2025-11-17T22:52:15-06:00 2024-12-31 331374517 PKF O'CONNOR DAVIES ADVISORY LLC 245 PARK AVENUE 12TH FLOOR NEW YORK NY 10167 990 2024-01-01 132634120 NEW YORK APARTMENT ASSOCIATION INC NEWY 2122149277 123 WILLIAM STREET 12 FL NEW YORK NY 100383804 KENNETH BURGOS CHIEF EXECUTIVE OFFICER 2122149277 2025-11-17 1 1 EVA MRUK P00543254 2122862600 2025-11-17 2024 2025-03-06 01:10:19Z X KENNETH BURGOS 123 WILLIAM STREET 12 FL NEW YORK NY 100383804 33295900 0 X WWW.HOUSINGNY.ORG X 1970 NY ADVOCATES FOR THE PROPERTY RIGHTS OF ITS MEMBERS (RENT-REGULATED PROPERTY OWNERS IN NEW YORK CITY) THROUGH LEGISLATIVE AND LEGAL ACTION, KEEPS ITS MEMBERSHIP INFORMED ON CRITICAL ISSUES THROUGH ITS NEWSLETTER, SEMINARS, WEBSITE AND OTHER OUTREACH MECHANISMS AND PROVIDES OWNERS WITH SERVICES THEY NEED, EITHER DIRECTLY OR BY REFERRAL, TO MAINTAIN AND OPERATE THEIR PROPERTIES WITHIN LEGAL REQUIREMENTS. 57 57 28 57 0 0 0 80171 5539404 7322180 2478126 4050548 51955 170296 8069485 11623195 757116 35500 0 0 3846567 4811012 0 0 0 4389674 4836613 8993357 9683125 -923872 1940070 59870343 62498867 5167155 4434797 54703188 58064070 X NYAA PROVIDES SERVICES TO LANDLORDS INCLUDING COMPUTERIZED RENT REGISTRATION OF RENT STABILIZED APARTMENTS WITH THE NEW YORK STATE DIVISION OF HOUSING AND COMMUNITY RENEWAL IN COMPLIANCE WITH NYS & NYC LAWS & REGULATIONS. 0 0 MEMBERSHIP DUES- MEMBERSHIP INCOME IS BASED ON A FEE OF $10.00 PER APARTMENT/UNIT. DUES ARE USED FOR PROVIDING INFORMATION REGARDING RENT STABILIZED APARTMENTS VIA NEWSLETTER, EMAIL & OTHER PUBLICATIONS. THE ORGANIZATION IS ACTIVE IN REPRESENTING THE INTERESTS OF OWNERS BEFORE THE STATE AND LOCAL GOVERNMENTS. NYAA SUPPLIES DATA TO THE RENT GUIDELINES BOARD IN ITS DELIBERATIONS WITH REGARD TO RENT INCREASES FOR RENT STABILIZED APARTMENTS, AND HOLDS DISCUSSIONS AND MEETINGS WITH GOVERNMENT ON TECHNICAL CHANGES AND BUILDING REGULATIONS INVOLVED WITH MEMBERS' BUILDINGS. SAFETY RELATED SERVICES-WINDOW GUARD/LEAD PAINT SERVICES: THESE SERVICES CONSISTS OF MAILINGS TO OVER 400,000 TENANTS SO THAT REAL ESTATE OWNERS AND MANAGEMENT AGENTS CAN DETERMINE IF WINDOW GUARDS NEED TO BE INSTALLED IN ACCORDANCE WITH NEW YORK CITY LAW. FIRE SAFETY SERVICE: ON AN ANNUAL BASIS, ALL OWNERS OF MULTIPLE DWELLINGS MUST COMPLY WITH THE NEW YORK CITY FIRE DEPARTMENT REGULATIONS, REQUIRING OWNERS TO PREPARE AND DISTRIBUTE A FIRE SAFETY PLAN CONTAINING FIRE SAFETY AND EVACUATION PROCEDURES.ADDITIONALLY, IT IS REQUIRED FOR OWNERS TO DISTRIBUTE AND POST A FIRE SAFETY NOTICE INFORMING RESIDENTS OF