2023-10-11T16:46:08-05:00 2022-12-31 263753134 CBIZ MHM LLC 500 BOYLSTON STREET BOSTON MA 02116 990 2022-01-01 042254705 MASSACHUSETTS HIGHER EDUCATION ASSISTANCE CORPORATION MASS 6177284549 33 ARCH STREET 2100 BOSTON MA 02110 BARBARA MATEZ PRESIDENT/CEO/TREASURER 6177284549 2023-10-04 1 BARBARA MATEZ 999009999 0 CRAIG KLEIN P00734640 6177610600 2023-10-04 2 AAL1 IAL1 2022 2023-04-26 12:10:37Z AMERICAN STUDENT ASSISTANCE JEAN EDDY 33 ARCH STREET 2100 BOSTON MA 02110 935416049 0 X WWW.ASA.ORG X 1956 MA PROVIDE ACCESS TO AND CONDUCT ACTIVITIES IN FURTHERANCE OF HIGHER EDUCATION. 11 10 124 0 -514 0 3274977 1389402 99159065 87981477 21653256 -8234020 0 783497 124087298 81920356 12045671 6167167 0 0 14115189 15748514 0 0 0 53748133 47387753 79908993 69303434 44178305 12616922 1090709677 945178364 145522363 125579526 945187314 819598838 THE ORGANIZATION'S PRIMARY EXEMPT PURPOSE IS TO PROVIDE ACCESS TO AND CONDUCT ACTIVITIES IN FURTHERANCE OF HIGHER EDUCATION. 0 0 19887026 200001 87981476 MASSACHUSETTS HIGHER EDUCATION ASSISTANCE CORPORATION (MHEAC) RELIEVES THE BURDENS OF GOVERNMENT AND ASSISTS STUDENTS AND PARENTS IN SUCCESSFULLY COMPLETING A PROGRAM OF HIGHER EDUCATION BY CONTINUING TO ACT AS A GUARANTOR OF STUDENT LOANS MADE BY LENDERS, IN CONNECTION WITH THE FEDERAL HIGHER EDUCATION ACT OF 1965. IN ADDITION, MHEAC ENGAGES IN A VARIETY OF ACTIVITIES IN FURTHERANCE OF HIGHER EDUCATION, INCLUDING HELPING STUDENTS EXPLORE ALTERNATIVE EDUCATION PATHWAYS IN PURSUIT OF SUCCESSFUL AND FULFILLING CAREERS. 39532039 5967166 MIDDLE AND HIGH SCHOOL ACTIVITIES: MHEAC ENGAGES IN A VARIETY OF ACTIVITIES IN FURTHERANCE OF HIGHER EDUCATION. THE MISSION IS TO HELP STUDENTS KNOW THEMSELVES, KNOW THEIR OPTIONS, AND MAKE INFORMED DECISIONS TO ACHIEVE THEIR EDUCATION AND CAREER GOALS. ASA IS COMMITTED TO HELPING STUDENTS EXPLORE EDUCATION AND CAREER OPTIONS STARTING IN MIDDLE SCHOOL, EXPERIMENT THROUGH HANDS-ON OPPORTUNITIES, AND EXECUTE A PLAN TO MEET THEIR GOALS. ASA'S INNOVATIVE PROGRAMS AND PARTNERSHIPS, COMBINED WITH A ROBUST RESEARCH AGENDA AND ADVOCACY PLATFORM, ENABLE ASA TO PROVIDE MEANINGFUL IMPACT TO YOUNG PEOPLE ON A NATIONAL SCALE. 1646181 COLLEGE ACCESS PROGRAMS - MHEAC OFFERS FREE COMPREHENSIVE INFORMATION, GUIDANCE AND PRACTICAL HELP TO ASSIST UNDERSERVED AND UNDER-REPRESENTED INDIVIDUALS GAIN ACCESS TO AND SUCCEED WITHIN THE POST-SECONDARY EDUCATION SYSTEM. HIGH SCHOOL STUDENTS ARE ABLE TO PARTICIPATE IN SCHOOL-BASED PROGRAMS THAT INCLUDE COLLEGE CAMPUS TOURS, SUMMER COLLEGE PREPARATORY PROGRAMS, STANDARDIZED TEST PREPARATION, SCHOLARSHIP SEARCH, COLLEGE SELECTION AND THE APPLICATION PROCESS. INDIVIDUALS WITHOUT ACCESS TO SCHOOL-BASED PROGRAMS ARE PROVIDED SERVICES AT SEVERAL DEDICATED COLLEGE PLANNING CENTERS (CPCS) BASED IN URBAN COMMUNITIES. THE SERVICES INCLUDE INDIVIDUALIZED COUNSELING ON THE COLLEGE PLANNING, APPLICATION AND FINANCING PROCESSES. 