2020-11-12T11:59:05-06:00 2020-06-30 GRANT THORNTON LLP 171 N CLARK ST SUITE 200 CHICAGO IL 60601 990 2019-07-01 362960981 National Futures Association % DAVID HAWRYSZ NATI 3127811300 300 S Riverside Plaza Suite 1800 Chicago IL 606066615 DAVID HAWRYSZ Sr VP, CFO,Treasurer 3127811300 2020-11-12 true BRIDGET T ROCHE P00666837 3128560200 108.84.33.62 36941220203175000008 2020-11-12 P F41D5C9F8972B572E8F276B48083085B3CDA3F70 DB64C1701B389F151E46C096E2734789DEA2CBCD 2019 2021-04-22 16:20:28Z NFA David Hawrysz 300 S Riverside Plaza Chicago IL 60606 120873183 false X www.nfa.futures.org X 1976 DE NFA IS A SELF-REGULATORY MEMBERSHIP ORGANIZATION FORMED TO MONITOR AND MAINTAIN THE INTEGRITY OF THE DERIVATIVES TRADING INDUSTRY. 29 29 601 0 0 0 0 0 112792818 118871659 2448716 2001524 0 0 115241534 120873183 0 0 0 0 75147486 81714093 0 0 0 26006633 24538476 101154119 106252569 14087415 14620614 142277544 160552859 24537761 26589398 117739783 133963461 X AS A CONGRESSIONALLY AUTHORIZED SELF-REGULATORY ORGANIZATION, NATIONAL FUTURES ASSOCIATION (NFA) IS THE SELF-REGULATORY ORGANIZATION FOR THE U.S. DERIVATIVES INDUSTRY, INCLUDING EXCHANGE TRADED FUTURES, RETAIL OFF-EXCHANGE FOREIGN CURRENCY (FOREX) AND OTC DERIVATIVES (SWAPS). NFA HAS DEVELOPED AND ENFORCES RULES, PROVIDES PROGRAMS AND OFFERS SERVICES THAT SAFEGUARD MARKET INTEGRITY, PROTECT INVESTORS AND HELP OUR MEMBERS MEET THEIR REGULATORY RESPONSIBILITIES. false false 0 0 0 REGISTRATION NFA SCREENS ALL FIRMS AND INDIVIDUALS WISHING TO REGISTER WITH THE CFTC AND BECOME MEMBERS. NFA'S REGISTRATION DEPARTMENT PROCESSED APPROXIMATELY 370 FIRM REGISTRATIONS AND OVER 6,606 INDIVIDUAL REGISTRATIONS. REGISTRATION INVESTIGATION CASES NFA'S REGISTRATION INVESTIGATIONS GROUP OPENED APPROXIMATELY 1,158 CASES. THESE INVESTIGATION CASES ARE DUE TO INFORMATION OBTAINED DURING NFA'S BACKGROUND CHECKS. INFORMATION CENTER NFA'S INFORMATION CENTER - A SERVICE NFA OFFERS TO MEMBERS AND THE INVESTING PUBLIC - RECEIVED MORE THAN 21,788 CALLS AND RESPONDED TO NEARLY 3,855 EMAILS. ENFORCEMENT ACTIONS ENFORCEMENT OF NFA RULES IS CRITICAL TO THE EFFECTIVENESS OF THE SELF-REGULATORY PROCESS. IN FISCAL YEAR 2020: NFA'S BUSINESS CONDUCT COMMITTEE ISSUED 16 COMPLAINTS AGAINST 35 RESPONDENTS. A NUMBER OF THESE CASES INVOLVED MEMBERS AND ASSOCIATES WHO FAILED TO SUPERVISE, COOPERATE WITH NFA IN AN INVESTIGATION OR OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE. NFA'S DISCIPLINARY PANELS ISSUED 19 DECISIONS AND ORDERED 11 MEMBERSHIP BARS, NINE SUSPENSIONS AND NFA COLLECTED MORE THAN $2.8 MILLION IN FINES. 