A private D.C. cooperative that does not require federal legislation, appropriation, or USDA rulemaking to operate.
Flagship use case: brand-donated grocery value routes to EBT/SNAP cardholders at the register. Federal SNAP funds draw only on the uncovered portion of a basket, offsetting federal outlay dollar-for-dollar on the brand-funded share. Coordination with USDA-FNS is the one external dependency — the cooperative is seeking, not assuming, FNS concurrence.
The four-line answer your principal will ask for
USDA-FNS
Coordination request, not a rulemaking ask. The cooperative seeks FNS concurrence on the displacement-routing logic at POS. No regulatory change required for the cooperative to operate; FNS concurrence improves audit precision.
State SNAP Administrators
No mandatory change. State systems continue to operate normally. Variation exists in how some states process coupon-class adjudications; pilot sequencing accommodates this.
Treasury
Nothing required today. The 1:1 par convertibility to a future Treasury IC is a roadmap commitment, not a current operational feature, and is not required for the cooperative's SNAP-pathway value.
Congress
Nothing required. The cooperative operates under existing D.C. cooperative statutes (Title 29 Ch. 9 + Ch. 10) and existing IRS regimes (Subchapter T cooperative tax, §170(e)(3) charitable contribution, §§ 4966–4967 DAF rules). No new legislation needed.
What your office may want to verify
Statutory basis
D.C. Code Title 29 Ch. 9 + Ch. 10, IRC §§ 1381–1388 (Subchapter T), IRC § 170(e)(3) + §§ 4966–4967 (DAF rules), USDA-FNS coordination posture. Each citation linked to source text.
See the citations →Risk register
Explicit risks (USDA concurrence, DAF arm's-length compliance burden, state-level SNAP-admin variation, anti-fraud and beneficiary-verification dependence on civic-class NGOs) with mitigation status for each.
See the register →50-page legal memo
Full counsel memo with table of contents, statutory citations, and per-section anchors. PDF download for offline review.
Download PDF →Beyond the Year-1 SNAP-shelf flagship
Three federal-endpoint use cases sit one paragraph behind the brand-donation flagship. None require federal legislation today; each becomes operational at the Phase III par event when the federal Innovation Credit program ships. The cooperative pre-stages the rails so adoption is a credit-and-accounting question, not a multi-year federal build.
Tariff-to-credit transition
WTO-compatible sovereign Innovation Credit replaces import duty. Importer pre-staging today.
Sovereign balance-sheet reframe
$36T-in-liabilities → $36T against a growing innovation-backed asset base. Year-4 federal projection.
Sovereign data asset
Supply-chain vulnerability detection; macro early warning; multi-node fabrication defense.
Schedule a 30-minute briefing
For agency staff, congressional staff, or state SNAP-administrator offices. Routes directly to a named Founders Council policy contact.
Request a policy briefing