Checked by someone who didn't prepare it.
Your administrator prepares the return. Your grant system pays the grants. Your custodian holds the assets. Each is a party to what it records. Type the foundation's name or EIN: the 990-PF you filed comes back from the IRS, its arithmetic re-done exactly and sealed. Free, in seconds, checkable by anyone you send it to.
Three systems act. A fourth reads.
Your CPA firm prepares the 990-PF. Your grant system pays the grants. Your custodian holds the assets. Each is a party to what it records. We are party to none of it. We check.
| What you run | What it does | What a second party adds |
|---|---|---|
| Your CPA firm | Prepares and files the 990-PF; monitors the payout it computed. | A second party that re-does the return it filed. |
| Your grant system | Pays the grants, runs the applications, reports the program. | The return's own figure for what was paid, set beside what it says was to be paid. |
| Your custodian or reporting platform | Holds the assets; keeps and reports the books. | A reading of the books by a party that does not keep them. |
| The record | Reads the filed return and re-does it exactly. Seals what the committee decided, the day it decided. Publishes a fingerprint anyone can check. | It is the second party to all three: it re-does the return, reads the books and seals the decisions. |
A preparer and a second party that re-does the return are two parties by definition. That is all independence means here; it says nothing about any firm’s own review. A record kept by a party with no return to prepare, no grant to pay and no asset to hold can be checked without asking us. A trustee, an auditor or an attorney general can check it.
A trustee answers for decisions made years ago, on numbers nobody kept.
The public filing shows the figures. It does not show what the committee saw, decided or approved, or on which numbers. The record is the contemporaneous answer, kept where nobody, us included, can rewrite it.
The examination: The IRS asks about a year three chairs ago.
The new chair: Why is the spending rate what it is, and who set it?
The family: A dispute over a gift, and what the committee saw when it decided.
The auditor: How was that manager kept, on which numbers?
The attorney general: How was the restricted gift invested?
The next preparer: What did the last one file, and does this year's opening balance agree?
What the record holds when it is asked: the return as filed, re-done by a party that did not prepare it; each decision, the day it was made, the figures it rested on, and who approved it; a fingerprint anyone can check without us. It does not decide whether a standard was met. Counsel does. It makes sure the facts exist when counsel is asked.
Nine controls, read from the return, in six words.
Agrees. Differs. Reported. Not reported. Not applicable. Not checked. Agrees or differs where the form's own arithmetic can be re-done; reported or not reported where the return carries the figure or does not; not applicable where the form says the Part does not apply; not checked where a second sealed year is needed. Compliant is a word we never use; it is counsel's, not ours.
FC-1: Minimum investment return
Part IX line 6 against 5% of line 5, prorated for a short year
FC-2: Excise tax
Part V line 1 against the rate the form prescribes for the filer: 1.39% of net investment income, or 4% of gross investment income for a foreign organization
FC-3: Distributable amount
Part X line 7 against the form's own chain from line 1
FC-4: Payout coverage
Part XI total against Part X line 7
FC-5: Payout deadline
Part XII undistributed income and the date it falls due
FC-6: Holdings tie-out
The corporate-stock schedule against Part II line 10b
FC-7: The foundation's own answers
Part VI-B 2a, 3a, 3b, 4a and 4b, each answered
FC-8: Filing timeliness
The e-file timestamp beside the original due date and the extension window, each with its IRC §7503 roll to the next business day
FC-9: Year-to-year continuity
This year's opening balances against last year's closing
11,842 foundation returns re-done by the same code; in 11,827 every line we recompute agrees. The study. Every control is on every sealed proof page, recomputed each time the page is read. A line that differs is the return’s figure beside the recomputed one: a question for the preparer, not a finding, since the return may carry a treatment or a reason the page cannot read. FC-9 needs two sealed years: a record is worth one more year every year, and a seal carries the day it was made; none can be dated earlier. Not an audit, review or compilation, and not tax or legal advice; whether anything met a requirement is counsel’s question. The verifier, verify_proof.py, needs nothing from us.
A payout is owed on last year's assets, whatever this year's market does.
A year's distributable amount is computed on that year's assets and may be paid out through the end of the next. So what is to be paid this year was fixed last year. A fall this year does not lower it; it lowers next year's. The calendar on every proof page states both, to the dollar and the date, with the undistributed income Part XII carries.
Carried to next year
The undistributed income the return reports in Part XII, and the date the following tax year ends. Whether it was paid is on the next return.
Next year, projected
The minimum investment return, the excise and the distributable amount if nothing changes, each with its due date, each with the assumption written beside it.
After a 20% fall
What is already carried, unchanged; next year's minimum investment return, shown, and the difference from the projection.
A projection under stated assumptions from the foundation’s own filed figures. Not a forecast, not advice; your preparer computes the actual amounts from the year’s monthly values. Not shown for a private operating foundation.