0 false false false true false false false true false true false false false true true true false false false true false false false false false false false false true false false false false false false false false false false false false false false true 72 0 true 601 true false false false false false false false false X 29 29 false false false false true true true true true false false true true true true true true true true false CA X DAVID HAWRYSZ 3127811300 300 SOUTH RIVERSIDE PLAZA SUITE 18 Chicago IL 60606 Thomas Sexton President and CEO 40.0 0.0 X 784477 0 62277 Daniel Driscoll Special Advisor 40.0 0.0 X 655984 0 72274 Regina Thoele Senior VP 40.0 0.0 X 603228 0 61382 Edward Dasso Vice President 40.0 0.0 X 549391 0 72438 David Hawrysz Sr. VP, CFO, and Treasurer 40.0 0.0 X 479708 0 62323 Carol Wooding VP, GC, and Secretary 40.0 0.0 X 472836 0 59307 Timothy McHenry Vice President 40.0 0.0 X 458045 0 61302 Karen Wuertz Senior VP 40.0 0.0 X 444948 0 59304 Jamila Piracci Vice President 40.0 0.0 X 383019 0 36947 Joseph Hawrysz Managing Director, Compliance 40.0 0.0 X 326803 0 50393 Joseph Zangri Managing Director, Exams OTC 40.0 0.0 X 319235 0 48596 Thomas Gisonda Managing Dir, OTC Derivatives 40.0 0.0 X 310056 0 45755 Dale Spoljaric Managing Director, Compliance 40.0 0.0 X 299031 0 52670 Adrianna Joves Associate Counsel 40.0 0.0 X 311102 0 38484 Yvette Christman Vice President 40.0 0.0 X 252804 0 36840 NANCY BOHANON Vice President 40.0 0.0 X 198640 0 40646 Michael Otten Vice President 40.0 0.0 X 44174 0 1677 Douglas Harris Board Member 1.0 0.0 X 43500 0 0 Ronald Filler Board Member 1.0 0.0 X 42000 0 0 Ronald Oppenheimer Board Member 1.0 0.0 X 42000 0 0 Michael Moskow Board Member 1.0 0.0 X 41500 0 0 Todd Petzel Board Member 1.0 0.0 X 40000 0 0 Charles Nastro Board Member 1.0 0.0 X 25500 0 0 Jim Marshall Board Member 1.0 0.0 X 21500 0 0 Michael Schaefer Board Member 1.0 0.0 X 21500 0 0 Mary McDonnell Board Member 1.0 0.0 X 20000 0 0 Douglas Bry Board Member 1.0 0.0 X 16000 0 0 Ernest Jaffarian Board Member 1.0 0.0 X 16000 0 0 Maureen Downs Chairperson 1.0 0.0 X 16000 0 0 David Goone Board Member 1.0 0.0 X 16000 0 0 John Sandner Board Member 1.0 0.0 X 16000 0 0 Don Thompson Vice Chair 1.0 0.0 X 16000 0 0 Thomas Kadlec Board Member 1.0 0.0 X 14000 0 0 Gerald Corcoran Board Member 1.0 0.0 X 10000 0 0 Michael Burke Board Member 1.0 0.0 X 8000 0 0 Martin Lueck Board Member 1.0 0.0 X 8000 0 0 Nicola Watson Board Member 1.0 0.0 X 8000 0 0 Scott Stewart Board Member 1.0 0.0 X 8000 0 0 Seth Bender Board Member 1.0 0.0 X 8000 0 0 Mark Bagan Board Member 1.0 0.0 X 6000 0 0 Maria Chiodi Board Member 1.0 0.0 X 2000 0 0 SHERYL WALLACE BOARD MEMBER - THRU 2/2020 1.0 0.0 X 0 0 0 Charlotte McLaughlin Board Member 1.0 0.0 X 0 0 0 William McCoy Board Member 1.0 0.0 X 0 0 0 Arthur Hahn Board Member 1.0 0.0 X 0 0 0 Mariam Rafi Board Member - AS OF 2/2020 1.0 0.0 X 0 0 0 Hector Fernandez Board Member - As of 2/2020 1.0 0.0 X 0 0 0 7170981 0 862615 244 false true false CDW Direct LLC 200 N MILWAUKEE AVENUE VERNON HILLS IL 60061 computer support 875093 Jenner Block LLP 353 N Clark Street CHICAGO IL 60654 Legal Consulting 872718 Redlegg 