61065246 1 1 0 1 0 0 0 0 0 0 1 1 0 0 1 1 0 1 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 1 81 0 1 124 1 1 1 0 0 0 0 0 0 0 0 0 0 0 X 11 10 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 MA X CARMELA CAPLAIN 6175352606 33 ARCH STREET SUITE 2100 BOSTON MA 02110 ALEX RAPPAPORT DIRECTOR 1.00 X 50000 0 0 CARLA THOMPSON DIR/CHAIR OF IMPACT INVESTING 1.00 X 50750 0 0 CAROL FULP DIRECTOR/CHAIR OF COMPENSATION/VICE 1.00 X X 63000 0 0 EMILY MCCANN DIRECTOR 1.00 X 50000 0 0 JEAN EDDY PRESIDENT/CEO/DIRECTOR 40.00 X X 705315 0 33224 KEN JONES DIR./CHAIR OF AUDIT COMMITTEE 1.00 X 53000 0 0 LAWRENCE H GENNARI DIR/CHAIR OF BOARD/CHAIR 1.00 X X 68000 0 0 PATTY DIAZ-ANDRADE DIRECTOR 1.00 X 50000 0 0 PETER SEGALL DIRECTOR 1.00 X 53000 0 0 STEPHANIE CRIMMINS DIRECTOR 1.00 X 52250 0 0 THOMAS GRAF DIR./CHAIR OF INV COMMITTEE 1.00 X 53000 0 0 ANGELINE L CASTERA CHIEF PEOPLE OFFICER 40.00 X 149012 0 11677 BARBARA MATEZ EVP & CFO 40.00 X 492834 0 33513 JOHN CHRISTOPHER SHEEHAN VP & GENERAL COUNSEL 40.00 X 369216 0 34405 ALISA WILKE SVP PRODUCT DEVELOPMENT 40.00 X 353827 0 56656 CAMERON F LOGAN PHD VICE PRESIDENT OF TECHNOLOGY 40.00 X 243722 0 40111 CARMELA CAPLAIN VICE PRESIDENT OF FINANCE 40.00 X 277392 0 31083 CLAY COLARUSSO CMO & SVP DIGITAL STRATEGY 40.00 X 383768 0 54372 JAMES G SMITH VICE PRESIDENT OF MARKETING 40.00 X 256361 0 52662 JUDY GOLDSTEIN SVP PUBLIC RELATIONS COMMUNICATIONS 40.00 X 332072 0 62586 JULIE LAMMERS SVP ADVOCACY CORP RESP 40.00 X 336768 0 59288 KYLE G MORIN VP INVESTMENT & FINANCIAL ANALYSIS 40.00 X 154933 0 30448 RILWAN MEERAN VP MISSION IMPACT INVESTMENTS 40.00 X 438836 0 59778 ALAN WHITE SR. DIR. STR RES DATA ANALY 40.00 X 179560 0 50155 ANDREW DYKE SR. DIRECTOR OF TECHNOLOGY 40.00 X 221549 0 19563 ANNA M SINGER DIR COMPENSATION & BENEFITS 40.00 X 237061 0 47355 LEE WALDVOGEL SR PROGRAM DIR PARTNERS 40.00 X 184924 0 47046 SANDY DAWKINS PMO PROGRAM DIRECTOR 40.00 X 172789 0 30343 ANNABEL CELLINI FORMER CHIEF STRATEGY OFFICER 40.00 X 105769 0 0 6138708 0 754265 44 1 1 0 ECMC 111 WASHINGTON AVENUE SOUTH MINNEAPOLIS MN 55401 GUARANTOR SERVICES 32063450 DEVITO VERDI INC 330 HUDSON ST 16TH FLOOR NEW YORK NY 10013 CONSULTING SERVICES 6749836 DELTA MANAGEMENT ASSOCIATES 100 EVERETT AVE STE 6 CHELSEA MA 02150 DEBT COLLECTION ASSISTANCE 758886 TAPJOY INC 30 3RD STREET SAN FRANCISCO CA 94103 SOCIAL MEDIA 722358 ARCHETYPE CONSULTING INC 180 CANAL STREET SUITE 600 BOSTON MA 02114 DATA ENGINEERING 527533 46 1389402 1389402 LOST REVENUE REIMBURSE 900099 74836409 74836409 ACCOUNT MAINTENANCE FE 900099 7811127 7811127 DEFAULT AVERSION FEE 900099 2318899 