2024-06-14T18:39:39-05:00 2023-07-31 941254756 HOOD & STRONG LLP 60 SO MARKET ST STE 200 SAN JOSE CA 95113 990 2022-08-01 942340692 PALO ALTO UNIVERSITY INC PALO 8008186136 1791 ARASTRADERO ROAD PALO ALTO CA 94304 JEANINE HAWK CFO 8008186136 2024-06-14 1 JEANINE HAWK 999009999 0 MAGA E KISRIEV P01008919 4089988400 2 AAL1 IAL1 2022 2023-04-26 12:10:37Z MAUREEN O'CONNOR 1791 ARASTRADERO ROAD PALO ALTO CA 94304 42937630 0 X WWW.PALOALTOU.EDU X 1975 CA TO PROVIDE UNDERGRADUATE AND GRADUATE LEVEL EDUCATION IN THE FIELD OF PSYCHOLOGY. 28 27 594 27 0 0 1678187 1290806 37492705 36373594 230182 400527 425000 425000 39826074 38489927 1347795 1273194 0 0 24191124 24213471 0 0 264519 13027172 13537908 38566091 39024573 1259983 -534646 39165769 45847970 14730927 21783949 24434842 24064021 X THROUGH EDUCATION, RESEARCH, AND TRAINING IN PSYCHOLOGY AND COUNSELING, PALO ALTO UNIVERSITY PREPARES ITS STUDENTS TO ADDRESS PRESSING AND EMERGING ISSUES THAT EQUITABLY MEET THE NEEDS OF OUR EVER-CHANGING HUMAN CONDITION. 0 0 4331789 265867 6881769 PSY.D. CLINICAL PSYCHOLOGY:THE UNIVERSITY OFFERS A FIVE-YEAR ONSITE DOCTORAL PROGRAM IN CLINICAL PSYCHOLOGY, LEADING TO A DOCTOR OF PSYCHOLOGY DEGREE (PSY.D). THIS PROGRAM IS IMPLEMENTED IN COLLABORATION WITH THE STANFORD SCHOOL OF MEDICINE DEPARTMENT OF PSYCHIATRY AND BEHAVIORAL SCIENCES AND WAS APPROVED BY WASC IN 2002. THE PROGRAM, THE PGSP-STANFORD PSY.D. CONSORTIUM, WAS FIRST ACCREDITED BY APA IN 2006, RE-ACCREDITED IN 2013 BY APA FOR SEVEN YEARS, AND CURRENTLY PREPARING FOR ITS NEXT APA SELF-STUDY.DURING THE 22-23 ACADEMIC YEAR, THIS PROGRAM WELCOMED A NEW COHORT OF 30 STUDENTS, GRADUATED 39 STUDENTS, AND EXPERIENCED 2 WITHDRAWALS OF THE 163 STUDENTS IN THE PROGRAM (1.2% ATTRITION). ADDITIONAL OUTCOMES DATA IS REPORTED ANNUALLY TO WASC, THE DEPARTMENT OF EDUCATION, THE AMERICAN PSYCHOLOGICAL ASSOCIATION, AND OTHER INSTITUTIONS. THE UNIVERSITY MAINTAINS A DETAILED PUBLIC ACCOUNTING OF ATTRITION, TIME TO COMPLETION, INTERNSHIP MATCH RATES AND MORE AT WWW.PALOALTOU.EDU/ACADEMIC-PROGRAMS/PGSP-STANFORD-PSYD-CONSORTIUM/STUDENT-ADMISSIONS-OUTCOMES-AND-OTHER-DATA. 1581858 0 268006 THE GRONOWSKI CENTER:THE GRONOWSKI CENTER IS A PSYCHOLOGY TRAINING CLINIC DEDICATED TO PROVIDING COMPASSIONATE COUNSELING, PSYCHOTHERAPY AND ASSESSMENT SERVICES TO ADULTS, OLDER ADULTS, COUPLES, ADOLESCENTS, CHILDREN AND FAMILIES IN SANTA CLARA COUNTY AND SAN MATEO COUNTY.THE CLINIC OFFERS SERVICES ON A SLIDING SCALE BASIS AS A PART OF ITS COMMUNITY MISSION. SERVICES ARE PROVIDED BY DOCTORAL LEVEL PSYCHOLOGY STUDENTS UNDER THE SUPERVISION OF LICENSED PSYCHOLOGISTS. 