Two entities. One mission.
A 501(c)(3) fund supporting frontline immigration legal services, paired with a 501(c)(4) advocacy arm. Governed by strict legal and financial separation under a formal Resource Sharing Agreement.
Built for complementary power.
Most nonprofits are limited to either charitable work or political advocacy. We do both through two legally separate entities that share resources under strict IRS-compliant terms, all in service of immigration legal organizations on the front lines.
The operational engine. Will deploy capacity-building grants to frontline immigration legal organizations through the Discovery Protocol. Conducts 90-day discovery cycles to map systemic bottlenecks in immigration legal services. Will eventually fund open-source legal infrastructure tools informed by field data. Contributions will be tax-deductible retroactively upon approval of our pending 501(c)(3) determination.
The political arm. Provides legislative and political support for immigration system reforms: lobbying for administrative modernization, legislative and policy advocacy, and translating technical pilots from the Fund into law and policy. Contributions are not tax-deductible.
The Tri-Gate: Three questions, every decision.
Before any capital is deployed, every grant decision must clear all three gates. This framework ensures we maintain rigor without losing speed.
The firewall that makes it work.
The two entities operate under a formal Resource Sharing Agreement (RSA), a legal document that governs exactly how resources, staff time, and office infrastructure are shared between the 501(c)(3) and 501(c)(4).
The Fund (c3) serves as the "Provider" entity and is reimbursed at fair market value for any resources shared with Action (c4). This prevents prohibited "private inurement," ensuring that charitable contributions never subsidize political advocacy work.
What's Separated
- Separate bank accounts (dual Chase Business Checking)
- Separate governance (independent Board oversight)
- Separate financial records (independent QuickBooks instances)
- Separate program operations (no comingling of grant capital)
What's Shared (Under RSA Terms)
- Office space and digital infrastructure (reimbursed at FMV)
- Staff time where legally permissible (tracked and allocated)
- Strategic intelligence (bottleneck data informs both charitable programs and policy advocacy)
Active oversight. Not passive compliance.
Our Board of Directors consists of independent voting members who actively participate in operational planning, grant decisions, and strategic direction. This is not a passive advisory board. Members review every proposed grant through the formal Vetting Matrix and vote on all funding recommendations.
Board Responsibilities
- Review and vote on all Discovery Protocol grant recommendations via the three-tier Vetting Matrix
- Analyze Monthly Executive Flash Reports covering pipeline movement, capital burn rates, and technology intelligence
- Ensure the dual-entity firewall remains intact through quarterly Resource Sharing Agreement reviews
- Execute the Conflict of Interest Policy annually
- Vote on annual operating budgets for both entities
Key Board Resolutions (Q1 2026)
- Ratified organization-to-organization grant model exclusively. No direct-to-individual grants
- Delayed technology development until Discovery Protocol validates bottleneck data
- Paused 501(c)(4) operations for Q1/Q2 2026 to concentrate resources on the pilot
- Confirmed seed capital balance for pilot deployment
- Directed development of the Master Dossier and Operational Roadmap
Structural integrity isn't overhead. It's how you prove you can be trusted with other people's money.