2015-01-30T10:05:44-06:00 2014-05-31 390859910 BAKER TILLY VIRCHOW KRAUSE LLP 777 E WISCONSIN AVENUE 32ND FLOOR MILWAUKEE WI 53202 990 2013-06-01 420680351 WARTBURG COLLEGE WART 3193528411 100 WARTBURG BLVD WAVERLY IA 50677 RICHARD SEGGERMAN VP FINANCE & ADMINISTRATION 3193528411 2015-01-15 1 TROY E MARINE CPA P00187863 4147775500 2015-01-15 2013 2016-03-07 17:11:31Z DARREL D COLSON 100 WARTBURG BLVD WAVERLY IA 50677 91311853 0 X WWW.WARTBURG.EDU X 1852 IA UNDERGRADUATE HIGHER EDUCATION THAT CHALLENGES AND NURTURES STUDENTS FOR LIVES OF LEADERSHIP AND SERVICE AS A SPIRITED EXPRESSION OF THEIR FAITH AND LEARNING. 28 24 2049 500 223682 0 10081936 7082157 69966799 72460279 3451777 3225871 2649950 2400009 86150462 85168316 27272004 29095388 0 0 27257895 28200604 0 0 2041694 24587938 26110386 79117837 83406378 7032625 1761938 193094880 197840757 96807666 96038172 96287214 101802585 UNDERGRADUATE HIGHER EDUCATION THAT CHALLENGES AND NURTURES STUDENTS FOR LIVES OF LEADERSHIP AND SERVICE AS A SPIRITED EXPRESSION OF THEIR FAITH AND LEARNING. 0 0 47228679 29095388 56538434 INSTRUCTION OF STUDENTS ENROLLED AND THE RELATED ACADEMIC SUPPORT; 1,680 AND 1,607 FULL-TIME EQUIVALENT STUDENTS ENROLLED FOR THE FALL 2013 AND WINTER 2014 TERMS RESPECTIVELY. 9255069 15513492 AUXILIARY ENTERPRISES SUPPORTS STUDENTS LIVING AND EATING ON CAMPUS AS WELL AS PROVIDING BOOKS. THERE WERE 1,386 AND 1,318 STUDENTS LIVING ON CAMPUS FOR THE FALL 2013 AND WINTER 2014 TERMS, RESPECTIVELY. 12030290 2370889 ALL OTHER PROGRAM RELATED SERVICES 68514038 1 1 0 1 0 0 0 1 0 1 1 1 0 0 1 1 1 0 1 0 1 0 0 0 0 0 0 0 1 1 1 0 0 0 0 0 0 1 0 1 0 1 0 0 0 0 0 0 0 0 1 2175 0 1 2049 1 1 1 0 0 0 0 0 1 1 0 0 0 X 28 24 0 0 0 0 0 0 0 1 1 0 0 0 1 1 1 1 0 1 0 0 X TRACY RUCKER 3193528238 100 WARTBURG BLVD WAVERLY IA 506772215 ANDREA WESTMEYER REGENT 0.10 X 0 0 0 BARBARA GAMEZ SIMS REGENT 0.10 X 0 0 0 REVEREND JAMES ARENDS REGENT 0.10 X 0 0 0 REVEREND STEVEN ULLESTAD REGENT 0.10 X 0 0 0 DOROTHY BOWEN REGENT 0.10 X 0 0 0 DR DELFORD DOHERTY REGENT 0.10 X 0 0 0 DR GIL WESSEL REGENT 0.10 X 0 0 0 DR GRADY BALLENGER REGENT, VICE CHAIR - BOARD 0.10 X 0 0 0 DR HANS-PETER BRODHUN REGENT 0.10 X 0 0 0 DR MARILYN FLACHMAN REGENT 0.10 X 0 0 0 FRED HAGEMANN REGENT 0.10 X 0 0 0 GARY HOOVER REGENT 0.10 X 0 0 0 GUNTER SCHUCHARDT REGENT 0.10 X 0 0 0 JACK SALZWEDEL REGENT, VICE CHAIR - BOARD 0.10 X 0 0 0 JANET FELBERG REGENT 0.10 X 0 0 0 JIM LOVERIDGE REGENT 0.10 X 0 0 0 JOANN KILGUS REGENT 0.10 X 0 0 0 KIRK KINNEAR REGENT 0.10 X 0 0 0 LIZ MATHIS REGENT 0.10 X 0 0 0 MARK BALDWIN REGENT 0.10 X 0 0 0 MIKE MCCOY REGENT, VICE CHAIR - BOARD 0.10 X 0 0 0 REVEREND