2024-05-14T00:10:59-05:00 2023-06-30 366055558 GRANT THORNTON LLP 757 THIRD AVENUE 3RD FLOOR NEW YORK NY 100172013 990 2022-07-01 111635105 ST FRANCIS COLLEGE STFR 7184895364 179 LIVINGSTON STREET BROOKLYN NY 11201 MARK SANDERS ACTING CFO 7184895364 2024-05-13 1 MARK SANDERS XXX-XX-XXXX 1 DANIEL ROMANO P00504182 2125990100 2 AAL1 IAL1 2022 2023-04-26 12:10:37Z MARK SANDERS 179 LIVINGSTON STREET BROOKLYN NY 11201 236431299 0 X WWW.SFC.EDU X 1957 NY ST. FRANCIS COLLEGE IS AN INDEPENDENT, COEDUCATIONAL INSTITUTION (SEE SCHEDULE O) 16 15 683 0 24566 26776 14427303 4067143 65425776 66236881 1168655 115484036 390708 1103915 81412442 186891975 36561400 31728035 0 0 37151139 37800259 0 0 950283 41457834 51334075 115170373 120862369 -33757931 66029606 452826805 505951692 434353554 420851284 18473251 85100408 X ST. FRANCIS COLLEGE IS AN INDEPENDENT, COEDUCATIONAL INSTITUTION OF HIGHER EDUCATION CHARTERED BY AN ACT OF THE REGENTS OF THE UNIVERSITY OF THE STATE OF NEW YORK ON APRIL 10, 1957. 0 1 62872384 31728035 66236881 INSTRUCTIONAL - THE COLLEGE PROVIDES DIRECT SERVICES THROUGH ITS FACULTY TO APPROXIMATELY 2,500 FULL AND 150 PART TIME STUDENTS LEADING PRIMARILY TO BACCALAUREATE AND ASSOCIATE DEGREES.STUDENT AID AND OTHER - FUNDING FOR SCHOLARSHIPS, GRANTS, AND OTHER FINANCIAL AID. THE COLLEGE AWARDS FEDERAL AND STATE GRANTS AND/OR LOANS BASED UPON FINANCIAL NEED. COLLEGE FUNDED INSTITUTIONAL AND ENDOWED GRANTS/SCHOLARSHIPS ARE AWARDED BASED UPON FINANCIAL NEED AND ACADEMIC MERIT. 33701339 0 0 ACADEMIC SUPPORT - PROVIDES FUNDING FOR SUPPORT SERVICES TO THE INSTRUCTIONAL DEPARTMENTS, ACADEMIC ENHANCEMENT AND STUDENT ORIENTATION SERVICES, HONORS PROGRAMS, AND THE LIBRARY. STUDENT SERVICES - PROVIDES FUNDING FOR THE OFFICES OF ADMISSIONS, REGISTRAR, AND OTHER STUDENT RELATED SUPPORT SERVICES AND ACTIVITIES TO ENSURE STUDENTS' EMOTIONAL AND PHYSICAL WELL-BEING AND DEVELOPMENT OUTSIDE THE FORMAL INSTRUCTIONAL PROGRAM. 96573723 1 1 0 1 0 0 0 1 0 1 1 0 0 1 1 1 1 0 1 0 1 0 0 0 1 0 0 0 1 1 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 180 0 1 683 1 1 1 0 0 0 0 1 1 0 0 0 0 0 0 X 16 15 1 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 X ALISON EASTWOOD CONTROLLER 7184895364 179 LIVINGSTON STREET BROOKLYN NY 11201 DENIS J SALAMONE TRUSTEE - CHAIR 8.00 0.00 X X 0 0 0 BARBARA G KOSTER TRUSTEE - VICE CHAIR 5.00 0.00 X X 0 0 0 JUDY RICE TRUSTEE - SECRETARY 5.00 0.00 X