2022-04-12T13:12:23-05:00 2022-02-28 411360831 OLSEN THIELEN & CO LTD 2675 LONG LAKE ROAD ST PAUL MN 55113 990 2021-07-01 411921094 CLEARWAY MINNESOTA (SM) CLEA 9528963364 8300 NORMAN CENTER DRIVE 1000 MINNEAPOLIS MN 55437 J PATRICK PLUNKETT ADMINISTRATOR FOR CLEARWAY MN 9528963364 2022-04-06 1 J PATRICK PLUNKETT XXX-XX-XXXX RYAN VETTRUS CPA P01243596 6514834521 3 AAL1 IAL1 2021 2022-09-23 18:48:47Z X X J PATRICK PLUNKETT 8300 NORMAN CENTER DRIVE 1000 MINNEAPOLIS MN 55437 1799781 0 X N/A X 1998 MN SEE SCHEDULE O X 0 0 16 11 0 0 0 0 0 0 -66585 4738 -7586 2819 -74171 7557 1021995 445137 0 0 2053737 546896 0 0 0 1102549 244099 4178281 1236132 -4252452 -1228575 2060134 0 831559 0 1228575 0 X SEE PART I, LINE 1 0 1 523531 445137 0 SEE SCHEDULE OAS CLEARWAY MINNESOTA'S LIMITED LIFETIME ENDED ON DECEMBER 31, 2021, THE ORGANIZATION HAS NOW CLOSED DOWN PROGRAMS AND CEASED OPERATIONS. FINAL ACTIVITIES IN FISCAL YEAR 2021 AND THE FIRST SIX MONTHS OF FISCAL YEAR 2022 (THE FINAL MONTHS OF THE ORGANIZATION'S EXISTENCE) INCLUDED THE SECOND ITERATION OF THE TRIBAL TOBACCO USE PROJECT SURVEY (TTUP II), CONTRACTED TO THE AMERICAN INDIAN CANCER FOUNDATION. DURING FISCAL YEAR 2022, TTUP II CONTINUED SURVEY IMPLEMENTATION AND DATA COLLECTION. TTUP II WILL GENERATE STATEWIDE AND TRIBAL-SPECIFIC DATA ON COMMERCIAL AND TRADITIONAL TOBACCO USE AND RELATED KNOWLEDGE, ATTITUDES, AND BELIEFS AMONG AMERICAN INDIAN ADULTS IN MINNESOTA. RESULTS (EXPECTED TO BE RELEASED IN CALENDAR YEAR 2022) WILL HIGHLIGHT CHANGES SINCE THE FIRST TTUP SURVEY AND SERVE AS A GUIDE FOR TRIBAL AND STATEWIDE STAKEHOLDERS FOR REDUCING THE HARMS OF COMMERCIAL TOBACCO USE STATEWIDE AND WITHIN INDIVIDUAL TRIBAL NATIONS.IN THE AREA OF PUBLIC AFFAIRS AND POLICY ADVOCACY, THIS YEAR CLEARWAY MINNESOTA CONCLUDED ITS EFFORTS TO REDUCE TOBACCO'S HARM THROUGH COALITION BUILDING, POLICY ADVOCACY AND PUBLIC EDUCATION. CONTRACTORS WERE THE AMERICAN LUNG ASSOCIATION IN MINNESOTA AND THE ASSOCIATION FOR NONSMOKERS-MINNESOTA (ANSR-MN), WHICH CONTRIBUTED TO CLEARWAY MINNESOTA'S STATEWIDE POLICY GOALS BY EDUCATING LAWMAKERS ABOUT THE GROWING YOUTH TOBACCO EPIDEMIC IN MINNESOTA AND THE IMPORTANCE OF PASSING STRONG STATEWIDE POLICIES TO HELP SMOKERS QUIT AND PREVENT YOUTH FROM STARTING, INCLUDING PROHIBITING THE SALE OF FLAVORED TOBACCO PRODUCTS AND INCREASING FUNDING FOR TOBACCO PREVENTION. CLEARWAY MINNESOTA ALSO CONCLUDED ITS CO-LEADERSHIP OF MINNESOTANS FOR A SMOKE-FREE GENERATION, A STATEWIDE COALITION