2022-03-15T09:58:28-05:00 2021-06-30 410746749 CLIFTONLARSONALLEN LLP 901 N GLEBE ROAD SUITE 200 ARLINGTON VA 22203 990 2020-07-01 221905062 MARINE CORPS SCHOLARSHIP FOUNDATION INC MARI 7035490060 909 N WASHINGTON STREET NO 400 ALEXANDRIA VA 22314 EDWARD PROBERT JR PRESIDENT & CHIEF EXECUTIVE OFFICER 7035490060 2022-03-04 1 EDWARD PROBERT JR XXX-XX-XXXX MICHAELA J CROMAR CPA P00895728 5712279500 2022-03-04 3 AAL1 IAL1 2020 2022-09-23 18:48:47Z EDWARD PROBERT JR 909 N WASHINGTON STREET NO 400 ALEXANDRIA VA 22314 78361458 0 X WWW.MCSF.ORG X 1962 NJ TO HONOR MARINES BY EDUCATING THEIR CHILDREN. 28 27 37 379 0 0 18010379 18003057 0 0 2511106 13905448 707019 2377211 21228504 34285716 7560233 8819080 0 0 3597183 3649119 452765 442592 3107894 3221822 2333270 14832003 15244061 6396501 19041655 126336184 149128193 9416635 10492244 116919549 138635949 X SEE SCHEDULE O.THE MARINE CORPS SCHOLARSHIP FOUNDATION IS THE NATION'S OLDEST AND LARGEST PROVIDER OF NEED-BASED SCHOLARSHIPS TO MILITARY CHILDREN. FOUNDED IN 1962, THE MARINE CORPS SCHOLARSHIP FOUNDATION PROVIDES ACCESS TO EDUCATION FOR THE CHILDREN OF MARINES, NAVY CORPSMEN, NAVY CHAPLAINS, AND RELIGIOUS PROGRAM SPECIALISTS ATTENDING POST-HIGH SCHOOL, UNDERGRADUATE, AND CAREER TECHNICAL EDUCATION PROGRAMS. THROUGHOUT OUR HISTORY, WE HAVE AWARDED NEARLY 50,000 SCHOLARSHIPS VALUED AT $155 MILLION. EVERY QUALIFIED STUDENT WHO HAS APPLIED HAS RECEIVED AID. 0 0 10784247 8819080 SEE SCHEDULE OIN THE 2021-22 ACADEMIC YEAR, THE MARINE CORPS SCHOLARSHIP FOUNDATION AWARDED $9.2 MILLION TO 2,510 CHILDREN OF MARINES AND NAVY CORPSMEN IN ALL 50 STATES AND OVERSEAS. THE QUALITY OF THE STUDENTS WE INVEST IN, CHILDREN RAISED BY HONORABLE MARINE AND NAVY CORPSMAN PARENTS, IS HIGHLIGHTED IN THEIR ACADEMIC ACCOMPLISHMENTS. THEY GRADUATE AT A RATE OF 91% (COMPARED TO 56% NATIONALLY), DEMONSTRATING THAT OUR INVESTMENT IN THEIR EDUCATION PAYS OFF. WITH 50% OF OUR RECIPIENTS REPORTING LITTLE TO NO DEBT AT GRADUATION (COMPARED TO 30% NATIONALLY), WE ARE CONFIDENT THAT OUR SCHOLARSHIP SUPPORT MAKES A SIGNIFICANT IMPACT IN THEIR LIVES AFTER GRADUATION.GIVEN THE EVENTS OF 2020, WE ANTICIPATE THE NEXT 5-10 YEARS WILL BRING ITS OWN SET OF NEW DEMANDS FOR SUPPORT. DURING THIS UNPRECEDENTED TIME, WE ARE MONITORING THE UNEXPECTED IMPACTS OF COVID-19 ON HIGHER EDUCATION, THE DEMAND FOR OUR SCHOLARSHIPS, AND THE ACADEMIC PLANS OF INDIVIDUAL STUDENTS. 