X 0 0 0 BROTHER WILLIAM A BOSLET TRUSTEE 5.00 0.00 X 0 0 0 TIM CECERE COO (AS OF 08/2022)/ACTING PRESIDENT 35.00 0.00 X X 103324 0 1350 EDWARD N CONSTANTINO TRUSTEE 5.00 0.00 X 0 0 0 BROTHER LEONARD CONWAY TRUSTEE 5.00 0.00 X 0 0 0 ARKELL COX TRUSTEE 5.00 0.00 X 0 0 0 MARY BETH DAWSON TRUSTEE (THRU 06/2023) 5.00 0.00 X 0 0 0 JEAN DESRAVINES TRUSTEE 5.00 0.00 X 0 0 0 LESLIE S JACOBSON TRUSTEE (THRU 07/2022) 5.00 0.00 X 0 0 0 MIKE MACINTYRE TRUSTEE 5.00 0.00 X 0 0 0 J CHRISTOPHER MANGAN TRUSTEE 5.00 0.00 X 0 0 0 VICTOR J MASI TRUSTEE 5.00 0.00 X 0 0 0 BROTHER GABRIEL O'BRIEN TRUSTEE 5.00 0.00 X 0 0 0 ANA OLIVEIRA TRUSTEE 5.00 0.00 X 0 0 0 CHARLES D SMITH TRUSTEE (THRU 01/2023) 5.00 0.00 X 0 0 0 JOHN F TULLY TRUSTEE 5.00 0.00 X 0 0 0 HELEN GAUDETTE TRUSTEE 5.00 0.00 X 0 0 0 MIGUEL MARTINEZ-SAENZ PRESIDENT 35.00 0.00 X 406130 0 267767 MAUREEN LAWRENCE CHIEF FINANCE OFFICER 35.00 0.00 X 237007 0 25960 JENNIFER LANCASTER VP FOR ACADEMIC AFFAIRS 35.00 0.00 X 225165 0 23387 DENNIS ANDERSON AS OF 062023 PROVOST/SVP FOR ACADEMIC AFFAIRS 35.00 0.00 X 213636 0 30902 HAYLEY DRYER VP AND GENERAL COUNSEL 35.00 0.00 X 248148 0 22790 MONIQUE MOORE PRYOR THRU 623 CHIEF EGMNT. & EXT. AFFAIRS OFFICER 35.00 0.00 X 235565 0 66529 ALLEN BURDOWSKI DEAN OF SCIENCES 35.00 0.00 X 232142 0 22754 REZA FAKHARI VP OF INTERNATIONALIZATION 35.00 0.00 X 215369 0 28004 KEVIN O'ROURKE VP OF FACILITIES 35.00 0.00 X 200932 0 63632 TIMOTHY J HOULIHAN FACULTY/FORMER PROVOST 35.00 0.00 X 214297 0 49440 2531715 0 602515 71 0 1 0 STERLING PROJECT DEVELOPMENT GROUP LLC 111 GREAT NECK RD GREAT NECK NY 11021 CONSULTING SERVICES 550000 CULLEN DYKMAN 100 QUENTIN ROOSEVELT BLVD GARDEN CITY NY 115304850 LEGAL SERVICES 495694 EFFICIENT ENERGY COMPLIANCE 248 WEST 35TH STREET 8TH FLOOR NEW YORK NY 10001 COMPLIANCE 355544 GERI A GERGOR CPA PLLC 65 EAST OLIVE STREET LONG BEACH NY 11561 CONSULTING SERVICES 275110 JEFFREY BETHKE 1835 N CLEVELAND AVE CHICAGO IL 606145205 CONSULTING SERVICES 245000 15 2175 678133 3386835 4324 4067143 STUDENT TUITION & FEES 611710 64317006 64317006 INTERNATIONAL SUMMER PROGRAM 611710 1699531 1699531 ATHLETIC RELATED INC. 611710 220344 220344 66236881 1498852 -12629 1511481 228448 0 228448 228448 228448 7473860 156016163 7293023 42211816 180837 113804347 113985184 113985184 60977 2175 34485 26492 26492 CAFETERIA/VENDING REVENUE 721000 219331 219331 POOL RENTAL 900099 102355 37195 