 Great. Okay. So without further ado, I'm going to turn it over. I welcome you again to the session and I'm going to turn it over to our speaker today, Sean, to get us started. Thank you, Claire. And hello everyone. Thanks a lot for joining us today. My name is Sean Subramanian and I'm senior council with NGO source and NGO source is a project of council on foundations and tech soup. And our aim really is to improve the efficiency of international grant making and hopefully inspire an increase in international giving. As you'll see, we provide a service called equivalency determination, and we believe equivalency determination benefits both grant makers and your international grantees in a number of ways. NGO source has issued over 23,000 equivalency determinations on 8,000 unique organizations in 165 countries on behalf of over 600 grant makers. So, as Claire mentioned, I will save some time at the end for Q&A about 15 minutes or so. So please feel free to put your questions in the chat, or when we get to that portion, feel free to unmute yourself and ask your question out loud if you'd prefer. I would sincerely appreciate it if you can share your name and your organization in the chat, and also what brings you here today, what makes you interested in this topic. And if you'd like to share some additional resources if you'd like to learn more ways to contact us and as Claire mentioned this presentation will be recorded. So this is intended to be a very broad overview of equivalency determination, both the process and the requirements. So we do recommend consulting with legal counsel to understand how the laws that will be talking about apply to your organization and your specific circumstances. And as much as possible I'll try to share concepts that will be broadly applicable to everyone here. I want to start by defining equivalency determination or ED for short. How does it help grant makers and how does it help international grantees as well. And these are the organizations that will primarily benefit from an equivalency determination. These are the legal requirements for an ED, and we'll look at an example of an organization that goes through the process. What are some of the common challenges that they may run into and how can we resolve those challenges. We'll look at our unique ED repository model. We'll talk about any questions that you may have, such as about the requirements or about the process, or about NGO source in our organization. So before we talk about what an ED is, I want to just cover a few concepts on grant making in the United States. As you all are with grant making organizations you may already be familiar with these concepts but I think it's helpful to understand why we have an ED and how it can be helpful. The private foundations must make grant payments to further their charitable purposes. Under US tax law and regulations, the term charitable has a very technical definition that has been developed over time through treasure regulations and IRS rulings. I don't want to too much detail on the definition of charitable, but an example would be a grant payment to an organization for the relief of the poor or distressed for the advancement of education for the advancement of science. These are examples of charitable purposes under US tax law. Grants made for non charitable purposes are subject to a penalty tax. Now, if your grant, if the grant from a private foundation is awarded to a 501 C3 public charity, then it is presumed that the grant is made for charitable purposes and the reason for this is because public charities are subject to a thorough evaluation by the IRS. The IRS looks at the nature of their financial support, their activities and their purposes and then it makes a determination about whether the organization is organized and operated exclusively for charitable purposes. In the case of a foreign organization and non US organization. It is possible that they have obtained a 501 C3 public charity designation, but this is unlikely, and most do not because of the cost and the administrative burden associated with the process to obtain a 501 C3 public charity designation. So this is where an equivalency determination or an ED comes in. ED is a good faith determination of whether a non US organization is the equivalent of a 501 C3 public charity. It is designed for US grant makers that want to distribute funds to a non US organization that has not received a ruling or determination that it is a 501 C3 public charity. I want to note here that we don't evaluate the effectiveness or the quality of service of the organization we're focused on the legal requirements, whether it is legally equivalent to a 501 C3 public charity. Now if the organization is deemed equivalent, then the grant maker can make grants to the non US organization in the same way that it would as a to a 501 C3 US public charity. One practical benefit to both the grant maker and the foreign organization is that the GM the grant maker can make can provide general operating support to the non US organization. So that's a benefit to the organization as well as the grant maker. I do want to point out that a donor advised fund, although it is held and controlled by a 501 C3 public charity. It is subject to similar disbursement rules as private foundations. And that's why a donor advised fund will also benefit from an ED. And ED is generally valid for two years from the last completed fiscal year for which information was made available for review. So let's say that a foreign organization does not have an ED from NGO source or elsewhere. Then the grant maker can still make a grant to a foreign organization, but it has to go through a more burdensome and time consuming process called expenditure responsibility. At a minimum this involves inquiring about prior history and experience of the grantee organization. The foreign organization would also have to submit full and complete reports on how they are spending the funds and that this funds are going towards accomplishing the purposes set out in the grant. The grant maker also has to submit information on the grant to the IRS in its info annual information return that it submits. And the grantee also has to maintain the grant funds in a separate dedicated fund, and they have to investigate potential diversions on the use of funds. And so this process for these reasons is more burdensome for both the grand tour and the grantee. And that means that they have to spend