PROCEDURES TO BE FOLLOWED IN THE EVENT OF A FIRE IN THE BUILDING. NYAA FIRE SAFETY SERVICES PREPARES AND DISTRIBUTES ALL REQUIRED INFORMATION, INCLUDING:-DEVELOPMENT OF A CUSTOMIZED FIRE SAFETY PLAN FOR EACH BUILDING-MAILING FIRE SAFETY PLAN TO ALL TENANTS AND BUILDING EMPLOYEES -FURNISHING APPROPRIATE FIRE SAFETY NOTICES (LONG-LASTING SELF ADHESIVE VINYL) TO BE POSTED IN INDIVIDUAL APARTMENTS-PROVIDING PROOF OF MAILING AND MEETING FOUR YEAR RECORD REQUIREMENTS LEGAL FUND- THE LEGAL FUND CONSISTS OF VOLUNTARY CONTRIBUTIONS RESTRICTED TO MATTERS RELATED TO REGULATIONS AND LAWS ENACTED ON FEDERAL, STATE AND LOCAL LEVELS, AND TO ASSIST MEMBERS IN INITIATING AND APPEALING LITIGATION CLAIMS. SUCH REVENUE IS RECOGNIZED AT THE TIME WHEN CONTRIBUTIONS ARE MADE. RENT REGISTRATION- THIS SERVICE PROVIDES REGISTRATION OF RENT STABILIZED APARTMENTS AND RECORD/INFORMATION RETENTION AS REQUIRED BY NEW YORK STATE DIVISION OF HOUSING & COMMITTEE RENEWAL (DHCR).LEASE RENEWAL SERVICE- NYAA SENDS OUT FORMS TO LANDLORDS FOR THE RENEWAL OF THE TENANTS' LEASES, AS SCHEDULED, PRIOR TO THE LEASE EXPIRATIONS. THE LEASES PROVIDE FOR CHOICES OF ONE AND TWO YEAR RENEWALS AND THE APPROPRIATE INCREASES. 0 1 0 1 0 0 0 0 0 1 0 0 0 1 1 0 1 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 0 1 1 1 0 1 28 0 28 1 0 0 0 0 0 0 0 0 X 57 57 1 0 1 0 1 1 0 1 1 0 0 1 1 1 1 1 1 1 1 0 X MARIA AGUAS CONTROLLER 2122149277 123 WILLIAM STREET 12TH FL NEW YORK NY 10038 AARON SIRULNICK CHAIRMAN 0.10 X X 0 0 0 ZACHARY KERR VICE-CHAIR 0.10 X X 0 0 0 MICHAEL LAUB SECRETARY 0.10 X X 0 0 0 LENNARD KATZ TREASURER 0.10 X X 0 0 0 DARIN GOLDSTEIN OFFICER 0.10 X X 0 0 0 CHRISTOPHER ATHINEOS DIRECTOR 0.10 X 0 0 0 JESSICA BARAN DIRECTOR 0.10 X 0 0 0 LEWIS BARBANEL DIRECTOR 0.10 X 0 0 0 DANIEL BENEDICT DIRECTOR 0.10 X 0 0 0 MICHELLE BENGELSDORF DIRECTOR 0.10 X 0 0 0 PAUL BRENSILBER DIRECTOR 0.10 X 0 0 0 HELEN DANIELS DIRECTOR 0.10 X 0 0 0 DAVID DIAMOND DIRECTOR 0.10 X 0 0 0 SCOTT DONNER DIRECTOR 0.10 X 0 0 0 ALISTAIR ECONOMAKIS DIRECTOR 0.10 X 0 0 0 MARK ENGEL DIRECTOR 0.10 X 0 0 0 MATTHEW ENGEL DIRECTOR 0.10 X 0 0 0 JEFFREY FARKAS DIRECTOR 0.10 X 0 0 0 BARRY FISHMAN DIRECTOR 0.10 X 0 0 0 NATHAN FISHMAN DIRECTOR 0.10 X 0 0 0 MARIO GAZTAMBIDE DIRECTOR 0.10 X 0 0 0 JASON GLICK DIRECTOR 0.10 X 0 0 0 ALEXANDER GOLDSTEIN DIRECTOR 0.10 X 0 0 0 BRETT GREENBERG DIRECTOR 0.10 X 0 0 0 ANITA GUPTA DIRECTOR 0.10 X 0 0 0 ANDREW HOFFMAN DIRECTOR 0.10 X 0 0 0 JOHN ILIBASSI DIRECTOR 0.10 X 0 0 0 GARY JACOB DIRECTOR 0.10 X 0 0 0 BRUCE KAFENBAUM DIRECTOR 0.10 X 0 0 0 JEFFREY KATZ DIRECTOR 0.10 X 0 0 0 MICHAEL KERR DIRECTOR 0.10 X 0 0 0 JEFFREY MANOCHERIAN DIRECTOR 0.10 X 0 0 0 ROGER MELZER DIRECTOR 0.10 X 0 0 0 HOWARD MILSTEIN DIRECTOR 0.10 X 0 0 0 MICKEY NAPOLITANO DIRECTOR 0.10 X 0 0 0 ROBERT NELSON DIRECTOR 0.10 X 0 0 0 JONATHAN OHEBSHALOM DIRECTOR 0.10 X 0 0 0 ADAM PARKOFF DIRECTOR 0.10 X 0 0 0 DAVID PARKS DIRECTOR 0.10 X 0 0 0 OSCAR PEREZ DIRECTOR 0.10 X 0 0 0 NICHOLAS PETRAS DIRECTOR 0.10 X 0 0 0 JEFFREY PIKUS DIRECTOR 0.10 X 0 0 0 JORDAN PLATT DIRECTOR 0.10 X 0 0 0 MICHAEL ROTHSCHILD DIRECTOR 0.10 X 0 0 0 RICHARD RUBEL DIRECTOR 0.10 X 0 0 0 BARRY RUDOFSKY DIRECTOR 0.10 X 0 0 0 ROCIO SANZ DIRECTOR 0.10 X 0 0 0 FRANCINE SCHIFF DIRECTOR 0.10 X 0 0 0 WILLIAM SCHUR DIRECTOR 0.10 X 0 0 0 MATTHEW SCHMELZER DIRECTOR 0.10 X 0 0 0 JIMMY SILBER DIRECTOR 0.10 X 0 0 0 STEPHEN WALLACH DIRECTOR 0.10 X 0 0 0 ALAN WASSERMAN DIRECTOR 0.10 X 0 0 0 ARDON WIENER DIRECTOR 0.10 X 0 0 0 JOANNA WONG DIRECTOR 0.10 X 0 0 0 JOSEPH ZITOLO DIRECTOR 0.10 X 0 0 0 LAURIE ZUCKER DIRECTOR 0.10 X 0 0 0 JOSEPH STRASBURG PRESIDENT 35.00 X 707550 0 103411 FRANK RICCI EXECUTIVE VICE PRESIDENT 35.00 1.00 X 343314 0 54505 KENNETH BURGOS CHIEF EXECUTIVE OFFICER 35.00 X 254509 0 48508 OLGA SOMERAS GENERAL COUNSEL 35.00 X 290425 0 31890 MARIA AGUAS CONTROLLER 35.00 1.00 X 214930 0 34041 MELODY LEON ASST. CONTROLLER 35.00 X 176066 0 37388 MICHAEL TOBMAN MARKETING DIRECTOR 35.00 X 176330 0 40155 JASON MARTIN SVP-EXTERNAL AFFAIRS 35.00 X 214090 0 17688 KELLY FARRELL POLICY ANALYST 35.00 X 122353 0 43163 2499567 0 410749 9 0 1 0 GREEN STRETT STUDIO INC 101 EMERSON ROAD SOMERSET NJ 08873 ADVERTISING/PUBLIC RELATIONS/ADVERTISING 535000 CONTINENTAL MANAGEMENT SOLUTIONS 12240 SW 533RD STREET SUITE 51 COOPER CITY FL 33330 DATA PROCESSING 477600 IMS INC 245 COMMERCE BOULEVARD LIVERPOOL NY 13088 PRINTING AND POSTAGE SERVICES 453924 PERLMANPERLMAN LLP 521 FIFTH AVENUE 30TH FLOOR NEW YORK NY 10175 LEGAL (MERGER-RELATED COSTS) 250851 THE MIRRAM GROUP 5030 BROADWAY SUITE 801 NEW YORK NY 10034 GOVERNMENT RELATIONS SERVICES 157500 10 80171 80171 MEMBERSHIP DUES 561499 4765801 4765801 SAFETY RELATED SVCS 561499 888344 888344 RENT REGISTRATION 561499 674985 674985 LEGAL FUND 561499 657135 657135 NETWORKING/SOCIAL EVENTS 561499 220764 220764 115151 115151 7322180 1780304 1780304 23942949 21672705 2270244 2270244 2270244 EQUITY IN SUBSIDIARIES 561499 102943 102943 OTHER INCOME 561499 65507 65507 EQUITY IN BROKERAGE 561499 1846 1846 170296 11623195 7322180 0 4220844 X 35500 1834112 2256084 80204 406247 234365 6212 78175 222875 299689 1340696 283097 696741 495793 963166 85870 13188 157939 86106 DUES/PUBLICATIONS/CONT. 85338 REPAIRS & MAINTENANCE 19848 EXCISE TAX 1880 9683125 596148 871949 2856765 2429475 4070 27106 243965 174932 2766016 2448975 464232 317041 52087563 55774869 340195 407297 3277405 2496198 59870343 62498867 511422 654916 696905 717039 3958828 3062842 5167155 4434797 X 54703188 57187268 0 876802 54703188 58064070 59870343 62498867 X 1940070 2105168 -684356 X X 0 1 X 1 0 RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 4765801 290630 290630 1429740 -1139110 1244560 985064 259496 676214 619306 56908 845242 844605 637 317041 LEASE LIABILITY 3062842 3062842 X 13770975 2105168 342301 2447469 11323506 299689 299689 11623195 9725737 342301 342301 9383436 299689 299689 9683125 PART X, LINE 2: THE ASSOCIATION RECOGNIZES THE EFFECT OF INCOME TAX POSITIONS ONLY IF THOSE POSITIONS ARE MORE LIKELY THAN NOT OF BEING SUSTAINED. MANAGEMENT HAS DETERMINED THAT THE ASSOCIATION HAD NO UNCERTAIN TAX POSITIONS THAT WOULD REQUIRE RECOGNITION OR DISCLOSURE IN THE CONSOLIDATED FINANCIAL STATEMENTS. THE ASSOCIATION'S TAX RETURNS FOR ALL YEARS SINCE 2021 REMAIN OPEN TO EXAMINATION BY THE RESPECTIVE TAXING AUTHORITIES. THERE ARE CURRENTLY NO TAX EXAMINATIONS IN PROGRESS. PART XI, LINE 2D - OTHER ADJUSTMENTS: REVENUE OF SUBSIDIARIES 342,301. PART XII, LINE 2D - OTHER ADJUSTMENTS: EXPENSES OF SUBSIDIARIES 342,301. 1 BELKIN BURDEN WENIG & GOLDMAN LLP 60 EAST 42ND STREET 16TH FLOOR NEW YORK NY 10165 133500325 15000 0 GENERAL SUPPORT INNER CIRCLE PO BOX 5372 NEW YORK NY 10185 133360989 501(C)(3) 8500 0 GENERAL SUPPORT 1 1 PART I, LINE 2: GRANTS WERE APPROVED BY THE ORGANIZATION'S PRESIDENT AND DETAILED RECORDS WERE MAINTAINED DOCUMENTING THE AMOUNT OF THE GRANTS, PURPOSE OF THE GRANTS, AND USE OF THE FUNDS. X X X 0 0 0 JOSEPH STRASBURG PRESIDENT 702798 0 0 0 4752 0 45850 0 57561 0 810961 0 0 0 FRANK RICCI EXECUTIVE VICE PRESIDENT 290814 0 52500 0 0 0 13589 0 40916 0 397819 0 0 0 OLGA SOMERAS GENERAL COUNSEL 277925 0 12500 0 0 0 9913 0 21977 0 322315 0 0 0 KENNETH BURGOS CHIEF EXECUTIVE OFFICER 229509 0 25000 0 0 0 46000 0 2508 0 303017 0 0 0 MARIA AGUAS CONTROLLER 202430 0 12500 0 0 0 9077 0 24964 0 248971 0 0 0 JASON MARTIN SVP-EXTERNAL AFFAIRS 161590 0 52500 0 0 0 9610 0 8078 0 231778 0 0 0 MICHAEL TOBMAN MARKETING DIRECTOR 176330 0 0 0 0 0 5534 0 34621 0 216485 0 0 0 MELODY LEON ASST. CONTROLLER 173566 0 2500 0 0 0 9080 0 28308 0 213454 0 0 0 KELLY FARRELL POLICY ANALYST 113853 0 8500 0 0 0 