2017-09-08T15:55:12-05:00 2016-10-31 GRANT THORNTON LLP 757 THIRD AVE 4TH FLOOR NEW YORK NY 100172013 990 2015-11-01 320178959 Securities Industry and Financial Markets Association % NAM KIM SECU 2123131371 120 Broadway 35TH FLOOR New York NY 10271 DAVID KRASNER CFO & CAO 2123131371 2017-09-08 true Qi Wen Liang P01270238 2125990100 2015 2021-01-29 14:40:06Z KENNETH E BENTSEN 120 Broadway 35TH FLOOR New York NY 10271 66073559 false X www.sifma.org X 2006 DE SIFMA is the voice of the U.S. securities industry. We represent broker-dealers, banks and asset managers, whose 1 million employees provide access to the capital markets. (Sch O) 41 40 175 13121 26900 0 0 62431309 63253574 1510806 1454849 1410280 1365136 65352395 66073559 492400 713927 0 0 35684678 36561391 0 0 0 28367382 26905118 64544460 64180436 807935 1893123 67976235 67911138 29182017 30781884 38794218 37129254 X SIFMA is the voice of the U.S. securities industry. We represent the broker-dealers, banks and asset managers whose nearly 1 million employees provide access to the capital markets, raising over $2.5 trillion for businesses and municipalities in the U.S., serving clients with over $18.5 trillion in assets and managing more than $67 trillion in assets for individual and institutional clients including mutual funds and retirement plans. false false Continued development and maintenance of best practices that are conducive to efficient conduct of the business and members of the organization: CYBERSECURITY The protection of client assets and information and the ability for markets to function through cyber attacks is a top industry priority. With our members, SIFMA has taken the lead in developing policies and procedures for cyber defense and recovery; advocated for harmonization of regulations arising from multiple regulators; coordinated the development of International Cybersecurity, Data and Technology Principles through our global affiliate, GFMA; and sponsored comprehensive industry testing efforts. Our ultimate goal is to identify vulnerabilities and defensive needs, improve resiliency and information sharing, and develop recovery protocols. Municipal Bond Disclosure The disclosure regime in the municipal securities market differs significantly from that of other product sectors. Due to constraints on its ability to regulate and enforce disclosure requirements on municipal issuers directly, the SEC regulates issuer disclosure indirectly through underwriters and dealers, imposing significant compliance burdens and risks relative to other sectors. In 2014, the SECs Division of Enforcement initiated the Municipalities Continuing Disclosure Cooperation (MCDC) Initiative, an ostensibly voluntary enforcement program. The SEC has completed over 100 enforcement actions against municipal securities underwriters and issuers. In the wake of that experience, SIFMA has undertaken an initiative to identify steps regulators and market participants can take to improve disclosure compliance by municipal issuers. We continue to work with a broad group of stakeholders including issuers, investors, auditors, credit analysts and others on initiatives of common interest related to disclosure. MARKET STRUCTURE The structure of our equity and fixed income markets must be continually evaluated to ensure regulation evolves with the dynamic marketplace, while avoiding any unintended negative consequences. Regulators should recognize the uniqueness, importance and diversity of each market as they contemplate myriad issues, including the implementation of a Consolidated Audit Trail (CAT), the impending move to a T+2 shortened settlement cycle, and contemplated rulemakings related to the U.S. Treasury markets. DOL FIDUCIARY STANDARD The Department of Labors final fiduciary rule, issued in April 2016, will have a dramatic impact on how financial advisors interact with their clients. The rule becomes fully applicable in January 