2023-09-15T12:45:18-05:00 2022-10-31 910189318 MOSS ADAMS LLP 4747 EXECUTIVE DR SUITE 1300 SAN DIEGO CA 92121 990 2022-07-01 900171867 NORTHCENTRAL UNIVERSITY NORT 8586428100 9388 LIGHTWAVE AVE SAN DIEGO CA 92123 DAVE C LAWRENCE EXEC VP, ADMIN, FINANCE 8586428100 2023-09-15 1 DAVE LAWRENCE 999009999 0 PATRICIA J MAYER P00188643 8586271400 2 AAL1 IAL1 2022 2023-04-26 12:10:37Z X JAMES BILLINGS 9388 LIGHTWAVE AVE SAN DIEGO CA 92123 51016833 0 X WWW.NCU.EDU X 2004 CA THE ORGANIZATION IS A POST-SECONDARY LEVEL EDUCATIONAL INSTITUTION. X 18 17 801 19 0 0 395928 1932736 154951146 49047781 -58779 -7475 46318 34526 155334613 51007568 17788657 5807269 0 0 33363426 12466323 0 0 0 118405684 33984909 169557767 52258501 -14223154 -1250933 54917275 0 21973591 0 32943684 0 X NORTHCENTRAL UNIVERSITY EDUCATES STUDENTS THROUGH ACCESS TO INCLUSIVE, PERSONALIZED, AND INNOVATIVE LEARNING-CENTERED EXPERIENCES. WE SUPPORT EVERY STUDENT IN BECOMING LIFE-LONG LEARNERS AND PROMOTE THEIR ABILITY TO MAKE MEANINGFUL CONTRIBUTIONS TO THEIR PERSONAL AND PROFESSIONAL COMMUNITIES. 0 1 40426124 5807269 49047781 PROVIDE EDUCATION AND TRAINING TO PROFESSIONALS LOOKING TO ACHIEVE ACADEMICALLY, PROFESSIONALLY AND BECOME VALUABLE CONTRIBUTORS TO THEIR COMMUNITIES AND WITHIN THEIR PROFESSIONS. 40426124 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 0 0 1 0 1 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 1 0 0 1 1 1 0 0 1 36 0 1 801 1 0 0 0 0 0 0 0 0 0 0 0 0 X 18 17 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 CA X MICHELLE BELLO VP FINANCE 8586428636 9388 LIGHTWAVE AVE SAN DIEGO CA 92123 ANA GOMEZ CHAPMAN TRUSTEE (THRU 7/31/22) 3.00 X 0 0 0 CARLOS RODRIGUEZ TRUSTEE 3.00 X 0 0 0 DAN PITTARD TRUSTEE 3.00 X 0 0 0 DR E LEE RICE TRUSTEE, VICE CHAIR 3.00 X X 0 0 0 DR ERLINDA MARTINEZ TRUSTEE 3.00 X 0 0 0 HAROLD GREENBERG TRUSTEE 3.00 X 0 0 0 HIEP QUACH TRUSTEE 3.00 X 0 0 0 JEANNE CONNELLY TRUSTEE 3.00 X 0 0 0 JOANNE PASTULA TRUSTEE 3.00 X 0 0 0 KIM FOLSOM TRUSTEE 3.00 X 0 0 0 LEE WILLS-IRVINE TRUSTEE 3.00 X 0 0 0 MICHAEL R MCGILL TRUSTEE, CHAIR 3.00 X X 0 0 0 RICHARD CHISHOLM TRUSTEE, TREASURER 3.00 X X 0 0 0 RUTHANN HEINRICH TRUSTEE 3.00 X 0 0 0 STACY ALLISON TRUSTEE 3.00 X 0 0 0 TAHJAR ROAMARTINEZ TRUSTEE (THRU 7/31/22) 3.00 X 0 0 0 THOMAS TOPUZES TRUSTEE, SECRETARY 3.00 X X 0 0 0 TOM CLEVINGER TRUSTEE 3.00 X 0 0 0 MARK MILLIRON TRUSTEE, PRESIDENT (AS OF 10/1/22) 3.00 X X 0 0 0 DR MICHAEL CUNNINGHAM CHANCELLOR, TRUSTEE (THRU 9/30/22) 3.00 X X 0 0 0 JAMIE NICKEL CHIEF FINANCIAL OFFICER 45.00 X 156397 0 11200 JAMES BILLINGS INTERIM PRESIDENT 45.00 X 165845 