Episode of The Nonprofit Compliance Brief — practical guidance on charitable solicitation compliance.
Episode Summary:
Many nonprofits assume registration happens after fundraising begins, but in many cases registration obligations arise before the first donation is received. This episode explains when charitable solicitation registration is triggered, how online fundraising affects requirements, and how organizations can avoid compliance problems early.
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Educational podcast for nonprofit leadership and compliance teams covering charitable solicitation registration and multi-state fundraising requirements.
Episode Length: 23 minutes
Release Date: February 22, 2026
Series: The Nonprofit Compliance Brief
New episodes released weekly covering nonprofit compliance and multi-state fundraising.
Key Topics Covered
- When charitable solicitation registration requirements begin
- Why fundraising intent matters — not just receiving donations
- How websites, email campaigns, and online platforms create obligations
- The role of the Charleston Principles in multi-state fundraising
- Common mistakes nonprofits make before launching campaigns
- Practical steps organizations can take before soliciting donations
Episode Overview
Many nonprofits assume registration happens after fundraising begins. In practice, most states regulate the act of solicitation itself, meaning compliance obligations often arise before fundraising campaigns begin.
Modern fundraising methods — including websites, email outreach, social media campaigns, and donation platforms — can unintentionally create multi-state solicitation activity. Organizations may trigger registration requirements without realizing their audience extends beyond their home state.
This episode explains how regulators interpret fundraising activity, how intent and public outreach affect registration obligations, and why early compliance planning prevents disruptions later.
Understanding these requirements early helps nonprofits avoid delayed campaigns, regulator inquiries, and administrative strain during periods of organizational growth.
Unsure whether your organization needs to register before fundraising? We help nonprofits evaluate requirements across all states.
Schedule a Consultation
Who Should Listen
- Executive directors planning fundraising expansion
- Development and fundraising teams
- Finance and compliance staff
- Board members overseeing risk management
- Organizations launching online donation programs
Related Compliance Resources
- Charitable Solicitation Registration Services
- Multi-State Fundraising Compliance Guide
- Charleston Principles Explained
- Managing Multi-State Charitable Registrations
Episode Transcript
Below is a full transcript of this episode for accessibility and reference.
SPEAKER_01: 0:00
Welcome to the Nonprofit Compliance Brief, where we explain charitable solicitation and multistate fundraising requirements in clear, practical terms for nonprofit leaders and finance teams. This podcast is produced by Ironwood Registrations.
SPEAKER_00: 0:13
It is uh it’s really great to be here.
SPEAKER_01: 0:16
Yeah. Glad to have you back. Today we are tackling a subject that honestly sits in the back of a lot of minds in the nonprofit world. It’s it’s that quiet worry that pops up at you know 2 a.m.
SPEAKER_00: 0:26
Oh yeah, the the 2 a.m. panic.
SPEAKER_01: 0:28
Yeah.
SPEAKER_00: 0:28
I think um practically every executive director or CFO knows exactly that feeling.
SPEAKER_01: 0:34
Right.
SPEAKER_00: 0:34
It’s usually this nagging suspicion that while you were busy, you know, out there saving the world, you missed some crucial piece of administrative fine print.
SPEAKER_01: 0:43
Trevor Burrus, Jr. Exactly. And specifically for this deep dive, we’re looking at the scenario of unregistered solicitation, or basically fundraising before you actually register to do so. Trevor Burrus, Jr.
SPEAKER_00: 0:51
Which is arguably the single most common compliance gap we see across the entire sector right now.
SPEAKER_01: 0:56
Aaron Powell The setup is usually pretty simple, right? We’re an organization, we’re doing great work, fundraising is going well. But then we suddenly realize we might be actively soliciting donations in states where we literally aren’t legally allowed to ask for money. Right. So the big question we want to explore today is what actually happens next? Like what is the real world consequence?
SPEAKER_00: 1:18
And that that is exactly where the imagination just runs completely wild.
SPEAKER_01: 1:22
Oh, for sure.
SPEAKER_00: 1:23
When people realize they have a gap in their compliance, they tend to just um fill in the blanks with the absolute worst-case scenarios.
SPEAKER_01: 1:31
Aaron Powell It’s just human nature. We picture this like compliance SWAT team kicking down the door.