potentially limited resources on these administrative tasks. It's also ongoing effort for both the grant maker and the grantee. Whereas with equivalency determination as we'll talk about there is upfront work, but there's less the organization may not have to go through the process for each separate grant maker whereas with expenditure responsibility, they would have to exercise expenditure responsibility for each grant to the foreign organization. So what are the requirements and before we talk about the requirements. I just want to step back and say that it is a lot of information, but we will have an example to see how these rules play out. And as I mentioned, we will have links to additional resources and contact information if you have additional questions. Overall, our reviewers will evaluate whether the non US organization is organized like a US public charity. Another way of thinking about this is that we'll look to see what it is permitted to do and what it is not permitted to do. And to do so we'll look at the organization's governing documents and also any applicable country laws. Second, we'll look to see whether the non US organization is operated like a US public charity and this is about what the organization does in practice so in the first part of the analysis we're looking at what it is permitted to do, but then we'll look at what it doesn't practice. Finally, most organizations will have to meet certain public support requirements. They will do their financial information for a specified five year period, and will determine whether or not they're publicly supported now organizations may be able to qualify as a school, a church, and that would include other houses of worship, a supporting organization or a hospital, in which case they would not need to submit detailed financial information but this is not typical. We also have to meet certain other criteria that we're not going to be talking about today. I also want to mention that different rules apply to organizations that are government entities and government instrumentalities so I'm not going to go into too much detail on these rules. But we do issue legal opinions verifying that organizations are foreign government agencies or instrumentalities. They're the same as an ED so grant payments would still have to be made for charitable purposes, but the grant maker would not have to go through the expenditure responsibility process for those types of grants. So first, we want to see that the organization is organized for charitable purposes we look to the organizations governing documents and also local law. When I say governing documents this might include an organization's bylaws, its internal statutes or its constitution, for example, and typically these documents will outline the purposes for which the organization is established. We might also look to local law that governs the type of organization. It is that might provide information on how it must be organized. The purpose of charitable purposes as I talked about include the relief of the poor and the distressed advancement of education or science advancement of religion. And there are many other purposes that qualify as charitable that we won't get into today. It will also be limited to charitable purposes so for example, if let's say we're reviewing an organization's governing documents, and it has two main purposes to provide relief to the poor or the distressed, and then also to undertake any commercial activity necessary to earn profits for the organization that would not be compliant because the second purpose is not a charitable purpose. We might follow up with the organization because more than likely the purposes that are outlined in its governing documents will not align precisely with the US requirements so we might need additional information, maybe there are other documents that expand on those purposes. We might also have global partners that can assist us with culturally sensitive translation and who are familiar with local laws and customs so we might partner with them also when we're communicating with the NGO. Next we look at how the organization's assets must be distributed on dissolution of the organization. One is the termination or closing of an organization, and an organization might dissolve because maybe it's accomplished its mission or there's no longer need for its services or it just doesn't have sufficient resources so whatever the reason under US tax law a charity's assets must be dedicated to charitable purposes in perpetuity so that means even when they dissolve. So it must go to another charity or for charitable purposes or to the government for public purposes. That means that it can't be returned to let's say an individual founder or a for profit company to do as they wish with those assets. So we also want to make sure that the organization is required to transfer assets in this way not just that they plan to or that they hope to, but that that they're required by their governing documents or local law to transfer assets in this way. Another common issue that comes up through the ED process is that maybe the organization will will not have a clause that aligns with US requirements in which case we will propose an amendment if they're able and willing to amend their governing documents we will work with them to amend those documents so that they are compliant with the US requirements. So governing documents also cannot permit certain activities. So it cannot permit political campaign activity, which will, we'll talk about the definition on the next slide. It can't permit a substantial amount of lobbying activity, and we'll talk about the definition of lobbying, and it also can't permit a substantial amount of other non charitable activity. So for example, operating a manual any manufacturing business to earn profits. Right, but if we do have some indication that it has to be an insubstantial part of the organization's activities, then that would be permitted so for example, let's say we come to an organization that says that any commercial activity has to be less than 5% of the organization's activities, then we have some confidence that this non charitable activity has to be an insubstantial part of the organization's activities. We also look to see what the organization does in practice. So this is based on their descriptions. It's based on their website if they have a website. It also has a, you know it's based on any other online presence that