2018, and SIFMA is working with our members on its complicated implementation. Our members feel strongly that the approach taken by the DOL could result in less investor choice and greater cost, at the expense of those it attempts to help. We continue our long support for SEC action to establish a uniform standard or best interest standard for broker-dealers and investment advisers when providing personalized investment advice about securities to retail customers. PROTECTING SENIOR INVESTORS SIFMA is committed to finding solutions that help financial advisors protect their senior clients from exploitation and fraudulent practices. We work actively with industry members, academics, and state and federal policymakers to advance policies, practices, rules, regulations and laws which enhance senior investor protections. Advocacy for issues of importance to its members: SIFMA brings together the shared interests of hundreds of broker-dealers, banks and asset managers. We advocate in support of effective and resilient capital markets. SIFMA, on behalf of the financial services industry, engages with policymakers and regulators on a state, federal and global level through comment letters, testimony, studies and more. SIFMAs goal is to ensure regulation is effective, balanced and consistent with its intended purpose, appropriately coordinated with other regulators and regulatory regimes, and avoids constraining capital formation and credit availability, or otherwise impeding the functioning of the markets and the individuals they serve. SHORTENED SETTLEMENT CYCLE SIFMA, together with our partners at the Investment Company Institute (ICI) and Depository Trust Clearing Corporation (DTCC), has developed an implementation playbook at the request of the Securities and Exchange Commission for the industry to adopt this monumental undertaking. Conferences and Seminars SIFMA events foster meaningful conversations about critical issues impacting our financial markets. By providing relevant and lively forums, we bring together industry professionals with leading industry executives and experts, regulators, and policymakers to discuss the most pressing issues facing the capital markets today. In 2016, SIFMA delivered more than 100 in-person and virtual programs for nearly 17,000 industry professionals. In addition, countless roundtables and workshops provided thought leadership, critical industry and policy analysis, continuing education and professional development. SIFMA ANNUAL MEETING At SIFMAs Annual Meeting, financial market professionals gathered with policymakers and regulators to explore how todays business and regulatory environment is impacting the ability of the capital markets to spur economic growth. SIFMA COMPLIANCE & LEGAL SOCIETY ANNUAL SEMINAR SIFMAs C&L Annual Seminar gathered almost 2,000 compliance and legal professionals and regulators for its 48th forum, including more than 65 breakout sessions from more than 100 organizations. These experts covered both core and emerging topics, and provided an opportunity for industry professionals and regulators alike to share their respective expertise and insight with the goal of preserving our capital markets as the most fair, transparent and ethical in the world. PRIVATE CLIENT CONFERENCE For 39 years, SIFMAs annual Private Client Conference has served as North Americas leading event for financial professionals who service the individual investor. The event brings together the top industry leaders to discuss relevant and pressing topics affecting our industry today, while delivering practical strategies to enhance the client experience, help advisors succeed, and operate more effectively. OPERATIONS CONFERENCE & EXHIBITION The trusted resource for broker-dealers and asset managers on the evolution of operations and regulation since 1973, the 43rd annual Operations Conference & Exhibition gathered industry leaders to discuss