WORKING TO SUPPORT POLICIES THAT HELP PREVENT YOUNG PEOPLE FROM INITIATING COMMERCIAL TOBACCO USE. CLEARWAY MINNESOTA CONTINUED CONTRACTING WITH RAPP STRATEGIES, INC., FOR PUBLIC AFFAIRS SUPPORT DURING THIS FISCAL YEAR. 523531 1 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 1 12 0 1 16 1 0 0 0 0 0 0 0 0 0 0 0 0 X 0 0 0 0 1 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 MN X X J PATRICK PLUNKETT ADMINISTRATOR OF CLEARWAY MN 9528963364 8300 NORMAN CENTER DRIVE STE 1000 MINNEAPOLIS MN 55437 DAVID J WILLOUGHBY CHIEF EXECUTIVE OFFICER 40.00 X 226838 0 76501 MOLLY MOILANEN VICE PRESIDENT - THROUGH 11/30/21 40.00 X 171515 0 49321 LANA KOPYLOV - DIRECTOR OF FINANCE - THROUGH 12/31/2021 40.00 X 137342 0 44639 NICOLE TOVES - DIRECTOR OF HEALTH EQUITY PROGRAMS -THRU 8/31/21 40.00 X 127754 0 30846 JOANNE D'SILVA - DIRECTOR OF HEALTH EQUITY RESEARCH -THRU 8/31/21 40.00 X 136422 0 21169 ADAM KINTOPF - DIRECTOR OF STRATEGIC COMMUNICATIONS-THRU 11/21 40.00 X 122668 0 33807 KAREN KRAEMER BOARD CHAIR - THROUGH 12/31/2021 4.00 X X 0 0 0 BRIAN OSBERG VICE CHAIR - THROUGH 12/31/2021 2.00 X X 0 0 0 LAURIE LAFONTAINE TREASURER - THROUGH 12/31/2021 2.00 X X 0 0 0 GAIL AMUNDSON DIRECTOR - THROUGH 7/21/2021 1.00 X 0 0 0 JANET AVERY DIRECTOR - THROUGH 7/21/2021 1.00 X 0 0 0 MAE BROOKS DIRECTOR - THROUGH 7/21/2021 1.00 X 0 0 0 JUDY BROWN DIRECTOR - THROUGH 7/21/2021 1.00 X 0 0 0 NEVADA LITTLEWOLF DIRECTOR - THROUGH 7/21/2021 1.00 X 0 0 0 SARAH OQUIST DIRECTOR - THROUGH 7/21/2021 1.00 X 0 0 0 ANNE VARS DIRECTOR - THROUGH 7/21/2021 1.00 X 0 0 0 GREG WULF DIRECTOR - THROUGH 7/21/2021 1.00 X 0 0 0 922539 0 256283 6 0 1 0 HABERMAN & ASSOCIATES INC 43 SE MAIN STREET STE 300 MINNEAPOLIS MN 55414 MEDIA BUY AND ADVERTISING SERVICES 247290 1 718 718 1792974 3270 1792224 0 750 3270 4020 4020 MISCELLANEOUS INCOME 2819 2819 2819 7557 0 0 7557 X 445137 445137 288848 16953 271895 192793 10168 182625 5719 573 5146 20980 2102 18878 38556 2360 36196 39821 39821 26700 26700 65401 65401 8061 171 7890 15399 15399 1061 1061 3450 3450 17395 17395 CONTRIBUTION OF FINAL A 26067 26067 PUBLIC EDUCATION/RELATI 21000 20000 1000 CONSULTANTS 12925 12925 OTHER EXPENSES 6819 6819 1236132 523531 712601 0 250019 0 0 0 14211 0 0 0 0 0 3680 0 0 0 0 0 1792224 0 0 0 0 0 2060134 0 831559 0 831559 0 X 1228575 0 1228575 0 2060134 0 -1228575 0 X X 0 1 X 1 0 X X 1 SEE SCH A PART VI 411921094 6 1 0 0 1 0 0 1 0 0 0 0 1 0 0 0 0 0 0 0 0 0 1 0 PART I, LINE 12G COLUMNS (I) & (II) - STATE OF MINNESOTA