Get Ahead of the Year-End Rush: Pre-vetting Tips for Equivalency Determination

Hello everyone. Thank you for joining. We'll just give another minute for a few more people to join. If you could please introduce yourself, tell us where you're joining from today, and what the weather is like. Uh that'll be our icebreaker to get us started while others are joining. All right. Uh thank you everyone for joining us today. I'm Jonathan Fairhead, um senior director for NGO Source. I oversee our global partnerships. Um and welcome to our busy season webinar. First off, a little bit about NGO Source. We're a project of TechSoup and the Council on Foundations. We launched in 2013 as a shared repository for uh US grantmakers making international grants using equivalency determinations. Um this is a uh webinar for grantmakers, but we really do see the NGOs around the world um as our clients as well. And um one of our main goals is to save them time so they don't have to duplicate their work and oh, a bit of echo. Uh not sure about that. Perhaps um our tech colleague can have a look at that. Um but our main one of our main tasks is saving time for NGOs around the world so that they don't have to duplicate their work on EDs on your behalf. So since we launched in 2013, we've done EDs on over 12,000 organizations around the world on behalf of approximately 1,000 US grant makers. So the repository is you know hitting its stride, critical mass and working as a sector resource. Uh let's go to introductions and I can introduce you to the senior members of our legal team or they'll introduce themselves. >> Hello everybody. Thank you for joining. Michael Damian, managing counsel and senior director of NGO source, also associate general counsel for TechSoup. I'll be discussing some of the ED challenges that we face while doing ED reviews and I'm happy to answer any questions at the end of the session. Thank you again for being here. I'll pass it over to Ricky. >> Hi there. I'm Ricky Stewart. I'm also a senior counsel and I am coming at you from the very, very hot desert of Utah right now. Um happy to have you all here. Thanks for coming in and I'll pass it over to Mike. >> Hi everybody. My name is Mike Hilton. I am also senior counsel here at NGO source. Um I forgot to put that it is also humid here in central North Carolina as you could expect. Um happy to be here and also delighted to answer any questions you might have. All right. >> Thank you so much, Mike. Once again, Jonathan Fairhead, um, NGOsource. I'm the only person on this call who is on this panel who is not an attorney. Um, I imagine I have that in common with many of you. So, I'm a proud generalist. Um, I learned everything I know as a grantmaker, um, working with attorneys. Um, and in my previous role, I actually even worked as a paralegal, uh, doing EDs, uh, on on behalf of a foundation, uh, before that foundation transitioned to NGOsource. Um, next slide, please. So, we're here. Um, you know, the grantmaking, uh, end of year is approaching. Um, all of our work to, you know, even out, flatten the curve for, uh, you know, end of year rush has has been somewhat effective, but we're still going to be working towards, um, the end of year payment deadlines. And these are some very high-level tips that we're going to be providing you today to, um, help you decide if an NGO, uh, partner is a good fit for ED. So, these are, you know, tools, uh, tools for the tool belt of a grantmaker, um, who, like myself, is a generalist and not a lawyer. Um, and, um, you know, these are these are some great tips. So, let's get over. First, we're going to look, next slide, please. Um, at our ED process. So, as I said, uh, NGOsource is a shared repository. We're a sector resource. We were, um, launched and invented by our constituents, which are grantmakers, NGOs, um, technologists, um, lawyers, members of the legal community, um and many others who launched uh NGO Source. So, what happens when you request an ED? Um and a smart questionnaire is sent to the NGO um in the language that you've selected. The NGO is able to adjust the language if they need to. Um and of course, one of the, you know, great things about NGO Source is that we have a network of global partners who attempt as much as possible to localize a very US-centric legal process and to provide in-country uh supports to the NGO. Um once the questionnaire is filled out, um it's sent back to our uh operations colleagues. Many of you probably interact with our colleagues in operations and account support at ngosource.org. Um and also, once that's completed, sent on to the legal team. Um there's a formal [clears throat] legal review, um an analysis is written, and um at the end of that, an equivalency determination is sent to you, the grant maker. We let the NGO know as well, and it's added to the repository. Next slide, please. So, pre-screening tools. Um These tools may be useful for grant makers to discuss with a prospective grantees before putting the grantee through an equivalency determination. It's never a substitute for putting an organization through ED. Um the outcome of such an inquiry is never a guarantee that an organization will or will not qualify for ED, as many nuances are not captured here. So, once again, very high-level overview of what an ED is, and what we're