Letters Needed on New Postal Service Regs'Write Now!
(June 14, 2004) Comments to the United States Postal Service (USPS) regarding its proposed new "exclusive purpose" regulations are due by June 18, and all U.S. charities and fundraisers are encouraged to write letters.
The proposed rule would change the guidelines for sending charitable solicitations and force many charities to pay First-Class postage rates for their mail. Itwould no longer permit charities to distribute letters with dual purposes (education and fundraising) if it contains personal information about an individual other than name and address.
If a nonprofit mailing piece is personalized beyond name and address, the purpose of the mailing can solely be for fundraising. Otherwise, it must be sent First Class, forcing the charity to incur additional costs -- as much as 20 cents per letter.
Under the proposal, personal information would only be permitted in letters where:
- Advertising and solicitation are the exclusive purposes of the letter.
- The personal information included in the letter is directly related to the advertising or solicitation and is used only to increase the effectiveness of the advertisement or solicitation.
This would be an extremely burdensome change for many charities that include educational materials with their solicitation letters. It also would be a difficult standard to enforce, as it could be argued that some educational material is critical for the solicitation activity so donors can understand why charities need the money.
The USPS is accepting letters only by mail (no fax or email). However, even with the deadline looming ahead (June 18), AFP strongly encourages all members to write letters to the USPS this week and mail them as soon as possible. In most instances, federal agencies will consider letters received shortly after a deadline.
A sample letter developed by the Alliance of Nonprofit Mailers is below that members should personalize before sending. A copy of the request for comments by the USPS can be found by clicking on the Attachments section at the end of this article.
Your letter should focus on three points:
- Who you are and how your organization uses the Nonprofit Standard Rate to further your mission. How much your organization spends on postage annually and what that amount represents in your budget. (For many mailers that figure represents one of the top expenditures faced every year.)
- Use your own words and show exactly how this change would impact your mission. The USPS has expressed an interest in seeing sample mailpieces to show how you rely upon multiple use fundraising mailpieces.
- Ask the USPS to support efforts that will address the personal /personalized issue without harming the nonprofit community's access to the preferred postal rate for multiple purposed fundraising and educational campaigns.
Sherry Freda Manager, Mailing Standards U.S. Postal Service 1735 N. Lynn St., Room 3025 Arlington, VA 22209-6038
Dear Ms. Freda:
As [TITLE] of the [ORGANIZATION], I want to call your attention to a very serious problem. Under the proposed USPS rule of April 19, [ORGANIZATION] would not be able to use the preferred nonprofit postal rate to raise funds and disseminate information or share other important program-related materials to our constituents. [Or, describe how you use the mail.]
In this time of budget cuts and belt-tightening, the [ORGANIZATION] and other groups like us are more necessary than ever before. We rely upon the mail to raise funds to address our mission. A rule change that prohibits the use of Nonprofit Standard rates would severely hurt our programs and negatively affect the people we serve in [YOUR CITY] and throughout America.
In drafting the new rule, we are concerned that the USPS was not aware of how charities approach their mail campaigns. Nonprofit development campaigns usually serve multiple purposes -- to raise awareness, educate the public or to motivate action, for example. These multiple purpose appeals are often the only contact a donor has with a charity and may be the sole impetus for giving. This rule would prove extremely costly to charities because they would have to sort their mailings into education and fundraising categories, increasing expenses at a time when the public and donors are encouraging charities to be as cost-efficient as possible.
In addition, the proposed ruling flies in the face of AICPA SOP 98-2, which allows charities to allocate costs for a mailing jointly among program, fundraising and administrative expenses. In order to allocate costs jointly among program, fundraising and administrative expenses, this new rule dictates an exclusive purpose test that would prevent us from using any "personal information," such as a donor's contribution history or other relevant giving information in our multiple purpose campaigns -- or we must mail at the First-Class rates.
The new rule would harm the nonprofit community's access to the preferred postal rate for multiple purposed fundraising and educational campaigns. Please consider a revision that would protect nonprofit access to the preferred rates of nonprofits so that we may continue using the mail to further our good work.