THROUGH THE SECOND JUDICIAL DISTRICT COURT. CLEARWAY MINNESOTA (SM) WAS CREATED BY (AND REMAINS SUBJECT TO THE AUTHORITY OF) THE STATE OF MINNESOTA'S JUDICIAL BRANCH, HAVING BEEN FORMED BY ORDER OF THE STATE'S SECOND JUDICIAL DISTRICT COURT TO RECEIVE AND ADMINISTER FUNDS RECEIVED FROM THE SETTLEMENT MINNESOTA RECEIVED FROM A CONGLOMERATE OF TOBACCO COMPANIES AFTER BRINGING A LAWSUIT AGAINST THEM IN THE 1990S. FROM INCEPTION THE ORGANIZATION'S GOVERNANCE STRUCTURE WAS UNDER CONTROL OF THAT COURT, AND THE ORGANIZATION'S BOARD WAS COMPOSED IN PART OF APPOINTEES WHO SERVED AT THE PLEASURE OF THE STATE'S LEGISLATURE AND EXECUTIVE BRANCHES. EIN IS N/A. COLUMN (IV) - AS EXPLAINED IN CLEARWAY MINNESOTA (SM)'S EXEMPTION APPLICATION, THERE WAS NO SPECIFIC NAMING OF A "SUPPORTED ORGANIZATION IN THE ARTICLES OF INCORPORATION, BUT THE ARTICLES WERE PART OF THE COURT'S ORDER WHICH ITSELF BOTH CREATED THE ORGANIZATION WITH PURPOSES AND GOVERNANCE STRUCTURE FURTHERING THE STATE'S NEEDS AS MANDATED BY THE COURT ORDER. COLUMN (V) - 100% OF THE ORGANIZATION'S PROGRAM SERVICE EXPENDITURES ($523,531) RELATED TO UNDERTAKINGS THAT WERE MANDATED BY TERMS ESTABLISHED AT THE TIME OF THE ORGANIZATION'S FORMATION BY THE COURT, MEMORIALIZED WITHIN AND CONTROLLING PURSUANT TO THE ORGANIZATION'S ARTICLES OF INCORPORATION. COLUMN (VI) - 100% OF THE ORGANIZATION'S MANAGEMENT EXPENDITURES ($712,601), AS WELL AS THE ENTIRETY OF ITS EFFORTS CONDUCTED VIA VOLUNTEERS, SUPPORTED THE ORGANIZATION'S UNDERTAKINGS FURTHERING THE MEETING OF THE STATE OF MINNESOTA'S NEEDS ADDRESSED IN THE RESPONSE FOR THE PRECEDING COLUMN, (V). PART IV, SECTION A, LINE 6 HISTORICALLY, AND IN LINE WITH REPORTING OBLIGATIONS TO THE STATE'S COURTS AND OFFICIALS, CLEARWAY MINNESOTA REPORTED PAYMENTS TO ORGANIZATIONS ISSUED UNDER RFPS, AND SOME PAYMENTS TO INDIVIDUALS PROVIDED UNDER RFPS, AS "GRANTS," IN LARGE PART TO ENSURE SYNCHRONICITY WITH THE EXPANDED REPORTING ON SUCH "GRANTS" EFFECTED UPON SCHEDULE I AND REPORTING TO THE RAMSEY COUNTY DISTRICT COURT CLEARWAY MINNESOTA MADE ON AN ANNUAL BASIS. HOWEVER, THE CHARACTERIZATION OF THE RECIPIENTS AS GRANTEES RATHER THAN AS PROVIDERS OF SERVICES IN LINE WITH THE "GRANT" PROGRAMS' RFPS WAS ALWAYS AN ISSUE IN PREPARATION OF FORM 990'S PART IX STATEMENT OF FUNCTIONAL EXPENSES, AS THE EXPENDITURES COULD HAVE BEEN REPORTED UPON LINE 11 RATHER THAN LINE 1 (IN THE CASE OF "GRANT" AGREEMENTS WITH ORGANIZATIONS) OR LINE 2 (IN THE CASE OF "GRANT" AGREEMENTS WITH