Charitable Solicitation Rules: Your State’s Adjustments

by | Jul 20, 2020

Keeping up with change is a challenge, especially for nonprofits. In today’s pandemic-driven environment, there are more than ever — especially if your organization handles charitable solicitations. Recently, more than half of the states with solicitation reporting requirements have adjusted their filing deadlines and fees. The changes were made mostly due to the IRS’s reasoning that pandemic conditions required a relaxation on the filing deadlines for Form 990.

Based on NASCO’s latest State Charity Registration Provisions (dated May 15, 2020) we’ve put together a list of the states with COVID-related changes or relief. Is your state one of them?

Charitable Solicitation Rules for States

Take a look to see if your organization’s charitable solicitation reporting is affected:

Alabama – Charities now have the option to file 180-day extensions.

California – The Registry is honoring all IRS extensions for annual renewal filing deadlines, including the Forms RRF-1, CT-TR-1, and IRS Forms. The Registry will consider other extension requests on a case-by-case basis.

Colorado – Filing deadlines extended to August 15, 2020.

District of Columbia – 45-day extension for filings/registrations and waiver of late fees for late filing.

Florida – $25 late fee waived (Emergency Order 2020-003) Charities soliciting for a charitable purpose related to the COVID-19 pandemic and raising over $50,000 must file special reports with the state.

Georgia – Online filing now available. Secretary issued orders on filing relief.

Illinois – Extensions available. 

Maryland – Extensions for charitable registration are automatically granted to organizations with current registration. Charitable organizations no longer need to file a written request for an extension to the registration deadline. The Charities Division will no longer process written requests for extension. Deadlines for registration and reporting extended to 30 days after the state of emergency order has been terminated.

Massachusetts – The Division is extending by six months the filing deadlines for all annual charities’ filings for the fiscal year 2019. This extension is in addition to automatic six-month extensions that many charities are granted. Reasonable delays in submitting annual charities filings and/or initial registration materials as a result of COVID-19-related interruptions will not adversely impact whether a charity or solicitor is in good standing with registration and filing requirements. For initial charities registrations, the Division is processing new submissions as PDF attachments via email only.

Michigan – Will work with charities to extend registrations based on new IRS due dates.

Minnesota – Soliciting charities’ annual reports that would otherwise be due between April and July are automatically extended by four months. The Division will not enforce or assess late fees for late annual registration statement filings by professional fundraisers (currently due on April 30) until November 16, 2020.

Mississippi – Filings due by May 15, 2020 have been automatically extended to July 15, 2020.

New Hampshire – Website advisory explains COVID-19 adjustments. Organizations already on extended deadline to April, May, or June may file an annual report July 15, 2020.

New Jersey – No changes. NJ statute provides for an extension for compliant organizations. It is granted upon request for justified reason.

New Mexico – 180-day extension on registration deadlines if requested.

New York – The Charities Bureau currently grants an automatic six-month extension to charities required to file an annual financial report. Any organization whose 2019 or 2020 filing deadline, including the automatic six-month extension, was originally after February 15, 2020 will be given an additional six-month extension to file its annual financial report.

Ohio – Attorney General’s Office will automatically extend the final annual report filing deadline for any organization with a May 2019 fiscal year-end from April 15, 2020, to June 1, 2020, and any organization with a June fiscal year-end from May 15, 2020, to July 15, 2020. No action is required to receive this extension. Ohio’s online registration system assumes that charities are seeking all IRS extensions prior to assessing late fees. The office previously extended the filing deadline for groups with a final deadline of April 15. In light of the IRS’s recent extensions related to the 990s, additional changes will be made within the online filing system.

Oklahoma – Filings must be made through mail or online.

Oregon – Due dates for the CT-12/CT12F/CT-12S annual financial reports extended. The maximum extension period is increased so that all reports that were due between March 15, 2020, and July 15, 2020, are now due by August 15, 2020. Organizations that are eligible for a longer extension should submit an extension request on or before August 15, 2020.

Pennsylvania – All deadlines for registration extended for three months.

South Carolina – Automatic extensions granted by the IRS due to COVID will be honored by the Secretary of State. This extension is for the financial report only.

Utah – If a charitable organization is unable to file a timely renewal application as a result of the COVID-19 pandemic, they need to contact dcpcharities@utah.gov for an extension.

Washington – Organizations are not required to renew with the Charities Program until the end of the 11th month after their fiscal year-end. The office is taking additional extensions on a case by case basis.

For details on any of these rule changes, please check with your state’s agency for the most up-to-date information. If you need a hand with your nonprofit’s reporting on charitable solicitations, we’re happy to help. Nonprofit accounting is our specialty. Talk to an expert and give yourself peace-of-mind. Schedule a quick (free) call with our Qbix team today.

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