Advancement · Grants and Funding

Every interest disclosed,
every year, on the record.

Log each board member’s annual statement and outside interests. The organizer flags statements more than a year old, interests that involved business with your organization and need a review with the member out of the room, and anything still to clarify.

Add a disclosureWhat you get
$12one-time · every device you sign in on
Buy · $12

Included with Caveat Classroom and Whole-school licenses. Or get it in the Grant writer’s desk, $49 for 32 items.

Disclosures

The worked example is made up: a treasurer whose bank holds the operating account and whose spouse works for a contractor, with last year’s statement overdue, and a chair with one interest and no business. Records save on this device only.

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What you get

Advancement · Grants & Funding$12 · included with Classroom and Whole-school licenses

What you finish with
A record per member’s annual disclosure with initials, role, year and signing date; each outside interest with organization, relationship, description and whether there was business this year; four policy steps; counts of current statements and transactions; flags for overdue statements, transactions to review and interests to clarify.
Who it is for
Board chairs and secretaries, executive directors, school foundation and PTA boards, and staff who prepare governance records and the Form 990.
Format
Browser organizer with a saved record per disclosure. Prints a member’s disclosure, the whole board as a table for the annual review or a blank disclosure form; downloads a spreadsheet (.csv); exports and imports a file.
Access
$12 one-time, yours on every device you sign in on; the tool opens once you are signed in with it. Included with Caveat Classroom and Whole-school licenses. Also in the Grant writer’s desk ($49) and the Advancement Suite pass ($99), and 1 more bundle. Everything you type stays in this browser; nothing is sent to Caveat.
Where it lives
The Grants & Funding space in Caveat Advancement.
Support
Questions about access, an order or a correction: team@caveatacademic.com.

How to use it

  1. Hand each member the policy and a blank form at the start of the year.
  2. Log each signed statement and every interest it lists.
  3. Bring any interest with business this year to the board, with the member out of the room.
  4. Record the review and any recusal in the minutes.
  5. Print the board table for the annual governance review.

Add a disclosure

Disclose, step out, review, record

How a disclosed interest is handled1DiscloseThe member tellsthe board aboutthe interest, inwriting, everyyear andwhenever itcomes up.2Step outThe memberleaves thediscussion andthe vote on thatmatter.3ReviewThe othermembers comparethe deal withalternatives anddecide whetherit is fair totheorganization.4RecordThe minutes notethe disclosure,who stepped out,what wascompared and thedecision.How a disclosed interest is handled1. DiscloseThe member tells the board about theinterest, in writing, every year andwhenever it comes up.2. Step outThe member leaves the discussion andthe vote on that matter.3. ReviewThe other members compare the dealwith alternatives and decide whetherit is fair to the organization.4. RecordThe minutes note the disclosure, whostepped out, what was compared and thedecision.
A conflict of interest is not wrongdoing in itself. Handling it in the open, every time, is what protects the member and the organization.

What the Form 990 asks

Part VI of the Form 990 asks whether the organization has a written conflict-of-interest policy, whether officers, directors and key employees must disclose interests that could give rise to conflicts every year, and whether the organization regularly and consistently monitors and enforces the policy. An organized annual disclosure process is how a board can answer yes and mean it.

Transactions with insiders

A deal with a board member’s business can be perfectly fair, but it needs to be shown to be fair. Federal tax rules on excess benefit transactions give boards a way to do that: approval by members without a conflict, a comparison with what similar deals cost, and a written record made at the time.

Sources

  1. Internal Revenue Service. Instructions for Form 990, Part VI, lines 12a to 12c: conflict-of-interest policy, annual disclosure and monitoring (irs.gov).
  2. Internal Revenue Service. Instructions for Form 1023, Appendix A: sample conflict-of-interest policy (irs.gov).
  3. United States Code, 26 U.S.C. 4958, and Treasury Regulations 53.4958-6: excess benefit transactions and the rebuttable presumption of reasonableness.
  4. National Council of Nonprofits. Conflict of interest policies for nonprofit boards (councilofnonprofits.org).

The worked example is made up. Your bylaws, your policy and state nonprofit law govern; public school boards follow state ethics laws instead. This is not legal or tax advice. Nothing you type is sent to Caveat. Support: team@caveatacademic.com.