Santa Clara Stadium AuthorityStudy SessionProposed Santa Clara Stadium Authority FY 2026/27 Budget, 2026 Marketing Plan, and Compliance and Management PoliciesItem #1 (26-17490)February 24, 2026 Agenda
2 1. Budget Development 2. Methodology and Limitations3. Budget Flowchart4. Organizational Chart5. Key Summary6. Excess Revenues Distribution7. Stadium Authority Operating Budget8. Stadium Authority Debt Service Budget Agenda (cont.)
3 9. Stadium Authority Capital Budget10.Outstanding/Pending Items11.Stadium Operations and Maintenance Plan (SOMP)12.2026 Marketing Plan13.Key Summary14.Recommendations FY 2026/27 Budget Development
4 Stadium Authority staff worked with ManCo to discuss the annual budget plan which included the dates that ManCo would provide all necessary documents as required by the Stadium Agreements. October/November 2025Stadium Authority staff provided the Stadium Authority G&A, Public Safety Capital Expenses, and Discretionary Fund costs to ManCo for review and incorporation into the annual budget.December 2025At least 45 days prior to the start of the fiscal year (January 30) ManCo provided the required documents per the Stadium Agreements:• Stadium Operations and Maintenance Plan• Annual Shared Expense Budget with Five Year Projection• Annual Stadium Authority Operations Budget, Capital Expenditure Plan with Five-Year Projection• Annual Public Safety Budget• 2026 Marketing Plan and Public Safety Document UpdatesJanuary 2026Staff submitted a series of questions to ManCo on February 10, 2026, and received responses on February 23rd. February 2026Study Session on Fiscal Year 2026/27 Operating, Debt Service, and Capital Budget, Stadium Operation and Maintenance Plan, Public Safety Budget and Marketing PlanFebruary 24, 2026 Special Study Session on Fiscal Year 2026/27 Operating, Debt Service, and Capital Budget, Stadium Operation and Maintenance Plan, Public Safety Budget and Marketing PlanMarch 3, 2026, if neededPublic Hearing to approve the SCSA Proposed Fiscal Year 2026/27 Operating, Debt Service, and Capital BudgetMarch 10, 2026SCSA Notice of approval/disapproval of the Stadium Manager’s Draft Annual Stadium Authority BudgetMarch 13, 2026Stadium Manager required to submit Adopted Budget to the Trust (10 days prior to start of FY)March 20, 2026 FY 2026/27 Budget Development (cont.)
5 oGeneral Information oYear in Review for both NFL and Non-NFL EventsoExcess Revenues DistributionoOperating Budget•Stadium Authority General and Administrative Budget•Stadium Manager Shared Expenses and 5 Year Forecast•10-Year Forecast oDebt Service BudgetoCapital Expense Budget•Capital Expenditure Plan and 5 Year ForecastoStadium Authority Work Plan FY 2026/27 Budget Development (cont.)
6 Attachments:1. Proposed Santa Clara Stadium Authority Fiscal Year 2026/27 Operating, Debt Service, and Capital Budget 2. Annual Public Safety Budget3. 2026 Marketing Plan4. Stadium Authority Budget Policy 5. Stadium Authority Compliance and Management Policy Methodology and Limitations
7 oThe Budget is on an accrual basis, which records revenues and expenses when they are incurred, regardless of when cash is exchanged.oThe Budget report was based in part on documentation and submitted by ManCo. on January 30, 2026. Additional responses received February 23, 2026 have not been incorporated. oThe Capital Budget included proposals from both the Stadium Authority and Stadium Manager.oLong-term 10-year forecast represents best known data at the time.
Stadium Authority Budget Flowchart
8 City of Santa Clara
City of Santa ClaraoOwns LandoGround Leases to SCSAoLeases Stadium for 49er Football Company oStadium OwneroLeases Stadium to StadCo during the NFL Season (6 months) Santa Clara Stadium Authority (SCSA)
Santa Clara Stadium Authority (SCSA)
StadCo
StadCo
ManCo
ManCooManages Stadium for StadCo and SCSA
Stadium Authority Organizational Chart
9 Stadium Authority Organizational Chart(cont.)
10*Position count is provided by ManCo and does not include positions in Other Expenses
Stadium Authority FY2026/27 Budget Key Summary
11Operating Budget$65.9MDebt Service Budget$21.0MCapEx Budget$22.2MDebt Service and Capital Transfers Out$27.8MTotal Budget$81.3M Stadium Authority FY2026/27 Budget Key Summary(cont.)
