2024-11-14T14:13:07-06:00 2023-12-31 BDO USA ONE INTERNATIONAL PLACE BOSTON MA 02110 990 2023-01-01 274620963 Social Finance Inc % JOHN WOODS SOCI 6179399900 2 Atlantic Avenue 5th Floor Boston MA 02110 Kirstin Hill President & COO 6179399900 2024-10-22 true true Brian Vigneault P00540650 6174220700 2023 2024-10-15 13:58:12Z Kirstin Hill 2 Atlantic Avenue 5th Floor Boston MA 02110 37740714 false X www.socialfinance.org X 2011 MA SOCIAL FINANCE IS A NATIONAL IMPACT FINANCE AND ADVISORY NONPROFIT. WE WORK WITH PUBLIC, PRIVATE, AND SOCIAL SECTORS TO BUILD INNOVATIVE (CONTINUED ON SCHEDULE O.) 17 16 144 16 0 0 65663400 24185912 7594640 11064040 124327 3773111 21450 193882 73403817 39216945 228000 1644263 0 0 16027535 20085571 0 0 229085 7037376 9846079 23292911 31575913 50110906 7641032 153587163 158209325 20054853 21001572 133532310 137207753 X SOCIAL FINANCE IS A NATIONAL IMPACT FINANCE AND ADVISORY NONPROFIT. OUR AIM IS SIMPLE: TO PRODUCE MEANINGFUL OUTCOMES THAT SPARK SOCIAL CHANGE. BY WORKING WITH PUBLIC, PRIVATE, AND SOCIAL SECTORS, WE CREATE PARTNERSHIPS AND INVESTMENTS TO MEASURABLY IMPROVE LIVES. true false 14948097 64800 4248278 SEE SCHEDULE O 10332768 1579463 7009644 SEE SCHEDULE O 686159 0 0 SEE SCHEDULE O 213281 0 0 26180305 true true false true false false false false false false true false true false true true false true false false true true false false false false false true false true false false false true false false false false false false false false true true true true false false true 40 0 true 144 true false false false false false false false false false false false false X 17 16 false false false false false false false true true false false false true true true true false true true false CA MA NY X X JOHN WOODS 6179399900 2 ATLANTIC AVENUE 5TH FLOOR Boston MA 02110 X TRACY PALANDJIAN President & CEO 40.0 0.0 X X 504220 0 39411 MICHAEL GROSSMAN Managing DIR (until 12/23) 40.0 0.0 X 371726 0 39403 JOHN WOODS Chief Financial Officer 40.0 0.0 X 267340 0 44354 JACOB SEGAL Managing Director 40.0 0.0 X 266331 0 36782 NAVJEET K BAL MANAGING DIR & GENERAL COUNSEL 40.0 0.0 X 263220 0 27169 Catherine Cho VP, Impact Investments 40.0 0.0 X 231720 0 32166 JUSTIN BAKULE VP, IMPACT INVESTMENTS 40.0 0.0 X 228655 0 34126 Stephen Vicinelli VP, Impact Investments 40.0 0.0 X 221734 0 34779 Catherine Dun Rappaport VP, Impact Investments 40.0 0.0 X 220731 0 33348 ANDREW C CHEN VP, IMPACT INVESTMENTS 40.0 0.0 X 216700 0 26366 Kirstin Hill President & COO (AS OF 9/23) 40.0 0.0 X 156660 0 0 Karen Anderson MANAGING DIR, SFI (AS OF 9/23) 40.0 0.0 X 86868 0 0 EMILY FRIEDMAN CHIEF ADMIN. 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(UNTIL 2/23) 40.0 0.0 X 72279 0 8186 BRACEBRIDGE H YOUNG JR Chairperson & Director 2.0 0.0 X X 0 0 0 EDWARD L SHAPIRO Vice Chair & Director 2.0 0.0 X X 0 0 0 PAMELA DIPPEL CHONEY Treasurer & Director 2.0 0.0 X X 0 0 0 NANCY ZIMMERMAN Clerk & Director 2.0 0.0 X 0 0 0 Sir Ronald Cohen Director 2.0 0.0 X 0 0 0 Karen Dynan Director 2.0 0.0 X 0 0 0 Doug Henderson Director 2.0 0.0 X 0 0 0 Laura Lauder Director 2.0 0.0 X 0 0 0 Elizabeth Lempres Director 2.0 0.0 X 0 0 0 Andrew Marino Director 2.0 0.0 X 0 0 0 Governor Deval Patrick Director 2.0 0.0 X 0 0 0 Alexa Rachlin Director 2.0 0.0 X 0 0 0 Dr Lauren Smith Director 2.0 0.0 X 0 0 0 Ian Simmons Director 2.0 0.0 X 0 0 0 Laurene Sperling Director 2.0 0.0 X 0 0 0 Sandra A Urie Director 2.0 0.0 X 0 0 0 3108184 0 356090 82 false true false Focus Technology 10 Post Office Square Suite S1005 BOSTON MA 02109 Information tech. 338062 Project Affinity Inc 170 Columbus Avenue Floor 3 SAN FRANCISCO CA 94133 CRM 164649 Social Finance NL BV 64 MAURITSKADE AMSTERDAM 0 NL 1092 AD Generalist Contr. 