For Policy · Risk Register

Eight named risks. Mitigation status for each. Cooperative posture, on the record.

Three status categories: Open · in active coordination (cooperative is working on it), Mitigated · structural (architecture addresses it), and Bounded · roadmap not base case (the cooperative is viable without the upside firing).

Briefing · Professional · 7 minV5

Coop-IC Anatomy of Trust

Three-tier audit cadence — monthly custodian, quarterly Big Four SOC 1, annual GAAP — plus a five-tier insurance stack and proactive IRS Private Letter Ruling preparation.

R1. USDA-FNS concurrence required for clean order-of-draw at POS

Open · in active coordination
Risk
The cooperative's wallet-side displacement-routing logic applies DAF-held value to qualifying SKUs first; federal SNAP funds draw only on the residual. The mechanism operates within existing SNAP rules, but FNS concurrence is desirable for audit precision and to remove any state-administrator ambiguity.
Mitigation
Coordination request in flight. Cooperative has prepared the operational briefing pack and is seeking, not assuming, agency concurrence. The cooperative is operationally functional without FNS concurrence — the mechanism does not require regulatory change. Treat this as a concurrence ask, not a rulemaking ask.

R2. DAF arm's-length compliance burden

Mitigated · structural
Risk
The DAF cash-contribution structure requires documented arm's-length separation between the brand's cash gift to the DAF and the DAF's subsequent purchase of SKU-level gift-cards from the brand. IRC § 4967 prohibits more-than-incidental donor benefit.
Mitigation
Structurally addressed through the two-tier DAF + Sponsor §501(c)(3) architecture (master spec §6.2.2). DAF holds donor-restricted charitable assets under independent fiduciary discipline; gift-card purchase is a commercial transaction at retail face value between two separate legal persons. Both transactions independently documented; donor retains advisory rights only.

R3. State SNAP administrator variation

Open · in active coordination
Risk
State SNAP systems vary in how they process coupon-class adjudications and in their tolerance for novel POS routing logic. Some states may require additional briefing or sign-off before live operation in that state.
Mitigation
Pilot sequencing accommodates state-level variation. Initial launches will start in states with the most established coupon-class adjudication infrastructure. Subsequent state additions follow a per-state coordination cadence; no state is required for the cooperative to launch.

R4. Anti-fraud and beneficiary-verification dependence on civic NGOs

Mitigated · structural
Risk
The cooperative does not operate eligibility certification directly. Beneficiary registration and verification rest with civic-class §501(c)(3) member NGOs. A failure of the eligibility-certification layer would create fraud exposure on wallet-bound redemption.
Mitigation
Civic-class member NGOs are selected for established beneficiary-services infrastructure and existing certification practice. Wallet-bound redemption is tied to verified-cardholder identity at the POS rail layer; cross-check happens at SKU adjudication. Cooperative's audit standard requires civic-class members to maintain documented eligibility-certification SOPs reviewed annually.

R5. Wave 1 brand-pathway scale uncertainty

Open · in active coordination
Risk
The flagship Brand Donation Pathway scales with brand-side participation. Wave 1 founding-brand recruitment is in flight; specific dollar volumes will be a function of how many brands sign at what donation budgets in the first cycle.
Mitigation
Wave 1 is intentionally sized as a pilot, not as a national-scale claim. The cooperative is operationally viable at modest Wave 1 volume; scale follows as additional founding brands sign each quarter. Public communication treats Wave 1 volumes as ranges, not as projections.

R6. Treasury IC adoption uncertainty

Bounded · roadmap not base case
Risk
The 1:1 par convertibility of Coop-IC to a future Treasury-issued Innovation Credit depends on federal action that is outside the cooperative's control. Authorization timing, scope, and methodology are Treasury and congressional decisions.
Mitigation
Explicitly bounded as roadmap, not base case. The cooperative is structured to be commercially viable on standalone economics without Treasury convertibility. The investor floor is patronage cash flow plus HAE-eligible Data Trust collateral; the Treasury bridge is the upside thesis. The cooperative's commitment is to build to the contemplated specification — Treasury action remains outside the cooperative's control.

R7. Retailer POS rail concentration risk

Mitigated · structural
Risk
The cooperative's POS integration runs through two existing rails — a national coupon-class clearinghouse and a SKU-level adjudication program manager. Concentration in two rail operators creates dependency exposure.
Mitigation
Both rails are already industry-standard and already live at major US retailers; the rail operators bear independent operational risk that the cooperative monitors but does not control. The dual-rail architecture itself is a partial mitigation — neither rail alone would meet operational requirements; the cooperative is not single-rail-dependent. Additional rail integrations are tracked as second-wave architectural options.

R8. Coop-IC secondary-market liquidity

Open · in active coordination
Risk
Investor-member redemption pathways include a secondary-market wrapper via the cooperative's tokenization partner. Secondary-market depth and price discovery are functions of broader market participation that builds over time.
Mitigation
Cooperative's first commitment is to the par-redemption mechanism (USD at face value); secondary-market is a supplemental liquidity pathway, not the primary investor-exit. Tokenization partner is selected for institutional-grade settlement and audit standards. Hold-period and redemption-window design accommodates a gradual buildout of secondary-market depth.

This register is maintained as a living document by the cooperative's Founders Council policy work-stream. Items move between categories as the architecture matures and as external coordination advances. Full counsel memo is available as a 50-page PDF on the For Policy front door.

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