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Archive for November 18th, 2017

About MRFP, Inc. (NAAG/NASCO’s “Single Portal Initiative” for MultiState Registration and Filing by Charities — except, apparently, for MRFP, Inc, NAAG, and NASCO). Also See my New Page (publ. 11/11/17) on SimpleCharityRegistration.com [This post publ. 11/18/2017].

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Post Title: About MRFP, Inc. (NAAG/NASCO’s “Single Portal Initiative” for MultiState Registration and Filing by Charities — except, apparently, for MRFP, Inc, NAAG, and NASCO). Also See my New Page (publ. 11/11/17) on SimpleCharityRegistration.com [This post Publ. 11/18/2017](case-sensitive shortlink here ends “-7X8”).

Subtitle:  Who’s Regulating the Regulators? Why are they exempt from the rules they exist to enforce?  Wake Up, People!!

Those Acronyms in the Title:    “MRFP” = (see post title).* “NAAG” = National Association of Attorneys General.  And “NASCO,” it’s said, is “National Association of State Charity Officials.”**

  • *Technically speaking, “MRFP, Inc.” is a business name, not an acronym, but it does seem to represent the phrase”MultiState Registration and Filing Portal.”
  • **“Proof of Life” or business entity personhood is just not found so far, despite other similar or interested entities, even the IRS.gov itself, publicizing, positively, the name in full and as an acronym as if a creditable point of reference and a legitimate entity with a legal domicile somewhere in the USA or one of its territories.
  • **If so, if NASCO exists, where is its incorporation or charitable registration; does it even have an EIN#? If yes, then where are its tax returns or even a single Form 990-N?  Or where is it on someone else’s tax return as its fiscal agent?  
  • **…Speaking of which, I’d ask NAAG (i.e., a NAAG Tax return/Form 990) which seems to be acting as a fiscal agent for some NASCO functions — but where are NAAG’s returns (even though NAAG’s EIN#, no thanks to NAAG’s own website, was eventually found)?? 

For an example of references to NASCO (as well as apparent confusion, as ever, between the puppet and the puppeteers, that is, the creation and the creators — specifically a business with a product, and the product itself), these next two links to a single document written as if responding to the “RFI” (Request for Information) on the Single Portal Initiative, showing the logos for “GUIDESTAR” on the left and “SimpleCharityRegistration.com” on the right, and the found document was actually posted at MRFP, Inc. …

By the time you get through my page on this, you’ll see that SimpleCharityRegistration.com also adds fully FOUR logos labeled “in partnership with” of which one is Guidestar, and another one (BizFilings.com) provides us clues to the whole mess that predates the federal income tax, and how corporate law was adjusted (and by whom) to get around anti-trust laws of the same era. It’s fascinating information and definitely turned on some of my own lights as to the phenomenon I’d already observed of effective monopolies (or “oligarchies”) within the nonprofit sector and intersecting with government itself.

I also discuss several aspects of that situation here, adding some new links.

Annotated: RFI response to MRFP by GuideStar and Simple Charity Registration (4pp, p1 only shown)  My many annotations highlight the troubled verbiage found at a RFI posted at MRFP, Inc.  What’s more, that pdf seems immune to being displayed as an image other than directly from the website (meaning, if the link changes, “too bad.”).. Please do click that link and read my annotations … The annotations make for a visually cluttered page but still raise ongoing and important questions about the language.  I question whether anyone who could produce and would even think it appropriate to post a mess like this should be taken seriously when the topic is organizing and monitoring charitable entities (!!).  Apparently some corners (lots of them) have been cut in putting up a show of fair usage of the funds involved for such a project.

Plain: Link to a clean copy, all 4 pages, posted at MRFPinc.org under “Request for Information” and apparently from this and other context dated sometime after 2015 or 2016, although it’s not actually dated (or signed) within those four pages, at all. One of the companies mentioned on it, I still haven’t found.


On 11/11/2017, after some days of rapt attention to this new area of learning about how many different ways (and how many red flags along the ways) government employees of high rank and authority over and responsibility to regulate major parts of the private sector can and so often do form private-sector corporations, boasting among each other and on the private-sector corporate websites (which many of the public may never stumble across, ever…) about the public benefits for the project — and doing this all while withholding/concealing identifiable registration of the same private-sector (tax-exempt of course), or failing-to-file, and/or failing-to-file-IRS Forms 990 even when they may have registered,* and in general thus distracting the public from one of the most critical things that public deserves to know,** I published a new page containing a helpful list, alpha by state, of where charities have to register…unless they don’t because for some reason they’re exempt.