2966794 761035 15973552 PH.D. CLINICAL PSYCHOLOGY:THE UNIVERSITY HAS OFFERED A FIVE-YEAR ONSITE DOCTORAL PROGRAM IN CLINICAL PSYCHOLOGY, LEADING TO A DOCTOR OF PSYCHOLOGY (PH.D.) SINCE 1975. THE PH.D. PROGRAM WAS ACCREDITED BY THE AMERICAN PSYCHOLOGICAL ASSOCIATION (APA) IN 1988 AND WAS RE-ACCREDITED IN 2016 BY APA FOR SEVEN YEARS.DURING THE 22-23 ACADEMIC YEAR, THIS PROGRAM WELCOMED A NEW COHORT OF 65 STUDENTS, GRADUATED 79 STUDENTS, AND EXPERIENCED 12 WITHDRAWALS OF THE 445 STUDENTS IN THE PROGRAM (2.6% ATTRITION). ADDITIONAL OUTCOMES DATA IS REPORTED ANNUALLY TO WASC, THE DEPARTMENT OF EDUCATION, THE AMERICAN PSYCHOLOGICAL ASSOCIATION, AND OTHER INSTITUTIONS. THE UNIVERSITY MAINTAINS A DETAILED PUBLIC ACCOUNTING OF ATTRITION, TIME TO COMPLETION, INTERNSHIP MATCH RATES AND MORE AT WWW.PALOALTOU.EDU/ACADEMIC-PROGRAMS/PHD-CLINICAL-PSYCHOLOGY/OUTCOMES-AND-DATA. 20304109 246292 13675267 PAU MASTER'S PROGRAMS: M.A. IN COUNSELING: THIS PROGRAM OFFERS A MASTER OF ARTS IN COUNSELING IN ONE OF TWO AREAS OF EMPHASIS: "MARRIAGE, FAMILY AND CHILD", OR "CLINICAL MENTAL HEALTH". BOTH EMPHASIS AREAS ARE CACREP ACCREDITED SINCE JANUARY 2017, AND PREPARE STUDENTS TO PURSUE LICENSURE IN COUNSELING. THE PROGRAM HAS BEEN WASC ACCREDITED SINCE 2009 FOR DISTANCE LEARNING, AND SINCE 2011 FOR THE RESIDENTIAL VERSION. DURING THE 22-23 ACADEMIC YEAR, THIS PROGRAM WELCOMED A NEW COHORT OF 265 STUDENTS, GRADUATED 200 STUDENTS, EXPERIENCED 32 WITHDRAWALS OF THE 497 STUDENTS IN THE PROGRAM (6.4% ATTRITION).M.S. IN PSYCHOLOGY: THE M.S. IN PSYCHOLOGY IS PRIMARILY A PREPARATORY PROGRAM FOR STUDENTS SEEKING ENTRANCE TO THE PH.D. PROGRAM. PAU WAS GRANTED WASC ACCREDITATION FOR A DISTANCE EDUCATION M.S. IN PSYCHOLOGY DEGREE PROGRAM IN 2000. DURING THE 22-23 ACADEMIC YEAR, THIS PROGRAM WELCOMED A NEW COHORT OF 39 STUDENTS, GRADUATED 16 STUDENTS, EXPERIENCED 9 WITHDRAWALS OF THE 71 STUDENTS IN THE PROGRAM (12.7% ATTRITION).PAU UNDERGRADUATE PROGRAMS:PAU OFFERS TWO SEPARATE DEGREE COMPLETION PROGRAMS AT THE UNDERGRADUATE LEVEL. ENTERING STUDENTS ARE REQUIRED TO HAVE COMPLETED FRESHMAN AND SOPHOMORE GENERAL EDUCATION REQUIREMENTS AT ANOTHER ACCREDITED INSTITUTION. B.S. IN PSYCHOLOGY AND SOCIAL ACTION:PAU WAS GRANTED WASC APPROVAL FOR A BACHELOR OF SCIENCE IN PSYCHOLOGY AND SOCIAL ACTION ONSITE DEGREE PROGRAM IN 2006, FOLLOWED BY APPROVAL TO OFFER A DISTANCE EDUCATION VERSION STARTING IN 2011. DURING THE 22-23 ACADEMIC YEAR, THIS PROGRAM WELCOMED A NEW COHORT OF 23 STUDENTS, GRADUATED 16 