Form 990 Schedule D, Supplemental Financial Statements, is a vital annual filing for US tax-exempt organizations, ensuring financial transparency to stakeholders and the IRS.
Purpose of Schedule D
Schedule D serves as a crucial extension to the Form 990, demanding detailed disclosures beyond the standard financial reporting. It’s designed to provide a comprehensive view of an organization’s financial health, specifically focusing on supplemental financial statements. These statements encompass areas like donor-advised funds, conservation easements, and valuable collections – art, historical treasures, and similar assets.
The primary goal is enhanced transparency, allowing the IRS and the public to assess how nonprofits manage their resources. Schedule D also requires reporting on escrow accounts, custodial arrangements, and endowment funds, offering a complete picture of financial activities. Essentially, it’s about accountability and ensuring responsible stewardship of tax-exempt funds.
Who Must File Schedule D?

Generally, nonprofit organizations filing Form 990 are potentially required to attach Schedule D. However, the necessity isn’t universal; it depends on specific circumstances outlined in the IRS filing requirements. Organizations responding “Yes” to certain questions on Form 990 Part IV – lines 6, 7, 8, 9, 10, 11a through 11f, 12a, or 12b – must complete and submit Schedule D.
These lines relate to having donor-advised funds, conservation easements, collections of art or historical treasures, escrow or custodial arrangements, or endowment funds. If an organization engages in any of these activities, detailed reporting via Schedule D is mandatory, ensuring full financial disclosure to the IRS.
Relationship to Form 990
Schedule D isn’t a standalone form; it’s an integral supplement to the core Form 990, the annual information return for tax-exempt organizations. It provides a deeper dive into specific financial areas triggered by responses on the main Form 990. Think of Form 990 as the overview, and Schedule D as the detailed supporting documentation.
Information reported on Schedule D directly impacts the overall financial picture presented in Form 990. It allows the IRS and the public to gain a comprehensive understanding of an organization’s assets, liabilities, and financial activities. Completing Schedule D accurately is crucial for a compliant and transparent Form 990 filing.

Part I: Supplemental Financial Statements Overview
Part I of Schedule D requires completion if the organization answered “Yes” to specific questions on Form 990, detailing financial aspects.
General Instructions for Part I
Part I of Form 990 Schedule D demands meticulous attention to detail. Organizations must complete this section if they responded affirmatively to questions on Form 990, specifically lines 6, 7, 8, 9, 10, 11a through 11f, 12a, or 12b.
These lines pertain to various financial disclosures, including donor-advised funds, conservation easements, and holdings of art, historical treasures, or similar assets. The IRS instructions emphasize accurate reporting of all supplemental financial information.
Organizations should carefully review the specific requirements for each line item to ensure complete and compliant filing. Proper completion of Part I is crucial for maintaining tax-exempt status and demonstrating financial accountability to stakeholders.
Reporting Requirements for Donor-Advised Funds
Schedule D necessitates detailed reporting on donor-advised funds (DAFs). Organizations maintaining DAFs must disclose information regarding contributions, earnings, grants, and administrative expenses associated with these funds. Specific reporting includes the aggregate value of contributions received during the year and the number of separate funds held.
Furthermore, organizations must report grants made from DAFs, including the amount and recipient of each grant. Accurate accounting for investment earnings and administrative costs is also essential.
The IRS scrutinizes DAF reporting to ensure compliance with regulations governing these charitable vehicles, emphasizing transparency and proper fund management.
Conservation Easements Reporting
Schedule D requires comprehensive reporting on conservation easements held by organizations. This includes detailing the initial value of each easement granted, the date of the grant, and the name of the donor. Organizations must also report any subsequent changes in the value of the easement, such as due to appraisals or modifications to the easement terms.
Detailed descriptions of the conservation restrictions imposed by the easement are crucial, outlining the permitted uses of the land and the restrictions placed upon it. Reporting ensures compliance with IRS regulations regarding charitable contributions for conservation purposes, verifying the easement’s lasting impact.
Reporting on Art, Historical Treasures, and Similar Assets
Schedule D demands detailed reporting on collections of art, historical treasures, and similar assets. Organizations must disclose acquisition costs, accession records, and any appraisals conducted to determine fair market value. This section requires outlining policies regarding the use of collection items, including exhibitions, loans, and research.
Furthermore, organizations must report conservation and preservation efforts undertaken to maintain the collection’s integrity. Adequate insurance coverage details are also essential, demonstrating responsible stewardship of these valuable assets. Accurate reporting ensures transparency and accountability regarding the management and preservation of cultural heritage.

