Department of the Treasury Internal Revenue Service
Public Charity Status and Public Support
Complete if the organization is a section 501(c)(3) organization or a section
4947(a)(1) nonexempt charitable trust.
Attach to Form 990 or Form 990-EZ. See separate instructions.
OMB No. 1545-0047
2011
Open to Public Inspection
Name of the organization
BERKLEE COLLEGE OF MUSIC INC
Employer identification number
04-2300472
Part I
Reason for Public Charity Status
(All organizations must complete this part.) See instructions
The organization is not a private foundation because it is: (For lines 1 through 11, check only one box.)
1
2
3
4
5
section 170(b)(1)(A)(iv). (Complete Part II.)
6
7
8
9
receipts from activities related to its exempt functions—subject to certain exceptions, and (2) no more than 331/3% of
its support from gross investment income and unrelated business taxable income (less section 511 tax) from businesses
acquired by the organization after June 30, 1975. See section 509(a)(2). (Complete Part III.)
10
11
e
By checking this box, I certify that the organization is not controlled directly or indirectly by one or more disqualified persons other than foundation managers and other than one or more publicly supported organizations described in section 509(a)(1) or section 509(a)(2).
f
If the organization received a written determination from the IRS that it is a Type I, Type II or Type III supporting organization, check this box
..................................................
g
Since August 17, 2006, has the organization accepted any gift or contribution from any of the following persons?
(i) a person who directly or indirectly controls, either alone or together with persons described in (ii)
Yes
No
and (iii) below, the governing body of the the supported organization?
................
11g(i)
No
(ii)
a family member of a person described in (i) above?
......................
11g(ii)
No
(iii)
a 35% controlled entity of a person described in (i) or (ii) above?
................
11g(iii)
No
h
Provide the following information about the supported organization(s).
(i) Name of supported organization
(ii) EIN
(iii) Type of organization (described on lines 1- 9 above or IRC section (see instructions))
(iv) Is the organization in col. (i) listed in your governing document?
(v) Did you notify the organization in col. (i) of your support?
(vi) Is the organization in col. (i) organized in the U.S.?
(vii) Amount of support?
Yes
No
Yes
No
Yes
No
Total
For Paperwork Reduction Act Notice, see the Instructions for Form 990.
Cat. No. 11285F
Schedule A (Form 990 or 990-EZ) 2011
Schedule A (Form 990 or 990-EZ) 2011
Page 2
Part II
Support Schedule for Organizations Described in IRC 170(b)(1)(A)(iv) and 170(b)(1)(A)(vi) (Complete only if you checked the box on line 5, 7, or 8 of Part I or if the
organization failed to qualify under Part III. If the organization fails to
qualify under the tests listed below, please complete Part III.)
Section A. Public Support
Calendar year(or fiscal year beginning in)
(a) 2007
(b) 2008
(c) 2009
(d) 2010
(e) 2011
(f) Total
1
Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") ....
2
Tax revenues levied for the organization's benefit and either paid to or expended on its behalf.......
3
The value of services or facilities furnished by a governmental unit to the organization without charge..
4
Total. Add lines 1 through 3..
5
The portion of total contributions by each person (other than a governmental unit or publicly supported organization) included
on line 1 that exceeds 2% of the amount shown on line 11, column (f)..
6
Public Support. Subtract line 5 from line 4.
Section B. Total Support
Calendar year(or fiscal year beginning in)
(a) 2007
(b) 2008
(c) 2009
(d) 2010
(e) 2011
(f) Total
7
Amounts from line 4..
8
Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources..
9
Net income from unrelated business activities, whether or not the business is regularly carried on..
10
Other income. (Explain in Part IV.) Do not include gain or loss from the sale of capital assets..
11
Total support (Add lines 7 through 10).
12
Gross receipts from related activities, etc. (See instructions.)
..................
12
13
First Five Years
If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a 501(c)(3) organization,
check this box and stop here..........................................
Section C. Computation of Public Support Percentage
14
Public Support Percentage for 2010 (line 6 column (f) divided by line 11 column (f))
.........
14
15
Public Support Percentage for 2009 Schedule A, Part II, line 14
...............
15
16a
33 1/3% support test—2011.
If the organization did not check the box on line 13, and line 14 is 33 1/3% or more, check this box
and stop here. The organization qualifies as a publicly supported organization
......................
b
33 1/3% support test—2010.
