A Big Deal: The 990’s Are Here for State Charters

Candid, the company which publishes the 990 IRS returns for non-profits, announced that it has loaded over one million returns for the filing years 2020, 2021 and 2022.  Candid includes the previous service provided by Guidestar.

Because state chartered credit unions receive their federal tax exemption from an IRS ruling, they must file this report annually with the IRS. The form is due  on the 15th day of the 5th month following the end of the organization’s taxable year. For most credit unions whose fiscal year ends in December, the Form 990 is required by May 15th of the following year.

Credit unions and other nonprofits with gross revenue  of less than $50,00 or total assets of smaller than $500,000 are not required to file.  A firm failing to file for three consecutive tax years will automatically lose its tax-exempt status.

In addition to the balance sheet and income statement, the report also contains details of financial, governance/compensation, business relationships and donations available nowhere else.  For credit unions some of this new information includes:

  • Officers and directors total compensation. All current and former key employees who earned over $100,000 must be listed in Part VII with the total number who were paid more than $100,000. Schedule J Parts I and II gives much more detail of compensation policies and benefits including first class travel, club fees and gross up to cover tax expenses.  Compensation is shown in multiple categories of benefits.
  • Political contributions and lobbying expenditures in Schedule C.
  • Statements with the number of directors, affirmations of policy oversight and questions of family relationships in Part VI.
  • Section C sets out how the 990 filing will be publicly disclosed.
  • Section B of Part VII lists the names of the five highest independent contractors paid $100,000. Examples would be PSCU, MasterCard, Fiserv, and Microsoft along with the total number of all firms paid more than $100,000.
  • Part IX shows expense details, not in the 5300 report, such as compensation by category of employee, travel and conference expenses, even taxes paid.
  • Schedule I provides a listing of grants to individuals, organizations and the total number of all such grants.

Transparency and Accountability

The 990 information is much more comprehensive than the financial data NCUA collects primarily for safety and soundness monitoring.   It tries to pull back the covers on a nonprofit’s use of funds both internally and with external parties.

The form runs almost 40 pages.   The additional schedules listed above provide greater details for the summary  information first shown.

Every member would be much better informed about their credit union’s operations and use of funds from this report versus the 5300.

There are two areas where the current process could be improved.

  1. The 990 filing is almost a year and a half old by the time the form is published. At the moment the latest filings are for the year ending 2021.
  2. There is only one form per year, so that multiple years are necessary to see trends, rather than just a single point in time disclosure.

Why This is a Big Deal

The following is from the June 15 Candid press release about the availability of this recent data:

Before the COVID-19 pandemic, Candid received comprehensive IRS 990 data about 1.5–2 years after the end of a given calendar year. But IRS extensions, process changes, and delays during the pandemic slowed this timeline to a frustrating crawl. We’ve dubbed this the data/crisis catch-22—the fact that the pandemic made up-to-date data more critical to access and yet also more difficult to come by.   

In fact, between August 2022 and April 2023, the IRS released very little 990 data at all. Because of this, we have been considering 990 data for fiscal years 2020 onward “incomplete”i; research leveraging 990 data for years 2020 and on required the caveat that data collection was ongoing.

Between May 5–18, 2023, the IRS released around a million 990 files. To put these numbers into perspective, in April 2023, Candid could only account for about 60k 990 filings for fiscal years 2021 and 2022 combined. 

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