2012-03-06T06:35:24-06:00 2011-05-31 CLIFTONLARSONALLEN LLP 2900 SOUTH QUINCY ST SUITE 150 ARLINGTON VA 22206 990 2010-06-01 530259954 NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS NATI 2028612500 1110 VERMONT AVENUE NW NO 800 WASHINGTON DC 20005 WILLIAM DILLON 2028612500 2012-03-06 1 JENNIFER M ALDRIDGE 7039985100 2010 2016-02-24 21:20:13Z JOHN WALDA 1110 VERMONT AVENUE NW NO 800 WASHINGTON DC 20005 15761889 0 X WWW.NACUBO.ORG X 1956 IL TO DEVELOP, PROMOTE, AND IMPROVE BUSINESS AND FINANCIAL PRINCIPLES AND PRACTICES IN THE ADMINISTRATION OF INSTITUTIONS OF HIGHER EDUCATION. 23 22 55 22 704239 117696 246189 280959 11975649 12220599 206831 205237 720348 628423 13149017 13335218 0 0 0 0 5630742 5134186 0 0 144381 7379664 7057311 13010406 12191497 138611 1143721 11693026 13506929 8480855 8303402 3212171 5203527 X THE USUAL PUBLIC ACTIVITIES OF NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS ARE TO DEVELOP, PROMOTE, AND IMPROVE BUSINESS AND FINANCIAL PRINCIPLES AND PRACTICES IN THE ADMINISTRATION OF INSTITUTIONS OF HIGHER EDUCATION AND TO FOSTER AMONG MEMBER INSTITUTIONS PROFESSIONAL IDEALS AND STANDARDS IN BUSINESS AND FINANCIAL ADMINISTRATION. NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS' CORE MISSION IS TO IMPROVE FINANCIAL AND ADMINISTRATIVE MANAGEMENT AT INSTITUTIONS OF HIGHER EDUCATION. TO THIS END, NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS MARSHALS EXPERTISE, SHARES KNOWLEDGE, PROVIDES TECHNICAL ASSISTANCE, AND ENCOURAGES INNOVATION IN BUSINESS PRACTICES. AREAS OF FOCUS INCLUDE ACCOUNTING AND FINANCIAL MANAGEMENT INCLUDING ENDOWMENTS AND DEBT, TAXATION, STUDENT FINANCIAL SERVICES, AND BUSINESS OPERATIONS INCLUDING INFORMATION TECHNOLOGY AND FACILITIES MANAGEMENT. 0 0 4098363 4872896 CONFERENCES, WORKSHOPS AND SEMINARSIN 2010-2011, A COMMUNITY OF APPROXIMATELY 300 COMMITTEE AND FACULTY MEMBERS OR PRESENTERS ALONG WITH ASSOCIATION STAFF PARTICIPATED IN THE PROCESS OF DESIGNING AND DELIVERING PROGRAMS TO MORE THAN 2000 REGISTRANTS. THE NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS ANNUAL MEETING IS THE MOST IMPORTANT PROFESSIONAL DEVELOPMENT EVENT OF THE YEAR FOR COLLEGE AND UNIVERSITY BUSINESS OFFICERS AND THEIR STAFF. APPROXIMATELY 1350 PAID REGISTRANTS ATTENDED THE CONFERENCE, HELD IN SAN FRANCISCO, CALIFORNIA FOR 2011 FISCAL YEAR. SESSION TOPICS INCLUDED PROGRAM SERVICE ACCOMPLISHMENTS, ACCOUNTING, FINANCIAL ADMINISTRATION, AUXILIARY ENTERPRISES, CHANGE MANAGEMENT, DISTANCE EDUCATION, TAXATION, AND MANY OTHER TECHNICAL, MANAGERIAL, AND LEADERSHIP ISSUES.NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS PRESENTED 15 WEB CASTS FROM THE ASSOCIATION'S STUDIO DURING THE YEAR. MORE THAN 2000 SITES WERE REGISTERED. THE WEB CASTS COVERED "HOT TOPICS" IN HIGHER EDUCATION BUSINESS AND ADMINISTRATION. THIS DEPARTMENT ADMINISTERS A CONTINUING PROFESSIONAL EDUCATION (CPE) CREDIT PROGRAM FOR CERTIFIED PUBLIC ACCOUNTANTS. NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS IS REGISTERED WITH THE NATIONAL ASSOCIATION OF STATE BOARDS OF ACCOUNTANCY (NASBA) AS A SPONSOR OF CONTINUING PROFESSIONAL