Certified Development Company Annual Report Guide

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OMB Approval No.: 3245-0075Expiration Date: 10/31/2023CERTIFIED DEVELOPMENT COMPANY (CDC)ANNUAL REPORT GUIDECDCs are required to submit an Annual Report on their operations to SBA. (13 CFR, §§ 120.826and 120.830). All reports are to be prepared in accordance with these regulations, SOP 50 10,and the instructions set forth in this guide. This report is required to ensure that the CDC is incompliance with SBA’s Loan Program Requirements.CDCs may include, along with the Annual Report, a request for renewal of their AccreditedLender Program (ALP) or Premier Certified Lender Program (PCLP) status (if applicable). If theCDC chooses to include a renewal request in its Annual Report, the CDC must clearly indicate inits Annual Report that a renewal request is included. Any status renewal request submitted alongwith a CDC’s Annual Report must meet SBA’s Loan Program Requirements for the statusrequest. CDCs are reminded to refer to ALP/PCLP guidance in SOP 50 10 when preparing theirrenewal requests. Office of Credit Risk Management (OCRM) staff, when reviewing either theAnnual Report or the status renewal request, may ask for updated information as needed tocomplete the review. Initial requests for Priority Status, ALP status, PCLP authority, a LocalEconomic Area (LEA) Expansion, or a Multi-state Expansion should not be included in theAnnual Report and must be sent separately according to the instructions set forth in SOP 50 10.Submission Requirements: CDCs are requested to submit the Annual Reports to their LeadDistrict Office electronically via email with a copy to OCRM at CDCAnnualReports@sba.gov.(CDCs submitting hard copies of their Annual Report do not need to provide a copy toCDCAnnualReports@sba.gov.) CDCs should note that the size limitation on SBA email boxes is10MB. If the electronic file is larger than 10MB, you may need to separate the electronic file intomultiple attachments.CDCs also have the option of submitting their Annual Reports through the CorporateGovernance Repository located on the Capital Access Financial System (CAFS)(https://caweb.sba.gov/cls/dsp login.cfm) under the CDC Online function. Use of the CorporateGovernance Repository will avoid email size limitations. CDCs using the Corporate GovernanceRepository to submit their Annual Reports will need to submit any ALP or PCLP renewalrequests separately.In order to ensure uniform and comparable data by all CDCs, the Annual Report has beendesigned to standardize reporting requirements. CDCs should report on every item within eachTab of the guide (items or tabs without information being reported should state “N/A”). Bothelectronic and hard-copy submissions should be organized with tabs that correspond with thetabs indicated in this guide. (The Corporate Governance Repository requires the items in eachtab to be uploaded document-by-document.) CDCs that choose to submit hard copies of theirAnnual Report must use only 8.5 by 11-inch paper and must provide their original AnnualReport, plus one copy of the report to their Lead District Office. The Lead District Office willforward one hard copy of the Annual Report to OCRM and retain the other hard copy of theReport for their records. The CDC’s Lead District Office can be found at www.SBA.gov.The Annual Report, whether submitted electronically or as a hard copy, must include all of therequired documents, signatures and attachments and comply with the instructions set forth in thisguide. CDCs may use the Corporate Governance Repository to upload some of the documents