STUDENTS, EXPERIENCED 12 WITHDRAWALS OF THE 56 STUDENTS IN THE PROGRAM (21.4% ATTRITION).B.S. IN BUSINESS PSYCHOLOGY:PAU WAS GRANTED WASC APPROVAL FOR A BACHELOR OF SCIENCE IN BUSINESS PSYCHOLOGY ONSITE DEGREE PROGRAM IN 2009, FOLLOWED BY APPROVAL TO OFFER A DISTANCE EDUCATION VERSION STARTING IN 2011. DURING THE 22-23 ACADEMIC YEAR, THIS PROGRAM WELCOMED A NEW COHORT OF 1 STUDENT, GRADUATED 0 STUDENTS (NONE), EXPERIENCED 0 (NONE) WITHDRAWAL OF THE 5 STUDENTS IN THE PROGRAM (0.0% ATTRITION). 20304109 246292 13675267 29184550 1 1 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 0 1 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1341 0 1 594 1 0 0 0 0 0 0 0 0 0 0 0 0 X 28 27 1 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 CA X X MAYA RAMAKRISHNAN 8008186136 1791 ARASTRADERO ROAD PALO ALTO CA 94304 MAUREEN O'CONNOR PRESIDENT 40.00 X X 487969 0 142581 CAROL BOBBY TRUSTEE 3.00 X 0 0 0 NICHOLAS COCHRAN TRUSTEE 3.00 X 0 0 0 MARTIN DODD TRUSTEE 3.00 X 0 0 0 JEFF GEE TRUSTEE 3.00 X 0 0 0 JAMES IOANNIDIS TRUSTEE 3.00 X 0 0 0 MICHAEL KERNER TRUSTEE 3.00 X 0 0 0 DANIEL KOSTENBAUDER TRUSTEE 3.00 X 0 0 0 MATT LEVINE TRUSTEE 3.00 X 0 0 0 DANIELE LEVY TRUSTEE 3.00 X 0 0 0 MARILYN MANNING LONERGAN TRUSTEE 3.00 X 0 0 0 RICHARD LONERGAN TRUSTEE 3.00 X 0 0 0 DEREK MINNO TRUSTEE 3.00 X 0 0 0 JAMES OTIENO TRUSTEE 3.00 X 0 0 0 ISRAEL NIV TRUSTEE 3.00 X 0 0 0 KATHRYN PRYOR TRUSTEE 3.00 X 0 0 0 SARA EISNER RICHTER TRUSTEE 3.00 X 0 0 0 KAREN SCUSSEL TRUSTEE 3.00 X 0 0 0 JORGE WONG TRUSTEE 3.00 X 0 0 0 TOM YEH TRUSTEE 3.00 X 0 0 0 CYNTHIA JAMES TRUSTEE 3.00 X 0 0 0 JIM BEALL TRUSTEE 3.00 X 0 0 0 MARY ANN DEWAN TRUSTEE 3.00 X 0 0 0 KY LE TRUSTEE 3.00 X 0 0 0 SHARI MILES-COHEN TRUSTEE 3.00 X 0 0 0 JESSICA DIVENTO DZUBAN TRUSTEE 3.00 X 0 0 0 TOM WEINGARTEN TRUSTEE 3.00 X 0 0 0 HELEN WILMOT TRUSTEE 3.00 X 0 0 0 MELANIE MORRISON SECR., DIR OF BOARD & PRES OPS 40.00 X 110272 0 17913 ERIKA CAMERON PROVOST, VP ACAD STDNT AFFAIRS 40.00 X 272887 0 36761 PATRICIA ZAPF VP OF CONTINUING & PROF. STUDIES 40.00 X 384595 0 72115 JAMES BRECKENRIDGE CHIEF OF STAFF 40.00 X 265891 0 13943 RICARDO MUNOZ DISTINGUISHED PROFESSOR 40.00 X 269084 0 12799 JOYCE MOORE PROFESSOR 40.00 X 242778 0 19176 WILLIAM FROMING PROFESSOR 40.00 X 225392 0 23423 JUNE KLEIN FR VP BUS AFF/CFO (THRU 12/31/21) 0.00 X 279197 0 0 2538065 0 338711 82 1 1 0 STANFORD UNIVERSITY 401 QUARRY ROAD RM 3208 STANFORD CA 94035 CONSORTIUM 3317958 RODAN BUILDERS 3486 INVESTMENT BLVD SUITE B HAYWARD CA 94545 CONSTRUCTION SERVICES 2246725 LFH CONSULTING 63183 RIVERSTONE DRIVE