Southeast Community Capital Corporation

“The president and cfo review the 990 before it is filed with the irs. They compare each line item to the prior year form 990 as well as comparable form 990s for other not-for-profit entities. The current year form is also reconciled to the current year financial statements. The form 990 is presented to all board members before it is filed for their review.”

“All new employees are given and required to sign an employee handbook upon hiring. It addresses a code of conduct including a conflict of interest statement and a whistleblower policy. Each employee is also required to sign annually a statement that they have no conflicts of interest.”

“Scc has a compensation committee that meets as needed to set the salaries of the president, executive vice presidents, and the chief financial officer. The president was given discretionary powers to set the salaries of all other personnel and to give the board an overview of those decisions. The president was also given the authority to increase salaries within set parameters for the evp and cfo. All salaries are disclosed to the committee. A compensation policy was put into effect on 01/16/2008 in order to comply with internal revenue code section 4958. When the salaries are put in place for all employees, a comparison with other similar organizatons is made and reviewed by the committee. The salaries are compiled from tax returns of other 990 organizations that are published with guidestar. Salary inquiries of similar jobs are reviewed on careerbuilder and salary.com and other formal salary surveys.”

“Scc maintains a website at www.pathwaylending.org where the public is given a contact name for further information regarding availability of disclosures. The 990 is also available on the guidestar website.”

“As part of their loan program, pathway sometimes remits payments to certain third party creditors on behalf of the loan client as part of the servicing of the loan or at the time of the loan closing. These creditors then receive a form 1099 nec from pathway for services rendered to the loan client, not for services rendered to pathway. Thus, pathway does not list those creditors as payments for services on form 990, part vii, section b, but they are included in the total number of 1099s over $100,000.”