2023-08-16T15:14:44-05:00 2022-12-31 111986323 MARCUM LLP 1899 L STREET NW 850 WASHINGTON DC 20036 990 2022-01-01 530132493 NATIONAL FOUNDATION FOR CREDIT COUNSELING INC NATI 2026774314 2033 K STREET NW 425 WASHINGTON DC 20006 MICHAEL CROXSON CEO 2026774314 2023-08-15 1 MICHAEL CROXSON 999009999 0 AARON MFOX P01365820 2028225000 2023-08-15 0 AAL1 IAL1 2022 2023-04-26 12:10:37Z MICHAEL CROXSON 2033 K STREET NW 425 WASHINGTON DC 20006 9648541 0 X WWW.NFCC.ORG X 1970 DC THE NFCC AND ITS MEMBERS OFFER PEOPLE SOLUTIONS AND SUPPORT TO ADDRESS FINANCIAL CHALLENGES AND TAKE CHARGE OF THEIR OWN FINANCIAL FUTURES. 13 13 22 19 0 0 5275437 6069586 3481351 3578094 698 861 2618 0 8760104 9648541 2764073 2850782 0 0 3171413 3434424 0 0 204173 3434126 3699199 9369612 9984405 -609508 -335864 8192491 9402187 2516283 4061843 5676208 5340344 X TO LEAD A NATIONAL MOVEMENT THAT BETTER EQUIPS AMERICANS TO MANAGE THEIR FINANCIAL FUTURES AND, IN TURN, ADVANCES THE ECONOMY AND OUR NATION AS A WHOLE. FOUNDED IN 1951, THE NATIONAL FOUNDATION FOR CREDIT COUNSELING (NFCC) IS THE OLDEST NONPROFIT DEDICATED TO IMPROVING PEOPLE'S FINANCIAL WELL-BEING. WITH 50 MEMBER AGENCIES AND OVER 1,200 NFCC CERTIFIED CREDIT COUNSELORS SERVING 50 STATES AND ALL U.S. TERRITORIES, OUR NFCC CERTIFIED CREDIT COUNSELORS ARE FINANCIAL ADVOCATES, EMPOWERING MILLIONS OF CONSUMERS TO TAKE CHARGE OF THEIR FINANCES THROUGH ONE-ON ONE FINANCIAL REVIEWS THAT ADDRESS CREDIT CARD DEBT, STUDENT LOANS, HOUSING DECISIONS, AND OVERALL MONEY MANAGEMENT. 0 0 3568276 2495262 3578094 HOUSING COUNSELING: DEVELOP AND MAINTAIN PARTNERSHIPS WITH THE UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (HUD) AND INDUSTRY LEADERS, INCLUDING MORTGAGE LENDERS AND SERVICERS, TO HELP MEMBERS ASSIST CONSUMERS WITH PRE-HOME OWNERSHIP (PRE-PURCHASE) COUNSELING, POST-PURCHASE COUSENLING TO HELP ENSURE THAT NEW OWNERS CAN REMAIN IN THEIR HOMES, EVICTION PREVENTION (FOR RENTERS) AND FORECLOSURE PREVENTION (FOR HOME OWNERS). 3153001 MEMBERSHIP SUPPORT: FOSTER MEMBER COMMUNICATIONS; MEMBER MEETINGS AND ANNUAL CONFERENCE; COUNSELOR CERTIFICATION; PROVIDE A PATH TO ASSISTANCE FOR CONSUMERS VIA THE CONSUMER'S PREFERRED METHOD (CURRENTLY PHONE AND ONLINE FORM, WHILE BUILDING-OUT VIDEO AND DIGITAL ENTRY OPTIONS). MAINTAIN RELATIONSHIPS WITH CREDIT-GRANTING ORGANIZATIONS TO SUPPORT CLIENTS AND MEMBER ORGANIZATIONS, BUILD AWARENESS FOR MISSION THROUGH MEDIA OUTREACH. 592478 306895 GENERAL FINANCIAL EDUCATION: DEVELOP AND MAKE AVAILABLE EDUCATIONAL MATERIALS TO MEMBER AGENCIES AND CONSUMERS ON THE RESPONSIBLE USE OF CREDIT; DEVELOP PARTNERSHIPS WITH OTHER ORGANIZATIONS TO ADDRESS THE NEED FOR PERSONAL FINANCIAL LITERACY. NFCC MEMBER AGENCIES HAVE HELPED ALMOST 30 MILLION PEOPLE SINCE 2006. 