0 22986 MICHELLE BELLO SR VP, ADMIN, FINANCE 3.00 X 0 0 0 DAVE C LAWRENCE EXEC VP, ADMIN, FINANCE 3.00 X 0 0 0 ANDREW RIGGLE DEAN, SCHOOL OF EDUCATION 45.00 X 153724 0 11816 LISA HUTTON DEAN, SCHOOL OF LAW 45.00 X 147893 0 21066 EUGENE WILKERSON DEAN, SCHOOL OF BUSINESS 45.00 X 144143 0 4213 ROBERT SAPP DEAN, SCHOOL OF TECHNOLOGY 45.00 X 137964 0 4225 CHRIS DUNHAM DEAN, SCHOOL OF UNDERGRADUATE STUDIES 45.00 X 119299 0 13598 DAVID HARPOOL FORMER PRESIDENT/SENIOR ADVISOR 45.00 X 310866 0 32807 1336131 0 121911 14 1 1 0 SYSTEM MANAGEMENT GROUP 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 ADMIN AND BACK OFFICE SERVICES 73776887 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 ADMIN AND BACK OFFICE SERVICES 8891340 PADRES LP 100 PARK BOULEVARD SAN DIEGO CA 92101 COMMENCEMENT SERVICES 256204 3 1785009 147727 1932736 EDUCATIONAL SERVICES 611310 49047781 49047781 49047781 7475 -7475 -7475 -7475 9284 1790 7494 7494 27032 27032 27032 51007568 49047781 0 27051 5773215 5773215 34054 34054 295281 42641 252640 10316357 10101511 214846 198308 189934 8374 925776 881361 44415 730601 712040 18561 24985 24985 221510 139261 82249 9799572 9776130 23442 307426 101080 206346 125522 99032 26490 154693 131392 23301 79852 72290 7562 27443 27443 19458960 9066589 10392371 1550965 1131380 419585 1957 1957 BAD DEBT 1542483 1484673 57810 COURSE MATERIALS AND LI 683876 683876 5665 5665 52258501 40426124 11832377 0 12343133 0 0 0 16381658 0 0 0 0 0 1743875 0 0 0 5531276 0 0 0 18917333 0 0 0 0 54917275 0 2691331 0 12419354 0 6862906 0 21973591 0 X 32943684 0 32943684 0 54917275 0 X -1250933 -31692751 X 0 1 X 1 1 1 X 68960781 1125239 1096154 395928 1932736 73510838 60901757 144120950 162372366 154951146 49047781 571394000 129862538 145246189 163468520 155347074 50980517 644904838 68960781 18200 9100 68988081 0 68960781 18200 9100 68988081 575916757 28752 39028 59714 36316 163810 129862538 145274941 163507548 155406788 51016833 645068648 0.89280 0.88370 0.00000 0.00000 X SCHEDULE A, PART III, LINE 12, EXPLANATION OF OTHER INCOME: OTHER INCOME - 2019 AMOUNT: $ 28,752. 2020 AMOUNT: $ 39,028. 2021 AMOUNT: $ 59,714. 2022 AMOUNT: $ 36,316. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 X 43418890 0 43418890 7588678 7588678 51007568 46454832 3600 3600 46451232 5807269 5807269 52258501 PART X, LINE 2: NORTHCENTRAL IS EXEMPT FROM FEDERAL INCOME TAX UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE AND RELATED STATE PROVISIONS AND FROM STATE INCOME TAXES UNDER RELEVANT PROVISIONS OF STATE LAW. ACCORDINGLY, NO PROVISION FOR INCOME TAXES HAS BEEN