Liberty Counsel Inc

“Anita Staver and Mathew Staver have a family relationship.”

“The Organization's top management official and top financial official each review the Form 990 prior to its filing with the IRS. A copy of the final Form 990 is also provided to the voting members of the Organization's governing body prior to its filing with the IRS.”

“The Organization's conflict of interest policy is distributed to each member of the Organization's governing body, its officers, and its key employees on an annual basis. Each such individual provides an annual disclosure statement indicating that they have received, read, understood and agreed to comply with the policy, and certifying that: (1) they have no relationships or interests that present a conflict of interest, (2) they have one or more conflicts of interest that have been fully disclosed as required by the policy and have been properly administered in conformity with the policy, or (3) they have previously undisclosed conflicts of interest and are disclosing the details of such conflicts. Any disclosure statement with previously undisclosed conflicts of interest are forwarded to appropriate Organization officials to take appropriate actions as required by the policy.”

“The Organization has adopted an executive compensation setting policy applicable to its key leaders, including the Organization's CEO, officers and other top leadership personnel. Under the policy, an independent committee of the Board of Directors annually reviews and approves the compensation levels of all individuals subject to the policy. The deliberations and decisions of the committee are documented in the minutes of the committee meeting. In its deliberations, the committee utilizes appropriate information regarding compensation amounts paid for comparable positions in comparable organizations. These procedures are followed to ensure that compensation arrangements for the Organization's key leaders are reasonable and appropriate. Mathew Staver and Anita Staver are both attorneys who actively lead and manage the Organization. A committee of independent members of the Board of Directors without a conflict of interest set the salaries for the Organization's leadership after evaluating comparative data regarding compensation for similar positions, including a review of salary information from the IRS Form 990s of other nonprofit legal organizations, and concluded that Mathew and Anita Staver have been consistently paid less than attorneys of other nonprofit legal groups. Their salaries were raised effective July 2013, based on a review indicating a total compensation range of $151,000 to more than $369,000 for attorneys who lead legal organizations, and a range of $200,363 to $311,674 for attorneys who manage litigation. Individual leaders of groups with much smaller budgets than Liberty Counsel (under $2.5 million) are compensated between $151,000 to $270,500. In addition, some Form 990s show that their nonprofit legal organization leaders are compensated by several separately incorporated entities, while other salaries are unverifiable because the groups compensate their leaders with multi-million dollar payments to their own for-profit law firms. Even with the new salaries, their compensation remains lower than similar organizations, and in addition, the Stavers donated $20,700 (more than 7% of their combined income) back to the Organization.”

“The Organization provides, upon request, copies of its Articles of Incorporation, bylaws, conflict of interest policy, and its financial statements.”

“leasing program during the year ended June 30, 2015 for some of its employees. The Organization did not directly process payroll for these employees; rather, the employees were paid by the Organization's professional employer organization. Therefore, a Form W-3 was not submitted by the Organization, but by ADP TOTALSOURCE MI VI, LLC (EIN: 65-0945794) for the Organization's 2 leased employees. In addition, the Organization reimbursed another not-for-profit organization for a portion of the cost of services provided by 36 attorneys and administrative personnel. A Form W-3 was submitted by the other nonprofit organization to report the compensation paid to these individuals. The number of employees reported on this Form 990 reflects the employees reported under the arrangements described above, which comprise the Organization's entire staff.”

“The Organization's Board of Directors, or a committee thereof, assumes responsibility for the oversight of the audit of its financial statements, and the selection of an independent accountant. This process has not changed from the prior year.”