2020-06-03T16:49:31-05:00 2019-09-30 PricewaterhouseCoopers LLP 600 13TH STREET NW STE 1000 WASHINGTON DC 20005 990 2018-10-01 541558882 CNA CORPORATION % DONALD DEBUCK CNAC 7038242000 3003 WASHINGTON BOULEVARD ARLINGTON VA 22201 DONALD DEBUCK CFO 7038242022 2020-06-03 true TRAVIS L PATTON P00369623 2024141000 2020-06-01 155.201.35.117 52580220201555000000 2020-06-03 P 0EBABC6EBE59E07D7A0B0201016F629EF3516635 5158B7CCA2E78A19819A49449AEA5E8F0A6DDA05 2018 2021-01-29 14:40:06Z KATHERINE MCGRADY 3003 WASHINGTON BOULEVARD ARLINGTON VA 22201 127967093 false X WWW.CNA.ORG X 1942 VA RESEARCH ORGANIZATION THAT SPECIALIZES IN OBJECTIVE, EMPIRICAL RESEARCH AND ANALYSIS TO HELP DECISION MAKERS DEVELOP POLICIES, MAKE INFORMED DECISIONS, AND MANAGE PROBLEMS. 12 11 722 0 0 0 122044106 123773109 0 0 1760218 559867 0 0 123804324 124332976 0 0 0 0 90840347 91998330 0 0 0 31058802 31387140 121899149 123385470 1905175 947506 73165884 76522100 21780732 22973747 51385152 53548353 X CNA IS A NON-PROFIT RESEARCH ORGANIZATION THAT OPERATES THE CENTER FOR NAVAL ANALYSES, A FEDERALLY FUNDED RESEARCH CENTER THAT HAS SUPPORTED THE NAVY AND MARINE CORPS FOR NEARLY SEVENTY YEARS, AND THE INSTITUTE FOR PUBLIC RESEARCH THAT PROVIDES SUPPORT TO A BROAD RANGE OF GOVERNMENT CLIENTS IN EDUCATION, HEALTH CARE AND PUBLIC HEALTH, HOMELAND SECURITY, HUMAN CAPITAL MANAGEMENT AND AIR TRAFFIC MANAGEMENT. CNA SPECIALIZES IN OBJECTIVE, EMPIRICAL RESEARCH AND ANALYSIS TO HELP DECISION MAKERS DEVELOP SOUND POLICIES, MAKE BETTER-INFORMED DECISIONS, AND MANAGE PROGRAMS MORE EFFECTIVELY. false true 29089266 0 0 THE OPERATIONAL WARFIGHTING (OPS) DIVISION FOCUSES ON IMPROVING THE ABILITY OF THE DEPARTMENT OF THE NAVY TO ORGANIZE, PLAN, TRAIN, AND EXECUTE AT THE OPERATIONAL LEVEL OF WARFARE. OPS ANALYSIS TYPICALLY LINKS WARGAMING, CONCEPT DEVELOPMENT, HYPOTHESIS TESTING, AND EXERCISE AND OPERATIONAL ASSESSMENT INTO AN ITERATIVE CYCLE. THE DIVISION'S RESEARCH EMPHASIZES NAVAL INTEGRATION, JOINT AND COMBINED OPERATIONS, CYBER EFFECTS, INTELLIGENCE SUPPORT AND SPECIAL OPERATIONS. 20694638 0 0 THE RESOURCES AND FORCE READINESS (RFR) DIVISION PROVIDES ANALYSIS THAT HELPS THE NAVY, MARINE CORPS, AND OTHER SERVICES ADDRESS CRITICAL RESOURCE ALLOCATION CHALLENGES AND MAXIMIZE PERSONNEL READINESS. MILITARY LEADERS RELY ON RESOURCES AND FORCE READINESS ANALYSIS TO DEVELOP, EVALUATE AND IMPLEMENT POLICIES AND PROGRAMS THAT MAKE THEIR PEOPLE, BUDGETS AND ASSETS MORE EFFECTIVE AND EFFICIENT. 