If the organization did not check the box on line 13 or 16a, and line 15 is 33 1/3% or more, check this
box and stop here. The organization qualifies as a publicly supported organization
.....................
17a
10%-facts-and-circumstances test—2011.
If the organization did not check a box on line 13, 16a, or 16b and line 14
is 10% or more, and if the organization meets the "facts and circumstances" test, check this box and stop here. Explain
in Part IV how the organization meets the "facts and circumstances" test. The organization qualifies as a publicly supported
organization
..................................................
b
10%-facts-and-circumstances test—2010.
If the organization did not check a box on line 13, 16a, 16b, or 17a and line
15 is 10% or more, and if the organization meets the "facts and circumstances" test, check this box and stop here.
Explain in Part IV how the organization meets the "facts and circumstances" test. The organization qualifies as a publicly supported organization
..............................................
18
Private Foundation
If the organization did not check a box on line 13, 16a, 16b, 17a or 17b, check this box and see
instructions
...................................................
Schedule A (Form 990 or 990-EZ) 2011
Schedule A (Form 990 or 990-EZ) 2011
Page 3
Part III
Support Schedule for Organizations Described in IRC 509(a)(2) (Complete only if you checked the box on line 9 of Part I or if the organization
failed to qualify under Part II. If the organization fails to qualify under
the tests listed below, please complete Part II.)
Section A. Public Support
Calendar year(or fiscal year beginning in)
(a) 2007
(b) 2008
(c) 2009
(d) 2010
(e) 2011
(f) Total
1
Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") .
2
Gross receipts from admissions, merchandise sold or services performed, or facilities furnished in any activity that is related to the organization's tax-exempt purpose......
3
Gross receipts from activities that are not an unrelated trade or business under section 513..
4
Tax revenues levied for the organization's benefit and either paid to or expended on its behalf...
5
The value of services or facilities furnished by a governmental unit to the organization without charge..
6
Total. Add lines 1 through 5.
7a
Amounts included on lines 1, 2, and 3 received from disqualified persons...
b
Amounts included on lines 2 and 3 received from other than disqualified persons that exceed the greater of $5,000 or 1% of the amount on line 13 for the year.
c
Add lines 7a and 7b..
8
Public Support (Subtract line 7c from line 6.)
Section B. Total Support
Calendar year (or fiscal year beginning in)
(a) 2007
(b) 2008
(c) 2009
(d) 2010
(e) 2011
(f) Total
9
Amounts from line 6...
10a
Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources..
b
Unrelated business taxable income (less section 511 taxes) from businesses acquired after June 30, 1975.
c
Add lines 10a and 10b.
11
Net income from unrelated business activities not included in line 10b, whether or not the business is regularly carried on.
12
Other income. Do not include gain or loss from the sale of capital assets (Explain in Part IV.)
13
Total support (Add lines 9, 10c, 11 and 12.).
14
First Five Years
If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a 501(c)(3) organization,
check this box and stop here.............................................
Section C. Computation of Public Support Percentage
15
Public Support Percentage for 2011 (line 8 column (f) divided by line 13 column (f))
.........
15
16
Public support percentage from 2010 Schedule A, Part III, line 15
...............
16
Section D. Computation of Investment Income Percentage
17
Investment income percentage for 2011 (line 10c column (f) divided by line 13 column (f))
......
17
18
Investment income percentage from 2010 Schedule A, Part III, line 17
.............
18
19a
33 1/3% support tests—2011.
If the organization did not check the box on line 14, and line 15 is more than 33 1/3% and line 17 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization
..........
b
33 1/3% support tests—2010.
If the organization did not check a box on line 14 or line 19a, and line 16 is more than 33 1/3% and line 18 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization
....
20
Private Foundation
If the organization did not check a box on line 14, 19a or 19b, check this box and see instructions
.....
Schedule A (Form 990 or 990-EZ) 2011
Schedule A (Form 990 or 990-EZ) 2011
Page 4
Part IV
Supplemental Information.
Supplemental Information. Complete this part to provide the explanation required by Part II, line 10; Part II, line 17a or 17b; or Part III, line 12. Also complete this part for any additional information. (See instructions).