198992 48625 VETERAN FINANCIAL EDUCATION: PARTNER WITH THE ASSOCIATION OF MILITARY BANKS OF AMERICA (AMBA) TO PROVIDE ACCESS TO CREDIT COUNSELING FOR VETERANS, THROUGH THEIR VETERANS BENEFITS BANKING PROGRAM, TARGETED AT PROVIDIING VETERANS ACCESS TO DIRECT DEPOSIT AND OTHER FINANCIAL SERVICES.SMALL BUSINESS COUNSELING: THE NFCC BEGAN DEVELOPMENT OF A NATIONAL SMALL BUSINESS COUSNELING PROGRAM WHICH WAS INITIALLY INTERGRATED INTO THE SHARPEN YOUR FINANCIAL FOCUS INITIATIVE. MEMBER AGENCIES SUPPORT ENTREPRENEURS' PERSONAL FINANCIAL MATTERS AS THEY LAUNCH AND MANAGE THEIR BUSINESS.STUDENT LOAN COUNSELING: PROVIDE A NATIONAL STUDENT LOAN PROGRAM TO TRAIN AND SUPPORT MEMBER AGENCIES IN COUNSELING CLIENTS WITH STUDENT LOAN DEBT TO REDUCE AND MANAGE THEIR FINANCIAL BURDEN AND HELP THEM ON A PARTH OF FINANCIAL SECURITY 198992 48625 7512747 1 1 0 1 0 0 0 0 0 0 1 0 0 1 1 0 1 0 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 1 29 0 1 22 1 0 0 0 0 0 0 0 0 0 0 0 0 X 13 13 0 0 0 0 1 1 1 1 1 0 0 1 1 1 1 1 1 1 1 0 NY X MATT RIBE 2026774314 2033 K STREET NW SUITE 425 WASHINGTON DC 20006 DEBBIE BIANUCCI CHAIR 1.00 X X 0 0 0 JAY DESMARTEAU TREASURER 1.00 X X 0 0 0 GLORIA BANKS TRUSTEE 1.00 X 0 0 0 GENGER CHARLES TRUSTEE 1.00 X 0 0 0 DUANE ELMER TRUSTEE 1.00 X 0 0 0 JILL FELDMAN TRUSTEE 1.00 X X 0 0 0 SARAH GOLDFRANK TRUSTEE 1.00 X 0 0 0 ELEANOR HOHMAN TRUSTEE 1.00 X 0 0 0 SCOTT LAUGHLIN TRUSTEE 1.00 X 0 0 0 JIM TRIGGS TRUSTEE 1.00 X 0 0 0 FAISAL UDDIN TRUSTEE 1.00 X 0 0 0 CHRISTOPHER VIALE TRUSTEE 1.00 X 0 0 0 GARY VOLLMER TRUSTEE 1.00 X 0 0 0 REBECCA STEELE CEO - UNTIL 02/2022 50.00 X 447908 0 7567 JEFFREY FAULKNER CFO, HEAD OF FUNDRAISING & RESEARCH 50.00 X 478031 0 36200 JENNIFER LANDIS PIZI COO 50.00 X 381818 0 25558 MICHAEL CROXSON CEO - AS OF 09/2022 50.00 X 100852 0 12505 MATT RIBE GENERAL COUNSEL 50.00 X 194837 0 42767 ELLEN GOURY VP, FINANCE 50.00 X 174655 0 34005 HERMOND PALMER VP, HOUSING 50.00 X 158183 0 10065 BRUCE MCCLARY SVP, MEMBERSHIP & COMMUNICATIONS 50.00 X 141500 0 16025 TIMOTHY MADIGAN DIRECTOR, ACCOUNTING & FEDERAL GRANTS 50.00 X 126984 0 15582 2204768 0 200274 10 0 1 0 GOOGLE LLC PO BOX 39000 SAN FRANCISCO CA 94139 MARKETING ADVERTISING 732282 FINREGLAB INC 900 19TH STREET WASHINGTON DC 20006 INDUSTRY STUDIES 484803 FRONTLINE MANAGED SERVICES 1990 K ST NW SUITE 600 WASHINGTON DC 20006 INFORMATION TECHNOLOGY 337748 CREDITLY CORP 625 WEST RIDGE PIKE CONSHOHOCKEN PA 19428 INFORMATION TECHNOLOGY 222286 HARRIS INSIGHTS & ANALYTICS 300 N LASALLE STREET CHICAGO IL 60654 SURVEYS 142740 9 2661255 3408331 6069586 NATIONAL LOCATOR LINE 900099 2070161 2070161 MEMBERSHIP DUES 900099 1114589 1114589 CERTIFICATION FEES 900099 223780 223780 STUDENT LOAN PORTAL 900099 140000 140000 OTHER PROGRAM SERVICES 900099 28544 28544 1020 1020 3578094 