insights and strategies addressing industry challenges including the Department of Labors fiduciary rule, T+2 implementation, regulatory changes, operational risk, cybersecurity, Blockchain, the Consolidated Audit Trail and more. THE SECURITIES INDUSTRY INSTITUTE The Securities Industry Institute (R)(SII) is an executive education program uniquely tailored to financial services professionals, delivered through SIFMAs partnership with The Wharton School of Business at the University of Pennsylvania. Held on the Wharton campus, participants meet for one week each March to complete required coursework over three consecutive years. High-performance talent is nurtured with forward-thinking, relevant curriculum that delivers long-term impact; the highest standards of integrity, ethics and professional excellence; and tremendous networking opportunities. Graduates of SII have advanced to increasingly higher levels of management and leadership within their firms and the industry. false false false true false false false true false true false false false true true true false false false false false false false false false false true false true false false false false false false false false false false false false false false true 180 0 true 175 true true true false false false false false X 41 40 false false false false true true false true true false false true true true true true true true true false X NAM KIM 2123131371 120 BROADWAY 35TH FLOOR NEW YORK NY 10271 JOHN FW ROGERS CHAIRMAN OF THE BOARD 2.0 0.0 X X 0 0 0 TIMOTHY C SCHEVE CHAIR-ELECT 2.0 0.0 X X 0 0 0 LISA KIDD HUNT VICE CHAIR 2.0 0.0 X X 0 0 0 GERARD MCGRAW TREASURER 2.0 0.0 X X 0 0 0 JAMES R ALLEN DIRECTOR 1.0 0.0 X 0 0 0 DAN ARNOLD DIRECTOR 1.0 0.0 X 0 0 0 BARRY BAUSANO DIRECTOR 1.0 0.0 X 0 0 0 CURT BRADBURY JR DIRECTOR 1.0 0.0 X 0 0 0 VALERIE G BROWN DIRECTOR 1.0 0.0 X 0 0 0 WILLIAM C CACCAMISE DIRECTOR 1.0 0.0 X 0 0 0 DANIEL B COLEMAN DIRECTOR 1.0 0.0 X 0 0 0 MICHAEL CROWL DIRECTOR 1.0 0.0 X 0 0 0 LISA DOLLY DIRECTOR 1.0 0.0 X 0 0 0 ANDEW S DUFF DIRECTOR 1.0 0.0 X 0 0 0 JOHN ETTELSON DIRECTOR 1.0 0.0 X 0 0 0 DAVID FINDLAY DIRECTOR 1.0 0.0 X 0 0 0 CATHERINE FLAX DIRECTOR 1.0 0.0 X 0 0 0 KIM TILLOTSON FLEMING DIRECTOR 1.0 0.0 X 0 0 0 SUNI HARFORD DIRECTOR 1.0 0.0 X 0 0 0 TIM HOCKEY DIRECTOR 1.0 0.0 X 0 0 0 DOUGLAS M HODGE DIRECTOR 1.0 0.0 X 0 0 0 WILLIAM A JOHNSTONE DIRECTOR 1.0 0.0 X 0 0 0 JAMES B KELLIGREW JR DIRECTOR 1.0 0.0 X 0 0 0 ANDREW KOMAROFF DIRECTOR 1.0 0.0 X 0 0 0 RONALD J KRUSZEWSKI DIRECTOR 1.0 0.0 X 0 0 0 BRAND MEYER DIRECTOR 1.0 0.0 X 0 0 0 ROGER OCHS DIRECTOR 1.0 0.0 X 0 0 0 SANDRA O'CONNOR DIRECTOR 1.0 0.0 X 0 0 0 DAVID ORNSTEIN DIRECTOR 1.0 0.0 X 0 0 0 EDWARD PICK DIRECTOR 1.0 0.0 X 0 0 0 PAUL E PURCELL DIRECTOR 1.0 0.0 X 0 0 0 PAUL REILLY DIRECTOR 1.0 0.0 X 0 0 0 SUZANNE SHANK DIRECTOR 1.0 0.0 X 0 0 0 PAUL STEVELMAN DIRECTOR 1.0 0.0 X 0 0 0 JOSEPH E SWEENEY DIRECTOR 1.0 0.0 X 0 0 0 JAMES A TRICARICO JR DIRECTOR 1.0 0.0 X 0 0 0 JOHN ADAMS VACCARO DIRECTOR 1.0 0.0 X 0 0 0 JAMES WALLIN DIRECTOR 1.0 0.0 X 0 0 0 LEWIS H WIRSHBA DIRECTOR 1.0 0.0 X 0 0 0 W RUFUS YATES DIRECTOR 1.0 0.0 X 0 0 0 FRANCOIS O BARTHELEMY DIRECTOR (THRU 11/2015) 1.0 0.0 X 0 0 0 DAVID L BRUNNER DIRECTOR (THRU 02/2016) 1.0 0.0 X 0 0 0 KENNETH D GIBBS DIRECTOR (THRU 11/2015) 1.0 0.0 X 0 0 0 THOMAS HARNETT DIRECTOR (THRU 01/2016) 1.0 0.0 X 0 0 0 TIMOTHY P O'HARA DIRECTOR (THRU 09/2016) 1.0 0.0 X 0 0 0 RICHARD B PAYNE JR DIRECTOR (THRU 03/2016) 1.0 0.0 X 0 0 0 KAREN B PEETZ DIRECTOR (THRU 07/2016) 1.0 0.0 X 0 0 0 JIM ROSENTHAL DIRECTOR (THRU 11/2015) 1.0 0.0 X 0 0 0 JOHN G TAFT DIRECTOR (THRU 11/2015) 1.0 0.0 X 0 0 0 KEIKO TASHIRO DIRECTOR (THRU 03/2016) 1.0 0.0 X 0 0 0 FREDERICK TOMCZYK DIRECTOR (THRU 09/2016) 1.0 0.0 X 0 0 0 GEORGE WALKER DIRECTOR (THRU 07/2016) 1.0 0.0 X 0 0 0 KENNETH E BENTSEN JR PRESIDENT AND CEO 40.0 0.0 X X 2242560 0 71989 RANDOLPH C SNOOK EXECUTIVE VICE PRESIDENT 40.0 0.0 X 1029676 0 67043 IRA D