De Minimis Threshold Basis & Deregistration Validation

Date: 2026-08-29 Method: Seven parallel research agents verified primary sources (state statutes, official AG/SOS pages, official forms) for (1) the geographic basis of every de minimis registration threshold in Tab 11, and (2) the deregistration method, fee, and final-report requirement claimed in Tab 12 for every jurisdiction where CSJ is registered. Raw per-state research blocks with verbatim statute quotes and source URLs are in research/*.txt.

Part 1 — Threshold basis: in-state vs. total contributions

Bottom line: only ONE jurisdiction (DC) measures in-state solicitation. Everything else is either explicitly nationwide or written without any geographic qualifier — and the unqualified ones read as organization-level totals. The sheet's "NY = in-state" framing is not supported by the statute.

State	Threshold	Basis	Confidence	Key evidence
District of Columbia	$25K (CPI-adjusted)	in-state	medium	§ 44-1703 caps "solicitations... exempted", and the section regulates only soliciting "in the District" — inference from scope
Minnesota	$25K	nationwide	high	Explicit: "from the public within or without this state"
Pennsylvania	$25K	nationwide	high	BCO-10 instructions: "total national contributions from all sources... not just contributions received from Pennsylvania"
Colorado	$25K or ≤10 contributors	nationwide	high	"Gross revenue" org-level; same paragraph says "in this state" elsewhere, so omission is deliberate
Florida	$50K (not $25K!)	nationwide	medium	"$50,000 in total contributions" — threshold raised from $25K effective 2024-07-01
Georgia	$25K	nationwide	medium	"Total revenue from contributions"
Kansas	$10K	nationwide	medium	"Gross contributions received by such charitable organization"
Ohio	$25K	nationwide	medium	Org-level "gross revenue" (excl. gov't/501(c)(3) grants)
Washington	$50K	nationwide	medium	WAC frames it as org-level "revenue in any accounting year"
Arkansas	$50K	unclear	high	Bare "contributions" — no qualifier
Connecticut	$50K	unclear	high	"Contributions annually" — no qualifier
Hawaii	$25K	unclear	low	Only 2011 codification reachable; the "3-yr avg" convention in Tab 11 could not be confirmed in any fetched source
Maine	$35K or ≤35 contributors	unclear	high	"From the public" — no geography
Maryland	$25K	unclear	high	"From the public" — no geography
Massachusetts	$5K or ≤10 contributors	unclear	high	"From the public" — no geography (and lifts only the Solicitation Certificate, not Form PC)
Michigan	$25K/12-mo	unclear	high	No qualifier in MCL 400.283(b)
New Jersey	$10K	unclear	high	"Gross contributions" — no geography; definition of "contribution" also geography-free
New York	$25K (7-A only)	unclear	high	Sheet's "NY contributions" framing is NOT in the statute — § 172-a(2)(d) says unqualified "gross contributions"; contrast with a neighboring exemption that IS NY-limited suggests the $25K test is total, but no official source says so outright
North Carolina	$50K	unclear	high	No qualifier at all
Rhode Island	$25K	unclear	medium	No qualifier; excludes corporate/foundation/gov't/federated-fund gifts from the count
South Carolina	$20K	unclear	medium	"From the public" — no geography; also requires IRS letter + no one compensated >$500/yr
Tennessee	$50K	unclear	medium	"Gross contributions" defined as "total solicited revenue" — leans nationwide
Virginia	$5K (3-yr lookback)	unclear	medium	"From the public" — no geography; $10 exemption filing required
West Virginia	$50K	unclear	medium	"From the public" — no geography
Wisconsin	$25K	unclear	medium	Threshold clause unqualified even though the registration trigger says "in this state" — leans nationwide

Practical reading for CSJ: since no state except DC clearly measures in-state-only donations, the safe planning assumption is that CSJ's total nationwide contributions are what count against every threshold. The "unclear" states lean the same way on plain reading (an organization-level "gross contributions" figure); none of them offers statutory support for an in-state-only reading.

