Audit of Visit Orlando’s

Compliance with the 2019

Tourism Promotion
Agreement

Phil Diamond, CPA

County Comptroller
Orange County, Florida
www.occompt.com

Report 520
July 2025
County Audit Division

Wendy Kittleson, CPA, CIA

Assistant Comptroller

Lisa Fuller, CISA, CIA, CGAP

Director

Erin Boley, CPA, CIA

Deputy Director

Audit Team

Wendy Magno, CPA, CIA, CGAP Jaqueline Bedoya, CIA, CGAP

Audit Supervisor Audit Supervisor

Krupali Patel, CIA, CFE Brenda Feliciano, CPA

Audit Supervisor Audit Supervisor

Christina Eng Andrew Gibb, CIA

Senior Auditor Senior Auditor

Orange County Comptroller’s Office

Mission
The mission of the Orange County Comptroller’s Office is to serve the citizens of
Orange County and our customers by providing responsive, ethical, effective, and
efficient protection and management of public funds, assets, and documents, as
specified in the Florida Constitution and Florida Statutes.

Vision
The vision of the Orange County Comptroller’s Office is to be recognized as a highly
competent, cohesive team leading the quest for continuing excellence in the
effective safeguarding and ethical management of public funds, assets, and
documents.
 Audit of Visit Orlando’s Compliance with the
2019 Tourism Promotion Agreement

TABLE OF CONTENTS

TRANSMITTAL LETTER.............................................................................................................................. 1

EXECUTIVE SUMMARY .............................................................................................................................. 2

Background .............................................................................................................................................. 5
Overall Evaluation .................................................................................................................................... 7

RECOMMENDATIONS FOR IMPROVEMENT ............................................................................................ 8

1. Visit Orlando Incorrectly Classified and Deposited TDT Revenues as Private Funds .................. 8
2. Return on Investment Analysis Was Not Performed to Determine if TDT Funds Were Spent
Appropriately ............................................................................................................................... 14
3. TDT Funds Were Used to Pay for Ineligible Expenses ............................................................... 17
4. Orange County Should Enhance Contract Monitoring and Enforcement ................................... 19
5. Inappropriate Use of TDT Funds for Member-Related Overhead Costs .................................... 21
6. Visit Orlando Engaged in Lobbying Activities Without Board of County Commissioners Approval
..................................................................................................................................................... 23
7. Visit Orlando Did Not Comply with Its Procurement Policies ...................................................... 24

SCOPE, OBJECTIVES, AND METHODOLOGY ....................................................................................... 26

Audit Scope ............................................................................................................................................ 26

Audit Objective ....................................................................................................................................... 26
Audit Methodology ................................................................................................................................. 26

VISIT ORLANDO ACTION PLAN .............................................................................................................. 28

COUNTY ADMINISTRATION ACTION PLAN ........................................................................................... 31

APPENDIX A – VISIT ORLANDO’S MANAGEMENT RESPONSE .......................................................... 32

APPENDIX B – COUNTY ADMINISTRATION’S MANAGEMENT RESPONSE ....................................... 43

APPENDIX C – INTERIM MEMO AND RESPONSE TO VISIT ORLANDO .............................................. 47

APPENDIX D – DETAILED LIST OF REVENUES .................................................................................... 56

APPENDIX E – EXCERPT OF VISIT ORLANDO'S EXPENSE POLICY .................................................. 57

APPENDIX F – VISIT ORLANDO EXAMPLE LUNCHEON AGENDA...................................................... 59

 Audit of Visit Orlando’s Compliance with the
EXECUTIVE SUMMARY 2019 Tourism Promotion Agreement

Executive Summary
Why This Audit is Important

Millions of visitors pay Tourist Development Taxes (TDT) at hotels and other short-
term rentals in Orange County every year. The County collected more than $353
million of TDT in 2023 and provided $105 million to Visit Orlando (VO) under the
2019 Tourism Promotion Agreement (Agreement). TDT collections have increased
regularly with VO receiving over $100 million in TDT Funds every year since 2022.
This Agreement is the County’s largest annual TDT commitment. VO also collected
about $8.98 million from other sources. The distinction between TDT and Private
Funds is an important issue in this report. Florida law and the Agreement both
restrict how TDT Funds can be spent. Private Funds do not have such restrictions.
Additionally, given the importance of tourism to the County economy and
community, it is essential that the TDT Funds collected by the County are well
spent.

According to the Agreement, “VO shall use its best commercially reasonable
efforts to advertise, sell, promote, and market the tourism attractions,
accommodations and amenities in Orange County.” This audit focused on VO’s
compliance with the Agreement to ensure that TDT funds are spent in the best
commercially reasonable way and transparent with reporting to taxpayers.

Transparency in public spending is essential to maintaining the trust and

confidence of taxpayers. It ensures that TDT funds are used efficiently and
responsibly. Recipients of tax funds should adequately document how funds are
allocated and spent to ensure accountability and enable public oversight.

What We Found

The audit revealed several compliance issues, including misclassifying TDT

revenues as Private Funds, TDT expenditures that did not promote tourism, and
engaging in lobbying activities without BCC approval. VO also did not adhere to
internal policies regarding the evaluation of event returns and competitive
procurement practices. In addition, we identified areas where the County should
improve contract monitoring. We also identified areas where the Agreement should

2 | Page
 Audit of Visit Orlando’s Compliance with the
EXECUTIVE SUMMARY 2019 Tourism Promotion Agreement

be modified to clarify its terms. This would help avoid competing interpretations of
the Agreement’s terms. Details about each of these issues are provided below.

Revenues Should Have Been Reimbursed to TDT Funds

As previously identified in our 2019 audit, VO incorrectly classified TDT revenues

as Private Funds and failed to reimburse VO’s TDT Funds. This audit revealed that
in 2023, at least $3.54 million in other revenue should have been reimbursed to
VO’s TDT Funds because the revenues were directly related to TDT expenditures.
Further, the Agreement is unclear whether an additional $996,100 from
website/newsletter advertising should also have been reimbursed to VO’s TDT
Funds. If so, the total amount due to TDT Funds would increase to $4.54 million.

Return on Investment Was Not Evaluated on Events Paid For With TDT
Funds

VO staff did not comply with internal policies for evaluating the return on events
hosted by VO. VO’s internal expense reporting policy requires its staff to evaluate
ROI for hosted events and business travel exceeding $500 as part of a Summary
Report. VO’s policy highlights ROI/return evaluation as a key component of event
documentation. However, management stated that costs are not included in the
Summary Reports. As a result, there is a gap between VO’s policy and actual
practice, as none of the Summary Reports reviewed included ROI calculations.

