Turnbull Creek Community Development District

ANNUAL FINANCIAL REPORT

September 30, 2021

Turnbull Creek Community Development District ANNUAL FINANCIAL REPORT
September 30, 2021 TABLE OF CONTENTS
Page Number

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
Notes to Financial Statements	16-27
INDEPENDENT AUDITORS’ 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	28-29
MANAGEMENT LETTER	30-33
INDEPENDENT ACCOUNTANTS’ REPORT/COMPLIANCE WITH
SECTION 218.415, FLORIDA STATUTES	34

REPORT OF INDEPENDENT AUDITORS

To the Board of Supervisors
Turnbull Creek Community Development District St. Johns County, Florida

Report on the Financial Statements

We have audited the accompanying financial statements of Turnbull Creek Community Development District as of and for the year ended September 30, 2021, 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 audit. We conducted our audit 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.

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To the Board of Supervisors
Turnbull Creek 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 Turnbull Creek Community Development District, as of September 30, 2021, 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

In accordance with Government Auditing Standards, we have also issued a report dated June 29, 2022 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 Turnbull Creek Community Development District’s internal control over financial reporting and compliance.

Berger, Toombs, Elam, Gaines & Frank Certified Public Accountants PL
Fort Pierce, Florida June 29, 2022

- 2 -

Management’s discussion and analysis of Turnbull Creek 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 private-sector companies. 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. 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 financed by the District include general government, physical environment, culture and recreation, and debt service.

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. 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.

The government-wide financial statements and the fund financial statements provide different pictures of the District. The government-wide financial statements provide an overall picture of the District’s financial standing. These statements are comparable to private-sector companies and give a good understanding of the District’s overall financial health and how the District paid for the various activities, or functions, provided by the District. All assets of the District, including capital assets, are reported in the statement of net position. All liabilities, including principal outstanding on bonds are included. In the statement of activities, transactions between the different functions of the District have been eliminated in order to avoid “doubling up” the revenues and expenses. The fund financial statements provide a picture of the major funds of the District. In the case of governmental activities, outlays for long lived assets are reported as expenditures and long-term liabilities, such as general obligation bonds, are not included in the fund financial statements. To provide a link from the fund financial statements to the government-wide financial statements, reconciliation is provided from the fund financial statements to the government-wide financial statements.

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, 2021.

The District’s total liabilities exceeded total assets by $(1,950,104) (net position). Net investment in capital assets was $(2,849,030), restricted net position was $109,373 and unrestricted net position was $789,553.

Governmental activities revenues totaled $2,529,081 while governmental activities expenses totaled $2,101,398.

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 and is presented by category for comparison purposes.

Net Position

Governmental Activities 2021	2020

Current assets	$	859,917	$	686,825	
Restricted assets	986,857	1,004,028	
Capital assets		11,188,521 		11,627,650 	
Total Assets		13,035,295 		13,318,503 	

Current liabilities	
1,049,648	
994,076	
Non-current liabilities		13,935,751 		14,702,214 	
Total Liabilities		14,985,399 		15,696,290 	

Net investment in capital assets	
(2,849,030)	
(3,150,219)	
Restricted net postion	109,373	107,172	
Unrestricted net position		789,553 		665,260 	
Total Net Position	 $ (1,950,104)	 $  (2,377,787)	

The increase in current assets is related to the increase in cash in the current year. The decrease in capital assets is mainly related to current year depreciation.
The increase in net position is the result of revenues in excess of expenses in the current year.

The decrease in non-current liabilities is related to the principal payments made 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 and is presented by category for comparison purposes.

Change In Net Position

	Governmental Activities	
		2021			2020		
Program Revenues Charges for services	
$	2,509,048	
$	2,529,362	
Investment earnings	372	11,409	
Miscellaneous revenues		19,661 		12,070 	

General government	175,189	168,293	
Physical environment	576,514	577,452	
Culture/recreation	723,309	702,959	
Interest and other charges		626,386 		647,840 	
Total Expenses		2,101,398 		2,096,544 	
Change in Net Position	427,683	456,297	
Net Position - Beginning of Year		(2,377,787)		(2,834,084)	
Net Position - End of Year	 $ (1,950,104)	$ (2,377,787)	

Total Revenues		2,529,081 		2,552,841  Expenses

The increase in culture/recreation is mainly the result of the increase in repairs in the current year.

