Commission Recommendations - Churches, Accountability, and Donor Engagement

Religious and Charitable Organizations

  1. Churches should be appropriately accountable to their members, congregants, and financial supporters. Churches and their leaders should consider public reaction and damage caused by activities, transactions, or arrangements that the public perceives as lavish, extravagant, excessive, or unreasonable. Churches and their leaders should not engage in abusive financial activities, nor should they improperly exploit the exemption from filing Form 990, because doing so undermines the credibility of their organizations and the religious community as a whole. Abuses also result in threats to the important tax exemptions and benefits that are available to religious organizations. Churches should, as a best practice, establish appropriate measures to verifiably demonstrate (through independent accreditation by a bona fide accrediting organization, denominational oversight, or by other appropriate methods) to their members, congregants, and financial supporters that they have adequate and proper oversight regarding financial activities and that they do not engage in or tolerate abusive activities.

The Giving Public

  1. Financial supporters (donors) of religious or other nonprofit organizations should be appropriately engaged in the process and should take the necessary actions to make informed giving decisions. A donor should seek or request from a church such information about its financial and other activities as the donor believes appropriate. A donor should evaluate the information available about a church’s activities and/or its response, or lack of response, to requests for information in making a wise giving decision. Put simply, our message to donors is "Know the organizations you support."


  1. The IRS and Treasury Department should rectify the matter of identifying an appropriate "high-level Treasury official" for the purpose of properly administering the Church Audit Procedures Act (Code Section 7611).


  1. Congress should never pass legislation requiring churches to file Form 990 or any similar information return or form with the federal government. To require such a filing would not only place a substantial and unnecessary burden on churches and the government, it would also raise significant constitutional concerns. New churches should not have registration or notification requirements beyond those that already exist.