FIND THE EXPLANATION
Follow the payment from your bank to each creditor before enrolling in a debt management plan.
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The controlling distinction is between an organization’s eligibility for federal income-tax exemption and a consumer’s rights under a particular service arrangement. Section 501(q) imposes conditions on exemption when providing credit-counseling services is a substantial organizational purpose. It includes consumer-facing protections, but its text does not itself establish a comprehensive DMP contract, guarantee creditor concessions, prescribe a national dollar fee cap, or expressly supply a consumer damages or refund remedy. Those conclusions are limited to the provisions examined here. They do not establish that another law or contract supplies no remedy. See claims C004, C021–C024, and C051–C054 below. uscode.house.gov+1
This investigation uses public primary sources retrieved in this conversation. No prior research chat, Library finding, provider record, exemption-status database, organization roster, client information, or identifying entry was used as a foundation. All organizational applications remain unknown and parent-held.
Access date for every source and retrieval attempt below: October 27, 2026, America/Los_Angeles. Jurisdiction: United States federal law.
For readability, S001 means R034-P1-S001, C001 means R034-P1-C001, and B01 means R034-P1-B01 throughout.
The complete current-edition §501(q)(1)–(4) was read, including every nested clause, in the Office of the Law Revision Counsel’s compilation displaying laws in effect through Public Law 119-134, October 20, 2026. The necessary text of §501(a), (b), and (c)(3)–(4), together with the relevant source, amendment, reference, and effective-date notes, was also read. Section 501(q) ends after paragraph (4); it does not contain a paragraph establishing a general related-organization revenue aggregation rule. uscode.house.gov+3
The enacted source is Pension Protection Act of 2006, Pub. L. 109-280, §1220, August 17, 2006, 120 Stat. 1086–1089. Its complete §1220 was read in the official session-law text. This matters because the general effective-date transition appears in §1220(c), while the graduated creditor-revenue percentages appear inside §501(q)(2)(B)(ii). They are separate provisions with different predicates. govinfo.gov+2
For §513(j), the readable OLRC body displayed a cutoff of Public Law 119-120, October 7, 2026. Attempts to retrieve a newer §513 body failed. The OLRC classification table prepared October 20, 2026, was checked for its complete Title 26 block; that block does not list §§501 or 513. This provides a bounded update check, not a substitute for a successfully retrieved newer §513 body or a complete session-law audit. uscode.house.gov+2
The relevant eCFR pages for §§1.501(c)(3)-1, 1.501(c)(4)-1, and 1.513-1 displayed Title 26 as updated through October 26, 2026. The §1.501(a)-1 retrieval displayed October 23, 2026, with a title-level last-amended date of October 19. These are publisher compilation labels; they are not dates on which every provision on the page was amended. The eCFR describes itself as authoritative but unofficial, rather than the official legal edition of the CFR. ecfr.gov+3
| Material class | Treatment in this pass |
|---|---|
| Current statutory text | §501(q) read completely at the displayed October 20, 2026 cutoff; §513(j) read with the separate October 7 cutoff and classification-table qualification above. |
| Current regulatory text | Necessary general exemption and unrelated-business provisions read from eCFR, with each displayed currency date retained. |
| Historical enacted transitions | Preserved as historical, predicate-specific rules. They are not a recurring grace period for newly formed organizations. |
| IRS HTML explanations | Read as official explanatory guidance. Their retrieved bodies did not expose an issuance or revision date; crawl dates were not substituted for agency publication dates. |
| IRS November 1, 2011 FAQ PDF | Read as a dated historical explanatory version, including its transition examples and simplifying statements. |
| Revenue rulings from 1965 and 1969 | Read completely as published IRS rulings addressing their stated generic facts. They predate §501(q). |
| Chief Counsel Advice dated May 9, 2006 | Read as nonprecedential internal legal advice containing generic examples; it predates §501(q). |
| JCT explanation dated August 3, 2006 | Read as staff legislative explanation of the bill, not an IRS ruling or operative statutory text. |
| Final versus temporary rules | T.D. 9819’s final status, effectiveness, applicability, and removal of corresponding temporary regulations were checked. |
| Proposed, future-effective, withdrawn, stayed, or vacated materials | No such material was used as governing authority. A comprehensive withdrawal, judicial-validity, or later-history audit was not performed. |
| Court opinions | No opinion was independently retrieved or used for a holding. Cases discussed inside older explanatory materials were not converted into independently verified precedent. |
The source labels and amendment notes do not establish a complete audit of every session law, unclassified provision, administrative development, or judicial decision through the access date.
The read-bounds column below is the source-read log. HTML and PDF versions of the same explanation, and related sections of the same regulatory instrument, are grouped. They are not counted as independent corroboration.
PDF page indices are zero-based. Findings below rely on retrieved HTML and parsed PDF text; no pixel-inspection finding is claimed.
| Source ID | Issuer, title, and complete literal HTTPS URL | Exact location, version/status, read extent, and limits |
|---|---|---|
| R034-P1-S001 | Congress; OLRC, 26 U.S.C. §501, Exemption from tax on corporations, certain trusts, etc. https://uscode.house.gov/us/usc/119-134/t26/s501/ | Complete §501(q)(1)–(4); complete necessary §501(a), (b), (c)(3), (c)(4)(A)–(B); relevant source credit, reference note identifying August 17, 2006, amendment entry for §1220(a), and effective-date note for §1220(c). Displayed cutoff: P.L. 119-134, October 20, 2026. HTML; PDF index N/A. Other exemption categories were not substantively investigated. uscode.house.gov+5 |
| R034-P1-S002 | Congress; GPO, Pension Protection Act of 2006, Pub. L. 109-280 https://www.govinfo.gov/content/pkg/PLAW-109publ280/html/PLAW-109publ280.htm | Complete §1220(a)–(c), 120 Stat. 1086–1089: insertion of §501(q), addition of §513(j), and both general effective-date clauses. Enacted August 17, 2006. Official session-law HTML with printed-page markers; no session-law PDF inspection claimed. Remainder of the Act excluded. govinfo.gov+2 |
| R034-P1-S003 | Congress; OLRC, 26 U.S.C. §513, Unrelated trade or business https://uscode.house.gov/us/usc/119-120/t26/s513/ | Complete §513(j), necessary §513(a), and source/amendment/effective-date notes concerning §1220(b)–(c). Displayed cutoff October 7, 2026. Another retrieved path, https://uscode.house.gov/us/usc/119-118/t26/s513/, displayed the same October 7 cutoff. These are the same instrument, not separate corroboration. Newer-body retrieval gap remains. uscode.house.gov+2 |
| R034-P1-S004 — exemption rule | Treasury/IRS; eCFR, 26 CFR §1.501(a)-1, Exemption from taxation https://www.ecfr.gov/current/title-26/section-1.501%28a%29-1 | Necessary reliance: (a)(1)–(2), (c), and (f), including the distinction between nonprofit operation and exemption, definition of private shareholder/individual, and applicability language. Retrieved page displayed October 23, 2026 currency. Procedural and territorial material returned on the page was not used for application or territorial conclusions. ecfr.gov |
| R034-P1-S004 — §501(c)(3) rule | Treasury/IRS; eCFR, 26 CFR §1.501(c)(3)-1 https://www.ecfr.gov/current/title-26/section-1.501%28c%29%283%29-1 | Read (a)–(c), (d)(1)–(3), including the private-benefit examples, and (g)–(h)/source notes. Relied principally on organizational/operational tests, earnings/private-interest rules, and charitable/educational definitions. Displayed currency October 26, 2026. Paragraph (g) supplies the general historical applicability rule; (h) makes specified procedural paragraphs applicable on and after July 1, 2014. Full enforcement, excess-benefit, and judicial-validity analysis excluded. ecfr.gov+6 |
| R034-P1-S004 — §501(c)(4) rule | Treasury/IRS; eCFR, 26 CFR §1.501(c)(4)-1, Civic organizations and local associations of employees https://www.ecfr.gov/current/title-26/section-1.501%28c%29%284%29-1 | Complete (a)–(b) and source note read. Displayed currency October 26, 2026. Source note identifies T.D. 6500 and amendment by T.D. 8308, August 31, 1990. No actual category determination; §504 consequences and full political-activity analysis excluded. ecfr.gov |
| R034-P1-S004 — related-business rule | Treasury/IRS; eCFR, 26 CFR §1.513-1, Definition of unrelated trade or business https://www.ecfr.gov/current/title-26/section-1.513-1 | Substantive text (a)–(h) retrieved and read; necessary reliance on (d)(1)–(3), concerning contribution to exempt purposes and excessive scale. Displayed currency October 26, 2026. Paragraph (h) gives general applicability to taxable years beginning after December 12, 1967, with optional earlier reliance and a distinct later date for (f). No tax computation performed. ecfr.gov |
| R034-P1-S012 | Treasury/IRS; Federal Register, T.D. 9819, Guidelines for the Streamlined Process of Applying for Recognition of Section 501(c)(3) Status https://www.federalregister.gov/documents/2017/06/30/2017-13866/guidelines-for-the-streamlined-process-of-applying-for-recognition-of-section-501c3-status | 82 FR 29730–29733, June 30, 2017. Final regulations/removal of temporary regulations; effective June 30, 2017, applicable specified provisions on and after July 1, 2014. Substantive preamble, dates, and regulatory amendments read in HTML. Used narrowly to verify status/date of the general regulations and obsolete procedural references. No form eligibility, filing, or application advice adopted. PDF index N/A. federalregister.gov+4 |
For all S005 HTML entries, the complete substantive answer shown on the page was read. No agency issue/update date was exposed in the retrieved body. Their status is official IRS explanatory webpage, not statute, regulation, revenue ruling, or individualized determination.
| Source ID / subdivision | Title and complete literal HTTPS URL | Exact read location and limits |
|---|---|---|
| R034-P1-S005 — index and dated PDF | Credit counseling organizations: Questions and answers about new requirements https://www.irs.gov/charities-non-profits/credit-counseling-organizations-questions-and-answers-about-new-requirements ; dated PDF: https://www.irs.gov/pub/irs-tege/creditcounselingfaqs11_01_11.pdf | Index and its general caveat read. Entire PDF, printed pp. 1–4, indices 0–3, updated November 1, 2011, including all 12 questions. HTML numbering differs because the dated PDF includes an effective-date question. PDF simplifications are not substituted for statutory exceptions. Internal Revenue Service+2 |
| S005 — applicability | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-applicability | Complete answer and incidental financial-literacy-course example; HTML Q1, PDF Q1, p.1 [0]. Internal Revenue Service |
| S005 — general criteria | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-new-criteria-for-exemption | Complete list; HTML Q2, PDF Q2, p.1 [0]. The HTML preserves the no-fee/no-interest loan exception; the dated PDF’s abbreviated loan bullet does not. Board summaries omit the separate 20% test. Internal Revenue Service+1 |
| S005 — no DMP offered | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-organizations-that-do-not-provide-debt-management-plan-services | Complete answer; HTML/PDF Q4, PDF p.2 [1]. Must be read with the substantial-purpose predicate. Internal Revenue Service |
| S005 — governing board | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-composition-of-governing-board | Complete answer/example; HTML/PDF Q5, PDF p.2 [1]. Membership shorthand does not replace the statutory voting-power measurements. Internal Revenue Service |
| S005 — taxable subsidiaries | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-taxable-subsidiaries | Complete answer/examples; HTML/PDF Q6, PDF pp.2–3 [1–2]. Statutory ownership bases and exceptions remain controlling. Internal Revenue Service |
| S005 — customer lists | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-customer-lists | Complete answer; HTML/PDF Q7, PDF p.3 [2]. Used for IRS interpretation of paid leads/referrals, not privacy-law conclusions. Internal Revenue Service |
| S005 — contributions | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-ban-on-soliciting-contributions-from-consumers | Complete answer; HTML/PDF Q8, PDF p.3 [2]. Category limitation comes from §501(q)(2). Internal Revenue Service |
| S005 — creditor revenues | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-limitation-on-income-from-debt-management-plans | Complete answer; HTML/PDF Q9, PDF p.3 [2]; additional percentages in PDF Q3, p.2 [1]. Its statement about consumer fees must be read against the statutory numerator and total-revenue denominator. Internal Revenue Service+1 |
| S005 — unrelated business | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-income-taxable-if-requirements-not-met | Complete answer/example; HTML Q10, PDF Q11, p.4 [3]. Read with §513(j), not as a guarantee that an organization retains exemption. Internal Revenue Service |
| S005 — resource hub | https://www.irs.gov/charities-non-profits/charitable-organizations/credit-counseling-organizations-under-the-federal-tax-law | Complete resource listing read to locate statutory/JCT material. Linked historical compliance reports and testimony were not adopted as substantive current authority. Internal Revenue Service |
| Source ID | Issuer, title, and complete literal HTTPS URL | Version/status, precise read extent, and limits |
|---|---|---|
| R034-P1-S006 | IRS, Rev. Rul. 65-299, 1965-2 C.B. 165 https://www.irs.gov/pub/irs-tege/rr65-299.pdf | Entire reformatted two-page PDF read, indices 0–1; original C.B. citation p.165. Published revenue ruling, 1965; an exact issue-day is not printed in this copy. Generic social-welfare facts. Predates §501(q); historical district-director/Form 1024 language is not current filing advice. No original C.B. page-image inspection or complete later-history audit. RR65-299.C4+1 |
| R034-P1-S007 | IRS, Rev. Rul. 69-441, 1969-2 C.B. 115 https://www.irs.gov/pub/irs-tege/rr69-441.pdf | Entire reformatted two-page PDF read, indices 0–1; original C.B. citation p.115. Published revenue ruling, 1969; exact issue-day not shown. Its no-charge services, creditor approval, trust account, and funding facts are conditions of the stated example, not new universal rules inferred from §501(q). RR69-441.C3+2 |
| R034-P1-S008 | IRS Office of Chief Counsel, Credit Counseling Organizations, Chief Counsel Advice 200620001 https://www.irs.gov/pub/irs-wd/0620001.pdf | Dated May 9, 2006, released May 19, 2006; institutional author: Chief, Exempt Organizations Branch 2. All available text of 11 PDF pages [0–10] read, including both generic fact patterns, analysis, qualifications, and concluding sections. Expressly nonprecedential; predates §501(q). Redacted material was not reconstructed. Cases and another CCA discussed inside it were not independently investigated or adopted as holdings. irs.gov+3 |
| R034-P1-S009 | Staff of the Joint Committee on Taxation, JCX-38-06, Technical Explanation of H.R. 4 https://www.irs.gov/pub/irs-tege/jcx38_06.pdf | August 3, 2006; bill as passed by House July 28 and considered by Senate August 3. IRS-hosted extract, but JCT staff authorship. Complete credit-counseling Explanation of Provision, printed pp.316–320 [PDF 5–9], including footnotes 432–436, definitions, and effective date, read. Earlier historical background was only partly read and is not a case-history foundation. Legislative explanation, not operative law. Pensions Technical Explanation 7-28.doc+3 |
| R034-P1-S010 | IRS, Frequently asked questions about applying for tax exemption https://www.irs.gov/charities-non-profits/frequently-asked-questions-about-applying-for-tax-exemption | Complete answers to “What is the difference between nonprofit and tax-exempt status?” and “How does an organization become tax-exempt?” read. Official explanatory webpage; no agency revision date exposed. Remainder of application procedures excluded. Internal Revenue Service |
| R034-P1-S011 | OLRC, Currency and Updating; Classification Tables https://uscode.house.gov/currency.html ; https://uscode.house.gov/classification/tables.html ; https://uscode.house.gov/classification/tbl119cd_2nd.html | Currency explanation and classification-table scope read; 2026 table heading/date and complete Title 26 block read. Table prepared October 20, 2026, covering the listed 119th Congress second-session laws through P.L.119-134. Only classified provisions are represented. This is an update aid, not operative statutory language or a complete unclassified-law audit. US Code+3 |
| Claim ID | Verified claim, with conditions and limits | Exact authority/source |
|---|---|---|
| R034-P1-C001 | The complete §501(q) body retrieved at the current-edition link comprises paragraphs (1)–(4), with a displayed October 20, 2026 compilation cutoff. That label does not certify a complete amendment or case-history audit through October 27. | S001, heading and §501(q); S011 currency explanation. uscode.house.gov+2 |
| R034-P1-C002 | Section 1220(a) of P.L.109-280 inserted §501(q); §1220(b) added §513(j). Under §1220(c)(1), the default applicability is to taxable years beginning after the Act’s enactment on August 17, 2006, subject to the separate existing-organization transition. OLRC’s note explains the editorial execution of the amendment despite the Act not naming the Code in the amendment instruction. | S002 §1220(a)–(c)(1), 120 Stat.1086–1089; S001 amendment note. govinfo.gov+2 |
| R034-P1-C003 | The general delayed-start provision applies to an organization described in §501(c)(3) or (4) for which credit counseling was a substantial purpose on enactment. For that predicate, §1220’s amendments apply to taxable years beginning after the date one year after enactment. The clause does not repeat the separate revenue-transition requirement of being exempt under §501(a) on enactment. | S002 §1220(c)(2), 120 Stat.1089. govinfo.gov |
| R034-P1-C004 | When providing defined credit-counseling services is a substantial purpose, exemption under §501(a) is unavailable unless the organization is described in §501(c)(3) or (4) and is both organized and operated in accordance with the applicable §501(q) requirements. This is a necessary-condition framework, not an independent exemption category. | S001 §501(q)(1), introductory text. uscode.house.gov |
| R034-P1-C005 | Defined credit-counseling services encompass public educational information on budgeting, personal finance, financial literacy, saving and spending practices, and sound consumer-credit use; counseling individuals and families with financial problems; or a combination. The definition does not impose a general low-income-only criterion. | S001 §501(q)(4)(A)(i)–(iii). uscode.house.gov |
| R034-P1-C006 | Offering no DMP does not itself avoid §501(q). Conversely, the IRS gives an incidental financial-literacy course within a school curriculum as an example outside the substantial-purpose trigger. Neither the subsection nor that explanation supplies a universal numerical substantial-purpose threshold. | S001 §501(q)(1), (4)(A); S005 applicability and no-DMP answers. Internal Revenue Service+2 |
| R034-P1-C007 | Defined DMP services include services related to debt repayment, consolidation, or restructuring, including negotiating lower creditor interest rates, fee waiver/reduction, and DMP marketing and processing. A service may fit that definition without guaranteeing a concession or establishing that credit counseling is a substantial organizational purpose. | S001 §501(q)(4)(B), read with (q)(1). uscode.house.gov |
