Civic Intelligence

Fairways for Freedom Inc

EIN 47-5491069 • 501(c)3 • Singer Island, FL

Profile

Fairways for freedom provides combat-injured veterans with instruction and practice in evidence-informed, clinically tested, self-regulation techniques; opportunities for therapeutic, recreational (golf, and community building social activities); training on healthy lifestyle choices and education about community-based veteran resources for post- retreat reintegration.) the goal is also to connect leaders in the business community with combat-injured verterans through the game of golf. Business professionals serve as mentors to the veterans and, in turn, learn what true sacrifice is all about. The company had two trips in 2023: one to vermont on june 16, 2023 with 8 combat-injured veterans, and one to ireland september 9-17, 2023 with 8 combat-injured veterans and 5 supporting ambassadors along with 2 company directors.

5200 N Ocean Drive Unit 401Singer Island, FL 33404

www.fairwaysforfreedom.us

Siviq Scores

Precomputed percentiles relative to similar nonprofits. These scores are descriptive rather than judgmental.

Liabilities / Assets

76th percentile

0.06x

Higher debt load relative to assets than 76% of similar nonprofits.

501(c)3 • <$500k nonprofits • Source year 2024

Liabilities / Revenue

67th percentile

0.01x

Higher debt load relative to revenue than 67% of similar nonprofits.

501(c)3 • <$500k nonprofits • Source year 2024

Net Margin

33rd percentile

-7.7%

Higher net margin than 33% of similar nonprofits.

501(c)3 • <$500k nonprofits • Source year 2024

Top Officer Pay

Score unavailable

No value available

No filing with officer rows is available for this organization yet.

Asset Growth

19th percentile

-46%

Faster asset growth than 19% of similar nonprofits.

501(c)3 • <$500k nonprofits • Annualized from 2022 to 2024

Revenue Growth

34th percentile

-17%

Faster revenue growth than 34% of similar nonprofits.

501(c)3 • <$500k nonprofits • Annualized from 2022 to 2024

Assets

Down

$23,138

Down $71,355 (-76%) from 2023

Liabilities

Up

$1,489

Up $1,489 from 2023

Net Assets

Down

$21,649

Down $72,844 (-77%) from 2023

Revenue

Up

$188,045

Up $1,237 (+0.7%) from 2023

Expenses

Up

$202,557

Up $29,842 (+17%) from 2023

Net Income

Down

-$14,512

Down $28,605 (-203%) from 2023

Trend Graphs

Balance Sheet Trend

Grouped bars show assets, liabilities, and net assets across loaded filings.

$200K$150K$100K$50K$0Assets 2016: $46,130Liabilities 2016: $0Net Assets 2016: $46,1302016Assets 2017: $49,275Liabilities 2017: $0Net Assets 2017: $49,2752017Assets 2018: $50,914Liabilities 2018: $635Net Assets 2018: $50,2792018Assets 2019: $42,124Liabilities 2019: $0Net Assets 2019: $42,1242019Assets 2020: $98,117Liabilities 2020: $0Net Assets 2020: $98,1172020Assets 2021: $166,291Liabilities 2021: $0Net Assets 2021: $166,2912021Assets 2022: $80,400Liabilities 2022: $0Net Assets 2022: $80,4002022Assets 2023: $94,493Liabilities 2023: $0Net Assets 2023: $94,4932023Assets 2024: $23,138Liabilities 2024: $1,489Net Assets 2024: $21,6492024

Highlighted filing

2024

Assets$23,138
Liabilities$1,489
Net Assets$21,649

Operations Trend

Revenue, expenses, and net income by year, with the latest filing highlighted.

