Locus

“A copy of the completed 990 will be provided to the organization prior to the filing deadline. The return will not be provided to the board prior to signing but it will be reviewed by the president and cfo, who are entrusted by the board for their review, prior to the return being signed by the cfo.”

“At least annually, officers, and directors are required to review and sign the conflict of interest policy, which contains a duty to disclose clause. These are reviewed by the president. Any issues identified are investigated and discussed with the cfo for financial reporting or regulatory/compliance impact. In the event of a potential conflict, that person will recuse themselves from all discussion and/or vote on the matter.”

“Management utilizes the vba annual salary survey as a guideline for determining market for bank executives and staff. Management then passes this info up to the human resources/compensation committee for further review and approval. All discussions are documented in the meeting minutes.”

“Financial statements are posted on the website. Governing documents and conflicts of interest policy are available upon request.”

“Consulting: program service expenses 0. Management and general expenses 229,686. Fundraising expenses 0. Total expenses 229,686.”

“Change in net assets from undistributed income of bank subsidiary 2,306,782. Change in net assets from undistributed income of non-bank subsidiary 1,189,381. Change in accumulated other comprehensive loss 297,709. Dividends paid on subsidiary's preferred stock -424,667. Dividends paid to minority shareholders on subsidiary class a stock -1,082. Dividends paid to minority shareholders on subsidiary class b stock -193,261. Noncontrolling interest in subsidiary 45,880,557. Py noncontrolling interest in subsidiary -45,222,839.”

“Process has not changed from prior year.”