2318899 CONSOLIDATED COLLECTIO 900099 2067259 2067259 REHABILITATED COLLECTI 900099 932934 932934 14849 14849 87981477 20425093 -514 20425607 824836580 853495693 -28659113 -28659113 -28659113 OTHER INCOME 900099 783497 783497 783497 81920356 87981477 -514 -7450009 6167167 6167167 5053846 3750409 1303437 8230838 6869932 1360906 1457822 1173663 284159 1006008 804806 201202 600730 600730 202958 202958 8373 8373 8164317 8164317 110798 88638 22160 2935952 2348762 587190 2097130 1677704 419426 331910 265528 66382 2775859 2220687 555172 1759833 1407866 351967 1230720 984576 246144 3RD PARTY SERVICES FEE 19421631 19421631 CONSULTING & PROF. SERV 4754134 2829309 1924825 PROGRAM DEVELOPMENT FEE 2035756 2035756 957652 846122 111530 69303434 61065246 8238188 0 12630082 16092362 60925683 69101017 5063302 3695536 1938170 1923992 18529225 7853838 5985383 10675387 918937957 741454651 7544116 87409909 77684984 14825510 1090709677 945178364 43033721 24912577 99052845 99155703 3435797 1511246 145522363 125579526 X 945187314 819598838 945187314 819598838 1090709677 945178364 X 12616922 -138316784 111386 X 0 1 X 1 1 1 X 962420 2275612 1861891 3274977 1389402 9764302 56962352 106783867 68368183 99159065 87981477 419254944 57924772 109059479 70230074 102434042 89370879 429019246 0 5612442 10442835 9733746 8201285 6713162 40703470 5612442 10442835 9733746 8201285 6713162 40703470 388315776 7032031 16466079 13855556 21137292 20425604 78916562 7032031 16466079 13855556 21137292 20425604 78916562 64956803 125525558 84085630 123571334 109796483 507935808 0.76450 0.77430 0.15540 0.13710 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 1 0 0 0 0 1 1173 0 1 7200 8373 0 PART II-B, LINE 1: ADVISE ON LEGISLATIVE AND POLICY MATTERS RELATED TO HIGHER EDUCATION; HELP MAINTAIN RELATIONSHIPS WITH GOVERNMENT OFFICIALS AND THEIR STAFFS. 158237174 -158237174 138154558 20082616 158237174 112546240 25611554 3236 138154558 120498681 -7948866 3575 112546240 0.00000 0.00000 0.00000 3700339 1045271 2655068 2144587 2133634 10953 12684299 4674933 8009366 10675387 VENTURE CAPITAL INVESTMENT 13157027 F HEDGE FUND INVESTMENTS 68988526 F PRIVATE EQUITY INVESTMENTS 5264356 F 87409909 RESERVE FOR CONTINGENCIES 1307937 OTHER 203309 1511246 X -56396428 -138316784 -138316784 81920356 0 81920356 69303434 0 69303434 0 69303434 PART V, LINE 4: ASA PREVIOUSLY ESTABLISHED ASA FUND LLC ("ASA FUND", ALSO REFERRED TO AS "NEW PROGRAMS"), A SINGLE MEMBER LLC ESTABLISHED TO HOLD FUNDS DESIGNATED BY THE BOARD AS A QUASI-ENDOWMENT FOR THE BENEFIT OF THE NEW PROGRAMS. DURING 2021, ASA'S BOARD OF DIRECTORS RESOLVED TO CLOSE ASA FUND AS A SEPARATE ENTITY AND TO TRANSFER ALL ASSETS AND LIABILITIES BACK TO ASA. PART X, LINE 2: ASA ACCOUNTS FOR THE EFFECT OF ANY UNCERTAIN