2021-09-15T09:45:18-05:00 2020-12-31 203992693 RANDY WALKER & CO 7800 IH 10 WEST STE 505 SAN ANTONIO TX 78230 990 2020-01-01 412046295 THE CITIZENS FOUNDATION USA CITI 8887293022 9494 SOUTHWEST FREEWAY NO 620 HOUSTON TX 77074 ARIF GAFUR PRESIDENT & DIRECTOR 8887293022 2021-09-03 1 ARIF GAFUR 999009999 RANDY L WALKER CPA P00963779 2103669430 2 AAL1 IAL1 2020 2022-09-23 18:48:47Z ARIF GAFUR 9494 SOUTHWEST FREEWAY NO 620 HOUSTON TX 77074 15303430 0 X WWW.TCFUSA.ORG X 2002 IL TCF, USA PROVIDES QUALITY EDUCATION FOR UNDER PRIVILEGED CHILDREN IN PAKISTAN. THE GOAL IS TO BUILD CIVIL SOCIETY AND PROMOTE EQUALITY. 12 12 13 200 0 0 11059741 15132430 0 0 51626 22963 0 0 11111367 15155393 9693319 11575147 0 0 577850 586571 0 0 932655 508770 557767 10779939 12719485 331428 2435908 4042267 6662711 35802 177546 4006465 6485165 X TCF-USA PROVIDES QUALITY EDUCATION FOR UNDERPRIVILEGED CHILDREN IN PAKISTAN, THE GOAL IS TO BUILD CIVIL SOCIETY AND PROMOTE GENDER EQUALITY. AN ALL-FEMALE FACULTY ENCOURAGES PARENTS TO ENROLL THEIR GIRLS, WHILE SIMULTANEOUSLY CREATING EMPLOYMENT OPPORTUNITIES AS TEACHERS AND PRINCIPALS FOR THOUSANDS OF WOMEN. TCF GRADUATES ARE PROVIDED SUPPORT FOR COLLEGE AND VOCATIONAL TRAINING. 0 0 8768636 8768636 ANNUAL OPERATING EXPENSES OF SCHOOLS:IN 2020, TCF-USA RAISED 8.4M USD FROM USA DONORS FOR THE OPERATIONAL SUPPORT OF SCHOOLS IN PAKISTAN, INCLUDING MULTIYEAR SUPPORT, EDUCATING UNDERPRIVILEGED CHILDREN. OPERATIONAL EXPENSES OF RUNNING THE SCHOOL EFFICIENTLY WITH A PRINCIPAL, TRAINED TEACHERS, AND ADMIN STAFF IS COVERED BY THE SUPPORT, INCLUDING THE PICK AND DROP OF ALL FEMALE TEACHERS TO SCHOOLS LOCATED, MAINLY, IN DIFFICULT TO ACCESS AREAS OF THE CITIES OR VILLAGES.HIGHER EDUCATION SCHOLARSHIPS WORTH 0.36M USD WERE ALSO PROVIDED TO SUPPORT STUDENTS. THESE SCHOLARSHIPS INCENTIVIZE STUDENTS AND, BOOSTS SELF-CONFIDENCE AND OPEN DOORS TO PROMISING OPPORTUNITIES. THESE AWARDED STUDENTS TO BECOME ROLE MODELS, NOT ONLY WITHIN THEIR OWN FAMILIES AND SCHOOLS, BUT WITHIN THE COMMUNITIES. 2023865 1978050 CAMPUS CONSTRUCTION:IN 2020, TCF-USA SUPPORTED BUILDING NEW PRIMARY AND SECONDARY SCHOOL UNITS BY RAISING FUND AMOUNTING TO 2.02M USD. THIS HELPED CREATE EDUCATIONAL OPPORTUNITIES FOR UNDERPRIVILEGED CHILDREN IN THE MOST IMPOVERISHED AND REMOTE REGIONS OF PAKISTAN. EACH OF THESE SCHOOLS HAVE A CAPACITY OF 180 STUDENTS. 