SPEAKER_00: 1:37
Yeah.
SPEAKER_01: 1:37
We imagine the state attorney general raiding the development office or just issuing an immediate cease and desist that shuts down your entire website overnight. Trevor Burrus, Jr.
SPEAKER_00: 1:46
Or or a fine so massive that it literally bankrupts the charity.
SPEAKER_01: 1:50
Aaron Powell Exactly. We catastrophize it.
SPEAKER_00: 1:51
We do. But if we look at the actual data and look at how state charity offices actually operate day-to-day, the reality is very different. It’s rarely that dramatic explosive event.
SPEAKER_01: 2:03
Aaron Powell Right. State attorneys general aren’t actually looking to put good nonprofits out of business.
SPEAKER_00: 2:07
Trevor Burrus, no. No handcuffs involved.
SPEAKER_01: 2:09
Trevor Burrus, OK. That’s a relief.
SPEAKER_00: 2:11
However, and this is really the key insight we need to establish for today, the reality is often more insidious precisely because it is slower.
SPEAKER_01: 2:21
Aaron Powell What do you mean by slower?
SPEAKER_00: 2:22
Aaron Powell I mean it’s not a fatal blow, it’s friction. It’s um it’s like throwing a handful of sand into the gears of a really high performance engine. Right. It doesn’t instantly blood up the car, but it just grinds everything to a painful halt right when you need to be speeding up.
SPEAKER_01: 2:38
Aaron Powell Which is almost worse in a way. You know, an explosion you can at least try to fix, but sand in the gears just wears your team down over time.
SPEAKER_00: 2:45
Exactly.
SPEAKER_01: 2:46
So our mission for this deep dive is to really unpack that friction. We need to look at what we’re calling the growth trap, how regulators actually spot these errors out in the wild, and then crucially, the actual operational cost of fixing it.
SPEAKER_00: 2:58
Aaron Powell That’s a great roadmap. And I think we really should start with the why. Because I don’t think I’ve ever met a nonprofit leader who woke up, had their coffee, and said, I am going to intentionally defraud the state of Mississippi today.
SPEAKER_01: 3:11
I would certainly hope not.
SPEAKER_00: 3:13
Right. It’s almost never malice.
SPEAKER_01: 3:15
Aaron Powell So if it’s not intentional evasion, is it just, I don’t know, incompetence? Or is the system just too complex for an average development team to handle?
SPEAKER_00: 3:25
Well, the complexity plays a part, but it’s actually usually a side effect of success. It’s what the sources refer to as the growth trap.
SPEAKER_01: 3:33
The growth trap. That feels a bit counterintuitive, doesn’t it? I mean, growth is the whole goal for a nonprofit.
SPEAKER_00: 3:38
It is the goal. But think about how fundraising works in the modern digital era versus say 20 or 30 years ago. Okay. In the past, you printed a newsletter and you mailed it to a specific zip code. You knew exactly where your solicitation was landing because you physically put a stamp on the envelope and sent it to Ohio.
SPEAKER_01: 3:57
Right. It was very contained.
SPEAKER_00: 3:58
Exactly. But today, if you launch a really compelling campaign on social media, or you put up a highly polished donate now page, that signal goes everywhere. Instantly.
SPEAKER_01: 4:10
And that’s what you want. You want the message to travel across state lines. You want your campaign to go viral.
SPEAKER_00: 4:16
You absolutely do. But from a legal standpoint, solicitation is often defined by where the request is received, not just where your headquarters sent it from.
SPEAKER_01: 4:26
Oh, that’s a crucial distinction.
SPEAKER_00: 4:28
It really is. So let’s say you have an email list. You started with a hundred local supporters in your home city. Three years go by, your content is incredible, and people are forwarding it to their friends.
SPEAKER_01: 4:38
Yeah.
SPEAKER_00: 4:39
Suddenly, purely organically, you have a pocket of subscribers in Florida, a huge group in New York, and a few major donors out in California.
SPEAKER_01: 4:48
And none of those new subscribers waved a flag saying, hey, just so you know, I’m sitting in a regulated jurisdiction.
