Distributed Fundraising: Frequently Asked Questions

Trust us, since we incorporated our own organization: incorporating takes a lot of time, reams of paperwork, and hundreds (or potentially thousands) of dollars in fees. On top of that, each type of non-profit has a variety of legal restrictions—for example, 501(c)(3) organizations are generally prohibited from taking part in elections. By using the national Indivisible fundraising system, you won’t have to worry about managing your donations, and we’ll handle a lot of the paperwork on the front end.

You can see information about common legal structures here. If you choose to become a legal entity, your group would be responsible for forming the entity and remaining compliant with fundraising, spending, and reporting. Indivisible staff cannot assist with that.

The distributed fundraising account is completely separate from your legal entity, and does not serve as your legal entity’s bank account.

If you have additional questions about compliance and reporting for spending or fundraising outside of the distributed fundraising program, contact a lawyer and/or tax professional in your state.

Donors will have the opportunity to contribute to local Indivisible groups, our national organization, or both! We view our local and national fundraising efforts as collaborative and promised in our fundraising philosophy that we will try not to compete with local groups’ fundraising efforts. We want your fundraising efforts to be a success and to support your group’s activities, and we will be providing toolkits, resources, and campaign ideas to help you do the most effective fundraising you can. Within ActBlue, you will have direct access to everyone who’s donated to you so it’s easy for you to follow-up with your supporters.

At the same time, we’re proud to be fueled by small dollar donations at the national level because it ensures we’re most accountable to the millions standing indivisible across the country. We’ll continue to pursue donors across the country, including those who give to your local groups.

Groups are free to leave the program if it does not meet their needs. If you would like to leave, please reach out to fundraising@indivisible.org.

Candidates for public office and public elected officials may not hold the treasurer position. If your current treasurer becomes a candidate for office they must immediately resign from their position by emailing fundraising@indivisible.org. Note: This only applies to positions that appear on ballots for all voters in your jurisdiction.

The treasurer can be any other member or leader of your group that is not a candidate or elected official.

The treasurer that you list on the distributed fundraising program application will:

• Sign the distributed fundraising program agreement, agreeing to follow the rules of the program
• Serve as the primary point of contact to receive any updates about the distributed fundraising program from Indivisible
• File all necessary reports including monthly reports and political spending reports
• Have the TrueLink debit card issued in their name
• Be responsible for making sure that all expenses are permitted

The treasurer should be able to complete the following technical tasks to fulfill their role:

• Successfully create site logins by entering an email address and password, checking email (including spam) to confirm account details, and request replacement passwords as needed; sites include ActBlue, and Truelink (login information for your Truelink account is the last four of your card, the last for of your SSN, and your date of birth)
• Open, edit, and save csv files OR open and save PDF files
• Save, find and attach jpeg or pdf files

If your original treasurer can no longer fulfill their duties, your group can switch treasurers. Fill out the form here and we’ll be in touch with next steps.

You can join the distributed fundraising community Facebook group here! This is a place where Indivisible group leaders and treasurers can discuss experiences using the distributed fundraising program to learn and connect together.

Though there are ActBlue and TrueLink debit card fees, Indivisible now pays those fees on groups’ behalf so that 100% of the funds your group raises are deposited onto your debit card to spend on permitted group activities. In short – there are no longer fees for your group!

Groups do not receive tax-exempt status though Indivisible when they’re formed. Groups may, on their own, choose to apply for tax-exemption directly with the IRS or remain unincorporated. You can find more information on groups and common legal structures here. This means that Indivisible cannot provide proof of nonprofit status for group events, meetings, or expenses.

For all funds raised outside of the distributed fundraising program, you are responsible for complying with any reporting and compliance requirements. Indivisible will not ask for information about this activity or provide any oversight.

Election Work:

• If you’re spending funds, outside of the distributed fundraising program, to pay for communications (mailers, phonebanks, textbanks, lit drop, paid ads etc.) that are in support of or in opposition to a specific candidate for federal office, this could meet thresholds requiring reporting through the FEC. Indivisible staff are not able to consult on this topic if it is being done outside of our programs, so we encourage you to check the FEC website to ensure you are in compliance.
• If you’re spending funds, outside of the distributed fundraising program, to pay for communications (mailers, phonebanks, textbanks, lit drop, paid ads etc.) that are in support of or in opposition to a specific candidate for state or local office (schoolboard, city council, Mayor, State Assembly, Governor, etc.) or ballot measures, this could meet thresholds for requiring reporting through state or local election laws. Indivisible staff are not able to consult on this topic if it is being done outside of our programs, so we encourage you to check your secretary of state’s website to ensure you are in compliance.

