2020-08-12T12:56:28-05:00 2019-09-30 341884125 CBIZ MHM LLC 4722 N 24TH ST STE 300 PHOENIX AZ 85016 990 2018-10-01 866037149 THE NARBHA INSTITUTE INC NARB 9282338667 616 N BEAVER STREET FLAGSTAFF AZ 86001 MARY JO GREGORY CHIEF EXECUTIVE OFFICER 9282338667 2020-08-12 1 AMY A O'LOUGHLIN P00869687 6022646835 2020-08-12 12.221.96.220 2020-08-12 12:02:41 MS P DA39A3EE5E6B4B0D3255BFEF95601890AFD80709 1212D86953DF9911D4E957E54162B84DD93DFAA7 2018 2020-09-23 17:36:50Z MARY JO GREGORY 616 N BEAVER STREET FLAGSTAFF AZ 86001 8774845 0 X WWW.NARBHAINSTITUTE.ORG X 1967 AZ MEDICAID MANAGED CARE SUBCONTRACTOR, SUPPORTED HOUSING, BEHAVIORAL CARE VIA AFFILIATE 4 2 11 4 0 0 4276240 3376329 1322574 4223491 838596 799570 -9567 31973 6427843 8431363 1489614 3959973 0 0 1512778 1783883 0 0 0 1628256 2479758 4630648 8223614 1797195 207749 65040397 66174390 391239 613750 64649158 65560640 X SERVE MEDICAID MANAGED CARE SUBCONTRACT, SUPPORTED HOUSING FOR MENTALLY ILL, CONVENER/SUPPORTER IN HEALTH/SOCIAL DETERMINANTS. DRIVE IMPROVED MENTAL HEALTH OUTCOMES FOR VULNERABLE POPULATIONS VIA AFFILIATED AGENCY PROVIDING OUTPATIENT, INPATIENT & RESIDENTIAL SVS. 1 0 3262892 2354775 1857507 EFFECTIVE AUGUST 27, 2018, THE INSTITUTE ENTERED INTO AN AFFILIATION AGREEMENT WITH THE GUIDANCE CENTER (TGC), A SEPARATE 501 (C)(3) ORGANIZATION, IN WHICH THE INSTITUTE BECAME ITS SOLE MEMBER. THERE IS A SEPARATE BOARD TO OVERSEE MANAGEMENT OF TGC. TGC PROVIDES INPATIENT AND OUTPATIENT BEHAVIORAL HEALTH SERVICES IN THE FLAGSTAFF REGION. UNDER THE AFFILIATION AGREEMENTS, THE INSTITUTE PROVIDES SUBSTANTIAL FINANCIAL AND IN-KIND SUPPORT AND APPOINTS A MAJORITY OF ITS GOVERNING BOARD. 2548051 1492198 620053 THE NARBHA INSTITUTE'S LARGEST PROGRAM IS ITS PROVISION OF SERVICES, SUPPORT AND GRANTS TO HEALTHCARE PROVIDERS WHO SERVE PRIMARILY MEDICAID BENIFICIARIES AND INDIGENT POPULATIONS. THIS INCLUDES GRANTS TO SUCH ORGANIZATIONS TO ACHIEVE HEALTH AND HEALTH RELATED SOCIAL OUTCOMES SUCH AS EMPLOYMENT, MEDICAID ELIGIBILITY COMPLIANCE, TIMELY MENTAL HEALTH ASSESSMENTS, PATIENT SATISFACTION, HOUSING, CRIMINIAL JUSTICE COORDINATION AND CULTURALLY-COMPETENT SERVICES. A MAJOR INITIATIVE WAS TO SUPPORT MENTAL HEALTH FIRST AID THROUGH NORTHERN ARIZONA THROUGH BUYING THE TRAINING MATERIALS AND TRAINING THE TRAINERS. 