EDUCATION ON THE NATIONAL REGISTRY OF CPE SPONSORS. PROFESSIONAL DEVELOPMENT (PDC) -NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS CREATES AND DELIVERS A BROAD RANGE OF PROGRAMS, SERVICES, AND PRODUCTS THAT ARE DESIGNED TO STRENGTHEN THE ABILITIES AND KNOWLEDGE OF CAMPUS ADMINISTRATORS AT ALL LEVELS. TO MEET THE CHANGING NEEDS OF HIGHER EDUCATION, NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS HAS DEVELOPED A VARIETY OF WORKSHOPS AND MATERIALS COVERING TOPICS IN THE FIELDS OF ACCOUNTING, HIGHER EDUCATION FINANCE, LEADERSHIP AND MANAGEMENT, TAX, STUDENT FINANCIAL SERVICES, CAMPUS OPERATIONS, AND TECHNOLOGY. 3975790 7356528 OTHER MEMBER SERVICESADVOCACY -NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS MONITORS AND ANALYZES PUBLIC POLICY ISSUES, FEDERAL LEGISLATION, AND AGENCY REGULATIONS THAT AFFECT THE FINANCIAL MANAGEMENT AND ADMINISTRATION OF COLLEGES AND UNIVERSITIES. THE ASSOCIATION KEEPS MEMBERS INFORMED OF FEDERAL ACTIONS, SOLICITS MEMBER OPINIONS AND CONCERNS, AND ADVOCATES FOR THE BEST INTERESTS OF COLLEGES AND UNIVERSITIES WITH CONGRESS AND FEDERAL AGENCIES. THE ASSOCIATION'S ADVOCACY EFFORTS WERE COORDINATED WITH A NUMBER OF OTHER ASSOCIATION'S REPRESENTING VARIOUS HIGHER EDUCATION CONSTITUENCIES. IN ADDITION, NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS IS THE VOICE FOR HIGHER EDUCATION WITH THE VARIOUS BODIES THAT SET STANDARDS FOR ACCOUNTING PRACTICES, SUCH AS THE FINANCIAL ACCOUNTING STANDARDS BOARD, THE ASSOCIATION OF CERTIFIED PUBLIC ACCOUNTANTS, AND THE U.S. GENERAL ACCOUNTING OFFICE.RESEARCH - NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS UNDERTAKES BOTH ON-GOING LONGITUDINAL STUDIES IMPORTANT TO THE HIGHER EDUCATION INDUSTRY SUCH AS THE ASSOCIATION'S ANNUAL STUDY OF COLLEGE AND UNIVERSITY ENDOWMENTS AND SHORT SURVEYS OR RESEARCH ON SPECIFIC ISSUES OF CONCERN.REGIONAL ASSOCIATIONS AND PARTNERSHIPS -NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS MANAGES AN ASSOCIATION MANAGEMENT SYSTEM THAT SERVES THE JOINT MEMBERSHIP OF THE NATIONAL ASSOCIATION AND ITS FOUR REGIONAL AFFILIATED ASSOCIATIONS (CACUBO, EACUBO, SACUBO AND WACUBO). THE SYSTEM CAPTURES A VARIETY OF DATA POINTS THAT ENABLE IMPROVED TRACKING OF INDIVIDUAL MEMBER ACTIVITY AND DUES BILLING AND COLLECTION PROCESSES. THIS DATABASE IS LINKED TO BOTH A CONTENT MANAGEMENT SYSTEM AND THE ASSOCIATION WEBSITE IMPROVING MEMBER SERVICE.AWARDS PROGRAM -NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS RECOGNIZES INSTITUTIONAL AND INDIVIDUAL EXCELLENCE THROUGH ITS AWARDS PROGRAM. THESE AWARDS WERE PRESENTED TO INDIVIDUALS WHO SHOWED OUTSTANDING ACHIEVEMENT AND EXEMPLARY PERFORMANCE IN THE AREAS OF FINANCIAL MANAGEMENT, ENDOWMENT MANAGEMENT, PROFESSIONAL DEVELOPMENT AND MORE. INSTITUTIONS WERE RECOGNIZED THAT DEMONSTRATED INNOVATION IN THE AREAS OF PROCESS IMPROVEMENT AND RESOURCE ENHANCEMENT. 