12 oNet Non-NFL Events Revenue budgeted at $4.6 million•Lower than prior two fiscal years (FY)FY 2024/25 Actual: $10.2 millionFY 2025/26 Projection: $6.2 million•Historical performance increases from preliminary budget projectionoPublic Safety Costs (PSC) reimbursements over threshold expenditure is budgeted to be $2.5 million•$1.9 million from PSC Reserve•$0.6 million from Discretionary FundoPSC 2024 Outstanding Balance ($4.7 million in FY 2025/26, $0.8 million in FY 2026/27)•Projected to be paid off at end of FY 2026/27oBudget supports 2026 World Cup events Stadium Authority FY2026/27 Budget Key Summary (cont.)
13 oDirect payments to the General Fund at $6.6 million •Performance Rent for FY 2026/27 ($1.8 million, accrual basis)•Projected FY 2026/27 Excess Revenue ($3.6 million)•Ground Rent ($1.0 million)•Senior and Youth Fees ($248,000)oAdditional $5.7 million transfer to the CapEx fund to projects necessary to maintain the facility pending finalization of a facility condition assessment•Carryover projects adjusted to cover rising construction costs•Project contingencies has been increased from 5% to 10%•Impacts to future excess revenue transfers in out-years Excess Revenues Distribution
14 Excess Revenues Distribution: If revenues exceeds expenses in a lease year the Excess Revenues are required to be distributed in the order as set forth in Article 14 of the Stadium Lease agreement as shown below (contributions and balances projected below are as of 03/31/26).1. Payoff any outstanding ManCo Revolving Loan –N/A2. Fund Future Stadium Authority Expenses up to $2M – Completed in FY 2014/153. Fund Stadium Capital Expenditure Reserve up to $1M + 3% Annual Inflator –Annual Contribution Ongoing: $1.4M contribution projected4. Fund Operating Expense Reserve up to $10M – Completed in FY 2014/155. Repay any outstanding principal balance on Subordinate Loan – Completed in FY 2022/236. Fund Operating Expense Reserve up to $20M –Annual 3% Contribution Ongoing: $27.7M balance projected7. Fund Renovation / Demolition Reserve (50% if less than $70M) – In progress: $53.1M balance projected8. Public Safety Cost 2024 Outstanding Balance (50% of remaining) - In progress: $0.8M balance projected9. Additional disbursements can be used to pay Stadium Authority Discretionary Expense, including the City’s General Fund – Future Allocation: $4.7M contribution projected
Excess Revenues Distribution (cont.)
15Excess Revenue Cash Reserves Summary(cash based)FY 2026/27 BudgetFY 2025/26 ProjectedFY 2024/25 ActualReserve Category$0.6M $11.4M $16.9M Capital Expenditure Reserve$28.5M $27.7M $26.9M Operating Reserve$57.5M $53.1M $43.8M Renovation/Demolition Reserve$86.7M $92.2M $87.5M Total
Stadium Authority Operating Budget
16 Key Assumptions in Proposed Operating Budget:oGeneral and Administrative Expenses -$4.6 million, includes 7.9 full time equivalent positions as a baseline level of support•Budget decreased by $120,000 or 3% oNet Non-NFL Events -$4.6 million projected for FY 2026/27•Stadium Manager is projecting four (4) concerts and one (1) soccer match for FY 2026/27Net Non-NFL Events Revenue SummaryFY 2026/27 BudgetFY 2025/26 ProjectedFY 2024/25 Actual$4.6M $6.2M $10.2M Stadium Authority Operating Budget (cont.)
17 Key Assumptions in Proposed Operating Budget:oStadium Manager Shared Expenses -$15.2 million, includes 75 full time equivalent positionsFY 2024/25 Actuals: $11.8 million; FY 2025/26 Projected: $13.8 millionCosts increased by $1.4 million or 9%Higher compensation costs in Stadium Ops and SecurityHigher outside services costs in SecurityoSBL Sales and Service -$2.5 million, includes 12.4 positions charged based on actual time spentFY 2024/25 Actuals: $2.3 million; FY 2025/26 Projected: $2.3 millionFuture organizational assessment of SBL Sales and Service by third-party consultant Stadium Authority Operating Budget (cont.)
