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Federations Working with Maguire/Maguire Release Their CFC Reg Comments

5/1/2013

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​The federations served by Maguire/Maguire, Inc. have released their reaction to the government’s proposed CFC regulations. Below are some of their key points.
Others have also begun to submit comments to OPM. To date, the government has not published this material. We trust that will change soon.

As background, Maguire/Maguire, Inc. describes itself as “an association management firm that specializes in providing headquarters support services and member support services for America’s finest independent charitable federated groups.”
The commentary just now released opens with a statement of support for the OPM effort now underway: “We applaud OPM’s decision to modernize the campaign to make it a more efficient and effective giving vehicle for Federal employees and the charities they support.”

The letter continues:

“The most important counsel we can offer is this: Test. Test. Test.

“The proposed rules establish a campaign structure so fundamentally different – and the potential impact of campaign failure is so deleterious if the rules do not work as planned – that it would be imprudent not to test the new design first. We recommend testing the new system in one or two regions for at least two campaign cycles.”

The letter delves into 10 issues, offering recommendations such as:

“We support the concept of a charity application fee to underwrite the campaign expenses so that 100% of donors’ contributions can be distributed to the charities the donors have selected.”

“We recommend the application fee be a flat fee only, not percentage-based on charity size or previous CFC campaign revenues.”

“The prohibition on accepting cash/check gifts is unnecessary.”

“We endorse the idea of moving to an all-online campaign, but the regulations should provide for flexibility rather than a ‘one size fits all’ approach. An all-online campaign sounds good until you consider how many federal employees don’t have access to the web at work. Most major CFCs already offer online giving, but 84% of CFC givers still give by paper. The culture isn’t ready for an overnight change (and an all-online campaign is not something the CFC-50 Commission recommended).“

We invite people to read their entire letter.

While we do not agree with all their points, we do support what we believe to be their central recommendation: The government should proceed carefully with changes as sweeping as those now under consideration.
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    We are the Workplace Giving Alliance, a group of federations participating in the Combined Federal Campaign and dedicated to its success. These posts are written by Marshall Strauss, CEO of WGA.

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