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Donations to administrative account of trade association

A trade association may solicit and accept donations of money, goods or services from its members to defray the operating, administrative and solicitation expenses of the association’s SSF. Such donations are not “contributions” as long as the donor qualifies as a member of the association. (The Commission has reasoned that when these funds were placed in the trade association’s general treasury, the association could use them in any event to pay the administrative and solicitation costs of its SSF.)

Funds received for an SSF’s administrative, operating or solicitation expenses must be kept in a separate account from the SSF contributions (sometimes referred to as an "administrative fund"). This account must be used only for the administrative and solicitation costs of the SSF.

Member donations of prizes or entertainment

When prizes or entertainment are donated for an association's SSF fundraising event, the SSF must apply the “one-third rule” and reimburse the connected organization if the donated items are disproportionately valuable in comparison with the amount raised by the event.

Donations from non-members

If a trade association receives an unsolicited donation, to cover the SSF’s administrative and solicitation expenses, from an individual who is not a member of the trade association, that donation is a contribution to the SSF and is subject to the donor’s $5,000 annual limit. Because goods and services contributed by non-member individuals are in-kind contributions, they are not subject to the one-third rule. Similar contributions by non-member corporations are prohibited.

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