CampaignFoundations.com

A couple times a year, we get calls from folks who have received a letter signed by the 'PayPal Compliance Department', and a subject line warning: 'Your PayPal Account: Action Required', with details on contacting their 'Resolution Center' with correspondence reading: ATTN: Compliance: Due Diligence.

I'm not sure if PayPal only audits a representative sampling, or if most of our clients work this out without my intervention. But here is what this is about.

Without knowing the details of the current stance, I am aware of ongoing struggles between PayPal and regulatory authorities over the extent to which they should be regulated as a financial institution and in what respects. I'm not sure whether this is a 'voluntarily' measure, in that way corporations seeking to avoid regulatory incursion onto what they perceive as their turf (namely the ability to make money unhindered); or the result of regulatory mandate. But it is clear that PayPal has an interest in avoiding participation in fraudulent transactions.

So when an individual seeks to do business with them under a fictitious name, a dba/, or corporate name, a trademark, or for CampaignFoundations.com clients, as an organization or a political campaign committee, PayPal wants to know that the treasurer is authorized to act on behalf of this fictitiously named organization.

They want to see government and bank sanctioned paperwork saying that you can legitimately do business as your campaign committee or organization. If you are incorporated, they want to see the Secretary of State's seal on your filings, And if you are a campaign committee, they can be satisfied with the registration documents for your campaign committee.

It can be a nuisance to be told that the money you have already raised and need to urgently spend to move your campaign forward, that that money is not available to you until you fax in a bunch of paperwork. But know that the paperwork which satisfies PayPal's due diligence office is the same paperwork necessary for your compliance with campaign finance laws.

The PayPal letter tells you: "You must use the cover page provided by PayPal. The cover page contains information specific to you and using it ensures that your documents are routed and handled in a timely manner." Heed that warning. Their barcoded cover pages will route your incoming fax directly to your accounts file. If you send in your documents without the barcode, the manual backup had a three day backlog on matching documents with suspended accounts, last I asked.

Hope this was helpful.