| R034-P1-C008 | Nonprofit organizational status does not automatically produce federal income-tax exemption. IRS describes nonprofit status as a state-law concept; federal exemption requires satisfaction of federal tax law. Section 501(b) also preserves taxation of specified activities notwithstanding organizational exemption. | S010 nonprofit-status answer; S001 §501(a)–(b); S004 §1.501(a)-1(a)(1)–(2). Internal Revenue Service+2 |
| R034-P1-C009 | A §501(c)(3) credit-counseling organization must still satisfy the underlying organizational and operational tests for an exempt purpose, commonly charitable or educational here. Governing language and actual operations are separate requirements; educational subject matter alone does not establish compliance. | S001 §501(c)(3); S004 §1.501(c)(3)-1(a), (b), (c)(1), (d)(2)–(3). uscode.house.gov+3 |
| R034-P1-C010 | Section 501(c)(3) forbids net earnings inuring to a private shareholder or individual. The regulatory definition refers to persons with a personal and private interest in organizational activities. Board-percentage permissions do not authorize earnings diversion. | S001 §501(c)(3); S004 §§1.501(c)(3)-1(c)(2), 1.501(a)-1(c). uscode.house.gov+2 |
| R034-P1-C011 | The §501(c)(3) public-interest requirement is broader than the earnings-inurement prohibition: an organization must serve public rather than private interests. Satisfying an ownership or board ceiling does not resolve this separate condition. | S004 §1.501(c)(3)-1(d)(1)(ii)–(iii); S001 §501(q)(1) introductory requirement. ecfr.gov+2 |
| R034-P1-C012 | The §501(c)(3) statutory baseline also restricts substantial legislative influence, subject to §501(h), and prohibits campaign participation/intervention for or against candidates. Section 501(q) supplies no exception to those conditions. The §501(h) election machinery was not investigated. | S001 §501(c)(3); S004 §1.501(c)(3)-1(b)(3), (c)(3). uscode.house.gov+2 |
| R034-P1-C013 | The civic-organization route under §501(c)(4) requires nonprofit organization/operation and promotion of social welfare. The regulation describes primary engagement in community common good and welfare, and does not treat a business conducted primarily in the manner of a for-profit business as sufficient social-welfare operation. | S001 §501(c)(4)(A); S004 §1.501(c)(4)-1(a)(1)–(2). uscode.house.gov+1 |
| R034-P1-C014 | Section 501(c)(4)(A) separately names local employee associations: membership must be limited to employees of a designated person or persons in a particular municipality, and net earnings must be devoted exclusively to charitable, educational, or recreational purposes. This is not a §501(q) rule requiring credit-counseling consumers to be members. | S001 §501(c)(4)(A); S004 §1.501(c)(4)-1(b). uscode.house.gov+1 |
| R034-P1-C015 | Section 501(c)(4)(B) independently bars net-earnings inurement to private shareholders or individuals. Absence of the §501(c)(3)-specific revenue ceiling does not remove this safeguard. | S001 §501(c)(4)(B), (q)(2). uscode.house.gov+1 |
| Claim ID | Verified claim, with conditions and limits | Exact authority/source |
|---|---|---|
| R034-P1-C016 | Services must be tailored to consumers’ specific needs and circumstances. Section 501(q) does not prescribe a nationally uniform interview script, assessment score, counseling duration, or DMP enrollment result. | S001 §501(q)(1)(A)(i); complete subsection. uscode.house.gov+1 |
| R034-P1-C017 | Making loans to debtors is prohibited except loans with neither fees nor interest. That exception satisfies only this particular condition; it does not establish compliance with all exemption or other lending rules. | S001 §501(q)(1)(A)(ii). uscode.house.gov |
| R034-P1-C018 | Negotiating the making of loans on debtors’ behalf is separately prohibited; the text does not repeat the own-loan exception for this prohibition. JCT footnote 432 distinguishes negotiating loan terms from processing a loan and says assistance obtaining a loan is not necessarily negotiation. This is a bounded explanatory distinction, not permission for an undefined origination business. | S001 §501(q)(1)(A)(ii); S009 p.317 [6], fn.432. uscode.house.gov+1 |
| R034-P1-C019 | Services intended to improve a consumer’s credit record, history, or rating are permitted only insofar as incidental to credit counseling. JCT describes a direct outgrowth of counseling; a separate primary credit-repair purpose is not authorized by this clause. | S001 §501(q)(1)(A)(iii); S009 p.317 [6], fn.433. uscode.house.gov+1 |
| R034-P1-C020 | A separately stated fee for services intended to improve a consumer’s credit record, history, or rating is prohibited. This is a prohibition, not a percentage ceiling or a reasonable-price allowance. | S001 §501(q)(1)(A)(iv). uscode.house.gov |
| R034-P1-C021 | Credit-counseling services may not be refused because the consumer cannot pay, is ineligible for DMP enrollment, or is unwilling to enroll. The provision does not require enrollment of an ineligible consumer in a DMP. | S001 §501(q)(1)(B). uscode.house.gov |
| R034-P1-C022 | An established and implemented fee policy must require reasonable consumer service fees. No national dollar amount appears. JCT footnote 434 treats consistency with state fee requirements as evidence of reasonableness, not a conclusive determination. | S001 §501(q)(1)(C)(i); S009 p.317 [6], fn.434. uscode.house.gov+1 |
| R034-P1-C023 | The fee policy must allow fee waiver when the consumer cannot pay; the IRS explanation says to provide waivers in that situation. Read with C021, this is a substantive accessibility condition. The reviewed provisions supply no universal income percentage, poverty multiplier, documentary checklist, or conclusive presumption for inability to pay. | S001 §501(q)(1)(B), (C)(ii); S005 general criteria. uscode.house.gov+1 |
| R034-P1-C024 | Except to the extent state law allows, the fee policy must prohibit fees based wholly or partly on a percentage of consumer debt, payments to be made under a DMP, or projected or actual DMP savings. The state-law exception modifies this percentage-fee restriction; it does not erase reasonableness or inability-to-pay requirements. No state predicate was investigated. | S001 §501(q)(1)(C)(i)–(iii). uscode.house.gov |
| Claim ID | Verified claim, with measurement and exceptions | Exact authority/source |
|---|---|---|
| R034-P1-C025 | At all times, the governing body must be controlled by persons representing broad public interests. Examples are public officials acting in that capacity, persons with credit/financial-education expertise, and community leaders. The numerical tests below are additional requirements. | S001 §501(q)(1)(D), (D)(i). uscode.house.gov |
| R034-P1-C026 | 20% ceiling, at all times: numerator = aggregate governing-body voting power vested in persons employed by the organization or financially benefiting directly/indirectly from its activities; denominator = total governing-body voting power. Exclude benefits consisting of reasonable directors’ fees or repayment of consumer debt to creditors other than the counseling organization or its affiliates. An independently applicable employment or other financial-benefit predicate is not erased. This is not a per-director allowance or annual average. | S001 §501(q)(1)(D)(ii). uscode.house.gov |
| R034-P1-C027 | 49% ceiling, at all times: numerator = aggregate governing-body voting power vested in employed or directly/indirectly financially benefiting persons; denominator = total governing-body voting power. Here the stated exception is reasonable directors’ fees only. The third-party creditor-repayment exception appearing in the 20% clause is absent. | S001 §501(q)(1)(D)(iii). uscode.house.gov |
| R034-P1-C028 | The 20% and 49% tests must both be satisfied, together with public control. They use voting power, not necessarily seat count. Their numerators can overlap; adding the ceilings or treating them as separate allotments is unsupported. A person satisfying multiple predicates is not counted twice within the same voting-power numerator. | Construction of S001 §501(q)(1)(D)(i)–(iii); compare S005 board shorthand. uscode.house.gov+1 |
| R034-P1-C029 | Corporate ownership ceiling: the counseling organization may not own more than 35% of a covered corporation’s total combined voting power. Numerator = its owned corporate voting power; denominator = that corporation’s total combined voting power. The text excepts a corporation both described in §501(c)(3) and exempt under §501(a). It specifies no annual averaging period or related-owner aggregation formula. | S001 §501(q)(1)(E)(i). uscode.house.gov |
| R034-P1-C030 | Partnership ownership ceiling: the measure is ownership of more than 35% of a covered partnership’s profits interest, not capital or gross receipts. The text expressly excepts a partnership both described in §501(c)(3) and exempt under §501(a). Whether any actual arrangement could satisfy that exception is not determined. No annual averaging or attribution formula is supplied in this clause. | S001 §501(q)(1)(E)(ii). uscode.house.gov |
| R034-P1-C031 | Trust/estate ownership ceiling: the measure is ownership of more than 35% of the covered trust’s or estate’s beneficial interest. The parenthetical exception expressly names a qualifying, exempt trust; it does not name an estate. No annual averaging or related-owner attribution rule is stated here. | S001 §501(q)(1)(E)(iii). uscode.house.gov |
| R034-P1-C032 | The ownership ceilings concern businesses lending money, repairing credit, providing DMP services, payment processing, or similar services. They regulate ownership by the counseling organization, not a general 35% ceiling on each director’s personal holdings. IRS examples include DMP processing, debt negotiation/settlement, and short-term loan initiation. | S001 §501(q)(1)(E)(i)–(iii); S005 taxable-subsidiaries answer. uscode.house.gov+1 |
| R034-P1-C033 | The organization may receive no amount for referring others for DMP services. The receipt prohibition is expressly tied to DMP-service referrals. | S001 §501(q)(1)(F), first limb. uscode.house.gov |
| R034-P1-C034 | The organization may pay no amount to obtain consumer referrals. The payment limb is not textually limited to referrals that ultimately produce a DMP. Neither limb establishes a small permissible referral-fee allowance. | S001 §501(q)(1)(F), second limb. uscode.house.gov |
| R034-P1-C035 | The IRS customer-list explanation says an organization cannot purchase customer leads from third-party vendors or sell customer names to other providers. This supports scrutiny of substance rather than renaming a referral payment as a lead purchase. It is not a complete advertising or privacy-law analysis. | S005 customer-list answer. Internal Revenue Service |
| R034-P1-C036 | JCT footnote 436 says a fee for using or maintaining a consumer locator service is not considered a referral. That narrow explanation does not establish that every directory charge, lead list, advertising arrangement, or enrollment-contingent payment qualifies. | S009 p.318 [7], fn.436. Pensions Technical Explanation 7-28.doc |
| Claim ID | Verified claim, with measurement and exceptions | Exact authority/source |
|---|---|---|
| R034-P1-C037 | For a covered §501(c)(3) organization, contributions may not be solicited from consumers during initial counseling or while they receive organizational services. This is a solicitation prohibition with specified consumer/time predicates, not a ceiling on donations. Section 501(q)(2) does not impose this additional condition on §501(c)(4). | S001 §501(q)(2)(A)(i); S005 contribution answer. uscode.house.gov+1 |
| R034-P1-C038 | IRS distinguishes permitted reasonable service fees from prohibited solicitation of voluntary contributions during those periods, and identifies grants and contributions from noncustomers as funding possibilities. Calling a compulsory service charge a donation does not settle its legal character. The statutory clause prohibits solicitation; it does not expressly resolve every unsolicited-receipt situation. | S001 §501(q)(1)(C), (2)(A)(i); S005 contribution answer. The characterization and unsolicited-receipt limits are textual conclusions, not blanket permissions. uscode.house.gov+2 |
| R034-P1-C039 | For a covered §501(c)(3) organization, aggregate organization revenues from payments by its consumers’ creditors and attributable to DMP services may not exceed 50% of the organization’s total revenues, subject to the historical transition in C043. Numerator combines all qualifying creditor payments, not a separate allowance per creditor; denominator is total organization revenues. The taxable-year context is explained in C041. | S001 §501(q)(2)(A)(ii), (B)(i); S005 revenue answer. uscode.house.gov+1 |
| R034-P1-C040 | Consumer setup and monthly fees are not payments from consumers’ creditors, so they do not belong in the restricted creditor-payment numerator. The FAQ’s abbreviated exclusion does not justify removing properly recognized consumer-fee revenue from the statutory total-revenue denominator. Whether a particular amount is organization revenue remains a separate accounting question. | S001 §501(q)(2)(A)(ii); S005 revenue answer. Denominator conclusion is a reading of the statutory distinction. uscode.house.gov+1 |
| R034-P1-C041 | The transition and effective-date provisions use taxable years, and the dated IRS FAQ applies the percentages by calendar/fiscal accounting year. The core sentence in (2)(A)(ii) does not separately define an accounting period, accounting method, or averaging convention. No rolling, lifetime, per-plan, or service-count averaging rule is supplied. Use the same relevant taxable-year context for numerator and denominator; do not invent a different measurement window. | S001 §501(q)(2)(B)(ii); S002 §1220(c); S005 PDF Q3 and Q10, pp.2–3 [1–2]. uscode.house.gov+3 |
| R034-P1-C042 | Section 501(q) does not define total revenues through a gross-receipts, support, participant-debt, assessed-charge, or custodial-payment formula. It does not state how to classify every debt payment held for another or allocate mixed payments. Such amounts must not be inserted merely because they pass through an account. Their precise tax-accounting treatment remains unresolved here. | S001 complete §501(q), especially (2)(A)(ii), (4); S005 revenue answer. uscode.house.gov+2 |
| R034-P1-C043 | The graduated percentage applies only where credit counseling was a substantial purpose and the organization was both described in §501(c)(3) and exempt under §501(a) on August 17, 2006. The ceiling is 80% for the first taxable year beginning after August 17, 2007; 70% for the second such taxable year; 60% for the third; then the general 50% rule. The revenue numerator/denominator remain those in C039; this is not a new-organization phase-in today. | S001 §501(q)(2)(B)(i)–(ii), reference note; S002 §1220(a). uscode.house.gov+2 |
| R034-P1-C044 | A covered §501(c)(4) organization must notify the Secretary, in the manner regulations may prescribe, that it is applying for recognition as a credit-counseling organization. The §501(c)(3)-specific solicitation and creditor-revenue conditions are not transplanted into (q)(3). Exact present notification mechanics were not resolved in this pass. | S001 §501(q)(3), compared with (q)(2). uscode.house.gov |
| R034-P1-C045 | The subsection uses organization ownership, direct/indirect financial benefit, and the organization’s affiliates in specific clauses. It does not define a general related-organization group, constructive-ownership rule, or combined-revenue denominator. That textual absence is not authority to disregard indirect benefits, private benefit, agency, or another applicable attribution rule. | S001 §501(q)(1)(D)–(E), (2), (4); S004 private-interest rules. uscode.house.gov+2 |
| R034-P1-C046 | Section 513(j) includes DMP services within unrelated trade or business when provided by an organization other than one meeting §501(q). Separately, §501(q)’s exemption conditions can prevent exemption when its substantial-purpose framework applies. The IRS incidental-school example therefore does not mean every noncompliant credit-counseling organization simply pays tax on DMP income while retaining exemption. | S003 §513(j); S001 §501(b), (q)(1)–(3); S005 taxable-income answer. uscode.house.gov+4 |
| R034-P1-C047 | Satisfying the creditor-revenue percentage is not an exemption safe harbor or an automatic finding that DMP income is related income. The general regulation asks whether the income-producing activity contributes importantly to exempt purposes and whether it exceeds the scale reasonably necessary for those purposes. JCT applies that distinction to DMP services. | S004 §1.513-1(d)(1)–(3); S009 pp.319–320 [8–9]. ecfr.gov+1 |
| Claim ID | Verified claim, with conditions and limits | Exact authority/source |
|---|---|---|
| R034-P1-C048 | The 2006 CCA contrasts an educational counseling process—individual financial understanding, alternatives, appropriate recommendations, training, and follow-up—with a process primarily designed to qualify consumers for and sell DMPs. Its conclusion depends on the combined facts, with inurement/private benefit separately relevant. It is not a mandatory national checklist or a current exemption determination. | S008 pp.1–5, 8–10 [0–4, 7–9]; express nonprecedential statement p.1 [0]. irs.gov+2 |
| R034-P1-C049 | Rev. Rul. 69-441 finds §501(c)(3) qualification on stated facts combining public education, assistance to low-income people, free counseling/budget-plan services, representative governance, and creditor contributions. Its trust-account, creditor-consent, and full-credit facts describe that example; they do not create a universal §501(q) distribution deadline or contract entitlement. | S007 entire ruling, PDF [0–1]; current additional conditions in S001. RR69-441.C3+3 |
| R034-P1-C050 | Rev. Rul. 65-299’s generic §501(c)(4) example includes individualized financial analysis, creditor-consented arrangements, free counseling, a nominal processing charge, and community support. Eligibility was not confined to charitable recipients. This is a fact-dependent historical example, not a universal processing-fee cap or proof that every DMP operation promotes social welfare. | S006 entire ruling, PDF [0–1]. RR65-299.C4+1 |
| R034-P1-C051 | Section 501(q)’s express legal consequence concerns exemption. Its text contains no express consumer cause of action, damages formula, automatic contract rescission, or fee-refund remedy. Whether a consumer can enforce a condition through another legal route remains unresolved and parent-held. | Textual limit of S001 complete §501(q). This is not a comprehensive no-remedy opinion. uscode.house.gov+1 |
| R034-P1-C052 | Defining negotiation of creditor concessions as DMP services does not compel a creditor to accept a plan, lower interest, waive fees, release principal, or admit that a disputed debt is valid. Those outcomes are not determined by organizational tax qualification. | S001 §501(q)(4)(B), read in the exemption framework of (q)(1)–(3). uscode.house.gov+1 |
| R034-P1-C053 | The subsection supplies no nationally universal dollar DMP fee cap, creditor-distribution deadline, DMP approval guarantee, completion guarantee, or general cancellation/refund rule. The specific fee protections it does contain remain enforceable tax-qualification conditions; the absence of these additional terms does not erase those conditions. | S001 complete §501(q), particularly (1)(B)–(C), (4)(B). uscode.house.gov+1 |
| R034-P1-C054 | Federal tax qualification/recognition, a client contract, creditor assent, state authorization, and bankruptcy-counseling approval answer different questions. Section 501(q) does not confer those separate approvals or settle contract terms. JCT expressly states that the provision was not intended to affect the bankruptcy approval process. No separate approval system was investigated. | S001 §501(q); S010 recognition explanation; S009 pp.316–317 [5–6]. uscode.house.gov+2 |
