2025-07-09T16:47:01-05:00 2024-08-31 410746749 CLIFTONLARSONALLEN 901 N GLEBE ROAD SUITE 200 ARLINGTON VA 22203 990 2023-09-01 521001304 AMERICAN BANKERS ASSOCIATION AMER 2026635054 1333 NEW HAMPSHIRE AVE NW WASHINGTON DC 20036 KARIN PETERSEN FLYNN CFAO 2026635054 2025-07-09 1 0 AMY CHAPMAN P00843460 5712279500 2025-07-09 2023 2025-03-06 01:10:19Z ROBERT S NICHOLS 1333 NEW HAMPSHIRE AVE NW WASHINGTON DC 20036 244661976 0 X WWW.ABA.COM X 1875 DC PROVIDE ADVOCACY, EDUCATION, & SOLUTIONS TO ITS MEMBERS AND THE FINANCIAL SERVICES INDUSTRY 24 23 400 1200 1276200 94315 589673 3291201 93310304 96493497 15304336 31486288 41454770 44149619 150659083 175420605 299982 206846 0 0 78097222 83118821 0 0 0 59237803 65783451 137635007 149109118 13024076 26311487 782282636 903374225 168907744 182879576 613374892 720494649 X SEE SCHEDULE OTHE ABA'S MISSION IS TO BE A MEMBER-FOCUSED ORGANIZATION THAT PROVIDES ADVOCACY, EDUCATION, BUSINESS SOLUTIONS, AND FORUMS FOR AN EXCHANGE OF VIEWS AND INFORMATION THAT ASSISTS OUR MEMBERS IN PROVIDING FINANCIAL SERVICES TO THEIR COMMUNITIES IN COMPLIANCE WITH THE COMPLEX AND CHALLENGING REGULATORY AND STATUTORY ENVIRONMENT THAT GOVERNS THEIR OPERATIONS. 0 0 CONVENTION, CONFERENCES, SCHOOLS, PROFESSIONAL CERTIFICATIONS AND REMOTE LEARNING OPPORTUNITIES:THE FINANCIAL SERVICES INDUSTRY IS A HIGHLY REGULATED INDUSTRY THAT REQUIRES CONSTANT EDUCATION ON THE CHANGING RULES INCLUDING NEW OR ENHANCED REGULATION, SUPERVISION AND OVERSIGHT. ABA OFFERS OPPORTUNITIES FOR GAINING INSIGHT AND GREATER UNDERSTANDING THROUGH IN-PERSON AND VIRTUAL MEETINGS, ONSITE SCHOOLS, CERTIFICATIONS AND AT-THE-DESK OFFERINGS INCLUDING WEBINARS AND INTERNET CLASSES. MEMBERSHIP RELATIONS AND COMMUNICATIONS:ABA OUTREACHES TO ITS MEMBERSHIP THROUGH A NUMBER OF COMMUNICATION TOOLS INCLUDING DAILY EMAIL NEWS, WEEKLY SUMMARIES, ITS WEBSITE, AND BRIEFINGS ON THE CHANGING ADVOCACY AND REGULATORY ISSUES. THESE EFFORTS FACILITATE THE DEVELOPMENT OF ABA'S POLICY POSITIONS AND PROVIDE THE MEMBERSHIP AND OTHERS WITH THE BACKGROUND AND TOOLS FOR FURTHER USE IN THEIR LOCAL COMMUNITIES. PUBLICATIONS, PRODUCTS AND SERVICES:THE ABA OFFERS BOOKS, TOOL KITS, SEVERAL MAGAZINES, E-BULLETINS, AND A VARIETY OF PRODUCTS AND SERVICES IN AN EFFORT TO EDUCATE AND FACILITATE THE CONTINUED COMPLIANCE AND COMPETITIVENESS OF THE INDUSTRY IT SERVES. 