TAX POSITIONS BASED ON A "MORE LIKELY THAN NOT" THRESHOLD TO THE RECOGNITION OF THE TAX POSITIONS BEING SUSTAINED BASED ON THE TECHNICAL MERITS OF THE POSITION UNDER SCRUTINY BY THE APPLICABLE TAXING AUTHORITY. IF A TAX POSITION OR POSITIONS ARE DEEMED TO RESULT IN UNCERTAINTIES OF THOSE POSITIONS, THE UNRECOGNIZED TAX BENEFIT IS ESTIMATED BASED ON A "CUMULATIVE PROBABILITY ASSESSMENT" THAT AGGREGATES THE ESTIMATED TAX LIABILITY FOR ALL UNCERTAIN TAX POSITIONS. ASA HAS IDENTIFIED ITS TAX STATUS AS A TAX-EXEMPT ENTITY, ITS DETERMINATION OF WHICH ACTIVITIES ARE RELATED AND UNRELATED AND ITS PRESENTATION OF CERTAIN NET OPERATING LOSS CARRYFORWARDS AS ITS ONLY SIGNIFICANT TAX POSITIONS. ASA, HOWEVER, HAS DETERMINED THAT ITS POSITION RELATIVE TO TAX STATUS OR DETERMINATION OF WHICH ACTIVITIES ARE RELATED AND UNRELATED DOES NOT RESULT IN AN UNCERTAINTY REQUIRING RECOGNITION. THE POSITION ON LOSS CARRYFORWARDS IS UNCERTAIN AND THUS SUCH CARRYFORWARDS HAVE NOT BEEN RECOGNIZED AS TAX ASSETS. ASA IS NOT CURRENTLY UNDER EXAMINATION BY ANY TAXING JURISDICTION. ASA'S FEDERAL AND STATE TAX RETURNS ARE GENERALLY OPEN FOR EXAMINATION FOR THREE YEARS FOLLOWING THE DATE FILED. 1 ASSOCIATION FOR MIDDLE LEVEL EDUCATION 283 WHISTLEWOOD LANE WINCHESTER VA 22602 310865702 501(C)(3) 50000 0 CAREER EXPLORATION BIG PICTURE LEARNING 325 PUBLIC STREET PROVIDENCE RI 02972 050485883 501(C)(3) 535000 0 WORKBASED LEARNING COALITION FOR CAREER DEVELOPMENT CCD CENTER 901 NORTH WASHINGTON STREET SUITE 600 ALEXANDRIA VA 22314 852426988 501(C)(3) 300000 0 CAREER EXPLORATION JOBS FOR THE FUTURE 88 BROAD STREET BOSTON MA 02110 061164568 501(C)(3) 1500000 0 POSTSECONDARY PATHWAYS JOBS FOR THE FUTURE 88 BROAD STREET BOSTON MA 02110 061164568 501(C)(3) 75000 0 SPONSORSHIP LEARN LAUNCH INC 1 LINCOLN ST BOSTON MA 02111 461270864 501(C)(3) 200000 0 SPONSORSHIP NETWORK FOR TEACHING ENTREPENEURSHIP 120 WALL STREET 18TH FLOOR NEW YORK NY 10005 133408731 501(C)(3) 25000 0 SPONSORSHIP NEW PROFIT INC 99 BEDFORD ST SUITE 500 BOSTON MA 02111 043396766 501(C)(3) 500000 0 POSTSECONDARY PATHWAYS RODEL FOUNDATION OF DELAWARE 100 WEST 10TH STREET SUITE 704 WILMINGTON DE 19801 911944585 501(C)(3) 566666 0 CAREER EXPLORATION SOCIAL INNOVATION FORUM INC 2 OLIVER STREET SUITE 802 BOSTON MA 02109 473923576 501(C)(3) 100000 0 WORK-BASED LEARNING THE NATIONAL MENTORING PARTNERSHIP 201 SOUTH STREET SUITE 615 BOSTON MA 02111 521674088 501(C)(3) 900000 0 CAREER EXPORATION AMERICA SUCCEEDS 1390 LAWRENCE STREET SUITE 200 DENVER CO 80204 455334937 501(C)(3) 200000 0 CAREER READINESS CHICA PROJECT 1266 FURNACE BROOK PARKWAY SUITE 410 QUINCY MA 02169 453866647 501(C)(3) 100000 0 WORK-BASED LEARNING FLARE EDUCATION INC 288 WESTERN AVE CAMBRIDGE MA 02139 871145016 