| R034-P1-C055 | IRS FAQ summaries require statutory qualification: the board answer does not present the separate 20% test; the dated PDF loan bullet omits the statutory exception; consumer-fee shorthand does not define total revenues; the taxable-income answer does not resolve organizational exemption. | Comparison of S005 with S001 and S003; underlying rules C017, C026–C028, C040, C046. irs.gov+5 |
| R034-P1-C056 | The 1965/1969 rulings and May 2006 CCA predate §501(q). Their statements concerning creditor-supported operations cannot override the later §501(c)(3) creditor-revenue ceiling. A current official hosting location does not convert a historical example into a complete present-law permission. | S006–S008 dates; S002 enactment; S001 §501(q)(2). RR69-441.C3+4 |
| R034-P1-C057 | The general §501(c)(3) regulation contains a distinct historical organizational-test clause for certain determinations before July 27, 1959, and rules for a later requested determination. Its current procedural paragraphs have the July 1, 2014 applicability specified in (h). These provisions do not supply an exemption from §501(q). | S004 §1.501(c)(3)-1(b)(6), (g)–(h); S012 final amendment. ecfr.gov+2 |
| R034-P1-C058 | Failure to satisfy a §501(c)(3) condition does not itself establish §501(c)(4) status. The latter has its own requirements; its regulation also expressly distinguishes certain action organizations according to prior §501(c)(3) exemption after October 4, 1976 and refers to §504. No conversion or §504 analysis was performed. | S004 §1.501(c)(4)-1(a)(2)(ii); S001 §501(q)(3). ecfr.gov+1 |
| R034-P1-C059 | Section 501(q) contains no general public-support percentage, per-donor contribution cap, or gross-receipts support test. Its revenue restriction is the specific creditor-payment fraction in C039. Separate public-charity/private-foundation classification rules were not substituted for it or investigated. | S001 complete §501(q), especially (2) and (4). uscode.house.gov+1 |
| R034-P1-C060 | Currentness remains bounded: newer §513-body retrieval failed; the October 20 classification table contains no §§501/513 entry in its Title 26 block, but only classified provisions are covered. No conclusion about unreviewed later laws or judicial history follows from that result. | S003; S011 table scope, date, and Title 26 block; failure log below. uscode.house.gov+3 |
| Question | Covered §501(c)(3) organization | Covered §501(c)(4) organization | What must not be inferred |
|---|---|---|---|
| Underlying exempt purpose | Must satisfy §501(c)(3), including organizational/operational and private-interest restrictions. | Must satisfy the applicable §501(c)(4) route and its safeguards. | A nonprofit charter or counseling label establishes neither category. C008–C015. |
| Shared §501(q) conditions | All §501(q)(1)(A)–(F) requirements apply. | Same shared requirements apply. | Category choice does not remove tailoring, fee, governance, ownership, or referral conditions. C016–C036. |
| Consumer contribution solicitation | Additional prohibition during initial counseling and ongoing services. | This particular additional §501(q)(2) condition is not imposed by (q)(3). | Its absence for (c)(4) is not blanket approval under all law or all exemption conditions. C037–C038, C015. |
| Creditor-funded DMP revenue | Aggregate qualifying creditor revenue limited to the applicable fraction of total revenue. | Section 501(q) does not impose that (c)(3)-specific fraction. | Failure of the fraction does not automatically produce valid (c)(4) status. C039–C043, C058. |
| Recognition-related condition | General recognition requirements remain separate from substantive qualification. | Section 501(q)(3) expressly adds notification that it is applying for credit-counseling recognition. | A label, notice, or application is not itself proof of satisfaction of every condition. C004, C008, C044. |
| DMP-related income | The revenue ceiling does not establish related-business treatment. | Shared qualification likewise does not automatically resolve related-business treatment. | Taxing an activity and denying organizational exemption are not interchangeable conclusions. C046–C047. |
| Consumer agreement and other approvals | Not established by tax category. | Not established by tax category. | No tax-label inference about creditor assent, contractual performance, licensing, or bankruptcy approval. C051–C054. |
The historical IRS CCA supports examining how counseling develops the consumer’s understanding and recommendations. An educational process considers the individual’s circumstances and alternatives, uses appropriately trained counselors, and connects any DMP recommendation to the counseling function. A process that principally gathers enough information to qualify a consumer for a predetermined DMP may present a different exempt-purpose issue. These are combined-fact examples in nonprecedential, pre-enactment advice—not automatic outcomes from a single feature. C048; S008, pp.3–5 and 8–10.
That distinction does not require concluding that a substantial amount of DMP activity is always disqualifying. Nor does it make creditor criteria alone sufficient. The current statutory tailoring requirement and the separate related-business standard remain the relevant governing anchors. C016, C047–C048.
These are rule expressions, not worked financial illustrations. No actual or invented financial amounts, participant balances, board rosters, or ownership records have been supplied.
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20% test percentage
= 100 × counted voting power under §501(q)(1)(D)(ii)
÷ total governing-body voting power
Required result: <= 20%
Measurement time: at all times
Units: voting-power units divided by voting-power units
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49% test percentage
= 100 × counted voting power under §501(q)(1)(D)(iii)
÷ total governing-body voting power
Required result: <= 49%
Measurement time: at all times
Units: voting-power units divided by voting-power units
The exception sets differ as detailed in C026–C027. The tests overlap and cannot be added. Public control under C025 remains a separate requirement. No rule authorizing rounding an excessive result down into compliance was identified. Where voting rights, denominator, or counting predicates are unknown, the result remains unknown.
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Corporate percentage
= 100 × organization-owned voting power
÷ corporation's total combined voting power
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Partnership percentage
= 100 × organization-owned profits interest
÷ total partnership profits interest
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Trust or estate percentage
= 100 × organization-owned beneficial interest
÷ total beneficial interest
For each covered entity, the statutory ceiling is <= 35%, subject to its exact exception in C029–C031. The statute does not prescribe an annual average. It does not specify a general constructive-ownership or related-owner aggregation formula. Those gaps must not be filled by importing a similarly numbered threshold from another tax provision.
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Restricted creditor DMP revenues
= sum of organization revenues from its consumers' creditors
that are attributable to DMP services
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Restricted creditor DMP revenues
<= applicable percentage ÷ 100 × total organization revenues
Units: the same currency units of organization revenue on both sides. Period: the same relevant taxable-year context, with the limits in C041. Default percentage: 50%. Historical percentages: only the predicate-specific 80%, 70%, and 60% sequence in C043.
The numerator is not all DMP revenue, participant indebtedness, or all incoming cash. Consumer service fees do not enter the restricted creditor-payment numerator merely because they relate to DMPs. Custodial debt payments and mixed receipts require their own revenue-classification authority; no classification is assumed here. C039–C043.
No division should be performed on an unresolved or zero denominator as though it produced a verified percentage. The original statutory inequality can be preserved while the legal accounting inputs remain unresolved.
No numerical illustration is justified in this pass: a calculation would add assumed accounting, voting, ownership, or historical-status facts that the investigation does not establish.
Status key: “Answered” means the generic public-law proposition is established within the cited bounds. “Partial” means the governing rule is identified but a legal construction or predicate remains unresolved. “Excluded application” means actual application is parent-held, not that noncompliance is suspected.
| Branch / status | Verified rule and qualitative branch | Missing evidence or authority | Adverse inference to avoid | Exact next permissible public-law inquiry |
|---|---|---|---|---|
| B01 — Substantial purpose unknown. Partial; application excluded. | Financial education alone can trigger the framework if substantial; incidental counseling may not. C004–C006; S001 §501(q)(1), (4)(A). | Relative organizational purposes and operations; any controlling published interpretation giving content to substantial purpose. | “No DMP means no §501(q),” or “any financial lesson necessarily triggers it.” | Search only Treasury/IRS published generic guidance addressing the substantial-purpose trigger in §501(q)(1); retain the absence of a verified numerical threshold. |
| B02 — Nonprofit form versus exemption. Answered; application excluded. | A nonprofit form is insufficient to establish federal exemption. C008; S010 nonprofit-status answer. | Actual legal form and tax qualification remain held. | The word nonprofit proves recognized exemption or service quality. | If further explanation is needed, examine only generic IRS guidance separating state organizational form, substantive exemption, and recognition. |
| B03 — §501(c) category unknown. Partial; application excluded. | Shared conditions apply to either covered category, but (q)(2) and (q)(3) differ. C009–C015, C037–C044; S001 §501(q)(2)–(3). | Category and underlying exempt-purpose predicates; current notice mechanics. | Apply the (c)(3) revenue ceiling automatically to every nonprofit, or presume an automatic switch to (c)(4). | Examine published generic guidance on §501(q)(3)’s notification requirement and its relationship to general (c)(4) procedures; no application or status lookup. |
| B04 — Educational/counseling purpose versus another purpose. Partial. | Tailoring and underlying exempt-purpose requirements matter; a DMP sales process is not made educational by its label. C009, C016, C048; S008 generic methodology discussion. | Purpose and methodology facts; authoritative treatment of an unresolved methodology issue beyond the dated CCA. | A brochure conclusively proves education, or a single sales-oriented feature conclusively disproves exemption. | Seek current published IRS interpretations of §501(q)(1)(A)(i) and general educational purpose; do not turn the CCA’s examples into mandatory national procedures. |
| B05 — Public service/accessibility unknown. Partial. | Public education is expressly included; inability to pay or DMP unwillingness/ineligibility cannot be the reason to refuse counseling. C005, C021; S001 §501(q)(1)(B), (4)(A). | Service-access predicates, reasons for any hypothetical refusal, and category-specific public-purpose analysis. | Everyone must be admitted to every DMP, or services must always be restricted to poor consumers. | Examine generic IRS explanations of the scope of counseling access under (q)(1)(B), without importing another approval system’s eligibility rules. |
| B06 — Inability-to-pay/waiver predicate. Partial. | Fee policy must allow waiver for inability to pay, and counseling cannot be refused on that basis. C021–C023; S001 §501(q)(1)(B)–(C). | A verified inability-to-pay standard and the predicate’s application; neither is supplied here. | A request automatically satisfies every waiver predicate, or absence of a stated poverty threshold permits refusal. | Search published IRS/Treasury guidance specifically defining inability to pay for §501(q); do not borrow bankruptcy fee-waiver thresholds. |
| B07 — Voluntary contribution versus compulsory charge. Partial. | For covered (c)(3) organizations, prohibited solicitation can concern voluntary contributions; genuine fees remain subject to fee protections. C037–C038; S005 contributions answer. | Nature of payment, solicitation, service relationship, and timing; treatment of unsolicited receipts. | A donation label avoids fee rules, or every unsolicited payment is expressly prohibited by the solicitation clause. | Seek published generic interpretation of solicit contributions in (q)(2)(A)(i), including unsolicited receipts and mislabeled service charges. |
| B08 — Counseling/DMP services versus loan making or origination. Partial. | Own loans have the narrow no-fee/no-interest exception; negotiating new loans is separately prohibited. Processing is not necessarily negotiation. C007, C017–C018; S001 §501(q)(1)(A)(ii); S009 fn.432. | Legal character of an activity, especially processing versus negotiating terms. | The word consolidation permits a fee-bearing new loan, or every administrative assistance task is prohibited negotiation. | Look for an official published interpretation applying (q)(1)(A)(ii) to generic processing/origination functions. |
| B09 — Incidental credit repair versus separate service. Partial. | Incidental credit-improvement services and no separately stated fee are distinct conditions. C019–C020; S001 §501(q)(1)(A)(iii)–(iv). | Whether the activity is incidental and whether a charge is separately stated. | Any credit-score improvement makes counseling unlawful, or embedding a fee conclusively establishes a permissible primary credit-repair business. | Seek published IRS interpretation of incidental and separately stated fee in these specific clauses. |
| B10 — Referral/lead payment versus locator service. Partial. | Referral payments/receipts face the statutory prohibitions; IRS includes paid leads; JCT describes a narrow locator-service distinction. C033–C036; S005 customer-list answer; S009 fn.436. | Nature of the service and consideration; later authoritative treatment of the locator distinction. | Any advertising fee is necessarily a referral fee, or any “directory” label makes a paid lead permissible. | Search published IRS/Treasury guidance on §501(q)(1)(F) distinguishing advertising, locator services, and consumer referrals. |
| B11 — Governance independence and related interests. Partial. | Public control, 20% voting, and 49% voting tests operate together with different exclusions. C025–C028; S001 §501(q)(1)(D). | Voting rights, employment/benefit predicates, public-interest representation, affiliate meaning. | Headcount proves voting compliance; creditor-related interests are excluded from both tests; or both ceilings can be added. | Seek published generic interpretation of control, voting power, indirect benefit, and affiliates in (q)(1)(D). No officer/director searches. |
| B12 — Numeric base or period unknown. Partial. | Ownership, voting, and revenue tests measure different things; the revenue fraction does not measure participant debt or service volume. C026–C031, C039–C043; S001 §501(q)(1)(D)–(E), (2). | Correct unit, legal accounting base, relevant period, and any applicable exclusion. | Substitute cash receipts, support, debt principal, capital ownership, or number of clients. | Seek q-specific published accounting guidance on total revenues and creditor-attributable DMP revenues before any calculation. |
| B13 — Related-organization aggregation. Partial. | The body contains no general combined-revenue or constructive-ownership formula, but expressly addresses indirect benefits and affiliates in particular places. C045; S001 §501(q). | The precise statute/regulation making attribution, consolidation, agency, or another related-party rule applicable to the question. | “No express aggregation clause” proves subsidiaries can be ignored, or all related entities must automatically be consolidated. | Identify an expressly applicable public tax authority for the proposed attribution or aggregation; do not borrow a different provision’s 35% test. |
| B14 — Exception or transition unknown. Partial. | Loan, fee, board, ownership, and historical transitions each have distinct predicates. C003, C017, C024, C026–C031, C043; S001; S002 §1220. | Predicate-specific authority/facts, including historical category/exemption status where relevant. | A general nonprofit label establishes an exception, or the historical phase-in restarts for a new organization. | Reconcile the exact exception’s wording and effective clause in official text; actual historical qualification remains held. |
| B15 — Recognition versus client contract. Answered boundary; application excluded. | Recognition concerns tax status; §501(q) does not supply a complete client agreement or decide its performance. C008, C044, C051–C054; S010. | Recognition and contract facts are expressly held. | A recognition label guarantees the contract, or a service dispute alone proves tax revocation. | Within this pass, only generic IRS explanations of recognition’s legal scope are permissible; contract and actual recognition work remain parent-held. |
| B16 — Tax qualification versus state/bankruptcy authorization. Answered boundary; separate systems excluded. | Section 501(q) does not confer either separate authorization. C054; S001; S009 pp.316–317. | Jurisdiction and separate approval predicates, all held. | Tax exemption equals licensing, registration, or bankruptcy approval. | No separate-system investigation in this pass; any future inquiry must begin with the appropriate generic public law after that parent dimension is released. |
| B17 — Creditor concessions and debt validity unknown. Answered boundary; application excluded. | The DMP definition includes negotiating concessions; it does not compel concessions or validate debt. C007, C052; S001 §501(q)(4)(B). | Creditor assent, debt validity, and contract facts remain held. | A qualifying organization can bind a creditor or establish an underlying balance. | No additional §501(q) inquiry can supply those facts. Separate generic contract/debt-validity law belongs to the held parent work. |
| B18 — Noncompliance versus consumer remedy. Partial; remedies excluded. | The statute states exemption conditions and contains no express consumer damages/refund mechanism. C051–C053; S001 §501(q). | Independent cause of action, contract, remedy, and procedural authority; all held. | Tax noncompliance automatically creates a refund, or the absence of an express remedy proves no remedy exists anywhere. | Within scope, preserve the textual finding only. A later authorized inquiry would require specific public remedy authority; no docket or actual case-record search. |
| B19 — DMP marketing/processing without a completed plan. Partial. | Marketing and processing are expressly within the DMP-service definition; completed enrollment is not the definition’s sole trigger. C007; S001 §501(q)(4)(B). | Activity characterization and its relationship to credit counseling as a substantial purpose. | No completed DMP necessarily means no DMP services, or DMP services alone conclusively establish every §501(q) predicate. | Seek published generic interpretation of the relationship between (q)(4)(B)’s service definition and (q)(1)’s purpose trigger. |
| B20 — Tax on activity versus retention of exemption. Partial. | Section 513(j), general relatedness rules, and §501(q)’s organizational conditions answer distinct questions. C046–C047; S003 §513(j); S004 §1.513-1(d). | Current §513-body retrieval gap and the hypothetical legal category/activity predicates; tax computations held. | Paying unrelated-business tax necessarily cures a substantial exempt-purpose failure. | Retrieve the newer official §513 body and any published generic IRS explanation reconciling §513(j) with §501(q)(1)–(3). |
This is an optional analytical worksheet, not an IRS form, application, examination request, or consumer eligibility determination. It contains no identity fields. Actual findings remain blank.