Direct and Grassroots Lobbying:

• If you are spending money, outside of the distributed fundraising program, to do activities that are intended to support or oppose legislation at the state or local level, this could require you to report grassroots and/or direct lobbying activities. This activity could include hosting lobbying days, doing a texting/email/phone/social media campaign to encourage neighbors to call their elected officials, or even planning to put together those types of activities. Indivisible staff are not able to consult on this topic if it is being done outside of our programs, so we encourage you to check your state and local statutes. You can also find a summary of the state laws here: https://www.ncsl.org/ethics/lobbyist-registration-requirements, however, Indivisible can not vouch for the accuracy of this resource.

Taxable Income:

• If you are concerned whether your activity outside of the distributed fundraising program creates taxable income, we encourage you to consult an income tax professional. Indivisible staff are not able to consult on this topic if it is being done outside of our programs

Fundraising considerations:

• Fundraisers via raffle, auction, bingo, or other games of chance are regulated at the state and sometimes local level. Compliance for these events often involves applying for a license, strict rules for selling tickets, as well as restrictions and reporting on the use of proceeds. We strongly recommend against fundraising via games, but if your group chooses to do so they should consult a lawyer familiar with their state’s gaming laws.

If you have additional questions about compliance and reporting for spending or fundraising outside of the distributed fundraising program, contact a lawyer and/or tax professional in your state.

There are lots of ways you can raise funds for your group using the distributed fundraising program! Some of the most common are via email and social media, or in person at events. You should be aware of restrictions around certain types of fundraising activities. You can see more fundraising advice and information here.

Yes! We will create a template ActBlue fundraising page for you, which you can use as-is. If you prefer, you can directly edit your ActBlue page by following the instructions here.

We recommend including information about your group’s activities and mission. Ideally, the page is specific about what your group does and gives some level of detail, but is not so detailed or time-specific that you’ll need to update it frequently or that you’ll be legally restricting the donation. If you list specific types of spending as examples, it should be clear that those are examples and not the exact things you’ll spend funds on.

Be sure not to ask for support for any work that is not allowed within the distributed fundraising program.

If your fundraising asks are paid (like a Facebook ad) and you’re mentioning a candidate, you should go through the political spending approval process before spending funds on that ask.

If you need any assistance drafting your fundraising page ask, reach out to fundraising@indivisible.org.

 We prefer that all donations come through your group’s ActBlue page. Funds donated online are the easiest for us to process.

If you have donors that would prefer to contribute via check, we are able to accept checks of $50 or more. Your group is responsible for taking in all checks and ensuring the following guidelines are met:

1. Checks must be made out to “The Indivisible Project.” Please note that contributions to Indivisible Project are not tax deductible as charitable contributions or as business expenses under IRC Section 162(e).
2. The name of your group must be included in the memo line.
3. Checks MUST be accompanied by a deposit form that can be downloaded here.
4. Mail the check(s) and deposit form to the address listed on the deposit form.
5. The deposit form and your group’s name in the memo line are the only way we can distinguish between a gift that is intended to support your group versus a general gift to Indivisible.

You could keep the cash outside of the distributed fundraising account. You’d be responsible for any reporting associated with the spending of funds outside of the distributed fundraising account and the national organization would have no oversight related to those funds.

A group leader can collect the funds and then give a donation in that amount via ActBlue or check without that donation being reported to the FEC as an individual contribution if the total collected donation is $200 or less. All individual donations over $200 will be recorded as personal donations by the person donating via check or ActBlue, and are reportable to the FEC.

Your group will have a unique ActBlue donation page with your group’s name and information.

ActBlue does send email receipts to donors.

Yes, you can find more information here.

