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
BENNINGTON COLLEGE CORPORATION
Employer identification number
03-0179414
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)
(ii)
a family member of a person described in (i) above?
......................
11g(ii)
(iii)
a 35% controlled entity of a person described in (i) or (ii) above?
................
11g(iii)
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
BENNINGTON COLLEGE CORPORATION
Employer identification number
03-0179414
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
SCHEDULE E - EXPLANATION FOR LINE 3
BENNINGTON COLLEGE IS COMMITTED TO A POLICY OF NON-DISCRIMINATION AS DEFINED UNDER APPLICABLE STATE AND FEDERAL LAWS. ILLEGAL DISCRIMINATION WITH REGARD TO AGE, SEX, CREED, DISABILITY, NATIONAL ORIGIN, RACE, COLOR, SEXUAL ORIENTATION, GENDER IDENTITY, MARITAL STATUS, OR ANY OTHER LEGALLY PROTECTED CATEGORY IS PROHIBITED. THIS POLICY IS PUBLICIZED ON THE COMMON APPLICATION, WHICH IS PART OF OUR APPLICATION PROCESS AND PROVIDED TO PROSPECTIVE STUDENTS.
SCHEDULE E - EXPLANATION FOR LINE 6A
BENNINGTON COLLEGE STUDENTS RECEIVE SEOG, PELL, AND FEDERAL WORK STUDY MONEY.
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
BENNINGTON COLLEGE CORPORATION
Employer identification number
03-0179414
Identifier
Return Reference
Explanation
ORGANIZATION'S MISSION
PART III, LINE 1
THE MEN AND WOMEN WHO BROUGHT BENNINGTON COLLEGE INTO BEING SOUGHT TO CREATE A COLLEGE THAT WOULD EMPHASIZE "THE INDIVIDUAL STUDENT AND HER DEVELOPING INTERESTS," LEARNING "BY ACTIVITY AND LIVING," A COMMUNITY LIFE DESIGNED TO "BREAK DOWN ARTIFICIAL BARRIERS BETWEEN TEACHER AND STUDENT AND BETWEEN CURRICULUM AND EXTRA CURRICULUM," AND "A CONSCIOUS ELASTICITY IN EDUCATIONAL PLANS." THE PRINCIPLE OF LEARNING BY PRACTICE AND THE EMPHASIS ON THE INDIVIDUAL UNDERLIE EVERY MAJOR FEATURE OF A BENNINGTON EDUCATION: THE CLOSE WORKING RELATIONSHIP BETWEEN STUDENT AND TEACHER, THE INSISTENCE ON SELF-DETERMINATION, THE COMMITMENT TO LEARNING ACROSS THE DISCIPLINES, AND THE FIELD WORK TERM, WHICH GIVES STUDENTS WORK EXPERIENCE AND CONNECTS THEM TO THE GREATER COMMUNITY. THE PLAN PROCESS, THROUGH WHICH STUDENTS DESIGN THEIR ACADEMIC EXPERIENCES AND NAVIGATE THEIR BENNINGTON CAREERS, EMBODIES THE COLLEGE'S MISSION. ALSO KEY TO BENNINGTON'S PHILOSOPHY IS THE CONVICTION THAT A COLLEGE EDUCATION SHOULD NOT MERELY PROVIDE PREPARATION FOR GRADUATE SCHOOL OR A CAREER, BUT SHOULD BE AN EXPERIENCE VALUABLE IN ITSELF AND THE MODEL FOR A LIFELONG HABIT OF LEARNING. IN THE 1930S THE COLLEGE'S FIRST PRESIDENT, ROBERT DEVORE LEIGH, DEVELOPED A STATEMENT DESCRIBING BENNINGTON'S GUIDING IDEALS. THIS STATEMENT-WHICH WAS READ AT THE FIRST COMMENCEMENT IN 1936 AND HAS BEEN PART OF EVERY COMMENCEMENT SINCE-CONTINUES TO EXPRESS THE COLLEGE'S MISSION AND PURPOSES.