$400K$200K$0-$200KRevenue 2016: $220,901Expenses 2016: $174,771Net Income 2016: $46,1302016Revenue 2017: $210,783Expenses 2017: $207,638Net Income 2017: $3,1452017Revenue 2018: $184,857Expenses 2018: $183,853Net Income 2018: $1,0042018Revenue 2019: $201,838Expenses 2019: $201,415Net Income 2019: $4232019Revenue 2020: $125,440Expenses 2020: $69,447Net Income 2020: $55,9932020Revenue 2021: $167,995Expenses 2021: $99,821Net Income 2021: $68,1742021Revenue 2022: $271,454Expenses 2022: $357,345Net Income 2022: -$85,8912022Revenue 2023: $186,808Expenses 2023: $172,715Net Income 2023: $14,0932023Revenue 2024: $188,045Expenses 2024: $202,557Net Income 2024: -$14,5122024

Highlighted filing

2024

Revenue$188,045
Expenses$202,557
Net Income-$14,512

Filings

Latest Filing Detail
Jump To
Filing Snapshot
Filing Period
Jan 1, 2024 to Dec 31, 2024
Signed
Nov 6, 2025
Return Version
2024v5.0
Gross Receipts
$188,045
Mission and Program Overview

Mission

Fairways for freedom provides combat-injured veterans with instruction and practice in evidence-informed, clinically tested, self-regulation techniques; opportunities for therapeutic, recreational (golf, and community building social activities; training on healthy lifestyle choices and education about community -based veteran resources for post-retreat reintegration. The goal is also to connect leaders in the business community with combat-injured verterans through the game of golf. Business professionals serve as mentors to the veterans and, in turn, learn what true sacrifice is all about.

Fairways for freedom provides combat-injured veterans with instruction and practice in evidence-informed, clinically tested, self-regulation techniques; opportunities for therapeutic, recreational (golf, and community building social activities); training on healthy lifestyle choices and education about community-based veteran resources for post- retreat reintegration. The goal is also to connect leaders in the business community (ambassadors/donors) with combat-injured veterans through the game of golf. Business professionals serve as mentors to the veterans and, in turn, learn what true sacrifice is all about.

Balance Sheet Detail
LineBeginningEndChange
Assets
Rtn Earn Endowment Incm Other Fnds$94,493$21,649▼ $72,844
Cash and Non-Interest-Bearing Accounts$46,788$12,374▼ $34,414
Savings and Temporary Cash Investments$47,705$7,192▼ $40,513
Other Notes and Loans Receivable, Net-$3,572-
Total Assets$94,493$23,138▼ $71,355
Liabilities
Accounts Payable and Accrued Expenses-$1,489-
Total Liabilities$0$1,489▲ $1,489
Net Assets / Fund Balance
Total Net Assets Fund Balance$94,493$21,649▼ $72,844
Total Liabilities and Net Assets / Fund Balance$94,493$23,138▼ $71,355
Compensation and Service Providers

Board Members and Trustees

NameTitle
Roger SchiffmanPresident
Anne McneilDirector
Bob FinleyDirector
David SingerDirector
Kathleen SchiffmanSecretary
Patricia DonnellyTreasurer
Revenue and Support

Revenue Composition

Contributions and Grants
$187,005
Program Service Revenue
$0
Investment Income
$1,040
Other Revenue
$0
All Other Contributions
$187,005
Change in Net Assets
$-14,512
Expenses and Functional Allocation

Major Expense Lines

Line ItemAmount
Other Expenses$202,557
Total Fundraising Expense$42,764
Grants and Similar Amounts Paid$0
Professional Fundraising Fees$0
Salaries, Compensation, and Employee Benefits$0

Functional Expense Allocation

Line ItemProgramManagementFundraisingTotal
Travel$114,977-$1,235$116,212
All Other Expenses$7,033$3,857$335$11,225
Office Expenses$5,961$1,333$100$7,394
Insurance-$4,595-$4,595
Other Expenses$1,394$2,498$156$3,892
Advertising--$3,039$3,039
Information Technology-$1,978-$1,978
Total Functional Expenses$145,532$14,261$42,764$202,557
Fundraising, Events, and Gaming
Fundraising activities
No
Gaming activities
No
Professional fundraiser used
No