| Audit item | Governing claim(s) | Finding / evidence reference — blank |
|---|---|---|
| Applicable published statutory version and access date | C001–C003, C060 | __________ |
| Substantial-purpose trigger | C004–C006 | __________ |
| Which part of the credit-counseling definition is implicated | C005 | __________ |
| Whether the activity falls within the DMP-service definition | C007 | __________ |
| Nonprofit form distinguished from federal exemption | C008 | __________ |
| §501(c) category assumption | C009–C015, C044 | __________ |
| Organizational and operational exempt-purpose requirements | C009, C013 | __________ |
| Public-interest and private-benefit analysis | C010–C011, C015 | __________ |
| Tailoring of counseling to consumer circumstances | C016 | __________ |
| Loan making; exact exception if relevant | C017 | __________ |
| Loan negotiation versus processing | C018 | __________ |
| Incidental credit-improvement activity | C019 | __________ |
| Separately stated credit-improvement fee | C020 | __________ |
| Counseling access despite inability to pay or DMP nonparticipation | C021 | __________ |
| Reasonable-fee policy | C022 | __________ |
| Inability-to-pay waiver predicate and policy | C023 | __________ |
| Percentage-based fee and state-law exception predicate | C024 | __________ |
| Public control of governing body | C025 | __________ |
| 20% voting-power numerator, denominator, and exclusions | C026, C028 | __________ |
| 49% voting-power numerator, denominator, and exclusions | C027–C028 | __________ |
| Ownership type, correct measurement base, covered activity, exception | C029–C032 | __________ |
| Referral receipts, referral payments, and lead/locator distinction | C033–C036 | __________ |
| Consumer contribution solicitation and relevant service period | C037–C038 | __________ |
| Restricted creditor DMP revenue classification | C039–C040 | __________ |
| Total-revenue denominator and same-period accounting | C041–C042 | __________ |
| Historical percentage-transition predicate | C043 | __________ |
| §501(c)(4) notification rule and unresolved mechanics | C044 | __________ |
| Specific authority for any attribution or aggregation | C045 | __________ |
| Related-business treatment distinguished from exemption | C046–C047 | __________ |
| Historical explanation not substituted for current statute | C048–C050, C055–C058 | __________ |
| Contract, creditor assent, separate approval, and remedies held apart | C051–C054 | __________ |
| Public-support ratios not substituted for §501(q) revenues | C059 | __________ |
| Remaining public-law question and permitted source route | Relevant branch B01–B20 | __________ |
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Governing-body voting-power unit: __________
Total voting power: __________
Counted power for 20% test: __________
Applicable exclusions and authority: __________
Counted power for 49% test: __________
Applicable exclusions and authority: __________
Public-control conclusion: __________
Plain text
Ownership-interest type: __________
Correct denominator: __________
Covered business predicate: __________
Statutory exception predicate: __________
Attribution/aggregation authority, if any: __________
Plain text
Relevant taxable-year context: __________
Revenue accounting authority/convention: __________
Restricted creditor DMP revenues: __________
Total organization revenues: __________
Custodial or mixed amounts requiring separate classification: __________
Applicable percentage and transition authority: __________
Result, only if all required inputs are established: __________
The branch table in §6 supplies separate coverage status, missing evidence, adverse inference, and next inquiry for every substantive branch. The table below maps each numbered question and its material subparts to the findings.
| User question / material subpart | Coverage status and reason | Claim / branch / source links | Missing evidence or exact next investigation |
|---|---|---|---|
| 1 — Complete current §501(q), nested clauses and exceptions | Answered at the displayed October 20 cutoff. All of (q)(1)–(4) read. | C001, C004–C007, C016–C045; S001–S002. | No missing clause in the retrieved subsection. Later unclassified/session-law audit not completed. |
| 1 — Necessary §501(c)(3)/(4) baseline | Answered within focused scope. Both categories’ relevant text and general regulations read. | C008–C015, C057–C058; S001, S004. | Full exemption procedures, political-activity elections, and §504 consequences remain outside scope. |
| 1 — Substantial-purpose trigger | Partial for construction/application; generic rule answered. | C004–C006; B01; S001, S005. | No verified universal quantitative threshold; next inquiry is q-specific published generic interpretation. |
| 1 — Nonprofit form versus exemption | Answered. | C008; B02; S010, S004. | Actual form/status held; no provider search permitted. |
| 1 — Organization treatment versus consumer entitlement | Answered as a textual boundary; remedies excluded. | C051–C054; B15–B18; S001. | No complete private-enforcement/remedies analysis. |
| 1 — Source, amendments, effectiveness, transitions | Answered for enacted §1220 and relevant notes; broader history partial. | C001–C003, C043, C057, C060; S001–S003, S011–S012. | Newer §513 body remains a retrieval gap; complete later-history audit not asserted. |
| 2 — Educational/counseling/service conditions | Answered generically. | C005, C009, C016–C020, C048–C050; B04, B08–B09; S001, S004, S006–S009. | Actual methodology and purpose facts excluded. |
| 2 — Public accessibility | Answered for stated federal conditions; application excluded. | C005, C021–C023; B05–B06; S001, S005. | No imported national income threshold or universal DMP admission rule. |
| 2 — DMP design/implementation and assessment | Partial by design. Statutory tailoring and generic educational examples covered. | C007, C016, C047–C050; B04, B19; S001, S004, S008–S009. | No actual assessment, participation, distribution, completion, or contract investigation. |
| 2 — Ability to pay, waiver, fees, no refusal | Answered rule; predicate construction partial. | C021–C024; B06; S001, S005, S009 fn.434. | Exact inability-to-pay standard and any state-law allowance unresolved. |
| 2 — Governance, independence, private benefit | Answered text and distinct tests; application excluded. | C010–C011, C015, C025–C032; B11; S001, S004. | Actual voting/benefit facts held; generic affiliate/control construction may require further authority. |
| 2 — Prohibitions versus ceilings | Answered. | C017–C024, C026–C039; measurement section. | No numerical organizational illustration performed. |
| 2 — Contributions versus fees | Answered core distinction; unsolicited-receipt edge partial. | C037–C040; B07; S001, S005. | Further published interpretation needed for disputed characterization. |
| 2 — Origination/referrals/leads/repair/loan distinctions | Answered core clauses; processing/locator edges partial. | C017–C020, C033–C036; B08–B10; S001, S005, S009. | Need specific public guidance for an unresolved generic boundary, not transaction records. |
| 2 — Complete necessary official explanations | Answered within identified read bounds. | S005 PDF complete; S006–S008 complete available text; S009 complete relevant explanation. | No undisclosed portions or underlying case holdings treated as read. |
| 2 — Avoid invented national fee/concession/deadline/refund rights | Answered. | C051–C054; B17–B18. | Separate rights remain held rather than negated. |
| 3 — Complete material definitions | Answered. | C005, C007; S001 §501(q)(4). | Undefined accounting/affiliate terms remain explicitly unresolved. |
| 3 — Additional rules by §501(c) category | Answered. | C037–C044; comparison table; B03. | Current (c)(4) notice mechanics not fully traced. |
| 3 — Contribution/receipt/support ratios | Answered as to what §501(q) actually contains. | C037–C043, C059; S001, S005. | General public-support classification excluded; no substitution permitted. |
| 3 — Numerator, denominator, period, exclusions | Answered statutory bases; accounting details partial. | C026–C031, C039–C043; B12; equations. | Published authority needed for revenue recognition, custodial/mixed amounts, and any averaging claim. |
| 3 — Related organizations/aggregation | Partial. Express textual features identified; general attribution not established. | C045; B13; S001, S004. | Identify the precise applicable attribution/agency/consolidation authority. |
| 3 — Governance membership and exceptions | Answered. Voting power separated from membership shorthand; local employee-association language separately identified. | C014, C025–C031, C055; B11. | No actual membership or voting-rights data collected. |
| 3 — Special exceptions and transitions | Answered text; application excluded. | C003, C017, C024, C026–C031, C043, C057; B14. | Historical status and state-law predicates held. |
| 4 — Necessary official guidance/final regulations and status | Answered within read bounds. | S004–S012; C048–C050, C055–C058. | No q-specific comprehensive implementing regulation identified or claimed absent. |
| 4 — Actual dates/effectiveness/currentness distinctions | Partial only to stated limits. Dates and compilation labels recorded; broad later history not audited. | C001–C003, C043, C056–C057, C060; §1 and source table. | Newer §513 body; historical-ruling/interpretation later history; any material judicial-validity question. |
| 4 — Generic forms/instructions, optional/required role | Not triggered. No IRS blank form or form instructions were examined. | Source/read log; original worksheet §7. | Historical references to forms were not treated as present filing directions; no filing or identifier entry. |
| 4 — Recognition, creditor acceptance, bankruptcy approval, state authorization, contract | Answered separation; separate systems excluded. | C044, C051–C054; B15–B18. | All actual and separate-law predicates remain parent-held. |
| 5 — Provision-specific comparison and blank worksheet | Delivered visibly. | §§4–5 and 7. | Worksheet findings remain blank. |
| 5 — All requested qualitative branches | Delivered visibly and individually. | B01–B20, each with rule, claim/source, gap, adverse inference, next inquiry. | Actual application intentionally excluded. |
| 5 — Fully worked numerical illustration if justified | Omitted with reason. Not necessary; required inputs and legal accounting conventions are not established. | §5; B11–B14. | No invented data or calendar deadline. |
| 5 — Sources, claims, coverage, read/failure log, crosswalk, gaps, self-check | Delivered visibly. | §§2–3, 6, 8–10. | No download substitutes for the answer. |
A failed URL is a retrieval result, not evidence that the law is absent. Repeated attempts at the same path are grouped.
| Failure ID | Exact attempted URL | Observed result | Effect on findings |
|---|---|---|---|
| F001 | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title26-section501&num=0&edition=prelim | Fetch failed: 404 Not Found. | Resolved for substantive §501 reading through the publisher’s current-edition route and S001. |
| F002 | https://uscode.house.gov/us/usc/119-134/t26/s501/ and https://uscode.house.gov/us/usc/119-134/t26/s501 | Initial direct attempts: “not accessible via this tool.” | Later successful retrieval by following “Continue” from https://uscode.house.gov/us/usc/t26/s501/. Complete q reread in that version. |
| F003 | https://uscode.house.gov/view.xhtml?req=title26:section501&num=0&edition=prelim | “not accessible via this tool.” | Route failure retained; substantive content resolved by S001. |
| F004 | https://usc-cdn.house.gov/view.xhtml?req=granuleid:USC-prelim-title26-section501&num=0&edition=prelim | 400; Timeout fetching. | No claim based on this response; S001 supplies the text. |
| F005 | https://uscode.house.gov/us/usc/119-121/t26/s513/ | 404 Not Found. | Readable S003 used with its actual cutoff. |
| F006 | https://uscode.house.gov/view.xhtml?req=title26:section513&num=0&edition=prelim | “not accessible via this tool.” | No newer-body verification from this route. |
| F007 | https://uscode.house.gov/us/usc/119-134/t26/s513/ | Repeated direct attempts: “not accessible via this tool.” | Newer §513 body remains unresolved; classification-table check is separately bounded. |
| F008 | https://uscode.house.gov/us/usc/t26/s513/ | “not accessible via this tool.” | No current-edition redirect content obtained for §513. |
| F009 | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title26-section513&num=0&edition=prelim | Fetch failed: 404 Not Found. | Same unresolved newer-body limitation. |
Generic searches also returned provider-specific or case-specific material incidentally. Those hits were not opened or used as foundations. No inference was drawn from their snippets. Searches for q-specific regulations and accounting explanations did not produce a verified comprehensive answer to the unresolved questions below; that is not a finding that no such authority exists.