65160 527289 527289 848975 186891975 66236881 24566 116563385 31728035 31728035 2531716 1100609 1431107 27309113 22919748 3662632 726733 1455450 1170764 250192 34494 4053700 3260796 696831 96073 2450280 1971005 421203 58072 809191 809191 228145 81920 146225 132300 132300 2580011 650128 1929883 225406 225406 487946 312938 155065 19943 11223506 8610414 2613092 350032 330044 19988 333260 263998 69262 4128597 4128597 3858262 2643291 1214971 OPERATING LEASE EXPENSE 12649154 8665924 3983230 PHYSICAL PLANT MAINT. 11283525 7706580 3576945 BAD DEBT EXPENSE 1779706 1779706 1265034 1028932 221134 14968 120862369 96573723 23338363 950283 760743 2205270 3777984 22938277 2408337 1054792 1538410 2308267 383907 201120 1406478 13618370 79705308 17160642 54603968 62544666 17305812 6887066 21953492 12066101 348687674 382127763 452826805 505951692 12391659 12139508 22856 22856 116181803 0 305757236 408688920 434353554 420851284 X -21398895 44375741 39872146 40724667 18473251 85100408 452826805 505951692 66029606 597551 0 X 0 1 X 1 1 1 X 4657721 8668237 17689664 14427303 4067143 49510068 4657721 8668237 17689664 14427303 4067143 49510068 298874 49211194 1557306 1035423 666802 660801 1727300 5647632 610551 543687 136065 240832 909952 2441087 57598787 325283681 0.85440 0.86180 X SCHEDULE A, PART II, LINE 10, EXPLANATION OF OTHER INCOME: FUNDRAISING REVENUE - 2018 AMOUNT: $ 124,290. 2019 AMOUNT: $ 0. 2020 AMOUNT: $ 70,300. 2021 AMOUNT: $ 168,618. 2022 AMOUNT: $ 60,977. VENDOR COMMISSIONS OTHER - 2018 AMOUNT: $ 486,261. 2019 AMOUNT: $ 543,687. 2020 AMOUNT: $ 65,765. 2021 AMOUNT: $ 72,214. 2022 AMOUNT: $ 0. CAFETERIA/VENDING REVENUE - 2018 AMOUNT: $ 0. 2019 AMOUNT: $ 0. 2020 AMOUNT: $ 0. 2021 AMOUNT: $ 0. 2022 AMOUNT: $ 219,331. POOL RENTAL - 2018 AMOUNT: $ 0. 2019 AMOUNT: $ 0. 2020 AMOUNT: $ 0. 2021 AMOUNT: $ 0. 2022 AMOUNT: $ 102,355. OTHER REVENUE - 2018 AMOUNT: $ 0. 2019 AMOUNT: $ 0. 2020 AMOUNT: $ 0. 2021 AMOUNT: $ 0. 2022 AMOUNT: $ 527,289. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 0 0 0 1 132300 132300 0 PART II-B, LINE 1: THE COLLEGE HIRES CONSULTANTS TO PROVIDE ADVICE, STRATEGIC PLANNING, AND PROGRAM IMPLEMENTATION ON VARIOUS PROJECTS AND ISSUES. ADDITIONALLY, ON BEHALF OF THE COLLEGE THE CONSULTANT ATTENDS AND PERFORMS VARIOUS PRESENTATIONS BEFORE ELECTED OFFICIALS, PUBLIC HEARINGS AND GOVERNMENT ADMINISTRATORS. 