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, 2021 and 2020.

Governmental Activities
	2021		2020	

Land and improvements	
$	3,846,133		
$	3,846,133	
Infrastructure	5,052,657		5,052,657	
Buildings	8,344,455		8,337,572	
Equipment	19,046		7,100	
Less: accumulated depreciation		(6,073,770)			(5,615,812)	
Capital Assets, net	 $ 11,188,521 		 $ 11,627,650 	

Current year activity consisted of additions to equipment of $11,946, and buildings of $6,883, and depreciation of $457,958.

General Fund Budgetary Highlights

Budgeted expenditures exceeded actual expenditures primarily due to less landscape maintenance, pool monitoring and legal expenditures incurred in the current year than were anticipated.

The September 30, 2021 budget was amended for additional repairs and engineering cost, not anticipated in the original budget.

Debt Management

Governmental Activities debt includes the following:

In March 2015, the District issued $13,375,000 Special Assessment Refunding Bonds, Series 2015A and $1,280,000 Special Assessment Bonds, Series 2015B. The Bonds were issued to provide funds to refund and redeem the Special Assessment Bonds, Series 2005 and to finance the Phase 1 - Pond Bank Reconstruction Project. The balance outstanding at September 30, 2021 for the Series 2015A Bonds was
$10,180,000 and the Series 2015B Bonds was $1,110,000.

OVERVIEW OF THE FINANCIAL STATEMENTS (CONTINUED)

Debt Management (Continued)

In April 2016, the District issued $4,196,000 Special Assessment Refunding Bonds, Series 2016. The Bonds were issued to refund and redeem the outstanding Special Assessment Bonds, Series 2006 and retire the deferred costs. The balance outstanding at September 30, 2021 was $3,438,000.

Economic Factors and Next Year’s

The District does not expect any economic factors to have a significant effect on the financial position or results of operations of the District in fiscal year 2022.

Request for Information

The financial report is designed to provide a general overview of Turnbull Creek 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 Turnbull Creek Community Development District’s Accounting Department at 3434 Colwell Avenue, Suite 200, Tampa, Florida, 33614.

STATEMENT OF NET POSITION
September 30, 2021

ASSETS	
Current Assets	
Cash	
Investments	
Due from other governments	
Due from other	
Prepaid expenses	
Total Current Assets	
Non-Current Assets	
Restricted Assets	
Investments	
Capital Assets, Not Being Depreciated	
Land and improvements	
Capital Assets, Being Depreciated	
Infrastucture	
Buildings	
Equipment	
Less: accumulated depreciation	
Total Non-Current Assets	
Total Assets	

LIABILITIES	
Current Liabilities	
Accounts payable	
Bonds payable, current	
Accrued interest	
Total Current Liabilities	
Non-Current Liabilities	
Bonds payable, net	
Total Liabilities	

NET POSITION	
Net investment in capital assets	
Restricted for debt service	
Restricted for capital projects	
Unrestricted	
Total Net Position	

See accompanying notes to financial statements.

Governmental Activities

$	542,323	
266,594	
23,429	
19	
	27,552 	
	859,917 	

986,857

3,846,133

5,052,657	
8,344,455	
19,046	
     (6,073,770)	
     12,175,378 	
     13,035,295 	

57,585	
740,000	
       252,063 	
      1,049,648 	

	13,935,751 
	14,985,399 

(2,849,030)	
106,629	
2,744	
	789,553 	
 $	(1,950,104)	

STATEMENT OF ACTIVITIES
For the Year Ended September 30, 2021

		Net (Expense)	
		Revenues and	
Program		Changes in	
Revenues		Net Position	
Charges for		Governmental	
Services		Activities	

Functions/Programs	Expenses

$	(175,189)	
(576,514)	
(723,309)	
	(626,386)	
 $	(2,101,398)	

$	200,114	$	
441,308	(	
499,060	(	
	1,368,566  		
 $	2,509,048 	

Governmental Activities General government Physical environment Culture/recreation
Interest and other charges
Total Governmental Activities

General Revenues	
Investment earnings	
Miscellaneous revenues	
Total General Revenues	

24,925
135,206)
224,249)
742,180 
407,650

372
	19,661 
	20,033 

Change in Net Position	427,683	
Net Position - October 1, 2020		(2,377,787)	
Net Position - September 30, 2021	 $	(1,950,104)	

See accompanying notes to financial statements.