10784247 1 1 0 0 0 0 0 0 0 1 1 0 0 0 1 1 1 0 0 1 1 0 1 1 1 0 0 0 1 1 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 1 23 0 37 1 0 0 0 0 0 1 1 0 0 0 0 0 0 X 28 27 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 AL AR AZ AK CA CT FL GA HI IL KS KY LA ME MO MA MD MI MN MS NC NH NJ NM NY NV OH OK OR PA RI SC TN UT VA WI WV DC CO ND WA X X RANDAL TURNER 5713842820 909 N WASHINGTON STREET SUITE 400 ALEXANDRIA VA 22314 RUARK ROBERT R PRESIDENT AND CEO 40.00 X X 245304 0 13245 ROBERT B NELLER CHAIRMAN 1.00 X X 0 0 0 ERIC J CANDELORI VICE CHAIRMAN 1.00 X X 0 0 0 RICHARD D STEPHENS TREASURER 1.00 X X 0 0 0 STEVEN M POST GENERAL COUNSEL 1.00 X X 0 0 0 MICHEAL P BARRETT DIRECTOR 1.00 X 0 0 0 RICHARD A BERGEN DIRECTOR 1.00 X 0 0 0 CHARLES F BOLDEN JR DIRECTOR 1.00 X 0 0 0 JON M DAVIS DIRECTOR - THRU SEPT 20 1.00 X 0 0 0 MIGUEL EATON DIRECTOR 1.00 X 0 0 0 GEORGE J FLYNN DIRECTOR 1.00 X 0 0 0 STEVE FUSCO DIRECTOR 1.00 X 0 0 0 MATTHEW GANTZ DIRECTOR 1.00 X 0 0 0 TRACY GARRETT DIRECTOR 1.00 X 0 0 0 FRANK J GAUDIO DIRECTOR 1.00 X 0 0 0 ROBERT E JOYCE JR DIRECTOR 1.00 X 0 0 0 PAUL KENNEDY DIRECTOR 1.00 X 0 0 0 MARGARET G KIBBEN DIRECTOR 1.00 X 0 0 0 THOMAS J LYONS DIRECTOR - THRU SEPT 20 1.00 X 0 0 0 FRANK D MARTELL DIRECTOR 1.00 X 0 0 0 PETER MCCALLUM DIRECTOR 1.00 X 0 0 0 SUSAN E MORRISON DIRECTOR 1.00 X 0 0 0 DAN NELSON DIRECTOR 1.00 X 0 0 0 MELISSA D PALMISCIANO DIRECTOR 1.00 X 0 0 0 GREG PARSONS DIRECTOR 1.00 X 0 0 0 PAUL POHL DIRECTOR 1.00 X 0 0 0 ROBERT W SCHRODER DIRECTOR 1.00 X 0 0 0 CHARLES SCIANNA DIRECTOR 1.00 X 0 0 0 HARVEY SEEGERS DIRECTOR 1.00 X 0 0 0 ROBERT J STEVENS DIRECTOR - THRU SEPT 20 1.00 X 0 0 0 CATHERINE THOMAS DIRECTOR 1.00 X 0 0 0 BERNARD J WILLETT DIRECTOR 1.00 X 0 0 0 PETERSON STEVEN D EXECUTIVE VP, OPERATIONS 40.00 X 200491 0 13291 THAKUR RITA SENIOR DIR OF ACCOUNTING & FINANCE 40.00 X 137794 0 24767 PROBERT EDWARD EXECUTIVE VP, DEVELOPMENT 40.00 X 221084 0 40914 TRISTAN STEPHANIE DIRECTOR OF DEVELOPMENT 40.00 X 136944 0 38319 SAVILLE ASHLEY E SENIOR PHILANTHROPIC OFFICER 40.00 X 163903 0 8192 WILSON CHRISTINE DIRECTOR OF DEVELOPMENT 40.00 X 118855 0 21270 BALSON COURTNEY DIRECTOR INVESTOR RELATIONS 40.00 X 113113 0 19139 ADAMS JEANNA DIRECTOR, SCHOLARSHIP PROGRAMS 40.00 X 109221 0 14089 1446709 0 193226 9 0 1 0 ANNE LEWIS STRATEGIES LLC 120 EAST 1ST STREET PAPOLLION NE 68046 DIGITAL MARKETING PROGRAM 422433 DATOCWITTEN GROUP INC 13145 APPLEGROVE LANE HERNDON VA 20171 EVENT MANAGEMENT 308740 DATA AXLE INC 120 EAST 1ST STREET PAPOLLION NE 68046 DIGITAL MARKETING PROGRAM 165965 INCONIC COLLECTIVE LLC 4136 DEL REY AVENUE SUITE 601 MARINA DEL REY CA 90292 CONTRACTED COMMUNICATIONS SERVICES 151479 PATRICIA J HURLEY & ASSOCIATES INC 205 W WACKER DR STE 1400 CHICAGO IL 60606 EVENT MANAGEMENT 117239 7 16522 5930446 564622 11491467 118998 18003057 2468567 2468567 