17 KiB
NCOSE Schedule R, For Good DAF, and Meta Super PAC Investigation
Research Date: 2026-03-13 Data Sources: IRS Form 990 XML e-files (ProPublica), FEC API, state ethics commission filings, investigative reporting Scope: Three parallel investigations into fiscal sponsorship pathways and political spending
Executive Summary
Three parallel investigations produced one breakthrough finding, two definitive negatives, and critical new context:
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NCOSE Schedule R reveals a two-entity evolution — the original "NCOSE Action" (EIN 86-2458921, c4→c3) was replaced by a new "Institute for Public Policy" (EIN 88-1180705, c4). All 19 transaction indicators between NCOSE and the Institute are marked "No." DCA does not appear on any NCOSE Schedule R. However, NCOSE's lobbying spend tripled ($78K→$204K) concurrent with the ASAA push.
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For Good DAF is a dead end — 59,736 grant recipients across 5 years (~$1.73 billion) searched. Zero matches for DCA, DCI, NCOSE, NCOSEAction, or any related entity. DCA's donation page exists on the platform, but no money has flowed through the DAF to any investigation target.
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Meta's super PACs are state-level entities, not FEC-registered — deliberately structured to scatter filings across state ethics commissions rather than the searchable FEC database. Forge the Future's website explicitly lists "empowering parents with oversight of children's online activities" as a policy priority — ASAA-aligned language.
1. NCOSE Form 990 Schedule R — The Corporate Family Evolution
Four Years of Schedule R Filings
| Filing Year | Related Organizations Listed | Key Change |
|---|---|---|
| FY2020 | None | No Schedule R filed |
| FY2021 | NCOSE Action (EIN 86-2458921) — 501(c)(4), Virginia | First appearance of c4 affiliate |
| FY2022 | NCOSE Action (EIN 86-2458921) — 501(c)(3), DC | Reclassified from c4 to c3 supporting org |
| FY2023 | NCOSE Action (86-2458921, c3) + Institute for Public Policy (88-1180705, c4) | NEW c4 entity created |
| FY2024 | Institute for Public Policy (88-1180705, c4) only | NCOSE Action dropped from Schedule R |
The Two-Entity Switcheroo
The entity publicly branded as "NCOSEAction" on NCOSE's website maps to two different legal entities over time:
Entity 1: NCOSE Action (EIN 86-2458921)
- Created as a 501(c)(4) in Virginia (FY2021)
- Reclassified to 501(c)(3) Type II supporting organization (FY2022-FY2023)
- Disappeared from Schedule R by FY2024
- Never filed independently with IRS — not on ProPublica
- Activities: "Engages public officials to support a world free from sexual exploitation"
Entity 2: National Center on Sexual Exploitation Institute for Public Policy (EIN 88-1180705)
- First appeared on Schedule R in FY2023
- 501(c)(4) — the replacement lobbying vehicle
- IRS ruling date: May 2025
- Address: 1201 F St NW, Ste 200, Washington, DC 20004
- Direct controlling entity: NCOSE
- Filing requirement: 990-N (e-Postcard, ≤$50K gross receipts)
- Financial data: All zeros — no revenue, assets, or income reported
- No website (ncoseaction.org does not resolve)
The Zero-Transaction Anomaly
All 19 transaction-type indicators between NCOSE and the Institute for Public Policy are marked "No" on Schedule R:
- No grants or other assistance
- No shared employees
- No shared facilities
- No reimbursements paid or received
- No loans or loan guarantees
- No transfers of any kind
This is notable because:
- NCOSE's website describes NCOSEAction as "created by NCOSE"
- Schedule R lists the Institute as a "controlled organization" with NCOSE as "direct controlling entity"
- Marcel van der Watt is Senior VP at NCOSE AND principal officer of the Institute
- Yet NCOSE reports zero transactions of any kind with its own controlled c4
DCA Is Not on Schedule R
DCA does not appear as a related organization on any NCOSE 990 filing. If DCA were formally a project of NCOSEAction or the Institute for Public Policy, it would likely not trigger Schedule R disclosure (fiscal sponsorships within a c4 are not "related organizations" in the IRS sense). However, the complete absence of DCA from all NCOSE filings — including narrative program descriptions — is significant.