457111 103349 THROUGH A DISREGARDED ENTITY (WELL NORTH COMMUNITIES LLC), THE NARBHA INSTITUTE PROVIDES PERMANENT SUPPORTED HOUSING TO APPROXIMATELY 40 FAMILIES LIVING WITH SERIOUS MENTAL ILLNESS IN NORTHERN ARIZONA. TENANTS PAY AN INCOME-ADJUSTED PORTION OF RENT (WHICH IS OFTEN ZERO) AND RESIDE IN APARTMENTS PURCHASED WITH FUNDING FROM THE ARIZONA DEPARTMENT OF HEALTH SERVICES. WHILE NOT LISTED ON FINANCIAL STATEMENTS AS AN EXPENSE, THE OPPORTUNITY COST OF THESE HEAVILY DISCOUNTED RENTS IS OVER $222,000 PER YEAR EXCLUDING UTILITIES, BASED ON HUD & SURVEY DATA. 404542 1642582 THE NARBHA INSTITUTE'S JOINT VENTURE WAS SUB-CONTRACTED WITH THE ARIZONA MEDICAID PROGRAM AS AN INTEGRATED REGIONAL BEHAVIORAL HEALTH AUTHORITY (RBHA) WHICH IS A MANAGED CARE ORGANIZATION SERVING MEDICAID COVERED LIVES IN NORTHERN ARIZONA. NARBHA PROVIDES A VARIETY OF SERVICES IN ADDITION TO GOVERNANCE OVERSIGHT OF THE VENTURE, SUCH AS MAINTENANCE OF CERTAIN HEALTHCARE FACILITIES IN REMOTE AREAS, HOUSING FOR PATIENTS LIVING WITH SERIOUS MENTAL ILLNESS AND PROVISION OF OFFICE SPACE TO THE JV. 208251 113000 SEDI-SUSTAINABLE ECONOMIC DEVELOPMENT INITIATIVE (RELATED ORGANIZATION), FILES A SEPARATE FORM 990, PROVIDES ECONOMIC DEVELOPMENT SERVICES, RELATED TO THE NARBHA INSTITUTE'S MISSION TO PROMOTE EMPLOYMENT AS A KEY SOCIAL DETERMINANT OF HEALTH. 612793 113000 1642582 6880847 1 1 0 0 0 0 0 0 0 0 1 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 0 0 0 1 23 0 1 11 1 0 0 0 0 0 0 0 0 0 0 0 0 X 4 2 0 0 0 0 0 0 0 1 1 0 1 1 0 1 1 1 1 1 1 1 1 1 X JUDY MARFECHUK 9282338667 616 N BEAVER STREET FLAGSTAFF AZ 86001 MARY JO GREGORY PRESIDENT & CEO 47.00 X X 493487 0 28388 JAMES WURGLER VICE-PRESIDENT (THRU 11/2019) 6.00 X X 0 0 0 MARRINER CARDON SECRETARY (THRU 1/2019) 2.00 X X 0 0 0 JIM DYKES DIRECTOR 4.00 6.00 X 32475 0 0 CELESTE IRONS DIRECTOR 4.00 X 0 0 0 MICHAEL KUZMIN CFO 16.00 24.00 X 48141 0 5855 MARK CARROLL CHIEF HEALTH OFFICER 40.00 2.00 X 310671 0 49782 NATHAN JONES LEGAL COUNSEL 20.00 20.00 X 170689 0 13996 JUDITH MARFECHUK CONTROLLER 35.00 5.00 X 149452 0 14675 ERIC MARCUS CHIEF OPERATING OFFICER 25.00 15.00 X 146205 0 28140 1351120 0 140836 5 0 1 0 STRATEGIC HEALTH ADVISORS INC 90 DORNOCH WAY COTO DE CAZA CA 92679 CONSULTING 182593 1 3376329 3376329 GUIDANCE CENTER INC 621400 1857507 1857507 CONSULTING INCOME 541610 1000000 1000000 RENTAL REVENUE 531110 745931 745931 COMMUNITY REINVESTMENT 524298 620053 620053 4223491 755794 755794 16998 15981 1017 1017 1017 371277 327501 43776 43776 43776 MISCELLANEOUS 900099 30956 30956 30956 8431363 4223491 0 831543 3959973 3959973 1083973 749745 334228 552431 401252 151179 75175 54246 20929 72304 51193 21111 31080 31080 215225 153654 61571 73000 73000 124799 124799 531352 207462 323890 117932 78758 39174 36895 26159 10736 513819 500206 13613 78690 51071 27619 284895 229239 55656 384918 371867 13051 64406 64406 DUES AND SUBSCRIPTIONS 19400 