California Firefighters Benefit Trust

“There are nine trustees, six of whom are selected by the members of the participating labor organizations and three of whom are appointed by the board of directors of the participating labor organizations. In the event of early termination of appointment, resignation or death of a trustee, the board of directors of the participating labor organizations shall select a successor trustee for the remainder of that term. The appointment of a trustee may be terminated at any time by the entity which originally made the appointment, according to such entity's internal rules, procedures or practices.”

“The trust has no separate committees.”

“The chairman reviews the form 990 and compares it to the audited financial statements for completeness and accuracy before signing and filing. A copy of the form 990 is provided to each member of the board of trustees prior to filing with the irs.”

“The trust has a conflict of interest policy adopted in march 2008 and amended in march 2011, which requires the trustees to submit a signed conflict of interest disclosure statement upon acceptance of the trustee position and to disclose any conflict of interest as soon as it is discovered. In particular, the trustee shall disclose a conflict of interest prior to any board decision on the matter related to the conflict of interest. If the board has determined that there is a conflict of interest, the trustee will be excused from the meeting during all discussions and voting on the issue. The trustees are required to review this policy annually.”

“The trust's financial information is provided to participants in the summary annual report. A full set of financial statements, conflict of interest policy, and governing documents is available to participants upon request.”

“The trust's document retention policy is included in the trust agreement article vi, section 11.”

“No compensation is paid to any trustees or officers by the filing entity. The trust has no employees.”

“The trust's whistleblower policy is included in the trust agreement article vi, section 18.”

“The trust does not have information regarding the compensation received by the trustees as a firefighter. The members of the board of trustees are paid firefighters of the city of san diego, city of riverside and north county fire district (the local governments). They are employed by the local governments and receive all their compensation solely connected to their duties as firefighters. In their role as trustees, they are fiduciaries and subject to legal prohibitions against self-dealing. They serve on a volunteer basis as trust fiduciaries; they do not receive any additional compensation from the local governments or any other party for their services on the board of trustees. Further, the trust has a conflict of interest policy, which requires trustees to disclose any financial arrangements that would create a conflict of interest. Section 7(a) of the conflict of interest policy of the trust, effective march 1, 2011 as amended, states the following: "covered persons shall have a duty to disclose to the board any conflict of interest as soon as it is discovered and, in particular, prior to any board or committee decision on the matter related to the conflict of interest. Upon acceptance of trustee position, trustees shall submit a signed conflict of interest disclosure to the board and shall have the duty to update such disclosures upon discovering a change." the policy also requires regular disclosure in written form of "any entities in which you [the trustee] presently have a compensation arrangement that may present an actual or potential conflict of interest. Note also that the disclosure of compensation requested on the form 990 would cause additional administrative burden by requiring the trust to collect this information annually, since the trustees' compensation as firefighters varies from year to year, and from trustee to trustee. Finally, and very importantly, the form 990 is public information. It is likely that requiring the disclosure of compensation will dissuade firefighters from volunteering to serve on the board. The trust would then have to spend trust assets to hire a professional trustee. Please contact the trust office if you would like further information, and/or would like to discuss this further. The trustees want to be cooperative with the irs, but requesting this compensation information is problematic for the reasons stated above.”

“Third party administrators 185,325. Actuarial fees 33,302. Consulting 294.”