159892 BDO One International Place BOSTON MA 02110 Accountant 138224 ACA Group 909 Rose Avenue Suite 950 NORTH BETHESDA MD 20852 COMPLIANCE CNSLT 115288 5 432649 23753263 24185912 PROGRAM FEES 541611 10084009 10084009 OUTCOME PAYMENTS 541611 980031 980031 11064040 5249342 5249342 0 0 0 0 0 -1476231 1476231 -1476231 -1476231 0 0 0 0 0 0 0 0 0 OTHER INCOME 541611 193882 193882 193882 39216945 11257922 3773111 1394800 1394800 0 249463 249463 0 2183949 1687712 476503 19734 0 14718217 11383320 3231695 103202 356435 271360 85075 1658913 1273858 320118 64937 1168057 891291 276766 746731 746731 69181 65507 3674 179172 153081 26091 0 0 0 2298040 2181180 88002 28858 216213 199454 15583 1176 523397 429171 90889 3337 785231 610281 174950 0 1234762 940045 294221 496 486607 465283 13979 7345 0 0 447162 447162 0 343801 294432 49369 112925 93317 19608 CLOSE OUT EXPENSES 1159598 1159598 LIVING STIPEND 692673 692673 PROGRAM EVAULATOR (MDRC) 527765 527765 BAD DEBT EXPENSE 4560 4560 18261 18261 31575913 26180305 5166523 229085 3600000 8771935 38348852 34813610 28923504 11638986 2023922 1960715 0 2526178 0 0 3963024 14484850 0 0 378210 695071 1108229 542416 598682 565813 65095910 66535300 0 0 4316021 9207861 0 0 6339038 7009006 153587163 158209325 3711302 3919558 0 0 2833150 1898499 0 0 0 0 0 0 0 0 7650622 7483478 5859779 7700037 20054853 21001572 X 55717949 65844849 77814361 71362904 133532310 137207753 153587163 158209325 X 7641032 352020 -4317609 X false true X true true true X 18715742 9805446 74358353 65663400 24185912 192728853 0 0 18715742 9805446 74358353 65663400 24185912 192728853 59091258 133637595 165350 118040 36973 1415925 5249342 6985630 0 12689 7500 46500 21450 193882 282021 199996504 36692798 0.66820 0.68681 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 244693 71510 173183 512879 365192 147687 350657 105714 244943 565813 UP FUND, LP 3975418 F SOCIAL FINANCE IMPACT FIRST 5232443 F 9207861 0 LEASE LIABILTY 5713169 OTHER LIABILITIES 1986868 7700037 X SCHEDULE D, PART X, LINE 2: THE ORGANIZATION FOLLOWS THE ACCOUNTING STANDARD FOR UNCERTAINTY IN INCOME TAXES. THE STANDARD PRESCRIBES A MINIMUM RECOGNITION THRESHOLD AND MEASUREMENT METHODOLOGY THAT A TAX POSITION TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN IS REQUIRED TO MEET BEFORE BEING RECOGNIZED IN THE CONSOLIDATED FINANCIAL STATEMENTS. IT ALSO PROVIDES GUIDANCE FOR DE-RECOGNITION, CLASSIFICATION, INTEREST AND PENALTIES, DISCLOSURE, AND TRANSITION. SHOULD THERE BE INTEREST ON UNDERPAYMENT OF INCOME TAX, THE ORGANIZATION WOULD CLASSIFY IT AS INTEREST EXPENSE. THE ORGANIZATION WOULD CLASSIFY PENALTIES IN CONNECTION WITH UNDERPAYMENT OF INCOME TAX AS OTHER EXPENSE. THE ORGANIZATION DOES NOT BELIEVE IT HAS TAKEN ANY MATERIAL UNCERTAIN TAX POSITIONS, AND ACCORDINGLY, IT HAS NOT RECORDED ANY LIABILITY FOR UNRECOGNIZED TAX BENEFITS. THE ORGANIZATION HAS FILED FOR AND RECEIVED INCOME TAX EXEMPTIONS IN THE JURISDICTIONS WHERE IT IS REQUIRED TO DO SO. ADDITIONALLY, THE ORGANIZATION HAS FILED ALL APPLICABLE RETURNS IN JURISDICTIONS WHERE SO REQUIRED. FOR THE YEARS ENDED DECEMBER 31, 2023 AND 2022, THERE WERE NO INTEREST OR PENALTIES RECORDED OR INCLUDED IN THE CONSOLIDATED STATEMENTS OF ACTIVITIES. true Europe (Including Iceland and Greenland) 0 0 Grantmaking 249463 0 0 0 0 249463 249463 Europe (Including Iceland and Greenland) TO DISBURSE CERTAIN GIFTS, GRANTS, CONTRIBUTIONS AND OTHER REVENUES TO SUPPORT THE ORGANIZATION'S PROGRAM ACTIVITIES. 