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Form 990 Part VI - Governance - Due Diligence to Obtain Information about Governing Members, Officers, and Key Employees

How hard do we have to look for the information requested in Questions 1 and 2 of Form 990, Part VI regarding independent directors and business and family relationships among Board members, officers, and key employees?  What if we are unable to obtain and report all the reportable information?

As described in the instructions, the organization need not engage in more than a reasonable effort to obtain the necessary information to answer these questions.  An example of a reasonable effort would be for the Form 990 preparer or an officer eligible to sign the Form 990 to distribute a questionnaire annually to each of the organization’s officers, directors, trustees, and key employees asking for the information that needs to be reported in response to Questions 1 and 2. The questionnaire could include the name, title, date, and signature of the person reporting information, and contain the Form 990 Glossary definitions of independent voting member of governing body, family relationship, business relationship, and key employee.  The organization may rely on information it obtains in response to such a questionnaire in answering Questions 1 and 2.