12856 6544 MISCELLANEOUS EXPENSES 3347 2086 1261 8223614 6880847 1342767 0 2697358 1409408 11716257 12408547 2221 2956181 174728 99068 11971795 3807375 8146588 8164420 22311108 23497323 19992137 17639443 65040397 66174390 391239 613750 391239 613750 X 64649158 65560640 64649158 65560640 65040397 66174390 207749 703733 0 X 0 0 0 X 197900920 6454150 5953979 4276240 3376329 217961618 197900920 6454150 5953979 4276240 3376329 217961618 217961618 102136 94657 357451 589759 772792 1916795 11107 10200 510611 672 30956 563546 220441959 7623905 0.98870 0.99530 X SCHEDULE A, PART II, LINE 10, EXPLANATION OF OTHER INCOME: REBATES BOOK SALES OTHER MISC - 2014 AMOUNT: $ 11,107. MISCELLANEOUS INCOME - 2015 AMOUNT: $ 10,200. 2016 AMOUNT: $ 8,902. 2017 AMOUNT: $ 672. 2018 AMOUNT: $ 30,956. AHIP REFUND - 2016 AMOUNT: $ 501,709. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 2160465 2160465 9588035 3616568 5971467 223295 190807 32488 8164420 INVESTMENT IN HEALTH CHOICE INTEGRATED CARE, LLC 8561040 INVESTMENT IN THE GUIDANCE CENTER 9078403 17639443 X PART X, LINE 2: NARBHA QUALIFIES AS A TAX-EXEMPT ORGANIZATION UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE (THE CODE) AND, THEREFORE, THERE IS NO PROVISION FOR INCOME TAXES IN THE FINANCIAL STATEMENTS. IN ADDITION, NARBHA QUALIFIES FOR THE CHARITABLE CONTRIBUTION DEDUCTION UNDER SECTION 170 OF THE CODE AND HAS BEEN CLASSIFIED AS AN ORGANIZATION THAT IS NOT A PRIVATE FOUNDATION. INCOME DETERMINED TO BE UNRELATED BUSINESS TAXABLE INCOME (UBTI) WOULD BE TAXABLE. MANAGEMENT DOES NOT BELIEVE NARBHA HAS ANY UBTI FOR THE YEAR ENDED SEPTEMBER 30, 2019. NARBHA EVALUATES ITS UNCERTAIN TAX POSITIONS, IF ANY, ON A CONTINUAL BASIS THROUGH REVIEW OF ITS POLICIES AND PROCEDURES, REVIEW OF ITS REGULAR TAX FILINGS, AND DISCUSSIONS WITH OUTSIDE EXPERTS. 1 FLAGSTAFF FAMILY FOOD CENTER PO BOX P FLAGSTAFF AZ 86002 860754044 501(C)(3) 7500 PROGRAM SUPPORT COTTONWOOD-OAK CREEK SCHOOL DISTRICT 1 N WILLARD STREET COTTONWOOD AZ 86326 866000563 GOVERNMENT 75000 PROGRAM SUPPORT NORTHERN ARIZONA UNIVERSITY PO BOX 4080 FLAGSTAFF AZ 86011 742579628 GOVERNMENT 271952 PROGRAM SUPPORT NORTHERN ARIZONA UNIVERSITY FOUNDATION PO BOX 4094 FLAGSTAFF AZ 86011 860193726 501(C)(3) 10350 PROGRAM SUPPORT COCONINO COUNTY SUSTAINABLE ECONOMIC DEVELOPMENT INITIATIVE 616 N BEAVER STREET FLAGSTAFF AZ 86001 261077054 501(C)(3) 53167 59833 CASH REIMBURSEMENT WAGES, EMPLOYEE RELATED EXPENSES PROGRAM SUPPORT SOUTHWEST BEHAVIORAL HEALTH SERVICES INC 3450 N 3RD STREET PHOENIX AZ 85012 860290033 501(C)(3) 6200 PROGRAM SUPPORT SPECTRUM HEALTH CARE INC 8 E