Mission and Charitable Purpose

Q: What is the mission or charitable purpose of Seed Savers Exchange?
A: Seed Savers Exchange exists to serve its members, and the public, through its charitable mission to (1) save the world’s diverse, but endangered, garden heritage for future generations; (2) build a network of people committed to collecting, conserving and sharing heirloom seeds and plants; and (3) educate people about the value of genetic and cultural diversity. Article I, Section 2 of the By-Laws (November 2007) lists 18 more-specific charitable objectives and purposes that Seed Savers Exchange may pursue to fulfill its mission. To see Seed Savers Exchange’s current By-Laws, click here.

Q: What does Seed Savers Exchange mean today when it refers to “big picture thinking?”
A: When Amy Goldman was elected to lead the Board of Directors in March 2007, she asked for increased “big picture thinking” at Seed Savers Exchange. Generally, this included reflection on where the organization has been, thoughts for where it should be going, and re-focusing on the original, core mission. At this Board meeting, Kent Whealy and Diane Ott Whealy shared their perspectives on the history and future of Seed Savers Exchange. In addition, Amy led discussion on the following questions:

• How can we better serve our members?
• Have we properly balanced seed exchange, seed collection, and seed selling?
• Are we appropriately focused on seed exchange among listed members, per our name and mission?
• How have we done in executing our strategic plan and what should our next strategic plan include?
• What kind of growth have we had and what kind of growth do we want to have in the future?
• What have been our sources of funding and what do we need to do for future funding?
• Are there other organizations with similar, complimentary, or overlapping missions/purposes where mutual benefits could be realized by working together (e.g., Slow Food)?
• Should the Board be expanded by adding more Directors?
• Should succession planning be undertaken for key positions?

SSE’s Collection and Other Seed Banks

Q: What is Seed Savers Exchange's relationship with other seed banks, like Svalbard?
A: SSE has deposited duplicate seeds from its collection in other seed banks when our research gives confidence that doing so will further protect SSE’s collection and advance SSE's mission. Such deposits by SSE include the USDA’s National Center for Genetic Resources Preservation in Ft. Collins, Colorado (began in 2002) and the Global Seed Vault in Svalbard, Norway (began in 2008).

Seed Savers was among the opening day depositors in the Svalbard Global Seed Vault in 2008, with an initial deposit of 485 varieties of vegetable seed from its collection. A second deposit was shipped to Svalbard in April 2009. Matthew Barthel, SSE vice president of gardens and collections and his staff tested seed viability and then listed, packaged and prepared the deposits, in compliance with the Seed Vault's regulations. SSE signed the Standard Seed Deposit Agreement, and followed the depository guidelines, which are available at: http://www.nordgen.org/sgsv/index.php?page=depositor_guidelines

Q: Can commercial seed companies, such as Monsanto, obtain and patent seeds that SSE deposited in the Svalbard Global Seed Vault?
A: No. Misleading information and erroneous speculations published as “facts” by a few persons have attempted to confuse the public and mischaracterize the true nature of the Svalbard Global Seed Vault (“Seed Vault”). Accurate facts about the Seed Vault can be found at the following websites:

• http://www.croptrust.org/main/arctic
• http://www.regjeringen.no/en/dep/lmd/campain/svalbard-global-seed-vault.html
• http://www.nordgen.org/sgsv/

As specified in the depositor's agreement signed by Seed Savers Exchange, the seeds that SSE deposits in the Svalbard Global Seed Vault are available only to SSE—there is no transfer of ownership of the seeds that are deposited by SSE, or any other entity, in the Seed Vault. Financial donors to the Global Crop Diversity Trust (see www.croptrust.org) do not get access to seeds in the Seed Vault, except to those seeds they may have deposited there themselves. A wide range of developed and developing countries are donors to the Global Crop Diversity Trust for many purposes other than the Seed Vault's operating costs, and include the United Kingdom, Australia, Canada, Germany, Italy, Sweden, Switzerland, Ireland, Ethiopia, Brazil, Colombia, and India. Corporate donors—including Syngenta and Pioneer/DuPont, but not Monsanto—who made unrestricted donations to the Global Crop Diversity Trust for its endowment prior to the Seed Vault's existence, do not have access to seeds stored in the Seed Vault by others. (They themselves have not made use of the Seed Vault through deposits of their own.)

