The Cooper Union for The

“The form 990 is prepared and reviewed internally before being reviewed by the university's external audit firm's tax specialists (grant thornton). Subsequent to revisions, the form 990 is provided first to the audit committee for review and approval and then to the full board prior to filing. The audit committee and full board receive the entire form 990 except for schedule b which is not provided to protect the confidentiality of donors. Should a committee or board member desire to see schedule b they can request to do so. Gifts or donors appearing on schedule b that are out of the ordinary are discussed in board/committee meetings as a matter of the university's gift acceptance policy.”

“The cooper union conducts an annual review of the conflict of interest policy and procedures as follows: the cooper union prohibits members of the board of trustees, officers and staff from participating in the governing body's deliberations and decision-making regarding transactions that may present a conflict of interest under the conflict of interest policy. An annual policy questionnaire is sent to all trustees and officers. All completed conflict of interest questionnaires are returned to and reviewed by the corporate secretary. A list of all actual or apparent conflicts disclosed on the questionnaires are then submitted to the chair of the audit committee. Any disclosures that the audit committee chair determines are actual or apparent conflicts are reviewed by the audit committee. The audit committee and, if necessary, the board of trustees, documents, through meeting minutes, any decisions related to transactions involving an actual or possible conflict of interest. The secretary to the board of trustees maintains a list of conflicts disclosed by trustees, officers, and staff annually. Cooper union conducts a periodic review of transactions involving significant expenditures to ensure any compensation paid continues to be reasonable.”

“The board compensation committee, on behalf of the entire board, follows the procedures referred to in i.r.c. 4958 to establish a "rebuttable presumption of reasonableness" with respect to the compensation of the president. The committee reviews comparable compensation data from industry surveys to evaluate the reasonableness of the compensation amounts. The results of this process are recorded in the committee's minutes. All adjustments to the president's compensation are approved by the board. The compensation committee follows these same procedures to review the compensation amounts of other officers and key employees.”

“The cooper union will make its governing documents, conflict of interest policy and financial statements available upon request at management's discretion.”

“Amount not yet recognized as a component of net periodic benefit cost 395,081.”