MICHAEL HOUSHOLDER REGENT 0.10 X 0 0 0 RACHEL RIENSCHE REGENT, VICE CHAIR - BOARD 0.10 X 0 0 0 RAY MCCASKEY REGENT, CHAIRMAN - BOARD 0.10 X 0 0 0 ROBERT SEVERSON REGENT 0.10 X 0 0 0 RUTH BAHE-JACHNA REGENT, VICE CHAIR - BOARD 0.10 X 0 0 0 REVEREND SHERMAN HICKS REGENT 0.10 X 0 0 0 DARREL COLSON PRESIDENT 40.00 X X 249898 0 33504 DEBORAH LOERS VICE-PRESIDENT 40.00 X 112785 0 26647 EDITH WALDSTEIN VICE-PRESIDENT 40.00 X 122467 0 30493 GRAHAM GARNER VICE-PRESIDENT 40.00 X 100734 0 25152 MARK BIERMANN VICE-PRESIDENT 40.00 X 129803 0 28968 RICHARD SEGGERMAN VICE-PRESIDENT 40.00 X 102893 0 29323 SCOTT LEISINGER VICE-PRESIDENT 40.00 X 124285 0 23267 942865 0 197354 7 0 1 0 PETERS CONSTRUCTION CORPORATION 901 BLACK HAWK ROAD WATERLOO IA 50704 CONSTRUCTION CONTRACTOR 664706 MIDWEST FIELD TURF COMPANY 22 S MAIN SUITE B DENISON IA 51442 ATHLETIC FIELD CONTRACTOR 536476 RUFFALOCODY PO BOX 718 DES MOINES IA 503030718 INST. ADVANCEMENT/ ADMISSIONS CONSULTANT 335129 BEYNON SPORTS SURFACES INC 16 ALT ROAD HUNT VALLEY MD 21030 ATHLETIC SURFACE CONTRACTOR 315000 DON GARDNER CONSTRUCTION COMPANY 315 LA PORTE ROAD WATERLOO IA 50702 CONSTRUCTION CONTRACTOR 295179 11 345514 6736643 1623778 7082157 TUITION & FEES 611310 56538434 56538434 AUXILIARY ENTERPRISES 611710 15921845 15702591 219254 72460279 1461164 1461164 106467 106467 103274 78926 24348 24348 24348 7548189 174662 5864812 199799 1683377 -25137 1658240 1658240 CAMPUS GROUP 541900 2177132 1987689 189443 OTHER PROGRAM RELATED 541900 171501 171501 COPY CENTER 561439 22600 22600 4428 4428 2375661 85168316 74422815 223682 3439662 29095388 29095388 1140323 299337 638656 202330 19691031 17407874 1465350 817807 1308824 1144449 97399 66976 4681511 4103135 348385 229991 1378915 1206336 102615 69964 42844 42394 450 85083 85083 530000 530000 651789 443284 48504 160001 297393 275262 22131 1620862 1325591 120620 174651 1021233 612740 408493 2007646 1858150 149403 93 1575703 1218197 117259 240247 6995 6461 521 13 4542878 4542878 3773359 3773359 432399 400221 32178 FOOD PURCHASES & BOOKST 3221197 3221197 CAMPUS GROUPS & MAY TER 1928117 1928117 ALL OTHER EXPENSES 1725700 1575329 128422 21949 SERVICE AGREEMENTS 1144284 1025358 85154 33772 1502904 1367612 111842 23450 83406378 68514038 12850646 2041694 12792285 9940110 5000000 4600000 1631604 1928827 3441919 3495423 511297 430290 701361 1062073 141686128 43795821 98095313 97890307 45106522 50829900 21139726 21729245 4674853 5934582 193094880 197840757 6502712 6680163 2972198 2992646 200847 171526 82553066 81584988 4578843 4608849 96807666 96038172 X 40565917 40218643 15872198 19115450 39849099 42468492 96287214 101802585 193094880 197840757 1761938 3753433 0 X 0 1 X 1 1 1 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 1 4526 0 0 0 4526 0 PART II-B, LINE 1: THE COLLEGE PAYS MEMBERSHIP DUES TO VARIOUS ORGANIZATIONS, SOME PORTION OF WHICH MAY BE USED FOR LOBBYING IN CONNECTION WITH ISSUES THAT IMPACT HIGHER EDUCATION. 