New Form 990-related Policies and Procedures

Policies and procedures related to the new Form 990 are linked below:

• Local branches, chapters, and affiliates (Part VI, Question 9b). If an organization had local chapters, branches or similar affiliates during the year, the Form 990 asks if there are written policies and procedures governing their activities to ensure consistency with the activities of the organization. If the answer to this question is No, an explanation is required in Schedule O as to how the organization ensures that the local unit’s activities are consistent with its own.
• Review of Form 990 (Part VI, Question 10). Organizations must describe in Schedule O the process, if any, the organization uses to review the Form 990. While no process to review the Form 990 is required, a simple procedure may be appropriate to indicate if and when the board receives the Form 990 and the process for handling questions/comments from the board.
• Conflicts of interest policy (Part VI, Question 12 a-c). Organizations are asked if they have a written conflict of interest policy, if applicable individuals are required to disclose annually interests that could give rise to conflicts (a questionnaire might accomplish this disclosure), and how the organization regularly and consistently monitors and enforces compliance with the policy. An explanation is required on Schedule O of how this is done.
• Whistleblower policy (Part VI, Question 13). Organizations are asked if they have a written whistleblower policy. 
• Document retention and destruction policy (Part VI, Question 14). Organizations are asked if they have a written document retention and destruction policy.
• Compensation approval of top management official and key employees (Part VI, Question 15 a-b).  Organizations are asked to describe on Schedule O the process for determining compensation, including a review and approval by independent persons, comparability data, and contemporaneous substantiation of the deliberation and decision relating to the organization’s CEO, Executive Director, or top management official plus other officers or key employees.
• Joint venture policy (Part VI, Question 16 a-b). Organizations are asked if they invest in, contribute assets to, or participate in a joint venture or similar arrangement with a taxable entity. If Yes, the organization is asked if it has adopted a written policy or procedure requiring the organization to evaluate its participation in joint venture arrangements under applicable Federal tax law, and taken steps to safeguard the organization’s exempt status with respect to such arrangement.
• Public inspection of Form 1023, 990, and 990-T (Part VI, Question 18). Organizations are asked how they make these forms available for public inspection. This question suggests an organization should have a procedure.
• Disclosure of governing documents, conflict of interest policy, and financial statements (Part VI, Question 19). Organizations are asked if it makes its governing documents, conflicts of interest policy, and financial statements available to the public. This question suggests an organization should have a procedure.
• Policy for the payment of a housing allowance, first class charter travel, spousal travel, gross-up payments, discretionary spending, health or social club dues, etc. (Schedule J, Question 1b).
• Gift acceptance guidelines (this link is for a document relating to both of the following items):
  • Gift acceptance policy of non-standard gifts (Schedule M, Question 31). Organizations that meet the $25,000 gifts-in-kind threshold for filing this form are asked if they have a gift acceptance policy that requires the review of any non-standard contributions.
  • Soliciting, processing, or sale of non-cash contributions (Schedule M, Question 32 a-b). Organizations that meet the $25,000 gifts-in-kind threshold for filing this form are asked if they hire or use third parties or related organizations to solicit, process, or sell non-cash contributions. If Yes, a description is required in Part II of Schedule M.