INDIVIDUALS), AND THE EXPANDED REPORTING UPON SAME IN SCHEDULE I. ACCORDINGLY, THE "YES" ANSWER AT PART IV SECTION A LINE 6 IS NOT INDICATIVE OF A VIOLATION OF REG. 1.509(A)-4(I)(2), AS CLEARWAY MINNESOTA RECOGNIZED THAT AS A SUPPORTING ORGANIZATION IT MUST ENGAGE SOLELY IN ACTIVITIES THAT SUPPORTED OR BENEFITED ITS SUPPORTED ORGANIZATION AND DID NOT DEVIATE FROM THIS REQUIREMENT, WHICH PER THE CITED REGULATIONS IN GENERAL MEANS THAT SUPPORTING ORGANIZATIONS ARE ALLOWED TO: - MAKE GRANTS DIRECTLY TO SUPPORTED ORGANIZATIONS; - PROVIDE SERVICES AND FACILITIES DIRECTLY TO ITS SUPPORTED ORGANIZATIONS; - MAKE GRANTS OR PROVIDE SERVICES OR FACILITIES TO EITHER INDIVIDUAL MEMBERS OF THE CHARITABLE CLASS BENEFITED BY ITS SUPPORTED ORGANIZATION OR OTHER SUPPORTING ORGANIZATIONS THAT ALSO SUPPORT OR BENEFIT ITS SUPPORTED ORGANIZATION. CLEARWAY MINNESOTA'S OPERATION OF RFP'S TO EFFECT THE "GRANTS" PROGRAMS EFFECTUATED IN THE SPECIFIC PROGRAM ARENAS NOTED IN THIS FORM'S PART III LINE 4A (AND FULLY DISCUSSED IN FLOW-OVER NARRATION FROM THAT PART TO SCHEDULE O) IS THE METHODOLOGY THAT THE STATE OF MINNESOTA EMBRACED, BOTH WHEN CLEARWAY WAS CREATED AND FUNDED WITH THE STATE OF MINNESOTA'S MONIES AND AS THE STATE CONTINUED TO MAKE GRANTS AND HAVE REPORTING ON SAME PROVIDED BACK TO THE STATE'S COURT AND OFFICIALS. 1873 59704 61577 1174555 1236132 198613 49653 0 0 680169 530519 358914 198613 1768215 2652323 158361 146207 48816 61577 414961 170042 132630 89729 49653 442054 663081 88619 73404 21280 1873 185176 PART II-A - BRIEF DESCRIPTION OF ORGANIZATION'S LOBBYING ACTIVITIES: IN FISCAL YEAR 2022, CLEARWAY MINNESOTA CLOSED DOWN ITS PUBLIC AFFAIRS PROGRAMMING, WHICH INCLUDED LOBBYING. THE ORGANIZATION CONTINUED CONTRACTING WITH LOCKRIDGE, GRINDAL, NAUEN PLLP FOR SERVICES IN LIGHT OF THE ORGANIZATION'S APPROACHING DISSOLUTION, AND AWARDED A GRANT TO THE AMERICAN CANCER SOCIETY CANCER ACTION NETWORK TO SUPPORT GOVERNMENT RELATIONS AND LOBBYING SERVICES FOR THE MINNESOTANS FOR A SMOKE-FREE GENERATION COALITION DURING THE 2022 LEGISLATIVE SESSION. 0 X 7557 0 7557 0 7557 1236132 0 1236132 0 1236132 PART X, LINE 2: FIN 48 (ASC 740) DISCLOSURE FROM AUDITED FINANCIAL STATEMENTS: THE ORGANIZATION IS EXEMPT FROM FEDERAL INCOME TAXES UNDER THE PROVISIONS OF SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE. THE ORGANIZATION IS ALSO EXEMPT FROM MINNESOTA INCOME TAXES. THE ORGANIZATION FOLLOWS THE CURRENT ACCOUNTING GUIDANCE RELATED TO UNCERTAINTY IN INCOME TAXES. THIS