Media Matters for America has a sister chapter in Colorado. Because Media Matters for America (MMFA) is a non-profit 501(c)(3) organization, they are required by certain state laws to register with the Secretary of State in order to solicit funds for their charitable organization, even if that organization is located in another state.

I decided to investigate these filings with a few states and here are some things I found.

Per the Colorado Secretary of State's office:

The Colorado Charitable Solicitations Act (Title 6, Article 16, C.R.S.) requires charitable organizations that seek contributions from the public (with a few specific exceptions listed at 6-16-104(6)(a)-(c), C.R.S.) to register and provide general identifying information about themselves and to file annual financial reports. Paid solicitors, who solicit contributions on behalf of charitable organizations, must provide general identifying information about their businesses and file solicitation notices and solicitation campaign financial reports for each campaign they conduct.

I did a search of their database for Media Matters. Here is their filing. They list their NTEE (National Taxonomy of Exempt Entities) code as 'Civil Rights, Social Action & Advocacy'. When MMFA filed with the IRS they listed their NTEE code as A30—Media, Communications Organizations (per http://www.guidestar.org/). This isn't really a big deal, it just highlights a minor discrepancy in their classification as an exempt organization. This filing also lists the names of states in which they have registered to solicit or where they have received exemption (more on that below).

However, when I did a record search on Media Matters in the business center section of the Colorado SOS's site, I found something curious. They have registered under ID 20061240245 with a statement of foreign entity authority and according to the filing results, their 'registered agent' is listed as Ridder-Braden, Inc. in Denver, CO. Next, I looked up Ridder-Braden, Inc and found who they are (emphasis mine).

Rick Ridder - President and Co-Founder; He has served as a senior consultant for three presidential campaigns (including both Clinton/Gore campaigns)

Craig Hughes - Director of Research; Craig came to RBI after working as Eastern Political Director in the Clinton White House from 1998-2000. In that position, he supervised political activities for the President, First Lady, Vice President, and Mrs. Gore in twelve Eastern states. Craig was one of the earliest staff members hired for the Clinton for President Campaign in 1991, and subsequently worked for both Clinton/Gore campaigns as well as the Democratic National Committee.

You may recall my earlier post this week with research about Media Matters and their ties. In that post I linked to Mark Finkelstein of Newsbusters who reported the claim from Media Matters that Senator Clinton (D-NY) did NOT help start nor did she support Media Matters.

So, Media Matters claims Clinton didn't start or support its 'charitable organization' but the Colorado chapter's business agent lists two Clinton political operatives. Strictly coincidence? You be the judge.

And, what about MMFA's ability to solicit funds in other states either via registration or exemption? At my first attempt to verify this, I looked at the State of Maryland, since it is so close to DC. I did a search in the Maryland Charities Database for Media Matters. The query yielded one entry for Media Matters but it shows a disclaimer.

Disclaimer: This organization has applied to register under the Maryland Solicitation Act but has not submitted all of the required information to be registered and in full compliance with the Act and cannot solicit charitable donations.

According to their website, a new law was passed that addresses this.

Effective October 1, 2006, under House Bill 398 Chapter 459, Acts of 2006, all new charitable registrations MUST be in full compliance and receive a registration letter from the Secretary of State's (SOS) office before soliciting.

This raises some important questions.

1) Is Media Matters in violation of the law if it solicits and receives donations in the State of Maryland?

2) Are Media Matters emails to citizens in Maryland that request donations considered a violation of the Maryland Solicitation Act? Media Matters sends weekly summary emails (I have seen a copy of such emails.) to those who register on their website. At the end of these emails (Note: The email address listed below is a substitute for a legitimate email address.), they include the following:

This mail was sent by Media Matters for America to 'johndoe@emailaddress.com'. Please visit us at http://mediamatters.org/

You can help support our work; become a volunteer media monitor, or donate to Media Matters for America.

The "donate" link takes you directly to their website page where you can contribute.

3) If they are not in full compliance, is the SOS of Maryland obligated to investigate any possible violations?

UPDATE: IRS Form 990 filings can be found here in PDF.