LeadingAge has filed comments to a proposed rule issued by the Internal Revenue Service (IRS) that would allow charities to voluntarily forgo the current gift substantiation process of providing contemporaneous written acknowledgments (CWAs) upon the request of donors in favor of filing a new annual form with the IRS, in addition to the already-required Form 990. The new form would include donor names, addresses, and Social Security Numbers for all gifts in excess of $250. In addition to collecting donor information and filing the additional form, participating charities would also be required to provide each donor a copy of the report that contains his or her personal information. LeadingAge commented that the rule, while presently optional, would pose serious compliance obstacles and carry with it the potential for significant limitations on members’ ability to sustain their current level of fundraising. Click here to read LeadingAge’s comments.