Section 117 reporting where every foreign source is found, totaled against $250,000 and threaded to its record before three people sign
No foreign source missed or understated, every reported line traced to its record.
See one case, screen by screen ↓Section 117 Foreign Gift Reporting is a solution for Section 117 reporting: seven agents find gifts and contracts from foreign sources across the advancement CRM, ERP receivables, the grants system and contracts management, total each source by calendar year against $250,000, and draft the report in the federal portal's fields with every line threaded to its agreement, record and cash. The Compliance Officer decides, the AVP for Finance reviews, and the Vice President for Finance and Administration certifies.
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Section 117 reporting is the twice-yearly disclosure every college that takes federal student aid owes the Department of Education: each foreign source whose gifts and contracts reach $250,000, alone or combined, in a calendar year, filed by January 31 or July 31, with the amount, the date, the country and, for a restricted or conditional gift, a description of the conditions. Compliance is part of the Program Participation Agreement for federal student aid, Executive Order 14282 of April 23, 2025 made enforcement a priority, and the Department opened a new Section 117 reporting portal on January 2, 2026.
The money rarely sits in one place. Advancement runs a CRM query for foreign addresses, sponsored programs and the contracts office pull foreign parties into spreadsheets, the controller's office adds foreign wires, and the compliance officer merges it all by hand, guesses which names are the same source, reads each agreement and keys every line into the portal. One foundation booked under two names, in two languages or two systems, stays under the threshold twice; a contract modified after filing waits for the next report; and the officer who certifies signs from a summary, with no trace from a line to its money.
Estimated split of one semiannual filing's preparer hours, by hand and with the agents. The totals, 164 hours for a hand-built filing and 38 with the agents, are the demo university's own time log in the working solution; the split across steps is our estimate.
Seven agents find, resolve, total, read terms, recount and draft the report; three named people prepare, review and certify.
Halden State University's report for January 1 to June 30, 2026 is due Friday, July 31. On Tuesday, July 14, here is how one German foundation booked under two names reaches the report, and how the report reaches the federal portal, in the working solution.
The Finder agents read the advancement CRM, ERP receivables, the grants system and contracts management: 652 foreign-source transactions found in 36,220 gifts and contracts screened since January. Each find carries its signal and a proposal: a ¥18,000,000 pledge from Kaiyō Mirai Foundation, a donor with an address in Spain whose U.S. citizenship is verified, a wire from a bank in Switzerland with no record at all. Eighteen wait for the Compliance Officer.
F-0624: a wire from a bank in Switzerland with no record. Proposal: ask the office.
The report preview holds 138 lines from 38 foreign sources in 30 countries, $30,352,300, in the federal portal's fields. Above it, the threshold-crossers strip builds each source's calendar-year total gift by gift toward $250,000. Two bars sit under the line and are marked "May be one source": Rheinwald Foundation, $190,000 in the CRM, and Rheinwald-Stiftung, $80,000 in the ERP.
Kaiyō Mirai Foundation: $180,000 so far, with a pledge that crosses $250,000 on September 15 if paid.
The CRM booked donor C-118204 as Rheinwald Foundation; the ERP booked customer 40-77310 as Rheinwald-Stiftung. The agent shows the German original, Rheinwald-Stiftung für Technik und Recht, beside the English, with the evidence: register entry StV-2011-0484 for both names, the same signatory, Dr. Katrin Vogel, and the same bank account ending 4471. It proposes a join at confidence 0.97.
Fundação Aurora Atlântica and a U.S. charity: "Ask Advancement first", confidence 0.62.
Elena joins the two names. Together the three gifts are $270,000 in 2026, over $250,000 since June 3 with the School of Law gift, and all three belong in the report due July 31. The Checker agent recounts the total from ledger cash and agrees. Two of the gifts are restricted: a lecture program, and fellowships for German nationals.
Joined by you at 10:06 a.m. · source FS-0211 · 3 lines added · the report has 141 lines.
Line 54, Rheinwald-Stiftung, Germany, non-government gift, $95,000, February 18, carries its thread: the report fields, gift agreement GA-26-0118, CRM donor C-118204, cash receipt CR-26-104417 from the account ending 4471, and the register entry. The new lines count only when Elena approves them, and she does.