19082793 0 0 THE SYSTEMS, TACTICS AND FORCE DEVELOPMENT (STFD) DIVISION PROVIDES CLASSICAL WARFARE ANALYSES TO THE NAVY AND DOD FOCUSED ON SYSTEMS AND PLATFORMS AT THE TACTICAL LEVEL FOR GREAT POWER COMPETITION. STFD CONDUCTS QUANTITATIVE ANALYSES OF FLEET SYSTEMS AND MULTI-MISSION PLATFORMS TO DEVELOP PERFORMANCE ESTIMATES AGAINST CHINA, RUSSIA AND OTHER THREATS. THE DIVISION ANALYZES AND ASSESSES COMBINATIONS OF NETWORKS, SENSORS, WEAPONS, AND PLATFORMS TO PROVIDE MARITIME WARFIGHTING CAPABILITIES IN ALL WARFARE AREAS, UNDER REALISTIC CONDITIONS FOR CURRENT OPERATIONS AND FUTURE-FORCE ARCHITECTURES. 35972809 0 0 OTHER PROGRAMS (SEE SCHEDULE O) 35972809 0 0 104839506 true true false false false false false false false false true false false false true false true false false true true false false false false false false false false true false false false false false false false false false false false false false false false false false false 172 0 722 true false false false false false false false false false false false false X 12 11 false false false false false false false true true false false true true true true true true true true false CA X DONALD DEBUCK 7038242022 3003 WASHINGTON BOULEVARD ARLINGTON VA 22201 ROBERT R BLACKMAN TRUSTEE 3.0 0.0 X 28000 0 0 WILLIAM R BURKE TRUSTEE 3.0 0.0 X 29100 0 0 DANIEL A DOMENECH TRUSTEE 3.0 0.0 X 25000 0 0 MARK E FERGUSON TRUSTEE 3.0 0.0 X 27000 0 0 CAROL L GRAHAM TRUSTEE 3.0 0.0 X 29500 0 0 MAURA A HARTY TRUSTEE 3.0 0.0 X 40500 0 0 ADAM M ROBINSON TRUSTEE 3.0 0.0 X 29500 0 0 LAURIE O ROBINSON TRUSTEE 3.0 0.0 X 29500 0 0 SARAH SEWALL TRUSTEE 3.0 0.0 X 27000 0 0 RODERICK K VON LIPSEY TRUSTEE 3.0 0.0 X 28000 0 0 SEAN STACKLEY TRUSTEE (UNTIL SEPT 2019) 3.0 0.0 X 24000 0 0 KATHERINE MCGRADY PRESIDENT & CEO 40.0 0.0 X X 523959 0 89067 LEIGH WARNER TRUSTEE (AS OF MARCH 2019) 3.0 0.0 X 0 0 0 DONALD DEBUCK EXEC. VP, CFO, & TREASURER 40.0 0.0 X 378314 0 71167 MARK ROSEN SVP, GEN COUNSEL & SECRETARY 40.0 0.0 X 344422 0 31451 TIMOTHY BERES EXECUTIVE VP 40.0 0.0 X 335222 0 85705 MARK GEIS EXECUTIVE VP 40.0 0.0 X 369277 0 57442 DAVID KAUFMAN VP & DIRECTOR 40.0 0.0 X 284128 0 70925 KEITH COSTA VP & DIRECTOR 40.0 0.0 X 278632 0 54348 JASON THOMAS VP & DIRECTOR 40.0 0.0 X 237356 0 73812 LINDA CAVALLUZZO VP & DIRECTOR 40.0 0.0 X 276833 0 28056 DAVID VORDICK VP & CIO 40.0 0.0 X 283368 0 59987 DAVID FINKELSTEIN VP & DIRECTOR 40.0 0.0 X 265903 0 81460 PEARL MIHARA VP HUMAN RESOURCES 40.0 0.0 X 290531 0 27519 STACEY JORDAN VP & DIRECTOR (UNTIL OCT 2018) 40.0 0.0 X 374751 0 35107 KIM DEAL CRO 40.0 0.0 X 278363 0 58412 4838159 0 824458 359 false true false MEEHAN RESEARCH GROUP 18 Beachwood Road FERNANDIA BEACH FL 320346504 SUBCON ON DIR CNTRCT 687245 ARIZONA STATE UNIVERSITY 660 SOUTH MILL AVENUE SUITE 312 TEMPE AZ 85827 SUBCON ON DIR CNTRCT 587069 INNOVATIVE ARCHITECTS LLC 3122 HILL STREET DULUTH GA 30096 SUBCON ON