828461 828461 ENDOWMENTS FOR FUTURE OPERATION OF SCHOOLS: TCF-USA CONTRIBUTES TOWARDS THE ENDOWMENT OF TCF-USA BUILT SCHOOLS. IN 2020, TCF-USA RAISED 0.83M USD UNDER ENDOWMENT FUNDS. THIS ENSURES LONG-TERM SUSTAINABILITY FOR SCHOOLS IN PAKISTAN AND HELPS US TO CONTINUE, YEAR AFTER YEAR, TO PROVIDE QUALITY EDUCATION TO THE UNDERPRIVILEGED CHILDREN. 11620962 1 1 0 0 0 0 0 0 0 1 1 0 0 0 1 1 1 0 0 1 1 1 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 1 9 0 1 13 1 0 0 0 0 0 0 0 0 0 0 0 0 X 12 12 1 0 0 0 1 1 0 1 1 0 1 1 1 1 1 1 1 1 1 1 0 IL NJ X X X RAYOMAND H GHADIALI 8887293022 9494 SOUTHWEST FREEWAY NO 620 HOUSTON TX 77074 FAKHIA RASHID COO & DEVELOPMENT MANAGER 40.00 X 80000 0 0 DANIAL NOORANI DIRECTOR DEVELOPMENT 40.00 X 41200 0 0 RAYOMAND GHADIALI CFO 30.00 X 59950 0 0 JAWAID EKRAM DIRECTOR 2.00 X 0 0 0 ALIA FAIZ DIRECTOR THRU FEB 2020 1.00 X 0 0 0 ABDULLAH JAFARI DIRECTOR 20.00 X 0 0 0 BARBARA JANES DIRECTOR THRU FEB 2020 1.00 X 0 0 0 SHIMMI KIDWAI DIRECTOR 1.00 X 0 0 0 AZHAR HAMEED DIRECTOR 1.00 X 0 0 0 AMJAD NOORANI DIRECTOR 1.00 X 0 0 0 EJAZ A SHAMEEM DIRECTOR 1.00 X 0 0 0 SHAUKAT DHANANI DIRECTOR THRU SEPT 2020 1.00 X 0 0 0 KASHMALA SHARIF DIRECTOR 1.00 X 0 0 0 HAROON ISMAIL DIRECTOR FROM JAN 2020 1.00 X 0 0 0 ADIL NAJAM DIRECTOR FROM JUN 2020 1.00 X 0 0 0 HAJI MODY DIRECTOR & SECRETARY 2.00 X X 0 0 0 FARAZ KHAN DIRECTOR & TREASURER 2.00 X X 0 0 0 ARIF GAFUR PRESIDENT & DIRECTOR 40.00 X X 0 0 0 181150 0 0 0 0 0 0 0 2298378 12834052 223965 15132430 22963 22963 148037 2298378 148037 0 15155393 0 0 22963 11575147 11575147 181151 14257 20090 146804 359664 28327 39860 291477 45756 3231 6550 35975 80513 38014 42499 60658 60658 142090 14082 128008 29711 3806 25905 3286 2926 360 9119 1549 7570 3005 867 2138 2960 2960 5919 2209 3710 CONTRIBUTIONS PROC. FEE 98987 98987 PRINTING, POSTAGE AND D 55801 8 55793 UNCOLLECTABLE EXPENSE 29880 29880 MARKETING - GALA 20832 20832 15006 3067 11939 12719485 11620962 165868 932655 295463 667756 2958974 5264043 177982 53087 31291 24832 6394 6459 452291 465489 151163 205877 4042267 6662711 35802 50546 0 127000 35802 177546 X 2149315 3133358 1857150 3351807 4006465 6485165 4042267 6662711 2435908 42792 0 X X 0 1 X 1 0 X 8577707 8395717 10080513 11059741 15132430 53246108 8577707 8395717 10080513 11059741 15132430 53246108 1931173 51314935 12824 75783 32060 51626 22963 195256 53441364 0.96020 0.99560 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 571497 42377 613874 502110 69387 571497 546584 -44474 502110 1042167 80042 500000 72000 3625 546584 1012254 33747 3834 1042167 0.87780 0.12220 0.00000 1 0 25797 21058 4739 5494 3774 1720 6459 PPP REFUNDABLE ADVANCE 127000 127000 X 15238500 42792 