2026-04-08T14:48:14-05:00 2025-06-30 420714325 RSM US LLP 19026 RIDGEWOOD PKWY STE 400 SAN ANTONIO TX 78259 990 2024-07-01 426081293 PALMER COLLEGE FOUNDATION PALM 5638845000 1000 BRADY STREET DAVENPORT IA 52803 JENNIFER RANDAZZO TREASURER 5638845141 2026-03-30 1 1 REBECCA A RODRIGUEZ P01073764 2108286281 2026-03-30 2024 2025-03-06 01:10:19Z PALMER COLLEGE OF CHIROPRACTIC DENNIS MARCHIORI DC PHD 1000 BRADY STREET DAVENPORT IA 52803 245048969 0 X WWW.PALMER.EDU X 1897 IA PROMOTE LEARNING, DELIVER HEALTH CARE, ENGAGE OUR COMMUNITIES AND ADVANCE KNOWLEDGE THROUGH RESEARCH. 12 11 992 400 0 0 2898815 3189552 77873586 81438762 8543558 18390098 4333546 4194559 93649505 107212971 3397403 3579844 0 0 33980865 37169878 200996 346656 392263 35891864 36135204 73471128 77231582 20178377 29981389 320084450 343544806 59645107 58603352 260439343 284941454 X PROMOTE LEARNING, DELIVER HEALTH CARE, ENGAGE OUR COMMUNITIES AND ADVANCE KNOWLEDGE THROUGH RESEARCH. 0 0 38089413 3579844 79467899 PALMER COLLEGE EDUCATES STUDENTS WITH A DOCTOR OF CHIROPRACTIC DEGREE. STUDENTS ARE PROVIDED CLASSROOM AND LAB INSTRUCTION TO LEARN THE SCIENCE, ART AND PHILOSOPHY OF CHIROPRACTIC. ENROLLMENT FOR THE SPRING 2025 TERM WAS 1,943 STUDENTS. 9542236 0 1385643 PALMER COLLEGE OPERATES CHIROPRACTIC CLINICS TO EXTEND THE STUDENT EDUCATION FROM THE CLASSROOM TO DIRECT PATIENT CARE. THE DOCTOR OF CHIROPRACTIC DEGREE IS A 10 TRIMESTER PROGRAM OF WHICH THE FINAL 1/3 IS SPENT IN THE CLINIC SETTING WORKING WITH PATIENTS. STUDENT TUITION REPORTED ABOVE IS USED TO OFFSET THE COST OF CLINIC OPERATIONS. 2703697 0 0 PALMER CENTER FOR CHIROPRACTIC RESEARCH IS DEDICATED TO IMPACTING PATIENT CARE AND POLICY THROUGH RESEARCH, ANALYSIS AND INTELLIGENCE. PCCR TAKES A COMPREHENSIVE APPROACH TO RESEARCH FOCUSING ON BASIC AND CLINICAL SCIENCES IN ADDITION TO HEALTH SERVICES WORK. GRANT INCOME RECEIVED DURING THE YEAR WAS JUST OVER $1,100,000. 6596327 500662 AUXILIARY ENTERPRISES AND ACTIVITIES RELATED TO OPERATION OF BOOKSTORE, CAFETERIA, PRINT SHOP, STUDENT HOUSING, AND CONTINUING EDUCATION PROGRAMS. 6596327 500662 56931673 1 1 0 0 0 0 0 1 0 1 1 0 0 0 1 1 0 1 1 0 0 0 0 1 0 0 0 1 1 1 1 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 1 1 1 0 0 1 2529 0 1 992 1 0 0 0 0 0 0 0 0 0 0 1 0 X 12 11 0 0 0 0 1 1 1 1 1 0 0 1 1 1 1 1 1 1 0 0 AK CA IA MD NH OR SC WA X JENNIFER RANDAZZO 5638845000 1000 BRADY STREET DAVENPORT IA 52803 TREVOR V IRELAND DC TRUSTEE/CHAIRPERSON 20.00 10.00 X X 0 0 0 PAUL VANDUYNE PE DC TRUSTEE/VICE CHAIRPERSON 5.00 2.00 X X 0 0 0 VICKIE A PALMER HCD TRUSTEE/SECRETARY GENERAL 1.00 1.00 X X 0 0 0 KENNETH R KOUPAL TRUSTEE/INTERIM ASST SEC GENERAL 1.00 1.00 X X 1099 0 0 KENT