2023-05-15T08:49:54-05:00 2022-06-30 366055558 GRANT THORNTON LLP 757 THIRD AVENUE 3RD FLOOR NEW YORK NY 100172013 990 2021-07-01 391711417 AFS-USA INC AFS- 2122999000 120 WALL STREET 4TH FL NEW YORK NY 10005 MICHELLE PINEDO CFO 6467512004 2023-05-15 1 MICHELLE PINEDO XXX-XX-XXXX SCOTT THOMPSETT P00741490 2125990100 3 AAL1 IAL1 2021 2023-04-26 12:10:37Z TARA HOFMANN 120 WALL STREET 4TH FL NEW YORK NY 10005 23583977 0 X WWW.AFSUSA.ORG X 1991 IL AFSUSA EMPOWERS PEOPLE TO BECOME GLOBALLY ENGAGED CITIZENS VIA INTERCULTURAL EXCHANGES. 15 15 133 2625 0 0 12967688 14397489 1234786 7414797 893141 370797 565413 51891 15661028 22234974 258497 802721 0 0 6711596 8174061 0 0 795405 6443854 12114464 13413947 21091246 2247081 1143728 15380429 16224004 4961168 5612745 10419261 10611259 X AFS-USA EMPOWERS PEOPLE TO BECOME GLOBALLY ENGAGED CITIZENS BY DELIVERING MEANINGFUL INTERCULTURAL EXPERIENCES THAT PROVIDE THE KNOWLEDGE AND SKILLS NEEDED TO HELP CREATE A MORE JUST AND PEACEFUL WORLD. 0 0 17830065 802721 7414797 AFS-USA PROMOTES INTERCULTURAL LEARNING THROUGH WORLDWIDE EXCHANGE PROGRAMS FOR STUDENTS AND PROFESSIONALS. IN DOING SO, IT RELIES ON VOLUNTEERS IN THE UNITED STATES TO BE HOST FAMILIES AND SUPPORT AFS PARTICIPANTS, AND ON THE AMERICAN SCHOOL SYSTEM TO PROVIDE EDUCATIONAL OPPORTUNITIES FOR PARTICIPANTS. AFS-USA SENT 170 PARTICIPANTS ABROAD IN FY22 (CONTINUED IN SCHEDULE O).FOR AMERICANS GOING ABROAD, AFS-USA OFFERS SCHOOL YEAR, SEMESTER, SUMMER AND A GROWING NUMBER OF SHORT OR CUSTOMIZED PROGRAMS. FROM THE PARTICIPANT FEES IT COLLECTS, AFS-USA PROVIDES SELECTION, ORIENTATION, INTERNATIONAL TRAVEL, AND LIAISON WITH AFS OFFICES ABROAD DURING THE PROGRAM. AFS-USA ALSO HOSTED PARTICIPANTS FROM OTHER COUNTRIES ON PROGRAMS OF VARYING LENGTHS, INCLUDING SCHOOL YEAR, SEMESTER OR PROGRAMS OF SHORTER DURATIONS. AFS-USA HOSTED 996 PARTICIPANTS FROM ABROAD IN FY22. IN HOSTING, IT COLLECTS A TRANSFER FEE FROM THE SENDING AFS ORGANIZATION AND PROVIDES SERVICES SUCH AS FINDING HOST FAMILIES, PROVIDING ORIENTATIONS, ARRANGING DOMESTIC TRAVEL, AND OFFERING COUNSELING SUPPORT DURING THE STAY. PARTICIPATING CHAPTERS ARE AFFILIATED COMMUNITY-BASED ORGANIZATIONS THAT MAY ENGAGE IN FUND-RAISING ACTIVITIES, SPONSOR STUDENTS GOING ABROAD, AND SUPPORT HOST FAMILIES AND HOSTED STUDENTS. 