18 Key Assumptions in Proposed Operating Budget:oOther Expenses - $1.7 million, includes other supporting staff, software costs, lender fees and share of ManCo staff office space•This is an increase of $1.0 million (or 150%) over FY2025/26 Projected Actuals of $687,000•Main driver is cost of Stadium Authority share of ManCo office lease spaceStadium Authority staff has requested additional informationManCo has requested to meet and confer on this line item Stadium Authority Operating Budget (cont.)
19 Revenues:$ 24,762,000Facility Rent 16,166,000NFL Ticket Surcharge8,307,000Naming Rights5,154,000SBL Proceeds4,600,000Non-NFL Event Net Revenue 4,097,000Non-NFL Event Ticket Surcharge3,155,000Interest794,000Sponsorship Revenue (STR)248,000Senior & Youth Program Fees84,000Non-NFL Events PSC Depreciation Reimbursement$67,367,000Total Revenues Stadium Authority Operating Budget (cont.)
20 Expenses:$15,248,000Shared Stadium Manager Expenses4,567,000Stadium Authority General & Administrative3,550,000Transfer to City General Fund from Excess Revenues2,500,000PSC Over Threshold2,468,000SBL Sales and Service1,868,000Utilities1,800,000Performance Rent 1,717,000Other Expenses1,250,000Discretionary Fund Expense1,000,000Ground Rent859,000Buffet Costs836,000Public Safety Costs (PSC) 2024 Outstanding Balance248,000Senior and Youth Program Fees142,000Naming Rights Expenses75,000Use of StadCo Tenant Improvements$38,128,000Total Expenses$6.6 million projected to the City’s General Fund Stadium Authority Operating Budget (cont.)
21 General and Administrative BudgetVarianceFY 2026/27 Proposed BudgetFY 2025/26 Amended BudgetExpense Type$ 97,000$ 3,415,000$ 3,318,000Staff Support(55,000)460,000515,000Legal Services(60,000)100,000160,000Audit ServicesConsultants26,000126,000100,000- Community Outreach/Communications/Engagement-87,00087,000- Noise Monitoring(109,000)340,000449,000Administrative Services(20,000)30,00050,000Other Expenses1,0009,0008,000Board Stipends($ 120,000)$ 4,567,000$ 4,687,000Total Stadium Authority Operating Budget (cont.)
22oThe Discretionary Fund is projected to be used to cover NFL public safety costs above the public safety cost threshold, and the costs of a civic event in FY 2026/27 (if approved tonight, Proposed Budget will be amended to reflect Board action for the Civic Event to occur in FY 2025/26)Discretionary Fund Projected Ending BalancePublic Safety Costs Over ThresholdFY 2026/27 Discretionary Fund Expense50% of FY 2026/27 Base Non-NFL Event Ticket SurchargeProjected Beginning Balance$869,000($582,000)($1,250,000) $1,097,000 $1,604,000 Stadium Authority Operating Budget (cont.)
23 Performance Rent CalculationoStadium Authority pays the City performance-based rent on top of the fixed ground rentoPerformance-based rent is equal to 50% of the net income from Non-NFL events less 50% of the ground rent and any credited public safety costsoCredited public safety costs is the amount by which public safety costs exceed the public safety costs thresholdoPerformance-based rent is remitted to the City in July following the Stadium Authority’s fiscal year-end.
Stadium Authority Operating Budget (cont.)
24 Performance Rent Calculation (cont.)$5.2 $6.1 $5.3 $5.2 $-$(2.7)$(0.5)$(0.3)$8.8 $8.3 $10.2 $6.2 $4.6 $(4.0) $(2.0) $- $2.0 $4.0 $6.0 $8.0 $10.0 $12.0Non-NFL Event Net Revenue (in millions) Stadium Authority Operating Budget (cont.)