Turnbull Creek Community Development District BALANCE SHEET -
GOVERNMENTAL FUNDS
September 30, 2021

Total Governmental

ASSETS	
Cash	
Investments	
Due from other funds	
Due from other governments	
Due from other	
Prepaid expenses	
Restricted assets	
Cash and investments, at fair value	
Total Assets	

	General	  Debt Service   Capital Projects 	Funds	

$	170,890	
266,594	
-	
13,359	
19	
27,552	

$	-	
-	
2,709	
10,070	
-	
-	

$	371,433	
-	
-	
-	
-	
-	

$	542,323	
266,594	
2,709	
23,429	
19	
27,552	

	986,857 	
 $	1,849,483 	

	-  	984,113  	2,744 

LIABILITIES AND FUND BALANCES

 $	478,414 

 $	996,892 

 $	374,177 

LIABILITIES	
Accounts payable	
Due to other funds	
Total Liabilities	

$	57,585	$	-	$	-	$	57,585
	2,709  	-  	-  	2,709 
	60,294  	-  	-  	60,294 

FUND BALANCES	
Nonspendable:	
Prepaid expenses	
Restricted:	
Debt service	
Capital projects	
Assigned - capital projects	
Unassigned	
Total Fund Balances	
Total Liabilities and Fund Balances	

27,552	-	-	27,552

-		996,892		-		996,892	
-		-		2,744		2,744	
-		-		371,433		371,433	
390,568		-		-		390,568	
	418,120 			996,892 			374,177 			1,789,189 	
 $	478,414 		 $	996,892 		 $	374,177 		 $	1,849,483 	

See accompanying notes to financial statements.

Turnbull Creek Community Development District RECONCILIATION OF TOTAL GOVERNMENTAL FUND BALANCES TO NET POSITION OF GOVERNMENTAL ACTIVITIES
September 30, 2021

Total Governmental Fund Balances

Amounts reported for governmental activities in the Statement of Net Position	
are different because:	

Capital assets, land and improvements, $3,846,133, infrastructure	
$5,052,657, buildings, $8,344,455, and equipment, $19,046, net of	
accumulated depreciation, $(6,073,770), used in governmental activities	
are not current financial resources and therefore, are not reported	
at the fund level.	

Long-term liabilities, including bonds payable, $(14,728,000), and bond	
discount, $52,249, are not due and payable in the current period	
and therefore, are not reported at the governmental fund level.	

$	1,789,189

11,188,521

(14,675,751)

Accrued interest expense for long-term debt is not a current financial use	
and therefore, is not reported at the governmental fund level.	

	(252,063)

Net Position of Governmental Activities	 $ (1,950,104)

See accompanying notes to financial statements.

Turnbull Creek Community Development District STATEMENT OF REVENUES, EXPENDITURES AND CHANGES
IN FUND BALANCES – GOVERNMENTAL FUNDS
For the Year Ended September 30, 2021

Total Governmental

Revenues	
Special assessments	
Investment earnings	
Miscellaneous revenues	
Total Revenues	

$1,140,482		
$ 1,368,566		
$	-		
$	2,509,048	
33		338		1		372	
19,661		-		-		19,661	
1,160,176		1,368,904		1		2,529,081	

Expenditures	
Current	
General government	
Physical environment	
Culture/recreation	
Capital outlay	
Debt service	
Principal	
Interest	
Other	
Total Expenditures	