501(C)(3) 100000 0 WORK-BASED LEARNING MASSACHUSETTS BUSINESS ALLIANCE FOR EDUCATION 10 POST OFFICE SQUARE SUITE 800 SOUTH BOSTON MA 02109 043274599 501(C)(3) 10000 0 SPONSORSHIP RENNIE CENTER FOR EDUCATION RESEARCH AND POLICY 114 STATE STREET BOSTON MA 02109 510548106 501(C)(3) 90000 0 EDUCATION RESEARCH THE CENTER FOR BLACK EDUCATOR DEVELOPMENT 7901 HIDDEN LANE ELKINS PARK PA 19027 841814119 501(C)(3) 200000 0 CAREER EXPLORATION US CHAMBER OF COMMERCE FOUNDATION 1615 H STREET NW WASHINGTON DC 200622000 461561597 501(C)(3) 500000 0 WORK-BASED LEARNING CONSORTIUM OF UNIVERSITIES OF THE WASHINGTON METROPOLITAN 1020 19TH STREET NORTHWEST SUITE 500 WASHINGTON DC 20036 520847610 501(C)(3) 200001 0 TO COLLABORATE WITH THE AGENCY TO PROMOTE ACCESS TO HIGHER EDUCATION IN THE WASHINGTON DC METRO AREA 19 0 PART I, LINE 2: GRANT FUNDING IS MEMORIALIZED IN A WRITTEN GRANT FUNDING DOCUMENT WHICH SETS FORTH THE PURPOSES OF THE GRANT AND ELIGIBILITY CRITERIA. THE ORGANIZATION REQUIRES PERIODIC REPORTS AND CONDUCTS RANDOM REVIEWS OF GRANTEES TO ENSURE GRANT REQUIREMENTS ARE BEING MET. 1 X X X X X 1 0 0 0 0 0 0 1 0 JEAN EDDY PRESIDENT/CEO/DIRECTOR 447369 0 247500 0 10446 0 21350 0 11874 0 738539 0 0 0 BARBARA MATEZ EVP & CFO 342369 0 138000 0 12465 0 21350 0 12163 0 526347 0 0 0 RILWAN MEERAN VP MISSION IMPACT INVESTMENTS 280906 0 150000 0 7930 0 12626 0 47152 0 498614 0 0 0 CLAY COLARUSSO CMO & SVP DIGITAL STRATEGY 266838 0 110000 0 6930 0 20500 0 33872 0 438140 0 0 0 ALISA WILKE SVP PRODUCT DEVELOPMENT 240385 0 105000 0 8442 0 21350 0 35306 0 410483 0 0 0 JOHN CHRISTOPHER SHEEHAN VP & GENERAL COUNSEL 272454 0 88320 0 8442 0 21350 0 13055 0 403621 0 0 0 JULIE LAMMERS SVP ADVOCACY CORP RESP 230108 0 100000 0 6660 0 20500 0 38788 0 396056 0 0 0 JUDY GOLDSTEIN SVP PUBLIC RELATIONS COMMUNICATIONS 237648 0 87500 0 6924 0 21350 0 41236 0 394658 0 0 0 JAMES G SMITH VICE PRESIDENT OF MARKETING 207339 0 41200 0 7822 0 18472 0 34190 0 309023 0 0 0 CARMELA CAPLAIN VICE PRESIDENT OF FINANCE 222708 0 45000 0 9684 0 19388 0 11695 0 308475 0 0 0 ANNA M SINGER DIR COMPENSATION & BENEFITS 209725 0 26250 0 1086 0 16184 0 31171 0 284416 0 0 0 CAMERON F LOGAN PHD VICE PRESIDENT OF TECHNOLOGY 181830 0 56000 0 5892 0 6629 0 33482 0 283833 0 0 0 ANDREW DYKE SR. DIRECTOR OF TECHNOLOGY 190409 0 30000 0 1140 0 15626 0 3937 0 241112 0 0 0 LEE WALDVOGEL SR PROGRAM DIR PARTNERS 151838 0 32000 0 1086 0 13489 0 33557 0 231970 0 0 0 ALAN WHITE SR. DIR. STR RES DATA ANALY 151900 0 26250 0 1410 0 11530 0 38625 0 229715 0 0 0 SANDY DAWKINS PMO PROGRAM DIRECTOR 148234 0 23145 0 1410 0 11897 0 18446 0 203132 0 0 0 KYLE G MORIN VP INVESTMENT & FINANCIAL ANALYSIS 110076 0 40000 0 4857 0 11148 0 19300 0 185381 0 0 0 ANGELINE L CASTERA CHIEF PEOPLE OFFICER 