# sgosoftware.com — Comprehensive Technical & Regulatory Documentation for LLMs

> Complete technical specification, regulatory compliance blueprint, and operational architecture for sgosoftware.com — the multi-tenant SaaS platform for Scholarship Granting Organizations (SGOs) under IRC § 25F and the federal Education Freedom Tax Credit.

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## 1. Executive Summary & Mission

sgosoftware.com provides end-to-end, multi-tenant cloud infrastructure for 501(c)(3) Scholarship Granting Organizations (SGOs). Built to eliminate the friction, security risks, and exorbitant software licensing costs associated with legacy scholarship portals, the platform automates:
- Donor contributions, tax receipting, and statutory reporting under Internal Revenue Code (IRC) § 25F.
- Student household income verification against HUD Area Median Gross Income (AMGI) thresholds.
- Direct automated ACH disbursements to verified schools and educational vendors.
- Real-time double-entry ledger accounting with segregated state accounts and a 90% spending engine.
- Form 990 operational reporting and cryptographic CPA audit trail export packages.

### Platform Economics
- **Pricing**: Transparent flat 3% technology fee on settled donor contributions.
- **Upfront Fees**: $0.
- **Recurring Monthly Retainers**: $0.
- **Per-Application Review Fees**: $0.
- **Founder**: Joseph Friedman, former Google engineer specializing in distributed systems, double-entry financial ledgers, and institutional compliance architectures.

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## 2. Statutory & Regulatory Architecture (IRC § 25F)

The platform is engineered around the statutory mandates of the federal Education Freedom Tax Credit and proposed Treasury Regulations 26 CFR Part 1 (§§ 1.25F-1 through 1.25F-4).

### Module 1: IRS Electronic Registration & Identity Engine (§ 1.25F-4(b))
- Mandatory electronic registration workflow capturing legal entity name, Employer Identification Number (EIN), registered physical address, formation year, and taxable year.
- Point-of-contact verification and Form 2848 Power of Attorney validation.
- Mandatory IRC § 6103(c) Public Disclosure Authorization checkbox allowing the IRS to publish the SGO on irs.gov. Without this consent, taxpayers cannot claim Section 25F credits.
- Algorithmic generation of permanent, uniform Unique Donor Numbers (UDNs) assigned to each donor upon their first contribution and maintained across tax years.

### Module 2: Contribution Checkout, Irrevocable Designations & Acknowledgments (§§ 1.25F-1(a)(12), 1.25F-4(c))
- Cash-Only Payment Rails: Accepts ACH bank debit, physical currency, check, and credit/debit cards in U.S. Dollars.
- Automated Blocking of Digital Assets: Digital assets (cryptocurrency, tokens, NFTs) are rejected at checkout.
- Netting Consideration: Subtracts the fair market value of any goods or services provided to the donor to calculate the true qualified contribution amount.
- Multistate Allocation Routing: Enables donors to designate funds to a specific covered state or participating school; funds automatically route to the corresponding segregated ledger.
- Timely Written Acknowledgments (§ 1.25F-4(c)(1)): Digital delivery of compliant acknowledgments to donors by January 31 following the contribution year, containing SGO EIN, UDN, aggregate annual contributions, goods/services disclosures, and electronic consent timestamps.
- Annual IRS Batch Contribution Reporting (§ 1.25F-4(c)(2)): Compiles annual donor contribution data for secure transmission to the IRS by February 28.

### Module 3: Anti-Commingling Ledger, 90% Spending & 85% Safe Harbor (§ 1.25F-3(b)(2), § 1.25F-3(c))
- Isolated Segregated Bank Account Ledgers: 100% of qualified contributions and credited interest are tracked in an isolated Section 25F Segregated Account ledger. Multistate SGOs maintain distinct ledgers for each covered state.
- 90% Income Spending Engine: Evaluates income using the cash receipts method. Enforces a 2-year First-In, First-Out (FIFO) spending window: qualified contributions received in Year 1 must be disbursed as scholarships before the final day of Year 2.
- Returned Payment Ledger: Returned school or vendor payments are treated as new income in the year returned, extending their spending deadline to the end of the following year.
- 85% Activity Safe Harbor Ledger (§ 1.25F-3(c)(2)): If scholarship activities represent $\ge 85\%$ of total organizational activity, the 90% spending requirement applies exclusively to the Section 25F Segregated Account rather than total entity gross receipts.

### Module 4: Student Household Income Verification & AMGI Engine (§ 1.25F-3(c)(6))
- Prior Calendar Year Window: Household income is evaluated strictly on the calendar year immediately preceding the application date.
- Household Definition (24 CFR 5.100): Aggregates all individuals residing together in the student's primary household.
- Shared Custody Allocation: Evaluates the household where the student resides longest, or the higher-earning household if time is split equally.
- Cash Gross Income Standard (Modified 24 CFR 5.609): Measures gross cash earnings (W-2 Box 1/5, Form 1040 Line 1z, pay stubs, cash child support, nontaxable alimony). Excludes non-cash items, Section 8 vouchers, and imputed returns on assets.
- HUD/IRS AMGI & Family Size Multiplier Engine:
  - Integrates annual HUD/IRS Area Median Gross Income tables.
  - Multipliers: 0.70 (1 person), 0.80 (2), 0.90 (3), 1.00 (4), 1.08 (5), 1.16 (6), 1.24 (7), 1.32 (8), +0.08 for each additional member.
  - Statutory Ceiling: Household Gross Income $\le 300\% \times \text{AMGI} \times \text{Multiplier}$.
- Categorical Safe Harbors: Immediate qualification upon verifying active 12-month award letters for SNAP, TANF, WIC, Section 8, SSI, or Foster Care court placement.
- Tutoring & Special Needs Safe Harbor: Validates HUD Qualified Census Tract (QCT) locations ($\ge 80\%$ QCT residence) for tutoring/special-needs applicants with independent diagnostician documentation.