342402 563436 PUBLICATIONS AND OTHER PRODUCTSNATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS PUBLICATIONS REMAIN A SOURCE OF PROFESSIONAL INFORMATION FOR MEMBERS. CIRCULATION OF THE MONTHLY BUSINESS OFFICER MAGAZINE HAS GROWN TO 27,800. NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS SELLS APPROXIMATELY 55 PUBLICATION TITLES, INCLUDING FOUR ANNUAL SUBSCRIPTION SERVICES. NEW PUBLICATIONS IN FY11 INCLUDE STRATEGIC FINANCIAL ANALYSIS IN HIGHER EDUCATION AND GUIDE TO UNITIZING INVESTMENT POOLS. 8416555 1 0 0 1 0 0 0 0 0 1 0 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 41 0 1 55 1 1 1 0 0 0 0 0 0 0 0 0 X 23 22 0 0 0 0 1 0 1 1 1 0 0 1 1 1 1 1 1 1 1 0 X WILLIAM DILLON 2028612500 1110 VERMONT AVENUE NW NO 800 WASHINGTON DC 20005 JOHN D WALDA 50.00 X X 469255 0 50361 CYNTHIA TENIENTE-MATSON 1.00 X X 0 0 0 KEVAN C BUCK 1.00 X X 0 0 0 RUTH CONSTANTINE 1.00 X X 0 0 0 MARY L HERRIN 1.00 X X 0 0 0 ROGER V BRUSZEWSKI 1.00 X 0 0 0 DAVID CLARK 1.00 X 0 0 0 KENNETH CODY 1.00 X 0 0 0 LYNN C COLEMAN 1.00 X 0 0 0 HENRY E DEVRIES II 1.00 X 0 0 0 ROBERT DIXON 1.00 X 0 0 0 JAMES R FISHER 1.00 X 0 0 0 ANTOINE M GARIBALDI 1.00 X 0 0 0 THOMAS H GIBSON 1.00 X 0 0 0 PHILIP J HANLON 1.00 X 0 0 0 CHARLES INGRAM 1.00 X 0 0 0 DENNIS R KLAUS 1.00 X 0 0 0 DANIEL D MORRIS 1.00 X 0 0 0 RONALD L RHAMES 1.00 X 0 0 0 ROGER W STACKPOOLE 1.00 X 0 0 0 WILLIAM B STEPHAN 1.00 X 0 0 0 CHARLES A TEGEN 1.00 X 0 0 0 MICHAEL T UNEBASAMI 1.00 X 0 0 0 WILLIAM DILLON 50.00 X 171733 0 37452 MATT HAMIL 50.00 X 184070 0 30842 ELBERT OUZTS 50.00 X 132265 0 27278 MARTA PEREZ-DRAKE 50.00 X 129523 0 20184 SUSAN MENDITTO 50.00 X 128847 0 25216 ANNE GROSS 50.00 X 121290 0 26273 DAVID DELORENZO 50.00 X 137832 0 34928 SUSAN JUROW 35.00 X 100811 0 12894 1575626 0 265428 10 1 1 0 AUGUST JACKSON COMPANY 1001 CONNECTICUT AVE NW SUITE 909 WASHINGTON DC 20036 AV PRODUCTION 388578 MINDSHIFT TECHNOLOGIES INC 307 WAVERLEY OAKS RD 201 WALTHAM MA 02452 IT SERVICES 268381 UNITED LITHO 21800 BEAUMEADE CIRCLE ASHBURN VA 20147 PRINTING 221225 AVECTRA 7901 JONES BRANCH DRIVE 5TH FLOOR MCLEAN VA 22102 CONSULTING MEMBERSHIP DATABASE 206888 ON24 201 THIRD STREET SUITE 300 SAN FRANCISCO CA 94103 TECH SUPPORT 121200 5 280959 280959 MEMBERSHIP DUES 900099 6584594 6584594 CONFERENCES, WORKSHOPS 900099 4872896 4231396 641500 ADVERTISING 541800 704239 704239 JOB BANK 900099 58870 58870 12220599 175049 175049 2362719 2332531 30188 30188 30188 657576 94140 563436 563436 SUBSCRIBER FEES REVENU 900099 8825 8825 56162 56162 64987 13335218 11388251 704239 961769 1085652 255471 828177 2004 2382182 1756203 569027 56952 477139 313291 153847 10001 928768 566746 345090 16932 260445 154528 101327 4590 65102 65102 46143 46143 2069378 1500898 568480 98324 96624 1193 507 633872 313063 320612 197 6869 4470 2399 1016356 35522 980834 486622 342478 139901 4243 512189 507785 4404 2584 2584 334239 334239 78779 14860 63919 990T/UBIT/FEDERAL & DC 52067 52067 FOOD/ BEVERAGES 1151651 1068776 80972 1903 PUBLICATIONS - PRINTING 392289 390368 378 1543 DATABASE/BOOKS/SUBSCRIP 46803 39267 7536 MEMBERSHIP FEES 35098 23032 12066 28946 1033173 -1049736 45509 12191497 8416555 3630561 144381 500 500 3233723 4438455 417819 275911 198262 125593 1126492 1240512 3517537 2294007 1525158 1223530 5191072 6202428 11693026 13506929 1257557 1316086 5919295 5783294 1304003 1204022 8480855 8303402 