2021-09-17T07:04:54-05:00 2020-12-31 111986323 MARCUM LLP 1899 L STREET NW SUITE 850 WASHINGTON DC 20036 990 2020-01-01 300126510 CENTER FOR AMERICAN PROGRESS CENT 2026821611 1333 H STREET NW 10TH FLOOR WASHINGTON DC 20005 DEBORAH HOLSTON VP OF FINANCE AND INTERIM CFO 2026821611 2021-09-17 1 DEBORAH HOLSTON 999009999 AARON M FOX P01365820 2022274000 2021-09-15 3 AAL1 IAL1 2020 2022-09-23 18:48:47Z DEBORAH HOLSTON 1333 H STREET NW 10TH FLOOR WASHINGTON DC 20005 50710695 0 X WWW.AMERICANPROGRESS.ORG X 2002 DC NON-PARTISAN RESEARCH AND EDUCATION DEDICATED TO ADVANCING PROGRESSIVE POLICY IDEAS. 12 11 380 11 0 0 46527777 49970182 311684 233012 829303 168221 71169 339280 47739933 50710695 10995745 10074959 0 0 28646649 29486258 0 0 1685470 9793023 9134492 49435417 48695709 -1695484 2014986 59246466 60558796 5927579 5224923 53318887 55333873 X THE CENTER FOR AMERICAN PROGRESS (CAP) IS AN INDEPENDENT NON-PARTISAN POLICY INSTITUTE THAT IS DEDICATED TO IMPROVING THE LIVES OF ALL AMERICANS, THROUGH BOLD, PROGRESSIVE IDEAS, AS WELL AS STRONG LEADERSHIP AND CONCERTED ACTION. OUR AIM IS NOT JUST TO CHANGE THE CONVERSATION, BUT TO CHANGE THE COUNTRY. 0 0 22491002 985765 233012 POLICY PROGRAMS: PUBLIC POLICY RESEARCH AND ANALYSIS WAS CONDUCTED IN AREAS OF ENERGY AND THE ENVIRONMENT, EDUCATION, HEALTH CARE, IMMIGRATION, OPEN GOVERNMENT, POVERTY, LGBT RIGHTS, AND WOMEN'S RIGHTS. IN ADDITION, THE ECONOMIC POLICY TEAM CONDUCTED PROJECTS RELATING TO MIDDLE CLASS ECONOMICS, TAX FAIRNESS, HOUSING, AND POST-SECONDARY EDUCATION. CAP'S NATIONAL SECURITY TEAM WORKED ON PROJECTS RELATING TO CHINESE AND MIDDLE EASTERN RELATIONS WITH THE U.S. 8884943 6325304 EXTERNAL RELATIONS: THE EXTERNAL RELATIONS DEPARTMENT ENGAGED IN EDUCATION OF THE PUBLIC, POLICYMAKERS, OPINION LEADERS AND ADVOCATES REGARDING PUBLIC POLICY THROUGH A WIDE ARRAY OF DISSEMINATION CHANNELS, INCLUDING FAITH COMMUNITIES, CAMPUS ORGANIZATIONS, PRINT, AND ONLINE MEDIA. 6464997 2729890 COMMUNICATIONS: THE COMMUNICATIONS TEAM EDUCATED THE PUBLIC AND ASSISTED THE WORK OF POLICY TEAMS BY PROVIDING PRESS, COMMUNICATIONS, AND EVENTS SUPPORT. 2350067 34000 EXECUTIVE OFFICE 1896864 ART AND EDITORIAL 886744 GENERATION PROGRESS 5133675 34000 42974617 1 1 0 1 0 0 0 0 0 0 1 0 0 0 1 1 1 0 0 0 1 1 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 80 0 1 380 1 0 0 0 0 0 0 0 0 0 0 0 0 X 12 11 1 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 AL AK AR CA CT FL GA HI IL KS KY MD MA MI MN MS NH NJ NM NY NC OK OR PA RI SC TN UT VA WV WI X DEBORAH HOLSTON 2026821611 1333 H STREET NW 10TH FLOOR WASHINGTON DC 20005 NEERA TANDEN PRESIDENT 