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If you’ve ever registered your nonprofit for charitable solicitations with state governments (or if you’re just getting started with nonprofit compliance), you’ve perhaps encountered the Unified Registration Statement (URS). This consolidated form was originally created to help nonprofits complete multiple charitable solicitation registrations at once. The intent behind the URS is to round up all of the registration essentials in a single document, to which the registering nonprofit can then add more required documentation as needed for specific states.
However, the URS often raises more questions than answers for organizations looking to simplify their registrations. What is the URS? Is it worth your nonprofit’s time to complete? Are there better ways to streamline the registration process?
State filing requirements for nonprofits can be complicated, and the URS is no exception. This guide will walk through the essentials to keep in mind about the Unified Registration Statement. Here’s what we’ll cover:
- Unified Registration Statement FAQ
- Benefits and Challenges of the URS
- How to Use the Unified Registration Statement
- Ensuring Complete State Registration Compliance
At Labyrinth, we’ve worked with thousands of charities across the country to register and remain compliant in all the states where they actively fundraise. We’ve seen state-level regulations and the URS evolve over time, so we’re happy to shed some light on what can (understandably) be a confusing topic for nonprofits. As you research the URS and your own organization’s compliance requirements, don’t hesitate to reach out for help—it’s our mission to help nonprofits take the guesswork out of compliance. For now, let’s start with the essentials and some frequently asked questions about the Unified Registration Statement.
Unified Registration Statement FAQ
What is the Unified Registration Statement?
The Unified Registration Statement (URS) is a consolidated form that was created to help nonprofits file charitable solicitation registration in multiple state jurisdictions. It attempts to compile the requirements of all US states that require registration into a single document that can ideally streamline the entire process for nonprofits. This effort was organized in 1997 by the National Association of State Charities Officials and the National Association of Attorneys General.
When was the URS last updated?
The last changes made to the URS were in 2014. However, the URS guidelines have not been significantly updated since 2010. This means that closely following the (now largely outdated) guidelines in the URS can result in nonprofits’ filings being rejected by state offices.
Is the Unified Registration Statement useful for nonprofits?
It depends. The URS has become outdated since its inception in 1997 and is not actively kept up-to-date today, making it an ineffective choice for many nonprofit organizations. We’ll cover some specific reasons why in a section below. However, the URS might still be a helpful tool in a few limited scenarios. Nonprofit teams that are already very familiar with their registration and renewal requirements can use the URS to save time. Professional nonprofit compliance experts might also use the URS to streamline multiple registrations in some situations.
At Labyrinth, we only use state-specified registration forms to ensure the process moves as quickly as possible. It’s generally not recommended that smaller organizations or those that are new to complex filing requirements use or rely on the URS in its current form unless necessary.
Do many states accept the Unified Registration Statement?
Two states currently accept the URS as a primary registration method: Kentucky and Louisiana. In Kentucky, however, the URS is used only for the initial application, with annual renewals requiring only the submission of your last Form 990.
A number of other states can accept the Unified Registration Statement for charitable solicitation registration, but they’ll require supplemental attachments to satisfy requirements that are not covered in the URS. This means that for most states that accept the URS, the registration process would involve both completing the URS and providing this additional state-specific information. The move towards online-only applications has further complicated matters since the URS cannot be complicated digitally. If the jurisdictions in which you’re filing require online submission, it’s a safe bet to assume that you’ll be unable to use the URS for those filings.
Several states do not accept the Unified Registration Statement at all, due to the logistical complexities and inaccuracies that it can produce. These include Colorado, Florida, and Oklahoma, although the broader shift towards online filing means that the URS will be increasingly phased out of the process in more states.
If you’re ever unsure about the exact requirements or methods of submission that currently apply in the jurisdictions where your nonprofit fundraises, start by researching the relevant states’ most up-to-date requirements. Reach out to compliance experts or the appropriate state agencies for additional guidance.
Benefits and Challenges of the Unified Registration Statement
The URS has a number of benefits and drawbacks that should be considered before you fully commit to using it. Here’s what you need to know:
Let’s start with the main benefit of using the URS for charitable solicitation registration: the URS can help you save time in some situations.
When filing for fundraising registration with multiple states, the URS can be a helpful, time-saving resource to ensure you’ve satisfied the most fundamental requirements. Just remember that each state will likely have additional requirements for information that will need to be attached.
For charities that are new to the filing process, it is still generally not recommended that they use the Unified Registration Statement. Today, there are more drawbacks than benefits of using the URS for state registration:
- The URS is outdated. As mentioned above, the URS has not been updated since 2014. State registration requirements are constantly changing, so nonprofits using the URS should expect to spend time double-checking the accuracy of the requirements for relevant jurisdictions.
- The URS is long. Additional information will need to be attached to satisfy each state’s unique registration requirements if they’re not completely covered in the URS. To account for this, the URS was expanded over time to include some of these additional requirements. As a result, the URS is currently 85 pages long and can be time-consuming to complete and double-check for accuracy.
- The URS is difficult to submit digitally. Many states now accept (or even require) registration filings that are submitted online. This makes the URS less valuable as a time-saving tool since digital filings require information to be entered individually for each state rather than sent as copies of one physical document.
- The URS often causes filings to be rejected. The drawbacks listed above frequently result in nonprofits’ URS filings being rejected. The drain on state resources that this can cause is why many states now specifically do not accept URS filings at all. Additionally, using the URS can easily cause nonprofits to miss their renewal deadlines (and accrue late fees) since states do not all follow a uniform timeframe for renewals.
