# Schedule O & Financial Structure Deep Dive **Date:** 2026-02-16 **Status:** HIGH CONFIDENCE — Multiple confirmed red flags --- ## Executive Summary Analysis of Schedule O narratives and full XML filings for **[[Conservative Partnership Institute|CPI]]** (2023), **State Freedom Caucus Foundation** (2024), and **1792 Exchange** (2024) reveals a tightly interlocked financial network with circular money flows, shared service entities controlled by insiders, zero-employee structures, family relationships on governing boards, and governance red flags including explicit refusal of public transparency. --- ## 1. The "Compass Professional" Control Node **Finding:** SFOF's own 990 XML confirms that its **books and records are kept by Compass Professional Inc** at **300 Independence Ave SE, Washington DC 20003**. This is the same entity that: - [[Conservative Partnership Institute|CPI]] paid **$813,590** in 2023 for "Accounting/Consulting" - Is **beneficially owned by Russell Vought** (former OMB Director, [[Conservative Partnership Institute|CPI]] network leader) - Shares [[Conservative Partnership Institute|CPI]]'s physical address > **Implication:** The Compass entity doesn't just service [[Conservative Partnership Institute|CPI]]—it functions as the **shared back-office for the entire network**, controlling financial records for multiple organizations while being owned by a network insider. This is the infrastructure of control. --- ## 2. The Circular Money Flow (CONFIRMED) ### [[Conservative Partnership Institute|CPI]] → SFOF → [[Conservative Partnership Institute|CPI]] Loop | Direction | Amount | Purpose | | :----------------------------------- | :------------------ | :------------------ | ----- | | [[Conservative Partnership Institute | CPI]] → SFOF | **$568,500** (2023) | Grant | | SFOF → CPI | **$244,944** (2024) | "Program Support" | | **Net flow to SFOF** | **$323,556** | | CPI grants over half a million to SFOF, and SFOF grants a quarter million back to [[Conservative Partnership Institute|CPI]]. This is a textbook circular funding pattern. While the net flow is to SFOF, the bidirectional grants create financial opacity—each org can claim larger revenue figures and grant totals than the actual net movement of money. ### SFOF Also Grants to: - **Renew Massachusetts Coalition Foundation Inc** — $100,000 ("Program Support"), also at **300 Independence Ave SE** > Another org at the same address receiving grants from the network. --- ## 3. The Zero-Employee Structure **Finding (Schedule O, Part V):** SFOF states: > _"The Foundation does not issue W-2s under its EIN. The compensation reported on Part VII and Schedule J is allocated respectively to related filing organization, State Freedom Caucus Network."_ SFOF reports **0 employees** and **0 volunteers**, yet reports $939,649 in salary expenses. All personnel are technically employed by the **State Freedom Caucus Network** (501c4, EIN 87-3648308), a related entity. This structure means: - SFOF (the 501c3 "educational" arm) has no direct employees - All staff are employed by the Network (501c4 "social welfare" arm which can do political activity) - Compensation is "allocated" back, creating a cost-sharing arrangement that obscures who is actually directing the work ### SFOF Officer Compensation (Split Across Orgs) | Officer | SFOF Comp | Related Org Comp | Title | | :-------------- | :-------- | :--------------- | :------------------ | | Andrew Roth | $163,678 | $86,322 | President, Director | | Justin Ouimette | $92,200 | $67,800 | Sr. VP, Director | | Suanne Edmiston | $52,139 | $57,533 | AZ State Director | | Connie Hair | $45,391 | $65,364 | LA State Director | > Officers split their time between the 501c3 and 501c4, with some spending **more** time on the Network than the Foundation. --- ## 4. The Corrigan Family (Board Governance) **Finding (Schedule O, Part VI):** SFOF discloses: > _"Ed Corrigan and Patrick Corrigan have a family relationship."