Seed stored at the Svalbard Global Seed Vault by SSE will not be distributed to others by the Norwegian government, nor will it be made available to patent claims of others. Seeds in the SSE Collection are pre-existing, or "prior art," and as such, they cannot be patented. And if a patent is mistakenly granted for a pre-existing variety, there is legal recourse to annul the patent. On the other hand, new varieties, derived from or created using an old variety, are patentable in most countries of the world, provided they meet the applicable country's criteria for patentability. Deposit of seed in Svalbard has no bearing on such national laws and in no way facilitates the exercise of rights under such laws. SSE prohibits dividing and reselling Yearbook seeds; but the Yearbook specifically acknowledges that after seeds are re-grown once, the resulting seeds, plants, and produce are available to SSE members to use however they please. A new variety that is made with an SSE Collection variety in its pedigree can be patented, but that does not change the legal status of the SSE variety. Nor does the patenting of a new variety prohibit later access to, or use, of a variety within the new variety’s pedigree. In other words, the patenting of a new variety cannot restrict the use of the SSE variety in other, additional breeding programs.

The Seed Vault functions like a safety deposit box for biodiversity and global food supply preservation, storing duplicate collections of seeds on behalf of gene banks from around the world. The Seed Vault offers protection against loss of diversity due to natural disasters, wars, equipment failures, accidents, and loss of funding that can plague even the best gene banks.

As a service to the world community, the Government of Norway paid for the complete cost of the Seed Vault's construction. The Global Crop Diversity Trust and the Government of Norway are financing the operating costs of the Seed Vault. The Seed Vault is managed by the Nordic Gene Bank (NordGen) under a tripartite agreement between the Government of Norway, the Global Crop Diversity Trust, and NordGen. Storage of seed in the Seed Vault is free of charge. An International Advisory Council oversees operations.

Located at 78 degrees north, far above mainland Norway, three vault rooms have been fashioned inside a mountain, down a 125-yard tunnel chiseled out of solid stone. Naturally below freezing already, the Seed Vault is further cooled to below -2 degrees Fahrenheit. At this temperature, seeds can be stored safely for decades-even if the earth warms or the power goes out. The Seed Vault has the capacity to store 4.5 million different seed samples (each sample containing about 500 seeds) potentially from 1,400 gene banks around the world. The Seed Vault will soon house and secure the world's largest collection of seeds, including many varieties no longer grown by farmers or gardeners.

The emerging international norm is to have each distinct plant variety conserved in one facility where it can be actively managed under international standards (including availability for viability testing, regeneration, and distribution), plus inactive back-up storage at Svalbard. Seed Savers Exchange's seed collection does not fully meet this international norm, although SSE's own efforts, and its inactive storage at the Seed Vault and at the U.S. National Genebank in Fort Collins, Colorado, are steps in the right direction and should be sufficient to guard against any future loss due to accidents, natural disaster, etc. Storage at the Seed Vault provides credible conservation and robust protection for the varieties that SSE is entrusted to preserve, though the seeds remain the property of SSE.

SSE deposits seeds from its Collection in the Seed Vault as a way to “deepen the commitment of the organization to ensuring the long-term conservation of the diversity that has been entrusted to us," per SSE Chair of the Board, Amy P. Goldman. "We honor, trust and depend upon our members, but we know that varieties can be lost and that neither the membership nor our own seed collection is immune from loss. The Seed Vault offers free insurance to us and the other seed banks of the world. It is internationally accepted and monitored. We are happy to participate, grateful for the opportunity, and fully supportive of the goals of the Seed Vault."

Corporate Governance

Q: What are the duties of Directors (who together, make up the Board) of a charitable/non-profit corporation?
A: The Directors of Seed Savers Exchange are unpaid volunteers who cannot gain financially from the dissolution of the organization or business transactions of Seed Savers Exchange. Each Director has a fiduciary duty to the corporation, which sets the standard of conduct for Directors. Fiduciary duties of Directors of a non-profit organization are further broken down into three general categories: the duty of care, the duty of loyalty, and the duty of obedience. To fulfill the duty of care, a Director makes decisions and oversees operations of the organization with reasonable attention (ordinary care), good faith, and adequate information. To fulfill the duty of loyalty, a Director puts the corporation’s best interests first, does not engage in self-dealing, and does no harm to the corporation. The duty of obedience is special, in that it only applies to non-profit/charitable corporations, and not to for-profit corporations. To fulfill the duty of obedience, a Director carries out the mission and charitable purposes of the organization, insures required filings are made, and complies with governing documents (i.e., articles of incorporation and by-laws).