TDT Funds Spent on Ineligible Expenditures

We identified $379,780 in TDT Fund expenditures that did not promote tourism.
VO also improperly used TDT Funds to pay for member-related overhead costs.

Reserve Funds Source Cannot Be Determined

VO commingled TDT and Private Funds in one reserve account. As of December

31, 2023, the account had a balance of $15 million. We confirmed that 52% of the
amount had been transferred from TDT Funds, and only $875,000 had been
transferred from Private Funds. VO is unable to provide evidence of the source of
funds for the remaining balance of $6,367,794.

VO Engaged in Lobbying Without BCC Approval

3 | Page
 Audit of Visit Orlando’s Compliance with the
EXECUTIVE SUMMARY 2019 Tourism Promotion Agreement

The Agreement explicitly prohibits VO from engaging in state legislative lobbying

activities without prior approval from the BCC. Our review of VO’s website
identified instances where VO staff engaged in activities that appear to be lobbying
without BCC approval.

Contract Monitoring Was Not Adequately Performed By Orange County

The County did not adequately monitor VO’s compliance with the Agreement. As
a result, VO’s noncompliance issues were not identified. Additionally, the County
has not conducted an independent economic analysis of its investment in VO. This
analysis could enable the BCC to better understand the benefits and costs
associated with its spending on VO and other TDT recipients.

Overall Evaluation

We have conducted an audit of Visit Orlando’s compliance with the 2019 Tourism
Promotion Agreement. We have identified violations of the current Agreement.
Additionally, we have found material concerns related to revenues and
expenditures of Tourist Development Tax Funds, which can be remedied by Visit
Orlando's actions and through an amendment to the Agreement. These violations
and material concerns are detailed in the recommendations section of the report.

4 | Page
 Audit of Visit Orlando’s Compliance with the
INTRODUCTION 2019 Tourism Promotion Agreement

Background

Orlando/Orange County Convention & Visitors Bureau, Inc., doing business as

Visit Orlando (VO), is the official destination marketing organization for Orange
County (County). It is responsible for promoting the region as a premier destination
for leisure, conventions, and business travel.
Established as a not-for-profit trade
association, VO collaborates with County
government and local tourism stakeholders
to drive economic impact through travel and
tourism. With 74 million visitors in 2023,
Central Florida is one of the most visited
places in the United States, according to VO.

VO is governed by a board of directors

composed of representatives from the
tourism, hospitality, and business sectors, as
well as public officials. The organization
operates under the 2019 Tourism Promotion
Agreement (Agreement) with the County.
The County has provided VO with a portion
of the Orange County Tourist Development Taxes (TDT) collected since VO’s
inception in 1983.

TDT is a local option tax authorized by the State of Florida and levied on short-
term rentals, including hotels, motels, vacation rentals, and other transient
accommodations. The current TDT rate in Orange County is 6%. The use of TDT
is regulated by Section 125.0104, Florida Statutes.

Tourism is the largest sector of the County’s economy. The County collected over
$353 million of TDT revenue in 2023. The County paid VO $105 million from
calendar year 2023 TDT collections. 1 VO also collected revenue from other
sources, including membership fees, cooperatives, participation fees, advertising
revenue, and interest earnings. However, as shown in the following chart, revenue
from these other sources has declined over the past decade while TDT funding

1 The County also provided VO $1 million for the Business Development Fund and $4 million for
the Sports Incentive Fund.

5 | Page
 Audit of Visit Orlando’s Compliance with the
INTRODUCTION 2019 Tourism Promotion Agreement

has increased. To better align cost recovery with program expenses, VO should
reassess its fees to ensure they better align with its costs.

VO is expected to receive approximately $1 billion

in TDT Funds from 2013 through the end of 2025

The distinction between TDT and Private Funds is an important issue in this report.
Florida law and the Agreement both restrict how TDT Funds can be spent. Private
Funds do not have such restrictions. Additionally, given the importance of tourism
to the County economy and community, it is essential that the TDT Funds collected
by the County are well spent.

In 2019, the County and VO entered into a long-term agreement to continue

providing funding to VO. In exchange, the Agreement requires VO, among other
things, to:

6 | Page
 Audit of Visit Orlando’s Compliance with the
INTRODUCTION 2019 Tourism Promotion Agreement

“… use its best commercially reasonable efforts to advertise, sell, promote,

and market the tourism attractions, accommodations and amenities … in
order to maintain and increase the numbers and quality of visitors,
conventions, trade shows and meetings in Orange County throughout the
term of this Agreement.”

The Board of County Commissioners (BCC) approved amendments in 2024

addressing provisions related to board appointments, funding levels, and the term
of the Agreement — extending it for four years. Additional modifications were made
in part based on an interim memorandum issued by our office during this audit. 2

Overall Evaluation

We have conducted an audit of Visit Orlando’s compliance with the 2019 Tourism
Promotion Agreement. We have identified violations of the current Agreement.
Additionally, we have found material concerns related to revenues and
expenditures of Tourist Development Tax Funds, which can be remedied by Visit
Orlando's actions and through an amendment to the Agreement. These violations
and material concerns are detailed in the recommendations section of the report.

2 Appendix C – Interim Memo and Response to Visit Orlando

7 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

1. Visit Orlando Incorrectly Classified and Deposited TDT Revenues as

Private Funds

Visit Orlando (VO) divides its revenue into two categories — Tourist Development
Tax Funds (TDT Funds) and Non-TDT Funds (Private Funds). The distinction is
that TDT Funds are subject to spending restrictions and other terms and conditions
based on the Agreement, including numerous accountability and transparency
requirements. TDT Funds are also subject to spending restrictions as mandated
by Florida law. Private Funds are not subject to these restrictions or requirements.

Agreement Requirements

In our prior audit, we found that VO was misclassifying certain expense

reimbursements paid with TDT Funds as Private Funds — instead of correctly
classifying those funds as TDT Funds. We recommended that VO correct this
practice, and VO agreed. As a result, the following section was added to the
Agreement:

“Visit Orlando will treat reimbursements from advertising partners for

cooperative marketing, promotional, and advertising opportunities (co-
ops) or similar arrangements, where the Tax was used to cover the cost
of the program as being subject to all restrictions and all requirements
of this Agreement applicable to Tax funds and will provide reporting for
these expenditures/reimbursements in a format acceptable to the
County.”