Material corrections to Tab 11 found along the way

Florida's threshold is $50,000, not $25,000 — raised effective July 1, 2024 (confirmed in the current statute and by FDACS). If CSJ is between $25K and $50K, Florida just became an exemption candidate.
New York should not be treated as in-state — reclassify as unclear/likely-total.
Hawaii's "3-year average" convention could not be confirmed in any reachable source — treat with caution until verified.
Seven statute citations in Tab 11 are wrong (right statute, wrong subsection — matters when citing in an exemption application):
- Maryland: exemption is Bus. Reg. § 6-102(c)(1)(ii)(4), not § 6-402(b)(4)
- Minnesota: § 309.515 subd. 1(a), not 1(b)
- Ohio: § 1716.03(G), not (A)(6)
- Pennsylvania: § 162.6(a)(8), not (a)(6) — and "gross national contributions" is guidance language, not statutory text
- Virginia: § 57-60(A)(3), not (A)(6)
- West Virginia: § 29-19-6(7), not (4)
- Georgia: § 43-17-9(a)(5), not (a)(9)

Part 2 — Deregistration validation (34 jurisdictions where CSJ is registered)

Verdicts after re-verification pass: 17 confirmed, 14 corrected, 2 with one unverifiable step each (MN, NM), 1 researched fresh (Columbus). Most exits are genuinely free, but six states charge a fee on the way out, and several of the sheet's claimed exit mechanisms don't exist.

Exit cost summary

Cost to exit	States
$0, minimal or no filing	AL, AR, CO, CT, FL, GA, HI, KS, KY, ME, MI, ND, NJ (lapse after last normal renewal), NV, OK, PA, RI, SC, TN, WA, WI
Fee required	IL $15 (final AG990-IL) · WV $15 (final registration statement — sheet wrongly said no final filing) · NH $75 (final NHCT-12) · NY 10–25 Art. 7-A (+$25+ EPTL if dual-registered) · OR $20 min (final CT-12F) · MA 35–2,000 scale (final Form PC — at CSJ's size, bottom tier) · MN $25 (last annual report, then lapse)
Unknown	NM ($0 near-certain — NM charges no registration fees), MD (final Annual Update may carry normal fee), MS

Corrections to Tab 12 (most important first)

California: cannot withdraw while delinquent. The Registry requires "Current" standing before processing withdrawal — so curing the FY2025 delinquency (CT-TR-1 by ~Sept 25) is a prerequisite for any CA exit, not just a compliance chore. Submission is mail/in-person to the Registry, not the Online Filing Service.
West Virginia: the free non-renewal letter is wrong. § 29-19-5 requires a final registration statement for the last solicitation fiscal year, with the normal $15 fee. Silently lapsing accrues $25/month late penalties.
DC: "allow BBL to lapse" is wrong. DC requires a formal Business License Cancellation via the DLCP portal; failing to cancel accrues late fees and penalties. Also, the BBL category changed Oct 2025 ("Charitable Solicitation" → "Charitable Services", 99/2 − yr; under−10K orgs fee-exempt) — verify which license CSJ actually holds.
Wisconsin: "Form #296 Termination Statement" does not exist — #296 is the registration application. Exit is a cancellation letter/email to DFI (DFICharitableOrgs@dfi.wisconsin.gov).
Washington: wrong form. The claimed "Voluntary Business Closure" form closes the corporate entity. The charity registration exit is a closure notice + final solicitation report under WAC 434-120-045 ($0).
Nevada: no withdrawal filing exists. No "final" checkbox in SilverFlume; simply omit the CSRS from the next annual filing and the registration lapses.
Oklahoma: no withdrawal filing exists. Registration self-expires annually; lapse is the de facto exit (the claimed "written notice to SOS" has no official basis).
North Dakota: cancellation is an online FirstStop filing, not a written notice.
Arkansas: the sheet's contact is obsolete — charity administration moved from the AG to the Secretary of State (charities@sos.arkansas.gov).
Connecticut is easier than claimed — no final report required; DCP's FAQ officially sanctions letting the registration expire.
South Carolina: withdrawal is by letter/email (charities@sos.sc.gov), not the online filing system; financial reports must be current through the last SC solicitation date first.
Massachusetts: exit is not free — the final Form PC carries the normal 35–2,000 gross-support-scaled fee (bottom tier at CSJ's size), filed via the mandatory AGO portal.