Fundraising and Gaming Totals

Line ItemAmount
Professional Fundraising Fees$0
Political and Lobbying Activity
Political campaign activity
No
Lobbying activity
No
Subject to proxy tax
No
Governance and Compliance

Governance Checklist

Compiled or reviewed by an accountant
No
Annual disclosure for covered persons
Yes
Business relationship with 35% controlled entity
No
Business relationship with family members
No
Business relationship with organization members
No
Material changes to governing documents
No
Compensation from other sources disclosed
No
CEO compensation reviewed
Yes
Other officer compensation reviewed
No
Conflict-of-interest policy
Yes
Audited financial statements prepared
No
Key decisions subject to board approval
No
Management duties delegated
No

Governance Explanations

Form 990, Page 6, Part VI, Line 2

Roger schiffman pres/dir spouse patricia donnelly treasurer spouse kathleen schiffman secretary daughter

Form 990, Page 6, Part VI, Line 11B

The officers and director(s) of the organization are intimately involved with and in the organization's activities, and use this knowledge to review the form 990.

Form 990, Page 6, Part VI, Line 12C

Article 9 (conflict of interest and compensation approval policies) of the taxpayer's bylaws provides in section3 (conflict of interest avoidance procedures) as follows: a. Duty to disclose. In connection with any actual or possible conflict of interest, an interested person defined in section 2(a) as including 'any director, principal officer, member of a committee with governing board delegated powers, or any other person who is a "disqualified person" as defined in section 4958(f)(1) of the internal revenue code and as amplified by section 53-4958-3 of the irs regulations, who has a direct or indirect financial interest' must disclose the existence of the financial interest and be given the opportunity to disclose all material facts to the directors and members of committees with governing board delegated powers considering the proposed transaction or arrangement. B. Determining whether a conflict of interest exists. After disclosure of the financial interest and all material facts, and after any discussion with the interested person, he/she shall leave the governing board or committeemeeting while the determination of a conflict of interest is discussed and voted upon. The remaining board or committee members shall decide if a conflict of interest exists. C. Procedures for addressing the conflict of interest. An interested person may make a presentation at the governing board or committee meeting, but after the presentation, he/she shall leave the meeting during the discussion of, and the vote on, the transaction or arrangement involving the possible conflict of interest. The chairperson of the governing board or committee shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement. After exercising due diligence, the governing board or committee shall determine whether the corporation can obtain, with reasonable efforts, a more advantageous transaction or arrangemnt from a person or entity that would not give rise to a conflict of interest. If a more advantageous transaction or arrangement is not reasonably possible under the circumstances not producing a conflict of interest, the governing board or committee shall determine, by a majority vote of the disinterested directors, whether the transaction or arrangement is in the corporation's best interest, for its own benefit, and whether it is fair and reasonable. In conformity with the above determination, it shall make its decision as to whether to enter into the transaction or arrangement. D. Violations of the conflicts of interest policy. If the governing board or committee has reasonable cause to believe a member has failed to disclose actual or possible conflicts of interest, it shall inform the member of the basis for such belief and afford the member an opportunity to explain the alleged failure to disclose. If, after hearing the member's response and after making further investigation as warranted by the circumstatnces, the governing board or committee determines the member has failed to disclose an actual or possible conflict of interest, it shall take the appropriate disciplinary and corrective action.

