What Are The Best Practices For A Cio Policy Per The Irs? Essay

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BACKGROUND: Lakewood Church has a conflicts of interest policy which is meant to protect the Corporations interest when it is entering transactions that might benefit the private interest of an individual heavily involved in or employed with the Corporation. ISSUE: Issue #1: Who does the current COI policy apply to? Issue #2: Does the current COI policy apply to lower level employees? What is considered lower level employee? Issue #3: What are the best practices for a CIO policy per the IRS? Issue #4: Does our COI policy comply with these best practices? CONCLUSION: Issue #1: Lakewood’s current COI policy applies to any director, officer, member of a committee with board delegated powers or senior staff member with any direct or indirect financial interest in respect to any outreach or exempt function. Issue #2: The current CIO policy does not apply to any employees who are not considered a “senior staff member.” Issue #3: The current recommendations by the IRS are actually contained in a sample conflict of interest policy on the IRS website: http://www.irs.gov/instructions/i1023/ar03.html Issue #4: The current COI policy adopted by Lakewood Church is actually more restrictive than that recommended by the IRS and there have only been two changes to the IRS’s recommendations that are noted below. APPLICABLE LAW/EXPLANATION: Issue #1 – Current COI Policy Coverage Lakewood’s current COI policy applies to any director, officer, member of a committee with board delegated

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