Bruce R. Hopkins

The Law of Fundraising


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contributions pledged to and collected by the charitable organization—not just in the particular state but in all jurisdictions in which fundraising took place

       The amount from the solicitation that was or is to be devoted to charitable purposes, as well as the amounts paid or to be paid for fundraising (including the fees of professional fundraisers) and for administration

       Identification of any professional fundraisers and/or professional solicitors utilized

       The net receipts disbursed or dedicated for disbursement within the particular state, by category of expenditure

      The annual report is due at varying times as required by the states' charitable solicitation statutes. The filing may have to be made within 30 days after the close of the accounting period, within 60 days of that period, within 75 days of the period, within 90 days of the period, within five months of the period, or within six months of the period. The regulators in a few states are authorized by statute to require the filing of a report, in some instances in addition to an annual report, by a charitable organization with respect to some other period.

      In some states, the annual report filing requirement, or the extent of it, depends on the level of annual contributions received and/or use of a professional fundraiser and/or professional solicitor. In a few states, a registration or other authorization may be canceled or not renewed until the required annual report is filed.

      The annual report of a parent charitable organization must include information with respect to all of its fundraising affiliated groups.

      A few states provide, by statute, the fee to be paid with the filing of an annual report. In other states, any fees of this nature are set administratively.

      Occasionally, a charitable organization soliciting contributions in a state is required to file financial reports on a quarterly basis during its first year of existence.

      In many of these states this exemption is not found within the portion of the statute providing for exemptions but instead is located in the definition of charitable entities.

      It is less common for an exemption for religious organizations to be confined to the registration or other requirements as to preapproval. Some states provide religious organizations with exemption from their registration (and sometimes reporting) or like requirements.

      Some states exempt at least certain types of educational institutions (often with emphasis on higher education) from the entirety of their charitable solicitation acts. Usually, this exemption applies only where the institution is accredited. The more common practice is to exempt educational institutions from only the registration or other preapproval (and sometimes reporting) requirements.

      States may, either as an alternative to or in addition to the foregoing approach, exempt from the registration and reporting requirements educational institutions that confine their solicitations to their “constituency.” Thus, a state's law may provide an exemption from registration for any other educational institution confining its solicitation of contributions to its student body, alumni, faculty and trustees, and their families.

      On occasion, a state may exempt solicitations by educational institutions of their constituency from the entirety of their charitable solicitation laws.