DIR CNTRCT 543439 ALLIED UNIVERSAL SECURITY 161 WASHINGTON STREET STE 600 CONSHOHOCKEN PA 19428 PROFESSIONAL SVCS 370912 PRICEWATERHOUSECOOPERS LLP 1800 TYSONS BLVD MCLEAN VA 22102 PROFESSIONAL SVCS 299875 20 123773109 123773109 0 887611 887611 0 0 0 0 0 3306302 71 3627909 6208 -321607 -6137 -327744 -327744 0 0 0 0 0 0 0 0 0 0 124332976 559867 0 0 0 0 3985385 2184093 1801292 0 63722476 55898018 7824458 6125498 5337449 788049 13265072 11469762 1795310 4899899 4229025 670874 0 30169 30169 491273 491273 0 0 29079 29079 8490891 7691391 799500 0 730685 266599 464086 3283494 2492225 791269 0 10941840 8879745 2062095 4496066 4161332 334734 0 0 0 0 1679703 1427494 252209 0 TRAINING/DEVELOPMENT 1213940 802373 411567 123385470 104839506 18545964 0 0 0 17685697 19253022 0 0 15718994 15010925 0 0 0 0 0 0 0 0 770393 988985 32555389 19321039 14476264 13234350 22456308 25914833 0 0 0 0 0 0 2058228 2119985 73165884 76522100 13157696 13584543 0 0 554966 786065 0 0 0 0 0 0 0 0 0 0 8068070 8603139 21780732 22973747 X 51385152 53548353 0 0 0 0 51385152 53548353 73165884 76522100 947506 1215695 X false true X true true true X 112757736 118243179 122305622 122044106 123773109 599123752 0 0 112757736 118243179 122305622 122044106 123773109 599123752 0 599123752 494196 375907 373974 709961 887611 2841649 0 0 601965401 0.99528 0.99597 X 112757736 118243179 122305622 122044106 123773109 599123752 0 0 0 0 112757736 118243179 122305622 122044106 123773109 599123752 0 0 0 599123752 494196 375907 373974 709961 887611 2841649 0 494196 375907 373974 709961 887611 2841649 0 0 113251932 118619086 122679596 122754067 124660720 601965401 0.99528 0.99597 0.00472 0.00403 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 12632366 4282144 8350222 7389222 5368083 2021139 12533801 9670812 2862989 13234350 0 DEFERRED RENT 6291673 OTHER LIABILITIES 2311466 8603139 125525729 1215695 -29079 1186616 124339113 -6137 -6137 124332976 123362528 6137 6137 123356391 29079 29079 123385470 SCHEDULE D, PART XI, LINE 2D: INVESTMENT EXPENSES INCLUDED IN NET INVESTMENT INCOME: ($29,079) SCHEDULE D, PART XI, LINE 4B: RECLASS LOSS ON FIXED ASSET DISPOSAL: ($6,137) East Asia and the Pacific 0 6 Program Services ONSITE CLIENT ANALYSIS 2605427 Europe (Including Iceland and Greenland) 0 1 Program Services ONSITE CLIENT ANALYSIS 587666 Middle East and North Africa 0 1 Program Services ONSITE CLIENT ANALYSIS 516881 0 8 0 8 3709974 3709974 false false false false false false X true true X X X X X true false false false false false false true false KATHERINE MCGRADY PRESIDENT & CEO 394446 0 84500 0 45013 0 48750 0 40317 0 613026 0 0 0 DONALD DEBUCK EXEC. VP, CFO, & TREASURER 277729 0 61457 0 39128 