Page Title: State-by-State Charity Lookup Links (from SimpleCharityRegistration.com’s March 2017 WordPress post)   Started Nov. 8, 2017, Published Nov. 11; intended for my “Vital Links” sidebar menu. Case-sensitive, generated short-link ends “-7Vm”       Recommended — read that Page before this Post for better statement of context.


Without a glossary of organizations and sense of who they are and how they interact, and some examples of how they speak and act (for “act,” I’m talking filing accountability and transparency issues, absence or presence of double-talk, or promoting what may (and sometimes sure seem to be acting like) fake-name persona (repetition of reference among the community substituting for actual registration and production of tax returns, or a declaration why there are none), this gets complicated.  [The complication on the part of above-named organizations seems intentional.]  I’ve been studying this situation for about two weeks (with the new page, which unfortunately doesn’t show automatically on blog “Archives” calendar, published Nov. 11, mid-way), processing information and considering whether it fits with or contrasts/challenges my existing understanding (skepticism) about the field as a whole.

Showing this with exhibits, typically each exhibit becomes its own section, takes some time. I repeat some of the above paragraphs (this post title + acronyms; the paragraph introducing new page title /yellow background) below to help with continuity. //LGH.


This topic takes precedence over follow-up posts which I’d promised recently because it is so current and the issues it signifies so weighty. I also gather this project is probably not reported much outside the government and philanthropic circles (with mutual self-interests on both parts), and on their respective journals, newsletters or “Gazettes” posted on websites.

This post also generated its own follow-up list of three.  In order of writing:

  •  Upcoming, based on my recent check-in with The Urban Institute Form 990:
Title:  A Year In the Life (2015, the latest available from this perspective) of a VFTT (Very Famous Think Tank), through its IRS Form 990 Tax Return. (shortlink ends “-7Xz.” Post begun Nov. 13, 2017).This VFTT entity’s address can be seen in the URL domain name to a one-page, Sept. 2015 description of the Single Portal Initiative and MRFP, Inc. (as “working with” the NAAG/NASCO combo).
  • Then, on another mega (well, large and prominent) foundation in New York, I wrote:  Verrry interesting. It’s a whole other category of “out-there” “You’ve GOT to be kidding!” information and presentations, again, demonstrating how those already IN nonprofit board (or even major program — as in involving decisions on grant-making) power circles manage to spread their roots, quickly transplant operations if deemed a good idea, and seeking to standardize nonprofit measurement globally — while at home, leaving BIG gaps in accountability and transparency on their various organizations… And, I off-ramped it, except just two images to support a reference in the title.  See next five-line post title:
  • and, from RHF, above, tracking just two nonprofits associated with just one of its prominent (“star-studded” might be a better word) board of directors, and one of the nonprofits’ recent contractor, “Blessing White,” where “Blessing White Courses” generated $766K revenue in a single year (FY2015) for the entity, and obviously some certification/ replication / global consultancy with on-line deliverables was involved.

Looks like [Jeffrey] Immelt went straight from Harvard MBA (after a BA/BS from Dartmouth in Applied Math) to GE and hasn’t left yet.  Meanwhile he sits on a variety of foundations, a seat at a White House Admin table (this quote is as of Oct. 2016, obviously before changeover of White House Administration to President Trump), and the Business Roundtable.

[See off-ramped post currently called]: Catalyst Inc, Blessing White Courses, GP Strategies (Global PIC*), GSE Systems, and the Ronald Reagan Presidential Foundation. (*PIC = “Performance Improvement Company”) (shortlink ends “-7YU,” moved here Nov. 17, 2017, cf. Jeffrey Immelt, director of Robin Hood Foundation, a single drill-down on just two nonprofits mentioned from his Bloomberg.com profile….).

Those are the three posts that this one inspired (sections already written in the process of writing it) but for which length restrictions and focus considerations got them bounced off.  The process for each is similar and basic but always time-consuming: I look at the financials (typically mostly the 990s but sometimes also a financial statement, if one is available) and talk about them, comparing sources of revenue, expenses, assets accumulation over time, and sometimes in what they are declaring investments. …. I look at related entities if shown, and connect with other available information on either the directors, or corporations mentioned in them, I compare.

