Nonprofit organizations often assume that fundraising is as simple as holding an event, selling tickets, or sending a donation appeal. But once you solicit outside your own jurisdiction, things quickly become complicated. Many cities and counties have their own rules for charitable solicitations and raffles, and failing to comply can put your organization at risk of civil penalties or even criminal charges.
Let’s look at how a few major cities handle charitable solicitations and raffles:
Los Angeles
There are no city-specific raffle rules beyond what is required by the California Attorney General. However, in order to solicit charitable contributions within Los Angeles county, charitable organizations – with the exception of religious organizations and membership organizations soliciting only their members – must register with Los Angeles County’s Business License Commission by filing a Notice of Intention to Solicit and Report of Results required under County Code Ch. 7.24. The City of Los Angeles adds another layer: a Notice of Intention must be filed with the LAPD Police Commission’s Charitable Services Section 15 days before solicitations begin, and activity cannot start until the Commission issues an Information Card. If the charity violates these requirements by non-compliance, it is a misdemeanor.
San Francisco
Similar to Los Angeles, there are no specific city raffle requirements beyond the state Attorney General’s requirements. In order to solicit generally, charitable organizations must register with the San Francisco Police Department, which issues a Solicitation for Charitable Purposes Card. Without it, you cannot solicit. The Police Commission may order an audit, and violations are misdemeanors.
Boston
Massachusetts law is stricter: only nonprofit entities organized and active in Massachusetts for at least two years may conduct raffles. Out-of-state organizations cannot hold raffles in Massachusetts.
In addition to the general state charitable solicitation requirements, the City of Boston requires a raffle permit from the city clerk. Extra requirements apply if ticket prices exceed $10 or prizes exceed $10,000. Special taxes apply to raffle revenue.
Philadelphia
While Philadelphia doesn’t require any extra licensing for general solicitations beyond Pennsylvania’s state requirements, nonprofit organizations must obtain a Small Games of Chance License for ongoing raffles. If you hold fewer than three raffles, you can apply for a Limited Engagement License. Large prizes require a Special Permit License.
New York City
The New York State Gaming Commission regulates raffles, with different licensing requirements depending on anticipated net proceeds. Selling tickets online or outside your home municipality requires special permission.
In NYC, nonprofit organizations must obtain a Games of Chance License from the Department of Consumer and Worker Protection. Only certain charitable organizations are eligible, including religious, charitable, veterans, or volunteer firefighter groups. The city also requires a Public Solicitation License from the Human Resources Administration for any charitable solicitation in the city.
As these examples show, raffle and solicitation rules vary widely not only by state but also by city and county. What’s simple in one jurisdiction may be tightly regulated, or even prohibited in another. The penalties are real, with violations often carrying misdemeanor criminal liability, fines, and reputational risk.
Before hosting a raffle or launching a multi-city campaign, check the specific requirements in every jurisdiction where you will solicit. Being registered with a state AG’s office does not automatically cover you in local jurisdictions. Engage legal counsel or compliance professionals to ensure your organization remains in good standing everywhere you raise funds.
If your nonprofit organization is considering raffles or fundraising outside your local area, don’t go at it alone. Contact the Church Law Center of California to help you navigate the complex patchwork of state and city requirements and protect your mission from unnecessary risk.
