# 06 — Market Evidence, Comparables, and Regulatory Constraints

**Venture under study:** a funding-readiness and capital-progression system, delivered first as a cohort-based shared funding office for 5–8 NYC nonprofits (basic needs / education / community development / technology access), later productized as software plus human guidance.

**Research date:** 2026-09-23. All figures below were checked against the cited source on that date unless marked otherwise. "Not stated" means the source did not publish the figure; nothing is estimated. Outcome claims from vendors are labeled **[marketing]**. Nothing here is legal advice.

---

## PART 1 — Problem evidence (the problem is real, material, under-served)

### 1.1 Problem evidence table

| # | Claim | Figure | Source | Date | Applicability to 5–8 small NYC nonprofits |
|---|---|---|---|---|---|
| 1 | Most nonprofits run thin on cash | 52% have ≤3 months cash on hand; 18% have ≤1 month | Nonprofit Finance Fund, 2025 State of the Nonprofit Sector Survey (n=2,206) — https://nff.org/state-of-the-nonprofit-sector-survey/2025-state-of-the-survey-nonprofit-sector-survey/ | Survey released 2025 (full-results PDF dated Oct 2025) | Direct: cohort members are likely in the ≤3-month group; cash-flow forecasting and reserve-building belong in "readiness" |
| 2 | Deficits at a 10-year high | 36% ended 2024 with an operating deficit — highest in 10 years of NFF survey data | NFF 2025 survey (same) | 2025 | Direct |
| 3 | Demand outrunning capacity | 85% expect service demand to increase in 2025; 63% expanded programs in 2024 | NFF 2025 survey (same) | 2025 | Direct for basic-needs orgs |
| 4 | Government funding expected to shrink | 84% of respondents with government funding expect cuts | NFF 2025 survey (same) | 2025 | Direct: diversification away from government revenue is the core "capital progression" problem |
| 5 | Wage pressure | Only 41% can pay all full-time staff a living wage; 86% report inflation cost impact | NFF 2025 survey (same) | 2025 | Indirect: capacity for in-house development staff is constrained |
| 6 | NYC: government pays late, badly | 32% of NYC respondents paid >90 days late; only 19% paid on time; average first payment 6.5 months after contract start | NFF NYC brief, "NYC Nonprofits are Enduring Under Strain…" — https://nff.org/insights/survey-nyc-nonprofits-are-enduring-under-strain-of-funding-pullbacks-and-severe-government-payment-delays/ | 2025-09-17 | Direct: NYC-specific; late payment forces bridge borrowing |
| 7 | NYC: coping with delays | 45% took on debt; 29% delayed vendor payments; 29% drew on savings; 12% paused/reduced services | NFF NYC brief (same) | 2025-09-17 | Direct |
| 8 | NYC: demand vs capacity | 80% saw demand rise 2023→2024; 52% do not expect to meet demand in 2025; >80% report difficulty raising funds that cover full costs | NFF NYC brief (same) | 2025-09-17 | Direct |
| 9 | NYC: contract registration chronically late | 90.7% of human-services contracts registered late in FY24 (88.5% in FY23); 2,508 contracts worth $4.6B awaiting registration past start date | NYC Comptroller, "Nonprofit, Nonpayment" follow-up — https://comptroller.nyc.gov/newsroom/comptroller-lander-spotlights-nonprofit-payment-delays-in-follow-up-report-launches-audits-of-3-agencies-with-worst-delays | 2025-04-29 | Direct for any cohort member with City contracts |
| 10 | NYC: unpaid invoice backlog | ~4,000 nonprofit invoices worth $861M pending; ≥$675M billed for services from 2024 or earlier; active nonprofit contracts eligible for up to $4.9B additional payment (as of 2025-04-15) | NYC Comptroller (same) | 2025-04-29 | Direct |
| 11 | NYC: first-payment lag by agency | 7 of 8 agencies took >200 days to first payment; HPD averaged 765 days | NYC Comptroller (same) | 2025-04-29 | Direct |
| 12 | NYC: FY24 late registration, all human-services contracts | 9 in 10 human-services contracts arrive late to Comptroller; nearly 40% (1,387) registered >1 year late | NYC Comptroller, "9-out-10 Human Service Contracts Arrive Late" — https://comptroller.nyc.gov/newsroom/9-out-10-human-service-contracts-arrive-late-to-comptroller-for-review/ | FY24 data (published 2024–25) | Direct |
| 13 | NYC: live transparency now exists | Late Contracts Dashboard (data FY2011–present) launched after Comptroller's early-2026 nonprofit roundtables; live data via Checkbook NYC | NYC Comptroller — https://comptroller.nyc.gov/services/for-the-public/late-contracts-dashboard/ | 2026 | Useful data feed for a readiness/cash-flow product |
| 14 | NYS: state contracts to nonprofits also late | 76% of NFP contracts (5,286 of ~6,900) processed after start/renewal date in CY2025 (78% in 2024); 14 agencies (47%) had 100% late; 11 agencies paid $379,544 prompt-contracting interest on 430 contracts; 2,810 potentially interest-eligible contracts got no interest | NYS Comptroller, 2025 Not-for-Profit Prompt Contracting Annual Report — https://www.osc.ny.gov/files/state-agencies/contracts/2025/pdf/prompt-contracting-report-2025.pdf | May 2026 | Direct for cohort members with State contracts; interest recovery is a concrete "capital progression" lever |
| 15 | NYS nonprofit sector scale | 33,536 NY nonprofits; 1.3M jobs (2022), >1 in 6 private-sector jobs; wages $96.8B; nearly half of nonprofit jobs in NYC; >56% of 2023 state contracts processed late | NYS Comptroller DiNapoli, nonprofit industry report — https://www.osc.ny.gov/press/releases/2025/01/dinapoli-releases-report-nonprofit-industry | 2025-01-08 | Market sizing context |
| 16 | NYS: providers owed money | 65% of NY nonprofits concerned about funding basic operations; 1 in 3 with state contracts owed for services already delivered; ~$650M owed | HSC + NY Council of Nonprofits survey via Times Union / NY Senate — https://www.nysenate.gov/newsroom/in-the-news/2025/shelley-b-mayer/most-ny-nonprofits-have-funding-concerns-slow-state | 2025-05-21 | Direct |
| 17 | NYC federal exposure | 21 surveyed NYC nonprofits (combined $2.3B budgets) average 29% federal revenue ($678M); AmeriCorps dismantling eliminated pay for >1,200 NYC nonprofit workers; El Puente laid off 20 staff (20%) after $3.1M EPA grant cancellation; SAGE lost $3M (14% of budget) | Center for an Urban Future, "NYC's Safety Net on the Brink" — https://nycfuture.org/research/nycs-safety-net-on-the-brink | Dec 2025 | Direct; CUF recommends a NYC Nonprofit Stabilization Fund and pro bono financial services |
| 18 | National: 2025 federal disruption | One-third of nonprofits had ≥1 government funding disruption in H1 2025; 21% lost government funding; 27% had delays/freezes; 6% got stop-work orders; disrupted orgs relied on government for 42% of revenue vs 28% average; 29% of disrupted orgs cut staff | Urban Institute, "How Government Funding Disruptions Affected Nonprofits in Early 2025" — https://www.urban.org/research/publication/how-government-funding-disruptions-affected-nonprofits-early-2025 | 2025-10-07 | Direct |
| 19 | National: dependence on government grants | >80,000 nonprofits (~1/3 of full-990 filers) report government grants; $304B (2021) → $294B (2022) → $240B (2023); in 2023 no congressional district existed where grantee nonprofits could cover expenses without them; 60–86% at risk across states | Urban Institute, "What Is the Financial Risk of Nonprofits Losing Government Grants?" — https://www.urban.org/research/publication/what-financial-risk-nonprofits-losing-government-grants | 2026-03-23 | Direct; NY state-level value available only via the interactive map (not extracted) |
| 20 | National: risk magnitude | 60–80% of government grantees could not cover expenses without the grants; median grantee runs 9% surplus with grants, 13% deficit without; ~1/3 rely on government for >50% of revenue | Urban Institute Urban Wire / Candid–Urban joint analysis — https://www.urban.org/urban-wire/government-funding-cuts-put-nonprofits-risk-across-nation ; https://candid.org/blogs/how-losing-government-funding-impacts-nonprofits-candid-urban-institute-data/ | 2025 | Direct |
| 21 | Giving is growing in dollars, not breadth | Total US giving $617.20B in 2025 (+5.7%; +3.0% real). Individuals $394.2B (64%, +4.1%); foundations $117.15B (19%, +5.7%); bequests $62.19B (+19.7%); corporations $43.67B (7%, +3.1%). Human services $99.50B (+5.3%); education $92.01B (+11.7%) | Giving USA 2026 — https://givingusa.org/giving-usa-charitable-giving-rose-to-617-20-billion-in-2025-surpassing-the-600-billion-mark-for-the-first-time/ | June 2026 | Foundations are ~19% of giving but the dominant "grant" pool for small orgs; individuals still 64% — board/individual giving cannot be ignored |
| 22 | Donor base shrinking, retention weak | Q1 2026: dollars +4.3% YoY, donor count −0.8% (improved from −2.3%); a retention rate reported flat at 18.0% (2024 high 18.2%) — FEP's Q4 2025 overall retention was 43.3%, so the 18.0% figure is consistent with new-donor retention, not overall (see row A24); retention fell in Small, Midsize, Major, Supersize segments; only Micro improved; donors giving 7+ times retained at 88.1%; 15,700 orgs / 3.2M donors / $3.5B analyzed | Fundraising Effectiveness Project Q1 2026 via AFP — https://afpglobal.org/news/fundraising-effectiveness-project-reports-easing-donor-losses-q1-2026-new-data-shows-growth ; https://publications.fepreports.org/ | 2026 | Direct: recurring/repeat-donor conversion is where retention lives; new-donor and repeat-donor retention splits not stated in the Q1 2026 summary |
| 23 | Grant volume drives grant success | 87% of respondents submitted ≥1 application in 2025; 90.8% of those won ≥1 award; 1 application → 64.5% award rate, 2 → 76.6%, more → up to 99.4%; median total grant funding $200,000; median largest government award $240,000; median largest federal award $500,000 | GrantStation, 2026 State of Grantseeking Report — https://grantstation.com/sites/default/files/imageLibrary/SoG/2026/2026%20State%20of%20Grantseeking%20Report.pdf | 2026 | Direct: "submit more, better-targeted applications" is the operating logic of a shared funding office |
| 24 | Small orgs win small | Median largest individual awards ranged from $7,750 for small organizations upward with budget size; 52.3% of respondents had budgets <$250k in one segment | GrantStation 2026 (same) | 2026 | Direct: cohort orgs are in the small-award bands |
| 25 | Award rates by funder type | Private foundation grants had the highest reported award rate (69.4%), local government 68.2%, federal 49.6% | GrantStation 2026 (same) | 2026 | Direct |
| 26 | Collaboration is rare | 68.3% did not participate in collaborative grantseeking in 2025 | GrantStation 2026 (same) | 2026 | Direct: a cohort model is differentiated simply by existing |
| 27 | Federal funding reach | 34% regularly receive federal funding; 32.4% received it in 2025; 41% reported increased indirect/administrative costs in 2025 | GrantStation 2026 (same) | 2026 | Indirect |
| 28 | Effort per application | Most respondents said their largest government award took ≤5 days of total effort (research, design, writing, submission, reporting); largest non-government award ≤3 days | GrantStation 2026 (same) | 2026 | Contextual; self-reported and skews toward established orgs (>half ≥26 years old) |
| 29 | Effort per application (secondary) | Federal applications 80–200 hours; relationship-based ("existing funder") success ~80% vs cold applications 30–40%; 61% of orgs rely on 1–2 people for grants | Grantboost roundup citing Submittable and GrantStation — https://www.grantboost.io/blog/grant-success-rate-statistics/ | 2026-07-07 | Secondary source; treat as indicative, not verified at origin |
| 30 | 2025 GrantStation baseline | 39% regularly receive federal funding; 36.1% received it in 2024; median largest government award $300,000; median largest federal award $516,800; small orgs' median total awards $24,000 | GrantStation 2025 Key Findings — https://grantstation.com/sites/default/files/imageLibrary/SoG/2025/2025%20State%20of%20Grantseeking%20Report%20Key%20Findings.pdf | 2025 | Shows federal reach falling 39%→34% in one year |
| 31 | NYC structural fragility | ~10% of NYC nonprofits insolvent (18% in health & human services); up to 40% have virtually no cash reserves | SeaChange Capital Partners / Oliver Wyman, "Risk Management for Nonprofits" (page now returns HTTP 410; figure from secondary references) | Original study 2016; not re-verified live | Older but widely cited NYC baseline; label as dated |
| 32 | Board giving benchmarks | Not verified live this session (BoardSource Leading with Intent) | — | — | Not stated |
| 33 | Share of nonprofits under $500k / $1M | Not verified live this session (Independent Sector / NCCS) | — | — | Not stated; GrantStation 2026 respondent mix (52.3% <$250k in one cohort) is a proxy only |

