Charitable Allies Inc.

“Zachary Kester, has several business relationships with other Directors of Charitable Allies through his work with the organization. Zachary Kester is on the Board of Directors of Ascent 121, the organization that Director Megan McGuire serves as CEO. Ascent 121 is also a client of Charitable Allies. Matt McGuire is the CEO of Brackets for Good, which is a client of Charitable Allies. Rima Shahid is the Executive Director of Women4Change of Indiana, which is a client of Charitable Allies. It is important for Charitable Allies to have client representation on its Board and these are such representatives.”

“Each member of the board of directors is given a copy of the 990 prior to filing so that they may review and provide feedback.”

“Board members are required to disclose any potential conflicts of interest at each board meeting and are subject to sanctions for failure to disclose a potential conflict. Prior to electing any board member, the Executive Director reviews any past employment history that may be a conflict of interest. The ED also looks into any change of employment or outside activities for conflicts when these things occur.”

“Comparability data was examined thoroughly when determining the Executive Director's compensation. The board also reviewed and approved the compensation structure for the Executive Director and the board reviews any raise or bonus structure for the ED as well.”

“The governing documents, conflict of interest policy and financial statements are not currently treated as public documents.”

“From September 3, 2019 to December 20, 2019, Notre Dame sponsored a fellowship for Charitable Allies. We are reporting this fellowship here, under Volunteers, as our one non-board member volunteer for the year of 2019.”

“Description of Services and Explanation of Public Charity Status. Charitable Allies serves tax-exempt organizations and/or their key stakeholders (members, officers, directors, trustees or donors) with annual gross receipts at or below $10m or assets with a value below $100m. If a potential client's revenue and assets exceed these levels, Charitable Allies will only represent that organization if it lacks liquid assets to pay legal counsel generally, if other law firms with deep tax-exempt organization experience were conflicted off of representation, if the client only needs the services of CA as "back up" or support counsel to their general counsel law firm or in-house counsel, or the client can demonstrate through some other compelling factor that it is a member of a charitable class. The provision of legal and educational services as described in Part III, Lines 4a and 4b is charitable because the clients themselves serve tax-exempt purposes, they lack adequate representation in the private sector and are generally unable to pay market rates for sophisticated, unique exempt-organization legal services that require specialized* knowledge, and they are so numerous and indefinite that aiding them benefits the whole community and not private interests. Charitable Allies' essential purpose is to serve a charitable class made up of tax-exempt orgs (below a certain size or otherwise needy) and their stakeholders in helping them fulfill their exempt purpose. Charitable Allies provides these services generally at reduced rates (low bono)--calculated as at or below 50% of FMV--and sometimes free. Charitable Allies does not compete with other private law firms. The most comparable are (1) an EO Group within a large law firm, (2) a boutique law firm that focuses on exempt-organization representation, and (3) a small law firm that provides EO legal services. Most clients served are unable to afford the market rates of (1) and (2). However, most attorneys and/or firms in group (3), as well as some in groups (1) and (2), lack the depth of EO experience and knowledge of the attorneys at Charitable Allies, and they are distinguishable on the grounds that they are not subject to nonprofit governance requirements and restrictions on ownership that apply to nonprofit law firms. CA management answers to a Board of Directors, salaries for attorneys are set using comparable rates paid to lawyers in other types of nonprofit work, and attorneys do not share in the ownership or successes of CA except through a modest pre-approved, fixed bonus structure not tied to legal service revenue. Attorneys operating in for-profit law firms do not have these restrictions. Ultimately, Charitable Allies charges rates that are based on client's limited ability to pay. Charitable Allies is also frugal in infrastructure and materials costs, and pays a lower salary than the private sector. Many of the staff attorneys take advantage of income-based repayment and loan forgiveness programs for school loans. Charitable Allies does not aim to compete with private, for-profit lawyers; its work is providing a service to clients that attorneys in private practice cannot afford to represent. Charitable Allies ultimately provides services that require a high level of knowledge and skill, and its work is designed to help its clients do their tax-exempt work work more effectively. *The word "specialized" is used above in the Rule of Ethics 1.1 competency sense, not in the Rule 7.2 sense.”

“Real estate transactions, employment law, contract analysis and disputes, and nearly any other common legal issue for which a nonprofit organization would need legal representation.”

“Add back adjustment.”