39.00 X X 394716 0 54625 CYNTHIA W STACHELBERG EVP, EXTERNAL AFFAIRS 38.00 X 232370 0 30822 GORDON GRAY TREASURER, COO 40.00 X 238727 0 20179 ALEX DEMOTS SVP, GENERAL COUNSEL AND SECRETARY 38.00 X 201860 0 35681 CHRISTINA GOLDFUSS VP, CLIMATE 39.00 X 202423 0 33277 BRIAN DEMARCO VP, DEVELOPMENT 39.00 X 206277 0 18681 JODI ENDA SENIOR FELLOW 40.00 X 201552 0 22815 MARA RUDMAN EVP, POLICY 39.00 X 200742 0 19429 SHANE BATEMAN SVP FINANCE AND ADMIN CFO - UNTIL 12/2020 32.00 X 175694 0 21455 SENATOR TOM DASCHLE CHAIR 1.00 X 0 0 0 STACEY ABRAMS DIRECTOR 1.00 X 0 0 0 JULIAN CASTRO DIRECTOR 1.00 X 0 0 0 STEVE DAETZ DIRECTOR 1.00 X 0 0 0 ANDREW HAUPTMAN DIRECTOR 1.00 X 0 0 0 GLENN HUTCHINS DIRECTOR 1.00 X 0 0 0 ERIC MINDICH DIRECTOR 1.00 X 0 0 0 KRISTIN MUGFORD DIRECTOR 1.00 X 0 0 0 JOHN PODESTA DIRECTOR/AUDIT COMMITTEE CHAIR 15.00 X 0 0 0 DONALD SUSSMAN DIRECTOR 1.00 X 0 0 0 HANSJORG WYSS DIRECTOR 1.00 X 0 0 0 2054361 0 256964 95 0 1 0 GBAO 1701 STREET NW WASHINGTON DC 20006 PUBLIC POLL 263000 CATHLEEN KELLY 8 PINE AVENUE TAKOMA PARK MD 20912 CONSULTANT 222226 RHODIUM GROUP LLC 5 COLUMBUS CIRCLE NEW YORK NY 10019 RESEARCH 200000 VAN BROWNCOM LTD 22 FORESTERS WALK STAMFORD BRIDGE UK Y041 1BB SENIOR FELLOW 141084 K2D STRATEGIES 4075 WILSON BOULEVARD SUITE 800 ARLINGTON VA 22203 CONSULTANT 111814 7 49970182 49970182 PROGRAM SERVICE INCOME 900099 233012 233012 233012 168221 168221 6312 6312 SUBLEASE INCOME 900099 326804 326804 OFFICE SHARING INCOME 900099 6164 6164 332968 50710695 233012 0 507501 10056015 10056015 18944 18944 1142937 748845 339608 54484 23794297 20254509 2526992 1012796 1141158 977778 115445 47935 1424546 1217320 146893 60333 1983320 1673444 225408 84468 72219 60935 8208 3076 81961 69155 9315 3491 2549288 2324797 57060 167431 103820 100056 228 3536 489810 412858 54177 22775 936752 794802 108198 33752 2719423 2294538 309067 115818 182287 164306 5581 12400 267772 265296 1871 605 379067 319841 43082 16144 92131 77736 10471 3924 UBI TAX 10523 8879 1196 448 OTHER EXPENSES 714376 614872 69126 30378 PUBLIC OPINION ANALYSIS 390700 390700 SUBSCRIPTIONS 119363 103991 3696 11676 25000 25000 48695709 42974617 4035622 1685470 3267487 203471 40977764 49887916 13553500 8481264 189745 512948 456115 553577 9636209 8943860 523233 692349 270828 227271 7794 0 59246466 60558796 2271198 2985216 3656381 2239707 5927579 5224923 X 29492660 30260606 23826227 25073267 53318887 55333873 59246466 60558796 2014986 0 X 0 1 X 1 0 X 40506676 51162013 43221801 46527777 49970182 231388449 40506676 51162013 43221801 46527777 49970182 231388449 45362849 186025600 462730 360994 992561 1151671 501337 3469293 74715 50313 5925 6043 6164 143160 235000902 1354429 0.79160 0.78660 X SCHEDULE A, PART II, LINE 10, EXPLANATION OF OTHER INCOME: OFFICE SHARING INCOME - 2016 AMOUNT: $ 74,715. 