Nonprofit Annual Conflict of Interest Disclosure Process
Annual conflict of interest disclosure is required by IRS Form 990 Part VI and is a fundamental governance expectation for tax-exempt organizations. This process ensures all board members, officers, and key employees annually disclose potential conflicts and that disclosed conflicts are properly managed.
- Industry: Nonprofit
- Frequency: Annually
- Estimated Time: 1-2 hours
- Role: Board Secretary / Executive Director
- Total Items: 27
Policy Review and Currency
Verify conflict of interest policy is current.
- Written conflict of interest policy adopted by the board?
- Policy reviewed annually for currency with IRS guidance and state law?
- Policy distributed to all new board members, officers, and key employees?
- Policy covers not only board members but also key employees and senior staff?
Disclosure Form Collection
Manage annual disclosure collection process.
- Disclosure forms distributed to all covered persons?
- Clear response deadline communicated?
- Completed disclosure forms received from 100% of covered persons?
- New board members and key employees completed disclosure at onboarding?
- Completed disclosure forms filed in secure, confidential location?
Disclosure Review and Analysis
Review disclosed interests for potential conflicts.
- All disclosures reviewed by appropriate authority (board chair or audit committee)?
- Potential conflicts identified and categorized?
- Pending organizational transactions reviewed for potential conflicts?
- Related party transactions identified and reviewed per FASB ASC 850?
Conflict Management and Recusal
Manage identified conflicts appropriately.
- Recusal procedures for conflicted persons clearly defined and applied?
- Conflicted persons excluded from deliberation and voting on related matters?
- Related party transactions conducted at arm's length on market terms?
- All identified conflicts and actions taken documented in board minutes?
- Material conflicts reported in Form 990 Schedule L as required?
Education and Training
Ensure covered persons understand conflict of interest requirements.
- Board members trained on conflict of interest obligations?
- New board members receive conflict of interest training at orientation?
- Examples of common conflicts relevant to the organization's work provided?
- Annual reminder of ongoing disclosure obligation sent to covered persons?
IRS Form 990 Documentation
Verify documentation ready for Form 990 reporting.
- Documentation ready to answer Form 990 Part VI Lines 12a-12c affirmatively?
- Annual disclosure process documented for governance records?
- Schedule L data compiled for any required related party transaction disclosures?
- Changes from prior year disclosures noted and addressed?
- Audit committee or full board reviewed conflict of interest compliance?
Related Nonprofit Checklists
- New Nonprofit Board Member Orientation Checklist
- Nonprofit Board Governance Self-Assessment
- Nonprofit Whistleblower Policy Compliance and Implementation Review
- Nonprofit Annual Reporting and Compliance Calendar Audit
- Nonprofit Document Retention Policy Compliance Review
- Nonprofit Executive Succession Planning and Emergency Preparedness
- Nonprofit Volunteer Onboarding and Orientation Checklist
- Nonprofit Grant Tracking and Fund Accounting Ledger Review
Related Governance Compliance Checklists
- Nonprofit Board Meeting Preparation Checklist - FREE Download
- Nonprofit Bylaws Annual Review and Compliance Audit - FREE Download
- IRS Form 990 Annual Filing Preparation Checklist - FREE Download
- State Charitable Registration and Renewal Compliance Checklist - FREE Download
- Nonprofit Executive Director Annual Performance Review - FREE Download
- New Nonprofit Board Member Orientation Checklist - FREE Download
- Nonprofit Board Governance Self-Assessment - FREE Download
- Nonprofit Whistleblower Policy Compliance and Implementation Review - FREE Download
- Nonprofit Annual Reporting and Compliance Calendar Audit - FREE Download
- Nonprofit Document Retention Policy Compliance Review - FREE Download
Why Use This Nonprofit Annual Conflict of Interest Disclosure Process?
This nonprofit annual conflict of interest disclosure process helps nonprofit teams maintain compliance and operational excellence. Designed for board secretary / executive director professionals, this checklist covers 27 critical inspection points across 6 sections. Recommended frequency: annually.
Frequently Asked Questions
What does the Nonprofit Annual Conflict of Interest Disclosure Process cover?
This checklist covers 27 inspection items across 6 sections: Policy Review and Currency, Disclosure Form Collection, Disclosure Review and Analysis, Conflict Management and Recusal, Education and Training, IRS Form 990 Documentation. It is designed for nonprofit operations and compliance.
How often should this checklist be completed?
This checklist should be completed annually. Each completion takes approximately 1-2 hours.
Who should use this Nonprofit Annual Conflict of Interest Disclosure Process?
This checklist is designed for Board Secretary / Executive Director professionals in the nonprofit industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.
Can I download this checklist as a PDF?
Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.