861 861 9648541 3578094 0 861 2850782 2850782 1490439 568992 921447 1488405 856963 575229 56213 94795 55623 32806 6366 175785 97145 68972 9668 185000 97623 78960 8417 70000 41653 28347 48563 28897 19666 448168 271630 66089 110449 1561351 1561351 138308 91259 46202 847 875404 708745 166604 55 188221 91870 91930 4421 61675 41782 19483 410 69680 44626 22242 2812 142049 69334 69379 3336 39898 14294 25102 502 DUES & SUBSCRIPTION 43113 15446 27125 542 BAD DEBTS 10843 3885 6823 135 TRAINING 1689 706 983 TAXES 237 141 96 9984405 7512747 2267485 204173 6572266 5104850 465979 1749298 244993 219539 7039 114285 56154 910476 451656 593319 458820 194610 1813526 8192491 9402187 407663 596180 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HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CAMBRIDGE CREDIT COUNSELING CORP 67 HUNT ST AGAWAM MA 01001 043337726 501(C)(3) 261287 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING MONEY MANAGEMENT INTERNATIONAL 12603 SOUTHWEST FREEWAY STAFFORD TX 77477 541837741 501(C)(3) 260969 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CREDIT ADVISORS FOUNDATION 1818 S 72ND ST OMAHA NE 68124 470751100 501(C)(3) 210081 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER EDUCATION SERVICES INC 3700 BARRETT DR RALEIGH NC 27609 562106758 501(C)(3) 205389 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING GARDEN STATE CONSUMER CREDIT COUNSELING INC 200 US HIGHWAY 9 MANALAPAN NJ 07726 223120920 501(C)(3) 170301 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING FAMILY SERVICE ASSOCIATION 1930 N 8TH ST SHEBOYGAN WI 53081 390808501 501(C)(3) 149867 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING SPRINGBOARD NONPROFIT CONSUMER CREDIT MANAGEMENT INC 1450 IOWA AVENUE SUITE 200 RIVERSIDE CA 92507 330656671 501(C)(3) 119688 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER CREDIT COUNSELING SERVICES OF CENTRAL OHIO 690 TAYLOR RD COLUMBUS OH 43213 310731111 501(C)(3) 100607 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER CREDIT COUNSELING SERVICES OF DELAWARE VALLEY 1635 MARKET STREET PHILADELPHIA PA 19103 231671903 501(C)(3) 98450 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING TAKE CHARGE AMERICA 20430 N 19TH AVENUE SUITE 155 PHOENIX AZ 85027 860593598 501(C)(3) 77841 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER CREDIT COUNSELING SERVICES OF ROCHESTER 1050 UNIVERSITY AVE STE A ROCHESTER NY 14607 160972260 501(C)(3) 68161 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER DEBT COUNSELORS INC 831 W MORSE BLVD WINTER PARK FL 32789 593548266 501(C)(3) 63088 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER CREDIT COUNSELING OF SPRINGFIELD MISSOURI INC 151 S GLENSTONE SPRINGFIELD MO 65804 431483251 501(C)(3) 55088 