Visit Orlando Revenues Received

VO received $105 million from County TDT collections for 2023. 3 This was 92% of
VO’s total funding. In addition to County TDT payments, VO collected revenue
from other sources, including membership fees, cooperatives, participation fees,
advertising revenue, and interest earnings. In total, it collected about $8.98 million
from these other sources in 2023.

3 The County also provided VO $1 million for the Business Development Fund and $4 million for
the Sports Incentive Fund.

8 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

We categorized the $8,976,767 in other revenue as follows: 4

$3,869,025
Reimbursements of
TDT Expenses
$3,353,798
Revenue Not Related to TDT
Expenses
$757,844
Interest Earned
$996,100
Website/Newsletter Revenue

Below are some revenue sources where VO appears to have misclassified some
or all TDT revenues as Private revenues. As a result, TDT funds would not have
been spent transparently and may not have complied with the Agreement.

Other Revenue Owed to VO’s TDT Account

VO deposited the entire $8.98 million in its Private Funds bank account. Of that
amount, at least $3.54 million should have been reported and deposited as TDT
Funds — not Private Funds.

Further, it is unclear in the

Agreement whether an additional
$996,100 from website/newsletter
advertising should also have been
reimbursed to VO’s TDT Funds. If
so, the total amount due to TDT
Funds would increase to $4.54
million.

The following sections explain the issues with these revenue sources in more
detail.

4 Appendix D – Detailed List of Revenues

9 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

Cooperative Advertising

During our prior audit of VO, we identified approximately $2.8 million in TDT Funds
reimbursed to VO by its advertising partners. We found that VO incorrectly
classified these reimbursements as Private Funds, and VO concurred. The
Agreement was amended to address this audit issue as shown above.

During this audit, we noted that VO received similar reimbursements of $965,358

in 2023. Although VO deposited this money in its Private Funds bank account, VO
transferred $713,008 to the TDT account in March 2024 — shortly after the start
of our audit. VO never reimbursed the remaining $252,350. This amount
should be reimbursed to VO’s TDT Funds.

Participation Fees

VO collected $1,322,422 from its members to attend or sponsor trade shows, sales
events, and familiarization tours hosted by VO. These events included expenses
paid with both Private and TDT Funds. However, VO classified 100% of these
reimbursements as Private Funds — not TDT Funds.

The Agreement does not specifically define how these reimbursements should be
allocated. However, we calculated an allocation based on the percentage of
expenses paid from each funding source. Under that methodology, $608,263
should have been reimbursed to VO’s TDT Funds for 2023 participation fees.

One event
included in these
totals was the
2023
Tallahassee
Winter Mingle.
VO collected
$63,525 from its
members to
attend the event.
Event expenses totaled $76,344. VO paid $37,315 from its Private Funds and
$39,029 from its TDT Funds. However, VO classified the entire $63,525 collected
as Private Funds. Therefore, VO had surplus revenue of $26,210 from this event.

10 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

VO also misclassified the revenues it received from the 2023 IPW trade show.
Here, 19 members paid
VO $1,200 to $1,400
each for a 10x10 booth in
the “member village.”
These member fees
were all recorded as
Private Funds.

At the same time, VO

paid almost $12,000 per
booth in décor costs from
TDT Funds for each of
the 19 member booths.
VO’s reimbursements
should have been classified as TDT Funds — subject to public disclosure.

Miscellaneous TDT Reimbursements

We also identified miscellaneous revenues totaling $1,581,245. 5 We estimate that

$1,445,121 of these amounts were TDT expense reimbursements and should
be repaid to VO’s TDT Funds.

The bulk of this amount was an Employee Retention Tax Credit that VO received
from the IRS. Although approximately 94% of VO’s payroll expenses are paid with
TDT Funds, VO classified the entire payroll tax credit as Private Funds.

Interest Earnings

In 2023, VO earned $757,844 in interest from the following accounts:

• TDT Funds checking,
• Private Funds checking, and
• Two reserve accounts.

VO incorrectly recorded the full amount of interest as Private Funds. Based on the
account sources, $525,694 of the interest should have been allocated to TDT
Funds and deposited into the TDT bank account.

5 Appendix D – Detailed List of Revenues

11 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

Additionally, VO commingled TDT and Private Funds in one reserve account. As

of December 31, 2023, the account had a $15 million balance, composed of:

• $3,878,603 – TDT Funds deposit (January 2023)

• $3,878,603 – TDT Funds deposit (December 2022)
• $875,000 – Private Funds deposit (2014)
• $6,367,794 – Source of funds undetermined

VO has not provided documentation to evidence the source of the remaining

$6,367,794. TDT and Private Funds should be accounted for separately as
required by the Agreement. 6

Other Advertising Revenue Not Addressed in Agreement

VO received $996,100 in revenue from advertising on the VO website and digital

newsletters in 2023. VO used only TDT Funds to pay for the website and
newsletter. In 2023, it paid over $1 million from TDT Funds to maintain the website.
Although VO used its Membership staff — paid from Private Funds — to sell this
advertising, VO did not track and allocate their time to advertising sales. As a
result, an allocation between TDT Funds and Private Funds can’t be computed.

Management stated that revenues should only be allocated to TDT Funds for any
additional expenses incurred. However, management’s argument ignores the fact
that there would be nothing to sell (and no revenues) without the TDT Funds
invested in VO’s website. VO’s Agreement doesn’t specifically address this
situation. If the Agreement outlined revenue allocation based on direct/indirect
costs, it would be clear to all parties how these revenues should be allocated.

Other Revenue Reimbursements 2019 - 2022

As noted above, VO repaid a portion of the 2023 cooperative advertising

reimbursements shortly after our audit started. However, VO elected not to
reimburse more than $600,000 of 2022 cooperative advertising reimbursements
to the TDT bank account. According to management, VO didn’t reimburse those
funds because it used Private Funds for TDT-eligible expenses.

6 VO Agreement section 2.9 — Visit Orlando shall keep its accounting transactions in accordance
with accounting principles generally accepted in the United States (GAAP), and in detail sufficient
to segregate and account separately for its revenues and expenditures in accordance with the
provisions of this Agreement.

12 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

If VO offset reimbursements by paying TDT-eligible expenses from Private Funds,

TDT expenses were omitted from the public TDT disbursement listing. This would
be a violation of the Agreement and would undermine the transparency and
accountability of tax funds as required by the BCC through the Agreement.

Our audit only reviewed 2023 revenues in detail. The Agreement provision
requiring VO to treat reimbursements as TDT Funds has been in effect since 2019.
As a result, additional TDT reimbursements may be due for 2019-2022.