COMMENCEMENT STATEMENT
BENNINGTON REGARDS EDUCATION AS A SENSUAL AND ETHICAL, NO LESS THAN AN
INTELLECTUAL, PROCESS. IT SEEKS TO LIBERATE AND NURTURE THE INDIVIDUALITY, THE CREATIVE INTELLIGENCE, AND THE ETHICAL AND AESTHETIC SENSIBILITY OF ITS STUDENTS, TO THE END THAT THEIR RICHLY VARIED NATURAL ENDOWMENTS WILL BE DIRECTED TOWARD SELF-FULFILLMENT AND TOWARD CONSTRUCTIVE SOCIAL PURPOSES. WE BELIEVE THAT THESE EDUCATIONAL GOALS ARE BEST SERVED BY DEMANDING OF OUR STUDENTS' ACTIVE PARTICIPATION IN THE PLANNING OF THEIR OWN PROGRAMS, AND IN THE REGULATION OF THEIR OWN LIVES ON CAMPUS. STUDENT FREEDOM IS NOT THE ABSENCE OF RESTRAINT, HOWEVER; IT IS RATHER THE FULLEST POSSIBLE SUBSTITUTION OF HABITS OF SELF-RESTRAINT FOR RESTRAINT IMPOSED BY OTHERS. THE EXERCISE OF STUDENT FREEDOM IS THE VERY CONDITION OF A MEANINGFUL EDUCATION, AND AN ESSENTIAL ASPECT OF THE NURTURE OF FREE CITIZENS, DEDICATED TO CIVILIZED VALUES AND CAPABLE OF CREATIVE AND CONSTRUCTIVE MEMBERSHIP IN MODERN SOCIETY.
PROGRAM SERVICE ACCOMPLISHMENTS
PART III, LINE 4A
BENNINGTON'S CENTER FOR THE ADVANCEMENT OF PUBLIC ACTION, WHICH OPENED IN 2011, IS THE LATEST EXPRESSION OF THE COLLEGES COMMITMENT TO ENGAGING THE WORLD: BY EMBEDDING IN THE CURRICULUM AN ONGOING DYNAMIC BETWEEN PUBLIC RESPONSIBILITIES AND PRIVATE AMBITIONS, BENNINGTON AIMS TO INCREASE THE ODDS THAT ITS GRADUATES ARE COMMITTED TO, AND CAPABLE OF EFFECTIVE ACTION IN THE WORLD. BENNINGTON STUDENTS DRAW ON THE FULL BREADTH OF THE COLLEGE'S CURRICULUM-WHICH OFFERS PROGRAMS IN THE HUMANITIES, NATURAL SCIENCES, MATHEMATICS, SOCIAL SCIENCES, AND VISUAL AND PERFORMING ARTS-TO DESIGN INDIVIDUAL COURSES OF STUDY THAT ARE UNIFIED AND FUELED BY THEIR INTELLECT AND IMAGINATION, GUIDED BY THEIR FACULTY, AND SHAPED BY THEIR EXPERIENCE WORKING IN THE WORLD EACH YEAR. THE COLLEGE'S 688 UNDERGRADUATES HAIL FROM 36 COUNTRIES AND 46 STATES, AND THEY HAVE SPENT FIELD WORK TERMS ON 6 OUT OF 7 CONTINENTS.
FORM 990 REVIEW PROCESS
PART VI, SECTION B, LINE 11A
THE FINANCE AND AUDIT COMMITTEE OF THE BOARD OF TRUSTEES RECEIVES A DRAFT OF THE FORM 990 FOR THEIR REVIEW AND COMMENTS. AFTER ALL COMMENTS AND QUESTIONS HAVE BEEN ADDRESSED, ANY NECESSARY CHANGES OR CORRECTIONS ARE MADE TO FORM 990. THE FINANCE AND AUDIT COMMITTEE RECEIVES A FINAL COPY OF THE FORM 990 RETURN PRIOR TO FILING OF THE RETURN.
CONFLICT OF INTEREST POLICY
PART VI, SECTION B, LINE 12C
1. TRUSTEES, OFFICERS AND KEY EMPLOYEES OF BENNINGTON COLLEGE SHALL AVOID PLACING THEMSELVES IN POSITIONS IN WHICH THERE MAY BE CONFLICT BETWEEN THEIR PERSONAL INTERESTS AND THEIR DUTIES TO BENNINGTON. 2. A CONFLICT OF INTEREST EXISTS WHEN THERE IS THE POTENTIAL THAT A TRUSTEE, OFFICER, OR KEY EMPLOYEE MAY OBTAIN A DIRECT OR INDIRECT PECUNIARY OR OTHER PERSONAL BENEFIT, OR ANY OTHER IMPROPER GAIN OR ADVANTAGE, AT THE EXPENSE OF THE INTERESTS OF THE COLLEGE, OR WHEN A TRUSTEE, OFFICER, OR KEY EMPLOYEE OF THE COLLEGE ACCEPTS A GIFT OR OTHER FAVOR UNDER CIRCUMSTANCES FROM WHICH IT MIGHT BE INFERRED THAT SUCH GIFTS WERE INTENDED TO INFLUENCE THE PERFORMANCE OF DUTIES FOR THE COLLEGE. 