### 1.2 Additional evidence from parallel research (Part 1 agent)

Parallel verification pass (same date). Rows overlap with 1.1 where both passes hit the same source; differences are noted rather than reconciled silently.

| # | Claim | Figure | Source | Date | Applicability |
|---|---|---|---|---|---|
| A1 | NFF 2025: cash on hand | 52% have ≤3 months cash; 18% ≤1 month; 62% of respondents have budgets <$2M; 67% primarily serve lower-income people | NFF 2025 exec summary — https://nff.org/wp-content/uploads/NFF-2025-Survey-Executive-Summary-1.pdf ; https://nff.org/insights/survey-us-nonprofits-at-critical-point-as-funding-for-community-needs-falters/ | Released 2025-06-17 (n=2,206; FY2024 data) | High |
| A2 | NFF 2025: late government payment (national) | Among respondents with government funding, 55% paid late; 11% report average delays >90 days; >70% received government money in 2024; 45% had federal grants/contracts in FY24 | NFF 2025 exec summary | June 2025 | National baseline; NYC (row A29) far worse |
| A3 | NFF 2025: deficits | 36% ended 2024 in deficit (10-year high); repeat respondents 37% (2024) vs 13% (2021) | NFF 2025 | June 2025 | High |
| A4 | NFF 2025: full cost / indirect | 85% expect demand up; 81% say raising funds that cover full costs is a challenge; 70% can charge an indirect rate of ≤10% | NFF 2025 | June 2025 | High for City/State contractors |
| A5 | NFF 2025: revenue concentration | 88% receive individual donations but only 35% list them as a top-2 source; 41% list foundation grants as top source; 13% corporate | Independent Sector Health of Sector 2025 citing NFF — https://healthysector.org/economy-finance/ | Oct–Dec 2025 | Medium-high |
| A6 | No NFF 2026 edition | NFF site lists 2025, 2022, 2018 editions only | https://nff.org/state-of-the-nonprofit-sector-survey/ | Checked 2026-09-23 | Use 2025 |
| A7 | Urban: share receiving government funding | 2 in 3 nonprofits received ≥1 government grant/contract in 2023; average ~25% of revenue from government; ~2 in 10 get >50%; **New York: 75% received government grants/contracts** | Urban Institute data tables, "Government Grants and Contracts for Nonprofits in 2023" — https://www.urban.org/sites/default/files/2025-02/Government%20Grants%20and%20Contracts%20for%20Nonprofits%20in%202023_Data%20Tables%20from%20Nonprofit%20Trends%20and%20Study_0.pdf | Feb 2025 (n=2,539; orgs ≥$50K expenses) | High for NY |
| A8 | Urban: at risk without government grants (national) | 67.35% of 103,475 990 filers reporting government grants would have negative operating surplus without them; median surplus 9.05% with vs −12.83% without; $267.7B total | Urban factsheets — https://apps.urban.org/features/nonprofit-52-factsheets-map-drop-sheet-2025/ | 2025-02-21 (TY2021); updated 2026-03-23 (60–86% across states) | High; 990 filers only (>$200K revenue) |
| A9 | Urban: **New York** at-risk figure | 69.53% of 8,743 NY government-grant-receiving 990 filers at risk; $29.72B in government grants; median surplus 8.36% with vs −12.97% without | Urban NY factsheet — https://apps.urban.org/features/nonprofit-52-factsheets-map-drop-sheet-2025/factsheets/new-york.html | Feb 2025 (TY2021) | High; NY-specific |
| A10 | Urban: 2025 disruptions | 33% disrupted in first 4–6 months of 2025 (21% lost funding, 27% delay/freeze, 6% stop-work); disrupted orgs 42% government revenue vs 28% avg; 29% of disrupted cut staff (15% overall) | https://www.urban.org/research/publication/how-government-funding-disruptions-affected-nonprofits-early-2025 | 2025-10-07 (n=2,737) | High; very small orgs excluded |
| A11 | Candid/Urban: poverty-serving orgs hit harder | 25% of nonprofits serving people below FPL lost government funding vs 15% of others; 31% vs 23% had delays/freezes; 18% vs 8% reduced staff | https://candid.org/blogs/nonprofits-serving-people-living-in-poverty-face-significant-challenges-2025/ | 2025 | Very high for basic-needs orgs |
| A12 | Independent Sector 2025 annual review | 1.9M registered nonprofits; 81% struggled to cover costs; 36% deficit; 32% <3 months cash; 68% expect demand up but only 31% expanding people served; 37% received federal funding in 2024; 12% of orgs <$250K offer health insurance vs 67% overall | https://healthysector.org/wp-content/uploads/sites/43/2025/12/Independent-Sector-Health-of-the-Nonprofit-Sector-Report-2025.pdf | 2025-12-04 | High; no 2026 edition found |
| A13 | NCCS: share of small public charities | 66.9% of reporting public charities had <$500K expenses (210,670 orgs), <2% of total spending; orgs ≥$10M were 5.3% of charities but ~87% of spending | Urban NCCS, Nonprofit Sector in Brief 2018 — https://urbaninstitute.github.io/nccs-legacy/briefs/sector-brief-2018 | Dec 2018 (2015 data; last narrative edition) | Medium; under-$1M share not stated |
| A14 | Candid: count and size | 1,935,344 registered US nonprofits; nearly 60% are very small (990-N filers, budgets <$50K) | https://candid.org/impact-insights/us-social-sector/organizations/ ; https://candid.org/blogs/data-insights-very-small-nonprofits-make-up-majority-us-nonprofits/ | 2023 BMF; blog 2025-05-01 | High |
| A15 | Candid: cash runway without government grants | ~19% of grantees (>14,000 orgs) have ≤3 months runway; ~31% ≤6 months; ~2/3 would run deficits; **in NY >91,000 people work at human-services nonprofits with ≤3-month runway** | https://candid.org/blogs/how-long-nonprofits-cash-runway-can-survive-without-government-grants/ | 2025-05-07 | High; NY figure directly relevant |
| A16 | Candid 2026: instability | 39% of leaders reported a 2025 deficit (22% in 2022); 36% reduced federal and 34% reduced state/local funding since Jan 2025; 73% saw demand up; ~60% say foundation grants harder to secure; >40% considering drawing reserves | https://candid.org/blogs/nonprofit-financial-instability/ | 2026-05-18 | High |
| A17 | Giving USA 2026 | $617.20B (+5.7%; +3.0% real); Individuals $394.2B (64%); Foundations $117.15B (19%); Bequests $62.19B (10%, +19.7%); Corporations $43.67B (7%); Human services $99.50B (+5.3%); Education $92.01B (+11.7%); Public-society benefit $72.06B (+11.6%) | https://givingusa.org/giving-usa-charitable-giving-rose-to-617-20-billion-in-2025-surpassing-the-600-billion-mark-for-the-first-time/ | Released 2026-06-23 | Medium; growth concentrated in bequests |
| A18 | GrantStation 2026: award rates | 87% applied; 90.8% of applicants won ≥1 award; 64.5% (1 application), 76.6% (2), 89.4% (3–5), 99.4% (>30) | 2026 report PDF (see 1.1 row 23) | Survey March 2026, n=1,354 | High; "award rate" = won at least one grant, not per-application |
| A19 | GrantStation 2026: award sizes | Median largest award $90,000 overall; small orgs (<$100K budget) $7,750; median total awards $10,250 for small orgs; median largest government award $240,000 vs $50,000 non-government; federal $500,000 | same | 2026 | Small/medium tiers = 54.8% of respondents |
| A20 | GrantStation 2026: effort and staffing | 59.1% had only 1–2 people on largest award; 24.8% used de minimis indirect rate; 21.4% waived indirect; lack of time/staff top obstacle (17%) | same | 2026 | High; % using consultants not stated |
| A21 | Instrumentl win-rate benchmarks | Typical nonprofit ~1 in 7 (~14%); Instrumentl users 34–40% [vendor claim]; by funder type (2021–23 platform data): state/local 52%, private foundations 30%, associations 28%, federal 25%, corporate 22% | https://www.instrumentl.com/blog/how-to-calculate-grant-win-rate ; https://www.instrumentl.com/blog/grant-funder-success-rates | 2026-05-07; 2024-09-16 | Medium (vendor, self-selected); no new-vs-repeat dataset published |
| A22 | Hours per application (trade estimates) | Foundation 15–20 h vs federal 100+ h; 41% of grant writers spend 10–20 h per application, 21.7% <10, 6.5% 40+; practitioner: 10–20 foundation / 40–60 state / 100–150 federal | https://www.instrumentl.com/blog/grant-statistics-and-trends ; https://grantwritingandfunding.com/how-long-does-it-really-take-to-write-a-grant/ | 2025 | Medium; no peer-reviewed figure |
| A23 | GPA 2024 Compensation & Benefits | Grant professionals write mean 30.1 (median 20) proposals/yr; 42% of time writing, 30% managing; government = 50% of proposals (federal 24%, state 19%, local 7%), foundations 38%, corporate 9% | https://cdn.ymaws.com/grantprofessionals.org/resource/resmgr/publications/salary_surveys/gpa_2024_compensation_and_be.pdf | 2024 | Medium |
| A24 | FEP Q4 2025 (full-year 2025) | Dollars +5.0%; donors −3.6% (fifth straight decline); overall retention 43.3% (from 43.1%); growth almost entirely from Major/Supersize donors (3.4% of donors); micro ($1–100) and small ($101–500) = 49.3% and 30.8% of donors and declined fastest; 15,102 orgs / 7.8M donors / $13.2B | https://publications.fepreports.org/archive/2025-q4/ ; https://afpglobal.org/news/fundraising-effectiveness-project-reports-strongest-revenue-growth-five-years-even-fewer | 2026-04-21 | High. Note: Q4 "overall retention" (43.3%) is the year-over-year metric; the Q1 2026 18.0% figure in 1.1 row 22 is new-donor retention — the two are not the same measure. Repeat 59.3% / new 18.9% appear only in secondary summaries |
| A25 | FEP Q1 2026 | Dollars +4.3%; donors −0.8%; new-donor retention flat at 18.0%; retention fell for Small, Midsize, Major, Supersize | https://publications.fepreports.org/ | mid-2026 | High |
| A26 | BoardSource: board giving | 76.8% of boards require every member to give; 18.6% specify an amount; 13.7% no requirement | Leading with Intent 2021 — https://leadingwithintent.org/wp-content/uploads/2021/06/2021-Leading-with-Intent-Report.pdf | 2021 (n=820 CEOs) | Medium; "% of boards at 100% giving" not stated (secondary cites 46%) |
| A27 | NFF NYC 2025 breakout | 133 NYC respondents; 78% receive government funding; 19% paid on time (vs 47% elsewhere); 32% paid >90 days late (vs 10%); 24% ≤1 month cash; 40% ran 2024 deficit; 13,000 NYC nonprofits, ~$78B/yr, ~18% of workers | https://nff.org/insights/survey-nyc-nonprofits-are-enduring-under-strain-of-funding-pullbacks-and-severe-government-payment-delays/ ; https://nff.org/highlight/championing-fairer-government-funding-nyc-nonprofits/ | 2025-09-17 | Very high; best single NYC dataset |
| A28 | NYC Comptroller FY24 | 80.65% of all contracts late; 90.59% of nonprofit contracts late (88.19% FY23); median payment cycle to human-services providers 355 days | https://comptroller.nyc.gov/newsroom/9-out-10-human-service-contracts-arrive-late-to-comptroller-for-review/ ; https://council.nyc.gov/press/wp-content/uploads/sites/56/2025/04/nonprofit-procurement-brief_041425.pdf | 2025-02-06; 2025-04-14 | Very high |
| A29 | NYC Comptroller "Nonprofit, Nonpayment" | first payment averaged 388 days (FY24) / 426 days (FY23) after contract start; over a third of nonprofit contracts registered >6 months late | https://comptroller.nyc.gov/reports/nonprofit-nonpayment/ | 2025-04-29 | Very high |
| A30 | NYC Comptroller FY25 annual contracts report | 12,955 contracts, $42.45B; citywide retroactivity 72.64% (vs 80.65% FY24); still ~8 in 10 nonprofit/human-services contracts late; >2,000 discretionary contracts pending as of July 2025 | https://comptroller.nyc.gov/reports/annual-summary-contracts-report-for-the-city-of-new-york-2025/ | 2025-10-31 | Very high; Council discretionary awards matter to small CBOs |
| A31 | MOCS FY25 indicators | 66% of contracts registered within 30 days of start (62% FY24); 88% of FY26 HHS contract actions submitted on time by 2025-07-01; human services $15.6B = 37% of City procurement | https://www.nyc.gov/site/mocs/resources/citywide-indicator-reports.page | FY25 | City's own metric differs from Comptroller's |
| A32 | HSC City procurement survey | 90% had delayed City payments totaling $365M; >32% delayed >6 months; >48% took loans/lines of credit ($87M, ~$6M interest); >81% struggled to meet payroll; 77% delayed vendors | https://humanservicescouncil.org/wp-content/uploads/2024/11/111924_HSC-City-Procurement-Survey-Results.pdf | 2024-11-14 | Very high. HSC 2026 Advocacy Agenda: State reimburses only 3% interest vs ~10%+ borrowing cost — https://humanservicescouncil.org/wp-content/uploads/2026/01/2026-HSC-Advocacy-Agenda.pdf |
| A33 | HSC sector size | City and State invest $5.8B/yr in NY human-services nonprofits; NYC human-services procurement >$12B/yr | https://humanservicescouncil.org/wp-content/uploads/2025/12/Priorities-for-the-Human-Services-Sector.pdf | 2025 | Context |
| A34 | OSC Prompt Contracting 2024 | 78% of 6,721 State NFP contracts late (56% in 2023); 15 agencies 100% late; 6 agencies paid $128,645 interest on 207 contracts; 2,756 interest-eligible got none | https://www.osc.ny.gov/files/state-agencies/contracts/2024/pdf/prompt-contracting-report-2024.pdf | May 2025 | Very high |
| A35 | CUF "Safety Net on the Brink" | 40+ human-services nonprofits interviewed; City owes >$1B in unpaid invoices back to 2022; Food Bank 10M fewer lbs of food; projected 300,000 NYC SNAP losses | https://nycfuture.org/research/nycs-safety-net-on-the-brink | Dec 2025 | Very high |
| A36 | SeaChange/Oliver Wyman NYC fragility | ~10% of NYC nonprofits technically insolvent (18% health & human services; 13–15% grassroots); ~40% virtually no reserves; >40% lost money over prior 3 years; bottom 10% hold 0.3 months of cash | https://seachangecap.org/wp-content/uploads/2016/03/SeaChange-Oliver-Wyman-Risk-Report.pdf | March 2016 (2013 990 data) | Dated but the standing NYC benchmark; no newer edition |
| A37 | Nonprofit New York 2025 | Sector Insights Survey (June 2025): financial stability, workforce capacity, political/regulatory complexity top challenges; Safeguarding forum 200+ leaders (Jan 2025) | https://www.nonprofitnewyork.org/wp-content/uploads/2026/05/npny_2025impactreport_digital_final.pdf | May 2026 | Medium; percentages not stated |

