2018-11-09T13:42:52-06:00 2017-12-31 PricewaterhouseCoopers LLP 300 Madison Avenue New York NY 10017 990 2017-01-01 133298818 INT'L SWAPS & DERIVATIVES ASSOCIATION INC % HUZEFA DEESAWALA CFO INTL 2129016000 10 EAST 53RD STREET 9TH FLOOR NEW YORK NY 10022 SCOTT O'MALIA CEO 2129016000 2018-11-07 true LAURA J PARELLO P01080295 6464713000 155.201.188.32 13049920183135000008 2018-11-09 P 618ACE5A638F5610B23A87A01F7C418F45FC2D61 111A21EDF88F1D2542120DD6D5F547A19EC6A083 2017 2019-02-21 02:37:17Z SCOTT O'MALIA 10 EAST 53RD STREET 9TH FLOOR NEW YORK NY 10022 58618532 false X www.isda.org X 1985 NY ISDA FOSTERS SAFE AND EFFICIENT DERIVATIVES MARKETS TO FACILITATE EFFECTIVE RISK MANAGEMENT FOR ALL USERS OF DERIVATIVE PRODUCTS. 27 26 68 0 0 0 0 43512524 42907296 -964694 745185 13697111 14960685 56244941 58613166 0 0 0 0 22401400 24003538 0 0 0 25390991 23134530 47792391 47138068 8452550 11475098 90246533 91513174 47371997 37021621 42874536 54491553 X SEE SCHEDULE O false false COMMITTEES - ESTABLISHED TO ENABLE MEMBERS TO ADDRESS SPECIFIC ISSUES RELATED TO DOCUMENTATION, ACCOUNTING, NETTING, COLLATERAL RISK MANAGEMENT, REGULATORY DEVELOPMENTS AND OTHER INDUSTRY TOPICS OF MUTUAL CONCERN AND INTEREST. CONFERENCES - CONDUCTED 86 EDUCATIONAL SEMINARS AROUND THE WORLD TO ADVANCE THE KNOWLEDGE AND UNDERSTANDING OF SWAPS AND DERIVATIVES MARKETS. ANNUAL GENERAL MEETING - ISDA'S ANNUAL GENERAL MEETING AND STRATEGIC PLANNING SESSION PROVIDE FORUMS FOR MEMBERS AND THE BOARD OF DIRECTORS TO EXCHANGE INFORMATION AND IDEAS ABOUT DEVELOPMENTS AFFECTING SWAPS AND DERIVATIVES MARKETS AROUND THE WORLD. A FULLER DESCRIPTION OF ACCOMPLISHMENTS IS AVAILABLE ON THE WEBSITE @ WWW.ISDA.ORG false false false true false false false false false true true false false true true false true false true true false false false false false false false false true false false false false false false false false false false true true true true false true X 2 0 true 68 true false true UK HK SN JA false false false false X 27 26 true false true false true true true true true false false false true true true true true true true true true X HUZEFA DEESAWALA CFO 2129016000 10 EAST 53RD STREET 9TH FLOOR NEW YORK NY 10022 X EMMANUEL VERCOUSTRE DIRECTOR 1.0 0.0 X 0 0 0 WILL ROBERTS DIRECTOR 1.0 0.0 X 0 0 0 YASUNOBU ARIMA DIRECTOR UNTIL 5/1/2017 1.0 0.0 X 0 0 0 KEITH BAILEY SECRETARY 1.0 0.0 X X 0 0 0 BENJAMIN JACQUARD DIRECTOR 1.0 0.0 X 0 0 0 MIKE LESAGE DIRECTOR UNTIL 7/11/2017 1.0 0.0 X 0 0 0 BISWARUP CHATTERJEE DIRECTOR 1.0 0.0 X 0 0 0 KIM TAYLOR DIRECTOR UNTIL 5/10/2017 1.0 0.0 X 0 0 0 JOHN DABBS DIRECTOR 1.0 0.0 X 0 0 0 DIXIT JOSHI DIRECTOR 1.0 0.0 X 0 0 0 AXEL VAN NEDERVEEN DIRECTOR 1.0 0.0 X 0 0 0 GUY SAIDENBERG DIRECTOR UNTIL 3/24/2017 1.0 0.0 X 0 0 0 JEROEN