Resolved on re-verification (2nd pass, same day)

Florida — CONFIRMED, and stronger than claimed: written cessation notice to FDACS is a statutory duty — Fla. Stat. § 496.405(10): the org "shall immediately notify the department in writing of the date such activities ceased." $0, no final report, include the SO#. Mail to FDACS Solicitation of Contributions, P.O. Box 6700, Tallahassee, FL 32314-6700. (The "donation-page disclaimer" claim appears nowhere official — third-party lore only.)
Maine — CORRECTED: no withdrawal mechanism exists at all. The license expires Nov 30 annually and renewal is elective (9 M.R.S. § 5004(4)); the AFAR is statutorily part of the renewal application (§ 5005-B(1)), so a non-renewing org has no final AFAR to file. Exit = don't renew; courtesy email to charitable.sol@maine.gov optional.
New Jersey — CORRECTED: no "final" checkbox exists (verified on the actual CRI-300R form, every page). Exit = file the normal renewal covering the last year of NJ solicitation ($30 at CSJ's size), then stop renewing; N.J.A.C. 13:48-3.1(g) governs the lapse. One email to CharitiesPortalSupport@njoag.gov keeps the lapse from reading as delinquency.

One step still unverifiable — confirm with the state before acting

Minnesota: the statutory exit is now established — registration terminates by lapse when an annual report goes unfiled (§ 309.52 subd. 7), so: file the last annual report ($25) for the final soliciting year, then stop. Whether the Division also wants a cessation email is unpublished; confirm at 651-757-1496.
New Mexico: annual reports through the last NM year are owed in NM-COROS (confirmed); the third-party "notarized affidavit" step could not be verified in any official source, including wayback captures of the NMDOJ pages. Email charity.registrar@nmag.gov (verified official contact) for the exact procedure before drafting. $0 near-certain — NM charges no registration fees.

Columbus, OH — probably nothing to withdraw from

City Code Chapter 525 is an event/roadway-permit scheme, not a standing charitable registration. A nonprofit soliciting by mail/online in Columbus has no city-level registration beyond the Ohio AG's. This raises a real question about what the "Columbus, OH — Registered" row in Tab 1 refers to — ask Labyrinth what exactly was registered there. If it's a lapsed event permit, the row can likely be retired. (Caveat: Municode/columbus.gov blocked full-text fetch; details from indexed excerpts of official sources.)

AL (Notice of Non-Renewal form, $0) · CO (CHAR_WITHD form, $0, paper-only) · GA (Withdrawal form, $0) · HI (named deactivation form; not final until AG confirms in writing) · IL (final AG990-IL, $15, 6-month deadline) · KS (lapse, statutory) · KY (just stop filing 990 copies) · MD (§ 6-417 intent statement + final annual report) · MI (letter + MI asset inventory + financials, $0, email preferred) · MS (online Final Report within 30 days of ceasing) · NH (NHCT-12 + Schedule E, $75) · NY (final CHAR500, fees apply) · OR (CT-12F Line 6 + separate written notice, fees apply) · PA (BCO-2, $0, online) · RI (statutory auto-expiry) · TN (named Form SS-6087, $0, online portal)

How this feeds the fee-savings decision

A state is a clean drop candidate when: threshold ≥ CSJ's total revenue (nationwide basis assumed) + exemption conditions met (usually all-volunteer/no paid fundraisers) + $0 exit + no final report. On the verified record, the cheapest exits among registered states are CT, RI, KS, KY, OK, NV, ME, NJ (passive or near-passive, $0, no final filing) plus FL (one mandatory-but-free cessation letter). The most involved exits are CA (cure delinquency first), MA/NY/OR/NH/WV/IL (fees + final filings), and MI (asset inventory). Florida's threshold rise to $50K may convert it from "must register" to "exempt" — worth re-running the numbers.

One caution: exemption ≠ deregistration. Several states (AR, GA, SC, WV, FL) require an affirmative exemption filing or annual exemption renewal even below the threshold — dropping registration without filing the exemption where required creates a new gap. Tab 11's "Exemption Filing Required?" column covers this; it was not re-verified in this pass.