The archdiocese again declined to comment.
In August 2018 the Washington archdiocese told CNA that the fund was designated for McCarrick's "personal works of charity and other miscellaneous expenses" and audited annually, along with all other archdiocesan accounts - although not included in any published financial reports or materials - and that "no irregularities were ever noticed."
If personal payments to Church officials in Rome were offered with money from the Archbishop's Fund, it is unclear what "charitable purpose" or "miscellaneous expenses" they would have been for, or how such expenditures would have been recorded.
Sources close to McCarrick and familiar with archdiocesan records have told CNA he made multiple "donations" to individuals with fund resources, and sources close to the archdiocesan chancery previously have told CNA that annual expenditures may have been examined only to ensure either a "broadly charitable" purpose or a "reasonable" miscellaneous expense.
The archdiocese declined to comment on the auditing process and standards used to evaluate McCarrick's use of the Archbishop's Fund over the years.
In February the archdiocese told CNA that although the account was held under the umbrella of the archdiocese, the funds were considered to be McCarrick's own to use as he wished, but a former financial advisor to the archdiocese told CNA on July 11 that the fund was, for accounting purposes, archdiocesan money.
Kathy McKinless served as a financial consultant to the archdiocese between 2003 - 2018, throughout much of McCarrick's tenure in Washington, and as acting chief financial officer from July 2015 to January 2016.
She told CNA that while McCarrick was responsible for raising and allocating the money in the Archbishop's Fund, "it was on the general ledger of the archdiocese, so gifts that were made to the account were considered gifts to the archdiocese and the checks written out were considered checks of the archdiocese, because he still had standing as our archbishop emeritus."
McKinless told CNA that while McCarrick had the freedom to give as he saw fit, there was some oversight by the archdiocese, while stressing that she did not herself have a direct role in scrutinizing the account.
"It was definitely treated as being under the umbrella of the archdiocese because I know that the reconciliations were done at the pastoral center."
"It was only handled as an account that was reconciled [annually] at the pastoral center, it had inflows which were gifts to him and outflows which were checks from him but they were seen by somebody at the pastoral center," she told CNA.
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McKinless said it would have been possible for McCarrick to write checks to individuals, such as bishops or cardinals either in Rome or elsewhere, without raising suspicion, though she added that "I just was not in a position that I would have seen it."
McKinless stressed to CNA that while there was potential for abuse, the rationale behind the fund's existence should not be considered insidious: "I actually think that it is a worthy system, even if [McCarrick] abused it. There are lots of legitimate reasons you might want a retired bishop from your diocese to continue to do good works."
McKinless told CNA that bishops from Asian or African dioceses and other parts of the world would often come through Washington and leave with financial support for different projects from McCarrick. Similar accounts of his legitimate generosity were given by former staff close to McCarrick, both in Washington and Newark.
A former priest-secretary who served under McCarrick told CNA that he would often make large donations to Church projects or institutions.
"A bishop from India or Africa would come through town and cry over dinner that he couldn't feed his seminarians and McCarrick would make sure he left with a $10,000 check; he was good like that, very open-handed."
McKinless suggested that structures and oversight could be tightened in the light of possible abuses.