For Policy · Statutory Basis
Each statute. What it authorizes. What changes for the agency.
The cooperative operates under existing D.C. cooperative law and existing IRS regimes. No federal legislation, appropriation, or rulemaking is required to operate. The one external coordination dependency is USDA-FNS — and that is a concurrence request, not a rulemaking ask.
| Statute / standard | What it authorizes | What changes for the agency |
|---|---|---|
| D.C. Code Title 29, Chapter 9 — General Cooperative Associations | Charter of the cooperative's standards-body entity (the GCA). One-member-one-vote among institutional members. Holds Coop-IC issuance authority and the cooperative brand. | Nothing for any federal agency. The cooperative files under existing D.C. cooperative law; no federal action required. |
| D.C. Code Title 29, Chapter 10 — Limited Cooperative Associations | Charter of the operating entity (the LCA), one of the more modern multi-stakeholder cooperative statutes in the country. Hosts the nine patron classes, the patronage dividend engine, and the bounded founding-round Investor-Member sleeve. | Nothing for any federal agency. D.C. registrar-level filing only. |
| IRC §§ 1381–1388 — Subchapter T (cooperative tax regime) | Federal tax treatment for the cooperative. Patronage dividends paid to patron-members in proportion to qualified activity are deductible at the cooperative level (§ 1382(b)) and reported as income at the patron level (§ 1385). The cap-on-investor-return and patron-majority-governance commitments hold Sub T treatment in place. | Nothing operationally. Treasury/IRS continue to administer Subchapter T as written. No regulatory amendment or guidance change requested. |
| IRC § 170(c) — Cash charitable contributions to qualified §501(c)(3)s | Brand's deduction for the cash contribution to the cooperative's chartered DAF sponsor. This is the structurally cleaner pathway for gift-card and intangible-asset donations, replacing reliance on § 170(e)(3) inventory-classification engineering. | Nothing. Standard cash-contribution substantiation under existing IRS guidance. |
| IRC § 170(e)(3) — Enhanced inventory-donation deduction | Alternative pathway for actual inventory donation (e.g., shelf-stable food shipped from a brand's warehouse to the Sponsor §501(c)(3) for care of the ill, needy, or infants). C-corporation donor; deduction equals cost basis plus 50% of appreciation, capped at twice cost. | Nothing. Available alongside the cash-contribution pathway where the donated asset is true inventory rather than a cash-equivalent. |
| IRC §§ 4966–4967 — Donor-Advised Fund regime | DAF compliance regime. The cooperative contracts as a service provider to a chartered DAF sponsor; the sponsor bears DAF-specific compliance obligations including limits on donor benefit (§ 4967). | Nothing. IRS continues to administer the DAF regime as written. |
| IRS Form 8283 — Non-cash charitable contribution substantiation | Substantiation pathway for non-cash donations over $5,000. Used when a brand or manufacturer donates intangible assets (data, IP, contract rights, professional service hours) to the DAF. | Nothing. Standard Section B substantiation. Qualified appraisal required for items over $5,000. |
| USDA-FNS — SNAP coordination posture | No statutory authorization required for the cooperative to operate. The wallet-side displacement-routing logic at POS — applying cooperative DAF-held value first before SNAP funds draw — operates within existing SNAP rules. | Coordination request, not a rulemaking ask. The cooperative is seeking, not assuming, FNS concurrence on order-of-draw at the register. FNS concurrence improves audit precision and removes state-administrator ambiguity. The cooperative is operationally functional without it. |
| GS1 Application Identifier 8112 — SKU-level credit attachment | Open standards-body attachment of cooperative-issued credits at the SKU level. The cooperative's Coop-IC attaches via AI 8112 and adjudicates at POS through the existing SKU-level adjudication program manager already live at major US retailers. | Nothing. Open standard administered by GS1. No agency role. |
Citations match the InnovateCredits progressive glossary's expert-tier statutory anchors. Full counsel memo is available as a 50-page PDF on the For Policy front door; this table is the one-screen reference for a constituent-services or principal briefing.
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