looking for, and what type of organizations uh will be um you know, well, are more likely to qualify. Uh not all relevant questions are included here, only certain threshold questions that are common cases for an organization's inability to qualify. Next slide, please. All right. Preliminary questions. These are questions that I asked myself in previous roles as a grant maker when looking at an organization to determine if they're a good fit for ED. Um and over to you, Mike. Next slide. >> All right. So, for the next several slides, Ricky and I are going to walk through some of the basic pre-submission questions that Jonathan just kind of touched on. Um these are questions that can help streamline the ED process. Uh so, we get, you know, basic things out of the way before before you even submit to us. Um throughout these slides, you're going to see that we have included some NGO Source educational materials. These links down at the bottom, as you can see, see how registration with the IRS impacts the ED. Um these are these are a bunch of resources that we have on our our website. I encourage you to review those links. They are clickable in the PowerPoint, so you can you can review those once we send the PowerPoint out after this webinar wraps. So, one of the preliminary questions that we we would like GMs to grant makers to ask their target organizations is whether or not they have already been kind of evaluated and recognized by the IRS as an organization that is a 501c something. Um occasionally, we will see organizations that, you know, already have 501c3 status in the US. And, you know, if we see that, we we can't perform an equivalency determination on that. It is already a US charity. Uh, and our determinations can't really overcome what the IRS has has said. Um, so, you know, if you if there's an organization that is of registered US 501c6, um, we cannot evaluate that for an equivalency determination, um, because the IRS, again, has already determined what it is. So, yeah, that is a great first question to be asking your your target organizations. Uh, and on our next slide, we will have more great questions. Excellent. So, another thing that that we kind of encounter in the ED process is there are a range of different organizations that types of organizations that can qualify for an ED aside from your typical like standard charity. Um, so, you know, asking some questions up front will help us determine what kind of organization we're looking at, and it'll help us make sure that these, uh, organizations answer the right questions in our questionnaire. So, uh, you know, we have schools. Uh, so, that's a, you know, a school. Uh, it's school, college, university. Uh, there's some basic things there that we look for. Um, does it have does the organization organization have a formal curriculum? Uh, does it have regular faculty? Does it have a student body that is consistently attending classes at a physical location? Um, so, if we can, you know, get yeses to these, then we know we're going to be looking at a school. That will help facilitate our review. Um, another common, uh, organization type we see is the church or religious congre- congregation. Uh, this again, you're looking at whether or not this organization has a a formal code or uh, doctrine. Uh, does the congregation made up of members of the public? Do they go and, you know, worship or attend some kind of you know, uh, events at a at a specific physical location. Are these regular events? So, you know, that that will help us kind of start getting down the road on our our church evaluation. We also see hospitals. And so, you know, this is you can ask does the organization treat patients at a physical location? It's okay if that physical location is a bus that kind of like moves from rural community to rural community providing care. Also, we're looking to see if this organization employs physicians. Are they or are they primarily primarily engaged in medical research, medical care? These are the kinds of basic questions that help us determine, yep, that's going to be a hospital and then we can make sure we're applying the right analysis there. Finally, we also sometimes see supporting organizations. Basic questions here are does the organization exist solely to support one or more other designated organizations or charities? We'll still see this frequently with supporting organization that is created to support a university for instance. Other things that are relevant to supporting organizations is you know, is the organization's board controlled by the charities it's supposed to be supporting? And those factors are generally kind of hidden in the governing documents. Not hidden, they're pretty obvious, but they're in the governing documents. So, sometimes you can ask an organization to look there and tell you exactly what's going on. So, if you know, one of these kind of types applies, we will probably not need to satisfy income questions because none of these organization organization types have a specific like required public support that they need to meet. And if none of these questions apply, then we or none of these uh categories apply, then we will probably have to look at the public support. Um, and we can go to the next slide. Oh, yeah. All right. So, this one is important. Uh this is a