Not found / not stated after both passes: any post-2016 NYC insolvency share; a Candid or GPA figure for hours per federal vs foundation application (trade estimates only); exact % decline of micro/small donors in FEP Q4 2025 (chart only); % of nonprofits using grant consultants; share of nonprofits under $1M budget (only the 2015-data <$500K figure, 66.9%).

### 1.3 Reading of the evidence

- The pain is not "we don't know where grants are." It is cash-flow timing (late government payment), revenue concentration (government), thin reserves, and low application volume. Application volume is the single most controllable variable with the steepest payoff (64.5% → 99.4% probability of at least one award as submissions rise, GrantStation 2026).
- NYC is a uniquely acute market: two Comptrollers (City and State) publish annual, worsening late-payment data, and CUF (Dec 2025) explicitly calls for pro bono financial services and a stabilization fund. The venture's "capital progression" framing maps onto documented public-policy demand.
- Donor-side evidence (FEP) says retention is flat at ~18% and growth comes from repeat donors, not acquisition — which argues that a readiness system must include recurring-donor and board-giving workflows, not grants alone.

---

## PART 2 — Comparable products, services, and precedents

### 2.1 Comparables verified directly this session

| Name | Category | Serves | Price (verified) | Claims **[marketing]** | Gap | URL | Date verified |
|---|---|---|---|---|---|---|---|
| Instrumentl | Grant database + pipeline + AI drafting | Nonprofits with budgets typically ≥$500k; grant consultants | Discover $299/mo annual ($349 monthly), 3 users; Pre-Award $499/mo annual ($579 monthly), 5 users, adds funder peer-prospecting, CRM sync, "Apply" AI drafting, Award Assistant; Full Lifecycle $999/mo annual ($1,159 monthly), 15 users, post-award spend tracking, accounting integrations; Enterprise custom | "Find opportunities that are the best fit for your mission"; AI + past content to write faster | $3.6k–$12k/yr per org is out of reach for sub-$500k orgs; no cash-flow/late-payment, board-giving, or cohort layer; no verification of readiness | https://www.instrumentl.com/pricing | 2026-09-23 |
| Candid Foundation Directory | Funder database (990-derived) | Grantseekers of all sizes; libraries | Public pricing page (as of 2026-06-17 per third-party capture) lists Free, Premium $219/mo or $1,199/yr, Ultimate $1,699/yr, Enterprise custom; older Essential (~$449/yr) / Professional (~$1,599/yr) names still circulate; free Professional access for a year to small nonprofits with a Seal of Transparency; direct fetch of shop.candid.org returned 403 | Largest funder dataset | Data, not workflow or guidance; no NYC contract/payment intelligence | https://shop.candid.org/Subscriptions/FDOProfessionalPlan (403 on fetch); https://help.candid.org/s/article/What-are-the-differences-among-Foundation-Directory-Online-Essential-and-Professional | 2026-09-23 (secondary) |
| Open Collective Foundation (OCF) | Fiscal sponsor (dissolved) | Mutual-aid, open-source, community collectives | Was 5% host fee; fiscal sponsorship ended 2024-09-30, collectives frozen 2024-10-01, entity dissolved 2024-12-31 (>600 collectives had to exit); platform now stewarded by Open Finance Consortium (501(c)(6)) | — | Confirms that a 5% fee could not sustain a high-touch fiscal sponsor — a pricing warning for any shared-service model | https://opencollective.com/foundation/updates/announcement-we-are-dissolving-open-collective-foundation-at-the-end-of-this-year ; https://blog.opencollective.com/open-collective-official-statement-ocf-dissolution/ | 2026-09-23 |
| Fund for the City of New York — Partner Project Program | NYC fiscal sponsor + back office (payroll, HR, legal, benefits, bookkeeping); also Cash Flow Loan Program and the City's Returnable Grant Fund bridge loans | NYC public-interest projects and nonprofits with government contracts | Fee % not stated publicly (secondary sources cite 4–10% for NYC sponsors generally) | 80+ partner projects since early 1990s | Provides money and back office, not fundraising readiness or funder pipeline | https://www.fcny.org/ ; https://www.fcny.org/nonprofit-loan-financing/ | 2026-09-23 |
| Wyoming DUNA (legal wrapper) | DAO legal form | DAOs with ≥100 members | Statute effective 2024-07-01 (SF50); state filing fees not stated | a16z: "an oasis for DAOs"; can contract, bank, pay taxes, limit member liability; may apply for federal exemption like any unincorporated association | NY has no DUNA analogue; 501(c)(3) recognition for a DUNA is untested in public record | https://a16zcrypto.com/posts/article/duna-for-daos/ ; https://prestonbyrne.com/2024/03/08/dunaa/ | 2026-09-23 |

### 2.2 Comparables from parallel research (Part 2 agent)

Legend: **[L]** price fetched live from the vendor's own page on 2026-09-23; **[S]** live search snippet of the vendor's own page (direct fetch blocked); **[3P]** third-party source only; "not stated" = no public price found. All outcome claims are vendor marketing unless noted.