they have. So we want to make sure that they're engaging exclusively in charitable activities so they might be issuing publications that are freely available to the public. And we look at how those programs and activities are are operating are conducted. And if we have any questions again we will reach out to the NGO. One important point here and this is a common point of confusion for many non US organizations is that in the United States under US tax law, just because an activity generates income for the organization. It doesn't mean that it's not charitable so if the income generating activity directly and substantially furthers charitable purposes, then it is considered a charitable activity under US tax law. For example, let's say that you have an organization that is organized to promote awareness about non violence, human rights and anti discrimination. And let's say that they have a museum and they charge some admission fees, but the purpose of the museum is to promote awareness about these causes. In this case, we have some confidence that the income generating activity in this case the museum is directly and substantially furthering those purposes of raising awareness about non violence and anti discrimination. Again, we may need to contact the organization, or set up a call with them to better understand their activities. We also can't engage in political campaign activity. This means supporting or opposing a candidate for public office. So for example, it might be clear if an organization says, we endorse this candidate for president of Chile, but implicit political support or opposition is also not permitted. The organization creates a voter guide that we determine is clearly designed to favor one candidate over the other. That would also be considered a political campaign intervention. But there are many activities related to elections that an organization still do, for example, telling people how they can exercise their right to vote, giving them information on their polling location or who is eligible to vote. We also can't engage in substantial lobbying. Now lobbying is another term that has a very technical definition. And so we may have to share information about how lobbying is defined in the United States under US tax law. But generally speaking, it means attempting to influence specific legislation. So for example, calling a lawmaker and asking the lawmaker to vote for a bill. There are many activities that actually don't fall within the definition of lobbying or actually, or they're an exception to lobbying. So let's say an organization is trying to influence how a law is being implemented. That would be an example of advocacy that's not trying to influence legislation. I mean, we look to make sure that there is no private enurement and private enurement is about a benefit to an individual, a private shareholder or an insider of the organization that has a personal or private interest in the activities of the organization. So an example of an insider might be an executive officer, high level employees or directors. Reasonable payments for compensation or services would be permitted. But we want to look to see if there's any other kind of private enurement, or if there is private enurement. We look to a related concept called private benefit and private benefit is about benefits to private individuals who are not insiders of the organization we want to make sure that the activity is not primarily serving private interest so let's take an example. This is a conservation organization, and they want to clean up a lake. And the reason for this is because they've documented some health hazards, they want to benefit the neighboring community, and they also want to benefit people who visit the lake. Now, we determine okay this is primarily benefiting the public. There is also a benefit to homeowners near the lake in that their their property values increase. So we may be able to determine looking at this that there's only an incidental benefit to those private homeowners, in which case this would still be a permitted activity considered a charitable activity. And then finally, we, as we talked about we look to see whether is organized for charitable purposes and operated for charitable purposes. Finally, we look to see whether it meets certain public support requirements. As I mentioned, it may be able to qualify in a different way but as a school church supporting organization or a hospital, but I'm not going to get into those details. So as part of the public support test. We look to see whether the organization is primarily supported by gifts grants and contributions from the government and the general public. Now, there are actually two types of public support tests, but I'm going to be talking about the most common one and that's called 509 a one public support test. The test looks to see whether the organization receives at least 33 and a third percent of its support from public sources. So this would include us charities, governments, and limited donations from private foundations and individuals. It's a complex formula but just to put this more simply if the organization receives almost all of its support from one large donor or a few large private donors, it will have a difficult time meeting this public support test. I think that it doesn't have 33 and a third percent public support, it may still be able to meet the support public support test, but in order to do so, it has to one, at least receive at least 10% of its total support from public support. It also needs to have a program to raise funds from the general public. And it also needs to meet certain other facts and circumstances so it has to operate programs that benefit the public. It also has to have a board that is representative of the community. It has to have members that of the public that are regularly involved in the organization's programs and there are certain other facts and circumstances so the purpose of this analysis is to show that although it may receive funding from primarily one private donor or a few large donors. It still operates in a way that benefits the public at large as opposed to those few donors. So let's go through a specific example and this is a fictional organization but it is modeled after organizations we might see and any resemblance to real organization is completely incidental. So let's say we have a private foundation in the United States called support Cameroon Foundation, and they're