I do not subscribe to Nonprofit Quarterly, Circle of Philanthropy or similar journals (I do to “Institutional Investor” magazine and I also read the paper versions of The Wall Street Journal regularly, and The New York Times, some), but it’s my impression that what I talk about here, in “lay terms” for the general public, they do not. They (such publications targeting the philanthropic sector, whether seeking grantees or grants, or both) also don’t even seem much concerned about the discrepancies regularly found on Forms 990 within and between organizations except as it might discredit the sector and impact: jobs, social status, and the status quo.


Significant elements of the philanthropic and government (private/public) sectors say they have been collaborating on the “Single Portal Initiative” to better streamline, establish and facilitate the rapid increase in filings by the nonprofit sector, already a significant “player” in (influence on) the national and international economic landscapes.  Allegedly this is “the better to monitor them with” also…

And for those who happen to subscribe to philanthropic journals, either looking for grants, grantees, or seeking to align policies for outcomes, and in competition for donation dollars, there have been some articles also.  These journals seem to feed off each others’ energy and optimism, regardless of poor results for some project being promoted, synchronously, among them.

Here’s an article in such a journal commenting on how hard the project must be, since after receiving Department of Commerce Funds for it in 2003, a follow-up “Request for Information” didn’t surface from one of the recipients until 2016!  The article provides more clues to in what direction the credibility crisis on tax-exempt organizations for those who do pay attention, will be, and is being as we speak, leveraged. Please click annotated text image below to read some of the terms in context I will be bringing up repeatedly in this post (and also do on the page):

Nonprofit Quarterly, Summer 2016, 8/11/2016, The Rising of the States in Nonprofit Oversight by Lloyd Hitoshi Mayer, from another article in same publication called  “The New Nonprofit Regulatory Environment: What You Should Know” article (graphic + title only).  Notice my warning “only 3 free articles remaining.”

excerpt from Nonprofit Quarterly, Summer 2016, 8/11/2016, The Rising of the States in Nonprofit Oversight, 8/11/2016, by Lloyd Hitoshi Mayer. Notice references to NASCO (1979), US DOC funding in 2003 to NASCO/Guidestar (another 1995ff highly profitable (program service revenues) nonprofit providing a subscription database of nonprofits, or much less information in less flexible format, for free) for the Single Portal Initiative and to a “National Attorneys General Program at Columbia Law School, (NY) working with the Urban Institute, yet another nonprofit known (in part) for its own charitable database (formerly NCCS.dataweb.urban.org).

Only after I did discover the “Single Portal Initiative” looking for the charitable registry of a single state and discovering a list of on-line registration links alpha by state (in states where registration is required, that is), did my more targeted search phrase bring up more material on it and patterns start surfacing; not always the patterns which were being reported on, however.

Did you know that Columbia University’s Law School had a National Attorneys General Program, or than an entity called NASCO is alleged to exist (and whether it does or not?  I’m still looking!).  Is it not a little odd that those reporting on the above information using the FTC’s and unified state attorneys’ general (probably unified via NASCO / NAAG meetings) recent victory over two sham cancer charities becomes a “clarion call” to change the IRS oversight of tax-exempt charities, possibly privatizing it?  Another article — footnoted above — by Lloyd Hitoshi Mayer (also in 2016) proposes this, and makes little mention of why thirteen years of not even an “RFI” after government funding to a NASCO/ Guidestar collaboration is evidence of competency?

Do you feel that the privatization should involve private associations named after public state-level offices which such as NASCO, NAAG (National Association of Attorneys General) who do not post their tax returns (although they seem to be private) on their websites, even in response to their own “FAQ” labeled “Where does it get its funding?”….

I found it odd but relevant (when size and scope of operations is considered) that the top of this article starts out mentioning the cancer charity sham (so does the website NASCOnetSupport.org, apparently the result of the collaboration mentioned above) and the first two footnotes are to that victory.

The third footnote is another article (recommended read!) by the same author, but this time in a Columbia Journal of Tax Law, and apparently part of a Univ. of Minnesota symposium.  It raises the question, and proposes possible answers, to how should the poor (lacking the resources for oversight), reputation-recently-battered-by Congress and the media, IRS reign in the bad charities and preserve the domain for the good guys?  I don’t agree, but it’s well-written and informative.  I suggest reading it, and noting the timeline of even requiring charities to register, and how very recent (2006) the practice of even revoking those who refuse to file three years in a row, are good to know (and that information should also be validated; I haven’t…).

The introduction sets the stage for saying, the IRS just isn’t up to regulation, and I’ve posted links to the concluding sections (a radical alternative) IV and V. Note: this is copyrighted material which can be read on-line and there is as you can see a downloadable link for full text:

 

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November 18, 2017 at 8:53 pm

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