Private organizations and fundraising on Scott AFB Published Sept. 26, 2008 By Capt. Robert Palmer 375th Airlift Wing Judge Advocate SCOTT AIR FORCE BASE, Ill. -- Sometimes it seems like every corner on base this time of year has private organizations fundraising. Holiday parties to raise money for the unit booster club; cupcake sales in front of the Base Exchange to raise money for the unit holiday party. Scouts collecting sundry items for wounded servicemembers; servicemembers collecting toys and coats for children at Christmas time. Chances are that conversations have been heard about those or like subjects on a frequent basis, or there is someone involved in a similar situation in the unit. It's good to know the basic ins and outs to negotiating all of the rules and guidelines that involve private organizations and fundraising on Scott AFB. Private Organizations are spouses' clubs, chiefs' clubs, unit booster clubs, etc. More formally, they're a group composed of military and/or Department of Defense members, not formally affiliated with the DoD, that have come together for a specific purpose (say, raising money for the unit holiday party), have a chartering document such as a constitution and/or bylaws approved by the installation commander and whose assets (assets meaning not only bank accounts, but property that the club owns and anything they might be stockpiling to sell to fundraise) exceed $1,000 a month for any consecutive three-month period. If a group's assets are below the $1,000 threshold, they are called an unofficial activities -- think less formal organizations like unit sunshine funds, flower funds, snack bars and other small operations. However, if the unit snack bar offers more beverage variety than Starbucks and rakes in a couple hundred bucks a week, it's probably over the monetary threshold and needs to incorporate as a private organization. For more information on incorporating private organizations, contact Lynda Lindsay at the 375th Services Squadron at 256-6324 or visit the 375th SVS website at www.375services.com and click on the Private Organizations tab on the lower right hand side. Private organizations and unofficial activities are important because they are the only entities that have the ability to fundraise on an Air Force Installation. There are some very basic and important rules about fundraising that can be categorized as when fundraising can occur, where fundraising may occur and a few other important general prohibitions. The most important rule here is that fundraising by private organizations and unofficial activities cannot generally occur during the Combined Federal Campaign or the Air Force Assistance Fund Campaign. The CFC is the world's largest and most successful annual workplace charity campaign, helping to raise millions of dollars each year to support eligible non-profit organizations that provide health and human service benefits throughout the world. Similarly, the AFAF provides an annual effort to raise funds for the charitable affiliates that provide support to the Air Force family (active duty, retirees, reservists, guard and their dependents, including surviving spouses) in need. Because of the great importance and wide reach of these programs, private organizations and unofficial activities are prohibited from fundraising on Scott AFB during these campaigns. The CFC runs this year from Oct. 3-Nov. 17. The AFAF ran this year from March 17-April 27. However, every rule has its exception, a drop box for canned goods or toys for children can still be seen during these periods. Non-monetary item drop boxes of food, coats or toys may be appropriate if they don't interfere with either campaign. There are two other basic when considerations to keep in mind for fundraising. Fundraising cannot be done during duty hours, although lunch hours are permissible. The other consideration for when a fundraiser can occur is only once the event has been coordinated with Services, had a legal review done by the legal office and has been approved by the installation commander or his or her designee. Next, is the consideration of where to fundraising. The general rule is not in the workplace. If a booster club's plan was to set up a hot dog stand in the wing conference room to feed starving meeting attendees and raise money for your holiday party, they will want to go back to the drawing board. Again every rule has its exceptions and in this case there are several places that are generally not considered to be the workplace: entrances, lobbies, concourses of buildings, schools, chapels, break rooms and base quarters. However, of course, the private organization's request to use these areas is still subject to the wing commander or his or her designee's discretion. Finally, there are a few very important general fundraising prohibitions to be aware of. Air Force members must not do anything that implies federal endorsement of a private organization's fundraisers/activities. That means not fundraising in uniform and not using government e-mail or letterhead to advertise. It also means using the following disclaimer when advertising in the local community, especially important for all those booster clubs that use a unit designation as part of their name,: "This is a private organization. It is not a part of the Department of Defense or any of its components and it has no governmental status." This disclaimer must also be provided in verbal communication and public announcements. Another general prohibition is no frequent resale activities and no competing with AAFES or Services affiliated activities. Occasional, the opposite of frequent, is defined as no more than two bake sales, carnivals, car washes, etc. during a given calendar quarter. Yet another set of general prohibitions involves those twin vices of alcohol and games of chance. Simply put, no selling alcoholic beverages of any kind and no poker nights, lotteries or other similar gambling activities. However, raffles can be held on an infrequent basis when they don't violate city, county or state laws, and they raise money to promote some charitable, civic or other community welfare purpose with the DoD community, and which directly benefits DoD personnel or their family members. A raffle where the proceeds go to military members whose belongings were lost in a hurricane is probably okay. A raffle where the proceeds are used to underwrite the cost of the private weekend ski trip or even to fund the unit holiday party, definitely are not. Remember, start planning early. For more information, contact the Scott Legal Office.