Due Diligence verifies grantee compliance status in CommunitySuite using native data sourced directly from the Internal Revenue Service's Business Master File (IRS BMF), Publication 78 (Pub78), Form 990 filings, the Office of Foreign Assets Control (OFAC), and the Canada Revenue Agency (CRA).
Due Diligence is available as an alternative to GuideStar or Grant Connect Charity Check, and provides compliance data refreshed daily for United States organizations and monthly for Canadian organizations. Only users with the Financials and Compliance permission in Grantees Permissions can run due diligence.
Who: Finance and grants management staff who run compliance checks on grantees before approving or processing grants.
When to Run Due Diligence
Run due diligence to:
- Verify a grantee's tax-exempt status against the IRS Business Master File for United States organizations and CRA for Canadian organizations, before approving a grant.
- Access compliance data that is refreshed daily for organizations based in the United States.
- Align grantee compliance data in CommunitySuite with compliance checks run in Grant Lifecycle Manager (GLM).
- Review a complete history of both Candid/Grant Connect and Due Diligence checks for a grantee in one acknowledgement log.
Enable Due Diligence
The compliance check that will run in CommunitySuite can be enabled using a site-wide setting. If Due Diligence is enabled, it will take priority over the GuideStar and Grant Connect charity check options if either of those is also enabled.
To enable due diligence:
- Navigate to the Grants page and click Settings in the left-side menu.
- Click Set next to Enable Due Diligence.
- Review the Data Acknowledgement information, and then click Accept.
- Due Diligence will not work if the data acknowledgment is denied.
- Due Diligence will not work if the data acknowledgment is denied.
Run Due Diligence on Grantees
Due diligence checks can be run from the grantee designation, from an individual grant record during grant processing, or in bulk from the Grants page.
From the Grantee Designation
To run a due diligence check from a grantee designation in CommunitySuite:
- Navigate to the Grantees page.
- Enter the grantee name in the Grantee field and select the grantee from the drop-down list.
- In the Details tab, click View next to Financials and Compliance.
- Review the grantee's Financials and Compliance data, and then click Acknowledge.
- Acknowledging this data confirms that a due diligence check has been run on the grantee.
- Acknowledging this data confirms that a due diligence check has been run on the grantee.
If the grantee passes due diligence, a confirmation message will appear alongside a Due Diligence Check Data table with additional due diligence data. If they fail, an error message detailing which field failed will be available. Refer to the Review Due Diligence Check Data section of this article for details on the data fields.
Click View Log on the Financials and Compliance page to view a complete log of all compliance checks run on this grantee.
From an Individual Grant Record
To run a due diligence check from a grant record during grant processing:
- Create and Process an External Grant.
- Click due diligence on the grant record.
A confirmation page will appear, and the date of the due diligence check will be available on the grant record.
Run Due Diligence in Bulk
To run due diligence checks across multiple grants:
- Navigate to the Grants page and click Due Diligence Check All in the left-side menu.
- Check the box next to the grants that need a due diligence check, and then click Due Diligence Check All Grants.
A confirmation message for how many grantees passed the check will be available.
Review Due Diligence Check Data
The Due Diligence Check Data page is available after due diligence is run from the grantee designation. It is important to understand which data fields control whether a grantee will pass or fail a due diligence check, and which fields show when data was updated.
Due Diligence Compliance Fields
The table below describes four fields important to whether a grantee passes a due diligence check and the conditions they must meet to pass. On the Due Diligence Check Data page, these fields will populate with a Yes or No.
| Due Diligence Check Data Field | Description |
|---|---|
| bmf_status |
Indicates whether the organization is in the IRS Business Master File, which is the master list of all tax-exempt organizations. This field must populate with Yes for the grantee to pass the due diligence check. |
| pub78_verified |
Indicates whether the organization is eligible to receive tax-deductible charitable contributions and is listed in Publication 78. This field must populate with Yes for the grantee to pass the due diligence check. |
| currently_revoked |
Indicates whether the organization has lost its tax-exempt status, typically for failure to file required Form 990 returns for three consecutive years (automatic revocation). This data comes from the IRS Auto-Revocation List. This field must populate with No for the grantee to pass the due diligence check. |
| ofac_found |
Indicates whether the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) has identified a person, organization, or entity as a national security, foreign policy, or economic threat, and U.S. persons, including foundations and grantmakers, are legally prohibited from doing business with them. This field must populate with No for the grantee to pass the due diligence check. |
Note that an organization can have tax-exempt status (bmf_status: Yes) but not be eligible for deductible donations (pub78_verified: No). For example, social welfare organizations 501(c)(4) are tax-exempt, but contributions to them are not tax-deductible.
Data Update Timestamp Fields
CommunitySuite checks IRS sources daily for updates. CRA data will be updated monthly from CRA data sources, and Grant data will be updated as new Form-990 PF filings are processed.
The table below describes timestamp fields related to data updates. The full field name will depend on what data source is being referenced (e.g., bmf_last_checked, pub78_last_checked, cra_irs_last_checked).
| Due Diligence Check Data Field | Description |
|---|---|
| *_last_checked | Indicates when CommunitySuite last polled the source for updates. Reflects the system's check frequency, not whether data actually changed. |
| *_last_updated | Indicates when the source (IRS, CRA, etc.) last published an updated file or dataset. Comes from source-provided metadata. |
| *_last_modified | Indicates when the specific record for this organization was last changed within the source data. |
Due Diligence Data Sources
The following data sources are used to run due diligence checks in CommunitySuite.
United States Organizations (IRS Data):
- IRS Business Master File (BMF) - Core organization information, tax-exempt status, and NTEE codes.
- OFAC SDN List - Office of Foreign Assets Control sanctions screening.
- Publication 78 - Deductibility status for charitable contributions.
- Auto-Revocation List - Organizations that have lost tax-exempt status for failure to file.
- Internal Revenue Bulletin (IRB) - Official IRS announcements of status changes.
- Form 990 Variants - Financial data from Form 990, 990-EZ, 990-PF, and 990-N.
Canadian Organizations (CRA Data):
- CRA Charity Database - Registered charity status, charity type, and designation.
- CRA Historical Records - Organization status changes over time.