2026-05-12T10:42:47-05:00 2025-06-30 991856619 GRANT THORNTON ADVISORS LLC 757 THIRD AVENUE 9TH FLOOR NEW YORK NY 100172013 990 2024-07-01 111635105 ST FRANCIS COLLEGE STFR 7184895364 179 LIVINGSTON STREET BROOKLYN NY 11201 MARK SANDERS CFO 7184895364 2025-11-14 1 0 DANIEL ROMANO P00504182 2125990100 2024 2025-03-06 01:10:19Z TIM CECERE 179 LIVINGSTON STREET BROOKLYN NY 11201 83164769 0 X WWW.SFC.EDU X 1957 NY ST. FRANCIS COLLEGE IS AN INDEPENDENT, COEDUCATIONAL INSTITUTION (SEE SCHEDULE O) OF HIGHER EDUCATION CHARTERED BY AN ACT OF THE REGENTS OF THE UNIVERSITY OF THE STATE OF NY ON APRIL 10, 1957. 15 15 522 0 0 0 3479243 4096217 69140009 71034087 3300779 928669 1954784 925153 77874815 76984126 25995446 24124671 0 0 30017440 28802235 0 0 0 41571896 54411971 97584782 107338877 -19709967 -30354751 368999187 338057414 302747488 301202568 66251699 36854846 ST. FRANCIS COLLEGE IS AN INDEPENDENT, COEDUCATIONAL INSTITUTION OF HIGHER EDUCATION CHARTERED BY AN ACT OF THE REGENTS OF THE UNIVERSITY OF THE STATE OF NEW YORK ON APRIL 10, 1957. 0 0 73737773 24124671 71034087 INSTRUCTIONAL - THE COLLEGE PROVIDES DIRECT SERVICES THROUGH ITS FACULTY TO APPROXIMATELY 1,700 FULL AND PART TIME STUDENTS LEADING PRIMARILY TO BACCALAUREATE AND ASSOCIATE DEGREES AND APPROXIMATELY 2,850 STUDENTS LEADING TO GRADUATE DEGREES.STUDENT AID AND OTHER - FUNDING FOR SCHOLARSHIPS, GRANTS, AND OTHER FINANCIAL AID. THE COLLEGE AWARDS FEDERAL AND STATE GRANTS AND/OR LOANS BASED UPON FINANCIAL NEED. COLLEGE FUNDED INSTITUTIONAL AND ENDOWED GRANTS/SCHOLARSHIPS ARE AWARDED BASED UPON FINANCIAL NEED AND ACADEMIC MERIT. 0 0 0 ACADEMIC SUPPORT - PROVIDES FUNDING FOR SUPPORT SERVICES TO THE INSTRUCTIONAL DEPARTMENTS, ACADEMIC ENHANCEMENT AND STUDENT ORIENTATION SERVICES, HONORS PROGRAMS, AND THE LIBRARY. STUDENT SERVICES - PROVIDES FUNDING FOR THE OFFICES OF ADMISSIONS, REGISTRAR, AND OTHER STUDENT RELATED SUPPORT SERVICES AND ACTIVITIES TO ENSURE STUDENTS' EMOTIONAL AND PHYSICAL WELL-BEING AND DEVELOPMENT OUTSIDE THE FORMAL INSTRUCTIONAL PROGRAM. 73737773 1 1 0 1 0 0 0 1 0 1 1 0 0 1 1 1 1 0 1 0 1 0 0 0 1 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 94 0 1 522 1 0 0 0 0 0 1 1 0 0 0 0 0 0 X 15 15 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 X ALISON EASTWOOD CONTROLLER 7184895364 179 LIVINGSTON STREET BROOKLYN NY 11201 TIMOTHY CECERE PRESIDENT 45.00 0.00 X X 485940 0 20832 DENIS SALAMONE TRUSTEE - CHAIR 5.00 0.00 X X 0 0 0 BARBARA KOSTER TRUSTEE - VICE CHAIR 5.00 0.00 X X 0 0 0 HELEN GAUDETTE TRUSTEE 5.00 0.00 X 0 0 0 EDWARD