74150 X X 0 53287753 2540203 5425628 780234 1371791 59101559 45679819 2445139 7150663 714057 1273811 53287753 49190421 1808279 -3476472 649266 1193143 45679819 40182889 2100248 8732948 621036 1204628 49190421 36575945 693726 4798095 647681 1237196 40182889 0.33000 0.67000 0 0 126550 3558120 3684670 119448021 34365589 85082432 6520733 4220625 2300108 12032704 5209607 6823097 97890307 CSV - LIFE INSURANCE 2549709 F OTHER 7146803 F FUND OF HEDGE FUNDS 12032733 F 21729245 STUDENT DEPOSITS 1069817 ANNUITIES PAYABLE 2853330 DEPOSITS HELD IN CUSTODY 115702 ASSET RETIREMENT OBLIGATION 570000 4608849 X 59593320 3753433 3753433 55839887 530000 28798429 29328429 85168316 54077949 271822 271822 53806127 530000 29070251 29600251 83406378 PART III, LINE 4: THE COLLEGE DOES NOT HAVE A SIGNIFICANT ART COLLECTION. THE ITEMS THAT ARE HELD ARE USED FOR EDUCATIONAL PURPOSES IN VARIOUS COURSES AND FOR THE BENEFIT OF THE GENERAL PUBLIC. PART V, LINE 4: THE COLLEGE'S ENDOWMENT FUNDS ARE USED TO SUPPORT THE EDUCATIONAL AND OTHER SUPPORT SERVICES PROVIDED TO THE STUDENT BODY. PART X, LINE 2: THE COLLEGE FOLLOWS THE ACCOUNTING STANDARDS FOR CONTINGENCIES IN EVALUATING UNCERTAIN TAX POSITIONS. THE GUIDANCE PRESCRIBES RECOGNITION THRESHOLD PRINCIPLES FOR THE FINANCIAL STATEMENT RECOGNITION OF TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN ON A TAX RETURN THAT ARE NOT CERTAIN TO BE REALIZED. NO LIABILITY HAS BEEN RECOGNIZED BY THE COLLEGE FOR UNCERTAIN TAX POSITIONS AS OF MAY 31, 2014 AND 2013. THE COLLEGE'S TAX RETURNS ARE SUBJECT TO REVIEW AND EXAMINATION BY FEDERAL AND STATE AUTHORITIES. THE TAX RETURNS FOR THE CURRENT YEAR AS WELL AS FISCAL YEARS 2011 AND THEREAFTER ARE OPEN TO EXAMINATION BY FEDERAL AND STATE AUTHORITIES. PART XI, LINE 4B - OTHER ADJUSTMENTS: ACTUARIAL ADJUSTMENTS - LOSS -192,896. RENTAL EXPENSES -78,926. FINANCIAL AID 29,095,388. GAIN/LOSS ON DISPOSAL OF PLANT ASSETS -25,137. PART XII, LINE 2D - OTHER ADJUSTMENTS: ACTUARIAL ADJUSTMENTS - LOSS 192,896. RENTAL EXPENSES 78,926. PART XII, LINE 4B - OTHER ADJUSTMENTS: FINANCIAL AID 29,095,388. GAIN/LOSS ON DISPOSAL OF PLANT ASSETS -25,137. 