situation we run into somewhat frequently. Um, is the organization that you are targeting to forgiving an independent legal entity, or is it a project or a part of a larger organization? Um, frequently we will see organizations that are like a lab within a university. Uh, and sometimes that lab is an independent organization. It has its own governing documents. It has its own like legal form. But, often times this lab, while it operates in an independent fashion, is actually part of the university itself. It doesn't have an independent legal status. So, if that is the case, and you know, that the organization that you're targeting forgiving is not an independent legal organization, one thing that uh we can do is we will reach out to to you the grant maker at if this determination has been made on our side, and say, "Hey, this is not an independent legal organization. It's a part of this larger org. Would you like us to evaluate the larger organization to see if it is equivalent to US charity?" In which case, there can be a restricted grant made to that organization. Um, as a funds will flow straight through to to the targeted project that you'd like to give to. Um, yeah. All right. Uh, I will I will uh say next slide and pass it off to my colleague Ricky. >> Hi there. Thanks, Mike. Um, here we're looking at what does the organization actually do? And we would suggest that you take a look at not only the information that they provide you, but also take a look at their website. Um, a flag for us is when the organization is actually selling some sort of a product or a service. In that case, we pause and look to see how extensive those sales are. Is it something that's substantial or is it something tiny? Um, or is it aligned with their charitable purpose? Is it something that actually gets to drive why the organization is a charity in the first place? Um, an example of this in US terms is a B Corp. I like to think of Patagonia. Patagonia Patagonia has an amazing mission statement and they do really great things. My favorite thing that they do is on Black Friday, 100% of their sales goes to environmental organizations. Really great cause. But at the end of the day, when you look at Patagonia's website, you're not seeing all of its charitable works. Instead, you're seeing amazing ads for outdoor gear. So, Patagonia qualifies as a B corporation, not as a public charity. Um, next slide for us. Okay, with this, another flag that you want to look at is as you're going through governing documents, if you see the word shareholder, pause for a minute and start reading a little bit deeper. Um, we want you to look at any instance where they are distributing profits or any sort of dividends, um, or even at dissolution, if they're transferring those remainder assets to any private individuals or private entities, like private businesses. In that case, um, we're going to have a difficulty in actually getting them certified. This can be a pretty sig- significant roadblock for us because typically, if we're seeing shareholders and they are distributing those dividends um, or profits, that's typically an organizational defect. And depending on the country that they are actually organized in, they may or may not be able to amend their documents. In In fact, it's actually the rare exception that they're able to amend their documents to the extent that it effectively changes their type of business organization. So, understand that this might be a very extended ED or it could also be one that's just ultimately denied. Okay, and our next one. Okay, with this guy we're looking at political candidates. Once again, get into their website, get into their social media. For us, we have some pretty extensive questions in our questionnaire that get into whether or not they are actively endorsing a political candidate or a political party. And when you're looking at their website or their social media posts, take a look at blog posts, at the news tabs. Those typically are where we're seeing that. Some guys are are so it's so prevalent in the organization that it'll be on the front page. There would be a picture of a candidate there. But, take a close look at this cuz this one's going to also create problem. I'm going to go ahead and send this one over to Michael and he's going to discuss the three-prong test. >> Thank you, Ricky and Mike. I'll be discussing the three-prong test. Just to give a quick summary of what's required for a 501c3, which is also required for a non-US organization to be equivalent to a 501c3 public charity. After this, I'll also discuss some of the challenges that we commonly face when we do an ED review. So, as a quick summary, there are three tests that the organization needs to fulfill. One is the organizational test, next is the operational test, and the next, if applicable, is the public support test. The organizational test is the first one. Often times, we'll receive a request from a foundation asking us to pre-review an organization's governing document to see if it might qualify um for ED certification. While we're very happy to do that, and we do that often, um please know that that's only 1/3 of the equation. So, even though we we could determine that an organization's governing documents would pass organizational test, we would not know if they would ultimately