2024-11-14T15:00:13-06:00 2023-12-31 135565207 KPMG LLP 350 N 5TH ST SUITE 600 MINNEAPOLIS MN 55401 990 2023-01-01 472237488 ECMC EDUCATION INC ECMC 6512210566 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 MARTIN A SCANLON CFO & TREASURER 6512210566 2024-11-14 1 0 HOLLY K MOEN P01800653 6123055000 2023 2024-10-15 13:58:12Z ALTIERUS CAREER COLLEGE DANIEL S FISHER 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 31590718 0 X WWW.ECMCEDUCATION.ORG X 2014 DE TO TRANSFORM CAREER AND TECHNICAL EDUCATION TO PROVIDE ASPIRING AND CURRENT LEARNERS WITH SKILLS TO ELEVATE THEIR CARRERS AND COMMUNITIES. 9 8 82 0 0 0 27213516 18983184 16279524 386025 0 977091 2612 11244418 43495652 31590718 1924278 47329 0 0 18521013 3251067 0 0 0 29323910 9560385 49769201 12858781 -6273549 18731937 11798068 5890322 53189778 28550095 -41391710 -22659773 X ECMC EDUCATION, INC.'S MISSION IS TO TRANSFORM CAREER AND TECHNICAL EDUCATION TO PROVIDE ASPIRING AND CURRENT LEARNERS WITH SKILLS TO ELEVATE THEIR CAREERS AND COMMUNITIES. 0 0 6687221 386025 INSTRUCTION AND STUDENT SERVICES:ECMC EDUCATION, INC., DBA ALTIERUS CAREER COLLEGE, IS A NONPROFIT PROVIDER OF CAREER SCHOOL TRAINING IN THE POSTSECONDARY EDUCATION INDUSTRY OFFERING EDUCATIONAL OPPORTUNITIES WITH AN EMPHASIS IN ALLIED HEALTH AND TRADES. ECMC EDUCATION, INC. ENGAGES WITH FACULTY, INDUSTRY LEADERS, AND EMPLOYERS TO HELP IDENTIFY SKILLS, COMPETENCIES, BEHAVIORS AND CERTIFICATIONS THAT FIT THE NEEDS OF THE MARKETPLACE AND ENHANCE EACH GRADUATE'S ABILITY TO FIND A JOB IN HIS OR HER CHOSEN FIELD. THE SCHOOLS ARE ACCREDITED TO GRANT DIPLOMA AND ASSOCIATE DEGREES. ECMC EDUCATION, INC. SERVES A NON-TRADITIONAL, UNDERSERVED STUDENT POPULATION: 65% OF ECMC EDUCATION, INC. STUDENTS ARE ELIGIBLE FOR PELL GRANTS (54% ARE ELIGIBLE FOR FULL PELL GRANTS); 73% OF ECMC EDUCATION, INC.'S STUDENT BODY IS FEMALE; 87% OF STUDENTS ARE NON-WHITE; 58% OF STUDENTS ARE OLDER THAN 25 YEARS OLD; 62% OF ECMC EDUCATION, INC.'S STUDENTS ARE FIRST-TIME, FIRST-YEAR COLLEGE STUDENTS; AND ONLY 16% OF STUDENTS DEPEND UPON THEIR PARENTS OR GUARDIANS' FINANCIAL RESOURCES. ECMC EDUCATION, INC. DELIVERS SERVICES THAT MAKE A STUDENT'S TRANSITION FROM HIGH SCHOOL TO A POSTSECONDARY INSTITUTION AS EASY AND STRAIGHTFORWARD AS POSSIBLE. ECMC EDUCATION, INC. DELIVERS A HOLISTIC LEARNING EXPERIENCE BY PROVIDING STUDENTS WITH INDIVIDUALIZED ACADEMIC SUPPORT THROUGH ACADEMIC COUNSELING, TUTORING AND REMEDIAL EDUCATION SERVICES THAT FURNISH TOOLS AND RESOURCES NECESSARY FOR SUCCESSFUL PROGRAM COMPLETION; FINANCIAL LITERACY COUNSELING TO ASSIST STUDENTS IN MANAGING THEIR STUDENT LOANS AND TO HELP MINIMIZE THEIR STUDENT