GUIDANCE CLARIFIES THE RECOGNITION THRESHOLD AND MEASUREMENT REQUIREMENTS FOR INCOME TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN IN INCOME TAX RETURNS. THIS INCLUDES POSITIONS THAT THE ENTITY IS EXEMPT FROM INCOME TAXES OR NOT SUBJECT TO ADDITIONAL INCOME TAX LIABILITY ON UNRELATED BUSINESS INCOME. UNDER THE STANDARDS, THE ORGANIZATION RECOGNIZES TAX BENEFITS FROM UNCERTAIN TAX POSITIONS ONLY IF IT IS MORE LIKELY THAN NOT THAT THE TAX POSITIONS WILL BE SUSTAINED ON EXAMINATION BY TAXING AUTHORITIES. THE ORGANIZATION HAS IDENTIFIED NO SIGNIFICANT INCOME TAX UNCERTAINTIES. THE ORGANIZATION FILES INFORMATION RETURNS AS A TAX-EXEMPT ORGANIZATION. SHOULD THAT STATUS BE CHALLENGED IN THE FUTURE, ALL YEARS SINCE INCEPTION COULD BE SUBJECT TO REVIEW BY THE IRS. 1 AMERICAN INDIAN CANCER FOUNDATION 3001 BROADWAY ST NE STE 185 MINNEAPOLIS MN 55413 270300026 501C(3) 166220 0 IMPLEMENTATION AWARD FOR THE TRIBAL TOBACCO USE PROJECT-II AMERICAN INDIAN CANCER FOUNDATION 3001 BROADWAY ST NE STE 185 MINNEAPOLIS MN 55413 270300026 501C(3) 13300 0 DISSEMINATION AWARD FOR THE TRIBAL TOBACCO USE PROJECT-II & POWWOW SPONSORSHIP AMERICAN LUNG ASSOCIATION OF THE UPPER MIDWEST 490 CONCORDIA AVENUE ST PAUL MN 55103 204392201 501C(3) 72737 0 LOCAL POLICY CONTRACTOR ASSOCIATION FOR NONSMOKERS-MINNESOTA (ANSR) 2395 UNIVERSITY AVE W STE 310 ST PAUL MN 55114 411410442 501C(3) 101580 0 LOCAL POLICY CONTRACTOR AMERICAN CANCER SOCIETY CANCER ACTION NETWORK 555 11TH ST NW STE 300 WASHINGTON DC 20004 522340031 501C(3) 55000 0 GRANT TO SUPPORT CY'22 LOBBYIST SERVICES ON BEHALF OF THE MINNESOTANS FOR A SMOKE-FREE GENERATION COALITION GRANT-RELATED EXPENSES 33300 0 GRANT-RELATED EXPENSES 4 0 PART I, LINE 2: CLEARWAY MINNESOTA NO LONGER FUNDS ANY CURRENT GRANTS. X X X X 0 0 0 0 0 0 0 0 0 DAVID J WILLOUGHBY CHIEF EXECUTIVE OFFICER 226838 0 0 0 0 0 44972 0 31529 0 303339 0 0 0 MOLLY MOILANEN VICE PRESIDENT - THROUGH 11/30/21 171515 0 0 0 0 0 29690 0 19631 0 220836 0 0 0 LANA KOPYLOV - DIRECTOR OF FINANCE - THROUGH 12/31/2021 137342 0 0 0 0 0 26578 0 18061 0 181981 0 0 0 NICOLE TOVES - DIRECTOR OF HEALTH EQUITY PROGRAMS -THRU 8/31/21 127754 0 0 0 0 0 16988 0 13858 0 158600 0 0 0 JOANNE D'SILVA - DIRECTOR OF HEALTH EQUITY RESEARCH -THRU 8/31/21 136422 0 0 0 0 0 20191 0 978 0 157591 0 0 0 ADAM KINTOPF - DIRECTOR OF STRATEGIC COMMUNICATIONS-THRU 11/21 122668 0 0 0 0 0 17974 0 15833 0 156475 0 0 0 CASH 2022-02-10 26067 ACTUAL VALUE MINNESOTA DEPT OF HEALTH 625 ROBERT