qualify as ED equivalent unless we put it through a full examination where we can also look at its operations and its income stream. The organizational test is dependent on the organization's governing documents. The three things to look for are whether or not the organization has charitable objectives. So, that would be the first and foremost. If you are doing your own pre-vetting and looking through the governing document, that would be the first thing to look for. The second thing to look for is if there's some sort of clause or provision that describes how the organization's assets are restricted. That could be in the form of a dissolution clause, which discusses how the organization's assets where would they would go if the if the organization dissolves. It also could be in a separate clause, which generally discusses how an organization's assets should be used and how it's restricted. Ideally, they would have both, but if not, if as long as they have one, and it meets the requirements, then it could pass the dissolution requirement. Those are the two things we look for. That's specifically explicit in the governing document. The other things we look at are not in the document. We want to make sure there is no mention of it, or if there is, it's there's some limited mention. So, for example, private benefit. The requirement here is that the organization's governing documents should not explicitly provide for private benefit. So, as Ricky was mentioning, sometimes an organization's structure allows for shareholders, allows for dividend payments. If that's the case, then the presumption is that they do engage in private benefit, and they either would not qualify, or they would have to go through some extension extensive level of amendments to get to the point of qualification. The other things would be um more related to the operational section, which I'll now jump to. The operational section discusses what an act what an organization actually does on a daily basis, so it's activities. We heavily rely on what the organization describes in the in the questionnaire, how it describes its current, past, and and uh future activities. We also rely on the website or social media posts, and any other supporting document that the organization might provide, such as an annual report. Those will give us a good picture of what the organization actually does on the on a day-to-day basis, whether or not those activities are charitable, and how aligned they are with the organization's objectives. In the operational test, we also look for whether or not an organization is engaged engaged in political campaigning or or a substantial amount of lobbying. Now, if you find wording like this, I'm jumping back to the organizational test, if you find wording like this in the governing document, it doesn't necessarily mean that the organization will not pass an ED. If they talk about political campaigning, that is an absolute bar, so that would probably be the only thing that completely bars it, but even then, we would have to make sure that it's the type of political campaigning that is specific to US law. Lobbying, sometimes an organization will have a statement in its um objectives saying that they do engage in lobbying, but again, we'd have to look at their actual activities in the operational test to determine whether or not those activities are actually lobbying or um and if they are, whether they hit the threshold of being substantial. So, in summary, the things that we don't want to see in a governing document are things that have to do with lobbying, political campaigning, or private benefit. But, to the extent that they are there, there are ways that we can get around it if we are able to examine those type of activities in the operational test. The final test is the public support test. This only applies to organizations, as Mike mentioned, that are not hospitals, schools, churches, supporting organizations, or government. Those organizations have a specific analysis based on that specific entity type, and they do not need to fulfill a public support test. All other organizations need to show that they are bringing in at least 33 and a third percent of their income from the public. If they are less than 33 and a third, but but over 10%, that is an acceptable range so long as they're maintaining um uh a a program for fundraising and attracting public income, and they meet other facts and circumstances. I'll discuss this in more detail uh in in future slides. The other thing I want to mention here, and we get this question quite frequently from foundations, is what defines a government instrumentality. This is a little bit different than um some parts of the tax code that define what a US government instrumentality is. While that's helpful, what we're looking for here is in a different part of the tax code that describes a foreign government or an organization that is controlled by multi-governments. Foreign government is clear. It's It often is similar to the way we would evaluate a US government entity. It's a part of the government, it's part of the uh the organizations um the the the the the countries um governing structure. A multi-government organization is more akin to an international organization. Now, this is not to be confused with public international organizations