| # | Name | Category | What it does | Serves | Price (verified) | Claims **[marketing]** | Gap | URL | Date verified |
|---|---|---|---|---|---|---|---|---|---|
| 1 | Instrumentl | Grant DB + AI | Funder/RFP discovery (36k RFPs, 450k funder profiles), tracking, AI prospecting, AI drafting ("Apply"), post-award budget tracking | Dev teams with 20+ active grants | **[L]** Discover $299/mo annual ($349 monthly, 3 users); Pre-Award $499/mo ($579; 5 users; AI drafting here); Full Lifecycle $999/mo ($1,159; 15 users); Enterprise custom | "Average $1.4M increase in annual grant revenue"; "Save 192 hours/yr" | $3.6k–$12k/yr; out of reach for <$500k orgs; AI gated to $499 tier | instrumentl.com/pricing | 2026-09-23 |
| 2 | Candid Foundation Directory (Candid Search) | Grant DB + AI | Funder/grants/990 research; AI fundraising assistant; funder recommendations; compliance data (Ultimate) | Grantseekers, researchers | **[L]** Free $0; Premium $219/mo or $1,199/yr; Ultimate $1,699/yr; Enterprise custom. Legacy Essential/Professional names no longer on pricing page | Data comprehensiveness (28M+ grants); no ROI stat | No writing/pipeline; annual commitment for best price | candid.org/pricing | 2026-09-23 |
| 3 | GrantStation | Grant DB | 150k+ funder profiles, 15k+ curated grants, guides, tracking | Small/mid nonprofits | **[L]** 1-yr $199; 2-yr $299 (TechSoup promos $95–$150/yr **[3P]**) | Qualitative only | Discovery-only; no AI writing | grantstation.com/product/grantstation-membership | 2026-09-23 |
| 4 | GrantWatch | Grant DB + AI | 12.4k "human-verified" active grants, 374k funder profiles, AI search, pipeline, AI proposal help | Nonprofits, small biz, individuals | **[L]** $22/wk; $49/mo; $100/qtr; $249/yr (AI tokens per tier) | Users won "$10k–$400k+"; "raised >$13M for clients" | Listing-style DB; token-metered AI | grantwatch.com/plans.php | 2026-09-23 |
| 5 | Grantable | AI grant writing | AI "grants department" (agents, drafting with org memory, 990-based funder scans, dashboard) | Solo writers, small teams, agencies | **[L]** Free (5 msgs/day); Starter $50/mo ($25 nonprofit discount, <$500k budget, 1 yr); Pro $150/mo ($75); Agency Hub +$300/mo | "Real capacity to start"; no win-rate stat | No award-history data; discount conditional | grantable.co/pricing | 2026-09-23 |
| 6 | Grant Assistant (FreeWill) | AI grant writing | Maker confirmed: **FreeWill Co. (Delaware PBC)**. Semantic "Discover" matching + "Respond" drafting; compliance check vs RFP | Mid/large nonprofits, INGOs, higher-ed, public sector | **not stated** — contact sales (verified on grantassistant.ai and nonprofits.freewill.com) | "Trained on 7,000+ successful proposals"; "50–90% time reduction"; "$300k grant won" | Opaque; enterprise motion excludes small orgs | nonprofits.freewill.com/products/grant-assistant | 2026-09-23 |
| 7 | OpenGrants | Grant DB + AI | 8,000+ open grants/contracts; AI eligibility check | Nonprofits, startups, agencies | **[L]** 7-day free; $9/mo or $99/yr | "The easy way to find grants" | Thin DB; no writing depth | opengrants.io | 2026-09-23 |
| 8 | Fundwriter.ai | AI fundraising copy | 30+ writing "skills" (appeals, proposals, LOIs); Raiser's Edge NXT integration | Development staff | **[S]** Basic $29/mo ($22 annual, 20k words); Professional $89/mo ($68 annual); +$50/user | Qualitative | Copy only; no discovery/pipeline | fundwriter.ai/pricing | 2026-09-23 |
| 9 | GrantHub (Foundant) | Grant tracking | Grantseeker tracking/deadlines; GrantHub Pro added Candid search **[3P]** | Small nonprofits | **not stated** — no longer on foundant.com product pages; granthub.com unreachable. Foundant funder-side GLM $6,500/$9,900/$13,900/yr **[3P]** | n/a | Product status unclear | foundant.com | 2026-09-23 |
| 10 | Submittable | Funder-side grants mgmt | Application portal, review, financial tracking, CSR | Foundations, government, corporations | **[L]** not stated — contact sales | Customer quotes | Not for grantseekers | submittable.com/pricing | 2026-09-23 |
| 11 | Bloomerang | CRM | Donor CRM, fundraising, volunteer mgmt, Prospect AI | Small/mid nonprofits | **[L]** Giving Platform $242/mo annual; CRM $125/mo; Fundraising add-on $40/mo; Volunteer $119/mo | "47% first-time donor retention (top 20% customers) vs 19% industry" | No grants module | bloomerang.com/pricing | 2026-09-23 |
| 12 | Bonterra (EveryAction / Network for Good) | CRM | NFG: coaching-first fundraising for small orgs; EveryAction: AI CRM + advocacy | Small (NFG) to large (EA) | **[L]** not stated — "Based on plan". 3P estimates NFG $1.5k–$8.5k/yr; EveryAction $12k–$85k+/yr | Qualitative | Opaque; implementation fees | bonterratech.com/pricing/fundraising-and-engagement | 2026-09-23 |
| 13 | Blackbaud Raiser's Edge NXT | CRM | AI donor mgmt for major gifts, campaigns, grants | Mid/large with dev teams | **[L]** not stated — "Ask About Pricing" | "44% average increase in total dollars raised" | Enterprise cost/complexity | blackbaud.com/products/blackbaud-raisers-edge-nxt | 2026-09-23 |
| 14 | Givebutter | Fundraising platform | Forms, pages, events, auctions, CRM, payments | All sizes | **[L]** Free: 0% platform fee with donor tips on (3% if off); processing 2.9%+$0.30 card / 1.9%+$0.30 ACH if tips off; Plus $29–$1,548/mo by contacts | "92% of donors cover fees"; "#1 on G2" | Tip model shifts cost to donors | givebutter.com/pricing | 2026-09-23 |
| 15 | Zeffy | Fundraising platform | 100% free forms/events/payments, tip-funded | Nonprofits | **[L]** $0; no platform/processing fees; optional tips | "100k+ nonprofits raised $2B+, saved ~$100M in fees" | Tip-dependent; limited CRM depth | zeffy.com/pricing | 2026-09-23 |
| 16 | Classy (GoFundMe Pro) | Fundraising platform | Donation pages, recurring, P2P, events, Salesforce | Mid/large | **[L]** not stated — annual subscription + per-donation fee, quote-only | "46% higher completion" (Salvation Army) | Quote-gated | pro.gofundme.com/c/pricing | 2026-09-23 |
| 17 | DonorsChoose | Education comparator | Teachers post projects; donors fund; DC vets, buys, ships | US public-school teachers | **[L]** Free to teachers; flat $30 fulfillment fee/project; suggested 15% optional donation to DC | "$314M+ distributed"; "68% of US public schools" | Education-only; not a general grant model | donorschoose.org/about/finance.html | 2026-09-23 |
| 18 | Grantboost | AI grant writing (entrant) | Discovery across "1.5M sources", drafting, brand voice, pipeline | Small nonprofits, agencies | **[L]** Starter $32/mo; Growth $49/mo; Autopilot $66/mo | Qualitative | No award-history data | grantboost.io/pricing | 2026-09-23 |
| 19 | GrantOrb | AI grant writing (entrant) | Auto-discovery + submission-ready proposals; per-proposal pricing | Small nonprofits, consultants | **[L]** Learning $119 one-time (1 proposal); Starter $499/yr (10); Growth $1,650/yr (50); Impact $2,640/yr (100) | "Six weeks to minutes" | Volume-priced; quality unverified | grantorb.com/pricing | 2026-09-23 |
| 20 | GrantPro (grantpro.net) | AI grant writing (entrant) | Federal + curated foundation/state search, fit scoring, drafting | Small nonprofits | **[S]** Free tier; Pro $79/mo | "$79/month, not $2,000+" | Name collision with grantpro.org ($24.95/mo, $249.95/yr **[S]**) | grantpro.net | 2026-09-23 |
| 21 | Granted AI | AI grant writing (entrant) | 140k+ grants, matching, drafting, multi-reviewer scoring | Nonprofits, researchers | **[S]** Free; Basic $18/mo ($220/yr); Pro $57/mo ($680/yr) | "Pro writer charges $5k–$15k/proposal" | New; no win data | grantedai.com/pricing | 2026-09-23 |
| 22 | Charity Grant AI / "Streamline" | AI grant writing (named) | — | — | **not verifiable** — charitygrant.ai DNS not found; no grant-writing product named "Streamline" surfaced (GrantMind $99/$199/mo and CharityIQ $69/$219/$499/mo appeared **[S]**) | n/a | Treat as unverified names | — | 2026-09-23 |
| 23 | Candid AI / Instrumentl AI | Incumbent AI | Bundled AI assistants/prospecting/drafting inside existing plans | Existing subscribers | See rows 1–2; no separate AI SKU | Instrumentl: 192 hrs saved | AI bundled into $1.2k–$6k/yr plans | candid.org/pricing; instrumentl.com/pricing | 2026-09-23 |
| 24 | Grant-writing firm norms (2026) | Services | Hourly, per-proposal, retainer | Nonprofits hiring consultants | **[3P, multiple 2026 guides]** Hourly $40–$150 (Upwork **[L]** median $50, range $35–$60); per-proposal $1,000–$8,000+ (foundation $1.5k–$5k; federal $5k–$15k+); retainers $1.5k–$6k/mo. GPA Compensation & Benefits Report paywalled; GPA/AFP codes prohibit contingency/% fees | "16x return if $3k fee wins $50k" | Wide variance; GPA figures not public | upwork.com/hire/grant-writers/cost; giddingsconsulting.com/blog/grant-writer-cost; grantsmarts.com/grant-writer-cost-guide | 2026-09-23 |
| 25 | Nonprofit Grant Writers (published price list) | Services | Flat-fee proposals | Nonprofits | **[S]** New proposal $3,500; rewrite $2,500; RFP/RFA response $3,500–$7,500+; research + distribution +$1,500; proofreading $1,000 | None | Small firm example | nonprofitgrantwriters.com/price-list | 2026-09-23 |
| 26 | GrantWriterTeam | Marketplace | Classifieds matching grant writers and seekers | Nonprofits, business, municipalities | **[L]** not stated (listing fees) | Disclaims guarantees | No vetting | grantwriterteam.com | 2026-09-23 |
| 27 | Fractional development director / outsourced dev office | Services | Embedded senior fundraiser on retainer | Orgs <$5M budget | **[S, firm pages]** Working Within $5,000–$5,500/mo (6-mo min); Sound Fundraising Strategies $4k–$5k/mo (12-mo min); Further Together $5,500/mo; More Than Giving from $1,550/mo (10 hrs); Quarrie Dev Group $8k/$16k/$25k/mo; IVA $6,000/mo | "Senior expertise at junior-hire cost ($48k–$66k/yr vs $90k–$150k DoD)" | $48k–$78k/yr still out of reach for <$500k orgs | soundfundraisingstrategies.com/blog/what-does-fractional-fundraising-cost; workingwithin.net/services/revenue-retainer | 2026-09-23 |
| 28 | Cause Effective | NYC capacity builder | Fundraising/board consulting, coaching, Fellows | NYC nonprofits | **[L]** not stated | "74% boards more engaged; 62% raised more" | Site says org is "taking a step back from daily operations to explore strategic alternatives" | causeeffective.org | 2026-09-23 |
| 29 | Community Resource Exchange (CRE) | NYC capacity builder | Strategic planning, leadership dev, CAREpacity Camp, CRE Rising Fund | NYC nonprofits | **[L]** not stated | "40+ years" | No published fees | crenyc.org | 2026-09-23 |
| 30 | Support Center for Nonprofit Management (NY/NJ) | NYC capacity builder | Strategy consulting, interim ED, exec search, leadership institutes | Nonprofits | **[L]** not stated | Qualitative | No published fees | supportcenteronline.org | 2026-09-23 |
| 31 | Nonprofit New York | Membership association | Advocacy, 50+ trainings/yr, resource library, referral center, 403(b) | NYC nonprofits | **[L]** Dues by budget: <$125k $95; $125–250k $175; $250–500k $395; $500–750k $550; $750k–1M $700; $1–5M $925; $5–10M $1,600; $10–25M $2,000; >$25M $2,300 | Qualitative | No grant-writing/dev services | nonprofitnewyork.org/join | 2026-09-23 |
| 32 | Lawyers Alliance for New York | Legal capacity | Transactional legal services via staff + 140+ firms' volunteers | NYC nonprofits serving low-income communities | **[L]** "affordable"; free/fee split not stated | Qualitative | Legal only | lawyersalliance.org | 2026-09-23 |
| 33 | Pro Bono Partnership | Legal capacity | Free legal services, board training, helpline | Nonprofits in CT/NY/NJ | **[L]** Free | "~1,000 clients; 1,794 volunteer attorneys; $24M+ value" | Legal only | probonopartner.org | 2026-09-23 |
| 34 | NYC Service (Mayor's Office) | Government capacity | Volunteer platform, Civic Impact Funding, AmeriCorps hosting | NYC nonprofits | **[L]** Free | None quantified | Volunteers, not fundraising | nycservice.org | 2026-09-23 |
| 35 | Robin Hood (Power Fund / FUEL / management assistance) | Funder capacity | Power Fund: grants + Management Acceleration team for leaders of color; FUEL for 50: 50 orgs × $25k → up to 10 × $250k → 3 × ~$1M with TA | NYC anti-poverty nonprofits | Funder-paid. **[L]** Power Fund restricted funding "spent down as of 12/31/2024"; **[S]** ~$11M to 23 leaders/22 orgs + $750k capacity grants; FUEL $52.3M since 2017 | "2.7M New Yorkers served (2025)"; "$140M in 515 grants" | Invitation/competition-only; Power Fund concluded | robinhood.org/programs/the-power-fund; robinhood.org/programs/fund-for-early-learning | 2026-09-23 |
| 36 | Catchafire | Skills-based volunteering | On-demand pro bono projects for grantees | Funders buy for grantees | **[L]** Funder-paid; prices not listed | "$326M+ value; 15k+ nonprofits; 5x funder ROI yr 1" | Access depends on a funder buying seats | catchafire.org | 2026-09-23 |
| 37 | Taproot Foundation (Taproot Plus) | Skills-based volunteering | Free pro bono projects/consults in 9 areas | Any nonprofit | **[L]** Free | "$300M+ delivered; 19k+ orgs" | Volunteer-dependent, not ongoing capacity | taprootfoundation.org | 2026-09-23 |
| 38 | Candid Funding Information Network (NYPL/BPL) | Library access | On-site Foundation Directory/Candid Search | Public | **[S]** Free on-site at NYPL (Schwarzman, SNFL, Bronx Library Center, Schomburg, St. George, LPA) and BPL Central | n/a | On-site only | libguides.nypl.org/foundation-directory-online-professional; candid.org/resources/candid-near-you | 2026-09-23 |
| 39 | Fund for the City of New York — Partner Project Program | Fiscal sponsor (NYC) | Full back office: finance, HR/payroll/benefits, insurance, audit | NYC startup and established projects | **[L]** fee **not stated** on site | "Hundreds of orgs over 30+ years" | Fee opaque; inquiry-based | fcny.org/partner-project-program | 2026-09-23 |
| 40 | FJC | Fiscal sponsor (NYC) | DAFs + fiscal sponsorship, operational/fiscal mgmt | Donors, nonprofits | **[L]** "competitive fees" — % not stated | Qualitative | Fee opaque | fjc.org | 2026-09-23 |
| 41 | Tides | Fiscal sponsor | Model A comprehensive; Model C fundraising/grants admin | Social-justice orgs | **[L]** Model A **9%** of revenue; **15%** on government grants; reduced above $1M after yr 1; $4,000 minimum annual reserve | "130+ sponsored partners" | High minimums for micro-orgs | tides.org/fiscal-sponsorship | 2026-09-23 |
| 42 | Social Good Fund | Fiscal sponsor | Model A and C | Community projects, artists, environmental | **[L]** Model A 8% (<$500k), 7% ($500k–1M), 6% (>$1M); Model C 6.5%/5%; 8% international; $29/mo fee (refunded at $5k raised; waived at $10k) | None | Monthly fee for micro-projects | socialgoodfund.org/fiscal-sponsorship/sponsorship-rates | 2026-09-23 |
| 43 | Players Philanthropy Fund | Fiscal sponsor | Model A/C, nationwide registration, W-2 staffing; 600+ projects | Athletes/entertainers/changemakers | **[L]** **6%** (government grants separate); $5,000 opening deposit | "6% vs 20–30% overhead" | Deposit barrier | ppf.org/fiscal-sponsorship | 2026-09-23 |
| 44 | Fractured Atlas | Fiscal sponsor (arts) | Donations, crowdfunding, grant applications | Artists, creative groups | **[L KB]** **8%** admin fee on donations; membership dues $10/mo Pro, $20/mo Org **[3P]** | Qualitative | Arts-only | fracturedatlas.zendesk.com/hc/en-us/articles/115001290913 | 2026-09-23 |
| 45 | Community Initiatives | Fiscal sponsor | Full back office, legal, grants mgmt; 155 projects | Diverse issue areas | **[S]** **10%** of gross revenue; **15%** government funds; $24k minimum budget | Candid Platinum, CN 4-star | Minimum excludes micro-projects | communityinitiatives.org | 2026-09-23 |
| 46 | Open Collective Foundation → replacements | Fiscal sponsor (dissolved) | **Confirmed:** OCF announced dissolution 2024-02-28; ceased fiscal sponsorship 2024-09-30; dissolved 2024-12-31. Open Source Collective (501(c)(6), OSS-only) unaffected. **Raft Foundation** (501(c)(3) on Open Collective) is a successor host; fee tiered, % not captured | Mutual aid, community tech, OSS | OSC fee not stated (fees page 404); Raft not stated | Raft: "10% of admin allocations go to a collectively managed fund" | Replacement hosts fragmented | blog.opencollective.com/open-collective-official-statement-ocf-dissolution; raft.foundation | 2026-09-23 |
| 47 | HCB (Hack Club Bank) | Fiscal sponsor | 501(c)(3) umbrella, bank account, cards, 990, payroll, transparent ledgers | Teen-led and other nonprofits | **[L]** **7%** of revenue, no other fees | "$100M+ processed; 6,500+ projects" | Teen/hacker focus | hackclub.com/fiscal-sponsorship | 2026-09-23 |
| 48 | "Edgeworth" | Unverified | **Could not identify** any fiscal sponsor or DAO wrapper named Edgeworth (matches: Edgeworth Economics, Edgeworth Capital, a real-estate firm) | — | not stated | n/a | Likely a misremembered name — drop or re-source | — | 2026-09-23 |
| 49 | Endaoment | DAO/crypto wrapper | Onchain 501(c)(3) community foundation: DAFs, Community Funds (collectively advised, pre-defined recipients), crypto donation rails; exploring fiscal sponsorship | Crypto donors, DAOs, nonprofits | **[L]** Donor fee 1.5% (tiered inbound; 1.0% on grants; never >1.5% combined); $0 to nonprofits | "1.8M+ nonprofits"; "$50M+ crypto donations" **[3P]** | Community Funds ≠ full fiscal sponsorship (cannot hire staff/run programs) | endaoment.org; docs.endaoment.org/donors/about/about-community-funds | 2026-09-23 |
| 50 | Giveth / Gitcoin | Crypto public-goods funding | Giveth: zero-fee crypto donations, QF rounds; Gitcoin: quadratic funding via Allo Protocol | Web3 projects, nonprofits | **[L]** Giveth 0%; Gitcoin fees not stated; **neither provides 501(c)(3) fiscal sponsorship** | Giveth "~$7.18M to 8,634 projects" | No tax-deductibility umbrella for DAO projects | giveth.io; gitcoin.co | 2026-09-23 |
| 51 | Big Green (Big Green DAO) | DAO grantmaking precedent | 501(c)(3)-led participatory grantmaking (grantees + donors decide) | Food-growing/food-access nonprofits with 501(c)(3) or sponsor | **[L]** Grants $10k / $25k / $40k | Peer network | Requires existing 501(c)(3)/sponsor | biggreen.org/dao | 2026-09-23 |
| 52 | Wyoming DUNA (SF0050) | DAO legal wrapper | Effective 2024-07-01: entity status, limited liability, ≥100 members | Blockchain networks/DAOs | Statutory filing; a16z guidance free | a16z: "works for 100 members or 10 million" | Not a 501(c)(3); no tax-deductible donations by itself | a16zcrypto.com/posts/article/duna-for-daos | 2026-09-23 |
| 53 | Otonomos | DAO wrapper provider | Entity formation in 20 jurisdictions; crypto payment accepted | DAOs, Web3 founders | **[L]** Wyoming LLC from $269; Panama IBC $1,495; BVI $2,616; Cayman Web3 Foundation $7,357 | "1,000+ companies" | For-profit wrappers, not charitable | otonomos.com | 2026-09-23 |
| 54 | Opolis | Web3 employment commons | Member-owned employer-of-record co-op (payroll, benefits, W-2) | Independent/DAO contributors | **[L]** Community membership $97 one-time; employment pricing not stated | "$210M+ payroll; 1,150+ W-2s" | Employment only | opolis.co | 2026-09-23 |
| 55 | Shared grant writer / "Grant Collaborative" (Muscatine, IA) | Shared dev staff precedent | City + County + Community Foundation each fund $25k/yr for one grant writer employed by the CF; committee sets priorities | 3 public/philanthropic entities | **[S]** $75k/yr pooled | "Leveraged $8M in two years"; Dubuque CF replicating | Municipal model; nonprofit-cohort version not found | muscatineiowa.gov (agreement PDF); iowacounciloffoundations.org | 2026-09-23 |
| 56 | Community Spaces Network (formerly Nonprofit Centers Network) | Shared services/space | Peer network for shared nonprofit centers and back office | Center operators | **[S]** dues $425 (<$1M) / $650 ($1–5M) / $1,000 (>$5M) | "500+ spaces, 8,500 orgs" | Space/back-office, not development staff | communityspaces.org/center-in-operation-membership | 2026-09-23 |
| 57 | Fast Forward Accelerator | Tech-nonprofit accelerator | 3-month program, unrestricted grant, mentorship | Early-stage tech/AI nonprofits with MVP | **[L]** Free; **$25k+ grant**; 2025 cohort **10 orgs** **[S]** | "112 orgs; $1.4B follow-on" | Tech-nonprofit only; ~10 slots/yr | ffwd.org/accelerator | 2026-09-23 |
| 58 | Camelback Ventures Fellowship | Accelerator | 16-week hybrid, coaching | Ed/conscious-tech founders (94% BIPOC) | **[L]** Free; **$40,000** unrestricted; 2×/yr; cohort size not stated | "220+ entrepreneurs; $50M+ raised" | Sector-limited | camelbackventures.org/fellowship | 2026-09-23 |
| 59 | Echoing Green Fellowship | Fellowship | 18-month leadership program + seed funding | Early-stage social entrepreneurs | **[L]** **$100,000** over 18 months; 2025 cohort ~18–20 from 4,200 applicants **[S]** | "35+ years" | <0.5% acceptance | echoinggreen.org/fellowship | 2026-09-23 |
| 60 | Robin Hood Blue Ridge Labs (Founder Fellowship / Catalyst) | NYC accelerator | Fellowship to launch social-impact startups; Catalyst (10th cohort) | NYC founders | **[L]** stipend/cohort size not stated | "100+ founders; 55 ventures; $200M+ raised" | Opaque terms | robinhood.org/our-work/blue-ridge-labs | 2026-09-23 |
| 61 | Bridgespan (Leading for Impact / Leadership Accelerator) | Cohort programs | Cohort-based exec-team program on a strategic goal; online accelerator | Nonprofit exec teams | **[L]** not stated (typically funder-subsidized) | Qualitative | Cost/cohort opaque | bridgespan.org/our-services/cohort-based-services-for-nonprofits-and-ngos | 2026-09-23 |
| 62 | Nonprofit Finance Fund | Financial capacity | Consulting, Full Cost framework, scenario planning, loans | Nonprofits, funders | **[L]** not stated | "Thousands of nonprofits" | No dev/grant-writing capacity | nff.org | 2026-09-23 |
| 63 | Brooklyn Org | NYC funder capacity | Trainings, coaching, resource library, pro bono referrals | Brooklyn nonprofits | **[L]** Free; grant amounts/cohort sizes not stated | Qualitative | No structured cohort found | brooklyn.org/nonprofit-resources | 2026-09-23 |
| 64 | Laurie M. Tisch Illumination Fund | NYC funder | Arts in Health, Play to Thrive ($10M, 2025), team-development grants | NYC orgs $50k–$5M (2021 RFP) | **[S]** Invitation-only; 2021 RFP: 120 LOIs → 14 grantees | "NYC COVID Fund $100M+ to ~800 nonprofits" | No unsolicited proposals | thelmtif.org/about-us | 2026-09-23 |
| 65 | NYC Nonprofit Resiliency Committee / Mayor's Office of Nonprofit Services | Government outputs | "Helping providers get paid," Returnable Grant Fund, CNO network, trainings | City-contracted nonprofits | Free | "$374M FY18 human-services investment incl. indirect" **[S]** | Serves contracted providers, not grassroots | nyc.gov/site/nonprofits; cpc-nyc.org/news/1317 | 2026-09-23 |
| 66 | New York Community Trust | NYC funder | Capacity/technical-assistance grants | NYC nonprofits | **not verified** — nycommunitytrust.org (redirect loop) and thenyct.org (DNS) both failed on 2026-09-23 | n/a | Re-check manually | — | 2026-09-23 |

