Recently, I noticed that an organisation’s FCRA renewal was denied due to issues related to
The association has received huge donation from UK Online Giving Foundation which is donor adviser fund and not the actual donor. Association has done incorrect filing in FC-4 form and accordingly it is refused U/S 16 read with section 18 of FCRA 2010..
Please advise on the next steps in such cases.
I’ve observed that nearly 80% of organisations receiving funds through platforms like UK Online, CAF America, and Benevity have not disclosed the original donor details who actually contributed via these intermediary platforms.
Thanks for the query. The two basic and cardinal principles under FCRA is that funds should come (a) from a foreign source and (b) for a defined purpose/project. Violation of these two hits at the very basis of the objective of the legislation. If the renewal application has been rejected, there are 2 options, (a) make application for revision of order if the details of foreign source can be obtained which may or may not be tenable or (b) make a fresh application for registration where the violation would linger.
You are right that FC funding from intermediaries or crowdfunding/giving platforms are coming. This would come to the notice of MHA during audit or renewal process only. Getting FC funds directly from donor with details and purpose therefore is critical for compliance.