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 1 0 1 SCHEDULE E, PART I, LINE 3 THE COLLEGE FOLLOWS A NONDISCRIMINATORY POLICY REGARDING ALL PROGRAMS. ENROLLMENT OF STUDENTS IS WITHOUT DISCRIMINATION AS TO RACE, SEX, COLOR, SEXUAL ORIENTATION, HANDICAP, OR NATIONAL ORIGIN AND IS PUBLISHED IN THE COLLEGE'S CATALOG, AND THE COLLEGE'S WEBSITE. RECRUITMENT PROCEDURES ARE DESIGNED AND CARRIED OUT TO REACH ALL RACIAL SEGMENTS IN THE GEOGRAPHICAL AREA SERVED BY THE COLLEGE. SCHEDULE E, PART I, LINE 6 THE COLLEGE RECEIVES FINANCIAL ASSISTANCE FROM THE U.S. GOVERNMENT IN CONNECTION WITH VARIOUS PROGRAMS SUCH AS THE PELL GRANT PROGRAM, TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANT PROGRAM, FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANT (SEOG), FEDERAL WORKSTUDY PROGRAM AND FEDERAL PERKINS LOAN PROGRAM. THE COLLEGE ALSO RECEIVES SUPPORT FROM THE STATE OF IOWA THROUGH THEIR TUITION GRANT PROGRAM AND OTHER RELATED STATE PROGRAMS. CENTRAL AMERICA AND THE CARIBBEAN 0 0 PROGRAM SERVICES SEE PART V 80007 EAST ASIA & PACIFIC 0 0 PROGRAM SERVICES SEE PART V 18807 EUROPE (INCLUDING ICELAND AND GREENLAND) 0 0 PROGRAM SERVICES SEE PART V 118844 MIDDLE EAST AND NORTH AFRICA 0 0 PROGRAM SERVICES SEE PART V 839 NORTH AMERICA (INCLUDING CANADA AND MEXICO BUT NOT THE UNITED STATES) 0 0 PROGRAM SERVICES SEE PART V 3279 SOUTH AMERICA 0 0 PROGRAM SERVICES SEE PART V 34312 SUB-SAHARAN AFRICA 0 0 PROGRAM SERVICES SEE PART V 23173 0 0 0 0 0 0 279261 0 279261 0 0 0 0 0 0 SCHEDULE F, PART I, LINE 3 - COLUMN (E): LINE 1 - INSTRUCTION LINE 2 - INSTRUCTION AND STUDENT SERVICES LINE 3 - INSTITUTIONAL SUPPORT, ACADEMIC SUPPORT, INSTRUCTION AND STUDENT SERVICES LINE 4 - INSTRUCTION LINE 5 - ACADEMIC SUPPORT, INSTRUCTION AND STUDENT SERVICES LINE 6 - INSTRUCTION AND STUDENT SERVICES LINE 7 - INSTRUCTION AND STUDENT SERVICES 1 INSTITUTIONAL SCHOLARSHIPS AND GRANTS 1625 1220292 27719351 TUITION DISCOUNTING INSTITUTIONAL SCHOLARSHIPS AND GRANTS ARE USED AS A DIRECT REDUCTION OF THE TUITION THAT EACH FULL-TIME STUDENT IS REQUIRED TO PAY. SUPPLEMENTAL EDUCATION OPPORTUNITY GRANT 401 155745 FAIR MARKET VALUE SUPPLEMENTAL EDUCATION OPPORTUNITY GRANT (SEOG) IS A FEDERAL GRANT THAT IS AWARDED BY THE COLLEGE TO QUALIFIED STUDENTS IN ORDER TO REDUCE THE COST THE STUDENT MUST PAY FOR THEIR EDUCATION. PART I, LINE 2: THE COLLEGE PROVIDES GRANTS AND SCHOLARSHIPS TO ITS FULL-TIME, DEGREE SEEKING STUDENTS, BY CREDITING SUCH AMOUNTS DIRECTLY TO THEIR STUDENT ACCOUNTS, TO BE ONLY USED AS AN OFFSET FOR TUITION. X X X 1 1 X X X 0 0 0 0 0 0 0 0 0 DARREL COLSON PRESIDENT 224342 0 0 0 25556 0 18440 0 15064 0 283402 0 0 0 EDITH WALDSTEIN VICE-PRESIDENT 119536 0 0 0 2931 0 10240 0 20253 0 152960 0 0 0 MARK BIERMANN VICE-PRESIDENT 127718 0 0 0 2085 0 10600 0 18368 0 158771 0 0 0 A IOWA HIGHER