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Member Comments Requested on New IRS Substantiation Regulations

November 24, 2015

The Internal Revenue Service (IRS) has proposed new regulations that would modify its requirements that nonprofits obtain a “contemporaneous written acknowledgement” for contributions of $250 or more, and AFP is requesting comments and concerns from its members about the proposal.

AFP is preparing official comments to the IRS regarding the substantiation regulations. As reported previously in eWire, the proposal creates a new information return document for donee (charity) reporting that may be used “at the option of a donee organization.” The full text of the proposed regulations can be found here.

What’s most concerning about the new document is that it would include information such as the donor’s taxpayer ID number (most likely, their social security number). Even if the use of the document were to remain voluntary (and it seems clear from previous actions that the IRS would like to make it mandatory at some point), some donors might require use of this document, which might affect an organization’s internal policies on privacy and data collection.

PLEASE SEND US YOUR COMMENTS! AFP is seeking input from members on the impact of these proposed regulations if they had to record and safeguard donor’ social security numbers, as well as other aspects of the new form. There are concerns about the added administrative burden (and privacy issues) regarding the safekeeping of donor social security numbers, especially for smaller charities.

With a comment deadline to the IRS of Dec. 16, AFP would like to receive your comments by Friday, Dec. 11. Send any input to Jason Lee, AFP’s general counsel, at

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