PILCHER TRUSTEE 1.00 1.00 X 2464 0 0 DONNA CRAFT DC TRUSTEE 1.00 1.00 X 0 0 0 DON BETZ PHD TRUSTEE 1.00 1.00 X 1485 0 0 DONALD DOUCETTE PHD TRUSTEE 1.00 1.00 X 0 0 0 SUSAN HATFIELD PHD TRUSTEE 1.00 1.00 X 658 0 0 MICHAEL CHANCE DC TRUSTEE 1.00 1.00 X 2784 0 0 NATHAN HINKELDEY DC DACRB TRUSTEE 1.00 1.00 X 0 0 0 CHARLES KELLER DC MA TRUSTEE 1.00 1.00 X 0 0 0 DENNIS MARCHIORI DC PHD PRESIDENT/CEO 30.00 10.00 X 1207266 0 129174 DAN WEINERT DC PROVOST/EXECUTIVE VICE PRESIDENT 40.00 X 299667 0 128835 JENNIFER RANDAZZO VICE CHANCELLOR FINANCE/TREASURER 30.00 10.00 X 240409 0 108156 WILLIAM SHERRIER DC MA CAMPUS PRESIDENT 40.00 X 194230 0 48326 ROBERT PERCUOCO DC VICE CHANCELLOR 40.00 X 214841 0 51766 CYNTHIA LONG DC DEAN OF RESEARCH 40.00 X 218026 0 47220 BARBARA MELBOURNE JD VICE CHANCELLOR 40.00 X 209118 0 50757 MICHAEL NORRIS PHD VICE CHANCELLOR OF ADMISSIONS 40.00 X 214360 0 50247 IAN MCLEAN DIRECTOR OF CLINIC RADIOLOGY 40.00 X 230807 0 13385 KEVIN CUNNINGHAM DC FACULTY (FORMER VICE CHANCELOR) 40.00 X 132679 0 50890 3169893 0 678756 64 1 1 0 ESTES COMPANY PO BOX 3608 DAVENPORT IA 52808 CAMPUS CONSTRUCTION PROJECTS 1507108 ARAMARK 1101 MARKET ST PHILADELPHIA PA 19107 CAMPUS FOOD SERVICES 1134130 MAD FISH DIGITAL PO BOX 11333 PORTLAND OR 97211 ADVERTISING SERVICES 962377 FBG SERVICE CORPORATION 407 S 27TH AVENUE OMAHA NE 68131 CAMPUS JANITORIAL SERVICES 904390 PER MAR SECURITY SERVICES 1910 E KIMBERLY RD DAVENPORT IA 52807 CAMPUS SECURITY SERVICES 836410 28 2025888 1163664 10277 3189552 TUITION AND FEES 611600 79467899 79467899 CLINIC REVENUE 611710 1385643 1385643 AUXILIARY ENTERPRISES 611600 500662 500662 INT ON LOANS RECEIVABL 900099 49486 49486 REGSTRTN FEES & LIBRAR 900099 35072 35072 81438762 5549776 5549776 3278348 0 3278348 3278348 3278348 147989930 1419893 135072412 1497089 12917518 -77196 12840322 12840322 1937158 1266497 670661 670661 RESEARCH EXP RECOVERY 900099 176265 176265 CAMPUS BASE ADMIN INC 900099 37328 37328 SUNDRY INCOME 900099 31957 31957 245550 107212971 81354204 0 22669215 20000 20000 3559844 3559844 1755351 15249 1740102 26550283 20137565 6412718 2280223 1364144 916079 4565682 3408879 1156803 2018339 1471584 546755 172768 172768 102064 102064 346656 346656 182565 182565 6529239 4820249 1668921 40069 1728677 1502003 225529 1145 2034074 1445177 584671 4226 3561437 2495383 1066054 7495023 5999222 1495801 445887 236455 209265 167 455196 12759 442437 1763960 1763960 7260951 5785651 1475300 1479801 189118 1290683 UBI TAX 6 6 RESEARCH EXPENSE 891447 891447 STUDENT AID 856343 856343 LIBRARY 444624 444624 731142 512017 219125 77231582 56931673 19907646 392263 1788703 1010428 61666354 94933792 2309046 1938211 918642 