40315 83107 15155393 0 15155393 12759800 40315 40315 12719485 0 12719485 PART V, LINE 4: THE ORGANIZATION'S ENDOWMENT CONSISTS OF INVESTMENT FUNDS ESTABLISHED FOR SUPPORTING ONGOING OPERATIONS AND MAINTENANCE OF SCHOOLS BUILT IN THE AREA IMPACTED BY THE 2005 EARTHQUAKE IN PAKISTAN. INVESTMENT AND SPENDING POLICY. THE ORGANIZATION HAS ADOPTED INVESTMENT POLICIES, APPROVED BY THE BOARD OF DIRECTORS AND INVESTMENT COMMITTEE, FOR ENDOWMENT ASSETS. THE ORGANIZATION WILL INVEST ONLY IN LOW-RISK, CONSERVATIVE INVESTMENT VEHICLES IN ORDER TO MAINTAIN THE PURCHASING POWER OF CURRENT ASSETS AND FUTURE CONTRIBUTIONS IN RELATION TO COST INCREASES AND INFLATION AND MAXIMIZE RETURN WITHIN REASONABLE AND PRUDENT LEVELS OF RISK. INVESTMENT ASSETS ARE INVESTED IN A WELL-DIVERSIFIED ASSET MIX, WHICH INCLUDES EQUITY AND DEBT SECURITIES THAT ARE MANAGED BY THE ORGANIZATION'S INVESTMENT COMMITTEE TO PREVENT EXPOSING THE FUND TO UNACCEPTABLE LEVELS OF RISK. WITH REGARDS TO RETURNS ON ENDOWMENTS, THE ORGANIZATION HAS ADOPTED A SPENDING POLICY WHICH WILL APPLY TO ALL ENDOWED FUNDS UNLESS A PARTICULAR DONOR HAS OTHERWISE STIPULATED SPENDING RESTRICTIONS. THE ORGANIZATION WILL NOT SPEND RETURNS FROM THE ENDOWMENT IF IT FALLS BELOW THE ORIGINAL ENDOWMENT AMOUNT. MANAGEMENT, WITH APPROVAL FROM THE INVESTMENT COMMITTEE, HAS DISCRETION OVER HOW AND WHETHER OR NOT SURPLUS RETURNS ARE USED. PART X, LINE 2: THE ORGANIZATION APPLIES THE PROVISIONS OF FASB ASC TOPIC 740, INCOME TAXES, (FORMERLY FASB INTERPRETATION NO. 48 (FIN 48), ACCOUNTING FOR UNCERTAINTY IN INCOME TAXES - AN INTERPRETATION OF FASB STATEMENT NO. 109), WHICH PRESCRIBES A RECOGNITION THRESHOLD AND MEASUREMENT ATTRIBUTE FOR FINANCIAL STATEMENT RECOGNITION AND MEASUREMENT OF A TAX POSITION TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN. FIN 48 ALSO PROVIDES GUIDANCE ON DE-RECOGNITION, CLASSIFICATION, INTEREST AND PENALTIES, ACCOUNTING IN INTERIM PERIODS, DISCLOSURES AND TRANSITION. THE ORGANIZATION BELIEVES THAT IT HAS APPROPRIATE SUPPORT FOR ANY TAX POSITIONS TAKEN, AND AS SUCH, DOES NOT HAVE ANY UNCERTAIN TAX POSITIONS THAT ARE MATERIAL TO THE FINANCIAL STATEMENTS. 