1278945 0 0 VOLUNTEER ACTIVITIES - AFS-USA HAS A NETWORK OF MORE THAN 2,625 U.S. VOLUNTEERS WHO SUPPORT INTERNATIONAL STUDENTS AND THEIR HOST FAMILIES, SUPPORT U.S. STUDENTS WHO WANT TO STUDY ABROAD AND THEIR FAMILIES AND WORK WITH EDUCATORS, COMMUNITY LEADERS AND OTHERS THROUGH ACTIVITIES IN HIGH SCHOOLS AND IN THE COMMUNITY. VOLUNTEERS INCREASE AWARENESS FOR AFS PROGRAMS AND THE NEED FOR AMERICANS TO SUPPORT INTERNATIONAL EDUCATION AND INTERCULTURAL LEARNING AS A WAY TO FULFILL THE AFS MISSION OF HELPING TO BUILD A MORE JUST AND PEACEFUL WORLD. 19109010 1 1 0 1 0 0 0 0 0 1 1 0 0 1 1 1 1 0 0 0 1 0 0 0 0 0 0 1 1 1 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 1 36 0 1 133 1 0 0 0 0 0 0 0 0 0 0 0 0 X 15 15 0 0 0 0 0 0 0 1 1 0 1 1 1 1 1 1 1 1 1 1 0 AR CA FL GA HI IL KS KY MD MA MI MN MS NH NJ NM NY NC OR PA RI SC TN UT VA WV WI X X MICHELLE PINEDO 6467512004 120 WALL STREET 4TH FLR NEW YORK NY 10005 WENDY KURAN CHAIR (AS OF 6/24/2022) 3.00 0.00 X X 0 0 0 BOB STABLESKI CHAIR (THRU 06/25/2022) 3.00 0.00 X X 0 0 0 SARAH YANCEY - VICE CHAIR (THRU 06/2022)/BOARD MEMBER 3.00 0.00 X X 0 0 0 PATRICK MOON SECRETARY (AS OF 06/24/2022) 3.00 0.00 X X 0 0 0 PETER J WESTORT TREASURER (THRU 12/12/2021) 3.00 0.00 X X 0 0 0 ALAN WILLIAMS TREASURER (AS OF 6/24/2022) 3.00 0.00 X X 0 0 0 JOHN BACON BOARD MEMBER 3.00 0.00 X 0 0 0 CLARA BERGER BOARD MEMBER (THRU 06/25/2022) 3.00 0.00 X 0 0 0 EMRE EVREN BOARD MEMBER (THRU 12/12/2021) 3.00 0.00 X 0 0 0 MARI TREVINO GLASS BOARD MEMBER (AS OF 6/24/2022) 3.00 0.00 X 0 0 0 ZENITH N HOUSTON BOARD MEMBER (AS OF 6/24/2022) 3.00 0.00 X 0 0 0 DEBRA MALY BOARD MEMBER (THRU 06/25/2022) 3.00 0.00 X 0 0 0 GISELE MARCUS BOARD MEMBER (AS OF 6/24/2022) 3.00 0.00 X 0 0 0 SUSAN S MOON BOARD MEMBER 3.00 0.00 X 0 0 0 SUDIP MUKHERJEE BOARD MEMBER (THRU 06/24/2022) 3.00 0.00 X 0 0 0 BARBARA OLSON BD. MEM./VICE CHAIR (AS OF 06/2022) 3.00 0.00 X X 0 0 0 REGINA L PESZAT BOARD MEMBER (THRU 06/25/2022) 3.00 0.00 X 0 0 0 JANE RANSOM BOARD MEMBER 3.00 0.00 X 0 0 0 PETER M ROBINSON BOARD MEMBER 3.00 0.00 X 0 0 0 ANN SWEET BOARD MEMBER (AS OF 6/24/2022) 3.00 0.00 X 0 0 0 JULIA VOLLMERS BOARD MEMBER (THRU 06/24/2022) 3.00 0.00 X 0 0 0 JAMES WALKER BOARD MEMBER 3.00 0.00 X 0 0 0 CHRISTINA V WOOD BOARD MEMBER (AS OF 6/24/2022) 3.00 0.00 X 0 0 0 TARA HOFMANN PRESIDENT 35.00 0.00 X 214757 0 26793 MICHELLE PINEDO CHIEF FINANCIAL OFFICER 35.00 0.00 X 158054 0 10295 MARLENE BAKER CHIEF EXT RELATIONS/COMMUNICATIONS 35.00 0.00 X 164404 0 17990 KERI DOOLEY CHIEF GOVERNMENT RELATIONS 35.00 0.00 X 166696 0 8078 MELVIN HARMON CHIEF MKTING & CUSTOMER EXPERIENCE 35.00 0.00 X 133457 0 4237 ROBIN