How to Use the Unified Registration Statement
If your nonprofit chooses to use the URS to complete some of your state charitable registrations, we have several recommendations to keep in mind. Considering the various drawbacks listed above, taking an extremely organized approach and having a clear roadmap will be invaluable when using the URS. Try breaking the process down into these core stages:
Stage 1: Research
Before beginning the URS, complete these initial research steps:
- Research whether each state that you’re registering with accepts the URS. If a state doesn’t accept the URS, plan ahead to complete its registration process separately.
- Understand your requirements and current registration status prior to starting. If you’re registering with a state for the first time, double-check if there are any additional requirements or exemptions that you should keep in mind when completing the URS.
- Identify each state’s prerequisites and other requirements that may need to be handled before filing. For instance, some jurisdictions may require corporate registration or the appointment of registered agents alongside the charitable solicitation registration process.
- Compile all supplemental documents and information in advance. These often include your most recent Form 990, audited or reviewed financial statements, your IRS Letter of Determination, and contracts with third-party fundraising consultants.
- Identify each state’s filing fees and required payment methods. Record this information for future reference once it’s time to submit your application.
Stage 2: Apply
Once you’re ready to fill out your applications, remember these essentials:
- Identify all the appropriate forms and requirements for each state. Again, some states may have additional requirements that aren’t covered or fully up-to-date in the URS, so double-check for each jurisdiction.
- Prepare your filing for each jurisdiction:
- Complete each form using the state’s preferred medium (paper application, online portal, fillable digital form, etc.). If you’re using the URS, this may mean compiling all the relevant information in the document so that you can submit it through an online portal once you’re finished.
- Attach all additional requirements for each state. These may not be covered in the URS, so always take the time to confirm your requirements with the relevant state office or a compliance expert.
- Provide the required authorized signatures for each jurisdiction. Again, these requirements can vary by state, so double-check before finalizing your forms.
- Include payment for initial filing or renewal fees as needed based on each state’s required methods. Then, submit your applications to each filing authority.
Stage 3: Follow-Up
After you submit your nonprofit’s registration applications, you’ll need to actively keep track of their progress. Approval can take a long time depending on each state office’s capacity for reviewing them. Additionally, the complexities of the URS can cause the review period to take even longer or result in rejections that will need to be resolved quickly. During this follow-up stage, we recommend following these tips:
- Create an internal tracking and filing system to keep the entire process organized. Losing track of an application should definitely be avoided.
- Store and organize your licenses and other documents as you begin receiving approvals from the jurisdictions that you submitted filings to.
- Continually update (or create for the first time) a calendar of renewal deadlines for the next year. These timeframes can vary by jurisdiction and may fluctuate based on the date that your application was approved. Using the URS can easily cause nonprofits to lose track of these deadlines, so laying out a concrete calendar is a fairly easy step toward ongoing compliance.
- Ensure that your disclosure statements and any financial statements required to be publicly available are up-to-date and easily accessible.
Stage 4: Renew
Finally, whether you’ve used the URS for part of the process or handled each state filing separately, remember to plan ahead for renewals. As mentioned above, registration renewals have hard deadlines that vary by jurisdiction. Renewals may also have different requirements and fee structures, so take an organized approach to compile these requirements and documents for future use.
If you’ve used the URS for parts of this process, make note of any issues or roadblocks that you ran into—rejections, out-of-date state guidelines, missing attachments, etc.—so that you can avoid them next time or decide whether or not the URS will be a good choice for your nonprofit’s future filings.
Ensuring Complete State Registration Compliance
The Unified Registration Statement, although originally intended to simplify the entire state fundraising registration process, has ultimately resulted in added levels of complexity. In some limited situations, the URS can still be a helpful tool. However, handling each jurisdiction’s charitable solicitation registration separately is generally the safer choice, especially for nonprofits that don’t yet have much experience in the regulatory landscape.
For the best results, nonprofits should work with experts to ensure 100% registration compliance.
At Labyrinth, our job is to stay on top of the constantly changing world of nonprofit compliance and take the guesswork out of filing requirements. We file tens of thousands of state registrations annually for nonprofits of all sizes, so we understand the ins and outs of nonprofit regulations. We offer a complete range of filing services, including:
- Charity registration preparation and filing
- Corporate registration preparation and filing
- Registered agent services
- IRS 990 preparation and nonprofit bookkeeping
- Tax exemption filings
And for CPA services and preparation of financial audits and reviews, our sister firm—Urich CPAs LLC—is ready to serve your nonprofit.
Working with compliance experts allows your organization to completely avoid the logistical complications (and potential rejections) that come with the Unified Registration Statement. Firms like Labyrinth can handle your initial registration filings and manage your renewals on an ongoing basis, meaning your nonprofit spends less time on paperwork and more time pursuing your mission. Contact us to learn more about our services or the world of nonprofit compliance—we’re happy to help.
To keep learning about nonprofit regulations and state filing requirements, continue your research with these additional resources:
- Nonprofit State Filing Requirements: Complete Overview. State offices often require more than just a charitable solicitation registration. Learn more with this crash course on what to expect from different jurisdictions in the US.
- Charitable Solicitation Registration: A Compliance Guide. Want a deeper dive into the fundraising registration process? We’ve rounded up all of the essential aspects to know in this complete guide.
- Directory of Nonprofit Regulations and Requirements. For more information on other elements of nonprofit compliance, including tax exemption, political activity, and donor substantiation, check out our directory of helpful resources.