required for the Annual Report, even if the CDC elects not to submit the entire Annual Reportusing the Corporate Governance Repository. Documents that have been uploaded to theCorporate Governance Repository do not need to be resubmitted if the CDC elects to file theAnnual Report by email or hard copy. Instead, the CDC must list in the email or hard copy of theAnnual Report all of the documents that have been uploaded to the Corporate GovernanceRepository and the date of availability.Timing: The Annual Report must be filed with the CDC’s Lead District Office within 180calendar days after the end of the CDC’s fiscal year; although CDCs are requested to submittheir Annual Reports sooner if possible. A CDC that is certified by SBA within 6 months of theCDC’s fiscal year-end is not required to submit an Annual Report for that year.Incomplete or unacceptable reports will be returned to the CDC and the CDC will beconsidered to have not fulfilled the requirement. If a CDC does not submit its AnnualReport in a timely manner, this will be reported to OCRM for potential supervisory orenforcement actions.PLEASE NOTE: The estimated burden for this collection of information is 28 hours. You are notrequired to respond to any collection of information unless it displays a currently valid OMBapproval number. Comments or questions on the burden estimate, or ways to improve the guideshould be sent to US Small Business Administration, Director, Records Management Division,409 3rd St., SW, Washington, DC 20416 and/or SBA Desk Officer, Office of Management andBudget, New Executive Office Building, Room 10202, Washington, DC 20503.ORGANIZATION OF THE ANNUAL REPORTTAB 1. Economic Development ReportCDC must report on the previous year’s investment and results, the current year’s investmentand expected results and the upcoming year’s budget estimate. CDCs should use a results-basedassessment when considering the investment and/or reinvestment year after year. The entityand/or program receiving the investment should be required to provide results-based reporting tothe CDC. All of this information together should be reviewed and approved by the CDC’s Boardof Directors.The Economic Development Report is designed to provide local economic information as well asanalytical data on the impact of the CDC’s non-504 assistance to small business. This reportmust include the following information in the order described:1. Local economic changes which impact lending. (For Multi-State CDCs, these commentsmust be provided for each state.)2. Summary of CDC activity in lending programs other than 504 (either SBA or non-SBA).3. Summary of CDC activity in non-lending programs (grants or non-lending economicdevelopment efforts).4. CDC’s economic development strategy that outlines the efforts the CDC will undertakeduring the upcoming fiscal year to serve its Area of Operations. This includes projections

for 504 loan activity and investments in other economic development. (For Multi-StateCDCs, these comments must be provided for each state.)Include evidence of CDC Board of Directors’ approval of the investment plan for the upcomingfiscal year and the basis for determining the type/amount of investment.Guidance on Reporting on non-lending investments in economic development activities:CDCs are required to report on investment in economic development per 13 CFR §120.830(a)(4). CDCs must document non-lending investments in economic developmentactivities by instituting a results-based reporting requirement from the recipient entity. For nonlending investments in economic development activities, the CDC should track and report on:1. The initial investment amount for each program;2. The amount of investment made during the fiscal year being reported;3. The expected results of the investment in the specific program(s) (at the time ofinvestment); and4. The actual results of the investment in non-lending other economic developmentactivities.TAB 2. Operating Report1. Directors/Committees (as of the end of the CDC’s fiscal year being reported)Changes from the previous CDC fiscal year must be noted with an asterisk. If a newDirector has joined the Board, the CDC must provide the date(s) that SBA Form 1081and resume(s) were submitted to SBA.Board of Directors. Organize as follows:i. Director’s name;ii. Area of each director’s expertise;iii. The director’s current occupation, business address, and business phonenumber;iv. Each director’s residence (City, State);v. If an officer of the board, state office; andvi. If the CDC is a Multi-State CDC, and the CDC added two additionalmembers to the Board who live or work in the State into which the CDCexpanded (the “additional State”), identify these members and provide theinformation listed in paragraphs a.i. through iv. above.Identification of “Close Relatives”: CDCs must identify any relationshipsbetween Directors and/or CDC employees that are defined as “close relatives” per13 CFR §120.10.

CDC Board Meetings – List the following information:i. Dates of the CDC Board meetings during the fiscal year being reported;ii. Names of the Board members present at each meeting, including identifyingwhich of the required areas of expertise the Board member represents;iii. For the present Board Members with experience in Commercial Lending, listeach member’s name, title, lending institution, and number of years ofexperience. Specify if one is the CDC manager;iv. A listing of the borrower names (to include the loan numbers, if available) ofany 504 loans approved during the meeting. In addition, for Multi-StateCDCs that add at least two additional members to the Board to represent theadditional State, the Board minutes must identify the members who voted onthe loan for any Project located in the additional State; andv. A complete collection of the minutes for each meeting during the reportingperiod. The meeting minutes must identify any recusals from voting by anyDirector due to potential or actual conflicts of interest. Note: Board minutesmay be accepted instead of a full listing of items c.i. through c.iv. aboveONLY IF the minutes are signed and provide all of the required informationlisted above.Executive CommitteeIf the CDC has an Executive Committee, provide the name and area of expertiseof each Executive Committee member.Executive Committee MeetingsIf, in addition to the Board meetings, the CDC has Executive Committeemeetings, the CDC must provide the same information listed under CDC BoardMeetings (items c.1. through c.v. above) for Executive Committee meetings,including a complete collection of the Executive Committee minutes for eachExecutive Committee meeting during the reporting period, which must identifyany recusals from voting by any Committee members due to potential or actualconflicts of interest.Loan Committee(s)i. If the CDC has a Loan Committee which is separate from the Board ofDirectors, provide the following information for each Loan Committeemember:a)Committee member’s name;b)Area of each Committee member’s expertise;c)The Committee member’s current occupation, business address, andbusiness phone number; andd)Each Committee member’s residence (City, State).ii. If Board of Directors serves as the CDC’s Loan Committee, a separate listingis not required. CDC may denote Loan Committee members clearly on the