Notes on the comparables pass:
- ~45 prices fetched live from vendor pages; ~12 via live snippets of vendor pages; 4 third-party only (Bonterra, GrantStation promos, Fractured Atlas dues, Foundant GLM); 3 unreachable (NYCT, granthub.com, Candid legacy FDO page).
- Naming drift: Candid no longer sells "Essential/Professional/Enterprise"; Nonprofit Centers Network is now Community Spaces Network; "Edgeworth," "Charity Grant AI," and "Streamline" could not be found as products.
- DAO/crypto: no verified 501(c)(3) fiscal sponsor advertises hosting DAO-native projects. Closest: Endaoment Community Funds (grant-only), Raft Foundation, HCB (7%). A Wyoming DUNA confers legal personhood, not charitable status.
- Price bands for a small NYC org: AI grant tools $18–$79/mo (Granted, Grantboost, GrantPro, Fundwriter, discounted Grantable) vs incumbents $1.2k–$12k/yr (Candid, Instrumentl); fiscal sponsorship 6–10% (15% on government funds at Tides/Community Initiatives); fractional development $4k–$6.5k/mo; per-proposal grant writing $1.5k–$5k foundation / $5k–$15k federal.
- Gap pattern: nothing verified offers a shared, ongoing development function priced for sub-$500k-budget orgs — tools are self-serve, services start ~$48k/yr, capacity builders do not publish fees, and cohorts/accelerators are competitive and funder-gated (10–20 slots).

