Citigroup Staff Member'S Association

“The trust does not have any committees.”

“The form 990 is prepared by an independent accounting firm based on information provided by the association and in consultation with its staff. The draft prepared by the accounting firm is then carefully reviewed by the sponsor's finance, tax, corporate benefits for review and comment prior to filing with the irs.”

“Employees are required to annually disclose their interests that could give rise to conflicts of interests. Completed conflicts of interest disclosure forms are reviewed by the human resources department and disclosed conflicts are reviewed by chief of human resources.”

“Financial reports are made public pursuant to irs filing requirements. Written requests for other information is forwarded to appropriate authorities for consideration.”

“The benefit plans funded by veba trusts are subject to erisa rules, which imposes requirements for fiduciary conduct, avoiding related party transactions (self-dealing), providing for disclosure to participants, etc.”

“A veba trust has its trustee(s) appointed by the employer sponsoring the underlying benefit plan. These trustees and other plan fiduciaries are subject to erisa standards for fiduciary conduct, and are bound by terms of underlying plan documents. These standards and plan documents provide the governance and management transparency that the irs is looking for in this section.”

“Any assistance provided, such as the payment of any benefit in connection with the provisions of the veba trust to employees of the sponsoring employer is not to be reported in schedule i or schedule f.”

“This question does not apply to a veba. Any assistance provided, such as payment of a benefit, can only be done pursuant to the nondiscrimination rules in section 505.”

“The company decided not to fund the veba trust at the end of 2024, to pay for ibnr claims in 2025. As such, the related claims are paid directly out of the company's general assets.”