Board listing.iii. Multi-State CDCs have the option of either:a) Establishing a separate Loan Committee in each State into which the CDCexpanded (the “additional State”); orb) Adding at least two additional members who live or work in the additionalState either to the Loan Committee in the CDC’s State of incorporation (ifestablished) or to the CDC’s Board.Accordingly, Multi-State CDCs must provide the information described inparagraphs f.i.a) through d) above for either the members of the LoanCommittee established in the additional State or the two or more additionalmembers who are added to the CDC’s Loan Committee. (If the twoadditional members are added to the CDC’s Board, see ¶ 1.a.vi. above.)Loan Committee MeetingsIf, in addition to the Board meetings, the CDC has Loan Committee meetings,CDC must provide:i. The same information listed under CDC Board Meetings (items c.i. throughc.v. above) must be supplied for Loan Committee Meetings, including, butnot limited to, a complete collection of the Loan Committee minutes for eachLoan Committee meeting during the reporting period, which must identifyany recusals from voting by any Committee members due to potential oractual conflicts of interest. In addition, for Multi-State CDCs that add atleast two additional members to the Loan Committee to represent anadditional State, the Loan Committee minutes must identify the memberswho voted on the loan for any Project located in the additional State; andii. A listing of each loan approved by the Loan Committee between 1,000,000to 2,000,000 and the date that the Board or Executive Committee ratifiedthe action of the Loan Committee.2. Professional Staff. Organize by CDC office location as follows:Organizational chart which reflects the structure of the CDC and the relationshipamongst personnel and departments;A listing of all CDC staff by name, position title, function, and years of 504 loanexperience (including, but limited to: marketing, screening, packaging, processing,closing, servicing, liquidation, management);i. If the individual fulfills more than one 504 loan program staff function,identify each function and the approximate percentage of time that the personspends on each activityFor example:Jane Doe, Loan Officer, 15 years of 504 experienceScreening, packaging, and processing (75%)Servicing (25%)

ii. If the individual is contributed by a non-profit affiliate, identify the affiliateand the approximate time the individual spends on CDC-related activitiesversus affiliate- related activitiesFor example:John Doe, CDC Manager/President of ABC Economic Development Corp.,15 years of 504 experienceABC Economic Development Corp. activities (50%)CDC-related activities (50%)iii. If applicable, any CDC office the staff person holds.3. Contracts – The CDC must provide:A list of all contracts that require SBA’s prior written approval under 13 CFR120.824 and that are in effect during the reporting period (with the contract’stermination date), including contracts for:i. Management, marketing, packaging, processing, closing, servicing, orliquidation functions;ii. Independent loan reviews conducted for the CDC by another CDC;iii. Employee benefits (such as retirement and health benefits) for the CDC's staffthrough a contract under which the contractor and the CDC are deemed coemployees of both the CDC and the contractor; andiv. Legal services in connection with liquidation or litigation.If the CDC has previously submitted to SBA a fully executed copy of any of thecontracts listed above and no changes have been made to the contract, the CDCmust provide a statement as part of this report that certifies on behalf of the CDCthat the CDC has previously provided a fully executed copy of the contract toSBA, the date that the contract was provided, and the name of the SBA employeeto whom the contract was provided. If the CDC has not previously provided SBAwith a fully executed copy of the contract, the CDC must provide a copy of thecontract with this report. Contracts that the CDC enters into for accounting,independent loan review (by a non-CDC), IT, or legal services are not required tobe submitted for review and approval, except for legal services in connection withloan liquidation or litigation.Contracts that have not been previously approved by SBA must be submittedseparately to the OFA 504 Loan Program Branch at 504Requests@sba.gov torequest review/pre- approval prior to the start of each contract term, as requiredby SOP 50 10. The submission of a copy of the contract in the CDC’s AnnualReport DOES NOT constitute submission of the contract to OFA for review/preapproval.