CONSTANTINO TRUSTEE 5.00 0.00 X 0 0 0 J CHRISTOPHER MANGAN TRUSTEE 5.00 0.00 X 0 0 0 PATRICK DUGAN TRUSTEE 5.00 0.00 X 0 0 0 JUDY RICE TRUSTEE - SECRETARY 5.00 0.00 X X 0 0 0 ARKELL COX TRUSTEE 5.00 0.00 X 0 0 0 MICHAEL MACINTYRE TRUSTEE 5.00 0.00 X 0 0 0 BROTHER WILLIAM BOSLET TRUSTEE 5.00 0.00 X 0 0 0 BROTHER LEONARD CONWAY TRUSTEE 5.00 0.00 X 0 0 0 ROBERT GORE TRUSTEE 5.00 0.00 X 0 0 0 VICTOR MASI TRUSTEE 5.00 0.00 X 0 0 0 JOHN TULLY TRUSTEE 5.00 0.00 X 0 0 0 BROTHER GABRIEL O'BRIEN TRUSTEE (TERM 12/2024) 5.00 0.00 X 0 0 0 ANA OLIVEIRA TRUSTEE (TERM 01/2025) 5.00 0.00 X 0 0 0 HAYLEY DRYER VP & GENERAL COUNSEL 45.00 0.00 X 506755 0 31898 MARK SANDERS ACTING CFO 45.00 0.00 X 294718 0 39736 ROBERT OLIVA VP ENROLLMENT MGMT & COMMUNITY 45.00 0.00 X 285525 0 46060 KEVIN S O'ROURKE VP OF FACILITIES 45.00 0.00 X 252607 0 52058 DENNIS ANDERSON PROFESSOR 45.00 0.00 X 256137 0 26242 NICOLE HALL EXECUTIVE DIRECTOR OF HR 45.00 0.00 X 250085 0 21175 GALE GIBSON GAYLE VP OF GRADUATE EDUCATION 45.00 0.00 X 236120 0 47602 JOHN EDWARDS VP FOR ACADEMIC AFFAIRS 45.00 0.00 X 174713 0 7669 MANFRED KRUEGER CHIEF INFORMATION OFFICER 45.00 0.00 X 7719 0 363 STANLEY BAZILE AVP STUDENT AFFAIRS 40.00 0.00 X 208562 0 22577 MATTHEW HOGAN EXEC DIR OF IT OPS & CLIENT SVS 40.00 0.00 X 178139 0 22789 ALLEN BURDOWSKI VP OF RESEARCH & COMPLIANCE 45.00 0.00 X 232031 0 11362 KEITH HOELL ASSISTANT PROFESSOR 40.00 0.00 X 226968 0 39169 JENNIFER M LANCASTER PROFESSOR 40.00 0.00 X 224255 0 30937 TIMOTHY J HOULIHAN ASSOCIATE PROFESSOR 40.00 0.00 X 216764 0 39409 LOUIS D'ELIA ASSISTANT PROFESSOR 40.00 0.00 X 216516 0 31092 4253554 0 490970 67 0 1 0 CULLEN DYKMAN 100 QUENTIN ROOSEVELT BLVD GARDEN CITY NY 11530 LEGAL SERVICES 893244 GERI A GREGOR CPA PLLC 65 EAST OLIVE STREET LONG BEACH NY 11561 CONSULTING 515886 COLLINS BUILDING SERVICES 24-01 44TH RD 15TH FL LONG ISLAND CITY NY 11101 MAINTENANCE SERVICES 452017 PILLSBURY WINTHROP SHAW PITTMAN LLP PO BOX 601240 CHARLOTTE NC 282601240 LEGAL SERVICES 306413 ATI 62277 COLLECTIONS CHICAGO IL 60693 EDUCATIONAL SERVICES 255865 11 38993 1138339 2918885 4637 4096217 STUDENT TUITION & FEES 611710 68784875 68784875 INTERNATIONAL SUMMER PROGRAM 611710 2249212 2249212 71034087 920796 920796 684961 0 684961 684961 684961 6067107 6059234 7873 7873 7873 269612 38993 121409 148203 148203 91989 91989 91989 76984126 71034087 0 1853822 24124671 24124671 4871166 2465209 2405957 18172031 17210351 961680 751104 664839 86265 3009327 2663704 345623 1998607 1769066 229541 3308062 3308062 210170 210170 240230 240230 2061131 563385 1497746 314021 314021 463719 305735 157984 9637926 6999063 2638863 151622 97930 53692 128020 110352 17668 36392 24932 11460 3360845 2302512 1058333 OPERATING LEASE EXPENSE 13027701 8925266 4102435 LEGAL SETTLEMENT 12000000 12000000 PHYSICAL PLANT MAINT. 