..."Nonprofit Enterprises: Law and Taxation", attached. Some cases compare directors to "mandatories", persons who have gratuitously undertaken to perform...apply ordinary skill and diligence - but no more. "One who voluntarily takes the position of director, and invites confidence in that relation, undertakes,...

...cases it has been said that inasmuch as directors are usually not paid for their services they are to be regarded as mandataries — persons who have gratuitously undertaken to perform certain duties, and are bound to exercise only ordinary care and prudence — and that they are liable to the corporation...