4. Affiliations – For affiliations with all other entities, list: the name of the affiliated entity,nature of affiliation, effective date of the affiliation, and identify the provision under 13CFR 120.820 that permits the affiliation. If no affiliations exist, indicate “none.”5. Legal - Provide a statement signed by the CDC’s Board Secretary or Legal Counsel thatcertifies to the following:That all changes to the Articles of Incorporation or By-Laws made during thereporting period have been submitted to the CDC’s Lead District Office with thedate of the change(s), or a signed certification that no changes have been made.That the CDC’s Board of Directors and any Loan and Executive Committees arein compliance with SBA regulations governing CDCs; andIf the CDC is involved in any legal proceeding as a plaintiff or defendant, thatSBA has been adequately notified, including: a summary description of any legalproceedings; the date that SBA was notified; and the name of the individual andthe SBA office to which the notification was sent, or, a signed certification thatthe CDC is not involved in any legal proceedings.6. Independent Loan Review PackageCDCs are required by 13 CFR § 120.826 and SOP 50 10 to establish a Board-approvedinternal control policy, which includes providing for a periodic loan review function to beperformed at a minimum of every 2 years (unless otherwise directed by OCRM) by aperson who is not directly or indirectly responsible for the functions being reviewed, suchas loan making or loan servicing, or by a contractor.The CDC may contract for independent loan review services without SBA’s priorapproval, except that the CDC must obtain SBA’s prior written approval of the contract ifthe review will be conducted by another CDC. CDCs must include an Independent LoanReview Package in the Annual Report which evidences, at a minimum:A copy of the Engagement Letter from the Reviewer (if performed by an outsidecontractor).A copy of the completed Independent Loan Review Report which follows thecontent and reporting guidelines set forth in the Independent Loan ReviewGuide, and includes:i. A description of the individuals conducting the review, demonstrating theirindependence from the function they are responsible to review (if conductedinternally);ii. The loan selection methodology or criteria used for the sample; andiii. A copy of the checklist that was used in the loan review.andEvidence that the Board of Directors acknowledged receipt of the results of theIndependent Loan Review Report and approved the CDC Management’s plan toremedy the findings from the loan review.7. Ownership and Control.

a. For-profit CDCs. Under 13 CFR 120.818(b), no person or entity can own orcontrol more than 25 percent of a for-profit CDC’s stock. Each for-profit CDCmust provide a list of each owner of stock, the percentage of ownership, and thedate that the stock was acquired. If the CDC has previously submitted thisinformation to SBA in a prior Annual Report and there have been no changes,the CDC does not need to resubmit the information, but must indicate in whichAnnual Report the information was previously provided and must also state thatthere are no changes in stock ownership to report.b. Non-profit CDCs. Under 13 CFR 120.816(d), if a non-profit CDC has amembership and the members are responsible for electing or appointing votingdirectors to the CDC’s Board of Directors, no person or entity can control morethan 25 percent of the CDC’s voting membership. If the CDC’s members areresponsible for electing or appointing voting directors to the CDC’s Board ofDirectors, the CDC must provide a list that identifies each member and the entitythat the member represents or indicate that the member is serving in theirindividual capacity. If the CDC has previously submitted this information toSBA in a prior Annual Report and there have been no changes, the CDC does notneed to resubmit the information, but must indicate in which Annual Report theinformation was previously provided and must also state that there are nochanges in membership to report.TAB 3. Financial Report13 CFR § 120.830 contains the requirements for a CDC’s annual Financial Report. CDCs areresponsible for reviewing this regulation to ensure compliance. The following is a summaryof the financial reporting requirements.1. Level of reviewFor CDCs with a 504 loan portfolio balance of 30 million dollars or more (ascalculated by SBA), the CDC’s Financial Report must include:i. Audited financial statements prepared by an independent certified publicaccountant (CPA) in accordance with Generally Accepted AccountingPrinciples; ANDii. The auditor’s letter to management on internal control weaknesses.For CDCs with a 504 loan portfolio balance of less than 30 million dollars (ascalculated by SBA), the CDC’s Financial Report must include financialstatements reviewed by an independent certified public accountant (CPA) inaccordance with Generally Accepted Accounting Principles.2. For all audited or reviewed Financial Reports, refer to 13 CFR § 120.826(c) and (d) forCPA requirements.3. Affiliates - The CDC’s report must include audited or reviewed, as applicable, financial

