Resources for Community Development

“Form 990 review process: a draft of the form 990 is reviewed by the controller. After any necessary corrections are made, an electronic copy is e-mailed to the board and the executive director. A meeting of the executive committee of the board is called to review and approve the form 990. Staff input is provided to answer questions and provide any additional information requested.”

“Explanation of monitoring and enforcement of conflicts: all board members, officers, and key employees are required to complete an annual questionnaire which asks them to disclose if they, their family members, any entity where they or their family member owned more than 35% or any profit entity where they or their family member owned more than 5% engaged in any business transactions over $10,000 with rcd or any of its related entities. It also asks whether they had a family or business relationship with any other board member or key employee. Rcd's bylaws and personnel handbook govern how actual or apparent conflicts of interests that may impact the organization's staff or board of directors are handled. Staff are to avoid even the appearance of a conflict of interest, and gifts and remunerative activity related to rcd duties are strictly limited. The bylaws require that no member of the board of directors shall have any financial interest in an organization doing business with rcd without disclosure to the board. At that point, the majority of the board must vote on a finding that the organization could not obtain a more advantageous arrangement with reasonable effort, that the transaction is to the benefit of the organization, and it is at a fair and reasonable price.”

“Rcd has instituted a process to determine fair compensation for its ceo and key employees as follows: the ceo's performance and compensation is evaluated annually by an executive committee of the board of directors. The executive committee is provided with third-party compensation studies for the ceo role by the cfo. The executive committee then determinates the ceo's salary based on the information provided, independent research it may undertake, and ceo performance. Non-ceo compensation for officers and key employees are approved by the ceo based on a combination of third-party compensation studies and employee performance.”

“The organization does not make its governing documents, conflict of interest policy and financial statements available to the general public because the organization considers them to be internal documents.”

“All projects that rcd enters into must fall within our mission to develop and operate rent restricted affordable housing and be compatible with our tax-exempt status. All projects must be approved by the internal oversight committee and the board housing and finance committee. Any joint venture that we enter into with a taxable entity would be governed by a partnership agreement to ensure that their operations are consistent with rcd's tax-exempt mission.”

“Policy re: fasb 116 and 117: starting with fiscal year 6/30/95, organization resources for community development (rcd) has elected to follow fasb 116 & 117. We have determined that under fasb 116 & 117 amounts paid by a governmental unit do not qualify as contributions but rather as exchange transactions, because the government is in the business of providing services to the general public. That income is shown on the financial statements as government contracts rather than as contributions. Therefore we have recorded these amounts as income when earned instead of when we received an unconditional promise to pay. However, on form 990 and schedule a, in accordance with irs regulations, we have classified as contributions amounts received from a governmental unit, since all funds received by rcd from the government are for the purpose of providing a service to the general public. Furthermore, in order to keep the total income on the tax return consistent with the financial statements, we are not recognizing on the form 990 the future income that fasb 116 would require. This is consistent with the irs position that reporting grants received in accordance with fasb 116 for 990 purposes is acceptable but not required. Ref: irs 1995 publication 557, chapter 3, page 28, support from a governmental unit; 1995 form 990 instructions, page 1, changes to note; and 11/14/96 conversation with lynn kawecki, irs exempt organization division, washington office.”

“The process has not changed from prior years.”