0 43250 0 27917 0 449481 0 0 0 MARK ROSEN SVP, GEN COUNSEL & SECRETARY 255187 0 52100 0 37135 0 27500 0 3951 0 375873 0 0 0 TIMOTHY BERES EXECUTIVE VP 254036 0 54900 0 26286 0 46000 0 39705 0 420927 0 0 0 MARK GEIS EXECUTIVE VP 273895 0 56000 0 39382 0 30250 0 27192 0 426719 0 0 0 DAVID KAUFMAN VP & DIRECTOR 223460 0 39400 0 21268 0 32748 0 38177 0 355053 0 0 0 KEITH COSTA VP & DIRECTOR 210873 0 32100 0 35659 0 27334 0 27014 0 332980 0 0 0 JASON THOMAS VP & DIRECTOR 187407 0 29900 0 20049 0 40279 0 33533 0 311168 0 0 0 DAVID VORDICK VP & CIO 229024 0 35800 0 18544 0 23627 0 36360 0 343355 0 0 0 DAVID FINKELSTEIN VP & DIRECTOR 200619 0 39100 0 26184 0 45430 0 36030 0 347363 0 0 0 PEARL MIHARA VP HUMAN RESOURCES 219863 0 33900 0 36768 0 20000 0 7519 0 318050 0 0 0 LINDA CAVALLUZZO VP & DIRECTOR 224563 0 31200 0 21070 0 26774 0 1282 0 304889 0 0 0 STACEY JORDAN VP & DIRECTOR (UNTIL OCT 2018) 161914 0 30300 0 182537 0 22720 0 12387 0 409858 0 0 0 KIM DEAL CRO 214898 0 33700 0 29765 0 25167 0 33245 0 336775 0 0 0 SCHEDULE J, PART I, LINE 1: TRAVEL FOR BUSINESS PURPOSES IS LIMITED TO ECONOMY CLASS FOR ALL MODES OF TRANSPORTATION. FIRST-CLASS TRAVEL MAY BE GRANTED TO ANY EMPLOYEE WHEN ECONOMY CLASS REQUIRES CIRCUITOUS ROUTING AND PROLONGED TRAVEL WOULD OFFSET TRANSPORTATION SAVINGS, OR IS NOT REASONABLY ADEQUATE FOR THE PHYSICAL OR MEDICAL NEEDS OF THE TRAVELER. THESE BENEFITS ARE CORPORATE-WIDE POLICIES AND NOT OFFERED EXCLUSIVELY TO EXECUTIVES. ONE OFFICER, TWO KEY EMPLOYEES, & ONE HIGHEST-PAID EMPLOYEE RECEIVED NON-TAXABLE BUSINESS/FIRST CLASS TRAVEL BENEFITS. SCHEDULE J, PART I, LINE 4A: STACEY JORDAN RECEIVED A SEVERANCE PAYMENT OF $149,312. SCHEDULE J, PART I, LINE 7: ALL BONUSES HAVE A WRITTEN JUSTIFICATION. BONUSES ARE APPROVED BY VICE PRESIDENTS FOR THEIR STAFFS AND APPROVED BY THE NEXT LEVEL EXECUTIVE(PRESIDENTS OR COO OR CFO) MAKING SURE THAT THE BONUSES ARE EQUITABLE AND REASONABLE AND WITHIN THE ALLOTTED POOL OF MONEY. EACH EXECUTIVE'S COMPLETE SET OF DATA IS THEN PRESENTED TO THE CEO FOR APPROVAL. THE CEO DESIGNATES BONUSES FOR VPS AND ABOVE. THE PEOPLE AND COMPENSATION COMMITTEE OF THE BOARD OF TRUSTEES REVIEWS THE CEO'S DIRECT REPORTS AND APPROVES THEM AS WELL AS DESIGNATING ANY BONUS FOR THE CEO. THE BONUS PAYMENTS WERE BASED ON: 1) SUPERIOR PERFORMANCE: IN RECOGNITION OF VARIOUS FORMS OF PERFORMANCE ABOVE AND BEYOND EXPECTATIONS. EXAMPLES OF SUCH ACTIONS ARE: PERFORMING WORK THAT HAS A SIGNIFICANT IMPACT ON A CLIENT'S DECISION OR GOVERNMENT PERFORMANCE; TURNING A BAD CLIENT RELATIONSHIP INTO A GOOD ONE THROUGH UNUSUAL EFFORTS; MAKING A SIGNIFICANT PERSONAL SACRIFICE TO SUPPORT CNA OBJECTIVES; MAKING CNA SIGNIFICANTLY MORE EFFICIENT THROUGH UNUSUALLY CREATIVE MANAGERIAL OR ADMINISTRATIVE ACTIONS; ACHIEVING ANALYTICAL EXCELLENCE OF AN OUT-OF-THE-ORDINARY MANNER. NORMALLY, SUSTAINED SUPERIOR PERFORMANCE IS NOT A CRITERION FOR THIS AWARD. 