They go to David Achterberg for review; he cannot approve a change he made.
For each restricted or conditional gift, the agent quotes the agreement beside the four kinds of condition Section 117 names and drafts the description the portal asks for. Gift GA-26-0142 from Hokuto Academic Exchange Society, 北斗学術交流会, has a visiting professor chosen by a committee of two University faculty and one Society representative: faculty employment or assignment, confidence 0.93. Elena confirms, edits, or marks it not restricted with a reason.
213 totals were recomputed from ledger cash, invoices and contract modifications, and 211 agree to the dollar. Sørhavn Teknologi AS of Norway shows $410,000 in the contracts register and $435,000 in the ERP invoicing plan, which includes modification 2, signed June 19. Elena sets the line to $435,000, citing the modification; the agent never settles a disagreement itself.
Kaiyō Mirai Foundation: $180,000 at the pledge-date rate, $180,481 credited on receipt, under $250,000 either way.
Report 2025-2, filed January 29, listed Northmere Analytics Ltd, United Kingdom, contract SA-25-0388, at $640,000 on line 87. Modification 3, signed May 4, reduced it to $580,000, so the agent drafts the amendment. Elena files it with this report; she could also hold it with a reason.
David's queue holds five changes: the Rheinwald join, the Sørhavn amount, five restricted descriptions, the Northmere amendment, and the finds decided not foreign or not reportable. Each shows who prepared it and the evidence behind it: the register entry, the shared bank account, the restricted terms, the Checker agent's agreement. He approves each one, and he cannot review a change he made himself.
Certification opens only when six conditions pass: the preparer and the reviewer approved every change, every disagreement and every find is decided by a person, every restricted description is confirmed, and all 141 lines are threaded. Dr. Kaplan acknowledges the 18 U.S.C. 1001 statement and certifies 141 lines from 39 foreign sources in 30 countries, $30,647,300. The report is filed with confirmation S117-2026-1-04417, and the review package is sealed.
The same report, seen by the people who prepare it, review it, sign it, answer for its donors and audit it: what their filing looked like, and what it looks like now.
Seven agents find, resolve, total, read terms, recount and draft the report; three named people prepare, review and certify.
Reads the advancement CRM, ERP receivables, the grants system and contracts management every night for foreign-source signals (citizenship, residence, incorporation, a foreign bank, a foreign sponsor) and proposes foreign, not foreign, not reportable, or ask the office.
Resolves names in any language and script to one legal source, the original beside the English, with register, signatory and bank-account evidence.
Reads each agreement, maps its conditions to the four kinds Section 117 names, quotes the clause and drafts the description the portal asks for.
Totals each source by calendar year against $250,000, with crossing dates and forecasts from pledges and payment schedules.
Recounts every total a second way, from ledger cash, invoices and contract modifications, and puts both counts in front of a person when they differ.
Builds the report in the federal portal's fields and the bulk upload file, with a thread from every line to its agreement, record and cash, and seals the review package.
Watches 252 filed lines and drafts an amendment when a contract is modified or a gift changes after filing.
Three named people. The agents propose; a named person decides.
The assistant answers from the records, cites each fact, and opens the screen where the work is done.
Which sources are close to $250,000?
Four, in calendar-year totals: the two Rheinwald names, $270,000 together, over if they are one source; Fundação Aurora Atlântica, $240,000, or $290,000 if a U.S. charity's gift is hers; Kaiyō Mirai Foundation, $180,000, crossing September 15 if paid; and donor D-42591, $62,500 with $250,000 pledged.
Why are the two Rheinwald names one source?
Three facts, each cited. The foundation register lists one legal entity, Rheinwald-Stiftung für Technik und Recht. All three agreements are signed by its board member Dr. Katrin Vogel. And all three gifts came from the same bank account, ending 4471. Together they are $270,000, over the threshold since June 3.
What is still open before July 31?
The items still open, each with its owner: the decisions with Elena, the review of every change with David Achterberg by July 24, and certification with Dr. Simone Kaplan by July 29. The statutory date is July 31, and compliance is a condition of federal student aid.
Build the compliance review package
The report as filed, every line's thread to its agreement, record and cash, every join and disagreement with who decided it, the restricted terms, the three approvals and the agent versions. Names of individual donors are masked in the auditor copy.