6789424 4586337 2203087 BAD DEBT EXPENSE 905300 905300 1777408 924421 852987 107338877 73737773 33601104 0 1945906 1868510 7665794 8664104 522891 164657 1471524 1059745 150323 143047 13841213 1243477 79705308 23875594 59190558 55829714 7067094 7190227 11907819 8762371 265236065 253131562 368999187 338057414 5321781 8257664 4147634 6002058 293278073 286942846 302747488 301202568 X 35331627 6403790 30920072 30451056 66251699 36854846 368999187 338057414 -30354751 957898 0 X 0 1 X 1 1 1 X 17689664 14427303 4067143 3479242 4096217 43759569 17689664 14427303 4067143 3479242 4096217 43759569 760967 42998602 666802 660801 1727300 4132685 1605757 8793345 136065 240832 909952 1250294 361600 2898743 55451657 339221572 0.77540 0.81030 X SCHEDULE A, PART II, LINE 10, EXPLANATION OF OTHER INCOME: FUNDRAISING REVENUE - 2020 AMOUNT: $ 70,300. 2021 AMOUNT: $ 168,618. 2022 AMOUNT: $ 60,977. 2023 AMOUNT: $ 419,491. 2024 AMOUNT: $ 269,611. CAFETERIA/VENDING REVENUE - 2020 AMOUNT: $ 0. 2021 AMOUNT: $ 0. 2022 AMOUNT: $ 219,331. 2023 AMOUNT: $ 0. 2024 AMOUNT: $ 0. POOL RENTAL - 2020 AMOUNT: $ 0. 2021 AMOUNT: $ 0. 2022 AMOUNT: $ 102,355. 2023 AMOUNT: $ 0. 2024 AMOUNT: $ 0. OTHER REVENUE - 2020 AMOUNT: $ 65,765. 2021 AMOUNT: $ 72,214. 2022 AMOUNT: $ 527,289. 2023 AMOUNT: $ 830,803. 2024 AMOUNT: $ 91,989. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 0 0 0 1 240230 240230 0 PART II-B, LINE 1: THE COLLEGE HIRES CONSULTANTS TO PROVIDE ADVICE, STRATEGIC PLANNING, AND PROGRAM IMPLEMENTATION ON VARIOUS PROJECTS AND ISSUES. ADDITIONALLY, ON BEHALF OF THE COLLEGE THE CONSULTANT ATTENDS AND PERFORMS VARIOUS PRESENTATIONS BEFORE ELECTED OFFICIALS, PUBLIC HEARINGS AND GOVERNMENT ADMINISTRATORS. 200205 X X CURRENTLY HELD IN STORAGE 0 25221492 100050 1666295 2061647 648875 24277315 30757223 130725 1746104 3125509 4287051 25221492 31791147 352128 1892285 775024 2503313 30757223 40712093 248239 -4679750 1195344 3294091 31791147 28712076 452079 15527868 407537 3572393 40712093 0.00000 0.52014 0.47986 0 0 57085474 5708550 51376924 22419629 18167044 4252585 200205 200205 55829714 RIGHT-OF-USE ASSETS 231506513 CASH RESTRICTED FOR LOAN PROGRAMS 7423 OTHER RECEIVABLES 1072618 SECURITY DEPOSIT ON LEASE 20545008 253131562 OPERATING LEASE LIABILITIES 284851569 REFUNDABLE LOAN PROGRAM 68035 