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER CREDIT COUNSELING SERVICE OF THE SAVANNAH AREA INC 7505 WATERS AVE PARK S SAVANNAH GA 31406 580958705 501(C)(3) 51104 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING INCHARGE DEBT SOLUTION 5750 MAJOR BLVD ORLANDO FL 32819 330770440 501(C)(3) 49426 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING NORTH SEATTLE COMMUNITY COLLEGE FOUNDATION 600 UNIVERSITY ST SEATTLE WA 98101 911163554 501(C)(3) 45338 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING HOMEOWNERSHIP CENTER OF GREATER DAYTON 130 W SECOND STREET DAYTON OH 45402 364500925 501(C)(3) 44004 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING TENFOLD 308 E KING ST LANCASTER PA 17602 231731792 501(C)(3) 42793 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING JC VISION AND ASSOCIATES INC 135 E M L KING JR DR HINESVILLE GA 31313 582525433 501(C)(3) 42419 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER CREDIT COUNSELING SERVICE OF NORTHERN ILLINOIS INC 13707 W JACKSON STREET WOODSTOCK IL 60098 363185383 501(C)(3) 42221 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING PARACHUTE CREDIT COUNSELING INC 40 GARDENVILLE PKWY WEST SENECA NY 14224 160909583 501(C)(3) 39680 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING FAMILY COUNSELING CENTER OF MOBILE 705 OAK CIR DR EAST MOBILE AL 36609 630388685 501(C)(3) 39030 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING HOUSING AND CREDIT COUNSELING INC 1195 S W BUCHANAN TOPEKA KS 66604 480822466 501(C)(3) 35002 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING AMERICAN CONSUMER CREDIT COUNSELING 130 RUMFORD AVE AUBURNDALE MA 02466 043166982 501(C)(3) 34942 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER CREDIT COUNSELING SERVICES OF PUERTO RICO 1607 PONCE DELEON SAN JUAN PR 00909 660471799 501(C)(3) 31326 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER CREDIT COUNSELING SERVICES OF MID-OHIO VALLEY 2715 MURDOCH AVE PARKERSBURG WV 26102 237124716 501(C)(3) 27943 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING LUTHERAN SOCIAL SERVICE OF MINNESOTA 424 W SUPERIOR ST DULUTH MN 55808 410872993 501(C)(3) 23246 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING FINANCIAL PATHWAYS OF THE PIEDMONT 7820 N POINT BLVD WINSTONSALEM NC 27106 561015074 501(C)(3) 20967 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER CREDIT COUNSELING SERVICE OF SOUTHERN OREGON INC 820 CRATER LAKE AVE MEDFORD OR 97504 930585893 501(C)(3) 20244 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING ADVANTAGE CREDIT COUNSELING SERVICE INC 2403 SIDNEY ST STE 225 PITTSBURGH PA 15203 251201741 501(C)(3) 15703 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER CREDIT COUNSELING SERVICE OF MARYLAND AND DELAWARE 