ (6,172,486)	

Program Revenues

General Revenues

The decrease in other revenues is the receipt of rental income and land sale proceeds in the prior year.

The reduction in general government expenses is related to the reduction in SPE related expenses.

OVERVIEW OF THE FINANCIAL STATEMENTS (CONTINUED)

Capital Assets Activity

The following schedule provides a summary of the District’s capital assets as of September 30, 2017 and 2016.

Governmental Activities

 	Description		 	2017		 	2016	

Land and improvements	$	719,533	$	719,533	
Construction in progress	2,990,291	1,075,299	
Infrastructure	431,434	430,751	
Recreation facilities	1,526,077	1,519,727	
Accumulated depreciation	 	(820,992)	 	(730,368)	

Total Capital Assets (Net)

  $	4,846,343 

  $	3,014,942 

 	

During the year depreciation was $90,624, and additions of $1,922,025 in construction in progress, infrastructure and recreational facilities.

General Fund Budgetary Highlights

The budget was exceeded by actual expenditures primarily because actual capital outlay expenditures were more than anticipated.

There were no amendments to the September 30, 2017 General Fund Budget.

Debt Management

Governmental Activities debt includes the following:

In July 2007, the District issued $7,350,000 Series 2007 Capital Improvement Revenue Bonds. The bonds were issued to finance the acquisition and construction of certain improvements for the benefit of the District. The District has $425,000 in matured bonds outstanding and the remaining balance outstanding at September 30, 2017 was
$6,045,000.

In June 2016, the District issued $3,385,000 Series 2016 Capital Improvement Revenue Bonds. The bonds were issued to financial the acquisition, construction, equipping and installation of certain improvement for the benefit of Phase II of the District improvements. The balance outstanding at September 30, 2017 was $3,385,000.

OVERVIEW OF THE FINANCIAL STATEMENTS (CONTINUED)

Economic Factors and Next Year’s Budget

The District’s financial conditions has changed since prior years; however, the future of the project remains uncertain. In June 2016, the District issued 2016 Capital Improvement  Revenue Bonds amounting to $3,385,000. However, the District is still in default on the Series 2007 Bonds outstanding balance. The impact of the sale of certain land cannot be determined at this time and the District remains obligated with respect to the principal and interest on the Series 2007 and 2016 Bonds.

Request for Information

The financial report is designed to provide a general overview of Amelia Concourse Community Development District’s finances for all those with an interest. Questions concerning any of the information provided in this report or requests for additional information should be addressed to the Amelia Concourse Community Development District, Governmental Management Services, 475 West Town Place, St. Augustine, FL 32092.

	Governmental
Activities	
ASSETS		
Current Assets		
Cash and cash equivalents	$	285,579	
Investments	53,846	
Accounts receivable	9	
Assessment receivables	410	
Deposits	2,475	
Prepaid expenses	 	3,367 	
Total Current Assets	 	345,686 	
Non-Current Assets		
Restricted assets		
Investments	1,103,897	
Land held for resale	54,656	
Capital assets, not being depreciated		
Land and improvements	719,533	
Construction in progress	2,990,291	
Capital assets, being depreciated		
Recreation facilities and amenities	1,526,077	
Infrastructure	431,434	
Less: accumulated depreciation	 	(820,992)	
Total Non-Current Assets	 	6,004,896 	
Total Assets	 	6,350,582 	
LIABILITIES		
Current Liabilities		
Accounts payable and accrued expenses	9,246	
Accrued interest	239,635	
Matured bonds payable	425,000	
Matured interest payable	2,976,944	
Unearned revenues	27,560	
Bonds payable	 	200,000 	
Total Current Liabilities	 	3,878,385 	
Non-Current Liabilities		
Bonds payable	 	9,230,000 	
Total Liabilities	 	13,108,385 	
NET POSITION		
Net investment in capital assets	(820,992)	
Restricted for special purpose entity	56,609	
Unrestricted	 	(5,993,420)	
Total Net Position	  $	(6,757,803)	

See accompanying notes.
- 9 -

Amelia Concourse Community Development District STATEMENT OF ACTIVITIES
For the Year Ended September 30, 2017

						Net (Expense)	
						Revenues and	
						Changes in	
			Program Revenues		Net Position	

Functions/Programs	

Expenses		Charges for Services	Operating
Grants and Contributions		Governmental Activities	
Primary government							
Governmental Activities							
General government	$	(124,146)		$	88,222	$	130,210		$	94,286	
Physical environment	(208,682)		97,704	-		(110,978)	
Interest on long-term debt	 	(714,073)		 	117,416     		- 		 	(596,657)	
Total Governmental Activities	  $ (1,046,901)		  $	303,342      	$	130,210 		(613,349)	

General Revenues				
	Investment earnings			5,312	
	Miscellaneous revenues			 	22,720 	
	Total General Revenues			 	28,032 	
	Change in Net Position			(585,317)	
	Net Position - October 1, 2016			 	(6,172,486)	
	Net Position - September 30, 2017			  $	(6,757,803)	

See accompanying notes.

Amelia Concourse Community Development District BALANCE SHEET
GOVERNMENTAL FUNDS
September 30, 2017

			Special Purpose		Debt		Capital		Governmental	
	General		Entity		Service		Projects		Funds	
ASSETS										
Cash and cash equivalents	$	252,566		$	33,013		$	-		$	-		$	285,579	
Investments	53,846		-		-		-		53,846	
Accounts receivable	9		-		-		-		9	
Assessments receviables	173		-		237		-		410	
Deposits	2,475		-		-		-		2,475	
Prepaid expenses	3,367		-		-		-		3,367	
Land held for resale	-		54,656		-		-		54,656	
Restricted assets										
Investments, at fair value	-		-		961,332		142,565		1,103,897	
Total Assets	$	312,436		$	87,669		$	961,569		$	142,565		$ 1,504,239	

LIABILITIES AND FUND BALANCES										
Liabilities:										
Accounts payable and accrued expenses	$	5,746		$	3,500		$	-		$	-		$	9,246	
Unearned revenues	-		27,560		-		-		27,560	
Matured bonds payable	-		-		425,000		-		425,000	
Matured interest payable	-		-		2,976,944		-		2,976,944	
Total Liabilities	5,746		31,060		3,401,944		-		3,438,750	

Fund Balances:										
Nonspendable										
Deposits and prepaid expenses	5,842		-		-		-		5,842	
Restricted										
Capital projects	-		-		-		142,565		142,565	
Special purpose	-		56,609		-		-		56,609	
Unassigned	300,848		-		(2,440,375)		-		(2,139,527)	
Total Fund Balances	306,690		56,609		(2,440,375)		142,565		(1,934,511)	
Total Liabilities and Fund Balances	$	312,436		$	87,669		$	961,569		$	142,565		$ 1,504,239	

See accompanying notes.

