Janet: The reference in the FFATA guidance is the confirmation that
your 990 meets the public reporting requirement [Section 170.110(b)(3)].
Section 6104 directs you to make your 990, including the compensation
data available to the public upon request. [Code 26 USC 6104(d)] Thus,
the confirmation that the 990 meets the requirement is in the text of
the OMB Guidance. Okay?
Carol Blum
Director, Research Compliance and Administration
Council on Governmental Relations (COGR)
1200 New York Ave., NW, Suite 750
Washington DC 20005
202-289-6655, ext. 17
xxxxxx@cogr.edu
-----Original Message-----
From: Research Administration List [mailto:xxxxxx@hrinet.org] On
Behalf Of Holmberg, Janet
Sent: Thursday, October 14, 2010 5:34 PM
To: xxxxxx@hrinet.org
Subject: [RESADM-L] FFATA
Hi all -
I have gone through all the FFATA guidance I can find and am still
unclear about one thing. I work for a 501c3 and our top 5 executive
salaries are disclosed yearly on our IRS 990 form. Per our CFO, we are
exempt from reporting compensation, and I THINK that is correct under
the IRS code. But, I can't find anything definitive to confirm that the
990 meets the requirement and a quick skim of the IRS code just left me
confused. I'm sure someone out there can point me to the exact place to
find the language. I really appreciate the help!
janet
Janet Holmberg
Grants & Contracts Specialist
Lovelace Respiratory Research Institute
505 348-9507
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