Attach to Form 990 or 990-EZ.
Go to www.irs.gov/Form990 for the latest information.
| Return Reference | Explanation |
|---|---|
| FORM 990, PART VI, SECTION B, LINE 11B | THE ORGANIZATION ENGAGES AN OUTSIDE ACCOUNTING FIRM TO PREPARE THE FORM 990. ONCE PREPARED, A DRAFT OF THE RETURN IS SENT TO TRUSTEES AND EMPLOYER ADVOCATES TO REVIEW BEFORE BEING FILED. |
| FORM 990, PART VI, SECTION B, LINE 12C | THE CONFLICT OF INTEREST POLICY REQUIRES (A) EACH TRUSTEE TO ANNUALLY SIGN A STATEMENT ACKNOWLEDGING THE CONFLICT OF INTEREST POLICY, STATING THEY UNDERSTAND AND WILL COMPLY WITH THE POLICY, AND THEY UNDERSTAND THE PLAN/TRUST ARE FOR THE EXCLUSIVE BENEFIT OF PARTICIPANTS AND BENEFICIARIES; AND (B) PERIODIC REVIEWS TO DETERMINE COMPENSATION ARRANGEMENTS WITH SERVICE PROVIDERS, IF ANY, ARE REASONABLE AND ARM LENGTH. IF COMPENSATION ARRANGEMENTS AND/OR CONTRACTS EXIST, THE TRUSTEES WILL ANALYZE AND DOCUMENT THAT THEY COMPLY WITH THE CONFLICT OF INTEREST POLICY, E.G., COMPENSATION IS REASONABLE, ARRANGEMENTS DO NOT CONSTITUTE PROHIBITED TRANSACTIONS, AND ARRANGEMENTS ARE FOR THE EXCLUSIVE BENEFIT OF PARTICIPANTS. THE TRUSTEES WILL REVIEW AND DOCUMENT THIS IN THE TRUSTEE MINUTES ANNUALLY. AFTER DISCLOSURE OF THE FINANCIAL INTEREST AND ALL MATERIAL FACTS, AND AFTER ANY DISCUSSION WITH THE INTERESTED PERSON, HE/SHE SHALL LEAVE THE TRUSTEE MEETING WHILE THE DETERMINATION OF A CONFLICT OF INTEREST IS DISCUSSED AND VOTED UPON. THE REMAINING TRUSTEES SHALL DECIDE IF A CONFLICT OF INTEREST EXISTS. IF A CONFLICT OF INTEREST EXISTS, IT WILL BE ADDRESSED AT THE TRUSTEE MEETING. AN INTERESTED PERSON MAY MAKE A PRESENTATION AT THE MEETING AND LEAVE DURING THE DISCUSSION OF, AND THE VOTE ON, THE TRANSACTION OR ARRANGEMENT INVOLVING THE CONFLICT OF INTEREST. IF THE TRUSTEES HAVE REASONABLE CAUSE TO BELIEVE A MEMBER HAS FAILED TO DISCLOSE ACTUAL OR POSSIBLE CONFLICTS OF INTEREST, THE INTERESTED PARTY WILL HAVE AN OPPORTUNITY TO EXPLAIN THE ALLEGED FAILURE TO DISCLOSE. THE TRUSTEES SHALL DETERMINE WHETHER THE MEMBER HAS FAILED TO DISCLOSE A CONFLICT OF INTEREST, APPROPRIATE DISCIPLINARY OR CORRECTIVE ACTION WILL BE TAKEN. |
| FORM 990, PART VI, SECTION C, LINE 19 | ANY DOCUMENTS SUBJECT TO OPEN RECORD REQUIREMENTS ARE MADE AVAILABLE UPON REQUEST. |
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