REFLECTED IN THE ACCOMPANYING FINANCIAL STATEMENTS. INCOME TAX BENEFITS AND/OR LIABILITIES ARE RECOGNIZED FOR INCOME TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN, ONLY WHEN IT IS DETERMINED THAT THE INCOME TAX POSITION WILL MORE-LIKELY-THAN-NOT BE SUSTAINED UPON EXAMINATION BY TAXING AUTHORITIES. NORTHCENTRAL HAS ANALYZED THE TAX POSITIONS TAKEN IN ITS FILINGS. NORTHCENTRAL BELIEVES THAT ITS INCOME TAX FILING POSITIONS WILL BE SUSTAINED UPON EXAMINATION AND DOES NOT ANTICIPATE ANY ADJUSTMENTS THAT WOULD RESULT IN A MATERIAL ADVERSE EFFECT ON ITS FINANCIAL CONDITION, CHANGES IN ITS NET ASSETS, OR CASH FLOWS. ACCORDINGLY, NORTHCENTRAL HAS NOT RECORDED ANY RESERVES, OR RELATED ACCRUALS FOR INTEREST AND PENALTIES FOR UNCERTAIN INCOME TAX POSITIONS AT OCTOBER 31, 2022. PART XI, LINE 4B - OTHER ADJUSTMENTS: SCHOLARSHIPS 5,807,269. GAIN/LOSS ON DISPOSAL OF FIXED ASSETS -7,475. COST OF GOODS SOLD -1,790. CONTRIBUTION FROM AFFILIATE 1,785,009. OTHER EXPENSE RECLASSIFICATION FOR THE RECONCILIATION TO THE FINANCIAL STATEMENTS 5,665. PART XII, LINE 2D - OTHER ADJUSTMENTS: GAIN/LOSS ON DISOSAL OF FIXED ASSETS 7,475. COST OF GOODS SOLD 1,790. OTHER EXPENSE RECLASSIFICATION FOR THE RECONCILIATION TO THE FSTHE FS THE FINANCIAL STATEMENTS -5,665. PART XII, LINE 4B - OTHER ADJUSTMENTS: SCHOLARSHIPS 5,807,269. 1 CENTRAL AMERICA AND THE CARIBBEAN 0 0 SCHOLARSHIPS 5742 EAST ASIA AND THE PACIFIC 0 0 SCHOLARSHIPS 3746 MIDDLE EAST AND NORTH AFRICA 0 0 SCHOLARSHIPS 2739 NORTH AMERICA (CANADA AND MEXICO) 0 0 SCHOLARSHIPS 10069 SUB-SAHARAN AFRICA 0 0 SCHOLARSHIPS 3185 SOUTH AMERICA 0 0 SCHOLARSHIPS 6684 EUROPE (INCLUDING ICELAND AND GREENLAND) 0 0 SCHOLARSHIPS 1889 0 0 0 0 0 0 34054 0 34054 FINANCIAL AID TO STUDENTS CENTRAL AMERICA AND THE CARIBBEAN 7 SCHOLARSHIPS 5742 TUITION CHARGE REDUCTION FMV FINANCIAL AID TO STUDENTS EAST ASIA AND THE PACIFIC 6 SCHOLARSHIPS 3746 TUITION CHARGE REDUCTION FMV FINANCIAL AID TO STUDENTS EUROPE (INCLUDING ICELAND AND GREENLAND) 3 SCHOLARSHIPS 1889 TUITION CHARGE REDUCTION FMV FINANCIAL AID TO STUDENTS MIDDLE EAST AND NORTH AFRICA 1 SCHOLARSHIPS 2739 TUITION CHARGE REDUCTION FMV FINANCIAL AID TO STUDENTS NORTH AMERICA (CANADA AND MEXICO) 14 SCHOLARSHIPS 10069 TUITION CHARGE REDUCTION FMV FINANCIAL AID TO STUDENTS SUB-SAHARAN AFRICA 2 SCHOLARSHIPS 3185 TUITION CHARGE REDUCTION FMV FINANCIAL AID TO STUDENTS SOUTH AMERICA 1 SCHOLARSHIPS 6684 TUITION CHARGE REDUCTION FMV 0 0 0 0 0 0 PART I, LINE 2: NORTHCENTRAL UNIVERSITY IDENTIFIES ELIGIBLE GRANTEES RELATED TO EDUCATIONAL AND COMMUNITY PURPOSES. GRANTEES ARE MONITORED AS