55141767 43704886 11436881 11436881 11436881 2735237 5930446 367221 2368016 2368016 12830 3635 9195 9195 34285716 0 0 16282659 8792204 8792204 26876 26876 912186 350321 186093 375772 2288258 1033569 252908 1001781 86842 39750 8855 38237 153701 69003 16653 68045 208132 90284 28096 89752 20803 20803 60894 60894 442592 442592 230384 230384 598587 112488 192133 293966 353006 40166 213437 99403 135564 21552 28528 85484 208316 99065 27990 81261 188128 80520 30778 76830 54392 7395 670 46327 17886 5250 7382 5254 36331 15804 5450 15077 40866 40866 OTHER FUNDRAISING EXP 165724 165724 DIRECT MAIL 130737 130737 91652 91652 15244061 10784247 1351920 3107894 17386966 23401949 913104 1338566 16487561 13877692 97039 86284 584774 862300 1026696 999252 59091 27444 90674268 109397864 133381 136094 126336184 149128193 264493 592219 7301082 8011204 1851060 1888821 9416635 10492244 X 15186985 22428658 101732564 116207291 116919549 138635949 126336184 149128193 X 19041655 2649436 25309 X 0 1 X 1 0 X 18807333 28786241 22566724 18010379 18003057 106173734 18807333 28786241 22566724 18010379 18003057 106173734 10795954 95377780 1391078 1637701 3301136 2543868 2468567 11342350 40416 27067 10550 78033 707019 707019 118301136 5363698 0.80620 0.71700 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 67499548 641055 11755040 2278601 77617042 64633001 2454390 2669798 2257641 67499548 58097977 4610876 3786158 1862010 64633001 58925152 1022542 -414230 1435487 58097977 50083327 3679771 6330436 1168382 58925152 0.00000 0.72380 0.27620 0 0 328791 307160 21631 697905 692092 5813 27444 OBLIGATIONS UNDER CHARITABLE TRUSTS AND ANNUITIES 1259883 DEFERRED RENT 59268 PAYCHECK PROTECTION PROGRAM LOAN 569670 1888821 X 37205238 2649436 103505 26109 2779050 34426188 230384 -370856 -140472 34285716 15488838 103505 371656 475161 15013677 230384 230384 15244061 PART V, LINE 4: THE FOUNDATION'S ENDOWMENT FUNDS ARE USED TO PROVIDE SCHOLARSHIPS TO THE CHILDREN OF MARINES, WHO APPLY AND QUALIFY ACCORDING TO THE REQUIREMENTS AS SET BY THE FOUNDATION'S POLICY. PART X, LINE 2: THE FOUNDATION IS EXEMPT FROM THE PAYMENT OF INCOME TAXES ON ITS EXEMPT ACTIVITIES UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE. THE FOUNDATION HAS RECEIVED FROM THE IRS A FAVORABLE RULING THAT IT IS RECOGNIZED AS A "PUBLIC CHARITY" WITHIN THE MEANING OF INTERNAL REVENUE CODE SECTION 170(B)(1)(A)(VI) AND THUS, MEETS THE EXCEPTION TO PRIVATE FOUNDATION STATUS UNDER SECTION 509(A)(1). THE FOUNDATION ADOPTED THE INCOME TAX STANDARD FOR UNCERTAIN INCOME TAX POSITIONS. THE FOUNDATION EVALUATED ITS TAX POSITIONS AND DETERMINED THAT ITS POSITIONS ARE