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 | A draft of the Form 990 filing is reviewed by the Executive Director, General Counsel and Senior Director of Finance. The Fund's Trustees are provided a final version of the Form 990 before it is filed with the IRS. |
| Form 990, Part VI, Section B, Line 12c | The organization (the "Fund") is subject to a Consent Decree entered by the United States District Court for the Northern District of Illinois Eastern Division. This Consent Decree requires the Fund's trustees and employees to comply with ERISA, including the avoidance of conflicts constituting a breach of fiduciary duty or prohibited transaction under that statute. The Trustees and employees are provided a copy of the Consent Decree. Furthermore, pursuant to the Consent Decree, the Court has appointed an Independent Special Counsel who reports to the Court and to the U.S. Department of Labor and who monitors the Fund with respect to compliance with the Consent Decree. The Fund also provides all employees with a written policy concerning the avoidance of conflicts of interest; this policy specifically provides that any violation of the policy can be grounds for termination. The Fund's management and Internal Audit Department monitor compliance with this conflicts policy. Management is assisted in this process through periodic meetings with the Fund's auditors specifically focused on methods to prevent and detect fraud or conflicts. |
| Form 990, Part VI, Section B, Line 15 | The compensation of the organization's (the "Fund's") Executive Director/General Counsel was determined by the Fund's Board of Trustees, based upon a review of comparability data, including published compensation surveys, Form 990 data from other funds and the existence of an employment opportunity with another entity competing for the Executive Director/General Counsel's services. The Board of Trustees' compensation determination with respect to the Executive Director/General Counsel was documented in a contract of employment. As with all contracts with service providers entered by the Fund, the Fund's Consent Decree (see Form 990, Part VI, Section B, Line 12c) and ERISA require that the Executive Director/General Counsel's compensation be fixed at a reasonable level. As noted, under the Consent Decree, an Independent Special Counsel has been appointed by the Court to monitor the Fund's compliance with the Consent Decree. The compensation of officers and key employees of the Fund was determined by the Executive Director/General Counsel, in consultation with the Board of Trustees, based on comparability data, including published salary surveys and Form 990 data from other funds. The compensation determination with respect to officers and key employees was documented in forms executed by the Executive Director/General Counsel. |
| Form 990, Part VI, Section C, Line 19 | The organization's (the "Fund's") Plan Document and Trust Agreement, as well as reports of the Fund's Independent Special Counsel (see Form 990, Part VI, Section B, Line 12c) are available on the Fund's website. The Fund's publicly filed annual report (Form 5500) is available to participants of the Fund upon request. The Fund's conflict of interest policy, to the extent it is imbedded in the Consent Decree governing the Fund (see Form 990, Part VI, Section B, Line 12c), is also available to participants upon request. |
| Software ID: | 18007995 |
| Software Version: | v1.00 |