74607 0 71250 0 3155 0 3479 0 8198 0 160689 0 0 0 ANNABEL CELLINI FORMER CHIEF STRATEGY OFFICER 0 0 0 0 105769 0 0 0 0 0 105769 0 0 0 PART I, LINE 4A ANNABEL CELLINI RECEIVED SEVERNACE IN THE AMOUNT OF $105,769 IN CALENDAR YEAR 2022. PART I, LINE 7 ALL OFFICERS AND MEMBERS OF MANAGEMENT PARTICIPATE IN A SPECIAL INCENTIVE AWARD WHICH IS BASED UPON THE ORGANIZATION'S SUCCESS IN ACHIEVING KEY MILESTONES IN SUPPORT OF CORPORATE STRATEGIC OBJECTIVES DERIVED FROM MHEAC'S MISSION. THESE MILESTONES AND CRITERIA ARE IDENTIFIED IN ADVANCE AND APPROVED BY THE COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS. RECOMMENDATIONS BASED ON THE OVERALL LEVEL OF ACHIEVEMENT OF THOSE CORPORATE STRATEGIC OBJECTIVES ARE PRESENTED TO THE COMPENSATION COMMITTEE FOR DETERMINATION OF THE OVERALL AWARD POOL SIZE AS WELL AS INDIVIDUAL AWARD LEVELS, SUBJECT TO AN ANNUAL CAP, WITHIN THE POOL BASED ON INDIVIDUALS' RELATIVE CONTRIBUTIONS. PART II, COLUMN C: ASA MATCHES EMPLOYEES' CONTRIBUTIONS TO THE SECTION 403(B) PLAN UP TO A DISCRETIONARY PERCENTAGE SET ANNUALLY BY THE BOARD OF DIRECTORS IN ACCORDANCE WITH IRS GUIDELINES AND LIMITS. AMOUNTS ACCRUED AT YEAR END ARE INCLUDED IN SCHEDULE J, PART II, COLUMN C. FORM 990, PART VI, SECTION B, LINE 11B THE FORM 990 IS PREPARED BY CBIZ MHM, LLC OUR NATIONAL TAX SERVICES FIRM WITH INFORMATION PROVIDED BY THE ACCOUNTING MANAGER AND VICE PRESIDENT, FINANCE. THE FORM 990 IS REVIEWED BY THE ACCOUNTING MANAGER, VICE PRESIDENT FINANCE, VICE PRESIDENT GENERAL COUNSEL, EXECUTIVE VICE PRESIDENT AND CFO, AND THE PRESIDENT/CEO. THE FULLY COMPLETED FORM 990 IS PROVIDED TO THE AUDIT COMMITTEE FOR REVIEW AND APPROVAL AND THEN PROVIDED TO THE ENTIRE BOARD OF DIRECTORS FOR REVIEW AND APPROVAL BEFORE IT IS ELECTRONICALLY SUBMITTED TO THE INTERNAL REVENUE SERVICE. FORM 990, PART VI, SECTION B, LINE 12C ALL OFFICERS, BOARD MEMBERS AND KEY EMPLOYEES SHALL ANNUALLY SIGN A STATEMENT WHICH AFFIRMS THAT THE PERSON; HAS RECEIVED A COPY OF THE CONFLICTS OF INTEREST POLICY, HAS READ AND UNDERSTANDS THE POLICY, AND HAS AGREED TO COMPLY WITH THE POLICY. IN ADDITION, EACH DIRECTOR, PRINCIPAL OFFICER AND MEMBER OF A COMMITTEE WITH BOARD-ASSIGNED POWERS SHALL LIST HIS OR HER BUSINESS AFFILIATIONS, INCLUDING MEMBERSHIPS ON BOARDS OF OTHER NON-PROFIT INSTITUTIONS, AND SHALL ALSO DISCLOSE ANY BUSINESS RELATIONSHIPS THAT MEMBERS OF HIS OR HER FAMILY HAVE OR ARE SEEKING WITH AMERICAN STUDENT ASSISTANCE. HE OR SHE SHALL ALSO UPDATE THE STATEMENT AS APPROPRIATE DURING THE YEAR. FORM 990, PART VI, SECTION B, LINE 15 COMPENSATION REVIEWS FOR THE TOP MANAGEMENT OFFICIALS (PRESIDENT/CEO, EXECUTIVE VICE PRESIDENT AND CFO) AND MEMBERS OF SENIOR MANAGEMENT STAFF ARE CONDUCTED ANNUALLY BY THE COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS. SENIOR