Opportunity Fund participation in School Diversification

Learning Together

Council Exchange Board of Trade Community Outcome Fund National Minority Technology Council Looking Forward Research & Development Enterprise School System Charter School Development for the Opening of New Charter Schools and for the Replication and Expansion of High-Quality Charter Schools

Expanding Opportunity Through Quality Charter Schools Program (CSP)

Public Comment on Priority 1 Spurring Investments in Opportunity Zones U.S. Department of Education proposed priorities, requirements, definitions, and selection criteria

Learning Together Charter School Development for the Opening of New Charter Schools and for the Replication and Expansion of High-Quality Charter Schools

Charter School Program Priorities – Public Comment on Priority 1: Spurring Investment in Opportunity Zones

Public Comment - Expanding Opportunity Through Quality Charter Schools Program

Learning Together Charter School Development for the Opening of New Charter Schools and for the Replication and Expansion of High-Quality Charter Schools

INTRODUCTION The major purposes of the U.S. Department of Education (ED), Office of Innovation and Improvement (OII): Charter Schools Program (CSP) are to expand opportunities for all students, particularly traditionally underserved students, to attend high-quality charter schools and meet challenging State academic standards; provide financial assistance for the planning, program design, and initial implementation of public charter schools; increase the number of high-quality charter schools available to students across the United States; evaluate the impact of charter schools on student achievement, families, and communities; share best practices between charter schools and other public schools; encourage States to provide facilities support to charter schools; and support efforts to strengthen the charter school authorizing process.

CSP—Grants to Charter School Developers for the Opening of New Charter Schools and for the Replication and Expansion of High-Quality Charter Schools (Developer Grants) are intended to support charter schools that serve early childhood, elementary school, or secondary school students by providing grant funds to eligible applicants for the opening of new charter schools (CFDA number 84.282B) and for the replication and expansion of highquality charter schools (CFDA number 84.282E) This Public Comment is focused on Proposed Priority 1 – Spurring Investment in Opportunity Zones. Created under the Tax Cuts and Jobs Act (Pub. L. 115-97), opportunity zones are intended to promote economic development and job creation in distressed communities through preferential tax treatment for investors. Specifically, if an individual invests capital gains in an opportunity fund—i.e., a vehicle established for the purpose of investing in property in an opportunity zone—the taxes the individual owes on those gains can be deferred and reduced.

Through this proposed priority, the Administration seeks to harness the power of opportunity zones to help increase the educational choices available to students in these communities.

The Department would use this priority to encourage the opening of new charter schools and the replication and expansion of high-quality charter schools in opportunity zones and to reward charter school developers that are partnering with an opportunity fund, especially for the purpose of acquiring or constructing school facilities

Public Comment - Expanding Opportunity Through Quality Charter Schools Program

Learning Together Charter School Development for the Opening of New Charter Schools and for the Replication and Expansion of High-Quality Charter Schools

1. PROPOSED PRIORITY 1 - SPURRING INVESTMENT IN OPPORTUNITY ZONES There is deep appreciation that ED would allow flexibility in the program area and allow time for the completion of any coordinated investment from a qualified opportunity fund in any given competition. This Public Comment is focused on the second area, particularly with regards to future opportunity fund investments from an identified opportunity fund.

The Council Exchange Board of Trade, a Virginia non-stock corporation registered with the IRS as a 501c6 business league, has a future strategy that postulates the creation of a holding company that wholly owns an opportunity fund. Following the new regulatory tranche on 1400Z-2 and the Securities Exchange Commission Reg D requirements this opportunity fund, under a special allocation, would create an opportunity fund complex that will allow future opportunity zone business investments to include investing in charter schools located in a 20 Region geographic footprint.

2. OPPORTUNITY FUND COMPLEX Opportunity Fund Complex Definition An opportunity fund complex (fund complex) is a single opportunity fund instrument that includes multiple collaborative arrangementsi organized as sub-fund joint ventures managed by the same fund complex. Each sub-fund will have its own objectives for growth and special allocation. Combining sub-funds into fund complex families provides more options for the investor. For example, an opportunity fund complex may contain separate funds focused on different regions across the United States. A fund complex may include sub-funds that are asset-based acquisitions, qualified opportunity zone business investments, state local and international partnerships and enterprise managed services collaborative arrangements for smart and connected communities.

Public Comment - Expanding Opportunity Through Quality Charter Schools Program

Learning Together Charter School Development for the Opening of New Charter Schools and for the Replication and Expansion of High-Quality Charter Schools

Outcome Fund Complex Framework  Structure Building an ecosystem driven financial instrument that embraces the complexity of community development with a construct organized to recognize the unique tapestry of stakeholders, anchor institutions and economic development programs requires a planned design methodology. The Fund Complex structure for the Outcome Fund arranges multiple qualified opportunity joint ventures controlled by an enterprise management team focused on acquisition and contract growth targets geared to increase investor and community returns.  Systems The Outcome Fund Complex is a group of interrelated entities, regionally distributed, centrally managed and modeled to learn and grow based on environmental and behavioral feedback. Conceptualizing the reality that “we are stronger together” the Opportunity Fund Complex takes a systems approach to decision making allowing for collective bargaining and the emergence of trust and transactional transparency.

Monitoring and managing entity success through cooperative strategies programed to ensure collective payoffs, smoothing returns over time while enriching neighborhoods and citizenry.  Competency Critical to the success of the Opportunity Fund Complex is the ability of the executive and management team to form and perform. Given the creative nature of change and community enrichment team members must bring the knowledge, confidence, and expertise directly to each region. The Outcome Fund team brings both management capacity and proficiency to the table. It is not enough to know how to solve the challenges of poverty and underemployment, it requires a savvy community development approach that is both inclusive and democratic. Communities have become jaded and are looking for Opportunity Funds that are community centric and not only focused on a “one-and-done” development strategy. Commitment and integrity are character traits that make up the essence of our team formation. Specifically management maintains the highest level of relationship intelligence, capable of negotiating with multiple types of stakeholders in order to implement and supervise the development and ongoing business concerns.

Public Comment - Expanding Opportunity Through Quality Charter Schools Program

Learning Together Charter School Development for the Opening of New Charter Schools and for the Replication and Expansion of High-Quality Charter Schools

3. FUTURE OPPORTUNITY FUND INVESTMENT Community Outcome Fund www.outcomefund.us

As illustrated above it would be simple to identify an opportunity fund on a proposal. The Community Outcome Fund investment to facilitate a Charter School acquisition strategy to facilitate the opening of new Charter Schools and for the replication and expansion of highquality Charter Schools.

Improvements include construction of new facilities, or the renovation, repair, or alteration of existing facilities. Investments could also go towards the predevelopment costs required to assess Charter School site locations and the acquisition of other tangible property.

Karl Cureton, Executive Chairman Council Exchange Board of Trade National Minority Technology Council 1750 Tysons Boulevard, Suite 1500 McLean, Virginia 22102 Office: 703-952-3334 www.council,exchange

Public Comment - Expanding Opportunity Through Quality Charter Schools Program