X 2708633 4804979 455038 350048 48500 48500 3212171 5203527 11693026 13506929 X 1143721 847635 X 0 1 1 X 0 X 229000 260361 751952 246189 280959 1768461 11583150 12134424 12341103 11933887 12115066 60107630 11812150 12394785 13093055 12180076 12396025 61876091 0 67434 477763 10540 6008 561745 67434 477763 10540 6008 561745 61314346 412505 449814 214195 128539 175049 1380102 1025794 1060780 710134 675657 704239 4176604 1438299 1510594 924329 804196 879288 5556706 45844 40853 184474 184972 123857 580000 13296293 13946232 14201858 13169244 13399170 68012797 0.90150 0.89490 0.08170 0.08880 X 25590 25590 12021526 12047116 752356 188089 0 0 849924 822275 805446 752356 3230001 4845002 28225 13635 40923 25590 108373 212481 205569 201362 188089 807501 1211252 1326363 513276 813087 606686 541595 65091 1584488 1239136 345352 1223530 DEFERRED LEASE LIABILITY 1181858 CAPITAL LEASE OBLIGATIONS 22164 1204022 13335218 12191497 1143721 847635 847635 1991356 14601143 847635 324150 94140 1265925 13335218 0 13335218 12609787 324150 94140 418290 12191497 0 12191497 DESCRIPTION OF UNCERTAIN TAX POSITIONS UNDER FIN 48: PART X: NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS IS EXEMPT FROM THE PAYMENT OF TAXES ON INCOME OTHER THAN NET UNRELATED BUSINESS INCOME UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE. NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS RECEIVED UNRELATED BUSINESS INCOME FROM ADVERTISING REVENUE THAT IS SUBJECT TO THE UNRELATED BUSINESS INCOME TAX. INCOME TAX EXPENSE OF APPROXIMATELY $52,100 AND $34,850 HAS BEEN PROVIDED FOR IN THE YEARS ENDED MAY 31, 2011 AND 2010, RESPECTIVELY, AND IS INCLUDED IN ADMINISTRATION EXPENSE IN THE ACCOMPANYING STATEMENTS OF ACTIVITIES. NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS PERFORMED AN EVALUATION OF UNCERTAIN TAX POSITIONS FOR THE YEARS ENDED MAY 31, 2011 AND 2010, 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. AS OF MAY 31, 2011, THE STATUTE OF LIMITATIONS FOR TAX YEARS 2007 THROUGH 2009 REMAINS OPEN WITH THE U.S. FEDERAL JURISDICTION OR THE VARIOUS STATES AND LOCAL JURISDICTIONS IN WHICH NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS FILES TAX RETURNS. IT IS NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS' POLICY TO RECOGNIZE INTEREST AND/OR PENALTIES RELATED TO UNCERTAIN TAX POSITIONS, IF ANY, IN INCOME TAX EXPENSE. PART XII, LINE 2D - OTHER ADJUSTMENTS: COST OF SALES 94,140. PART XIII, LINE 2D - OTHER ADJUSTMENTS: COST OF SALES 94,140. X 1 1 X X X X X 0 0 0 0 0 0 0 0 0 JOHN D WALDA 465325 0 0 0 3930 0 35835 0 14526 0 519616 0 0 0 WILLIAM DILLON 169753 0 0 0 1980 0 25348 0 12104 0 209185 0 0 0 MATT HAMIL 183620 0 0 0 450 0 26985 0 3857 0 214912 0 0 0 ELBERT OUZTS 132007 0 0 0 258 0 18985 0 8293 0 159543 0 0 0 SUSAN MENDITTO 128271 0 0 0 576 0 18491 0 6725 0 154063 0 0 0 DAVID DELORENZO 137541 0 0 0 291 0 21020 0 13908 0 172760 0 0 0 SUSAN JUROW 99707 0 0 0 1104 0 0 0 12894 0 113705 0 0 0 PART I, LINE 1A TRAVE FOR COMPANIONS MARTHA WALDA, PRESIDENT'S WIFE, AIRLINE COSTS, $7,798 - INCLUDIBLE IN MR. JOHN D. WALDA'S INCOME FORM 990, PART VI, SECTION A, LINE 