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How-to guide

How to track who's filed their conflict-of-interest disclosure

Collect a signed conflict-of-interest statement from every director and officer once a year, and keep a running list of who has filed and who hasn't so you can chase the stragglers. The IRS Form 990 asks whether you require annual disclosure and whether you monitor compliance — a list you can produce on demand is how you answer “yes” truthfully.

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The Steps

  1. 1

    Send the Statement to Everyone Once a Year

    Every director and officer — and covered committee members — signs annually. Send it on a set date each year so it's a routine, not a scramble.

  2. 2

    Track Filed vs. Outstanding

    Keep one list showing who has signed and who hasn't. “Who hasn't filed their COI?” should be a glance, not an email audit.

  3. 3

    Chase the Outstanding Few

    With the list in front of you, follow up with just the people who haven't filed — not a reminder to the whole board that the diligent members ignore.

  4. 4

    Keep the Signed Records

    Store the signed statements with the board records, dated. When the 990 preparer or an auditor asks, you produce the file rather than reconstructing it.

What you end up with

A current list of exactly who has and hasn't filed this year's disclosure, with the signed statements on file behind it — instead of a folder of PDFs and no idea who's missing.

And It’s Already on the Dashboard.

Completion tracks straight onto the board's governance dashboard, so conflict-of-interest status for the whole board is a live number — and the answer to the 990's question is already documented.

That’s the shift: the same task you already do turns into governance the board can see on Board Pulse, with nothing else to upload.

See It on Your Own Board’s Data.

Nonprofit Liaison runs this task — and the rest of the board’s cycle — in one place, flat-priced from $99/mo. Take a look in about twenty minutes.