249463 wire 1 false false false false false false SCHEDULE F, PART I, LINE 2: AS A FISCAL SPONSOR FOR SOCIAL FINANCE UK (SF UK). SOCIAL FINANCE HAS AGREED TO RECEIVE AND DISBURSE GRANTS IN SUPPORT OF PROJECTS OUTSIDE OF THE US THAT ALIGN WITH OUR MISSION. A FISCAL SPONSORSHIP AGREEMENT, EXECUTED BY BOTH PARTIES, ESTABLISHES THE PROCEDURE FOR MONITORING THESE GRANTS. THE AGREEMENT STATES THAT SOCIAL FINANCE RETAINS OVERSIGHT AUTHORITY TO ENSURE THAT THE FUNDS DISBURSED BY SOCIAL FINANCE TO SF UK ARE USED FOR THEIR INTENDED CHARITABLE PURPOSES, AND SOCIAL FINANCE HAS FULL ACCESS TO THE BOOKS, RECORDS, AND SENIOR MANAGEMENT AND FINANCIAL PERSONNEL OF SF UK WITH RESPECT TO THE SPONSORED ACTIVITIES, UPON REQUEST. THE TWO PARTIES HAVE AGREED TO PARTICIPATE IN REGULAR CALLS WITH DISCUSSION OF SPONSORED ACTIVITIES. PROJECT GOVERNANCE, AND COMPLIANCE WITH GRANT AGREEMENTS. AS APPROPRIATE. FINALLY, SF UK IS TO PROVIDE AN ANNUAL WRITTEN SUMMARY OF SPONSORED ACTIVITIES TO SOCIAL FINANCE TO THE EXTENT NOT COVERED BY REPORTS REQUIRED BY GRANTORS. SCHEDULE F, PART II, COLUMN (D): (A) REGION: EUROPE (INCLUDING ICELAND & GREENLAND) - ALBANIA, ANDORA, AUSTRIA, BELGIUM (D) PURPOSE OF GRANT: TO DISBURSE CERTAIN GIFTS, GRANTS, CONTRIBUTIONS AND OTHER REVENUE TO SUPPORT THE ORGANIZATION'S PROGRAM ACTIVITIES. true MERIT AMERICA 712 H STREET NE SUITE 1560 WASHINGTON DC 20002 842108762 501(C)(3) 64800 SUPPORT 18 KNOCKED OUT OR DENIED BORROWERS INLAND SOUTHERN CALIFORNIA UNITED WAY PO BOX 1613 RIVERSIDE CA 92502 951742174 501(C)(3) 300000 SUBGRANT DISBURSEMENT TO UW IN ORDER TO OPERATE A GUARANTEED INCOME PILOT PROGRAM MCKINLEYVILLE COMMUNITY COLLABORATIVE 1615 HEARTWOOD DR MCKINLEYVILLE CA 95519 680446130 501(C)(3) 930000 SUBGRANT DISBURSEMENT TO MCC IN ORDER TO OPERATE A GUARATEEN INCOME PILOT PROGRAM IFOSTER INC PO BOX 159 TRUCKEE CA 96160 800627614 501(C)(3) 100000 TO OPERATE A GUARANTEED INCOME PILOT PROGRAM 4 SCHEDULE I, PART I, LINE 2: SOCIAL FINANCE HOLDS REGULAR CALLS WITH GRANTEES TO ENSURE ACHIEVEMENT OF GRANT GOALS AND MONITOR COMPLIANCE. ADDITIONALLY, GRANTEES MAY BE PERIODICALLY REQUIRED TO SUBMIT DETAILED FINANCIAL AND PROGRAMMATIC REPORTING. SCHEDULE I, PART II: (1) MERIT AMERICA 712 H STREET NE, SUITE 1560 WASHINGTON, DC 20002 PURPOSE OF GRANT- SUPPORT 18 KNOCKED OUT OR DENIED BORROWERS (2) INLAND SOUTHERN CALIFORNIA UNITED WAY P.O. BOX 1613 RIVERSIDE, CA 92502 PURPOSE OF GRANT- SUBGRANT DISBURSEMENT TO UW IN ORDER TO OPERATE A GUARANTEED INCOME PILOT PROGRAM (3) MCKINLEYVILLE COMMUNITY COLLABORATIVE 1615 HEARTWOOD DR MCKINLEYVILLE, CA 95519 PURPOSE OF GRANT- SUBGRANT DISBURSEMENT TO MCC IN ORDER TO OPERATE A GUARATEEN INCOME PILOT PROGRAM (4) IFOSTER, INC. P.O. BOX 159 TRUCKEE, CA 96160 PURPOSE OF GRANT- TO OPERATE A GUARANTEED INCOME PILOT PROGRAM X X X false false false false false false false false false JUSTIN BAKULE VP, IMPACT INVESTMENTS 215000 0 12935 0 720 0 6450 0 27676 0 262781 0 0 