0 1 1 1 0 0 0 0 1 1 0 0 1 1 1 0 1 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 1 1 1 1 0 1 314 0 1 400 1 1 1 0 0 0 1 1 0 1 0 X 24 23 0 0 0 0 1 1 1 1 1 0 0 1 1 1 1 1 1 1 1 1 1 X CRYSTAL REDDING CFO 2026635384 1333 NEW HAMPSHIRE AVENUE NORTHWEST WASHINGTON DC 20036 ROBERT S NICHOLS PRESIDENT AND CEO 36.50 1.00 X X 5041890 0 86618 JULIEANN M THURLOW CHAIR 1.00 0.00 X X 0 0 0 JOHN C ASBURY CHAIR ELECT 1.00 0.00 X X 0 0 0 KENNETH KELLY VICE CHAIR 1.00 0.00 X X 0 0 0 CARISSA RODEHEAVER TREASURER 1.00 0.00 X X 0 0 0 DANIEL D ROBB CHAIR, NOMINATING COMMITTEE 1.00 0.00 X 0 0 0 SARAH A LONG CHAIR, ABA/STATE ASSOCIATION ALLIANCE 1.00 0.00 X 0 0 0 RICK CLAYBURGH VICE CHAIR, ABA/STATE ASSOCIATION ALLIANCE 1.00 0.00 X 0 0 0 GARY R SHOOK CHAIR, GOVERNMENT RELATIONS COUNCIL 1.00 0.00 X 0 0 0 BRENT BEARDALL BOARD MEMBER 1.00 0.00 X 0 0 0 CHERYL D BOWERS BOARD MEMBER 1.00 0.00 X 0 0 0 BRYAN D BRUNS BOARD MEMBER 1.00 0.00 X 0 0 0 JOHN R CIULLA BOARD MEMBER 1.00 0.00 X 0 0 0 SIMON CRUZ BOARD MEMBER 1.00 0.00 X 0 0 0 JOHN F HALL BOARD MEMBER 1.00 0.00 X 0 0 0 SALEEM IQBAL BOARD MEMBER 1.00 0.00 X 0 0 0 TIMOTHY MARSHALL BOARD MEMBER 1.00 0.00 X 0 0 0 JAMES J MCQUADE BOARD MEMBER 1.00 0.00 X 0 0 0 LARRY W MYERS BOARD MEMBER 1.00 0.00 X 0 0 0 DAVID D NELSON BOARD MEMBER 1.00 0.00 X 0 0 0 CHRISTIE HUBER OBENAUER BOARD MEMBER 1.00 0.00 X 0 0 0 JENNIFER PIEPSZAK BOARD MEMBER 1.00 0.00 X 0 0 0 JIM RYAN BOARD MEMBER 1.00 0.00 X 0 0 0 K WAYNE WICKER BOARD MEMBER 1.00 0.00 X 0 0 0 A SCOTT ANDERSON BOARD MEMBER - UNTIL SEP. 2023 1.00 0.00 X 0 0 0 FRED L GREEN III BOARD MEMBER - UNTIL SEP. 2023 1.00 0.00 X 0 0 0 CATHERINE OWEN BOARD MEMBER - UNTIL SEP. 2023 1.00 0.00 X 0 0 0 ANDREW ANDERSON BOARD MEMBER - UNTIL SEP. 2023 1.00 0.00 X 0 0 0 JAMES S MAHAN III BOARD MEMBER - UNTIL SEP. 2023 1.00 0.00 X 0 0 0 MICHAEL RAUH JR BOARD MEMBER - UNTIL SEP. 2023 1.00 0.00 X 0 0 0 IRA ROBBINS BOARD MEMBER - UNTIL SEP. 2023 1.00 0.00 X 0 0 0 KEVIN SABIN BOARD MEMBER - UNTIL SEP. 2023 1.00 0.00 X 0 0 0 KARIN PETERSEN FLYNN CHEIF FINANCE AND AMINISTRATION OFFICER 33.50 4.00 X 629792 0 119748 NAOMI CAMPER CHIEF POLICY OFFICER 37.50 0.00 X 1235205 0 85278 PETER C COOK CHIEF COMMUNICATION OFFICE 36.50 1.00 X 620612 0 81212 ALETHIA BAGGETT CHIEF HR OFFICER 37.50 0.00 X 559685 0 88637 THOMAS PINDER GENERAL COUNSEL & CORP. SE 37.50 0.00 X 548100 0 69311 LAENA F