interested in making a grant to an NGO in Cameroon called STEM in Cameroon. So we would invite the organization, let's say they want to go through NGO source to complete our questionnaire. And because of our multilingual questionnaire the organization, in this case in Cameroon if they so choose can see questions in French and also complete the questionnaire in French, if it's so so wishes and we do support many other languages as well. So we can interface with our global partner to support the NGO and completing the application. So let's say we we receive the information, and we determine that stem in Cameroon has an objective to provide science technology engineering and math education to underserved youth in Cameroon. We also see that it conducts activities to provide free training courses workshops, educational materials to youth ages nine to 18 in Cameroon. We also see that on dissolution, its assets would have to be transferred transferred to another nonprofit organization. We also see that it's bylaws say that no assets income profits or dividends may be distributed to its individual members. And then we see after reviewing its financial information that it has 20% public support. I also want to note that this specific organization might also qualify as a school but we would need some more information would have to meet certain other criteria. So we have potential issues here or challenges that we might have to resolve. So I've highlighted the potential challenges. One challenge is that the organizations assets here must go to another nonprofit organization, and it's 20% publicly supported, and that's less than the 33 and a third percent public support so it might still be able to qualify, but we would need to get more information. So why is the dissolution provision here a concern. Well, under US law, a nonprofit organization is not necessarily a charitable organization. So in the United States, labor unions and trade associations, chambers of commerce are nonprofit organizations, but they're not necessarily charitable organizations, organized for those specific purposes so we really need to make sure that it's going to meet those specific purposes, or two organizations that are organized for specific purposes and, as you probably gather, because country laws are so different those requirements might not align precisely now sometimes the definition of nonprofit in another organization, it might be consistent with the US definition of charitable, but we would need more information. So how might we may be able to resolve this to make sure that the assets are going for charitable purposes, or to the government for public purposes, or to another charity. Well let's say we come across another provision in its governing documents that says that the organization must apply all of its assets to further its objectives. The objective to provide science, technology, engineering and math education to underprivileged you is a clearly charitable purpose. So we have confidence that the organization must apply its assets to charitable purposes it has to be used for those purposes. Even though the organization's assets must go to a nonprofit organization, not necessarily a charitable organization, we know that it always has to apply its assets towards those charitable purposes. So we can make a strong argument that even on dissolution, the assets need to be applied in furtherance of those objectives. So we have confidence that the organization that meets the dissolution requirement. Alternatively, if the organization is willing to amend its governing documents, we might propose some language, for example, that says that it has to go to a nonprofit for the same purposes, or for charitable purposes. So that's another way the organization might meet the requirement. As far as public support, I mentioned that if it's less than 33 and a third, we would need to follow up to see whether it meets certain facts and circumstances, and maintains a continuous program to raise funds from the public. So again, the purpose of this is to show that even though it's primarily funded by one large private donor or a few large private donors. We still have confidence that it's operating in a way to benefit the public at large, and it's seeking to be publicly supported. So the way we receive those certifications and assurances, then it passes the facts and circumstances test, and the organization would be able to qualify as equivalent to a 501 C3 public charity so as you can see with this example. It is some upfront work for the organization, but it can benefit in many ways. So we talked about through general support, and potentially to not have to go through this process with multiple grant makers, you know, once they have gone through this so let's see how that might work with our repository model. So the NGO source repository model the ED process could be inefficient and duplicative. So the grant maker would often have to hire a qualified tax practitioner, an attorney outside council to conduct an ED for each separate organization and the cost for outside approval for a single ED can range from 5000 us dollars to 15,000 us dollars. So in contrast, our team of legal experts as well as our process allows NGO source to offer EDs at a significantly lower cost. But by centralizing the process, NGOs need only complete the ED process once for multiple grant makers freeing them up to do their important programmatic work. The NGO source members are actually able to search our online database at any time to view the ED status of specific NGOs and this information I do want to make clear it's only available to the NGO source members and not the general public so for privacy reasons members may not be able to see which grant makers initiated the request, but they will be able to see if the grant the NGOs in the repository. I also want to emphasize that an ED is specific to the G the grant maker making the request. So, even the, even though the IRS approved our repository model, which is the main service and benefit that NGO source offers the ED still has to be specific to the grant maker, but the process is significantly more efficient because the grant maker can make a selection from the NGOs that have already been approved. So finally, I just want to cover a few common ED challenges that come up and how we might be able to resolve them. But often in organizations assets on dissolution will not be required to be transferred to another charitable