If you've read through this site, you've seen the phrase "conflict of interest policy" come up repeatedly. It's worth explaining what that actually means, why it matters, and why the absence of a publicly disclosed one for the MYPros Community Crowdfund is a legitimate governance concern.
In the nonprofit context, a conflict of interest exists when a person in a position of trust — a board member, a staff member, a committee member — has a personal interest that could improperly influence their decision-making on behalf of the organization. The interest doesn't have to be financial. It can be a personal relationship, a business connection, or a prior reciprocal arrangement.
Conflicts of interest are not inherently disqualifying or scandalous. In small communities, they're nearly unavoidable. The question is not whether conflicts exist — they will — but whether the organization has a policy for identifying and managing them.
A conflict of interest policy is a documented set of rules that establishes how an organization identifies conflicts, discloses them, and manages decision-making when they exist. A typical policy includes: a definition of what constitutes a conflict; a requirement for board members, staff, and committee members to disclose potential conflicts before relevant decisions; a recusal procedure requiring conflicted parties to leave the room during discussion and voting; and annual disclosure requirements for board members.
The IRS does not technically mandate that all 501(c)(3) organizations adopt conflict of interest policies by law. However, the IRS Form 990 — the annual information return that tax-exempt organizations must file — asks explicitly whether the organization has a written conflict of interest policy, whether officers and directors annually disclose conflicts, and how the organization monitors compliance. Organizations that answer "no" attract scrutiny.
The IRS Form 1023, used to apply for tax-exempt status, includes a sample conflict of interest policy in its instructions and strongly recommends adoption. The IRS has made clear through guidance documents that conflict of interest policies are a marker of good governance that it expects tax-exempt organizations to have.
We have not been able to identify any publicly disclosed conflict of interest policy for the MYPros Community Crowdfund program. Neither the Midland Business Alliance's public-facing program pages nor the Midland Area Community Foundation's publicly available materials include a conflict of interest policy specific to the crowdfund selection process.
The MBA and MACF may have internal policies that apply. If they do, publishing them would be a straightforward way to address the questions this site raises. If they don't, that's a governance gap worth filling — especially given the documented overlap between selectors and recipients in recent years.
For a program like the MYPros Community Crowdfund, a conflict of interest policy should at minimum address: whether MYPros members are permitted to apply; whether MBA board members, staff, or committee members with relationships to applicants must recuse themselves; whether MACF board members whose businesses apply must recuse the MACF from the matching commitment; and what happens when a past recipient joins the selection committee.
None of these questions have been publicly answered. All of them could be answered by a single published document.