PRESS RELEASE

September 19, 2007

NASCUS Comments on IRS Draft Revised Form 990

ARLINGTON, Va. — In a September 14 letter to the Internal Revenue Service (IRS), NASCUS provided comments on the draft revised Form 990.

NASCUS commends the IRS for undertaking an extensive review and revision of the Form 990. NASCUS recognizes the value of IRS’ principles in redesigning the Form 990 to enhance transparency, promote tax compliance and minimize burden on filing organizations.

However, NASCUS makes recommendations to the IRS in four areas including the implementation timelines, group 990 filings, treatment of state-chartered credit unions and privacy concerns.

NASCUS asks the IRS to extend the comment period and implementation of the draft Form 990 until at least tax year 2009. “NASCUS believes the draft Form 990 poses several unique challenges for the state credit union system and that many state-chartered credit unions and their associations have had insufficient time for complete consideration of the draft,” states the NASCUS comment letter.

Further, NASCUS recommends that the IRS retain the group filing alternative. NASCUS explains that some state regulators, or the state credit union trade associations, file a group 990 on behalf of the state credit unions. NASCUS stresses that group filings can ease the regulatory burden and provide a form of parity between state and federal credit union charters. State-chartered credit unions are the only credit unions required to complete the Form 990.

NASCUS also suggests that given state-chartered credit unions’ unique nature, a generic approach to the Form 990 might no longer be practical. State credit unions operate in a highly regulated environment and the IRS might consider evaluating whether a one-size-fits-all approach to Form 990 is appropriate. Last, NASCUS points out that privacy concerns and the diversity of the tax-exempt community prompt a reconsideration of compensation thresholds and other disclosures in the Form 990.

NASCUS appreciates the opportunity to comment on the draft revised Form 990. To view NASCUS comment letter, click here.

Information Contact:
Kate Hartig, Director of Communications, (703) 528-0669 or kate@nascus.org

The NASCUS mission is to enhance state credit union supervision and advocate a safe and sound state credit union system. Founded in 1965, NASCUS represents all 48 state and territorial credit union supervisors and the NASCUS Credit Union Advisory Council, which is made up of nearly 500 of the nation's more than 3,400 state-chartered credit unions.