Exempt Organizations Annual Reporting Requirements - Form 990, Schedule L

The questions below relate to Schedule L, Transactions with Interested Persons, to Form 990, Return of Organization Exempt From Income Tax.

  1. Do all Form 990 and Form 990-EZ filers need to file Schedule L?
  2. What types of transactions are reportable on Schedule L, Form 990?
  3. Should our board member’s purchase on the open market of tax-exempt bonds that we issued be reported as a loan in Schedule L, Part II, Form 990?
  4. One of our governing board members is the president of a bank in which our organization has an account. We earn interest on the deposits, and pay fees to the bank throughout the year. Should this transaction be reported in Part II and/or Part IV of Schedule L, Form 990?
  5. Must our organization, a primary school, report in Schedule L, Part III, Form 990 the name of one of our officer’s family members to whom we granted a scholarship?
  6. We compensate our chief financial officer $110,000 and the CFO’s spouse (an employee) $20,000. Must we report one or both of these transactions in Schedule L, Part IV, Form 990?
  7. We don’t have enough room on Schedule L, Form 990, to include all of the information requested, such as a description of business transactions (Part IV) or the purpose of a loan (Part II). Must we limit our response to the space provided on Schedule L?
  8. 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?
  9. Our organization made payments during the year to someone who would be reported on Schedule L, Part IV, except that they do not reach the minimum dollar thresholds for that part. Should we answer Yes on line 28 of Part VI of Form 990 and note on Schedule L that the payment is below the reporting threshold? Or should we answer No on line 28 and not complete Schedule L?
  10. Form 990-EZ does not include a governance section.  However, Question 34 asks about changes to organizing documents.