902 S RANDALL ROAD STE C 319 ST CHARLES IL 60174 IT Security 266962 Ernst Young LLP 155 N WACKER DR CHICAGO IL 60606 Accounting Services 221351 Bloomberg LP 1 N LASALLE ST STE 3500 CHICAGO IL 60602 data services 204142 15 0 ASSESSMENT FEES & MARKET SERVICE REV 900099 73481759 73481759 0 0 MEMBERSHIP DUES 900099 40865454 40865454 0 0 REGULATORY FINES 900099 2525000 2525000 0 0 REGISTRATION & TESTING FEES 900099 1066378 1066378 0 0 ARBITRATION REVENUE 900099 675180 675180 0 0 257888 257888 0 0 118871659 2001524 2001524 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 120873183 118871659 0 2001524 0 0 0 0 6227286 0 57548321 5742327 7822887 4373272 0 607164 104305 0 0 0 3358891 44500 1054198 4649897 0 4558944 2164972 0 127432 0 0 6453747 0 EDUCATION AND RECRUITMENT 1141211 DUES AND SUBSCRIPTION 273215 106252569 111972 12140201 39791780 52274598 0 0 1332970 1248669 0 0 0 0 0 0 0 0 1069720 1565987 34209028 22643640 12799060 11565388 80587959 76315928 0 0 0 0 0 0 6584083 5442088 142277544 160552859 5599000 5549766 0 0 8504945 8813706 0 0 0 0 0 0 0 0 0 0 10433816 12225926 24537761 26589398 X 117739783 133963461 0 0 117739783 133963461 142277544 160552859 X 14620614 2663156 -1060092 X false true X true false false false false 114347213 19823 19823 19823 true 4352145 37228475 5270202 36310418 false 12036180 8588606 3447574 9390202 6368189 3022013 12782646 7686845 5095801 11565388 0 POST RETIREMENT 11205280 UNCLAIMED DISBURSEMENT 2528 ALL OTHER LIABILITIES 1018118 12225926 X 123536339 2663156 2663156 120873183 120873183 106252569 106252569 106252569 AGENT, TRUSTEE, CUSTODIAN, ETC. ARRANGEMENT SCHEDULE D, PART IV, LINE 1B THE COMMODITY FUTURES TRADING COMMISSION (CFTC) PERIODICALLY ASKS FEDERAL COURTS TO APPOINT NFA TO SERVE AS A COURT-APPOINTED MONITOR IN RESTITUTION JUDGMENTS AWARDED IN CFTC CASES BROUGHT BEFORE THE COURTS. AS MONITOR, NFA ASSISTS IN PROVIDING HARMED INVESTORS IDENTIFIED BY THE COURT ORDER WITH THEIR PRO-RATA SHARE OF RESTITUTION. THE RESTITUTION FUNDS ARE PLACED IN QUALIFIED SETTLEMENT FUNDS (QSF) WHICH ARE SEPARATE LEGAL ENTITIES ESTABLISHED AND TITLED PURSUANT TO A FEDERAL COURT ORDER. QSF ARE ORDINARILY SUBJECT TO THE CONTINUING JURISDICTION OF THE FEDERAL COURT. NFA HAS CHECK WRITING AUTHORITY FOR THE QSFS. LIABILITY FOR UNCERTAIN TAX POSITION (ASC 740) SCHEDULE D, PART X, LINE 2 THE ASSOCIATION FOLLOWS GUIDANCE THAT CLARIFIES THE ACCOUNTING FOR UNCERTAINTY IN TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN, INCLUDING ISSUES RELATING TO FINANCIAL STATEMENT RECOGNITION AND MEASUREMENT. THIS GUIDANCE PROVIDES THAT THE TAX EFFECTS FROM AN UNCERTAIN TAX POSITION CAN ONLY BE RECOGNIZED IN THE FINANCIAL STATEMENTS IF THE POSITION IS MORE LIKELY THAN NOT TO BE SUSTAINED IF THE POSITION WERE TO BE CHALLENGED BY A TAXING AUTHORITY. THE ASSESSMENT OF THE TAX POSITION IS BASED SOLELY ON THE TECHNICAL