### Module 5: Disqualified Persons & Relationship Graph (§ 1.25F-3(d))
- Substantial Contributor Monitoring: Flags any donor contributing $> \$5,000$ and $> 2\%$ of total annual contributions. Evaluates at both organizational and individual state-segregated account levels. Combines spousal donations.
- Duration Lock: Substantial contributor status persists for the contribution year plus the succeeding taxable year.
- Relationship Graphing: Maps officers, directors, trustees, selection committee members, substantial contributors, and their family members (spouses, ancestors, descendants, siblings, stepchildren, and adopted children) to prevent self-dealing.

### Module 6: Award Prioritization, State Residency & Expense Controls (§ 1.25F-3(c)(5), (7), (8))
- Mandatory Priority Tiers:
  - Tier 1: Prior school year scholarship recipients.
  - Tier 2: Siblings of prior recipients.
  - Tier 3: New eligible applicants.
- State Residency Verification: Validates legal student residence in the covered state under state law, with exceptions for military dependents and Indian Lands dependents.
- Direct School Payments: Disbursements paid directly to accredited schools for tuition, fees, room, and board.
- Child Award Ledger Wallets: Dedicated sub-nodes under the institutional account ensuring individual student attribution.
- Anti-Duplication Engine: Cross-checks student awards to ensure total funding does not exceed Coverdell educational expenses under IRC § 530(b)(3)(A).

### Module 7: Annual Operational Metrics (Form 990) & CPA Audit Engine (§ 1.25F-4(d)-(e))
- 11-Part Form 990 Attachment Generator: Automates mandatory annual reporting metrics (applicant counts, awards, averages, school counts, Coverdell expense breakdowns, in-state spending ratios, and spending percentages).
- Independent CPA Audit Package: Generates immutable, timestamped export packages with SHA-256 hashed document snapshots, ledger logs, and priority decision audit trails.

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## 3. System Architecture & Engineering Principles

### Multi-Tenancy & Identity
- SGO as Primary Tenant: Every data document, user, ledger entry, and configuration exists strictly scoped under `/tenants/{tenantId}`.
- Google Cloud Identity Platform (GCIP): Multi-tenant user pools ensuring complete isolation across administrative roles, donors, schools, and guardians.
- Subdomain & Custom Domain Routing: Automatic routing by subdomain (`tenant.sgosoftware.com`) and custom vanity domains (`giving.myorg.org`) with root caching in `/domain_index/{hostname}`.

### Zero Vendor Leakage
- Agnostic Service Adapters: All third-party payment gateways, banking rails, and financial aggregators are wrapped in generic interfaces (`PaymentLedgerService`, `BankVerificationService`).
- No vendor proper nouns appear in client-facing UI, documentation, error payloads, or logs.

### Double-Entry Ledgers & Automated Sweeps
- Donation Ingestion: Donor ACH debit $\to$ split 90% (Segregated State Scholarship Wallet) / 7% (SGO Operating Wallet) / 3% (Platform Wallet) $\to$ automated ACH sweep to respective bank accounts.
- Scholarship Disbursement: SGO Segregated Account $\to$ SGO State Wallet $\to$ School Account $\to$ Child Award Ledger Wallet $\to$ School Bank Payout.

### Frontend Technology Stack
- Angular v20+ with Signal-based reactive state management, OnPush change detection, standalone components, and modern control flow (`@if`, `@for`).
- Universal abstract components: `AbstractWizardComponent`, `ChecklistDashboardComponent`.
- Complete Playwright end-to-end testing coverage using standardized `data-testid` attributes.

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## 4. Frequently Asked Questions (FAQs)

### What is an SGO?
A Scholarship Granting Organization (SGO) is a state-recognized 501(c)(3) tax-exempt non-profit organization that receives contributions from taxpayers and distributes scholarship grants to eligible elementary and secondary school students.

### What is the Section 25F Education Freedom Tax Credit?
Section 25F of the Internal Revenue Code provides a federal dollar-for-dollar tax credit up to $1,700 for individual taxpayers making qualified contributions to eligible SGOs.

### How does sgosoftware.com charge for its platform?
We charge a simple, transparent 3% technology fee deducted automatically from settled contributions. There are no setup fees, no monthly software subscriptions, and no per-student application processing charges.

### How does the platform verify household income?
The platform calculates prior-calendar-year cash gross income according to 24 CFR 5.609 standards and compares it to 300% of the HUD Area Median Gross Income (AMGI) for the student's county and family size. Categorical safe harbors (SNAP, TANF, SSI, WIC, Section 8, Foster Care) provide instant auto-approval.

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## 5. Contact & Inquiries

- **General Inquiries & Walkthroughs**: https://sgosoftware.com/#contact
- **Launch Notification Waitlist**: https://sgosoftware.com (Click "Create Account" in header)
- **Portal Sign In**: https://sgosoftware.com/login
- **Founder**: Joseph Friedman (Direct inquiries via the website contact form)