_ - **Ed Corrigan** — Director of SFOF, also **COO of [[Conservative Partnership Institute|CPI]]** (where he earns compensation) - **Patrick Corrigan** — Treasurer of SFOF A father-son (or sibling) pair controls both the Director and Treasurer seats on a 4-person board. With only **2 of 4 directors being independent** (per the filing), the Corrigans effectively have outsized influence over financial decisions. --- ## 5. The Three-Headed Entity (Schedule R) SFOF's Schedule R discloses **two related organizations**: | Entity | EIN | Type | Address | Activity | | :--------------------------- | :--------- | :-------- | :------------------------------ | :------------- | | State Freedom Caucus Network | 87-3648308 | 501(c)(4) | 300 Independence Ave SE | Social Welfare | | State Freedom Caucus Action | 87-3542487 | 527 (PAC) | 316 Pennsylvania Ave SE Ste 201 | Political | **Shared operations confirmed:** - ✅ Sharing of facilities - ✅ Paid employees sharing - ✅ Reimbursement paid to other org This is a **three-entity structure**: 501c3 (tax-deductible donations for "education"), 501c4 (political advocacy), and 527 (direct political spending). Money flows in through the c3, personnel are shared via the c4, and political action happens through the 527. --- ## 6. Financial Distress Indicators (SFOF) | Metric | BOY | EOY | Trend | | :---------------- | :-------- | :-------- | :----------- | | Net Assets | -$367,370 | -$428,400 | ⬇️ Deepening | | Total Liabilities | $761,613 | $813,040 | ⬆️ Growing | | Unsecured Notes | $430,000 | $430,000 | ➡️ Static | | "Due to Network" | $316,356 | $365,538 | ⬆️ Growing | SFOF is **technically insolvent**, with liabilities exceeding assets by $428k. It carries $430k in unsecured notes (source unknown—likely [[Conservative Partnership Institute|CPI]] or the Network) and owes $365k to its own related entity. The organization has been operating at a loss every year since formation (2022). --- ## 7. CPI Schedule O Analysis CPI's Schedule O contains **standard boilerplate** governance claims: - Conflict of interest disclosure required ✅ (but Compass payments suggest non-enforcement) - Compensation "approved by the board" and based on "data from similar organizations" ✅ - No uncertain tax positions ✅ - 990 reviewed by board prior to filing ✅ - Documents made available "upon request, as required by law" ✅ > **Notable absence:** No explanation for the $1.6M in payments to Compass entities. No disclosure of the Vought ownership connection. These are material omissions. --- ## 8. 1792 Exchange — The "Anti-ESG" Vehicle ### Overview 1792 Exchange (EIN 27-3707886) is registered **c/o Cleta Mitchell** per ProPublica BMF data, based in Springboro, OH. The organization's stated mission is to fight "woke corporations" and ESG policies. It has experienced explosive revenue growth: | Year | Revenue | Growth | | :--- | :--------- | :----- | | 2021 | $225,000 | — | | 2022 | $2,295,000 | +920% | | 2023 | $5,800,308 | +153% | | 2024 | $8,145,397 | +40% | ### Leadership: Daniel Cameron CEO is **Daniel Cameron**, former Kentucky Attorney General (2019-2023) and unsuccessful Republican gubernatorial candidate. Total compensation: **$366,869** (base $283k + $50k bonus + benefits). - First Black American independently elected statewide in Kentucky history - Transitioned directly from AG office to 1792 Exchange CEO in January 2024 - **Federalist Society** affiliate ### Governance Red Flags 🚩 The 1792 Exchange filing reveals **four critical governance failures**: | Governance Policy | Required? | 1792 Exchange | | :--------------------------------- | :------------ | :------------------------------------------------ | | Whistleblower Policy | Best practice | ❌ **NO** | | Document Retention Policy | Best practice | ❌ **NO** | | CEO Compensation Review Process | Best practice | ❌ **NO** | | Other Officer Compensation Process | Best practice | ❌ **NO** | | Public Document Availability | Required | ❌ **"No documents are available to the public"** | > **Schedule O, Part VI, Line 19:** _"No documents are available to the public."