WEBBER SR DIR RISK MGMT & QLTY ASSURANCE 35.00 0.00 X 104468 0 13064 ELISSA DISANTI DIRECTOR OF HUMAN RESOURCES 35.00 0.00 X 109759 0 11140 1051595 0 91597 10 0 1 0 GRANT THORNTON LLP 757 THIRD AVENUE NEW YORK NY 10017 AUDITING 139870 1 12323563 2073926 58500 14397489 HOSTING TRANSFER FEES 611710 5482281 5482281 PARTICIPANT FEES 611710 1881196 1881196 ANCILLARY PROGRAM FEES 900099 51320 51320 7414797 156658 156658 1562380 1348241 214139 214139 214139 2329 762 1567 1567 MISCELLANEOUS REVENUE 900099 50324 50324 50324 22234974 7414797 0 422688 256758 256758 545963 545963 490308 429076 38974 22258 6159113 5389938 489579 279596 279167 253270 11032 14865 708952 641842 29688 37422 536521 470822 41461 24238 95445 95445 153568 153568 30600 30600 53024 53024 788467 629546 158921 212452 189484 22968 170587 157644 6237 6706 187973 153758 17114 17101 1770183 1642486 69346 58351 672720 648830 16336 7554 23944 22517 931 496 133433 133433 12221 12221 PARTICIPANT-RELATED EXP 4911665 4911665 HOSTING TRANSFER FEES 2460298 2460298 EQUIP PURCH/RENTAL/MAIN 217269 185267 18120 13882 PRINTING & PUBLICATIONS 42213 35630 322 6261 178402 53616 124786 21091246 19109010 1186831 795405 3993932 4090088 2371392 2148218 1726622 3955369 586457 118494 29243 28481 128108 79712 3155343 2874140 326142 281203 4958528 4216991 1260005 1305448 15380429 16224004 2869384 3465932 1266975 2123730 29065 0 795744 23083 4961168 5612745 X 2886512 4892308 7532749 5718951 10419261 10611259 15380429 16224004 X 1143728 -751765 -199965 X 0 1 X 1 1 1 X 13945290 13928627 13147420 12967688 14397489 68386514 20449979 19877358 17999703 1234786 7414797 66976623 34395269 33805985 31147123 14202474 21812286 135363137 95779 104852 49568 35465 42420 328084 0 95779 104852 49568 35465 42420 328084 135035053 167719 195000 715805 668450 156658 1903632 167719 195000 715805 668450 156658 1903632 331237 39748 29081 51941 52653 504660 34894225 34040733 31892009 14922865 22021597 137771429 0.98010 0.98010 0.01380 0.01240 X SCHEDULE A, PART III, LINE 12, EXPLANATION OF OTHER INCOME: MISCELLANEOUS REVENUE - 2017 AMOUNT: $ 321,181. 2018 AMOUNT: $ 29,101. 2019 AMOUNT: $ 25,790. 2020 AMOUNT: $ 50,960. 2021 AMOUNT: $ 50,324. GROSS SALES OF INVENTORY - 2017 AMOUNT: $ 10,056. 2018 AMOUNT: $ 10,647. 2019 AMOUNT: $ 3,291. 2020 AMOUNT: $ 981. 2021 AMOUNT: $ 2,329. