Friday, January 3, 2014

Source of Funding electronic forms a year late and a C3 short

Well here we go again.

It's time to file client semi annual reports.

And after a solid year of delay and incompetence the JOKE has finally provided for the disclosure of source of funding on the electronic filing system.


Now please tell us who gets the credit for this giant leap forward in technology use?

A solid year to get this up and running.

Had to be done by outside consultants.

I wonder what they charged?

As long as it took they must have charged by the hour.

But here is the strange part . . . after a year did anyone actually think about the regulated community and how they would use it?

Here is my point, and you would have to be a regular user of the system to understand the frustration.

As you are filling out the form you get to the tab for source of funding.

Now if you meet the requirements the system tells you to select either "Reporting is required and will be uploaded" or "Reporting is required and will be filed on paper"  simple and straight forward and there are directions online that tell you how to fill out the excell spreadsheet.

Now if you have an exemption pending or granted (you know those groups that requested exemptions even though they had not filed in the past - but that's for another blog) there is a selection for that as well.

If you do not meet the $50000 or 3% threshold there is a selection that states "Reporting is not required - under spending threshold".  Now its not clear if that is the $50000 threshold or the 3% but lets give the Joke the benefit of the doubt and say it applies to either.  And this will be the vast majority of filers.

If you meet threshold but have no applicable contributions there is a selection that says "Reporting is not required - no applicable contributions"  Now I'm not sure what that means and the directions do not explain it but it must mean you have met the threshold but have no one who has contributed over $5000.  I can't imagine how that happens but all those for profit businesses that hire lobbyists and meet the threshold will probably select this one.

And it's important that you select one because you cannot complete the form without doing so.

And that is the first problem because the electronic filing forms are suppose to mirror the paper forms and those filers using paper forms do not have to disclose why they are not submitting the source of funding disclosure they just leave it blank.

Electronic filers will now have to make an affirmative statement under oath.  I don't know about anyone else but I like to be sure my statement is truthful when  I have to do so under oath.

Well whats the big deal you may ask.  From what I stated above it might be a little bit of a blurred line for those selecting the last option and I would suggest a selection of not reporting would have been more consistent but who is hurt by the specificity contained in the selections?

501c3 are hurt that's who.

You see a c3 is exempt from reporting.

Not because they are under threshold, not because they don't have contributors but because they are EXEMPT by statute.

Which selection does a c3 make under oath?

Come on JOKE you had a year to get it right it's not that hard.

As for those of us who have to live with JJOKE screwups just put out an eblast that says either reporting not required is permissable for those that don't have to report.


Is there a new competent well informed regime at JCOPE?

It appears there just might be.

Lo and behold the Source of funding electronic form has been modified to include a selection for 501c3 entities.

Now I'm not going to take credit even though it was on the blog before the change  Lets just say the new JCOPE administration is on the ball and reacting in a positive manner to the regulated community and there issues,


I spoke too soon and JJOKE is overreacting to the blog.

They have just modified the paper forms to match the electronic forms (SMART) but did so by requiring an addendum to be filed to existing paper filings (DUMB TIMING)

I get that you want to be consistent and had the addendum been part of the original csa form no big deal but it is seperate, it requires another signature by the client and THEY DID IT IN THE MIDDLE OF THE LAST WEEK TO FILE

Are they crazy?

And no notice or announcement either.

It's like we are at a jersey shore house party and the cast forgot the red solo cups and are telling guests go out and buy your own.

Do they know how many clients will not know to file the addendum?

Do they have any idea of the additional work they just made for the regulated community?

Do they care?

Just when you think things are improving it is like they brought back the old Ginsberg crowd or the old Biben crowd . . . wait a minute most of them are still there   now it makes sense.

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