This article documents the steps taken to setup an unincorporated nonprofit club under the North Carolina Uniform Act. The document images presented are the actual documents filed with the state and were prepared by a lawyer. The document filed with the county has been registered as shown. The document filed with the Secretary of State has not been returned as approved so there may be some changes necessary before approval is granted. Most of the statements made are interpretations made by the author and have not been reviewed by a lawyer for legal accuracy. If you use this information in setting up a club or association, we would appreciate feedback, particularly if you or your lawyer interpret the requirements differently or recommend a different process.
To form a club or association you need two people who mutually agree to pursue some common goals. Although the UUNAA may not mandate that a group register with the state, it is highly recommended that you do so. Our group was one of the first (and maybe the first) to register under this new act in North Carolina. The documents were filed with the county and Secretary of State. The county documents have been registered, however at this time, the documents have not been returned as approved by the Secretary of State so there is still some question as to whether they are complete and acceptable by North Carolina. In addition to the two documents filed with North Carolina, additional steps are outlined which may or may not be useful. None are necessarily required, however none require any expense so your judgment is required. Our club tried to cover all bases without becoming overly bureaucratic. We wished to have a simple, fun club with as little structure as possible.
You might be able to copy our documents and bypass the lawyer expense, but as mentioned, this is a first-time through the process so advice of a lawyer is highly recommended. Some optional steps are included for Amateur Radio clubs to consider which of course can be ignored by other clubs.
The club was formed from the membership and officers of the Brunswick County Amateur Radio Society, Inc. Club after it was disbanded in February 2007 by the Brunswick County Amateur Radio Society, Inc. board of directors. Unannounced, and without the legal backing of the BCARS, Inc. members as required by the corporation bylaws and policies, the board of directors unilaterally rescinded their support for a club and released the club officers and all members.
To fight this illegal action would have prolonged the animosity and "hard feelings" that had been generated, and only delayed getting the club back to what amateur radio should be about; association with others interested in amateur radio, for enjoyment and pleasure. A copy of the documents (BCARS, Inc. bylaws; Club Policy; Articles of Incorporation; February 27, 2007 actions), a discussion of the illegal actions by the board of directors, KI4KK's view of the events leading up the the actions and the reason given by the BCARS, Inc. board of directors for taking the action is presented on KI4KK's BLOG
On February 28, the club officers and some members met and voted to continue the club, taking whatever actions were necessary to continue. The officers were to continue in their respective positions until the club could be reformed. The club President, KI4KK, accepted the responsibility to look into what was required, and if it was necessary, to incorporate. Shortly thereafter, he found information on the Uniform Unincorporated Nonprofit Association Act that had just gone into effect in North Carolina in January. The course for the club had been set.
So what is this new law all about: the National Conference of Commissioners on Uniform State Laws (NCCUSL) and a few special-interest groups have drafted and recommended for enactment by the states a set of uniform laws and model acts. One of the uniform acts of particular interest to those persons thinking of organizing an amateur radio club, is the Uniform Unincorporated Nonprofit Association Act. This act provides the same protection for association members with easier and less expensive costs than full incorporation.
As of the spring of 2007, 11 states (AL, AR, CO, DE, HI, ID, TX, WV, WI, WY, NC) and the District of Columbia have enacted the Uniform Unincorporated Nonprofit Association Act. The act has been introduced in Pennsylvania in 2007. California reviewed the Uniform Act but decided to rewrite existing laws and has enacted a similar statute. Bills to adopt the Uniform Act have been introduced in CT and OK but have not yet been passed. Although the intent of the act was to make it uniform across all states, some states have made changes, for example Colorado added that property may be encumbered in addition to being transferred, whereas the uniform act refers only to transferring.
An extensive analysis of the uniform unincorporated nonprofit association act is presented by LexisNexis and persons seriously considering this option should review that article (ref. 1) and also the specific requirements for your State as to filing and registering requirements. The assistance of a lawyer is most valuable. Here are some of the key points of the uniform act as adopted in the state of North Carolina.
To begin with, your club will need founders. The ARRL suggests four (4) persons, acting as a president, vice president, secretary and treasurer. The Uniform Act requires two (2) or more persons. If you choose to register, one person will be designated as GRANTEE to act as a responsible agent to accept real property and documents of due process, and a second person will be designated as GRANTOR authorizing the grantee. Our club decided register and in the articles of formation, specified four (4) persons; two (2) club officers, one (1) board member, one (1) person designated as the responsible agent registered with the State of North Carolina. The articles of formation allow expansion of the club with additional officers and board members as determined by the club bylaws.
The first order of business for the founders is to choose a name. This name will be registered in the county with the clerk of courts. It should be chosen to be unique and descriptive. Like a business, it can not be similar to other registered names in the county or state.
To begin with, a club should have a document stating: the purpose or intention of the group; the basic structure of officers and governing documents; membership requirements, if any; and the tax status . The ARRL refers to these as a Constitution, the State of North Carolina refers to these as Articles of Formation and some states refer to these as articles of association. If you incorporate, this document would be the Articles of Incorporation. Whatever the name, this document lays out the basic intention and foundation of the association. This will most likely be the document used in registering with the IRS and should therefore clearly define the nonprofit nature of the association.
