California Attorney General Webinar – Registration Delinquencies – October 30, 2018

The California Office of the Attorney General is streaming a live webinar on Tuesday, October 30, 2018, to assist charitable organizations that are delinquent in their registration with the Attorney General’s Registry of Charitable Trusts.

Join the Attorney General Charitable Trust Section for a live webinar to learn

more about the annual reporting requirements, understand the public

information about charitable organizations shared online by the Registry, and

obtain step-by-step instructions to bring a delinquent organization into



As mandated by state law, charitable organizations operating in California must

annually submit a report with the Attorney General’s Charitable Trusts Section that


  • A copy of the IRS Form 990
  • Renewal Registration Form (RRF-1 Form)
  • Applicable filing fees

Failure to file a complete report will result in a charitable organization’s status

as being delinquent with the Registry of Charitable Trust.


The webinar will be particularly helpful for organizations that do not have

attorneys or tax professionals to help with their filings.


Questions can be submitted live during the webinar.

Charity Registration

According to the Attorney General’s Guide for Charities:

All California public benefit corporations, and other persons or entities holding assets in trust for charitable purposes in California, must register with the Attorney General’s Registry of Charitable Trusts within 30 days of first receiving the assets. The initial registration is completed by filing the Initial Registration Form (CT-1 Form), along with a copy of the corporation’s articles of incorporation, bylaws, and a registration fee. Also provide copies of the corporation’s application for recognition of federal tax exemption and the determination letter issued by the IRS, if this process has begun or been completed. All California public benefit corporations required to register with the Registry of Charitable Trusts must also renew their registration by filing an Annual Registration Renewal Free Report (RRF-1 Form).

Notwithstanding the foregoing, California Government Code Section 12583 provides that certain types of organizations are exempt from the filing, registration, and reporting provisions to the Registry. Generally, governmental entities, religious organizations, educational institutions, hospitals, and health care service plans are among the types of organizations that are exempt from such provisions.

For more information about California’s registration requirements, see the Attorney General’s webpages on Initial Registration and Annual Registration Renewal. For Charity Registrants in Current status with the Registry of Charitable Trusts, there is a Charity Registration Online Renewal System that may be used  to submit annual renewal data and supporting documentation in lieu of mailing the Form RRF-1 and supporting documentation.


If an organization subject to the registration requirement fails to annually renew its registration, it will be listed as Delinquent in the Registry’s database. Late fees of $25 per month may be assessed, and if the delinquency is not remedied, it may result in a permanent suspension. 

A person or entity subject to the registration requirements of Government Code section 12580 et seq., must be registered and in good standing with the Registry of Charitable Trusts to operate or solicit for charitable purposes. A registration that is delinquent, suspended or revoked is not in good standing and is prohibited from engaging in conduct for which registration is required including, but not limited to solicitation for charitable purposes. – 11 CA ADC § 999.9.4

Charities operating or fundraising in California, whether or not incorporated in the State, should check their current status with the Registry here. If your charity is not listed on the Registry and is not exempt from registration, you should watch the webinar and visit the Delinquency page on the Attorney General’s website.

Registration Q&A from the AG’s Guide for Charities

“We are a foreign nonprofit corporation. We do not operate any programs directed to California, we have no board meetings in California, and we own no property in California. Do we need to register and file annual reports if all we do is solicit donations on our website without actively seeking out donors who reside in California?”

If the charity is not actively soliciting California donors and otherwise does not do business or hold property in California, then registration and reporting may not be required. By actively soliciting California donors, this means the charity is targeting or focusing on Californians for solicitations, as opposed to donors nationwide. For example, actively soliciting California donors includes a charity having a fundraising campaign purposefully directed at Californians, soliciting donations through California work campaigns, sending fundraising e-mails or mailings to those the charity knows or reasonably should know are California residents (including prior donors that move to California), or having website content that targets donations from California and other particular states. Yet simply having a “donate button” on one of the foreign charity’s fundraising websites, without more, would not be enough to trigger charitable registration and reporting in California.

However, another factor to consider is whether a foreign charity has received substantial donations from California residents, even when the charity does not actively solicit California donors and otherwise does not do business or hold property in California. Should this be the case, registration and reporting in California may be required. If there is any question about whether a foreign entity must register, contact the Registry at (916) 210-6400.