Review high-score charity funding loops for structural-vs-anomalous classification.

Monetary impact

Recoverable / prevention rate (2.0%) and indirect-cost rate (1.5%) are calibrated category-level defaults grounded in published auditor benchmarks. Implementation cost is a calibrated point estimate based on category complexity. Funders should refine all three with their own historical recovery data.

Risk overview

Justification & audit trail

50 cited matches · $93M at stake

The dataset shows 50 CRA-registered entities participating in circular money flows scored ≥12 on the TRACE attention scale. 46 are scored ≥18. Cumulative circular amount: $93M. Most loops are structurally normal (denominational hierarchies, federated charities, donation platforms) — the review is to distinguish those from loops that exist to inflate revenue, generate tax receipts, or absorb funds into overhead. The recommendation is grounded in 50 pattern-detector matches across the federal corpus. Each cited match links back to specific source rows; an auditor walking the citation can verify every dollar in the headline.

Confidence rationale. Calibrated from 50 cited matches at flag severity. Confidence increases with match volume and severity; the snapshot pipeline rebuilds nightly.

Timeline & dependencies

Calibrated next steps

1. 01For each top-score participant, examine the T3010 filings: reciprocal gifts, board overlap, program-vs-overhead ratios.
2. 02Cross-reference against published structural-exclusion lists (denominational hierarchies, known federated charity structures) before treating any loop as anomalous.
3. 03Where loops persist across review cycles AND the structural explanation does not hold, escalate to the appropriate audit body.