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 30600 30600 21061408 21092008 1000000 250000 0 0 1000000 1000000 1000000 1000000 4000000 6000000 30000 31100 30600 30600 122300 250000 250000 205124 250000 955124 1432686 0 0 0 0 5395834 17353 -425962 17725 918663 0 4050837 6489198 170052 1004689 27183 2240922 5395834 6119243 59627 598848 230689 57831 6489198 6448317 65236 -231363 124295 38652 6119243 5556193 528510 502228 103200 35414 6448317 0.01000 0.53000 0.46000 0 0 298819 123511 175308 2072951 1945604 127347 783573 805025 -21452 281203 BENEFICIAL INTEREST IN PERPETUAL TRUST 855024 DEPOSITS 450424 1305448 POSTRETIREMENT BENEFIT LIABILITIES 23083 23083 X 21489648 -751765 383335 -199203 -567633 22057281 53024 124669 177693 22234974 21297650 383335 762 384097 20913553 53024 124669 177693 21091246 PART V, LINE 4: ENDOWMENT FUND THE PURPOSE OF AFS-USA'S ENDOWMENT FUND IS PRIMARILY TO PROVIDE SUPPORT FOR THE ORGANIZATION'S SENDING AND HOSTING PROGRAMS. THE BOARD OF DIRECTORS HAS APPROVED AN ANNUAL SPENDING RATE OF 3% OF THE PERMANENTLY RESTRICTED ENDOWMENT BALANCE. IN ADDITION, THE BOARD OF DIRECTORS MAY APPROVE ADDITIONAL APPROPRIATIONS ABOVE THE 3% SPENDING RATE WHEN DEEMED NECESSARY. THE BOARD-DESIGNATED FUND IS MADE UP OF NUMEROUS BEQUESTS RECEIVED WITHOUT DONOR RESTRICTIONS, AS WELL AS SOME DEFUNCT CHAPTER PROCEEDS. AMOUNTS ARE APPROPRIATED BY THE BOARD OF DIRECTORS AS DEEMED NECESSARY. IN FISCAL YEAR 2022, AFS-USA WAS GRANTED RELIEF BY A U.S. CIRCUIT COURT TO RELEASE MONEY FROM FOUR FUNDS WITHIN ITS DONOR RESTRICTED ENDOWMENT TO BE USED BY THE PRESIDENT OF AFS-USA TO SUPPORT THE ORGANIZATIONS HIGH SCHOOL STUDENT EXCHANGE PROGRAMS. THE EXPENDITURE OF SUCH FUNDS IS REFLECTED IN SCHEDULE D, PART V, LINE 1(E). PART X, LINE 2: LIABILITY FOR UNCERTAIN TAX POSITION THE AFS-USA FOLLOWS GUIDANCE THAT 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 GUIDANCE PROVIDES THAT THE TAX EFFECTS FROM AN UNCERTAIN TAX POSITION CAN ONLY BE RECOGNIZED IN THE FINANCIAL STATEMENTS 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 AFS-USA IS EXEMPT FROM FEDERAL INCOME TAX UNDER IRC SECTION 501(C)(3), THOUGH IT IS SUBJECT TO TAX ON INCOME UNRELATED TO ITS EXEMPT PURPOSE, UNLESS THAT INCOME IS OTHERWISE EXCLUDED BY THE CODE. THE AFS- USA HAS PROCESSES PRESENTLY IN PLACE TO ENSURE THE MAINTENANCE OF ITS TAX-EXEMPT STATUS; TO IDENTIFY AND REPORT UNRELATED BUSINESS INCOME; TO DETERMINE ITS FILING AND TAX OBLIGATIONS IN JURISDICTIONS FOR WHICH IT WAS NEXUS; AND TO IDENTIFY AND EVALUATE OTHER MATTERS THAT MAY BE CONSIDERED TAX POSITIONS. THE AFS-USA HAS DETERMINED THAT