First, when you advertise the event, make sure that you clearly state the purpose of the event (issue area or legislative process) and that this is not a candidate event.Then, at the event, you should remind everyone in the room that you’re there to discuss issues and strategies for winning support for our positions on those issues. Here’s a helpful script:

“Hey everyone, I just wanted to make everyone aware that the purpose of the meeting today is to discuss issues, not to discuss supporting or opposing candidates for office. We may have discussions about candidates at a later date, but the purpose of this meeting is going to focus strictly on issues and is nonpartisan.”

If the candidate chooses to ignore that disclaimer and talk about him/herself as a candidate or tries to share campaign literature, politely remind them that it is inappropriate to talk about candidates at this particular event and try to refocus the discussion around the issues you’re there to discuss. Sometimes people are stubborn or just don’t get it, but your job is to ensure that the organization’s purpose is made clear and that the meeting does not get hijacked for other purposes.

In some instances Indivisible national is able to accept grants on behalf of groups through the distributed fundraising program. If you’re looking to accept grant funds through the program, contact fundraising@indivisible.org for next steps. Our legal, finance, and fundraising staff will assess whether we’re able to accept the grant. We do our best to work with groups and grantors to accept grants, but it’s not always possible. The decision making process, and agreement process if the grant can be accepted, usually takes 2-4 weeks.

Here are some things to note about grants accepted through the program:

• The funds must be granted to “Indivisible Project,” and will then be given as a sub-grant to your group. This requires all parties (your group, Indivisible Project, and the grantor) to sign a grant agreement (or agreements). Our legal staff will help draft the agreement(s).
• Your group is responsible for all reporting requirements, tracking of grant spending, and maintaining a relationship with the grantor (if required). Your group is still responsible for normal monthly reporting with Indivisible national.
• We are only able to accept grants from nonprofits, not corporations. Usually the nonprofit will need to be a 501(c)(4), but depending on circumstances it may be possible to accept funds from a 501(c)(3).
• The purpose of the grant spending must align with allowed spending within the distributed fundraising program, and should not be especially restrictive. It’s less likely that we’ll be able to accept the funds through the program if the spending is for partisan political activity.

Indivisible also offers a grant program called GrassRoots Organizing Wins (GROW) which supports group collaboration and capacity building. Groups can apply for grant money for projects, supplies, trainings, venues, vendors, and more. This program is administered through the distributed fundraising program. You can find more details here.

Starting on August 15th, 2020 all individual donations to groups in the distributed fundraising program over $200 will be disclosed to the FEC.

• Who will be affected: Donors to your group who make a donation over $200
• What information will be disclosed: Name, address, occupation, employer, date of contribution, and amount of contribution
• How will you get this info?: ActBlue automatically collects most of this information. If we need to confirm or collect occupation and employer information, we will reach out to donors who give over the disclosure threshold.
• Will donors be notified?: Yes, we will email donors who donate a gift over $200 to notify them that their donation will be disclosed to the FEC.

Indivisible’s fundraising philosophy states the following, and this extends to groups within the distributed fundraising program:

• We won’t accept funding from political parties, their leaders, and candidates for office to avoid any appearance of influence on our strategy.
• We will never accept funding from corporations.

In short, it’s not permitted to accept donations from political parties and their leaders, candidates for office, or corporations.

It is not permitted to sell tickets for events via your distributed fundraising account. You can hold an event where you suggest that attendees make a donation of a certain amount to your group.

It is not permitted to sell items via your distributed fundraising account. You can give out items and suggest a donation to the group.

If you’d like to sell items a member can do that personally and collect the funds personally, then donate them to the distributed fundraising account. Be aware that this may create taxable income for the individual. Any donation to your group over $200 will be reported to the FEC.

For federal, state and local elections, and ballot measures, it is NOT permitted to spend on:

• Contributions to candidates, campaigns, parties or PACs
• Travel to a candidate led canvass or candidate event
• Food that will be provided at a candidate led canvass or candidate event

Communications

Yes, for paid communications that support or oppose federal level candidates where you don’t coordinate with the campaign/candidate/party and the content is pre-approved by Indivisible. More information here.

No, for paid communications that support or oppose state and local candidates or ballot measures.

Events

For federal elections it IS permitted to spend on:

• Travel to an Indivisible canvass, or canvass led by another organization running an Independent Expenditure program  but NOT an organization that’s coordinating  with a candidate, campaign or party
• Spending money to purchase personal food before or after canvass led by another organization running an Independent Expenditure program  but NOT an organization that’s coordinating with a candidate, campaign or party
• Candidate questionnaires or hosting a non-partisan candidate forum for federal level candidates. Please email fundraising@indivisible.org to discuss more in depth.

