Board Review of 990 Prior to Filing

Posted on Wednesday, November 02, 2016

Line 11(a) of Part VI, Governance, Management, and Disclosure of Form 990, Return of Organization Exempt From Income Tax, asks “has the organization provided a complete copy of this Form 990 to all members of its governing body before filing the form?” 

Although it is not required under law to provide a copy of your organization’s Form 990 to the governing body prior to filing, it is a best practice for every nonprofit to have in place.  This question is required to be answered on Form 990 because the IRS considers such policy to generally improve tax compliance.  But have you properly provided your 990 to your board to answer this question “yes”?

Organizations may only answer “yes” to this question if the folfolowing have been done.

·        The copy must be the final version filed with the IRS.  (Written or electronic copies are permitted).

·        The copy must include all required schedules.

·        The copy must be provided to each person that was a voting member of the governing body at the time the  Form 990 was provided.

·        The copy must be provided prior to the filing of the return with the IRS.

If the organization only informs the governing board members that a copy of the Form 990 is available upon request, it cannot answer “yes” to this question.  If any information is excluded or redacted from the copy provided to the governing board (i.e. donors’ names and addresses from Schedule B), the organization cannot answer “yes.”

If your organization must answer “no” to this question, you may add an explanation in Schedule O as to the reason why. 

See our previous blog, Board Review of Form 990, for items that your board should be looking for during their review of Form 990.

Posted by: Carrie Minnich, CPA

Posted in Mission Minded Nonprofits

Disclaimer: The information contained in Dulin, Ward & DeWald’s blog is provided for general educational purposes only and should not be construed as financial or legal advice on any subject matter. Before taking any action based on this information, we strongly encourage you to consult competent legal, accounting or other professional advice about your specific situation. Questions on blog posts may be submitted to your DWD representative.

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