Recommendation No. 1

Visit Orlando should:

A) Reimburse TDT Funds for $3,436,243 of revenues generated from

TDT Funds. Payment should be made from its Private Funds to its
TDT bank account; 7
B) Perform a retrospective review of revenues received since 2019 to
identify additional TDT reimbursements that may have been
misclassified and deposited into its Private Funds;
C) In collaboration with County Administration, determine how the
undocumented reserve funds of $6,367,794 should be classified and
recommend its proposed plan to the Board of County
Commissioners for review and approval;
D) Develop and implement clear policies and procedures to ensure
accurate classification and reporting of revenue sources —
particularly for co-op revenues, interest income, and shared-cost
activities;
E) Deposit all revenues generated from TDT expenditures into its TDT
bank account promptly after receipt; and,
F) Evaluate participation fees charged to members to ensure that
revenues better align with costs.

7$3,544,436 minus $713,008 for 2023 cooperative advertising, plus $604,815 for 2022 cooperative
advertising.

13 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

As we have identified a material finding involving the inaccurate

classification of millions of dollars of TDT, County Administration should:

A) Consider invoking the “material concern” provision of the Agreement

to address and correct these issues with Visit Orlando. Remedies
include amending the Agreement to address ambiguities in the
contract related to revenue generated from programs and events
funded by TDT Funds; and,
B) Increase its oversight of Visit Orlando and require periodic revenue
reconciliations to ensure TDT Funds are managed in compliance
with all contractual requirements.

2. Return on Investment Analysis Was Not Performed to Determine if

TDT Funds Were Spent Appropriately

Analyzing Return on Investment (ROI) is critical for assessing expenditures,

comparing initiatives, and guiding resource allocation. 8 With limited funds and
unlimited marketing opportunities, VO should review marketing and promotion ROI
to determine which efforts are delivering value and which are not.

Event-Level ROI Analysis

VO’s internal expense reporting policy requires its staff to evaluate ROI for hosted
events and business travel exceeding $500 as part of a Summary Report. 9 VO’s
policy highlights ROI/return evaluation as a key component of event
documentation. However, management stated that costs are not included in the
Summary Reports. As a result, there is a gap between VO’s policy and actual
practice, as none of the Summary Reports reviewed included ROI calculations.
Specifically, we noted issues with each of the sampled event Summary Reports.

These issues included:

1. Familiarization Event: Showcased local hotels and attractions to 17

convention planners from one event management company.

8 ROI is typically calculated as: ROI = (Revenue – Costs) / Costs.

9 Appendix E – Excerpt of Visit Orlando’s Expense Policy

14 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

• Summary Report included estimated future revenue but failed to

include any associated costs. Therefore, ROI was impossible to
calculate.
• Revenue calculations included some events that were booked before
the familiarization event and should not have been considered
revenue generated from this event.

2. Canada Sales/Media Mission: Traveled to Canada to provide information

to travel agents and media on marketing Orlando as a destination.
• Summary Report included statistics — number of agents, room
nights, and published media content — but did not include any costs.
Therefore, ROI was impossible to calculate.

3. Florida Governor’s Conference on Tourism: Annual educational

conference for the Florida tourism industry.
• VO didn’t calculate costs or return. Therefore, ROI was impossible
to analyze.

Due to the consistent cost omissions, we did not review any other Summary
Reports. However, we identified several events where the ROI was unclear,
primarily due to their geographical location. One example is the Michelin Event
held in New York City, which was intended to promote tourism by showcasing a
Michelin-starred Orlando restaurant. 10

The event was marketed as featuring Capa, an Orlando restaurant. It was held at
The Musket Room in New York City and primarily featured dishes prepared by The
Musket Room’s chefs. This dinner, which hosted 40 guests, was paid for with TDT
Funds totaling $75,000 — $1,875 per guest. Given that the event was held out of
state and did not prominently feature the promoted Florida restaurant, we question
whether it delivered sufficient value in terms of promoting Orange County tourism.

ROI cannot be accurately calculated without including both return and cost
components. Otherwise, this could lead to investment in low-performing activities,
rather than prioritizing those with a demonstrably higher return on TDT Funds.

10 When Stars Align—Orlando's Capa Comes to New York's Musket Room

15 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

Agreement-Level ROI Analysis

The County has not conducted an independent ROI analysis of VO’s performance.
However, in response to discussions about potential TDT funding reductions, VO
commissioned a report to measure the total economic impact of its activities. This
report was presented to the BCC in November 2023. The report claimed a 33:1
ROI — every dollar provided to VO generated 33 dollars of economic activity.

Florida's Office of Economic & Demographic Research (EDR) conducted a similar

study in 2021 (covering 2016-2019) to measure the economic impact of Visit
Florida. EDR noted that multiple factors influence tourism demand — many
unrelated to marketing. ROI results can vary widely depending on assumptions
and inputs, especially when studies are commissioned by parties with a vested
interest.

It is unclear which factors were considered in the 33:1 calculation. An independent

analysis commissioned directly by the County is necessary to ensure an unbiased
evaluation of ROI. More importantly, this analysis would enable the BCC to better
understand the benefits, costs, and opportunity costs of its relationship with VO.

Recommendation No. 2
Visit Orlando should:

A) Revise its internal expense reporting policy to include a standardized

methodology for calculating ROI. The guidance should clearly define
required inputs (e.g., direct costs, attributable returns), appropriate
timeframes for measuring outcomes, and documentation standards.
This will help ensure consistency, accuracy, and transparency in ROI
reporting across all events and initiatives;
B) Provide additional training for employees on the requirement to
include both costs and the calculated ROI for each applicable event
or travel activity in Summary Reports, as stated in the current policy.
Reports lacking this information should be considered incomplete
and returned for revision; and,
C) Implement a review process to verify the accuracy of ROI/return
calculations, including validation of both cost and return components.

16 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

County Administration should periodically commission an independent

ROI assessment to evaluate the overall effectiveness of its tourism
promotion strategies and investments.