Form 990, Page 6, Part VI, Line 15A

Article 9(conflict of interest and compensation approval policies) of the taxpayer's bylaws provides in section 5 (compensation approval policies), as follows: "a voting member of the governing board who receives compensation, directly of indirectly, from the corporation is precluded from voting on matters pertaining to that member's compensation. A voting member of any committee whose jurisdiction includes compensation matters and who receives compensation, directly of indirectly, from the corporation for services is precluded fron voting on matters pertaining to that member's compensation. A voting member of the governing board or any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the corporation, either individually or collectively, is prohibited from providing information to any committee regarding compensation. When approving compensation for directors, officers and employees, contractors, and any other compensation contract or arrangement, in addition to complying with the conflict of interest requirements and policies contained in the preceding and following sections of this article as well as the preceding paragraphs of this section of this article, the board or a duly constituted committee of the board shall also comply with the following additional requirements and procedures: a. The terms of compensation shall be approved by the board or compensation committee prior to the first payment of compensation; b. All members of the board or compensation committee who approve compensation arrangements must not have a conflict of interest with respect to the compensation arrangement as specified in irs regulation section 53.4958-69(c)(iii), which generally requires that each board member or committee member approving a compensation arrangement between this organization and a 'disqualified person' (as defined in section 4958(f)(1) of the internal revenue code and as amplified by section 53.4958-3 of the irs regulations): 1. Is not the person who is the subject of the compensation arrangement, or a family member of such person; 2. Is not in an employment relationship subject to the direction or control of the person who is the subject of the compensation arrangement; 3. Does not receive compensation or other payments subject to approval by the person who is the subject of the compensation arrangement; 4. Has no material financial interest affected by the compensation arrangement; and 5. Does not approve a transaction providing economic benefits to the person who is the subject of the compensation arrangement, who in turn has approved or will approve a transaction providing benefits to the board or committee member. C. The board or compensation committee shall obtain and rely upon appropriate data as to comparability prior to approving the terms of compensation. Appropriate data may include the following: 1. Compensation levels paid by similarly situated organizations, both taxable and tax-exempt, for functionally comparable positions. 'similary situated' organizations are those of a similar size, purpose, and with similar resources; 2. The availability of similar services in the geographic area of this organization; 3. Current compensation levels compiled by independent firms; 4. Actual written offers from similar institutions competing for the services of the person who is the subject of the compensation arrangement. As allowed by irs regulation 4958-6, if this organization has average annual gross receipts (including contributions) for its prior three tax years of less than 1 million, the board or compensation committee will have obtained and relied upon appropriate data as to comparability if it obtains and relies upon data of compensation paid by three comparable organizations in the same or similar communities for similar services. D. The terms of compensation and the basis for approving them shall be recorded in written minutes of the meeting of the

Form 990, Page 6, Part VI, Line 19

The organization made such materials available upon request.

Filing and Contact Details

Filer

Filer Name
Fairways for Freedom Inc
EIN
47-5491069
Phone
9179211381
Address
5200 N OCEAN DRIVE UNIT 401, SINGER ISLAND, FL 33404

Signing Officer

Name
Roger Schiffman
Title
President
Phone
9179211381
Signed
2025-11-06

Organization Details

Principal Officer
Roger Schiffman
Formed
2016
Legal Domicile
De
Voting Board Members
6
Independent Board Members
6
Employees
0

Preparer

Firm
Mf & Associates Group LLC
Address
8409 N MILITARY TRAIL STE 119, PALM BEACH GARDENS, FL 33410
Preparer
David Beck
Phone
5616911100
Supplemental Narrative

Additional Explanations

FORM 990 - ORGANIZATION'S MISSION

Fairways for freedom provides combat-injured veterans with instruction and practice in evidence-informed, clinically tested, self-regulation techniques; opportunities for therapeutic, recreational (golf, and community building social activities); training on healthy lifestyle choices and education about community-based veteran resources for post- retreat reintegration.) the goal is also to connect leaders in the business community with combat-injured verterans through the game of golf. Business professionals serve as mentors to the veterans and, in turn, learn what true sacrifice is all about. The company had two trips in 2024: one to vermont on june 16, 2024 with 8 combat-injured veterans, and one to ireland september 9-17, 2024 with 8 combat-injured veterans and 5 supporting ambassadors along with 2 company directors.

Form 990

The company had three trips in 2024 for combat injured veterans, and 5 supporting ambassadorsalong with two company directors, one to sea island ga feb 25- march 1, one to vermont on june 9-14, and to ireland on sept 7-15

Raw XML Appendix317 raw XML fields

This appendix keeps the raw XML leaves available for debugging and edge-case review. The human report above is the primary experience.