EDUCATION LOAN AUTHORITY 421235696 462460VZ6 2005-12-29 49918166 SEE PART VI 0 0 0 B IOWA HIGHER EDUCATION LOAN AUTHORITY 421235696 462460VY9 2005-12-29 36706381 SEE PART VI 0 0 0 A 4020000 64582866 3531093 992887 60058886 2005 0 1 1 1 B 400000 39239746 3413088 3552458 734128 31540072 2008 0 0 1 1 A 0 0 0 0 0 0 1 B 0 1 0 0 0.01920 0.01920 0 0 1 A 0 0 0 1 0 0 1 SEE PART VI 5.000000000000 1 0 1 B 0 0 0 1 0 0 1 SEE PART VI 5.000000000000 1 0 1 A 1 B 1 SCHEDULE K, PART 1, COLUMN F - LINE A: THE 2005 SERIES A BOND PROCEEDS WERE USED TO ADVANCE REFUND THE 2002 (7/10/02) BONDS. SCHEDULE K, PART II, LINE 3: THE TOTAL PROCEEDS DO NOT AGREE TO THE ISSUE PRICE IN PART I, COLUMN (E) DUE TO INVESTMENT INCOME. SCHEDULE K, PART 1, COLUMN F - LINE B: THE 2005 SERIES B BOND PROCEEDS WERE USED TO FINANCE THE COST OF ACQUIRING, CONSTRUCTING, IMPROVING, AND EQUIPPING THE WELLNESS CENTER, TO PAY CAPITALIZED INTEREST DURING CONSTRUCTION OF THE WELLNESS CENTER, AND TO FUND THE SERIES B DEBT SERVICE RESERVE FUND. SCHEDULE K, PART IV, LINE 2C: COLUMN A: (A) ISSUER NAME: IOWA HIGHER EDUCATION LOAN AUTHORITY, DATE THE REBATE COMPUTATION WAS PERFORMED: 11/30/2010. SCHEDULE K, PART IV, LINE 2C: COLUMN B: (A) ISSUER NAME: IOWA HIGHER EDUCATION LOAN AUTHORITY, DATE THE REBATE COMPUTATION WAS PERFORMED: 11/30/2010 SCHEDULE K, PART IV, LINE 5B: COLUMN A: RESERVE FUND - ROYAL BANK OF CANADA, ESCROW FUND - MBIA, INC SCHEDULE K, PART IV, LINE 5B: COLUMN B: CONSTRUCTION FUND - MORGAN STANLEY, RESERVE FUND - ROYAL BANK OF CANADA, CAPITALIZED INTEREST FUND - MORGAN STANLEY SCHEDULE K, PART IV, LINE 5C: COLUMN A: RESERVE FUND - 5 YRS, ESCROW FUND - 6.8 YRS SCHEDULE K, PART IV, LINE 5C: COLUMN B: CONSTRUCTION FUND - 2.4 YRS , RESERVE FUND - 5 YRS, CAPITALIZED INTEREST FUND - 2.4 YRS DISCLOSURE SUBJECT TO FERPA LAWS 29500 MERIT SCHOLARSHIPS STUDENT FINANCIAL AID FRED WALDSTEIN FAMILY MEMBER OF EDITH WALDSTEIN, VICE PRESIDENT OF ENROLLMENT MANAGEMENT 93725 EMPLOYED AS FACULTY; PROFESSOR OF POLITICAL SCIENCE. REPORTS TO THE VICE PRESIDENT FOR ACADEMIC AFFAIRS. FAMILY MEMBER EDITH WALDSTEIN, VICE PRESIDENT FOR ENROLLMENT MANAGEMENT, HAS NO CONTROL OVER FACULTY COMPENSATION OR GOVERNANCE. 0 AMPERAGE MARKETING PARTIAL OWNER IS A FAMILY MEMBER OF LIZ MATHIS, REGENT 268871 MARKETING AND ADVERTISING SERVICES PROVIDED IN THE ORDINARY COURSE OF BUSINESS. FEES CHARGED ARE NORMAL AND REASONABLE FOR THE SERVICES PROVIDED. LIZ MATHIS HAS NO CONTROL OVER AMPERAGE MARKETING. 