6315 HILLSIDE COURT SUITE B COLUMBIA MD 21046 520846275 501(C)(3) 15279 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CREDIT COUNSELING OF ARKANSAS 1111 ZION RD FAYETTEVILLE AR 72703 710772094 501(C)(3) 12745 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CONSUMER CREDIT COUNSELING SERVICE OF WESTERN NORTH CAROLINA INC 50 S FRENCH BROAD AVE ASHEVILLE NC 28801 561056077 501(C)(3) 12562 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING GOODWILL INDUSTRIES OF NORTH CENTRAL WISCONSIN 1800 APPLETON ROAD MENASHA WI 54952 391144913 501(C)(3) 12339 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING FAMILYMEANS 1875 NORTHWESTERN AVE S STILLWATER MN 55082 416045574 501(C)(3) 7295 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING CHRISTIAN CREDIT COUNSELORS INC 5838 EDISON PLACE CARLSBAD CA 92008 382956171 501(C)(3) 7250 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING LUTHERAN SOCIAL SERVICES OF SOUTH DAKOTA INC 705 EAST 41ST STREET SIOUX FALLS SD 57105 460224731 501(C)(3) 5575 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING FAMILY FOUNDATIONS OF NORTHEAST FLORIDA INC 40 E ADAMS ST JACKSONVILLE FL 32202 590768265 501(C)(3) 5367 0 SUPPORT FOR HOUSING, CREDIT AND OTHER FINANCIAL COUNSELING 39 PART I, LINE 2: THE NFCC PERFORMS PERIODIC COMPLIANCE REVIEWS OF THE SUPPORTING DOCUMENTATION FOR THE FUNDS USED AND TAKES APPROPRIATE CORRECTIVE ACTION IF USAGE DOES NOT COMPLY WITH THE GRANT REQUIREMENTS. X X X X X 1 0 0 0 0 0 0 0 0 JEFFREY FAULKNER CFO, HEAD OF FUNDRAISING & RESEARCH 303031 0 62500 0 112500 0 18182 0 18018 0 514231 0 0 0 REBECCA STEELE CEO - UNTIL 02/2022 87092 0 131316 0 229500 0 4590 0 2977 0 455475 0 0 0 JENNIFER LANDIS PIZI COO 271818 0 10000 0 100000 0 16309 0 9249 0 407376 0 0 0 MATT RIBE GENERAL COUNSEL 152337 0 32500 0 10000 0 9140 0 33627 0 237604 0 0 0 ELLEN GOURY VP, FINANCE 161813 0 12842 0 0 0 9709 0 24296 0 208660 0 0 0 HERMOND PALMER VP, HOUSING 155295 0 2888 0 0 0 9318 0 747 0 168248 0 0 0 BRUCE MCCLARY SVP, MEMBERSHIP & COMMUNICATIONS 126500 0 10000 0 5000 0 7590 0 8435 0 157525 0 0 0 PART I, LINE 4A REBECCA STEELE - CEO - $229,500 MEREDITH LANDIS SISTER OF JENN PIZI 20260 STAFF AUGMENTATION FOR EMPLOYEE ON MATERNITY LEAVE 0 FORM 990, PART VI, SECTION A, LINE 6 THE NFCC BYLAWS PROVIDE, IN RELEVANT PART, THE FOLLOWING: CLASSES: THE FOUNDATION SHALL HAVE ONE CLASS OF MEMBERS IN ORDER TO BE A MEMBER AN ORGANIZATION MUST: BE TAX EXEMPT UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE. BE DULY QUALIFIED AND EXISTING UNDER THE LAWS OF THE DISTRICT OF COLUMBIA,OR ANY STATES OR TERRITORY OF THE UNITED STATES OF AMERICA. PROVIDE FINANCIAL COUNSELING SERVICES AND ACT IN COMPLIANCE WITH ALL APPLICABLE FEDERAL AND STATE LAWS AND REGULATIONS. OBTAIN AND