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Some Beg to Differ

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 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.

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The 2008 Form 990 Debuts on Guidestar

The Williams Form 990 for Fiscal 2008 (viz., July 1, 2007 to June 30, 2008) finally showed up on the Guidestar website yesterday, almost 14 months after the end of the reporting period.    For those, like myself, who think this document is very useful and affords more detailed insight into the finances and activities of the college, this is too long a wait.

For the last several years Williams has been filing its Form 990 with the IRS at the very outer limit of the permitted reporting window, around mid-May of the following fiscal year.   That is, the 4 1/2 month normal reporting limit,  plus the 3 month extension granted automatically on request, plus a second (and final) extension, which must also be requested by the reporting institution.   That makes the 10 1/2 months of “reporting lag.”   Add in the ca. 2 1/2 to 3  months it requires for Guidetar (and others) to acquire this material from the IRS Ogden office, and that accounts for the approximately 14 months before this material becomes “publicly visible” to interested parties on any website.

Some other colleges and universities do better, by filing earlier and themselves posting these documents on their own websites, something that will be detailed in a subsequent post in this space.

Compare the 10 1/2 month reporting delay and almost 3 month posting lag for Williams with the availability of the college’s audited financial statments, the latest of which was signed by the auditors on September 18, 2008, less than 3 months after the close of the 2008 fiscal year.  These, to be sure, are posted, albeit discretely, on the college website, although exact date of posting is not clear to me.  In fact, almost all colleges and universities I have reviewed seem to put these accounts up for their constituency to see.  But not Bennington!


Morty says “No” to Greater Financial Transparency: the Background

In a post on EphBlog (my first) on July 20, I recounted briefly how Williams President Shapiro said “No” to my suggestion that Williams  promote greater financial transparency by posting its annual Forms 990 on the college website.  The current post gives the background to the story and, of course, expresses the hope that Williams, under new administration, will “come around” and see the issue from a different perspective.

The Form 990, as data nerds know, is the annual information return filed by the majority of 501(c)(3) nonprofit, “charitable” organizations with the IRS.  Williams and other private colleges are among those organizations.  These forms are to be filed within 4 ½ months after the end of the nonprofit’s fiscal year which, in the case of most educational establishments, is end-June.  In certain circumstances a nonprofit can get up to six months additional time to file, but within at most 10 ½ months after fiscal year end, the 990s should be in hands of the IRS.

It is useful to note that a Form 990 is, by law, a public document.   The filing institution is obliged to make it available on request and/or provide a hard copy at cost, of the most recent three years’ reports.  The IRS will also furnish a copy if contacted using Form 4506-A, Request for Public Inspection or Copy of Exempt or Political Organization, the title of which is, yes, a bit of a mouthful.  For those “in the know,” recent Forms 990 can also be downloaded from (the nom de web of Philanthropic Research, Inc.) and a couple of other sites.  But, there are substantial lags before these documents make it to GuideStar, and in some cases they are not very timely when they get there.  In the case of Williams, it has frequently been a year to a year and half (measured from fiscal year end) before Form 990 filings make it to the GuideStar site.

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Williams Forms 990: Available History

This post updates the Available History on Williams Forms 990 with the 2008 report, recently obtained by Ronit Battacharyya from the Treasurer’s Office (hard copy, yuk!) and kindly provided for posting purposes.  Scanned by Ronit; OCR’d by myself.  (Hard copy requested from the IRS with Form 4506-A, mailed on 7/20/09, arrived on 8/13/09.)

The purpose of the current tabulation is to make available in one place the Forms 990 filed with the IRS by Williams in recent years.   At the present time, those for the period 1998-2008 are available, but as of 8/15/09 the 2008 filing is not yet on Guidestar.   Guidestar presently provides 3 years of Form 990s to “non-premium” members; the rest in this collection come from my private archive.  As new filings become available on the Guidestar website ( ), or from Williams directly,  it is proposed to add these, so that the time series of recent filings is gradually extended   This post is marked “no comments” to preserve the presentation from accumulating clutter.   EphBlog users are welcome/invited to provide their own posts/comments on the contents of Williams’ Form 990 filings as separate contributions in the Form 990 Category of the EphBlog.

Williams College is a 501(c)(3) nonprofit organization under the IRC and, as such, files a Form 990 information return annually with the IRS.  These are public documents.  Nonprofits are required to make their returns available for public inspection on request, or provide copies of them, at cost, for a period of three years.  The IRS requires nonprofits to file their returns within 4 1/2 months after fiscal year end, with the possibility of an automatic extension, on request, for 3 months and a further 3 month extension, at IRS discretion thereafter.   Thus, within ca. 10 1/2 months after the end of the nonprofit’s fiscal year, reports must be in the hands of the IRS.  As noted below, Williams has been filing electronically for the last few years.  The IRS also recommends that nonprofits post their Form 990s on their websites.