POMEROY CHIEF OF STAFF 37.50 0.00 X 432484 0 84101 VIRGINIA O'NEILL EVP, REGULATORY COMPLIANCE 37.50 0.00 X 542197 0 45822 JESS SHARP EXECUTIVE VICE PRESIDENT 37.50 0.00 X 669700 0 86618 KIRSTEN SUTTON EVP, CONGRESSIONAL RELATIO 37.50 0.00 X 532960 0 65482 SAYEE SRINIVASAN CHIEF ECONOMIST 37.50 0.00 X 502655 0 84109 RUSSELL DAVIS EVP, MEMBER EXPERIENCE 37.50 0.00 X 483801 0 82847 JAMES G EDRINGTON EXECUTIVE VP - UNTIL JUNE 2023 37.50 0.00 X 416724 0 41219 12215805 0 1021002 239 1 1 0 OUTTEN & GOLDEN LLP 685 THIRD AVENUE 25TH FLOOR NEW YORK NY 10017 LEGAL 2500000 JONES DAY 51 LOUISIANA AVENUE NW WASHINGTON DC 20001 LEGAL 1406506 MORRISON & FOERSTER LLP PO BOX 742335 LOS ANGELES CA 90074 CONSULTING 1132738 KEYBRIDGE RESEARCH LLC 3050 K STREET NW SUITE 220 WASHINGTON DC 20007 CONSULTING 551847 REVOLUTION MEDIA GROUP 500 MONTGOMERY ST STE 260 ALEXANDRIA VA 22314 ADVERTISING 520000 33 3291201 3291201 MEMBERSHIP DUES 813910 46063510 46063510 SCHOOLS & TRAINING 813910 21673172 21668172 5000 CONFERENCES & CONVENTION 813910 13508051 8245351 5262700 ALL OTHER PROGRAMS 813910 9135603 7796903 1276200 62500 PROFESSIONAL CERTIFICATIONS 813910 5479020 5479020 634141 614362 19779 96493497 18623063 18623063 44149619 44149619 82104596 69241371 12863225 12863225 12863225 175420605 89867318 1276200 80985886 206846 10044720 57852237 6176102 4996509 4049253 7395813 167464 2385281 498133 12639097 4673045 1705530 8830000 1376651 4752142 3964070 12602080 1888751 581966 TAXES AND FEES 1468491 CORPORATE MEMBERSHIPS 558362 TRAINING COURSE CONTENT 494049 OVERHEAD ALLOCATION -984013 786539 149109118 43692044 55599197 11089729 12357260 3885793 4713923 31259040 10329609 22375504 20929431 620704545 717450243 5945364 20910977 74589657 71413194 782282636 903374225 19990690 23873382 47908603 52809496 101008451 106196698 168907744 182879576 X 609550360 715419845 3824532 5074804 613374892 720494649 782282636 903374225 X 26311487 81733750 -925480 X 0 1 X 1 0 RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 1213720 1213720 1213720 1 0 0 1 52307482 6998708 -4279026 2719682 7952013 -5232331 PART I-A, LINE 1: THE ORGANIZATION'S POLITICAL CAMPAIGN ACTIVITIES DURING THE TAX YEAR CONSISTED OF INDEPENDENT ADVERTISING CAMPAIGNS IN SUPPORT OF VARIOUS CANDIDATES FOR PUBLIC OFFICE. FOR LOBBY REPORTING WE ADDED AN ADDITIONAL $1,399,566 OF SERVICE MEMBERSHIPS, $1,618,701 