LINE OF CREDIT 2023242 286942846 X 53938761 957898 121409 1079307 52859454 24124671 24124671 76984125 83335614 121409 121409 83214205 24124671 24124671 107338876 PART III, LINE 4: ART COLLECTIONS THE COLLEGE POSSESSES A COLLECTION OF CENTRAL AMERICAN ART HELD IN STORAGE. PART V, LINE 4: ENDOWMENT CERTAIN ENDOWMENT FUNDS ARE USED TO PROVIDE SCHOLARSHIPS TO STUDENTS IN ACCORDANCE WITH DONOR SPECIFICATIONS. IN ADDITION, THE BOARD OF TRUSTEES APPROVED A SPENDING POLICY THAT MADE AVAILABLE 5.0% OF THE AVERAGE MARKET VALUE OF INVESTMENTS TO SUPPORT OF THE COLLEGE'S STUDENTS. PART X, LINE 2: FIN 48 THE COLLEGE ADOPTED THE PROVISIONS OF ASC 740, ACCOUNTING FOR UNCERTAINTIES IN INCOME TAXES. ASC 740-10 CLARIFIES THE ACCOUNTING FOR UNCERTAINTY IN TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN, INCLUDING ISSUES RELATING TO FINANCIAL STATEMENT RECOGNITION AND MEASUREMENT. THIS STANDARD PROVIDES THAT THE TAX EFFECTS FROM AN UNCERTAIN TAX POSITION CAN BE RECOGNIZED IN THE FINANCIAL STATEMENTS ONLY IF THE POSITION IS MORE LIKELY THAN NOT TO BE SUSTAINED IF THE POSITION WERE TO BE CHALLENGED BY A TAXING AUTHORITY. THE ASSESSMENT OF THE TAX POSITION IS BASED SOLELY ON THE TECHNICAL MERITS OF THE POSITION, WITHOUT REGARD TO THE LIKELIHOOD THAT THE TAX POSITION MAY BE CHALLENGED. THE COLLEGE IS EXEMPT FROM FEDERAL AND NEW YORK INCOME TAXATION BY VIRTUE OF BEING AN ORGANIZATION DESCRIBED IN SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE (THE "CODE") AND SIMILAR PROVISIONS OF THE NEW YORK STATE TAX CODE. NEVERTHELESS, THE COLLEGE MAY BE SUBJECT TO TAX ON INCOME UNRELATED TO ITS EXEMPT PURPOSE, UNLESS THAT INCOME IS OTHERWISE EXCLUDED BY THE CODE. MANAGEMENT BELIEVES THAT THERE ARE NO MATERIAL UNCERTAIN TAX POSITIONS WITHIN ITS FINANCIAL STATEMENTS. PART XI, LINE 2D - OTHER ADJUSTMENTS: FUNDRAISING EXPENSES NETTED AGAINST REVENUE 121,409. PART XI, LINE 4B - OTHER ADJUSTMENTS: SCHOLARSHIPS & GOVERNMENT SPONSORED ASSISTANCE NETTED AGAINST REVENUE 24,124,671. PART XII, LINE 2D - OTHER ADJUSTMENTS: FUNDRAISING EXPENSES NETTED AGAINST REVENUE 121,409. PART XII, LINE 4B - OTHER ADJUSTMENTS: SCHOLARSHIPS & GOVERNMENT SPONSORED ASSISTANCE NETTED AGAINST REVENUE 24,124,671. 