0 SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, 1 2 PROGRAM SERVICES BUILDING & OPERATING; SCHOOLS (KG-10); CONSTRUCTION, OPERATION, ENDOWMENTS 11575147 1 2 0 0 1 2 11575147 0 11575147 SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, SCHOOL OPERATION 6346974 WIRE TRANSFER SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, SCHOOL CONSTRUCTION 1978050 WIRE TRANSFER SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, SCHOOL ENDOWMENT 828461 WIRE TRANSFER SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, SCHOLARSHIPS 333257 WIRE TRANSFER SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, VOCATIONAL TRAINING 36900 WIRE TRANSFER SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, COVID-19 SUPPORT 2024505 WIRE TRANSFER SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, SCHOLARSHIPS 27000 WIRE TRANSFER 2 0 0 0 0 0 0 0 PART I, LINE 2: THE CITIZENS FOUNDATION, USA (TCF-USA) MAINTAINS A HIGH LEVEL OF TRANSPARENCY IN ALL ITS FINANCIAL AND GOVERNANCE DEALINGS AND ADHERES TO A STRICT "DUE DILIGENCE" PROCESS. TO ADDRESS THE US GOVERNMENT'S CONCERN REGARDING ENHANCED SCRUTINY FOR FUNDS THAT GO OUTSIDE THE U.S., ALL RECIPIENTS OF TCF-USA FUNDS HAVE BEEN SELECTED BASED ON THE SECULAR AND SCIENTIFIC EDUCATION THEY ARE PROVIDING TO NEEDY CHILDREN IN SOUTH ASIA. TCF,USA TAKES THE FOLLOWING STEPS FOR DUE DILIGENCE: - COMPLETE BACKGROUND CHECK FOR THE GRANTEE ORGANIZATION'S BOARD AND STAFF MEMBERS USING OFAC LIST. THIS CHECK IS MADE PRIOR TO GRANTING ANY FUNDS. - OBTAINS AN EQUIVALENCY AFFIDAVIT FROM THE FOREIGN CHARITY SHOWING THAT IT'S EQUIVALENT TO A US CHARITY. - FOR PROJECT-RELATED GRANTS, OBTAIN A DETAILED PROPOSAL WITH TIMELINES AND PERIODIC UPDATES UNTIL COMPLETION. - OBTAINS AUDITED ANNUAL REPORTS. ALL TCF SCHOOLS ARE INTERNALLY AUDITED AT LEAST ONCE EACH YEAR AND TCF ACCOUNTS ARE AUDITED BY CHARTERED ACCOUNTING FIRMS OF INTERNATIONAL REPUTE. - OBTAINS BY-LAWS AND ARTICLES OF INCORPORATION OF GRANTEE ORGANIZATION. - SUBMISSION OF ACCEPTANCE AND SIGNED AGREEMENT AS PART OF THE GRANT LETTER BY THE CHIEF EXECUTIVE OFFICER OF THE GRANTEE ORGANIZATION COMPLYING WITH TERMS REGARDING PURPOSE, PUBLICITY, REPORTING, ACCOUNTS, PROHIBITED ACTIVITIES, OVERSIGHT AND COMPLIANCE. - TCF SCHOOLS ARE VISITED PERIODICALLY BY MEMBERS OF THE BOARD OF DIRECTORS AND MANAGEMENT OF TCF-USA AS WELL AS USA DONORS. PART III ACCOUNTING METHOD: FORM 990, SCHEDULE F, PART I, LINE 3, COLUMN (A) REGION: SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, PAKISTAN, AND SRI LANKA. SPECIAL EVENTS 2446415 2298378 148037 148037 2446415 2298378 148037 148037 148037 0 X 24 223965 FAIR MARKET VALUE 0 0 0 PART I, COLUMN (B): THE CITIZENS FOUNDATION, USA (TCF-USA) IS REPORTING THE NUMBER OF CONTRIBUTIONS IN PART I, COLUMN (B). FORM 990, PART I, LINE 1 TCF-USA IS A PROFESSIONALLY MANAGED ORGANIZATION THAT SUPPORTS THE EDUCATION OF UNDERPRIVILEGED