KRENS DIRECTOR 1.0 0.0 X 0 0 0 DIANE GENOVA TREASURER 1.5 0.0 X X 0 0 0 CIARAN O'FLYNN DIRECTOR UNTIL 5/10/2017 1.0 0.0 X 0 0 0 JOHN FEENEY VICE CHAIRMAN 1.0 0.0 X X 0 0 0 HIDEO KITANO DIRECTOR UNTIL 6/17/2017 1.0 0.0 X 0 0 0 BILL DE LEON DIRECTOR 1.0 0.0 X 0 0 0 JONATHAN HUNTER DIRECTOR UNTIL 5/10/2017 1.0 0.0 X 0 0 0 KIERAN HIGGINS DIRECTOR 1.0 0.0 X 0 0 0 ERIC LITVACK CHAIRMAN 1.0 0.0 X X 0 0 0 NEH THAKER DIRECTOR 1.0 0.0 X 0 0 0 DARCY BRADBURY DIRECTOR 1.0 0.0 X 0 0 0 DUNCAN RODGERS DIRECTOR 1.0 0.0 X 0 0 0 TJ LIM DIRECTOR 1.0 0.0 X 0 0 0 SCOTT O'MALIA CHIEF EXECUTIVE OFFICER 40.0 0.0 X X 1374241 0 16901 RICHARD PRAGER DIRECTOR UNTIL 2/10/2017 1.0 0.0 X X 0 0 0 THJIS AATEN DIRECTOR AS OF 5/10/17 1.0 0.0 X 0 0 0 JACK HATTEM DIRECTOR AS OF 2/14/17 1.0 0.0 X 0 0 0 MAX NUTTALL DIRECTOR AS OF 11/16/17 1.0 0.0 X 0 0 0 RANA YARED DIRECTOR AS OF 5/10/17 1.0 0.0 X 0 0 0 KEVIN MCCLEAR DIRECTOR AS OF 5/10/17 1.0 0.0 X 0 0 0 MASANOBU ICHIYA DIRECTOR AS OF 5/10/17 1.0 0.0 X 0 0 0 TOM WIPF DIRECTOR AS OF 5/10/17 1.0 0.0 X 0 0 0 YOSUKE INAIDA DIRECTOR AS OF 6/21/17 1.0 0.0 X 0 0 0 SIAN HURRELL DIRECTOR AS OF 5/10/17 1.0 0.0 X 0 0 0 STEVE KENNEDY SCH J PT III GLOBAL HEAD OF PUBLIC POLICY 40.0 0.0 X 752286 0 283058 KEITH NOYES DIRECTOR, ASIA-PACIFIC REGION 40.0 0.0 X 631990 0 6146 KATHERINE DARRAS SCH J PT III GENERAL COUNSEL 40.0 0.0 X 817464 0 26262 MARY CUNNINGHAM CHIEF OPERATING OFFICER 40.0 0.0 X 683520 0 36178 HUZEFA DEESAWALA SCH J PT III CHIEF FINANCIAL OFFICER 40.0 0.0 X 424554 0 154342 MARK GHEERBRANT HEAD OF RISK & CAPITAL 40.0 0.0 X 673053 0 3982 JING GU SENIOR COUNSEL 40.0 0.0 X 426027 0 2200 CORRINNE GREASLY CHIEF HUMAN RESOURCE OFFICER 40.0 0.0 X 618482 0 29088 KAREL ENGELEN SENIOR DIRECTOR 40.0 0.0 X 414760 0 55972 RICK SANDILANDS SENIOR COUNSEL EUROPE 40.0 0.0 X 397592 0 15163 BELLA ROZENBERG SCH J PT III SR COUN&HEAD,REG LEGAL PRAC GP 40.0 0.0 X 373769 0 144033 7587738 0 773325 64 false true false SATORI CONSULTING INC PO BOX 16700 JERSEY CITY NJ 073066700 CONSULTING 2227069 ALLEN OVERY ONE BISHOPS SQUARE LONDON 0 UK E1 6AD LEGAL SERVICES 1381502 ERNST YOUNG LLP 1 MORE LONDON PLACE LONDON 0 UK SE1 2AF CONSULTING 998757 SIFMA 120 BROADWAY NEW YORK NY 102710584 RENT PAYMENT 964843 SIMPSON THACHER BARTLETT LLP 1155 F STREET NW WASHINGTON DC 20004 LEGAL SERVICES 940981 42 0 MEMBERSHIP DUES 900099 39852404 39852404 CONFERENCES 900099 1971942 1971942 ANNUAL GENERAL MEETING 900099 1082950 1082950 42907296 745185 745185 0 5387187 5387187 508188 508188 0 508188 508188 0 0 0 0 0 0 0 1151530 5366 1146164 1146164 FPML SERVICES 900099 9600 9600 ISDA AMEND AND PROTOCOL FEES 900099 7909546 7909546 7919146 58613166 42907296 15705870 X 0 0 0 0 5143096 0 15608988 682904 1260560 1307990 0 7096131 251566 505341 0 0 3862868 