SPEAKER_00: 4:53
Precisely. You as the leader are just celebrating the growth. You’re looking at the open rates and the revenue metrics, not cross-referencing donor zip codes with state statutes. Or maybe you suddenly get an unexpected bequest from an estate in a state you’ve literally never visited. The fundraising engine is moving at 100 miles per hour, but the compliance map, the administrative infrastructure, is still just walking on foot.
SPEAKER_01: 5:17
So there’s this massive lag between the activity and the awareness.
SPEAKER_00: 5:21
A massive lag. And that brings up the core technical takeaway here, which is that compliance tends to expand alongside fundraising growth. And organizations that review requirements periodically avoid most problems. The gap happens when the shadow simply doesn’t keep up with the object casting it.
SPEAKER_01: 5:39
That makes perfect sense. Okay, so let’s say the shadow hasn’t kept up. We are out there successfully soliciting in states where we aren’t officially registered. Now we have to look at the other side of this equation, which is the regulators. Right. What is their actual posture here? Because I think a lot of that 2AM panic stems from viewing them as police officers hiding in the bushes with a radar gun.
SPEAKER_00: 5:58
That is the most common misconception. We project this highly punitive mindset onto them. But if you actually talk to state charity officials, you know, the people working in the Charities Bureau in New York or the Division of Consumer Affairs down in Tennessee, their primary mandate isn’t punishment.
SPEAKER_01: 6:14
What is it then?
SPEAKER_00: 6:15
It’s transparency.
SPEAKER_01: 6:16
Transparency. So they are less concerned with catching you in a trap and more concerned with protecting the consumer or the donor in this case.
SPEAKER_00: 6:24
Exactly. They function essentially as consumer protection agencies for their state’s residents. They want to ensure that if someone in their state is being asked for money, the entity asking is legitimate, their financials are properly disclosed, and there’s some basic accountability.
SPEAKER_01: 6:39
Okay.
SPEAKER_00: 6:40
So when they see an unregistered solicitation, they don’t immediately assume you are running a scam.
SPEAKER_01: 6:45
Right. They assume you’re just disorganized.
SPEAKER_00: 6:47
Yes. They assume you are disorganized or just totally unaware of that specific state’s filing statutes.
SPEAKER_01: 6:53
That is a really critical distinction for our listeners. The regulators generally assume incompetence or ignorance before they assume malice.
SPEAKER_00: 7:01
They do. They know the rules are complex. I mean, there are over 40 distinct jurisdictions, each with entirely different forms, different fees, different due dates. They expect to see gaps.
SPEAKER_01: 7:11
Okay. But here is the part I always struggle with. If I’m a medium-sized nonprofit based in Ohio, and I happen to have a few donors in Oregon, how on earth does the state of Oregon even know I exist? Do they have bots just crawling the web looking for donate buttons?
SPEAKER_00: 7:27
They are definitely getting smarter with technology, yes. But according to the data, there are three main detection methods, and they are surprisingly low-tech, but highly effective.
SPEAKER_01: 7:37
Lay them out for us.
SPEAKER_00: 7:38
The first is simply visible public activity. If you run a targeted Facebook ad for, say, Pacific Northwest nature lovers, and a state regulator sitting in Salem happens to see it in their own personal feed, they might just check the database.
SPEAKER_01: 7:52
Wow. Okay, so rule number one is don’t advertise your unregistered activity. If you are paying for REACH, you have to pay for the compliance that goes with it.
SPEAKER_00: 7:59
Exactly. Rule number two involves what we call the unhappy donor. This is a huge vector for discovery, and nonprofits constantly overlook it.
SPEAKER_01: 8:07
You mean like a donor who didn’t get a tax receipt on time?
SPEAKER_00: 8:10
Or a donor who just feels pestered. Maybe they tried to unsubscribe from your mailing list, but your CRM had a glitch and you keep emailing them every Tuesday.
SPEAKER_01: 8:18
Oh, that happens all the time.
SPEAKER_00: 8:19
Right. So they get annoyed. And instead of just deleting it, they call the Attorney General’s office to complain about spam.
SPEAKER_01: 8:26
And then what?
SPEAKER_00: 8:27
The very first thing that Office does before investigating the spam complaint is check if you are even registered to solicit in their state. If you aren’t, now they have you on two counts. The complaint regarding the harassment and the noncompliance regarding the registration.