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IRS990ScheduleO/SupplementalInformationDetail/ExplanationTxt0FAIRWAYS FOR FREEDOM PROVIDES COMBAT-INJURED VETERANS WITH INSTRUCTION AND PRACTICE IN EVIDENCE-INFORMED, CLINICALLY TESTED, SELF-REGULATION TECHNIQUES; OPPORTUNITIES FOR THERAPEUTIC, RECREATIONAL (GOLF, AND COMMUNITY BUILDING SOCIAL ACTIVITIES); TRAINING ON HEALTHY LIFESTYLE CHOICES AND EDUCATION ABOUT COMMUNITY-BASED VETERAN RESOURCES FOR POST- RETREAT REINTEGRATION.) THE GOAL IS ALSO TO CONNECT LEADERS IN THE BUSINESS COMMUNITY WITH COMBAT-INJURED VERTERANS THROUGH THE GAME OF GOLF. BUSINESS PROFESSIONALS SERVE AS MENTORS TO THE VETERANS AND, IN TURN, LEARN WHAT TRUE SACRIFICE IS ALL ABOUT. THE COMPANY HAD TWO TRIPS IN 2024: ONE TO VERMONT ON JUNE 16, 2024 WITH 8 COMBAT-INJURED VETERANS, AND ONE TO IRELAND SEPTEMBER 9-17, 2024 WITH 8 COMBAT-INJURED VETERANS AND 5 SUPPORTING AMBASSADORS ALONG WITH 2 COMPANY DIRECTORS.
IRS990ScheduleO/SupplementalInformationDetail/ExplanationTxt1THE COMPANY HAD THREE TRIPS IN 2024 FOR COMBAT INJURED VETERANS, AND 5 SUPPORTING AMBASSADORSALONG WITH TWO COMPANY DIRECTORS, ONE TO SEA ISLAND GA FEB 25- MARCH 1, ONE TO VERMONT ON JUNE 9-14, AND TO IRELAND ON SEPT 7-15
IRS990ScheduleO/SupplementalInformationDetail/ExplanationTxt2ROGER SCHIFFMAN PRES/DIR SPOUSE PATRICIA DONNELLY TREASURER SPOUSE KATHLEEN SCHIFFMAN SECRETARY DAUGHTER
IRS990ScheduleO/SupplementalInformationDetail/ExplanationTxt3THE OFFICERS AND DIRECTOR(S) OF THE ORGANIZATION ARE INTIMATELY INVOLVED WITH AND IN THE ORGANIZATION'S ACTIVITIES, AND USE THIS KNOWLEDGE TO REVIEW THE FORM 990.
IRS990ScheduleO/SupplementalInformationDetail/ExplanationTxt4ARTICLE 9 (CONFLICT OF INTEREST AND COMPENSATION APPROVAL POLICIES) OF THE TAXPAYER'S BYLAWS PROVIDES IN SECTION3 (CONFLICT OF INTEREST AVOIDANCE PROCEDURES) AS FOLLOWS: A. DUTY TO DISCLOSE. IN CONNECTION WITH ANY ACTUAL OR POSSIBLE CONFLICT OF INTEREST, AN INTERESTED PERSON DEFINED IN SECTION 2(A) AS INCLUDING 'ANY DIRECTOR, PRINCIPAL OFFICER, MEMBER OF A COMMITTEE WITH GOVERNING BOARD DELEGATED POWERS, OR ANY OTHER PERSON WHO IS A "DISQUALIFIED PERSON" AS DEFINED IN SECTION 4958(F)(1) OF THE INTERNAL REVENUE CODE AND AS AMPLIFIED BY SECTION 53-4958-3 OF THE IRS REGULATIONS, WHO HAS A DIRECT OR INDIRECT FINANCIAL INTEREST' MUST DISCLOSE THE EXISTENCE OF THE FINANCIAL INTEREST AND BE GIVEN THE OPPORTUNITY TO DISCLOSE ALL MATERIAL FACTS TO THE DIRECTORS AND MEMBERS OF