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 PUBLICIZES ITS RACIALLY NON-DISCRIMINATORY POLICY ON ITS WEBSITE. SCHEDULE E, PART I, LINE 6 FINANCIAL ASSISTANCE IS PROVIDED TO OUR STUDENTS BY THE U.S. DEPARTMENT OF EDUCATION THROUGH FEDERALLY FUNDED CAMPUS BASED PROGRAMS - FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANT (FSEOG), FEDERAL WORK STUDY (FWS) AND THE FEDERAL PERKINS LOAN PROGRAM. THE COLLEGE ALSO RECEIVES FINANCIAL ASSISTANCE UNDER MULTIPLE NEW YORK STATE AID PROGRAMS INCLUDING THE TUITION ASSISTANCE PROGRAM (TAP). CENTRAL AMERICA AND THE CARIBBEAN - ANTIGUA & BARBUDA, ARUBA, BAHAMAS, 0 0 INVESTMENTS 7211642 0 0 0 0 0 0 7211642 0 7211642 1 0 1 0 1 0 SCHEDULE F, PART IV ST. FRANCIS COLLEGE INVESTS DIRECTLY IN VARIOUS ALTERNATIVE INVESTMENTS THAT MAY BE ORGANIZED AS EITHER FOREIGN CORPORATIONS OR FOREIGN PARTNERSHIPS; IT LIKEWISE, INVESTS IN DOMESTIC LIMITED PARTNERSHIPS THAT MAY, IN TURN, INVEST IN FOREIGN CORPORATIONS OR PARTNERSHIPS. NEVERTHELESS, SFC'S INVESTMENT ACTIVITIES MAY NOT REACH THE THRESHOLDS REQUIRED FOR THE FILING OF FORMS 926, 5471, 8621, OR 8865. TO THE EXTENT THAT SFC IS REQUIRED TO COMPLETE ONE (OR MORE) OF THESE FOREIGN FORMS, THEY ARE FILED WITH THE FORM 990-T FILING. GOLF OUTINGS 157796 21320 136476 32500 1000 28529 AWARD DINNER 150809 17673 133136 1000 35390 1500 21490 308605 38993 269612 1000 32500 35390 2500 50019 121409 148203 1 COLLEGE FUNDED SCHOLARSHIPS 5330 23672198 SUPPLEMENTAL EQUAL OPPORTUNITY GRANT 643 255520 FEDERAL WORK STUDY 75 196953 PART I, LINE 2: THE COLLEGE AWARDS FEDERAL AND STATE GRANTS BASED UPON FINANCIAL NEED. COLLEGE FUNDED INSTITUTIONAL AND ENDOWED GRANTS/SCHOLARSHIPS ARE AWARDED BASED UPON FINANCIAL NEED AND ACADEMIC MERIT. THE COLLEGE MONITORS THESE GRANTS AND AWARDS BY SEMESTER TO VERIFY THAT RECIPIENTS ARE MAINTAINING THE MINIMUM STANDARDS REQUIRED TO RECEIVE THE GRANT OR AWARD. 1 X X X X X 0 0 0 0 0 0 0 1 0 HAYLEY DRYER VP & GENERAL COUNSEL 343380 0 162875 0 500 0 15346 0 16552 0 538653 0 0 0 TIMOTHY CECERE PRESIDENT 450180 0 0 0 35760 0 19731 0 1101 0 506772 0 0 0 MARK SANDERS ACTING CFO 292468 0 0 0 2250 0 0 0 39736 0 334454 0 0 0 ROBERT OLIVA VP ENROLLMENT MGMT & COMMUNITY 197812 0 84563 0 3150 0 9214 0 36846 0 331585 0 0 0 KEVIN S O'ROURKE VP OF FACILITIES 198058 0 53259 0 1290 0 9341 0 42717 0 304665 0 0 0 GALE GIBSON GAYLE VP OF GRADUATE EDUCATION 234860 0 0 0 1260 0 10106 0 37496 0 283722 0 0 0 DENNIS ANDERSON PROFESSOR 255037 0 0 0 1100 0 11913 0 14329 0 282379 0 0 0 NICOLE HALL EXECUTIVE DIRECTOR OF HR 205220 0 43000 0 1865 0 3986 0 17189 0 271260 0 0 0 KEITH HOELL ASSISTANT PROFESSOR 226968 0 0 0 0 0 2900 0 36269 0 266137 0 0 0 TIMOTHY J HOULIHAN ASSOCIATE PROFESSOR 216164 0 0 0 600 0 9800 0 29609 0 256173 0 0 0 JENNIFER M LANCASTER PROFESSOR 224255 0 0 0 0 0 6685 0 24252 0 255192 0 0 0 LOUIS D'ELIA ASSISTANT PROFESSOR 215556 0 0 0 960 0 4542 0 26550 0 