Do charities have to register only when they are mailing solicitations through an outside vendor?
No, even if you mail cards or letters in-house that can be construed as solicitations, you are required to register your charitable organization in accordance with the laws of each state on your mailing list. This includes annual giving requests and even emails in some states. The language defining “solicitation” in the Model Law is very broad. You can access this document here. If just one recipient of your mailing contacts the Attorney General and your organization is not registered, you are potentially liable for serious fines.
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