SPEAKER_01: 8:43
That makes so much sense. It’s exactly like getting pulled over because you have a broken tailet, and then the officer finds out you don’t even have a driver’s license. The small administrative error reveals the massive structural one.
SPEAKER_00: 8:54
That is a perfect analogy. And then the third method is a bit more technical, but arguably the most common for rapidly growing organizations, and that is cross-referencing.
SPEAKER_01: 9:04
Cross-referencing what exactly?
SPEAKER_00: 9:05
Your IRS Form 990.
SPEAKER_01: 9:07
Ah, of course. Because that’s a fully public document.
SPEAKER_00: 9:10
Exactly. Specifically Schedule G.
SPEAKER_01: 9:12
Right, where you have to detail your fundraising activities. But how do states use a federal form to catch you?
SPEAKER_00: 9:19
Because regulators talk to each other. State agencies share data. So if you decide to properly register in New York, New York is going to ask for a copy of your 990.
SPEAKER_01: 9:29
Yeah.
SPEAKER_00: 9:29
If that 990 clearly shows you have revenue coming in from all 50 states, but you were only registered in two of them, well, the math just doesn’t add up.
SPEAKER_01: 9:37
So the data is already out there telling on you. You’re literally handing them the evidence of your unregistered solicitation in your own federal filing.
SPEAKER_00: 9:44
You are. A regulator in Pennsylvania can just pull your 990, see that you proudly raised$2 million in national contributions, and then simply check their own local database. If your name isn’t there, they send a letter.
SPEAKER_01: 9:57
Okay, so the jig is up. They found us through a Facebook ad, an angry donor, or our own 990. This brings us to the actual bust. You mentioned earlier it’s not a siren and a SWAT team. So what does that gotcha moment actually look like?
SPEAKER_00: 10:10
It arrives in a standard, very unassuming business envelope. It’s called a notice letter.
SPEAKER_01: 10:15
A letter. I have to say, that feels a little anticlimactic.
SPEAKER_00: 10:18
It feels completely manageable when you’re just holding it in your hand. But the contents are serious business. It’s usually a formal request for information. It will say something to the effect of We have reason to believe you are soliciting in our jurisdiction. Please clarify your activities or register immediately.
SPEAKER_01: 10:36
Is it an actual cease and desist order?
SPEAKER_00: 10:39
Sometimes. But more often it’s framed as a notice to register or a request for information. They are essentially giving you a pathway to fix the issue. They will set a hard deadline, usually something like 15 or 30 days.
SPEAKER_01: 10:52
Okay, I’m going to play devil’s advocate here for a second. I’m a busy nonprofit leader. I get this letter. It’s just a piece of paper. Can’t I just file it in my desk drawer in the to-do later pile? Why is this a hair-on-fire moment?
SPEAKER_00: 11:04
Because of the operational disruption we talked about at the top of the show, the cost of that letter isn’t the paper it’s printed on, and it’s not even necessarily the filing fee. It’s the forensics required to answer their questions.
SPEAKER_01: 11:15
Forensics. That sounds intense. Like we need a lab coat.
SPEAKER_00: 11:18
Think about what they are actually asking you to prove. They often want to know exactly when you started soliciting in their state. They might demand a detailed year-by-year breakdown of all contributions received from their residents for the last three to five years.
SPEAKER_01: 11:33
Oh.
SPEAKER_00: 11:34
Yeah. Oh, now you have to go back to your donor database. You have to pull records from 2021. You have to determine if that$50 donation was a solicited gift resulting from an email or a passive gift from someone who just stumbled on your website.
SPEAKER_01: 11:49
Which most systems aren’t even set up to track that granularly.
SPEAKER_00: 11:52
Exactly. Then you have to pull financial statements from closed fiscal years. You might even need to locate old board mints to prove who was an officer at the time.
SPEAKER_01: 12:00
And you have to do all of this while you’re, you know, still trying to run your current day-to-day operations.
SPEAKER_00: 12:07
That is the real friction. Imagine receiving three of these letters from three different states in mid-November. Your development team is desperately trying to launch the big year-end appeal. Your finance team is trying to close the books. And suddenly you have to divert your absolute best people to dig through digital archives and fill out state-specific forms that require wet signatures from board members who might be away for the holidays.
