Fairways for Freedom Inc.

“1. Roger schiffman, who is the organization's president and a director, and patricia donnelly, who is the organization's treasurer, are husband and wife. 2. Kathleen schiffman, who is the organization's secretary and a director, is the daughter of roger schiffman and patricia donnelly.”

“The organization had no committees, which were formed, during 2016.”

“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.”

“Article 9 (conflict of interest and compensation approval policies) of the taxpayer's bylaws provides in section 3 (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 committee meeting 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 conflct of interest. The chairperson of the governing board or committee meeting 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 arrangement 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 circumstances, the governing board or committee determines the member has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action."”

“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 or 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 receivs compensation, directly or indirectly, from the corporation for services is precluded from voting on matters pertaining to that member's compensation. No 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 compensation 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 53.4958-6(c)(iii), which generally requires that each board member or committee member approving a compensation arrangment 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 compenation 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. 'similarly 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 organiztion 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 meet”

“The organization posted information and documents on its website, and also made such materials available upon request.”