Every factor the law names, on the record.
| A factor the prudence standard names | What the ledger holds, as it happens |
|---|---|
| General economic conditions, and the possible effect of inflation or deflation | The inflation and return assumptions adopted, each with its source, date, setter and approver. |
| The expected tax consequences, if any, of investment decisions | The tax assumptions relied on, with source and approver; the ledger records them and does not compute the institution's tax. |
| The role each investment plays within the overall portfolio | Each position's bucket and shared downside, approved, with concentration answers sealed on each book date. |
| Expected total return from income and appreciation | Expected return by class, and each manager's results after fees against the benchmark it chose. |
| The needs of the institution to make distributions and to preserve capital | Spending rate and reserve as approved policy, liquidity against them, and the distribution requirement as a dated deadline. |
| Other resources of the institution | The whole book across every entity, so each decision is made with everything in view. |
| An asset's special relationship or value to the charitable purposes | A decision to hold a gifted or mission-related asset, recorded with its rationale against the sealed numbers. |
Phrased after UPMIFA (foundations organized as corporations) and the Uniform Prudent Investor Act (those organized as trusts). For a private foundation, IRC §4944 also asks for ordinary business care and prudence at the time of the investment. Counsel decides what the standard requires; the ledger makes the record exist either way. Not legal or investment advice.
Kept where any change shows. Checked by anyone, without us.
The seal format is an open standard (/standard, CC BY): anyone may build a checker for it. Where checks converge is the public log, one entry a day with an independent timestamp. A format many can check outlives one only its author can.
Small staffs, rotating committees, permanent money.
When someone asks, the answer is a proof page, not old board books.
The auditor: How was the spending rate set?
A new chair: Why was that manager kept?
The attorney general: How was the restricted gift invested?
Three layers. Each one holds what the one below cannot.
Free, for any foundation from $10M: $0 The sealed 990-PF proof
Your return re-done and sealed in seconds, with the nine controls and the calendar ahead. Checkable by anyone you send it to. No account.
Direct, or through its firm at cost: $2,600 The Filing Record, a foundation, a year
Each filed year sealed on request beside the last; the due date as the return states it; a read seat for the firm; a verification page anyone can check. Invoiced to the foundation, or to its firm at cost with no margin. The foundation keeps the record and can take it anywhere.
Direct, from $75M: $17,000–$35,000 The Foundation Record, a year
Everything above, plus the committee's decisions and the policy, sealed the day they are made; board packs. Over $1B by quote. Ten founding seats: nothing to pay for ninety days, then the band price locked for thirty-six months.
$75M – $250M: $17,000 · $250M – $1B: $35,000. A flat price by size, never a fee on assets. What each layer includes.
We already use Foundation Source, Foundant or Archway. Is this a replacement?
No. Keep them. An administrator prepares the return; a grant system pays the grants; a reporting platform keeps the books it reports on. Each is a party to what it records. This is the record that reads them: the return re-done by a party that did not prepare it, the committee's decisions sealed the day they are made, and a fingerprint anyone can verify without us. It replaces nothing and prepares nothing.
Our foundation is run by the family's office. Is this a second system?
No. The foundation is an entity in the same book, with its own policy values, its own committee and its own decisions. The family's record and the foundation's are kept by the same ledger and can be shown separately: a board pack for the foundation's directors carries the foundation's rows and nobody else's.
What do the nine controls say, and what do they never say?
Each control reads one part of the filed return and states a fact in a fixed vocabulary: agrees, differs, reported, not reported, not applicable, not checked. No seventh word. Whether a foundation met a requirement is counsel's question; the controls make the facts exist so counsel can answer it.
Does writing the committee's reasons down create exposure?
That is a question for the foundation's counsel. A record like this is discoverable and not privileged. What it holds is what was decided, when, by whom, and on which sealed numbers. Whether that met the standard is counsel's question, and we are glad to have that conversation with counsel directly.
Who on the committee can approve?
Whoever holds the authority, and the ledger says who that is. A director or committee member is recorded as a capacity with the resolution or bylaw that grants it and the dates it runs; one person records an entry and a different person approves it, which the database enforces. An approval can be signed on the approver's own device, and the capacity they held that day is written into what is signed.
What does it not do?
We don't prepare or file your 990-PF, we pay no grants, we hold no assets, and we give no investment advice. We read the return you filed, re-do its arithmetic exactly, and seal what it says. The calendar ahead is a projection under stated assumptions, never a forecast; your preparer computes the actual amounts.
What happens when the committee turns over?
The record does not rotate off with the members. A new chair reads why the spending rate is what it is, when it changed, who approved it, and what was decided on each quarter's numbers, instead of inheriting minutes that record outcomes and not reasons. And each filed year sits beside the last: a record is worth one more year every year, and no seal can be dated earlier than the day it was made.
Seal your return first. Decide after.
Your 990-PF proof: free, now, no account.
Keep the record.
The Filing Record: invoiced to the foundation, or to the firm that prepares its return, at cost with no margin. The Foundation Record: a flat price by size, never a fee on assets.
- 01
The order form and the NDA
A named person sends both within two business days.
- 02
The policy and the committee
The investment policy's figures and each member's capacity, entered from the IPS and the bylaws, each approved by a second person.
- 03
Each meeting
One person records what was decided and on which sealed figures; a second approves it.
- 04
Each year
The filed return sealed on request beside the last.
Ten founding seats on the Foundation Record: nothing to pay for ninety days, then the band price locked for thirty-six months. Also: for trustees, for 990-PF preparers.