Facts And Circumstances Test
Explanation
Schedule A (Form 990 or 990-EZ) 2011
Additional Data
Software ID:
Software Version:
-
TIN:
SCHEDULE E(Form 990 or 990-EZ) Department of the TreasuryInternal Revenue Service
SchoolsComplete if the organization answered "Yes" to Form 990, Part IV, line 13,or Form 990-EZ, Part VI, line 48. Attach to Form 990 or Form 990-EZ.
OMB No. 1545-0047
2011
Open to Public Inspection
Name of the organization
BERKLEE COLLEGE OF MUSIC INC
Employer identification number
04-2300472
Part I
YES
NO
1
Does the organization have a racially nondiscriminatory policy toward students by statement in its charter, bylaws,
other governing instrument, or in a resolution of its governing body?
......................
1
Yes
2
Does the organization include a statement of its racially nondiscriminatory policy toward students in all its
brochures, catalogues, and other written communications with the public dealing with student admissions,
programs, and scholarships?
......................................
2
Yes
3
Has the organization publicized its racially nondiscriminatory policy through newspaper or broadcast media during
the period of solicitation for students, or during the registration period if it has no solicitation program, in a way
that makes the policy known to all parts of the general community it serves? If "Yes," please describe. If "No,"
please explain. If you need more space use Part II.
.............................
3
Yes
4
Does the organization maintain the following?
a
Records indicating the racial composition of the student body, faculty, and administrative staff?
..........
4a
Yes
b
Records documenting that scholarships and other financial assistance are awarded on a racially nondiscriminatory
Other extracurricular activities?
.....................................
5h
No
If you answered "Yes" to any of the above, please explain. If you need more space, use Part II.
6a
Does the organization receive any financial aid or assistance from a governmental agency?
...........
6a
Yes
b
Has the organization's right to such aid ever been revoked or suspended?
...................
6b
No
If you answered "Yes" to either line 6a or line 6b, explain on Part II.
7
Does the organization certify that it has complied with the applicable requirements of sections 4.01 through 4.05
of Rev. Proc. 75-50, 1975-2 C.B. 587, covering racial nondiscrimination? If "No," explain on Part II.
7
Yes
Paperwork Reduction Act Notice, see the Instructions for Form 990.
Cat. No. 50085D
Schedule E (Form 990 or 990-EZ) 2011
Schedule E (Form 990 or 990EZ) 2011
Page 2
Part II
Supplemental Information
Complete this part to provide the explanations required by Part I, lines 3, 4d, 5h, 6b, and 7, as applicable. Also complete this part to provide any other additional information (see instructions).
Identifier
Return Reference
Explanation
PUBLICIZE NONDISCRIMINATORY POLICY
LINE 3
THE COLLEGE'S POLICY OF NONDISCRIMINATION IS PUBLISHED IN ALL COLLEGE CATALOGUES AND BROCHURES, AS WELL AS ALL EMPLOYMENT ADVERTISEMENTS.
FINANCIAL AID OR ASSISTANCE
LINE 6A
THE COLLEGE RECEIVES FEDERAL AND STATE STUDENT FINANCIAL AID IN THE FORM OF GRANTS, LOANS, AND WORK STUDY.
Schedule E (Form 990 or 990-EZ) 2011
Additional Data
Software ID:
Software Version:
-
TIN:
SCHEDULE O (Form 990 or 990-EZ)
Department of the Treasury Internal Revenue Service
Supplemental Information to Form 990 or 990-EZ
Complete to provide information for responses to specific questions on
Form 990 or to provide any additional information.
Attach to Form 990 or 990-EZ.