HAMMERMAN EVP AND GENERAL COUNSEL, SECRE 40.0 0.0 X 925026 0 88274 CHERYL L CRISPEN EXECUTIVE VICE PRESIDENT 40.0 0.0 X 536308 0 38810 ANDY BLOCKER EXECUTIVE VICE PRESIDENT 40.0 0.0 X 682808 0 74374 DAVID B KRASNER CFO & CAO 40.0 0.0 X 633880 0 73990 SALVATORE CHIARELLI MANAGING DIRECTOR 40.0 0.0 X 292851 0 47376 TIMOTHY W CAMERON MANAGING DIRECTOR, AMG 40.0 0.0 X 585872 0 72524 KEVIN CARROLL MANAGING DIRECTOR 40.0 0.0 X 444384 0 37588 MICHAEL B DECKER MANAGING DIRECTOR 40.0 0.0 X 484599 0 76593 CARTER K MCDOWELL MD, ASSOCIATE GEN COUNSEL 40.0 0.0 X 486730 0 65001 ROBERT TOOMEY MANAGING DIRECTOR 40.0 0.0 X 449725 0 72681 8794419 0 786243 84 false true false CLEARY GOTTLIEB STEEN HAMILTON LL ONE LIBERTY PLAZA NEW YORK NY 10006 LEGAL 851136 TRUSTEES UNIV OF PENNSYLVANIA 255 S 38TH STREET PHILADELPHIA PA 19104 CONFERENCES 794508 DAVIS POLK WARDWELL LLP 450 LEXINGTON AVENUE NEW YORK NY 10017 LEGAL 665553 ERNST YOUNG PO BOX 640382 PITTSBURGH PA 152640382 CONSULTING 565639 SIDLEY AUSTIN LLP PO BOX 0642 CHICAGO IL 60690 LEGAL 510479 26 0 MEMBER DUES 541900 47191969 47191969 CONFERENCES 541900 15939067 15918617 20450 PUBLICATION SALES 900099 122538 116088 6450 63253574 1454849 1454849 0 119733 119733 0 0 0 0 0 0 0 SHARED SERVICE AGREEMENT 561000 1143001 1143001 MISCELLANEOUS REVENUE 900099 102402 102402 1245403 66073559 63226674 26900 2819985 713927 0 0 0 0 6842771 0 0 0 0 22992682 0 0 0 2625980 0 0 0 2718824 0 0 0 1381134 0 0 0 181885 0 0 0 3106364 0 0 0 177348 0 0 0 1500892 0 0 0 0 78405 0 0 0 2112230 0 1333461 0 0 0 655106 0 0 0 0 4586844 0 0 0 1645254 0 0 0 0 8085648 0 0 0 0 0 2089028 0 0 0 0 SUBSCRIPTION AND BOOKS 525044 0 0 0 BANK CHARGES & CC PROCESSING 281544 0 0 0 PRINTING 260576 0 0 0 DUES & REGISTRATION 211142 0 0 0 74347 64180436 0 0 0 1327546 1778565 17005739 19071377 0 0 220898 38032 0 0 0 0 0 0 0 0 4114207 3798520 29993654 20760580 10841086 9233074 32007032 32948350 0 0 0 0 0 0 2459727 1043220 67976235 67911138 10515050 11574238 0 0 3152806 2823599 0 0 1275882 1347036 0 0 0 0 0 0 14238279 15037011 29182017 30781884 X 38794218 37129254 0 0 0 0 38794218 37129254 67976235 67911138 X 1893123 -489489 -3068598 X false true X true false false false false 47191969 6555582 6555582 7078795 false true X 20593770 12256234 8337536 9399884 8504346 895538 9233074 0 EMPLOYEE BENEFITS PAYABLE 10037103 DEFERRED RENT & CONSTR. ALLOWANCES 4999908 15037011 X 65642191 -489489 -489489 66131680 -58121 -58121 66073559 67307155 3068598 3068598 64238557 -58121 -58121 64180436 Part IV Custodial Arrangements In order to finance certain member driven projects that are beyond SIFMA's operating budget resources and which impact only a subset of members, SIFMA syndicates out such project cost to participating member firms. The 3rd party project cost (and associated member reimbursement) is maintained within the SIFMA balance sheet. In 2016, the syndicated funds collected from members and disbursed for such special projects totaled $2,128,324 and $2,057,170, respectively. Part X FIN 48 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 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 processes presently in place to ensure the maintenance of its tax-exempt status; to identify and report unrelated income; to determine its filing and tax obligations in jurisdictions for which it has nexus; and to identify and evaluate other matters that may be considered tax positions. The tax years ending October 31, 2013, 2014, 2015, and 2016 are still open for audit for both federal and state purposes. The Association has determined that there are no material uncertain tax positions that require recognition or disclosure in the financial statements. Part XII, Line 2d Post-retirement related changes other than Net periodic post post-retirement benefit cost $2,900,481 Membership dues reserve $168,117 ------------ Total other changes: $3,068,598 ============ true SCHOLARSHIP AMERICA 226 W NASSAU STREET