Northwest Fire Fighters Benefits Trust

“Dennis Lawson, Greg Markley, Jeff Wainwright, Brian Hurley, and Craig Soucy are trustees of this organization, with Dennis serving as the president of the Washington State Council of Fire Fighters (WSCFF), Greg serving as the secretary-treasurer of the WSCFF, and with Jeff, Brian, and Craig serving as district representatives on the Executive Board of the WSCFF. Several trustees of this organization also serve as trustees of other organizations for fire fighters.”

“The Trust has contracted with a third-party administrator (Benefit Solutions, Inc.) to provide bookkeeping and administrative services and with a claims administrator (Regence BlueShield) for claims adjudication and payment services.”

“There are nine Trustees, five of whom are elected by delegates of participating labor organizations in the Trust benefit plan(s), and four of whom are appointed by the Executive Board of the Washington State Council of Fire Fighters (WSCFF), each for a three-year term. The term of a new Trustee will commence on July 1st following the WSCFF convention at which he was appointed or elected. Elections and appointments for the Board of Trustees are according to rules of the WSCFF for its election of its Executive Board and its appointments, or according to other special Trust election and appointment rules that the WSCFF adopts. Each person elected and at least one person appointed as a Trustee are active members of a member Local of the WSCFF. There is no more than one Trustee from any Local. Notwithstanding the foregoing, one of the Trustee positions may be held by a retiree, if available, who was an active member of a member Local of WSCFF until retirement, and who is participating in a benefit plan of the Trust. In the event of the termination of appointment, resignation, or death of a Trustee, a successor Trustee is selected as follows: a) if the terminating Trustee was elected, the remaining Trustees will select a Trustee for the balance of the term, or b) if the terminating Trustee was appointed, the Executive Board of the WSCFF will appoint a new Trustee for the balance of the term.”

“The Trust Agreement of the related trust may be amended by action of the Washington State Council of Fire Fighters (WSCFF) Executive Board, on its own accord, after ten days' advance written notice to the Board of Trustees, or upon recommendation of the Board of Trustees. If the WSCFF is terminated or otherwise ceases to exist without having made provisions for any remaining funds in the Trust, the remaining members of the Board of Trustees will have the power to amend. The related trust agreement may be terminated at any time by action of the WSCFF Executive Board on its own accord or by action of the Board of Trustees after thirty days' advance written notice to the WSCFF. In any event, the Trust Agreement will be automatically terminated upon the expiration of all collective bargaining agreements and subscription agreements requiring the payment of contributions to the Trust, and upon completion of the termination process. As part of the termination process, the Board of Trustees may arrange for retention of an independent trustee to administer the wasting trust. Upon termination, the Board of Trustees will wind up the affairs of the Trust. Any and all monies remaining in the Trust, after the payment of expenses, shall be allocated among the participating employees and beneficiaries as specified in Section 501, et seq., of the Internal Revenue Code and related authority. In no event will any of the remaining monies or assets in the Trust be paid to or be recoverable by any participating employer or labor organization.”

“The Form 990 was prepared by the independent accounting firm SCHOEDEL & SCHOEDEL, Certified Public Accountants, PLLC. Draft copies of the Trust's financial statements and Form 990 were first provided to the Trust's consultants and advisors, who reviewed the Form 990 for accuracy and completeness. Any questions, concerns or issues raised by the consultants and advisors were addressed and any necessary revisions were made to the Form 990. The revised Form 990 was then provided to the Board of Trustees for its review and approval. Any additional questions, concerns or issues raised by the Board of Trustees were addressed and any necessary revisions were made to the Form 990. The final version of the Form 990 was reviewed, approved and filed by the Board of Trustees.”

“Policies Regarding Conflicts of Interest: Identification of Parties in Interest and Distribution The Trust administration office prepares a list of labor organizations and service providers. This list is distributed to each Trustee, and to each service provider authorized to conduct transactions on behalf of the Trust. Each Trustee and service provider is given copies of 1) ERISA Section 406(a)(1) and Section 406(b), which prohibit certain transactions between the Trust and persons or entities that are "parties in interest" with respect to the Trust, and the transfer of Trust assets to or the use of such assets by or for the benefits of a "party in interest, and 2) ERISA Section 3(14), which sets forth the definition of a "party in interest." This list of parties in interest is updated and distributed to the Board of Trustees annually. The Trust administration office, with assistance from Trust legal counsel, maintains signed statements from the Trustees affirming they do not have any conflicts of interest. Specific Implementation Actions All proposed investments that would be made directly by the Trustees, as well as all proposed relationships with service providers, are reviewed by Trust legal counsel for compliance with the prohibited-transaction provisions of ERISA. All agreements between the Trust and service providers authorized to conduct transactions on behalf of the Trust are provided to Trust legal counsel for review before execution to ensure that, wherever applicable, the agreement contains appropriate restrictions or other protections against prohibited transactions with parties in interest. Any Trustee or service provider authorized to conduct transactions on behalf of the Trust who has reason to believe that a proposed transaction might constitute a prohibited transaction with a party in interest is directed to consult with Trust legal counsel and take whatever additional action may be appropriate to ensure that the proposed transaction is appropriate. Any fiduciary whose participation in a decision may result in a nonexempt prohibited transaction under Section 406 of ERISA must recuse himself or herself from discussing or voting on that decision. Annual Review of Party-in-Interest Transactions When required by the annual financial statement auditor, the Trust office distributes a post-interest questionnaire to plan fiduciaries in conjunction with the annual audit. The Trust office and Trust legal counsel assists the Trust's auditors, as appropriate, with the distribution and return of the party-in-interest inquiries made with respect to the annual audit to ensure that the responses are complete and timely.”

“There are no compensated management officials, officers or key employees of the organization. If the organization had such compensated individuals, policies and procedures would be developed to determine compensation.”

“The Trust's governing documents, conflict of interest policy, financial statements and Form 990 are available to the general public upon written request sent to the Trust in care of Benefit Solutions, Inc. at: P.O. Box 6; Mukilteo, WA 98275.”

“The Trust does not compensate any of the members of the Board of Trustees. The Board is comprised of nine individuals, all of whom are professional firefighters and/or union employees. The Chairman of the Trust is the secretary-treasurer of the Washington State Council of Fire Fighters (WSCFF). The Secretary of the Trust is the president of WSCFF. In their roles as Trustees, all nine are fiduciaries and understand their obligations under the Trust Agreement and the Trust's policies and procedures which include a conflict of interest policy. The Chairman and Secretary of the Trust, as part of their employment expectations, understand that they must serve on this board of trustees. Their regular compensation takes into consideration services performed by them in regard to the Trust. The other trustees serve on a voluntary basis, and receive no known compensation from their employers, or any other party, for their services on this board of trustees. The trust does not readily have access to information related to the compensation paid by other entities to the Trustees.”