LOAN DEBT; AND CAREER COUNSELING TO PROMOTE MEANINGFUL EMPLOYMENT AFTER GRADUATION IN THE STUDENT'S FIELD OF STUDY.LEARNING RESOURCE CENTERS ON ECMC EDUCATION, INC. CAMPUSES SUPPORT ACADEMIC PROGRAMS BY PROVIDING BOOKS, SHOP AND SERVICE MANUALS, PERIODICALS, COMPUTERS AND CURRICULUM-BASED ONLINE RESOURCES. THE LEARNING RESOURCE CENTERS ARE STAFFED WITH TRAINED PROFESSIONALS TO ASSIST IN THE RESEARCH NEEDS OF STUDENTS AND FACULTY.THE EDUCATION STUDENTS RECEIVE EMPHASIZES EMPLOYABILITY AND PROFESSIONAL ACCOMPLISHMENT. THE ACADEMIC AND CAREER SUCCESS OF OUR GRADUATES IS PARAMOUNT. ECMC EDUCATION, INC.'S HOLISTIC APPROACH FOCUSES ON THE GOAL OF GRADUATION AND JOB PLACEMENT, EMPHASIZING STUDENT ATTENDANCE, OVERALL ATTITUDE, ACADEMIC PERFORMANCE AND SELF-DIRECTED JOB SEARCH SKILLS ACQUIRED THROUGH WORKING WITH THE CAREER SERVICES STAFF. ECMC EDUCATION, INC.'S CAREER SERVICES EXPERTS PROVIDE STUDENTS WITH PLACEMENT ASSISTANCE, INCLUDING PREPARATION OF RESUMES AND LETTERS OF INTRODUCTION, INTERVIEWING TECHNIQUES AND JOB REFERRALS. ECMC EDUCATION, INC. CAREER SERVICES PROFESSIONALS ALSO ARRANGE ON-CAMPUS EMPLOYER VISITS, LECTURES, CAREER FAIRS AND FIELD TRIPS TO ENHANCE THE LIKELIHOOD THAT STUDENTS WILL OBTAIN WELL-PAYING JOBS. ECMC EDUCATION, INC. ALSO OFFERS STUDENT ACTIVITIES THAT ENCOURAGE SCHOOL SPIRIT AND DEVELOP STUDENT LEADERSHIP, INCLUDING INTRAMURAL SPORTS, CLUBS, PROFESSIONAL DEVELOPMENT PROGRAMS, RESOURCE FAIRS AND OTHER EXTRACURRICULAR ACTIVITIES PLANNED YEAR-ROUND. ON MARCH 31, 2022, A PLAN FOR LIQUIDATION FOR ECMC EDUCATION, INC. AND ALL THREE OF ITS ALTIERUS SCHOOLS WAS APPROVED BY THE ECMC GROUP, INC. BOARD OF DIRECTORS. THE TEACH-OUTS WERE COMPLETED DURING 2023 WITH RELATED EXPENSES BEING SETTLED THROUGH 2027. ECMC EDUCATION, INC. NO LONGER ENROLLS ANY STUDENTS AS OF DECEMBER 31, 2023. THE CHANGE IS PART OF ECMC GROUP, INC.'S PLAN TO CONCENTRATE PRIMARILY ON ITS EDUCATIONAL CREDIT MANAGEMENT CORPORATION GUARANTOR-RELATED ACTIVITIES, ECMC FOUNDATION AND EDUCATION IMPACT INVESTING. 47329 47329 GRANTS AND SCHOLARSHIPS:ECMC EDUCATION, INC. OFFERS THE FOLLOWING SCHOLARSHIP AND GRANT PROGRAMS TO MAKE COLLEGE AFFORDABLE FOR OUR STUDENTS: ALTIERUS GRANTS, IN IT TOGETHER SCHOLARSHIPS, EMPLOYEE AND MILITARY SCHOLARSHIPS. FUNDS ARE AVAILABLE TO PAY FOR TUITION, BOOKS AND FEES.THE ALTIERUS GRANT IS AN INSTITUTIONAL GRANT PROGRAM AWARDED ON AN ANNUAL BASIS TO STUDENTS OF ALTIERUS SCHOOLS OWNED BY ECMC EDUCATION, INC. WHO DEMONSTRATE FINANCIAL NEED. THE AMOUNT AND SOURCE OF THE GRANT, WHICH CAN BE UP TO $10,000 PER ACADEMIC YEAR, IS AVAILABLE FOR NEW AND CONTINUING STUDENTS AND MAY VARY BY STUDENT BASED ON THE