3. TDT Funds Were Used to Pay for Ineligible Expenses

VO is required to use TDT Funds for allowable uses under the Agreement and
Florida law. 11 Our review of a sample of TDT-funded expenditures identified
$379,780 in expenses that do not appear to promote tourism. Examples include:

• Local Events: We reviewed expenses from three luncheons VO hosted for

local attendees. 12 The events celebrated VO’s achievements while also
providing updates to members and guests on tourism-related travel trends,
economic forecasts, and performance metrics. For 2023, the total cost of
the three luncheons was more than $860,000. VO used $161,541 in TDT
Funds for audiovisual and décor costs for two of the 2023 events. VO
claimed these luncheons were intended to help members market
themselves to travel agents and tour operators. However, the event
agendas show there were no such opportunities. 13 Therefore, payments for
these events were not allowable uses of TDT Funds.
• Sustainability Strategy Contract: In 2023, VO signed a $427,700 multi-
year agreement (with $137,500 paid in 2023) to develop an environmental
sustainability plan. While this may be a good policy, it does not appear to
be an approved use of TDT Funds.
• Sky Boxes: VO spent $20,600 on two Kia Center sky boxes at the 2023
NCAA March Madness tournament. Only eight of the 48 attendees were
potential clients. The rest were VO staff, VO members, and elected officials.
As only eight clients attended, the second sky box does not appear
necessary for entertaining clients and should not have been paid for with
TDT Funds.

11 VO Agreement section 2.3

12 May Travel and Tourism Event, August Business Insights, and December Year-End Celebration
13 Appendix F – Example of Visit Orlando Luncheon Agenda

17 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

• Personal Item Purchases: VO used TDT Funds to purchase the following

items that had no demonstrated
connection to tourism promotion:
o Orange Vans sneakers
($1,821)
o Christmas sweaters and
card ($417)
o Tuxedo ($310)

• Executive Car Allowance: VO paid its CEO $12,210 from TDT Funds for
a car allowance. This was in addition to the executive’s other compensation.
The Agreement prohibits such executive benefits unless approved by VO’s
Board and disclosed to the County Administrator. VO could not provide
evidence of either.
• Trade Show Absence: VO paid $6,000 for an employee to attend a trade
show. However, the employee failed to attend, and VO did not send a
replacement. VO only received a $3,000 refund.
• Office Décor and Design: VO spent $6,505 of TDT Funds on architectural
design, a personal refrigerator for its COO’s office, and posters and window
clings for non-client-facing areas — none of which promote tourism.
VO’s use of TDT Funds for these expenditures violates the terms of the
Agreement, as they do not appear to directly support County tourism promotion.

Recommendation No. 3

Visit Orlando should strengthen its oversight processes to ensure that all
TDT expenditures strictly comply with the terms of the Agreement and
Florida law. Specifically, Visit Orlando should:

A) Implement a formal review process for all TDT expenditures to

ensure they are allowable uses under the Agreement;
B) Conduct periodic training for its finance and program staff on
allowable TDT Fund uses to ensure compliance with the
Agreement’s spending restrictions; and,

18 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

C) Repay $341,911 in unallowable TDT expenditures identified in this

audit. Payment should be made from its Private Funds to its TDT
bank account. 14

4. Orange County Should Enhance Contract Monitoring and

Enforcement

Effective Agreement monitoring is essential to ensure both parties fulfill their

obligations. VO has received more than $100 million in TDT Funds every year
since 2022. This amount has regularly increased. This Agreement is the
County’s largest annual TDT commitment and warrants ongoing oversight.

The Agreement details VO’s responsibilities to the

County, including various reports and documents
that VO must provide. However, no County
employee or department is currently responsible for
monitoring VO’s Agreement compliance or
overseeing overall performance. This lack of
monitoring has led to several instances where VO
has failed to meet contractual requirements that the
County did not identify. For example:

• The Agreement requires VO to submit a program-area based budget, in

sufficient detail to separately identify the receipt and expenditure of all
TDT Funds by August 1st. VO did not provide a 2023 budget. The 2023
expense budget on VO’s website totaled $72.5 million, yet the financial
statements reflected actual expenditures of $121 million — an overage
of $48.5 million, representing a 67% variance. The Agreement does not
require VO to submit budget amendments or provide explanations for
variances. This results in a lack of accountability for spending overages.

• The Agreement requires VO to submit an annual marketing plan and

budget (the "Work Plan") to the Orange County Convention Center
(OCCC) for approval. Any unused funds are to be rolled over to the next
year. However, we reviewed Work Plans from 2021 to 2024 and found
that none included a budget. OCCC management confirmed that it did

14 $37,869 was transferred to TDT in 2024 as a result of this audit.

19 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

not receive a budget for these years. Without a complete Work Plan,
OCCC cannot ensure that VO’s spending aligns with its priorities or
verify that unused funds were carried over properly.

• VO is required to submit a monthly TDT disbursement report to the

Comptroller’s Office. The report is then published on the Comptroller’s
website. However, we compared the 2023 disbursement reports to VO’s
2023 banking transactions and found unreported disbursements totaling
over $6 million, mostly related to Business Development Fund and
Sports Incentive Fund accounts.

• The Agreement requires VO to submit copies of all contracts utilizing

TDT Funds so that they can be posted on the Comptroller’s website. We
reviewed a sample of 38 VO contracts in effect in 2023 and found that
nine contracts were not submitted. Submitting these contracts is crucial
for ensuring public transparency in how TDT Funds are spent.

Strong monitoring is essential to ensure that VO complies with the Agreement. It

will also proactively identify potential issues to be addressed in future amendments
and provide opportunities to maximize the value that the County receives from its
investment in VO.

Recommendation No. 4

County Administration should:

A) Designate an individual responsible for overseeing Visit Orlando’s

performance under the Agreement. This individual should track
compliance with all contractual requirements, including the timely
submission of reports, budgets, and other documents, and promptly
address any issues; and,
B) Develop monitoring procedures for the employee(s) assigned this
responsibility.

Visit Orlando should submit a complete marketing plan and budget (the
"Work Plan") to the Orange County Convention Center for approval, as
required by the Agreement. This should include a clear budget to allow
OCCC to evaluate whether funds are aligned with its priorities and ensure
that unused funds are carried over as stipulated.

20 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

5. Inappropriate Use of TDT Funds for Member-Related Overhead Costs

In addition to promoting County tourism, VO provides membership services to over

1,600 members from various sectors of Central Florida’s tourism industry. While
membership benefits differ by industry, VO generally provides its members with
opportunities for networking, education, and consumer exposure. In exchange, VO
collects membership and participation fees, including event-related payments.

VO’s Membership group is dedicated to managing these member relationships. Its

key responsibilities include:

• Recruitment and Retention: Bringing in new members and ensuring

current members find value in their membership.

• Engagement and Support: Helping members make the most of VO’s

marketing and sales platforms.

• Events and Networking: Hosting events and educational opportunities to

foster collaboration within the tourism community.

• Account Management: Serving as the primary point of contact for

members.

Per the Agreement, using TDT Funds to support member-related activities is

limited to:

1. Assisting members in marketing themselves to tour operators and travel

agencies.
2. Paying for trade shows costs over and above member contributions.

