{
  "schema_version": "1.0",
  "plan_id": "JW-CV-GRANT-COI-001",
  "title": "Grant Readiness: Conflicts of Interest and Time Commitment",
  "as_of": "2026-10-19",
  "purpose": "Prepares the conflict-of-interest, conflict-of-commitment and time-commitment disclosures for grants where Jermaine E. Whiteside is an investigator and one or more of his organizations has another role. It is planning material, not a disclosure. Each disclosure is made in the applicant's own forms, under the applicant's written conflict-of-interest policy and the funding agency's rules.",
  "visibility_rule": "This page shows roles that are already public, ownership as stated by the owner, and the rules that apply. Effort percentages, person-months, compensation and contract amounts are kept in a private worksheet in the owner's Google Drive and are not published.",
  "roles": [
    {
      "entity": "Anointed Connect Church Inc.",
      "role": "Senior Pastor and Founder (2014–present)",
      "grant_role": "Applicant organization; Jermaine E. Whiteside as Principal Investigator",
      "interest": "Employment / leadership role",
      "source": "/cv/ (Selected Leadership)"
    },
    {
      "entity": "EWTECHNERD LLC",
      "role": "Founder and Managing Member",
      "grant_role": "Technical implementation contractor or technical partner",
      "interest": "Financial interest in a proposed contractor: {EWT} ownership (as of {ASOF})",
      "source": "https://ewtechnerd.com/"
    },
    {
      "entity": "Anointed Holdings LLC",
      "role": "Founder, Sole Member and Managing Member (2025–present)",
      "grant_role": "Holder of intellectual property that a project may license or use",
      "interest": "Financial interest in intellectual property used by the project: {AH} ownership (as of {ASOF})",
      "source": "/cv/ (Selected Leadership)"
    },
    {
      "entity": "IAM of America",
      "role": "Founder and Incorporator (owner statement, October 19, 2026)",
      "grant_role": "Possible applicant or partner",
      "interest": "Leadership role in a nonprofit; no ownership. South Carolina public-benefit nonprofit corporation; federal 501(c)(3) recognition application in development (iamofamerica.com)",
      "source": "https://iamofamerica.com/"
    },
    {
      "entity": "Reinvest Carolina Inc.",
      "role": "Director (sole director) and transitional custodian, preparing successor governance (reinvestcarolina.com)",
      "grant_role": "Possible applicant or partner",
      "interest": "Fiduciary duty as sole director of a nonprofit; no ownership. South Carolina public benefit nonprofit corporation established March 25, 2020",
      "source": "https://reinvestcarolina.com/"
    }
  ],
  "rules": [
    {
      "id": "2cfr200-318c1",
      "cite": "2 CFR 200.318(c)(1)",
      "summary": "The recipient must keep written standards of conduct covering conflicts of interest. No employee, officer, agent or board member with a real or apparent conflict of interest may take part in selecting, awarding or administering a contract supported by the award. A conflict exists when that person, an immediate family member, a partner or an employing organization has a financial or other interest in, or a tangible personal benefit from, an entity considered for the contract.",
      "url": "https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR45df7f6fdd8b3b0/section-200.318"
    },
    {
      "id": "2cfr200-318c2",
      "cite": "2 CFR 200.318(c)(2)",
      "summary": "A recipient with a parent, affiliate or subsidiary (other than a State, local government or Indian Tribe) must also keep written standards covering organizational conflicts of interest: where a relationship with a related organization means the recipient is, or appears to be, unable to be impartial in a procurement involving that organization.",
      "url": "https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR45df7f6fdd8b3b0/section-200.318"
    },
    {
      "id": "2cfr200-112",
      "cite": "2 CFR 200.112",
      "summary": "Federal agencies must establish conflict-of-interest policies for Federal awards. A recipient or subrecipient must disclose in writing any potential conflict of interest to the Federal agency or pass-through entity in accordance with that agency's policies.",
      "url": "https://www.law.cornell.edu/cfr/text/2/200.112"
    },
    {
      "id": "nspm33",
      "cite": "NSPM-33 (January 14, 2021)",
      "summary": "Directs research funding agencies to require disclosure of information related to potential conflicts of interest and commitment, including organizational affiliations and employment, other support (including in-kind resources), and positions and appointments whether or not paid. Defines conflict of commitment as accepting or incurring conflicting obligations between or among multiple employers or other entities.",
      "url": "https://trumpwhitehouse.archives.gov/presidential-actions/presidential-memorandum-united-states-government-supported-research-development-national-security-policy/"
    },
    {
      "id": "chips-10632",