organization, or exclusively for charitable purposes, or to the government for public purposes, unfortunately, on its own transfer profit does not necessarily mean charitable, and for similar purposes, even if the organization's purposes are charitable. The US tax authorities the IRS has clearly stated that a similar purpose is not necessarily charitable, even though the same purpose would be charitable. So those are some issues that come up but we are happy to work with an organization to amend their governing documents, sometimes local law will be helpful. And it'll have some details or requirements that do align with us requirements. Another issue is lobbying. As I mentioned, to be deemed equivalent an organization cannot engage in a substantial amount of lobbying activity. It has a very technical definition. And so there are many activities that are related to public policy advocacy, or research or raising awareness that will fit within an exception, or are not considered lobbying under Paris rules. Finally, as I mentioned, income generating activities. And this is another common point of confusion, maybe charitable if they are substantially and directly in furtherance of the organization's objectives so we'll have to clarify that with the organization as well to say that look because you may charge fees for an admission to a museum. It doesn't mean that that's automatically a non charitable activity so really matters what the purpose of the activity is, and how it's conducted. To learn more, we have our learning center which has a lot of helpful information about the ED process and about eds. We also have a frequently asked section question section of our website and I might direct you here for more details, any of the questions we have today. We also have a legal ease blog where we try to talk about legal concepts in plain English, and we have more detailed information about laws and organizations in different countries. We have an impact stories section of our website organizations that have benefited from receiving an ED so we would encourage you to check out that section of the website, also grant makers, discussing how their grantees have benefited from an ED. So I'm happy to take questions. And finally, I want to mention that you're welcome to email me. Ask Subramanian at TechSoup.org. You can also email or contact my colleague Jonathan, he's a director of global partnerships, if you have questions about membership partnership opportunities. And then also our general NGO source email is account support at NGO source.org. So, hopefully this was helpful in outlining a little bit about the ED process, how it can be beneficial, why and NGO sources model improves efficiency. And we hope to continue our relationship so this time I'll stop share and then open it up to any questions people have. And again feel free to put your question in the chat or just let me know in the chat if you'd prefer to ask your question out loud. Hi, I have a question. Hi, Shyam. My name is Jess and I'm with the Spencer Foundation in Chicago, and we work very closely with you all on various ED requests. And higher education institutions, universities, and education research, and we're increasingly funding more outside of the US so we work with all of you. Some questions and complexities that we often face in our requests to you are obviously with working with universities that are international trying to understand their NGO structures and navigating them. Obviously you find out but what we still are trying to understand as far as matching up to compliance on the US side. So I just wanted to ask about that and if anyone else here on the webinar has any similar experiences working with international universities. For the question Jess and if everyone if anyone has any thoughts or guidance that encourage you to also put that in the chat. So, as far as our approach, we, as I mentioned we do have global partners that can assist with translation but also are familiar with local laws and customs. So, they might be helpful in that situation. But also, you know, we're in addition to reviewing the governing documents that are translated that they translate into English, we do a thorough review of their website online presence. If there's any clarification that we need, we will again set up a call with them email them so just to give an example you talk mentioned universities there is a requirement about having a racially non discrimination. racial non discrimination policy or for following a racially non discriminatory policy. And so we'll provide explanation of what that means under US laws and, if needed, provide more guidance. So we do have some information in the questionnaire that says okay these are the US requirements. And if there's any confusion about it, we're happy to communicate with them but it's. Yeah, we definitely are aware that it's those universities there the way that they're operated and structured are not going to be aligned exactly with the US requirements so we're definitely mindful of that. So, next question from Nicole in the chat you mentioned that NGO source is happy to work with organizations on their governing documents to include proper dissolution. Would NGO source do that during the review process or does it need to be requested as a service before the funder requests ID initiation. No we would, we would review the dissolution clause and propose any amendments as part of the review process. And we would come to know if there are any issues only after we do review, because we need to look at the governing documents, we'd also need to see if there's any applicable law that we can rely on so we do actually have a law library. And in many of the countries we have provisions that we can rely on related to dissolution. So, even if the governing documents don't align precisely with us requirements we might be able to rely on a local law. And so that's something that we would do as part of the process, and we would work the with the organization, even if the organization, even if the grant maker doesn't specifically requested although if the organization is not willing or able to then you know, we would have to deny in that case because it does not meet the dissolution requirement. So, Suzanne asks, what is the general amount of processing time needed for an ED request. So, yeah, the general processing time varies. And I think the reason for this is because an organization, you know of course if it needs to