200205 X X CURRENTLY HELD IN STORAGE 0 31791147 352128 1892285 775024 2503313 30757223 40712093 248239 -4679750 1195344 3294091 31791147 28712076 452079 15527868 407537 3572393 40712093 42030550 693643 -1414228 365367 12232522 28712076 48099073 327078 6256998 468119 12184480 42030550 0.51600 0.48400 0 0 57085474 1902851 55182623 22419629 15257791 7161838 200205 200205 62544666 RIGHT-OF-USE ASSETS 242697952 CASH RESTRICTED FOR LOAN PROGRAMS 138901653 FUNDS HELD BY TRUSTEES 409381 OTHER RECEIVABLES 118777 382127763 OPERATING LEASE LIABILITIES 289346510 LINE OF CREDIT 117845641 DEFERRED REVENUE AND STUDENT DEPOSITS 1372591 REFUNDABLE LOAN PROGRAM 124178 408688920 X 155795976 597551 34485 632036 155163940 31728035 31728035 186891975 89168819 34485 34485 89134334 31728035 31728035 120862369 PART III, LINE 4: ART COLLECTIONS THE COLLEGE POSSESSES A COLLECTION OF CENTRAL AMERICAN ART HELD IN STORAGE. PART V, LINE 4: ENDOWMENT CERTAIN ENDOWMENT FUNDS ARE USED TO PROVIDE SCHOLARSHIPS TO STUDENTS IN ACCORDANCE WITH DONOR SPECIFICATIONS. IN ADDITION, THE BOARD OF TRUSTEES APPROVED A SPENDING POLICY THAT MADE AVAILABLE 5.0% OF THE AVERAGE MARKET VALUE OF INVESTMENTS TO SUPPORT THE OPERATIONS OF THE COLLEGE. THE ACTUAL AMOUNT USED FOR OPERATIONS WAS THE 5% SPENDING POLICY PLUS AN ADDITIONAL $3M EXTRAORDARY DRAW OF UNRESTRICTED FUNDS IN FISCAL 2023. PART X, LINE 2: FIN 48 THE COLLEGE ADOPTED THE PROVISIONS OF ASC 740, ACCOUNTING FOR UNCERTAINTIES IN INCOME TAXES. ASC 740-10 CLARIFIES THE ACCOUNTING FOR UNCERTAINTY IN TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN, INCLUDING ISSUES RELATING TO FINANCIAL STATEMENT RECOGNITION AND MEASUREMENT. THIS STANDARD PROVIDES THAT THE TAX EFFECTS FROM AN UNCERTAIN TAX POSITION CAN BE RECOGNIZED IN THE FINANCIAL STATEMENTS ONLY IF THE POSITION IS "MORE-LIKELY-THAN-NOT" TO BE SUSTAINED IF THE POSITION WERE TO BE CHALLENGED BY A TAXING AUTHORITY. THE ASSESSMENT OF THE TAX POSITION IS BASED SOLELY ON THE TECHNICAL MERITS OF THE POSITION, WITHOUT REGARD TO THE LIKELIHOOD THAT THE TAX POSITION MAY BE CHALLENGED. THE COLLEGE IS EXEMPT FROM FEDERAL AND NEW YORK INCOME TAXATION BY VIRTUE OF BEING AN ORGANIZATION DESCRIBED IN SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE (THE "CODE") AND SIMILAR PROVISIONS OF THE NEW YORK STATE TAX CODE. NEVERTHELESS, THE COLLEGE MAY BE SUBJECT TO TAX ON INCOME UNRELATED TO ITS EXEMPT PURPOSE, UNLESS THAT INCOME IS OTHERWISE EXCLUDED BY THE