Amelia Concourse Community Development District RECONCILIATION OF TOTAL GOVERNMENTAL FUND BALANCES TO NET POSITION OF GOVERNMENTAL ACTIVITIES
September 30, 2017

Total Governmental Fund Balances	$ (1,934,511)	
Amounts reported for governmental activities in the Statement of Net Position		
are different because:		
Capital assets not being depreciated, land and improvements, $719,533, and		
construction in progress, $2,990,291, used in governmental activities are not		
current financial resources and therefore, are not reported at the fund level.	3,709,824	
Capital assets being depreciated, infrastructure, $431,434 and recreation		
facilities and amenities, $1,526,077, net of accumulated depreciation,
$(820,992), used in governmental activities are not financial resources and therefore, are not reported at the fund level.	

1,136,519	
Long-term liabilities, including bonds payable, are not due and payable in the		
current period and; therefore, are not reported at the fund level.	(9,430,000)	
Accrued interest expense for long-term debt is not a current financial use and;		
therefore, is not reported at the fund level.	(239,635)	

Net Position of Governmental Activities	
  $ (6,757,803)	

See accompanying notes.

Amelia Concourse Community Development District STATEMENT OF REVENUES, EXPENDITURES AND CHANGES IN FUND BALANCES - GOVERNMENTAL FUNDS
For the Year Ended September 30, 2017

									Totals	
			Special Purpose		Debt		Capital		Governmental	
	General		Entity		Service		Projects		Funds	
Revenues										
Special assessments	$	185,926		$	-		$	117,416		$	-		$	303,342	
Bondholder contributions	-		130,210		-		-		130,210	
Investment earnings	143		-		3,331		1,838		5,312	
Miscellaneous revenues	22,720		-		-		-		22,720	
Total Revenues	208,789		130,210		120,747		1,838		461,584	

Expenditures										
Current										
General government	106,601		17,545		-		-		124,146	
Physical environment	118,058		-		-		-		118,058	
Capital outlay	215,702		-		-		1,706,323		1,922,025	
Debt service										
Principal	-		-		150,000		-		150,000	
Interest	-		-		546,352		-		546,352	
Other debt service costs	-		-		137,009		-		137,009	
Total Expenditures	440,361		17,545		833,361		1,706,323		2,997,590	

Excess of revenues over expenditures	
(231,572)		
112,665		
(712,614)		
(1,704,485)		
(2,536,006)	

Other financing sources (uses)										
Operating transfers in	110,240		-		-		20,766		131,006	
Operating transfers out	(20,659)		(110,240)		(107)		-		(131,006)	
Total Other Financing Sources (Uses)	89,581		(110,240)		(107)		20,766		-	

Net change in fund balances	
(141,991)		
2,425		
(712,721)		
(1,683,719)		
(2,536,006)	
Fund Balances - October 1, 2016	448,681		54,184		(1,727,654)		1,826,284		601,495	

Fund Balances - September 30, 2017	
$	306,690		
$	56,609		
$ (2,440,375)		
$	142,565		
$	(1,934,511)	

See accompanying notes.

For the Year Ended September 30, 2017

Net Change in Fund Balances - Total Governmental Funds	$ (2,536,006)	
Amounts reported for governmental activities in the Statement of Activities are		
different because:		
Governmental funds report capital outlays as expenditures, $1,922,025.		
However, in the Statement of Activities, the cost of those assets are allocated		
over their estimated useful lives as depreciation, $(90,624). This is the amount		
that capital outlays exceeded depreciation in the current period.	1,831,401	
Repayments of bond principal are expenditures at the fund level, but		
the repayments reduce long-term liabilities in the Statement of Net Position.	150,000	
In the Statement of Activities, interest is accrued on outstanding bonds; whereas		
in the fund level interest expenditures are reported when due. This is		
the change in accrued interest in the current period.	(30,712)	

Change in Net Position of Governmental Activites	
  $	(585,317)	

							Variance with	
							Final Budget	
	Original		Final				Positive	
	Budget		Budget		Actual		(Negative)	
Revenues								
Special assessments	$	293,545		$	293,545		$	185,926		$	(107,619)	
Investment earnings	-		-		143		143	
Miscellaneous revenues	500		500		22,720		22,220	
Total Revenues	294,045		294,045		208,789		(85,256)	

Expenditures								
Current								
General government	107,396		107,396		106,601		795	
Physical environment	165,990		165,990		118,058		47,932	
Capital outlay	 	- 		 	- 		 	215,702 		 	(215,702)	
Total Expenditures	273,386		273,386		440,361		(166,975)	

Excess of revenues over expenditures	
20,659		
20,659		
(231,572)		
(252,231)	

Other financing sources (uses)								
Transfer in	-		-		110,240		110,240	
Transfer out	(20,659)		(20,659)		(20,659)		-	

Total other financing sources/(uses)	
(20,659)		
(20,659)		
89,581		
110,240	

Net change in fund balances	
-		
-		
(141,991)		
(141,991)	
Fund Balances - October 1, 2016	 	- 		 	- 		 	448,681 		 	448,681 	
Fund Balances - September 30, 2017	  $	- 		  $	- 		   $	306,690 		  $	306,690 	