0 1611084 645890 0 4313696 1354602 0 1512901 0 0 627937 442377 BOARD MEETINGS 299273 INVESTIGATION CONTINGENCIES 266587 SMT TRAINING 232750 BAD DEBT PROVISIONS 22595 88932 47138068 3339705 2095441 46907574 53286735 0 0 34464206 25642101 0 0 0 0 0 0 12107 17652 1016782 1069380 4381835 1164396 1015929 3217439 0 0 2271559 5426404 0 0 0 0 1218671 758022 90246533 91513174 5855062 5944169 0 0 40928218 30315916 0 0 0 0 0 0 0 0 0 0 588717 761536 47371997 37021621 X 0 0 0 0 42874536 54491553 42874536 54491553 90246533 91513174 X 11475098 217212 -75293 X X false true X true false false false true 39852404 505341 9813 515154 605632 -90478 0 2158427 527037 1631390 0 2165715 770567 1395148 0 190901 0 190901 3217439 ISDA SERVICES EQUITY INTEREST 1000 F MERRILL LYNCH CD'S 247675 F ML CORPORATE BONDS 4005740 F EQUITY INVEST UNCONSOL ENTITY 1171989 F 5426404 0 SALES, PAYROLL & VAT TAXES PAY 22604 DEFERRED RENT PAYABLE 698455 INVESTMENT GAIN/LOSS LIABILITY 36953 CUSTOMER DEPOSIT ON ACCOUNT 2295 IMPORT WASH ACCOUNT 29 761536 X 58760451 103305 103305 58657146 -43980 -43980 58613166 47143434 5366 5366 47138068 47138068 FORM 990, SCHEDULE D, PART X, LINE 2 FINANCIAL STATEMENT FOOTNOTE ISDA IS A NOT-FOR-PROFIT BUSINESS LEAGUE AND AS SUCH IS NOT REQUIRED TO PAY FEDERAL OR STATE INCOME TAXES ON INCOME DERIVED FROM ITS CORE MISSION. ISDA IS SUBJECT TO INCOME TAXES ON UNRELATED BUSINESS INCOME. DURING 2017 AND 2016, ISDA PAID AN IMMATERIAL AMOUNT OF INCOME TAX EXPENSES IN FOREIGN JURISDICTIONS FOR UNRELATED BUSINESS INCOME. THIS AMOUNT HAS BEEN INCLUDED WITHIN GENERAL AND ADMINISTRATIVE ON THE CONSOLIDATED STATEMENTS OF ACTIVITIES AND CHANGES IN NET ASSETS. ISDA HAS REVIEWED ITS TAX EXEMPT STATUS AND PERFORMED AN ANALYSIS OF ALL OF ITS REVENUE STREAMS TO DETERMINE WHICH MAY BE TAXABLE IN THE EVENT THAT THEY WERE CHALLENGED BY THE INTERNAL REVENUE SERVICE. AS OF DECEMBER 31, 2017, ISDA DID NOT IDENTIFY ANY MATERIAL UNCERTAIN TAX POSITIONS. FORM 990, SCHEDULE D, PART XI, LINE 4B RECONCILIATION OF REVENUE BOOK-TAX DIFFERENCE IN UNCONSOLIDATED ENTITY : $ 75,293 REALIZED FX LOSS : $ (113,907) COST OF GOODS SOLD : $ (5,366) ------------------------------------------------------------- TOTAL : $ (43,980) FORM 990, SCHEDULE D, PART XII, LINE 2D RECONCILIATION OF EXPENSES COST OF GOODS SOLD : $ 5,366 Europe (Including Iceland and Greenland) 2 88 Maintaining offices GENERAL & ADMIN 10149394 East Asia and the Pacific 3 33 Maintaining offices GENERAL & ADMIN 3917154 Europe (Including Iceland and Greenland) 32 Program Services CONFERENCES 268421 East Asia and the Pacific 25 Program Services CONFERENCES 333966 North America 1 Program Services CONFERENCES 16786 Europe (Including Iceland and Greenland) 9 Program Services ANNUAL GENERAL MEETING 567136 