ST PETER MN 56082 042296967 501(c)(3) 17950 PROGRAM SUPPORT THE BARUCH COLLEGE FUND 1 BERNARD BARUCH WAY NEW YORK NY 10010 131988190 501(c)(3) 10000 PROGRAM SUPPORT NCSL FOUNDATION FOR STATE LEGISLATURES 7700 EAST FIRST PLACE DENVER CO 80230 742232576 501(c)(3) 7500 PROGRAM SUPPORT AMERICAN COUNCIL FOR CAPITAL FORMATION 1001 CONNECTICUT AVE WASHINGTON DC 20036 521266620 501(c)(6) 25000 PROGRAM SUPPORT COMMITTEE ON CAPITAL MARKETS REGULATION INC 125 MT AUBURN ST CAMBRIDGE MA 02138 300406260 501(c)(3) 50000 PROGRAM SUPPORT NEW YORK LAW SCHOOL 185 WEST BROADWAY SUITE 400 NEW YORK NY 10013 135645885 501(c)(3) 10000 PROGRAM SUPPORT SEC HISTORICAL SOCIETY 1101 PENNSYLVANIA AVE WASHINGTON DC 20004 522213646 501(c)(3) 10000 PROGRAM SUPPORT WOMEN'S INSTITUTE FOR A SECURE RETIREMENT 1140 19TH STREET WASHINGTON DC 20036 521405988 501(c)(3) 20000 PROGRAM SUPPORT CONCERTS FOR A CAUSE 718 7TH STREET NW WASHINGTON DC 20001 471552404 10000 PROGRAM SUPPORT PREVENT CANCER FOUNDATION 1600 DUKE STREET ALEXANDRIA VA 22314 741774063 501(c)(3) 7000 PROGRAM SUPPORT NAPSA PO BOX 96503 WASHINGTON DC 20090 300044497 501(c)(3) 25000 PROGRAM SUPPORT THE CLEVELAND DEVELOPMENT FOUNDATION 1240 HURON ROAD E CLEVELAND OH 44115 530204610 501(c)(3) 10000 PROGRAM SUPPORT FORMER MEMBERS OF CONGRESS INC 1401 K STREET WASHINGTON DC 20005 136122376 501(c)(3) 6000 PROGRAM SUPPORT UNITED STATES CAPITOL HISTORICAL SOCIETY 200 MARYLAND AVE NE WASHINGTON DC 20002 520796820 501(c)(3) 10000 PROGRAM SUPPORT WASHINGTON TENNIS & EDUCATION FOUNDATION 16TH AND KENNEDY ST WASHINGTON DC 20011 521914894 501(c)(3) 6000 PROGRAM SUPPORT THIRD WAY 1025 CONNECTICUT NW501 WASHINGTON DC 20036 201734070 501(c)(4) 82500 PROGRAM SUPPORT THE BROOKINGS INSTITUTION 1775 MA Ave WASHINGTON DC 20036 530196577 501(c)(3) 100000 PROGRAM SUPPORT AMERICAN ACTION FORUM 1747 Pennsylvania Ave Washington DC 20006 270567765 501(c)(3) 35000 PROGRAM SUPPORT Bipartisan Policy Center 1225 Eye Street NW Washington DC 20005 731628382 501(c)(3) 180000 PROGRAM SUPPORT THE RIPON SOCIETY 1155 15th Street NW Washington DC 20005 042340356 501(c)(4) 25000 PROGRAM SUPPORT SIFMA Foundation for Investor Education Inc 120 Broadway 35th Floor New York NY 10271 521087193 35000 PROGRAM SUPPORT 17 4 Part I, Line 2 Grant monitoring SIFMA provides support to charitable organizations to help those organizations further their exempt programs. SIFMA is not a grant making organization but will occasionally award a grant to organizations in support of a project that aligns itself with SIFMA's mission of promoting and supporting a strong financial industry. SIFMA maintains in its records the acknowledgment letter from the recipient organization and any follow up reports on the use of grant funds. X true true X X X X false true false KENNETH E BENTSEN JR PRESIDENT AND CEO 1488948 0 750000 0 3612 0 31800 0 40189 0 2314549 0 0 0 RANDOLPH C SNOOK EXECUTIVE VICE PRESIDENT 656064 0 370000 0 3612 0 33969 0 33074 0 1096719 0 0 0 IRA D HAMMERMAN EVP AND GENERAL COUNSEL, SECRE 578414 0 325000 0 21612 0 47550 0 40724 0 1013300 0 0 0 CHERYL L CRISPEN EXECUTIVE VICE PRESIDENT 361876 0 172500 0 1932 0 31800 0 7010 0 575118 0 0 0 ANDY BLOCKER EXECUTIVE VICE PRESIDENT 536548 0 145000 0 1260 0 31800 0 42574 0 757182 0 0 0 DAVID B KRASNER CFO & CAO 396948 0 235000 0 1932 0 31800 0 42190 0 707870 0 0 0 SALVATORE CHIARELLI MANAGING DIRECTOR 191591 0 100000 0 1260 0 31800 0 15576 0 340227 0 0 0 TIMOTHY W CAMERON MANAGING DIRECTOR, AMG 422260 0 160000 0 3612 0 31800 0 40724 0 658396 0 0 0 KEVIN CARROLL MANAGING DIRECTOR 328124 0 115000 0 1260 0 31800 0 5788 0 481972 0 0 0 MICHAEL B DECKER MANAGING DIRECTOR 357667 0 125000 0 1932 0 33969 0 42624 0 561192 0 0 0 CARTER K MCDOWELL MD, ASSOCIATE GEN COUNSEL 408118 0 75000 0 3612 0 31800 0 33201 0 551731 0 0 0 ROBERT TOOMEY MANAGING DIRECTOR 331113 0 115000 0 3612 0 33969 0 38712 0 522406 0 0 0 Part I, Line 1a Per the employment contract, SIFMA provided