OF VOTER EDUCATION FUND CONTRIBUTIONS AND $3,205,705 OF NON-DEDUCTIBLE SPECIAL ASSESSMENTS WHICH IS INCLUDED IN PART VIII, LINE 2F "ALL OTHER PROGRAM SERVICE FEE REVENUE" 459043517 84035934 543079451 429636638 29406879 459043517 1.00000 0.00000 0.00000 0 0 13761587 1573974 12187613 13859363 8074073 5785290 3638090 681562 2956528 20929431 RECEIVABLES FROM RELATED ORGANIZATION 2163294 LIFE INSURANCE POLICIES 28157890 RIGHT OF USE ASSETS 41092010 71413194 ACCRUED PENSION LIABILITY 29833025 DEFERRED COMPENSATION 7318510 OPERATING LEASE LIABILITY 69045163 106196698 X PART V, LINE 4: THE PURPOSE OF THE REVENUE PRESERVATION FUND IS TO PROVIDE STABLE FUNDING SHOULD FUTURE OPERATING BUDGETS HAVE A SIGNIFICANT DECLINE IN REVENUE STREAMS. PART X, LINE 2: MANAGEMENT EVALUATED THE ASSOCIATION'S TAX POSITIONS AND CONCLUDED THAT THE ASSOCIATION HAS TAKEN NO UNCERTAIN TAX POSITIONS THAT REQUIRE ADJUSTMENT TO THE CONSOLIDATED FINANCIAL STATEMENTS TO COMPLY WITH THE PROVISIONS OF THE GUIDANCE. GENERALLY, THE ASSOCIATION IS NO LONGER SUBJECT TO INCOME TAX EXAMINATIONS BY THE U.S. FEDERAL, STATE, OR LOCAL TAX AUTHORITIES FOR YEARS BEFORE 2021. 0 TAX FOUNDATION 1325 G STREET NW SUITE 950 WASHINGTON DC 20005 521703065 501(C)3 35000 0 N/A N/A GENERAL SUPPORT FOR 2024 BIPARTISAN POLICY CENTER INC 1225 EYE STREET NW SUITE 1000 WASHINGTON DC 20005 731628382 501(C)3 25000 0 N/A N/A SUPPORT INDEPENDENT RESEARCH AND POLICY WORK CAPSTONE COMMUNITY ACTION INC 20 GABLE PL BARRE VT 05641 030216254 501(C)3 25000 0 N/A N/A SUPPORT VERMONT MAIN STREET FLOOD RECOVERY FUND CHILDREN'S HOSPITAL FOUNDATION 1 INVENTA PLACE 6TH FLOOR WEST SILVER SPRING MD 20910 521640402 501(C)3 22500 0 N/A N/A SPONSORSHIP FOR 2024 CHILDREN'S BALL CENTER FOR LAW AND POLICY 1747 PENNSYLVANIA AVENUE SUITE 800 WASHINGTON DC 20006 854286787 501(C)3 15000 0 N/A N/A GENERAL SUPPORT FOR 2024 EASTER SEALS SERVING DC MD VA 1420 SPRING STREET SILVER SPRING MD 20910 530212296 501(C)3 12500 0 N/A N/A SUPPORT 2024 ADVOCACY AWARDS SPLASHES OF HOPE PO BOX 537 HUNTINGTON NY 11743 113355542 501(C)3 12000 0 N/A N/A SUPPORT PAINTING EVENT 'PAINTING FOR A PURPOSE' KENTUCKY BANKERS RELIEF FUND COMPANY 600 W MAIN STREET SUITE 400 LOUISVILLE KY 40202 203405062 501(C)3 10000 0 N/A N/A SUPPORT DISASTER RELIEF FUND FOR TORNADOS AT ARKANSAS THE URBAN INSTITUTE 500 LENFANT PLAZA SW