As a result of California Assembly Bill 488 (CA AB 488), online payment platforms are required to confirm that charities are current in their status with the IRS, Franchise Tax Board, and Registry of Charitable Trusts. Some charities have recently seen credit card transactions being declined because of a delinquent status with the California Attorney General’s Registry of Charitable Trusts (the agency to which the Form RRF-1 Annual Registration Renewal is filed).
The Registry recently issued a report, “Charities May Not Operate or Solicit for Charitable Purposes,” which provides a list of all entities that are delinquent (or suspended or revoked). This report appears to be a resource used by online payment platforms to determine if payments must be declined to a particular charity.
https://oag.ca.gov/charities/reports
We advise that all charities immediately check their Registry Status with the Registry of Charitable Trusts (the Registry). To do this, you can use the Registry search tool to look up your organization (https://rct.doj.ca.gov/Verification/Web/Search.aspx?facility=Y). The “Registry Status” is posted at the top of the page, and you can view the status of prior filings below. If any particular filing has an issue, the reason should be described there as well (e.g., “IRS Form 990 missing”).
To inquire about a delinquency, you should email delinquency@doj.ca.gov. Missing forms can be emailed to this address. Include in the email the organization’s full name and either the EIN, CA Secretary of State ID, or Charitable Trust (CT) ID. The registry does not operate a call center to discuss delinquencies with a representative over the phone.
The Registry also has an online submission portal, where organizations can submit the RRF-1 and 990 copies and make online payments. Organizations are encouraged to utilize this new feature to avoid filings and payments being lost in the mail. Registration is not immediate, as there is a verification code that must be obtained.
https://oag.ca.gov/charities/online-renewal-checklist
We also advise that all charities check their status with the following agencies:
IRS Tax Exempt Organization Search – https://apps.irs.gov/app/eos/
California Franchise Tax Board Entity Status Search – https://webapp.ftb.ca.gov/eletter
California Secretary of State Business Search – https://bizfileonline.sos.ca.gov/search/business
This article was written by Windes Nonprofit Tax Services Senior Manager Aaron Phillips.
Aaron Phillips, CPA
Audit & Assurance Services Manager
aphillips@windes.com
562.304.1202
For more information or questions about this article or to find out how Windes can assist, please contact our Nonprofit Team at nonprofit@windes.com.