Local 464A Educational Benefit Fund

“John t. Niccollai and john niccollai iii are father and son.”

“The union consists of approximately 12,422 members.”

“The union membership vote for members of the governing body every three years, including the constitutional officers and the members of the executive board.”

“Form 990 is prepared by an outside cpa firm. The completed form 990 is reviewed in detail by john t.niccollai. The form is presented at a trustees meeting and approval for filing the return is voted on.”

“Part vi-governance, management, and disclosure-section b-policies-question 12, 13 and 14-the fund and its trustees have long been subject to comprehensive federal statutes, including erisa and the taft-hartley act, that govern the financial relationships between the trustees and the fund. These laws prohibit financial transactions between the fund and "interested parties", including the trustees, the fund's employees and service providers, relatives of the trustees, employees and service providers and other persons. The regulations require both disclosure by trustees of conflicts of interest in any transactions to be entered into by the fund, and a vote by the disinterested trustees regarding any such transactions. Regulations issued under these laws define "conflict of interest" more broadly than the instructions for form 990, and require reporting of financial transactions at much lower thresholds than those contained on the schedules for form 990. The fund and the trustees have consistently operated in compliance with these comprehensive regulations governing conflicts of interest. In addition to being subject to federal and state whistleblower laws, the fund and its trustees have long been subject to comprehensive federal laws, such as erisa, that protect the right of employees, participants and beneficiaries to access information regarding the fund's operations and raise questions and concerns without retaliation. The fund and its trustees have consistently operated in compliance with these comprehensive regulations. The fund has long been subject to comprehensive federal regulations enforced by the dol, governing record retention and record destruction for purposes of audits of unions and their related funds performed by the dol. Additionally, federal laws such as the lmrda grant members access to certain documents maintained by the fund, thereby necessitating retention of certain documents by the fund. The fund has consistently operated in compliance with these comprehensive laws.”

“John t. Niccollai and a trustee review compensation on an annual basis and utilize comparative data from various sources, including tying executive and workforce increases to contracts negotiated on behalf of the membership.”

“Certain financial information is published in the union newsletter and all documentation is available for inspection upon request.”