592088 691233 584103 1386154 2131283 262540073 100218179 160660094 162321894 81927691 73418555 1431015 1034497 7305518 5579955 320084450 343544806 8956818 9904839 305039 0 2106733 1965447 33170536 31933590 14321411 13989063 784570 810413 59645107 58603352 X 202246255 226208828 58193088 58732626 260439343 284941454 320084450 343544806 X 29981389 -4298741 -1180537 X X 0 1 X 1 1 1 X 5602425 13404393 12675330 2898815 3189552 37770515 5602425 13404393 12675330 2898815 3189552 37770515 4744558 33025957 2885305 4182303 4989655 7418711 8828124 28304098 919 238 1157 446863 570858 335919 353217 245550 1952407 68028177 375987875 0.48550 0.52250 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 X X X 0 79177302 772920 9084469 1007864 602254 -424181 87848754 72258799 412925 8091744 1586165 79177303 65379747 2640448 6868686 2630082 72258799 75176266 1830998 -9383576 897264 1346981 65379443 60382037 444484 16546465 1164744 1031975 75176267 0.37000 0.63000 0.00000 0 0 6614172 6614172 206422594 71789150 134633444 17774319 10274747 7499572 25313216 18154282 7158934 6415772 6415772 162321894 ANNUITIES PAYABLE 148000 CONDITIONAL ASSET RETIREMENT OBLIGATION 647191 FUNDS HELD FOR RELATED PARTY 15222 810413 X 100694287 -4298741 1266497 -3032244 103726531 182565 3303875 3486440 107212971 76192176 2447034 2447034 73745142 182565 3303875 3486440 77231582 PART III, LINE 4: THE ART IS A COLLECTION OF ORIENTAL ART, SCULPTURES AND ARTIFACTS ACQUIRED BY THE PALMER FAMILY IN ITS TRAVELS IN THE EARLY 20TH CENTURY. THE COLLECTION WAS LATER DONATED TO THE COLLEGE BY THE FAMILY. THE CHIROPRACTIC PROFESSION WAS FOUNDED BY D.D. PALMER AND DEVELOPED BY FUTURE GENERATIONS OF PALMERS. IN THOSE EARLY YEARS THE DEVELOPMENT OF THE PROFESSION WAS CLOSELY LINKED TO THE FAMILY HISTORY. TO OUR STUDENTS WHO STUDY THE PHILOSOPHY, SCIENCE AND ART OF CHIROPRACTIC, THIS COLLECTION IS TANGIBLE EVIDENCE OF THE HISTORY OF THE CHIROPRACTIC PROFESSION. PART V, LINE 4: ENDOWMENT FUNDS ARE USED PER DONOR SPECIFICATIONS. THEY ARE PRIMARILY DESIGNATED TO PROVIDE STUDENT SCHOLARSHIPS BUT ARE ALSO USED FOR FACILITIES, PROGRAMS, AND ADMINISTRATIVE EXPENSES. THE ADMINISTRATIVE EXPENSES OF -424,181 IS RELATED TO THE TRANSFER FROM THE RELATED ORGANIZATION, PALMER COLLEGE OF CHIROPRACTIC WEST. PART X, LINE 2: MANAGEMENT HAS EVALUATED THEIR MATERIAL TAX POSITIONS, WHICH INCLUDE SUCH MATTERS AS THE TAX-EXEMPT STATUS OF EACH ENTITY AND VARIOUS POSITIONS RELATIVE TO POTENTIAL SOURCES OF UBI. AS OF JUNE 30, 2025 AND 2024, THERE WERE NO UNCERTAIN TAX BENEFITS IDENTIFIED AND RECORDED AS A LIABILITY. PART XI, LINE 2D - OTHER ADJUSTMENTS: COST OF GOODS SOLD NETTED WITH REVENUE 1,266,497. PART XI, LINE 4B - OTHER ADJUSTMENTS: INSTITUTIONAL GRANTS 3,559,844. ASSET DISPOSAL -77,196. EXPENSES NETTED WITH REVENUE -178,773. PART XII, LINE 2D - OTHER ADJUSTMENTS: COST OF GOODS SOLD NETTED WITH REVENUE 1,266,497. LOSS ON INTEREST RATE SWAP 1,180,537. PART XII, LINE 4B - OTHER ADJUSTMENTS: INSTITUTIONAL GRANTS 3,559,844. ASSET DISPOSAL -77,196. EXPENSES NETTED WITH REVENUE -178,773. 