174,969	
385,855	
436,351	
6,883	

-	
-	
-	
-	

220	
19,659	
-	
11,946	

175,189	
405,514	
436,351	
18,829	

General	Debt Service	Capital Projects	Funds

Other Financing Sources/(Uses)	
Transfers in	
Transfers out	
Total Other Financing Sources/(Uses)	

-		-		212,819		212,819	
(212,819)		-		-		(212,819)	
(212,819)		-		212,819		-	

-		745,000		-		745,000	
-		629,774		-		629,774	
-		1,351		-		1,351	
1,004,058		1,376,125		31,825		2,412,008	

Excess (deficiency) of revenues	
over/(under) expenditures	

156,118	(7,221)	(31,824)	117,073

Net Change in Fund Balances	(56,701)		(7,221)		180,995		117,073	
Fund Balances - October 1, 2020	474,821		1,004,113		193,182		1,672,116	

Fund Balances - September 30, 2021	
$  418,120		
$	996,892		
$	374,177		
$	1,789,189	

RECONCILIATION OF THE STATEMENT OF REVENUES, EXPENDITURES AND CHANGES IN FUND BALANCES OF GOVERNMENTAL FUNDS
TO THE STATEMENT OF ACTIVITIES
For the Year Ended September 30, 2021

Net Change in Fund Balances - Total Governmental Funds	$	117,073

Amounts reported for governmental activities in the Statement of Activities are	
different because:	

Governmental funds report capital outlays as expenditures. However, in the		
Statement of Activities, the cost of those assets is allocated over their		
estimated useful lives as depreciation. This is the amount by which capital outlay		
($18,829) was exceeded by depreciation ($(457,958)) in the current period.	(439,129)	

Bond principal payments are recorded as expenditures at the fund level, but	
reduce liabilities at the government-wide level.	745,000	

Amortization of bond discount does not require the use of financial current	
resources and therefore, is not reported in the governmental funds. This is the	
amount of amortization in the current period.	(3,537)	

In the Statement of Activities, interest is accrued on outstanding bonds;		
whereas in the governmental funds, interest expenditures are reported		
when due. This is the change in accrued interest in the current period.		8,276 	

Change in Net Position of Governmental Activities	 $	427,683 

Other Financing Sources/(Uses)	
Transfers out	

STATEMENT OF REVENUES, EXPENDITURES AND CHANGES IN FUND BALANCES – BUDGET AND ACTUAL – GENERAL FUND
For the Year Ended September 30, 2021

Variance with	
Final Budget	
Positive	
(Negative)	

Original	
Budget	

Final	
Budget	

Actual

Revenues	
Special assessments	
Investment earnings	
Miscellaneous revenues	
Total Revenues	

 	
$1,126,149	
-	
	5,000 	
  1,131,149 	

	
$1,140,482	
-	
	19,694 	
  1,160,176 	

	
$1,140,482	
33	
	19,661 	
  1,160,176 	

	
$	-	
33	
      (33)	
        - 	

Expenditures	
Current	
General government	
Physical environment	
Culture/recreation	
Capital outlay	
Total Expenditures	

157,053	
394,800	
428,330	
       - 	
   980,183 	

182,516	
397,107	
457,919	
       - 	
  1,037,542 	

174,969	
385,855	
436,351	
    6,883 	
  1,004,058 	

7,547	
11,252	
21,568	
     (6,883)	
     33,484 	

Excess of revenues over/(under) expenditures		150,966 		122,634 		156,118 		33,484 	
					
		(212,819)		(212,819)		(212,819)		- 	
Net Change in Fund Balances	(61,853)	(90,185)	(56,701)	33,484	
Fund Balances - October 1, 2020		61,853 		90,185 		474,821 		384,636 	
Fund Balances - September 30, 2021	 $	- 	 $	- 	 $  418,120 	 $	418,120 	

NOTE A – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

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.

Reporting Entity

The District was established on June 28, 2004, pursuant to the Uniform Community Development District Act of 1980, Chapter 190, Florida Statutes, as amended (the "Act"), by Ordinance #2004-47 of the Board of County Commissioners of St. Johns County, as a Community Development District. 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 district roads, landscaping, and other basic infrastructure projects within or outside the boundaries of the Turnbull Creek Community Development District. The District is governed by a five member Board of Supervisors elected by qualified resident electors residing within the District. The District operates within the criteria established by Chapter 190, Florida Statutes.

