| Return Reference | Explanation |
|---|---|
| Members or stockholder classes and rights Part VI line 6 | Voting Membership shall be open to organizations that are not-for-profit entities, which include private and public non-profit organizations and state agencies, a primary purpose of which is the purchase, servicing, origination, or financing/funding for postsecondary education loans, or to improve citizens access to and success in postsecondary education or training, or to provide funding/financing for education or training that enhances the education to workforce pipeline. EFCs primary membership is comprised of its Voting Members, who form the governing structure of EFC and drive the agenda of the association. EFC Affiliate Membership is open to any organization or individual interested in the availability, administration or financing/funding of education loans, or to improve citizens access to and success in postsecondary education or training, or to provide financing/funding for education or training that enhances the education to workforce pipeline. Affiliate Members may not vote on matters coming before the membership. |
| 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, or the Board may choose to leave the seat vacant until the next Board of Directors election. |
| Governing body decisions Part VI line 7b | The following actions may be taken by an affirmative vote by the majority of Voting Members: change to Voting member dues structure, amendments to the Bylaws, and amendments to the Certificate of Incorporation. The following actions may be taken by affirmative vote of two-thirds (2/3) of all Voting members: revoking membership of a member, removal of a director, and dissolution of the association. |
| 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 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 judgment 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; 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 conflict, 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 of 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 2023, 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 2023, 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, in September 2022, 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 may, in certain limited circumstances, grant bonuses outside of this program, at is 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 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: $153,996Research: $5,500Other Consultants: $8,822 |
| General explanation attachment | Mission Statement: Education Finance Council advocates on behalf of and offers a variety of membership services to its state-based and nonprofit members. EFC works with its members to advocate for and support their missions to help students and families succeed in postsecondary education or training by providing funding/financing options, improving the education to workforce pipeline, supporting excellence in loan servicing, encouraging robust financial literacy, information, and counseling programs, and providing a variety of other comprehensive products and services. |
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