IRS Form 990 Filing Requirement for Federal Credit Unions

Mr. Marc Shafroth
CUNA - Economics & Statistics Department
5710 Mineral Point Road
Madison, Wisconsin 53705-4454

Re: IRS Form 990 Filing Requirement for Federal Credit Unions.

Dear Mr. Shafroth:

You have written to request information concerning Internal Revenue Service (IRS) Form 990, which is an informational return required to be filed by certain tax-exempt organizations. You indicated that a CPA firm contacted you and asked whether NCUA files a consolidated Form 990, and if so, if it uses year-end call report data. Federal credit unions (FCUs) are not required to file a Form 990.

Prior to 1988, NCUA had filed a consolidated Form 990 for all FCUs. In 1988, in response to an NCUA inquiry, the IRS responded that FCUs are not required to file a Form 990. NCUA addressed the issue of filing a consolidated Form 990 in its Letter No. 100 to Credit Unions, dated October 27, 1988, a copy of which is enclosed for your reference. Also included is the attachment to Letter No. 100, which is the letter to NCUA from the IRS explaining its determination.