Part II: Collections of Art, Historical Treasures, or Other Similar Assets
This part of Schedule D focuses on detailed information regarding an organization’s collections, including acquisition, accession, and significant use of items.
Acquisition and Accession Records
Organizations maintaining collections of art, historical treasures, or similar assets must meticulously document their holdings on Schedule D. This section requires a thorough accounting of how items enter the collection – detailing acquisition methods like purchases, donations, or bequests.
Crucially, organizations must maintain accession records, assigning unique identification numbers to each item upon entry. These records should include essential details such as the date of acquisition, source, and a preliminary valuation. Utilizing these records, nonprofits indicate on Schedule D if they make significant use of their collection items, impacting financial reporting and public transparency. Accurate and comprehensive records are paramount for demonstrating responsible stewardship of these valuable assets.
Use of Collection Items
Schedule D requires organizations to disclose how they utilize their collections of art, historical treasures, and similar assets. Specifically, nonprofits must indicate if collection items are exhibited, loaned for exhibition, used for educational purposes, or studied by researchers.
Checking the relevant boxes on Part III signifies significant use, impacting how the organization demonstrates its commitment to public benefit. This section isn’t about monetary value derived from the collection, but rather the extent to which the items fulfill the organization’s mission. Proper documentation of these uses is vital, ensuring transparency and accountability to stakeholders and the IRS regarding the collection’s impact and accessibility.
Conservation and Preservation Efforts
Schedule D asks organizations maintaining collections to detail their conservation and preservation activities. This includes reporting on any significant conservation work undertaken during the year, such as restoration, stabilization, or preventative care measures. Organizations must indicate if they have a documented conservation policy in place, demonstrating a proactive approach to protecting their assets.
Detailing these efforts showcases responsible stewardship and commitment to long-term preservation. The IRS assesses this information to ensure collections are adequately maintained for future generations. Accurate reporting is crucial, as it reflects the organization’s dedication to safeguarding cultural heritage and maximizing the public benefit derived from these valuable holdings.
Insurance Coverage for Collections
Schedule D requires organizations to disclose details regarding insurance coverage for their collections. This includes specifying the types of insurance held – such as all-risk, fine arts, or transit coverage – and the total value of the insured collection. Reporting the deductible amounts and any significant limitations in coverage is also essential for transparency.
Adequate insurance demonstrates responsible financial management and protects the organization against potential losses due to theft, damage, or natural disasters. The IRS reviews this information to assess the organization’s risk management practices and ensure sufficient protection of its valuable assets. Accurate reporting is vital for maintaining compliance and demonstrating sound governance.

Part III: Organizations Maintaining Collections (Continued)
This section of Schedule D details how organizations utilize collection items, requiring a check of relevant activities based on their records.
Deaccessioning Policies
Schedule D requires organizations maintaining collections to clearly articulate their deaccessioning policies. Deaccessioning refers to the removal of items from the collection, and a formal policy is crucial for transparency and accountability.
The IRS expects a detailed explanation of how decisions are made regarding the removal of assets. This includes outlining the reasons for deaccessioning – such as items no longer fitting the organization’s mission, redundancy, or poor condition – and the procedures followed.
Organizations must also disclose how proceeds from deaccessioned items are used. Typically, these funds are restricted for future acquisitions or conservation efforts, ensuring the long-term health of the collection. A well-defined policy demonstrates responsible stewardship of cultural assets.
Loans of Collection Items
Schedule D necessitates reporting on loans of collection items, detailing the terms and conditions under which assets are temporarily transferred to other institutions. Organizations must disclose the number of items loaned, the lending institutions, and the duration of each loan arrangement.
The IRS requires information regarding the purpose of the loan – for exhibition, research, or conservation – and any associated agreements. Crucially, organizations must confirm that loaned items remain insured against loss or damage during the loan period.
Proper documentation of loan agreements is essential, demonstrating responsible oversight of the collection. This ensures the organization maintains control and accountability for its assets, even when they are not physically present on-site, safeguarding their long-term preservation.
Donations of Collection Items
Schedule D requires detailed reporting on donations of collection items received by the organization. This includes a description of the donated items, the donor’s name and address, and the date of the donation. Accurate valuation of donated items is critical, following established appraisal methods.
Organizations must disclose whether the donations were unconditional, and if any restrictions were placed on the use of the donated assets. Proper documentation, including appraisal reports and donation agreements, is essential for substantiation.
Reporting donation information ensures transparency and compliance with IRS regulations, demonstrating responsible stewardship of contributed assets and adherence to ethical fundraising practices. This section helps verify the legitimacy and value of contributions received.