Accordingly, VO uses Private Funds to cover direct expenses related to its

Membership group. However, VO management reported that it does not allocate
any portion of overhead expenses to Private Funds — even when those costs
support member-related functions. Instead, all overhead costs are paid with TDT
Funds. Examples of 2023 TDT-funded overhead expenditures include:

21 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

• $1.19 million for rent, utilities, and commercial insurance — expenses that
also support the Membership group.

• $5.5 million in salaries and benefits for

administrative support staff (e.g.,
Finance, HR, and IT) that serve the
entire organization, including the
Membership group.

• $164,826 in compensation for the

Senior Vice President of Membership
and Support Services, who oversees
the Membership group and other
client-related departments.

By failing to allocate any overhead costs to Private Funds, VO is improperly using

TDT Funds to support member-related activities — contrary to the terms of the
Agreement.

Recommendation No. 5

Visit Orlando should develop and implement a cost allocation

methodology to ensure that overhead expenses benefiting member-related
activities are appropriately charged to Private Funds, rather than to TDT
Funds. This methodology should:

A) Identify shared overhead costs (e.g., rent, administrative salaries,

utilities) that support both TDT-funded and member-related
functions; and,
B) Allocate those costs proportionally based on reasonable and
supportable criteria, such as staff time, square footage usage, or
departmental budgets.

County Administration should consider invoking the “material concern”

provision of the Agreement to address and correct these issues with Visit
Orlando. Remedies could include amending the Agreement to address the
allocation of overhead expenses and clearly outlining how overhead
expenses should be allocated. Additionally, the County should periodically
review Visit Orlando’s cost allocation practices to ensure continued
adherence to TDT spending restrictions.

22 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

6. Visit Orlando Engaged in Lobbying Activities Without Board of County

Commissioners Approval

The Agreement explicitly prohibits VO from engaging in state legislative lobbying

activities without prior approval from the BCC.

Our review of VO’s website identified instances where

VO staff engaged in activities that appear to be
lobbying without BCC approval. For example, in March
2023, VO CEO, Casandra Matej, “joined a statewide
delegation of colleagues to speak on behalf of our
industry… Through appointments with key legislators,
we discussed high-priority issues and bills that would
impact the allocation of county-based Tourist
Development Taxes and the future of VISIT
FLORIDA.” Although County Administration was
aware of these lobbying activities, the BCC did not approve these activities as
required by the Agreement.

According to Florida Statute 11.045(1)(e), “Lobbying means influencing or

attempting to influence legislative action or nonaction through oral or written
communication or an attempt to obtain the goodwill of a member or employee of
the Legislature.” According to VO, its meetings with legislators were educational in
nature and did not constitute lobbying. However, educational meetings could easily
influence legislative decisions. In short, education could easily be confused with
lobbying. Engaging in lobbying without BCC authorization is prohibited and may
conflict with the County’s legislative priorities.

Recommendation No. 6

Visit Orlando should obtain BCC approval before discussing potential

legislative matters with state legislators that could be perceived as lobbying.

23 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

7. Visit Orlando Did Not Comply with Its Procurement Policies

The Agreement requires VO to adopt procurement

policies that encourage competitive bidding and
requests for proposals (RFPs). It also requires VO to
comply with policies that support local businesses,
where practicable. We reviewed VO’s Procurement
Policy and Procedures (Procurement Policy). The
Procurement Policy details the following specific
competitive procurement requirements: 15

If the Purchase is Between: Documentation Required:

$0 - $10,000 Purchase Order

Purchase Order, three (3) bids, and Summary
$10,001 - $50,000
Memo
Purchase Order, three (3) bids, and Summary
$50,001 - $100,000
Memo; or RFQ and Summary Memo
$100,001 - $200,000 RFQ or RFP and Summary Memo
> $200,000 RFP and Summary Memo

We tested a sample of 42 purchases that met the criteria for competitive pricing.
We found that 14 of the 42 purchases (33%) did not comply with the
Procurement Policy. Key issues identified include:

• Outdated RFP: Four vendors with total purchases ranging from $400,000
to $3.7 million have not been subject to an RFP process since 2019 or
earlier — one goes back to 2014. The Procurement Policy permits an RFP
exemption only if services were competitively procured within the past 24
months and conditions remain unchanged. A nine-year gap significantly
exceeds the policy.
• Improper Sole Source Justification: VO classified eight purchases —
totaling over $1 million — as sole source procurements. However, based
on the nature of the goods and services, we found insufficient justification
to exempt these from competitive bidding.

15 Although the Procurement Policy was revised in April 2023, we evaluated purchases according
to the new policy requirements.

24 | Page
RECOMMENDATIONS Audit of Visit Orlando’s Compliance with the
FOR IMPROVEMENT 2019 Tourism Promotion Agreement

• Recurring Purchases Should Have an RFP: Two sets of purchases

totaling $200,139 (47 checks) and $158,289 (44 checks) were not
competitively bid. VO claimed the individual amounts were too small to
trigger RFP requirements. However, the policy clearly requires an RFP for
goods or services with annual or aggregate spending over $100,000 in
a two-year period. These purchases exceeded that limit.

Additionally, the Procurement Policy requires staff to document the selection

process for each vendor on a Summary Memo for all purchases. Nineteen of the
42 purchases had no Summary Memo.

Without a competitive process, there is limited pricing pressure, which may result
in overpaying for goods or services. Non-competitive procurement can also create
the appearance of favoritism, bias, or conflicts of interest. This undermines
confidence in the procurement process and impairs effective oversight.

Recommendation No. 7
Visit Orlando should:

A) Re-communicate the Procurement Policy to all relevant staff, with

emphasis on key thresholds, documentation requirements, and the
consequences of noncompliance; and,
B) Conduct mandatory training sessions for all employees and
reviewers involved in procurement, focusing on Procurement Policy
requirements and proper procedures.

25 | Page
SCOPE, OBJECTIVES, Audit of Visit Orlando’s Compliance with the
AND METHODOLOGY 2019 Tourism Promotion Agreement

Audit Scope

The audit scope was limited to Visit Orlando’s revenues and expenditures. The
audit period was from January 2023 to December 2023.

Audit Objective

The objective of the audit was to determine whether VO complied with the 2019
Tourism Promotion Agreement.

