| FORM 990, PART VI, SECTION B, LINE 11B |
THE CONTROLLER AND THE CHIEF OPERATING OFFICER REVIEW THE 990. IT IS THEN REVIEWED BY THE JCPA FINANCE COMMITTEE. A DRAFT OF THE 990 IS ALSO SENT TO THE FULL BOARD FOR REVIEW. IF THERE ARE ANY QUESTIONS THEY ARE DIRECTED TO THE TAX PREPARERS. |
| FORM 990, PART VI, SECTION B, LINE 12C |
1. DUTY TO DISCLOSE:IN CONNECTION WITH ANY ACTUAL OR POSSIBLE CONFLICT OF INTEREST, AN INTERESTED PERSON MUST DISCLOSE THE EXISTENCE OF THE FINANCIAL INTEREST AND BE GIVEN THE OPPORTUNITY TO DISCLOSE ALL MATERIAL FACTS TO THE DIRECTORS AND MEMBERS OF COMMITTEES WITH GOVERNING BOARD DELEGATED POWERS CONSIDERING THE PROPOSED TRANSACTION OR ARRANGEMENT. 2. DETERMINING WHETHER A CONFLICT OF INTEREST EXISTS: AFTER DISCLOSURE OF THE FINANCIAL INTEREST AAND ALL MATERIAL FACTS, AND AFTER ANY DISCUSSIONS WITH THE INTERESTED PERSON, HE/SHE SHALL LEAVE THE GOVERNING BOARD OR COMMITTEE MEETING WHILE THE DETERMINATION OF A CONFLICT OF INTEREST IS DISCUSSED AND VOTED UPON. THE REMAINING BOARD OR COMMITTEE MEMBERS SHALL DECIDE IF A CONFLICT OF INTEREST EXISTS. 3. PROCEDURES FOR ADDRESSING THE CONFLICT OF INTEREST: A. AN INTERESTED PERSON MAY MAKE A PRESENTATION AT THE GOVERNING BOARD OR COMMITTEE MEETING, BUT AFTER THE PRESENTATION, HE/SHE SHALL LEAVE THE MEETING DURING THE DISCUSSION OF, AND THE VOTE ON, THE TRANSACTION OR ARRANGEMENT INVOLVING THE POSSIBLE CONFLICT OF INTEREST. B. THE CHAIRPERSON OF THE GOVERNING BOARD OR COMMITTEE SHALL, IF APPROPRIATE, APPOINT A DISINTERESTED PERSON OR COMMITTEE TO INVESTIGATE ALTERNATIVES TO THE PROPOSED TRANSACTION OR ARRANGEMENT. C. AFTER EXERCISING DUE DILIGENCE, THE GOVERNING BOARD OR COMMITTEE SHALL DETERMINE WHETHER THE JCPA CAN OBTAIN WITH REASONABLE EFFORTS A MORE ADVANTAGEOUS TRANSACTION OR ARRANGEMENT FROM A PERSON OR ENTITY THAT WOULD NOT GIVE RISE TO A CONFLICT OF INTEREST. D. IF A MORE ADVANTAGEOUS TRANSACTION OR ARRANGEMENT IS NOT REASONABLY POSSIBLE UNDER CIRCUMSTANCES NOT PRODUCING A CONFLICT OF INTEREST, THE GOVERNING BOARD OR COMMITTEE SHALL DETERMINE BY A MAJORITY VOTE OF THE DISINTERESTED DIRECTORS WHETHER THE TRANSACTION OR ARRANGEMENT IS IN THE JCPA'S BEST INTEREST, FOR ITS OWN BENEFIT, AND WHETHER IT IS FAIR AND REASONABLE. IN CONFORMITY WITH THE ABOVE DETERMINATION IT SHALL MAKE ITS DECISION AS TO WHETHER TO ENTER INTO THE TRANSACTION OR ARRANGEMENT. 4. VIOLATIONS OF THE CONFLICTS OF INTEREST POLICY: A. IF THE GOVERNING BOARD OR COMMITTEE HAS REASONABLE CAUSE TO BELIEVE A MEMBER HAS FAILED TO DISCLOSE ACTUAL OR POSSIBLE CONFLICTS OF INTEREST, IT SHALL INFORM THE MEMBER OF THE BASIS FOR SUCH BELIEF AND AFFORD THE MEMBER AN OPPORTUNITY TO EXPLAIN THE ALLEGED FAILURE TO DISCLOSE. B. IF, AFTER HEARING THE MEMBER'S RESPONSE AND AFTER MAKING FURTHER INVESTIGATION AS WARRANTED BY THE CIRCUMSTANCES, THE GOVERNING BOARD OR COMMITTEE DETERMINES THE MEMBER HAS FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT OF INTEREST, IT SHALL TAKE APPROPRIATE DISCIPLINARY AND CORRECTIVE ACTION. THE PRESIDENT, CEO, AND CHEIF FINANCIAL OFFICER CLOSELY MONITOR ALL CONTRACTS AND EXPENSES TO ENSURE THEY ARE FREE FROM POTENTIAL CONFLICTS OF INTEREST. |
| FORM 990, PART VI, SECTION B, LINE 15 |
THE JCPA PERSONNEL COMMITTEE DETERMINES CEO OFFICER COMPENSATION, WHICH IS THEN SUBMITTED FOR REVIEW AND APPROVAL TO THE FULL BOARD. TO DETERMINE COMPENSATION, THE COMPENSATION COMMITTEE UTILIZES FORM 990S OF OTHER ORGANIZATIONS, COMPENSATION SURVEYS, AND A WRITTEN EMPLOYMENT CONTRACT. |
| FORM 990, PART VI, SECTION C, LINE 18 |
THE ORGANIZATION MAKES ITS FORM 1023 AND FORM 990S AVAILABLE UPON REQUEST. |
| FORM 990, PART VI, SECTION C, LINE 19 |
THE ORGANIZATION MAKES ITS GOVERNING DOCUMENTS AVAILABLE UPON REQUEST. |
| FORM 990, PART IX, LINE 11G |
PROFESSIONAL FEES AND OUTSIDE CONSULTING: PROGRAM SERVICE EXPENSES 69,494. MANAGEMENT AND GENERAL EXPENSES 426,134. FUNDRAISING EXPENSES 0. TOTAL EXPENSES 495,628. |
| FORM 990, PART XI, LINE 9: |
BAD DEBT EXPENSE -14,370. |
| FORM 990, PART XII, LINE 2C: |
THE OVERSIGHT PROCESS HAS NOT CHANGED FROM THE PRIOR YEAR. |
Attach to Form 990 or 990-EZ.