WASHINGTON DC 20024 520880375 501(C)3 10000 0 N/A N/A MEMBERSHIP DUES AND SUPPORT THROUGH THE HOUSING FINANCE INNOVATION FORUM (HFIF) NATIONAL HOUSING CONFERENCE 1900 M STREET NW SUITE 550 WASHINGTON DC 20036 530208180 501(C)3 8900 0 N/A N/A MEMBERSHIP DUES FOR GENERAL SUPPORT 10 0 X X X X 1 1 X X X X 0 1 0 ROBERT S NICHOLS PRESIDENT AND CEO 1986979 0 2570000 0 484911 0 39600 0 47018 0 5128508 0 0 0 NAOMI CAMPER CHIEF POLICY OFFICER 711861 0 144215 0 379129 0 39600 0 45678 0 1320483 0 0 0 JESS SHARP EXECUTIVE VICE PRESIDENT 550721 0 115363 0 3616 0 39600 0 47018 0 756318 0 0 0 KARIN PETERSEN FLYNN CHEIF FINANCE AND AMINISTRATION OFFI 508842 0 103880 0 17070 0 75209 0 44539 0 749540 0 0 0 PETER C COOK CHIEF COMMUNICATION OFFICE 481246 0 96838 0 42528 0 39600 0 41612 0 701824 0 0 0 ALETHIA BAGGETT CHIEF HR OFFICER 428839 0 88192 0 42654 0 39600 0 49037 0 648322 0 0 0 THOMAS PINDER GENERAL COUNSEL & CORP. SE 449537 0 88192 0 10371 0 64979 0 4332 0 617411 0 0 0 KIRSTEN SUTTON EVP, CONGRESSIONAL RELATIO 438926 0 91142 0 2892 0 39600 0 25882 0 598442 0 0 0 VIRGINIA O'NEILL EVP, REGULATORY COMPLIANCE 440617 0 93000 0 8580 0 39600 0 6222 0 588019 0 0 0 SAYEE SRINIVASAN CHIEF ECONOMIST 410307 0 87078 0 5270 0 39600 0 44509 0 586764 0 0 0 RUSSELL DAVIS EVP, MEMBER EXPERIENCE 399272 0 81260 0 3269 0 39600 0 43247 0 566648 0 0 0 LAENA F POMEROY CHIEF OF STAFF 344446 0 87000 0 1038 0 39600 0 44501 0 516585 0 0 0 JAMES G EDRINGTON EXECUTIVE VP - UNTIL JUNE 2023 225194 0 0 0 191530 0 30238 0 10981 0 457943 0 0 0 PART I, LINE 1A FIRST-CLASS TRAVEL & TRAVEL FOR COMPANIONS: CERTAIN OFFICERS OF THE ORGANIZATION (FIVE IN TOTAL) ARE ALLOWED TO FLY FIRST CLASS AND MAY BRING A COMPANION AT THEIR DISCRETION. ANY SUCH TRAVEL FOR A NON-EMPLOYEE REIMBURSED BY ABA IS INCLUDED IN TAXABLE INCOME OF EMPLOYEE. TAX INDEMNIFICATION AND GROSS-UP PAYMENTS: CERTAIN MEMBERS OF EXECUTIVE LEADERSHIP INVOLVED IN SERP'S (DESCRIBED IN 4B BELOW) HAVE VESTED BUT UNPAID AMOUNTS INCLUDED IN COMPENSATION. A GROSS UP OF 12.25% OF THE TAXABLE AMOUNT IS PAID TO THE EXECUTIVE. SOCIAL CLUB DUES: SOCIAL CLUB DUES ARE PROVIDED FOR BUSINESS USE ONLY. PART I, LINE 4B DEFINED CONTRIBUTION PLANS SPONSORED BY THE ASSOCIATION. THE FOLLOWING OFFICERS, KEY EMPLOYEES, AND HIGHEST COMPENSATED EMPLOYEES PARTICIPATED IN A NONQUALIFIED SUPPLEMENTAL EMPLOYEE RETIREMENT PLAN WITH ACCRUED