Audit Methodology

To meet the audit objectives, we performed the following testing: 16

• Compared listings of TDT disbursements provided to the County
Comptroller to VO’s TDT bank statements to determine if the listings were
complete.
• Reviewed procedures for check distributions to determine if controls were
adequately designed.
• Analyzed VO’s bank statements and general ledger entries to verify whether
all deposits were recorded in VO’s financial system.
• Reviewed a sample of revenue journal entries to determine if they were
generated from TDT Funds and appropriately accounted for as
reimbursements of TDT Funds.
• Reviewed a sample of Meetings & Convention Sales and Marketing
(MCSM) Funds expense transactions to determine if each was an allowable
use of MCSM Funds.
• Analyzed the MCSM budget for calendar years 2020 to 2023 to determine
the effect of not requiring a minimum budget amount.
• For a sample of travel and entertainment expenses, determined if each item
complied with both the Agreement and VO’s Expense Policy and Reporting
Procedures.
• For a sample of procurements, performed the following:

16 As the samples used were non-statistical, results were not extrapolated to the entire population.

26 | Page
SCOPE, OBJECTIVES, Audit of Visit Orlando’s Compliance with the
AND METHODOLOGY 2019 Tourism Promotion Agreement

o Verified whether a competitive procurement process was used as

stipulated under VO’s Procurement Policy.
o Determined if each procurement was supported by documentation
as required under VO’s Procurement Policy.
o If contracts were executed, determined if the contract was provided
to the Comptroller for posting to the Comptroller’s website.
• Verified whether membership-related expenses were appropriately paid for
with only Private Funds.
• Reviewed both the County’s and the State of Florida’s lobbyist websites, as
well as VO’s corporate blog for evidence of VO engaging in lobbying
activities.
• For a sample of transactions paid with TDT Funds, reviewed supporting
documentation to determine if the associated costs were for activities
allowed under the Agreement.
• For a sample of projects, reviewed VO’s calculation of the return on
investment.

27 | Page
 Audit of Visit Orlando’s Compliance with the
ACTION PLAN 2019 Tourism Promotion Agreement

VISIT ORLANDO ACTION PLAN

MANAGEMENT’S RESPONSE
NO. RECOMMENDATIONS PARTIALLY DO NOT
CONCUR
CONCUR CONCUR
1. Visit Orlando should:
A) Reimburse TDT Funds for $3,436,243 of revenues
generated from TDT Funds. Payment should be
made from its Private Funds to its TDT bank 
account;
B) Perform a retrospective review of revenues received
since 2019 to identify additional TDT
reimbursements that may have been misclassified 
and deposited into its Private Funds;
C) In collaboration with County Administration,
determine how the undocumented reserve funds of
$6,367,794 should be classified and recommend its 
proposed plan to the Board of County
Commissioners for review and approval;
D) Develop and implement clear policies and
procedures to ensure accurate classification and
reporting of revenue sources — particularly for co- 
op revenues, interest income, and shared-cost
activities;
E) Deposit all revenues generated from TDT
expenditures into its TDT bank account promptly 
after receipt; and,
F) Evaluate participation fees charged to members to
ensure that revenues better align with costs. 
2. Visit Orlando should:
A) Revise its internal expense reporting policy to
include a standardized methodology for calculating
ROI. The guidance should clearly define required
inputs (e.g., direct costs, attributable returns),
appropriate timeframes for measuring outcomes, 
and documentation standards. This will help ensure
consistency, accuracy, and transparency in ROI
reporting across all events and initiatives;
B) Provide additional training for employees on the
requirement to include both costs and the calculated
ROI for each applicable event or travel activity in 
Summary Reports, as stated in the current policy.
Reports lacking this information should be

28 | Page
 Audit of Visit Orlando’s Compliance with the
ACTION PLAN 2019 Tourism Promotion Agreement

VISIT ORLANDO ACTION PLAN

MANAGEMENT’S RESPONSE
NO. RECOMMENDATIONS PARTIALLY DO NOT
CONCUR
CONCUR CONCUR
considered incomplete and returned for revision;
and,
C) Implement a review process to verify the accuracy of
ROI/return calculations, including validation of both 
cost and return components.
3. Visit Orlando should strengthen its oversight
processes to ensure that all TDT expenditures
strictly comply with the terms of the Agreement and
Florida law. Specifically, Visit Orlando should:
A) Implement a formal review process for all TDT
expenditures to ensure they are allowable uses 
under the Agreement;
B) Conduct periodic training for its finance and program
staff on allowable TDT Fund uses to ensure
compliance with the Agreement’s spending 
restrictions; and,
C) Repay $341,911 in unallowable TDT expenditures
identified in this audit. Payment should be made 
from its Private Funds to its TDT bank account.
4. Visit Orlando should submit a complete marketing
plan and budget (the "Work Plan") to the Orange
County Convention Center for approval, as required
by the Agreement. This should include a clear 
budget to allow OCCC to evaluate whether funds are
aligned with its priorities and ensure that unused
funds are carried over as stipulated.
5. Visit Orlando should develop and implement a cost
allocation methodology to ensure that overhead
expenses benefiting member-related activities are
appropriately charged to Private Funds, rather than
to TDT Funds. This methodology should:
A) Identify shared overhead costs (e.g., rent,
administrative salaries, utilities) that support both 
TDT-funded and member-related functions; and,
B) Allocate those costs proportionally based on
reasonable and supportable criteria, such as staff
time, square footage usage, or departmental 
budgets.

29 | Page
 Audit of Visit Orlando’s Compliance with the
ACTION PLAN 2019 Tourism Promotion Agreement

VISIT ORLANDO ACTION PLAN

MANAGEMENT’S RESPONSE
NO. RECOMMENDATIONS PARTIALLY DO NOT
CONCUR
CONCUR CONCUR
6. Visit Orlando should obtain BCC approval before
discussing potential legislative matters with state 
legislators that could be perceived as lobbying.
7. Visit Orlando should:
A) Re-communicate the Procurement Policy to all
relevant staff, with emphasis on key thresholds,
documentation requirements, and the 
consequences of noncompliance; and,
B) Conduct mandatory training sessions for all
employees and reviewers involved in procurement,
focusing on Procurement Policy requirements and 
proper procedures.

