# sgosoftware.com — Scholarship Granting Organization (SGO) Infrastructure

> Purpose-built SaaS infrastructure for 501(c)(3) Scholarship Granting Organizations (SGOs) operating under the federal Section 25F Education Freedom Tax Credit (EFTC). Automates applicant eligibility verification, donor tax-credit contributions, state-segregated ledgers, and direct school disbursements with zero upfront licensing fees.

## Overview

sgosoftware.com provides end-to-end operational software for state-level and multi-state Scholarship Granting Organizations (SGOs). Built specifically to satisfy the strict requirements of proposed 26 CFR Part 1 (Internal Revenue Code § 25F) and state scholarship programs, the platform replaces manual spreadsheets and fragmented tools with a unified, auditable, multi-tenant system.

- **Primary Website**: https://sgosoftware.com
- **Core Portal**: https://sgosoftware.com/login
- **Platform Pricing**: Flat 3% technology fee on settled contributions. No upfront software fees, no monthly retainers, no per-application review fees.
- **Architecture**: Multi-tenant isolation with dedicated per-SGO tenant pools, isolated state-segregated account ledgers, and automated ACH disbursement rails.

## Regulatory Framework: IRC § 25F & Proposed Regulations

The platform enforces the statutory rules defined under proposed Treasury Regulations (§§ 1.25F-1 through 1.25F-4):

1. **IRS SGO Registration & Disclosure (§ 1.25F-4(b))**: Electronic registration capture including EIN, primary address, formation year, point-of-contact authorization, and mandatory IRC § 6103(c) public disclosure consent for irs.gov listing.
2. **Unique Donor Number (UDN) Generator (§ 1.25F-4(c))**: Algorithmic generation of permanent, IRS-formatted Unique Donor Numbers for taxpayers upon their first qualified contribution, maintained across tax years.
3. **Cash-Only Checkout & Digital Asset Blocking (§ 1.25F-1(a)(12))**: Strict cash/ACH/card rails in USD; automatic blocking of cryptocurrency and non-cash assets.
4. **Netting Consideration (§ 1.25F-1(a)(12))**: Automatic subtraction of fair market value of any goods or services provided to determine net qualified tax-credit amounts.
5. **Anti-Commingling & Segregated Bank Ledgers (§ 1.25F-3(b)(2))**: 100% of qualified scholarship contributions and credited interest are tracked in isolated Section 25F Segregated Account ledgers. Multistate SGOs maintain distinct ledgers for each covered state.
6. **90% Spending Engine (§ 1.25F-3(c)(4))**: Strict FIFO 2-year spending window where donations received in Year 1 must be disbursed as scholarships before the end of Year 2.
7. **85% Activity Safe Harbor (§ 1.25F-3(c)(2))**: Tracks entity-wide operations to ensure scholarship activities represent $\ge 85\%$ of total organizational activity.
8. **Student Household Income & AMGI Engine (§ 1.25F-3(c)(6))**: Verifies prior-calendar-year cash gross earnings against 300% of the Area Median Gross Income (AMGI / AMI) published by HUD/IRS, scaled by HUD family size multipliers (0.70 for 1 person to 1.32 for 8 persons, +0.08 per additional person).
9. **Categorical Safe Harbors**: Automated qualification paths for SNAP, TANF, WIC, Section 8, SSI award letters, Foster Care placements, and HUD Qualified Census Tract (QCT) special-needs safe harbors.
10. **Disqualified Persons & Relationship Graph (§ 1.25F-3(d))**: Enforces IRC § 4946 self-dealing prohibitions. Monitors substantial contributors (contributing $> \$5,000$ and $> 2\%$ of annual contributions) and maps familial relationships of officers and directors.
11. **Mandatory Award Priority Tiering (§ 1.25F-3(c)(5))**: Tier 1: Prior school year recipients; Tier 2: Siblings of prior recipients; Tier 3: New eligible applicants.
12. **Anti-Duplication & Coverdell Alignment (§ 1.25F-3(c)(8))**: Restricts total scholarships so aggregate funding does not exceed allowable Coverdell expenses under IRC § 530(b)(3)(A).
13. **Annual Operational Reporting (Form 990) & CPA Audit Package (§ 1.25F-4(d)-(e))**: Generates the 11-part Form 990 operational schedule and immutable SHA-256 hashed export packages for external CPA programmatic audits.