MORE LIKELY THAN NOT TO BE SUSTAINED ON EXAMINATION. THE FOUNDATION'S INCOME TAX RETURNS ARE SUBJECT TO REVIEW AND EXAMINATION BY FEDERAL AND STATE AUTHORITIES. PART XI, LINE 2D - OTHER ADJUSTMENTS: CHANGE IN VALUES OF OBLIGATIONS UNDER CHARITABLE TRUSTS 26,109. PART XI, LINE 4B - OTHER ADJUSTMENTS: FUNDRAISING EVENT EXPENSES -367,221. GAMING EVENT EXPENSES -3,635. PART XII, LINE 2D - OTHER ADJUSTMENTS: FUNDRAISING EVENT EXPENSES 367,221. GAMING EVENT EXPENSES 3,635. BAD DEBTS 800. 0 NORTH AMERICA 0 0 GRANTS TO RECEIPIENTS LOCATED IN THE REGION 1500 EUROPE 0 0 GRANTS TO RECEIPIENTS LOCATED IN THE REGION 9000 EAST ASIA AND THE PACIFIC 0 0 GRANTS TO RECEIPIENTS LOCATED IN THE REGION 8876 CENTRAL AMERICA AND THE CARIBBEAN 0 0 GRANTS TO RECEIPIENTS LOCATED IN THE REGION 7500 0 0 0 0 0 0 26876 0 26876 SCHOLARSHIPS NORTH AMERICA 1 1500 CHECK N/A N/A SCHOLARSHIPS EUROPE 2 9000 WIRE $1,500; CHECK $7,500 N/A N/A SCHOLARSHIPS EAST ASIA AND THE PACIFIC 2 8876 WIRE $3,876; CHECK $5,000 N/A N/A SCHOLARSHIPS CENTRAL AMERICA AND THE CARIBBEAN 2 7500 CHECK N/A N/A 0 0 0 0 0 0 PART I, LINE 2: BEFORE AWARDS ARE MADE, STUDENTS APPLY FOR THE SCHOLARSHIPS AND A POINT SYSTEM IS USED TO DETERMINE THE AWARD AMOUNT TO EACH STUDENT BASED ON ELIGIBILITY AND NEED OF THE STUDENT. STUDENTS MUST PROVIDE INFORMATION TO THE ORGANIZATION, INCLUDING TRANSCRIPTS, VERIFICATION OF STUDENT EXPENSES AND AID FROM THE EDUCATIONAL INSTITUTIONS, AND A STATEMENT OF USE OF THE SCHOLARSHIP FUNDS. EACH STUDENT AND THE EDUCATIONAL INSTITUTION WHERE THE STUDENT IS ENROLLED AGREES THAT THE PAYMENT, OR THE UNUSED PORTION OF THE PAYMENT, MUST BE REFUNDED TO THE SCHOLARSHIP FOUNDATION IF 1) THE STUDENT TRANSFERS, WITHDRAWS OR OTHERWISE LEAVES SCHOOL, 2) THE STUDENT DOES NOT REMAIN IN SATISFACTORY ACADEMIC STANDING AS DEFINED BY THE SCHOOL, 3) THE STUDENT'S BEHAVIOR IS NOT CONSISTENT WITH THE SCHOOL'S STUDENT CONDUCT CODE, OR 4) THE STUDENT IS FOUND GUILTY OF A VIOLATION OF ANY CIVIL CODE. PART III ACCOUNTING METHOD: X X X X X 1 DATOCWITTEN INC 13145 APPLEGROVE LN HERNDON VA 20171 EVENT MANAGEMENT 0 5206737 165100 5041637 THE FASHIONABLE EVENT 1101 WALNUT F HUNTINGTON BEACH CA 92648 EVENT MANAGEMENT 0 1217718 8992 1208726 PATRICIA J HURLEY & ASSOCIATES 205 WEST WACKER DR STE 1400 CHICAGO IL 60606 EVENT MANAGEMENT 0 861817 40000 821817 DATA AXLE INC 120 EAST 1ST ST PAPOLLION NE 68046 DIRECT MARKETING PROGRAM 0 746023 60000 686023 ANNE LEWIS STRATEGIES LLC 120 EAST 1ST ST PAPOLLION NE 68046 DIGITAL ADVERTISING AND MARKETING 0 687206 168500 518706 8719501 442592 8276909 AL AK AZ AR CA CO CT DC FL GA HI IL KS KY LA MA MD ME MI MN