5 188 5 188 15252857 15252857 false false false false false false X X X X X true false false SCOTT O'MALIA CHIEF EXECUTIVE OFFICER 855822 454989 63430 13514 3387 1391142 0 STEVE KENNEDY SCH J PT III GLOBAL HEAD OF PUBLIC POLICY 464286 288000 0 247179 35879 1035344 288000 KEITH NOYES DIRECTOR, ASIA-PACIFIC REGION 438273 193717 0 0 6146 638136 0 KATHERINE DARRAS SCH J PT III GENERAL COUNSEL 394196 423268 0 3818 22444 843726 230112 MARY CUNNINGHAM CHIEF OPERATING OFFICER 461838 221682 0 23000 13178 719698 0 HUZEFA DEESAWALA SCH J PT III CHIEF FINANCIAL OFFICER 294379 130175 0 118290 36052 578896 130175 MARK GHEERBRANT HEAD OF RISK & CAPITAL 426459 208965 37629 0 3982 677035 0 JING GU SENIOR COUNSEL 316419 109608 0 0 2200 428227 0 CORRINNE GREASLY CHIEF HUMAN RESOURCE OFFICER 123582 35350 459550 5000 24088 647570 0 KAREL ENGELEN SENIOR DIRECTOR 274797 139963 0 19920 36052 470732 0 RICK SANDILANDS SENIOR COUNSEL EUROPE 324324 73268 0 13514 1649 412755 0 BELLA ROZENBERG SCH J PT III SR COUN&HEAD,REG LEGAL PRAC GP 280769 93000 0 108540 35493 517802 93000 FORM 990, SCHEDULE J, PART I, LINE 4A CORRINNE GREASLY RECEIVED A SEVERANCE PAYMENT OF $459,550 REPORTED ON SCHEDULE J, PART II, COLUMN B(III). FORM 990, SCHEDULE J, PART II, COLUMN F * DEFERRED BONUSES FOR THE YEAR ENDED DECEMBER 31, 2017, HUZEFA DEESAWALA, STEVE KENNEDY, KATHERINE DARRAS, AND BELLA ROZENBERG WERE PAID BONUSES DEFERRED FROM 2016, REFLECTED IN SCHEDULE J, COLUMN (B)(II) & COLUMN (F). THE 2017 BONUSES FOR HUZEFA DEESAWALA, STEVE KENNEDY, AND BELLA ROZENBERG REFLECTED IN SCHEDULE J, COLUMN (C) WERE DEFERRED IN 2017 AND PAID IN 2018. FORM 990, PART III, LINE 1 MISSION STATEMENT ISDA FOSTERS SAFE AND EFFICIENT DERIVATIVES MARKETS TO FACILITATE EFFECTIVE RISK MANAGEMENT FOR ALL USERS OF DERIVATIVE PRODUCTS. STRATEGY STATEMENT ISDA ACHIEVES ITS MISSION BY REPRESENTING ALL MARKET PARTICIPANTS GLOBALLY, PROMOTING HIGH STANDARDS OF COMMERCIAL CONDUCT THAT ENHANCE MARKET INTEGRITY AND LEADING INDUSTRY ACTION ON DERIVATIVES ISSUES. THIS INCLUDES BEING: THE PREEMINENT VOICE OF THE GLOBAL DERIVATIVES MARKETPLACE -REPRESENTING THE INDUSTRY THROUGH PUBLIC POLICY ENGAGEMENT, EDUCATION AND COMMUNICATION ADVOCATE FOR EFFECTIVE RISK AND CAPITAL MANAGEMENT -ENHANCING COUNTERPARTY AND MARKET RISK PRACTICES AND ENSURING A PRUDENT AND CONSISTENT REGULATORY CAPITAL AND MARGIN FRAMEWORK THE SOURCE FOR GLOBAL INDUSTRY STANDARDS IN DOCUMENTATION -DEVELOPING STANDARDIZED DOCUMENTATION GLOBALLY TO PROMOTE LEGAL CERTAINTY AND MAXIMUM RISK REDUCTION A STRONG PROPONENT FOR A SAFE, EFFICIENT MARKET INFRASTRUCTURE FOR DERIVATIVES TRADING, CLEARING AND REPORTING -ADVANCING PRACTICES RELATED TO TRADING, CLEARING, REPORTING AND PROCESSING OF TRANSACTIONS IN ORDER TO ENHANCE THE