DEMONSTRATED FINANCIAL ASSISTANCE NEEDED AND INSTITUTIONAL GRANT FUNDING AVAILABILITY. ALTIERUS MILITARY SCHOLARSHIPS OFFER UP TO 10% OF TUITION PER TERM OR ACADEMIC PERIOD FOR THEIR SPOUSES, AS WELL AS FOR VETERANS AND THEIR DEPENDENTS USING VA EDUCATION BENEFITS. AS OF DECEMBER 31, 2023, ECMC EDUCATION, INC. NO LONGER ENROLLS ANY STUDENTS AND VOLUNTARILY CEASED PARTICIPATION WITH TITLE IV PROGRAMS IN ALIGNMENT WITH THE PLANNED CLOSURES OF THE THREE CAMPUSES DURING 2023. 6734550 1 1 0 0 0 0 0 0 0 0 0 0 0 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 1 97 0 82 1 0 0 0 0 0 0 0 0 0 0 0 1 X 9 8 0 0 0 0 1 1 1 1 1 0 0 1 1 1 1 1 1 1 1 0 CA GA MN X MARTIN A SCANLON 6512210566 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 X DANIEL FISHER PRESIDENT & CEO, ECMC GROUP 0.00 40.00 X X 0 1268659 126730 JAMES V MCKEON DIRECTOR 1.00 16.00 X 0 197500 0 DIANA J INGRAM DIRECTOR 1.00 11.00 X 0 151250 0 JACK O'CONNELL DIRECTOR 1.00 9.00 X 0 145000 0 JULIA S GOUW DIRECTOR 1.00 9.00 X 0 155000 0 DEREK LANGHAUSER DIRECTOR 1.00 8.00 X 0 137500 0 JAMES RUNCIE DIRECTOR 1.00 10.00 X 0 128750 0 JENNIFER ANDERSON DIRECTOR 1.00 9.00 X 0 148750 0 K PAUL SINGH BOARD CHAIR 1.00 11.00 X 0 141875 0 JACOB KASSUBA VP, CAMPUS OPERATIONS 40.00 0.00 X 245835 0 49589 JONI KURLAND VP, ACCRED, LIC & CAMPUS COMPLIANCE 40.00 0.00 X 216054 0 12870 BRIAN BOARDMAN GENERAL COUNSEL & CORP SECRETARY 0.00 40.00 X 0 453655 86354 MARTIN SCANLON CFO & TREASURER 0.00 40.00 X 0 918311 104819 SHARON CLAY CAMPUS DIRECTOR-THRU 11/23 40.00 0.00 X 207143 0 22956 LYN CROSS ASSC VP, FIN AID OPS-THRU 11/23 40.00 0.00 X 187856 0 29183 CHRISTIAN JAHNSEN MGR, CENTRAL REGISTRAR-THRU 7/23 40.00 0.00 X 120341 0 12480 TIM DENGLER CAMPUS DIRECTOR-THRU 4/23 40.00 0.00 X 115974 0 10747 VICTOR CORNIER PROG CHAIR, SURGICAL TECH-THRU 11/23 40.00 0.00 X 113989 0 18728 I KING JORDAN FORMER DIRECTOR 0.00 0.00 X 0 30000 0 JOHN F DEPODESTA FORMER BOARD CHAIR 0.00 0.00 X 0 60000 0 JEREMY WHEATON FORMER PRESIDENT & CEO, ECMC GROUP 0.00 0.00 X 0 1622127 0 1207192 5558377 474456 9 1 1 0 CHESTNUT RIDGE CONSTRUCTION INC 407 HOLLISTER LANE NEW ALEXANDRIA PA 15670 FACILITY SERVICES 591760 JONES LANG LASALLE AMERICAS INC 71700 TREASURY CTR LOCKBOX 33845 CHICAGO IL 60694 FACILITY SERVICES 480223 KUSTOM US INC 3307 E KILGORE RD KALAMAZOO MI 49001 FACILITY SERVICES 212836 KITTO SHEDS & EQUIPMENT 136 KITTO LANE DUNDEE FL 33838 FACILITY SERVICES 122499 4 18959896 23288 18983184 INSTRUCTION 611310 386025 386025 386025 977091 0 977091 977091 977091 LIQUIDATION ADJUSTMENT 900099 11241884 11241884 INTERCOMPANY SERVICING 900099 2534 2534 11244418 31590718 386025 0 12221509 47329 47329 524350 295425 