As required by GAAP, these financial statements present the Turnbull Creek Community Development District (the primary government) as a stand-alone 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.

Based upon the application of the above-mentioned criteria as set forth in Governmental Accounting Standards the District has identified no component units.

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

NOTE A – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Measurement Focus and Basis of Accounting (Continued)

Government-wide Financial Statements

The government-wide financial statements are reported using the economic resources measurement focus and the accrual basis of accounting. Government- wide financial statements report all non-fiduciary information about the reporting government as a whole. These statements include all the governmental activities of the primary government. The effect of interfund activity has been removed from these statements.

Governmental activities are supported by special assessments. 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.

Fund Financial Statements

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 or expenses, as appropriate. 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.

NOTE A – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

2. Measurement Focus and Basis of Accounting (Continued)

b. Fund Financial Statements (Continued) Governmental Funds
The District reports fund balance according to 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 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.

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.

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 – For all governmental funds except special revenue funds, 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.

NOTE A – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Measurement Focus and Basis of Accounting (Continued)

b. Fund Financial Statements (Continued) Governmental Funds (Continued)
Governmental fund financial statements are reported using the current financial resources measurement focus and the modified accrual basis of accounting. Revenues are considered to be available when they are collected within the current period or soon thereafter to pay liabilities of the current period. For this purpose, the District considers revenues to be available if they are collected within 60 days of the end of the current fiscal period.

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. 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.

Basis of Presentation

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.

NOTE A – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

Basis of Presentation (Continued)

Governmental Major Funds (Continued)

Debt Service Fund – The Debt Service Fund accounts for debt service requirements to retire the Special Assessment Bonds.

Capital Projects Fund – The Capital Projects Fund accounts for the acquisition and construction of infrastructure improvements located within the boundaries of the District.

Non-current Governmental Assets/Liabilities

GASB Statement 34 requires that non-current governmental assets, such as construction in progress, 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.

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;

NOTE A – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

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

Cash and Investments (Continued)

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

Cash and investments include time deposits, certificates of deposit, money market funds, and all highly liquid debt instruments with original maturities of three months or less.

Restricted Assets

Certain net position of the District are classified as restricted assets 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 net position, 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, infrastructure, equipment and buildings, are reported in the governmental activities column.

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.

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:

Building	10-30 years
Infrastructure	30 years
Equipment	5–7 years

NOTE A – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

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

Unamortized Bond Discounts

Bond discounts associated with the issuance of revenue bonds are amortized according to the straight line method of accounting. For financial reporting, unamortized bond discounts are netted against the applicable long-term debt.

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. As a result, deficits in the budget columns of the accompanying financial statements may occur.

NOTE B – CASH AND INVESTMENTS

All deposits are held in qualified public depositories and are included on the accompanying balance sheet 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 to it. The District does not have a formal deposit policy for custodial credit risk, however, they follow the provisions of Chapter 280, Florida Statutes regarding deposits and investments. As of September 30, 2021, the District's bank balance was $548,102 and the carrying value was $542,323. Exposure to custodial credit risk was as follows. The District 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.

NOTE B – CASH AND INVESTMENTS (CONTINUED)
Investments
As of September 30, 2021, the District had the following investments and maturities:

	Investment			Maturity		 Fair Value 
First American Government Obligation Fund	14 days*	$	802,191
Goldman Sachs Government Fund	38 days*	184,666 US Bank Money Market		N/A	266,552 Florida PRIME	49 days* 		42 
Total	 $ 1,253,451 

* 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 use 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 investments in First American Government Obligation Fund and Goldman Sachs Government Fund are Level 1 assets.
The District’s investment policy allows management to invest funds in investments permitted under Section 218.415, Florida Statutes. The investment in Florida PRIME is measured at amortized cost. Florida PRIME has established policies and guidelines regarding participant transactions and the authority to limit or restrict withdrawals or impose a penalty for an early withdrawal. As of September 30, 2021, there were no redemption fees, maximum transaction amounts, or any other requirement that would limit daily access to 100 percent of the account value.
Interest Rate Risk
The District does not have a formal investment policy that limits investment maturities as a means of managing its exposure to fair value losses arising from increasing interest rates.