      "cite": "Public Law 117-167, § 10632 (42 U.S.C. 19232)",
      "summary": "Each covered individual listed on a research and development proposal certifies that they are not a party to a malign foreign talent recruitment program, in the proposal and annually for the duration of the award.",
      "url": "https://www.govinfo.gov/content/pkg/PLAW-117publ167/html/PLAW-117publ167.htm"
    },
    {
      "id": "chips-10634",
      "cite": "Public Law 117-167, § 10634 (42 U.S.C. 19234)",
      "summary": "Each covered individual listed on an application for a research and development award certifies that they completed research security training within one year of the application.",
      "url": "https://www.govinfo.gov/content/pkg/PLAW-117publ167/html/PLAW-117publ167.htm"
    },
    {
      "id": "nih-overlap",
      "cite": "NIH commitment overlap (NIAID guidance)",
      "summary": "Commitment overlap occurs when an individual's time commitment exceeds 100 percent (12 person-months), regardless of how the effort or salary is supported.",
      "url": "https://pubweb-prod.niaid.nih.gov/grants-contracts/dont-overlook-three-types-overlap"
    }
  ],
  "scenarios": [
    {
      "id": "A",
      "name": "Anointed Connect applies; EWTECHNERD does the technical work",
      "conflicts": [
        "Financial conflict of interest: the Principal Investigator, who also leads the applicant, has a financial interest in the proposed contractor (2 CFR 200.318(c)(1)).",
        "Organizational conflict of interest if the applicant and EWTECHNERD are treated as related organizations (2 CFR 200.318(c)(2)).",
        "Conflict of commitment: time spent for EWTECHNERD and for Anointed Connect is counted together (NSPM-33; NIH overlap)."
      ],
      "controls": [
        "Anointed Connect adopts written standards of conduct covering conflicts of interest, including organizational conflicts, before applying.",
        "Jermaine E. Whiteside does not take part in selecting EWTECHNERD, setting its price, approving its invoices or accepting its deliverables. A named officer or board member does instead, and the recusal is minuted.",
        "EWTECHNERD is selected through competitive quotes or a documented cost comparison, kept with the award file.",
        "The conflict and the controls are disclosed in writing to the agency (2 CFR 200.112) in the form the agency asks for.",
        "EWTECHNERD's contract is priced at arm's length and its effort is shown separately from the investigator's."
      ],
      "language": "Jermaine E. Whiteside, the proposed Principal Investigator, is Senior Pastor and Founder of Anointed Connect Church Inc., the applicant. He is also the founder of EWTECHNERD LLC and owns {EWT} of it. EWTECHNERD LLC is proposed as the technical implementation contractor. Anointed Connect Church Inc. has written standards of conduct covering conflicts of interest, adopted on [date]. Mr. Whiteside did not take part in selecting EWTECHNERD LLC or setting its price. The selection was approved by [name, title] on [date] after [competitive quotes / a documented cost comparison]. [Name, title], not Mr. Whiteside, will approve EWTECHNERD LLC's invoices and accept its deliverables."
    },
    {
      "id": "B",
      "name": "The project uses intellectual property held by Anointed Holdings",
      "conflicts": [
        "Financial conflict of interest: the Principal Investigator is the sole member of the company that owns intellectual property the project would license or use."
      ],
      "controls": [
        "A written license sets the terms (royalty-free or a stated fee), approved by an official of the applicant other than Jermaine E. Whiteside.",
        "Any license fee charged to the award is priced at arm's length and justified in the budget; otherwise the license is royalty-free for the project.",
        "Ownership of new intellectual property created under the award follows the award terms, not the license, and is stated in the application.",
        "The interest is disclosed in writing to the agency with the other conflicts."
      ],
      "language": "Intellectual property used in this project, [describe], is held by Anointed Holdings LLC. Jermaine E. Whiteside is its founder, sole member and managing member, and owns {AH} of it. Anointed Holdings LLC licenses this intellectual property to [applicant] for the project on [royalty-free / stated] terms under a written license dated [date], approved by [name, title] without Mr. Whiteside's participation. Rights in intellectual property created under the award will be handled as the award terms require."
    },
    {
      "id": "C",
      "name": "Jermaine E. Whiteside is an investigator on another organization's grant; EWTECHNERD is the technical partner",
      "conflicts": [
        "Financial conflict of interest at the lead organization: an investigator has a financial interest in a proposed subrecipient or contractor (2 CFR 200.318(c)(1)).",
        "Conflict of commitment: effort as investigator and effort for EWTECHNERD are counted separately and together."