25 Performance Rent Calculation (cont.)Per Stadium Lease Paragraph 7.5.3(a), credited public safety costs is the amount by which public safety costs exceed the public safety costs threshold. Fiscal Year 2026/27 BudgetFiscal Year 2025/26 ProjectionPerformance Rent Calculation$ 1,000,000 $ 1,000,000 Ground Rent4,600,000 6,222,000 Net Non-NFL Event Revenue (Expense)$ 2,300,000 $ 3,111,000 50% of Net Non-NFL Event Revenue (Expense)(500,000)(500,000)Performance Rent Credit from Ground Rent (50% of Ground Rent)$ 1,800,000 $ 2,611,000 Subtotal00Public Safety CreditsN/AN/AOther Credits$ 1,800,000 $ 2,611,000 Net Performance Rent paid to the City of Santa Clara Stadium Authority Operating Budget (cont.) Shared Stadium Manager Expenses (cont.) There are four (4) positions added to Security and one (1) position removed from Engineering:oSecurity: FTE is increasing by 4 positions•Supports enhanced stadium security measures. In 2025, all 24/7 security responsibilities were transitioned in-house and removed from third-party vendors. Armed guard services, will be provided by a third-party contractor beginning in February 2026.oEngineering: FTE is decreasing by net one position•Director of Engineering role shifted from Stadium Operations to Engineering. In addition, the Principal Project Manager and Project Manager roles were reallocated from Engineering to Stadium Operations. Eliminate the Vice President of Hospitality & Retail position.26 Stadium Authority Operating Budget (cont.)
27SecurityStadium Operations Engineering Guest Services Groundskeeping TotalTotal Compensation (2)1,732,026$ 3,066,903$ 2,127,223$ 320,577$ 124,842$ 7,371,571$ Travel, Meals & Entertainment 9,100 152,568 10,825 34,367 3,010 209,870 Outside Services 826,900 7,900 1,442,888 12,500 545,165 2,835,353 General Supplies 11,875 20,786 11,625 63,650 50,605 158,541 Telephone 22,900 336,100 8,820 1,600 458 369,878 Equipment 93,600 105,548 37,855 5,020 2,864 244,887 Uniforms 20,000 4,500 9,250 33,200 955 67,905 Other 25,000 19,900 3,745 20,575 - 69,220 Subtotal 2,741,401$ 3,714,205$ 3,652,231$ 491,489$ 727,899$ 11,327,225$ Insurance (3) 3,636,000 Management Fee (4) 285,000 Total 15,248,225$ (3) The stadium lease sets Stadium Authority's share of insurance expense at $2,550,000 for the first lease year with each succeeding lease year's expense increasing 3%.Santa Clara Stadium Authority Proportionate Share of Stadium Expenses (1)(1) The Santa Clara Stadium Authority proportionate share of stadium expenses is rounded to the nearest $1,000 in the operating budget.(4) The stadium management agreement sets the base management fee at $400,000 for the first lease year with each succeeding lease year's management fee increasing 3%. This base management fee is split 50/50 between Stadium Authority and StadCo.(2) Total compensation is based on a total of 75 full time equivalent positions.
Stadium Authority Ten-Year Forecast
28 oExcess revenues projected in each year, $16.7 million in FY 2026/27 to $9.3 million in FY2035/36•Excess revenue transfer to City’s General Fund in FY 2026/27 is projected to be $3.6 million; all years thereafter are projected to be $0 oPublic Safety Cost 2024 Outstanding Balance paid off in FY 2026/27oRenovation/Demolition Reserve not projected to be filled in the next ten yearsoOverall Stadium Authority Reserves increase from $103.5 million in FY2026/27 to $110.7 million in FY2035/36oContributions to the City’s General Fund include ground and performance rent, Senior and Youth Fees and Stadium Authority Excess Revenue.
Stadium Authority Ten-Year Forecast
29 Stadium Contribution to the General Fund(in millions)FY35/36FY34/35FY33/34FY32/33FY31/32FY30/31FY29/30FY28/29FY27/28FY26/27$1.2$1.2$1.1$1.1$1.1$1.1$1.1$1.0$1.0$1.0Ground Rent0.50.40.60.70.71.30.21.81.82.6Performance Rent0.30.30.30.30.30.30.30.30.30.2Senior & Youth Fees---------3.6Excess Revenue$2.0$1.9$2.0$2.1$2.1$2.7$1.6$3.1$3.1$7.4Total GF Impact*Assumptions surrounding revenues and expenses in future years are described in the budget document. Information presented is based on budget submissions and assumptions that will need further refinement. The reduction to contribution from excess revenue reflects potential increases in capital contributions in future years which are still pending additional staff analysis.