---

## PART 3 — Legal, ethical, and regulatory constraints on the business model (New York first)

### 3.1 Regulatory constraints table (verified directly this session)

| Rule | What it requires | Who it binds | Source | Implication for the business model |
|---|---|---|---|---|
| NY Exec. Law §171-a(2) "contribution" | Defined as the promise or grant of money/property "including a grant or other financial assistance from any agency of government" | Everyone under Art. 7-A | https://www.nysenate.gov/legislation/laws/EXC/171-A (verified 2026-09-23) | Grants — foundation and government — are "contributions"; grant-seeking is therefore "solicitation" territory under NY law |
| §171-a(9) "fund raising counsel" (FRC) | Any person who for compensation consults with a charity or plans, manages, advises, or assists with solicitation in NY, but has no access to contributions and does not solicit. **Exclusion:** "an individual engaged solely to draft applications for funding from a governmental agency or an entity exempt … under 501(c)(3) shall not be deemed a fund raising counsel." Bona fide officers/employees/volunteers and retained attorneys are also excluded | Consultants, including grant consultants | same | A pure grant-writer (drafting applications to government or 501(c)(3) funders only) is exempt. A "funding office" that also advises on individual/board/recurring-donor solicitation, plans campaigns, or manages solicitation strategy falls squarely inside FRC and must register. Design the service line (or the contract) to make the boundary explicit |
| §171-a(4) "professional fund raiser" (PFR) | Any person who for compensation plans, manages, conducts, or assists a charitable solicitation, or solicits, or engages others to solicit | Anyone who solicits or handles funds | same | If staff ever ask donors for money on a member's behalf, or hold/receipt donations, the venture becomes a PFR (bond + stricter filings). Keep custody of funds and direct asks with the nonprofit |
| §173 registration | Annual registration, under oath, $800 annual fee; PFRs must file a $10,000 surety bond; registration valid one year; books and records kept ≥3 years after contract ends; willful violation is a misdemeanor | PFRs and FRCs | https://www.nysenate.gov/legislation/laws/EXC/173 (verified 2026-09-23); forms CHAR013 (PFR), CHAR014 (FRC), CHAR016A/B (contract certification), CHAR037 (closing statement), CHAR009 summary — https://ag.ny.gov/resources/organizations/charities-nonprofits-fundraisers/charities-fundraisers | Budget $800/yr + compliance time; bond only if PFR. Registration is a modest cost and a trust signal — consider registering as FRC voluntarily |
| §173-a contracts | Written contract with each charity before acting; file with the AG within 10 days of execution; state financial terms; closing statements within 90 days of termination (interim annually for multi-year); PFRs may not begin until AG acknowledgment or 15 days elapse | PFRs and FRCs | https://www.nysenate.gov/legislation/laws/EXC/173-A (verified 2026-09-23) | Every cohort membership agreement is a filable contract if the venture is an FRC; build the 10-day filing into onboarding |
| AFP Code of Ethical Standards, Standards 21, 23, 24 | No compensation based on a percentage of contributions; no finder's or contingent fees; proposal writers must agree in advance to a fixed fee (bonus schedules allowed if not % of funds raised) | AFP members; de facto sector norm | https://afpglobal.org/ethics/code-ethical-standards ; https://afpglobal.org/ethical-standard-deep-dive-standard-21 (verified 2026-09-23) | Rules out "% of grants won" pricing. Use flat cohort fees, tiered subscriptions, or milestone fees tied to deliverables (not dollars raised). Funders also disfavor paying grant-writer commissions from grant funds |
| IRS Rev. Rul. 72-369 | An organization providing managerial/consulting services to unrelated 501(c)(3)s for a fee — even at cost — is not itself exempt; it is a trade or business ordinarily carried on for profit | Any entity seeking 501(c)(3) status for a shared-services model | https://nonprofitlawblog.com/commerciality-doctrine-denial-exemption/ ; IRS PLR 201701002 https://www.irs.gov/pub/irs-wd/201701002.pdf (verified 2026-09-23) | Structuring the venture itself as a 501(c)(3) is risky unless services are substantially below cost/grant-subsidized and clearly charitable (e.g., capacity-building for low-income-serving orgs, free to members). Later PLRs have allowed fee-based consulting to social-sector orgs without UBIT when substantially related — but exemption at formation remains the hard step. A for-profit (or LLC/PBC) selling to nonprofits has no exemption issue |
| NY SHIELD Act, GBL §899-aa/899-bb | "Any person or business" owning/licensing computerized private information of NY residents must maintain reasonable administrative, technical, physical safeguards; small-business scaling allowed; AG may seek up to $5,000 per violation; breach notification rules | Nonprofits and their vendors, including this venture | https://www.pillsburylaw.com/en/news-and-insights/ccpa-new-york-shield-law.html ; https://www.proskauer.com/alert/the-new-shield-act-changes-breach-notification-rules-and-data-security-standards-for-new-yorkers-personal-information (verified 2026-09-23) | The software must ship with a written security program, vendor agreements, and breach procedures; keep beneficiary PII out of the platform where possible (handle donor/funder data, not client data) |
| NY Exec. Law §172-b financial reporting thresholds | Gross revenue and support >$1,000,000 → independent CPA audit; $250,000–$1,000,000 → CPA review; ≤$250,000 → unaudited report; AG may compel an audit; CHAR500 due 15th day of 5th month after FYE (May 15 for calendar year) | Every Art. 7-A registered charity (cohort members) | https://www.nysenate.gov/legislation/laws/EXC/172-B (verified 2026-09-23) | "Readiness" must include audit/review status: crossing $250k or $1M changes what funders and the AG demand; build it into the progression ladder |
| NY Exec. Law §172-b(9) dual filing with Department of State | Enacted effective 2021-01-01 for >$250k filers ($25 fee); later reported eliminated (2022) per practitioner sources; verify current status on the DOS site before advising | Cohort members | https://www.hodgsonruss.com/newsroom/publications/New-Nonprofit-Filing-Requirements-with-NYS-Department-of-State (2021 article) | Compliance-calendar feature must be maintained against changing NY rules |
| NY Prompt Contracting Law (State Finance Law Art. XI-A) | State agencies must meet statutory contracting timeframes; interest owed to nonprofits on late contracts in certain cases; annual OSC report | State agencies; benefits nonprofits | https://www.osc.ny.gov/files/state-agencies/contracts/2025/pdf/prompt-contracting-report-2025.pdf (May 2026) | 2,810 interest-eligible late contracts got no interest in 2025 — an interest-recovery workflow is a concrete, legal "capital progression" feature |
| Wyoming DUNA Act (SF50, effective 2024-07-01) | DUNA needs ≥100 members; may contract, bank, hold property, pay tax; members shielded from liability; may apply for federal tax exemption like any unincorporated association | DAO-structured nonprofit member | https://prestonbyrne.com/2024/03/08/dunaa/ ; https://a16zcrypto.com/posts/article/duna-for-daos/ (verified 2026-09-23) | The DAO-structured basic-needs org will likely need a fiscal sponsor or a conventional NY not-for-profit corporation to receive foundation/government grants; a DUNA alone is not a recognized NY charity form |

### 3.2 Regulatory constraints from parallel research (Part 3 agent)

Parallel verification pass against primary sources (statutes on nysenate.gov, AG forms, IRS, eCFR, NNFS). Same date. Where this pass differs from 3.1, the difference is noted.