Here are options for hosting a federal candidate at an event that’s being funded with distributed fundraising:

• Host a no cost event.
• Host the candidate for a small portion of a group event. I.E. the candidate could come to the last 15 minutes of a monthly group meeting. Regular meeting expenses are ok in this situation.
• If the candidate is a sitting elected official then they can be invited in their official officeholder that capacity. The Ssubject matter of the event should only involve official-side business, no campaign speeches, materials or solicitationsing.
• Hold a nonpartisan event such as a debate or town hall with all Dem candidates in the Primary or both Dem and Rep candidates for the general. Please email fundraising@indivisible.org to discuss more in depth.
• None of these events should involve fundraising for the candidate, or the candidate or the group sharing non-public strategic info about their campaign or election activity.

General costs

For federal, state and local elections but not ballot measures it is permitted to spend money for the benefit of your group on the following:

• General event supplies (i.e. pens/markers, clipboards, paper/poster board, speakers or other tech or supplies that are to be used at multiple events over the year)
• Canvassing supplies for use by the group only (i.e. snacks, sunscreen, water bottles, hand sanitizer, hand warmers, etc)
• Costumes or props that do not include written electoral messages
• Nonpartisan Activities:
  • GOTV messages without reference to any party or candidates (i.e. Vote on November 4, 2025) See specific rules here as it relates to Arizona.
  • Nonpartisan voter registration (state rules may apply)
  • Educating voters on the electoral process (i.e. how early voting works, information on vote by mail, ID required for voting, registration or election deadlines)

No cost activities

For any federal, state or local election, you can engage in activities that don’t have a direct cost:

• Unpaid, organic social media activity, including reposting a candidate’s public content, linking to their fundraising pages, or unsponsored posts expressly advocating the election or defeat of a particular candidate.
• Press releases
• Letters to the editor
• Time spent on GOTV activity (i.e. participating in a partner-org canvass or phone-bank)
• Attending public rallies, protests, etc.
• Participating in public volunteer opportunities with a candidate, campaign or party

You can view the spending rules here.

It is permitted to pay vendors but not independent contractors or staff.

A vendor (permitted to pay) sells a good or service on a transactional basis and provides it widely to potential clients and often has multiple clients at once buying their goods and services. They serve as a “partner” that provides a good or service that contributes to the supply chain and the steady flow of operations for a business or organization. The client determines the exact good/service they want and when and where it should be provided. For the purposes of Indivisible groups, this would be something like a company that provides catering for monthly group meetings, audio visual support for a protest/rally, or even a software that the group uses to manage their contacts. The vendor provides an invoice or receipt for the specific service that they provide and the nature of the relationship is transactional and does not need to be ongoing.

An independent contractor (not permitted to pay), however, is often brought on to do work for the company or organization using a contract that defines specific projects that they are completing for the client for a defined period of time. They have independence in how they complete the task and provide specialized skills to complete a series of goals and deliverables on a certain timeline. For the purposes of Indivisible groups, an example of an independent contractor would be someone who is brought on to work with the group leaders to strategize on how to recruit more people to the group meetings, how to plan a protest/rally, or how to manage your data within the software the group purchased from a vendor.

When understanding the difference between the two, look at:

• The Nature of Relationship: Independent Contractor relationships are project-specific and time-limited, whereas vendor relationships can be ongoing, but are transactional where vendors are providing a consistent supply of goods or services.
• Independence vs. Partnership: Independent Contractors operate independently, managing their own time/resources and working towards project goals. Vendors, on the other hand, engage in more of a partnership, focusing on maintaining a steady and reliable supply chain and the client controls the specifics of the good or service they are purchasing.
• Project-Based vs. Operational Support: Independent Contractors contribute to specific projects, bringing specialized skills to accomplish defined goals. Vendors, on the other hand, contribute to the overall operations of a business by providing essential goods or services.

If you have any questions, reach out to fundraising@indivisible.org.

If the Facebook ad is for general group activities, events, and recruitment, then funds raised through the program may be spent without pre-approval.