NCOSE Lobbying Spending Tripled
| Year | Total Lobbying | Direct Lobbying | Grassroots Lobbying |
|---|---|---|---|
| FY2021 | $60,000 | — | — |
| FY2022 | $60,000 | — | — |
| FY2023 | $78,000 | — | — |
| FY2024 | $204,000 | $125,700 | $78,300 |
The 162% increase from FY2023 to FY2024 is concurrent with DCA's launch (~December 2024) and the ASAA legislative push. However, NCOSE's Part III program descriptions do not mention ASAA, age verification, app stores, or DCA.
Casey Stefanski Never Appears on NCOSE's 990
Despite reportedly working at NCOSE for 10 years as Senior Director of Global Partnerships, Casey Stefanski is not listed on any of the four NCOSE 990 filings examined (Part VII officers, directors, trustees, key employees, or highest compensated). This means she was not among the five highest-compensated employees and was not an officer or key employee during her tenure.
NCOSE Officers and Key Employees (FY2024)
| Name | Title | Compensation |
|---|---|---|
| Dawn Hawkins | CEO | $185,000 |
| Patrick Trueman | President/Director | $140,251 |
| Marcel van der Watt | Senior VP, Impact & Operations | $130,000 |
| Peter Gentala | Senior Legal Counsel | $218,960 |
| Benjamin Bull Esq | SVP & Director, Law Center | $215,033 |
| Eleanor Gaetan | VP & Director Policy | $163,240 |
Note: Van der Watt has since been promoted to President & CEO of NCOSE.
NCOSE Financial Summary (FY2024)
| Metric | Amount |
|---|---|
| Total Revenue | $5,427,150 |
| Total Expenses | $5,436,436 |
| Contributions/Grants | $5,375,839 (99%) |
| Program Services | $4,209,850 (77.4%) |
| Employee Retention Credits received | $837,500 |
2. For Good DAF — Definitive Negative Finding
Search Scope
| Year | Grant Recipients | Total Grants |
|---|---|---|
| 2024 | 4,733 | ~$220M |
| 2023 | 9,605 | ~$338M |
| 2022 | 12,527 | ~$440M |
| 2021 | 15,171 | ~$547M |
| 2020 | 17,700 | ~$683M |
| Total | 59,736 | ~$1.73 billion |
Target Organization Search — ALL NEGATIVE
Across all five years and 59,736 grant recipients:
| Search Term | Result |
|---|---|
| "Digital Childhood Alliance" | NOT FOUND |
| "Digital Childhood Institute" | NOT FOUND |
| EIN 39-3684798 (DCI) | NOT FOUND |
| "NCOSE" / "National Center on Sexual Exploitation" | NOT FOUND |
| EIN 88-1180705 (NCOSEAction) | NOT FOUND |
| "NCOSEAction" | NOT FOUND |
| "Age Verification" | NOT FOUND |
| "Online Safety" / "Internet Safety" | NOT FOUND |
| "App Store" / "App Rating" | NOT FOUND |
Full-text search of every XML element (not just Schedule I) confirmed zero matches in any year.
Structural Observations
- All grants are to 501(c)(3) organizations identified by EIN — no separate "Project" reporting category on the 990
- Every grant is listed as "UNRESTRICTED" — no purpose-specific grants
- Each EIN appears once per year (amounts aggregated per recipient)
- NFG became a subsidiary of DCSO (Durable Capital for Sustainable Outcomes, Inc., EIN 99-0468956) on June 7, 2024
Implications
DCA's donation page exists on the NFG/Bonterra platform (digitalchildhoodalliance.networkforgood.com), but no money has flowed through the For Good DAF to DCA, DCI, NCOSE, or any related entity during 2020-2024. This means either:
- The donation page was set up but has processed zero or negligible donations
- Donations flow through a different mechanism than the For Good DAF (e.g., direct Bonterra payment processing that bypasses the DAF)
- The page is cosmetic — DCA's actual funding comes from Meta and/or other sources, not small-dollar DAF donations
- Donations are aggregated under a different entity's EIN that we haven't identified
The most likely explanation: the NFG donation page is window dressing — it provides the appearance of grassroots fundraising while DCA's actual operating budget comes from Meta (per Bloomberg) and potentially from NCOSE/NCOSEAction institutional support.