0 NAVJEET K BAL MANAGING DIR & GENERAL COUNSEL 250000 0 12500 0 720 0 7500 0 19669 0 290389 0 0 0 Catherine Cho VP, Impact Investments 220000 0 11000 0 720 0 3300 0 28866 0 263886 0 0 0 Catherine Dun Rappaport VP, Impact Investments 215000 0 5011 0 720 0 5375 0 27973 0 254079 0 0 0 MICHAEL GROSSMAN Managing DIR (until 12/23) 338914 0 18300 0 14512 0 9351 0 30052 0 411129 0 0 0 TRACY PALANDJIAN President & CEO 475000 0 28500 0 720 0 13463 0 25948 0 543631 0 0 0 JACOB SEGAL Managing Director 254500 0 11111 0 720 0 7635 0 29147 0 303113 0 0 0 Kirstin Hill President & COO (AS OF 9/23) 126420 0 30000 0 240 0 0 0 0 0 156660 0 0 0 JOHN WOODS Chief Financial Officer 258000 0 8620 0 720 0 7740 0 36614 0 311694 0 0 0 Stephen Vicinelli VP, Impact Investments 215000 0 6014 0 720 0 5913 0 28866 0 256513 0 0 0 ANDREW C CHEN VP, IMPACT INVESTMENTS 205000 0 10980 0 720 0 6150 0 20216 0 243066 0 0 0 TRACY PALANDJIAN CEO RETIREMENT PLAN X 2483585 2526178 false true true 2526178 SCHEDULE L, PART II: THE ABOVE REFERENCED LOAN WAS MADE IN 2023 TO FUND PREMIUMS FOR A SUPPLEMENTAL EXECUTIVE RETIREMENT PLAN ("SERP") FOR CEO, TRACY PALANDJIAN. THE SERP WAS CANCELLED IN SEPTEMBER 2024 AND ALL SERP PREMIUMS PAID WERE RETURNED TO SOCIAL FINANCE, INC. THE ASSOCIATED LOAN WITH CO-FOUNDER & CEO, TRACY PALANDJIAN, WAS CANCELLED WITH NO AMOUNTS DUE FROM EITHER PARTY. SUBSEQUENTLY IN SEPTEMBER 2024, SOCIAL FINANCE, INC. ENTERED INTO A DEFERRED COMPENSATION PLAN WITH MS. PALANDJIAN, AFTER FOURTEEN YEARS OF SERVICE, TO PROVIDE INCENTIVES FOR LONG-TERM RETENTION. THE FIRST YEAR OF COMPENSATION UNDER THE NEW PLAN WILL BE PRESENTED IN SCHEDULE J IN THE 2024 FORM 990. FORM 990, PART I, LINE I, ORGANIZATION MISSION: PARTNERSHIPS AND INVESTMENTS THAT MEASURABLY IMPROVE LIVES. FORM 990, PART I, LINE 8- CONTRIBUTIONS & GRANTS: In 2022, total contributions were $65,663,400. In 2023, total contributions were $24,185,912, representing a decrease of $41,477,488. Included in the 2022 contributions was $40,347,407 of restricted grant support that was received for the sole purpose of investing in our economic mobility funds, WHICH WILL SUPPORT LOANS AND SERVICES OVER SEVERAL YEARS. FORM 990, PART III, LINE 4A, IMPACT INVESTING SERVICES: IMPACT INVESTMENTS Through its Impact Investing portfolio, SFI develops and manages impact-first investments and innovative financing solutions that generate positive outcomes for people and communities. In May 2023, SF Advisors, LLC, a wholly-owned subsidiary of SFI, became a registered investment adviser ("RIA") under As an RIA, SFI designs, launches, and manages impact-first investments, designed to generate positive outcomes for people and communities. SFI partners with individuals, family offices, and foundations to amplify their impact by directing more capital towards positive social and/or environmental outcomes. SFI offers asset management services, in which it manages impact-first private investment funds and Pay It Forward Funds. SFI also provides impact-investment advisory services to foundations, donor advised funds, and individuals on building impact investing portfolios. SFI also partners with federal, state, and local governments seeking to deploy public funds to address long-standing social issues, with a focus on outcomes and, in some cases, by leveraging private impact investment funds. SFI also analyses program