Nonprofit public benefit corporation · IRC § 501(c)(3) public charity
The Council works at the intersection of cross-border banking and education finance — publishing voluntary standards, participating in federal rulemaking, and conducting independent third-party reviews under engagement.
Its intended proposals advance real-time data capture and AI-driven analysis managed by joint working groups, offered for consideration through the public comment process.
- The organization
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The Council for Education (CED)
a nonprofit public benefit corporationExempt under IRC § 501(c)(3) and classified as a public charity under § 509(a)(2) — IRS determination (Letter 947), EIN 82-3295336, effective date of exemption 20 September 2024, contributions deductible under IRC § 170. The Council participates in federal notice-and-comment rulemaking and conducts independent third-party reviews under engagement.
What the Council is
The Council’s comment record is addressed to the Department of Education across dockets concerning financial responsibility, Title IV oversight, accreditation, and foreign-source reporting under Section 117 of the Higher Education Act (20 U.S.C. § 1011f), and to the Federal Reserve Board on reporting-form data collection.
That record is the Council’s standard-setting activity, and it is public. Its work addresses measurement gaps: cases in which a regulator’s own data system fails to capture the dominant flow channel while the underlying activity continues at scale. A gap in measurement is not an absence of activity — it is an absence of visibility, and it is the condition this work exists to correct.
How the Council works
A documented finding leaves the Council through one of three channels.
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Channel 01
Regulatory referral
A finding is routed to the agency holding examination authority over the subject. The Council refers; it does not examine.
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Channel 02
Rulemaking comment
The same finding enters the public record as a comment under 5 U.S.C. § 553, where a measurement gap can be addressed by rule rather than case by case.
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Channel 03
Public-interest litigation
Where a finding supports it, litigation including qui tam actions under the False Claims Act. Every such determination is made by counsel.
The three channels operate independently of whether any institution adopts the Council’s methodology. Adoption is never sought as a condition of resolving a matter, and a matter is never opened to encourage adoption. Standards outreach and enforcement referral are kept separate deliberately, because a standard advanced under pressure is not a standard.
Intended proposals
The Council intends to organize a federally chartered banking entity, to be titled the New Bank Committee™, and advances services built on the CBMAS™ framework and the BAoHC methodology as intended revenue sources for that planned entity. Under that model, customers of the planned entity would be licensed to operate agentic-AI systems built on the CBMAS™ framework and the BAoHC methodology, governed by the S.T.E.E.R. sequence published with the methodology.
The Council’s rulemaking participation before the Federal Reserve Board advances CBMAS™ and the BAoHC methodology as intended proposals: submissions offered for consideration through public comment, proposing to replace the U.S. Department of Education’s eZ-Audit electronic submission system with more frequent, real-time data collection and AI-based analysis. They remain proposed methodologies — not adopted rules, and not validated deployments.
Standing
- The entity is planned, not chartered; no application, approval, or charter is asserted, and no license is offered by this page.
- CBMAS™ and BAoHC are proposed methodologies — not adopted rules, and not validated deployments.
Public record
The record is public. The Council’s tax-exempt status, its rulemaking participation, the regime its education-finance work is measured against, and the registration of its methodology’s source text are all matters of public record.
- Comment filed
- Rule as adopted
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Tax-exempt status
Council for Education — exempt under IRC § 501(c)(3); public charity under § 509(a)(2)
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Copyright registration
Broken Windows Theory Applied to Banking and Offshore Financial Centers (BAoHC) — Registration TXu 2-547-918
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CBMAS™ and New Bank Committee™ are trademarks of The Council for Education, subject to pending applications before the United States Patent and Trademark Office. The planned banking entity is planned, not chartered; no application, approval, or charter is asserted. This page is an organizational summary and does not constitute legal, accounting, or audit advice.