THERE ARE NO MATERIAL UNCERTAIN TAX POSITIONS THAT REQUIRE RECOGNITION OR DISCLOSURE IN THE FINANCIAL STATEMENTS. IN ADDITION, THE AFS-USA HAS NOT RECORDED A PROVISION FOR INCOME TAXES AS IT HAS NO MATERIAL TAX LIABILITY FROM UNRELATED BUSINESS INCOME ACTIVITIES. PART XI, LINE 2D - OTHER ADJUSTMENTS: CHANGE IN BENEFICIAL INTEREST IN PERPETUAL TRUST -199,965. RECLASS OF COST OF GOODS SOLD 762. PART XI, LINE 4B - OTHER ADJUSTMENTS: RECLASS OF SCHOLARSHIP EXPENSE 124,669. PART XII, LINE 2D - OTHER ADJUSTMENTS: RECLASS OF COST OF GOODS SOLD 762. PART XII, LINE 4B - OTHER ADJUSTMENTS: RECLASS OF SCHOLARSHIP EXPENSE 124,669. EAST ASIA AND THE PACIFIC 6 152 PROGRAM SERVICES TRANSFER FEES 709483 EUROPE (INCLUDING ICELAND & GREENLAND) 19 113 PROGRAM SERVICES TRANSFER FEES 638638 SUB-SAHARAN AFRICA 4 89 PROGRAM SERVICES TRANSFER FEES 450962 MIDDLE EAST AND NORTH AFRICA 1 44 PROGRAM SERVICES TRANSFER FEES 402458 SOUTH ASIA 1 79 PROGRAM SERVICES TRANSFER FEES 184657 SOUTH AMERICA 3 9 PROGRAM SERVICES TRANSFER FEES 41310 CENTRAL AMERICA AND THE CARIBBEAN 1 3 PROGRAM SERVICES TRANSFER FEES 24071 RUSSIA AND NEIGHBORING STATES 1 4 PROGRAM SERVICES TRANSFER FEES 8719 36 493 0 0 36 493 2460298 0 2460298 0 0 0 0 0 0 PART III ACCOUNTING METHOD: 1 IOWA RESOURCE FOR INTERNATIONAL SERVICE 600 FIFTH STREET SUITE 301 AMES IA 50010 421394408 501(C)(3) 256758 0 PROGRAM ACTIVITY 1 SCHOLARSHIPS 25 124669 0 STIPENDS 2164 421294 0 PART I, LINE 2: SCHOLARSHIPS AND STIPENDS AFS-USA, INC. AWARDS HOSTING SCHOLARSHIPS TO ITS NETWORK PARTNERS, GENERALLY BASED ON DONOR STIPULATIONS. AFS-USA, INC. MONITORS GRANTEE EXPENSES TO ENSURE THAT THEY ARE ALLOWABLE UNDER A-122 GUIDELINES. IN ADDITION, ALL GRANTEES MUST PROVIDE SIGNED CERTIFICATIONS THAT THE EXPENSES ARE TRUE AND CONFORM TO DONOR CONDITIONS. IN ADDITION, AFS-USA, INC. CLOSELY MANAGES ITS SUB-AWARDEES' PROGRAM ACTIVITIES BY HOLDING WEEKLY MEETINGS AND BY CONDUCTING ANNUAL SITE VISITS. THE PURPOSE OF THE SITE VISITS IS FOR AFS-USA, INC. PROGRAM DIRECTORS TO: (1) MEET A MINIMUM OF 20% OF THE SUB-AWARDEES' PROGRAM PARTICIPANTS, AND (2) MEET WITH SUB-AWARDEE STAFF AND LOCAL COORDINATORS TO DISCUSS PROGRAMMATIC OR FINANCIAL ISSUES THAT MAY ARISE DURING PROGRAM DELIVERY. FINALLY, WE CONDUCT THOROUGH REVIEWS OF SUB-GRANTEE BUDGETS AND BUDGET NARRATIVES AND ENSURE THAT ALL SUB-GRANTEE BILLINGS ARE REASONABLE AND WELL DOCUMENTED. SCHOLARSHIPS - AFS-USA, INC. AWARDS SCHOLARSHIPS IN THE FORM OF FEE REDUCTIONS