MAINTAIN THE FOUNDATION-APPROVED ACCREDITATION. COMPLY WITH THE NFCC'S MEMBER QUALITY STANDARDS. FORM 990, PART VI, SECTION A, LINE 7A THE NFCC MEMBERS ELECT MEMBER-REPRESENTATIVE TRUSTEES TO THE NFCC BOARD OF TRUSTEES AT THE ANNUAL MEETING OF THE MEMBERS. ADDITIONALLY, MEMBERS VOTE TO RATIFY AT-LARGE TRUSTEES ELECTED TO THE BOARD OF TRUSTEES BY THE BOARD OF TRUSTEES PRIOR TO THE ANNUAL MEETING. FORM 990, PART VI, SECTION A, LINE 7B SEE LINE 7A. FORM 990, PART VI, SECTION B, LINE 11B THE IRS FORM 990 IS INITIALLY PREPARED BY THE NFCC'S PUBLIC ACCOUNTING FIRM, WITH INPUT AND REVIEW BY COUNSEL. NFCC STAFF PREPARE A DRAFT FOR THE BOARD TO REVIEW, AND AFTER THE BOARD REVIEWS IT, THE 990 IS FINALIZED AND SUBMITTED TO THE IRS. FORM 990, PART VI, SECTION B, LINE 12C PLEASE NOTE THAT ALL TRUSTEES, OFFICERS AND COMMITTEE MEMBERS ("INTERESTED PERSONS") ARE SUBJECT TO THE CONFLICT OF INTEREST POLICY AND ARE REQUIRED TO ANNUALLY AFFIRM HAVING RECEIVED, READ AND UNDERSTOOD THE POLICY AND HAVE AGREED TO COMPLY WITH THE POLICY. THE POLICY, IN RELEVANT PART, REQUIRES: DISCLOSURE REQUIREMENT: IN CONNECTION WITH ANY ACTUAL OR POSSIBLE CONFLICT, AN INTERESTED PERSON MUST DISCLOSE THE EXISTENCE OF THE FINANCIAL INTEREST AND BE GIVEN THE OPPORTUNITY TO DISCLOSE ALL MATERIAL FACTS TO THE TRUSTEES AND/OR COMMITTEE MEMBERS CONSIDERING THE PROPOSED TRANSACTION OR ARRANGEMENT. CONFLICT DETERMINATION BY BOARD: FOLLOWING FULL DISCLOSURE OF AN ACTUAL OR POSSIBLE CONFLICT, AND AFTER ANY DISCUSSION WITH THE INTERESTED PERSON, HE/SHE SHALL LEAVE THE BOARD OR COMMITTEE MEETING, AS THE CASE MAY BE, WHILE THE DETERMINATION OF A CONFLICT IS DISCUSSED AND VOTED UPON. THE REMAINING BOARD OR COMMITTEE MEMBERS SHALL DECIDE IF A CONFLICT EXIST. THE POLICY FURTHER SPECIFIES THE PROCEDURE FOR ADDRESSING CONFLICTS THAT ARISE AND VIOLATIONS OF THE POLICY. PROCEDURES FOR ADDRESSING POSSIBLE CONFLICTS: (A) IF THE BOARD OR THE COMMITTEE, AS THE CASE MAY BE, HAS REASONABLE CAUSE TO BELIEVE A PERSON HAS FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT, IT WILL INFORM THE PERSON OF THE BASIS FOR THAT BELIEF AND AFFORD THE PERSON AN OPPORTUNITY TO EXPLAIN THE ALLEGED FAILURE TO DISCLOSE. (B) IF, AFTER HEARING THE PERSON'S RESPONSE AND MAKING FURTHER INVESTIGATION AS WARRANTED BY THE CIRCUMSTANCES, THE BOARD OR THE COMMITTEE, AS THE CASE MAY BE, DETERMINES THAT THE PERSON HAS FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT, IT WILL TAKE APPROPRIATE DISCIPLINARY AND CORRECTIVE ACTION. (C) AFTER EXERCISING DUE DILIGENCE, THE BOARD OR COMMITTEE,AS THE CASE MAY BE, WILL DETERMINE WHETHER THE NFCC CAN OBTAIN WITH REASONABLE EFFORTS A MORE ADVANTAGEOUS TRANSACTION OR ARRANGEMENT FROM A PERSON OR ENTITY THAT WOULD NOT GIVE RISE TO A CONFLICT. (D) IF A MORE