PRESENT VALUE ESTIMATED BENEFITS FOR THE YEAR: ROBERT S. NICHOLS $508,800 KARIN PETERSEN FLYNN $35,609 NAOMI G. CAMPER $64,812 PETER COOK $30,940 ALETHIA BAGGETT $24,251 LAENA F. POMEROY $13,736 THOMAS PINDER $25,379 FORM 990, PART VI, SECTION A, LINE 1A AUTHORITY AND COMPOSITION: THE EXECUTIVE COMMITTEE IS ACCOUNTABLE TO THE BOARD OF DIRECTORS. IT HAS AUTHORITY TO ACT IN PLACE OF THE BOARD BETWEEN MEETINGS OF THE BOARD, SUBJECT TO THE LIMITATIONS IN THE BYLAWS OR OTHER RESTRICTIONS ESTABLISHED BY THE BOARD. THE MEMBERS OF THE EXECUTIVE COMMITTEE ARE: THE CHAIRMAN, THE CHAIRMAN-ELECT, THE VICE CHAIRMAN, THE TREASURER, THE PRESIDENT AND CEO, THE CHAIRMAN OF THE ASSOCIATION'S GOVERNMENT RELATIONS COUNCIL, AND THE VICE CHAIRMAN OF THE GRC. ADDITIONALLY, A MEMBER OF THE BOARD OF DIRECTORS WHO REPRESENT AN INSTITUTION WITH A MUTUAL FORM OF CHARTER WILL BE ADDED TO THE EXECUTIVE COMMITTEE IF NO OTHER MEMBER OF THE EXECUTIVE COMMITTEE REPRESENTS A REGULAR MEMBER THAT IS ORGANIZED UNDER THAT FORM OF CHARTER. FORM 990, PART VI, SECTION A, LINE 6 THE AMERICAN BANKERS ASSOCIATION (ABA) IS A 501(C)(6) NONPROFIT BUSINESS LEAGUE INCORPORATED IN THE DISTRICT OF COLUMBIA. ITS MEMBERSHIP IS COMPOSED OF NATIONAL BANKS, STATE-CHARTERED BANKS, SAVINGS BANKS, SAVINGS AND LOAN ASSOCIATIONS, TRUST COMPANIES, AND OTHER BANKING ENTITIES SITUATED WITHIN THE UNITED STATES AND ITS DEPENDENCIES, THAT HAVE FILED AN APPLICATION FOR FEDERAL DEPOSIT INSURANCE CORPORATION INSURANCE OF ACCOUNTS ("REGULAR MEMBERS"). FORM 990, PART VI, SECTION A, LINE 7A MEMBERS OF THE ABA ANNUALLY ELECT THE ORGANIZATION'S OFFICERS AND BOARD OF DIRECTORS, WHICH ACTS AS THE ASSOCIATION'S GOVERNING BODY. FORM 990, PART VI, SECTION A, LINE 7B IN ADDITION TO THE ANNUAL ELECTIONS, MEMBERS VOTE ON MAJOR CORPORATE ACTIONS SUCH AS A MERGER OR ACQUISITION AND IN THE EVENT OF A POSSIBLE DISSOLUTION. FORM 990, PART VI, SECTION B, LINE 11B ABA'S MANAGEMENT, WHICH INCLUDES CERTIFIED PUBLIC ACCOUNTANTS, CONDUCTED SEVERAL INTERNAL REVIEWS OF THE FORM 990 RETURN PREPARED BY AN OUTSIDE ACCOUNTING FIRM. A COPY OF THE FORM 990 INCLUDING ALL REQUIRED SCHEDULES WAS PROVIDED TO THE AUDIT COMMITTEE OF THE ABA IN ELECTRONIC FORM PRIOR TO ITS FILING WITH THE IRS. PER ABA BOARD ADOPTED POLICY, THE AUDIT COMMITTEE WAS DELEGATED THE RESPONSIBILITY FOR REVIEWING THE TAX RETURN IN ADVANCE OF