TO PARTICIPANTS IN AFS PROGRAMS. THERE IS GENERALLY NO DIRECT MONETARY AWARD TO THE PARTICIPANT SO THERE IS NO NEED TO MONITOR USE OF THE FUNDS. STIPENDS - IN ADDITION TO SCHOLARSHIPS AFS-USA, INC. ALSO PROVIDES ASSISTANCE IN THE FORM OF MONTHLY STIPENDS TO PARTICIPANTS IN CERTAIN GOVERNMENT GRANT FUNDED PROGRAMS. THESE STIPENDS WHICH ARE STIPULATED AS PART OF THE GOVERNMENT GRANT AWARD ARE INTENDED TO HELP THE PARTICIPANTS DEFRAY DAY-TO-DAY EXPENSES WHILE PARTICIPATING IN THE PROGRAM. PART II: IN FISCAL YEAR 2022, AFS-USA RECEIVED FUNDING FROM THE FEDERAL GOVERNMENT THAT IT, IN TURN, AWARDED TO A SUB-GRANTEE WHOSE MISSION CLOSELY ALIGNS WITH ITS OWN. ELIGIBILITY TO RECEIVE THE FEDERAL AWARD IS CONDITIONED UPON ASSURANCES FROM THE SUB-GRANTEE THAT THE FUNDS WOULD BE EXPENDED IN A MANNER CONSISTENT WITH BOTH ITS AND AFS-USA'S TAX-EXEMPT MISSION. X X X 0 0 0 0 0 0 0 0 0 TARA HOFMANN PRESIDENT 212497 0 0 0 2260 0 18332 0 8461 0 241550 0 0 0 MARLENE BAKER CHIEF EXT RELATIONS/COMMUNICATIONS 159680 0 0 0 4724 0 13753 0 4237 0 182394 0 0 0 KERI DOOLEY CHIEF GOVERNMENT RELATIONS 165840 0 0 0 856 0 8078 0 0 0 174774 0 0 0 MICHELLE PINEDO CHIEF FINANCIAL OFFICER 156506 0 0 0 1548 0 6058 0 4237 0 168349 0 0 0 X 15 56100 MARKET VALUE X SOFTW LICEN. 1 2400 FMV 0 1 1 PART I, COLUMN (B): AFS-USA, INC. IS REPORTING THE NUMBER OF CONTRIBUTIONS RECEIVED. PART I, LINE 32B: AFS-USA'S INVESTMENT BROKER, CHARLES SCHWAB, PROCESSES AND SELLS DONATIONS OF STOCK RECEIVED BY AFS-USA, INC. GENERAL INFORMATION REGARDING PAYCHECK PROTECTION PROGRAM LOAN: TO HELP MITIGATE THE IMPACT OF THE COVID-19 PANDEMIC, AFS-USA PARTICIPATED IN VARIOUS FEDERAL PROGRAMS WITH THE SMALL BUSINESS ADMINISTRATION. IN FISCAL YEAR 2022, AFS-USA RECEIVED FULL FORGIVENESS OF THE $731,010 PPP LOAN IT APPLIED FOR DURING THE PANDEMIC. THIS IS REPORTED AS A GOVERNMENT GRANT IN PART VIII, LINE 1(E). FORM 990, PART VI, SECTION B, LINE 11B 990 REVIEW PROCESS THE ORGANIZATION'S FORM 990 IS PREPARED BY AN INDEPENDENT ACCOUNTING FIRM. ONCE THE DRAFT OF THE 990 HAS BEEN VETTED AND APPROVED BY RESPONSIBLE STAFF MEMBERS, IT IS REVIEWED BY MEMBERS OF THE AUDIT AND FINANCE COMMITTEES OF THE BOARD. ANY REQUIRED UPDATES ARE MADE PRIOR TO FILING THE RETURN. THE FINAL VERSION OF THE IRS FORM 990 AND SUPPORTING SCHEDULES ARE DISTRIBUTED TO EACH MEMBER OF THE AFS-USA'S BOARD OF DIRECTORS PRIOR TO FILING WITH THE IRS. FORM 990, PART VI, SECTION B, LINE 12C CONFLICT OF INTEREST POLICY MONITORING