Attach to Form 990 or 990-EZ.
Go to www.irs.gov/Form990 for the latest information.
| Return Reference | Explanation |
|---|---|
| Officer directors etc family relationship Part VI line 2 | Kentucky Higher Education Student Loan Corporation/Kentucky Higher Education Assistance Authority purchased rehabilitated student loans from Vermont Student Assistance Corporation. |
| Member election for additional members Part VI line 7a | Directors are elected by the voting members by ballot annually with each voting member entitled to cast one vote for each individual it supports for the board up to the number of positions available. In the event of a vacancy on the board occurring because of a directors death, incapacity, resignation or removal, the board may appoint any qualified individual to serve for the remainder of the term of the vacant position. |
| Governing body decisions Part VI line 7b | The following actions may be taken by an affirmative vote by the majority of voting members: voting member dues structure; amendments to the bylaws; amendments to the certificate of incorporation; and dissolution of the association. The following actions may be taken by affirmative vote of two-thirds (2/3) of all voting members: revoking membership of any member and removal of a director. |
| Form 990 governing body review Part VI line 11 | EFC management performs a preliminary review of the Form 990 and if necessary sends the contracted accountant corrections and/or updates. The subsequent draft of the Form 990 is submitted to the Audit & Finance Committee for additional review. Once the Audit & Finance Committee completes its review, the final draft is submitted to the full Board of Directors for review and approval. Upon approval by the Board of Directors, the Form 990 is submitted to the Internal Revenue Service. |
| Conflict of interest policy compliance Part VI line 12c | EFC maintains a Conflict of Interest Policy that covers the Board of Directors and all EFC employees. In general, a conflict of interest is a circumstance in which a reasonable person would perceive a Board or a staff members judgement to be compromised. A conflict of interest may also include situations in which a Board or staff member has a private or personal interest sufficient to appear to influence the objective exercise of his or her official duties. If personal pursuits create obligations or interests that are not compatible with EFC objectives or responsibilities, a conflict of interest arises. The policy covers a broad spectrum of areas where potential conflicts could occur, including but not limited to: outside financial interest, outside employment, relations with members and suppliers; relations with government officials and holding public office; corporate gifts; and procurement. When a conflict of interest, or a reasonable appearance of one, cannot be avoided, depending upon who has the potential conflict - board, staff or president - the policy addresses the appropriate channels and procedures for reporting a potential confilct, who will be involved in the discussion of the issue and the potential conflict, and who will decide how to deal with the reported conflict. |
| CEO executive director top management comp Part VI line 15a | In determining the presidents salary and compensation package, the EFC board of directors periodically examines comparative data on organizations in the greater Washington, DC area that are similarly structured, sized, and purposed. The board also annually reviews the presidents performance based on established criteria of success, and provides an annual review of, and adjustment of, the presidents base salary as well as any potential performance-based bonus awards. In 2018, EFC retained the services of a compensation consultant to perform a comparative analysis of the presidents salary and provide recommendations to the board of directors. |
| Other officer or key employee compensation Part VI line 15b | The president determines employee compensation based on performance reviews and comparative data. The board reviews and approves the compensation and benefits package through the budgeting process. In 2018, EFC retained the services of a compensation consultant to perform a comparative analysis of employee salaries and provide the president and the board of directors with recommendations. In addition, on March 12, 2019, the EFC Board of Directors approved a revised Annual Employee Bonus Plan (Plan), that is designed to provide an effective means to motivate and compensate eligible employees, on an annual basis, through cash award bonuses based on the achievement of business performance objectives within the fiscal year. The compensation contemplated under this Plan is considered payment for success in that any payout under the Plan is subject to the achievement of specific performance goals by EFC staff. The Plan is intended to be EFCs primary vehicle for the granting of bonuses. However, EFCs Board of Directors (Board) may, in certain limited circumstances, grant bonuses outside of this program, at its sole discretion. |
| Governing documents etc available to public Part VI line 19 | EFC has a Corporate Governance Manual that contains all of the organizations policies and procedures including those covering conflicts of interest. This manual as well as the Form 990, the EFC Annual Financial Review, and the in-house quarterly financial statements are available on the EFC website for voting members, directors, and staff to access and review. The EFC corporate Governance Manual and the EFC financials are available upon request to affiliate members but are not available to the public. The Form 990 is available to the public upon request. |
| List of other fees for services expenses Part IX line 11g | Government Relations Firm - $120,000Other Consultant/Contractor- $5,400401(k) Processing Fees - $2,762 |
| General explanation attachment | Mission Statement: The mission of EFC is to support its state-based and nonprofit members capacity to expand access to post secondary education, facilitate student success, assist students and families in identifying their best sources of education funding, assist individuals with connecting post secondary education and career outcomes, encourage smart borrowing, and advocate for and with borrowers in support of successful management of their education loan debt. |
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