that are designated by executive order. Those are the ones that US government has predetermined are actually public international organizations and they are defined in that category based on um a certain definition and they're determined by executive order. If you're trying to find an organization that is listed um as one of those organizations and you can find those in the link here, then that organization does not require an ED, does not require an ER, any sort of uh due diligence. So long as the funds are being used for charitable purposes and it doesn't require us to predetermine that those organizations are equivalent to a government instrumentality because the US government has already determined that. Now, what to make it on that executive order list, the US has to be a member of one of those organizations and because of that um the result of being put on that list, those organizations are able to uh have the privilege of certain immunities. That's all to say that an organization that is designated as international organization because it's controlled by multi-governments doesn't necessarily have to be on that list. If it's not on that list and you'd like us to evaluate it to make sure that is an international organization that is equivalent to one that's on that list except for the fact that the US is is not a member, uh we can do that. It will go through the same government instrumentality analysis as any other type of foreign government. Next slide, please. One of the main challenges that we uh that we face in doing an ED review is terminology. And this is an example of that. The term charitable versus nonprofit. In the US, 501c3s are both charitable and nonprofits. But not all nonprofits in the US are charitable. You could have a different type of 501 C designation, which would make you a nonprofit, but you're not your activities are not necessarily charitable. Um in some other countries, the terms are either interchangeable or there's no clear um overlap between charitable and nonprofit. This comes into play when we look at something like the dissolution clause, for example. Um if a dissolution clause says something like all the organization's assets upon dissolution will be distributed to another nonprofit organization. Unless there's local law that defines a nonprofit as being charitable or unless we can obtain an opinion of counsel of local counsel stating that local law is interpreted that way, then we would use the US definition of nonprofit, which is too broad. If it's simply saying that assets will go to a nonprofit organization, that doesn't necessarily mean that those assets will be used for charitable purposes or that the organization itself is charitable. In that scenario, that these terms uh tend to be problematic. So in the to the extent that you're evaluating an organization's dissolution clause or the type of organization it is or how it's using certain terminology, this is one to look for. Next slide, please. Dissolution is by far the biggest challenge that we see and it again comes down to terminology. I already described the the example of nonprofit versus charitable. Another example that we see often is similar purposes. The The IRS has already determined that the term similar is too broad. If an organization In order for an organization to use uh In order for an organization to pass the dissolution requirement, that requirement must state that the organization's assets upon dissolution are distributed to another charitable organization or to another in general specifically for charitable purposes or to the government for public purposes or some variation of those of that language. So long as those assets are dedicated in one of those ways, then it will pass the dissolution requirement. Often times it will say that an organization's assets will be dedicated to similar purposes. This is a funny one because if I was an attorney in another country and I wasn't aware of US law, I would probably recommend that the organization state it this way because how often would you find another organization that has the same exact purposes? Nonetheless, that is the requirement if uh if it's not meeting one of the other three uh examples here that I've stated or some variation of it and it simply refers to the organization's purposes, then it must state that assets will go to another organization that has the same purposes. Now, this can be overcome in a couple of ways. We look for another clause called an asset use clause. That's our own terminology. That clause dedicates the organization's assets generally to the organization's own purposes. Often times the organization will have both a dissolution clause and an asset use clause. If the dissolution clause is not compliant because it uses that similar purposes language, but the governing document contains this other clause that dedicates the assets generally to its own purposes in combination, we can argue that the dissolution clause is actually compliant because there is another clause that does dedicate the assets more specifically to the organization's own purposes, and we've already determined through the operational test or the organizational test that the that the organization's purposes are indeed charitable. So, by extension, the organization's assets would be dedicated to charitable