National Foundation for Credit Counseling Inc

“The nfcc bylaws provide, in relevant part, the following: classes: the foundation shall have one class of members in order to be a member an organization must: be tax exempt under section 501(c)(3) of the internal revenue code. Be duly qualified and existing under the laws of the district of columbia,or any states or territory of the united states of america. Provide financial counseling services and act in compliance with all applicable federal and state laws and regulations. Obtain and maintain the foundation-approved accreditation. Comply with the nfcc's member quality standards.”

“The nfcc members elect member-representative trustees to the nfcc board of trustees at the annual meeting of the members. Additionally, members vote to ratify at-large trustees elected to the board of trustees by the board of trustees prior to the annual meeting.”

“SEE LINE 7A.”

“The irs form 990 is initially prepared by the nfcc's public accounting firm, with input and review by counsel. Nfcc staff prepare a draft for the board to review, and after the board reviews it, the 990 is finalized and submitted to the irs.”

“Please note that all trustees, officers and committee members ("interested persons") are subject to the conflict of interest policy and are required to annually affirm having received, read and understood the policy and have agreed to comply with the policy. The policy, in relevant part, requires: disclosure requirement: in connection with any actual or possible conflict, an interested person must disclose the existence of the financial interest and be given the opportunity to disclose all material facts to the trustees and/or committee members considering the proposed transaction or arrangement. Conflict determination by board: following full disclosure of an actual or possible conflict, and after any discussion with the interested person, he/she shall leave the board or committee meeting, as the case may be, while the determination of a conflict is discussed and voted upon. The remaining board or committee members shall decide if a conflict exist. The policy further specifies the procedure for addressing conflicts that arise and violations of the policy. Procedures for addressing possible conflicts: (a) if the board or the committee, as the case may be, has reasonable cause to believe a person has failed to disclose an actual or possible conflict, it will inform the person of the basis for that belief and afford the person an opportunity to explain the alleged failure to disclose. (b) if, after hearing the person's response and making further investigation as warranted by the circumstances, the board or the committee, as the case may be, determines that the person has failed to disclose an actual or possible conflict, it will take appropriate disciplinary and corrective action. (c) after exercising due diligence, the board or committee,as the case may be, will determine whether the nfcc can obtain with reasonable efforts a more advantageous transaction or arrangement from a person or entity that would not give rise to a conflict. (d) if a more advantageous transaction or arrangement is not reasonably possible under the circumstances without producing a conflict, the board or the committee, as the case may be, will determine, by a majority vote of the disinterested members, (i) whether the transaction or arrangement is in the nfcc's best interest for its own benefit, and (ii) whether its terms and conditions are fair and reasonable. In conformity with the above determinations, the board or the committee, as the case may be, will make its decision as to whether to authorize the nfcc to enter into the transaction or arrangement. Violations of the conflicts of interest policy: (a) if the board or the committee, as the case may be, has reasonable cause to believe a person has failed to disclose an actual or possible conflict, it will inform the person of the basis for that belief and afford the person an opportunity to explain the alleged failure to disclose. (b) if, after hearing the person's response and making further investigation as warranted by the circumstances, the board or the committee, as the case may be, determines that the person has failed to disclose an actual or possible conflict, it will take appropriate disciplinary and corrective action.”

“The national foundation for credit counseling's board of trustees enacted the following policy on the process of determining compensation for the nfcc's chief executive officer; and other officers and key employees of the nfcc whose compensation is required to be disclosed on form 990. The process includes all of the following elements: 1. Review and approval: (a) compensation of the chief executive officer is reviewed and approved by the nfcc's executive committee, provided that persons with conflicts of interest with respect to the compensation arrangement at issue are not involved in this review and approval. (b) compensation of the other officers and key employees is approved by the chief executive officer and overall staff compensation is reviewed on an annual basis by the nfcc's board of trustees or the executive committee. 2. Use of data as to comparable compensation: the compensation of the person is reviewed and approved using data as to comparable compensation for similarly qualified persons in functionally comparable positions at similarly situated organizations. 3. Contemporaneous documentation and recordkeeping: the executive committee records the deliberations and decisions regarding the compensation arrangement in committee meeting minutes.”

“Nfcc does not make its governing documents, conflict of interest policy and financial statements available to the public.”

“The audit oversight process has remained unchanged from the prior year.”