Part IV: Escrow and Custodial Arrangements
Schedule D demands disclosure of details regarding any escrow accounts or custodial arrangements, ensuring transparency of assets held by third parties for the organization.
Reporting Escrow Account Details
Organizations utilizing escrow or custodial arrangements must provide comprehensive details on Schedule D. This includes identifying the escrow agent or custodian, specifying the nature of the arrangement, and detailing the assets held within the account.
Specifically, nonprofits need to report the total amount held in escrow, the purpose for which the funds are being held, and any restrictions placed on their use. Accurate reporting is crucial for demonstrating responsible financial stewardship and ensuring compliance with IRS regulations.
Furthermore, organizations should disclose the terms of the escrow agreement, including conditions for release of funds. This section aims to provide a clear picture of any off-balance-sheet assets and potential liabilities associated with these arrangements, fostering transparency and accountability.
Custodial Arrangements Disclosure
Schedule D requires detailed disclosure of any custodial arrangements held by the organization. This encompasses situations where a third party holds assets on behalf of the nonprofit. Reporting necessitates identifying the custodian, outlining the arrangement’s purpose, and specifying the types of assets under their control.
Organizations must clearly articulate the terms governing the custodial agreement, including any limitations on accessing or utilizing the held assets. Transparency regarding these arrangements is paramount for demonstrating sound financial oversight and adherence to IRS guidelines.
Complete disclosure ensures stakeholders understand how the organization manages its assets and mitigates potential risks. Accurate reporting of custodial arrangements contributes to a comprehensive financial picture, bolstering public trust and regulatory compliance.

Part V: Endowment Funds
Schedule D demands reporting on endowment fund details, including investment and spending policies, providing insight into long-term financial stability and asset management practices.
Reporting Endowment Fund Information
Organizations utilizing endowment funds must provide comprehensive details on Schedule D. This includes reporting the fair market value of endowment assets, both at the beginning and end of the reporting period. Specifically, nonprofits need to delineate the composition of these funds, categorizing them by asset class – such as cash, stocks, bonds, and alternative investments.
Furthermore, the schedule requires disclosure of any significant changes in endowment value during the year, stemming from investment gains or losses, contributions, or withdrawals. Detailed information regarding related party transactions involving endowment funds is also crucial for maintaining transparency and accountability. Accurate reporting ensures stakeholders understand how these funds are managed and utilized to support the organization’s mission.
Investment Policies for Endowment Funds
Schedule D necessitates a clear articulation of an organization’s investment policies governing its endowment funds. This includes outlining the overall investment strategy, encompassing asset allocation targets and risk tolerance levels. Nonprofits must detail their approach to diversification, specifying permissible investment types and any restrictions imposed.
Crucially, the schedule requires disclosure of the criteria used for selecting investment managers and monitoring their performance. Organizations should also describe their process for periodically reviewing and updating these policies to ensure alignment with their long-term financial goals and fiduciary responsibilities. Transparency in investment policy demonstrates responsible stewardship of endowment assets.
Spending Policies for Endowment Funds
Schedule D demands detailed reporting on an organization’s spending policies for endowment funds. This includes specifying the percentage of the endowment that is available for spending each year, often guided by a prudent spending rate. Nonprofits must clarify how spending decisions are made, outlining any specific purposes for which endowment funds can be utilized.

The schedule requires disclosure of any formulas or guidelines used to determine the annual spending amount, ensuring consistency and accountability. Organizations should also describe their approach to handling underwater endowments, detailing any adjustments made to spending policies during periods of market decline. Clear spending policies demonstrate responsible endowment management.

