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This looks like a classic case where the sample policy is a starting point rather than the final word. The distinction between an “interested person” and a “disqualified person” shows why nonprofit leaders need to look beyond sample forms and understand the underlying rules. Using a narrower definition could potentially create problems, particularly around executive compensation and Section 4958. I would favour a policy that clearly addresses the broader requirements, followed by professional review where necessary. This is one of those areas where double-checking the actual law is far better than discovering a gap after the fact.