ITS FILING. THE AUDIT COMMITTEE REPORTS TO THE ASSOCIATION'S GOVERNING BODY AND IS COMPRISED OF BOARD OF DIRECTOR MEMBERS. THE RETURN WILL BE AVAILABLE TO THE FULL BOARD PRIOR TO FILING. FORM 990, PART VI, SECTION B, LINE 12C ABA MONITORS AND ENFORCES ITS CONFLICTS OF INTEREST POLICY BY, AT LEAST ANNUALLY, HAVING EACH OFFICER, MEMBER OF THE BOARD OF DIRECTORS, AND ALL EMPLOYEES ATTEST BY SIGNATURE THAT THEY HAVE READ, UNDERSTAND, AND ARE IN COMPLIANCE WITH THE POLICY. ON AN ANNUAL BASIS, THE BOARD IS PROVIDED A COPY OF THE POLICY, OFFERED AN OPPORTUNITY TO DISCUSS ITS REQUIREMENTS, AND HAVE ANY QUESTIONS ANSWERED. STAFF ATTENDS THE MEETINGS OF THE BOARD IN ORDER TO MONITOR COMPLIANCE WITH THE REQUIREMENTS AND THAT THE MINUTES OF THE MEETINGS FAIRLY REPRESENT THE DISCUSSIONS OF THE BOARD. FORM 990, PART VI, SECTION B, LINE 15 ABA'S COMPENSATION COMMITTEE, COMPRISED OF BOARD OF DIRECTOR MEMBERS, IS RESPONSIBLE FOR REVIEWING THE COMPENSATION OF THE ASSOCIATION'S CEO, ITS OTHER OFFICERS AND ITS KEY EMPLOYEES AND MAKES THE FINAL COMPENSATION RECOMMENDATION TO THE BOARD OF DIRECTORS, WHICH HAS FINAL APPROVAL. THE PROCESS USED BY THE COMPENSATION COMMITTEE IS MADE IN CONJUNCTION WITH AN OUTSIDE INDEPENDENT CONSULTING FIRM THAT CONDUCTED A COMPREHENSIVE COMPENSATION STUDY FOR THE ASSOCIATION. THE METHODOLOGY USED INCLUDED THE FOLLOWING: - UTILIZING SALARY SURVEYS, INCLUDING THOSE FROM MERCER, WATSON WYATT, PRM CONSULTING, QUATT ASSOCIATES AND ASAE, JOBS WERE BENCHMARKED TO COMPARABLE POSITIONS. - THE OUTSIDE COMPENSATION CONSULTING FIRM REVIEWED APPLICABLE MARKET DATA AND THE BENCHMARKED POSITION INFORMATION AND DEVELOPED A MARKET-BASED PAY STRUCTURE. - ADDITIONAL FACTORS CONSIDERED WERE POSITION REQUIREMENTS, ORGANIZATIONAL IMPACT, AND JOB COMPLEXITY. - MINUTES ARE KEPT OF THE COMPENSATION COMMITTEE'S DELIBERATIONS AND DECISIONS REGARDING COMPENSATION ARRANGEMENTS. THE PROCESS DESCRIBED HERE WAS LAST COMPLETED IN 2023. FORM 990, PART VI, SECTION C, LINE 19 ABA DOES NOT MAKE ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, OR ITS FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC. THE ORGANIZATION'S FORM 990 IS AVAILABLE FOR PUBLIC INSPECTION UPON REQUEST. FORM 990, PART XI, LINE 9: PENSION RELATED CHANGES DUE TO CHANGES IN ACTUARIAL ASSUMPTIONS -925,480. 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