MO MS MT NC ND NE NH NJ NM NV NY OH OK OR PA RI SC SD TN UT VA WA WI WV WY WASHINGTON CELEBRATORY GALA 510893 386200 124693 1264 21731 42310 WICKENBURG RANCH GOLF 210860 115860 95000 4110 10983 38625 24 7940273 5428386 2511887 62458 65538 120202 8662026 5930446 2731580 67832 98252 201137 367221 2364359 SCHEDULE G, PART I, LINE 2B, COLUMN (V) MARINE CORPS SCHOLARSHIP FOUNDATION, INC. (THE FOUNDATION) PAID PROFESSIONAL FUNDRAISERS FOR PROFESSIONAL FUNDRAISING SERVICES AND ADMINISTRATIVE FEES. IN 2020, THE FOUNDATION PAID ADMINISTRATIVE FEES AND EXPENSE REIMBURSEMENTS TO THE FOLLOWING PROFESSIONAL FUNDRAISERS: PATRICIA J. HURLEY - $40,000 THE FASHIONAL EVENT - $20,981 DATOC WITTEN - $165,724 ANNE LEWIS, LLC - $274,000 DATA AXLE - $110,590 1 SCHOLARSHIP AWARDS 2726 8792204 N/A N/A PART I, LINE 2: BEFORE AWARDS ARE MADE, STUDENTS APPLY FOR THE SCHOLARSHIPS AND A POINT SYSTEM IS USED TO DETERMINE THE AWARD AMOUNT TO EACH STUDENT BASED ON ELIGIBILITY AND NEED OF THE STUDENT. STUDENTS MUST PROVIDE INFORMATION TO THE ORGANIZATION, INCLUDING TRANSCRIPTS, VERIFICATION OF STUDENT EXPENSES AND AID FROM THE EDUCATIONAL INSTITUTIONS, AND A STATEMENT OF USE OF THE SCHOLARSHIP FUNDS. EACH STUDENT AND THE EDUCATIONAL INSTITUTION WHERE THE STUDENT IS ENROLLED AGREES THAT THE PAYMENT, OR THE UNUSED PORTION OF THE PAYMENT, MUST BE REFUNDED TO THE SCHOLARSHIP FOUNDATION IF 1) THE STUDENT TRANSFERS, WITHDRAWS OR OTHERWISE LEAVES SCHOOL, 2) THE STUDENT DOES NOT REMAIN IN SATISFACTORY ACADEMIC STANDING AS DEFINED BY THE SCHOOL, 3) THE STUDENT'S BEHAVIOR IS NOT CONSISTENT WITH THE SCHOOL'S STUDENT CONDUCT CODE, OR 4) THE STUDENT IS FOUND GUILTY OF A VIOLATION OF ANY CIVIL CODE. X 1 1 X X X X 0 0 0 1 0 0 0 0 0 PROBERT EDWARD EXECUTIVE VP, DEVELOPMENT 212069 0 0 0 9015 0 11475 0 29439 0 261998 0 0 0 RUARK ROBERT R PRESIDENT AND CEO 245304 0 0 0 0 0 12225 0 1020 0 258549 0 0 0 PETERSON STEVEN D EXECUTIVE VP, OPERATIONS 191269 0 7500 0 1722 0 10111 0 3180 0 213782 0 0 0 TRISTAN STEPHANIE DIRECTOR OF DEVELOPMENT 122970 0 0 0 13974 0 6670 0 31649 0 175263 0 0 0 SAVILLE ASHLEY E SENIOR PHILANTHROPIC OFFICER 153903 0 10000 0 0 0 8192 0 0 0 172095 0 0 0 THAKUR RITA SENIOR DIR OF ACCOUNTING & FINANCE 120020 0 7500 0 10274 0 7375 0 17392 0 162561 0 0 0 PART I, LINE 1A MRS. CHRISTINE COETZEE, THE SPOUSE OF PRESIDENT AND CEO LIEUTENANT GENERAL ROBERT RUARK, TRAVELED TO EVENTS FOR THE SCHOLARSHIP FOUNDATION IN A PROFESSIONAL CAPACITY ON TWO OCCASIONS IN 2020. THE EXPENSES INCURRED WERE FLIGHTS TOTALING $2,030.20, NOT INCLUDED IN TAXABLE COMPENSATION. AT THESE EVENTS, MRS. COETZEE'S DEVELOPMENT OF RELATIONSHIPS