      ],
      "controls": [
        "The lead organization's conflict-of-interest policy governs; its official, not Jermaine E. Whiteside, approves EWTECHNERD's selection and payments.",
        "The investigator's effort and EWTECHNERD's effort appear on separate budget lines, and total commitments stay within 12 person-months.",
        "Disclosed in writing to the lead organization and, through it, to the agency."
      ],
      "language": "Jermaine E. Whiteside, [investigator role] on this project, is the founder of EWTECHNERD LLC and owns {EWT} of it. EWTECHNERD LLC is proposed as [subrecipient / contractor] for [technical scope]. Under [lead organization]'s conflict-of-interest policy, [name, title] approved EWTECHNERD LLC's selection on [date], and Mr. Whiteside will not approve its payments or accept its deliverables. Mr. Whiteside's effort as investigator ([x] calendar months) is budgeted separately from EWTECHNERD LLC's work."
    },
    {
      "id": "D",
      "name": "IAM of America or Reinvest Carolina applies; EWTECHNERD or Anointed Holdings is involved",
      "conflicts": [
        "Financial conflict of interest: the person leading the applicant owns the proposed contractor or IP licensor (2 CFR 200.318(c)(1)).",
        "Organizational conflict of interest between nonprofits led by Jermaine E. Whiteside and companies he owns (2 CFR 200.318(c)(2)).",
        "Conflict of commitment: time for each nonprofit is counted with every other role (NSPM-33; NIH overlap).",
        "Reinvest Carolina Inc. currently has a sole director, so no one inside the organization can approve a related-party contract while he is recused."
      ],
      "controls": [
        "The applying nonprofit adopts written standards of conduct covering conflicts of interest, including organizational conflicts, before applying.",
        "An approver independent of Jermaine E. Whiteside decides on any contract with EWTECHNERD or license from Anointed Holdings. For Reinvest Carolina Inc., seat at least one additional director, or obtain documented review by an independent party, before it applies.",
        "Selection is documented through quotes or a cost comparison, and the conflict is disclosed in writing to the agency (2 CFR 200.112).",
        "Confirm the applicant's eligibility for the program; IAM of America's 501(c)(3) recognition is still in development."
      ],
      "language": "Jermaine E. Whiteside, the proposed [Principal Investigator / project director], is [Founder of IAM of America / sole director and transitional custodian of Reinvest Carolina Inc.], the applicant. He also owns {EWT} of EWTECHNERD LLC, proposed as [contractor role], [and is sole member of Anointed Holdings LLC, which licenses (describe) to the project]. The applicant has written standards of conduct covering conflicts of interest, adopted on [date]. Mr. Whiteside did not take part in the selection or approval, which was made by [name, title / independent reviewer] on [date] after [competitive quotes / a documented cost comparison]."
    }
  ],
  "time_commitment": {
    "method": "Person-months = percent of a full-time year × 12. Add every commitment for the same 12 months: each organization role, each active award and each pending application. The total may not exceed 12 person-months (100%).",
    "inputs": [
      "Liberty University doctoral study (time, not employment)",
      "Anointed Connect Church Inc. (Senior Pastor)",
      "EWTECHNERD LLC",
      "Anointed Holdings LLC",
      "Each active award",
      "Each pending application"
    ],
    "worksheet": "Private Google Sheet in the owner's Drive (Funding Strategy & Grant Readiness folder): JW_Grant_COI_Commitment_Readiness_2026-10-19."
  },
  "research_security": {
    "training": "CITI Research Security Training (Combined), record 70645209, completed October 18, 2026. Completed within one year of applications submitted through October 18, 2027.",
    "training_link": "/evidence-cv/citi-research-training/#jw-cv-citi-usc-007",
    "foreign_talent": "The malign foreign talent recruitment program certification (§ 10632) is a separate statement made by the individual in each proposal and annually during an award."
  },
  "checklist": [
    "Applicant has written standards of conduct covering conflicts of interest, including organizational conflicts.",
    "Recusal of Jermaine E. Whiteside from selecting and administering EWTECHNERD (and any Anointed Holdings license) is minuted, with the approving official named.",
    "Contractor selection documented (quotes or cost comparison).",
    "Written disclosure to the agency prepared from the scenario language above.",
    "Time-commitment worksheet totals 12 person-months or less, including the new application.",
    "Research security training completed within one year of the application (current through October 18, 2027).",
    "Malign foreign talent recruitment program certification reviewed and signed by the individual.",
    "Current and Pending (Other) Support lists every position, appointment and in-kind resource, paid or unpaid."