MERITS OF THE POSITION, WITHOUT REGARD TO THE LIKELIHOOD THAT THE TAX POSITION MAY BE CHALLENGED. THE ASSOCIATION IS EXEMPT FROM FEDERAL INCOME TAX UNDER INTERNAL REVENUE CODE (IRC) SECTION 501(C)(6), THOUGH IT IS SUBJECT TO TAX ON INCOME UNRELATED TO ITS EXEMPT PURPOSE, UNLESS THAT INCOME IS OTHERWISE EXCLUDED BY THE CODE. THE ASSOCIATION HAS DETERMINED THAT THERE ARE NO MATERIAL UNCERTAIN TAX POSITIONS THAT REQUIRE RECOGNITION OR DISCLOSURE IN THE FINANCIAL STATEMENTS, AND THERE ARE NO INTEREST AND PENALTIES RECOGNIZED IN THE ACCOMPANYING FINANCIAL STATEMENTS. North America 28 Program Services Exams of Member Firms 116057 Europe (Including Iceland and Greenland) 35 Program Services Exams of Member Firms 133807 East Asia and the Pacific 6 Program Services Exams of Member Firms 32591 South America 1 Program Services IOSCO 2639 70 70 285094 285094 false false false false false false METHOD USED TO ACCOUNT FOR EXPENDITURES SCHEDULE F, PART I, LINE 3, COLUMN (F) THE TOTAL PROGRAM SERVICE EXPENDITURES IN NORTH AMERICA, EUROPE, ASIA AND SOUTH AMERICA HAVE BEEN REPORTED USING THE ACCRUAL METHOD OF ACCOUNTING, THE SAME METHOD USED FOR NFA'S AUDITED FINANCIAL STATEMENTS. X true true X X X false false false Thomas Sexton President and CEO 706401 0 75000 0 3076 0 39200 0 32423 0 856100 0 0 0 Daniel Driscoll Special Advisor 589746 0 65000 0 1238 0 39200 0 33074 0 728258 0 0 0 Regina Thoele Senior VP 532873 0 67250 0 3105 0 39200 0 30682 0 673110 0 0 0 Karen Wuertz Senior VP 387632 0 53500 0 3816 0 39200 0 29348 0 513496 0 0 0 David Hawrysz Sr. VP, CFO, and Treasurer 430069 0 47500 0 2139 0 39200 0 32454 0 551362 0 0 0 Edward Dasso Vice President 493176 0 55000 0 1215 0 39200 0 33238 0 621829 0 0 0 Jamila Piracci Vice President 382214 0 0 0 805 0 16800 0 20147 0 419966 0 0 0 Yvette Christman Vice President 222224 0 27500 0 3080 0 25429 0 11411 0 289644 0 0 0 Timothy McHenry Vice President 395766 0 60000 0 2279 0 39200 0 22102 0 519347 0 0 0 Carol Wooding VP, GC, and Secretary 409790 0 60000 0 3046 0 39200 0 21387 0 533423 0 0 0 Joseph Hawrysz Managing Director, Compliance 297330 0 28000 0 1473 0 30316 0 20077 0 377196 0 0 0 Adrianna Joves Associate Counsel 285610 0 25000 0 492 0 30342 0 8142 0 349586 0 0 0 Thomas Gisonda Managing Dir, OTC Derivatives 294552 0 12500 0 3004 0 25681 0 20074 0 355811 0 0 0 Joseph Zangri Managing Director, Exams OTC 303005 0 15000 0 1230 0 29431 0 19165 0 367831 0 0 0 Dale Spoljaric Managing Director, Compliance 281913 0 16500 0 618 0 30800 0 21870 0 351701 0 0 0 NANCY BOHANON Vice President 179978 0 17600 0 1062 0 21155 0 20090 0 239885 0 0 0 HEALTH OR SOCIAL CLUB DUES OR INITIATION FEES SCHEDULE J, PART I, LINE 1A HEALTH CLUB DUES PROVIDED TO CAROL WOODING, DANIEL DRISCOLL, MICHAEL OTTEN, REGINA THOELE, KAREN WUERTZ, TIMOTHY MCHENRY, DAVID HAWRYSZ, EDWARD DASSO, JAMILA PIRACCI AND THOMAS SEXTON, STAFF