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June 13, 2019

What Constitutes “Proof of Funding” When Filing for a Temporary Activity?

In conversation with The China NGO project, multiple NGOs have expressed confusion about the exact documentation required to satisfy the requirement for “proof of funding” (“资金来源证明材料”) when filing for a temporary activity. We are unaware of detailed written guidance on this point, and different foreign NGOs have reported supplying different documentation.

One NGO said it created a document, which it called “临时活动项目经费及资金来源证明 / Statement on Cost and Funding Source for Temporary Activities,” and provided it to the Public Security Bureau Foreign NGO Management Office in the relevant province. This document, which was written in both Chinese and English, included:

  • A brief (paragraph) introduction of the organization.
  • A brief (two-paragraph) description of the activity in question.
  • A statement on the duration of the activity (listed as: “The starting date is the date on which the record filing is accepted. The temporary activities will end 1 year after the starting date”).
  • A statement on the “cost and funding source” of the activity, which stated that the foreign NGO “anticipates to provide XXX USD” to the Chinese Partner Unit.
  • A statement that the signatory (in this case, a vice president of the organization) certified the information on the form as true and correct.

Another NGO said it provided the following as part of its successful filing for a temporary activity:

  • A recent bank statement that showed: a) the NGO’s current account balance, b) the average balance over the last 12 months, and c) the NGO’s “customer information” (that the account was held by the NGO in question, and who the signatories were—in this case, the NGO’s treasurer and three other people).
  • A letter from one of the NGO’s bank account signatories saying that the NGO’s account contained enough funds to support the temporary activity (the letter specified this amount based on the estimated temporary activity cost the NGO had provided in its other filing documentation). This letter was notarized.
  • A New York All-Purpose Acknowledgment form, complying with Real Property Law Section 309a which attests to the legitimacy of the previous two documents. (The NGO in question is based in New York State.) The acknowledgment form was also notarized.

To read further about one NGO’s experiences with temporary activity filing, see our post on one of the first foreign NGOs to file for and carry out a temporary activity.

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