data, often working with external evaluators with specific expertise. SFI's impact investments are structured either through equity or loan financing structures. It establishes separate affiliates or subsidiaries for each impact investment financing to hold the various contracts with its impact investors, governments (if applicable), the applicable service or training providers, as well as evaluators and loan or income share agreement originators and servicers. Five impact investment strategies employed to date include: . Career Impact Bonds ("CIBs"), a distinct contracting structure based on deferred tuition agreements like outcomes based loans ("OBLs") in which impact investors' funds cover upfront program costs and frequently wraparound support services for low income, under-skilled or under-employed students in order to advance their economic mobility. Unlike traditional student loans, agreements under the CIB programs link repayment to outcomes: students repay program costs once they gain meaningful employment after graduation and achieve the designated income threshold. Repayments are capped at a certain dollar amount and duration. SFI has funded CIBs through its UP Fund, and it has structured certain CIB projects as "pay it forward funds" where student repayments are recirculated to support future cohorts of students. . Career Certificate Fund Trust, a unique loan fund, was established to support economic mobility and prosperity by expanding the access of underserved, underemployed individuals to high-quality training programs designed for in-demand occupations using multiple Google Career Certificate programs. The Trust relies on the CIB financing structure to make interest free loans available to those seeking access to the Google Career Certificate programs. DREAMers Graduate Education loan fund, a unique impact fund which supports graduate educational loans for DREAMers (undocumented immigrant youth who came to this country at a young age and qualify for Deferred Action for Childhood Arrivals immigration status) to attend graduate school to achieve their professional goals. The fund provides graduate education funding at terms comparable to government student loan programs for DREAMers, who do not have access to these traditional educational loans. Social Finance Impact First Fund, an open-end fund of funds, was developed to address the barriers that donor-advised funds ( DAFs ), community and private foundations, PRI-makers, and other philanthropic capital investors face when pursuing innovative funds and investment strategies that support meaningful and measurable change for people and the planet. The Impact First Fund primarily invests in emerging, private market funds with the goal to catalyze positive, measurable environmental and social impact at scale as well as to make impact-first investing easier, more accessible, and more cost efficient. Social Impact Bonds (SIBs) which enable governments to achieve results for communities by partnering with investors, donors, and service providers to tackle particular social challenges. Governments only pay once a program achieves outcomes that benefit service recipients and generate public value. SIBs transfer the risk of non-performance from the public to the private sector and align project partners on the achievement of meaningful impact. Each impact