ADVANTAGEOUS TRANSACTION OR ARRANGEMENT IS NOT REASONABLY POSSIBLE UNDER THE CIRCUMSTANCES WITHOUT PRODUCING A CONFLICT, THE BOARD OR THE COMMITTEE, AS THE CASE MAY BE, WILL DETERMINE, BY A MAJORITY VOTE OF THE DISINTERESTED MEMBERS, (I) WHETHER THE TRANSACTION OR ARRANGEMENT IS IN THE NFCC'S BEST INTEREST FOR ITS OWN BENEFIT, AND (II) WHETHER ITS TERMS AND CONDITIONS ARE FAIR AND REASONABLE. IN CONFORMITY WITH THE ABOVE DETERMINATIONS, THE BOARD OR THE COMMITTEE, AS THE CASE MAY BE, WILL MAKE ITS DECISION AS TO WHETHER TO AUTHORIZE THE NFCC TO ENTER INTO THE TRANSACTION OR ARRANGEMENT. VIOLATIONS OF THE CONFLICTS OF INTEREST POLICY: (A) IF THE BOARD OR THE COMMITTEE, AS THE CASE MAY BE, HAS REASONABLE CAUSE TO BELIEVE A PERSON HAS FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT, IT WILL INFORM THE PERSON OF THE BASIS FOR THAT BELIEF AND AFFORD THE PERSON AN OPPORTUNITY TO EXPLAIN THE ALLEGED FAILURE TO DISCLOSE. (B) IF, AFTER HEARING THE PERSON'S RESPONSE AND MAKING FURTHER INVESTIGATION AS WARRANTED BY THE CIRCUMSTANCES, THE BOARD OR THE COMMITTEE, AS THE CASE MAY BE, DETERMINES THAT THE PERSON HAS FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT, IT WILL TAKE APPROPRIATE DISCIPLINARY AND CORRECTIVE ACTION. FORM 990, PART VI, SECTION B, LINE 15 THE NATIONAL FOUNDATION FOR CREDIT COUNSELING'S BOARD OF TRUSTEES ENACTED THE FOLLOWING POLICY ON THE PROCESS OF DETERMINING COMPENSATION FOR THE NFCC'S CHIEF EXECUTIVE OFFICER; AND OTHER OFFICERS AND KEY EMPLOYEES OF THE NFCC WHOSE COMPENSATION IS REQUIRED TO BE DISCLOSED ON FORM 990. THE PROCESS INCLUDES ALL OF THE FOLLOWING ELEMENTS: 1. REVIEW AND APPROVAL: (A) COMPENSATION OF THE CHIEF EXECUTIVE OFFICER IS REVIEWED AND APPROVED BY THE NFCC'S EXECUTIVE COMMITTEE, PROVIDED THAT PERSONS WITH CONFLICTS OF INTEREST WITH RESPECT TO THE COMPENSATION ARRANGEMENT AT ISSUE ARE NOT INVOLVED IN THIS REVIEW AND APPROVAL. (B) COMPENSATION OF THE OTHER OFFICERS AND KEY EMPLOYEES IS APPROVED BY THE CHIEF EXECUTIVE OFFICER AND OVERALL STAFF COMPENSATION IS REVIEWED ON AN ANNUAL BASIS BY THE NFCC'S BOARD OF TRUSTEES OR THE EXECUTIVE COMMITTEE. 2. USE OF DATA AS TO COMPARABLE COMPENSATION: THE COMPENSATION OF THE PERSON IS REVIEWED AND APPROVED USING DATA AS TO COMPARABLE COMPENSATION FOR SIMILARLY QUALIFIED PERSONS IN FUNCTIONALLY COMPARABLE POSITIONS AT SIMILARLY SITUATED ORGANIZATIONS. 3. CONTEMPORANEOUS DOCUMENTATION AND RECORDKEEPING: THE EXECUTIVE COMMITTEE RECORDS THE DELIBERATIONS AND DECISIONS REGARDING THE COMPENSATION ARRANGEMENT IN COMMITTEE MEETING MINUTES. FORM 990, PART VI, SECTION C, LINE 19 NFCC DOES NOT MAKE ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC. FORM 990, PART XII, LINE 2C: THE AUDIT OVERSIGHT PROCESS HAS REMAINED UNCHANGED FROM THE PRIOR YEAR.