COTTONWOOD STREET COTTONWOOD AZ 86326 860207499 501(C)(3) 5450 PROGRAM SUPPORT THE GUIDANCE CENTER INC 2187 N VICKEY STREET FLAGSTAFF AZ 86004 860223720 501(C)(3) 4550 2354775 CASH REIMBURSEMENT WAGES, EMPLOYEE RELATED EXPENSES, RENOVATIONS PROGRAM SUPPORT WEST YAVAPAI GUIDANCE CENTER 3343 N WINDSONG DRIVE PRESCOTT AZ 86314 860206928 501(C)(3) 7600 PROGRAM SUPPORT CORNUCOPIA COMMUNITY ADVOCATES 95 SPOTTED FAWN CT SEDONA AZ 86351 860990310 501(C)(3) 8000 PROGRAM SUPPORT COUNTY OF YAVAPAI 255 E GURLEY STREET PRESCOTT AZ 86301 866000561 GOVERNMENT 127706 PROGRAM SUPPORT OLD CONCHO COMMUNITY ASSISTANCE CENTER INC PO BOX 50 CONCHO AZ 85924 860907044 501(C)(3) 30000 PROGRAM SUPPORT NORTHERN ARIZONA HEALTHCARE FOUNDATION INC 1030 N SAN FRANCISCO ST 130 FLAGSTAFF AZ 86005 860110232 501(C)(3) 9400 PROGRAM SUPPORT NORTHERN ARIZONA PRIDE ASSOCIATION PO BOX 1604 FLAGSTAFF AZ 86002 860974341 501(C)(3) 5500 PROGRAM SUPPORT VITALYST HEALTH FOUNDATION 2929 N CENTRAL SUITE 1550 PHOENIX AZ 85012 860097240 501(C)(3) 20000 PROGRAM SUPPORT ARIZONA TOWN HALL 2400 W DUNLAP AVE 200 PHOENIX AZ 85021 860177876 501(C)(3) 10000 PROGRAM SUPPORT TECHNICAL ASSISTANCE PARTNERSHIP OF ARIZONA 2929 N CENTRAL AVENUE SUITE 1550 PHOENIX AZ 85012 860975231 501(C)(3) 8500 PROGRAM SUPPORT UNITED WAY OF NORTHERN ARIZONA 1515 E CEDAR AVE STE D-1 FLAGSTAFF AZ 86004 860211666 501(C)(3) 13000 PROGRAM SUPPORT WILLIAMS UNIFIED SCHOOL DISTRICT 636 SOUTH 7TH STREET WILLIAMS AZ 86046 860592836 GOVERNMENT 27000 PROGRAM SUPPORT AHCCCS-STATE MEDICAID PROGRAM 701 E JEFFERSON STREE PHOENIX AZ 85034 GOVERNMENT 15000 PROGRAM SUPPORT COCONINO COUNTY 219 E CHERRY AVE FLAGSTAFF AZ 86001 866000441 GOVERNMENT 55000 PROGRAM SUPPORT YAVAPAI COUNTY EDUCATION SERIVCE AGENCY 2970 CENTERPOINTE EAST DRIVE PRESCOTT AZ 86301 861018326 GOVERNMENT 52544 PROGRAM SUPPORT NAVAJO COUNTY PO BOX 668 HOLBROOK AZ 86025 866000541 GOVERNMENT 69250 PROGRAM SUPPORT PREVENT CHILD ABUSE ARIZONA PO BOX 26495 PRESCOTT AZ 86312 860832901 501(C)(3) 26500 PROGRAM SUPPORT MENTAL HEALTH COALITION VERDE VALLEY PO BOX 654 SEDONA AZ 86339 812882235 501(C)(3) 15000 PROGRAM SUPPORT NAMI ARIZONA 5025 E WASHINGLON ST STE 112 PHOENIX AZ 85034 860464872 501(C)(3) 15000 PROGRAM SUPPORT AMERICAN HEART ASSOCIATION INC 7272 GREENVILLE AVENUE DALLAS TX 75231 135613797 501(C)(3) 7500 PROGRAM SUPPORT THE TRANSLATIONAL GENOMICS RESEARCH INSTITUTE 445 N 5TH STREET SUITE 600 PHOENIX AZ 85004 753065445 501(C)(3) 500000 PROGRAM SUPPORT 28 PART I, LINE 2: THE INSTITUTE BOARD APPROVES A BUDGET THAT INCLUDES GRANTS AND SPONSORSHIPS. STAFF REVIEW GRANT APPLICATIONS FOR