Stadium Authority Debt Service Budget
30BudgetDebt Type$3,744,000CFD Advance$17,226,000Term A Loan$20,970,000Total oDebt service amount of $21.0 million includes principal payment of $10.8 million and interest payment of $10.2 millionoTotal outstanding debt is projected to decrease to $199.0 millionFY 2026/27 $- $100 $200 $300 $400 $500 $600 $700Total Outstanding Debt (in millions) Construction LoanStadCo Agency AdvanceTerm B LoanTerm A LoanStadCo CFD AdvanceStadCo Subordinated Loan$41.1$396.1$653.4$561.6$464.7$429.8$382.7$340.2$325.3$296.8$245.3$228.7$280.3$219.6$209.7$199.031 Stadium Authority Debt Service Budget (cont.)70% reduction in outstanding debt from March 2014 Stadium Authority Capital Budget
32 Total Capital Budget of $22.2 millionoStadium Improvements: $20.7 million•New Projects: $10.0 millionConstruction ($6.3 million): LED Lighting Replacement, Fire Alarm Upgrade, Restroom Flushing Device ReplacementEquipment ($2.8 million): Cooling Towers, Back of House Control Panels, Amplifiers & SpeakersContingency ($910,000)•Carryover Projects: $12.2 millionConstruction ($5.8 million): Lighting Systems, Waterproofing/Caulk/Joint ReplacementsEquipment ($3.9 million): Cooling Towers, HVAC Boilers Exhaust FluesContingency ($972,000)oStadium Warranty-Related Construction: $1.5 million•Outstanding projects and claims are under review, upon confirmation that no warranty work is anticipated, funds can be allocated to general Stadium improvements Stadium Authority Capital Budget (cont.)New Capital Expenditure ProjectsoLED Lighting Replacement ($4.8 million) – Replace existing fluorescent, incandescent, and older LED fixtures with new fixtures compatible with the new lighting control system.oBack of House (BOH) Control Panels, Amplifiers & Speakers ($2.1 million) – Upgrade Outdated and failing audio control systems with modern, standardized equipment to improve reliability and performance.oFire Alarm Panel Upgrade ($682,000) – Existing system being phased out, in need of replacement. 33 Stadium Authority Capital Budget (cont.)Carryover Capital Expenditure ProjectsoLED Retrofit Project Phase 2 ($1.1 million) – Replacement of existing fixtures that are no longer manufactured and/or inefficient lighting fixtures.oBoilers ($575,000) – Replace boiler and critical support components to ensure reliable operations to support events.34 Outstanding/Pending ItemsStadium Authority Share of ManCo Office Lease 35oOther Expenses line of $1.7 million includes the Stadium Authority’s portion of office space lease expense for ManCo staff.oManCo noted in their FY 2026/27 budget submittal that Stadium Authority staff and ManCo are to meet and confer on this item.oThese costs were excluded from last year’s budget; further analysis is needed for this request.
Outstanding/Pending Items (cont.)Analysis of Carryover projects 36oThe following projects have been carried over for the past 3-9 yearsYear Project Total CostFY 2016/17 Miscellaneous 114,950$ FY 2016/17 Main Kitchen Equipment 303,555 FY 2018/19 Asphalt 181,730 FY 2019/20 Women's Locker Room 19,909 FY 2019/20 Automatic Logic Control Building Engineering System 63,221 FY 2019/20 Replace furniture for BNY Field Clubs, United, Levi's 501 & Yahoo clubs and Special Event spaces3,160 FY 2019/20 Install New Kitchen Exhaust Fans throughout the building 265,271 FY 2019/20 Install Stadium Camera Booths Card Readers 96,558 FY 2019/20 Radio Booth Cabling - Phase I 606,133 FY 2020/21 Enhance Stadium Security Access Control 270,133 FY 2022/23 Aesthetic Improvements - Premium Areas / Special Event Spaces 156,256 FY 2022/23 Miscellaneous 114,950 Total 2,195,826 oRe-allocate warranty related construction expense of $1.5 million Outstanding/Pending Items (cont.)Additional Capital Expense / Facilities Assessment 37oStadCo funded FCA to support long-term financial planning, operational efficiency, and structural integrityoThe FCA identifies necessary repairs, capital improvements, and compliance requirements•Stadium Authority has not received the FCA yet, numbers are preliminary pending SCSA analysisoPotential CapEx contributions above the contractual requirementsTotalFY 30/31FY 29/30FY 28/29FY 27/28FY 26/27$41.9M$9.0M$9.0M$9.1M$9.1M$5.7MCapital Contribution Outstanding/Pending Items (cont.)
