WASHINGTON — IRS Form 990 is not appropriate for credit unions because of the many substantial differences between credit union and other tax-exempt entities.
"Credit unions are demonstrably different from charitable organizations that solicit funds from the public to support their endeavors," CUNA Senior Vice President and Deputy General Counsel Mary Dunn wrote. "As financial institutions, credit unions receive no public donations or contributions to underwrite their activities." In addition, state chartered credit unions are strictly regulated, report much of the 990 information to their regulator, and are democratically controlled by the membership.
If credit unions do have to file 990s, CUNA asked that the IRS continue allowing state regulators to file consolidated forms. Missouri, Wisconsin, and Virginia announced last week that they would no longer file group returns for the state credit unions.
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Additionally, CUNA cited specific items in the updated 990 form that raised concerns, including the draft form's request for certain person's city and state of residence raises privacy issues and the corporate governance portions are inappropriate.
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