228925 2088414 1573274 515140 97829 68060 29769 378451 335968 42483 162023 123302 38721 24755 24755 123830 123830 729558 623845 105713 130275 77754 52521 328989 13587 315402 1749923 1739231 10692 85430 45620 39810 5666 2471 3195 30400 30400 10096 10096 636665 632297 4368 IMPAIRMENT 3615590 3615590 LEGAL SETTLEMENTS 1067341 1067341 EXCISE TAX EXPENSE 959896 959896 BOOKSTORE 20765 20765 41206 37881 3325 12858781 6734550 6124231 0 5963042 4434264 251029 0 1061374 0 0 0 0 0 4522623 1456058 11798068 5890322 28721198 12635253 244120 0 24224460 15914842 53189778 28550095 X -41391710 -22659773 -41391710 -22659773 11798068 5890322 18731937 0 X 0 1 X 1 0 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 RIGHT OF USE ASSET 1422715 SECURITY DEPOSITS RECEIVABLE 33343 1456058 LEASE INCENTIVE OBLIGATION 15761178 DUE TO ECMC GROUP, INC. 76413 DUE TO EDUCATIONAL CREDIT MANAGEMENT CORPORATION 6708 DUE TO ECMC SHARED SERVICES COMPANY, LLC 70543 15914842 X 364518 0 364518 31226200 31226200 31590718 -367419 -11241884 -11241884 10874465 1984316 1984316 12858781 PART X, LINE 2: ECMC EDUCATION IS EXEMPT FROM TAX ON RELATED INCOME UNDER SECTION 501(C)(3) AND QUALIFIES AS A PUBLIC CHARITY UNDER SECTION 509(A)(2) OF THE INTERNAL REVENUE CODE. EDUCATION IS ALSO EXEMPT FROM STATE INCOME TAX. HOWEVER, ANY UNRELATED BUSINESS INCOME MAY BE SUBJECT TO TAXATION. EDUCATION FOLLOWS THE ACCOUNTING STANDARDS FOR CONTINGENCIES IN EVALUATING UNCERTAIN TAX POSITIONS. THIS GUIDANCE PRESCRIBES RECOGNITION THRESHOLD PRINCIPLES FOR THE FINANCIAL STATEMENT RECOGNITION OF TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN ON A TAX RETURN THAT ARE NOT CERTAIN TO BE REALIZED. NO LIABILITY HAS BEEN RECOGNIZED BY EDUCATION FOR UNCERTAIN TAX POSITIONS AS OF DECEMBER 31, 2023 AND 2022. EDUCATION'S TAX RETURNS ARE SUBJECT TO REVIEW AND EXAMINATION BY FEDERAL AND STATE AUTHORITIES. PART XI, LINE 4B - OTHER ADJUSTMENTS: SEOG GRANT FA MATCH 24,901. SCHOLARSHIPS AND FINANCIAL ASSISTANCE 22,428. CONTRIBUTIONS FROM ECMC GROUP, INC. 18,959,896. GAIN FROM SALES OF FIXED ASSETS 977,091. LIQUIDATION ADJUSTMENT 11,241,884. PART XII, LINE 2D - OTHER ADJUSTMENTS: LIQUIDATION ADJUSTMENT -11,241,884. PART XII, LINE 4B - OTHER ADJUSTMENTS: SEOG GRANT FA MATCH 24,901. SCHOLARSHIPS AND FINANCIAL ASSISTANCE 22,428. EXPENSE ACCRUED BY ECMC GROUP, INC. ON BEHALF OF ECMC EDUCATION, INC. FOR SECTION 4968 EXCISE TAX ON NET INVESTMENT INCOME OF ECMC GROUP, INC. & SUBS 959,896. GAIN FROM SALES OF FIXED ASSETS 977,091. 