COMMITTEES WITH GOVERNING BOARD DELEGATED POWERS CONSIDERING THE PROPOSED TRANSACTION OR ARRANGEMENT. B. DETERMINING WHETHER A CONFLICT OF INTEREST EXISTS. AFTER DISCLOSURE OF THE FINANCIAL INTEREST AND ALL MATERIAL FACTS, AND AFTER ANY DISCUSSION WITH THE INTERESTED PERSON, HE/SHE SHALL LEAVE THE GOVERNING BOARD OR COMMITTEEMEETING WHILE THE DETERMINATION OF A CONFLICT OF INTEREST IS DISCUSSED AND VOTED UPON. THE REMAINING BOARD OR COMMITTEE MEMBERS SHALL DECIDE IF A CONFLICT OF INTEREST EXISTS. C. PROCEDURES FOR ADDRESSING THE CONFLICT OF INTEREST. AN INTERESTED PERSON MAY MAKE A PRESENTATION AT THE GOVERNING BOARD OR COMMITTEE MEETING, BUT AFTER THE PRESENTATION, HE/SHE SHALL LEAVE THE MEETING DURING THE DISCUSSION OF, AND THE VOTE ON, THE TRANSACTION OR ARRANGEMENT INVOLVING THE POSSIBLE CONFLICT OF INTEREST. THE CHAIRPERSON OF THE GOVERNING BOARD OR COMMITTEE SHALL, IF APPROPRIATE, APPOINT A DISINTERESTED PERSON OR COMMITTEE TO INVESTIGATE ALTERNATIVES TO THE PROPOSED TRANSACTION OR ARRANGEMENT. AFTER EXERCISING DUE DILIGENCE, THE GOVERNING BOARD OR COMMITTEE SHALL DETERMINE WHETHER THE CORPORATION CAN OBTAIN, WITH REASONABLE EFFORTS, A MORE ADVANTAGEOUS TRANSACTION OR ARRANGEMNT FROM A PERSON OR ENTITY THAT WOULD NOT GIVE RISE TO A CONFLICT OF INTEREST. IF A MORE ADVANTAGEOUS TRANSACTION OR ARRANGEMENT IS NOT REASONABLY POSSIBLE UNDER THE CIRCUMSTANCES NOT PRODUCING A CONFLICT OF INTEREST, THE GOVERNING BOARD OR COMMITTEE SHALL DETERMINE, BY A MAJORITY VOTE OF THE DISINTERESTED DIRECTORS, WHETHER THE TRANSACTION OR ARRANGEMENT IS IN THE CORPORATION'S BEST INTEREST, FOR ITS OWN BENEFIT, AND WHETHER IT IS FAIR AND REASONABLE. IN CONFORMITY WITH THE ABOVE DETERMINATION, IT SHALL MAKE ITS DECISION AS TO WHETHER TO ENTER INTO THE TRANSACTION OR ARRANGEMENT. D. VIOLATIONS OF THE CONFLICTS OF INTEREST POLICY. IF THE GOVERNING BOARD OR COMMITTEE HAS REASONABLE CAUSE TO BELIEVE A MEMBER HAS FAILED TO DISCLOSE ACTUAL OR POSSIBLE CONFLICTS OF INTEREST, IT SHALL INFORM THE MEMBER OF THE BASIS FOR SUCH BELIEF AND AFFORD THE MEMBER AN OPPORTUNITY TO EXPLAIN THE ALLEGED FAILURE TO DISCLOSE. IF, AFTER HEARING THE MEMBER'S RESPONSE AND AFTER MAKING FURTHER INVESTIGATION AS WARRANTED BY THE CIRCUMSTATNCES, THE GOVERNING BOARD OR COMMITTEE DETERMINES THE MEMBER HAS FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT OF INTEREST, IT SHALL TAKE THE APPROPRIATE DISCIPLINARY AND CORRECTIVE ACTION.