APPROPRIATE THROUGH PERIODIC REPORTS AND SITE INSPECTIONS. PART I, LINE 3: ACCRUAL BASIS PART III ACCOUNTING METHOD: PART III: ACCRUAL BASIS 1 FINANCIAL AID TO STUDENTS 6795 5773215 FMV TUTION CHARGES ARE REDUCED BY THE AMOUNT OF THE INDIVIDUAL SCHOLARSHIP OR DISCOUNT AWARDED TO STUDENTS PART I, LINE 2: NORTHCENTRAL UNIVERSITY IDENTIFIES ELIGIBLE GRANTEES RELATED TO EDUCATIONAL AND COMMUNITY PURPOSES. GRANTEES ARE MONITORED AS APPROPRIATE THROUGH PERIODIC REPORTS AND SITE INSPECTIONS. X 1 1 X X X 0 0 0 0 0 0 0 1 0 DAVID HARPOOL FORMER PRESIDENT/SENIOR ADVISOR 310212 0 0 0 654 0 9306 0 23501 0 343673 0 0 0 JAMES BILLINGS INTERIM PRESIDENT 149744 0 15813 0 288 0 3746 0 19240 0 188831 0 0 0 LISA HUTTON DEAN, SCHOOL OF LAW 132872 0 14823 0 198 0 0 0 21066 0 168959 0 0 0 JAMIE NICKEL CHIEF FINANCIAL OFFICER 142444 0 13641 0 312 0 4273 0 6927 0 167597 0 0 0 ANDREW RIGGLE DEAN, SCHOOL OF EDUCATION 138381 0 15049 0 294 0 4152 0 7664 0 165540 0 0 0 PART I, LINE 1A FIRST CLASS TRAVEL IS MADE AVAILABLE TO BOARD MEMBERS IF THE FLIGHT IS OVER 3 HOURS. THIS IS NOT INCLUDED AS TAXABLE INCOME TO SUCH BOARD MEMBERS. PART I, LINE 7 NON-FIXED PAYMENTS RECEIVED BY LISTED PERSONS ON SCHEDULE J, PART II, REPRESENT DISCRETIONARY BONUSES NOT BASED ON A FORMULA SPECIFIED IN CONTRACTS. CASH 2022-10-31 6101306 BOOK VALUE 237172306 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 501(C)(3) STUDENT ACCOUNTS RECEIVABLE 2022-10-31 17079635 BOOK VALUE 237172306 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 501(C)(3) PREPAID EXPENSES AND OTHER ASSETS 2022-10-31 485626 BOOK VALUE 237172306 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 501(C)(3) PROPERTY AND EQUIPMENT, NET 2022-10-31 4904362 BOOK VALUE 237172306 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 501(C)(3) INTANGIBLE ASSETS, NET 2022-10-31 18547555 BOOK VALUE 237172306 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 501(C)(3) ACCOUNTS PAYABLE AND ACCRUED EXPENSES 2022-10-31 -651197 BOOK VALUE 237172306 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 501(C)(3) STUDENT CREDIT BALANCES 2022-10-31 -263144 BOOK VALUE 237172306 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 501(C)(3) TITLE IV STUDENT CREDIT BALANCES 2022-10-31 -896000 BOOK VALUE 237172306 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 501(C)(3) DEFERRED REVENUE 2022-10-31 -12471394 BOOK VALUE 237172306 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 501(C)(3) DUE TO AFFILIATES 2022-10-31 -1143998 BOOK VALUE 237172306 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVENUE SAN DIEGO