CODE. MANAGEMENT BELIEVES THAT THERE ARE NO MATERIAL UNCERTAIN TAX POSITIONS WITHIN ITS FINANCIAL STATEMENTS. PART XI, LINE 2D - OTHER ADJUSTMENTS: FUNDRAISING EXPENSES NETTED AGAINST REVENUE 34,485. PART XI, LINE 4B - OTHER ADJUSTMENTS: SCHOLARSHIPS & GOVERNMENT SPONSORED ASSISTANCE NETTED AGAINST REVENUE 31,728,035. PART XII, LINE 2D - OTHER ADJUSTMENTS: FUNDRAISING EXPENSES NETTED AGAINST REVENUE 34,485. PART XII, LINE 4B - OTHER ADJUSTMENTS: SCHOLARSHIPS & GOVERNMENT SPONSORED ASSISTANCE NETTED AGAINST REVENUE 31,728,035. PART IX, RIGHT-OF-USE ASSETS THE FINANCIAL ACCOUNTING STANDARDS BOARD ("FASB") IMPLEMENTED A NEW LEASE ACCOUNTING STANDARD THAT BECAME EFFECTIVE FOR ST. FRANCIS COLLEGE IN THE YEAR ENDING JUNE 30, 2021. THIS ACCOUNTING STANDARD WAS EFFECTUATED TO IMPROVE THE TRANSPARENCY SURROUNDING KEY INFORMATION PERTAINING TO AN EXEMPT ORGANIZATION'S LEASING ARRANGEMENTS (AND TO ENSURE THAT ALL ORGANIZATIONS WERE RECORDING THE TRANSACTIONS UNIFORMLY ON THEIR BALANCE SHEETS). 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 1 0 1 SCHEDULE E, PART I, LINE 3 THE COLLEGE PUBLICIZES ITS RACIALLY NON-DISCRIMINATORY POLICY ON ITS WEBSITE. SCHEDULE E, PART I, LINE 6 FINANCIAL ASSISTANCE IS PROVIDED TO OUR STUDENTS BY THE U.S. DEPARTMENT OF EDUCATION THROUGH FEDERALLY FUNDED CAMPUS BASED PROGRAMS - FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANT (FSEOG), FEDERAL WORK STUDY (FWS) AND THE FEDERAL PERKINS LOAN PROGRAM. ADDITIONALLY, ST. FRANCIS COLLEGE WAS ALSO PROVIDED FINANCIAL ASSISTANCE BY THE U.S. DEPARTMENT OF EDUCATION THROUGH HIGHER EDUCATION EMERGENCY RELIEF FUND GRANTS TO PROVIDE EMERGENCY FINANCIAL AID TO STUDENTS IMPACTED BY THE COVID-19 PANDEMIC. CENTRAL AMERICA AND THE CARIBBEAN 0 0 INVESTMENTS 9631076 0 0 0 0 0 0 9631076 0 9631076 1 0 1 0 1 0 PART III ACCOUNTING METHOD: SCHEDULE F, PART IV ST. FRANCIS COLLEGE INVESTS DIRECTLY IN VARIOUS ALTERNATIVE INVESTMENTS THAT MAY BE ORGANIZED AS EITHER FOREIGN CORPORATIONS OR FOREIGN PARTNERSHIPS; IT LIKEWISE, INVESTS IN DOMESTIC LIMITED PARTNERSHIPS THAT MAY, IN TURN, INVEST IN FOREIGN CORPORATIONS OR PARTNERSHIPS. NEVERTHELESS, SFC'S INVESTMENT ACTIVITIES MAY NOT REACH THE THRESHOLDS REQUIRED FOR THE FILING OF FORMS 926, 5471, 8621, OR 8865. TO THE EXTENT THAT SFC IS REQUIRED TO COMPLETE ONE (OR MORE) OF THESE FOREIGN FORMS, THEY ARE FILED WITH THE FORM 990-T FILING. GOLF OUTINGS 62452 2175 