BEND OR 97703 CONSULTING SERVICES 210000 SCELC 5161 LANKERSHIM BLVD SUITE 250 NORTH HOLLYWOOD CA 91601 LIBRARY CONSORTIUM 204313 JENZABAR 111 HUNTINGTON AVENUE SUITE 530 BOSTON MA 02199 ERP SOFTWARE SYSTEM 154077 16 698016 592790 1290806 TUITION 611600 30640447 30640447 COURSE FEES 611600 3997223 3997223 CLINIC INCOME 611710 1526355 1526355 OTHER PROGRAM INCOME 611710 209569 209569 36373594 441966 441966 4406264 4447703 -41439 -41439 -41439 LEASE TERMINATION 900099 425000 425000 425000 38489927 36798594 0 400527 1273194 1273194 1068383 799347 259193 9843 20129456 15107374 4842009 180073 689638 481648 200341 7649 910267 691803 209361 9103 1415727 1096725 307032 11970 67348 6024 61324 106200 106200 2111361 747450 1341072 22839 342031 121084 220947 488967 54321 434646 1481226 1390952 90274 261623 261623 1774305 1619174 151235 3896 235543 207006 27969 568 68098 63149 3280 1669 906566 687171 216066 3329 304689 304689 CONSORTIUM PAYMENTS 3534118 3534118 AWARDS/ACKNOWLEDGMENTS 384338 31683 352655 PROF DUES & LICENSE 192845 152055 39248 1542 MEALS & ENTERTAINMENT 160505 101056 59400 49 1118145 757593 348563 11989 39024573 29184550 9575504 264519 4193326 3118373 10060459 9535868 647450 868010 8989431 8911542 1216475 1298725 19740983 8833586 9366722 10907397 3537430 3730857 69525 69525 573000 573000 511951 6834673 39165769 45847970 3600035 2970949 10595248 11008920 535644 7804080 14730927 21783949 X 22568988 21734555 1865854 2329466 24434842 24064021 39165769 45847970 -534646 163825 0 X 0 1 X 1 1 1 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 3864153 84500 203621 33515 4118759 3936749 48500 -121096 3864153 3252856 22650 778743 117500 3936749 2835341 206500 250984 39969 3252856 2790449 127755 -70568 12295 2835341 0.76925 0.23075 0.00000 0 0 2950000 2950000 9007500 2048450 6959050 4142768 3626681 516087 3640715 3158455 482260 10907397 FEDERAL DIRECT LOAN FUNDS RECEIVABLE 100370 OPERATING LEASE RIGHT-OF-USE ASSETS 6734303 6834673 OPERATING LEASE LIABILITIES 7804080 7804080 X 37380558 163825 -1273194 -1109369 38489927 0 38489927 37751379 0 37751379 1273194 1273194 39024573 PART V, LINE 4: THE UNIVERSITY'S ENDOWMENTS CONSIST OF ELEVEN INDIVIDUAL FUNDS, ALL ESTABLISHED TO GENERATE SUPPORT FOR THE UNIVERSITY'S GENERAL OPERATIONS, TUITION ASSISTANCE AND PROGRAMS. ITS ENDOWMENT INCLUDES DONOR-RESTRICTED ENDOWMENT FUNDS AND FUNDS DESIGNATED BY THE BOARD OF TRUSTEES TO FUNCTION AS ENDOWMENTS. PART X, LINE 2: THE UNIVERSITY IS RECOGNIZED BY THE INTERNAL REVENUE SERVICE AS AN ORGANIZATION EXEMPT FROM INCOME TAXES ON RELATED