make amendments that might take more time. Also, if we need to clarifications. Then we need to follow up with them and then it's dependent on you know how soon they respond could take anywhere from four weeks to 16 weeks. Also because of coven 19 there were delays there could be situations in specific countries that are leading to delays maybe related to their judicial system or their political situation so it does vary. And we do also for members there isn't an option to expedite certain requests as well. Great so. Yes, is there any guidance on who to select as NGO sources contact person for the grantee institution when requesting an ED. I will say that when the legal team reaches out, typically we're asking legal questions so someone who's either familiar or who can contact someone familiar with, you know, with their governing documents, the provisions and their governing documents. I don't know if they are or know somebody who's familiar with local laws. So, typically we are asking questions about their governing documents. Also, the way that they're conducting their activities so someone with intimate knowledge of their different systems often will have questions about their financial information. So it's helpful to have someone who's familiar with that information or at least they can loop in someone who is who can report on the financial information that they submitted. I think those are some general guidelines for the, the best contact person for NGO source. Next question. What level of technical assistance to organizations receive, or can they access for example, organizations who are near the end of their grace period on the public support test. Can NGO source assist proactively, or does it merely catch when the test is failed. So, if we think that, you know, we can provide guidance that can help an organization will qualify then then we will share that guidance so for example, you talked about public support. One thing that I didn't mention was that, you know, there are, there are organizations that are have not been in existence for five years, and so they can't provide five years of completed financial information. So in that case they would need to provide a combination of actual and projected financial information. So, we will let them know. Look, these are the guidelines around projected information. It must be realistic, but it can be aspirational, we will not hold you to the projections. If we see that an organization does not qualify for the public support test, we will reach out to see if they've reported all of their income. We will reach out to clarify the different income categories, because potentially there's an issue with how they've categorized their income. So, most of the time I can say that, you know, on the first pass, when we're going through, we will follow up and provide clarification as needed, because it's possible that perhaps the, there's a misunderstanding related to the US definitions. So, as I mentioned with, if they say, hey, we, we do 35% of our organization of our activities are not charitable, we will follow up and say, this is the definition of charitable, do you still maintain that 35% are not charitable. And if so, what are those activities. If you have any questions, and please, if I didn't answer your question properly, please let me know. And if you have any questions related to membership opportunities or partnerships again please, my colleague Jonathan would be happy to ask you. In the chat, I'm just reading it out for everyone. We made a grant to a government instrumentality and the information on the blog and FAQ pages was very helpful for understanding the difference between a charity and a government's instrumentality. That's great. Thank you. Thanks for that comment. Jamie says this is the clearest explanation of ED that I've received in my time in philanthropy. Huge thanks to Sean and Geo source and Pete for offering. Thank you for the kind words and yes, again, thank you to peak for offering and organizing the session. It's great to have so many people join. And yeah, thank you all for joining. So we still have a few more minutes, happy to take any questions. Yeah, so that's a great question the renewal process. So, as I mentioned the validity period, or an ED is generally it can be up to two years generally two years. And so one benefit of our process is that the organization can go through a significantly streamlined process in order to have their ED renew once it's in our repository. So if we have the due diligence work that we've done, we still we still need them to provide certain certifications, but we can ask them to look at the information previously submitted and certify whether there have been any material changes to the information. We will still make sure that there are no material changes will look at the website look at the programs that they've been doing. We will, in most cases will receive new financial information, but it is a significantly more streamlined process so once they're in there in the repository. The fact that we have all that due diligence work will reduce the amount of work, the time and burden for the NGO to be able to renew its ED for another, another two years. And that of course as you might gather the, the cost for the renewal ED is significantly less expensive than for a new ED that's not in the repository. Yes, we can certainly share the presentation slide deck I'll share it as a PDF with the meeting participants. If there are no other questions Jonathan or Claire, is there anything that you want to add. Just thank you everyone for being here today and the account support email is on the slide deck so if you have any additional questions you can email that it hits our whole team or you can reach out to show me directly. Thank you, Sean. Thank you. Thank you. One thing that I forgot to mention at the beginning that I just want to point out is that right now NGO source has issued over 23,000 equivalency determinations on 8,000 unique organizations, 165 countries, or maybe I did mention this but I just wanted to mention this again then. I will say thank you so much again Sean for this great session and to everyone for your great questions. And just again to NGO source for being a really great partner and supporter of peak so we really appreciate it. So I will definitely follow up with everyone in the next few days with the recording contact information and the slide deck so thank you. Thanks everyone. Thanks Claire.