SPEAKER_01: 12:32
I see. It completely kidnaps your leadership team’s time and attention.
SPEAKER_00: 12:36
It does. It forces you into a state of reactive compliance. Proactive compliance is a steady, predictable maintenance task, kind of like changing the oil in your car.
SPEAKER_01: 12:46
Right, a minor inconvenience.
SPEAKER_00: 12:48
But reactive compliance is fixing a blown gasket on the side of the highway in the pouring rain. It takes five times as long and costs twice as much in raw labor hours.
SPEAKER_01: 12:58
And presumably you can’t keep actively fundraising in those specific states while you’re busy fixing it.
SPEAKER_00: 13:03
That is the massive risk. If they issue a cease and desist alongside the notice letter, you literally have to turn off the spigot. You might have to actively geoblock donors from that state or scrub them from your email campaigns. That is direct, measurable revenue loss.
SPEAKER_01: 13:18
So that quiet worry at 2 a.m. actually results in a very loud, very expensive operational problem.
SPEAKER_00: 13:24
Correct. And keep in mind that’s just the regulator side of the equation.
SPEAKER_01: 13:27
Right. Which brings me to another trigger you mentioned when we were preparing for this. You call them checkpoints. Because sometimes it’s not actually a state regulator who catches you out of bounds, it’s a partner.
SPEAKER_00: 13:38
Yes. This is becoming so much more common as the entire nonprofit sector professionalizes. Compliance gaps often stay completely hidden in the shadows until your organization tries to do something big.
SPEAKER_01: 13:51
Like applying for a major grant.
SPEAKER_00: 13:53
A large grant. Exactly. Private foundations and grant makers are becoming incredibly risk-averse these days. They are conducting their own rigorous due diligence before they write a check.
SPEAKER_01: 14:04
Because they don’t want to give a million dollars to an organization that isn’t legally allowed to ask for it. It looks bad on them.
SPEAKER_00: 14:11
Exactly. Imagine your team has spent six whole months cultivating a relationship with a major national foundation. You write the perfect proposal, you get the program staff completely on board, everyone is thrilled.
SPEAKER_01: 14:22
Okay.
SPEAKER_00: 14:23
The proposal goes over to their legal or compliance team for the final rubber stamp, and they kick it back.
SPEAKER_01: 14:28
They say, we can’t cut the check because you aren’t registered in our state.
SPEAKER_00: 14:32
Or worse, you aren’t even properly registered in your own home state. I have personally seen it happen. The momentum of the deal dies instantly. You aren’t losing the money because your charitable program is bad. You are losing it because the administrative paperwork wasn’t done. That is a truly devastating conversation to have with your board of directors.
SPEAKER_01: 14:53
Yeah, standing up and saying, sorry everyone, we lost the million dollar gram because I forgot to file a$200 form. That is definitely a career-limiting conversation for a leader.
SPEAKER_00: 15:03
It absolutely is. And the exact same principle applies to mergers, strategic partnerships, or even something as simple as switching online donation platforms.
SPEAKER_01: 15:11
Wait, really? The payment platforms themselves care about stat registration.
SPEAKER_00: 15:15
Oh, yes. Major payment processors and donation software platforms are increasingly requiring proof of good standing before they will even process funds for you.
SPEAKER_01: 15:23
Why do they care?
SPEAKER_00: 15:24
Because they are under intense pressure from regulators to ensure they aren’t accidentally facilitating unregistered, illegal solicitation.
SPEAKER_01: 15:32
So the walls are really closing in a bit. The ecosystem is checking itself.
SPEAKER_00: 15:35
The Wild West days of early online fundraising are definitely ending. The infrastructure is tightening up across the board.
SPEAKER_01: 15:43
Okay, let’s talk about the actual money for a second. We established earlier that the FBI rate is a myth, but surely there are real financial penalties. If I’ve been actively soliciting in Pennsylvania for five years without asking permission, they aren’t just gonna say, oopsie and let it slide.