NOTE B – CASH AND INVESTMENTS (CONTINUED)

Credit Risk
The District's investments are limited by state statutory requirements and bond compliance. The District has no investment policy that would further limit its investment choices. As of September 30, 2021, the District's investment in the Goldman Sachs Government Fund, Florida PRIME, and First American Government Obligation Funds 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 fund. The investments in First American Government Obligation Funds represent 64% of the District's total investments. The investments in Goldman Sachs Government Fund represent 15% of the District’s total investments. The US Bank Money Market represents 21% of the Districts total investments. The District’s investment in Florida PRIME represents less than 1% of the District’s total investments.

The types of deposits and investments and their level of risk exposure as of September 30, 2021 were typical of these items during the fiscal year then ended.

NOTE C – CAPITAL ASSETS

Capital Asset activity for the year ended September 30, 2021 was as follows:

	Balance October 1,
	2020		

  Additions 	

 Deletions 	Balance September 30,
	2021		
Governmental Activities:						
Capital assets, not being depreciated:
Land and improvements		
 $	3,846,133 	
 $	- 	
 $	- 	
 $	3,846,133 	
Capital assets being depreciated
Infrastucture		
5,052,657	
-	
-	
5,052,657	
Buildings		8,337,572	6,883	-	8,344,455	
Equipment			7,100 		11,946 		- 		19,046 	
Total Capital Assets Being Depreciated		13,397,329	18,829	-	13,416,158	
Less: accumulated depreciation			(5,615,812)		(457,958)		- 		(6,073,770)	
Total Capital Assets Being Depreciated,	Net		7,781,517 		(439,129)		- 		7,342,388 	

Governmental Activites Capital Assets, Net	
 $ 11,627,650 	
 $ (439,129)	
 $	- 	
 $ 11,188,521 	

Depreciation was charged to physical environment, $171,000 and culture and recreation,
$286,958.

NOTE D – LONG-TERM DEBT

The following is a summary of activity in the long-term debt account group of the District for the year ended September 30, 2021:

Long-term debt at October 1, 2020	$ 15,473,000	
Principal payments		(745,000)	
Long-term Debt at September 30, 2021	14,728,000	
Less: bond discount, net		(52,249)	
Bonds Payable, Net	$ 14,675,751	
Long-term debt is comprised of the following:		
Special Assessment Refunding Bonds		
$13,375,000 Series 2015A Bonds are due in annual principal installments beginning May 2016, maturing May 2035. Interest is due semi-annually on May 1 and November 1, beginning May 1, 2016, at variable rates of 1.25% to 4.75%.	

$  10,180,000	

$1,280,000 Series 2015B Bonds are due in annual principal installments beginning May 2016, maturing May 2045. Interest is due semi-annually on May 1 and November 1, beginning May 1, 2016, at variable rates of 1.25% to 5.00%.	

$	1,110,000	

$4,196,000 Series 2016 Bonds are due in annual principal installments beginning May 2017, maturing May 2037. Interest is due semi-annually on May 1 and November 1, beginning May 1, 2016, at fixed rate of 3.70%.	

$	3,438,000	

NOTE D – LONG-TERM DEBT (CONTINUED)

The annual requirements to amortize the principal and interest of bonded debt outstanding as of September 30, 2021 are as follows:

Year Ending
 September 30, 	 	

	Principal		 	

	Interest		 	

	Total		

2022	
$	740,000	
$	604,949	
$	1,344,949	
2023	767,000	578,999	1,345,999	
2024	798,000	550,867	1,348,867	
2025	824,000	520,334	1,344,334	
2026	856,000	488,273	1,344,273	
2027-2031	4,866,000	1,886,170	6,752,170	
2032-2036	5,042,000	758,551	5,800,551	
2037-2041	555,000	113,384	668,384	
2042-2045		280,000 		32,924 		312,924 	

Totals	
 $	14,728,000 	
$	5,534,451	
$	20,262,451	

Significant Bond Provisions

The Series 2015A, 2015B and 2016 Bonds are subject to redemption at the option of the District prior to their maturity, in whole or in part, in the manner provided by the Bond Indenture. The Bonds are also subject to extraordinary mandatory redemption in the manner determined by the Bond Registrar if certain events occur as outline in the Bond Indenture.

