You and members of your organization have until Wed., Dec. 16 to tell the IRS your concerns! Please take three minutes to tell the IRS the impact their proposed regulations could have on your organization! Submit your comments here.

Gift substantiation proposed regulation — background:

Under new rules proposed by the US Department of Treasury and the Internal Revenue Service, nonprofits could be allowed to participate in a record-keeping system that asks for personal information like Social Security Numbers from donors who give more than $250. While the system is voluntary, the impacts could be twofold:

1. A voluntary option like this creates two systems, making the process of record keeping for donors, nonprofits and the IRS difficult to juggle. In fact, it might be too complex to keep both systems and it could eventually be mandatory for nonprofits to use the system that requires asking donors for their SSNs.

2. Donors are less likely to give if they are asked to provide information such as their Social Security Number. They will either donate amounts less than $250 to avoid giving their personal information, or will decide not to give at all. This system also adds security concerns and puts organizations at risk for being liable.

What can you do?

> Submit comments to the IRS! You have until Wed., Dec. 16 at 10:59 pm to tell the IRS what asking for your donors’ SSNs could do to your individual giving plan. Forefront's draft comments are below; please customize these comments to reflect your organization and submit them here.
> Add your organization's name to the letter to the IRS!
> Read and learn more! The National Council of Nonprofits has great information on these proposed regulations.

Forefront's comments to the IRS that you can customize for your own organization:

We at Forefront, Illinois’ statewide association for nonprofits, foundations, and advisors would like to express our deep concerns with the proposed regulations. We provide education, advocacy, thought leadership, and project management to attract investment to the sector, develop top talent, improve systems and policies and build organizational capacity. Our 1,100 members focus on varying issues across the state, including the arts, environment, education and human services.
 
In Illinois, nonprofits are operating with limited resources and in an unstable environment as a result of decades long budget cuts, delayed state payments, and a seemingly constant fiscal crisis.
 
It would be devastating to place additional burdens on nonprofits that would also provide disincentives for individual giving. The proposed regulations would give nonprofits additional administrative tasks and liability and give potential donors a good reason to refrain from donating due to a reasonable hesitancy to share their Social Security Numbers.
 
Nonprofits cannot afford to bear the administrative or liability costs, nor are they in a position to risk losing individual donors. The IRS has stated that the current system without the proposed regulations works well for donors and nonprofits, and that individuals should avoid giving out their Social Security Numbers when possible. These proposed regulations are in direct conflict with those previous statements. Forefront urges the IRS to abandon the proposed rules and maintain the current system.

If you have questions or concerns, please contact me at [email protected] or 312-327-8912.

— Alison Leipsiger, Manager, Policy + Advocacy