							Variance with	
							Final Budget	
	Original		Final				Positive	
	Budget		Budget		Actual		(Negative)	
Revenues								
Bondholder contributions	$	122,292		$	122,292		$	130,210		$	7,918	

Expenditures								
Current								
General government	34,400		34,400		17,545		16,855	

Excess of revenues over expenditures	
87,892		
87,892		
112,665		
24,773	

Other financing sources (uses)								
Transfer out	(87,892)		(87,892)		(110,240)		(22,348)	

Net change in fund balances	
-		
-		
2,425		
2,425	
Fund Balances - October 1, 2016	-		-		54,184		54,184	

Fund Balances - September 30, 2017	
  $	- 		
  $	- 		
   $	56,609 		
  $	56,609 	

The financial statements of the District have been prepared in conformity with generally accepted accounting principles (GAAP) as applied to governmental units. The Governmental Accounting Standards Board (GASB) is the accepted standard-setting body for establishing governmental accounting and financial reporting principles. The District's more significant accounting policies are described below.

1.	Reporting Entity

The District was established on July 10, 2006, by Ordinance 2006-58 of Nassau County, Florida, pursuant to the Uniform Community Development District Act of 1980, otherwise known as Chapter 190, Florida Statutes. The District was established for the purposes of financing and managing the acquisition, construction, maintenance and operation of the infrastructure necessary for community development within its jurisdiction. The District is authorized to issue bonds for the purpose, among others, of financing, funding, planning, establishing, acquiring, constructing or re-constructing, enlarging or extending, equipping, operating and maintaining water management, bridges or culverts, district roads, landscaping, street lights and other basic infrastructure projects within or without the boundaries of the Amelia Concourse Community Development District. The District is governed by a five-member Board of Supervisors who are elected for four year terms. The District operates within the criteria established by Chapter 190, Florida Statutes.

As required by GAAP, these financial statements present the Amelia Concourse Community Development District (the primary government) as a local unit of special-purpose government. The reporting entity for the District includes all functions of government in which the District’s Board exercises oversight responsibility including, but not limited to, financial interdependency, selection of governing authority, designation of management, significant ability to influence operations and accountability for fiscal matters. To be includable within the District’s financial statements, the component unit must be financially accountable or the exclusion of the nature and significance of their relationship with the District would cause the financial statements to be misleading or incomplete. Blended component units must be financially accountable to the District; there must be a financial burden/benefit relationship and the entity, although legally separate, must operate like a fund of the District.

Based upon the application of the above-mentioned criteria as set forth in Governmental Accounting Standards Board, the District has identified one blended component unit.

The blended component unit is a legally separate entity. It is reported as a Special Revenue Fund. The blended component unit of the District is as follows:

Reporting Entity (Continued)

Amelia Concourse SPE, LLC – The Company is a Special Purpose Entity (the “SPE”) that owns, manages, maintains, and will sell and/or dispose of the Property for the benefit of the District. The District, pursuant to an agreement between the Company, the District, and the
U.S. Bank National Association (the “Trustee”), will not impose annual maintenance assessments on the Property but instead will receive funding per request from the Trustee on a quarterly basis. Should funding cease or become delinquent for sixty days, the District holds the right to impose maintenance assessments and take all actions necessary, including foreclosure. In such a scenario, the Company waive any rights, arguments, claims or defenses of the Company in foreclosure proceedings and agree in no way to prevent the District from taking action. Whenever the Company receives cash from the sale of any portion of the Property, all monies will be remitted to the Trustee to apply pursuant to the Trust Indenture.

Measurement Focus and Basis of Accounting

The basic financial statements of the District are composed of the following:

Government-wide financial statements

Fund financial statements

Notes to financial statements

a. Government-wide Financial Statements

Government-wide financial statements report all non-fiduciary information about the reporting government as a whole and its blended component unit. These statements include all the governmental activities of the primary government and its component unit. The effect of interfund activity has been removed from these statements.

Governmental activities are supported by special assessments, developer contributions, intergovernmental revenues and interest. Program revenues are netted with program expenses in the Statement of Activities to present the net cost of each program.

Amounts paid to acquire capital assets are capitalized as assets, rather than reported as an expenditure. Proceeds of long-term debt are recorded as liabilities in the government-wide financial statements, rather than as an other financing source.

Amounts paid to reduce long-term indebtedness of the reporting government are reported as a reduction of the related liability, rather than as an expenditure.

The underlying accounting system of the District is organized and operated on the basis of separate funds, each of which is considered to be a separate accounting entity. The operations of each fund are accounted for with a separate set of self-balancing accounts that comprise its assets, liabilities, fund equity, revenues and expenditures. Governmental resources are allocated to and accounted for in individual funds based upon the purposes for which they are to be spent and the means by which spending activities are controlled.

Fund financial statements for the primary government’s governmental funds are presented after the government-wide financial statements. These statements display information about major funds individually.

Governmental Funds

The District implemented the Governmental Accounting Standards Board Statement 54
– Fund Balance Reporting and Governmental Fund Type Definitions. The Statement requires the fund balance for governmental funds to be reported in classifications that comprise a hierarchy based primarily on the extent to which the government is bound to honor constraints on the specific purposes for which amounts in those funds can be spent. The classifications include non-spendable, restricted, committed, assigned and unassigned.

The District has various policies governing the fund balance classifications.

Nonspendable Fund Balance – This classification consists of amounts that cannot be spent because they are either not in spendable form or are legally or contractually required to be maintained intact.

Restricted Fund Balance – This classification includes amounts that can be spent only for specific purposes stipulated by constitution, external resource providers, or through enabling legislation.

Committed Fund Balance – This classification consists of amounts that can only be used for specific purposes pursuant to the constraints imposed by a formal action of the government’s highest level of decision making authority.

Assigned Fund Balance – This classification consists of the Board of Supervisors’ intent to be used for specific purposes, but are neither restricted nor committed. The assigned fund balances can also be assigned by the District’s management company.