## Core Workflows

### 1. Applications & Household Intake
- **Custom Application Builder**: Dynamic JSON-schema form templates customized per SGO with immutable version locking for submitted applications.
- **Custody Questionnaire**: Resolves shared custody and alternating tax-year allocations in accordance with 24 CFR 5.100.
- **Sibling Priority Queue**: Automatic linking of siblings for multi-year retention and tier prioritization.

### 2. Donor Contributions & Tax Receipts
- **Federal $1,700 Credit Calculator**: Interactive estimator calculating projected federal tax liability based on filing status and gross income to verify credit benefit.
- **Irrevocable Designations**: Real-time donor allocation to specific participating schools, state general funds, or unlisted school write-in leads.
- **Timely Written Acknowledgments (§ 1.25F-4(c)(1))**: Digital delivery of IRS-compliant acknowledgments by January 31 following the contribution year.
- **Annual IRS Batch Transmission (§ 1.25F-4(c)(2))**: Formatted data extraction for annual February 28 reporting.

### 3. Disbursements & School Partnerships
- **Direct School & Vendor Payments**: Tuition, fees, room, and board paid directly to verified educational institutions.
- **Child Award Ledger Wallets**: Dedicated ledger sub-nodes representing each child's award under the school account for absolute financial traceability.
- **School Agreement CMS**: In-platform authoring and digital signature capture of institutional participation agreements with timestamp and audit logs.

## Pricing & Economics

| Feature | SGO Software | Traditional Vendor |
| :--- | :--- | :--- |
| **Pricing Model** | **Flat 3% on donations** | \$10,000–\$50,000/year license + 3-5% transaction fees |
| **Upfront Setup Costs** | **\$0** | \$5,000–\$25,000 onboarding fee |
| **Per-Application Review Fee** | **\$0 (Included)** | \$15–\$35 per student application |
| **ACH Direct Rails** | **Automated, integrated** | Manual batch CSV exports |
| **IRS § 25F Ledgers** | **Automated 90%/7%/3% splits** | Manual accounting adjustments |
| **Form 990 Audit Package** | **1-Click export with SHA-256 hashes** | Weeks of manual CPA reconciliation |

## Technical Architecture & Developer Standards

- **Frontend**: Angular (v20+) with reactive signals, OnPush change detection, standalone architecture, and comprehensive Playwright end-to-end test automation (`data-testid`).
- **Backend**: Serverless Cloud Functions (Node.js/TypeScript) with modular services (`PaymentLedgerService`, `BankVerificationService`, `ActionCreditsService`, `FederalTaxCalculator`).
- **Database**: Cloud Firestore with multi-tenant subcollection isolation (`platform/`, `private/`, `public/`) and strict security rules.
- **Identity**: Multi-tenant Google Cloud Identity Platform (GCIP) with tenant context resolution by subdomain and custom domain.
- **Zero Vendor Leakage**: Clean abstraction boundaries preventing third-party vendor names and proprietary tokens from appearing in client UI or public logs.

## Links & Documentation

- [Home Page](https://sgosoftware.com/)
- [SGO Software Overview](https://sgosoftware.com/sgo-software)
- [How It Works](https://sgosoftware.com/#how-it-works)
- [Pricing Structure](https://sgosoftware.com/#pricing)
- [Founder & Engineering Profile](https://sgosoftware.com/#about)
- [Direct Contact Form](https://sgosoftware.com/#contact)
- [Full LLM Context & Specification](https://sgosoftware.com/llms-full.txt)