AND OFFICERS, IN THE AMOUNT OF $5,089 WAS REPORTED AS COMPENSATION ON FORM W-2. NFA CURRENTLY DOES NOT OFFER FIRST CLASS TRAVEL ON OVERSEAS BUSINESS TRIPS, NFA OFFICERS MAY ELECT TO FLY BUSINESS CLASS. MEMBERS OR STOCKHOLDERS FORM 990, PART VI, SECTION A, LINE 6 MEMBERS ARE DIVIDED INTO CATEGORIES BASED UPON THEIR REGISTRATION TYPE WITH THE COMMODITY FUTURES TRADING COMMISSION (CFTC). THE MEMBERSHIP CATEGORIES INCLUDE: CONTRACT MARKETS, FUTURES COMMISSION MERCHANTS AND LEVERAGED TRANSACTION MERCHANTS, INTRODUCING BROKERS, RETAIL FOREIGN EXCHANGE DEALERS, SWAP DEALERS, MAJOR SWAP PARTICIPANTS, COMMODITY POOL OPERATORS AND COMMODITY TRADING ADVISORS. MEMBERS ELECT REPRESENTATIVES FROM THEIR RESPECTIVE CATEGORIES TO THE BOARD OF DIRECTORS. THE BOARD OF DIRECTORS ELECTS PUBLIC DIRECTORS (NON-MEMBERS) TO THE BOARD OF DIRECTORS. OTHER THAN A CHANGE IN THE ARTICLES OF INCORPORATION, MEMBERS GENERALLY DO NOT APPROVE SIGNIFICANT DECISIONS OF THE GOVERNING BODY. UPON DISSOLUTION, THE NET ASSETS OF NFA, AFTER PAYMENT OF LIABILITIES, SHALL BE DISTRIBUTED TO THE MEMBERS IN PROPORTION TO THE DUES AND ASSESSMENTS PREVIOUSLY PAID. MEMBERS OR STOCKHOLDERS WHO MAY ELECT FORM 990, PART VI, SECTION A, LINE 7A A VACANCY ON THE BOARD THAT OCCURS BEFORE THE EXPIRATION OF A DIRECTOR'S TERM OR BECAUSE ADDITIONAL DIRECTORS IN EXISTING OR NEW MEMBER CATEGORIES ARE REQUIRED SHALL BE FILLED (FOR THE UNEXPIRED TERM) BY AN ELIGIBLE INDIVIDUAL ELECTED BY MAJORITY VOTE OF THE REMAINING DIRECTORS WHO REPRESENT THE CATEGORY OF MEMBERS IN WHICH THE VACANCY OCCURRED. SEE FORM 990, PART VI, LINE 6 ABOVE FOR THE NATURE OF THE VOTING RIGHTS. DECISIONS SUBJECT TO APPROVAL FORM 990, PART VI, SECTION A, LINE 7B A CHANGE IN NFA'S ARTICLES OF INCORPORATION REQUIRES APPROVAL OF THE MAJORITY OF THOSE VOTING IN EACH MEMBERSHIP CATEGORY. FORM 990 REVIEW PROCESS FORM 990, PART VI, SECTION B, LINE 11B THE NFA TAX RETURNS ARE PREPARED BY A NATIONAL OUTSIDE PUBLIC ACCOUNTING FIRM. PRIOR TO FILING THE FORM 990 IT IS REVIEWED AND APPROVED BY NFA'S AUDIT COMMITTEE (THREE MEMBERS). THE REVIEW INVOLVES AN IN-DEPTH PRESENTATION BY NFA STAFF TO THE COMMITTEE. THE COMMITTEE WILL ALSO REVIEW THE OVERALL ACCURACY AND COMPLETENESS OF THE FORM 990. PRIOR TO FILING THE FORM 990, THE DRAFT RETURN IS PROVIDED TO THE REMAINING VOTING MEMBERS OF NFA'S GOVERNING BODY. NFA'S CFO ALSO REVIEWED THE 990 FOR OVERALL ACCURACY AND COMPLETENESS PRIOR TO FILING. CONFLICT OF INTEREST POLICY MONITORING & ENFORCEMENT FORM 990, PART VI, SECTION B, LINE 12C AT NFA'S BOARD OF DIRECTORS' ANNUAL MEETING, NFA'S GENERAL COUNSEL PRESENTS, IN WRITING, NFA'S POLICY AND PROCEDURE ON CONFLICTS AND DUALITIES OF INTEREST ("POLICY"). EACH DIRECTOR IS SUBSEQUENTLY REQUIRED TO SIGN A WRITTEN STATEMENT THAT DISCLOSES ANY AFFILIATION THAT MAY GIVE RISE TO POTENTIAL CONFLICTS AND DUALITIES OF INTEREST UNDER THE POLICY. THE