2) BUSINESS DEVELOPMENT: IN RECOGNITION OF UNCOMMON EFFORTS TO ATTRACT ABOVE-CEILING AND ABOVE-CORE BUSINESS. IN CERTAIN CASES, A PORTION OF A BONUS AWARD MAY BE EARNED EVEN IF THE EFFORT DOES NOT RESULT IN NEW BUSINESS. THE DEGREE OF DIFFICULTY INVOLVED IN PURSUING THE NEW BUSINESS AND THE DEGREE OF SUCCESS IN ACQUIRING NEW BUSINESS SHOULD BE CONSIDERED. DIRECTORSOFFICERS' LIABILITY INSURANCE PREMIUMS HAVE BEEN PAID BY THE ORGANIZATION. BENEFIT IS BEING REPORTED IN TOTAL AND IS NOT SHOWN IN THE ALLOCATION OF PART VII/ SCHEDULE J. THE CURRENT YEAR PREMIUM IS $14,723. PART III, LINE 3: THE CNA EDUCATION (EDU) DIVISION WAS DISSOLVED DURING FY19. PART III, LINE 4D: THE STRATEGY, POLICY, PLANS, AND PROGRAMS (SP3) DIVISION LEVERAGES SOCIAL SCIENCE METHODOLOGIES, FIELD RESEARCH, REGIONAL EXPERTISE, PRIMARY LANGUAGE SKILLS, TRACK 1.5 PARTNERSHIPS, AND POLICY AND OPERATIONAL EXPERIENCE TO SUPPORT SENIOR DECISION-MAKERS. THE DIVISION'S WORK IS ALIGNED WITH THE NATIONAL DEFENSE STRATEGY AND HAS REGULARLY INFORMED DECISIONS CRITICAL TO NATIONAL SECURITY. THE CHINA AND INDO-PACIFIC SECURITY AFFAIRS (CIP) DIVISION IS THE LARGEST NON-GOVERNMENTAL RESEARCH GROUP STUDYING CHINESE AND INDO-PACIFIC MILITARY AND SECURITY AFFAIRS IN WASHINGTON. MORE THAN 40 CIP ANALYSTS COVER THE COASTAL NATIONS FROM SOUTH ASIA TO NORTHEAST ASIA, INCLUDING OCEANIA, AND ARE FLUENT IN MANDARIN, JAPANESE, RUSSIAN AND HINDI. CNA'S CHINA STUDIES PROGRAM HAS PROVIDED THE GOVERNMENT WITH GREAT POWER COMPETITION RESEARCH ON CHINA FOR MORE THAN 20 YEARS. THE MARINE CORPS PROGRAM OVERSEES AND MANAGES ALL ASPECTS OF CNA'S SUPPORT TO THE MARINE CORPS. THE PROGRAM PROVIDES ANALYTIC SUPPORT ON A WIDE RANGE OF ISSUES CRITICAL TO THE MARINE CORPS LEADERSHIP. THIS WORK IS EXECUTED WITHIN THE FFRDC RESEARCH DIVISIONS. IN ADDITION TO CNA HEADQUARTERS-BASED ANALYSTS, CNA ANALYSTS PROVIDE FULL-TIME ON-SITE SUPPORT TO KEY MARINE CORPS OPERATING FORCE COMMANDS AS PART OF OUR FIELD PROGRAM. THE MARINE CORPS PROGRAM ALSO INCLUDES ANALYTIC SUPPORT TO MAJOR EXERCISES AND ON-SITE DEPLOYED SUPPORT FOR ALL MAJOR REAL-WORLD OPERATIONS AND CONTINGENCIES INVOLVING MARINE CORPS FORCES. ENTERPRISE SYSTEMS AND DATA ANALYSIS (ESDA) WITHIN CNA'S INSTITUTE FOR PUBLIC RESEARCH PROVIDES OUR CLIENTS WITH WIDE-RANGING TECHNICAL AND ANALYTICAL SUPPORT TO MEET THEIR GOALS. OUR WORK CONSIDERS THE WHOLE OF AN ORGANIZATION, NOT JUST A PORTION IN ISOLATION. WE ANALYZE THE ENTIRETY OF A CLIENT'S SYSTEMS