Governmental Funds (Continued)

Unassigned Fund Balance – This classification is the residual classification for the government’s general fund and includes all spendable amounts not contained in the other classifications. Unassigned fund balance is considered to be utilized first when an expenditure is incurred for purposes for which amounts in any of those unrestricted fund balance classifications could be used.
Fund Balance Spending Hierarchy – When restricted, committed, assigned, and unassigned fund balances are combined in a fund, qualified expenditures are paid first from restricted or committed fund balance, as appropriate, then assigned and finally unassigned fund balances.
Expenditures generally are recorded when a liability is incurred, as under accrual accounting. Interest associated with the current fiscal period is considered to be an accrual item and so has been recognized as revenue of the current fiscal period.

Under the current financial resources measurement focus, only current assets and current liabilities are generally included on the balance sheet. The reported  fund balance is considered to be a measure of “available spendable resources”. Governmental fund operating statements present increases (revenues and other financing sources) and decreases (expenditures and other financing uses) in net current assets. Accordingly, they are said to present a summary of sources and uses of “available spendable resources” during a period.

Because of their spending measurement focus, expenditure recognition for governmental fund types excludes amounts represented by non-current liabilities. Since they do not affect net current assets, such long-term amounts are not recognized as governmental fund type expenditures or fund liabilities.

Amounts expended to acquire capital assets are recorded as expenditures in the year that resources are expended, rather than as fund assets. In addition, the proceeds of long-term debt are recorded as an other financing source rather than as a fund liability.

Debt service expenditures are recorded only when payment is due.

Governmental Major Funds

General Fund – The General Fund is the District’s primary operating fund. It accounts for all financial resources of the general government, except those required to be accounted for in another fund.

Special Purpose Entity Fund – The Special Purpose Entity Fund is a Special Revenue Fund that accounts for the activities of the SPE, a blended component unit of the government. The SPE owns, manages, maintains, and will sell and/or dispose of the Property for the benefit of the District.

Debt Service Funds – The Debt Service Fund is used to account for the accumulation of resources for the annual payment of principal and interest on long-term debt.

Capital Projects Funds – Accounts for construction of infrastructure improvements within the district.

Non-current Governmental Assets/Liabilities

GASB Statement 34 requires that non-current governmental assets, such as infrastructure and improvements, and non-current governmental liabilities, such as general obligation bonds, be reported in the governmental activities column in the government-wide Statement of Net Position.

Assets, Liabilities, and Net Position or Equity

Cash and Investments

Florida Statutes require state and local governmental units to deposit monies with financial institutions classified as "Qualified Public Depositories," a multiple financial institution pool whereby groups of securities pledged by the various financial institutions provide common collateral from their deposits of public funds. This pool is provided as additional insurance to the federal depository insurance and allows for additional assessments against the member institutions, providing full insurance for public deposits.

Assets, Liabilities, and Net Position or Equity (Continued)

Cash and Investments (Continued)

The District is authorized to invest in those financial instruments as established by Section 218.415, Florida Statutes. The authorized investments consist of:

Direct obligations of the United States Treasury;

The Local Government Surplus Funds Trust or any intergovernmental investment pool authorized pursuant to the Florida Interlocal Cooperative Act of 1969;

Interest bearing time deposits or savings accounts in authorized qualified public depositories;

Securities and Exchange Commission, registered money market funds with the highest credit quality rating from a nationally recognized rating agency.

Cash equivalents include time deposits and certificates of deposit with original maturities of three months or less and held in a qualified public depository as defined by Section 280.02, Florida Statutes.

Restricted Assets

Certain assets of the District and a corresponding liability or portion of net position is classified as restricted on the statement of net position because their use is limited either by law through constitutional provisions or enabling legislation, or by restrictions imposed externally by creditors. In a fund with both restricted and unrestricted assets, qualified expenses are considered to be paid first from restricted net position and then from unrestricted net position.

Capital Assets

Capital assets, which include land and improvements, recreational facilities and infrastructure are reported in the governmental activities column in the government-wide statements.

The District defines capital assets as assets with an initial, individual cost of $5,000 or more and an estimated useful life in excess of one year. The valuation basis for all assets is historical cost.

The costs of normal maintenance and repairs that do not add to the value of the asset or materially extend its useful life are not capitalized.

Major outlays for capital assets and improvements are capitalized as projects are constructed.

NOTE A – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

4. Assets, Liabilities, and Net Position or Equity (Continued)

Capital Assets (Continued)

Depreciation of capital assets is computed and recorded by utilizing the straight-line method. Estimated useful lives of the various classes of depreciable capital assets are as follows:

Infrastructure	20 years
Recreational facilities	30 years

Budgets

Budgets are prepared and adopted after public hearings for the governmental funds, pursuant to Chapter 190, Florida Statutes. The District utilizes the same basis of accounting for budgets as it does for revenues and expenditures in its various funds. The legal level of budgetary control is at the fund level. All budgeted appropriations lapse at year end. Formal budgets are adopted for the general and debt service funds.

NOTE	B	–		RECONCILIATION	OF	GOVERNMENT-WIDE	AND	FUND	FINANCIAL STATEMENTS

1. Explanation of Differences Between the Governmental Fund Balance Sheet and the Government-wide Statement of Net Position

“Total fund balances” of the District’s governmental funds ($(1,934,511)) differs from “net position” of governmental activities ($(6,757,803)) reported in the Statement of Net Position. This difference primarily results from the long-term economic focus of the Statement of Net Position versus the current financial resources focus of the Governmental Fund Balance Sheet. The effect of the differences is illustrated below.

Capital related items

When capital assets (infrastructure and recreational facilities that are to be used in governmental activities) are purchased or constructed, the cost of those assets is reported as expenditures in governmental funds. However, the Statement of Net Position included those capital assets among the assets of the District as a whole.