2017 AMOUNT: $ 50,313. 2018 AMOUNT: $ 5,925. 2019 AMOUNT: $ 6,043. 2020 AMOUNT: $ 6,164. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 40351 97898 138249 48557460 48695709 1000000 250000 0 0 1000000 1000000 1000000 1000000 4000000 6000000 328535 213768 195855 138249 876407 250000 250000 250000 250000 1000000 1500000 110354 34158 17308 40351 202171 4812509 4175852 636657 1464476 1443635 20841 3359224 3324373 34851 692349 DEFERRED LEASE OBLIGATIONS 1497966 DEFERRED COMPENSATION OBLIGATION 227271 DUE TO CENTER FOR AMERICAN PROGRESS ACTION FUND 514470 2239707 X 50710695 0 50710695 0 50710695 48695709 0 48695709 0 48695709 PART X, LINE 2: CAP EVALUATED ITS UNCERTAINTY IN INCOME TAXES FOR THE YEARS ENDED DECEMBER 31, 2020 AND 2019, AND DETERMINED THAT THERE WERE NO MATTERS THAT WOULD REQUIRE RECOGNITION IN THE FINANCIAL STATEMENTS OR THAT MAY HAVE ANY EFFECT ON ITS TAX-EXEMPT STATUS. 1 EUROPE 0 0 GRANTMAKING 18944 0 0 0 0 0 0 18944 0 18944 EUROPE SUPPORT CHARITABLE EDUCATION ACTIVITIES 18944 WIRE 1 0 0 0 0 0 0 0 PART I, LINE 2: CAP REQUIRES GRANTEE ORGANIZATIONS TO REPRESENT, WARRANT AND AGREE: THAT IT WILL USE GRANT FUNDS SOLELY FOR PURPOSES CONSISTENT WITH CAP'S TAX-EXEMPT STATUS UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE; THAT NO PORTION OF GRANT FUNDS WILL BE USED DIRECTLY OR INDIRECTLY TO EXPRESSLY OR IMPLICITLY SUPPORT OR OPPOSE ANY CANDIDATE SEEKING ELECTION TO PUBLIC OFFICE, OR PROVIDE A BENEFIT TO ANY POLITICAL PARTY OR CANDIDATE; THAT IT WILL ALLOW CAP'S STAFF OR REPRESENTATIVES TO CONDUCT EVALUATIONS AND AUDITS OF THE USE OF GRANT FUNDS, WHICH MAY INVOLVE VISITS TO OBSERVE, REVIEW AND DISCUSS ITS OPERATIONS, FINANCIAL RECORDS, AND OTHER MATERIALS CONNECTED WITH THE GRANTEE; AND THAT IT WILL SEND CAP FINAL FINANCIAL AND NARRATIVE REPORTS BY A DATE SPECIFIED IN THE ORIGINAL AWARD LETTER. CAP REQUIRES DONEE ORGANIZATIONS TO PROVIDE NARRATIVE AND FINANCIAL REPORTS THAT: ARE SIGNED BY AN OFFICER OF THE ORGANIZATION; DESCRIBE HOW THE FUNDS WERE SPENT AND WHAT WAS ACCOMPLISHED; AND TO PROVIDE A REASONABLY DETAILED ACCOUNT OF THE ACTIVITIES CONDUCTED BY THE GRANTEE IN PERFORMANCE OF THE AGREED UPON WORK. PART I, LINE 3: THE ACCRUAL METHOD OF ACCOUNTING WAS USED TO ACCOUNT FOR THE FOREIGN EXPENDITURES. PART III ACCOUNTING METHOD: PART II, LINE 1: THE ACCRUAL METHOD OF ACCOUNTING WAS USED TO ACCOUNT FOR THE FOREIGN GRANTS. 