60277 20356 6344 6074 AWARD DINNER 700 700 1711 63152 2175 60977 20356 6344 7785 34485 26492 1 COLLEGE FUNDED SCHOLARSHIPS 2331 31208095 SUPPLEMENTAL EQUAL OPPORTUNITY GRANT 192 361263 FEDERAL WORK STUDY 78 152677 AID P.T.S. AWARDS 6 6000 PART I, LINE 2: THE COLLEGE AWARDS FEDERAL AND STATE GRANTS BASED UPON FINANCIAL NEED. COLLEGE FUNDED INSTITUTIONAL AND ENDOWED GRANTS/SCHOLARSHIPS ARE AWARDED BASED UPON FINANCIAL NEED AND ACADEMIC MERIT. THE COLLEGE MONITORS THESE GRANTS AND AWARDS BY SEMESTER TO VERIFY THAT RECIPIENTS ARE MAINTAINING THE MINIMUM STANDARDS REQUIRED TO RECEIVE THE GRANT OR AWARD. X 1 1 X X X X X 0 0 0 0 0 0 0 0 0 MIGUEL MARTINEZ-SAENZ PRESIDENT 406130 0 0 0 0 0 30500 0 237267 0 673897 0 0 0 MONIQUE MOORE PRYOR THRU 623 CHIEF EGMNT. & EXT. AFFAIRS OFFICER 234715 0 0 0 850 0 25065 0 41464 0 302094 0 0 0 HAYLEY DRYER VP AND GENERAL COUNSEL 248148 0 0 0 0 0 6815 0 15975 0 270938 0 0 0 KEVIN O'ROURKE VP OF FACILITIES 200302 0 0 0 630 0 21264 0 42368 0 264564 0 0 0 TIMOTHY J HOULIHAN FACULTY/FORMER PROVOST 213697 0 0 0 600 0 21497 0 27943 0 263737 0 0 0 MAUREEN LAWRENCE CHIEF FINANCE OFFICER 237007 0 0 0 0 0 23531 0 2429 0 262967 0 0 0 ALLEN BURDOWSKI DEAN OF SCIENCES 232142 0 0 0 0 0 20844 0 1910 0 254896 0 0 0 JENNIFER LANCASTER VP FOR ACADEMIC AFFAIRS 225165 0 0 0 0 0 22405 0 982 0 248552 0 0 0 DENNIS ANDERSON AS OF 062023 PROVOST/SVP FOR ACADEMIC AFFAIRS 213496 0 0 0 140 0 16936 0 13966 0 244538 0 0 0 REZA FAKHARI VP OF INTERNATIONALIZATION 215369 0 0 0 0 0 21485 0 6519 0 243373 0 0 0 PART I, LINE 1A HOUSING ALLOWANCE IN CALENDAR YEAR 2022, ST. FRANCIS COLLEGE PROVIDED THE PRESIDENT, MIGUEL MARTINEZ-SAENZ, WITH HOUSING IN CLOSE PROXIMITY TO THE CAMPUS AS REQUIRED AS A CONDITION UNDER HIS CONTRACT AND IN ORDER TO BE AVAILABLE 24/7 TO RESPOND TO EMERGENT SITUATIONS, ENTERTAIN POTENTIAL DONORS AND OTHER COLLEGE GUESTS AND CONDUCT BUSINESS AS AN EXTENSION OF CAMPUS. THE VALUE OF THE HOUSING IS REPORTED AS $194,598 WHICH IS INCLUDED WITHIN THE NONTAXABLE BENEFITS REPORTED ON SCHEDULE J, PART II, COLUMN D. SUBSTANTIAL CONTRIBUTOR SUBSTANTIAL CONTRIBUTOR 550000 CONSULTING SERVICES 0 SCH L, PART IV: THE TRANSACTION WAS AT ARMS-LENGTH AND THE DONATIVE RELATIONSHIP HAD NO BEARING ON THE TRANSACTION. FORM 990, PRINCIPAL OFFICER: EFFECTIVE AUGUST 2022, TIM CECERE WAS APPOINTED AS COO AND THEN HE TOOK ON THE POSITION OF ACTING PRESIDENT IN MARCH OF 