3. Meta Super PAC Network — State-Level, Not Federal
Why They Don't Appear in FEC Searches
Meta's super PACs are structured as nonfederal committees registered with state ethics commissions. This is a deliberate transparency strategy: by avoiding FEC registration, the PACs' filings are scattered across individual state databases rather than centralized in the searchable federal system.
The only Meta committee in the FEC database:
- META PLATFORMS, INC. PAC (Committee ID: C00502906) — traditional corporate PAC, DC-based, treasurer Ritika Robertson
The Four-PAC Architecture
Meta Platforms, Inc.
│
├── $45M (Sep 2025) ──→ ATEP (American Technology Excellence Project)
│ │ 527 PAC, bipartisan
│ │ Brian Baker (R) + Hilltop Public Solutions (D)
│ │
│ ├──→ Forge the Future Project with Meta
│ │ State PAC, Republican-aligned
│ │ Registered TX Jan 23, 2026
│ │ $1.2-1.36M Texas spending
│ │
│ └──→ Making Our Tomorrow
│ State PAC, Democrat-aligned
│ Chair: Brian Rice (Meta VP Public Policy)
│ $750K Illinois budget
│
├── $20M (Aug 2025) ──→ META California
│ State PAC
│ Chair: Brian Rice (Meta VP Public Policy)
│ $19.7M cash on hand entering 2026
│
└── $5M ──────────────→ California Leads
State candidates
Total documented Meta political spending: $70+ million
Forge the Future — ASAA-Aligned Policy Priorities
Forge the Future's website (texasforgefuturepac.com) lists three policy priorities:
- "Championing U.S. technology companies"
- "Empowering parents with oversight of children's online activities across devices and digital environments"
- "Favorable regulatory conditions to bring AI products to market"
Priority #2 is functionally identical to ASAA's framing — parental oversight of children's online activities through device/app store-level controls. This is the first direct evidence that Meta's super PAC spending is ideologically connected to the ASAA legislative campaign.
Known Candidates Supported
Texas (Forge the Future):
| Candidate | Office | Amount | Result |
|---|---|---|---|
| Kelly Hancock | TX Comptroller (R primary) | $500,000 | Lost to Don Huffines |
| 2 unnamed | TX State Senate | Unknown | Unknown |
| 1 unnamed | TX State House (North TX) | Unknown | Unknown |
Of 20 Meta-backed candidates in Texas and North Carolina primaries, only one lost (per Washington Post, March 12, 2026).
Illinois (Making Our Tomorrow):
- Paul Kendrick (IL House D-12)
- Adam Braun (IL House D-13)
- Aja Kearney (IL House D-34)
- Jaime Andrade (IL House D-40)
Connection to ASAA Sponsors — Not Confirmed
No direct evidence links Meta's super PAC spending to specific ASAA bill sponsors:
| Sponsor | State | PAC Activity Found? |
|---|---|---|
| Todd Weiler | Utah | No Meta PAC activity in Utah |
| Kim Carver | Louisiana | No Meta PAC activity in Louisiana |
| Angela Paxton | Texas | Forge the Future backed unnamed TX senators — Paxton's inclusion is unknown |
| Caroline Fairly | Texas | No specific connection found |
| Matt Ball | Colorado | No Meta PAC activity in Colorado |
| Amy Paschal | Colorado | No Meta PAC activity in Colorado |
Critical caveat: Forge the Future supported at least two unnamed Texas state Senate candidates. Angela Paxton is a sitting state senator and ASAA sponsor. Whether she was among the unnamed beneficiaries cannot be determined from available reporting.
Key Personnel
| Person | Meta Title | PAC Role |
|---|---|---|
| Brian Rice | VP of Public Policy | Chairs Making Our Tomorrow + META California |
| Greg Maurer | Executive | Co-runs political spending with Rice |
| Brian Baker | Republican strategist | Co-leads ATEP |
| Hilltop Public Solutions | Dem consulting firm | Co-leads ATEP (also involved with DCA messaging) |
Hilltop Public Solutions connection: This firm co-leads ATEP (Meta's $45M super PAC) AND was previously identified as involved in DCA's messaging coordination. This is the first confirmed overlap between Meta's super PAC operation and the DCA astroturf campaign.