1 1 0 1 1 1 0 0 0 0 0 0 0 0 0 1 0 1 SCHEDULE E, PART I, LINE 3 ECMC EDUCATION, INC.'S RACIALLY NONDISCRIMINATORY POLICY IS PUBLISHED IN THE SCHOOL CATALOG, IN MATERIALS PROVIDED TO PROSPECTIVE STUDENTS AND TO MATRICULATED STUDENTS. IN ACCORDANCE WITH IRS REV. PROC. 75-50, SUBSECTION 2(C) APPLIES AS ECMC EDUCATION, INC. DRAWS STUDENTS FROM DIVERSE POPULATIONS AND DOES NOT DISCRIMINATE AGAINST ANY RACE, COLOR, ETHNICITY, NATIONAL ORIGIN OR ANY OTHER PROTECTED CLASS. SCHEDULE E, PART I, LINE 4 NO CONTRIBUTIONS ARE SOLICITED SCHEDULE E, PART I, LINE 6 ECMC EDUCATION, INC. PARTICIPATED IN U.S. DEPARTMENT OF EDUCATION SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANT AND PELL GRANT PROGRAMS. IN APRIL 2023, ECMC EDUCATION, INC. VOLUNTARILY CEASED PARTICIPATION WITH TITLE IV PROGRAMS IN ALIGNMENT WITH THE PLANNED CLOSURES OF THE THREE REMAINING CAMPUSES IN 2023. 1 STUDENT SCHOLARSHIPS & FINANCIAL ASSISTANCE 15 47329 PART I, LINE 2: A VARIETY OF STUDENT FINANCING OPTIONS ARE AVAILABLE TO HELP STUDENTS FINANCE THEIR EDUCATION COSTS. ENROLLMENT AND ELIGIBILITY IN ECMC EDUCATION, INC. SCHOLARSHIPS AND GRANTS ARE MONITORED INTERNALLY. OTHER AWARDS ARE MONITORED BY THE RESPECTIVE GRANTING AGENCIES. X X 1 1 X X X X 1 1 0 0 1 0 1 0 0 JEREMY WHEATON FORMER PRESIDENT & CEO, ECMC GROUP 0 0 0 0 0 1622127 0 0 0 0 0 1622127 0 122127 DANIEL FISHER PRESIDENT & CEO, ECMC GROUP 0 565637 0 676489 0 26533 0 91123 0 35607 0 1395389 0 22500 MARTIN SCANLON CFO & TREASURER 0 417201 0 475795 0 25315 0 74390 0 30429 0 1023130 0 22500 BRIAN BOARDMAN GENERAL COUNSEL & CORP SECRETARY 0 285326 0 160921 0 7408 0 45095 0 41259 0 540009 0 4902 JACOB KASSUBA VP, CAMPUS OPERATIONS 178412 0 65775 0 1648 0 11776 0 37813 0 295424 0 0 0 SHARON CLAY CAMPUS DIRECTOR-THRU 11/23 104492 0 51324 0 51327 0 2644 0 20312 0 230099 0 0 0 JONI KURLAND VP, ACCRED, LIC & CAMPUS COMPLIANCE 165000 0 49500 0 1554 0 12870 0 0 0 228924 0 0 0 LYN CROSS ASSC VP, FIN AID OPS-THRU 11/23 89612 0 30000 0 68244 0 8415 0 20768 0 217039 0 0 0 JAMES V MCKEON DIRECTOR 0 197500 0 0 0 0 0 0 0 0 0 197500 0 0 JULIA S GOUW DIRECTOR 0 155000 0 0 0 0 0 0 0 0 0 155000 0 0 DIANA J INGRAM DIRECTOR 0 151250 0 0 0 0 0 0 0 0 0 151250 0 0 JOHN F DEPODESTA FORMER BOARD CHAIR 0 60000 0 0 0 0 0 0 0 0 0 60000 0 0 I KING JORDAN FORMER DIRECTOR 0 30000 0 0 0 0 0 0 0 0 0 30000 0 0 PART I, LINE 1A TAX INDEMNIFICATION AND GROSS-UP PAYMENTS: CERTAIN TAXABLE BENEFITS ARE GROSSED UP TO MAKE THE EMPLOYEE WHOLE; THIS HAS BEEN APPROVED BY THE BOARD OF DIRECTORS. TRAVEL FOR COMPANIONS: ECMC GROUP, INC.'S TRAVEL POLICY HAD AN EXCEPTION THAT WAS APPROVED BY THE CFO (AND DEVIATIONS FROM ANY PROVISION OF THE POLICY MUST BE APPROVED IN WRITING BY AN OFFICER IN CONJUNCTION WITH THE ECMC GROUP, INC. CFO). IN 2023, ECMC EDUCATION, INC. PAID TRAVEL EXPENSES FOR AN ECMC