ACTIVITIES UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE AND SECTION 23701D OF THE CALIFORNIA REVENUE AND TAXATION CODE. AS OF JULY 31, 2023 AND 2022, MANAGEMENT EVALUATED THE UNIVERSITY'S TAX POSITIONS AND CONCLUDED THAT THE UNIVERSITY HAD MAINTAINED ITS TAX-EXEMPT STATUS AND HAD TAKEN NO UNCERTAIN TAX POSITIONS THAT REQUIRE ADJUSTMENT TO THE FINANCIAL STATEMENTS. THEREFORE, NO PROVISION OR LIABILITY FOR INCOME TAXES HAS BEEN INCLUDED IN THE FINANCIAL STATEMENTS. PART XI, LINE 2D - OTHER ADJUSTMENTS: FINANCIAL AID NETTED AGAINST REVENUE ON FINANCIAL STATEMENTS -1,273,194. PART XII, LINE 4B - OTHER ADJUSTMENTS: FINANCIAL AID NETTED AGAINST REVENUE ON FINANCIAL STATEMENTS 1,273,194. 1 1 0 1 1 1 1 0 0 0 0 0 0 0 0 1 0 1 SCHEDULE E, PART I, LINE 3 THIS INFORMATION IS INCLUDED IN THE STUDENT HANDBOOK, ON PAU WEBSITE AND IN ALL RECRUITMENT MATERIALS FOR PROSPECTIVE STUDENTS. SCHEDULE E, PART I, LINE 6 THE UNIVERSITY RECEIVES FEDERAL AID UNDER TITLE IV OF THE STUDENT FINANCIAL ASSISTANCE PROGRAM. THE PROGRAMS THAT THE UNIVERSITY PARTICIPATES IN ARE THE WILLIAM D. FORD FEDERAL DIRECT LOAN PROGRAM, THE FEDERAL WORK STUDY PROGRAM, THE FEDERAL PELL GRANT PROGRAM, AND THE FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANT PROGRAM. 1 SCHOLARSHIPS, GRANTS AND FINANCIAL AIDS 187 1273194 PART I, LINE 2: THE ORGANIZATION PROVIDES FINANCIAL AID ONLY TO QUALIFIED STUDENTS ENROLLED AT THE UNIVERSITY. THE DIVISION OF ACADEMIC & STUDENT AFFAIRS IS RESPONSIBLE FOR MANAGING THE FELLOWSHIP AND SCHOLARSHIP ALLOCATION FOR NEW STUDENTS. THE FACULTY AND THE STAFF AT ACADEMIC & STUDENT AFFAIRS DIVISION WORK TOGETHER TO AWARD FELLOWSHIPS OR SCHOLARSHIPS TO NEW STUDENTS. X X 1 1 X X X X X 1 1 0 1 0 0 0 1 0 MAUREEN O'CONNOR PRESIDENT 487969 0 0 0 0 0 48250 0 94331 0 630550 0 0 0 PATRICIA ZAPF VP OF CONTINUING & PROF. STUDIES 234143 0 100000 0 50452 0 11057 0 61058 0 456710 0 0 0 ERIKA CAMERON PROVOST, VP ACAD STDNT AFFAIRS 272887 0 0 0 0 0 14521 0 22240 0 309648 0 0 0 RICARDO MUNOZ DISTINGUISHED PROFESSOR 254915 0 2500 0 11669 0 11865 0 934 0 281883 0 0 0 JAMES BRECKENRIDGE CHIEF OF STAFF 265891 0 0 0 0 0 13009 0 934 0 279834 0 0 0 JUNE KLEIN FR VP BUS AFF/CFO (THRU 12/31/21) 0 0 0 0 279197 0 0 0 0 0 279197 0 0 0 JOYCE MOORE PROFESSOR 207479 0 2500 0 32799 0 10712 0 8464 0 261954 0 0 0 WILLIAM FROMING PROFESSOR 149992 0 0 0 75400 0 10313 0 13110 0 248815 0 0 0 PART I, LINE 1A MAUREEN O'CONNOR, PRESIDENT AND PATRICIA A. ZAPF, VP, CONTINUING & PROFESSIONAL STUDIES RECEIVED HOUSING ALLOWANCE AS PART OF THEIR COMPENSATION