The forms tabulated below are in the more or less stable format in use up until 2007.   Beginning with reports filed for 2008ff (after several years of deliberation) the format of the Form 990 was revised and expanded in certain respects.   Williams Form 990s for this new regime are not yet available.  The 2009 Form 990 presumably will be in the new format.

Note that each Williams Form 990 covers the fiscal year from July of the previous year to June of the current year so, e.g., Form 990 for “2007”  is the report for the period July, 2006 through June, 2007.  It is typically more than a year before the Williams Form 990s show up on Guidestar (some institutions are a good bit faster!).   This has to do with submission deadlines, sometimes delayed by requested extensions, and scanning/processing as nonprofit results are conveyed to Guidestar (aka Philanthropic Research Inc.)

Each of the Forms 990 included below should be in “searchable pdf” format — produced from IRS scans by the OCR in Acrobat 8 — for those who like to go right to some issue or other.  In this update of the post, I have included indications of when each Form 990 was signed by the Treasurer’s Office at Williams, when it was stamped as received by the IRS Office in Ogden Utah, and when it was scanned for subsequent transmission to Guidestar.  Signature dates on the last few Williams submission suggest they were filed right up against the final deadline.  The path from the IRS to Guidestar is a bit convoluted, and may be covered in a subsequent post.  Note that, as from the 2006 reports, Williams’ submission has been electronic, so therefore the signature and receipt dates are effectively  the same, and there is no longer any need for separate scanning.  Without further ado, here they are.


WilliamsForm990 2008

(copy provided by IRS on 8/13/09 signed 5/15/09; electronic submission.)

Williams Form990 2007

(signed 5/15/08; electronic submission)

Williams Form990 2006

(signed 5/15/07; electronic submission)

Williams Form990 2005

(signed 5/11/06; received 4/27/07 [ sic !]; scanned 6/1/07)

Williams Form990 2004

(signed ? – blacked out; received 5/9/05; scanned 6/7/05)

Williams Form990 2003

(signed ? – blacked out; received 4/19/04; scanned 4/30/04)

Williams Form990 2002

(signed ? – blacked out; received 3/6/03; scanned 3/27/03)

Williams Form990 2001

(signed 2/14/02; received 2/21/02; scanned 3/13/02)

Williams Form990 2000

(signed 3/8/01; received 3/15/01; scanned 3/27/01)

Williams Form990 1999

(signed 3/31/00; received 4/10/00; scanned 4/13/00)

Williams Form990 1998

(signed 2/12/99; received 2/16/99; scanned 3/9/99)


Addendum:  EphBlog readers may wish to note the following.   The Panel on the Nonprofit Sector’s Principles for Good Governance and Ethical Practice:  A Guide for Charities and Foundations, published in October, 2007, stated the following about “Legal Compliance and Public Disclosure:”

Section 7:  A charitable organization should make information about its operations, including its governance, finances, programs and activities, widely available to the public….

Another source of transparency and accountability and a key method for communicating about the organization’s work is a website, which can be maintained independently or through another organization. A website should feature the same information recommended for annual reports, with links directly to or instructions on how to request the organization’s most recent IRS Form 990 return and other financial statements (emphasis added)….  (page 12)

End of post.


Williams Forms 990: Completing the Set

Several posts under “Form 990” on the EphBlog contain links to forms 990 filed by Williams with the IRS in recent years.   Those for 2004 and 2005 seem to be missing.    Here, to complete the set, are these two filings.

Williams Form990 2004 and Williams Form990 2005

If any reader feels moved to acquire the whole set from the past 10 years, they happen to be living on my computer, and I can provide.

For those historians searching for pre-1998 forms 990, it appears to be the IRS standard to destroy these nonprofits’ filings after 10 years, so they may be hard to obtain.    The website currently makes available only the most recent three year run for non-premium users.

At the present moment, Williams’ 2008 form 990, which should have been filed with the IRS months ago,  is not yet posted on Guidestar, but it should be along shortly.   When the 2008 filing appears, it will find its way onto the EphBlog like the others.


Greater Financial Transparency? Morty says “No.”

During the recent reunion weekend, in a public meeting, President Shapiro said “No” to the suggestion that Williams should post on its website the Forms 990 it submits on an annual basis to the IRS, even though the information in these forms is, by law, open to the public.    Details on this exchange coming shortly.


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