EDUCATION, INC. EMPLOYEE'S SPOUSE TO ATTEND A COMPANY-SPONSORED EVENT. THE EXCEPTION TO POLICY WAS APPROVED. PART I, LINES 4A-B LINE 4A - SEVERANCE OR CHANGE-OF-CONTROL PAYMENT: THE FOLLOWING RECEIVED A SEVERANCE PAYMENT IN 2023: LYN CROSS - $51,423 SHARON CLAY - $48,046 TIM DENGLER - $29,252 CHRISTIAN JAHNSEN - $36,571 VICTOR CORNIER - $22,414 JEREMY WHEATON - $1,500,000 LINE 4B - SUPPLEMENTAL NONQUALIFIED RETIREMENT PLAN: ECMC GROUP, INC. MAINTAINS A SUPPLEMENTAL NONQUALIFIED RETIREMENT PLAN DESCRIBED IN SECTION 457(F), AND A SUPPLEMENTAL EMPLOYEE RETIREMENT PLAN (SERP), TO ATTRACT AND RETAIN EMPLOYEES, TYPICALLY IN MANAGEMENT POSITIONS. IN 2023, DANIEL FISHER AND MARTIN SCANLON PARTICIPATED IN THE 457(F) PLAN, AND RECEIVED EMPLOYER CONTRIBUTIONS OF $32,289 AND $11,248, RESPECTIVELY. PART I, LINE 5 ECMC GROUP, INC.'S ANNUAL OFFICER INCENTIVE PLAN REQUIRES ACHIEVEMENT OF STATED PRIMARY FINANCIAL GOALS, WHICH INCLUDES REVENUES, BEFORE ANY PAYMENT TO ANY OFFICER IS MADE. PART I, LINE 6 ECMC GROUP, INC.'S ANNUAL OFFICER INCENTIVE PLAN REQUIRES ACHIEVEMENT OF STATED KEY PERFORMANCE METRICS, WHICH INCLUDES NET EARNINGS, BEFORE ANY PAYMENT TO ANY OFFICER IS MADE. FORM 990, PART VI, SECTION A, LINE 6 ECMC EDUCATION, INC. HAS ONE MEMBER. THE MEMBER IS ECMC GROUP, INC. A DELAWARE, NONSTOCK, NONPROFIT CORPORATION EXEMPT UNDER SECTION 501(C)(3). THERE ARE NO STOCKHOLDERS. FORM 990, PART VI, SECTION A, LINE 7A ECMC GROUP, INC. HAS THE RIGHT TO ELECT AND/OR APPROVE ALL THE DIRECTORS OF THE ECMC EDUCATION, INC. BOARD OF DIRECTORS. FORM 990, PART VI, SECTION A, LINE 7B ECMC GROUP, INC., THE SOLE MEMBER OF ECMC EDUCATION, INC., RETAINS THE FOLLOWING AUTHORITY OVER ECMC EDUCATION, INC.: 1. TO AUTHORIZE AMENDMENTS TO THE ARTICLES OF INCORPORATION AND BYLAWS. 2. TO APPROVE THE STRATEGIC AND FINANCIAL PLANS. 3. TO ELECT AND/OR APPROVE THE MEMBERS OF THE BOARD OF DIRECTORS. 4. TO OVERSEE COORDINATION OF PROGRAMS AND SERVICES OFFERED. 5. TO AUTHORIZE FORMATION, GOVERNANCE AND DISSOLUTION. FORM 990, PART VI, SECTION B, LINE 11B ALL MEMBERS OF THE BOARD OF DIRECTORS AND EXECUTIVE MANAGEMENT ARE PROVIDED A COPY OF FORM 990 TO REVIEW AND PROVIDE COMMENTS PRIOR TO FILING. ALL MEMBERS OF THE BOARD OF DIRECTORS AND EXECUTIVE MANAGEMENT ARE PROVIDED WITH A COPY OF THE FINAL VERSION OF FORM 990 BEFORE IT HAS BEEN FILED. FORM 990, PART VI, SECTION B, LINE 12C OFFICERS, DIRECTORS AND ALL EMPLOYEES ARE REQUIRED TO REAFFIRM ON AN ANNUAL BASIS THEIR UNDERSTANDING OF THE COMPANY'S CONFLICT OF INTEREST POLICY. THE AFFIRMATION SPECIFICALLY REFERENCES THAT THE INDIVIDUAL WILL COMPLY WITH THE DIRECTIVES OF THE CONFLICT OF INTEREST POLICY. OFFICERS, DIRECTORS