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 1 0 1 SCHEDULE E, PART I, LINE 3 PALMER COLLEGE OF CHIROPRACTIC PUBLISHES ITS EQUAL OPPORTUNITY STATEMENT IN PRINTED MATERIALS THROUGHOUT THE STUDENT RECRUITMENT AND ORIENTATION PERIOD. PALMER COLLEGE OF CHIROPRACTIC DOES NOT ROUTINELY USE NEWSPAPER OR BROADCAST MEDIA IN ITS STUDENT RECRUITMENT EFFORTS. HOWEVER, THE COLLEGE DOES PUBLICIZE ITS RACIALLY NONDISCRIMINATORY POLICY IN A WAY THAT MAKES THE POLICY KNOWN TO PROSPECTIVE STUDENTS BY PUBLISHING THE COLLEGE'S EQUAL OPPORTUNITY STATEMENT IN PRINTED MATERIALS PROVIDED THROUGHOUT THE STUDENT RECRUITMENT PERIOD. IN ADDITION, THE FOUNDATION'S EQUAL OPPORTUNITY STATEMENT IS PROVIDED TO CURRENT STUDENTS AND THE GREATER COLLEGE COMMUNITY IN THE COLLEGE CATALOG, WHICH IS AVAILABLE IN PRINT AND ON THE PALMER WEBSITE, AS WELL AS IN THE STUDENT HANDBOOK, WHICH IS DISTRIBUTED TO ALL STUDENTS DURING THE STUDENT ORIENTATION PROGRAM. SCHEDULE E, PART I, LINE 6 FINANCIAL AID OR ASSISTANCE IS RECEIVED FROM THE FOLLOWING GOVERNMENTAL AGENCIES: PELL GRANT PROGRAM SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS (SEOG) FEDERAL WORK STUDY PROGRAMS (FWS) PERKINS LOAN PROGRAM DEPARTMENT OF HEALTH AND HUMAN SERVICES (HHS) NATIONAL INSTITUTE OF HEALTH (NIH) HEALTH RESOURCES AND SERVICES ADMINISTRATION (HRSA) X X X X X X 1 THE NUMAD GROUP PO BOX 230 HERMOSA SD 57744 FUNDRAISING CONSULTING 0 0 301656 -301656 TWB FUNDRAISING TWO N RIVERSIDE PLAZA STE 1875 CHICAGO IL 60606 FUNDRAISING CONSULTING 0 0 45000 -45000 346656 -346656 AL AK AR AZ CA CT DC DE FL GA HI IA ID IL IN KS KY LA MD ME MN MO MS MT NC ND NE NH NJ NM NV OH OK OR PA RI SC SD TN TX UT VA VT WA WI WV WY 1 FOUNDATION FOR CHIROPRACTIC PROGRESS PO BOX 560 CARMICHAEL CA 95609 202137895 501(C)(6) 20000 0 N/A N/A GENERAL FUND - TO SUPPORT MISSION OF EDUCATING THE PUBLIC ON CHIROPRACTIC HEALTHCARE 1 EDUCATIONAL GRANTS 715 2671848 N/A N/A SCHOLARSHIPS 497 887996 N/A N/A PART I, LINE 2: THE FOUNDATION MONITORS ELIGIBILITY FOR THESE AWARDS BY ASSESSING STUDENT RECORDS, FINANCIAL NEED AND ACADEMIC PERFORMANCE. THE SCHOLARSHIP COMMITTEE REVIEWS APPLICATIONS FOR AWARDS. X X 1 1 X X X X 0 1 0 0 0 0 0 1 0 DENNIS MARCHIORI DC PHD PRESIDENT/CEO 467830 0 100000 0 639436 0 93084 0 36090 0 1336440 0 0 0 DAN WEINERT DC PROVOST/EXECUTIVE