The Trust Indenture established certain amounts be maintained in a reserve account. In addition, the Trust Indenture has certain restrictions and requirements relating principally to the use of proceeds to pay for the infrastructure improvements and the procedures to be followed by the District on assessments to property owners. The District agrees to levy special assessments in annual amounts adequate to provide payment of debt service and to meet the reserve requirements.

NOTE D – LONG-TERM DEBT (CONTINUED)

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:

1. Reserve Fund – The 2016 Reserve Account was funded from the proceeds of the Series 2016 Bonds in an amount equal to the maximum annual debt service requirement. Monies held in the reserve account will be used only for the purposes established in the Trust Indenture.

Reserve Balance

Reserve Requirement

Series 2015A Special Assessment Bonds	$	497,317	$	488,241	
Series 2015B Special Assessment Bonds	$	41,383	$	35,881	
Series 2016 Special Assessment Bonds	$	114,421	$	114,079	

NOTE E – INTERFUND ACTIVITY
Interfund transfers for the year ended September 30, 2021, consisted of the following:
Transfers Out
Transfers In	General Fund
 	
Capital Projects Fund	 $	212,819 

Transfers from the General Fund to the Capital Projects Fund were to fund capital reserves.
NOTE F – 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 for which the government carries commercial insurance. There were no claims or settled claims from these risks that exceeded commercial insurance coverage in the past three years.

NOTE G – SUBSEQUENT EVENT

In May 2022, the District made prepayments on the Series 2015A and 2015B Bonds in the amounts of $45,000 and $5,000, respectively.

INDEPENDENT AUDITORS’ 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
Turnbull Creek Community Development District St. Johns 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 Turnbull Creek Community Development District, as of and for the year ended September 30, 2021, and the related notes to the financial statements, and have issued our report thereon dated June 29, 2022.

Internal Control Over Financial Reporting

In planning and performing our audit, we considered Turnbull Creek Community Development District's internal control over financial reporting (internal control) as a basis for designing 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 Turnbull Creek Community Development District’s internal control. Accordingly, we do not express an opinion on the effectiveness of Turnbull Creek Community Development District's internal control.

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 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.

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To the Board of Supervisors
Turnbull Creek Community Development District

Compliance and Other Matters

As part of obtaining reasonable assurance about whether Turnbull Creek 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.

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 purpose.

Berger, Toombs, Elam, Gaines & Frank Certified Public Accountants PL
Fort Pierce, Florida June 29, 2022

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MANAGEMENT LETTER

To the Board of Supervisors
Turnbull Creek Community Development District St. Johns County, Florida

Report on the Financial Statements

We have audited the financial statements of the Turnbull Creek Community Development District as of and for the year ended September 30, 2021, and have issued our report thereon dated June 29, 2022.

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 Reporting Requirements

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 those reports, which are dated June XX, 2022, 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 taken to address findings and recommendations made in the preceding financial audit report. There were no findings or recommendations in the preceding financial audit report.

Financial Condition and Management

Section 10.554(1)(i)5.a. and 10.556(7), Rules of the Auditor General, require us to apply appropriate procedures and communicate the results of our determination as to whether or not Turnbull Creek 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 Turnbull Creek Community Development District did not meet any of the conditions described in Section 218.503(1) Florida Statutes.

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To the Board of Supervisors
Turnbull Creek Community Development District

Pursuant to Sections 10.554(1)(i)5.b. and 10.556(8), Rules of the Auditor General, we applied financial condition assessment procedures for Turnbull Creek Community Development District. It is management’s responsibility to monitor the Turnbull Creek 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 as of September 30, 2021.

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.