purposes upon dissolution. That's one of the ways that we can overcome this. Another way, if there is no asset use clause and local law is not supportive, we would likely ask the organization to amend its governing document so that the dissolution clause is compliant based on one of these variations of language. This is important to know in your pre-vetting because to the extent that you are looking at the the the dissolution clause and you see the similar purposes issue or some other issue that I've described, just know that one of the resolutions might be that we would ask the organization to amend its governing documents, which could take several weeks to several months. So, in terms of your grant making strategy, if you have if you are doing pre-vetting and you see this language, just know that you might have to come up with a contingency plan in that sort of grant making or or it could be a way to set expectations in that this grant may not or this ED may not be approved this calendar year. So, this is a way for you to not only pre-vet based on this type of challenge, but to also plan accordingly. Next slide, please. Another issue that prevents ED certification is public support. I already talked about this in a previous slide, but to be uh more explicit about it, the public support test, when it does apply to to those organizations that where it's required, an organization's income must be coming from the public and uh must pass or if an organization's income is coming from the public to the extent that it's 33 and a third or over, it will definitely pass the public support test. If the public income is between 10% and 33 and a third, it must maintain a continuous program of seeking income from the public plus meet other facts and circumstances. Unless an organization does not have a continuous program of seeking income, unless that's the case, it will not get to the point where we If that's not the case, it will not get to the point where we examine other facts and circumstances and it will not pass. It has to meet that one important threshold before we even consider the other facts and circumstance questions. Once it passes that one threshold and we consider facts and circumstances, it's very rare that an organization will not pass the public support test in that scenario. Now, if an organization's public support is under 10%, then that organization is in private foundation status and it will not pass the uh the the the the ED review even if it does pass the other two tests of being organized and operated uh for charitable purposes. Now, there are exceptions to this. We do in NGOsource try to get the organization across that finish line as much as we possibly can, so we won't give an automatic denial. We will look for certain ways that we could still pass the organization. Sometimes an organization doesn't report its income properly. >> [clears throat] >> Excuse me. There are certain categories that an organization has to um provide or has to provide income for those for those categories that may not align with the way that its audited financials are reported. So, doing a deeper dive in how the organization is reporting its audited financials and extensive follow-up with the organization, we might determine that they've misinterpreted some of the categories and the income is not reported correctly. In that case, in some instances by changing some of the categories um and and uh correcting them, that could increase the public support percentage to the point where they can be certified. Another thing we look at is whether unusual grant applies. This is a very rare scenario, but sometimes it does work. It's sort of a second or third bite of the apple that the IRS provides. This is a scenario, I'll give an example of an organization that for several years has been passing the public support test, but currently they've they've received a very unexpected enormous grant from one foundation that has pushed the public support percentage down to private foundation status. So, the IRS, the way it looks at that is this organization shouldn't be penalized because it received one large enormous unexpected grant, so they have a process called unusual grant. So long as it meets those two standards where it's unexpected and it is large enough that it drastically affects the public support to the point that it pushes it down to private foundation status, then we can look at an unusual grant analysis where other factors have to be met, and if all factors are met, we can exclude that grant from the public support calculation. And in that scenario, the organization would not be um detrimentally affected by the one grant that they received. Another scenario is if an organization's income is largely coming from gross receipts from mission-related activities. This is a scenario where rather than being supported largely by grant income, it's being supported by payors rather than grantors. So, what a payor is is if somebody is paying for a specific service or product or um event that that benefits them directly. So, if you imagine something like ticket sales or entrance fees or even like a gift shop. Um that's something where you have a payor, an individual largely paying directly and getting something immediately upon return. That is quite different from a grant where