CONSISTENCY WITH THE NARBHA INSTITUTE'S MISSION AND CHARITABLE PURPOSE, SCREEN FOR CONFLICTS OF INTEREST, ASCERTAIN WHETHER THE GRANTEE IS A PUBLIC CHARITY OR GOVERNMENTAL ENTITY, AND MAKE A FINAL RECOMMENDATION TO THE BOARD OR CHIEF EXECUTIVE AS APPROPRIATE. IF AN AWARD IS MADE, THE REPRESENTATIONS MADE IN THE APPLICATION ARE MADE CONTRACTUALLY BINDING AND FUNDING IS RESTRICTED TO THE PURPOSE DESCRIBED IN THE GRANT. SOME SMALLER GRANTS (PRIMARILY EVENT SPONSORSHIPS) DO NOT FOLLOW THE FORMAL APPLICATION PROCESS BUT ARE MONITORED BY HAVING STAFF VERIFY THE PUBLIC CHARITY STATUS OF THE COMPANY HOSTING THE EVENT, HAVING STAFF ATTEND THE EVENT, AND REVIEWING EVENT INFORMATION AND MATERIALS. NARBHA MAY RELY ON THE PUBLIC CHARITY STATUS OF THE GRANTEE TO ENSURE THAT THE GRANT IS CONSISTENT WITH CHARITABLE PURPOSES, OR IT MAY REQUIRE (OR IN THE RARE CASE OF A GRANT TO AN ENTITY WHICH IS NOT A PUBLIC CHARITY OR GOVERNMENTAL UNIT, WILL REQUIRE) REPORTS AND MEASURED OUTCOMES DEMONSTRATING THE USE OF FUNDS CONSISTENT WITH THE NARBHA INSTITUTE'S CHARITABLE PURPOSE AND MISSION. X X X X X 0 0 0 0 0 0 0 0 0 MARY JO GREGORY PRESIDENT & CEO 488487 0 0 0 5000 0 0 0 28388 0 521875 0 0 0 MARK CARROLL CHIEF HEALTH OFFICER 310671 0 0 0 0 0 0 0 49782 0 360453 0 0 0 NATHAN JONES LEGAL COUNSEL 164560 0 0 0 6129 0 0 0 13996 0 184685 0 0 0 JUDITH MARFECHUK CONTROLLER 145956 0 0 0 3496 0 0 0 14675 0 164127 0 0 0 ERIC MARCUS CHIEF OPERATING OFFICER 141030 0 0 0 5175 0 0 0 28140 0 174345 0 0 0 PART I, LINE 3 BASED ON COMPARABILITY DATA FOR SIMILARLY QUALIFIED PERSONS IN FUNCTIONALLY COMPARABLE POSITIONS AT SIMILARLY SITUATED ORGANIZATIONS, THE COMPENSATION OF THE CEO AND KEY EMPLOYEES WAS REVIEWED AND APPROVED BY THE ORGANIZATION'S GOVERNING BODY, COMPOSED OF INDEPENDENT MEMBERS WITHOUT CONFLICTS. THE CEO'S COMPENSATION IS SET BY CONTRACT AND THE APPROVAL OF THE INDEPENDENT DIRECTORS IS BASED ON THE ADVICE OF INDEPENDENT COMPENSATION CONSULTANTS SPECFICALLY CONTRACTED TO ENSURE THAT COMPENSATION IS NOT EXCESSIVE IN LIGHT OF A COMPLEX HEALTHCARE ORGANIZATION OVERSEEING A JOINT VENTURE WHICH PROVIDES PHYSICAL AND BEHAVIORAL HEALTH SERVICES TO OVER 145,000 COVERED MEDICAID LIVES. FORM 990, PART III, LINE 2 EFFECTIVE 10/1/2018, THE CONTRACT BETWEEN HEALTH CHOICE INTEGRATED CARE (HCIC) (A JOINT VENTURE DESCRIBED ON SCHEDULE R AND AS "OTHER PROGRAMS" ON THIS SCHEDULE O) AND THE ARIZONA MEDICAID PROGRAM (AHCCCS) BECAME A SUBCONTRACT. A COMPANY NOT OWNED BY NARBHA INSTITUTE (NOW CALLED HEALTH CHOICE ARIZONA, OR HCA) RECEIVED THE MEDICAID CONTRACT AS OF THAT DATE. HOWEVER, HCA SIMULTANEOUSLY