STREET N ST PAUL MN 55164 GOVERNMENT 0 0 0 0 1 1 1 1 0 FORM 990, PART IV, LINE 31 CLEARWAY MINNESOTA WAS CREATED TO HAVE A MAXIMUM LIFESPAN OF 25 YEARS, AND SINCE 2009, THE ORGANIZATION HAS CONDUCTED LONG-TERM STRATEGIC PLANNING ACTIVITIES IN PREPARATION FOR ITS END OF LIFE. IN FISCAL YEAR 2021, CLEARWAY MINNESOTA CREATED A DISSOLUTION PLAN ARTICULATING ITS INTENDED CLOSURE ON DECEMBER 31, 2021. IN JUNE OF 2021, THE RAMSEY COUNTY DISTRICT COURT APPROVED CLEARWAY MINNESOTA'S DISSOLUTION PLAN. ALL PROGRAMS HAVE NOW BEEN CLOSED DOWN AND THE ORGANIZATION CEASED OPERATIONS ON DECEMBER 31, 2021. AS OF FEBRUARY 28, 2022, THE ORGANIZATION HAS NO INVESTMENTS REMAINING. AFTER PAYING OR PROVIDING FOR THE PAYMENT OF ALL DEBTS AND EXPENSES OF THE ORGANIZATION, ALL REMAINING ASSETS WERE CONVEYED TO THE STATE OF MINNESOTA TO BE USED FOR TOBACCO PREVENTION IN ACCORDANCE WITH THE REQUIREMENTS OF (A) MINNESOTA STATUTES SECTION 317A.735, AND (B) THE RAMSEY COUNTY DISTRICT COURT. ON FEBRUARY 18, 2022, THE ADMINISTRATOR TRANSFERRED THE REMAINING ASSETS OF THE ORGANIZATION (BEING IN THE FORM OF CASH) IN THE AMOUNT $26,067 TO THE STATE OF MINNESOTA. FORM 990, PART I, LINE 1, DESCRIPTION OF ORGANIZATION MISSION: CLEARWAY MINNESOTA WAS AN INDEPENDENT NONPROFIT ORGANIZATION WORKING TO IMPROVE THE HEALTH OF ALL MINNESOTANS BY ELIMINATING THE HARM CAUSED BY TOBACCO. CLEARWAY MINNESOTA WAS CREATED IN 1998 TO ADMINISTER 3 PERCENT ($202 MILLION) OF MINNESOTA'S TOBACCO SETTLEMENT FUNDS OVER A PERIOD OF NO MORE THAN 25 YEARS. CLEARWAY MINNESOTA'S MISSION WAS TO ENHANCE LIFE FOR ALL MINNESOTANS BY REDUCING TOBACCO USE AND EXPOSURE TO SECONDHAND SMOKE THROUGH RESEARCH, ACTION AND COLLABORATION. THE ORGANIZATION'S WORK WAS GROUNDED IN ESTABLISHED AND EMERGING SCIENCE AND IN PUBLIC HEALTH BEST AND PROMISING PRACTICES. THROUGH FISCAL YEAR 2020, IT INCLUDED A COMPREHENSIVE BODY OF TOBACCO CESSATION PROGRAMS (MARKETED AS QUITPLAN SERVICES), EXTENSIVE GRANT-MAKING ACTIVITIES IN AREAS OF RESEARCH, POLICY AND COMMUNITY DEVELOPMENT, AND MEDIA CAMPAIGNS TO RAISE AWARENESS OF TOBACCO'S HARMS AND TO PROMOTE QUITTING. THE BULK OF ACTIVITIES IN FISCAL YEAR 2021 AND THE FIRST SIX MONTHS OF FISCAL YEAR 2022 (THE FINAL MONTHS OF THE ORGANIZATION'S EXISTENCE) WERE RELATED TO CLOSING DOWN PROGRAMS AND PREPARING TO CEASE OPERATIONS. FORM 990, PART III, LINE 3 CLEARWAY MINNESOTA'S LIMITED LIFETIME ENDED ON DECEMBER 31, 2021. ALL PROGRAMS HAVE BEEN CLOSED DOWN AND OPERATIONS HAVE CEASED. FORM 