1 CENTER FOR AMERICAN PROGRESS ACTION FUND 1333 H STREET NW 10TH FLOOR WASHINGTON DC 20005 300192708 501(C)(4) 6907944 PUBLIC EDUCATION & ADVOCACY CENTER ON BUDGET AND POLICY PRIORITIES 1275 FIRST STREET NE SUITE 1200 WASHINGTON DC 20002 521234565 501(C)(3) 613750 SUPPORT CHARITABLE EDUCATION ACTIVITIES CENTER FOR LAW AND SOCIAL POLICY 1200 18TH STREET NE SUITE 200 WASHINGTON DC 20005 237000150 501(C)(3) 613750 SUPPORT CHARITABLE EDUCATION ACTIVITIES GEORGETOWN UNIVERSITY LAW CENTER 600 NEW JERSEY AVENUE NW WASHINGTON DC 20001 530196603 501(C)(3) 613750 SUPPORT CHARITABLE EDUCATION ACTIVITIES CENTER FOR HEALTH ENERGY AND DEMOCRACY 4511 34TH AVENUE SOUTH SUITE A MINNEAPOLIS MN 55406 452580349 501(C)(3) 603000 SUPPORT CHARITABLE EDUCATION ACTIVITIES NATIONAL EMPLOYMENT LAW PROJECT 90 BROAD STREET SUITE 1100 NEW YORK NY 10004 122758558 501(C)(3) 155000 SUPPORT CHARITABLE EDUCATION ACTIVITIES COMMUNITY LEGAL SERVICES 1424 CHESTNUT STREET PHILADELPHIA PA 19102 231671562 501(C)(3) 110000 SUPPORT CHARITABLE EDUCATION ACTIVITIES ACTION CENTER ON RACE AND THE ECONOMY AMERICANS FOR FINANCIAL REFORM 1901 W CARROLL AVENUE CHICAGO IL 60612 821199695 501(C)(3) 75000 SUPPORT CHARITABLE EDUCATION ACTIVITIES ARIZONA STATE UNIVERSITY PO BOX 876011 TEMPE AZ 85287 866051042 501(C)(3) 62500 SUPPORT CHARITABLE EDUCATION ACTIVITIES DARE DIRECT ACTION FOR RIGHTS AND EQUALITY 340 LOCKWOOD STREET PROVIDENCE RI 02907 050422763 501(C)(3) 50000 SUPPORT CHARITABLE EDUCATION ACTIVITIES US CLIMATE ACTION NETWORK 916 LADE STREET SANDPOINT ID 83864 054597308 501(C)(3) 50000 SUPPORT CHARITABLE EDUCATION ACTIVITIES ACTION NC 1817 CENTRAL AVENUE SUITE 211 CHARLOTTE NC 28205 581447670 501(C)(3) 35000 SUPPORT CHARITABLE EDUCATION ACTIVITIES COLORADO CENTER ON LAW AND POLICY 789 SHERMAN STREET DENVER CO 80203 841264154 501(C)(3) 30000 SUPPORT CHARITABLE EDUCATION ACTIVITIES CENTER FOR COMMUNITY SELF HELP 301 W MAIN STREET DURHAM NC 27701 561271685 501(C)(3) 25000 SUPPORT CHARITABLE EDUCATION ACTIVITIES THE CLEO INSTITTUTE 2103 CORAL WAY 2ND FLOOR MIAMI FL 33145 273185735 501(C)(3) 18000 SUPPORT CHARITABLE EDUCATION ACTIVITIES ADVOCATES FOR RESPONSIBLE CARE 1434 BROOK VALLEY LANE NE ATLANTA GA 30324 271347800 501(C)(3) 17821 SUPPORT CHARITABLE EDUCATION ACTIVITIES INERFAITH ALLIANCE OF IOWA PO BOX 41086 DES MOINES IA 50311 421459354 501(C)(3) 15000 SUPPORT CHARITABLE EDUCATION ACTIVITIES MOMSRISING EDUCATION FUND 12011 BE-RED ROAD SUITE 100A BELLEVUE WA 98005 452499952 501(C)(3) 15000 SUPPORT CHARITABLE EDUCATION ACTIVITIES NORTH CAROLINA COUNCIL OF CHURCHES 27 HORNE STREET RALEIGH NC 27607 560619364 501(C)(3) 15000 SUPPORT CHARITABLE EDUCATION