CA 92123 501(C)(3) 1 1 0 0 1 1 1 1 0 PART I, LINE 2E: PERSON(S) INVOLVED: BOARD OF TRUSTEES AND OFFICERS PART I, LINE 2E: EXPLANATION OF INVOLVEMENT: ALL OF THE EMPLOYEES OF NORTHCENTRAL UNIVERSITY BECAME EMPLOYEES OF NATIONAL UNIVERSITY AT THE TIME OF MERGER. TRUSTEES REPORTED IN PART VII OF THE FORM 990 WERE TRUSTEES OF NATIONAL UNIVERSITY PRIOR TO MERGER AND WILL CONTINUE TO BE TRUSTEES OF NATIONAL UNIVERSITY POST-MERGER. FORM 990, PART III, LINE 3 ON JULY 30, 2021, NORTHCENTRAL'S BOARD OF TRUSTEES APPROVED A PLAN OF MERGER BETWEEN NORTHCENTRAL AND NATIONAL UNIVERSITY, WITH NATIONAL UNIVERSITY TO BE THE SURVIVING ENTITY. THE EFFECTIVE DATE OF THE MERGER WAS NOVEMBER 1, 2022. THE OPERATIONS OF NORTHCENTRAL WILL CONTINUE UNDER THE NATIONAL UNIVERSITY NAME. FORM 990, PART VI, SECTION B, LINE 11B THE DRAFT FORM 990 WAS DISTRIBUTED TO SENIOR MANAGEMENT AND THE AUDIT COMMITTEE. THE FINAL VERSION OF FORM 990 WAS DISTRIBUTED FOR REVIEW BEFORE FILING TO THE TRUSTEES BY EMAIL. FORM 990, PART VI, SECTION B, LINE 12C THE BOARD OF TRUSTEES HAS ANNUALLY REVIEWED AND APPROVED (BY A MAJORITY OF DISINTERESTED TRUSTEES) THE BUSINESS TRANSACTIONS WITH TRUSTEES OR THEIR AFFILIATED PROFESSIONAL SERVICE FIRMS. SUCH REVIEWS INCLUDE CONSIDERATION OF DATA ON COMPARABLE SERVICE PROVIDERS COLLECTED BY UNIVERSITY COUNSEL. THE INTERESTED TRUSTEES WERE EXCUSED FROM BOARD SESSIONS DURING WHICH THOSE BUSINESS TRANSACTIONS WERE DISCUSSED AND DID NOT PARTICIPATE IN VOTING ON SUCH TRANSACTIONS. QUESTIONNAIRES ARE DISTRIBUTED EVERY JANUARY. COMPLIANCE WITH THE CONFLICT OF INTEREST POLICY IS MONITORED BY UNIVERSITY COUNSEL. FORM 990, PART VI, SECTION B, LINE 15 COMPENSATION OF THE PRESIDENT OF THE UNIVERSITY IS REVIEWED BY THE BOARD AT THE TIME OF HIRING AND AS NECESSARY THEREAFTER. COMPENSATION OF OTHER OFFICERS AND KEY EMPLOYEES IS REVIEWED BY THE HUMAN CAPITAL AND COMPENSATION COMMITEE. COMPENSATION IS DETERMINED WITH REGARD TO COMPENSATION PAID TO SENIOR EXECUTIVES OF COMPARABLE NON-PROFIT AND PROPRIETARY INSTITUTIONS IN EDUCATION AND OTHER FIELDS. THE PROCESS IS DOCUMENTED AND WAS LAST COMPLETED IN JUNE 2022. FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATION MAKES IT GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC UPON REQUEST VIA EMAIL. FORM 990, PART XI, LINE 9: NET ASSETS TRANSFER TO NATIONAL UNIVERSITY UPON MERGER -31,692,751. CITY UNIVERSITY OF SEATTLE 521 WALL STREET NO 100 SEATTLE WA 98121 237421224 EDUCATIONAL INSTITUTION WA 501(C)(3) LINE 2 N/A 1 JOHN F KENNEDY UNIVERSITY 9388 LIGHTWAVE AVE SAN DIEGO CA 92123 941610694 EDUCATIONAL