3. INDIVIDUALS COVERED BY THIS POLICY HAVE A DUTY TO VOLUNTARILY SELF-DISCLOSE TO THE CHAIR OF THE BOARD OF TRUSTEES (UNLESS THE DISCLOSURE IS BY THE CHAIR, IN WHICH EVENT IT SHALL BE MADE TO THE VICE CHAIR) ANY POTENTIAL CONFLICT OF INTEREST: (1) PRIOR TO ASSUMING THEIR RESPONSIBILITIES, AND (2) AT THE TIME ANY POTENTIAL CONFLICT ARISES. IN THE CASE OF DISCLOSURE BY A KEY EMPLOYEE UNRELATED TO THE PROCEEDINGS OF THE BOARD OF TRUSTEES, THE DISCLOSURE SHALL BE MADE TO THE PRESIDENT. 4. EACH PROPOSED TRANSACTION IN WHICH IS IT DISCLOSED OR OTHERWISE KNOWN TO THE BOARD OR TO MANAGEMENT THAT A TRUSTEE, OFFICER, OR KEY EMPLOYEE MAY HAVE A CONFLICT OF INTEREST SHALL BE SUBMITTED TO THE EXECUTIVE COMMITTEE OF THE BOARD OF TRUSTEES FOR SUCH ACTION AS THE EXECUTIVE COMMITTEE MAY DETERMINE AND REPORTED TO THE BOARD OF TRUSTEES. 5. ANY INDIVIDUAL COVERED BY THIS POLICY SHALL NOT VOTE OR USE THAT INDIVIDUAL'S PERSONAL INFLUENCE ON ANY MATTER WITH RESPECT TO WHICH THE INDIVIDUAL BELIEVES HIM OR HERSELF TO HAVE A CONFLICT OF INTEREST, OR WITH RESPECT TO WHICH THE EXECUTIVE COMMITTEE HAS DETERMINED PURSUANT TO PARAGRAPH 4 THAT THE INDIVIDUAL HAS A CONFLICT OF INTEREST SUBJECT TO THIS POLICY. 6. ALL DISSENTING VOTES AND ABSTENTIONS FROM VOTING SHALL BE DULY NOTED IN THE MINUTES OF ALL MEETINGS OF THE BOARD AND ITS COMMITTEES 7. EACH TRUSTEE, OFFICER OR KEY EMPLOYEE SHALL SIGN A CONFLICT OF INTEREST STATEMENT IN ACCORDANCE WITH THE STATEMENT ATTACHED HERETO. 8. THE SECRETARY OF THE CORPORATION SHALL MAINTAIN A FILE OF INFORMATION DISCLOSED BY TRUSTEES, OFFICER AND KEY EMPLOYEES. SUCH FILE OF INFORMATION SHALL BE AMENDED ANNUALLY ON SUCH DATE AS THE BOARD OF TRUSTEES SHALL DETERMINE.
COMPENSATION POLICY
PART VI, SECTION B, LINE 15
THE CHAIR OF THE BOARD OF TRUSTEES MEETS ANNUALLY WITH SELECTED BOARD MEMBERS TO REVIEW THE COMPENSATION OF THE COLLEGE'S PRESIDENT. AFTER EVALUATING THE PRESIDENT'S PERFORMANCE AND REVIEWING DATA FROM OTHER COMPARABLE INSTITUTIONS, THE COMMITTEE DETERMINES COMPENSATION FOR THE SUBSEQUENT FISCAL YEAR. THE CHAIR OF THE BOARD THEN INFORMS THE COLLEGE'S CFO IN WRITING OF THE BOARD'S DETERMINATION.
DISCLOSURE OF DOCUMENTS & POLICIES
PART VI, SECTION C, LINE 19
THE ORGANIZATION DOES NOT MAKE ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC DURING THE TAX YEAR.
PART XI, LINE 5 OTHER CHANGES IN NET ASSETS
NET UNREALIZED GAINS ON INVESTMENTS $(581,203) UNREALIZED NET GAIN ON CHANGES IN FAIR VALUE OF INTEREST RATE SWAP $(2,898,294) UNREALIZED NET GAIN ON CHANGES IN FAIR VALUE OF SPLIT-INTEREST AGREEMENTS $ (337,584) UNREALIZED NET LOSS ON CHANGES IN FAIR VALUE OF BENEFICIAL INTEREST $(111,178) ----------- TOTAL $(3,928,259) ===========
SCHEDULE K, PART I, LINE 3, COLUMN (F)
CONSTRUCTION OF FACILITY AND REFUND PRIOR ISSUE (10/21/1999).
SCHEDULE K, PART II, LINE 3
THE TOTAL PROCEEDS DO NOT AGREE TO THE ISSUE PRICE IN PART I, COLUMN (E) DUE TO INVESTMENT EARNINGS.
SCHEDULE K, PART V
WE ARE IN THE PROCESS OF ADOPTING VCAP PROCEDURES.
For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.