OMB No. 1545-0047
2011
Open to Public Inspection
Name of the organization
BERKLEE COLLEGE OF MUSIC INC
Employer identification number
04-2300472
Identifier
Return Reference
Explanation
ORGANIZATION'S MISSION
PART III, LINE 1
*MISSION AND PHILOSOPHY* THE MISSION OF BERKLEE COLLEGE OF MUSIC IS TO EDUCATE, TRAIN, AND DEVELOP STUDENTS TO EXCEL IN MUSIC AS A CAREER. DEVELOPING THE MUSICIANSHIP OF ALL OUR STUDENTS IS THE FOUNDATION OF OUR CURRICULUM. WE BELIEVE THAT THE LESSONS AND QUALITIES DERIVED FROM THAT WORK - THE SELF-DISCIPLINE NEEDED FOR EXCELLENCE, THE EMPATHY REQUIRED OF MUSIC MAKING, AND THE OPENNESS AND INQUISITIVENESS ESSENTIAL TO CREATIVITY - ARE CRITICAL TO ACHIEVEMENT IN ANY PURSUIT, MUSICAL OR OTHERWISE; AND THAT MUSIC IS A POWERFUL CATALYST FOR PERSONAL GROWTH, WHICH IS CENTRAL TO ANY COLLEGIATE EXPERIENCE. OUR COMPREHENSIVE CURRICULUM IS DISTINCTLY CONTEMPORARY IN ITS CONTENT AND APPROACH, AND COVERS THE PRINCIPAL MUSICAL MOVEMENTS OF OUR TIME. THROUGH A COURSE OF SCHOLARLY AND PRACTICAL LEARNING EXPERIENCES INTEGRATING PERFORMANCE AND WRITING, OUR CURRICULUM COVERS THE VARIETY OF INFLUENTIAL STYLES, RELEVANT TECHNOLOGIES, AND CAREER OPPORTUNITIES OPEN TO TODAY'S MUSIC PROFESSIONAL. *OBJECTIVES* TO DEFINE AND REFINE THE INDIVIDUAL TALENTS OF OUR STUDENTS BY PROVIDING A BROAD RANGE OF MAJOR PROGRAMS OFFERED BY A DISTINGUISHED FACULTY, AND TO PREPARE THEM FOR CAREERS IN MUSIC THAT REFLECT THE DIVERSITY OF EXPRESSION AND OPPORTUNITIES THAT DEFINE MUSIC TODAY.
TO ENABLE OUR STUDENTS TO EMPLOY THEIR MUSICAL EDUCATION IN A GLOBAL
SOCIETY BY PROVIDING A COHERENT LIBERAL ARTS CURRICULUM THAT INFORMS THEIR
THINKING ABOUT ISSUES THAT HAVE SHAPED OUR TIME. TO ENCOURAGE OUR STUDENTS TO APPRECIATE AND APPLY MUSIC'S ENORMOUS FORCE FOR THE ENRICHMENT OF SOCIETY AND INTERCULTURAL UNDERSTANDING. TO CULTIVATE A SUPPORTIVE LEARNING ENVIRONMENT BY ACTIVELY PROMOTING A CLIMATE OF RESPECT FOR PERSONAL AND CULTURAL DIFFERENCES, AND BY OFFERING A RANGE OF SERVICES AND ACTIVITIES TO SUPPORT THE NEEDS OF THE STUDENT MUSICIANS WHO COME TO US FROM AROUND THE WORLD. TO MAINTAIN THE VITALITY OF OUR COLLEGE COMMUNITY BY ENCOURAGING AND SUPPORTING CONTINUING PROFESSIONAL DEVELOPMENT FOR ALL OF ITS MEMBERS. TO PROVIDE AN ENVIRONMENT IN WHICH ALL KNOW THAT THEY ARE FULL AND VALUED MEMBERS OF THE COMMUNITY. TO VALUE ETHICAL BEHAVIOR IN ALL ASPECTS OF PERSONAL AND PROFESSIONAL LIFE BY ESTABLISHING A COMMUNITY THAT VALUES INTEGRITY IN ALL RELATIONSHIPS.