Land	$	719,533	
Construction in progress	2,990,291	
Infrastructure	431,434	
Recreational facilities	1,526,077	
Accumulated depreciation	 	(820,992)	
Total	$	4,846,343 	

NOTE	B	–		RECONCILIATION	OF	GOVERNMENT-WIDE	AND	FUND	FINANCIAL STATEMENTS (CONTINUED)

Explanation of Differences Between the Governmental Fund Balance Sheet and the Government-wide Statement of Net Position (Continued)

Long-term debt transactions
Long-term liabilities applicable to the District’s governmental activities are not due and payable in the current period and accordingly are not reported as fund liabilities.  All liabilities (both current and long-term) are reported in the Statement of Net Position.

Balances at September 30, 2017 were:
Bonds payable	$	(9,430,000)

Accrued interest
Accrued liabilities in the Statement of Net Position differ from the amount reported in governmental funds due to the accrued interest on bonds.

Accrued interest	$	(239,635)

Explanation of Differences Between the Governmental Fund Operating Statements and the Statement of Activities

The “net change in fund balances” for government funds ($(2,536,006)) differs from the “change in net position” for governmental activities ($(585,317)) reported in the Statement of Activities. The differences arise primarily from the long-term economic focus of the Statement of Activities versus the current financial resources focus of the governmental funds. The effect of the differences is illustrated below.

Capital related items

When capital assets that are to be used in governmental activities are purchased or constructed, the resources expended for those assets are reported as expenditures in governmental funds. However, in the Statement of Activities, the costs of those assets are allocated over their estimated useful lives as depreciation. The following is the amount that capital outlay exceeded depreciation in the current year.

Capital outlay	$	1,922,025	
Depreciation	 	(90,624)	
Total	$	1,831,401	

NOTE B – RECONCILIATION OF GOVERNMENT-WIDE AND FUND FINANCIAL STATEMENTS (CONTINUED)

2. Explanation of Differences Between the Governmental Fund Operating Statements  and the Statement of Activities (Continued)

Long-term debt transactions

Repayments of bond principal are expenditures at the fund level but reduce liabilities in the Statement of Net Position. The issuance of new debt is an other financing source at the fund level but it increases long-term liabilities in the Statement of Net Position.

Principal payments	$	150,000

Some expenses reported in the statement of activities do not require the use of current financial resources, therefore, are not reported as expenditures in governmental funds.

Change in accrued interest payable	$	(30,712)

NOTE C – CASH AND INVESTMENTS

All deposits are held in qualified public depositories and are included on the accompanying balance sheet and statement of net position as cash and investments.

Custodial Credit Risk – Deposits
Custodial credit risk is the risk that in the event of a bank failure, the District’s deposits may not be returned. The investment policy of the District follows the provisions of Chapter 280, Florida Statutes regarding deposits and investments. As of September 30, 2017, the District’s bank balance was $395,760 and the carrying value was $285,579. The District controls its exposure to custodial credit risk because it maintains all deposits in a qualified public depository in accordance with the provisions of Chapter 280, Florida Statutes, which means that all deposits are fully insured by Federal Depositors Insurance or collateralized under Chapter 280, Florida Statutes.

As of September 30, 2017, the District had the following investments and maturities:

 	Investment	
SBA Local Govt Surplus Funds	  Maturity 	    Fair Value		
Florida Prime	50 Days *	$	67,285	
Fidelity Government Portfolio	39 Days *	811,473	
US Bank Mmkt Managed	N/A	 	278,985 	
Total		  $ 1,157,743 	

* Weighted Average Maturity

The District categorizes its fair value measurements within the fair value hierarchy recently established by generally accepted accounting principles. The fair value is the price that would be received to sell an asset, or paid to transfer a liability, in an orderly transaction between market participants at the measurement date. The hierarchy is based on the valuation inputs used to measure the fair value of the asset. The District uses a market approach in measuring fair value that uses prices and other relevant information generated by market transactions involving identical or similar assets, liabilities, or groups of assets and liabilities.

Assets or liabilities are classified into one of three levels. Level 1 is the most reliable and is based on quoted price for identical assets, or liabilities, in an active market. Level 2 uses significant other observable inputs when obtaining quoted prices for identical or similar assets, or liabilities, in markets that are not active. Level 3 is the least reliable and uses significant unobservable inputs that uses the best information available under the circumstances, which includes the District’s own data in measuring unobservable inputs.

Based on the criteria in the preceding paragraph, the investment in Fidelity Government Portfolio and US Bank Managed Money Market are Level 1 assets.

Investments
The District's investment policy allows management to invest funds in investments permitted under Section 218.415, Florida Statutes. Among other investments, the policy allows the District to invest in the State Board of Administration Local Government Surplus Trust Funds.

Cash placed with the State Board of Administration represents the District's participation in the Local Government Surplus Trust Funds Investment Pool and is reported at fair value. As a pool participant the District invests in pools of investments in which shares are owned in the pool rather than the underlying investments.

Interest Rate Risk
The District monitors investment maturities as a means of managing its exposure to fair value losses arising from increasing interest rates.

Credit Risk
The District's investments in treasury funds, commercial paper, and government loans are limited by state statutory requirements and bond compliance. The District has no investment policy that would further limit its investment choices. The Local Government Surplus Funds Trust is an authorized investment under Section 218.415, Florida Statutes. The District's investments in the state investment pool and government loans are limited by state statutory requirements and bond compliance. The District had monies invested with the Local Government Surplus Funds Trust Fund, at September 30, 2017. This fund met the requirements of a "2-7a like pool" as defined in Government Accounting Standards Board, Statement 31. As of September 30, 2017, the District's investment in the Fidelity Government Portfolio, SBA Local Government Surplus Funds and Managed Money Market Accounts were rated AAAm by Standard & Poor's.

Concentration of Credit Risk
The District places no limit on the amount it may invest in any one issuer. The investment in Fidelity Government Portfolio represents 70% of the District's total investments. The investment in Local Government Surplus Funds Trust represents 6% of the District's total investments. The remaining 24% is invested in US Bank Managed Money Market Accounts.