VICE PRESIDENT 252715 0 45000 0 1952 0 84618 0 44217 0 428502 0 0 0 JENNIFER RANDAZZO VICE CHANCELLOR FINANCE/TREASURER 195116 0 45000 0 293 0 68987 0 39169 0 348565 0 0 0 ROBERT PERCUOCO DC VICE CHANCELLOR 204035 0 7000 0 3806 0 17190 0 34576 0 266607 0 0 0 CYNTHIA LONG DC DEAN OF RESEARCH 165542 0 50000 0 2484 0 14100 0 33120 0 265246 0 0 0 MICHAEL NORRIS PHD VICE CHANCELLOR OF ADMISSIONS 173342 0 40000 0 1018 0 48207 0 2040 0 264607 0 0 0 BARBARA MELBOURNE JD VICE CHANCELLOR 174638 0 32000 0 2480 0 48440 0 2317 0 259875 0 0 0 IAN MCLEAN DIRECTOR OF CLINIC RADIOLOGY 178433 0 7781 0 44593 0 11081 0 2304 0 244192 0 0 0 WILLIAM SHERRIER DC MA CAMPUS PRESIDENT 172354 0 20000 0 1876 0 48298 0 28 0 242556 0 0 0 KEVIN CUNNINGHAM DC FACULTY (FORMER VICE CHANCELOR) 131540 0 0 0 1139 0 11129 0 39761 0 183569 0 0 0 PART I, LINE 1A FIRST CLASS OR CHARTER TRAVEL - FIRST CLASS TRAVEL IS ONLY PERMITTED BY THE CURRENT CHAIRMAN OF THE BOARD OF TRUSTEES SINCE HE IS LOCATED IN ANCHORAGE, ALASKA. CHARTER TRAVEL IS ALLOWED IF IT IS LESS EXPENSIVE THAN INDIVIDUAL AIRFARE WHEN A GROUP IS TRAVELING. THESE BENEFITS ARE NOT TREATED AS TAXABLE INCOME. TRAVELS FOR COMPANIONS - FOR ONE BOARD MEETING A YEAR, SPOUSES OF THE BOARD OF TRUSTEES ARE INVITED TO ACCOMPANY HIS/HER SPOUSE TO THE CITY WHERE THE MEETING TAKES PLACE. MOST YEARS THE COLLEGE REIMBURSES THE TRUSTEE MEMBER FOR THE SPOUSE'S TRAVEL AND EACH TRUSTEE MEMBER IS PROVIDED AN IRS FORM 1099 FOR THAT REIMBURSEMENT. ON A LESS FREQUENT BASIS, SPOUSES OF EXECUTIVES ARE INVITED TO BOARD MEETINGS. THE COST OF THAT TRAVEL IS ADDED TO AN EMPLOYEE'S IRS FORM W-2. PART I, LINE 4B THE ORGANIZATION MAINTAINS A NON-QUALIFIED DEFERRED COMPENSATION PLAN UNDER SECTION 457(F) OF THE INTERNAL REVENUE CODE. THE PLAN PROVIDES FOR THE ORGANIZATION TO MAKE CONTRIBUTIONS FOR ELIGIBLE EMPLOYEES. CONTRIBUTIONS DURING THE YEAR TOTALED $387,732. THE FOLLOWING INDIVIDUALS HAD CONTRIBUTIONS DURING THE YEAR: * $67,884 FOR DENNIS MARCHIORI, DC, PH.D. * $64,095 FOR DAN WEINERT, DC * $52,500 FOR JENNIFER RANDAZZO * $34,610 FOR MICHAEL NORRIS, PH.D. * $34,742 FOR BARBARA MELBOURNE, JD * $34,510 FOR WILLIAM SHERRIER, DC, MA PART I, LINE 7 EXECUTIVE ADMINISTRATORS REPORTING DIRECTLY AND PRIMARILY TO THE CHANCELLOR ARE AWARDED BONUSES ON A DISCRETIONARY BASIS DETERMINED BY THE CHANCELLOR USING A REVIEW OF DIFFERENT FACTORS SUCH AS COLLEGE, DIVISION AND DEPARTMENT OUTCOMES. THE FUNDS USED FOR THESE BONUSES ARE DETERMINED BY THE CHANCELLOR AND VICE CHANCELLOR FOR FINANCE BASED ON A REVIEW OF FINANCES AND GENERAL ACCOMPLISHMENTS OF THE ADMINISTRATION. ADMINISTRATORS AND STAFF BELOW THE ORGANIZATIONAL LEVEL ARE ALSO ELIGIBLE FOR