Colorado Sheet Metal Workers' Local 9

“The fund has no committees with the authority to act on behalf of the trustees.”

“The form 990 is provided to the entire board prior to filing. After the board's review, the form is approved and filed.”

“Enforcement of conflict of interest policy - the fund is an employee welfare benefit plan governed by the employee retirement income security act of 1974 (erisa). Under erisa, it is the continuing responsibility of each member of the board of trustees to review transactions for potential conflicts of interest, immediately disclose any actual or potential conflicts of interest, and take appropriate action upon discovery of such conflict (e.g., by the affected trustee recusing himself from any decision related to such transaction). To assist the trustees in identifying and managing actual or potential conflicts of interest, the fund distributes to each trustee, officer and key employee (if any) an annual questionnaire asking for information regarding interests that could give rise to a conflict.”

“The governing documents, conflict of interest policy and financial statements are available to any participant in the plans upon request at the fund office.”

“The administrator of the plan was also the administrator of the related pension plan and the office manager of the local union. The union initially paid the administrator's salary and benefits. The plan reimbursed amounts on a monthly basis based on an allocation approved by the trustees. Plan trustee nathan cooper received compensation from a related organization during the year. As a sponsoring organization to the fund, sheet metal and air conditioning contractors colorado chapter (smacna) is considered related to the plan under this form's definition of related entities. Compensation received by these individuals are reported on page 7, part vii, line 1e. Trustees randy mitchell and jon alvino received compensation from a related organization during the year. As a contributing employer to the fund, sheet metal workers international association local 9 (the local) is considered related to the plan under this form's definition of related entities. Compensation received by these individuals is reported on page 7, part vii, line 1e. Form 990,part xii, line 2b: financial statements effective january 1, 2012, the trustees approved a resolution to establish a separate plan for retired participants. The sheet metal workers' local 9 medicare retiree plan and the sheet metal workers' local 9 family health plan operate under one trust agreement and each plan issues separate audited financial statements. Both plans are reported on this form 990 on a consolidated basis. Form 990, schedule r, part iv the form 990 instructions define related organizations to include employers who contribute to voluntary employee beneficiary organizations (veba). The fund is also a multi-employer plan operated under the taft-hartley act of 1947 and the employee retirement income security act of 1974 (erisa) which provides health and welfare benefits to employees, retirees (and dependents) of contributing employers who make contributions to the plan as required under a collective bargaining agreement and/or participation agreement.”