The types of deposits and investments and their level of risk exposure as of September 30, 2017 were typical of these items during the fiscal year then ended. The District considers any decline in fair value for certain investments to be temporary. In addition, the District has the ability to hold investments to maturity that have fair values less than cost. The District’s investments are recorded at book value.

NOTE D – INTERFUND TRANSFERS

Interfund transfers for the fiscal year ended September 30, 2017 were as follows:

 	Fund		 Transfer In	 	Transfer Out	

General

$	110,240

$	20,659

Special Revenue	-	110,240
Debt Service	-	107
Capital Projects	 	20,766 	- 
  $	131,006      $	131,006 
Transfers from the General fund were used to build up capital reserves. Transfers from the Special Revenue fund to the General fund were made to finance a portion of the District's general operations as the District is not imposing operating and maintenance assessments on the Property owned by the SPE.

Amelia Concourse Community Development District NOTES TO THE FINANCIAL STATEMENTS
September 30, 2017

NOTE E – SPECIAL ASSESSMENT REVENUES

Assessments are non-ad valorem assessments on benefitted property within the District. Operating and Maintenance Assessments are based upon adopted budget and levied annually. Debt Service Assessments are levied when bonds are issued and collected annually. The District may collect assessments directly or utilize the uniform method of collection (Chapter 197.3632, Florida Statutes). Direct collected assessments are due as determined by annual assessment resolution adopted by the Board of Supervisors. Assessments collected under the uniform method are mailed by County Tax Collector on November 1 and due on or before March 31 of each year. Property owners may prepay a portion or all of the Debt Service Assessments on their property subject to various provisions in the bond documents.

Assessments and interest associated with the current fiscal period are all considered to be susceptible to accrual and so have been recognized as revenues of the current fiscal period. Only the portion of assessments receivable due within the current fiscal period is considered to be susceptible to accrual as revenue of the current period.

NOTE F – CAPITAL ASSETS

Capital Asset activity for the year ended September 30, 2017 was as follows:

	Balance	Balance
October 1,	September 30,	

Governmental Activities:	 	2016	 Additions	 Deletions 	2017		
Capital assets, not being depreciated:
Land and improvements	
$	719,533	$	-	$	-	$	719,533	
Construction in progress	 	1,075,299 	1,914,992 	- 	2,990,291 	
Total Capital Assets Not Being Depreciated	 	1,794,832 	1,914,992 	- 	3,709,824 	
Capital assets, being depreciated: Infrastructure - stormwater management	
430,751	683	-	431,434	
Recreational facilities	 	1,519,727 	6,350 	- 	1,526,077 	
Total Capital Assets Being Depreciated	 	1,950,478 	7,033 	- 	1,957,511 	
Less accumulated depreciation for:		
Infrastructure - storm drainage	(98,963)	(14,506)	-	(113,469)	
Buildings and recreational facilities	 	(631,405) 	(76,118) 	- 	(707,523)	
Total Accumulated Depreciation	 	(730,368) 	(90,624) 	- 	(820,992)	
Governmental Activities Capital Assets	  $	3,014,942     $ 1,831,401    $	-    $	4,846,343 	

Depreciation of $90,624 was charged to physical environment.

NOTE G – LONG-TERM DEBT

The following is a summary of activity in the long-term debt of the District for the year ended September 30, 2017:

Long-term debt at October 1, 2016	$	9,580,000	
Principal payments	 	(150,000)	
Long-term debt at September 30, 2017	$	9,430,000 	
Long-term debt is comprised of the following:		
Capital Improvement Revenue Bonds		
$7,350,000 Series 2007 Capital Improvement Revenue Bonds due in annual principal installments beginning May 2009 and maturing May 1, 2038. Interest at a rate of 5.75% is due May and November beginning November 2007.	

$	6,045,000	
$3,385,000 Series 2016 Capital Improvement Revenue Bonds due in annual principal installments beginning May 2018 and maturing May 1, 2047. Interest at a rate of 6.00% is due May and November beginning November 2016.	

$	3,385,000	

The annual requirements to amortize the principal and interest of long-term debt outstanding as of September 30, 2017 are as follows:

Year Ending
 	September 30, 	 	Principal		 	Interest		 	Total		
2018	$	200,000	$	575,125	$	775,125	
2019	215,000	563,525	778,525	
2020	220,000	551,050	771,050	
2021	240,000	538,288	778,288	
2022	255,000	524,363	779,363	
2023-2027	1,505,000	2,383,300	3,888,300	
2028-2032	2,010,000	1,891,488	3,901,488	
2033-2037	2,680,000	1,234,863	3,914,863	
2038-2042	1,055,000	501,050	1,556,050	
2043-2047	 	1,050,000 	 	196,800 	 	1,246,800 	
Totals	  $	9,430,000 	  $	8,959,852 	  $	18,389,852 	

NOTE G – LONG-TERM DEBT (CONTINUED)

Capital Improvement Revenue Bonds (Continued)

Summary of Significant Bonds Resolution Terms and Covenants

Depository Funds – The bond resolution establishes certain funds and determines the order in which revenues are to be deposited into these funds. A description of the significant funds, including their purposes, is as follows:

Reserve Fund – The 2007 Reserve Account is funded from the proceeds of the Bonds in an amount equal to the reserve percentage, 7.0264%, times the deemed outstanding amount. Monies held in the reserve accounts will be used only for the purposes established in the Trust Indenture.

Reserve Fund – The 2016 Reserve Account is funded from the proceeds of the Bonds in an amount equal to 50% of the maximum annual debt service requirement for the Series 2016 Bonds, which amount initially equals $123,050. Monies held in the reserve accounts will be used only for the purposes established in the Trust Indenture.