These articles are generated by the founders before there are club members, so the articles will most likely be a permanent record and not likely to change over the life of the club. Some states require these to be filed with the Secretary of State. North Carolina does not. They should form a basis for more specific definitions of organization laid out in by-laws, operating rules, etc. which would normally be modified and approved by the club members.
After the founders have establish the articles of formation, to register the club under the uniform unincorporated nonprofit association act they need two people to create a Statement of authority as to real property This document is filed in the county in the same manner as a deed would be filed. This document is where you will register the name of your group. With the registration, you will receive a record number which will be used when registering with the Secretary of State.
Click HERE for PDF of the club document filed with the County register of deeds. PAGE 1 of 2 and PAGE 2 of 2
The Statement of authority as to real property is a document styled "affidavit" that contains the following:
A statement of authority shall be executed in the same manner as a deed.
Once the Statement of Authority as to Real Property is filed with the county and a number is received, a second document is filed with the Secretary of State, in the same manner as Articles of Incorporation would be filed, but less costly. Although similar, the registration process for both the statement of authority and appointment of agent does vary by state and the use of a local attorney to draft and submit the necessary legal documents is recommended.
Click HERE for PDF of the club document filed with the Secretary of State. PAGE 1 of 2 and PAGE 2 of 2
Here are the requirements as stated in the North Carolina act for the:
Appointment of agent to receive service of process.
(a) A nonprofit association may file in the office of the Secretary of State a statement appointing an agent authorized to receive service of process, notice, or demand required or permitted by law to be served on a nonprofit association.
(b) A statement appointing an agent must set forth all of the following:
(1) The name of the nonprofit association.
(2) Reserved for future codification purposes.
(3) The street address, and the mailing address if different from the street address, of the nonprofit association, and the county in which it is located, or, if the nonprofit association does not have an address in this State, its address out of state.
(4) The name of the person in this State authorized to receive service of process and the person's address, including the street address, in this State.
(c) A statement appointing an agent must be signed and acknowledged by a person authorized to manage the affairs of a nonprofit association. The statement must also be signed and acknowledged by the person appointed agent, who thereby accepts the appointment. The appointed agent may resign by filing a resignation in the office of the Secretary of State and giving written notice to the nonprofit association at its last known address.
(d) The sole duty of the appointed agent to the nonprofit association is to forward to the nonprofit association at its last known address any notice, process, or demand that is served on the appointed agent.
(e) The Secretary of State is not an agent for service of any process, notice, or demand on any nonprofit association.
(f) The Secretary of State shall collect the following fees when the documents described in this subsection are delivered to the Secretary of State for filing:
(1) Statement appointing an agent to receive service of process $5.00
(2) Amendment of statement appointing an agent $5.00
(3) Cancellation of statement appointing an agent $5.00
(4) Agent's statement of resignation No fee
(g) An amendment to or cancellation of a statement appointing an agent to receive service of process must meet the requirements for execution of an original statement. (2006§226, s. 1.)
NOTE: The Uniform Act for both the statement of authority and appointment of agent says that the association MAY file these two documents. It was the opinion of our lawyer that they were not necessarily required. It MAY be that the simple declaration of a nonprofit unincorporated association would suffice in a court of law, but being new ground our club decided to file both documents. Further, North Carolina did not specify that the number assigned by the County would be used in the registering of the agent, and requests by our lawyer to the Secretary of State got no response. Based on the Texas statute which has been in effect for some time, this seemed a logical approach to implementation of the uniform act.
How some of the states have implemented the uniform act:
The 'statement appointing an agent shall be signed and acknowledged by a person authorized to manage the affairs of the nonprofit association. The statement shall also be signed and acknowledged by the person appointed agent, who thereby accepts appointment. The statement and one copy thereof shall be delivered to the probate judge, who will transmit a certified copy to the Secretary of State. If the probate judge finds that the statement conforms to provisions of this section, he shall file such statement in his office, and upon such filing, the statement becomes effective.' (ref 2)
The address of the agent may not be a PO Box if the address is in a municipality of greater than 5000 people. (ref 3)
Things to consider when setting up a amateur club, society, association or organization.
Do you need a new club in your area? If your area already has a club or society which is incorporated, it may be easier to form under that charter.
Should you incorporate or is the unincorporated association status sufficient for your group? The uniform unincorporated nonprofit association act is new and has not been tested in the courts. If your association has a significant amount of capital it might be a target for someone to test this.
Incorporation can be setup as perpetual but unless canceled earlier, a recorded statement of authority as amended is canceled by operation of law five years after the date of the most recent statement of authority (or amendment to the statement). Will someone remember to renew or amend the statement of authority every 5 years?
Your club needs a name. The name can not be so similar to an existing organization such that there might be confusion between the two groups. The county register will determine if the name is available within your county but will not make the judgment as to how unique the name is. Just because you get the name registered, does not mean you can keep it. Some web searching before registering would be wise.
You need a statement that your are nonprofit. This is defined by the Internal Revenue Code (I.R.C.) of 1986 as amended Section 501(c ) (7) Clubs organized for pleasure, recreation, and other non profitable purposes, substantially all of the activities of which are for such purposes and no part of the net earnings of which inures to the benefit of any private shareholder.
For federal tax purposes, the definition of corporation includes unincorporated associations I.R.C. § 7701(a)(3).
Something to think about: the Uniform Unincorporated Nonprofit Association Act is new. It has not been tested in the courts. Hopefully a small amateur radio club would not be the worthy of a test.