first class air travel when traveling for SIFMA business for Kenneth E. Bentsen, Jr., President and CEO. The first-class air travel was excluded from taxable compensation on the individual's form W-2 because it was incurred for business reasons. Part I, Line 4B EVP and General Counsel participates in a 457(f) plan and a 457(b) plan. He received a taxable payment of $18,000 as part of the 457(b) plan included in his W-2, and SIFMA contributed $15,750 into the 457(f) Plan during calendar year 2015. Part I, Line 6 The number of volunteers was derived from SIFMA committee participants per the membership data base. Part III, Line 4d Continued serving as a source of market information, including statistics on many facets of the market place and publishing research reports, trade newsletters and other periodicals and books. Part VI, Section A, Line 6 SIFMA is a membership organization with the following classes of membership: Broker-Dealer Members and Asset Manager Members Each Broker-Dealer Member and Asset Manager Member shall be entitled to vote with respect to the election of Directors and other matters as may be submitted at any annual or other meeting of Members entitled to vote. Associate Members Associate Members shall not be entitled to vote with respect to the election of Directors and other matters as may be submitted at any annual or other meeting of Members entitled to vote, and shall not be eligible to serve as Directors of the Association. Part VI, Section B, Line 11a 990 REVIEW PROCESS The Accounting department of the Organization prepares the Form 990 based on audited financial information. The draft Form 990 is then reviewed by management and an external independent accounting firm. The Audit and Finance Committee will review the final draft signed off by the external independent tax accountant. This review will be noted as an agenda item at an Audit and Finance Committee meeting and will be duly noted in the minutes. The Form 990 will be provided to all voting members of the Board of Trustees prior to submission to the IRS. Part VI, Section B, Line 12c CONFLICT OF INTEREST POLICY MONITORING & ENFORCEMENT Any employee in a position where his or her objectivity may be questioned because of an individual interest or family or personal relationship is required to notify the General Counsel. Similarly, any employee aware of any transaction or relationship that could reasonably be expected to give rise to a personal conflict of interest is required to discuss the matter promptly with the General Counsel. In addition, once every year, directors, officers, key employees, and all the employees of SIFMA are required to review a copy of the Conflict of Interest Policy and to acknowledge in writing that he or she is compliant. Part VI, Section B, Line 15 PROCESS FOR DETERMINING COMPENSATION The executive committee and the board acting as compensation committee hire consultants to review comparable packages for any new incoming CEO and officers. The consultant presents data for comparable positions both locally and nationally and the board's executive committee makes the final decision for the salary package. Currently, the CEO has an employment contract which was approved by the executive committee and the board, governing annual salary increase and any bonus payments. For the remaining senior officers, the annual salary increase and bonus payments are determined by the annual evaluation process which must be approved by the board's compensation committee. Part VI, Section C, Line 19 AVAILABILITY OF DOCUMENTS Any request for governing documents, conflict of interest policy, and financial statements will be provided upon request at management's discretion. Part XI, Line 9 Post-retirement related changes other than Net periodic post-retirement benefit cost $(2,900,481) Membership dues reserve $(168,117) -------------- Total other changes: $(3,068,598) ==============