2023, WHILE FORMER PRESIDENT, MIGUEL MARTINEZ-SAENZ, IS ON LEAVE. FORM 990, PART III, LINE 3 ON MARCH 31, 2023, THE COLLEGE SOLD THE REMSEN PROPERTY FOR $160,000,000 TO A THIRD-PARTY BUYER AS PART OF THE PHYSICAL RELOCATION OF ITS PRIMARY CAMPUS. THE MOVE HAS PROVIDED AN UPDATED, STATE OF THE ART CAMPUS FOR OUR STUDENTS, STAFF, FACULTY AND COMMUNITY. NOT ONLY DOES IT PROVIDES A MORE FLEXIBLE AND EFFECTIVE LEARNING AND WORKPLACE ENVIRONMENT, IT IS ALSO MORE EASILY ACCESSIBLE BY NOW BEING FULLY ADA COMPLIANT AND MORE CONVENIENT TO REACH VIA PUBLIC TRANSPORTATION FOR THE STUDENT BODY WHICH IS PREDOMINANTLY A COMMUTER POPULATION. FORM 990, PART VI, SECTION A, LINE 2 RELATIONSHIP DISCLOSURE WILLIAM F. DAWSON AND MARY BETH DAWSON HAVE A FAMILY RELATIONSHIP. FORM 990, PART VI, SECTION B, LINE 11B FORM 990 REVIEW PROCESS THE FORM 990 IS PREPARED BY A NATIONALLY RECOGNIZED ACCOUNTING FIRM IN CONJUNCTION WITH THE ORGANIZATION'S FINANCE DEPARTMENT. ONCE THE PREPARATION AND REVIEW PROCESS IS COMPLETE, THE FULL 990 IS PROVIDED TO THE AUDIT COMMITTEE FOR REVIEW AND APPROVAL. UPON APPROVAL, A COPY OF THE FULL 990 IS PROVIDED TO ALL BOARD MEMBERS FOR REVIEW AND APPROVAL PRIOR TO FILING. FORM 990, PART VI, SECTION B, LINE 12C CONFLICT OF INTEREST POLICY ENFORCEMENT AND MONITORING THE CONFLICT OF INTEREST POLICY IS DISTRIBUTED TO ALL FACULTY, STAFF, AND ADMINISTRATION EVERY YEAR. CERTAIN EMPLOYEES ARE REQUIRED TO SIGN THE QUESTIONNAIRE AND DISCLOSE ANY CONFLICTS. ALL MEMBERS OF THE BOARD OF TRUSTEES ARE REQUIRED TO REVIEW THE POLICY AND SIGN AND COMPLETE A QUESTIONNAIRE ON AN ANNUAL BASIS, DISCLOSING POTENTIAL CONFLICTS. THE EXECUTIVE COMMITTEE OF THE BOARD MONITORS AND ENFORCES COMPLIANCE. IN THE EVENT A TRUSTEE, OFFICER OR KEY EMPLOYEE PLANS TO INITIATE OR PARTICIPATE IN A TRANSACTION, ARRANGEMENT OR ACTIVITY WITH OR ON BEHALF OF THE COLLEGE IN WHICH HE HAS A MATERIAL FINANCIAL INTEREST OF ANY NATURE, SUCH PERSON MUST DISCLOSE SUCH INTEREST TO THE AUDIT COMMITTEE OF THE COLLEGE BOARD OF TRUSTEES (THE "COMMITTEE") BEFORE COMMENCING SUCH ACTIVITY. AFTER DISCLOSURE OF ALL RELEVANT INFORMATION, THE DISCLOSING PERSON MAY MAKE A PRESENTATION AT THE COMMITTEE MEETING. AFTER SUCH PRESENTATION, THE COMMITTEE SHALL, IN ABSENCE OF THE DISCLOSING PERSON, DISCUSS AND VOTE ON, THE TRANSACTION, ARRANGEMENT OR ACTIVITY AND DETERMINE WHETHER A CONFLICT OF INTEREST EXISTS. IF THE DISCLOSING PERSON