SAFETY, LIQUIDITY AND TRANSPARENCY OF GLOBAL DERIVATIVES MARKETS FORM 990, PART VI, SECTION A, LINE 2 BUSINESS RELATIONSHIPS BETWEEN BOARD MEMBERS RICHARD PRAGER & JACK HATTEM HAVE A BUSINESS RELATIONSHIP. GUY SAIDENBERG & RANA YARED HAVE A BUSINESS RELATIONSHIP. CIARAN O'FLYNN & TOM WIPF HAVE A BUSINESS RELATIONSHIP. HIDEO KITANO & YOSUKE INAIDA HAVE A BUSINESS RELATIONSHIP. JONATHAN HUNTER & SIAN HURRELL HAVE A BUSINESS RELATIONSHIP. THE DIRECTORS LISTED ABOVE DID NOT SERVE ON THE BOARD CONCURRENTLY. FORM 990, PART VI, SECTION A, LINE 4 CHANGE TO GOVERNING DOCUMENTS THE BYLAWS WERE UPDATED IN 2017 TO CONFORM TO CERTAIN AMENDMENTS TO THE NEW YORK NOT-FOR-PROFIT LAW, WHICH TOOK EFFECT MAY 27, 2017. THE CHANGES TO THE ISDA BYLAWS EFFECT CERTAIN CLEANUP CHANGES TO THE BYLAWS, AS WELL AS CONFORM THE FOLLOWING PROVISIONS TO THE NEW AMENDMENTS: (I) THE CHAIRMAN, CO-CHAIRMAN OR VICE CHAIRMAN OF THE BOARD MAY BE NOW BE AN EMPLOYEE OF THE ASSOCIATION, IF APPROVED BY TWO-THIRDS OF THE BOARD; AND (II) ALLOW THAT IF THE BOARD CONSISTS OF AT LEAST 30 DIRECTORS, THE RESOLUTION TO APPOINT AN EXECUTIVE COMMITTEE (OR FILL A VACANCY OF SUCH COMMITTEE) MAY BE ADOPTED BY THREE-QUARTERS OF THE DIRECTORS PRESENT AT THE MEETING. FORM 990, PART VI, SECTION B, LINE 11 FORM 990 REVIEW PROCESS FORM 990 IS REVIEWED BY THE CFO AND CEO. PRIOR TO FILING, FORM 990 IS PROVIDED TO THE MANAGEMENT COMMITTEE. FORM 990, PART VI, SECTION B, LINE 12 CONFLICT OF INTEREST POLICY EACH MEMBER OF THE BOARD, OFFICER, AND KEY EMPLOYEE OF ISDA SHALL FURNISH A CONFLICT OF INTEREST DISCLOSURE STATEMENT TO THE SECRETARY OF ISDA PRIOR TO HIS OR HER ELECTION TO THE BOARD, ELECTION AS AN OFFICER OR APPOINTMENT OF A KEY EMPLOYEE, AS APPLICABLE, AND THEREAFTER ON AN ANNUAL BASIS. THE DISCLOSURE STATEMENTS SHALL BE REVIEWED ANNUALLY BY THE MANAGEMENT COMMITTEE, IN CONSULTATION WITH ISDAS GENERAL COUNSEL. IN ADDITION, EACH MEMBER OF THE BOARD, OFFICER, AND KEY EMPLOYEE SHALL REPORT PROMPTLY TO THE SECRETARY OF ISDA ANY POTENTIAL CONFLICT OF INTEREST AS AND WHEN IT ARISES. PROCEDURES FOR ADDRESSING THE CONFLICTS OF INTEREST: A. ALL QUESTIONS AS TO WHETHER A RELATED PARTY HAS A FINANCIAL INTEREST OR A DUALITY INTEREST, AS APPLICABLE, IN A TRANSACTION, AGREEMENT OR ARRANGEMENT IN WHICH ISDA IS A PARTICIPANT SHALL BE RESOLVED BY A VOTE OF THE BOARD OR THE AUTHORIZED COMMITTEE IN WHICH THE INTERESTED INDIVIDUAL, IF HE OR SHE IS A MEMBER OF THE BOARD, MAY NOT VOTE. B. THE OFFICE OF THE CEO SHALL, IF APPROPRIATE, APPOINT A DISINTERESTED PERSON OR COMMITTEE TO INVESTIGATE ALTERNATIVES TO THE PROPOSED TRANSACTION, AGREEMENT OR ARRANGEMENT. C. AFTER EXERCISING DUE DILIGENCE, IT SHALL BE DETERMINED WHETHER ISDA CAN OBTAIN WITH REASONABLE EFFORTS A MORE ADVANTAGEOUS TRANSACTION, AGREEMENT