foundations are often providing general support and not expecting anything in return. If the a majority of their income is coming from gross receipts from mission-related activities, then based on IRS codes, it's not falling under a 509A1, which covers the types of organizations that we've been discussing up to this point, but it would be covered under a 509A2. A 509A2 organization is just that, an an organization that whose income is coming largely from gross receipts from mission-related activities. If that's the case, there's a different type of public support analysis that the organization has to fulfill and different types of requirements. If we discover that an organization's income is coming largely from gross receipts uh or if they've miscategorized their income and it should be under the gross receipts line, then we will activate the 509A2 analysis um to determine whether the organization is still publicly supported based on those factors. That at that point, if it does pass public support, it's treated the same way as a 509A1 and it could the same type of tax deductions would apply, but it would be considered a 509A2 for purposes of the ED certification. Um So, these are some some of the ways that if an organization appears at first glance to not pass the public support, we would look at different things that either we might have missed or the NGO might have missed to see if there are other alternatives. Next slide, please. As we all know, the alternative to an ED is expenditure responsibility, ER. So, this is something that I know many of you want to avoid. Um it's it's very lengthy and it's very laborious, could be costly, requires a lot of resources for both the NGO and the and the foundation. Uh requires extensive grant reporting. The the grant money has to follow the activities. Those activities have to be charitable. The to the extent possible, the grantor has to ensure that those activities are charitable not through the grant agreement alone, but through continuous status reports. Um this is something that uh that while some foundations might have the resources for this, others might not. But in terms of your pre-vetting, what might be helpful is to determine whether or not an organization you're looking to fund could be a candidate for ER. So, if you are determining whether an organization is worth going the ER process, but you want to see if it would pass ED first, you could categorize it in that way and and perhaps even notify us of that. It wouldn't affect the our the way that we the level of scrutiny that we would that we would go through to go to uh pursue the ED review. However, it would be helpful us to know if the organization has an alternative, if the grant has an alternative. Um in your own strategy in your own grant-making strategy, this is helpful because you'll know that if if there's something that requires an extensive amount of time, such as a an amendment to a dissolution clause, there's at least an alternative you have in your books that if it does not pass ED in this calendar year, you could at least pursue ER. By contrast, there might be certain organizations where you're not willing to do the ER um process, and and ED is really the only way to go. Those organizations you might prioritize more in terms of um whether or not to submit an ED. Next slide, please. Many of the things we discussed here in terms of pre-screening, pre-vetting, uh we have a checklist that might be useful to many of you, and it covers some of the material that we've covered today. So, when we when we provide you with a copy of this presentation, we will also provide you with a PDF of this pre-screening checklist that might be helpful when you do your pre-screening, and if you have any questions about that, or you'd like assistance with your pre-screening, please feel free to reach out to any of us. I'll now pass it on to Jonathan to discuss partnerships and uh the various languages that we use with our partners. >> Great. Thank you so much, Michael, uh Ricky and Mike, and uh thank you for the great questions um in the chat. Um thank you, Kim. I see Ricky, we'll go back to you. So, um as we mentioned, um you we NGOsource uh strives to narrow the gap between um US grant makers um and organizations around the world going through this very US-centric process. Um and the way that we do that is we work with uh 13 global partner organizations. Uh in Brazil, in Brasilia, we have a partner called ATN. We work with Semathi in Mexico City. Um many of you've seen uh you know, some webinars that we've jointly done with Semathi. We have a partner in Poland, India, Australia, South Africa, Pemba, um Japan, Kenya, um Rashi Foundation in Israel, and then TechSoup Asia, which is in has offices in Taiwan and Indonesia. And lastly, the West African Civil Society Institute, which is in Accra, Ghana. So, these organizations are provide technical support in local time zones and in local languages. They work in English, Simplified Chinese, French, Portuguese, Spanish, Kiswahili, spoken Kiswahili, most writing is done in English, Traditional Chinese, Indonesian, Hebrew, and Japanese. Um the global partners of the legal team can bring them in if they need to, you know, some help supporting the NGO through some translation questions or we need a call, and they routinely work in