Exactly what to do
- Registration is expected in a state when you target its residents (ads, mailings, events aimed there) or receive repeated, substantial online gifts from them. A passive website alone, without targeting or a gift pattern, generally doesn't trigger it. Map your actual donor geography against the state-by-state chart.
- The states whose SGO lists you'll seek (stage 4) are the states where you'll actively court donors, so register there ahead of the campaign, not after the first gift lands. For §25F, listing in another state also takes being “located” there (authorized to do business, usually a foreign-corporation registration, and compliant with its charity laws), and that state’s account can fund only students who live in that state. Donors are different: under the proposed regulations a U.S. citizen or resident can claim the credit for a gift to an SGO on any participating state’s list, wherever the donor lives, so you can solicit donors well beyond the states you serve (registering wherever the Charleston test says you must).
- Once a year, pull the donor list by state and re-run the test; registration duties follow where your fundraising actually went. Add any new state's renewal to the calendar the day you register.