If the Facebook ad supports or opposes a candidate for elected office, your group must request pre-approval through this form. It will also require that an Indivisible staff member is an administrator on your group’s page for the length of the run of the ad so that the ad will have the correct disclaimer. When running ads to support or oppose a candidate, you will not be able to run other non-political ads concurrently. If you are interested in running political ads on Facebook, please reach out to fundraising@indivisible.org for more information.

Much like work on candidate elections, work on recall petitions is typically considered partisan political activity. Since recalls can only happen to officials governing at the state and local levels, then work on recall petitions or elections are not permitted through Distributed Fundraising since partisan political work at the state and local levels is not permitted through this program.

With funds raised via the distributed fundraising program,it is permitted to:

• Donate funds to a 501c3 organization, 501c4 organization, school or hospital
• Donate items to a 501c3 organization, 501c4 organization, school or hospital if the amount is $500 or less per expense

With funds raised via the distributed fundraising program, it is NOT permitted to:

• Donate funds directly to an individual or a GoFundMe page
• Donate items directly to an individual
• Pay for mutual aid costs directly on behalf of an individual (ex: legal fees, etc)

Individuals in your group can do mutual aid work directly, outside of the distributed fundraising account. You can also take part in activities that don’t involve spending money such as:

• Sharing mutual aid opportunities, GoFundMe pages, or other fundraisers on social media
• Including actions to get involved with mutual aid opportunities in your group emails
• Including information on your website that leads folks to local mutual aid organizations

All spending for political activity requires pre-approval. Just fill out this form here and you’ll receive a reply promptly after your request has been reviewed.

True Link is a third-party vendor that provides debit cards. When you sign up for a distributed fundraising account, they will send you a card in the mail.

If you have any issues with the True Link platform or card, you can contact their customer service at 1-800-299-7646 or send an email to support@truelinkfinancial.com. The support team is fully staffed Monday – Friday 6AM – 5PM PT. True Link also has a smaller staff on the weekends that returns voicemails and emails during business hours. If at any time you try to reach True Link and are not able to, you can leave a voicemail or send an email, and True Link will return your message in a timely manner.

Each group will receive a debit card that you’ll be able to use to access the funds you raise through your ActBlue page. We’ll send you the card after you start raising funds through ActBlue. Funds raised through ActBlue are transferred to the debit card every two weeks. Please note that we are unable to transfer less than $1. If this is the case, these funds will be added to your next transfer.

We will transfer funds from ActBlue to your True Link card every two weeks. However, the first transfer may take longer because you will have to receive your card in the mail and set up your account before True Link can add the funds to it. Please note that we are unable to transfer less than $1. If this is the case, these funds will be added to your next transfer.

You can check the balance on your card using any of the following ways 24 hours a day, 7 days a week:

Phone call: You can check your balance anytime using True Link’s phone system. Simply call 1-800-299-7646. You can also hear recent transactions or request to speak to a representative.

Online: Visit https://www.truelinkfinancial.com/ and click the “Login” button in the top right corner. Then click the link that says “True Link card user log in.” Provide the last 4 digits of your Social Security number, your date of birth, and the last 4 digits of your True Link Card number. You will then be able to see your balance, monthly statements, and recent transactions.

Text message: As long as True Link has your mobile number on file, it is very easy to check your balance from your phone. (Standard text message rates may apply). Send the word “balance” to 1-800-299-7646. If you receive an error message, please call their Customer Support team at 1-800-299-7646 to make sure your number is on file.

In the event that you are unable to use your True Link card to make purchases for your group, you are permitted to link your card to the mobile payment app Venmo to make reimbursements.

If you wish to reimburse other group members this way, you are required to submit itemized receipts along with your monthly report. Please remember that as your group’s treasurer, you are solely responsible for ensuring that all expenses fall within our spending guidelines, which can be found here. If you have any questions about permitted expenses, please reach out to fundraising@indivisible.org prior to making the reimbursement.

You should use only personal Venmo accounts, not business accounts. Anyone can create a Venmo account using these instructions. If you already have a personal Venmo account, that’s what you should use for this purpose. Venmo only allows one account per phone number, so you won’t be able to set up a separate personal and group account with the same phone number.