38oThis could impact Excess Revenue distributions to the Renovation/Demolition Reserve, payment of NFL public safety costs above the threshold, and distributions to the City’s General FundoThe Renovation/Demolition Reserve is no longer projected to reach $70 million within the next ten years•The Excess Revenue distribution to the General Fund is projected at $3.6 million in FY 2026/27 with no additional distributions currently projected in subsequent yearsAdditional Capital Expense / Facilities Assessment Outstanding/Pending Items (cont.)
39oProposed Budget included funds for SCSA-directed Facility Condition AssessmentoKey Next StepsoFinalize Proposed BudgetoLaunch SCSA Facility Condition AssessmentoReview StadCo Facility Condition Assessment when finalizedoAim to reach an agreement on Long-term Capital Project NeedsoExplore options for funding options and alternativesoObtain SCSA Board Feedback and Direction (throughout the process)Additional Capital Expense / Facilities Assessment Stadium Operations and Maintenance Plan (SOMP)
40 oManagement Agreement requires the Stadium Manager to prepare a SOMP designed to achieve a safe and well-maintained Stadium. oIn addition to the Shared Stadium Expense and Public Safety Budgets, and CapEx and Marketing Plans, the SOMP includes an internal operations and maintenance plan.oThe plan is a living document and updated to reflect information on topics like Equipment and Building Maintenance Services, Building Plans, Incident Management System, Emergency Operations Plan, etc.oStaff reviewed the 2025 SOMP, provided comments, and is reviewing the 2026 SOMP to ensure prior feedback was incorporated. Feedback on this confidential document will be shared directly with the Stadium Manager. oThe SOMP is approved administratively. 2026 Marketing Plan
41 oThe Stadium Manager submitted the 2026 Marketing Plan as part of annual Budget process.oThe Stadium Authority hired a consultant to conduct market trend research on how large multi-purpose venues market and promote Non-NFL Events and complete an assessment of the 2025 and 2026 Marketing Plans. oTogether, the research and review will:oAssess current market strategiesoProvide benchmarking of stadium performanceoIdentify industry trends and areas for improvements oWork efforts are in progress and expected to be completed in Summer 2026.oFinal report will provide recommendations to enhance strategic oversight of Non-NFL Event marketing.
Stadium Authority FY2026/27 Budget Key Summary
42 oNet Non-NFL Events Revenue budgeted at $4.6 million•Lower than prior two fiscal years (FY)FY 2024/25 Actual: $10.2 millionFY 2025/26 Projection: $6.2 million•Historical performance increases from preliminary budget projectionoPublic Safety Costs (PSC) reimbursements over threshold expenditure is budgeted to be $2.5 million•$1.9 million from PSC Reserve•$0.6 million from Discretionary FundoPSC 2024 Outstanding Balance ($4.7 million in FY 2025/26, $0.8 million in FY 2026/27)•Projected to be paid off at end of FY 2026/27oBudget supports 2026 World Cup events Stadium Authority FY2026/27 Budget Key Summary (cont.)
43 oDirect payments to the General Fund at $6.6 million •Performance Rent for FY 2026/27 ($1.8 million, accrual basis)•Projected FY 2026/27 Excess Revenue ($3.6 million)•Ground Rent ($1.0 million)•Senior and Youth Fees ($248,000)oAdditional $5.7 million transfer to the CapEx fund to projects necessary to maintain the facility pending finalization of a facility condition assessment•Carryover projects adjusted to cover rising construction costs•Project contingencies has been increased from 5% to 10%•Impacts to future excess revenue transfers in out-years Recommendations
44 1. Review and Provide Input on the Proposed Santa Clara Stadium Authority Fiscal Year 2026/27 Operating, Debt Service, and Capital Budget, Draft 2026 Levi’s Stadium Events Marketing Plan, and Proposed Stadium Authority Budget, Compliance and Management Policies Santa Clara Stadium AuthorityStudy SessionProposed Santa Clara Stadium Authority FY 2026/27 Budget, 2026 Marketing Plan, and Compliance and Management PoliciesItem #1 (26-17490)February 24, 2026