AND KEY EMPLOYEES ARE ALSO REQUIRED TO COMPLETE AN ANNUAL FORM 990 RELATIONSHIP DISCLOSURE DOCUMENT TO IDENTIFY ANY POTENTIAL CONFLICTS OF INTEREST. FINALLY, THE COMPANY'S VENDOR PROCUREMENT PROCESS INCLUDES QUESTIONS OF BUSINESS UNIT CONTRACT OWNERS TO DETERMINE IF ANY CONFLICTS OF INTEREST MAY EXIST. MONITORING AND ENFORCEMENT OF THE POLICY ARE ACCOMPLISHED THROUGH THE POLICY REAFFIRMATION PROCESS, AFFIRMATIVE DISCLOSURE REQUESTS AND THE POLICY REQUIREMENT THAT ALL CONFLICTS OF INTEREST BE REPORTED. IN CASES WHERE A POTENTIAL CONFLICT EXISTS AT THE OFFICER AND KEY EMPLOYEE LEVELS, THE ISSUE IS DISCLOSED TO THE INDIVIDUAL'S SUPERVISOR, GENERAL COUNSEL, AND/OR VICE PRESIDENT, DEPUTY GENERAL COUNSEL. FOR POTENTIAL CONFLICTS INVOLVING DIRECTORS, THE DISCLOSURE IS MADE TO THE BOARD (OR APPLICABLE COMMITTEE). THE DIRECTOR WILL BE REQUIRED TO EXCUSE THEMSELVES FROM DELIBERATION AND VOTING ON MATTERS FOR WHICH THEY MAY HAVE A CONFLICT OF INTEREST. FORM 990, PART VI, SECTION B, LINE 15 THE GOVERNANCE & COMPENSATION COMMITTEE OF THE ECMC GROUP, INC. (ECMC EDUCATION, INC.'S PARENT ORGANIZATION) BOARD OF DIRECTORS IS WHOLLY COMPRISED OF INDEPENDENT, OUTSIDE DIRECTORS. IN 2023, THE COMMITTEE RETAINED EXECUTIVE COMPENSATION EXPERTS FROM GRANT THORNTON, PEARL MEYER AND AON, GLOBAL COMPENSATION CONSULTING ORGANIZATIONS, THROUGH ARNOLD & PORTER KAYE SCHOLER LLP TO IDENTIFY APPROPRIATE CEO AND SENIOR EXECUTIVE COMPENSATION PACKAGES. ARNOLD & PORTER KAYE SCHOLER LLP PROVIDED AN OPINION ON THE REASONABLENESS OF THIS COMPENSATION. THE MARKET ANALYSIS PERFORMED BY GRANT THORNTON, PEARL MEYER AND AON FOR ARNOLD & PORTER KAYE SCHOLER LLP INCLUDES SALARY AND INCENTIVE DATA FROM AN APPROPRIATE PEER GROUP UNDER IRS REGULATIONS AND INCLUDES BOTH NONPROFIT AND FOR-PROFIT ENTITIES. FORM 990, PART VI, SECTION C, LINE 19 DOCUMENTS ARE MADE AVAILABLE TO THE PUBLIC AS REQUIRED BY LAW. FORM 990, PART VII, SECTION A: JOHN DEPODESTA AND I. KING JORDAN, FORMER DIRECTORS, HAD CONSULTING AGREEMENTS IN 2023. ECMC GROUP INC 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411991995 EDUCATION FINANCE DE 501(C)(3) LINE 12B TYPE II N/A 0 EDUCATIONAL CREDIT MANAGEMENT CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411778617 GUARANTOR MN 501(C)(3) LINE 10 ECMC GROUP INC 0 ECMC FOUNDATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411990628 PROMOTE EDUCATION DE 501(C)(3) LINE 12B TYPE II ECMC GROUP INC 0 ECMC REVENUE MANAGEMENT CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 831761663 STUDENT LOAN DEFAULT RESOLUTION DE 501(C)(3) LINE 10 EDUCATIONAL CREDIT MANAGEMENT CORPORATION 0 ECMC SERVICES INC 