THEIR PEOPLE, PROCESSES, DATA, AND TECHNOLOGY TO IDENTIFY A SOLUTION FOR IMPROVED OPERATIONS. WE ALWAYS BEGIN BY LOOKING AT OUR CLIENTS' DATA TO HELP THEM TO IDENTIFY THE ROOT CAUSE OF PROBLEMS AND TO FIND SOLUTIONS BASED ON THE DATA. SAFETY & SECURITY (SAS) PROVIDES ANALYSIS AND GUIDANCE TO SUPPORT EVOLVING STANDARDS AND PRACTICES AND GIVES RECOMMENDATIONS FOR IMPROVING DECISION-MAKING AT ALL LEVELS DURING CRISIS OPERATIONS. WE WORK WITH SENIOR DECISION-MAKERS IN FEDERAL, STATE, AND LOCAL AGENCIES AS WELL AS WITH MEMBERS OF THE HOMELAND SECURITY PROFESSIONAL COMMUNITY OF LAW ENFORCEMENT OFFICIALS, FIREFIGHTERS, PUBLIC HEALTH OFFICIALS, AND EMERGENCY MEDICAL PERSONNEL. WE CONSULT WITH EXPERTS AND OFFICIALS RESPONSIBLE FOR THE SECURITY ISSUES RELATED TO TRANSPORTATION AND TO NUCLEAR, CHEMICAL, AND BIOLOGICAL CONCERNS. AND WE WORK WITH SPECIALISTS IN THE AREAS OF INFRASTRUCTURE AND COMMUNICATIONS AT THE FEDERAL, REGIONAL, STATE, AND LOCAL LEVELS TO IMPROVE THE COORDINATION AND COOPERATION AMONG THESE DISPARATE DECISION-MAKERS. COOPERATION AMONG THESE DISPARATE DECISION-MAKERS. PART VI, LINE 11B: THE FORM 990 IS PREPARED BY CNA'S EXTERNAL TAX ADVISERS, REVIEWED BY CNA'S MANAGEMENT, AND PRESENTED TO THE AUDIT COMMITTEE. COPIES OF THE RETURN ARE PROVIDED TO ALL TRUSTEES. THE DRAFT VERSION IS THEN FINALIZED AFTER INCORPORATING FEEDBACK RECEIVED FROM THE AUDIT COMMITTEE. THE FINAL VERSION OF THE RETURN IS PROVIDED TO EACH VOTING BOARD MEMBER AND THEN FILED WITH THE IRS. PART VI, LINE 12C THE CONFLICT OF INTEREST FORMS ARE FILED ANNUALLY BY OUR TRUSTEES AND KEY EXECUTIVES. BOARD MEMBERS AND KEY EXECUTIVES ARE PROVIDED INFORMATION ABOUT ORGANIZATIONS AND VENDORS WITH WHOM CNA IS CONDUCTING BUSINESS ON A QUARTERLY BASIS. THESE INDIVIDUALS USE THAT INFORMATION TO DETERMINE POSSIBLE CONFLICTS OF INTEREST THROUGHOUT THE YEAR. THIS INFORMATION IS REVIEWED BY OUR IN-HOUSE LEGAL COUNSEL TO DETERMINE IF ANY CONFLICTS OR RELATIONSHIPS REQUIRING DISCLOSURE OCCUR. IF A CONFLICT NEEDS TO BE DISCLOSED OR ADDRESSED, LEGAL COUNSEL DETERMINES THE APPROPRIATE COURSE OF ACTION. PART VI, LINES 15A AND 15B: CNA'S HUMAN RESOURCES DEPARTMENT USES COMPENSATION SURVEYS AND EXTERNAL DATA TO DETERMINE SALARIES OF ALL EMPLOYEES. THE CEO'S SALARY IS APPROVED BY THE CHAIRMAN OF THE COMPENSATION COMMITTEE. THE SALARIES OF OTHER OFFICERS AND KEY EMPLOYEES ARE APPROVED BY THE CEO. THE LAST COMPENSATION REVIEW BY A THIRD PARTY AND SALARY BENCHMARKING FOR EXECUTIVES WAS CONDUCTED DURING THE TAX YEAR AND PRESENTED TO THE COMPENSATION COMMITTEE DURING THE SEPTEMBER 2018 MEETING. PART VI, LINE 19: CNA CORPORATION DOES NOT MAKE ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC.