2026-08-09T14:20:15-07:00 2025-12-31 412407768 BrightPeak Analytics LLC 801 Wayne Ave Ste 203 Silver Spring MD 20910 990 2025-01-01 530230056 BRIGGS CENTER FOR FAITH AND ACTION BRIG 2406001907 5148 MASSACHUSETTS AVENUE BETHESDA MD 20816 Rev Dr Timothy B Tutt Executive Director 2406001907 2026-05-01 true Mikiyas Tamru P01899607 3017681342 2025 2025-03-06 01:10:19Z Rev Dr Timothy B Tutt 5148 MASSACHUSETTS AVENUE BETHESDA MD 20816 374410 false X WWW.BRIGGSCENTER.ORG X 1952 MD THE BRIGGS CENTER FOR FAITH & ACTION WELCOMES, SUPPORTS, PROVIDES SERVICES FOR, AND ADVOCATES ON BEHALF OF IMMIGRANTS AND REFUGEES IN THE WASHINGTON, D.C. METRO AREA. 3 3 4 50 0 0 152551 49900 0 41097 45411 0 193648 95311 0 0 188498 185051 14427 12000 20764 143234 141434 346159 338485 -152511 -243174 915174 675903 13290 15922 901884 659981 THE BRIGGS CENTER FOR FAITH & ACTION WELCOMES, SUPPORTS, PROVIDES SERVICES FOR, AND ADVOCATES ON BEHALF OF IMMIGRANTS AND REFUGEES IN THE WASHINGTON, D.C. METRO AREA. false false 231428 0 0 THE BRIGGS CENTER FOR FAITH & ACTION CONDUCTS THREE VIBRANT PROGRAMS OF MINISTRY AND SERVICE-A LOW-COST OR NO-COST LEGAL IMMIGRATION CLINIC, FREE ESOL CLASSES, AND HOSPITALITY PROGRAM. THE BRIGGS CENTER ADVOCATES FOR JUSTICE FOR IMMIGRANTS, REFUGEES, AND ASYLUM-SEEKERS. THE CENTER PARTNERS WITH THE INDIVIDUALS IT SERVES TO BUILD SPACES OF TRUST AND DIGNITY. AND THE CENTER OFFERS MEANINGFUL WAYS FOR VOLUNTEERS TO MAKE A DIFFERENCE. IN 2025, THE CENTER PROVIDED FREE ESOL CLASSES TO OVER 100 ADULT LEARNERS. APPROXIMATELY 20 VOLUNTEERS LEAD 20 CLASSES EACH WEEK. THE COST TO THE CENTER FOR THIS PROGRAM FOR 2025 WAS $42,923.64, WHICH INCLUDED THE SALARY OF THE ESOL PROGRAM DIRECTOR, PERSONNEL, BOOKS, AND SUPPLIES. IN 2025, THE CENTER PROVIDED LEGAL ADVICE AND ASSISTANCE TO OVER 200 PERSONS. THE DIRECTOR OF THE PROGRAM AND A NETWORK OF TEN VOLUNTEERS PROVIDED THIS SUPPORT. THE COST TO THE CENTER FOR THIS PROGRAM FOR 2025 WAS $107,862.47, WHICH INCLUDED THE SALARY OF THE IMMIGRATION PROGRAM DIRECTOR, HEALTH INSURANCE BENEFITS, TRAINING, SUPPLIES, AND SOFTWARE. 231428 true true false false false false false false false false true true false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false true 0 0 4 true false false false false false false false false false false false false X 3 3 false false false false false false false true true false false true true true true false false true false false VA X Samantha Steinfeld 2403389706 5148 MASSACHUSETTS AVENUE BETHESDA MD 20816 ROBERT SHUE PRESIDENT/CHAIR 1.00 X X 0 0 0 ROBERT BENTON VICE PRESIDENT/SECRETARY 1.00 X X 0 0 0 TIMOTHY TUTT EXECUTIVE DIRECTOR 40.00 X 36000 0 0 FEREW HAILE DIRECTOR OF IMMIGRATION SERVICES 40.00 X 79011 0 0 GLORIA BETTS MEMBER OF TRUSTEES 1.00 X 0 0 0 115011 0 0 false false false 49900 49900 8770 0 8770 315740 279099 36641 36641 0 0 36641 95311 0 0 45411 131538 74245 52389 4904 41540 37735 544 3261 11973 8859 2515 599 7809 0 7809 0 12000 12000 4819 0 4819 0 25340 19733 5607 0 24579 20475 4104 0 11207 9336 1871 0 18247 15200 3047 0 3681 3066 615 0 1758 1464 294 0 16046 13367 2679 0 DIRECT SERVICES 27948 27948 0 0 338485 231428 86293 20764 205 0 10408 17402 3123 743094 315406 443733 427688 460828 227690 915174 675903 13290 15922 13290 15922 X 901884 659981 901884 659981 915174 675903 -243174 1271 X false false false X 0 62065 152965 159570 152551 49900 577051 0 0 62065 152965 159570 152551 49900 577051 0 577051 29526 20974 24237 14214 8770 97721 0 0 674772 0.85520 0.82820 X 0 0 0 Pt II Ln 17a PART II, SECTION C, LINE 17A, FACTS AND CIRCUMSTANCES TEST: Pt II Ln 17a THE BRIGGS CENTER FOR FAITH & ACTION IS A NON-PROFIT ORGANIZATION FOUNDED IN 2007, ORGANIZED BY THE FORMER MEMBERS OF BRIGGS MEMORIAL BAPTIST CHURCH, WHICH WAS FOUNDED IN WASHINGTON DC IN 1952. THE CENTER WELCOMES, SUPPORTS, PROVIDES SERVICES FOR, AND ADVOCATES ON BEHALF OF IMMIGRANTS AND REFUGEES IN THE WASHINGTON, D.C. METRO AREA. THROUGH A LEGAL IMMIGRATION CLINIC, FREE ESOL CLASSES, AND HOSPITALITY PROGRAM, THE BRIGGS CENTER PARTNERS WITH THE INDIVIDUALS WE SERVE TO BUILD SPACES OF TRUST AND DIGNITY AND ADVOCATES FOR JUSTICE. THE CENTER OFFERS MEANINGFUL WAYS FOR VOLUNTEERS TO MAKE A DIFFERENCE. Pt II Ln 17a THE CENTER QUALIFIES AS A PUBLICLY SUPPORTED ORGANIZATION DESCRIBED UNDER SECTION 170(B)(1)(A)(VI) AND THEREFORE AS AN ORGANIZATION DESCRIBED IN SECTION 509(A)(1) BECAUSE IT SATISFIES THE FACTS AND CIRCUMSTANCES TEST SET FORTH IN SECTION 1.170A-9(E)(3) OF THE TREASURY REGULATIONS. Pt II Ln 17a THE CENTER IS ELIGIBLE FOR A DETERMINATION OF PUBLIC SUPPORT UNDER THE FACTS AND CIRCUMSTANCES TEST BECAUSE IT MEETS THE TWO THRESHOLD REQUIREMENTS FOR CONSIDERATION. FIRST, THE PORTION OF THE CENTERS SUPPORT THAT QUALIFIES AS ELIGIBLE PUBLIC SUPPORT IS 85.52%, WHICH EXCEEDS THE 10% THRESHOLD REQUIRED UNDER TREASURY REGULATION SECTION 1.170A-9(E)(3)(I). SECOND, THE CENTERS OPERATIONS ENSURE THAT IT WILL CONTINUE TO ATTRACT NEW AND ADDITIONAL PUBLIC SUPPORT, AS REQUIRED BY TREASURY REGULATION SECTION 1.170A-9(E)(3)(II). THE CENTER HAS AN ACTIVE FUNDRAISING PROGRAM TARGETING GOVERNMENT AGENCIES, INDIVIDUALS, PRIVATE FOUNDATIONS, AND FOR-PROFIT CORPORATIONS THAT SHARE ITS MISSION, THEREBY SATISFYING THE OTHER THRESHOLD REQUIREMENT FOR QUALIFYING AS PUBLICLY SUPPORTED UNDER THE FACTS AND CIRCUMSTANCES TEST. Pt II Ln 17a IN DETERMINING WHETHER THE CENTER MEETS THE FACTS AND CIRCUMSTANCES TEST, THE TREASURY REGULATIONS ALSO PROVIDE A LIST OF FACTORS THAT SERVE AS INDICIA OF WHETHER AN ORGANIZATION QUALIFIES AS PUBLICLY SUPPORTED. THE HIGHER THE PERCENTAGE OF SUPPORT ABOVE THE 10% REQUIREMENT, THE LOWER THE CENTERS BURDEN IN ESTABLISHING ITS PUBLICLY SUPPORTED NATURE WITH OTHER FACTORS. THESE ADDITIONAL FACTORS, DISCUSSED BELOW, PROVIDE FURTHER EVIDENCE THAT THE CENTER SATISFIES THE FACTS AND CIRCUMSTANCES TEST. BECAUSE THE CENTERS PERCENTAGE OF SUPPORT IS 85.52%, THE CENTER HAS A LESSER BURDEN IN PROVING ITS PUBLICLY SUPPORTED NATURE THROUGH THESE FACTORS. Pt II Ln 17a THE CENTER HAS RECEIVED ITS PUBLIC SUPPORT FROM A WIDE VARIETY OF CONTRIBUTORS IN THE PAST FEW YEARS AND DOES NOT DEPEND ON A SINGLE FAMILY FOR CONTRIBUTIONS, TWO FACTS THAT PROVIDE FURTHER SUPPORT FOR THE CENTERS QUALIFICATION AS A PUBLICLY SUPPORTED ENTITY. THESE DONORS INCLUDE TAX-EXEMPT ENTITIES, A FOR-PROFIT CORPORATION, AND INDIVIDUALS. THE CENTER PLANS TO CONTINUE REACHING OUT TO NEW DONORS IN THE COMING YEARS. Pt II Ln 17a THE CENTER ENJOYS BROAD SUPPORT FROM THE LOCAL COMMUNITY AS EVIDENCED BY THE MORE THAN 50 LOCAL VOLUNTEERS THAT PARTICIPATE IN OR LEAD ITS FREE ENGLISH AS A SECOND LANGUAGE CLASSES (PROVIDED MULTIPLE TIMES PER WEEK DURING THE YEAR, APPROXIMATELY 150 VOLUNTEER HOURS EACH WEEK). THE CENTERS HEADQUARTERS BUILDING, THE CARPENTERS HOUSE OFFERS A VARIETY OF SERVICES EACH MONTH WITH AS MANY AS TEN VOLUNTEERS GIVING 150 HOURS EACH MONTH. Pt II Ln 17a THE REPRESENTATIVE NATURE OF AN ORGANIZATIONS GOVERNING BODY IS ALSO A FACTOR IN DETERMINING WHETHER IT QUALIFIES UNDER THE FACTS AND CIRCUMSTANCES TEST. IN CONSIDERING WHETHER A BOARD IS REPRESENTATIVE, SUCH FACTORS AS THE MEMBERS EXPERTISE IN THE RELEVANT FIELD, THEIR HISTORY OF LEADERSHIP IN THE COMMUNITY AND THEIR TRADITION OF PUBLIC SERVICE ARE RELEVANT. THE CENTERS BOARD OF DIRECTORS INCLUDES A VARIETY OF INDIVIDUALS WITH EXCEPTIONAL BACKGROUNDS AND VERY MUCH INVOLVED WITH PROVIDING ASSISTANCE TO THE COMMUNITY. THE FOLLOWING INDIVIDUALS CURRENTLY SERVE ON THE CENTERS BOARD OF DIRECTORS: Pt II Ln 17a PRESIDENT/CHAIR: ROBERT SHUE - MR. SHUE IS A SUCCESSFUL LOCAL BUSINESSMAN AND PROVIDES FINANCIAL MANAGEMENT AND ORGANIZATIONAL ADVICE TO THE CENTER. HE WORKS WITH THE FELLOWSHIP OF CHRISTIAN ATHLETES, WESTMORELAND CONGREGATIONAL UNITED CHURCH OF CHRIST, AND WASHINGTON JESUIT ACADEMY (A NONPROFIT BOYS SCHOOL IN DC). MR. SHUE IS ALSO A MEMBER OF THE PARENTS COUNCIL AT WAKE FOREST UNIVERSITY. Pt II Ln 17a VICE PRESIDENT/SECRETARY: ROBERT BENTON - MR. BENTON IS A SUCCESSFUL CORPORATE AND NON-PROFIT ATTORNEY WHO HAS SERVED IN MANY FAITH-BASED LEADERSHIP POSITIONS AND CHARITABLE ACTIVITIES FOR MANY YEARS INCLUDING, CHAIR OF THE BOARD OF DEACONS AT BRIGGS MEMORIAL BAPTIST CHURCH AND WESTMORELAND CONGREGATIONAL UCC (OVERSEEING LAY CARE OF CHURCH MEMBERS AND FRIENDS AS WELL AS SPIRITUAL ENRICHMENT PROGRAMS), CO-CHAIR OF THE PASTORAL SEARCH COMMITTEE AND WORSHIP INITIATIVE AND MEMBER OF THE EXECUTIVE COMMITTEE FOR WESTMORELAND CONGREGATIONAL UCC, CHAIR OF GENEROUS ASSOCIATES CAMPAIGN RAISING FUNDS FOR DC LEGAL AID, PROVIDING BENEFIT CONCERTS FOR THE LITTLE FALLS WATERSHED ALLIANCE, PROVIDING HOURS OF PRO BONO LEGAL ADVICE (AND PAID LEGAL ADVICE) TO PUBLIC CHARITIES AND OTHER NON-PROFITS. Pt II Ln 17a EXECUTIVE DIRECTOR: REV. TIM TUTT IS A PART-TIME EXECUTIVE DIRECTOR OF THE BRIGGS CENTER. HE HAS A DEEP CONNECTION TO THE BRIGGS CENTER, HAVING JOINED THE BRIGGS CHURCH IN 1992 AND SERVED AS ITS ASSOCIATE MINISTER FROM 1996-2001 WHILE ATTENDING WESLEY SEMINARY. HE WAS INSTRUMENTAL IN THE EARLY DAYS OF THE ESL PROGRAM AND NOW BRINGS NEW ENERGY AND IDEAS TO A NEW DECADE AND NEW ERA AT THE BRIGGS CENTER. Pt II Ln 17a MEMBER OF BOARD OF TRUSTEES: DR. GLORIA BETTS JOINED THE BRIGG CHURCH IN 1992. SHE SERVES ON THE SOCIAL ACTION TEAM AT WESTMORELAND CONGREGATIONAL UNITED CHURCH OF CHRIST. FROM SIERRA LEON AND THE UK SHE CAME TO THE US TO WORK. SHE SUBSEQUENTLY EARNED AN MBA AT GEORGE WASHINGTON UNIVERSITY AND HAS RECENTLY COMPLETED A PH.D. IN PUBLIC POLICY FROM WALDEN UNIVERSITY WRITING HER DISSERTATION ON COMMUNITY COLLEGES IN SIERRA LEONE. SHE WORKS IN ADMINISTRATION AT THE UNIVERSITY OF THE DISTRICT OF COLUMBIA AND ALSO TEACHES ECONOMICS AT THE SCHOOL. DR. BETTS IS ONE OF THE ORIGINAL ESL TEACHERS AT BRIGGS CHURCH. SHE BECAME A MEMBER OF THE BRIGGS BOARD OF TRUSTEES IN 2019. Pt II Ln 17a DIRECTOR OF IMMIGRATION SERVICES: FEREW M. HAILE - MR. HAILE IS A HUMAN RIGHTS LAWYER WITH A BACKGROUND IN NON-PROFIT MANAGEMENT AND ADVOCACY. HE COMPLETED HIS MASTERS DEGREE FROM AMERICAN UNIVERSITY WASHINGTON COLLEGE OF LAW IN 2018. MR. HAILE OVERSEES THE DAY-TO-DAY ACTIVITIES OF THE CENTER AND PROVIDES ASSISTANCE TO THE EXECUTIVE DIRECTOR. BRIGGS EXPANDED ITS MINISTRIES AND APPLIED FOR ACCREDITATION AND RECOGNITION WITH THE DEPARTMENT OF JUSTICE TO CREATE AN IMMIGRATION CLINIC. IT RECEIVED AUTHORIZATION IN JULY 2019. THE CLINIC PROVIDES IMMIGRATION SERVICES TO INDIGENT MEMBERS OF THE COMMUNITY WITH VARIOUS IMMIGRATION RELATED BENEFITS FROM THE U.S. GOVERNMENT. CURRENTLY, MR. HAILE LEADS THE LEGAL SERVICES PROGRAM. Pt II Ln 17a UNDER SECTION 1.170A-9(E)(3)(VI)(C)(1) OF THE TREASURY REGULATIONS, ONE FACTOR INDICATING THAT AN ORGANIZATION QUALIFIES AS PUBLICLY SUPPORTED UNDER THE FACTS AND CIRCUMSTANCES TEST IS THAT MEMBERS OF THE PUBLIC HAVING SPECIALIZED KNOWLEDGE OR EXPERTISE, PUBLIC OFFICIALS, OR CIVIC OR COMMUNITY LEADERS PARTICIPATE IN, OR SPONSOR, THE ORGANIZATIONS PROGRAMS. AS DISCUSSED ABOVE, ALL OF THE CENTERS BOARD MEMBERS ARE VERY MUCH INVOLVED IN THE COMMUNITY AND ALL HAVE EXPERTISE IN RELIGION, FAITH AND NON-PROFIT CHARITABLE SUPPORT ACTIVITIES. Pt II Ln 17a FURTHER, THE CENTER SPONSORS MULTIPLE PROGRAMS INVOLVING VOLUNTEERS WITH SPECIALIZED KNOWLEDGE AND EXPERTISE. TEN TEACHERS, MANY WITH DEGREES IN VARIOUS FIELDS OF HIGH SCHOOL AND COLLEGE EDUCATION, TEACH IN THE CENTERS ENGLISH AS SECOND LANGUAGE PROGRAM. Pt II Ln 17a IN SUMMARY, THE CENTER HAS THE CHARACTERISTICS OF A PUBLICLY SUPPORTED ORGANIZATION, BASED ON THE FACTS AND CIRCUMSTANCES TEST DESCRIBED IN SECTION 1.170A-9(E)(3) OF THE TREASURY REGULATIONS. SPECIFICALLY, A SMALL NUMBER OF DONORS DO NOT CONTROL THE CENTER; RATHER THE CENTER IS A GROWING INSTITUTION THAT BEARS MANY OF THE INDICIA OF A PUBLICLY SUPPORTED ORGANIZATION, INCLUDING PUBLIC SUPPORT FROM A WIDE CROSS-SECTION OF DONORS AND VOLUNTEERS, WITH A REPRESENTATIVE GOVERNING BODY. MOREOVER, THE CENTER IS CONTINUING TO SEEK NEW SOURCES OF SUPPORT FROM THE GENERAL PUBLIC AS WELL AS OTHER ORGANIZATIONS. ACCORDINGLY, THE CENTER QUALIFIES AS A PUBLICLY SUPPORTED ORGANIZATION DESCRIBED IN SECTION 170(B)(1)(A)(VI). RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 153700 153700 585000 311012 273988 4394 4394 0 427688 PUBLICLY TRADED SECURITIES 227690 F 227690 Other FORM 990, PART III, LINE 4A, PROGRAM SERVICE ACCOMPLISHMENTS: Other THIS DOES NOT INCLUDE COSTS FOR THE CENTERS EXCECUTIVE DIRECTOR AND STAFF ASSISTANT WHO INVEST MANY HOURS IN THE PROGRAM IN THE COURSE OF THE YEAR. NOT DOES IT INCLUDE COSTS FOR THR USE OF THE CENTERS CARPENETRS HOUSE, THE LOCATION OF ONGOING ACTIVITIES OF THE CENTER AND OFFICE SPACE FOR THE STAFF. THE MARGE AND FRANK HARVEY IMMIGRATION SERVICES CLINIC: THE MARGE AND FRANK HARVEY IMMIGRATION SERVICES CLINIC LAUNCHED AS A NATURAL OUTGROWTH OF THE MINISTRY OF THE BRIGGS CENTER FOR FAITH AND ACTION (BCFA). TWENTY-ONE YEARS AGO THE (THEN) BRIGGS CHURCH STARTED A SUNDAY MORNING ENGLISH AS SECOND LANGUAGE (ESL) PROGRAM. OVER THE YEARS SEVERAL THOUSAND PEOPLE FROM AROUND THE WORLD HAVE TAKEN. THE HARVEY CLINIC EMERGES OUT OF THAT PRESCIENT PARTNERSHIP WITH THE GOOD SHEPHERD CHURCH AND A TUTORING RELATIONSHIP WITH PUBLIC DEFENDER MARGOT COWAN OF TUCSON. FROM THESE AND OTHER CONNECTIONS THE HARVEY CLINIC PARTNERS WITH CATHOLIC CHARITIES AND A NATIONWIDE NETWORK OF SIMILAR AGENCIES ASSISTING IMMIGRANTS DEAL WITH THE REQUIREMENTS OF THE US GOVERNMENT. FEREW HAILE SERVES AS THE DOJ POINT OF CONTACT FOR THE HARVEY CLINIC. MR. HAILE, HIMSELF AN EX-PATRIATE FROM ETHIOPIA, IN ADDITION TO HIS EXTENSIVE LEGAL TRAINING, HAS RECEIVED CERTIFICATION BY THE US DEPARTMENT OF JUSTICE TO LEAD THE WORK OF THE CLINIC. THE HARVEY CLINIC HELPS COMMUNITY MEMBERS NAVIGATE THE CONFUSING AND INTIMIDATING IMMIGRATION PROCESS BY: PROVIDING INITIAL CONSULTATION TO DETERMINE ELIGIBILITY FOR IMMIGRATION BENEFITS ASSISTING ELIGIBLE LAWFUL PERMANENT RESIDENTS IN APPLYING FOR U.S. CITIZENSHIP, RENEWAL OF EMPLOYMENT AUTHORIZATION DOCUMENTS, OBTAINING AND MAINTAINING TEMPORARY PROTECTED STATUS (TPS)HELPING FAMILIES REUNITE THROUGH ASSISTANCE WITH FAMILY VISA PETITIONS, ADJUSTMENT OF STATUS AS WELL AS CONSULAR PROCESSING, OBTAINING LEGAL RELIEF FOR VICTIMS OF CRIMINAL ACTS UNDER THE U VISA PROGRAM. HOLDING INDIVIDUAL CONSULTATIONS, EDUCATIONAL WORKSHOPS AND IMMIGRATION CLINICS TO PROVIDE INFORMATION ON LEGALIZATION UNDER EXISTING LAWS AND PROPOSED MEASURES FOR REFORM. DURING 2025, IT PROVIDED THESE SERVICES FREE OF CHARGE FOR MORE THAN 165 INDIVIDUALS AND PROVIDED REFERRALS OF COMPLEX IMMIGRATION CASES TO PRO BONO AND LOW-COST ATTORNEYS. THE HARVEY CLINIC IS AN EXTENSION OF BCFAS ADVOCACY AND COMMUNITY EMPOWERMENT MADE POSSIBLE THROUGH INDIVIDUALS WHO CARE DEEPLY FOR SOCIAL JUSTICE AND HUMAN RIGHTS. THE HARVEY CLINIC TAKES TO HEART THE NATIONS HISTORY OF WELCOMING AND EQUIPPING PEOPLE FROM AROUND THE GLOBE WHO IMMIGRATE TO THE UNITED STATES. THE LONG-TERM BENEFIT OF THESE SISTERS AND BROTHERS FOR THE TOTAL LIFE OF THE NATION CANNOT BE OVERSTATED. AN INVESTMENT IN THE HARVEY CLINIC IS TRULY AN INVESTMENT IN THE FUTURE OF THE UNITED STATES OF AMERICA. THE CLINIC MISSION ECHOES A CHRISTIAN SCRIPTURE THAT SINGS WHOSOEVER WILL COME AND BE MADE WELCOME! Pt VI, Line 11b FORM 990, PART VI, SECTION B, LINE 11B: Pt VI, Line 11b AFTER THE FEDERAL FORM 990 IS PREPARED BY AN INDEPENDENT ACCOUNTANT, THE DRAFT VERSION OF THE FEDERAL FORM 990 IS REVIEWED BY THE ENTIRE BOARD OF DIRECTORS BEFORE BEING FILED WITH THE INTERNAL REVENUE SERVICE. Pt VI, Line 12c FORM 990, PART VI, SECTION B, LINE 12C: Pt VI, Line 12c REQUIRED TO DISCLOSE CONFLICTS ANNUALLY AND THE POLICY IS MONITORED BY HAVING EACH TRUSTEE AND OFFICER REAFFIRM THEIR UNDERSTANDING OF THE CONFLICT OF INTEREST POLICY (AND COMPLIANCE WITH IT) ON AN ANNUAL BASIS. IF THE GOVERNING BOARD OR COMMITTEE HAS REASONABLE CAUSE TO BELIEVE THAT A MEMBER HAS FAILED TO DISCLOSE ACTUAL OR POSSIBLE CONFLICTS OF INTEREST, IT SHALL INFORM THE MEMBER THE BASIS FOR SUCH BELIEF AND AFFORD THE MEMBER AN OPPORTUNITY TO EXPLAIN THE ALLEGED FAILURE TO DISCLOSE. IF, AFTER HEARING THE MEMBERS RESPONSE AND AFTER MAKING FURTHER INVESTIGATION AS WARRANTED BY THE CIRCUMSTANCES, THE GOVERNINING BOARD OR COMMITTEE DETERMINES THE MEMBER HAS FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT OF INTEREST, IT SHALL TAKE APPROPRIATE DISCIPLINARY AND CORRECTIVE ACTION. Pt VI, Line 15a FORM 990, PART VI, SECTION B, LINE 15A: Pt VI, Line 15a IN ORDER TO DETERMINE THE EXECUTIVE DIRECTORS COMPENSAION, NON-INTERESTED MEMBERS OF THE BOARD OF DIRECTORS USE A PROCESS THAT INCLUDES REVIEWING COMPARABLE DATA INFORMED BY MARKET RESEARCH AND OUTSIDE COUNSEL. Pt VI, Line 19 FORM 990, PART VI, SECTION C, LINE 19: Pt VI, Line 19 THE CENTER MAKES ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC UPON REQUEST.