CHILDREN IN PAKISTAN. IT HAS AN ACTIVE NETWORK OF OVER 42 CHAPTERS IN STATES ACROSS THE UNITED STATES. TCF-USA THROUGH ITS GRANTS, SUPPORTS SPECIFIC PROGRAMS, INITIATIVES AND PROJECTS OF THE CITIZENS FOUNDATION (TCF) IN PAKISTAN, ONE OF THE LEADING ORGANIZATIONS IN THE FIELD OF EDUCATION IN THAT COUNTRY. TCF HAS BUILT AND OPERATES 1,687 PURPOSE-BUILT SCHOOLS PROVIDING QUALITY EDUCATION TO 275,000 CHILDREN, WITH AN ALL-FEMALE FACULTY OF 12,950 TEACHERS. OUT OF THIS, TCF-USA DONORS HAVE CONTRIBUTED TO BUILD AND SUPPORT OVER 249 OF THESE ELEMENTARY & SECONDARY SCHOOLS WITH AN ENROLLMENT OF 65,000+ BOYS AND GIRLS. TCF-USA HAS CONSISTENTLY MAINTAINED A 4-STAR RATING BY CHARITY NAVIGATOR AND A PLATINUM RANKING BY GUIDESTAR ON GOALS, STRATEGY, COMPLIANCE, FINANCIALS AND MANAGEMENT. GLOBALLY, 2020 HAS BEEN A CHALLENGING YEAR. THE PANDEMIC USHERED IN AN AGE OF SHUTDOWNS AND HYBRID WORKING. ON FUND RAISING, SOCIAL DISTANCING IMPACTED BOTH, ONE ON ONE MEETINGS WITH IMPORTANT DONORS, OR LARGE FUNDRAISING EVENTS WITH GROUPS OF SUPPORTERS. TCF-USA INNOVATED AND ADAPTED TO NOVEL WAYS OF COMMUNICATION WITH LARGE GROUP OF DONORS AND KEEPING OUR GEOGRAPHICAL CHAPTERS ACTIVE. OUR IMPLEMENTATION PARTNERS IN PAKISTAN WAS EQUALLY SUCCESSFUL IN DEVISING DISTANT LEARNING PROGRAMS THAT COULD BE IMPLEMENTED WITHOUT INTERNET/PC ACCESS AVAILABLE TO THE RECIPIENTS. TCF-USA, HAD HISTORICALLY, ORGANIZED LARGE PHYSICAL EVENTS TO COMMUNICATE ABOUT WORK TO OUR SUPPORTERS AND POTENTIAL SUPPORTERS, AND TO PERSUADE THEM TO DONATE TO THE CAUSE. AUDIENCES ARE INSPIRED WHEN THEY HEAR TCF'S STORY AND COME ON-BOARD TO HELP THE CAUSE. WHEN PHYSICAL EVENTS WERE NO LONGER A CHOICE, TCF-USA TRANSITIONED TO VIRTUAL EVENTS, ONLINE PEER TO PEER FUNDRAISING CAMPAIGNS AND INTEGRATING WITH SOCIAL MEDIA. THIS NOT ONLY ENABLED US TO REACH MORE PEOPLE, IT ACTUALLY ALLOWED US TO SIMULTANEOUSLY DECREASE OUR FUNDRAISING EXPENDITURE. TCF-USA WAS ONE OF THE FEW NON-PROFITS WHO ACTUALLY INCREASED REVENUE WHILE LOWERING FUNDRAISING EXPENSES DURING THE PANDEMIC. THE SAVINGS ALLOWED US TO MOBILIZE MORE FUNDS TO OUR EDUCATION PROGRAMS. ON THE PROGRAM END, TCF'S SOLUTION TO REACH ITS STUDENTS WAS THROUGH MASS COMMUNICATION METHODS LIKE RADIO AND TELEVISION PROGRAMS. TCF DESIGNED AND CREATED STRUCTURED PROGRAMS WITH CUSTOMIZED CONTENT THAT WERE BROADCASTED TO A LARGE AUDIENCE. SECTION 1.263(A)-1(F) DE MINIMIS SAFE HARBOR ELECTION THE CITIZENS FOUNDATION, USA 9494 SOUTHWEST FWY, SUITE 620 HOUSTON, TX 77074 EMPLOYER IDENTIFICATION