SUBCONTRACTED ITS REGIONAL BEHAVIORAL HEALTH AUTHORITY (RBHA) MEDICAID MANAGED CARE GOVERNANCE BACK TO HCIC, RESULTING IN HCIC CONTINUING AS DESCRIBED IN THE PRIOR YEAR (2017) FORM 990, PART III, LINE 4B, BUT CHANGING FROM A DIRECT MEDICAID CONTRACT TO A SUBCONTRACT. IN ADDITION, AND ALSO AS OF 10/1/2018, THE STATE OF ARIZONA REALIGNED THE RBHA CONTRACT TO FOCUS ON POPULATIONS REQUIRING SPECIALIZED CARE, SUCH AS PERSONS LIVING WITH SERIOUS MENTAL ILLNESS, RESULTING IN A SMALLER BUT MORE VULNERABLE POPULATION COVERED VIA THE HCIC SUBCONTRACT. FINALLY, AS OF 10/1/2018 NARBHA INSTITUTE BEGAN CONTRACTING DIRECTLY WITH HCA FOR THE PURPOSE OF RECEIVING, DISBURSING AND ADMINISTERING CERTAIN STATE-REQUIRED CHARITABLE GRANTS INCLUDED ON THIS 2018 FORM 990 PART III, LINE 4B, AND SCHEDULE I, AND FOR THE PURPOSE OF OTHER ADVISORY SERVICES RELATED TO MEDICAID PROGRAM PROCUREMENT, SOCIAL DETERMINANTS OF HEALTH AND PERFORMANCE OF MEDICAID PROGRAM EXPECTATIONS. FORM 990 PART IV, LINE 12A THE NARBHA INSTITUTE IS IN THE PROCESS OF BEING AUDITED BY AN INDEPENDENT PUBLIC ACCOUNTING FIRM. THE AUDIT WAS UNABLE TO BE COMPLETED BEFORE THE FORM 990 FILING DEADLINE DUE TO THE UNAVAILABILITY OF FINALIZED FINANCIAL INFORMATION FROM IT JOINT VENTURE PARTNER. FORM 990, PART VI, SECTION B, LINE 11B CORPORATE PRACTICES REQUIRE REVIEW OF FORM 990 BY THE PRESIDENT AND VICE-PRESIDENT OF THE BOARD OF DIRECTORS ON BEHALF OF THE BOARD OF DIRECTORS PRIOR TO FILING THE ORGANIZATION'S 990 RETURN. FORM 990, PART VI, SECTION B, LINE 12C THE BOARD OF DIRECTORS ADOPTED THE IRS MODEL POLICY WHICH PROVIDES FOR ANNUAL DISCLOSURE BY "ANY DIRECTOR, PRINCIPAL OFFICER, OR MEMBER OF A COMMITTEE WITH GOVERNING BOARD DELEGATED POWERS." THE GENERAL COUNSEL ENSURES ANNUAL COMPLETION OF DISCLOSURES AND ENFORCES THE POLICY, WHICH ENSURES THAT NO INTERESTED PERSON WILL BE INVOLVED IN ANY DISCUSSION OR VOTE ON ANY MATTER ABOUT WHICH THEY HAVE DISCLOSED AN INTEREST. VIOLATIONS OF THE CONFLICTS POLICY MAY RESULT IN SANCTIONS UP TO AND INCLUDING REMOVAL. FORM 990, PART VI, SECTION B, LINE 15 THE NARBHA INSTITUTE HAS ENGAGED THE SERVICES OF INDEPENDENT COMPENSATION CONSULTANTS FOR BOTH THE CEO AND KEY EMPLOYEES, AND HAS ALSO DONE ORGANIZATION-WIDE COMPENSATION STUDIES. COMPENSATION OF THE CEO IS DETERMINED BY INDEPENDENT DIRECTORS BASED ON SUCH COMPENSATION STUDIES. FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATION'S ARTICLES OF INCORPORATION, BY-LAWS, CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS ARE MADE AVAILABLE TO THE PUBLIC UPON REQUEST. 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