statements of all CDC subsidiaries and affiliates, as determined by 13 CFR § 121.103.4. If the CDC’s management (through an SBA-approved management waiver) or staff isprovided by an affiliate of the CDC, and/or if an affiliate subsidizes the CDC’soperations, the CDC must also provide an explanation of the financial relationship of theaffiliation and a copy of the financial statements of the affiliate.5. Contents of Financial ReportThe Financial Report must include the following statements:Audited or reviewed balance Sheet;Audited or reviewed statement of income (or receipts) and expenses (see belowfor additional details);Audited or reviewed statement of source and application of funds;Such footnotes as are necessary to an understanding of the financial statements;Evidence of CDC Board’s acknowledgement of audited or reviewed financialstatements and the auditor’s letter on internal control weaknesses;Federal tax returns for the most recent year, including all schedules (ex. IRSForm 990, IRS Form 1120, Form 480.70); and504- Related Income/ExpensesIf the Income Statement does not include the following 504-specific income andexpense amounts, a separate listing must be attached that details thefollowing amounts (For Multi-state CDCs, this listing must be provided for eachstate):504-Related Income:i. Applicants/Approved Borrowers 504 Loan Depositsii. 504 Processing Fee Income (and the dollar amount of debentures funded)iii. 504 Closing Fee Income (excluding CDC attorney’s fees)iv. 504 Servicing Fee Incomev. 504 Late Fee Incomevi. 504 Assumption Fee Incomevii. 504 Escrow Float Interest Incomeviii. Other 504-Related Income (Identify what these miscellaneous items are)504-Related Expense:i. 504 Marketing, Screening, Packaging and Processing Staff Expenseii. 504 Servicing Staff Expenseiii. 504 Closing Staff Expense (excluding CDC attorney expense)iv. CDC Management Staff Expense

v. Other 504-Related Expense (Identify what these miscellaneous items are)vi. Funds invested in other economic development (for Multi-State CDCs, fundsmust be invested in economic development in each state in which the fundswere generated).6. 159 Reporting – include:a. CDC must provide copies of all SBA Forms 159, Fee Disclosure Form andCompensation Agreements, for all of the CDC’s 504 loans that closed during thefiscal year being reported.b. If copies of the SBA Forms 159 have been uploaded into the CorporateGovernance Repository, the CDC must provide a list of the uploaded forms withthe Annual Report.c. If the CDC elects not to submit copies of the SBA Forms 159 through theCorporate Governance Repository, the CDC must submit the copies of all of theforms with the Annual Report.d.If no copies of SBA Forms 159 are submitted to SBA either through theCorporate Governance Repository or with the Annual Report, the CDC mustinclude in the Annual Report a statement of no compensation/fees paid.7. Compliance with insurance requirement. Include copy of full policy binders for D&O andE&O insurance.TAB 4. Analysis of 504 Employment Impact1. The report requires a listing of all funded debentures (except debentures that have beenaccelerated, i.e. placed in liquidation status and required to be repurchased by SBA) byone of two categories:Debentures Funded Two or More Years: The actual jobs (as reported by theborrower on the 2 year anniversary of the funding of the debenture) createdand/or retained.i. The CDC must collect this information in writing from the borrower on adocument signed and dated by an authorized employee of the borrower.ii. The CDC must provide totals for this section. (Include prepaid debenturesbut NOT debentures that have been accelerated.)Debentures Funded Less Than 2 Years: The estimated (as indicated on the loanapplication) created and/or retained. The CDC must provide totals for this section. (Include prepaid debentures but NOT debentures that have been accelerated.)2. The report must also contain a summary section that calculates the CDC Job Creationand Job Retention Average as well as the of Debenture/job.With respect to Projects that do not involve manufacturing, the CDC must have a JobOpportunity average of 1 Job Opportunity created or retained for every 75,000 ofdebenture funding; or 85,000 for Projects located in Special Geographic Areas (Alaska,Hawaii, State-designated enterprise zones, empowerment zones, enterprise communities,labor surplus areas, and Opportunity Zones).