WITH INVESTORS AND KEY SUPPORTERS WAS CRITICAL TO THE PROMOTION OF THE SCHOLARSHIP FOUNDATION'S MISSION AND HELPED THE ORGANIZATION ACHIEVE ITS FUNDRAISING GOALS. X 14 108515 PUBLISHED MARKET VALUE X AUCTION ITEMS 5 2931 COST & SELLING PRICE 0 1 1 PART I, COLUMN (B): REPRESENTS NUMBER OF CONTRIBUTORS FOR SECURITIES AND NUMBER OF ITEMS FOR AUCTION. PART I, LINE 32B: STOCK CONTRIBUTIONS THROUGH EVENTS THAT USE THIRD PARTY SOLICITORS, AND INVESTMENT MANAGER TO SELL STOCK CONTRIBUTIONS UPON RECEIPT FORM 990, PART VI, SECTION A, LINE 1 THE BOARD OF DIRECTORS, BY RESOLUTION ADOPTED BY A MAJORITY OF THE ENTIRE BOARD, SHALL APPOINT FROM AMONG THE DIRECTORS AN EXECUTIVE COMMITTEE (WHICH SHALL INCLUDE COMPENSATION AMONG ITS FUNCTIONS), AND FROM AMONG THE DIRECTORS AND, IN THE BOARD'S SOLE DISCRETION, PERSONS WHO ARE NOT DIRECTORS, A CORPORATE GOVERNANCE COMMITTEE (WHICH SHALL INCLUDE NOMINATIONS AMONG ITS FUNCTIONS), A SCHOLARSHIP COMMITTEE, A DEVELOPMENT COMMITTEE, A FINANCE AND INVESTMENT COMMITTEE, AND AN AUDIT COMMITTEE. DIRECTORS SHALL COMPRISE A MAJORITY OF ANY SUCH STANDING COMMITTEE TO WHICH PERSONS WHO ARE NOT DIRECTORS MAY BE APPOINTED. THE BOARD, IN ITS SOLE DISCRETION, MAY ALSO APPOINT FROM AMONG THE DIRECTORS AND PERSONS WHO ARE NOT DIRECTORS ONE OR MORE OTHER COMMITTEES, EACH OF WHICH SHALL HAVE ONE OR MORE COMMITTEE MEMBERS INCLUDING AT LEAST ONE DIRECTOR. THE NUMBER OF DIRECTORS TO BE APPOINTED TO THE EXECUTIVE COMMITTEE SHALL NOT EXCEED TEN AND SHALL INCLUDE THE CHAIRMAN, THE VICE CHAIRMAN OR, IF THERE IS MORE THAN ONE, THE VICE CHAIRMAN DESIGNATED TO SUCCEED THE CHAIRMAN IN HIS OR HER ABSENCE, THE PRESIDENT, THE CHAIR OF EACH OF THE OTHER STANDING COMMITTEES, THE TREASURER, AND THE GENERAL COUNSEL. THE EXECUTIVE COMMITTEE SHALL HAVE AND EXERCISE THE FULL AUTHORITY OF THE BOARD OF DIRECTORS IN THE MANAGEMENT OF THE CORPORATION. ALL OTHER COMMITTEES, TO THE EXTENT PROVIDED IN THEIR RESPECTIVE ENABLING RESOLUTIONS AND NOT RESTRICTED BY LAW, SHALL HAVE AND EXERCISE SUCH AUTHORITY AS THE BOARD OF DIRECTORS SHALL PRESCRIBE IN THE MANAGEMENT OF THE CORPORATION. THE DESIGNATION OF ANY COMMITTEE, WHETHER UNDER THESE BYLAWS OR BY RESOLUTION ADOPTED BY THE BOARD, AND THE DELEGATION THERETO OF AUTHORITY SHALL NOT OPERATE TO RELIEVE THE BOARD OF DIRECTORS, OR ANY INDIVIDUAL DIRECTOR, OF ANY RESPONSIBILITY IMPOSED ON IT, HIM, OR HER BY LAW. FORM 990, PART VI, SECTION B, LINE 11B THE RETURN IS REVIEWED AND APPROVED BY MANAGEMENT, THE ORGANIZATION'S BOARD OF DIRECTORS AND GENERAL COUNSEL BEFORE FILING WITH IRS. FORM 990, PART VI, SECTION B, LINE 12C THE BOARD MEMBERS ARE REQUIRED