Proposed Changes to Form 990; CUNA Seeks Leeway for State Charters Posted by AVCU on 11:53 AM

In a letter of comment to an IRS proposal to change Form 990, CUNA urges the IRS to make changes to reduce the compliance burden for state chartered credit unions filing IRS Form 990. Vermont state-chartered credit unions are required to file Form 990 with the IRS annually. Since they're not subject to unrelated business income taxes (UBIT) federal charters aren't required to file.


Among other things, Form 990 calls for the names and compensation of key employees such as directors, their 20 highest compensated non-executive employees, independent contractor, and former high ranking or key employees. The reporting thresholds differ by position. CUNA suggests that the threshold for former directors be increased from $10,000 in compensation to $100,000. CUNA also seeks lowering the number of high-earning, non-director employees covered by Form 990 from 20 down to 5. Reports detailing their compensation should be limited to the last 2 years, rather than the previous 5 currently required. CUNA also seeks a separate Form 990 for 501(c)(3) organizations. Today, all 501(c) organizations use the same Form 990.

CUNA's full comment letter is available here.