DISCRETIONARY BONUSES REVIEWED BY THE EXECUTIVE ADMINISTRATION TEAM. A IOWA HIGHER EDUCATION LOAN AUTHORITY 421235696 000000000 2024-06-28 19450000 RENOVATION OF BUILDINGS - DAVENPORT CAMPUS 0 0 0 B CITY OF PORT ORANGE 596000412 000000000 2024-06-28 14000000 SEE PART VI 0 0 0 A 499554 19450000 19450000 2021 0 0 1 1 B 753874 14000000 14000000 2005 1 0 1 1 A 0 0 0 0 0 0 0 B 0 0 0 0 0 0 0 A 0 1 0 0 1 1 NORTHERN TRUST 5.000000000000 0 0 0 0 1 B 0 1 0 0 1 1 NORTHERN TRUST 5.000000000000 0 0 0 0 1 A 1 B 1 SCHEDULE K, PART I, LINE B(F): ALLOCATED TO REFUNDING LOANS I) USED FOR CONSTRUCTION OF EDUCATIONAL FACILITIES LOCATED IN PORT ORANGE, FL, II) USED FOR CONSTRUCTION OF EDUCATIONAL FACILITIES IN DAVENPORT, IA, III) USED FOR IMPROVEMENTS TO EDUCATIONAL FACILITIES LOCATED IN PORT ORANGE, FL. SCHEDULE K, PART I, LINE D(F): KENT PILCHER TRUSTEE > 35% OWNER OF ESTES COMPANY 434300 SEE PART V - PALMER COLLEGE FOUNDATION ENGAGED WITH ESTES COMPANY FOR SERVICES. THE COLLEGE PARTICIPATES IN A COMPETITIVE BIDDING PROCESS AND REVIEWS BIDS RECEIVED FOR BOTH VENDOR WORK QUALITY AND COST. IN BOARD MATTERS RELATED TO DECISIONS FOR CONSTRUCTION SERVICES IN WHICH ESTES COMPANY IS INVOLVED, MR. PILCHER ABSTAINS FROM THE VOTE. THE BOARD APPROVES ALL CONTRACTS WITH ESTES COMPANY. 0 FORM 990, PART VI, SECTION A, LINE 1A THE EXECUTIVE COMMITTEE SHALL ACT WITH THE FULL POWER AND AUTHORITY OF THE BOARD OF TRUSTEES DURING THE INTERIM PERIODS BETWEEN THE BOARD OF TRUSTEES REGULAR MEETINGS EXCEPT AMENDING THE ARTICLES AND BYLAWS, MERGING OR DISSOLVING THE CORPORATION, CHANGES IN THE MISSION OR PURPOSE OF THE COLLEGE, EXERCISING POWERS SPECIFICALLY DELEGATED TO OTHER COMMITTEES BY THE BOARD, HIRING/ELECTING AND REMOVAL OF THE PRESIDENT/CHANCELLOR, EXEC VP, TREASURER, ASST SEC GEN AND ANY OTHER OFFICERS OF THE CORPORATION. AT SUCH MEETINGS THERE SHALL BE PRESENT IN PERSON OR BY PROXY A MAJORITY OF THE TRUSTEES WHO ARE MEMBERS OF THE EXECUTIVE COMMITTEE. FORM 990, PART VI, SECTION A, LINE 6 THE ORGANIZATION HAS ONE CLASS OF MEMBERS, DENOMINATED AS "CERTIFICATE HOLDERS." THE MEMBERS MEET AT LEAST ANNUALLY. SEE ADDITIONAL EXPLANATION OF RIGHTS AND DUTIES IN RESPONSE TO FORM 990, PART VI, SECTION A, LINES 7A AND 7B. FORM 990, PART VI, SECTION A, LINE 7A TRUSTEES SHALL BE CHOSEN BY BALLOT BY THE AFFIRMATIVE VOTE OF A MAJORITY OF THE MEMBERS. NOMINEES FOR CANDIDACY AS A TRUSTEE SHALL BE PROVIDED TO THE MEMBERS BY THE TRUSTEE, AND GOVERNANCE AND BOARD AFFAIRS COMMITTEE OF THE BOARD OF TRUSTEES (GOVERNANCE COMMITTEE) IN ACCORDANCE WITH THE FOLLOWING PROCEDURE: (A) THE EXECUTIVE DIRECTOR OF BOARD OF AFFAIRS AND ASSISTANT SECRETARY SHALL IN EARLY MAY EACH YEAR, NOTIFY EACH