TY 2015 Form 990 Schedule O

efile Public Visual Render ObjectId: 201730589349300018 - Submission: 2017-02-27 TIN: 36-3514573

SCHEDULE O
(Form 990 or 990-EZ)

Department of the Treasury
Internal Revenue Service

Supplemental Information to Form 990 or 990-EZ

Complete to provide information for responses to specific questions on
Form 990 or 990-EZ or to provide any additional information.
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Attach to Form 990 or 990-EZ.
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Information about Schedule O (Form 990 or 990-EZ) and its instructions is at
www.irs.gov/form990.

OMB No. 1545-0047

2015

Open to Public
Inspection

Name of the organization

Nebraska Student Loan Program Inc

Employer identification number

36-3514573

Return Reference	Explanation
Form 990, Part VI, Line 6 & 7a	MEMBERS THE FOUNDATION FOR EDUCATIONAL SERVICES, INC. (FES), A NOT-FOR-PROFIT CORPORATION, SERVES AS THE SOLE MEMBER OF NEBRASKA STUDENT LOAN PROGRAM, INC. (NSLP) AND ELECTS NSLP'S BOARD OF DIRECTORS.
Form 990, Part VI, Line 11B	REVIEW OF THE FORM 990 THE 990 IS PREPARED BY KPMG, REVIEWED BY STAFF AND MAILED TO ALL BOARD MEMBERS. THE 990 IS PRESENTED TO THE AUDIT COMMITTEE AND THE BOARD BEFORE IT IS FILED.
Form 990, Part VI, Line 12c	CONFLICT OF INTEREST POLICY NSLP MAINTAINS A COMPREHENSIVE CONFLICTS OF INTEREST POLICY FOR DIRECTORS AND OFFICERS. THE POLICY EXISTS TO IDENTIFY POTENTIAL INSTANCES IN WHICH AN INDIVIDUAL COULD OBTAIN A DIRECT OR INDIRECT PERSONAL GAIN OR ADVANTAGE TO THE DETRIMENT OF THE ORGANIZATION, OR WHERE AN INDIVIDUAL'S CONDUCT COULD HAVE AN ADVERSE OR POTENTIALLY ADVERSE EFFECT ON THE INTERESTS OF THE ORGANIZATION. THE POLICY CONTAINS AN AFFIRMATIVE DUTY TO DISCLOSE, AS WELL AS A SPECIFIC PROCESS FOR DISCLOSURES OF POTENTIAL CONFLICTS OF INTEREST, A PROTOCOL IN WHICH INDEPENDENT, OUTSIDE LEGAL COUNSEL IS USED TO EVALUATE WHETHER A CONFLICT EXISTS, PROCEDURES FOR ADDRESSING ACTUAL CONFLICTS OF INTEREST, AND CONSEQUENCES FOR VIOLATIONS OF THE CONFLICTS POLICY. THE POLICY REQUIRES ALL DIRECTORS AND OFFICERS TO COMPLETE AND SUBMIT AN ANNUAL CONFLICTS DISCLOSURE FORM TO OUTSIDE LEGAL COUNSEL. IN ADDITION, THE CONFLICT OF INTEREST POLICY IS INCLUDED IN THE EMPLOYEE HANDBOOK WHICH ALL EMPLOYEES MUST ACKNOWLEDGE AND AGREE TO ABIDE BY.
Form 990, Part VI, Line 15a	PROCESS FOR DETERMINING COMPENSATION OUTSIDE LEGAL COUNSEL UNDERTAKES A COMPREHENSIVE EVALUATION OF THE COMPENSATION AND BENEFIT PACKAGES FOR OFFICERS AND OTHER AFFECTED EMPLOYEES OF THE ORGANIZATION, COMPARING THE SAME RELEVANT INDUSTRY AND OTHER MARKET COMPARABLES. COUNSEL THEN PROVIDES TO THE BOARD OF DIRECTORS A SUMMARY OF THE COMPARABILITY DATA, AN ANALYSIS OF THE DATA RELATIVE TO THE ORGANIZATIONAL EMPLOYEES, AND A REASONED OPINION CONCERNING THIS CONCLUSION. THE BOARD OF DIRECTORS THEN CONFIRMS AND RATIFIES ALL COMPENSATION/BENEFITS PACKAGES, WITH THE DECISION PROCESS PROPERLY DOCUMENTED AS REQUIRED BY THE REGULATIONS. ON A ROUTINE BASIS, NSLP ENGAGES AN INDEPENDENT COMPENSATION SPECIALIST TO PROVIDE DATA FOR KEY POSITIONS.
Form 990, Part VI, Line 19	PUBLIC AVAILABILITY OF DOCUMENTS, POLICIES, AND FINANCIAL STATEMENTS NSLP DOES NOT MAKE THEIR GOVERNING DOCUMENTS, CONFLICTS OF INTEREST POLICY, OR FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC.