| # | Rule | What it requires | Who it binds | Source | Implication for the business model |
|---|---|---|---|---|---|
| R1 | §171-a(2) "Contribution" | Includes "a grant or other financial assistance from any agency of government"; excludes member dues/payments for services | Everyone under Art. 7-A | https://www.nysenate.gov/legislation/laws/EXC/171-A (live) | Foundation and government grants are contributions; asking for them is solicitation |
| R2 | §171-a(10) "Solicit" | Any direct or indirect request for a contribution, through any medium, whether or not a gift results | Everyone under Art. 7-A | same; AG statute booklet https://ag.ny.gov/sites/default/files/regulatory-documents/statute_booklet.pdf | If staff submit proposals or make asks in the org's name, that is soliciting — keep the nonprofit as the submitting party |
| R3 | §171-a(4) Professional fund raiser | Plans/manages/conducts/assists a solicitation or solicits for compensation; bona fide officers/employees/volunteers and FRCs excluded | Paid outside fundraisers | same; CHAR013 https://ag.ny.gov/sites/default/files/regulatory-documents/char013.pdf | A pooled "shared office" bank account receiving grants would make the venture a PFR ($800 + $10,000 bond + closing statements). Never take custody of client funds |
| R4 | §171-a(9) Fund raising counsel; grant-writer exclusion | Consults/plans/advises on solicitation, no custody, does not solicit. Excludes officers/employees, retained attorneys, and "an individual engaged solely to draft applications for funding from a governmental agency or an entity exempt … under 501(c)(3)." CHAR500 Sched. 4a: "Professional fund raising does not include activities by … a grantwriter who has been hired solely to draft applications for funding from a government agency or tax exempt organization" | Paid consultants | AG statute booklet; CHAR500 https://ag.ny.gov/sites/default/files/regulatory-documents/CHAR500_2018.pdf ; CHAR014 https://ag.ny.gov/sites/default/files/2022-10/char014.pdf (live). Exclusion also confirmed on nysenate.gov §171-a in this session (see 3.1). Secondary source dates the exclusion to 2014-07-01 (Nonprofit Revitalization Act) | Exclusion covers an "individual"; whether a firm/LLC is likewise excluded is not stated — confirm with the Charities Bureau (Charities.Fundraising@ag.ny.gov, 518-776-2160). Donor strategy, appeals, campaigns, sponsorships = FRC work |
| R5 | §171-a(6) Commercial co-venturer | For-profit primarily in other commerce that advertises purchases benefit a charity | Cause marketers | same; CHAR009 https://ag.ny.gov/sites/default/files/regulatory-documents/char009.pdf | If the SaaS ever advertises "X% of subscriptions benefits [charity]," CCV contract and record rules apply (AG says no CCV registration filing) |
| R6 | §173(1) Registration, fee, bond | $800 annual fee for PFR and FRC; $10,000 bond for PFR only (AG CHAR014: FRC no bond); one-year term; material changes reported within 20 days; professional solicitor fee $80 (§173-b) | PFRs, FRCs | https://www.nysenate.gov/legislation/laws/EXC/173 (live; $800 and $10,000 confirmed) | Forms: CHAR014 (FRC); CHAR013 + CHAR015 bond (PFR); CHAR012 (solicitor) |
| R7 | §173(3) Criminal penalty | Willful violation is a misdemeanor | PFRs/FRCs/CCVs | AG statute booklet | Unregistered FRC activity is criminal, not merely civil |
| R8 | §173-a Contracts and statements | Written contract before services; certified copy filed with AG within 10 days; PFR closing statement (CHAR037) within 90 days of termination; interim statements annually | PFRs, FRCs, CCVs | https://www.nysenate.gov/legislation/laws/EXC/173-A ; CHAR037 https://ag.ny.gov/sites/default/files/regulatory-documents/char037.pdf | Build CHAR016A filing into cohort onboarding |
| R9 | 15-day cancellation right; mandatory contract terms | Charity may cancel without cost for 15 days after the contract is filed with the AG; contract must state parties' AG IDs, dates, services, "clear statement of the financial arrangement," signatures, cancellation right (CHAR016B). Failure to stop within 15 days of cancellation is "deemed to be a continuing fraud" | PFRs/FRCs | CHAR013/CHAR014/CHAR009 instructions (live); statutory basis §§172-d, 173-a, 174, 174-a (§174-a text not fetched) | Expect a 15-day free-cancellation window; write fees as a clear statement |
| R10 | §172-d(5) Charities may not hire unregistered PFR/FRC | Charity may not contract with a PFR/FRC required to register unless the vendor supplies a sworn statement of registration and compliance | Charities and their vendors | https://www.nysenate.gov/legislation/laws/EXC/172-D (live) | Client compliance officers will ask for your registration or a written statement of the exclusion scope |
| R11 | §172-d(1)–(2), (16) Prohibited acts | Material misstatements in filings; fraud/false pretenses; confusingly similar names | All under 7-A | same | Accuracy of drafted proposal content is a shared exposure |
| R12 | §174-b Solicitation disclosures | Written solicitations must state the charity's last financial report is available from the org/AG, describe programs, list AG website/phone; PFR/solicitor identity and compensation disclosures | Charities, PFRs, solicitors | https://www.nysenate.gov/legislation/laws/EXC/174-B (live) | Appeal templates supplied to members must carry NY disclosure language |
| R13 | §175 / §177 Enforcement | AG may enjoin, seek restitution/penalties, cancel registration, remove officers, dissolve; §177(2) civil penalty up to $1,000 per act/omission plus up to $100/day after 30-day cure notice | Charities, PFRs, FRCs, CCVs | https://www.nysenate.gov/legislation/laws/EXC/175 ; /177 (live) | Per-act, per-day exposure multiplies across a multi-client cohort |
| R14 | §172 / §172-a Charity registration; $25,000 exemption | Charities soliciting in NY (including from government/foundations) must register (CHAR410, $25). Exempt: gross contributions <$25,000 "provided none of its fund raising is carried on by professional fund raisers or fund raising counsel," plus religious, PTAs, certain educational, single-agency-funded orgs | NY-soliciting charities | https://www.nysenate.gov/legislation/laws/EXC/172 ; /172-A ; AG FAQ https://ag.ny.gov/resources/organizations/charities-non-profits-fundraisers/charities-non-profits-fundraisers-faqs (live) | Cohort intake must verify each member is registered or exempt; **engaging an FRC eliminates a small org's under-$25k exemption** |
| R15 | §172-b thresholds | >$1,000,000: CPA audit; $250,000–$1,000,000: CPA review; ≤$250,000: unaudited; due 15th day of 5th month after FYE | Registered charities | https://www.nysenate.gov/legislation/laws/EXC/172-B (live; confirmed) | NYC HHS prequalification mirrors these tiers |
| R16 | CHAR500 fee schedule (13 NYCRR §91.5) | Art. 7-A fee $10 if revenue <$250,000, $25 if ≥$250,000 or if a PFR/FRC was used; EPTL fee by net worth $25–$1,500; 7A due 4.5 months after FYE, EPTL 6 months; 180-day automatic extension. Schedule 4a requires disclosure of any PFR/FRC used (name, registration number, compensation) | Registered charities | https://ag.ny.gov/sites/default/files/2022-10/Regs-F.pdf ; CHAR500 instructions https://ag.ny.gov/sites/default/files/regulatory-documents/CHAR500_instructions_2018.pdf (live) | Unregistered FRC status will surface on the member's own CHAR500 |
| R17 | N-PCL §715 Related party transactions | Board must find the transaction fair, reasonable, in the corporation's best interest; consider alternatives; majority vote; contemporaneous documentation; AG remedies include rescission, double damages, removal | NY not-for-profit corporations | https://www.nysenate.gov/legislation/laws/NPC/715 (live) | If any venture founder sits on a member's board (or vice versa), the engagement is a related-party transaction for the member |
| R18 | N-PCL §715-a Conflict-of-interest policy | Every board must adopt a COI policy with disclosure, recusal, documentation, and annual director statements; no size threshold | All NY NFP corporations | https://www.nysenate.gov/legislation/laws/NPC/715-A (live) | Baseline readiness deliverable; NYC HHS PQL requires upload |
| R19 | N-PCL §715-b Whistleblower policy | Required at ≥20 employees and >$1,000,000 prior-year revenue; procedures, confidentiality, administrator, distribution | NFP corps meeting both tests | https://www.nysenate.gov/legislation/laws/NPC/715-B (live) | Flag members crossing 20 employees/$1M; NYC PQL asks for it regardless |
| R20 | N-PCL §712-a Audit oversight | Boards/independent audit committees of §172-b audit filers must oversee the audit; >$1M revenue adds pre-audit scope review, risk/control discussion, annual independence assessment | NFP corps filing audits | https://www.nysenate.gov/legislation/laws/NPC/712-A (live) | Audit-committee charter templates for members near $1M |
| R21 | Executive Order 38 (exec comp / admin caps) | Formerly $199,000 cap and 25%→15% admin limit for state-funded providers (2013). Not continued by EO 6 (2021-10-08); DOH repealed 10 NYCRR Part 1002 (2022); other agencies repealed earlier | Formerly state-funded providers | https://www.budget.ny.gov/guide/bprm/b/b-1208.html (historical); https://nyscouncil.org/formal-repeal-of-executive-compensation-executive-order/ ; Barclay Damon alert (secondary) | Treat EO 38 as rescinded; confirm no residual language in legacy contracts |
| R22 | AFP Code, Standards 23–24 (current numbering; formerly 21–24) | Compensation "may never be based on a percentage of funds raised"; decline finder's fees/commissions; proposal writers must not be paid a percentage of funds sought or raised | AFP members (voluntary) | https://afpglobal.org/ethics/code-ethical-standards ; 2019 guidelines PDF; Standard 21 deep dive (live) | Flat/retainer/hourly pricing only |
| R23 | AFP Position Paper on Professional Compensation | Percentage compensation "can encourage abuses, imperil the integrity of the voluntary sector"; bonuses allowed if not tied to a percentage of funds raised; adopted 1992, technical updates Sept 2024 | AFP members | https://afpglobal.org/sites/default/files/attachments/generic/Prof_Compensation_Position_Paper_2024_updates.pdf (live) | Staff bonuses tied to milestones, not to member grant dollars |
| R24 | GPA Code of Ethics, Standards 17–20 (rev. 2023-06-10) | Work for salary/wage/fee; bonuses not based on a percentage of grant monies; no finder's fee, commission, or percentage compensation; compensation not written into grants unless the funder allows; finder's fee includes payment "contingent upon the nonprofit receiving a grant" | GPA members | https://grantprofessionals.org/page/ethics (live) | "Pay only if funded" pricing is an express violation; do not bake fees into member grant budgets without funder permission |
| R25 | State laws on contingent/percentage fees | No state statute found that flatly bars contingent grant-writing fees. California Gov. Code §12599.1 reclassifies percentage-paid "fundraising counsel" as commercial fundraisers; Hawaii HRS §467B-12 and Ohio RC §1716.08 require disclosure of percentage/contingent compensation; California B&P §17510.87 caps paid solicitors at 50% of net. NY: not stated | Counsel/solicitors in those states | https://california.public.law/codes/government_code_section_12599.1 ; https://www.capitol.hawaii.gov/hrscurrent/Vol10_Ch0436-0474/HRS0467B/HRS_0467B-0012_0005.htm ; https://codes.ohio.gov/ohio-revised-code/section-1716.08 (live) | If software later serves clients outside NY, percentage pricing changes the regulatory category in CA — keep pricing non-contingent everywhere |
| R26 | 2 CFR 200.459 Professional service costs | Allowable when reasonable and "not contingent upon recovery of the costs from the Federal Government"; eight relevance factors; retainers need evidence of bona fide services | Federal award recipients/subrecipients | https://www.law.cornell.edu/cfr/text/2/200.459 (live) | Members can charge your fees to federal awards only under a documented, non-contingent agreement with rates and termination terms |
| R27 | 2 CFR 200.460 Proposal costs; 200.458 Pre-award costs | Proposal costs "normally should be treated as indirect costs and allocated to all current activities"; pre-award costs allowable only with written agency approval | Federal award recipients | https://www.law.cornell.edu/cfr/text/2/200.460 ; /200.458 (live) | Grant-writing fees are recoverable through the member's indirect rate, not as a direct charge to the grant won; help members establish an indirect rate |
| R28 | 2 CFR 200.450 Lobbying | Costs of "influencing activities associated with obtaining grants" and legislative lobbying unallowable; technical/factual presentations excepted | Federal award recipients | https://www.law.cornell.edu/cfr/text/2/200.450 (live) | Keep government-relations/appropriations advocacy separate and separately billed |
| R29 | IRS inurement / private benefit; IRC §4958 | No net earnings may inure to insiders; org may not be operated for private interests; excess-benefit excise taxes; revocation | 501(c)(3)s and insiders | https://www.irs.gov/charities-non-profits/charitable-organizations/inurement-private-benefit-charitable-organizations ; /intermediate-sanctions (live) | As a for-profit vendor: no issue; fees to a member's insider-affiliated vendor trigger §4958/§715 scrutiny |
| R30 | Rev. Rul. 72-369; Rev. Rul. 71-529; B.S.W. Group | Managerial/consulting services at cost to unrelated exempt orgs do not qualify — "lacks the donative element." Contrast 71-529 (services to controlling member colleges at substantially below cost, <15% of costs from fees, qualifies). Applied in recent adverse letter 202550033 | Would-be 501(c)(3) service providers | https://www.irs.gov/pub/irs-tege/rr72_369.pdf ; https://www.irs.gov/pub/irs-tege/rr71-529.pdf ; https://www.irs.gov/pub/irs-tege/eotopich86.pdf ; https://www.irs.gov/pub/irs-wd/202550033.pdf (live) | A fee-for-service shared funding office is unlikely to qualify as a 501(c)(3) unless fees are substantially below cost (grant-subsidized) and all clients are 501(c)(3)s; serving for-profits kills it |
| R31 | UBIT — IRC §§511–513; Pub. 598 | Income from a regularly carried-on trade or business not substantially related to exempt purpose; Form 990-T at ≥$1,000 gross UBI | Exempt organizations | https://www.irs.gov/charities-non-profits/unrelated-business-income-tax ; https://www.irs.gov/publications/p598 (live) | A nonprofit affiliate selling subscriptions at market rates faces UBIT and, if substantial, exemption risk |
| R32 | Fiscal sponsorship — NNFS Guidelines (Model A / Model C) | Model A: project becomes a program of the sponsor, which holds all legal/fiduciary responsibility and employs staff. Model C: project is a separate entity; sponsor makes a pre-approved grant under an arm's-length agreement, separate fund accounting, disclosed admin charges, variance power, annual audit. Fee percentages and spin-out timing: not stated in NNFS guidelines | Fiscal sponsors (voluntary standards) | https://www.fiscalsponsors.org/nnfs-guidelines ; Model C PDF https://fiscalsponsors.squarespace.com/s/NNFS-Guidelines-for-Pre-Approved-Grant-Fiscal-Sponsorship.pdf ; Model A PDF; NYLPI guide https://www.nylpi.org/wp-content/uploads/2020/07/Fiscal-Sponsorship-Guide.pdf (live) | If the "shared office" receives grants for unincorporated members, it is acting as a fiscal sponsor — requires a 501(c)(3) sponsor, variance power, and NY Art. 7-A registration. The 5–15% fee range is industry practice (verified vendor fees in Part 2: 6–10%, 15% on government funds), not an NNFS standard |
| R33 | NY fiscal sponsorship registration | Any org soliciting in NY (including foundation/government grants) must register; the sponsor is the registrant for projects; NYLPI cautions Model C must not be a mere conduit to a non-exempt project. AG fiscal-sponsorship-specific guidance: not found | Sponsors and projects soliciting in NY | https://ag.ny.gov/resources/government-organizations/charities-nonprofits-fundraisers/charities-registration ; NYLPI guide (live) | Sponsor must be CHAR410-registered and file CHAR500; a project soliciting in its own name may need its own registration |
| R34 | SHIELD Act GBL §899-bb | "Any person or business" owning/licensing NY residents' computerized private information must maintain reasonable safeguards; small-business (<50 employees, <$3M revenue, or <$5M assets) scaling; AG enforcement; no private right of action | Any person or business (nonprofits included) | https://www.nysenate.gov/legislation/laws/GBS/899-BB (live) | Written security program before hosting beneficiary or donor data |
| R35 | GBL §899-aa breach notification (amended Dec 2024) | Notice to residents within 30 days of discovery; notify AG, Department of State, State Police (and DFS if a 23 NYCRR 500 entity); consumer reporting agencies if >5,000 residents; "private information" adds medical and health-insurance information effective 2025-03-21; penalties up to greater of $5,000 or $20 per failed notice, max $250,000 | Any person or business | https://www.nysenate.gov/legislation/laws/GBS/899-AA ; S2659B https://www.nysenate.gov/legislation/bills/2023/S2659/amendment/B ; Ropes & Gray summary (live) | Basic-needs orgs hold SSNs, benefits IDs, health data — a 30-day clock and multi-agency notice belong in the incident-response plan and member DPAs |
| R36 | HIPAA | Applies to covered entities and business associates only | Covered entities/BAs | https://www.hhs.gov/hipaa/for-professionals/covered-entities/index.html (live) | Most basic-needs nonprofits are not covered; if a member bills Medicaid and you process PHI, a BAA is needed; SHIELD's medical category applies regardless |
| R37 | FERPA | Binds educational agencies receiving ED funds; contractors may receive records only under direct control and §99.33 redisclosure limits | Schools; contractors via contract | https://studentprivacy.ed.gov/ferpa (live) | Education members receiving student records take on "school official" duties that the software inherits |
| R38 | NY Education Law §2-d | Third-party contractors receiving student data must sign the Parents Bill of Rights, adopt a data security and privacy plan, encrypt, train, not sell/market, notify breaches without unreasonable delay; penalties up to $1,000/$5,000/$10,000 per violation and $10 per affected individual | Contractors of NY educational agencies | https://www.nysenate.gov/legislation/laws/EDN/2-D (live) | Mandatory if members or the software ingest DOE/school student data |
| R39 | NYC PASSPort enrollment and HHS prequalification | Vendor Enrollment Package to reach "Filed" status; HHS providers need an Approved HHS PQL: certificate of incorporation, board list, bylaws, IRS letter, COI policy, whistleblower policy, Charities Bureau filings by tier (CHAR500 + 990 + CPA review $250k–$1M; audit >$1M) | NYC vendors and HHS providers | https://www.nyc.gov/site/mocs/passport/articles/complete-vendor-enrollment.page ; https://www.nyc.gov/site/mocs/passport/articles/submit-hhsa-pql.page (live) | The PQL document list is a ready-made readiness checklist; the venture itself must enroll if the City ever pays it directly |
| R40 | NYC Indirect Cost Rate Initiative / HHS Cost Manual | Cost Manual (effective FY2020, derived from 2 CFR 200) governs City HHS contracts; Accepted ICR via 10% de minimis, federal NICRA, or CPA Independent Accountant's Report, valid three fiscal years; initiative baselined $94M for 361 orgs; FY26 policy: 50% advances on eligible HHS contracts; Council Int. 0245-2026 proposes a 20% de minimis (pending) | NYC HHS providers and agencies | https://www.nyc.gov/site/mocs/opportunities/icr-initiative.page ; Cost Manual PDF https://www.nyc.gov/assets/nonprofits/downloads/pdf/NYC%20HHS%20Cost%20Policies%20and%20Procedures%20Manual_12.22.2022.pdf ; https://legistar.council.nyc.gov/LegislationDetail.aspx?GUID=1DFC1C06-8FDC-4E48-A1AA-4F71814BFBF3&ID=7862028 (live) | High-value service: prepare the ICR schedule and Independent Accountant's Report so members exceed 10%; your fees are recoverable inside members' indirect pools; software could automate ICR schedules |
| R41 | NYC Nonprofit Resiliency Committee | Est. 2016; produced the Cost Manual, ICR initiative, 25% standard advances, automatic budget modifications up to 10%, three standard HHS contracts. Current page returns 404 | NYC HHS sector | https://www.nyc.gov/assets/opportunity/pdf/policybriefs/non-profit-resiliency.pdf (live) | Standard contract/cost definitions let budget templates be standardized across City agencies |
| R42 | NY State Finance Law Art. XI-A §179-f prompt payment | State agencies pay within 30 calendar days of a proper invoice (15 days for small businesses filing electronically), else interest under §179-g | State agencies | https://www.nysenate.gov/legislation/laws/STF/179-F (live) | Interest claims are a recoverable line item for state-funded members |
| R43 | NY State Finance Law Art. XI-B prompt contracting (§§179-q–179-ee) | Timeframes for new (§179-s) and renewal (§179-t) NFP contracts, advance payments (§179-u), interest for late contracts (§179-v), short-term revolving loan fund (§179-z). Day counts and interest formula: not extracted | State agencies contracting with NFPs | https://www.nysenate.gov/legislation/laws/STF/A11-B ; /179-V (index live; details not verified) | Members with late State contracts may be owed interest and eligible for bridge loans; verify §179-v mechanics before advising |
| R44 | Wyoming DUNA Act, W.S. 17-32 (SF0050) | Effective 2024-07-01; ≥100 members; separate legal entity (17-32-107); members not liable by membership; profits must serve the nonprofit purpose, no distributions, "reasonable compensation" allowed (17-32-104); reverts to a UNA below 100 members (17-32-114); "charitable purpose" defined by reference to 501(c)(3) (17-32-102). Tax-election language: not stated in extracted text | Wyoming DUNAs | https://www.wyoleg.gov/2024/Enroll/SF0050.pdf ; https://a16zcrypto.com/posts/article/duna-for-daos/ (live) | Nothing in the act confers 501(c)(3) status — Form 1023 still required and Rev. Rul. 72-369 still applies if it sells services; a DUNA soliciting NY contributions needs Art. 7-A registration |
| R45 | New York: no DUNA/UUNAA | NY has no statute governing nonprofit unincorporated associations; General Associations Law §§12–13 allow suits by/against the president or treasurer; an unincorporated association "is not a legal entity separate from the persons who compose it" (Meinhart v. Contresta) | NY unincorporated groups | https://independentsector.org/wp-content/uploads/2016/12/PrinciplesStateNewYork2016.pdf ; https://law.justia.com/codes/new-york/gas/article-3/ (secondary + index) | Unincorporated cohort members carry personal-liability exposure in NY; incorporate under N-PCL or use a fiscal sponsor |
| R46 | IRS treatment of crypto donations | No gain to donor; FMV deduction if held >1 year; donee signs Form 8283 for deductions >$5,000; donee files Form 8282 if disposed within 3 years; CCA 202302012: qualified appraisal required >$5,000 — exchange quotes do not suffice | Donors and donee charities | https://www.irs.gov/individuals/international-taxpayers/frequently-asked-questions-on-virtual-currency-transactions ; https://www.irs.gov/pub/irs-wd/202302012.pdf ; https://www.irs.gov/instructions/i8283 (live) | Any crypto-giving feature must generate 8283 acknowledgments, track the 3-year 8282 clock, and warn donors about appraisals |
| R47 | NY AG crypto guidance for charities | No Charities Bureau guidance specific to cryptocurrency donations found; Lawyers Alliance notes NYPMIFA (N-PCL Art. 5-A) prudence governs hold/convert decisions; DFS BitLicense governs exchanges | NY charities | https://lawyersalliance.org/userFiles/uploads/legal_alerts/Cryptocurrency_Legal_Alert.pdf (live; AG guidance not stated) | Members' gift-acceptance and investment policies must address crypto; do not represent that the AG has issued crypto-specific rules |