SPEAKER_00: 16:00
No, they will certainly want their pound of flesh. Uh-huh. But it varies wildly by jurisdiction. Some states just have flat late fees, maybe$25 a month, very manageable. Okay. But others have cumulative penalties that can run into the tens of thousands of dollars depending on exactly how long you were delinquent.
SPEAKER_01: 16:16
But but is there room for negotiation there? Or is it a strict liability pay up immediately situation?
SPEAKER_00: 16:22
There is almost always room for negotiation if you cooperate. This goes right back to what we said about their goal being transparency, not punishment. If you respond to that notice letter immediately, admit the oversight, frankly, and provide the historical data they ask for, regulators will very often reduce or completely waive the punitive fines. They’ll just charge you the standard back registration fees.
SPEAKER_01: 16:45
Because they want you on the books permanently more than they want a one-time penalty check.
SPEAKER_00: 16:49
100%. They want what’s called corrective registration. They want to turn you into a compliant, transparent entity. But, and this is a massive but, that goodwill evaporates instantly if you try to ghost them.
SPEAKER_01: 17:02
So responsiveness is the key variable.
SPEAKER_00: 17:06
Absolutely. If you ignore the letter hoping it goes away, or if you lie about the start date of your solicitation just to save a few bucks in back fees, that is when the hammer comes down.
SPEAKER_01: 17:15
That makes sense.
SPEAKER_00: 17:16
That is when a simple administrative oversight turns into a deceptive practice in the eyes of the law.
SPEAKER_01: 17:21
And that’s when you get put on the bad list, which naturally leads us to the secondary risks. And honestly, I think these are actually heavier than the financial fines. We need to talk about reputation.
SPEAKER_00: 17:30
Yes. Reputation is everything in this sector.
SPEAKER_01: 17:33
Yeah. And we aren’t just talking about getting a bad Yelp review.
SPEAKER_00: 17:36
No, we are talking about fundamental donor trust. High net worth donors are incredibly savvy. Their financial advisors are savvy. Before they make a major gift, they check Charity Navigator, they check GuideStar, they check the state database portals.
SPEAKER_01: 17:50
And if they look you up and see a status of not registered or delinquent, it just looks incredibly sloppy.
SPEAKER_00: 17:57
It immediately raises a red flag about the organization’s governance. The thought process for a donor is if this team can’t handle a simple, routine state filing, can they really handle my$100,000 restricted gift effectively?
SPEAKER_01: 18:12
Right. They wonder what else is broken. Is there other mismanagement happening behind the scenes?
SPEAKER_00: 18:16
Exactly. It strongly signals operational immaturity. And internally it creates terrible friction with the board of directors.
SPEAKER_01: 18:23
Because they have a fiduciary duty to protect the organization.
SPEAKER_00: 18:26
Right. If the board finds out the organization is technically operating illegally in 20 different states, they start asking very hard questions. They start worrying about their own personal liability. It creates a stress culture instead of a mission-driven culture.
SPEAKER_01: 18:41
Okay, we have thoroughly painted the picture of the friction here. The sand is in the gears, the engine is smoking, the major donors are paused, and the board is yelling, let’s pivot to fixing it.
SPEAKER_00: 18:52
Yes, let’s fix it.
SPEAKER_01: 18:53
If a listener is hearing this right now and getting that sinking feeling in their stomach, thinking, I think we have a gap, what is the immediate triage plan?
SPEAKER_00: 19:02
Step one is simple. Don’t panic. Take a deep breath. You really have to remember that this is usually a symptom of growth. You are in this position because people out there actually like your work and want to fund it.
SPEAKER_01: 19:14
Okay, I love that. Reframing the compliance headache as a success tax.
SPEAKER_00: 19:17
Exactly. Step two is get the data. You need to become a detective inside your own organization. You need to figure out where the money is actually coming from.
SPEAKER_01: 19:26
So pull a report.
SPEAKER_00: 19:27
Right. Look at your donor geography over the last two to three years.
SPEAKER_01: 19:30
And we should look at not just where the donations came from, but where the solicitation actually happened, right? Like where are the mass emails going?
SPEAKER_00: 19:38
Ideally, yes, you’d look at both. But practically speaking, the actual realized revenue is the strongest signal that regulators are going to look for. Once you have that heat map of where your donors are, you prioritize.
