How hard do we have to look for the information requested in Parts III and IV of Schedule L, Form 990, regarding assistance to and business transactions with interested persons? What if we are unable to obtain and report all of that information?
The organization need not engage in more than a reasonable effort to obtain the information needed to answer these questions. An example of a reasonable effort would be for the Form 990, Schedule L preparer, or an officer eligible to sign the Form 990, to distribute a questionnaire annually to each of its current or former officers, directors, trustees, key employees, and grant selection committee members, asking for the information that needs to be reported in Parts III and IV. The questionnaire could include the name, title, date and signature of the person reporting information. The organization may rely on information it obtains in response to such a questionnaire in answering the questions in Parts III and IV.