ACTIVITIES NORTH CAROLINIANS AGAINST GUN VIOLENCE 43 FAIROAKS CIRCLE CHAPEL HILL NC 27516 561897050 501(C)(3) 15000 SUPPORT CHARITABLE EDUCATION ACTIVITIES HOPEWELL FUND 1201 CONNECTICUTT AVENUE SUITE 300 WASHINGTON DC 20036 473681860 501(C)(3) 7500 SUPPORT CHARITABLE EDUCATION ACTIVITIES 20 1 PART I, LINE 2: CAP REQUIRES GRANTEE ORGANIZATIONS TO REPRESENT, WARRANT AND AGREE: THAT IT WILL USE GRANT FUNDS SOLELY FOR PURPOSES CONSISTENT WITH CAP'S TAX-EXEMPT STATUS UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE; THAT NO PORTION OF GRANT FUNDS WILL BE USED DIRECTLY OR INDIRECTLY TO EXPRESSLY OR IMPLICITLY SUPPORT OR OPPOSE ANY CANDIDATE SEEKING ELECTION TO PUBLIC OFFICE, OR PROVIDE A BENEFIT TO ANY POLITICAL PARTY OR CANDIDATE; THAT IT WILL ALLOW CAP'S STAFF OR REPRESENTATIVES TO CONDUCT EVALUATIONS AND AUDITS OF THE USE OF GRANT FUNDS, WHICH MAY INVOLVE VISITS TO OBSERVE, REVIEW AND DISCUSS ITS OPERATIONS, FINANCIAL RECORDS, AND OTHER MATERIALS CONNECTED WITH THE GRANTEE; AND THAT IT WILL SEND CAP FINAL FINANCIAL AND NARRATIVE REPORTS BY A DATE SPECIFIED IN THE ORIGINAL AWARD LETTER. CAP REQUIRES DONEE ORGANIZATIONS TO PROVIDE NARRATIVE AND FINANCIAL REPORTS THAT: ARE SIGNED BY AN OFFICER OF THE ORGANIZATION; DESCRIBE HOW THE FUNDS WERE SPENT AND WHAT WAS ACCOMPLISHED; AND TO PROVIDE A REASONABLY DETAILED ACCOUNT OF THE ACTIVITIES CONDUCTED BY THE GRANTEE IN PERFORMANCE OF THE AGREED UPON WORK. X X X X 0 0 0 0 0 0 0 0 0 NEERA TANDEN PRESIDENT 394716 0 0 0 0 0 35235 0 19390 0 449341 0 0 0 CYNTHIA W STACHELBERG EVP, EXTERNAL AFFAIRS 232370 0 0 0 0 0 18327 0 12495 0 263192 0 0 0 GORDON GRAY TREASURER, COO 238727 0 0 0 0 0 18953 0 1226 0 258906 0 0 0 ALEX DEMOTS SVP, GENERAL COUNSEL AND SECRETARY 201860 0 0 0 0 0 16018 0 19663 0 237541 0 0 0 CHRISTINA GOLDFUSS VP, CLIMATE 202423 0 0 0 0 0 16059 0 17218 0 235700 0 0 0 BRIAN DEMARCO VP, DEVELOPMENT 206277 0 0 0 0 0 10227 0 8454 0 224958 0 0 0 JODI ENDA SENIOR FELLOW 201552 0 0 0 0 0 10004 0 12811 0 224367 0 0 0 MARA RUDMAN EVP, POLICY 200742 0 0 0 0 0 11847 0 7582 0 220171 0 0 0 SHANE BATEMAN SVP FINANCE AND ADMIN CFO - UNTIL 12/2020 175694 0 0 0 0 0 14468 0 6987 0 197149 0 0 0 FORM 990, PART VI, SECTION A, LINE 2 JOHN PODESTA HAS CONSULTING AGREEMENTS WITH FIDELITY CHARITABLE AND THE SANDLER FOUNDATION. FORM 990, PART VI, SECTION B, LINE 11B THE FINANCE DEPARTMENT WORKED DIRECTLY WITH AN INDEPENDENT ACCOUNTING FIRM TO PREPARE THE FEDERAL FORM 990 ON BEHALF OF CAP. THE FINANCE DEPARTMENT MANAGES THE PROCESS, WITH CLOSE COORDINATION WITH THE LEGAL DEPARTMENT. THE ACCOUNTING FIRM PROVIDED A DRAFT FEDERAL FORM 990, WHICH