Nonprofit Accounting Basics

Personal Information-It Doesn't Belong in your 990!

Note: Articles published before January 1, 2017 may be out of date. We are in the process of updating this content.

Jan 27, 2021

With identity theft an ever-growing threat, it's never been more important for exempt organizations to make sure their filings contain no personal or private information that might expose to fraud or harm, any individual or entity connected with the organization. The IRS Tax Exempt and Government Entities Group (TE/GE) reportedly has become increasingly concerned with the amount of personal identification information mistakenly included on exempt organization returns and applications. With Form 990 filing season in full swing, here's a quick reminder of what NOT to put in your returns.

Exempt organizations, unlike most taxpayers, are required to make the following returns and forms available to the public:

• Forms 990, 990-EZ, 990-PF, 990-T (charities), and 5227 (with some redactions for Schedule B)

• Approved applications for tax-exempt status - Forms 1023 and 1024

Forms 990, for example, are freely available on Guidestar; the other forms must be provided when requested by either organizations or individuals. With the exception of automatically redacted information, such as Schedule B donor names and addresses, every page of a Form 990, as filed, will be made available for the public to view.

So, remember: make sure your organization's Form 990 does not contain the following information:

• Social security numbers

• Bank account numbers

• Names (other than those absolutely required per instructions), residential addresses, dates of birth, or health status

Where might names be erroneously disclosed on the 990? Chiefly, in our observation, it would be in the "grants paid" portions of the 990. Part III of Schedule I, which lists grants and other assistance provided to domestic individuals, does not require a listing of grantee names and addresses (unlike in 2007 and prior) - only the total amount of grants by category, and the number of grantees. Part III of Schedule F, likewise, requires only dollar and recipient totals for grants to foreign individuals. Although providing more information than strictly required on a 990 may be harmless in most circumstances, on Schedule F especially, disclosure of personal grantee information could potentially threaten the safety of individuals working in unstable regions overseas.