6 NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS HAS THE FOLLOWING TYPES OF MEMBERS: REGULAR, ASSOCIATE, PROVISIONAL, SUBSCRIBER, AFFILIATE, GOVERNING BOARD AND STUDENT/RETIREE. FORM 990, PART VI, SECTION A, LINE 7B DUES INCREASES ARE SUBJECT TO MEMBER APPROVAL. FORM 990, PART VI, SECTION B, LINE 11 THE FINANCE AND AUDIT COMMITTEE WILL REVIEW AND APPROVE THE 990 BEFORE IT IS FILED. THE ENTIRE BOARD WILL BE PROVIDED ACCESS TO REVIEW THE 990 FOR AT LEAST A MONTH BEFORE THE 990 IS FILED. FORM 990, PART VI, SECTION B, LINE 12C EACH EMPLOYEE HAS A DUTY TO PLACE NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS' INTERESTS FOREMOST IN ANY PERSONAL DEALINGS WITH NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS AND HAS A CONTINUING RESPONSIBILITY TO COMPLY WITH THE REQUIREMENTS OF THIS POLICY. THE CONDUCT OF PERSONAL BUSINESS BETWEEN ANY EMPLOYEE AND NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS IS PROHIBITED WITHOUT WRITTEN APPROVAL OF THE PRESIDENT AND CHIEF EXECUTIVE OFFICER OF NACUBO, AFTER FULL DISCLOSURE BY THE EMPLOYEE. EACH EMPLOYEE MUST SIGN THE CONFLICT OF INTEREST DISCLOSURE STATEMENT FOR PURPOSES OF PROVIDING THE EMT WITH THE INFORMATION NEEDED TO IMPLEMENT THIS POLICY. EMPLOYEE DISCLOSURE STATEMENTS WILL BE REVIEWED BY THE NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS PRESIDENT, WHO WILL RESOLVE ANY ACTUAL OR POTENTIAL CONFLICT(S). EACH EMPLOYEE SHALL ANNUALLY SIGN A DISCLOSURE STATEMENT WHICH AFFIRMS THAT SUCH PERSON: A. HAS RECEIVED A COPY OF THE CONFLICT OF INTEREST POLICY, B. HAS READ AND UNDERSTANDS THE POLICY, C. HAS AGREED TO COMPLY WITH THE POLICY. THE DISCLOSURE STATEMENT WILL ALSO PROVIDE AN OPPORTUNITY TO DISCLOSE OR DISCLAIM SPECIFIC FINANCIAL INTERESTS. THIS POLICY APPLIES TO THE BOARD OF DIRECTORS AS WELL AS ALL EMPLOYEES. FORM 990, PART VI, SECTION B, LINE 15 THE PROCESS WAS DONE FOR THE PRESIDENT IN MAY 2010. THE PROCESS WAS DONE FOR THE EXECUTIVE MANAGEMENT TEAM IN MAY 2010. INCREASES FOR BOTH WERE EFFECTIVE FOR FISCAL YEAR 2011. THE ORGANIZATION USES AN INDEPENDENT COMPENSATION CONSULTANT AND COMPENSATION SURVEYS AND STUDIES TO DETERMINE THE APPROPRIATE COMPENSATION AMOUNTS. ONCE APPROVED BY THE COMPENSATION COMMITTEE, A WRITTEN EMPLOYMENT CONTRACT IS WRITTEN FOR THE PRESIDENT/CEO AND THE EXECUTIVE MANAGEMENT TEAM. THE MOST RECENT YEAR THAT THE PROCESS TOOK PLACE WAS IN 2011. FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATION MAKES ITS GOVERNING DOCUMENTS AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC VIA ITS WEBSITE. IT DOES NOT MAKE ITS CONFLICT OF INTEREST POLICY AVAILABLE TO THE PUBLIC. CHANGES IN NET ASSETS OR FUND BALANCES: FORM 990, PART XI, LINE 5: NET UNREALIZED GAINS ON INVESTMENTS: 847,635. THIS RETURN IS BEING FILED BETWEEN MARCH 1, 2012, AND MARCH 30, 2012, AS DIRECTED BY THE IRS IN NOTICE 2012-4, BECAUSE ELECTRONIC FILING WAS NOT AVAILABLE JANUARY 1, 2012 THROUGH FEBRUARY 29, 2012. WE REQUEST THAT PENALTIES BE WAIVED BECAUSE IT WOULD BE INEQUITABLE TO IMPOSE A PENALTY ON US DUE TO THE UNUSUAL CIRCUMSTANCES REQUIRING US TO DELAY THE FILING OF THIS RETURN.