WAS THEN REVIEWED AND COMMENTED ON BY THE FINANCE DEPARTMENT, THE LEGAL DEPARTMENT AND THE CORPORATE OFFICERS. THE UPDATED DRAFT FEDERAL FORM 990 AND SUMMARY MATERIALS WERE THEN PROVIDED TO THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS FOR REVIEW AND CONSIDERATION ON BEHALF OF THE FULL BOARD OF DIRECTORS. THE AUDIT COMMITTEE WAS OFFERED THE OPPORTUNITY TO DISCUSS THE MATERIALS WITH CAP'S STAFF AND THE ACCOUNTING FIRM THAT PREPARED THE FEDERAL FORM 990. THE AUDIT COMMITTEE APPROVED THE DRAFT FEDERAL FORM, AND THE FULL BOARD OF DIRECTORS RECEIVED THE APPROVED VERSION OF THE FORM BEFORE FILING WITH THE INTERNAL REVENUE SERVICE. FORM 990, PART VI, SECTION B, LINE 12C CAP IS COMMITTED TO PREVENTING OUTSIDE FINANCIAL INTERESTS OF ITS BOARD MEMBERS, OFFICERS OR EMPLOYEES FROM INFLUENCING ITS ACTIVITIES. TO THAT END, IT HAS ADOPTED AND ENFORCES POLICIES TO PREVENT CONFLICTS OF INTEREST AND THE APPEARANCE OF CONFLICTS OF INTEREST, INCLUDING SEPARATE POLICIES GOVERNING (1) OFFICERS, DIRECTORS, AND KEY EMPLOYEES; AND (2) ALL EMPLOYEES. COMPLIANCE WITH POLICIES GOVERNING OFFICERS, DIRECTORS AND KEY EMPLOYEES. OFFICERS, DIRECTORS AND KEY EMPLOYEES (IF ANY) RECEIVE A COPY OF THE CONFLICT OF INTEREST POLICY ANNUALLY, AND ARE ASKED TO REVIEW THE POLICY AND SIGN AN ACKNOWLEDGEMENT AFFIRMING RECEIPT, REVIEW AND AGREEMENT TO COMPLY WITH THE POLICY, AS WELL AS UNDERSTANDING THAT CAP IS A CHARITABLE ORGANIZATION. IN ADDITION, OFFICERS, DIRECTORS AND KEY EMPLOYEES ARE ASKED TO COMPLETE AN ANNUAL INDEPENDENCE QUESTIONNAIRE, WHICH SEEKS DISCLOSURE OF CERTAIN RELATIONSHIPS, ARRANGEMENTS AND TRANSACTIONS IN ORDER TO DETERMINE INDEPENDENCE AND THE EXISTENCE OF CONFLICTS OF INTEREST. THESE POLICIES DESCRIBE POTENTIAL CONFLICTS, PROVIDE MEANS FOR DISCLOSURE, AND PROVIDE PROCESSES FOR INVESTIGATING AND RESOLVING POTENTIAL CONFLICTS. FORM 990, PART VI, SECTION B, LINE 15 IT IS THE POLICY OF CAP THAT THE PRESIDENT SUBMITS HIS OR HER RECOMMENDATIONS FOR COMPENSATION OF NEWLY HIRED SENIOR MANAGERS AT CAP TO THE COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS FOR APPROVAL WHEN, AMONG OTHER THINGS, THE RECOMMENDED SALARY EQUALS OR EXCEEDS AN INFLATION ADJUSTED THRESHOLD. FOR FELLOWS, THE BOARD OF DIRECTORS APPROVES A RANGE OF COMPENSATION, ADJUSTED ANNUALLY FOR INFLATION. SALARIES FOR HALF-TIME AND FULL-TIME FELLOWS AND FOR OTHER EMPLOYEES ARE PROPORTIONAL TO THIS PAY SCALE. THE PRESIDENT SUBMITS RECOMMENDATIONS FOR ANY FELLOW TO BE COMPENSATED OUTSIDE OF THIS RANGE. TO AVOID PAYING EXCESSIVE COMPENSATION TO EMPLOYEES, IT IS THE POLICY OF CAP THAT THE PRESIDENT SUBMITS HIS OR