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 831763915 STUDENT LOAN REPAYMENT SERVICES DE 501(C)(3) LINE 10 ECMC GROUP INC 0 AUBREY GEMS PARTNERS LP 800 THIRD AVE 28TH FL NEW YORK NY 10022 365009933 INVESTMENTS NY N/A 0 0 CHLOE CAPITAL FUND I LP 700 CASCADILLA ST STE 201 ITHACA NY 14850 844269068 INVESTMENTS DE N/A 0 0 COMMONFUND CAP SECONDARIES OPP FUND 15 OLD DANBURY RD WILTON CT 06897 842082338 INVESTMENTS DE N/A 0 0 CRP VF IV GP LP 7600 N CAP OF TX HWY BLDG B STE 130 AUSTIN TX 78731 863644095 INVESTMENTS DE N/A 0 0 ECMC-UV CO-INVESTMENT FUND LP 104 W 40TH ST STE 1600 NEW YORK NY 10018 813873029 INVESTMENTS DE N/A 0 0 FUND D-2 A SERIES OF RIOT VENTURES 313 GRAND BLVD 1079 VENICE CA 90291 920652495 INVESTMENTS DE N/A 0 0 GEM MINING 4 LLC 550 S MAIN ST STE 310 GREENVILLE SC 29601 871562792 INVESTMENTS DE N/A 0 0 ONRAMP EDUC & WORKFORCE INNOV FUND 821 E WASHINGTON AVE STE 200-G MADISON WI 53703 843999115 INVESTMENTS DE N/A 0 0 PC-1 DEVELOPERS LLC 3600 MAYBERRY DR RENO NV 89509 831603672 INVESTMENTS NV N/A 0 0 R7 FAMILY FUND LP 100 S WACKER DR STE 1675 CHICAGO IL 60606 851019413 INVESTMENTS DE N/A 0 0 RI FUND I A SERIES OF BOOST VC SPV LP PO BOX 3217 SEATTLE WA 98114 874641779 INVESTMENTS CJ N/A 0 0 TABOR OFFSHORE OPPORTUNITIES LTD 11 E 44TH ST STE 705 NEW YORK NY 10017 INVESTMENTS CJ N/A 0 0 UP FUND I A SERIES OF BOOST VC SPV LP PO BOX 3217 SEATTLE WA 98114 851519551 INVESTMENTS DE N/A 0 0 WY FUND I A SERIES OF BOOST VC SPV LP PO BOX 3217 SEATTLE WA 98114 851519506 INVESTMENTS DE N/A 0 0 BACKFLIP INCOME FUND 2 LLC 1312 17TH ST STE 71618 DENVER CO 80202 932740244 INVESTMENTS DE N/A 0 0 COLT ENERGY OPPORTUNITIES II LLC 2101 CEDAR SPRINGS RD STE 1230 DALLAS TX 75201 933370182 INVESTMENTS TX N/A 0 0 SOLGEN CAPITAL PARTNERS I LP 2000 PGA BLVD STE 4440 PALM BEACH GARDENS FL 33408 921378980 INVESTMENTS DE N/A 0 0 503 WWS INVESTORS LLC 2540 NE MARTIN LUTHER KING JR BLVD PORTLAND OR 97212 921393452 INVESTMENTS DE N/A 0 0 GENGLOBAL CORE LLC 2810 N CHURCH ST PMB 85501 WILMINGTON DE 19802 934209535 INVESTMENTS DE N/A 0 0 GALAHAD INVESTORS EAU CLAIRE LLC 4688 KEYSTONE CROSSING EAU CLAIRE WI 54701 991926788 INVESTMENTS MN N/A 0 0 GALAHAD INVESTORS MAPLEWOOD LLC 1910 COUNTY RD C E MAPLEWOOD MN 55109 991935774 INVESTMENTS MN N/A 0 0 OAKDALE INVESTMENT MANAGEMENT CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 352085743 HOLDING INVESTMENTS DE N/A C 0 ECMC HOLDINGS CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411991992 STRATEGIC OVERSIGHT DE N/A C 0 ECMC RECORDS & RECEIVABLES MANAGEMENT CORPORATION 111 WASHINGTON AVE SO STE 1400 MINNEAPOLIS MN 55401 411989959 DOCUMENT MANAGEMENT DE N/A C 0 0 0 1 0 1 0 0 0 0 0 0 0 1 1 0 1 1 0 0