tandem with our operations team um to support the NGO through the ED process. Next slide, please. All right, what we've all been waiting for, some recommendations, and of course the usual year-end deadlines and how some nuances around those and how to navigate those. So, to support year-end planning, we routinely suggest that you submit ED requests by September 30th to prioritize completion and certification in for payment in 2026. Um this allows a nice buffer for if there's, you know, some back and forth required if an NGO has a small staff and people are out of the office or working on, you know, their primary mission and focus, or if there any amendments needed. The September 30th deadline provides a a good amount of time for completing an ED uh in 2026 for payment. Um, and it's generally it is the safest date to go with. So, um that is our uh suggested date. Um, please um you know, work towards that uh to to the degree possible. Of course, you know, we'll continue processing ED requests after September 30th. Um, if you log on to Grant Maker portal, you'll see that their dates uh going later into December. Um, and we will work towards those dates, but we won't have that buffer um that I spoke about, you know, for any um you know, delays in communication, uh needing translation support, or having to make any amendments or clarifying uh follow-up. Um, so we will accommodate October uh up to October 30th, we'll accommodate those requests um to the best of our ability um and as circumstances allow, um but um after October 30th uh completion cannot be guaranteed. And before October 30th, you know, it's um if anything unusual comes up, there could be a delay. Um, all requests submitted after October 30th, um please expect uh those to be certified in early 2027. Um, currently turn around times, we provide a conservative estimates and you know, aim to beat them, um but we're estimating new EDs uh take up to 8 weeks, and renewals take up to 6 weeks uh of processing time. Um, as you know, or may know, um there is the option to expedite an ED request. Um, we're a shared service um and a you know, a work as a sector resource processing EDs in the order in which we receive them. Uh um But, for an extra $500, you can expedite your ED request, which puts your request at the front of the queue for priority processing, and that shaves off a good couple of weeks off the process. Um So, prepare your grantees. When I was a grant maker, I found the most useful thing to do was to as I requested the ED through the NGO Source Grant Maker portal, was to shoot that grantee a note saying, you know, look out for the questionnaire, look out for the invitation. We've asked NGO Source to do this, and there's some template language that I used to use. You can do that or just a personal note. That way, the invitation email doesn't get lost in a spam folder, and we don't have to, you know, go through several rounds of reminders and and not get a a response. Updated contact information. You know, especially with the case of renewals, it's a standardized process. The contacts are already listed in the Grant Maker portal. You know, give them a eyeball them and see if there's somebody new that you're working with who's especially responsive or there's been a change in staff. You can update that information. You can update that information as well. You can also write to us at accountsupport@ngosource.org, and a member of our operations team can update that information for you as well. And always, always let the NGO know that they can reach out to us for any support that they need. The global partner in their region will reach out to them to offer support as well, but our our operations team is always available and adept at supporting NGOs through the through the process. Next slide, please. All right, we're going to go to Q&A. If anyone has some uh some questions for us. Otherwise, you know where to find us. Let's go to the next slide, please. Um and then the slide after that. Thank you very much for joining us today. And we can just >> Looks like that was the end of the slides. >> Hey, could you do maybe just do the second There we go. Contact us. Um uh just take a minute um if you would like to reach out to uh Michael, Mike, Ricky uh with a legal question, or myself with anything to do with working with NGO Source, um or your partnership or your organization's partnership with NGO Source, please feel free to reach out. We're here um to support you through this busy season. Um and we're extremely motivated by the fact that um the work that we do plays a very small part in the um important work that these organizations do in their communities. So, thank you very much for being an NGO Source partner and for working with us. And we look forward to more questions throughout the throughout the year. Um and lastly, a couple of Legal Ease blog posts have been put in the chat. Um feel free to grab those. One on uh uh one on tipping. And here we have another one on um Here we have Ricky's put a resource a link to all of our Legal Ease blog posts, um which is especially helpful. We also have the NGO Source Learning Center, um which is on our website and is a wonderful multilingual resource for NGOs going through the ED process. I'll drop that link in now. But otherwise, thank you very much for joining us.