HER RECOMMENDATIONS FOR COMPENSATION OF NEWLY HIRED SENIOR EMPLOYEES AT CAP TO THE COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS FOR APPROVAL WHEN, AMONG OTHER THINGS, THE RECOMMENDED SALARY EQUALS OR EXCEEDS $150,000. THE RECOMMENDATION INCLUDES A JOB DESCRIPTION, INFORMATION ABOUT THE QUALIFICATIONS OF THE CANDIDATE, AND INFORMATION ABOUT WHAT COMPARABLE ORGANIZATIONS ARE PAYING FOR SIMILAR SERVICES. THE COMPENSATION COMMITTEE WILL CONSIDER AND MAY APPROVE THESE RECOMMENDATIONS. THE COMMITTEE DOCUMENTS THE BASIS FOR ITS DECISION WITH A CONTEMPORANEOUS RECORD THAT IS KEPT IN THE CORPORATION'S BOOKS AND RECORDS. THE COMPENSATION COMMITTEE IS COMPRISED OF INDEPENDENT DIRECTORS; ONLY MEMBERS WITHOUT A CONFLICT OF INTEREST VOTE FOR EACH RECOMMENDATION. ONCE COMPENSATION IS APPROVED BY THE BOARD OF DIRECTORS, THE PRESIDENT IS AUTHORIZED TO ADJUST THE SALARY LEVELS OF CERTAIN HIGHLY COMPENSATED EMPLOYEES AND FELLOWS WITHOUT APPROVAL BY THE COMPENSATION COMMITTEE WHEN (1) THE RELEVANT SUPERVISOR HAS COMPLETED AN EVALUATION OF THE EMPLOYEE'S OR FELLOW'S WORK AND IT WAS DETERMINED THAT HIS OR HER WORK "MET OR EXCEEDED EXPECTATIONS" FOR THAT POSITION; (2) THE PRESIDENT HAS REVIEWED RECENT DATA AS TO WHAT COMPARABLE ORGANIZATIONS ARE PAYING FOR SIMILAR SERVICES AND DETERMINED THAT THE ADJUSTED SALARY WOULD BE REASONABLE AND APPROPRIATE; (3) THE PRESIDENT HAS DETERMINED THAT THE ADJUSTMENT WOULD BE COMMENSURATE WITH OTHER HIGHLY COMPENSATED EMPLOYEES OR FELLOWS WITH SIMILAR RESPONSIBILITIES, AUTHORITY, AND PERFORMANCE WITHIN CAP; AND (4) THE SALARY INCREASE IS NOT MORE THAN 20% OF THE SENIOR STAFF OR FELLOW'S PER ANNUM SALARY, AND THAT THE TOTAL INCREASES OVER THREE YEARS NOT EXCEED 35%. THE COMPENSATION COMMITTEE IS COMPRISED OF INDEPENDENT DIRECTORS; ONLY MEMBERS WITHOUT A CONFLICT OF INTEREST VOTE FOR EACH RECOMMENDATION. FORM 990, PART VI, SECTION C, LINE 19 CAP MAKES ITS GOVERNING DOCUMENTS, CONFLICTS OF INTEREST POLICY, AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC. CAP'S GOVERNING DOCUMENTS ARE INCLUDED IN ITS FORM 1023, APPLICATION FOR RECOGNITION OF EXEMPTION UNDER SECTION 501(C)(3). CHANGES TO ITS GOVERNING DOCUMENTS ARE FILED WITH ITS ANNUAL FEDERAL FORM 990. BOTH FORMS ARE MADE AVAILABLE TO THE PUBLIC UPON REQUEST. CAP'S ANNUAL FEDERAL FORM 990 IS ALSO MADE AVAILABLE TO THE PUBLIC BY WAY OF THE ONLINE INFORMATION SERVICE, GUIDESTAR.ORG, AS WELL AS BY SOME OF THE STATES WHERE THE FEDERAL FORM 990 IS A REQUIRED SUBMISSION FOR REGISTRATION. CAP'S AUDITED FINANCIAL STATEMENTS ARE MADE AVAILABLE TO THE PUBLIC THROUGH GUIDESTAR.ORG AND UPON REQUEST.