TRUSTEE AND EACH MEMBER OF THE NUMBER OF VACANCIES TO BE FILLED ON THE BOARD OF TRUSTEES AT THE ANNUAL MEETING OF MEMBERS. (B) EACH TRUSTEE AND EACH MEMBER SHALL BE ENTITLED TO NOMINATE AS MANY NOMINEES AS THERE ARE VACANCIES ON THE BOARD OF TRUSTEES. (C) ALL PERSONS WHOSE NAMES HAVE BEEN PROVIDED SHALL BE EVALUATED BY THE GOVERNANCE COMMITTEE AND PRESENTED TO THE MEMBERS FOR CONSIDERATION. (D) AT THE ANNUAL MEETING OF THE MEMBERS, THE MEMBERS SHALL ELECT TRUSTEES FOR THE TERMS DETERMINED BY MEMBERS UPON A MAJORITY VOTE OF ALL THE MEMBERS. FORM 990, PART VI, SECTION A, LINE 7B THOSE PROVISIONS OF THE ARTICLES OF INCORPORATION AND/OR THE BYLAWS OF THE CORPORATION THAT AFFECT THE RIGHTS, POWERS AND/OR DUTIES OF THE MEMBERS, INCLUSIVE OF THE RIGHT TO ELECT MEMBERS AND TRUSTEES AND/OR DISSOLVE THE CORPORATION OR SELL ALL OF ITS ASSETS OR EFFECT A MERGER OR CONSOLIDATION, MUST BE APPROVED BY A MAJORITY VOTE OF ALL THE MEMBERS. FORM 990, PART VI, SECTION B, LINE 11B THE FORM 990 IS PREPARED BY AN EXTERNAL ACCOUNTING FIRM, AND PRESENTED TO THE VICE CHANCELLOR FOR FINANCE AND HER STAFF FOR THEIR REVIEW. THE FORM 990 DRAFT IS THEN PRESENTED TO THE AUDIT & COMPLIANCE COMMITTEE OF THE FOUNDATION'S BOARD OF TRUSTEES. THE AUDIT & COMPLIANCE COMMITTEE AND VICE CHANCELLOR FOR FINANCE WILL MEET TO REVIEW THE DRAFT FORM 990 WITH REPRESENTATIVES OF THE ACCOUNTING FIRM WHO COMPLETED THE DRAFT FORM 990, IF CONSIDERED NECESSARY. ONCE THE DRAFT HAS BEEN ACCEPTED BY THE AUDIT & COMPLIANCE COMMITTEE, COPIES OF THE FORM 990 WILL BE PROVIDED TO THE FULL BOARD OF TRUSTEES. ONCE BOARD RECEIPT HAS BEEN DETERMINED, THE VICE CHANCELLOR FOR FINANCE WILL SIGN AND FILE THE 990 WITH THE INTERNAL REVENUE SERVICE. FORM 990, PART VI, SECTION B, LINE 12C THE COLLEGE'S CONFLICT OF INTEREST POLICY FOR OFFICERS, DIRECTORS, AND TRUSTEES IS MANAGED BY THE TRUSTEE, GOVERNANCE & BOARD AFFAIRS (GOVERNANCE COMMITTEE) CHAIRPERSON IN CONJUNCTION WITH THE EXECUTIVE COMMITTEE OR GOVERNANCE COMMITTEE. THE POLICY IS DISCUSSED ANNUALLY AT THE SPRING MEETING AND THEN TRUSTEES COMPLETE AN ANNUAL DISCLOSURE FORM AND SUBMIT IT TO THE BOARD SECRETARY, WHO COMPILES THE LISTING OF ANY CONFLICTS AND PROVIDES A SUMMARY REPORT TO THE FULL BOARD AT THE SUMMER MEETING. THOSE WHO HAVE DECLARED A CONFLICT REFRAIN FROM PARTICIPATING IN RELATED DISCUSSIONS OR VOTING WHEN THAT CONFLICT ARISES. IN THE EVENT OF VIOLATION, THE EXECUTIVE OR GOVERNANCE COMMITTEE ADVISE THE TRUSTEE OR OFFICER OF THE STEPS THAT SHOULD BE TAKEN TO RECTIFY THE SITUATION. IN THE EVENT OF ANY CONFLICT DETERMINED BY THE BOARD TO BE SIGNIFICANT, IT MAY RESULT IN THE TRUSTEE/OFFICER BEING ASKED TO CEASE AND DESIST PARTICIPATION IN