A CDC may choose to separate Projects located in Special Geographic Areas from theremainder of its portfolio for the purpose of calculating the averages.3. The CDC’s report must include a listing of all funded debentures for manufacturingbusinesses (except debentures that have been accelerated) and the Job Opportunitiescreated or retained in the same format as the non-manufacturing loans described above.Loans to Small Manufacturers must have a Job Opportunity average of 1 Job Opportunitycreated or retained for every 120,000 of debenture funding. The report must show thedollar per job average of the manufacturing loans. (Note – these Job Opportunities neednot be included in the CDC’s overall Job Creation and Retention Average reported in thesummary section of the report.)4. The CDC must report the Job Opportunity information in a table with the following dataelements:a. CDC Nameb. States Reportedc. CDC Fiscal Year Endingd. Debentures Funded Less than 2 Years:i. SBA Loan No. (designate manufacturing projects with a letter “M”)ii. Borrower Nameiii. Date Fundediv. 504 Approval Amountv. Estimated Jobs Created (as indicated on Application)vi. Estimated Jobs Retained (as indicated on Application)vii. Total Estimated Job Opportunities (add Estimated Jobs Created andEstimated Jobs Retained)viii.Totals for Columns i. through vii. should be reported as follows:a)Total number of loansb)Total 504 Approval Amountc)Total Estimated Jobs Createdd)Total Estimated Jobs Retainede)Overall Total Estimated Job Opportunitiesix. Totals for Columns i. through vii. should be broken out as follows:a)Other than Manufacturingb)Manufacturinge. Debentures Funded 2 or More Yearsi. SBA Loan No. (designate manufacturing projects with a letter “M”)ii. Borrower Name

iii. Date Fundediv. 503/504 Approval Amountv.Date of Verification of Actual Job Opportunities (for debentures funded inFY 2015 or later)vi. Actual Jobs Created as Reported on 2 Year Anniversaryvii. Actual Jobs Retained as Reported on 2 Year Anniversaryviii. Total Actual Job Opportunities (add Actual Jobs Created and Actual JobsRetained)ix. Difference between Estimated Job Opportunities and Actual JobOpportunitiesx.Public Policy Loan? Yes or Noxi. Totals for Columns i. through ix. should be reported as follows:a)Total number of loansb)Total 503/504 Approval Amountc)Total Actual Jobs Createdd)Total Actual Jobs Retainede)Overall Total Actual Job Opportunitiesf)Total Difference between Estimated Job Opportunities and Actual JobOpportunitiesxii. Totals for Columns i. through ix. should be broken out as follows:a)Other than Manufacturingb)Manufacturingf. Summary Sectioni. Job Opportunities Summarya)Estimated Job Opportunities from Debentures Funded Less than 2 Yearsi) Other than Manufacturingii) Manufacturingb)Actual Job Opportunities from Debentures Funded 2 or More Yearsi) Other than Manufacturingii) Manufacturingc)Total Job Opportunities to Datei) All Loansii) Other than Manufacturingiii) Manufacturing

ii. Debentures Summarya)Sum of Debentures Funded Less than 2 Yearsi) Other than Manufacturingii) Manufacturingb)Sum of Debentures Funded 2 Years or Morei) Other than Manufacturingii) Manufacturingc)Overall Sum of Debentures Fundedi) All Loansii) Other than Manufacturingiii) Manufacturingiii. Job Creation Average Calculationa)All Loansi) Overall Sum of Debentures Funded (All Loans) divided by Total JobOpportunities (All Loans)b)Other than Manufacturingi) Overall Sum of Debentures Funded (Other than Manufacturing)divided by Total Job Opportunities (Other than Manufacturing)ii) *** Report this number as the Annual Jobs Ratioc)Manufacturingi) Overall Sum of Debentures Funded (Manufacturing) divided by TotalJob Opportunities (Manufacturing)TAB 5. Report on Compensation1. Provide a copy of the CDC’s Executive Compensation policy;2. Include documentation of the CDC Board of Directors’ basis for determining executivecompensation;3. Provide evidence of CDC Board of Directors’ review and approval of current executivecompensation package;4. Provide detailed information on all compensation (including salary, bonuses, andexpenses) paid within the CDC’s most recent tax year for current and former officers,directors, and key employees. (Compensation must be reported for all current and formerofficers, directors, and key employees even in cases where compensation is less than 100,000.) Include details of deferred compensation packages where applicable; and5. Provide detailed information on all compensation (including salary, bonuses, andexpenses) paid within the CDC’s most recent tax year for current and former employeesand independent contractors with total compensation of 100,000 or more during that

period. Include details of deferred compensation packages where applicable.Note – Report on Compensat

CDCs that choose to submit hard copies of their Annual Report must use only 8.5 by 11-inch paper and must provide their original Annual Report, plus one copy of the report to their Lead District Office. The Lead District Office will forward one hard copy of the Annual Report to OCRM and retain the other

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