0 X 29 1557807 AVG HI/LOW DATE OF GIFT X 1 65971 FMV 24 0 1 0 FORM 990, PART VI, SECTION B, LINE 11 THE COLLEGE PROVIDES PRELIMINARY TAX RETURN INFORMATION VIA SELECTED WORKPAPERS AND A SPECIALIZED TEMPLATE TO THE AUDIT FIRM. THE AUDIT FIRM THEN USES SPECIALIZED PROPRIETARY 990 TAX FORM SOFTWARE TO PERFORM DIAGNOSTICS AND PREPARE A DRAFT OF THE FORM 990 BASED ON INFORMATION PROVIDED TO THEM AND THEIR KNOWLEDGE OF HOW TO COMPLETE THE 990. AFTER RECEIVING THE DRAFT FORM 990 FROM THE AUDIT FIRM, PERSONNEL FROM THE BUSINESS OFFICE REVIEW THE DRAFT, RECONCILING INFORMATION BACK TO SUPPORTING WORK PAPERS WHERE POSSIBLE AND REVIEWING OTHER INFORMATION FOR COMPLETENESS, ACCURACY, CONSISTENCY, AND REASONABLENESS. NEXT, THE PRESIDENT'S CABINET AND THE BOARD'S AUDIT COMMITTEE MEMBERS REVIEW THE DRAFT OF THE FORM 990 FOR COMPLETENESS, ACCURACY, CONSISTENCY, AND REASONABLENESS. FEEDBACK FROM ALL REVIEW IS FORWARDED TO THE AUDIT FIRM, AND THE FORM 990 IS UPDATED ACCORDINGLY. A COPY OF THE FORM 990 (WITH DONOR NAMES REMOVED) IS POSTED TO THE SECURE, CONFIDENTIAL BOARD OF REGENTS WEB SITE, AND AN EMAIL IS SENT TO ALL BOARD MEMBERS NOTIFYING THEM THAT THE 990 IS AVAILABLE FOR REVIEW. FEEDBACK PROVIDED FROM THE BOARD MEMBERS IS REVIEWED AND DISCUSSED WITH INDIVIDUAL BOARD MEMBERS AS NECESSARY AND APPROPRIATE. ALL FEEDBACK THAT REQUIRES A SIGNIFICANT CHANGE TO THE FORM 990 IS PROVIDED IN A SUMMARY FASHION TO ALL BOARD MEMBERS, TO ALLOW ADDITIONAL FEEDBACK OR COMMENTS. THE FINAL APPROVED FEEDBACK IS GIVEN TO THE AUDIT FIRM TO INCORPORATE IN THE FINAL FORM 990. THE BOARD RECEIVES THE FINAL FORM 990 PRIOR TO IT BEING FILED. FORM 990, PART VI, SECTION B, LINE 12C THE CONFLICT OF INTEREST POLICY IS REVIEWED, UPDATED, AND APPROVED ANNUALLY BY THE BOARD. BOARD MEMBERS AND KEY EMPLOYEES ARE REMINDED OF THEIR RESPONSIBILITY TO FOLLOW THE CONFLICT OF INTEREST POLICY. BUSINESS OFFICE PERSONNEL ARE FAMILIAR WITH THE VENDORS USED BY THE COLLEGE AND WOULD FOLLOW THE CONFLICT OF INTEREST POLICY IF THERE WERE ANY POTENTIAL TRANSACTIONS THAT WOULD FALL WITHIN THE SCOPE OF THAT POLICY. FORM 990, PART VI, SECTION B, LINE 15A THE BOARD OF REGENTS ESTABLISHES COMPENSATION FOR THE PRESIDENT INITIALLY AND ANNUALLY, APPLYING ALL ELEMENTS NOTED IN THIS LINE'S QUERY. THE COMPARATOR GROUP IS LIMITED TO LIBERAL ARTS COLLEGES WITH COMPARABLE ENROLLMENTS, INCLUDING OTHER ELCA RELATED COLLEGES. THE PRESIDENT ESTABLISHES COMPENSATION FOR THE PRESIDENT'S CABINET INITIALLY AND ANNUALLY, APPLYING ALL ELEMENTS NOTED IN THIS LINE'S QUERY. THE COMPARATOR GROUP IS LIMITED TO LIBERAL ARTS COLLEGES WITH COMPARABLE ENROLLMENTS, INCLUDING OTHER ELCA-RELATED COLLEGES. FORM 990, PART VI, SECTION C, LINE 19 THE GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS ARE NOT MADE AVAILABLE TO THE PUBLIC.