AGREEMENT, WHICH IS PAID DIRECTLY BY THE SCHOOL. THE BENEFIT WAS TREATED AS NONTAXABLE COMPENSATION. PATRICIA ZAPF RECEIVED A TAX GROSS-UP PAYMENT AS PART OF A PERFORMANCE BONUS. THE PAYMENT WAS TREATED AS TAXABLE COMPENSATION. PART I, LINES 4A-B WILLIAM FROMING AND JUNE KLEIN RECEIVED THEIR PAYMENTS OF $75,000 AND $279,197, RESPECTIVELY IN ACCORDANCE WITH THE VOLUNTARY RETIREMENT AGREEMENT. MAUREEN O'CONNOR, PRESIDENT, PARTICIPATED IN A 457(F) DEFERRED COMPENSATION ARRANGEMENT. IN 2022, THE UNIVERSITY CONTRIBUTED $33,000 TO THE 457 TRUST. PART I, LINE 5 THE UNIVERSITY PAID $3,255 TO PATRICIA ZAPF, VICE PRESIDENT FOR CONTINUING & PROFESSIONAL STUDIES. THE PAYMENTS ARE DETERMINED BASED ON THE SALE OF THE UNIVERSITY'S ON-DEMAND PROGRAMS. PART I, LINE 7 THE PRESIDENT, IN CONSULTATION WITH THE CFO CONSULTANT AND DIRECTOR OF HUMAN RESOURCES DECIDED TO GIVE ALL FULL TIME EMPLOYEES A BONUS OF $2,500. THE BONUS AMOUNT WAS ADJUSTED FOR EMPLOYEES WHO WERE LESS THAN FULL TIME. SOME EMPLOYEES WERE GIVEN ADDITIONAL MERIT BONUS. PATRICIA ZAPF RECEIVED A PERFORMANCE BONUS OF $100,000 BASED ON WORK CONTRIBUTED TO THE TRAINING AND CURRICULAR NEEDS OF OUR STUDENTS, FACULTY, AND COMMUNITY ABOVE AND BEYOND THE EXPECTED WORKLOAD LEVEL. FORM 990, PART VI, SECTION A, LINE 2 RICHARD LONERGAN, TRUSTEE, AND MARILYN MANNING LONERGAN, TRUSTEE, HAVE A FAMILY RELATIONSHIP. FORM 990, PART VI, SECTION B, LINE 11B THE COMPLETED FORM 990 WAS REVIEWED BY THE CONTROLLER. AFTER THE CONTROLLER REVIEWED, THE CFO REVIEWED. ANY CHANGES WERE GIVEN TO THE ACCOUNTING FIRM. THE REVISED FORM 990 WAS REVIEWED BY THE BOARD OF TRUSTEES BEFORE FILING. FORM 990, PART VI, SECTION B, LINE 12C OFFICERS AND DIRECTORS/TRUSTEES ARE REQUIRED TO REVIEW AND SIGN THE CONFLICT OF INTEREST POLICY ANNUALLY. THE ORGANIZATION'S GOVERNING BODY DETERMINES WHETHER A CONFLICT EXISTS. OFFICERS, DIRECTORS/TRUSTEES AND KEY EMPLOYEES AND THE ORGANIZATION'S GOVERNING BODY MONITOR FOR CONFLICT. IF THERE IS A CONFLICT, RESTRICTIONS ARE IMPOSED ON A CASE BY CASE BASIS WITH DIRECTION FROM THE LEGAL COUNSEL. IN FY23, THERE ARE NO REPORTED KEY EMPLOYEES. FORM 990, PART VI, SECTION B, LINE 15 PAU PREVIOUSLY CONDUCTED A CEO COMPENSATION REVIEW BASED ON MARKET COMPENSATION REVIEW DATA WHICH RESULTED IN A 3 YEAR CONTRACT EFFECTIVE AUGUST 1, 2022 TO JULY 31, 2025. FORM 990, PART VI, SECTION C, LINE 19 GOVERNING DOCUMENTS, FINANCIAL STATEMENTS AND CONFLICT OF INTEREST POLICY ARE ON PALO ALTO UNIVERSITY WEBSITE AND AVAILABLE UPON REQUEST FOR THE SAME PERIOD OF TIME SET FORTH IN SEC. 6104(D).