Return Reference

Explanation

Form 990, Part VI, Line 6 & 7a

MEMBERS THE FOUNDATION FOR EDUCATIONAL SERVICES, INC. (FES), A NOT-FOR-PROFIT CORPORATION, SERVES AS THE SOLE MEMBER OF NEBRASKA STUDENT LOAN PROGRAM, INC. (NSLP) AND ELECTS NSLP'S BOARD OF DIRECTORS.

Form 990, Part VI, Line 11B

REVIEW OF THE FORM 990 THE 990 IS PREPARED BY KPMG, REVIEWED BY STAFF AND MAILED TO ALL BOARD MEMBERS. THE 990 IS PRESENTED TO THE AUDIT COMMITTEE AND THE BOARD BEFORE IT IS FILED.

Form 990, Part VI, Line 12c

CONFLICT OF INTEREST POLICY NSLP MAINTAINS A COMPREHENSIVE CONFLICTS OF INTEREST POLICY FOR DIRECTORS AND OFFICERS. THE POLICY EXISTS TO IDENTIFY POTENTIAL INSTANCES IN WHICH AN INDIVIDUAL COULD OBTAIN A DIRECT OR INDIRECT PERSONAL GAIN OR ADVANTAGE TO THE DETRIMENT OF THE ORGANIZATION, OR WHERE AN INDIVIDUAL'S CONDUCT COULD HAVE AN ADVERSE OR POTENTIALLY ADVERSE EFFECT ON THE INTERESTS OF THE ORGANIZATION. THE POLICY CONTAINS AN AFFIRMATIVE DUTY TO DISCLOSE, AS WELL AS A SPECIFIC PROCESS FOR DISCLOSURES OF POTENTIAL CONFLICTS OF INTEREST, A PROTOCOL IN WHICH INDEPENDENT, OUTSIDE LEGAL COUNSEL IS USED TO EVALUATE WHETHER A CONFLICT EXISTS, PROCEDURES FOR ADDRESSING ACTUAL CONFLICTS OF INTEREST, AND CONSEQUENCES FOR VIOLATIONS OF THE CONFLICTS POLICY. THE POLICY REQUIRES ALL DIRECTORS AND OFFICERS TO COMPLETE AND SUBMIT AN ANNUAL CONFLICTS DISCLOSURE FORM TO OUTSIDE LEGAL COUNSEL. IN ADDITION, THE CONFLICT OF INTEREST POLICY IS INCLUDED IN THE EMPLOYEE HANDBOOK WHICH ALL EMPLOYEES MUST ACKNOWLEDGE AND AGREE TO ABIDE BY.

Form 990, Part VI, Line 15a

PROCESS FOR DETERMINING COMPENSATION OUTSIDE LEGAL COUNSEL UNDERTAKES A COMPREHENSIVE EVALUATION OF THE COMPENSATION AND BENEFIT PACKAGES FOR OFFICERS AND OTHER AFFECTED EMPLOYEES OF THE ORGANIZATION, COMPARING THE SAME RELEVANT INDUSTRY AND OTHER MARKET COMPARABLES. COUNSEL THEN PROVIDES TO THE BOARD OF DIRECTORS A SUMMARY OF THE COMPARABILITY DATA, AN ANALYSIS OF THE DATA RELATIVE TO THE ORGANIZATIONAL EMPLOYEES, AND A REASONED OPINION CONCERNING THIS CONCLUSION. THE BOARD OF DIRECTORS THEN CONFIRMS AND RATIFIES ALL COMPENSATION/BENEFITS PACKAGES, WITH THE DECISION PROCESS PROPERLY DOCUMENTED AS REQUIRED BY THE REGULATIONS. ON A ROUTINE BASIS, NSLP ENGAGES AN INDEPENDENT COMPENSATION SPECIALIST TO PROVIDE DATA FOR KEY POSITIONS.

Form 990, Part VI, Line 19

PUBLIC AVAILABILITY OF DOCUMENTS, POLICIES, AND FINANCIAL STATEMENTS NSLP DOES NOT MAKE THEIR GOVERNING DOCUMENTS, CONFLICTS OF INTEREST POLICY, OR FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC.

For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.

Cat. No. 51056K

Schedule O (Form 990 or 990-EZ) 2015

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