| Gap | What remains unresolved | Required permissible public-source inquiry |
|---|---|---|
| G01 — Newer §513 body | The readable statutory body’s October 7 cutoff is older than the October 20 §501 compilation. | Retrieve the newer official §513 text; reconcile any relevant enacted amendments and effective clauses. The classification table alone does not close this gap. |
| G02 — Open-textured predicates | No universal numerical definition was verified for substantial purpose, incidental credit repair, reasonable fees, or inability to pay. | Locate a published Treasury/IRS interpretation specifically applying the relevant §501(q) clause. Do not substitute thresholds from another approval system. |
| G03 — Revenue accounting | Classification of custodial payments, mixed payments, accrual/cash timing, and other specific denominator questions is not supplied by the reviewed q text or short FAQ. | Identify published authority governing revenues for §501(q)(2)(A)(ii) and explain why any general accounting rule applies. |
| G04 — Related-party attribution | No express general aggregation/constructive-ownership formula appears in q. The meaning/application of affiliates and indirect financial benefit is not comprehensively defined there. | Identify the exact statute, regulation, or published IRS interpretation that makes an attribution rule applicable to the particular q measurement. |
| G05 — §501(c)(4) notification mechanics | The statutory obligation is established; a complete current procedural route and interaction with other general (c)(4) notice rules are not. | Review only current generic official instructions or published guidance addressing §501(q)(3) if that limited procedural question is later pursued. No application, identifier, or actual recognition inquiry. |
| G06 — Referral/locator boundary | The statute, IRS lead-list answer, and JCT locator footnote do not resolve every possible advertising arrangement. | Seek published generic IRS/Treasury treatment of the payment’s substance under §501(q)(1)(F). |
| G07 — Historical interpretive status and judicial limits | No complete later-history audit of the old rulings/CCA or independent opinion review was performed. The CCA discusses judicial limits surrounding educational methodology, but those discussions are not independently verified holdings here. | If necessary to decide a specific public-law construction, read the relevant published majority opinion and bounded later-history materials; no case-record or docket inquiry. Otherwise preserve the gap. |
| G08 — Actual application and consumer remedies | Every organization, governance, ownership, revenue, service, client, creditor, contract, recognition, authorization, and remedy predicate is held. | No factual investigation is authorized in this pass. Any future separate dimension requires its own defined public-law scope; missing evidence is not an adverse factual finding. |
No conclusion is made about an actual organization’s classification, recognition, good standing, tax exemption, compliance, or entitlement to any transition.
| Check | Result |
|---|---|
| Complete §501(q), including all nested paragraphs and material exceptions read | Yes, at the displayed October 20, 2026 cutoff. |
| Different §501(c)(3) and §501(c)(4) additions preserved | Yes. |
| Both board ceilings, different exclusions, voting-power units, and public control preserved | Yes. |
| Corporate voting, partnership profits, and trust/estate beneficial interests kept distinct | Yes. |
| Trust exception not silently extended to estates | Yes. |
| Aggregate creditor DMP revenue distinguished from total DMP fees, support, receipts, debt principal, and service counts | Yes; accounting gaps remain explicit. |
| Historical general transition distinguished from graduated revenue transition | Yes. |
| IRS summaries and older examples checked against statutory text | Yes; material simplifications identified. |
| Consumer-facing tax conditions distinguished from an independently established consumer remedy | Yes. |
| Source dates, legal status, read bounds, and failed retrievals disclosed | Yes. |
| No actual provider, person, account, roster, status database, filing, contact, purchase, or publication action | Yes. |
| No subagent, other research chat, prior Library foundation, or security/CAPTCHA workaround used | Yes. |
| No independent-review, unseen model-provenance, local-file, hash, or import claim | Yes. |
| Component, A034 parent, operational, or publication acceptance | None. |
END R034 PASS-01
Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
Material class · Treatment in this pass · 11 data rows
| Material class | Treatment in this pass |
|---|---|
| Current statutory text | §501(q) read completely at the displayed October 20, 2026 cutoff; §513(j) read with the separate October 7 cutoff and classification-table qualification above. |
| Current regulatory text | Necessary general exemption and unrelated-business provisions read from eCFR, with each displayed currency date retained. |
| Historical enacted transitions | Preserved as historical, predicate-specific rules. They are not a recurring grace period for newly formed organizations. |
| IRS HTML explanations | Read as official explanatory guidance. Their retrieved bodies did not expose an issuance or revision date; crawl dates were not substituted for agency publication dates. |
| IRS November 1, 2011 FAQ PDF | Read as a dated historical explanatory version, including its transition examples and simplifying statements. |
| Revenue rulings from 1965 and 1969 | Read completely as published IRS rulings addressing their stated generic facts. They predate §501(q). |
| Chief Counsel Advice dated May 9, 2006 | Read as nonprecedential internal legal advice containing generic examples; it predates §501(q). |
| JCT explanation dated August 3, 2006 | Read as staff legislative explanation of the bill, not an IRS ruling or operative statutory text. |
| Final versus temporary rules | T.D. 9819’s final status, effectiveness, applicability, and removal of corresponding temporary regulations were checked. |
| Proposed, future-effective, withdrawn, stayed, or vacated materials | No such material was used as governing authority. A comprehensive withdrawal, judicial-validity, or later-history audit was not performed. |
| Court opinions | No opinion was independently retrieved or used for a holding. Cases discussed inside older explanatory materials were not converted into independently verified precedent. |
Source ID · Issuer, title, and complete literal HTTPS URL · Exact location, version/status, read extent, and limits · 8 data rows
| Source ID | Issuer, title, and complete literal HTTPS URL | Exact location, version/status, read extent, and limits |
|---|---|---|
| R034-P1-S001 | Congress; OLRC, 26 U.S.C. §501, Exemption from tax on corporations, certain trusts, etc. https://uscode.house.gov/us/usc/119-134/t26/s501/ | Complete §501(q)(1)–(4); complete necessary §501(a), (b), (c)(3), (c)(4)(A)–(B); relevant source credit, reference note identifying August 17, 2006, amendment entry for §1220(a), and effective-date note for §1220(c). Displayed cutoff: P.L. 119-134, October 20, 2026. HTML; PDF index N/A. Other exemption categories were not substantively investigated. uscode.house.gov +5 |
| R034-P1-S002 | Congress; GPO, Pension Protection Act of 2006, Pub. L. 109-280 https://www.govinfo.gov/content/pkg/PLAW-109publ280/html/PLAW-109publ280.htm | Complete §1220(a)–(c), 120 Stat. 1086–1089: insertion of §501(q), addition of §513(j), and both general effective-date clauses. Enacted August 17, 2006. Official session-law HTML with printed-page markers; no session-law PDF inspection claimed. Remainder of the Act excluded. govinfo.gov +2 |
| R034-P1-S003 | Congress; OLRC, 26 U.S.C. §513, Unrelated trade or business https://uscode.house.gov/us/usc/119-120/t26/s513/ | Complete §513(j), necessary §513(a), and source/amendment/effective-date notes concerning §1220(b)–(c). Displayed cutoff October 7, 2026. Another retrieved path, https://uscode.house.gov/us/usc/119-118/t26/s513/, displayed the same October 7 cutoff. These are the same instrument, not separate corroboration. Newer-body retrieval gap remains. uscode.house.gov +2 |
| R034-P1-S004 — exemption rule | Treasury/IRS; eCFR, 26 CFR §1.501(a)-1, Exemption from taxation https://www.ecfr.gov/current/title-26/section-1.501%28a%29-1 | Necessary reliance: (a)(1)–(2), (c), and (f), including the distinction between nonprofit operation and exemption, definition of private shareholder/individual, and applicability language. Retrieved page displayed October 23, 2026 currency. Procedural and territorial material returned on the page was not used for application or territorial conclusions. ecfr.gov |
| R034-P1-S004 — §501(c)(3) rule | Treasury/IRS; eCFR, 26 CFR §1.501(c)(3)-1 https://www.ecfr.gov/current/title-26/section-1.501%28c%29%283%29-1 | Read (a)–(c), (d)(1)–(3), including the private-benefit examples, and (g)–(h)/source notes. Relied principally on organizational/operational tests, earnings/private-interest rules, and charitable/educational definitions. Displayed currency October 26, 2026. Paragraph (g) supplies the general historical applicability rule; (h) makes specified procedural paragraphs applicable on and after July 1, 2014. Full enforcement, excess-benefit, and judicial-validity analysis excluded. ecfr.gov +6 |
| R034-P1-S004 — §501(c)(4) rule | Treasury/IRS; eCFR, 26 CFR §1.501(c)(4)-1, Civic organizations and local associations of employees https://www.ecfr.gov/current/title-26/section-1.501%28c%29%284%29-1 | Complete (a)–(b) and source note read. Displayed currency October 26, 2026. Source note identifies T.D. 6500 and amendment by T.D. 8308, August 31, 1990. No actual category determination; §504 consequences and full political-activity analysis excluded. ecfr.gov |
| R034-P1-S004 — related-business rule | Treasury/IRS; eCFR, 26 CFR §1.513-1, Definition of unrelated trade or business https://www.ecfr.gov/current/title-26/section-1.513-1 | Substantive text (a)–(h) retrieved and read; necessary reliance on (d)(1)–(3), concerning contribution to exempt purposes and excessive scale. Displayed currency October 26, 2026. Paragraph (h) gives general applicability to taxable years beginning after December 12, 1967, with optional earlier reliance and a distinct later date for (f). No tax computation performed. ecfr.gov |
| R034-P1-S012 | Treasury/IRS; Federal Register, T.D. 9819, Guidelines for the Streamlined Process of Applying for Recognition of Section 501(c)(3) Status https://www.federalregister.gov/documents/2017/06/30/2017-13866/guidelines-for-the-streamlined-process-of-applying-for-recognition-of-section-501c3-status | 82 FR 29730–29733, June 30, 2017. Final regulations/removal of temporary regulations; effective June 30, 2017, applicable specified provisions on and after July 1, 2014. Substantive preamble, dates, and regulatory amendments read in HTML. Used narrowly to verify status/date of the general regulations and obsolete procedural references. No form eligibility, filing, or application advice adopted. PDF index N/A. federalregister.gov +4 |
Source ID / subdivision · Title and complete literal HTTPS URL · Exact read location and limits · 11 data rows
| Source ID / subdivision | Title and complete literal HTTPS URL | Exact read location and limits |
|---|---|---|
| R034-P1-S005 — index and dated PDF | Credit counseling organizations: Questions and answers about new requirements https://www.irs.gov/charities-non-profits/credit-counseling-organizations-questions-and-answers-about-new-requirements ; dated PDF: https://www.irs.gov/pub/irs-tege/creditcounselingfaqs11_01_11.pdf | Index and its general caveat read. Entire PDF, printed pp. 1–4, indices 0–3, updated November 1, 2011, including all 12 questions. HTML numbering differs because the dated PDF includes an effective-date question. PDF simplifications are not substituted for statutory exceptions. Internal Revenue Service +2 |
| S005 — applicability | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-applicability | Complete answer and incidental financial-literacy-course example; HTML Q1, PDF Q1, p.1 [0]. Internal Revenue Service |
| S005 — general criteria | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-new-criteria-for-exemption | Complete list; HTML Q2, PDF Q2, p.1 [0]. The HTML preserves the no-fee/no-interest loan exception; the dated PDF’s abbreviated loan bullet does not. Board summaries omit the separate 20% test. Internal Revenue Service +1 |
| S005 — no DMP offered | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-organizations-that-do-not-provide-debt-management-plan-services | Complete answer; HTML/PDF Q4, PDF p.2 [1]. Must be read with the substantial-purpose predicate. Internal Revenue Service |
| S005 — governing board | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-composition-of-governing-board | Complete answer/example; HTML/PDF Q5, PDF p.2 [1]. Membership shorthand does not replace the statutory voting-power measurements. Internal Revenue Service |
| S005 — taxable subsidiaries | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-taxable-subsidiaries | Complete answer/examples; HTML/PDF Q6, PDF pp.2–3 [1–2]. Statutory ownership bases and exceptions remain controlling. Internal Revenue Service |
| S005 — customer lists | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-customer-lists | Complete answer; HTML/PDF Q7, PDF p.3 [2]. Used for IRS interpretation of paid leads/referrals, not privacy-law conclusions. Internal Revenue Service |
| S005 — contributions | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-ban-on-soliciting-contributions-from-consumers | Complete answer; HTML/PDF Q8, PDF p.3 [2]. Category limitation comes from §501(q)(2). Internal Revenue Service |
| S005 — creditor revenues | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-limitation-on-income-from-debt-management-plans | Complete answer; HTML/PDF Q9, PDF p.3 [2]; additional percentages in PDF Q3, p.2 [1]. Its statement about consumer fees must be read against the statutory numerator and total-revenue denominator. Internal Revenue Service +1 |
| S005 — unrelated business | https://www.irs.gov/charities-non-profits/credit-counseling-legislation-income-taxable-if-requirements-not-met | Complete answer/example; HTML Q10, PDF Q11, p.4 [3]. Read with §513(j), not as a guarantee that an organization retains exemption. Internal Revenue Service |
| S005 — resource hub | https://www.irs.gov/charities-non-profits/charitable-organizations/credit-counseling-organizations-under-the-federal-tax-law | Complete resource listing read to locate statutory/JCT material. Linked historical compliance reports and testimony were not adopted as substantive current authority. Internal Revenue Service |
Source ID · Issuer, title, and complete literal HTTPS URL · Version/status, precise read extent, and limits · 6 data rows
| Source ID | Issuer, title, and complete literal HTTPS URL | Version/status, precise read extent, and limits |
|---|---|---|
| R034-P1-S006 | IRS, Rev. Rul. 65-299, 1965-2 C.B. 165 https://www.irs.gov/pub/irs-tege/rr65-299.pdf | Entire reformatted two-page PDF read, indices 0–1; original C.B. citation p.165. Published revenue ruling, 1965; an exact issue-day is not printed in this copy. Generic social-welfare facts. Predates §501(q); historical district-director/Form 1024 language is not current filing advice. No original C.B. page-image inspection or complete later-history audit. RR65-299.C4 +1 |
| R034-P1-S007 | IRS, Rev. Rul. 69-441, 1969-2 C.B. 115 https://www.irs.gov/pub/irs-tege/rr69-441.pdf | Entire reformatted two-page PDF read, indices 0–1; original C.B. citation p.115. Published revenue ruling, 1969; exact issue-day not shown. Its no-charge services, creditor approval, trust account, and funding facts are conditions of the stated example, not new universal rules inferred from §501(q). RR69-441.C3 +2 |
| R034-P1-S008 | IRS Office of Chief Counsel, Credit Counseling Organizations, Chief Counsel Advice 200620001 https://www.irs.gov/pub/irs-wd/0620001.pdf | Dated May 9, 2006, released May 19, 2006; institutional author: Chief, Exempt Organizations Branch 2. All available text of 11 PDF pages [0–10] read, including both generic fact patterns, analysis, qualifications, and concluding sections. Expressly nonprecedential; predates §501(q). Redacted material was not reconstructed. Cases and another CCA discussed inside it were not independently investigated or adopted as holdings. irs.gov +3 |
| R034-P1-S009 | Staff of the Joint Committee on Taxation, JCX-38-06, Technical Explanation of H.R. 4 https://www.irs.gov/pub/irs-tege/jcx38_06.pdf | August 3, 2006; bill as passed by House July 28 and considered by Senate August 3. IRS-hosted extract, but JCT staff authorship. Complete credit-counseling Explanation of Provision, printed pp.316–320 [PDF 5–9], including footnotes 432–436, definitions, and effective date, read. Earlier historical background was only partly read and is not a case-history foundation. Legislative explanation, not operative law. Pensions Technical Explanation 7-28.doc +3 |
| R034-P1-S010 | IRS, Frequently asked questions about applying for tax exemption https://www.irs.gov/charities-non-profits/frequently-asked-questions-about-applying-for-tax-exemption | Complete answers to “What is the difference between nonprofit and tax-exempt status?” and “How does an organization become tax-exempt?” read. Official explanatory webpage; no agency revision date exposed. Remainder of application procedures excluded. Internal Revenue Service |
| R034-P1-S011 | OLRC, Currency and Updating; Classification Tables https://uscode.house.gov/currency.html ; https://uscode.house.gov/classification/tables.html ; https://uscode.house.gov/classification/tbl119cd_2nd.html | Currency explanation and classification-table scope read; 2026 table heading/date and complete Title 26 block read. Table prepared October 20, 2026, covering the listed 119th Congress second-session laws through P.L.119-134. Only classified provisions are represented. This is an update aid, not operative statutory language or a complete unclassified-law audit. US Code +3 |
Claim ID · Verified claim, with conditions and limits · Exact authority/source · 15 data rows
| Claim ID | Verified claim, with conditions and limits | Exact authority/source |
|---|---|---|
| R034-P1-C001 | The complete §501(q) body retrieved at the current-edition link comprises paragraphs (1)–(4), with a displayed October 20, 2026 compilation cutoff. That label does not certify a complete amendment or case-history audit through October 27. | S001, heading and §501(q); S011 currency explanation. uscode.house.gov +2 |