Q: What is a self-perpetuating Board of Directors?
A: A self-perpetuating board of a corporation nominates and elects its own Directors, including re-electing current Directors, and this type of board is responsible for major organizational decisions and transactions. The alternative structure for a corporate board is one where members with voting rights elect Directors to the board, and make major organizational decisions. Self-perpetuating boards for non-profits are legally allowed in most, if not all, states—including Iowa, the state in which Seed Savers Exchange is incorporated. For various reasons, self-perpetuating boards are the most appropriate governance structure, and are normally used for non-profit organizations. Seed Savers Exchange has, and has always had, a self-perpetuating Board of Directors.

Q: Can Seed Savers Exchange be “taken over” or subject to a “hostile takeover” by its Board of Directors or an individual Director?
A: No. Takeovers and hostile takeovers only occur in for-profit corporations that have stockholders. Only Directors of Seed Savers Exchange have voting rights and the Board of Directors is self-perpetuating. Therefore, SSE cannot be taken over, by hostile or friendly forces, without the vote of a majority of its Board of Directors.

Q: Can the Directors of Seed Savers Exchange divide its assets among themselves?
A: No. Seeds Savers Exchange’s assets can only be used in compliance with its charitable purposes. The charitable assets of Seed Savers Exchange cannot be used for profit or to enrich any individual. The Directors of Seed Savers Exchange are unpaid volunteers who cannot gain financially from a merger or dissolution of the organization, and who are bound by fiduciary duties to the organization.

Q: What is the purpose of having By-Laws in a non-profit corporation?
A: By-laws are an important and legally mandated document of corporate governance. They are the general rules and framework of a corporation. By-laws give an organization structure, insure continuity of the organization, delegate and determine financial and contractual powers for the organization, and establish relationships between and among directors, members, boards, committees, and other important groups. Unlike for-profit corporations, charitable non-profit corporations (such as Seed Savers Exchange) must explain their charitable purpose(s) in their by-laws. By-laws are to be concise, simple and brief. Only essential provisions should be included in by-laws, not specific procedures, policies or practices.

Q: Why did Seed Savers Exchange change its By-Laws in November 2007?
A: The 2001 By-Laws of Seed Savers Exchange were revised in November 2007 to comply with changes in the Iowa laws governing non-profit corporations that were effective in 2004. To see Seed Savers Exchange’s current By-Laws, click here. The most significant changes of likely interest to members include the following:

• Separation of leadership positions from those for the Board of Directors (the group charged with corporate oversight) and those for staff (Corporate Officers who lead/manage daily operations). Previously, positions and duties were consolidated into combined Director/Officer positions, which concentrated power and provided little separation between oversight and daily operations. The revision provides a better system of checks and balances, reflecting the usual corporate structure. Positions on the Seed Savers Exchange Board of Directors now include a Chairperson (Amy Goldman), Vice-Chairperson (Neil Hamilton), a Board Treasurer (Rob Johnston) and a Board Secretary (Deborah Madison). Officers, who are on staff at Seed Savers Exchange, now include a President/Executive Director (George DeVault), Vice President of Education (Diane Ott Whealy), Vice President of Sales (Aaron Whaley), Vice President of Gardens and Collections (Matt Barthel), Corporate Treasurer (Larry Neuzil) and Corporate Secretary (Stephanie Hughes).

• Limitation of the term of a Director to three years, and staggering those terms. The number of terms a Director may serve is not limited. Previously, Directors served a single, unlimited term.

• Authorization of Honorary Board Members, who are chosen by the Board of Directors, but who have no duties or voting rights. No Honorary Board Members have yet been chosen.

• Authorization of the President/Executive Director as an Ex Officio Member of the Board, who attends most Board meetings, but has no voting rights.

• Addition of an Article regarding Board Committees (Article VI) and how Committees are to be operated.

• Deletion of portions of the former by-laws, including:
• Former Article II, Section 3, regarding tax exemption requirements, which was not required by Iowa law and is inherent for a non-profit; and
• Portions of former Article III that covered operational matters, and internal policies and practices, regarding non-voting members and Advisors.

