New Membership Rules Not Needed

LETTERS TO THE EDITOR

To the Editor:

Peter Panepento’s article on how groups define “members” (“Behind the Numbers,” August 4) raised some interesting issues, but failed to acknowledge that the law already provides definitions of membership with which organizations must comply.

For example, tax law provides a definition of “member” for 501(c)(3) organizations that have made the 501(h) election [to determine how they account for the amount of money they spend on advocacy efforts]. A person is a “member” of an electing public charity if the person makes a donation of more than a nominal amount of money or time. That is just one of many definitions of “member” among the laws regulating nonprofits, which creates some of the confusion the article describes.

Under current law, organizations have discretion in determining who counts as a “member.” Based on the above definition, many public charities are probably undercounting members.

Every organization should determine its membership standard and then create and follow internal procedures to categorize supporters appropriately and consistently. There is no need for new federal rules to define and govern membership — in fact, more rules would only create greater confusion.

Nan Aron
President
Alliance for Justice
Washington