THE RELATIONSHIP OR SEVER THEIR RELATIONSHIP WITH PALMER COLLEGE. ALL COMPLETED FORMS ARE SUBMITTED TO THE BOARD SECRETARY AND BOARD LEGAL COUNSEL ANNUALLY AND KEPT ON FILE. FOR KEY EMPLOYEES, CONFLICTS OF INTEREST OR COMMITMENT (COIC) ARE HANDLED BY THE COLLEGE'S COMPLIANCE DEPARTMENT. THE COLLEGE REQUIRES DISCLOSURE OF ANY CONFLICT (WHETHER ACTUAL, POTENTIAL OR PERCEIVED). IT IS THE RESPONSIBILITY OF ALL EMPLOYEES TO SELF-DISCLOSE COIC'S DURING THE ANNUAL COLLECTION PERIOD OR ANY TIME PRIOR TO THE EXISTENCE OF A CONFLICT. THE COLLEGE'S COIC COMMITTEE REVIEWS ALL DISCLOSURES AND CAREFULLY EVALUATES ALL CIRCUMSTANCES RELATED TO THE DISCLOSURES. WHERE A CONFLICT EXISTS, THE COIC COMMITTEE DETERMINES IF THE CONFLICT IS ACCEPTABLE OR NOT. THE COLLEGE MAY ALSO REQUIRE THE DEVELOPMENT OF A WRITTEN MANAGEMENT PLAN. SUCH A PLAN WILL SPECIFY HOW THE INDIVIDUAL WILL MANAGE OR RESOLVE THE CONFLICT. BECAUSE EACH CONFLICT MAY PRESENT UNIQUE CIRCUMSTANCES, THE CONTENT OF EACH PLAN MAY VARY. FORM 990, PART VI, SECTION B, LINE 15A THE BOARD CONSIDERS SEVERAL SOURCES IN DETERMINING COMPENSATION FOR SENIOR ADMINISTRATORS SUCH AS THE ACC SURVEYS, CHRONICLE OF HIGHER EDUCATION SURVEYS, GUIDANCE FROM PROFESSIONAL COMPENSATION CONSULTANTS AND ALSO WITH SURVEYS CONDUCTED BY OUR HUMAN RESOURCES DEPARTMENT. THE BOARD OF TRUSTEES' EXECUTIVE COMMITTEE MEETS PERIODICALLY DURING THE YEAR TO REVIEW THE CHANCELLOR'S PERFORMANCE AND SETS THE CHANCELLOR'S COMPENSATION. THESE DISCUSSIONS ARE DOCUMENTED IN THE BOARD MINUTES. THE CHANCELLOR SETS THE SENIOR ADMINISTRATORS SALARIES USING THE SURVEYS LISTED ABOVE AS GUIDANCE. PERIODICALLY, THE CHANCELLOR REPORTS TO THE APPROPRIATE BOARD COMMITTEE TO REVIEW SALARIES OF THE SENIOR ADMINISTRATORS. FORM 990, PART VI, SECTION C, LINE 19 PALMER COLLEGE DOES NOT MAKE ITS POLICIES, GOVERNING DOCUMENTS, OR FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC. THE CONFLICT OF INTEREST OR COMMITMENT POLICY IS AVAILABLE ON PALMER'S WEBSITE. FORM 990, PART XI, LINE 9: GAIN ON INTEREST RATE SWAP -1,180,537. FORM 990, PART XII, LINE 2C: THE ORGANIZATION'S AUDIT & COMPLIANCE COMMITTEE ASSUMES RESPONSIBILITY FOR OVERSIGHT OF THE AUDIT OF ITS FINANCIAL STATEMENTS AND SELECTION OF AN INDEPENDENT ACCOUNTANT. PALMER COLLEGE OF CHIROPRACTIC WEST 90 E TASMAN SAN JOSE CA 95134 942515428 EDUCATION CA 501(C)(3) LINE 2 PALMER COLLEGE FOUNDATION 1 DR DAVID D PALMER ATHLETIC TRUST 1000 BRADY STREET DAVENPORT IA 52803 274313852 FUND RAISING IA 501(C)(3) LINE 12A, I PALMER COLLEGE FOUNDATION 1 0 0 0 0 0 0 0 0 0 0 0 1 0 0 1 0 1 0 1 PALMER COLLEGE OF CHIROPRACTIC WEST Q 675105 CASH PALMER COLLEGE OF CHIROPRACTIC WEST S 510411 BOOK VALUE AND FMV