IS A MEMBER OF THE COMMITTEE, SUCH PERSON SHALL ABSTAIN FROM DELIBERATIONS AND VOTING, AND THE DISINTERESTED MEMBERS OF THE COMMITTEE SHALL MAKE THE DETERMINATION IN ABSENCE OF SUCH PERSON. THE DISCLOSING PERSON SHALL NOT IN ANY WAY IMPROPERLY INFLUENCE THE DELIBERATION OR VOTING ON THE TRANSACTION, ARRANGEMENT OR ACTIVITY GIVING RISE TO A POTENTIAL CONFLICT. THE COMMITTEE WILL REVIEW ALL RELEVANT INFORMATION. THE REVIEW PROCESS WILL BE DESIGNED TO PROTECT CONFIDENTIAL INFORMATION TO THE DEGREE PERMITTED BY LAW. THE COMMITTEE WILL MAKE A DETERMINATION AS TO WHETHER A SITUATION IS PERMISSIBLE OR A CONFLICT OF INTEREST EXISTS, WHICH SHALL BE FINAL, SUBJECT TO RATIFICATION BY THE ENTIRE BOARD AT ITS NEXT MEETING. IF THE COMMITTEE HAS REASONABLE CAUSE TO BELIEVE THAT A TRUSTEE, OFFICER OR KEY EMPLOYEE HAS KNOWINGLY FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT OF INTEREST, IT SHALL INFORM SUCH PERSON OF THE BASIS FOR SUCH BELIEF AND AFFORD SUCH PERSON AN OPPORTUNITY TO EXPLAIN THE ALLEGED FAILURE TO DISCLOSE. IF, AFTER RECEIVING THE RESPONSE OF THE INDIVIDUAL AND MAKING SUCH FURTHER INVESTIGATION AS MAY BE WARRANTED IN THE CIRCUMSTANCES, THE COMMITTEE DETERMINES THAT THE TRUSTEE, OFFICER OR KEY EMPLOYEE HAS IN FACT KNOWINGLY FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT OF INTEREST, IT SHALL TAKE APPROPRIATE DISCIPLINARY ACTION WHICH MAY INCLUDE A RECOMMENDATION TO THE ENTIRE BOARD FOR THE REMOVAL OF THE TRUSTEE OR OFFICER FOR THE DISCHARGE OF THE KEY EMPLOYEE IN ACCORDANCE WITH THE BYLAWS AND POLICIES AND PROCEDURES OF THE COLLEGE AND THE LAWS OF THE STATE OF NEW YORK. FORM 990, PART VI, SECTION B, LINE 15 PROCESS FOR DETERMINING COMPENSATION THE COLLEGE ENGAGED AN INDEPENDENT CONSULTANT IN JUNE 2020 TO REVIEW AND COMPARE THE COMPENSATION OF TOP MANAGEMENT TO SIMILAR INSTITUTIONS IN A COMPENSATION STUDY. A COMPENSATION SURVEY WAS PERFORMED REGARDING COMPENSATION OF OTHER OFFICERS. COMPENSATION DECISIONS AND REPORTS ARE CONTEMPORANEOUSLY DOCUMENTED IN THE BOARD MINUTES WHEN THE DECISIONS ARE MADE. THIS PROCESS IS PERFORMED BIANNUALLY AND WILL BE CONDUCTED AGAIN IN THE FUTURE. FORM 990, PART VI, SECTION C, LINE 19 PUBLIC DISCLOSURE OF DOCUMENTS THE AUDITED FINANCIAL STATEMENTS AND CONFLICT OF INTEREST POLICY ARE AVAILABLE ON THE COLLEGE'S WEBSITE AT WWW.SFC.EDU. GOVERNING DOCUMENTS ARE MADE AVAILABLE UPON REQUEST AT MANAGEMENT'S DISCRETION.