IRS990ScheduleO/SupplementalInformationDetail/ExplanationTxt5ARTICLE 9(CONFLICT OF INTEREST AND COMPENSATION APPROVAL POLICIES) OF THE TAXPAYER'S BYLAWS PROVIDES IN SECTION 5 (COMPENSATION APPROVAL POLICIES), AS FOLLOWS: "A VOTING MEMBER OF THE GOVERNING BOARD WHO RECEIVES COMPENSATION, DIRECTLY OF INDIRECTLY, FROM THE CORPORATION IS PRECLUDED FROM VOTING ON MATTERS PERTAINING TO THAT MEMBER'S COMPENSATION. A VOTING MEMBER OF ANY COMMITTEE WHOSE JURISDICTION INCLUDES COMPENSATION MATTERS AND WHO RECEIVES COMPENSATION, DIRECTLY OF INDIRECTLY, FROM THE CORPORATION FOR SERVICES IS PRECLUDED FRON VOTING ON MATTERS PERTAINING TO THAT MEMBER'S COMPENSATION. A VOTING MEMBER OF THE GOVERNING BOARD OR ANY COMMITTEE WHOSE JURISDICTION INCLUDES COMPENSATION MATTERS AND WHO RECEIVES COMPENSATION, DIRECTLY OR INDIRECTLY, FROM THE CORPORATION, EITHER INDIVIDUALLY OR COLLECTIVELY, IS PROHIBITED FROM PROVIDING INFORMATION TO ANY COMMITTEE REGARDING COMPENSATION. WHEN APPROVING COMPENSATION FOR DIRECTORS, OFFICERS AND EMPLOYEES, CONTRACTORS, AND ANY OTHER COMPENSATION CONTRACT OR ARRANGEMENT, IN ADDITION TO COMPLYING WITH THE CONFLICT OF INTEREST REQUIREMENTS AND POLICIES CONTAINED IN THE PRECEDING AND FOLLOWING SECTIONS OF THIS ARTICLE AS WELL AS THE PRECEDING PARAGRAPHS OF THIS SECTION OF THIS ARTICLE, THE BOARD OR A DULY CONSTITUTED COMMITTEE OF THE BOARD SHALL ALSO COMPLY WITH THE FOLLOWING ADDITIONAL REQUIREMENTS AND PROCEDURES: A. THE TERMS OF COMPENSATION SHALL BE APPROVED BY THE BOARD OR COMPENSATION COMMITTEE PRIOR TO THE FIRST PAYMENT OF COMPENSATION; B. ALL MEMBERS OF THE BOARD OR COMPENSATION COMMITTEE WHO APPROVE COMPENSATION ARRANGEMENTS MUST NOT HAVE A CONFLICT OF INTEREST WITH RESPECT TO THE COMPENSATION ARRANGEMENT AS SPECIFIED IN IRS REGULATION SECTION 53.4958-69(C)(III), WHICH GENERALLY REQUIRES THAT EACH BOARD MEMBER OR COMMITTEE MEMBER APPROVING A COMPENSATION ARRANGEMENT BETWEEN THIS ORGANIZATION AND A 'DISQUALIFIED PERSON' (AS DEFINED IN SECTION 4958(F)(1) OF THE INTERNAL REVENUE CODE AND AS AMPLIFIED BY SECTION 53.4958-3 OF THE IRS REGULATIONS): 1. IS NOT THE PERSON WHO IS THE SUBJECT OF THE COMPENSATION ARRANGEMENT, OR A FAMILY MEMBER OF SUCH PERSON; 2. IS NOT IN AN EMPLOYMENT RELATIONSHIP SUBJECT TO THE DIRECTION OR CONTROL OF THE PERSON WHO IS THE SUBJECT OF THE COMPENSATION ARRANGEMENT; 3. DOES NOT RECEIVE COMPENSATION OR OTHER PAYMENTS SUBJECT TO APPROVAL BY THE PERSON WHO IS THE SUBJECT OF THE COMPENSATION ARRANGEMENT; 4. HAS NO MATERIAL