Open questions from the regulatory pass:
1. Whether the §171-a(9) grant-writer exclusion (worded for an "individual") extends to a firm/LLC — ask the Charities Bureau.
2. §174-a (15-day cancellation) statutory text not fetched; verified via AG forms only.
3. 13 NYCRR Parts 90–99 (Charities Bureau regulations on PFR/FRC filings) not reviewed.
4. NNFS does not publish fee norms or spin-out guidance; 5–15% is industry practice (Part 2 verified 6–10%; 15% on government funds).
5. State Finance Law §§179-s/t/v day counts and interest rate not extracted.
6. IRS position on DUNA 501(c)(3) eligibility: not stated anywhere found.
7. Federal de minimis indirect rate (15% under the 2024 Uniform Guidance revision) not verified this pass; NYC de minimis remains 10% with a 20% proposal pending.
8. §172-b(9) Department of State dual filing: enacted 2021; practitioner sources report elimination in 2022; not re-verified against current statute text.

### 3.3 Business-model implications (synthesis)

1. **Entity form:** operate the funding office as a for-profit (LLC or public-benefit corporation) selling to nonprofits, or as a program housed inside an existing 501(c)(3) (Model A fiscal sponsorship) that is grant-subsidized and free/below-cost to members. Do not seek stand-alone 501(c)(3) status for a fee-for-service consultancy (Rev. Rul. 72-369).
2. **Registration posture:** if the service is limited to drafting applications to government and 501(c)(3) funders, it is exempt from FRC registration under §171-a(9); the moment it advises on donor/board/recurring-gift solicitation or plans campaigns, register as fund raising counsel ($800/yr, CHAR014, file each contract within 10 days). Never take custody of contributions or make direct asks (avoids PFR status and the $10,000 bond).
3. **Pricing:** flat cohort fee or subscription; milestone bonuses tied to deliverables, never to dollars raised (AFP 21/23/24, GPA code; also avoids funder objections to commissions charged against grants).
4. **Data:** SHIELD Act program from day one; minimize beneficiary PII; contracts with each member as data controller.
5. **Member readiness rules to encode:** CHAR500 + §172-b review/audit tiers, conflict-of-interest and whistleblower policies (N-PCL §715-a/715-b), related-party rules (§715), prompt-contracting interest claims, PASSPort vendor status.

---

## Market gap conclusion

The evidence shows a market saturated with **grant databases** (Candid, Instrumentl, GrantStation, GrantWatch) priced for organizations with ≥$500k budgets and dedicated staff, a crowded and fast-commoditizing layer of **AI drafting tools**, and a NYC ecosystem of **capacity builders, fiscal sponsors, and bridge lenders** (Fund for the City of New York, Nonprofit New York, CRE, Cause Effective, Robin Hood/Blue Ridge Labs) that each solve one slice — money, back office, coaching, or training — but none of which runs an integrated, ongoing *funding operation* for a small organization. What no comparable offers, and what the NFF, Urban Institute, Comptroller, CUF, GrantStation, and FEP data say small NYC nonprofits actually lack, is: (1) **verified readiness** — an auditable state of registrations (CHAR500, §172-b tier), policies, financials, and narratives that funders can trust; (2) **relationship intelligence** — which funders have funded peers, who is reachable through the cohort's combined board network, and renewal timing; (3) **volume workflow** — the disciplined pipeline that moves an org from 1–2 applications a year (64.5% chance of any award) to 6+ (≈90–99%); (4) **capital-progression finance** — cash-flow forecasting against known City/State payment lags, prompt-contracting interest recovery, bridge-loan readiness, and reserve targets; (5) **reporting and renewal** — post-award compliance that converts first grants into repeat grants and first donors into recurring donors (the only segment where FEP shows retention strength); and (6) **cohort economics** — a shared development office whose fixed cost is split 5–8 ways, delivering a full-time-equivalent funding function for the price of a database subscription. The defensible opportunity is therefore not another database or AI writer but an **integrated readiness-verification + workflow + relationship-intelligence system with a human-guided cohort layer**, priced flat (never percentage-based), sold by a for-profit or hosted inside a fiscal sponsor, registered as fund raising counsel when it touches donor strategy, and differentiated by NYC-specific payment-delay and funder data that national tools do not carry.

Three specifics sharpen the wedge. First, the price vacuum: AI writers now cost $18–$79/month and incumbents $1.2k–$12k/year, while the cheapest human help (fractional development) starts at ~$48k/year — a cohort that delivers a shared development function for roughly the cost of a Nonprofit New York membership plus an Instrumentl seat, split 5–8 ways, has no verified competitor. Second, NYC has a concrete, monetizable compliance-to-cash pathway that no tool addresses: the HHS PQL document set, the Indirect Cost Rate schedule (moving members off the 10% de minimis), prompt-contracting interest under State Finance Law, and Comptroller/Checkbook late-contract data — "capital progression" can be operationalized as recovering money members are already owed. Third, the regulatory posture is itself a moat: NY's grant-writer exclusion lets the core drafting service operate without registration, while voluntary FRC registration ($800/year, no bond) and AFP/GPA-compliant flat pricing signal trustworthiness that most AI entrants and Upwork writers cannot. The two-thirds of public charities under $500k in expenses (NCCS) and the 75% of NY nonprofits with government funding (Urban) define a large, under-served, and now acutely stressed customer base; the design risk is not demand but unit economics, which is exactly what the Open Collective Foundation collapse warns about and what a cohort (rather than one-to-one) delivery model is meant to solve.

---

## Summary of decision-relevant findings

1. NFF 2025: 52% of nonprofits have ≤3 months cash, 36% ran 2024 deficits (10-year high), 84% of government-funded orgs expect cuts — the problem is real and worsening.
2. NYC-specific pain is documented by two Comptrollers: 90.7% of City human-services contracts registered late (FY24), $861M in unpaid nonprofit invoices (Apr 2025), 76% of State NFP contracts late (CY2025), first City payments averaging 6.5 months after start.
3. GrantStation 2026: 1 application → 64.5% chance of any award; 6+ → ~90–99%. 68.3% of orgs do no collaborative grantseeking — volume and collaboration are the leverage points.
4. Giving USA 2026: $617.2B total; foundations 19%, individuals 64% — a grants-only product ignores most of the money; FEP retention is stuck at 18%, with growth from repeat donors only.
5. Instrumentl costs $3.6k–$12k/yr; Candid ~$1.2k–$1.7k/yr; both are databases/workflow for staffed orgs — no readiness verification, NYC payment intelligence, or cohort support.
6. Open Collective Foundation's 2024 collapse on a 5% fee is a live warning against under-priced high-touch shared services.
7. NY law: grants are "contributions," but a person engaged *solely* to draft applications to government/501(c)(3) funders is exempt from fund-raising-counsel registration; broader donor-strategy advice requires FRC registration ($800/yr, contracts filed within 10 days); soliciting or handling funds makes you a PFR ($10,000 bond).
8. AFP Standards 21/23/24 bar percentage-based and contingent fees — price flat or by milestone, never by dollars raised.
9. Rev. Rul. 72-369: a fee-for-service consultancy to nonprofits is not itself 501(c)(3)-eligible; run as a for-profit/PBC or inside a grant-subsidized fiscal sponsor.
10. Member readiness must encode NY §172-b tiers (≤$250k unaudited; $250k–$1M review; >$1M audit), SHIELD Act safeguards, and — for the DAO member — a fiscal sponsor or NY corporation, since a Wyoming DUNA is not a recognized NY charity form.