13 screens from the working solution, on its sample data. Pick one to see it large.
The thresholds, clocks and privacy rules every filing runs on are settings. A change is proposed as a new version, tested on the last report, and goes live when the AVP for Finance approves it.
| Setting | Default | Choose from |
|---|---|---|
| Reporting threshold | $250,000 per foreign source, calendar year | From the statute, read only; a change in law becomes a new settings version |
| Watch a source from | $200,000 | Shown on the threshold strip, with pledges and schedules forecast |
| Confidence to propose a join | 0.90 | Below it, the Entity agent asks instead of proposing |
| Office answers due | 3 business days | The AVP for Finance is told on day 5 |
| Internal dates, July filing | Preparer July 20 · reviewer July 24 · certifying official July 29 | The January filing uses the same offsets |
| Foreign currency | US dollars credited on receipt | Or the rate on the agreement date |
| Individual donors and bank accounts | Masked; last four digits only | Every view of a donor or contract record logged |
| Filing packages | Kept 7 years after filing | Legal hold extends it; deletion needs the AVP for Finance |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
Sources: 20 U.S.C. 1011f (Higher Education Act, section 117) · U.S. Department of Education, new Section 117 reporting portal live January 2, 2026 · HLC: 23 compliance reviews opened since 2019, Executive Order 14282 (April 23, 2025), the 2020 notice placing Section 117 in the Program Participation Agreement · Hunton, on the new portal · CRS IF12927 (March 25, 2026), on the DETERRENT Act, H.R. 1048 · "target" = design goal, measured in the live solution · "demo" = seen in the working solution, on its sample data · "typical" = published figures · "estimated" = our arithmetic. Halden State University and the people and organizations named on this page are fictional: characters and sample data in the working solution.
Section 117 Foreign Gift Reporting is a solution for Section 117 reporting: seven agents find gifts and contracts from foreign sources across the advancement CRM, ERP receivables, the grants system and contracts management, total each source by calendar year against $250,000, and draft the report in the federal portal's fields with every line threaded to its agreement, record and cash. The Compliance Officer decides, the AVP for Finance reviews, and the Vice President for Finance and Administration certifies.
Section 117 of the Higher Education Act, 20 U.S.C. 1011f, requires a college to report gifts from and contracts with a foreign source worth $250,000 or more, alone or combined, in a calendar year. A person's country is their citizenship or principal residence, and an entity's is its incorporation or principal place of business. For a restricted or conditional gift or contract, the report gives the amount, the date and a description of the conditions.
$250,000 per foreign source in a calendar year, gifts and contracts together, with reports due January 31 and July 31. The threshold is a read-only setting taken from the statute, and the solution watches sources from $200,000, forecasting pledges toward the line. The DETERRENT Act, which passed the House, would lower it to $50,000; it awaits the Senate.
Section 117 names four kinds of condition: the employment, assignment or termination of faculty; the establishment of departments, centers, research or lecture programs, or new faculty positions; the selection or admission of students; and aid restricted to students of a specified country, religion, sex, ethnic origin or political opinion. The Terms agent quotes the agreement's clause beside the matching kind and drafts the description, and a person confirms, edits or overrules it.
Yes. The Report agent builds the report in the portal's fields and a bulk upload file, watermarked "not certified" until the certifying official signs. Only then is it uploaded, and amendments to filed reports go with it.
No. The agents read the CRM, ERP, grants system and contracts management and never write to them. They propose joins, terms and amounts, never settle a disagreement between two counts, and never file.
Yes. The Compliance Officer approves every new line and every decision, the AVP for Finance approves every change she makes, and the certifying official signs only when six conditions pass, with the 18 U.S.C. 1001 statement in front of her. Overrides carry a reason code, and the rules themselves are versioned settings.
The Agentic Solution Engine builds and deploys it from your requirements and documents, such as your Section 117 procedures, exports from your systems and a past filing, and it goes live once every quality gate has passed. We will walk you through it on your own gifts and contracts first.
Every federally funded buy documented the day it is requested, with its proof.
1-min demoSingle Audit PreparationRepeat findings caught two months before fieldwork, each with a signed plan.
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1-min demoWe'll run Section 117 Foreign Gift Reporting on a sample of your own gifts, contracts and last filing.