In response to a suggestion that Williams be more pro-actively transparent by posting its annual Form 990s, (then) President Shapiro disagreed and said he thought “we were transparent enough.”  That is hardly an incontrovertible view,  so in the spirit of academic discussion, that position  may be examined and challenged.

For instance, while it is true that the college (like most private colleges, but not Bennington!) posts its audited financial statements, the detail in these is poor beer compared with the coverage of specific activities shown by the Form 990.  An interesting exercise would be a comparison of these two reports and, indeed, one might be forthcoming in this EphBlog space before too long.  Such an exercise shows that valuable elements of transparency are added to the college portrait when the 990 is included in the information set.

In response to an earlier post on this subject, one comment (by Mike) argued that the Form 990 is “easy to find” (e.g., on www.Guidestar.com) and, therefore, why press the college to post its own?   Sure, the Form 990 is easy to find, but only if the user is familiar with the 990 itself, knows about the Guidestar website, and is also a registered Guidestar user.   The number of such users is not large among potentially interested parties.   Face it:   this ain’t easy or obvious for lots of people.  Whatever that degree of “ease,” however, it is surely  much much easier for colleges to simply offer these reports to their alumni and donors by simply putting them up on their websites.

By the way, the arguments deployed here with respect to Williams apply with equal force to all other private colleges and universities (represented by the National Association of Independent Colleges and Universities – NAICU, itself a nonprofit, which offers its own Form 990 here), and also to the myriads of other “charitable organizations” in the current nonprofit universe.  There are about 2 million of them, these days.  So, this is not to pick on Williams alone.

Now, Morty may think it’s a bad idea to post a college’s 990 for the world to see, but it seems some other colleges “beg to differ.”    Admittedly, the number that take this small extra step toward transparency seems to be modest, but following are some examples that EphBloggers may wish to note and take into account:

Bates College, whose form is here.

St. Olaf College, here, and wow, look at those many years of forms!

Carleton College, here (ranked right up close to Williams)

Boston College, here;

Brooklyn College Foundation (part of CUNY, here;

Marymount Manhattan College, here;

St. Martin’s University (what?), here;

Fairleigh Dickenson, here, well, sort of;

University of California, San Diego, here (another nice long run!);

Southwestern University, here,

Temple University, here;

Willamette University, here;

Now, some public universities have private foundations that help support them, and some of these foundations post their own form 990s for people to see.  An example is the Washington State University Foundation, shown here.  And the James Madison University Foundation, here.

Regrettably, so far as I can tell at present, neither Amherst nor Wesleyan, so we sure aren’t leading the Little Three  in this respect.  Also, sorry to say, not Harvard or Yale, either.  Interestingly, the Office of General Counsel at Harvard posts instructions for student organizations interested in tax exempt status, here, but doesn’t say a single word about the public nature of the Form 990 filings!  Elsewhere, Harvard does give a phone contact for the “Form 990,” but without saying what this form is!  Hmmmm.

Now, some schools may be timid about posting, but they don’t conceal  the issue.  Stanford University (a reasonably well known name) doesn’t post its Form 990, at least makes an explicit offer to provide it, here.  MIT does the same,  here.  The University of Denver does something similar, here.  And Carnegie Mellon (another pretty good name), with an extensive discussion of the 990s and its offer to provide to the public, here, just to provide a few more examples.  Also Case Western Reserve, here (but with reservations; they want to know the “intended purpose…”).   Another that calls attention to its 990 and gives guidance on how to obtain it is Tufts University, here.    And here’s Bowdoin, too, albeit with a sort of dog in the manger snarl  (“The College  is required to ….”).   And Davidson, hereNYU is in this group, too, hereHere’s Haverford, but a bit too cute for my taste.  Quite a lot of them, in fact.  Much better to post rather than point, in my view, but at least they are open about it.  No such luck with Williams, Amherst, and Wesleyan.

This list, by the way, is just a preliminary compilation.  Searching out these pro-transparency schools is a somewhat arduous task, and there are disappointments along the way, even with help from Google.   So, I hereby offer a bounty of $10 each to EphBloggers who come up with the next 10 private colleges and universities that post their Form 990s for the world to see.   You find’em; I’ll add them into the tabulation.   If we aren’t prepared to “Climb high, Climb far” alone, perhaps we can take courage in numbers and join the group!

As noted in my July 27 blog on Williams Forms 990:  Available History,  the recent Panel on the Nonprofit Sector recommends that nonprofits post their Form 990s.  This blog shows that some schools do just that.   And what does the IRS itself say about all this?   Well, here are their current training materials on the subject of Governance and Related Topics for nonprofits which, of course, includes private colleges.  To focus for a moment on the “Transparency and Accountability” section (Part 6, page 7) of this document, consider the following:

“…The Internal Revenue Service encourages every charity to adopt and monitor procedures to ensure that its Form 1023, Form 990, Form 990-T, annual reports, and financial statements, are complete and accurate, are posted on its public website, and are made available to the public upon request (emphasis added).”

So there you have it.   Even the IRS says all nonprofits should put these things up for the public to see!  Whatever else Morty accomplished at Williams, I think he was wrong on the form 990 issue.  Let’s see what happens at Northwestern, and let’s encourage the new Williams administration to rethink this position.

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