Attach to Form 990 or 990-EZ.
Information about Schedule O (Form 990 or 990-EZ) and its instructions is at| Return Reference | Explanation |
|---|---|
| FORM 990, PART VI, SECTION A, LINE 6 | THERE ARE FIVE CLASSES OF MEMBERS: MORTGAGE SERVICER MEMBERS, GOVERNMENT/INVESTOR MEMBERS, AFFILIATED ATTORNEY-TRUSTEE MEMBERS AND NON-AFFILIATED ATTORNEY-TRUSTEE MEMBERS. ONLY AFFILIATED ATTORNEY-TRUSTEE MEMBERS AND NON-AFFILIATED ATTORNEY-TRUSTEE MEMBERS HAVE VOTING RIGHTS. |
| FORM 990, PART VI, SECTION A, LINE 7A | AFFILIATED ATTORNEY-TRUSTEE CLASS MEMBERS VOTE TO ELECT ONE DIRECTOR AND NON-AFFILIATED ATTORNEY-TRUSTEE MEMBERS VOTE TO ELECT THREE DIRECTORS. |
| FORM 990, PART VI, SECTION A, LINE 7B | AN AFFILIATED ATTORNEY-TRUSTEE CLASS DIRECTOR MAY BE REMOVED BY A MAJORITY OF THE NON-AFFILIATED ATTORNEY-TRUSTEE CLASS MEMBERS AND THE AFFILIATED ATTORNEY-TRUSTEE MEMBERS ATTENDING A MEETING OF SUCH MEMBERS. |
| FORM 990, PART VI, SECTION B, LINE 11 | THE ORGANIZATION'S OUTSIDE CPA FIRM PREPARES A DRAFT FORM 990 THAT IS PRESENTED TO THE ORGANIZATION'S OFFICERS AND LEGAL COUNSEL FOR REVIEW AND APPROVAL. AFTER APPROVAL, THE FINAL FORM 990 IS SUBMITTED TO THE BOARD OF DIRECTORS FOR REVIEW AND COMMENT PRIOR TO FILING THE RETURN WITH THE IRS. |
| FORM 990, PART VI, SECTION B, LINE 12C | THE MODEL EXECUTIVE TEAM AND BOARD OF DIRECTORS' CODE OF ETHICS FOR THE ORGANIZATION REQUIRED EXECUTIVES AND BOARD MEMBERS TO IDENTIFY POTENTIAL CONFLICTS OF INTEREST AND DISCLOSE SUCH CONFLICT AND TO BE REMOVED FROM ALL DISCUSSION AND VOTING ON SUCH MATTERS. EXECUTIVES AND BOARD MEMBERS ARE ALSO REQUIRED TO AVOID THE APPEARANCE OF PLACING THEIR OWN SELF-INTERESTS OR ANY THIRD-PARTY INTEREST ABOVE THAT OF THE ORGANIZATION. THE ORGANIZATION'S BOARD POLICY MANUAL ALSO REQUIRED THE BOARD MEMBERS TO AVOID CONFLICT OF INTERESTS WITH RESPECT TO THEIR FIDUCIARY RESPONSIBILITIES. SELF-DEALING AND BUSINESS BY A BOARD MEMBER WITH THE ORGANIZATION MUST BE ANNUALLY DISCLOSED INCLUDING INVOLVEMENT WITH ANY OTHER ORGANIZATION THAT MAY BE REASONABLY SEEN AS BEING IN CONFLICT. IF THERE IS AN UNAVOIDABLE CONFLICT OF INTEREST TRANSACTION SUCH AS A BOARD MEMBER'S WITHDRAWAL WITHOUT COMMENT FROM ANY VOTE OR DELIBERATION ON THE MATTER. THE ORGANIZATION'S BY-LAWS FURTHER PROVIDE THAT A CONFLICT OF INTEREST TRANSACTION IS NOT VOIDABLE IF THE DIRECTOR'S INTEREST WAS DISCLOSED AND KNOWN TO THE MEMBERS OR THE