自2024年7月1日起，美国将.S. Department of Education will mandate additional disclosures for higher education institutions in order to determine financial responsibility, 特别是与关联方的交易.
The definition of related parties mirrors the definitions in FASB 850 – Related-Party Disclosures, so this includes not only the members of the board of your institution, but also members of management and can include other entities established by donors and others. 在现行规则下, the Department of Education notes that this disclosure should include any related-party transactions, 所以没有最低限度.
你现在应该开始做些什么来为这种变化做准备呢?
审查并加强你的利益冲突政策. If you had established any types of thresholds that transactions were de minimis before, 这些都需要移除.
Evaluate who within the institution is completing the conflict-of-interest disclosures and determine if this population of individuals needs to be revisited.
Train those who are processing transactions on who is deemed to be a related party and develop a list of known related parties and ensure that list is regularly updated.
Evaluate your ability to capture transactions with related parties with your existing system. Do you need to develop additional reports to access the additional data you are seeking to capture?
Evaluate the level of detail you are capturing when establishing new vendors and determine if changes are needed to identify potential related parties.
Evaluate the different sources of your revenues and cash receipts (tuition, contributions, etc.) and evaluate if there is a way to identify related parties within those transactions.
执行一些基本的分析，比较金额, volume of transactions and number of related parties year over year, looking for trends that require further investigation or follow-up.
Ensure the information that you are disclosing in the financial statements matches the Form 990 disclosures in Schedule R and other schedules.
Ensure that significant transactions captured in other key documents (i.e.、董事会会议纪要、重要合同、捐赠协议等.) are flagged to be analyzed and verify they are included in the detailed reports.
Designate someone as responsible for capturing this information and designate someone to review who will challenge any assumptions, discrepancies and who has the knowledge of what they would expect to see captured based upon their knowledge of the relationships around the institution.
最后, maintain a master record and include the narrative of how you determined the completeness of the information you captured.
当你准备评估这些交易时, we are here to help in navigating these rules and ensuring your initiation can comply with these new requirements.
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