TO RETAIN OUR LEADERSHIP POSITION IN MUSIC EDUCATION AND TO ENSURE THAT
OUR CURRICULUM REMAINS RELEVANT BY PLEDGING TO VALUE ACADEMIC FREEDOM AND
INNOVATION. *PHILOSOPHY* BERKLEE WAS FOUNDED ON TWO REVOLUTIONARY IDEAS: THAT MUSICIANSHIP COULD BE TAUGHT THROUGH THE MUSIC OF THE TIME; AND THAT OUR STUDENTS NEED PRACTICAL, PROFESSIONAL SKILLS FOR SUCCESSFUL, SUSTAINABLE MUSIC CAREERS. WHILE OUR BEDROCK PHILOSOPHY HAS NOT CHANGED, THE MUSIC AROUND US HAS AND REQUIRES THAT WE EVOLVE WITH IT. FOR OVER HALF A CENTURY, WE'VE DEMONSTRATED OUR COMMITMENT TO THIS APPROACH BY WHOLEHEARTEDLY EMBRACING CHANGE. WE UPDATE OUR CURRICULUM AND TECHNOLOGY TO MAKE THEM MORE RELEVANT, AND ATTRACT DIVERSE STUDENTS WHO REFLECT THE MULTIPLICITY OF INFLUENCES IN TODAY'S MUSIC. WE PREPARE OUR STUDENTS FOR A LIFETIME OF PROFESSIONAL AND PERSONAL GROWTH THROUGH THE STUDY OF THE ARTS, SCIENCES, AND HUMANITIES. AND WE ARE DEVELOPING NEW INITIATIVES TO REACH AND INFLUENCE AN EVER-WIDENING AUDIENCE. MORE THAN A COLLEGE, BERKLEE HAS BECOME THE WORLD'S SINGULAR LEARNING LAB FOR THE MUSIC OF TODAY-AND TOMORROW. WE ARE A MICROCOSM OF THE MUSIC WORLD, REFLECTING THE INTERPLAY BETWEEN MUSIC AND CULTURE; AN ENVIRONMENT WHERE ASPIRING MUSIC PROFESSIONALS LEARN HOW TO INTEGRATE NEW IDEAS, ADAPT TO CHANGING MUSICAL GENRES, AND SHOWCASE THEIR DISTINCTIVE SKILLS IN AN EVOLVING COMMUNITY. WE ARE AT THE CENTER OF A WIDENING NETWORK OF INDUSTRY PROFESSIONALS WHO USE THEIR OPENNESS, VIRTUOSITY, AND VERSATILITY TO TAKE MUSIC IN SURPRISING NEW DIRECTIONS.
FAMILY AND BUSINESS RELATIONSHIPS
PART VI, SECTION A, QUESTION 2
SEVERAL TRUSTEES HAVE ENGAGED IN A BUSINESS TRANSACTION WITH ANOTHER TRUSTEE. THESE TRANSACTIONS OCCUR IN THE ORDINARY COURSE OF BUSINESS. TRUSTEE WILLIAM LYNCH EMPLOYS ANOTHER FORMER TRUSTEE, ALAN MCLEAN, IN HIS FIRM.
FORM 990 REVIEW PROCESS
PART VI, SECTION B, QUESTION 11A
THE FORM 990 IS PREPARED AND REVIEWED BY THE CONTROLLER'S DEPARTMENT AND REVIEWED BY THE COLLEGE'S TAX ADVISORS. UPON COMPLETION, THE DRAFT FORM 990 IS DISTRIBUTED TO THE MEMBERS OF THE AUDIT & FISCAL CONTROLS COMMITTEE FOR THEIR REVIEW AND COMMENTS. ONCE THE DRAFT IS APPROVED BY THE COMMITTEE, THE FINAL FORM 990 IS DISTRIBUTED TO THE FULL BOARD.
CONFLICT OF INTEREST POLICY
PART VI, SECTION B, QUESTION 12C
THE PURPOSE OF THE CONFLICTS OF INTEREST POLICY IS TO PROTECT THE COLLEGE'S INTEREST WHEN IT IS ENTERING INTO A TRANSACTION OR ARRANGEMENT THAT MIGHT BENEFIT THE PRIVATE INTEREST OF AN INTERESTED PERSON. AN INTERESTED PERSON IS DEFINED AS ANY PERSON WHO IS OR WAS DURING THE PREVIOUS FIVE YEARS IN A POSITION TO EXERCISE SUBSTANTIAL INFLUENCE OVER THE COLLEGE'S AFFAIRS, INCLUDING ANY TRUSTEE, OFFICER, SUBSTANTIAL DONOR, SENIOR MANAGER OR MEMBER OF A COMMITTEE WITH BOARD-DELEGATED POWERS (EACH A "FIDUCIARY"). IN CONNECTION WITH ANY ACTUAL OR POSSIBLE CONFLICTS OF INTEREST, A FIDUCIARY WILL DISCLOSE ALL MATERIAL FACTS TO THE PRESIDENT OR CHAIR AT THE EARLIEST POSSIBLE TIME AFTER THE CONFLICT OF INTEREST BECOMES KNOWN TO THE FIDUCIARY. ANY CONFLICT WILL BE MADE A MATTER OF RECORD THROUGH ANNUAL OR OTHER REPORTING AND CERTIFICATION PROCEDURE AS THE TRUSTEES REQUIRE FROM TIME TO TIME. AFTER DISCLOSURE OF THE CONFLICT OF INTEREST AND AFTER ANY DISCUSSION WITH THE RELEVANT FIDUCIARY, THE TRUSTEES SHALL FINALLY DETERMINE WHETHER ANY CONFLICT OF INTEREST EXISTS. IF A CONFLICT OF INTEREST IS DETERMINED TO EXIST, THE TRUSTEES MAY TAKE ACTIONS AS DEFINED IN THE BYLAWS OF THE COLLEGE.
