LWVNM Collaboration Agreement with Affiliated Leagues
Approved 4/25/26
BACKGROUND
The League of Women Voters of New Mexico (LWVNM) operates as a 501(c)(4) to engage in legislative advocacy, voter education, and membership activities in New Mexico. Although part of its budget can be financed by tax-deductible money, direct contributions to the organization are not deductible for donors. The League of Women Voters of New Mexico Education Fund (Ed Fund) was established as a 501(c)3. The Ed Fund is a separately incorporated legal entity, with separate and distinct bylaws, board of directors, bank account, financial records, meetings, minutes, and letterhead.
Although they are separate entities, LWVNM, New Mexico’s four local Leagues, and the Ed Fund share a dedication to empowering everyone to participate fully in our democracy. In pursuing that empowerment, LWVNM, the four local Leagues, and the Ed Fund may collaborate, and the Ed Fund may offer grants to LWVNM or a local League exclusively for 501(c)(3) permissible uses. This Agreement sets out the ways in which LWVNM, the four local Leagues of New Mexico, and the Ed Fund will assure that their affiliation and collaboration are consistent with protecting the Ed Fund’s status as a 501(c)(3) organization under the Internal Revenue Code.
501(c)(3) PERMISSIBLE SPENDING GUIDELINES
The Ed Fund is committed to making only expenditures allowed by IRS guidelines, for both the projects it manages directly, and for the projects it might fund that would be carried out by an affiliated entity. Prior to applying for a grant or seeking reimbursement from the Ed Fund, all affiliated Leagues should familiarize themselves with the relevant IRS publications, including the IRS Compliance Guide for Public Charities (Publication 4221).
Permissible activities for which the Ed Fund will consider grants or reimbursement to an affiliated League include nonpartisan candidate forums, voter guides and related promotional expenses, and voter registration events.
Any activity or project managed by the Ed Fund or for which a grant is sought from the ED Fund must: --Serve the public and not League members exclusively; --Be educational in nature and designed to inform the public in a fair and objective manner; --Document, in the event of joint operating costs, the allocation of expenses between permissible and non-permissible activities; --Not involve substantial advocacy for a position or policy, or urge action on a piece of legislation or rule at the local, state, or federal level; --Not involve work with political parties or candidates for office, other than nonpartisan voter service activities. --Not be used to promote League membership operations.
GRANTING PROCESS
The Ed Fund Board is responsible for stewardship of the charitable donations it receives, and has final discretion in determining whether a project meets IRS guidelines. The Board’s review of grant applications from affiliated entities will include a review of the sufficiency of approved Ed Fund budget items; a prioritization of grant requests; compliance with IRS and Ed Fund Guidelines; compliance with the League’s Diversity, Equity, and Inclusion Policy; consideration of whether the Board has sufficient information about the project proposed for funding; and whether the planned reporting for the project will sufficiently document permissible use.
The Ed Fund Board will communicate with local Leagues in a transparent, fair and timely manner so that each League is given the same information and opportunity to request funds. The Board will develop a protocol to determine how limited funds will be distributed equitably among the local Leagues.
The Ed Fund Board president and treasurer will make a prompt preliminary determination as to whether a project meets IRS and Ed Fund guidelines, and is consistent with funding obligations, before submitting the request to the Ed Fund Board for review and action. In the event a project is not approved for the requested funding, the decision will be explained in writing.
Grant applications from affiliated entities must be approved by the board of that entity and be submitted on an Ed Fund Project Request Form by the board president or designee. To facilitate decision-making and reduce delay, the general terms of a funding request may be presented orally to the Ed Fund executive committee before the requesting League submits a written application.
Each written application for funding must include a project description, project goals, activities, and timeline, how it relates to the shared mission, an itemized budget with potential sources of other funding available for the project, an assurance that project activities are permissible under IRS regulations, and an assurance that timely reports on the project will be submitted. Delays or denials may occur if the Ed Fund Board requires additional information or has unanswered questions about the application.
Formal written approval for a project must be finalized by the Ed Fund president and the president or designated board member of the requesting League before any reimbursable expenditures occur. Expenditures must be itemized and submitted on the Ed Fund Reimbursement Request form. The League managing the project is responsible for keeping all project receipts, invoices, copies of products, and other documentation. Reimbursement requests may be submitted after a project is completed or in increments, with a $200 minimum for each increment. Requests for reimbursement may not exceed the approved budgets, and expenditures must be reasonable and verifiable.
COMMUNICATION with LWVNM and LOCAL LEAGUES
In addition to the correspondence the Ed Fund Board sends to affiliated Leagues related to specific proposals for funding, the Ed Fund will submit the treasurer’s report and meeting minutes to the LWVNM Board prior to each state board meeting, including reimbursements for expenditures that have been approved in advance.
[signatures on behalf of all 6 boards]