| R034-P1-C002 | Section 1220(a) of P.L.109-280 inserted §501(q); §1220(b) added §513(j). Under §1220(c)(1), the default applicability is to taxable years beginning after the Act’s enactment on August 17, 2006, subject to the separate existing-organization transition. OLRC’s note explains the editorial execution of the amendment despite the Act not naming the Code in the amendment instruction. | S002 §1220(a)–(c)(1), 120 Stat.1086–1089; S001 amendment note. govinfo.gov +2 |
| R034-P1-C003 | The general delayed-start provision applies to an organization described in §501(c)(3) or (4) for which credit counseling was a substantial purpose on enactment. For that predicate, §1220’s amendments apply to taxable years beginning after the date one year after enactment. The clause does not repeat the separate revenue-transition requirement of being exempt under §501(a) on enactment. | S002 §1220(c)(2), 120 Stat.1089. govinfo.gov |
| R034-P1-C004 | When providing defined credit-counseling services is a substantial purpose, exemption under §501(a) is unavailable unless the organization is described in §501(c)(3) or (4) and is both organized and operated in accordance with the applicable §501(q) requirements. This is a necessary-condition framework, not an independent exemption category. | S001 §501(q)(1), introductory text. uscode.house.gov |
| R034-P1-C005 | Defined credit-counseling services encompass public educational information on budgeting, personal finance, financial literacy, saving and spending practices, and sound consumer-credit use; counseling individuals and families with financial problems; or a combination. The definition does not impose a general low-income-only criterion. | S001 §501(q)(4)(A)(i)–(iii). uscode.house.gov |
| R034-P1-C006 | Offering no DMP does not itself avoid §501(q). Conversely, the IRS gives an incidental financial-literacy course within a school curriculum as an example outside the substantial-purpose trigger. Neither the subsection nor that explanation supplies a universal numerical substantial-purpose threshold. | S001 §501(q)(1), (4)(A); S005 applicability and no-DMP answers. Internal Revenue Service +2 |
| R034-P1-C007 | Defined DMP services include services related to debt repayment, consolidation, or restructuring, including negotiating lower creditor interest rates, fee waiver/reduction, and DMP marketing and processing. A service may fit that definition without guaranteeing a concession or establishing that credit counseling is a substantial organizational purpose. | S001 §501(q)(4)(B), read with (q)(1). uscode.house.gov |
| R034-P1-C008 | Nonprofit organizational status does not automatically produce federal income-tax exemption. IRS describes nonprofit status as a state-law concept; federal exemption requires satisfaction of federal tax law. Section 501(b) also preserves taxation of specified activities notwithstanding organizational exemption. | S010 nonprofit-status answer; S001 §501(a)–(b); S004 §1.501(a)-1(a)(1)–(2). Internal Revenue Service +2 |
| R034-P1-C009 | A §501(c)(3) credit-counseling organization must still satisfy the underlying organizational and operational tests for an exempt purpose, commonly charitable or educational here. Governing language and actual operations are separate requirements; educational subject matter alone does not establish compliance. | S001 §501(c)(3); S004 §1.501(c)(3)-1(a), (b), (c)(1), (d)(2)–(3). uscode.house.gov +3 |
| R034-P1-C010 | Section 501(c)(3) forbids net earnings inuring to a private shareholder or individual. The regulatory definition refers to persons with a personal and private interest in organizational activities. Board-percentage permissions do not authorize earnings diversion. | S001 §501(c)(3); S004 §§1.501(c)(3)-1(c)(2), 1.501(a)-1(c). uscode.house.gov +2 |
| R034-P1-C011 | The §501(c)(3) public-interest requirement is broader than the earnings-inurement prohibition: an organization must serve public rather than private interests. Satisfying an ownership or board ceiling does not resolve this separate condition. | S004 §1.501(c)(3)-1(d)(1)(ii)–(iii); S001 §501(q)(1) introductory requirement. ecfr.gov +2 |
| R034-P1-C012 | The §501(c)(3) statutory baseline also restricts substantial legislative influence, subject to §501(h), and prohibits campaign participation/intervention for or against candidates. Section 501(q) supplies no exception to those conditions. The §501(h) election machinery was not investigated. | S001 §501(c)(3); S004 §1.501(c)(3)-1(b)(3), (c)(3). uscode.house.gov +2 |
| R034-P1-C013 | The civic-organization route under §501(c)(4) requires nonprofit organization/operation and promotion of social welfare. The regulation describes primary engagement in community common good and welfare, and does not treat a business conducted primarily in the manner of a for-profit business as sufficient social-welfare operation. | S001 §501(c)(4)(A); S004 §1.501(c)(4)-1(a)(1)–(2). uscode.house.gov +1 |
| R034-P1-C014 | Section 501(c)(4)(A) separately names local employee associations: membership must be limited to employees of a designated person or persons in a particular municipality, and net earnings must be devoted exclusively to charitable, educational, or recreational purposes. This is not a §501(q) rule requiring credit-counseling consumers to be members. | S001 §501(c)(4)(A); S004 §1.501(c)(4)-1(b). uscode.house.gov +1 |
| R034-P1-C015 | Section 501(c)(4)(B) independently bars net-earnings inurement to private shareholders or individuals. Absence of the §501(c)(3)-specific revenue ceiling does not remove this safeguard. | S001 §501(c)(4)(B), (q)(2). uscode.house.gov +1 |
Claim ID · Verified claim, with conditions and limits · Exact authority/source · 9 data rows
| Claim ID | Verified claim, with conditions and limits | Exact authority/source |
|---|---|---|
| R034-P1-C016 | Services must be tailored to consumers’ specific needs and circumstances. Section 501(q) does not prescribe a nationally uniform interview script, assessment score, counseling duration, or DMP enrollment result. | S001 §501(q)(1)(A)(i); complete subsection. uscode.house.gov +1 |
| R034-P1-C017 | Making loans to debtors is prohibited except loans with neither fees nor interest. That exception satisfies only this particular condition; it does not establish compliance with all exemption or other lending rules. | S001 §501(q)(1)(A)(ii). uscode.house.gov |
| R034-P1-C018 | Negotiating the making of loans on debtors’ behalf is separately prohibited; the text does not repeat the own-loan exception for this prohibition. JCT footnote 432 distinguishes negotiating loan terms from processing a loan and says assistance obtaining a loan is not necessarily negotiation. This is a bounded explanatory distinction, not permission for an undefined origination business. | S001 §501(q)(1)(A)(ii); S009 p.317 [6], fn.432. uscode.house.gov +1 |
| R034-P1-C019 | Services intended to improve a consumer’s credit record, history, or rating are permitted only insofar as incidental to credit counseling. JCT describes a direct outgrowth of counseling; a separate primary credit-repair purpose is not authorized by this clause. | S001 §501(q)(1)(A)(iii); S009 p.317 [6], fn.433. uscode.house.gov +1 |
| R034-P1-C020 | A separately stated fee for services intended to improve a consumer’s credit record, history, or rating is prohibited. This is a prohibition, not a percentage ceiling or a reasonable-price allowance. | S001 §501(q)(1)(A)(iv). uscode.house.gov |
| R034-P1-C021 | Credit-counseling services may not be refused because the consumer cannot pay, is ineligible for DMP enrollment, or is unwilling to enroll. The provision does not require enrollment of an ineligible consumer in a DMP. | S001 §501(q)(1)(B). uscode.house.gov |
| R034-P1-C022 | An established and implemented fee policy must require reasonable consumer service fees. No national dollar amount appears. JCT footnote 434 treats consistency with state fee requirements as evidence of reasonableness, not a conclusive determination. | S001 §501(q)(1)(C)(i); S009 p.317 [6], fn.434. uscode.house.gov +1 |
| R034-P1-C023 | The fee policy must allow fee waiver when the consumer cannot pay; the IRS explanation says to provide waivers in that situation. Read with C021, this is a substantive accessibility condition. The reviewed provisions supply no universal income percentage, poverty multiplier, documentary checklist, or conclusive presumption for inability to pay. | S001 §501(q)(1)(B), (C)(ii); S005 general criteria. uscode.house.gov +1 |
| R034-P1-C024 | Except to the extent state law allows, the fee policy must prohibit fees based wholly or partly on a percentage of consumer debt, payments to be made under a DMP, or projected or actual DMP savings. The state-law exception modifies this percentage-fee restriction; it does not erase reasonableness or inability-to-pay requirements. No state predicate was investigated. | S001 §501(q)(1)(C)(i)–(iii). uscode.house.gov |
Claim ID · Verified claim, with measurement and exceptions · Exact authority/source · 12 data rows
| Claim ID | Verified claim, with measurement and exceptions | Exact authority/source |
|---|---|---|
| R034-P1-C025 | At all times, the governing body must be controlled by persons representing broad public interests. Examples are public officials acting in that capacity, persons with credit/financial-education expertise, and community leaders. The numerical tests below are additional requirements. | S001 §501(q)(1)(D), (D)(i). uscode.house.gov |
| R034-P1-C026 | 20% ceiling, at all times: numerator = aggregate governing-body voting power vested in persons employed by the organization or financially benefiting directly/indirectly from its activities; denominator = total governing-body voting power. Exclude benefits consisting of reasonable directors’ fees or repayment of consumer debt to creditors other than the counseling organization or its affiliates. An independently applicable employment or other financial-benefit predicate is not erased. This is not a per-director allowance or annual average. | S001 §501(q)(1)(D)(ii). uscode.house.gov |
| R034-P1-C027 | 49% ceiling, at all times: numerator = aggregate governing-body voting power vested in employed or directly/indirectly financially benefiting persons; denominator = total governing-body voting power. Here the stated exception is reasonable directors’ fees only. The third-party creditor-repayment exception appearing in the 20% clause is absent. | S001 §501(q)(1)(D)(iii). uscode.house.gov |
| R034-P1-C028 | The 20% and 49% tests must both be satisfied, together with public control. They use voting power, not necessarily seat count. Their numerators can overlap; adding the ceilings or treating them as separate allotments is unsupported. A person satisfying multiple predicates is not counted twice within the same voting-power numerator. | Construction of S001 §501(q)(1)(D)(i)–(iii); compare S005 board shorthand. uscode.house.gov +1 |
| R034-P1-C029 | Corporate ownership ceiling: the counseling organization may not own more than 35% of a covered corporation’s total combined voting power. Numerator = its owned corporate voting power; denominator = that corporation’s total combined voting power. The text excepts a corporation both described in §501(c)(3) and exempt under §501(a). It specifies no annual averaging period or related-owner aggregation formula. | S001 §501(q)(1)(E)(i). uscode.house.gov |
| R034-P1-C030 | Partnership ownership ceiling: the measure is ownership of more than 35% of a covered partnership’s profits interest, not capital or gross receipts. The text expressly excepts a partnership both described in §501(c)(3) and exempt under §501(a). Whether any actual arrangement could satisfy that exception is not determined. No annual averaging or attribution formula is supplied in this clause. | S001 §501(q)(1)(E)(ii). uscode.house.gov |
| R034-P1-C031 | Trust/estate ownership ceiling: the measure is ownership of more than 35% of the covered trust’s or estate’s beneficial interest. The parenthetical exception expressly names a qualifying, exempt trust; it does not name an estate. No annual averaging or related-owner attribution rule is stated here. | S001 §501(q)(1)(E)(iii). uscode.house.gov |
| R034-P1-C032 | The ownership ceilings concern businesses lending money, repairing credit, providing DMP services, payment processing, or similar services. They regulate ownership by the counseling organization, not a general 35% ceiling on each director’s personal holdings. IRS examples include DMP processing, debt negotiation/settlement, and short-term loan initiation. | S001 §501(q)(1)(E)(i)–(iii); S005 taxable-subsidiaries answer. uscode.house.gov +1 |
| R034-P1-C033 | The organization may receive no amount for referring others for DMP services. The receipt prohibition is expressly tied to DMP-service referrals. | S001 §501(q)(1)(F), first limb. uscode.house.gov |
| R034-P1-C034 | The organization may pay no amount to obtain consumer referrals. The payment limb is not textually limited to referrals that ultimately produce a DMP. Neither limb establishes a small permissible referral-fee allowance. | S001 §501(q)(1)(F), second limb. uscode.house.gov |
| R034-P1-C035 | The IRS customer-list explanation says an organization cannot purchase customer leads from third-party vendors or sell customer names to other providers. This supports scrutiny of substance rather than renaming a referral payment as a lead purchase. It is not a complete advertising or privacy-law analysis. | S005 customer-list answer. Internal Revenue Service |
| R034-P1-C036 | JCT footnote 436 says a fee for using or maintaining a consumer locator service is not considered a referral. That narrow explanation does not establish that every directory charge, lead list, advertising arrangement, or enrollment-contingent payment qualifies. | S009 p.318 [7], fn.436. Pensions Technical Explanation 7-28.doc |
Claim ID · Verified claim, with measurement and exceptions · Exact authority/source · 11 data rows
| Claim ID | Verified claim, with measurement and exceptions | Exact authority/source |
|---|---|---|
| R034-P1-C037 | For a covered §501(c)(3) organization, contributions may not be solicited from consumers during initial counseling or while they receive organizational services. This is a solicitation prohibition with specified consumer/time predicates, not a ceiling on donations. Section 501(q)(2) does not impose this additional condition on §501(c)(4). | S001 §501(q)(2)(A)(i); S005 contribution answer. uscode.house.gov +1 |
| R034-P1-C038 | IRS distinguishes permitted reasonable service fees from prohibited solicitation of voluntary contributions during those periods, and identifies grants and contributions from noncustomers as funding possibilities. Calling a compulsory service charge a donation does not settle its legal character. The statutory clause prohibits solicitation; it does not expressly resolve every unsolicited-receipt situation. | S001 §501(q)(1)(C), (2)(A)(i); S005 contribution answer. The characterization and unsolicited-receipt limits are textual conclusions, not blanket permissions. uscode.house.gov +2 |
| R034-P1-C039 | For a covered §501(c)(3) organization, aggregate organization revenues from payments by its consumers’ creditors and attributable to DMP services may not exceed 50% of the organization’s total revenues, subject to the historical transition in C043. Numerator combines all qualifying creditor payments, not a separate allowance per creditor; denominator is total organization revenues. The taxable-year context is explained in C041. | S001 §501(q)(2)(A)(ii), (B)(i); S005 revenue answer. uscode.house.gov +1 |
| R034-P1-C040 | Consumer setup and monthly fees are not payments from consumers’ creditors, so they do not belong in the restricted creditor-payment numerator. The FAQ’s abbreviated exclusion does not justify removing properly recognized consumer-fee revenue from the statutory total-revenue denominator. Whether a particular amount is organization revenue remains a separate accounting question. | S001 §501(q)(2)(A)(ii); S005 revenue answer. Denominator conclusion is a reading of the statutory distinction. uscode.house.gov +1 |
| R034-P1-C041 | The transition and effective-date provisions use taxable years, and the dated IRS FAQ applies the percentages by calendar/fiscal accounting year. The core sentence in (2)(A)(ii) does not separately define an accounting period, accounting method, or averaging convention. No rolling, lifetime, per-plan, or service-count averaging rule is supplied. Use the same relevant taxable-year context for numerator and denominator; do not invent a different measurement window. | S001 §501(q)(2)(B)(ii); S002 §1220(c); S005 PDF Q3 and Q10, pp.2–3 [1–2]. uscode.house.gov +3 |
| R034-P1-C042 | Section 501(q) does not define total revenues through a gross-receipts, support, participant-debt, assessed-charge, or custodial-payment formula. It does not state how to classify every debt payment held for another or allocate mixed payments. Such amounts must not be inserted merely because they pass through an account. Their precise tax-accounting treatment remains unresolved here. | S001 complete §501(q), especially (2)(A)(ii), (4); S005 revenue answer. uscode.house.gov +2 |
| R034-P1-C043 | The graduated percentage applies only where credit counseling was a substantial purpose and the organization was both described in §501(c)(3) and exempt under §501(a) on August 17, 2006. The ceiling is 80% for the first taxable year beginning after August 17, 2007; 70% for the second such taxable year; 60% for the third; then the general 50% rule. The revenue numerator/denominator remain those in C039; this is not a new-organization phase-in today. | S001 §501(q)(2)(B)(i)–(ii), reference note; S002 §1220(a). uscode.house.gov +2 |
| R034-P1-C044 | A covered §501(c)(4) organization must notify the Secretary, in the manner regulations may prescribe, that it is applying for recognition as a credit-counseling organization. The §501(c)(3)-specific solicitation and creditor-revenue conditions are not transplanted into (q)(3). Exact present notification mechanics were not resolved in this pass. | S001 §501(q)(3), compared with (q)(2). uscode.house.gov |