Nonfederal Structure as Transparency Strategy
By registering PACs at the state level:
- Filings are scattered across 50 separate state databases
- No centralized search like FEC.gov
- Different states have different disclosure timelines and formats
- Researchers must individually query each state's ethics commission
- This creates structural opacity by fragmentation, even when each individual filing is technically public
4. Cross-Thread Connections
The Hilltop Connection
Hilltop Public Solutions appears in three separate contexts:
- Co-leads ATEP ($45M Meta super PAC) — the bipartisan Democratic partner
- Involved in DCA messaging — identified in prior investigative reporting
- Connected to ATEP super PAC — which funds Forge the Future, whose policy priorities mirror ASAA
This makes Hilltop a bridging entity between Meta's super PAC operation and the DCA advocacy campaign — the first firm connected to both tracks.
The NCOSE → NCOSEAction → DCA Personnel Chain
Marcel van der Watt
├── President & CEO, NCOSE (c3)
├── Principal Officer, Institute for Public Policy / NCOSEAction (c4)
│
└── Dawn Hawkins (reports to van der Watt)
├── CEO, NCOSE (c3)
├── Chair, DCA (c4 claimed)
│
└── Casey Stefanski (reports to Hawkins)
├── Former: 10 years at NCOSE, Sr Dir Global Partnerships
└── Current: Executive Director, DCA
Despite this direct personnel chain, NCOSE reports zero transactions with NCOSEAction on Schedule R, and DCA does not appear on any NCOSE filing.
The Lobbying Spend Timing
| Entity | FY2023 Lobbying | FY2024 Lobbying | Change |
|---|---|---|---|
| NCOSE | $78,000 | $204,000 | +162% |
| Meta (federal) | $24.4M | $26.3M | +8% |
| STF | — | $31M | — |
NCOSE's lobbying tripled in the same period that DCA launched and ASAA passed in three states. The coincidence of timing — combined with the personnel overlap — is notable, even though NCOSE's program descriptions don't mention ASAA.
5. Updated Fiscal Sponsor Assessment
| Factor | STF | NCOSEAction | For Good DAF |
|---|---|---|---|
| Tax status | c4 ✓ | c4 ✓ | c3 (DAF) |
| Financial capacity | $282M revenue | ≤$50K | $204M (pass-through) |
| Sponsored project model | Documented (hundreds) | Unknown | DAF model (not sponsorship) |
| Personnel overlap with DCA | Indirect (Eichberg) | Direct (Hawkins, Stefanski, van der Watt) | None |
| Evidence of DCA funding | $0 in Schedule I | $0 reported (no filing) | $0 in 59,736 grants |
| Confirmed DCA connection | No | Personnel chain only | Donation page exists, no money flows |
| Transaction disclosure | Zero child safety keywords | Zero transactions with NCOSE | All grants unrestricted to c3s |
Assessment: For Good DAF is ruled out as a funding pathway. STF remains the strongest candidate for financial capacity. NCOSEAction remains the strongest for personnel proximity. The most likely model: Meta funds DCA directly (per Bloomberg), with NCOSEAction/NCOSE providing institutional infrastructure (staff, expertise, coalition network) rather than acting as a fiscal pass-through.
Sources
IRS Filings
- NCOSE 990s (FY2020-FY2024): ProPublica Nonprofit Explorer, EIN 13-2608326
- For Good 990s (2020-2024): ProPublica Nonprofit Explorer, EIN 68-0480736
- IRS EO BMF: NCOSEAction EIN 88-1180705 confirmation
FEC
- Meta Platforms Inc PAC: FEC Committee ID C00502906
- FEC API: api.open.fec.gov
Investigative Reporting
- Politico: "Meta pours $45M into super PAC" (Feb 2, 2026)
- Texas Tribune: "Forge the Future" Texas spending (Feb 2026)
- Washington Post: Meta-backed candidate results (Mar 12, 2026)
- Illinois Sun-Times: Making Our Tomorrow Illinois spending (Feb 2026)
- Bloomberg Government: Meta California lobbying record (2025)
State Filings
- Texas Ethics Commission: Forge the Future Project with Meta registration
- Illinois State Board of Elections: Making Our Tomorrow filings
- Forge the Future website: texasforgefuturepac.com