_ This is a remarkable statement. While the law allows organizations to make documents available "upon request," explicitly stating that **no documents** are available goes beyond the norm and signals a deliberate opacity posture. **Board composition:** 5 voting members, only **2 independent**. No family/business relationships disclosed (unlike SFOF). ### Major Contractors — The Money Trail | Contractor | Amount | Service | Location | | :--------------------------------------------------- | :------------- | :---------------------------------- | :----------------- | | **Joseph David Advertising LLC** (now JDA Worldwide) | **$1,738,447** | "Program support" | Indianapolis, IN | | **Fusion Law PLLC** | **$1,093,602** | "Program support" | Phoenix, AZ | | **Beck & Stone Inc** | $299,435 | Media services | St. Petersburg, FL | | **Campbell Mille Payne PLLC** | $250,000 | "Legal services to further program" | Dallas, TX | > **Total to top 4 contractors: $3,381,484** — 44% of total expenses - **JDA Worldwide** is a faith-based advertising firm "built on Biblical values" that specializes in nonprofit fundraising - **Fusion Law PLLC** represents Arizona Republican legislative leaders (Speaker Ben Toma, Senate President Warren Petersen) in suits against EPA ### Financial Profile Books kept by **MLA Companies** in Springboro, OH (not Compass—1792 operates outside the CPI back-office) | Metric | BOY | EOY | | :---------------- | :------- | :------------- | | Total Assets | $947,659 | $2,334,048 | | Total Liabilities | $669,374 | $1,614,840 | | Net Assets | $278,285 | $719,208 | | Other Liabilities | $0 | **$1,038,223** | The $1M+ "Other Liabilities" is disclosed as an **operating lease liability** (office lease), not a suspicious intercompany loan. Revenue growth is strong and the org is in positive net asset territory, unlike SFOF. --- ## Network Architecture Summary ``` Bradley Foundation ($100k+) │ ▼ ┌─── CPI (Hub) ───────────────────────┐ │ │ │ │ │ $568,500 $813,590 $846,525 │ │ │ │ │ ▼ ▼ ▼ │ SFOF Compass Pro Compass Legal │ ($244,944 (Vought) (Mitchell) │ back to CPI) │ │ │ ┌────┼────┐ │ │ │ │ │ ▼ ▼ ▼ │ c3 c4 527 │ Found. Network Action │ (Educ) (Advoc) (PAC) │ │ Books kept by Compass Pro │ Board: Ed & Patrick Corrigan (family) │ Employees: 0 (all via Network) └──────────────────────────────────────┘ ┌─── 1792 Exchange (Satellite) ────────┐ │ CEO: Daniel Cameron (fmr KY AG) │ │ Registered c/o Cleta Mitchell │ │ Revenue: $225k → $8.1M (4 years) │ │ $1.7M → JDA Worldwide (advertising) │ │ $1.1M → Fusion Law (AZ litigation) │ │ "No documents available to public" │ │ No whistleblower / retention policy │ └──────────────────────────────────────┘ ``` --- ## Open Items - [x] ~~**1792 Exchange Schedule O** — Downloaded and analyzed. Registered c/o Cleta Mitchell. Major governance red flags.~~ - [ ] **$430k Unsecured Notes (SFOF)** — Who is the lender? Likely [[Conservative Partnership Institute|CPI]] (matches the $244k loan noted in earlier filings). - [ ] **Compass Professional ownership** — Russell Vought confirmed as beneficial owner 2021-2023. Current status unknown. - [ ] **JDA Worldwide / Fusion Law** — Are these entities connected to 1792 Exchange officers? Need beneficial ownership research. - [ ] **Daniel Cameron → Cleta Mitchell link** — Is Cameron connected to the [[Conservative Partnership Institute|CPI]] network beyond the c/o registration? Check FEC, Federalist Society events. --- ## Network Context For a broader analysis of how [[Conservative Partnership Institute|CPI]] and these entities fit into the larger Christian Nationalist network, see the **[[Christian_Nationalism_Network_Report_2026]]** located in `14DocsandFiles/Intelligence_Briefs`.