Methodist Retirement Communities

“Methodist retirement communities implemented new structures which would include four board meetings a year where all mrc and affiliates business would be discussed, with all affiliate board members included in the mrc boards. United methodist senior services foundation and aldersgate trust updates terms to be three years, consistent with the other entities. Pinecrest and cornerstone have been removed from the quorum, with language updates requiring president and executive director to be part of a quorum at crestview. They are now non-voting memebers who will not be counted for quorum. Bylaws changed to bring alignment by unifying the size of the board across all entities, create mroe consistency by bringing all key terms into alignment, and unify processes.”

“The organization updated it's bylaws during the year which included changes to the amount of members needed for a quorum along with changes in names and officers.”

“The management team currently reviews all form 990s prior to filing with the irs. They compare the results to the audited financial statements and review all disclosure information. The 990s are reviewed and approved by the audit committee of the board and also made available to the entire board prior to filing with the irs.”

“The organization requires signed affidavit identifying conflict of interest by annual board meeting of mrc each year.”

“Salary for the ceo, executive director, or top management official is set by the mrc board. In deciding compensation of other officers or key employees human resources collects comparability data from industry resources related to all industry-related positions. This is shared with appropriate supervisors or others in approval process. Vp of hr collects comparability data from industry resources related to all industry-related positions. Each location submits recommendations within wage scale parameters to ceo. Ceo approves within board approved budgeted guidelines.”

“Governing documents, conflict of interest policy, and financial statements are available upon request.”

“During the intervals between meetings of the board of directors, the executive committee shall possess and may exercise all the powers and functions of the board of directors in the management and direction of the affairs of the organization in all cases in which specific direction shall not have been given by the board of directors.”

“Change in fair value of interest rate swaps -34,913. Transfer from affiliate 1,000,000.”

“The organization has a committee which assumes responsibility for choosing the independent auditor and oversight of the independent audit. This process is consistent with prior years.”

“This statement is pursuant to regulation section 1.351-3(a) by the following entity, a significant transferor, methodist retirement communities (ein: 74-1403088) ("mrc"). During the tax year ended december 31, 2020, mrc, a u.s. Tax-exempt corporation, made cash transfers that represented non-taxable deposits in the amount of $4,566,643 to nfp assurance group, ltd. (ein: 98-0405035), ("nfp"), its subsidiary formed in the cayman islands. To the extent that such transfers are not treated as deposits, but rather as constructive capital contributions from mrc only to nfp for u.s. Federal tax purposes, mrc is reporting such amounts on this statement as a protective measure in compliance with regulation section 1.351-3(a). The cost basis in the cash equals the fair market value. No private letter rulings were received in connection with the section 351 exchanges. 1. Transferor. Methodist retirement communities ein: 74-1403088 1440 lake front circle ste 110, the woodlands, tx 77380 2. Transfer. I. Transferee nfp assurance group, ltd. Ein: 98-0405035 113 south church st., queensgate house, 5th fl, grand cayman, cayman islands ky1-1102 ii. Transfer. Methodist retirement communities, a u.s. Tax-exempt corporation (the "transferor"), made cash transfers that represented non-taxable deposits during the tax year ended december 31, 2020 in the amount of $4,566,643 in u.s. Dollars (the "transfers") to nfp assurance group, ltd., its wholly-owned subsidiary formed in the cayman islands (the "transferee"). To the extent that such transfers are not treated as deposits, but rather as constructive capital contributions from the transferor only to the transferee for u.s. Federal tax purposes, the transferor is reporting such amounts on this statement as a protective measure in compliance with code section 6038b. 3. Consideration received. The transferee did not issue additional shares to the transferor in exchange for the capital contributions (or non-taxable deposits) because the transferor is the sole shareholder of the transferee and the issuance of additional shares would have been meaningless gestures according to federal tax principles. 4. Property transferred. I. Active business property. The transferee received cash transfers in the amount of $4,566,643 in connection with an alternative risk financing arrangement that represented non-taxable deposits for u.s. Federal tax purposes. To the extent that such transfers are not treated as deposits, but rather as constructive capital contributions from the transferor only to transferee for u.s. Federal tax purposes, the transferor is reporting such amounts on this statement as a protective measure in compliance with code section 6038b. The cost basis in the cash equals the fair market value. Ii. Stock or securities. Not applicable iii. Depreciated property. Not applicable iv. Property to be leased. Not applicable v. Property to be sold. Not applicable vi. Transfers to fscs. Not applicable vii. Tainted property. A. Inventory, etc. Property described in 1.367(a)-5t(b). Not applicable b. Installment obligations, etc. Property described in 1.367(a)-5t(c). Not applicable c. Foreign currency, etc. Property described in 1.367(a)-5t(d). Not applicable d. Intangible property. Property described in 1.367(a)-5t(e). Not applicable e. Leased property. Property described in 1.367(a)-4t(f). Not applicable viii. Foreign loss branch. Not applicable ix. Other intangibles. Not applicable 5. Transfer of foreign branch with previously deducted losses. I. Branch operation. Not applicable ii. Branch property. Not applicable iii. Previously deducted losses. Not applicable iv. Character of gain. Not applicable 6. Application of section 367(a)(5). Not applicable”