FINANCIAL INTEREST AFFECTED BY THE COMPENSATION ARRANGEMENT; AND 5. DOES NOT APPROVE A TRANSACTION PROVIDING ECONOMIC BENEFITS TO THE PERSON WHO IS THE SUBJECT OF THE COMPENSATION ARRANGEMENT, WHO IN TURN HAS APPROVED OR WILL APPROVE A TRANSACTION PROVIDING BENEFITS TO THE BOARD OR COMMITTEE MEMBER. C. THE BOARD OR COMPENSATION COMMITTEE SHALL OBTAIN AND RELY UPON APPROPRIATE DATA AS TO COMPARABILITY PRIOR TO APPROVING THE TERMS OF COMPENSATION. APPROPRIATE DATA MAY INCLUDE THE FOLLOWING: 1. COMPENSATION LEVELS PAID BY SIMILARLY SITUATED ORGANIZATIONS, BOTH TAXABLE AND TAX-EXEMPT, FOR FUNCTIONALLY COMPARABLE POSITIONS. 'SIMILARY SITUATED' ORGANIZATIONS ARE THOSE OF A SIMILAR SIZE, PURPOSE, AND WITH SIMILAR RESOURCES; 2. THE AVAILABILITY OF SIMILAR SERVICES IN THE GEOGRAPHIC AREA OF THIS ORGANIZATION; 3. CURRENT COMPENSATION LEVELS COMPILED BY INDEPENDENT FIRMS; 4. ACTUAL WRITTEN OFFERS FROM SIMILAR INSTITUTIONS COMPETING FOR THE SERVICES OF THE PERSON WHO IS THE SUBJECT OF THE COMPENSATION ARRANGEMENT. AS ALLOWED BY IRS REGULATION 4958-6, IF THIS ORGANIZATION HAS AVERAGE ANNUAL GROSS RECEIPTS (INCLUDING CONTRIBUTIONS) FOR ITS PRIOR THREE TAX YEARS OF LESS THAN 1 MILLION, THE BOARD OR COMPENSATION COMMITTEE WILL HAVE OBTAINED AND RELIED UPON APPROPRIATE DATA AS TO COMPARABILITY IF IT OBTAINS AND RELIES UPON DATA OF COMPENSATION PAID BY THREE COMPARABLE ORGANIZATIONS IN THE SAME OR SIMILAR COMMUNITIES FOR SIMILAR SERVICES. D. THE TERMS OF COMPENSATION AND THE BASIS FOR APPROVING THEM SHALL BE RECORDED IN WRITTEN MINUTES OF THE MEETING OF THE
IRS990ScheduleO/SupplementalInformationDetail/ExplanationTxt6THE ORGANIZATION MADE SUCH MATERIALS AVAILABLE UPON REQUEST.
IRS990ScheduleO/SupplementalInformationDetail/FormAndLineReferenceDesc0FORM 990 - ORGANIZATION'S MISSION
IRS990ScheduleO/SupplementalInformationDetail/FormAndLineReferenceDesc1FORM 990
IRS990ScheduleO/SupplementalInformationDetail/FormAndLineReferenceDesc2FORM 990, PAGE 6, PART VI, LINE 2
IRS990ScheduleO/SupplementalInformationDetail/FormAndLineReferenceDesc3FORM 990, PAGE 6, PART VI, LINE 11B
IRS990ScheduleO/SupplementalInformationDetail/FormAndLineReferenceDesc4FORM 990, PAGE 6, PART VI, LINE 12C
IRS990ScheduleO/SupplementalInformationDetail/FormAndLineReferenceDesc5FORM 990, PAGE 6, PART VI, LINE 15A
IRS990ScheduleO/SupplementalInformationDetail/FormAndLineReferenceDesc6FORM 990, PAGE 6, PART VI, LINE 19
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