OR ARRANGEMENT FROM A PERSON OR ENTITY THAT WOULD NOT CONSTITUTE A CONFLICT TRANSACTION. D. IF A MORE ADVANTAGEOUS TRANSACTION OR ARRANGEMENT IS NOT REASONABLY POSSIBLE UNDER CIRCUMSTANCES NOT CONSTITUTING A CONFLICT TRANSACTION, THE BOARD OR THE AUTHORIZED COMMITTEE SHALL DETERMINE BY A MAJORITY VOTE OF THE DISINTERESTED MEMBERS OF THE BOARD WHETHER TO APPROVE THE PROPOSED TRANSACTION, AGREEMENT OR ARRANGEMENT BECAUSE IT IS FAIR, REASONABLE AND IN THE BEST INTEREST OF ISDA. E. THE MINUTES OF THE MEETING OF THE BOARD OR THE AUTHORIZED COMMITTEE CONSIDERING THE CONFLICT TRANSACTION SHALL (I) REFLECT THAT THE RELATED PARTYS FINANCIAL INTEREST OR DUALITY INTEREST, AS APPLICABLE, IN THE TRANSACTION, AGREEMENT OR ARRANGEMENT IN WHICH ISDA IS A PARTICIPANT WAS DISCLOSED, (II) STATE THAT THE RELATED PARTY (AND ANY MEMBER OF THE BOARD, OFFICER, OR KEY EMPLOYEE AFFILIATED WITH THE RELATED PARTY) WAS NOT PRESENT DURING THE FINAL DELIBERATION OR VOTE OF THE BOARD OR THE AUTHORIZED COMMITTEE ON THE CONFLICT TRANSACTION, (III) STATE THAT THE RELATED PARTY, IF A MEMBER OF THE BOARD, ABSTAINED FROM VOTING ON THE CONFLICT TRANSACTION, (IV) DESCRIBE THE ACTION TAKEN BY THE BOARD OR THE AUTHORIZED COMMITTEE RELATING TO THE CONFLICT TRANSACTION (E.G., APPROVAL OR DISAPPROVAL), AND (V) DESCRIBE ANY CONSIDERATION OF ALTERNATIVE TRANSACTIONS, TO THE EXTENT APPLICABLE, BY THE BOARD OR THE AUTHORIZED COMMITTEE. THE BOARD OR THE AUTHORIZED COMMITTEE WILL REPORT THE FOREGOING TO THE MANAGEMENT COMMITTEE PROMPTLY FOLLOWING SUCH MEETING. FORM 990, PART VI, SECTION B, LINES 15A & 15B COMPENSATION REVIEW PROCESS THE COMPENSATION FOR MANAGEMENT STAFF IS REVIEWED AND APPROVED BY THE MANAGEMENT COMMITTEE. THE CEO AND DEPUTY CEO RECUSE THEMSELVES FROM DISCUSSIONS OF THE MANAGEMENT COMMITTEE INVOLVING THEIR COMPENSATION. PRIOR TO APPROVING THE COMPENSATION, THE DATA IS COMPARED TO OTHER INDUSTRY ASSOCIATIONS SIMILAR TO ISDA, OTHER EXCHANGE NON-PROFITS AND FINANCIAL SERVICES COMPARISON GROUP. IN 2016, AN INDEPENDENT COMPENSATION STUDY WAS CONDUCTED. INDEPENDENT COMPENSATION STUDIES ARE CONDUCTED EVERY 2-3 YEARS. FORM 990, PART VI, SECTION C, LINE 19 PUBLIC DISCLOSURE THE BY-LAWS ARE AVAILABLE ON THE WEBSITE. THE CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS ARE AVAILABLE UPON REQUEST. FORM 990, PART XI, LINE 9 OTHER CHANGES IN NET ASSETS OR FUND BALANCES BOOK-TAX DIFFERENCE IN UNCONSOLIDATED ENTITY $ (75,293) FORM 990, PART XII, LINE 2C THE AUDIT PARTNER PRESENTS THE AUDIT RESULTS TO THE MANAGEMENT COMMITTEE AND THE MANAGEMENT COMMITTEE PRESENTS TO THE BOARD. THE AUDIT PARTNER IS ALSO AVAILABLE AT THE BOARD MEETING TO ANSWER ANY QUESTIONS REGARDING THE AUDIT PRESENTATION. 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