30 | Page
 Audit of Visit Orlando’s Compliance with the
ACTION PLAN 2019 Tourism Promotion Agreement

COUNTY ADMINISTRATION ACTION PLAN

MANAGEMENT’S RESPONSE
NO. RECOMMENDATIONS PARTIALLY DO NOT
CONCUR
CONCUR CONCUR
1. As we have identified a material finding involving the
inaccurate classification of millions of dollars of TDT,
County Administration should:
A) Consider invoking the “material concern” provision of
the Agreement to address and correct these issues
with Visit Orlando. Remedies include amending the
Agreement to address ambiguities in the contract 
related to revenue generated from programs and
events funded by TDT Funds; and,
B) Increase its oversight of Visit Orlando and require
periodic revenue reconciliations to ensure TDT
Funds are managed in compliance with all 
contractual requirements.
2. County Administration should periodically
commission an independent ROI assessment to
evaluate the overall effectiveness of its tourism 
promotion strategies and investments.
4. County Administration should:
A) Designate an individual responsible for overseeing
Visit Orlando’s performance under the Agreement.
This individual should track compliance with all
contractual requirements, including the timely 
submission of reports, budgets, and other
documents, and promptly address any issues; and,
B) Develop monitoring procedures for the employee(s)
assigned this responsibility. 
5. County Administration should consider invoking
the “material concern” provision of the Agreement to
address and correct these issues with Visit Orlando.
Remedies could include amending the Agreement to
address the allocation of overhead expenses and
clearly outlining how overhead expenses should be 
allocated. Additionally, the County should
periodically review Visit Orlando’s cost allocation
practices to ensure continued adherence to TDT
spending restrictions.

31 | Page
APPENDIX A –
VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

32 | Page
APPENDIX A –
VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

33 | Page
APPENDIX A –
VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

34 | Page
APPENDIX A –
VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

35 | Page
APPENDIX A –
VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

36 | Page
APPENDIX A –
VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

37 | Page
APPENDIX A –
VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

38 | Page
APPENDIX A –
VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

39 | Page
APPENDIX A –
VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

40 | Page
APPENDIX A –
VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

41 | Page
APPENDIX A –
VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

42 | Page
APPENDIX B –
COUNTY ADMINISTRATION’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

43 | Page
APPENDIX B –
COUNTY ADMINISTRATION’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

44 | Page
APPENDIX B –
COUNTY ADMINISTRATION’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

45 | Page
APPENDIX B –
COUNTY ADMINISTRATION’S Audit of Visit Orlando’s Compliance with the
MANAGEMENT RESPONSE 2019 Tourism Promotion Agreement

46 | Page
APPENDIX C – INTERIM MEMO
AND RESPONSE TO Audit of Visit Orlando’s Compliance with the
VISIT ORLANDO 2019 Tourism Promotion Agreement

47 | Page
APPENDIX C – INTERIM MEMO
AND RESPONSE TO Audit of Visit Orlando’s Compliance with the
VISIT ORLANDO 2019 Tourism Promotion Agreement

48 | Page
APPENDIX C – INTERIM MEMO
AND RESPONSE TO Audit of Visit Orlando’s Compliance with the
VISIT ORLANDO 2019 Tourism Promotion Agreement

49 | Page
APPENDIX C – INTERIM MEMO
AND RESPONSE TO Audit of Visit Orlando’s Compliance with the
VISIT ORLANDO 2019 Tourism Promotion Agreement

50 | Page
APPENDIX C – INTERIM MEMO
AND RESPONSE TO Audit of Visit Orlando’s Compliance with the
VISIT ORLANDO 2019 Tourism Promotion Agreement

51 | Page
APPENDIX C – INTERIM MEMO
AND RESPONSE TO Audit of Visit Orlando’s Compliance with the
VISIT ORLANDO 2019 Tourism Promotion Agreement

52 | Page
APPENDIX C – INTERIM MEMO
AND RESPONSE TO Audit of Visit Orlando’s Compliance with the
VISIT ORLANDO 2019 Tourism Promotion Agreement

53 | Page
APPENDIX C – INTERIM MEMO
AND RESPONSE TO Audit of Visit Orlando’s Compliance with the
VISIT ORLANDO 2019 Tourism Promotion Agreement

54 | Page
APPENDIX C – INTERIM MEMO
AND RESPONSE TO Audit of Visit Orlando’s Compliance with the
VISIT ORLANDO 2019 Tourism Promotion Agreement

55 | Page
APPENDIX D – Audit of Visit Orlando’s Compliance with the
DETAILED LIST OF REVENUES 2019 Tourism Promotion Agreement

TDT Private Revenue

2023 Revenue
Revenue Description Expense Expense Due to TDT
Collected by VO
Allocation Allocation Funds
Reimbursement of Expenses Paid with TDT

Advertising and
$965,358 100% 0% $965,358 17
Marketing Cooperatives
Tourism Economics
$35,000 100% 0% $35,000
Report
Employee Retention
$1,490,122 93.70% 6.30% $1,396,584
Credit

Credit Card Rebate $56,123 24.10% 75.90% $13,537

Participation Fees from
$1,322,422 46% 54% $608,263
Members
Subtotal $3,869,025 $3,018,742

Revenues with Expenses Fully Paid with Private Funds

Membership Dues $3,121,228 0% 100% $0

Membership Events $215,007 0% 100% $0

Other Revenues $17,563 0% 100% $0

Subtotal $3,353,798 $0

Interest Revenue
Not Not
Interest Revenue $757,844 $525,694
Applicable Applicable
Revenue Not Addressed in Agreement

Other Advertising Not Not

$996,100.00 $0
Revenue Determined Determined

2023 Total Revenue $8,976,767 $3,544,436

17 VO refunded $713,008 to the TDT account in 2024

56 | Page
APPENDIX E – EXCERPT
OF VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
EXPENSE POLICY 2019 Tourism Promotion Agreement

57 | Page
APPENDIX E – EXCERPT
OF VISIT ORLANDO’S Audit of Visit Orlando’s Compliance with the
EXPENSE POLICY 2019 Tourism Promotion Agreement

58 | Page
APPENDIX F –
VISIT ORLANDO EXAMPLE Audit of Visit Orlando’s Compliance with the
LUNCHEON AGENDA 2019 Tourism Promotion Agreement

59 | Page
APPENDIX F –
VISIT ORLANDO EXAMPLE Audit of Visit Orlando’s Compliance with the
LUNCHEON AGENDA 2019 Tourism Promotion Agreement

60 | Page
APPENDIX F –
VISIT ORLANDO EXAMPLE Audit of Visit Orlando’s Compliance with the
LUNCHEON AGENDA 2019 Tourism Promotion Agreement

61 | Page
APPENDIX F –
VISIT ORLANDO EXAMPLE Audit of Visit Orlando’s Compliance with the
LUNCHEON AGENDA 2019 Tourism Promotion Agreement

62 | Page
APPENDIX F –
VISIT ORLANDO EXAMPLE Audit of Visit Orlando’s Compliance with the
LUNCHEON AGENDA 2019 Tourism Promotion Agreement

63 | Page