COMPENSATION POLICY
PART VI, SECTION B, QUESTION 15
THE EXECUTIVE COMMITTEE OF THE BOARD OF TRUSTEES, SITTING AS THE COMPENSATION COMMITTEE, HAS THE AUTHORITY TO ESTABLISH FAIR AND APPROPRIATE COMPENSATION PACKAGES TO BE AWARDED TO THE PRESIDENT AND OTHER HIGHLY COMPENSATED ADMINISTRATORS OF THE COLLEGE. IN DETERMINING THE EXECUTIVE COMPENSATION PACKAGES, THE EXECUTIVE COMMITTEE CONSIDERS COMPARATIVE DATA, OBTAINED FROM PUBLISHED SOURCES OR A COMPENSATION CONSULTANT, REFLECTING THE COMPENSATION LEVELS AWARDED TO EQUIVALENTLY SITUATED INDIVIDUALS EMPLOYED BY COMPARABLE INSTITUTIONS. THE EXECUTIVE COMMITTEE REPORTS THE PROCESS AND AWARDING OF COMPENSATION PACKAGES TO THE BOARD OF TRUSTEES. WHEN THE COMPENSATION COMMITTEE IS MEETING, THE PRESIDENT DOES NOT PARTICIPATE.
PUBLIC DISCLOSURE
PART VI, SECTION C, QUESTION 19
THE COLLEGE MAKES THE DOCUMENTS, POLICIES AND FINANCIAL STATEMENTS AVAILABLE UPON WRITTEN REQUEST. THE COLLEGE'S FORM 990 IS ALSO AVAILABLE ONLINE AT WWW.GUIDESTAR.ORG.
OTHER CHANGES IN NET ASSETS
PART XI, LINE 5
UNREALIZED GAIN ON INVESTMENTS (20,030,671) PENSION OBLIGATION CHANGES OTHER THAN NET PERIODIC COSTS (20,554,129) BERKLEE VALENCIA PRIOR YEAR NET ASSETS 1,687,885 OTHER 1,140 TOTAL (38,895,775)
PURPOSE OF BOND ISSUES
SCHEDULE K, PART I
PROCEEDS OF THE BONDS WERE USED AS FOLLOWS: (1) $99,663,209 FOR EQUIPMENT PURCHASES, BUILDING RENOVATIONS, ONLINE COURSE DEVELOPMENT, OTHER BUDGETED CAPITAL EXPENDITURES AT THE COLLEGE'S EXISTING FACILITIES, AND TO ACQUIRE AND RENOVATE ADDITIONAL REAL PROPERTY AND PAY FOR CAMPUS MASTER PLANNING EXPENSES. (2) $72,610,864 TO REFINANCE OUTSTANDING DEBT BONDS ISSUED ON 8/14/97 AND 7/24/03. (3) $1,235,927 TO PAY FOR BOND ISSUANCE COSTS. PROCEDURES TO TAKE CORRECTIVE ACTION SCHEDULE K, PART V THE COLLEGE MONITORS THEIR TAX EXEMPT BONDS TO ENSURE THAT VIOLATIONS OF FEDERAL TAX REQUIREMENTS ARE TIMELY IDENTIFIED AND CORRECTED THROUGH THE VOLUNTARY CLOSING AGREEMENT PROGRAM IF SELF-REMEDIATION IS NOT AVAILABLE. THE COLLEGE PLANS TO HAVE WRITTEN PROCEDURES IN PLACE BY THE END OF MAY 31, 2013. HOWEVER, NO WRITTEN PROCEDURES WERE IN PLACE AT MAY 31, 2012.
For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.