BOARD AND COMMITTEE MEETING MINUTES.

Did the organization contemporaneously document the meetings held or written actions undertaken during the year by…A. The governing body? and B. Each committee with authority to act on behalf of the governing body?

If listed as true, “the organization contemporaneously documented…every meeting held and written action taken during the organization’s tax year by its governing body and committees with authority to act on behalf of the governing body.

If listed as false, “the organization did not contemporaneously document…every meeting held and written action taken during the organization’s tax year by its governing body and/or committees with authority to act on behalf of the governing body…explain…the organization’s practices or policies, if any, regarding documentation of meetings and written actions of its governing body and committees with authority to act on its behalf.”

The letter “F” also appears if the organization had no committees.

INTERNAL REVIEW OF FORM 990.

The answer is T for true “only if a complete copy of the organization’s final Form 990 (including all required schedules), as ultimately filed with the IRS, was provided to each person who was a voting member of the governing body at the time the Form 990 was provided, whether in paper or electronic form, before its filing with the IRS.” “Describe…the process, if any, by which any of the organization’s officers, directors, trustees, board committee members, or management reviewed the prepared Form 990, whether before or after it was filed with the IRS, including specifics about who conducted the review, when they conducted it, and the extent of any such review.

If no review was or will be conducted, enter “No review was or will be conducted.”

CONFLICT OF INTEREST POLICY.

Entry of “T” for True indicates that “as of the end of the organization’s tax year the organization had a written conflict of interest policy. A conflict of disclosure of information that can help identify conflicts of interest, and specifies procedures to be followed in managing conflicts of interest.”

CONFLICT OF INTEREST STATEMENT REQUIRED OF SENIOR STAFF.

The letter “T” indicates that “the organization’s officers, directors, trustees, and key employees are required to disclose or update annually (or more frequently) information regarding their interests and those of their family members that could give rise to conflicts of interest, such as a list of family members, substantial business or investment holdings, and other transactions or affiliations with businesses and other organizations and those of family members.”

CONFLICT OF INTEREST STATEMENT OF SENIOR STAFF IS MONITORED.

If marked “T” for True, “describe…the organization’s practices for monitoring proposed or ongoing transactions for conflicts of interest and dealing with potential or actual conflicts, whether discovered before or after the transaction has occurred.

“The description should include an explanation of which persons are covered under the policy, the level at which determinations of whether a conflict exists are made, and the level at which actual conflicts are reviewed.

“Also explain any restrictions imposed on persons with a conflict, such as prohibiting them from participating in the governing body’s deliberations and decisions in the transaction.”

WHISTLEBLOWER POLICY

“A whistleblower policy encourages staff and volunteers to come forward with credible information on illegal practices or violations of adopted policies of the organization, specifies that the organization will protect the individual from retaliation, and identifies those staff or board members or outside parties to whom such information can be reported.”

DOCUMENT RETENTION AND DESTRUCTION POLICY

“A document retention and destruction policy identifies the record retention responsibilities of staff, volunteers, board members, and outsiders for maintaining and documenting the storage and destruction of the organization’s documents and records.”

PROCESS FOR SETTING SALARY OF SENIOR OFFICIALS

“Did the process for determining compensation of [senior officials] include a review and approval by independent persons, comparability data, and contemporaneous substantiation of the deliberation and decision?

“If marked “T” for True, “describe the process…, identify the offices or positions for which the process was used to establish compensation of the persons who served in those offices or positions, and enter the year in which this process was last undertaken for each such person.

A “T” for true appears “if, during the tax year, the organization used a process for determining compensation … of [senior management] that included all of the following elements.
“• Review and approval by a governing body or compensation committee,
“• Use of data as to comparable compensation for similarly qualified persons in functionally comparable positions at similarly situated organizations.
“• Contemporaneous documentation and record keeping for deliberations and decisions regarding the compensation arrangement.”

DISCLOSURE OF DOCUMENTS

“Explain…whether the organization made its governing documents …, conflict of interest policy, and financial statements…available to the general public during the tax year, and if so, how it made them available to the public…

“If the organization didn’t make any of these documents available to the public, enter ‘No documents available to the public’…Federal tax law doesn’t require that such documents be made publicly available unless they were included on a form that is publicly available.”