Members

Q: What does it mean to be a “member” of Seed Savers Exchange?
A: Members are the backbone of Seed Savers Exchange. Members believe in and support fulfillment of our all-important mission and operations through annual dues ($30-$50 per year, depending on geographic location and status) and/or lifetime subscriptions ($1,000). Members get a 10 percent discount on orders from our commerical catalog and from The Lillian Goldman Visitors Center. They receive three annual publications (Yearbook, Spring Edition, Summer Edition and Harvest Edition), periodic e-mail newsletters, our annual catalog of commercially-available seeds, and periodic surveys seeking member input. Members can make posts on our electronic “forum.” Members receive special discounts for attending events at Seed Savers Exchange, including the Apple Grafting Workshop and our Annual Convention, which is held each July at our facilities in Decorah, Iowa, and includes presentations, workshops, tours, local food, a barn dance, and other fun activities. (In 2007 participation in the Annual Convention was opened to the general public.) Members of Seed Savers Exchange do not have voting rights. Seed Savers Exchange currently has over 10,000 members. To become a member of Seed Savers Exchange, or renew a membership, click here.

Q: What is a “listed member” of Seed Savers Exchange?
A: A “listed member” is a special sub-group of Seed Savers Exchange’s members who allow Seed Savers Exchange to publish their personal contact information and lists of seeds they are willing to make available for exchange with others in the Yearbook. The sole permitted use of the names and personal contact information in this list is for the exchange of seeds. Seed Savers Exchange takes every action possible to prevent improper use of the list and almost all members comply with the rules; rare violations are handled properly to prevent further violations and protect listed members.

In addition to the usual benefits and obligations as a member of Seed Savers Exchange, listed members list more than 12,000 varieties of rare vegetable, fruit and grain seeds available for exchange—which is more than two times the varieties that are offered for sale to the general public through the commercial catalog. While any member, listed or nonlisted, may get seeds through the exchange, listed members enjoy a reduced rate when requesting seeds from others. Seed Savers Exchange currently has 690 listed members. Neither listed nor nonlisted members have corporate voting rights.

Advisors

Q: What is an “Advisor” of Seed Savers Exchange?
A: Advisors of Seed Savers Exchange are persons with expertise in individual subjects related to our purposes and objectives, who assist us on a volunteer and as-needed basis. Advisors are not an organized group or body of Seed Savers Exchange and do not have voting rights. Advisors have been identified and selected from the members of Seed Savers Exchange. Currently, Seed Savers Exchange has 18 Advisors, whose names and areas of expertise are listed below:

• Nancy Arrowsmith – genetic preservation, German/Austrian seed collections
• Suzanne Ashworth – author of Seed to Seed and Seed to Seed (Second Edition), eggplants, ground cherries
• Will Bonsall – peas, potatoes, favas, runner beans, biennials
• Anthony Boutard – organic farming
• Dan Bussey – apples, grafting, orchards
• David Cavagnaro – photography, heirloom vegetables
• Glenn Drowns – preservation gardens, cucurbits, endangered poultry
• Joel Girardin – garlic
• Laura Jackson – prairies and grazing
• C.R. Lawn – heirloom vegetables, sustainable agriculture
• Craig LeHoullier – tomatoes
• Laura Merrick – cucurbits (cucumbers, gourds, melons, pumpkins), agronomy
• Jeff Nekola – native plant biodiversity, ecology, land snails, butterflies, tomatoes, peppers
• Michael Strauss – global change
• John Swenson – allium (onion family), history, foreign collecting
• Mark Widrlechner – horticulture, root and bulb vegetables, woody landscape plants and ornamental herbs
• Garrison Wilkes – biology, agronomy, teosinte and corn genetics
• Clive Blazey - Australian heirlooms

Financial Matters

Q: Are contributions to Seed Savers Exchange restricted to a particular use?
A: Some contributions and grants made to Seed Savers Exchange are restricted for a particular use by the donor or the granting entity, but most are not. Seed Savers Exchange complies with all restrictions on contributions and grants it receives. In addition, Seed Savers Exchange complies with all requirements on grants, which often include auditing and/or reporting requirements.