investment team remains engaged in an impact investment project once it is launched through an ongoing project management and active performance management role to support achievement of the project's goals and outcomes. FORM 990, PART III, LINE 4B, IMPACT ADVISORY SERVICES: IMPACT ADVISORY SERVICES-PUBLIC SECTOR PRACTICE - SFI PARTNERS WITH ELECTED OFFICIALS, POLICYMAKERS, CIVIC LEADERS, COMMUNITY MEMBERS, AND SERVICE PROVIDERS TO DEVELOP GOVERNMENT FUNDING TOOLS THAT LINK FUNDING TO OUTCOMES TO MAXIMIZE THE IMPACT OF TAXPAYER DOLLARS. SFI ANALYZES DATA TO SUPPORT BETTER DECISION MAKING AND HELPS ACTIVELY MANAGE PROGRAMS FOR OUTCOMES. WE ESTABLISH COLLABORATIVE GOVERNANCE STRATEGIES TO DRIVE IMPROVEMENT AND INNOVATION. SFI ALSO STRENGTHENS THE CAPACITY OF GOVERNMENT DEPARTMENTS TO ENABLE MORE EFFECTIVE AND EQUITABLE DELIVERY OF PUBLIC SERVICE, AND IT SUPPORTS PARTNERS IN DESIGNING AND EXECUTING INNOVATIVE PROGRAMS, PRACTICES, AND PARTNERSHIPS, GROUNDED IN PAY FOR SUCCESS PRINCIPLES. FORM 990, PART III, LINE 4C, SFI: SFI, THROUGH THE SOCIAL FINANCE INSTITUTE, OFFICIALLY LAUNCHED IN 2023, ASPIRES TO REALIGN MARKETS AND SYSTEMS AROUND OUTCOMES, INCLUDING THROUGH ACTIONABLE RESEARCH AND PUBLICATIONS THAT SYNTHESIZE SFI'S LEARNING IN ITS IMPACT INVESTMENT AND ADVISORY WORK. THROUGH KEY MARKET EDUCATION EFFORTS INCLUDING WHITE PAPERS, OP-EDS AND BLOG POSTS, SPEAKING OPPORTUNITIES, CONVENINGS, AND MEDIA ENGAGEMENTS, THE SOCIAL FINANCE INSTITUTE CONTRIBUTES TO THE ADVANCEMENT OF EVIDENCE-BASED POLICY, EFFECTIVE PHILANTHROPY, AND IMPACT INVESTING. BY DEVELOPING COHORT AND LEARNING MODULES, THE SOCIAL FINANCE INSTITUTE WILL FACILITATE NETWORKING AND KNOWLEDGE EXCHANGE ACROSS SECTORS, REGIONS, AND SILOS, CREATING OPPORTUNITIES FOR CHANGEMAKERS TO EXPLORE OUTCOMES-DRIVEN APPROACHES TO SOLVING CHALLENGES. FORM 990, PART III, LINE 4D, OTHER PROGRAM SERVICES: MARKET EDUCATION - SFI WORKS TO BUILD THE PFS FIELD THROUGH RESEARCH AND PUBLICATIONS THAT SYNTHESIZE SFI'S LEARNINGS IN ITS IMPACT INVESTMENT AND ADVISORY WORK. THROUGH KEY MARKET EDUCATION EFFORTS, INCLUDING WHITE PAPERS, OP-EDS AND BLOG POSTS, SPEAKING OPPORTUNITIES, AND MEDIA ENGAGEMENTS, SFI CONTRIBUTES TO THE ADVANCEMENT OF EVIDENCE-BASED POLICY, EFFECTIVE PHILANTHROPY, AND IMPACT INVESTING. EXPENSES $213,281 GRANTS $NONE REVENUE $NONE FORM 990, PART VI, SECTION B, LINE 11B: THE 990 IS REVIEWED BY SFI'S FINANCE AND LEGAL TEAM. IT IS ALSO REVIEWED AND APPROVED BY EXECUTIVE MANAGEMENT AND THE AUDIT & RISK COMMITTEE. FORM 990, PART VI, SECTION B, LINE 12C: AN ANNUAL CONFLICT OF INTEREST POLICY STATEMENT IS DISTRIBUTED TO OFFICERS, DIRECTORS, AND MEMBERS OF ANY COMMITTEES WITH GOVERNING BOARD DELEGATED POWERS FOR COMPLETION. ANY CONFLICT WILL BE DISCUSSED WITH THE INTERESTED PERSON AND THE GOVERNING BOARD BEFORE A DECISION IS MADE AS TO THE EXISTENCE OF A CONFLICT OF INTEREST. FORM 990, PART VI, SECTION B, LINE 15: ALL OFFICER'S AND DIRECTOR'S COMPENSATION WILL BE APPROVED BY A DISINTERESTED BOARD OF DIRECTORS AFTER RESEARCH IS PERFORMED REGARDING SALARIES PAID FOR COMPARABLE WORK IN SIMILARLY SITUATED ORGANIZATIONS AND OTHER APPROPRIATE SALARY SURVEY INFORMATION IS CONSIDERED. FORM 990, PART VI, SECTION C, LINE 19: THE ORGANIZATION MAKES ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS AVAILABLE UPON REQUEST. 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