  ],
  "limits": "This page summarizes rules for planning. It is not legal advice. The applicant's policy, the funding opportunity and the agency's grants policy statement control; confirm with the program officer or a grants administrator before submission.",
  "ownership": {
    "as_of": "2026-10-19",
    "EWTECHNERD LLC": "100%",
    "Anointed Holdings LLC": "100%",
    "update_rule": "For-profit ownership stated by the owner on October 19, 2026; nonprofits have no owners. Update the value and date when anything changes; the roles table, the disclosure language and the score read from it.",
    "IAM of America": "None (nonprofit)",
    "Reinvest Carolina Inc.": "None (nonprofit)"
  },
  "compliance_score": {
    "name": "Compliance Readiness Score",
    "method": "Counts the standing requirements that can be met before any particular application. Met = 1 point, in progress = 0.5, not met = 0. Score = points ÷ number of requirements. Items that depend on a specific application are listed separately and checked in the private worksheet for that application.",
    "requirements": [
      {
        "id": "R1",
        "item": "Research security training completed within one year of the application",
        "source": "Public Law 117-167 § 10634",
        "status": "met",
        "date": "2026-10-18",
        "evidence": "CITI record 70645209 (/evidence-cv/citi-research-training/#jw-cv-citi-usc-007)"
      },
      {
        "id": "R2",
        "item": "Ownership interests in related organizations recorded for disclosure",
        "source": "2 CFR 200.112; NSPM-33",
        "status": "met",
        "date": "2026-10-19",
        "evidence": "EWTECHNERD LLC {EWT}; Anointed Holdings LLC {AH} (owner statement, {ASOF})"
      },
      {
        "id": "R3",
        "item": "Positions, appointments and affiliations listed for Current and Pending (Other) Support, paid or unpaid",
        "source": "NSPM-33; NIH Common Forms",
        "status": "in-progress",
        "date": "",
        "evidence": "Roles listed on this page (five organizations); Other Support form not yet prepared"
      },
      {
        "id": "R4",
        "item": "Each organization that may apply (Anointed Connect Church Inc., IAM of America, Reinvest Carolina Inc.) has written standards of conduct covering conflicts of interest, including organizational conflicts",
        "source": "2 CFR 200.318(c)(1)–(2)",
        "status": "not-met",
        "date": "",
        "evidence": "Not yet documented"
      },
      {
        "id": "R5",
        "item": "An approving official other than Jermaine E. Whiteside is designated at each applicant, with a written recusal procedure, for matters involving EWTECHNERD LLC and Anointed Holdings LLC",
        "source": "2 CFR 200.318(c)(1)",
        "status": "not-met",
        "date": "",
        "evidence": "Not yet documented. Reinvest Carolina Inc. has a sole director; it needs an additional director or an independent reviewer first"
      },
      {
        "id": "R6",
        "item": "Template license for Anointed Holdings intellectual property (royalty-free or stated fee; approved without the owner)",
        "source": "Scenario B controls; 2 CFR 200.112",
        "status": "not-met",
        "date": "",
        "evidence": "Not yet documented"
      },
      {
        "id": "R7",
        "item": "Time-commitment baseline entered for current roles (person-months)",
        "source": "NSPM-33 (conflict of commitment); NIH commitment overlap",
        "status": "not-met",
        "date": "",
        "evidence": "Private worksheet: effort not yet entered"
      },
      {
        "id": "R8",
        "item": "ORCID iD linked to the eRA Commons Personal Profile, and both linked in SciENcv",
        "source": "NIH NOT-OD-26-079",
        "status": "in-progress",
        "date": "",
        "evidence": "Owner setting up eRA Commons"
      }
    ],
    "per_application": [
      "Contractor selection documented (quotes or cost comparison)",
      "Written disclosure to the agency (2 CFR 200.112) from the scenario language",
      "Malign foreign talent recruitment program certification (Public Law 117-167 § 10632)",
      "Total time commitment, including the new application, at or under 12 person-months",
      "Applicant eligibility confirmed for the program (for example, IAM of America's 501(c)(3) status if the program requires it)"
    ]
  },
  "template_tokens": {
    "{EWT}": "ownership['EWTECHNERD LLC']",
    "{AH}": "ownership['Anointed Holdings LLC']",
    "{ASOF}": "ownership['as_of']"
  }
}