Q: Who monitors how Seed Savers Exchange spends its money?
A: The Board of Directors provides direction and has ultimate oversight responsibility regarding how money is spent. The Board Treasurer, Rob Johnston, takes a lead role in this, including working with staff and chairing the Audit & Finance Committee. The Executive Director/President of SSE (George DeVault), the Corporate Treasurer (Larry Neuzil), and other staff to whom duties may be delegated, are responsible for carrying out the Board’s direction on a daily basis and reporting financial status and activities to the Board. Seed Savers Exchange is audited annually by CPAs.

Q: Where can I get financial information about Seed Savers Exchange?
A. Seed Savers Exchange annually publishes audited summary financial information each summer. Seed Savers Exchange’s fiscal year coincides with the calendar year. Because it takes several months to finalize year-end accounting, complete the annual audit, and prepare reports and tax returns, financial information on the most recently completed fiscal year is not ready or available until the summer of each year. In addition, Seed Savers Exchange’s IRS 990 (the tax return for non-profits) is available to anyone (see next Q&A). Click here for the most current IRS 990 report.

Q: Where can I get Seed Savers Exchange’s Tax Returns?
A: Seed Savers Exchange provides copies of its 990 report(s), although a reasonable copy charge may be assessed. Perhaps the fastest and least expensive way to get IRS 990 forms is from the IRS’ web site at http://www.irs.gov. At the IRS home page, choose the “Charities and Non-profits” tab (top of the page). Then click on “Search for Charities” (menu on the left-hand side of the page). Then, scroll down and click on “Search Now.” Enter the name of the organization you are searching for and the year of the report you want to see. Other web-based providers have IRS 990s also (e.g., http://atgdata.fdncenter.org/990search/search.php), but some may charge a fee to access/view the reports through them.

Ancient White Park Cattle

Q: How do the Ancient White Park Cattle fit with Seed Savers Exchange’s mission?
A: The mission and core purpose of Seed Savers Exchange is to (1) save the world’s diverse, but endangered, garden heritage for future generations; (2) build a network of people committed to collecting, conserving and sharing heirloom seeds and plants; and (3) educate people about the value of genetic and cultural diversity. Seed Savers Exchange has identified objectives and purposes that may be pursued in service to this broad mission, and these are listed in the By-Laws at Article I, Section 2. Included among those are the following: “…(i) Conserve endangered breeds of livestock and poultry, sometimes by harboring endangered herds and flocks until desirable homes can be found, or by maintaining breeding populations of rare breeds, including guidance from livestock and poultry geneticists; (j) Secure sufficient land needed to implement and maintain these types of genetic preservation projects – preservation gardens, historic orchards and vineyards, isolation gardens, and endangered livestock breeds…” For several years now, Seed Savers Exchange has maintained a herd of Ancient White Park Cattle. The cattle fit in the broad mission and these specific listed purposes.

Q: What does Seed Savers Exchange plan to do with the Ancient White Park Cattle in the future?
A: The Ancient White Park Cattle live and graze on Heritage Farm and Twin Valleys Farm, which are the lands of Seed Savers Exchange. In addition to their rareness and beauty, the cattle serve a valuable function of helping to maintain and control the pasture lands, as they are aggressive grazers.

Twin Valley farms is Seed Savers Exchange’s largest charitable asset and body of land and is subject to a permanent conservation easement with the USDA and the Iowa Natural Heritage Foundation. Seed Servers Exchange has never made a permanent commitment to maintain a herd of Ancient White Park Cattle, nor to maintain Twin Valleys as a sanctuary for Ancient White Park Cattle—not in the Twin Valleys easement, nor or in any program, grant nor donation, nor in any contract with any individual. Seed Savers Exchange has no present intention or plan to change how it maintains and manages the cattle. However, to be prudent, Seed Savers Exchange cannot limit our right and flexibility to do so if circumstances arise to require reassessment of the cattle, no matter how unforeseen or unlikely such circumstances may be.

Personnel Matters

Q: What type of employees does Seed Savers Exchange have—contract-based or at-will?
A: None of Seed Savers Exchange’s employees have employment contracts, whether collectively or individually bargained. Rather, all employees of Seed Savers Exchange are employed at-will, including the Executive Director. Employment at-will is the presumed type of employment for non-government employees throughout the United States (except in Montana). To be employed at-will means that either the employer or the employee may terminate the employment relationship at any time and for any legal reason, with or without notice.

