Can we get bulk mail at lower rates while our 501(c)(3) is pending?

Summary:

The Postal Service and the IRS have different rules and standards

Motherless Daughters wrote:
We're awaiting our 501(c)(3) status, and in the meantime would like to
apply for our nonprofit bulk mailing permit from the postal service. The
P.O. says that if we don't have a letter from the IRS that a letter from
an independent auditor, such as our accountant, stating that we're a
non-profit will do. Sounds fine, until our accountant (who was
recommended to us because he has lots of experience with non-profits)
says he doesn't know what we're talking about. Meanwhile, we're wasting
$20 to $30 per bulk mail and are growing increasing frustrated as the
IRS takes its time.

Does anyone know anything about this, or have additional information we
can pass on to our CPA to get the letter for our permit?

Putnam Barber responded on August 9, 1995:
The Postal Service has several good pamphlets on Special (ie Nonprofit)
bulk mail rules and regulations. If your accountant is puzzled about the
specific meaning of the term in USPS terms, these should help him sort
it out. Ask for them at the office where you make application for the
permit.

The Postal Service has an explanation of the application process online at http://www.usps.com/businessmail101/misc/nonprofitApplication.htm

Confusingly, the Postal Service and the IRS have differing standards
here -- some organizations which are eligible for 501(c)(3) standing are
not eligible for the special bulk rates (though I doubt it goes the
other way). And there is no requirement that you be recognized as
501(c)(3) -- or as far as I know even have any plans to apply for
recognition -- to be eligible for the bulk mail discount. The two
agencies (IRS and USPS) make separate determinations, based on different
acts of Congress and different sets of regulations.

Frankly, I'm surprised that the Postal Service asked about 501(c)(3).
Because the range of organizations eligible for the special rates is
narrower than 501(c)(3) requires, I thought they usually asked to see
bylaws, board minutes, previous (non "special") mailings, etc, and made
their own determination.

The Postal Service has an explanation of the qualifications for nonprofit rates online at http://www.usps.com/businessmail101/misc/nonprofitQualifications.htm

And while we're at it, I should add that the Postal Service looks at
each mailing which you bring them. It doesn't matter whether you have a
special bulk mail permit and put the "Non-profit Organization" indicia
on each piece. What matters is the content of the mailing. If it
does not meet the Postal Service's standards for material eligible to be
mailed at the special rate, you will be charged the higher rate. If you
don't pay it, the mail will not be sent. It's a good
idea to have the Bulk Mail Entry people preview any mailing which might
be called into question. It's a good idea also to have
extra money in your deposit account at all times. You can always appeal
and get the extra postage back if the person at the counter is
overruled, but you can't use a mailing that's been delayed past the date
of the events it describes while you argue with the PO.

Others may be able to add to this list, but I know the words "sponsored
by" are a red flag, as is anything promoting travel, insurance or
bank-card sales (even remotely -- I've heard of auction mailings where
the prize was a cruise being questioned). There's another Postal Service
pamphlet -- on "Cooperative Mailings" -- which is worth a read. Problems
with mailings can arise, though, when nothing like a forbidden
cooperative mailing is underway.

The people at the Bulk Mail Entry office (in Seattle) are very helpful and
responsive when consulted in advance about potential problems. And bad
things happen when deadlines are close and mailers haven't taken the
possibility of confusion (or that the mailing may violate the rules)
into account.