990, PART VI, SECTION A, LINE 4 ARTICLES OF DISSOLUTION WERE FILED WITH SECRETARY OF STATE OFFICE IN DECEMBER 2021 FORM 990, PART VI, SECTION B, LINE 11B THE IRS FORM 990 AND ATTACHMENTS ARE COMPLETED BY THE INDEPENDENT AUDITOR WITH INPUT FROM CLEARWAY EXECUTIVES AND STAFF. CLEARWAY MINNESOTA CEASED OPERATIONS ON DECEMBER 31, 2021. FINAL REVIEW AND APPROVAL WAS COMPLETED BY J. PATRICK PLUNKETT OF LARKIN HOFFMAN AS ADMINISTRATOR. AS ADMINISTRATOR, MR. PLUNKETT HAS RESPONSIBILITY TO SUBMIT FINAL NECESSARY FILINGS SUCH AS THE FORM 990 AFTER THE ORGANIZATION'S CLOSURE. FORM 990, PART VI, SECTION B, LINE 12C CONFLICTS OF INTEREST, INCLUDING POLICIES RELATING TO LOANS AND GIFTS, WERE GOVERNED BY CLEARWAY MINNESOTA'S CONFLICT OF INTEREST POLICY. ENFORCEMENT OF THE POLICY WAS CONDUCTED BY THE CLEARWAY MINNESOTA BOARD OF DIRECTORS. CLEARWAY MINNESOTA REGULARLY AND CONSISTENTLY MONITORED AND REQUIRED COMPLIANCE WITH ITS CONFLICT OF INTEREST POLICY. THE BOARD REQUIRED EACH BOARD MEMBER AND EMPLOYEE TO BE ADVISED OF THIS POLICY, WHICH WAS PROVIDED TO PERSONNEL IMMEDIATELY UPON ASSUMING THEIR CLEARWAY MINNESOTA DUTIES OR RELATIONSHIP. BOARD AND STAFF MEMBERS WERE PERIODICALLY REMINDED OF THIS POLICY AND EDUCATED CONCERNING ITS APPLICATION. EVERY BOARD MEMBER AND EMPLOYEE WAS RESPONSIBLE FOR KNOWING AND OBSERVING THE POLICY. EACH BOARD MEMBER AND EMPLOYEE WAS REQUIRED TO SUBMIT A CERTIFICATE OF COMPLIANCE ANNUALLY. THE CERTIFICATE OF COMPLIANCE REQUIRED BOARD MEMBERS AND EMPLOYEES TO REVIEW A LIST OF CURRENT CLEARWAY MINNESOTA GRANTEES AND CONTRACTORS AND TO DISCLOSE AFFILIATIONS WITH ANY ORGANIZATIONS THAT HAD GRANTS OR CONTRACTS WITH CLEARWAY MINNESOTA. CLEARWAY MINNESOTA HAD A CONFLICT OF INTEREST SCREENING PROCESS TO IDENTIFY POTENTIAL CONFLICTS INVOLVING APPLICANTS FOR FUNDING THAT HAD NOT HAD A GRANT OR CONTRACT WITH CLEARWAY MINNESOTA DURING THE PREVIOUS YEAR. THIS PROCESS IDENTIFIED POTENTIAL CONFLICTS EARLY IN THE APPLICATION PROCESS IN ORDER TO IMPLEMENT CONFLICT OF INTEREST MITIGATION STRATEGIES THAT MAY BE NECESSARY DURING THE APPLICATION REVIEW PROCESS. BOARD DIRECTORS AND STAFF HAD THE RESPONSIBILITY TO DISCLOSE TO THE ORGANIZATION THE RELEVANT FACTS OF ANY PROPOSED ACTION INVOLVING CLEARWAY MINNESOTA IN WHICH THEY HAD POSSIBLE OR PERCEIVED CONFLICTS AS SOON AS THEY WERE DISCOVERED. FORM 990, PART VI, SECTION B, LINE 15 CLEARWAY MINNESOTA REVIEWED COMPENSATION (SALARY RANGES AND BENEFITS) ON AN ANNUAL BASIS. AT LEAST EVERY TWO YEARS, AN