NUMBER: 41-2046295 FOR THE YEAR ENDING DECEMBER 31, 2020 THE CITIZENS FOUNDATION, USA IS MAKING THE DE MINIMIS SAFE HARBOR ELECTION UNDER REG. SEC. 1.263 A)-1(F). FORM 990, PART VI, SECTION A, LINE 2 DANIAL NOORANI, DIRECTOR DEVELOPMENT AND AMJAD NOORANI, DIRECTOR, HAVE A FAMILY RELATIONSHIP. FORM 990, PART VI, SECTION A, LINE 6 THE CITIZENS FOUNDATION, USA HAS AN INDEPENDENT BOARD OF GOVERNING BODY, SEE 990 PART VII. THE BOARD ELECTS ONE OR MORE OTHER QUALIFIED MEMBERS FROM VARIOUS SOURCES. ALL DECISIONS OF THE GOVERNING BODY ARE SUBJECT TO APPROVAL BY THE MAJORITY OF VOTES OF THE MEMBERS IN THE BOARD MEETINGS. FORM 990, PART VI, SECTION A, LINE 7A THE BOARD SHALL BY MAJORITY VOTE DESIGNATE A GOVERNANCE & NOMINATING COMMITTEE OF THREE OR MORE MEMBERS, COMPRISING OF AT LEAST TWO DIRECTORS OF THE BOARD. A MEMBER OF THE BOARD, WHOSE TERM OF MEMBERSHIP IS EXPIRING AND WHO IS ELIGIBLE FOR RE-ELECTION, SHALL NOT BE APPOINTED TO THE GOVERNANCE & NOMINATING COMMITTEE. THE GOVERNANCE & NOMINATING COMMITTEE SHALL SUBMIT A SLATE OF CANDIDATES TO THE BOARD FOR ACCEPTANCE AT A REGULAR MEETING OF THE BOARD. FORM 990, PART VI, SECTION B, LINE 11B THE COMPLETED FORM 990 IS REVIEWED BY THE CEO, TREASURER AND FINANCE & AUDIT COMMITTEE AND CIRCULATED TO BOARD MEMBERS PRIOR TO FINAL SUBMITTAL. FORM 990, PART VI, SECTION B, LINE 12C THE CITIZENS FOUNDATION HAS INCORPORATED ITS CONFLICT OF INTEREST POLICY IN ARTICLE 9 OF ITS BYLAWS. THE CEO MONITORS THE COMPLIANCE AND ENFORCEMENT OF THE POLICY BY KEY EMPLOYEES, AND THE BOARD PRESIDENT MONITORS AND ENFORCES COMPLIANCE BY THE DIRECTORS, IN ACCORDANCE WITH THE BYLAWS. FORM 990, PART VI, SECTION B, LINE 15 THE CITIZENS FOUNDATION, USA [TCF-USA] BOARD REVIEWS AND APPROVES THE COMPENSATION FOR THEIR CEO AND OTHER KEY EMPLOYEES. TCF-USA USES NON-PROFIT INDUSTRY SALARY BENCHMARKING STUDIES TO ESTABLISH COMPENSATIONS FOR ALL EMPLOYEES. THEY ALSO KEEP CONTEMPORANEOUS DOCUMENTATION AND RECORDKEEPING WITH RESPECT TO DELIBERATIONS REGARDING THE COMPENSATION ARRANGEMENTS. FORM 990, PART VI, SECTION C, LINE 19 THE CITIZENS FOUNDATION, USA [TCF-USA] MAKES AVAILABLE ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND AUDITED FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC UPON REQUEST AT ITS CORPORATE OFFICE. FORM 990, PART XII, LINE 2C THE ORGANIZATION'S PROCESS FOR ASSUMING RESPONSIBILITY FOR OVERSIGHT OF THE AUDIT, REVIEW, OR COMPILATION OF ITS FINANCIAL STATEMENTS AND THE SELECTION OF AN INDEPENDENT AUDITOR HAVE NOT CHANGED FROM THE PRIOR YEAR.