Specific Information
The information provided below was provided by management and has not been audited; therefore, we do not express an opinion or provide any assurance on the information.
As required by Section 218.39(3)(c) and Section 218.32(1)(c), Florida Statutes, and Section 10.554(1)(i)6, Rules of the Auditor General, the Turnbull Creek Community Development District reported:
The total number of district employees compensated in the last pay period of the District’s fiscal year: 3
The total number of independent contractors to whom nonemployee compensation, defined as individuals or entities that receive 1099s, was paid in the last month of the District’s fiscal year: 18
All compensation earned by or awarded to employees, whether paid or accrued, regardless of contingency: $6,465
All compensation earned by or awarded to nonemployee independent contractors, defined as entities or individuals that receive 1099s, whether paid or accrued, regardless of contingency: $902,221
Each construction project with a total cost of at least $65,000 approved by the District that is scheduled to begin on or after October 1, 2020, together with the total expenditures for such project: The District had no construction projects during the year.
A budget variance based on the budget adopted under Section 189.016(4), Florida Statutes, before the beginning of the fiscal year being reported if the District amends a final adopted budget under Section 189.016(6), Florida Statutes: There were amendments to the FY 2021 budget. See the following page.
As required by Section 218.39(3)(c) and Section 218.32(1)(c), Florida Statutes, and Section 10.554(1)(i)8, Rules of the Auditor General, the Turnbull Creek Community Development District reported:
The rate or rates of non-ad valorem special assessments imposed by the District: General Fund $1,249.25, and Debt Service Fund $88.08 - $1,451.69.
The amount of special assessments collected by or on behalf of the District: $2,509,048.
The total amount of outstanding bonds issued by the District and the terms of such bonds. Series 2015A1-A2, $10,180,000 matures May 2035, Series 2015B1-B2,
$1,110,000 matures May 2045, and the Series 2016, $3,438,000, matures in May 2037.
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To the Board of Supervisors
Turnbull Creek Community Development District

Original
	Budget	 	Actual	

Variance with Original Budget Positive
	(Negative)	

Revenues		
Special assessments	$	1,126,149	$	1,140,482	$	14,333	
Interest earnings	-	33	33	
Miscellaneous revenues		5,000 		19,661 		14,661 	
Total Revenues		1,131,149 		1,160,176 		29,027 	

Expenditures Current				
General government	157,053		174,969	(17,916)	
Physical environment	394,800		385,855	8,945	
Culture and recreation	428,330		436,351	(8,021)	
Capital outlay		- 			6,883 		(6,883)	
Total Expenditures		980,183 			1,004,058 		(23,875)	
Excess of revenues over/(under) expenditures	150,966		156,118	5,152	
Other Financing Sources/(Uses)					
Transfers out		(212,819)			(212,819)		- 	
Net changes in fund balance	(61,853)		(56,701)	5,152	
Fund Balances - October 1, 2020		61,853 			474,821 		412,968 	
Fund Balances - September 30, 2021	 $	- 		 $	418,120 	 $	418,120 	

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 warrants the attention of those charged with governance. In connection with our audit, we did not note any such findings.

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To the Board of Supervisors
Turnbull Creek Community Development District

Purpose of this Letter

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.

Berger, Toombs, Elam, Gaines & Frank Certified Public Accountants PL
Fort Pierce, Florida June 29, 2022

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INDEPENDENT ACCOUNTANTS’ REPORT/COMPLIANCE WITH SECTION 218.415, FLORIDA STATUTES

To the Board of Supervisors
Turnbull Creek Community Development District St. Johns County, Florida

We have examined Turnbull Creek Community Development District's compliance with Section 218.415, Florida Statutes during the year ended September 30, 2021. Management is responsible for Turnbull Creek Community Development District’s compliance with those requirements. Our responsibility is to express an opinion on Turnbull Creek 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 Turnbull Creek 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 Turnbull Creek Community Development District’s compliance with the specified requirements.

In our opinion, Turnbull Creek Community Development District complied, in all material respects, with the aforementioned requirements during the year ended September 30, 2021.

Berger, Toombs, Elam, Gaines & Frank Certified Public Accountants PL
Fort Pierce, Florida June 29, 2022

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