| R034-P1-C045 | The subsection uses organization ownership, direct/indirect financial benefit, and the organization’s affiliates in specific clauses. It does not define a general related-organization group, constructive-ownership rule, or combined-revenue denominator. That textual absence is not authority to disregard indirect benefits, private benefit, agency, or another applicable attribution rule. | S001 §501(q)(1)(D)–(E), (2), (4); S004 private-interest rules. uscode.house.gov +2 |
| R034-P1-C046 | Section 513(j) includes DMP services within unrelated trade or business when provided by an organization other than one meeting §501(q). Separately, §501(q)’s exemption conditions can prevent exemption when its substantial-purpose framework applies. The IRS incidental-school example therefore does not mean every noncompliant credit-counseling organization simply pays tax on DMP income while retaining exemption. | S003 §513(j); S001 §501(b), (q)(1)–(3); S005 taxable-income answer. uscode.house.gov +4 |
| R034-P1-C047 | Satisfying the creditor-revenue percentage is not an exemption safe harbor or an automatic finding that DMP income is related income. The general regulation asks whether the income-producing activity contributes importantly to exempt purposes and whether it exceeds the scale reasonably necessary for those purposes. JCT applies that distinction to DMP services. | S004 §1.513-1(d)(1)–(3); S009 pp.319–320 [8–9]. ecfr.gov +1 |
Claim ID · Verified claim, with conditions and limits · Exact authority/source · 13 data rows
| Claim ID | Verified claim, with conditions and limits | Exact authority/source |
|---|---|---|
| R034-P1-C048 | The 2006 CCA contrasts an educational counseling process—individual financial understanding, alternatives, appropriate recommendations, training, and follow-up—with a process primarily designed to qualify consumers for and sell DMPs. Its conclusion depends on the combined facts, with inurement/private benefit separately relevant. It is not a mandatory national checklist or a current exemption determination. | S008 pp.1–5, 8–10 [0–4, 7–9]; express nonprecedential statement p.1 [0]. irs.gov +2 |
| R034-P1-C049 | Rev. Rul. 69-441 finds §501(c)(3) qualification on stated facts combining public education, assistance to low-income people, free counseling/budget-plan services, representative governance, and creditor contributions. Its trust-account, creditor-consent, and full-credit facts describe that example; they do not create a universal §501(q) distribution deadline or contract entitlement. | S007 entire ruling, PDF [0–1]; current additional conditions in S001. RR69-441.C3 +3 |
| R034-P1-C050 | Rev. Rul. 65-299’s generic §501(c)(4) example includes individualized financial analysis, creditor-consented arrangements, free counseling, a nominal processing charge, and community support. Eligibility was not confined to charitable recipients. This is a fact-dependent historical example, not a universal processing-fee cap or proof that every DMP operation promotes social welfare. | S006 entire ruling, PDF [0–1]. RR65-299.C4 +1 |
| R034-P1-C051 | Section 501(q)’s express legal consequence concerns exemption. Its text contains no express consumer cause of action, damages formula, automatic contract rescission, or fee-refund remedy. Whether a consumer can enforce a condition through another legal route remains unresolved and parent-held. | Textual limit of S001 complete §501(q). This is not a comprehensive no-remedy opinion. uscode.house.gov +1 |
| R034-P1-C052 | Defining negotiation of creditor concessions as DMP services does not compel a creditor to accept a plan, lower interest, waive fees, release principal, or admit that a disputed debt is valid. Those outcomes are not determined by organizational tax qualification. | S001 §501(q)(4)(B), read in the exemption framework of (q)(1)–(3). uscode.house.gov +1 |
| R034-P1-C053 | The subsection supplies no nationally universal dollar DMP fee cap, creditor-distribution deadline, DMP approval guarantee, completion guarantee, or general cancellation/refund rule. The specific fee protections it does contain remain enforceable tax-qualification conditions; the absence of these additional terms does not erase those conditions. | S001 complete §501(q), particularly (1)(B)–(C), (4)(B). uscode.house.gov +1 |
| R034-P1-C054 | Federal tax qualification/recognition, a client contract, creditor assent, state authorization, and bankruptcy-counseling approval answer different questions. Section 501(q) does not confer those separate approvals or settle contract terms. JCT expressly states that the provision was not intended to affect the bankruptcy approval process. No separate approval system was investigated. | S001 §501(q); S010 recognition explanation; S009 pp.316–317 [5–6]. uscode.house.gov +2 |
| R034-P1-C055 | IRS FAQ summaries require statutory qualification: the board answer does not present the separate 20% test; the dated PDF loan bullet omits the statutory exception; consumer-fee shorthand does not define total revenues; the taxable-income answer does not resolve organizational exemption. | Comparison of S005 with S001 and S003; underlying rules C017, C026–C028, C040, C046. irs.gov +5 |
| R034-P1-C056 | The 1965/1969 rulings and May 2006 CCA predate §501(q). Their statements concerning creditor-supported operations cannot override the later §501(c)(3) creditor-revenue ceiling. A current official hosting location does not convert a historical example into a complete present-law permission. | S006–S008 dates; S002 enactment; S001 §501(q)(2). RR69-441.C3 +4 |
| R034-P1-C057 | The general §501(c)(3) regulation contains a distinct historical organizational-test clause for certain determinations before July 27, 1959, and rules for a later requested determination. Its current procedural paragraphs have the July 1, 2014 applicability specified in (h). These provisions do not supply an exemption from §501(q). | S004 §1.501(c)(3)-1(b)(6), (g)–(h); S012 final amendment. ecfr.gov +2 |
| R034-P1-C058 | Failure to satisfy a §501(c)(3) condition does not itself establish §501(c)(4) status. The latter has its own requirements; its regulation also expressly distinguishes certain action organizations according to prior §501(c)(3) exemption after October 4, 1976 and refers to §504. No conversion or §504 analysis was performed. | S004 §1.501(c)(4)-1(a)(2)(ii); S001 §501(q)(3). ecfr.gov +1 |
| R034-P1-C059 | Section 501(q) contains no general public-support percentage, per-donor contribution cap, or gross-receipts support test. Its revenue restriction is the specific creditor-payment fraction in C039. Separate public-charity/private-foundation classification rules were not substituted for it or investigated. | S001 complete §501(q), especially (2) and (4). uscode.house.gov +1 |
| R034-P1-C060 | Currentness remains bounded: newer §513-body retrieval failed; the October 20 classification table contains no §§501/513 entry in its Title 26 block, but only classified provisions are covered. No conclusion about unreviewed later laws or judicial history follows from that result. | S003; S011 table scope, date, and Title 26 block; failure log below. uscode.house.gov +3 |
Question · Covered §501(c)(3) organization · Covered §501(c)(4) organization · 7 data rows
| Question | Covered §501(c)(3) organization | Covered §501(c)(4) organization | What must not be inferred |
|---|---|---|---|
| Underlying exempt purpose | Must satisfy §501(c)(3), including organizational/operational and private-interest restrictions. | Must satisfy the applicable §501(c)(4) route and its safeguards. | A nonprofit charter or counseling label establishes neither category. C008–C015. |
| Shared §501(q) conditions | All §501(q)(1)(A)–(F) requirements apply. | Same shared requirements apply. | Category choice does not remove tailoring, fee, governance, ownership, or referral conditions. C016–C036. |
| Consumer contribution solicitation | Additional prohibition during initial counseling and ongoing services. | This particular additional §501(q)(2) condition is not imposed by (q)(3). | Its absence for (c)(4) is not blanket approval under all law or all exemption conditions. C037–C038, C015. |
| Creditor-funded DMP revenue | Aggregate qualifying creditor revenue limited to the applicable fraction of total revenue. | Section 501(q) does not impose that (c)(3)-specific fraction. | Failure of the fraction does not automatically produce valid (c)(4) status. C039–C043, C058. |
| Recognition-related condition | General recognition requirements remain separate from substantive qualification. | Section 501(q)(3) expressly adds notification that it is applying for credit-counseling recognition. | A label, notice, or application is not itself proof of satisfaction of every condition. C004, C008, C044. |
| DMP-related income | The revenue ceiling does not establish related-business treatment. | Shared qualification likewise does not automatically resolve related-business treatment. | Taxing an activity and denying organizational exemption are not interchangeable conclusions. C046–C047. |
| Consumer agreement and other approvals | Not established by tax category. | Not established by tax category. | No tax-label inference about creditor assent, contractual performance, licensing, or bankruptcy approval. C051–C054. |
Branch / status · Verified rule and qualitative branch · Missing evidence or authority · 20 data rows
| Branch / status | Verified rule and qualitative branch | Missing evidence or authority | Adverse inference to avoid | Exact next permissible public-law inquiry |
|---|---|---|---|---|
| B01 — Substantial purpose unknown. Partial; application excluded. | Financial education alone can trigger the framework if substantial; incidental counseling may not. C004–C006; S001 §501(q)(1), (4)(A). | Relative organizational purposes and operations; any controlling published interpretation giving content to substantial purpose. | “No DMP means no §501(q),” or “any financial lesson necessarily triggers it.” | Search only Treasury/IRS published generic guidance addressing the substantial-purpose trigger in §501(q)(1); retain the absence of a verified numerical threshold. |
| B02 — Nonprofit form versus exemption. Answered; application excluded. | A nonprofit form is insufficient to establish federal exemption. C008; S010 nonprofit-status answer. | Actual legal form and tax qualification remain held. | The word nonprofit proves recognized exemption or service quality. | If further explanation is needed, examine only generic IRS guidance separating state organizational form, substantive exemption, and recognition. |
| B03 — §501(c) category unknown. Partial; application excluded. | Shared conditions apply to either covered category, but (q)(2) and (q)(3) differ. C009–C015, C037–C044; S001 §501(q)(2)–(3). | Category and underlying exempt-purpose predicates; current notice mechanics. | Apply the (c)(3) revenue ceiling automatically to every nonprofit, or presume an automatic switch to (c)(4). | Examine published generic guidance on §501(q)(3)’s notification requirement and its relationship to general (c)(4) procedures; no application or status lookup. |
| B04 — Educational/counseling purpose versus another purpose. Partial. | Tailoring and underlying exempt-purpose requirements matter; a DMP sales process is not made educational by its label. C009, C016, C048; S008 generic methodology discussion. | Purpose and methodology facts; authoritative treatment of an unresolved methodology issue beyond the dated CCA. | A brochure conclusively proves education, or a single sales-oriented feature conclusively disproves exemption. | Seek current published IRS interpretations of §501(q)(1)(A)(i) and general educational purpose; do not turn the CCA’s examples into mandatory national procedures. |
| B05 — Public service/accessibility unknown. Partial. | Public education is expressly included; inability to pay or DMP unwillingness/ineligibility cannot be the reason to refuse counseling. C005, C021; S001 §501(q)(1)(B), (4)(A). | Service-access predicates, reasons for any hypothetical refusal, and category-specific public-purpose analysis. | Everyone must be admitted to every DMP, or services must always be restricted to poor consumers. | Examine generic IRS explanations of the scope of counseling access under (q)(1)(B), without importing another approval system’s eligibility rules. |
| B06 — Inability-to-pay/waiver predicate. Partial. | Fee policy must allow waiver for inability to pay, and counseling cannot be refused on that basis. C021–C023; S001 §501(q)(1)(B)–(C). | A verified inability-to-pay standard and the predicate’s application; neither is supplied here. | A request automatically satisfies every waiver predicate, or absence of a stated poverty threshold permits refusal. | Search published IRS/Treasury guidance specifically defining inability to pay for §501(q); do not borrow bankruptcy fee-waiver thresholds. |
| B07 — Voluntary contribution versus compulsory charge. Partial. | For covered (c)(3) organizations, prohibited solicitation can concern voluntary contributions; genuine fees remain subject to fee protections. C037–C038; S005 contributions answer. | Nature of payment, solicitation, service relationship, and timing; treatment of unsolicited receipts. | A donation label avoids fee rules, or every unsolicited payment is expressly prohibited by the solicitation clause. | Seek published generic interpretation of solicit contributions in (q)(2)(A)(i), including unsolicited receipts and mislabeled service charges. |
| B08 — Counseling/DMP services versus loan making or origination. Partial. | Own loans have the narrow no-fee/no-interest exception; negotiating new loans is separately prohibited. Processing is not necessarily negotiation. C007, C017–C018; S001 §501(q)(1)(A)(ii); S009 fn.432. | Legal character of an activity, especially processing versus negotiating terms. | The word consolidation permits a fee-bearing new loan, or every administrative assistance task is prohibited negotiation. | Look for an official published interpretation applying (q)(1)(A)(ii) to generic processing/origination functions. |
| B09 — Incidental credit repair versus separate service. Partial. | Incidental credit-improvement services and no separately stated fee are distinct conditions. C019–C020; S001 §501(q)(1)(A)(iii)–(iv). | Whether the activity is incidental and whether a charge is separately stated. | Any credit-score improvement makes counseling unlawful, or embedding a fee conclusively establishes a permissible primary credit-repair business. | Seek published IRS interpretation of incidental and separately stated fee in these specific clauses. |
| B10 — Referral/lead payment versus locator service. Partial. | Referral payments/receipts face the statutory prohibitions; IRS includes paid leads; JCT describes a narrow locator-service distinction. C033–C036; S005 customer-list answer; S009 fn.436. | Nature of the service and consideration; later authoritative treatment of the locator distinction. | Any advertising fee is necessarily a referral fee, or any “directory” label makes a paid lead permissible. | Search published IRS/Treasury guidance on §501(q)(1)(F) distinguishing advertising, locator services, and consumer referrals. |
| B11 — Governance independence and related interests. Partial. | Public control, 20% voting, and 49% voting tests operate together with different exclusions. C025–C028; S001 §501(q)(1)(D). | Voting rights, employment/benefit predicates, public-interest representation, affiliate meaning. | Headcount proves voting compliance; creditor-related interests are excluded from both tests; or both ceilings can be added. | Seek published generic interpretation of control, voting power, indirect benefit, and affiliates in (q)(1)(D). No officer/director searches. |
| B12 — Numeric base or period unknown. Partial. | Ownership, voting, and revenue tests measure different things; the revenue fraction does not measure participant debt or service volume. C026–C031, C039–C043; S001 §501(q)(1)(D)–(E), (2). | Correct unit, legal accounting base, relevant period, and any applicable exclusion. | Substitute cash receipts, support, debt principal, capital ownership, or number of clients. | Seek q-specific published accounting guidance on total revenues and creditor-attributable DMP revenues before any calculation. |
| B13 — Related-organization aggregation. Partial. | The body contains no general combined-revenue or constructive-ownership formula, but expressly addresses indirect benefits and affiliates in particular places. C045; S001 §501(q). | The precise statute/regulation making attribution, consolidation, agency, or another related-party rule applicable to the question. | “No express aggregation clause” proves subsidiaries can be ignored, or all related entities must automatically be consolidated. | Identify an expressly applicable public tax authority for the proposed attribution or aggregation; do not borrow a different provision’s 35% test. |
| B14 — Exception or transition unknown. Partial. | Loan, fee, board, ownership, and historical transitions each have distinct predicates. C003, C017, C024, C026–C031, C043; S001; S002 §1220. | Predicate-specific authority/facts, including historical category/exemption status where relevant. | A general nonprofit label establishes an exception, or the historical phase-in restarts for a new organization. | Reconcile the exact exception’s wording and effective clause in official text; actual historical qualification remains held. |
| B15 — Recognition versus client contract. Answered boundary; application excluded. | Recognition concerns tax status; §501(q) does not supply a complete client agreement or decide its performance. C008, C044, C051–C054; S010. | Recognition and contract facts are expressly held. | A recognition label guarantees the contract, or a service dispute alone proves tax revocation. | Within this pass, only generic IRS explanations of recognition’s legal scope are permissible; contract and actual recognition work remain parent-held. |
| B16 — Tax qualification versus state/bankruptcy authorization. Answered boundary; separate systems excluded. | Section 501(q) does not confer either separate authorization. C054; S001; S009 pp.316–317. | Jurisdiction and separate approval predicates, all held. | Tax exemption equals licensing, registration, or bankruptcy approval. | No separate-system investigation in this pass; any future inquiry must begin with the appropriate generic public law after that parent dimension is released. |
