Exempt Organizations Annual Reporting Requirements - Form 990, Parts I-V: Reporting Transactions with Interested Persons (Schedule L)

 

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 IV 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?

The answer should be No.  An organization is not required to answer Yes to a line in Form 990, Part IV, and complete the schedule (or Part of a Schedule) to which the question is directed if the organization is not required to provide any information in the schedule (or part of the schedule).  Thus, a minimum dollar threshold for reporting information in a Schedule may be relevant in determining whether the organization must answer Yes to a line in Form 990, Part IV.