5874 0 37289 0 165516 0 0 0 FORM 990, PART VI, SECTION A, LINE 2 MARK ENGEL AND MATTHEW ENGEL, DIRECTORS OF THE ORGANIZATION, HAVE A FAMILY RELATIONSHIP. BARRY FISHMAN AND NATHAN FISHMAN, DIRECTORS OF THE ORGANIZATION, HAVE A FAMILY RELATIONSHIP. FORM 990, PART VI, SECTION A, LINE 4 IN 2024, THE ORGANIZATION (FORMERLY RENT STABILIZATION ASSOCIATION OF N.Y.C., INC.) COMPLETED A MERGER WITH THE COMMUNITY HOUSING IMPROVEMENT PROGRAM, INC. THE GOVERNING DOCUMENTS WERE AMENDED AND RESTATED IN FULL AND THE ORGANIZATION WAS RENAMED NEW YORK APARTMENT ASSOCIATION, INC. SIGNIFICANT CHANGES INCLUDED (1) CONSOLIDATION OF MEMBERSHIP CLASSES INTO VOTING AND NON-VOTING CATEGORIES, (2) EXPANSION OF THE BOARD OF DIRECTORS TO INCLUDE REPRESENTATIVES FROM BOTH LEGACY ORGANIZATIONS, (3) CREATION OF NEW ADVISORY COMMITTEES FOR SMALL OWNERS AND HONORARY DIRECTORS, AND (4) REVISED OFFICER AND EXECUTIVE LEADERSHIP STRUCTURE. THESE CHANGES WERE APPROVED IN CONNECTION WITH THE MERGER EFFECTIVE APRIL 25, 2024. FORM 990, PART VI, SECTION A, LINE 6 NYAA IS A MEMBERSHIP ORGANIZATION OF OWNERS AND AGENTS OF RENT REGULATED BUILDINGS IN NEW YORK CITY. MEMBERSHIP CONSISTS OF ABOUT 7,820 ACTIVE AND 23,241 INACTIVE MEMBERS REPRESENTING APPROXIMATELY 20,473 (ACTIVE) AND 22,970 (INACTIVE) BUILDINGS. FORM 990, PART VI, SECTION A, LINE 7A NYAA MEMBERS HAVE THE POWER TO ELECT MEMBERS OF THE GOVERNING BOARD. FORM 990, PART VI, SECTION B, LINE 11B THE FORM 990 IS REVIEWED BY THE CONTROLLER, THEN FORWARDED WITH NOTES TO THE EXECUTIVE COMMITTEE (CHAIRMAN OF THE BOARD, TREASURER, AND PRESIDENT) FOR REVIEW AND APPROVAL. FORM 990, PART VI, SECTION B, LINE 12C BOARD MEMBERS AND OFFICERS ARE REQUIRED TO DISCLOSE ANY ACTUAL OR POSSIBLE CONFLICT OF INTEREST WITH THE GOVERNING BOARD ANNUALLY. AFTER DISCLOSURE, THE INDIVIDUAL IN QUESTION MUST RECUSE THEMSELVES FROM VOTING ON THE MATTER. SUCH MATTERS INVOLVING THE EXISTENCE OF CONFLICTS OF INTEREST ARE TO BE DOCUMENTED IN THE MINUTES OF THE GOVERNING BOARD. FORM 990, PART VI, SECTION B, LINE 15 CHIEF EXECUTIVE OFFICER - THE EXECUTIVE COMMITTEE REVIEWS THE PERFORMANCE OF THE CHIEF EXECUTIVE OFFICER. AS PART OF THIS PROCESS, COMPARATIVE COMPENSATION DATA FOR THE SAME POSITION AT SIMILAR NONPROFIT ORGANIZATIONS IS ANALYZED USING THE MOST RECENT FORM 990 FILINGS AVAILABLE. BASED ON THIS ANALYSIS AND THE COMMITTEE'S REVIEW, A RECOMMENDATION IS MADE AND PRESENTED TO THE EXECUTIVE COMMITTEE FOR CONSIDERATION. THE FINAL DECISION IS APPROVED AND SIGNED BY THE CHAIRMAN OF THE BOARD AND THEN FORWARDED