| B17 — Creditor concessions and debt validity unknown. Answered boundary; application excluded. | The DMP definition includes negotiating concessions; it does not compel concessions or validate debt. C007, C052; S001 §501(q)(4)(B). | Creditor assent, debt validity, and contract facts remain held. | A qualifying organization can bind a creditor or establish an underlying balance. | No additional §501(q) inquiry can supply those facts. Separate generic contract/debt-validity law belongs to the held parent work. |
| B18 — Noncompliance versus consumer remedy. Partial; remedies excluded. | The statute states exemption conditions and contains no express consumer damages/refund mechanism. C051–C053; S001 §501(q). | Independent cause of action, contract, remedy, and procedural authority; all held. | Tax noncompliance automatically creates a refund, or the absence of an express remedy proves no remedy exists anywhere. | Within scope, preserve the textual finding only. A later authorized inquiry would require specific public remedy authority; no docket or actual case-record search. |
| B19 — DMP marketing/processing without a completed plan. Partial. | Marketing and processing are expressly within the DMP-service definition; completed enrollment is not the definition’s sole trigger. C007; S001 §501(q)(4)(B). | Activity characterization and its relationship to credit counseling as a substantial purpose. | No completed DMP necessarily means no DMP services, or DMP services alone conclusively establish every §501(q) predicate. | Seek published generic interpretation of the relationship between (q)(4)(B)’s service definition and (q)(1)’s purpose trigger. |
| B20 — Tax on activity versus retention of exemption. Partial. | Section 513(j), general relatedness rules, and §501(q)’s organizational conditions answer distinct questions. C046–C047; S003 §513(j); S004 §1.513-1(d). | Current §513-body retrieval gap and the hypothetical legal category/activity predicates; tax computations held. | Paying unrelated-business tax necessarily cures a substantial exempt-purpose failure. | Retrieve the newer official §513 body and any published generic IRS explanation reconciling §513(j) with §501(q)(1)–(3). |
Audit item · Governing claim(s) · Finding / evidence reference — blank · 33 data rows
| Audit item | Governing claim(s) | Finding / evidence reference — blank |
|---|---|---|
| Applicable published statutory version and access date | C001–C003, C060 | __________ |
| Substantial-purpose trigger | C004–C006 | __________ |
| Which part of the credit-counseling definition is implicated | C005 | __________ |
| Whether the activity falls within the DMP-service definition | C007 | __________ |
| Nonprofit form distinguished from federal exemption | C008 | __________ |
| §501(c) category assumption | C009–C015, C044 | __________ |
| Organizational and operational exempt-purpose requirements | C009, C013 | __________ |
| Public-interest and private-benefit analysis | C010–C011, C015 | __________ |
| Tailoring of counseling to consumer circumstances | C016 | __________ |
| Loan making; exact exception if relevant | C017 | __________ |
| Loan negotiation versus processing | C018 | __________ |
| Incidental credit-improvement activity | C019 | __________ |
| Separately stated credit-improvement fee | C020 | __________ |
| Counseling access despite inability to pay or DMP nonparticipation | C021 | __________ |
| Reasonable-fee policy | C022 | __________ |
| Inability-to-pay waiver predicate and policy | C023 | __________ |
| Percentage-based fee and state-law exception predicate | C024 | __________ |
| Public control of governing body | C025 | __________ |
| 20% voting-power numerator, denominator, and exclusions | C026, C028 | __________ |
| 49% voting-power numerator, denominator, and exclusions | C027–C028 | __________ |
| Ownership type, correct measurement base, covered activity, exception | C029–C032 | __________ |
| Referral receipts, referral payments, and lead/locator distinction | C033–C036 | __________ |
| Consumer contribution solicitation and relevant service period | C037–C038 | __________ |
| Restricted creditor DMP revenue classification | C039–C040 | __________ |
| Total-revenue denominator and same-period accounting | C041–C042 | __________ |
| Historical percentage-transition predicate | C043 | __________ |
| §501(c)(4) notification rule and unresolved mechanics | C044 | __________ |
| Specific authority for any attribution or aggregation | C045 | __________ |
| Related-business treatment distinguished from exemption | C046–C047 | __________ |
| Historical explanation not substituted for current statute | C048–C050, C055–C058 | __________ |
| Contract, creditor assent, separate approval, and remedies held apart | C051–C054 | __________ |
| Public-support ratios not substituted for §501(q) revenues | C059 | __________ |
| Remaining public-law question and permitted source route | Relevant branch B01–B20 | __________ |
User question / material subpart · Coverage status and reason · Claim / branch / source links · 31 data rows
| User question / material subpart | Coverage status and reason | Claim / branch / source links | Missing evidence or exact next investigation |
|---|---|---|---|
| 1 — Complete current §501(q), nested clauses and exceptions | Answered at the displayed October 20 cutoff. All of (q)(1)–(4) read. | C001, C004–C007, C016–C045; S001–S002. | No missing clause in the retrieved subsection. Later unclassified/session-law audit not completed. |
| 1 — Necessary §501(c)(3)/(4) baseline | Answered within focused scope. Both categories’ relevant text and general regulations read. | C008–C015, C057–C058; S001, S004. | Full exemption procedures, political-activity elections, and §504 consequences remain outside scope. |
| 1 — Substantial-purpose trigger | Partial for construction/application; generic rule answered. | C004–C006; B01; S001, S005. | No verified universal quantitative threshold; next inquiry is q-specific published generic interpretation. |
| 1 — Nonprofit form versus exemption | Answered. | C008; B02; S010, S004. | Actual form/status held; no provider search permitted. |
| 1 — Organization treatment versus consumer entitlement | Answered as a textual boundary; remedies excluded. | C051–C054; B15–B18; S001. | No complete private-enforcement/remedies analysis. |
| 1 — Source, amendments, effectiveness, transitions | Answered for enacted §1220 and relevant notes; broader history partial. | C001–C003, C043, C057, C060; S001–S003, S011–S012. | Newer §513 body remains a retrieval gap; complete later-history audit not asserted. |
| 2 — Educational/counseling/service conditions | Answered generically. | C005, C009, C016–C020, C048–C050; B04, B08–B09; S001, S004, S006–S009. | Actual methodology and purpose facts excluded. |
| 2 — Public accessibility | Answered for stated federal conditions; application excluded. | C005, C021–C023; B05–B06; S001, S005. | No imported national income threshold or universal DMP admission rule. |
| 2 — DMP design/implementation and assessment | Partial by design. Statutory tailoring and generic educational examples covered. | C007, C016, C047–C050; B04, B19; S001, S004, S008–S009. | No actual assessment, participation, distribution, completion, or contract investigation. |
| 2 — Ability to pay, waiver, fees, no refusal | Answered rule; predicate construction partial. | C021–C024; B06; S001, S005, S009 fn.434. | Exact inability-to-pay standard and any state-law allowance unresolved. |
| 2 — Governance, independence, private benefit | Answered text and distinct tests; application excluded. | C010–C011, C015, C025–C032; B11; S001, S004. | Actual voting/benefit facts held; generic affiliate/control construction may require further authority. |
| 2 — Prohibitions versus ceilings | Answered. | C017–C024, C026–C039; measurement section. | No numerical organizational illustration performed. |
| 2 — Contributions versus fees | Answered core distinction; unsolicited-receipt edge partial. | C037–C040; B07; S001, S005. | Further published interpretation needed for disputed characterization. |
| 2 — Origination/referrals/leads/repair/loan distinctions | Answered core clauses; processing/locator edges partial. | C017–C020, C033–C036; B08–B10; S001, S005, S009. | Need specific public guidance for an unresolved generic boundary, not transaction records. |
| 2 — Complete necessary official explanations | Answered within identified read bounds. | S005 PDF complete; S006–S008 complete available text; S009 complete relevant explanation. | No undisclosed portions or underlying case holdings treated as read. |
| 2 — Avoid invented national fee/concession/deadline/refund rights | Answered. | C051–C054; B17–B18. | Separate rights remain held rather than negated. |
| 3 — Complete material definitions | Answered. | C005, C007; S001 §501(q)(4). | Undefined accounting/affiliate terms remain explicitly unresolved. |
| 3 — Additional rules by §501(c) category | Answered. | C037–C044; comparison table; B03. | Current (c)(4) notice mechanics not fully traced. |
| 3 — Contribution/receipt/support ratios | Answered as to what §501(q) actually contains. | C037–C043, C059; S001, S005. | General public-support classification excluded; no substitution permitted. |
| 3 — Numerator, denominator, period, exclusions | Answered statutory bases; accounting details partial. | C026–C031, C039–C043; B12; equations. | Published authority needed for revenue recognition, custodial/mixed amounts, and any averaging claim. |
| 3 — Related organizations/aggregation | Partial. Express textual features identified; general attribution not established. | C045; B13; S001, S004. | Identify the precise applicable attribution/agency/consolidation authority. |
| 3 — Governance membership and exceptions | Answered. Voting power separated from membership shorthand; local employee-association language separately identified. | C014, C025–C031, C055; B11. | No actual membership or voting-rights data collected. |
| 3 — Special exceptions and transitions | Answered text; application excluded. | C003, C017, C024, C026–C031, C043, C057; B14. | Historical status and state-law predicates held. |
| 4 — Necessary official guidance/final regulations and status | Answered within read bounds. | S004–S012; C048–C050, C055–C058. | No q-specific comprehensive implementing regulation identified or claimed absent. |
| 4 — Actual dates/effectiveness/currentness distinctions | Partial only to stated limits. Dates and compilation labels recorded; broad later history not audited. | C001–C003, C043, C056–C057, C060; §1 and source table. | Newer §513 body; historical-ruling/interpretation later history; any material judicial-validity question. |
| 4 — Generic forms/instructions, optional/required role | Not triggered. No IRS blank form or form instructions were examined. | Source/read log; original worksheet §7. | Historical references to forms were not treated as present filing directions; no filing or identifier entry. |
| 4 — Recognition, creditor acceptance, bankruptcy approval, state authorization, contract | Answered separation; separate systems excluded. | C044, C051–C054; B15–B18. | All actual and separate-law predicates remain parent-held. |
| 5 — Provision-specific comparison and blank worksheet | Delivered visibly. | §§4–5 and 7. | Worksheet findings remain blank. |
| 5 — All requested qualitative branches | Delivered visibly and individually. | B01–B20, each with rule, claim/source, gap, adverse inference, next inquiry. | Actual application intentionally excluded. |
| 5 — Fully worked numerical illustration if justified | Omitted with reason. Not necessary; required inputs and legal accounting conventions are not established. | §5; B11–B14. | No invented data or calendar deadline. |
| 5 — Sources, claims, coverage, read/failure log, crosswalk, gaps, self-check | Delivered visibly. | §§2–3, 6, 8–10. | No download substitutes for the answer. |
Failure ID · Exact attempted URL · Observed result · 9 data rows
| Failure ID | Exact attempted URL | Observed result | Effect on findings |
|---|---|---|---|
| F001 | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title26-section501&num=0&edition=prelim | Fetch failed: 404 Not Found. | Resolved for substantive §501 reading through the publisher’s current-edition route and S001. |
| F002 | https://uscode.house.gov/us/usc/119-134/t26/s501/ and https://uscode.house.gov/us/usc/119-134/t26/s501 | Initial direct attempts: “not accessible via this tool.” | Later successful retrieval by following “Continue” from https://uscode.house.gov/us/usc/t26/s501/. Complete q reread in that version. |
| F003 | https://uscode.house.gov/view.xhtml?req=title26:section501&num=0&edition=prelim | “not accessible via this tool.” | Route failure retained; substantive content resolved by S001. |
| F004 | https://usc-cdn.house.gov/view.xhtml?req=granuleid:USC-prelim-title26-section501&num=0&edition=prelim | 400; Timeout fetching. | No claim based on this response; S001 supplies the text. |
| F005 | https://uscode.house.gov/us/usc/119-121/t26/s513/ | 404 Not Found. | Readable S003 used with its actual cutoff. |
| F006 | https://uscode.house.gov/view.xhtml?req=title26:section513&num=0&edition=prelim | “not accessible via this tool.” | No newer-body verification from this route. |
| F007 | https://uscode.house.gov/us/usc/119-134/t26/s513/ | Repeated direct attempts: “not accessible via this tool.” | Newer §513 body remains unresolved; classification-table check is separately bounded. |
| F008 | https://uscode.house.gov/us/usc/t26/s513/ | “not accessible via this tool.” | No current-edition redirect content obtained for §513. |
| F009 | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title26-section513&num=0&edition=prelim | Fetch failed: 404 Not Found. | Same unresolved newer-body limitation. |
Gap · What remains unresolved · Required permissible public-source inquiry · 8 data rows
| Gap | What remains unresolved | Required permissible public-source inquiry |
|---|---|---|
| G01 — Newer §513 body | The readable statutory body’s October 7 cutoff is older than the October 20 §501 compilation. | Retrieve the newer official §513 text; reconcile any relevant enacted amendments and effective clauses. The classification table alone does not close this gap. |
| G02 — Open-textured predicates | No universal numerical definition was verified for substantial purpose, incidental credit repair, reasonable fees, or inability to pay. | Locate a published Treasury/IRS interpretation specifically applying the relevant §501(q) clause. Do not substitute thresholds from another approval system. |
| G03 — Revenue accounting | Classification of custodial payments, mixed payments, accrual/cash timing, and other specific denominator questions is not supplied by the reviewed q text or short FAQ. | Identify published authority governing revenues for §501(q)(2)(A)(ii) and explain why any general accounting rule applies. |
| G04 — Related-party attribution | No express general aggregation/constructive-ownership formula appears in q. The meaning/application of affiliates and indirect financial benefit is not comprehensively defined there. | Identify the exact statute, regulation, or published IRS interpretation that makes an attribution rule applicable to the particular q measurement. |
| G05 — §501(c)(4) notification mechanics | The statutory obligation is established; a complete current procedural route and interaction with other general (c)(4) notice rules are not. | Review only current generic official instructions or published guidance addressing §501(q)(3) if that limited procedural question is later pursued. No application, identifier, or actual recognition inquiry. |
| G06 — Referral/locator boundary | The statute, IRS lead-list answer, and JCT locator footnote do not resolve every possible advertising arrangement. | Seek published generic IRS/Treasury treatment of the payment’s substance under §501(q)(1)(F). |
| G07 — Historical interpretive status and judicial limits | No complete later-history audit of the old rulings/CCA or independent opinion review was performed. The CCA discusses judicial limits surrounding educational methodology, but those discussions are not independently verified holdings here. | If necessary to decide a specific public-law construction, read the relevant published majority opinion and bounded later-history materials; no case-record or docket inquiry. Otherwise preserve the gap. |
| G08 — Actual application and consumer remedies | Every organization, governance, ownership, revenue, service, client, creditor, contract, recognition, authorization, and remedy predicate is held. | No factual investigation is authorized in this pass. Any future separate dimension requires its own defined public-law scope; missing evidence is not an adverse factual finding. |
Check · Result · 14 data rows
| Check | Result |
|---|---|
| Complete §501(q), including all nested paragraphs and material exceptions read | Yes, at the displayed October 20, 2026 cutoff. |
| Different §501(c)(3) and §501(c)(4) additions preserved | Yes. |
| Both board ceilings, different exclusions, voting-power units, and public control preserved | Yes. |
| Corporate voting, partnership profits, and trust/estate beneficial interests kept distinct | Yes. |
| Trust exception not silently extended to estates | Yes. |
| Aggregate creditor DMP revenue distinguished from total DMP fees, support, receipts, debt principal, and service counts | Yes; accounting gaps remain explicit. |
| Historical general transition distinguished from graduated revenue transition | Yes. |
| IRS summaries and older examples checked against statutory text | Yes; material simplifications identified. |
| Consumer-facing tax conditions distinguished from an independently established consumer remedy | Yes. |
| Source dates, legal status, read bounds, and failed retrievals disclosed | Yes. |
| No actual provider, person, account, roster, status database, filing, contact, purchase, or publication action | Yes. |
| No subagent, other research chat, prior Library foundation, or security/CAPTCHA workaround used | Yes. |
| No independent-review, unseen model-provenance, local-file, hash, or import claim | Yes. |
| Component, A034 parent, operational, or publication acceptance | None. |
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
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Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.
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conditionally reviewed currentness interpretation and application holds
Original saved Markdown SHA-256: 5f3b632fc622e8ca34bfada9379e5fece8db571244b174b104dc5bcc996156e4. Public formatting, private-reference removal and correction annotations are separate from that immutable original.