247608 0 0 0 ALLEN BURDOWSKI VP OF RESEARCH & COMPLIANCE 232031 0 0 0 0 0 9340 0 2022 0 243393 0 0 0 STANLEY BAZILE AVP STUDENT AFFAIRS 98631 0 109931 0 0 0 3805 0 18772 0 231139 0 0 0 MATTHEW HOGAN EXEC DIR OF IT OPS & CLIENT SVS 174539 0 0 0 3600 0 6830 0 15959 0 200928 0 0 0 JOHN EDWARDS VP FOR ACADEMIC AFFAIRS 174713 0 0 0 0 0 6633 0 1036 0 182382 0 0 0 PART I, LINE 1A TRAVEL ALLOWANCE IN 2024, THE PRESIDENT, TIM CECERE, RECEIVED A TRANSPORTATION ALLOWANCE. THE GROSS AMOUNT PER PAYROLL WAS $34,860. PART I, LINE 4 DURING THE YEAR, THE COLLEGE WENT THROUGH A RESTRUCTURING WHICH INCLUDED SEVERAL CHANGES IN ROLES, POSITIONS, AND DUTIES, INCLUDING RETIREMENTS AND OTHER SEPARATIONS FROM EMPLOYMENT. TO THE EXTENT ANY SUCH PAYMENTS CONTINGENT ON AN EMPLOYEE'S SEPARATION WERE CONSIDERED SEVERANCE, OR SIMILAR, THEY ARE DISCLOSED IN COLUMN B(III), AS REQUIRED. THE COLLEGE IS NOT DISCLOSING THE NAMES OF ANY IMPACTED EMPLOYEES DUE TO CONFIDENTIALITY CLAUSES INCLUDED IN AGREEMENTS THAT WERE ENTERED INTO. PART I, LINE 7 DURING THE YEAR, RETENTION BONUSES WERE PAID TO SEVERAL EMPLOYEES IN ORDER TO RETAIN THEIR SERVICES THROUGH THE TRANSITION AND RESTRUCTURING. FORM 990, PART VI, SECTION B, LINE 11B FORM 990 REVIEW PROCESS THE FORM 990 IS PREPARED BY A NATIONALLY RECOGNIZED ACCOUNTING FIRM IN CONJUNCTION WITH THE ORGANIZATION'S FINANCE DEPARTMENT. ONCE THE PREPARATION AND REVIEW PROCESS IS COMPLETE, THE FULL 990 IS PROVIDED TO THE EXECUTIVE COMMITTEE FOR REVIEW AND APPROVAL. FORM 990, PART VI, SECTION B, LINE 12C CONFLICT OF INTEREST POLICY ENFORCEMENT AND MONITORING THE CONFLICT OF INTEREST POLICY IS DISTRIBUTED TO ALL FACULTY, STAFF, AND ADMINISTRATION EVERY YEAR. CERTAIN EMPLOYEES ARE REQUIRED TO SIGN THE QUESTIONNAIRE AND DISCLOSE ANY CONFLICTS. ALL MEMBERS OF THE BOARD OF TRUSTEES ARE REQUIRED TO REVIEW THE POLICY AND SIGN AND COMPLETE A QUESTIONNAIRE ON AN ANNUAL BASIS, DISCLOSING POTENTIAL CONFLICTS. THE EXECUTIVE COMMITTEE OF THE BOARD MONITORS AND ENFORCES COMPLIANCE. IN THE EVENT A TRUSTEE, OFFICER OR KEY EMPLOYEE PLANS TO INITIATE OR PARTICIPATE IN A TRANSACTION, ARRANGEMENT OR ACTIVITY WITH OR ON BEHALF OF THE COLLEGE IN WHICH HE HAS A MATERIAL FINANCIAL INTEREST OF ANY NATURE, SUCH PERSON MUST DISCLOSE SUCH INTEREST TO THE AUDIT COMMITTEE OF THE COLLEGE BOARD OF TRUSTEES (THE "COMMITTEE") BEFORE COMMENCING SUCH ACTIVITY. AFTER DISCLOSURE OF ALL RELEVANT INFORMATION, THE DISCLOSING PERSON MAY MAKE A PRESENTATION AT THE COMMITTEE MEETING. AFTER SUCH PRESENTATION, THE COMMITTEE SHALL, IN ABSENCE OF THE DISCLOSING