AND ENFORCEMENT THE BOARD AUDIT COMMITTEE RECEIVES A SIGNED CONFLICT OF INTEREST STATEMENT FROM EACH BOARD MEMBER AND KEY EMPLOYEE ANNUALLY. THESE FORMS ARE THEN REVIEWED BY THE AUDIT COMMITTEE. IF THE COMMITTEE DEEMS THAT A POTENTIAL CONFLICT EXISTS, THE MATTER IS REFERRED TO THE FULL BOARD. IF THE BOARD DETERMINES THAT THERE IS A BONA FIDE CONFLICT, THE CONFLICTED PARTY MUST BE RECUSED FROM ANY DISCUSSION AND/OR VOTE ON THE MATTER. FORM 990, PART VI, SECTION B, LINE 15 PROCESS OF DETERMINING COMPENSATION THE ORGANIZATION HAS INSTITUTED A PROCESS TO REVIEW THE COMPENSATION PAID TO ITS OFFICERS AND KEY EMPLOYEES AND FOLLOWS THE REBUTTABLE PRESUMPTION RULES OF TREAS REG 53.4958-6. THE ORGANIZATION'S POLICY IS TO CONDUCT A BIANNUAL ANALYSIS OF LIKE POSITIONS AT COMPARABLE ORGANIZATIONS. SUCH INFORMATION IS CONSIDERED WHEN DETERMINING THE COMPENSATION FOR THOSE STAFF MEMBERS THAT HAVE BEEN IDENTIFIED AS DISQUALIFIED PERSONS. THE COMPENSATION FOR THE PRESIDENT IS DETERMINED IN ACCORDANCE WITH RECOMMENDATIONS OF THE COMPENSATION CONSULTING FIRM HIRED BY THE ORGANIZATION AND IS APPROVED BY THE BOARD OF DIRECTORS IN EXECUTIVE SESSION. THE COMPENSATION OF THE CFO IS ALSO DETERMINED IN ACCORDANCE WITH THE RECOMMENDATIONS OF THE COMPENSATION CONSULTING FIRM AND IS APPROVED BY THE PRESIDENT. RECOMMENDED COMPENSATION OF ALL OTHER KEY EMPLOYEES IS APPROVED BY THE PRESIDENT. CONTEMPORANEOUS RECORDS OF COMPENSATION DETERMINATIONS ARE RECORDED IN THE ONLINE HR SYSTEM AND PLACED IN THE INDIVIDUAL STAFF MEMBER'S HR FILE. THE HIRING MANAGER PROPOSES THE SALARY FOR ALL NEW HIRES IN ACCORDANCE WITH THE SALARY GRADE AND RANGE FOR THE POSITION. ALL SALARIES ARE THEN APPROVED BY THE HR DIRECTOR AND THE CFO. THE MOST RECENT COMPENSATION STUDY WAS CONDUCTED IN JUNE OF 2022. FORM 990, PART VI, SECTION C, LINE 19 AVAILABILITY OF DOCUMENTS TO THE PUBLIC AFS-USA PUBLISHES ITS GOVERNING DOCUMENTS, ANNUAL AUDIT REPORT, FORM 990, ANNUAL REPORT, AND 501(C)(3) DESIGNATION ON ITS WEBSITE. THE CONFLICT OF INTEREST POLICY IS NOT MADE AVAILABLE TO THE PUBLIC. FORM 990, PART IX, LINE 24A: PARTICIPANT-RELATED EXPENSES PARTICIPANT-RELATED EXPENSES ARE COMPRISED OF: TRAVEL AND ORIENTATION EXPENSES OF $2,974,586; TUITION COSTS OF $138,873; NETWORK MANAGEMENT FEES OF $469,415; INSURANCE OF $667,494. THE REMAINING BALANCE CONSISTS OF A VARIETY OF SMALLER MISCELLANEOUS EXPENSES. FORM 990, PART XI, LINE 9: CHANGE IN BENEFICIAL INTEREST IN PERPETUAL TRUST -199,965.