INSTITUTION CA 501(C)(3) LINE 2 N/A 1 NATIONAL UNIVERSITY 9388 LIGHTWAVE AVE SAN DIEGO CA 92123 237172306 EDUCATIONAL INSTITUTION CA 501(C)(3) LINE 2 N/A 1 NATIONAL UNIVERSITY INTERNATIONAL INC 9388 LIGHTWAVE AVE SAN DIEGO CA 92123 453997908 INACTIVE CA 501(C)(3) LINE 2 N/A 1 NATIONAL UNIVERSITY VIRTUAL HIGH SCHOOL 9388 LIGHTWAVE AVE SAN DIEGO CA 92123 562438569 EDUCATIONAL INSTITUTION CA 501(C)(3) LINE 10 N/A 1 SPECTRUM PACIFIC LEARNING INC 9388 LIGHTWAVE AVE SAN DIEGO CA 92123 453996682 INACTIVE CA 501(C)(3) LINE 10 N/A 1 SYSTEM MANAGEMENT GROUP 9388 LIGHTWAVE AVE SAN DIEGO CA 92123 201269904 PROVIDE ADMINISTRATIVE SERVICES TO AFFILIATED INSTITUTIONS CA 501 (C)(3) LINE 12B, II N/A 1 0 0 1 0 1 0 0 0 0 0 0 0 1 0 0 1 0 1 0 NATIONAL UNIVERSITY C 1785009 CONTRIBUTION OF PAYABLE NATIONAL UNIVERSITY P 8891340 CASH NATIONAL UNIVERSITY R 31692751 MARKET VALUE SYSTEM MANAGEMENT GROUP M 29234528 CASH SYSTEM MANAGEMENT GROUP E 1143998 MARKET VALUE SCHEDULE R, RELATED ORGANIZATIONS: THE NUS IS AN ALLIANCE OF EDUCATIONAL INSTITUTIONS, SERVING DIVERSE LEARNERS FROM HIGH SCHOOL TO DOCTORAL PROGRAMS. THE NUS INCLUDES 6 INDEPENDENT NON-PROFIT ORGANIZATIONS EXEMPT UNDER IRC SECTION 501(C)(3): NATIONAL UNIVERSITY, NATIONAL UNIVERSITY VIRTUAL HIGH SCHOOL (WHICH CEASED OPERATIONS IN JUNE 2022), NORTHCENTRAL UNIVERSITY, JOHN F. KENNEDY UNIVERSITY (WHICH CEASED OPERATIONS IN DECEMBER 2020), CITY UNIVERSITY OF SEATTLE, AND SYSTEM MANAGEMENT GROUP (SMG). SMG IS A SUPPORTING ORGANIZATION EXEMPT UNDER IRC SECTION 509(A)(3) WHICH PROVIDES SUPPORT AND SERVICES TO ITS TAX-EXEMPT AFFILIATES IN THE NUS. SPECTRUM PACIFIC LEARNING COMPANY LLC AND NATIONAL UNIVERSITY INTERNATIONAL LLC ARE WHOLLY-OWNED BY NATIONAL UNIVERSITY, AND ARE TREATED AS DISREGARDED ENTITIES FOR TAX PURPOSES. THE BOARD OF TRUSTEES OF EACH NUS AFFILIATE GOVERNS EACH AFFILIATE INDEPENDENTLY. THE BOARD OF TRUSTEES HAS NO AUTHORITY TO REMOVE, REPLACE OR APPOINT A MAJORITY OF THE GOVERNING BODY OF THOSE OTHER AFFILIATES. THE BOARD OF TRUSTEES OF EACH AFFILIATE, ACTING IN ITS INDEPENDENT CAPACITY, PERIODICALLY APPOINTS ITS OWN NEW TRUSTEES. THE BOARD OF TRUSTEES HAS A MAJORITY OVERLAPPING COMPOSITION BETWEEN EACH AFFILIATE OF THE NUS. IN ADDITION, THE NUS AUDIT FIRM PREPARES A SET OF "COMBINED NOT "CONSOLIDATED" AUDITED FINANCIAL STATEMENTS THAT INCLUDE THE SIX INDEPENDENT NON-PROFIT ORGANIZATIONS EXEMPT UNDER IRC SECTION 501(C)(3): NATIONAL UNIVERSITY, NATIONAL UNIVERSITY VIRTUAL HIGH SCHOOL, NORTHCENTRAL UNIVERSITY, JOHN F. KENNEDY UNIVERSITY, CITY UNIVERSITY OF SEATTLE, AND SYSTEM MANAGEMENT GROUP.