Penn State's legal counsel is reviewing whether the university needs to report more specific information in its annual Right-to-Know disclosures, spokesman Geoff Rushton confirmed Wednesday.

The 63-page report for fiscal year 2009, released last week, is mandated under state transparency rules. It's largely the equivalent of an IRS Form 990, the disclosure document required of many nonprofit and charity groups.

As part of the report, Penn State indicated that at least one person in an influential position at the university has a family member who does business with the institution.

Disclosure standards require the university to acknowledge such transactions, and to share details when the transactions reach certain thresholds. The transparency requirements apply to arrangements involving Penn State and any relatives of its current or former directors, officers, trustees or key employees.

Explaining itself in the Right-to-Know document, Penn State wrote only that "the university knows of no significant transactions between it and any person described in the question other than transactions in the normal course of its activities.

"Any such transactions are conducted at arm's length for good and sufficient consideration, and the university believes that the terms and conditions of any such transactions have been fair and reasonable," the statement goes on.

Rushton, in an e-mail message, said that the university, "along with our attorney who reviewed the filing, believed (that) statement ... satisfied the requirement."

But "university counsel decided last week to review the details and see if we needed to report more specific information," Rushton went on.

He said the university will release an update when it's available.

A review of IRS rules shows that an "ordinary course of business" exception may not apply to Penn State in this case. Among other circumstances, it appears that the university is expected to detail instances when "interested persons," such as relatives, received more than $100,000 in annual total payments or more than $10,000 in annual compensation from the university.

An IRS spokesman today said the government agency cannot, as a matter of policy, comment on the merits of specific disclosure filings.

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