BOARD OF DIRECTORS. THE TRANSACTION IS NOT VOIDABLE IF THE DIRECTOR'S WAS DISCLOSED AND KNOWN TO THE MEMBERS OR THE BOARD OF DIRECTORS WHEN THE TRANSACTION WAS APPROVED, AUTHORIZED OR RATIFIED BY THE MEMBERS OR BOARD OF DIRECTORS, AS APPROPRIATE. PRIOR TO ALL BOARD MEETINGS THERE IS AN OPPORTUNITY FOR BOARD MEMBERS TO VOICE CONFLICTS OF INTEREST AND OUR ANTITRUST AVOIDANCE STATEMENT IS REITERATED BEFORE THE MEETING STARTS. THE ORGANIZATION ALSO ADOPTED A STAND-ALONE CONFLICT OF INTEREST POLICY EFFECTIVE AS OF SEPTEMBER 15, 2009. |
| FORM 990, PART VI, SECTION B, LINE 15 | THE ORGANIZATION'S BOARD POLICY MANUAL REQUIRES THE CEO TO NOT RETALIATE AGAINST ANY STAFF MEMBER FOR NON-DISRUPTIVE EXPRESSION OF DISSENT AND THE MODEL EXECUTIVE TEAM AND BOARD OF DIRECTOR CODE OF ETHICS PROVIDES THAT EACH MEMBER OF THE EXECUTIVE TEAM AND BOARD OF DIRECTORS WILL DISCLOSE (FULLY, FRANKLY AND TIMELY) ALL INFORMATION THAT THEY LEARN OF THAT THEY BELIEVE MAY ADVERSELY IMPACT OR OTHERWISE HARM THE ORGANIZATION OR ITS MEMBERS. THE CEO AND BOARD OF DIRECTORS CONDUCTED A COMPENSATION REVIEW FOR ALL EMPLOYEES. THE PROCEDURE INVOLVES A REVIEW OF THE EMPLOYEE'S ANNUAL INTERVIEW AND EVALUATION AND AN EXAMINATION OF THE COMPENSATION PAID TO SIMILARLY POSITIONED EMPLOYEES IN SIMILARLY SITUATED ORGANIZATIONS. FORM 990'S ARE REVIEWED OF OTHER SIMILAR ASSOCIATIONS, AND AS WELL AS A REVIEW OF ASSOCIATION COMPENSATION SURVEYS AND DATA PROVIDED BY ASAE. CEO RECOMMENDED COMPENSATION FOR ALL STAFF THAT THE BOARD THEN REVIEWED AND APPROVED. CEO COMPENSATION WAS REVIEWED AND APPROVED BY THE BOARD AFTER AN ANNUAL PERFORMANCE INTERVIEW, REVIEW OF OTHER FORM 990'S OF SIMILAR ORGANIZATIONS, REVIEWING ASSOCIATION COMPENSATION DATA FROM ASAE AND IN ACCORDANCE WITH AN EMPLOYMENT CONTRACT. |
| FORM 990, PART VI, SECTION C, LINE 18 | THE FORM 990 IS AVAILABLE FOR MEMBERS ON THE ORGANIZATION'S WEBSITE AND IS AVAILABLE UPON REQUEST FOR A PERIOD OF THREE YEARS FROM THE DUE DATE OF THIS RETURN FOR OTHER PERSONS. THE ANNUAL BOARD APPROVED OPERATING BUDGET AS WELL AS THE PREVIOUS YEAR'S BALANCE SHEET IS ALSO POSTED TO THE MEMBER ONLY PORTION OF THE ALFN WEBSITE FOR VIEWING BY ITS MEMBERS. |
| FORM 990, PART VI, SECTION C, LINE 19 | COPIES OF ALL OF THE ORGANIZATION'S GOVERNANCE DOCUMENTS PREVIOUSLY MADE PUBLIC ARE AVAILABLE TO THE PUBLIC UPON REQUEST. |
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