SPEAKER_01: 19:51
Meaning don’t try to boil the ocean all at once.
SPEAKER_00: 19:54
Exactly. You do not need to register in all 41 regulated states by this Friday. That is a recipe for complete team burnout. You start with the states where you have the highest volume of donors or where you have active boots on the ground fundraising campaigns.
SPEAKER_01: 20:09
You triage the workload based on your actual risk exposure.
SPEAKER_00: 20:13
Exactly. Now, if you have already received a notice letter from a state, that state immediately goes to the very top of the pile.
SPEAKER_01: 20:19
You respond right away.
SPEAKER_00: 20:20
Respond immediately. Even if your only answer on day one is we received this, we are currently gathering the data and we are working on it. Just acknowledging receipt buys you a tremendous amount of goodwill.
SPEAKER_01: 20:31
What about the fear of waking the sleeping giant? I’ve talked to leaders who think, well, if I voluntarily register now, I have to admit on the form that I was soliciting before, won’t come in clean just automatically trigger a fine.
SPEAKER_00: 20:45
That is the classic dilemma. It’s totally understandable. But the alternative is just waiting around until you inevitably get caught, at which point the fines will absolutely be higher and the reputation damage will be worse.
SPEAKER_01: 20:57
So being proactive pays off.
SPEAKER_00: 20:59
The early advantage is very real here. It is so much easier to explain away a six-month registration gap than it is to defend a six-year gap.
SPEAKER_01: 21:08
So basically, rip the band-aid off.
SPEAKER_00: 21:10
Rip it off. Clean it up. And then finally, step three is you have to future proof the process. This shouldn’t be a terrifying surprise that ambushes your team every two years.
SPEAKER_01: 21:19
How do we actually operationalize that though? How do we keep the shadow tied to the object?
SPEAKER_00: 21:23
You have to integrate your compliance discussions directly into your growth strategy. So when the development director pitches a massive new digital campaign, the finance director should be sitting right there in the room asking, great idea. Where exactly is this launching?
SPEAKER_01: 21:37
Registration just needs to be a standard part of the campaign launch checklist.
SPEAKER_00: 21:41
Yes. You should review your multi state compliance status annually. Just make it a routine part of your audit prep. If you treat regulatory compliance as a natural expected extension of your business operations, just like running payroll or renewing your insurance policy. It completely stops being scary.
SPEAKER_01: 22:02
It just becomes the normal cost of doing business.
SPEAKER_00: 22:04
Exactly.
SPEAKER_01: 22:05
I really appreciate that perspective. It moves compliance from being this heavy, punitive burden to almost being a badge of honor. It essentially means you’ve made it. Your organization is finally big enough and successful enough to be regulated across state lines.
SPEAKER_00: 22:19
I think that is the absolute best way to look at it.
SPEAKER_01: 22:22
We have covered a lot of crucial ground today. From understanding the growth trap to the actual mechanics of a notice letter to the absolute necessity of forensic readiness. If you could leave our listeners with just one core provocative thought to take back to their teams, what would it be?
SPEAKER_00: 22:38
I want them to realize that fundraising without registration is far more common than people realize. If you look into the hood and find a gap today, you aren’t a failure, you are likely just a growing organization. But the key is making that mindset shift. Don’t hide from it. Regulators generally want to help you align with the law. They don’t want to stop your mission. So view these compliance requirements as expanding naturally alongside your success. If you treat it that way, you can navigate the whole process without the fear.
SPEAKER_01: 23:07
That is a fantastic place to leave it. Growth is good, and compliance is just part of the package. If you found this discussion helpful, you can find additional compliance guides and visual resources at ironwoodregistrations.com. Thanks for listening.
About The Nonprofit Compliance Brief
The Nonprofit Compliance Brief explores the regulatory and operational realities nonprofits face as fundraising expands across multiple jurisdictions. Each episode explains complex compliance topics in clear, practical terms to help organizations understand requirements before they become problems.
Learn more and browse all episodes on The Nonprofit Compliance Brief Podcast.
About the Host
The podcast is produced by Ironwood Registrations. The firm focuses exclusively on charitable solicitation registration and multi-state compliance management for nonprofit organizations.
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