TO READ THE CONFLICT OF INTEREST POLICY ON AN ANNUAL BASIS. THEY MUST SIGN THAT THEY READ IT AND THEN COMPLETE A FORM THAT LISTS ANY CONFLICTS. THERE ARE PERIODIC REVIEWS TO ENSURE COMPLIANCE. AT SUCH TIME AS ANY MATTER COMES BEFORE THE BOARD IN SUCH A WAY AS TO GIVE RISE TO A CONFLICT OF INTEREST, THE INTERESTED OFFICER, IF ATTENDING THE MEETING, OR DIRECTOR SHALL MAKE KNOWN THE POTENTIAL CONFLICT, WHETHER OR NOT DISCLOSED BY HIS OR HER WRITTEN STATEMENT, AND AFTER ANSWERING ANY QUESTIONS THAT MIGHT BE ASKED OF SUCH OFFICER OR DIRECTOR, HE OR SHE SHALL WITHDRAW FROM THE MEETING FOR SO LONG AS THE MATTER SHALL CONTINUE UNDER DISCUSSION. SHOULD THE MATTER BE BROUGHT TO A VOTE, NEITHER THE INTERESTED DIRECTOR NOR ANY OTHER DIRECTOR HAVING A PECUNIARY BENEFIT TRANSACTION WITH THE FOUNDATION SHALL VOTE ON IT. A TWO-THIRDS (66 2/3%) VOTE OF THE ENTIRE BOARD IS REQUIRED TO AUTHORIZE ANY TRANSACTION OR OTHER MATTER IN WHICH AN OFFICER OR DIRECTOR HAS A POTENTIAL CONFLICT OF INTEREST. ALL PROCEEDINGS RELATED TO CONFLICTS OF INTEREST ARE DOCUMENTED IN THE MEETING MINUTES. FORM 990, PART VI, SECTION B, LINE 15 THE PROCESS FOR DETERMINING THE COMPENSATION OF CEO, EXECUTIVE DIRECTOR OR TOP MANAGEMENT OFFICIAL: CONSULTATION WITH HR CONSULTANT WHO PROVIDED A SALARY SURVEY OF COMPARABLE SIZED NONPROFIT ORGANIZATIONS (NPOS) NATIONALLY AND IN THE DC AREA, INCLUDING OTHER UNITED STATES MARINE CORPS (USMC)-RELATED NPOS. EXECUTIVE COMMITTEE REVIEWED SCOPE OF WORK, DEMANDS AND IF CEO ANNUAL GOALS WERE ACHIEVED. RECOMMENDED COMPENSATION WAS PROVIDED BY WRITTEN COMMUNICATION TO THE EXECUTIVE COMMITTEE WHICH WAS THEN DISCUSSED AND VOTED UPON FOR APPROVAL WITH EVIDENCE OF APPROVAL BEING MAINTAINED BY BOARD VICE CHAIR. THE PROCESS WAS LAST UNDERTAKEN IN FY 2020 THE PROCESS OF DETERMINING THE COMPENSATION OF OFFICERS OR KEY EMPLOYEES: CONSULTATION WITH HR CONSULTANT, WHICH INCLUDES SALARY SURVEYS FOR RESPECTIVE POSITIONS AND/OR INTERVIEWS OF OTHER SIMILAR NPOS, AND CONSULTATION WITH EXECUTIVE RECRUITERS REGARDING THEIR RECOMMENDED SALARY BASED ON NATURE AND DUTIES OF THE POSITION. INFORMATION REVIEWED BY PRESIDENT/CEO AND DOCUMENTED BY THE HR CONSULTANT. THE PROCESS WAS LAST UNDERTAKEN IN FY 2019. FORM 990, PART VI, SECTION C, LINE 19 THE FOUNDATION PUBLISHES AN ANNUAL REPORT THAT INCLUDES FINANCIAL DATA. THE ANNUAL REPORT, AS WELL AS AUDITED FINANCIAL STATEMENTS, ARE POSTED TO THE WEBSITE. THE GOVERNING DOCUMENTS AND CONFLICT OF INTEREST STATEMENT ARE AVAILABLE TO THE PUBLIC UPON REQUEST. FORM 990, PART XI, LINE 9: CHANGE IN VALUES OF OBLIGATIONS UNDER CHARITABLE TRUSTS 26,109. BAD DEBT -800.