Capital Improvement Revenue Bonds

Reserve
Balance

Reserve
Requirement

 
Series 2007 Capital Improvement Revenue Bonds	$		82,282	$	436,897 Series 2016 Capital Improvement Revenue Bonds	$	123,050	$	123,050

NOTE H – RISK MANAGEMENT

The District is exposed to various risks of loss related to torts; theft of, damage to, and destruction of assets; errors and omissions; and natural disasters. These risks are covered by commercial insurance from independent third parties. Settled claims from these risks have not exceeded commercial insurance coverage over the past three years.

NOTE I – DEFICIT FUND BALANCE

The Debt Service Fund reported a deficit fund balance of $(2,440,375) at September 30, 2017. The deficit is not expected to be covered until the Property owned by Amelia Concourse SPE, LLC is fully sold.

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Berger, Toombs, Elam,
....o,,	Gaines & Frank
Certified Public Accountants	PL

600 Citrus Avenue
Suite 200
Fort Pierce,  Florida 34950
7721461-6120  II 461-1155
FAX: 7721468-9278

INDEPENDENT AUDITOR'S REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS

To the Board of Supervisors
Amelia Concourse Community Development District Nassau County, Florida

We have audited, in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Comptroller General of the United States, the financial statements of Amelia Concourse Community Development District, as of and for the year ended September 30, 2017, and the related notes to the financial statements, and have issued our report thereon dated June 27, 2018.

Internal Control Over Financial Reporting

In   planning  and  performing	our   audit,   we   considered  Amelia  Concourse	Community· Development District's internal control over financial reporting to determine the audit procedures that are appropriate in the circumstances for the purpose of expressing our opinions on the financial statements, but not for the purpose of expressing an opinion on the effectiveness of Amelia Concourse Community Development District's internal control. Accordingly, we do not express an opinion on the effectiveness of Amelia Concourse Community  Development District's internal control over financial reporting.

A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct misstatements on a timely basis. A material weakness is a deficiency, or combination of deficiencies, in internal control, such that there is a reasonable possibility that a material misstatement of the entity's financial statements will not be prevented, or detected and corrected on a timely basis. A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough to merit attention by those charged with governance.

Our consideration of internal control over financial reporting was for the limited purpose described in the first paragraph of this section and was not designed to identify all deficiencies in internal control that might be material weaknesses or significant deficiencies. Given these limitations, during our audit we did not identify any deficiencies in internal control that we consider to be material weaknesses. However, material weaknesses may exist that have not been identified.

Member AICPA

Fort Pierce I Stuart
- 31 -
Member AICPA Division For CPA Firms Private Companies Practice Section

Member FICPA

fti Berger, Toombs, Elam,
,OJ Gaines & Frank
CertifiedPublitAcmunWl!J PL

Board of Supervisors
Amelia Concourse Community Development District

Compliance and Other Matters

As part of obtaining reasonable assurance about whether Amelia Concourse Community Development District's financial statements are free of material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements, noncompliance with which could have a direct and material effect on the determination of financial statement amounts. However, providing an opinion on compliance with those provisions was not an objective of our audit, and accordingly, we do not express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards.

We noted a compliance matter and other matters that we reported to management of the District in a separate letter dated June 27, 2018.

The District's responses to the findings identified in our audit are described in the accompanying Management Letter. We did not audit the District's responses and, accordingly, we express no opinion on them.

Purpose of this Report

The purpose of this report is solely to describe the scope of our testing of internal control and compliance and the results of that testing, and not to provide an opinion on the effectiveness of the entity's internal control or on compliance. This report is an integral part of an audit performed in accordance with Government Auditing Standards in considering the entity's internal control and compliance. Accordingly, this communication is not suitable for any other

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Berger, Toombs, Elam, Gaines & Frank
Certified Public Accountants Fort Pierce, Florida

June 27, 2018

- 32 -

Berger, Toombs, Elam, Gaines & Frank
Certified Public Accountants	PL
600 Citrus Avenue
Suite 200
Fort  Pierce,  Florida 34950
772/461-6120 II 461-1155
FAX: 7721468-9278

To the Board of Supervisors

MANAGEMENT LETTER

Amelia Concourse Community Development District Nassau County, Florida
Report on the Financial Statements

We have audited the financial statements of the Amelia Concourse Community Development District as of and for the year ended September 30, 2017, and have issued our report thereon dated June27, 2018.
Auditor's Responsibility

We conducted our audit in accordance with auditing standards generally accepted in the United States; the standards applicable to · financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States and Chapter 10.550, Rules of the Florida Auditor General.

Other Reports and Schedule

We have issued our Independent Auditor's Report on Internal Control over Financial Reporting. and on Compliance and Other Matters Based on an Audit of Financial Statements Performed in Accordance with Government Auditing Standards and our Independent Auditor's Report on an examination conducted in accordance with AICPA Professionals Standards, AT-C Section 315 regarding compliance requirements in accordance with Chapter 10.550, Rules of the Auditor General.	Disclosures in that report, which is dated June 27, 2018, should be considered in conjunction with this Management Letter.
Prior Audit Findings

Section 10.554(1)(i)1., Rules of the Auditor General, requires that we determine whether or not corrective actions have been made to address findings and recommendations made in the preceding financial audit report. The following findings or recommendations were made in the preceding financial audit report:

Findings and Recommendations

2012-01/2013-01/2014-01 Reserve Requirement

Finding: The Debt Service Reserve Requirement for 2007 Bond was not met at fiscal year end.

Recommendation: The District should make the necessary arrangements to ensure funds are available to make debt service payments.

Member AICPA

Fort Pierce I Stuart
- 33 -
Member AICPA Division For CPA Firms Private Companies Practice Section

Member FICPA

Berger, Toombs, Elam,

,t)J Gaines & Frank

To the Board of Supervisors
Amelia Concourse Community Development District

Management Response: The District is working directly with the Trustee and Bondholders to resolve all financial issues related to the non-payment of assessments which resulted in foreclosure of property, insufficient funds to meet debt service requirements, fund balance deficits and failure to meet Debt Service Reserve Fund requirements.