Q: Why are personnel matters for employees of Seed Savers employees “confidential?”
A: Many laws, and court decisions, require employers to keep personnel matters confidential. By necessity, employers have to gather, create and maintain private and personal information about their employees, and that information cannot be used or disclosed for purposes other than internal business needs. Personnel matters include, but are not limited to, work and educational histories, background and reference checks, disciplinary actions, performance reviews, counseling/coaching, investigations, separations from employment, benefit choices, compensation, medical information, tests, personal identifying information (e.g., social security numbers), etc. Even personnel matters of government employees are confidential, with the exception that pay provided to government employees is public information because tax dollars are being spent. There are strong legal protections for the confidentiality of personnel matters, and employers must staunchly observe the confidentiality of their employees and protect employee privacy. These legal requirements protect the employer and employee equally. Seed Savers Exchange’s status as a non-profit charitable organization does not give us any special exemption from these laws.

By way of illustration, Seed Savers Exchange cannot discuss the reasons or incidents that led to an employment decision, such as a termination of employment. The employee or former employee may choose to publicize his/her version of what happened, but that does not give the employer permission to respond with a break in confidentiality or privacy—no matter how difficult it may be for the employer to remain silent nor how difficult it may be for others to understand.

As another illustration, it has long been the policy of Seed Savers Exchange, and of most employers, to provide only very limited information when responding to reference checks from other employers about current or former employees. We provide dates of employment and the position(s) held, which is standard in the business community. It is our policy that additional information in response to employment reference checks may be given out if the employee or former employee provides Seed Savers Exchange with a proper signed release.

Q: Do Seed Savers Exchange employees have retirement benefits; and if so, how are those benefits protected?
A: Seed Savers Exchange is a small corporation and we were not able to offer our employees any retirement benefits until May of 2002. At that time a 401(k) plan was put into place. This plan is the only retirement benefit Seed Savers Exchange has available.

Q: Generally, what does Seed Savers Exchange’s 401(k) plan provide to the employees?
A: 401(k) plans are IRS qualified retirement plans, of the defined contribution type, and are governed by strict IRS codes and regulations. Employees with one year of service at Seed Savers Exchange and who are at least 18 years old, except seasonal employees, are eligible to participate in the 401(k) plan. Eligible employees may decline to participate in the 401(k) plan if they choose to do so. Participating employees defer a portion of their pre-tax pay to fund their 401(k) retirement account, up to an annual maximum limit set by law. Seed Savers Exchange matches employee contributions on a sliding scale based on years of service. The employee chooses investments for his/her 401(k) account from among a set of standardized offerings. The money in an employee’s 401(k) account changes based on the amount of pay deferred, the employer match, and gains or losses in the investments s/he chooses. Employees are always 100% vested in the deferred pay portion of his/her 401(k) account. There is a schedule governing vesting in the employer-match portion of an employee’s 401(k) account, and employees with six or more years of service at Seed Savers Exchange are 100% vested in the employer-match portion. 401(k) accounts are closely regulated by the government and monitored our provider, John Hancock Insurance and Financial Services.

Q: How is a Seed Saver Exchange employee’s retirement benefit protected?
A: Seed Savers Exchange cannot take or steal any employees’ 401(k) account. As the Summary Plan Description for the 401(k) plan states:

“As a general rule, your interest in your [401(k)] account, including your ‘vested interest,’ may not be alienated. This means that, your interest may not be sold, used as collateral for loan, given away or otherwise transferred. In addition, your creditors may not attach, garnish or otherwise interfere with your account. There are two exceptions to this general rule. The Administrator must honor a ‘qualified domestic relations order.’ A ‘qualified domestic relations order’ is defined as a decree or order issued by a court that obligates you to pay child support or alimony, or otherwise allocates a portion of your assets in the [401(k)] Plan to your spouse, former spouse, child or other dependent.”

Q: Does Seed Savers Exchange have an Employee Manual; and if so, what is its purpose?
A: Yes, Seed Savers Exchange has an Employee Manual that contains policies regarding management of our employees. The Employee Manual is a guide only; it clearly states it is not a legal document or employment contract, and that it does not create any contractual rights or obligations. Seed Savers Exchange has the discretion to interpret the policies, make exceptions to them, and change/add/delete them at any time.

Release Date: January 31, 2008
Last Revised: January 2009