WRITTEN STATEMENT ALSO ACKNOWLEDGES THAT THE DIRECTOR HAS RECEIVED, READ AND UNDERSTOOD, AND AGREES TO ABIDE BY NFA'S POLICY; AND THAT THE DIRECTOR WILL DISCLOSE, AS IT OCCURS, ANY AFFILIATION THAT MAY GIVE RISE TO A CONFLICT OR DUALITY OF INTEREST UNDER THE POLICY. NFA'S GENERAL COUNSEL REVIEWS AND MAINTAINS THESE WRITTEN STATEMENTS AND CONSIDERS THEM AS MATTERS UPON WHICH THE BOARD ACTS ARISE. IF ANY DIRECTOR HAS AN AFFILIATION THAT MAY GIVE RISE TO A CONFLICT OR DUALITY OF INTEREST UNDER THE POLICY IN CONNECTION WITH A MATTER COMING BEFORE THE BOARD, NFA'S GENERAL COUNSEL BRINGS THE AFFILIATION TO THE BOARD'S ATTENTION IN THE EVENT THAT THE DIRECTOR DOES NOT. NFA'S STAFF IS REQUIRED TO ADHERE TO A CONFLICT OF INTEREST POLICY, WHICH IS MONITORED BY HUMAN RESOURCES. STAFF ANNUALLY COMPLETE THEIR CONFLICT OF INTEREST QUESTIONNAIRES, WHICH HUMAN RESOURCES REVIEWS AND MAINTAINS. IF ANY CONFLICTS ARISE, THE GENERAL COUNSEL DISCUSSES THE POTENTIAL CONFLICT WITH THE STAFF MEMBER, AND DOCUMENTS ACTIONS TAKEN; WHETHER DISPOSAL OF THE INTEREST OR ANY DISCIPLINARY ACTION UNDER THE CODE OF PROFESSIONAL CONDUCT IS WARRANTED DEPENDS ON THE LEVEL OF CONFLICT UNDER REVIEW. PROCESS FOR DETERMINING COMPENSATION FORM 990, PART VI, SECTION B, LINES 15A AND 15B THE COMPENSATION COMMITTEE IS COMPRISED OF THREE VOTING MEMBERS OF THE BOARD. FOR ALL OFFICERS EXCEPT THE CEO, THE CEO COLLABORATES WITH THE COMPENSATION COMMITTEE TO DETERMINE THE OFFICERS' COMPENSATION. THE CEO AND THE COMPENSATION COMMITTEE DISCUSS EACH OFFICER'S CONTRIBUTION TO THE ORGANIZATION; THEY REVIEW COMPARABLE MARKET DATA PROVIDED BY NFA'S HUMAN RESOURCE DEPARTMENT AND DELIBERATE COMPENSATION RECOMMENDATIONS WHICH ARE DOCUMENTED AND PRESENTED TO THE EXECUTIVE COMMITTEE. THE SAME METHOD, AS DESCRIBED ABOVE, IS USED IN DETERMINING THE CEO'S COMPENSATION, ONLY THE CEO IS NOT PART OF THE PROCESS. THE EXECUTIVE COMMITTEE REVIEWS THE COMPENSATION COMMITTEE'S PROPOSED RECOMMENDATION AND EITHER ACCEPTS OR ADJUSTS THE PROPOSAL. THE EXECUTIVE COMMITTEE THEN MAKES ITS RECOMMENDATION TO THE BOARD OF DIRECTORS. THE BOARD OF DIRECTORS EITHER APPROVES OR MODIFIES THE EXECUTIVE COMMITTEE'S RECOMMENDATION. THE BOARD THEN APPROVES FINAL COMPENSATION FOR OFFICERS. THE ORGANIZATION CONTEMPORANEOUSLY DOCUMENTS AND MAINTAINS RECORDS OF DELIBERATIONS AND DECISIONS REGARDING THE COMPENSATION ARRANGEMENTS OF THE OFFICERS. HOW DOCUMENTS ARE MADE AVAILABLE TO THE PUBLIC FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATION MAKES ITS BYLAWS, ARTICLES OF INCORPORATION AND FINANCIAL STATEMENTS AVAILABLE ON ITS WEBSITE OR UPON WRITTEN REQUEST. THE CONFLICTS OF INTEREST POLICY IS AVAILABLE UPON REQUEST. RECONCILIATION OF NET ASSETS FORM 990, PART XI, LINE 9 OTHER CHANGES IN NET ASSETS OR FUND BALANCES CONSIST OF: POSTRETIREMENT BENEFIT CHANGES OTHER THAN NET PERIODIC BENEFIT COSTS $(1,060,092)