Linking your True Link Card to Venmo (This should be done for the person who will PAY others, someone that does not need to be reimbursed themselves )

• Open the Venmo App on your phone
• Tap the icon at the bottom right that says “me”
• Tap the gear icon in the top right
• Tap “Payment Methods”
• Tap “Add bank or card…” and then tap “Card”
• Select debit card
• Add your card information manually or with your phone’s camera

Make the payment (This should be done for the person who will PAY others)

• Make sure you have the username of those you need to pay – (you can find it by opening the app and navigating to the bottom right person w/ dollar sign. The username will be at the top and start with @)
• Open the Venmo App on your phone
• Hit “Pay or request”
• Enter the person’s Venmo username
• Select them from the drop-down list
• Enter the amount and a description
• Hit “Pay”
• Confirm payment

For extra security, we suggest that you do NOT make your TrueLink card the default payment method. When sending money to someone in Venmo, you have the option to switch your payment method before you pay. We suggest selecting your TrueLink card (which will say “Sunrise Banks”) at this point so you don’t accidentally use it when paying for personal expenses!

As a reminder, you must submit ALL itemized receipts for each reimbursement made through Venmo, so be sure to have all receipts in-hand before doing so. Please reach out to fundraising@indivisible.org with any additional questions or for assistance with linking your debit card to Venmo.

Via Venmo it’s not permitted to reimburse “yourself” with the funds, so you can disconnect the TrueLink card and reconnect it to another trusted group leader’s card who can process the reimbursement to you using the process above.

If none of these options work please see the next question down in the FAQ about how to get a check reimbursement.

The preferred method for reimbursements is to connect your True Link debit card to the mobile payment app Venmo. Instructions and guidance to do so can be found here.

Please note: Direct reimbursements should only be viewed as a last resort, and Indivisible will only make these in rare cases after every other avenue has been exhausted. Treasurers that are found to abuse the reimbursements policy — by intentionally paying through methods other than their TrueLink debit card (or encouraging others to do so), knowing that they have not successfully been able to link their debit card to a Venmo account and can request a direct reimbursement — will not be eligible for future reimbursements.

Before a reimbursement from Indivisible is considered, groups should attempt to connect their card to make the reimbursement themselves. If they are unable to do so, they should reach out to fundraising@indivisible.org to troubleshoot. Only after troubleshooting with the distributed fundraising associate and determining that it is not possible to provide their own reimbursement will a reimbursement from Indivisible be considered.

Additionally, the following guidelines must be met:

• Only treasurers with a signed fundraising agreement with Indivisible are eligible for reimbursements (we cannot provide reimbursements for other group members).
• Only expenses that are permitted through the distributed fundraising program are eligible for reimbursements.
• We cannot reimburse for partisan political expenses.
• The funds requested to be reimbursed must be available on the group’s TrueLink debit card at the time of the request.
• Treasurers need to fill out the reimbursement request form here.
  • The minimum amount for a reimbursement is $100. Multiple charges can be included with the reimbursement request form to meet this minimum.
  • Itemized receipts must be included along with the reimbursement request form.
• Reimbursements will run once a month. Reimbursement request forms submitted by the 5th of the month will be reimbursed by the end of that month.

Email fundraising@indivisible.org to alert us and we’ll walk through how you can reimburse for the purchase.

Each month that you spend funds, you need to log into the True Link website (www.truelinkcard.com) and download a copy of your transactions for the previous month. This report is available on the 5th and a reminder email will be sent to all treasurers that need to submit this report. A report is only needed if you spent funds the previous month.

After adding notes on the purpose for each expense (what, where, and why), you’ll submit the report here by the 15th.

It’s important for audit purposes that you submit your monthly report on time every month. Your report is due on the 15th day of the following month. As noted in the cardholder agreement, failure to submit accurate and complete monthly reports may result in your card being canceled. If your treasurer won’t be able to submit the report in time, please reach out to fundraising@indivisible.org so that it can be arranged for another group leader to submit the report.

If you do not have expenses for the previous month, you do not need to submit a report. We will send an email around the 5th of each month to treasurers that need to submit a report for the previous month’s expenses.

Yes! Please save all of your receipts in a file with a note about what the expenses were for. Indivisible is required to conduct random audits of group expenses to make sure that folks are complying with the rules above, and we may ask you to send us your receipts when doing so. Like most organizations, Indivisible also conducts an annual audit, and our auditors may ask to see your receipts for various purchases.