Affordable Housing Nonprofit President is using his private LLC to broker transactions and receiving direct payment from buyers. Is this a conflict?

I just started a job at an affordable housing nonprofit, an industry I’ve worked in for 8+ years. But this situation is a little bit new to me and I wanted advice.

Not sure how familiar y’all are, but I’ll take a stab.

Our nonprofit builds affordable homes for low to mod income buyers. They’re subsidized down to an affordable price and sold to the buyer.

Typically real estate transactions have agents who themselves have brokers to manage the sale. Well our President is a licensed broker, so I was told he just handles that. Okay, I figured it was part of his duties as President.

Today looking at some of our spreadsheets and saw payments to an LLC with our presidents initials and looked it up and sure enough, it’s his wholly owned personal LLC. For each home purchased, the buyer pays the LLC between $500-1000 directly in earnest money.

I’m no forensic accountant nor specialist in nonprofit ethics. But this seems… off. I didn’t find any disclosures on our 990 about “additional compensation”

Our personnel policies say we’re expected to avoid the fact or appearance of personal financial gain and has language about outside employment not conflicting with official duties.

Am I seeing a mountain when there is a molehill or does this seem like a legitimate issue?

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