TO HUMAN RESOURCES FOR IMPLEMENTATION. OTHER OFFICERS - EXECUTIVE VICE PRESIDENT / SENIOR VICE PRESIDENT - THE CHIEF EXECUTIVE OFFICER REVIEWS THE PERFORMANCE OF THE EXECUTIVE VICE PRESIDENT AND SENIOR VICE PRESIDENT. FOLLOWING THE REVIEW, THE CHIEF EXECUTIVE OFFICER SUBMITS RECOMMENDATIONS TO THE EXECUTIVE COMMITTEE FOR APPROVAL. FINAL COMPENSATION DECISIONS ARE AUTHORIZED BY THE CHAIRMAN OF THE BOARD AND FORWARDED TO HUMAN RESOURCES FOR IMPLEMENTATION. EMPLOYEES - SUPERVISORS CONDUCT ANNUAL PERFORMANCE APPRAISALS FOR ALL EMPLOYEES. THE RESULTS ARE DISCUSSED WITH EACH EMPLOYEE AND FORM THE BASIS FOR COMPENSATION RECOMMENDATIONS. ALL RECOMMENDATIONS AND PERFORMANCE APPRAISALS ARE FORWARDED TO THE CHIEF EXECUTIVE OFFICER, WHO REVIEWS AND PRESENTS PROPOSED RATE CHANGES TO THE EXECUTIVE COMMITTEE. THE CHIEF EXECUTIVE OFFICER APPROVES THE FINAL RATE CHANGES, AND THE APPROVED LIST IS SUBMITTED TO HUMAN RESOURCES FOR IMPLEMENTATION. ALL PERFORMANCE APPRAISALS AND SUPPORTING DOCUMENTATION ARE RETAINED IN EACH EMPLOYEE'S HUMAN RESOURCES FILE. THE COMPENSATION REVIEW PROCESS WAS LAST CONDUCTED IN 2024. FORM 990, PART VI, SECTION C, LINE 19 GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS ARE AVAILABLE TO THE PUBLIC UPON REQUEST. THE FORM 990 IS AVAILABLE UPON REQUEST AND ON WWW.GUIDESTAR.ORG. FORM 990, PART IX, LINE 11G CONSULTANT FEES 1,340,696. FORM 990, PART XI, LINE 9: NET LIABILITIES ASSUMED IN MERGER -684,356. FORM 990, PART XII, LINE 2C: THE ORGANIZATION HAS A COMMITTEE THAT ASSUMES RESPONSIBILITY FOR OVERSIGHT OF THE AUDIT OF ITS FINANCIAL STATEMENTS AND SELECTION OF AN INDEPENDENT ACCOUNTANT. THE PROCESS HAS NOT CHANGED FROM THE PRIOR YEAR. NYAA PAC 123 WILLIAM STREET 12TH FLOOR NEW YORK NY 10038 133647934 POLITICAL ORG NY 527 NEW YORK APARTMENT ASSOCIATION 1 REALTY SYSTEMS OF AMERICA INC 123 WILLIAM STREET 12TH FLOOR NEW YORK NY 10038 133318934 SUPPORT SERVICES NY NEW YORK APARTMENT ASSOCIATION C 56521 10098 1.00000 1 NYAA INSURANCE BROKERAGE INC 123 WILLIAM STREET 12TH FLOOR NEW YORK NY 10038 900090165 INSURANCE NY NEW YORK APARTMENT ASSOCIATION C 388723 567879 1.00000 1 1 0 0 1 0 0 0 0 0 1 0 0 0 1 1 0 1 0 0 REALTY SYSTEMS OF AMERICA INC Q 59000 BOOK VALUE NYAA INSURANCE AGENCY INC O 69453 BOOK VALUE NYAA INSURANCE AGENCY INC Q 85000 BOOK VALUE NYAA INSURANCE AGENCY INC A 2062 BOOK VALUE PART V, LINE 1A NYAA RECEIVED INTEREST INCOME, A SPECIFIED PAYMENT, FROM ITS CONTROLLED TAXABLE SUBSIDIARY. THIS PAYMENT WAS MADE AT ARM'S LENGTH AND MEETS THE FAIR MARKET VALUE STANDARD.