PERSON, DISCUSS AND VOTE ON, THE TRANSACTION, ARRANGEMENT OR ACTIVITY AND DETERMINE WHETHER A CONFLICT OF INTEREST EXISTS. IF THE DISCLOSING PERSON IS A MEMBER OF THE COMMITTEE, SUCH PERSON SHALL ABSTAIN FROM DELIBERATIONS AND VOTING, AND THE DISINTERESTED MEMBERS OF THE COMMITTEE SHALL MAKE THE DETERMINATION IN ABSENCE OF SUCH PERSON. THE DISCLOSING PERSON SHALL NOT IN ANY WAY IMPROPERLY INFLUENCE THE DELIBERATION OR VOTING ON THE TRANSACTION, ARRANGEMENT OR ACTIVITY GIVING RISE TO A POTENTIAL CONFLICT. THE COMMITTEE WILL REVIEW ALL RELEVANT INFORMATION. THE REVIEW PROCESS WILL BE DESIGNED TO PROTECT CONFIDENTIAL INFORMATION TO THE DEGREE PERMITTED BY LAW. THE COMMITTEE WILL MAKE A DETERMINATION AS TO WHETHER A SITUATION IS PERMISSIBLE OR A CONFLICT OF INTEREST EXISTS, WHICH SHALL BE FINAL, SUBJECT TO RATIFICATION BY THE ENTIRE BOARD AT ITS NEXT MEETING. IF THE COMMITTEE HAS REASONABLE CAUSE TO BELIEVE THAT A TRUSTEE, OFFICER OR KEY EMPLOYEE HAS KNOWINGLY FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT OF INTEREST, IT SHALL INFORM SUCH PERSON OF THE BASIS FOR SUCH BELIEF AND AFFORD SUCH PERSON AN OPPORTUNITY TO EXPLAIN THE ALLEGED FAILURE TO DISCLOSE. IF, AFTER RECEIVING THE RESPONSE OF THE INDIVIDUAL AND MAKING SUCH FURTHER INVESTIGATION AS MAY BE WARRANTED IN THE CIRCUMSTANCES, THE COMMITTEE DETERMINES THAT THE TRUSTEE, OFFICER OR KEY EMPLOYEE HAS IN FACT KNOWINGLY FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT OF INTEREST, IT SHALL TAKE APPROPRIATE DISCIPLINARY ACTION WHICH MAY INCLUDE A RECOMMENDATION TO THE ENTIRE BOARD FOR THE REMOVAL OF THE TRUSTEE OR OFFICER FOR THE DISCHARGE OF THE KEY EMPLOYEE IN ACCORDANCE WITH THE BYLAWS AND POLICIES AND PROCEDURES OF THE COLLEGE AND THE LAWS OF THE STATE OF NEW YORK. FORM 990, PART VI, SECTION B, LINE 15 PROCESS FOR DETERMINING COMPENSATION THE COLLEGE ENGAGED AN INDEPENDENT CONSULTANT IN FEBRUARY 2024 TO REVIEW AND COMPARE THE COMPENSATION OF TOP MANAGEMENT TO SIMILAR INSTITUTIONS IN A COMPENSATION STUDY. A COMPENSATION SURVEY WAS PERFORMED REGARDING COMPENSATION OF OTHER OFFICERS. COMPENSATION DECISIONS AND REPORTS ARE CONTEMPORANEOUSLY DOCUMENTED IN THE BOARD MINUTES WHEN THE DECISIONS ARE MADE. THIS PROCESS IS PERFORMED BIANNUALLY AND WILL BE CONDUCTED AGAIN IN THE FUTURE. FORM 990, PART VI, SECTION C, LINE 19 PUBLIC DISCLOSURE OF DOCUMENTS CONFLICT OF INTEREST POLICY IS AVAILABLE ON THE COLLEGE WEBSITE AT WWW.SFC.EDU. THE AUDITED FINANCIAL STATEMENTS AND GOVERNING DOCUMENTS ARE MADE AVAILABLE UPON REQUEST AT MANAGEMENT'S DISCRETION.