MANAGEMENT STAFF CONSISTS OF ALL VICE PRESIDENTS AND MANAGING DIRECTORS OF THE ORGANIZATION. PERIODICALLY, AN IN-DEPTH MARKET BENCHMARKING STUDY IS COMPILED FOR EACH SENIOR STAFF POSITION, INCLUDING THE CEO AND CFO, UTILIZING PUBLISHED, INDEPENDENT, THIRD-PARTY COMPENSATION SURVEYS TO COMPARE CURRENT BASE SALARIES AND TOTAL COMPENSATION WITH THE SAME OR SIMILAR POSITIONS IN THE BOSTON GEOGRAPHIC AREA, IN SIMILAR-SIZED ORGANIZATIONS, PRIMARILY IN THE FINANCIAL SERVICES, EDUCATION AND NOT-FOR-PROFIT SECTORS. ON A BI-ANNUAL BASIS, THE HUMAN RESOURCES DEPARTMENT ALSO EXAMINES FORM 990 DATA FROM SIMILAR ORGANIZATIONS AND ALSO OBTAINS A SEPARATE COMPENSATION ANALYSIS WITH COMPARATIVE MARKET DATA FROM AN INDEPENDENT COMPENSATION CONSULTANT. THIS COMPARABILITY DATA IS SYNTHESIZED INTO A DETAILED REPORT WITH THE MARKET RANGES AND EACH INCUMBENT'S POSITION IN THE RANGE AND INCLUDES COMPARATIVE BASE SALARY AND TOTAL COMPENSATION MARKET DATA. THIS REPORT IS PRESENTED TO THE PRESIDENT/CEO AND THE CFO WHO CONSIDER THE DATA AND MAKE DECISIONS REGARDING INDIVIDUAL SENIOR MANAGEMENT MERIT SALARY INCREASES. THE CEO PRESENTS THE FULL REPORT ALONG WITH THEIR PERFORMANCE REVIEWS AND SALARY RECOMMENDATIONS TO THE MEMBERS OF THE COMPENSATION COMMITTEE COMPRISED OF INDEPENDENT BOARD MEMBERS. THE COMPENSATION COMMITTEE DISCUSSES THE CEO'S DECISIONS FOR SENIOR MANAGEMENT STAFF. THE CEO ALSO REVIEWS AND MAKES A MERIT SALARY INCREASE RECOMMENDATION FOR THE CFO, WHICH IS ALSO PRESENTED TO THE COMPENSATION COMMITTEE FOR THEIR REVIEW AND APPROVAL. THE FULL BOARD OF DIRECTORS USES THE COMPARATIVE MARKET DATA TO REVIEW AND ESTABLISH THE COMPENSATION OF THE PRESIDENT/CEO. ANY ANNUAL INCENTIVE BONUS PLANS, THOUGH DISCRETIONARY, ARE ALSO APPROVED IN ADVANCE BY THE COMPENSATION COMMITTEE AND ANY PAYOUTS ARE DETERMINED BY THE COMPENSATION COMMITTEE BASED ON THE RESULTS OF PREVIOUSLY ESTABLISHED GOALS AND CRITERIA, OVERALL COMPANY PERFORMANCE, COMPARISON TO MARKET DATA, AND SUBJECT TO AN ANNUAL CAP. THE DELIBERATIONS AND DECISIONS OF THE COMPENSATION COMMITTEE ARE RECORDED CONTEMPORANEOUSLY IN THE MEETING MINUTES WHICH ARE RECORDED AND PRESERVED BY THE SPECIAL ASSISTANT TO THE PRESIDENT, ALONG WITH THE ANALYSIS DATA. KEY EMPLOYEES ARE NOT INCLUDED IN THE ABOVE-DESCRIBED COMPENSATION APPROVAL PROCESS. THEY ARE INCLUDED IN THE OVERALL PROCESS WHICH INCLUDES EMPLOYEES UNDER THEIR MANAGEMENT. FORM 990, PART VI, SECTION C, LINE 19 THE GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS ARE AVAILABLE UPON REQUEST. FORM 990, PART XI, LINE 9: PENSION PLAN FAS 158 GAIN -419. ROUNDING 111,805. ASA FUND I LLC 33 ARCH STREET SUITE 2100 BOSTON MA 02110 881527882 INVESTING AND HOLDING ASSETS MA -7125812 688463364 MHEAC