Part VI: Other Supplemental Information
Schedule D’s Part VI requests additional financial disclosures, net asset reconciliation, and significant accounting policies used by the organization for clarity.
Additional Financial Disclosures
This section of Part VI on Schedule D (Form 990) allows organizations to provide further details beyond the standard financial statements. It’s crucial for complete transparency, enabling stakeholders to gain a comprehensive understanding of the nonprofit’s financial health. Organizations might disclose information regarding significant unusual or infrequent transactions, contingent liabilities not previously reported, or details about related-party transactions that require further explanation.
These disclosures ensure compliance with accounting standards and provide context for interpreting the financial data presented elsewhere on the Form 990. Thorough completion of this section demonstrates a commitment to accountability and responsible financial management, fostering trust with donors, regulators, and the public. Accurate and detailed disclosures are essential for maintaining the organization’s tax-exempt status.
Reconciliation of Net Assets
Part VI of Schedule D (Form 990) requires a detailed reconciliation of net assets, bridging the gap between the beginning and ending balances reported on the statement of financial position. This involves explaining changes in net assets, categorized by restricted and unrestricted funds. Organizations must clearly outline increases due to revenue and gains, and decreases resulting from expenses and losses.
This reconciliation provides crucial insight into how the organization’s financial position evolved throughout the year. It demonstrates adherence to accounting principles and ensures the accuracy of reported figures. A well-prepared reconciliation helps stakeholders understand the sources and uses of funds, promoting transparency and accountability. Proper completion is vital for maintaining compliance with IRS regulations and demonstrating sound financial stewardship.
Significant Accounting Policies
Schedule D (Form 990), Part VI, necessitates a comprehensive disclosure of the organization’s significant accounting policies. This section demands a clear articulation of the methods used for revenue recognition, depreciation, and the valuation of assets, including those within collections. Organizations must detail their policies regarding contributions, including any restrictions placed on donated funds.
Transparency in accounting policies is paramount for understanding the financial statements. This disclosure allows stakeholders to assess the consistency and reliability of reported information. It also demonstrates adherence to Generally Accepted Accounting Principles (GAAP). Accurate and thorough documentation of these policies is crucial for IRS review and ensures accountability in financial reporting practices;

Resources and Further Information
Schedule D guidance is available on the IRS website and through resources like Tax990; consult a tax professional for tailored advice.
IRS Website for Form 990
The Internal Revenue Service (IRS) website is the primary source for all official Form 990 Schedule D related materials. You can find the current version of the form, along with detailed instructions, directly on IRS.gov.
Navigating the IRS website allows access to frequently asked questions, relevant publications, and updates regarding filing requirements. Specifically, search for “Form 990 Schedule D instructions” to locate the most pertinent documentation. The IRS provides comprehensive guidance on completing each section of the schedule, ensuring accurate reporting of supplemental financial information.
Tax-exempt organizations can also find information regarding deadlines, penalties, and other important compliance matters. Utilizing the IRS website ensures adherence to the latest regulations and best practices for Schedule D filing.
Tax990 Resources
Tax990 offers a valuable collection of resources dedicated to assisting nonprofits with Form 990 Schedule D compliance. Their website (Tax990.org) provides updated information, including articles explaining the purpose and filing requirements for Schedule D, as of August 21, 2024.
You’ll find detailed guidance on completing the schedule, covering topics like donor-advised funds, conservation easements, and reporting on art collections. Tax990 simplifies complex IRS regulations, making it easier for organizations to understand their obligations.
Furthermore, they often provide summaries of recent changes to the form and instructions, ensuring nonprofits stay current with the latest requirements. This resource is particularly helpful for navigating the nuances of supplemental financial reporting.
Professional Tax Advisor Consultation
Navigating Form 990 Schedule D can be complex, particularly regarding specialized areas like art collections, endowments, or escrow arrangements. Consulting a qualified professional tax advisor is highly recommended to ensure accurate and compliant filing.
An experienced advisor can provide tailored guidance based on your organization’s specific financial situation and activities. They can assist with interpreting IRS instructions, identifying applicable reporting requirements, and preparing the schedule correctly.
Professional advice minimizes the risk of errors, potential penalties, and ensures adherence to evolving tax laws. Seeking expert help is a prudent investment for maintaining your organization’s tax-exempt status and financial integrity.