INDEPENDENT COMPENSATION CONSULTANT COMPARED ALL JOBS TO APPLICABLE MARKET SURVEYS TO DETERMINE COMPENSATION COMPETITIVENESS TO THE MARKET. EVERY YEAR, THE CONSULTANT, USING THE MOST RECENT MARKET TRENDS, PROVIDED CLEARWAY MINNESOTA WITH GUIDELINES TO DETERMINE COMPENSATION INCREASES. FROM THESE ANALYSES, PAY RANGE MODIFICATIONS AND THE ANNUAL BUDGETED SALARY MERIT INCREASE PERCENTAGE WERE DETERMINED. THIS INFORMATION WAS REVIEWED BY THE BOARD OF DIRECTORS, WHICH MADE THE FINAL DECISION ON SALARY RANGE LEVELS AND BUDGET AMOUNTS. ALL STAFF SALARY CHANGES, EXCEPT THAT OF THE CHIEF EXECUTIVE OFFICER, WERE REVIEWED AND APPROVED BY THE CHIEF EXECUTIVE OFFICER. JOB PERFORMANCE AND SALARY CHANGES FOR THE CHIEF EXECUTIVE OFFICER WERE REVIEWED AND APPROVED BY THE BOARD OF DIRECTORS. FORM 990, PART VI, SECTION C, LINE 18 IRS FORMS 1023 AND 990 WERE AVAILABLE ON CLEARWAY MINNESOTA'S WEBSITE UNTIL DECEMBER 31, 2021. THEY CAN NOW BE ACCESSED BY CONTACTING ADMINISTRATOR J. PATRICK PLUNKETT COURTESY OF LARKIN HOFFMAN, 8300 NORMAN CENTER DRIVE, SUITE 1000, MINNEAPOLIS, MINNESOTA 55437. FORM 990, PART VI, SECTION C, LINE 19 CLEARWAY MINNESOTA'S GOVERNING DOCUMENTS, INCLUDING ITS CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS, WERE AVAILABLE AT THE CLEARWAY MINNESOTA OFFICE FOR INSPECTION. THEY CAN NOW BE ACCESSED BY CONTACTING ADMINISTRATOR J. PATRICK PLUNKETT COURTESY OF LARKIN HOFFMAN, 8300 NORMAN CENTER DRIVE, SUITE 1000, MINNEAPOLIS, MINNESOTA 55437. FORM 990, PART IX, LINE 11D: SEE SCHEDULE A PART VI, NARRATIVE RELATING TO REPORTING CONTRACTS AS GRANTS (WITH RESPECT TO SCHEDULE A, SECTION A, LINE 6) AND SCHEDULE C PART IV, NARRATIVE RELATING TO LOBBYING ACTIVITIES AND USE OF VENDORS, RELATING TO ABSENCE OF DOLLAR DISCLOSURE. FORM 990, PART IX: THE ORGANIZATION ALLOCATES ITS EXPENSES ON A FUNCTIONAL BASIS AMONG ITS VARIOUS PROGRAMS AND SUPPORT SERVICES. EXPENSES THAT CAN BE IDENTIFIED WITH A SPECIFIC PROGRAM ARE ALLOCATED DIRECTLY ACCORDING TO THEIR NATURAL EXPENDITURE CLASSIFICATION. GENERAL AND ADMINISTRATIVE THAT ARE COMMON TO SEVERAL FUNCTIONS ARE ALLOCATED BASED ON THE PROPORTION OF EACH PROGRAM'S DIRECT AND PERSONNEL EXPENSES TO THE TOTAL PROGRAM DIRECT AND PERSONNEL EXPENSES. AS A RESULT OF THE ORGANIZATION'S LIMITED LIFE STATUS, THE PERCENTAGE OF PROGRAM EXPENSES TO TOTAL EXPENSES HAS DECREASED FOR THE YEAR ENDED FEBRUARY 28, 2022 AS COMPARED TO PREVIOUS YEARS. FORM 990, PART XII, LINE 2C: THE PROCESS HAS NOT CHANGED FROM THE PRIOR YEAR.