Current Status: This finding has not been corrected as of September 30, 2017. 2012-02/2013-02/2014-02 Financial Condition Assessment
Finding: The District's financial conditions continue to deteriorate and the future of the project remains uncertain. The Debt Service Fund has reported deficit fund balances at the end of the last six years. Nonpayment of assessments by the former Developer caused there to be insufficient funds available to make the required debt service payments on the Series 2007 bond beginning with the scheduled· payment due on May 1, 2009. As a result, the interest portion of the May 1, 2009 debt service payment for the Series 2007 Bonds was made, in part, by a draw on the Debt Service Reserve Account and the May 1, 2009 principal payment was not made until March 12, 2013. Additional debt service payments were not made. However, the District did not make the current year principal payment, any of the past due interest nor did they make full payment of the current year interest due. The failures by the District to pay its debt service on 2007 Bond are considered events of default. The District remains obligated with respect to the principal and interest on the Series 2007 Bonds.

Recommendation: The District should take the necessary steps to improve the deteriorating financial condition.

Management Response: The District is working directly with the Trustee and Bondholders to resolve all financial issues related to the non-payment of assessments which resulted in foreclosure of property, insufficient funds to meet debt service requirements, fund balance deficits and failure to meet Debt Service Reserve Fund requirements.

Current Status: This finding has not been corrected as of September 30, 2017. Additionally, the District had a net deficit fund balance in the Debt Service Fund as of September 30, 2017.

2015-01 Budget Over Expenditures - SPE

Finding: The actual expenditures of the Special Purpose Entity Fund exceeded the budgeted amounts for the prior fiscal year.

Recommendation: The District should make the necessary changes to ensure that budgeted expenditures are not exceeded.

Management Response: The District in conjunction with the Special Purpose Entity, Amelia Concourse SPE, LLC, amend the current year budget to ensure that budgeted amounts were not exceeded.

Current Status: This finding has been corrected as of September 30, 2017.

Cmifl!d PubficAcmuntanl.i PL

To the Board of Supervisors
Amelia Concourse Community Development District

Financial Condition

Section 10.554(1)(i)5.a. and 10.556(7), Rules of the Auditor General, requires us to apply appropriate procedures and communicate the results of our determination as to whether or not Amelia Concourse Community Development District has met one or more of the conditions described in Section 218.503(1), Florida Statutes, and to identify the specific conditions met. In connection with our audit, we determined that the Amelia Concourse Community Development District did not meet one of the conditions described in Section 218.503(1), Florida Statutes.

Pursuant to Sections 10.554(1)(i)5.c. and 10.556(8), Rules of the Auditor General, we applied financial conditions assessment procedures as of September 30, 2017 for the Amelia Concourse Community Development District. It is management's responsibility to monitor the Amelia Concourse Community Development District's financial condition; our financial condition assessment was based in part on the representations made by management and the review of the financial information provided by the same.

Section 10.554(1)(i)2., Rules of the Auditor General, requires that we communicate any recommendations to improve financial management. In connection with our audit, we did not have any such recommendations.

Annual Financial Report

Section 10.554(1)(i)5.b. and 10.556(7), Rules of the Auditor General, requires that we apply appropriate procedures and communicate the results of our determination as to whether the . annual financial report for the Amelia Concourse Community Development District for the fiscal year ended September 30, 2017, filed with the Florida Department of Financial  Services pursuant to Section 218.32(1)(a), Florida Statutes, is in agreement with  the  annual financial audit report for the fiscal year ended September 30, 2017. In connection with our audit, we determined that these two reports were in agreement.

Additional Matters

Section 10.554(1)(i)3., Rules of the Auditor General, requires us to communicate noncompliance with provisions of contracts or grant agreements, or abuse, that have occurred, or are likely to have occurred, that have an effect on the financial statements that is less than material but which warrants the attention of those charged with governance. In connection with our audit, we did note the following finding.

2017-01

Finding: Response:

The General Fund actual expenditures exceeded the budget for the year ended September 30, 2017 which is in violation of Section 189.016, Florida Statutes.

Management will review current year spending to ensure that expenditures do not exceed appropriations.

To the Board of Supervisors
Amelia Concourse Community Development District

Purpose of this Letter

rJ	A

Our Management Letter is intended solely for the information and use of the Legislative Auditing Committee, members of the Florida Senate and the Florida House of Representatives, the Florida Auditor General, Federal and other granting agencies, the Board of Supervisors, and applicable management, and is not intended to be and should not be used by anyone other than these specified parties.
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Berger, Toombs, Elam, Gaines & Frank
Certified Public Accountants PL Fort Pierce, Florida

June 27, 2018

t Berger, Toombs, Elam,
.....o.,	Gaines & Frank
Certified Public Accountants	PL
600 Citrus Avenue
Suite 200
Fort Pierce,  Florida 34950
7721461-6120  II 461-1155
FAX: 7721468-9278

INDEPENDENT ACCOUNTANT'S REPORT/COMPLIANCE WITH SECTION 218.415, FLORIDA STATUTES

To the Board of Supervisors
Amelia Concourse Community Development District Nassau County, Florida

We have examined Amelia Concourse . Community Development District's compliance with Section 218.415, Florida Statutes during the year ended September 30, 2017. Management is responsible for Amelia Concourse Community Development District's compliance with those requirements. Our responsibility is to express an opinion on Amelia Concourse Community Development District's compliance based on our examination.

Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and, accordingly, included examining, on a test basis, evidence about Amelia Concourse Community Development District's compliance with those requirements and performing such other procedures as we considered necessary in the circumstances. We believe that our examination provides a reasonable basis for our · opinion. Our examination does not provide a legal determination on Amelia Concourse Community Development District's compliance with the specified requirements.

In our opinion, Amelia Concourse Community Development District complied, in all material respects, with the aforementioned requirements during the year ended September 30, 2017.
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Berger, Toombs, Elam, Gaines & Frank
Certified Public Accountants PL June 27, 2018

Member AICPA

Fort Pierce / Stuart
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Member AICPA Division For CPA Firms Private Companies Practice Section

Member FICPA