project

Regulation of Nonprofits and Philanthropy Project

Overview

The Regulation of Nonprofits and Philanthropy Project conducts research on the regulatory frameworks that govern the nonprofit sector with the goals of (1) systematically documenting current regulations across states, (2) developing research tools to access those regulations and promote research through the nonprofit Legal Compendium, (3) conducting research on regulation of nonprofits and philanthropy to deepen our understanding of how policies impact nonprofits, and (4) promoting the diffusion of research and best practices through publications and convenings.


Project Contributors
Portrait of Elizabeth

Elizabeth Boris

Institute Fellow

Urban Institute

Portrait of Teresa

Teresa Harrison

Professor

Drexel University

Portrait of Jesse

Jesse Lecy

Associate Professor, Data Scientist

ASU / Urban Institute

Portrait of Cindy

Cindy Lott

Clinical Professor of Philanthropic Studies

Indiana University




Highlighted Resources


Report Lott, Cindy M., Nathan Dietz, and Marcus Gaddy. State Regulation and Enforcement in the Charitable Sector. Washington, DC: Urban Institute, 2016.
Research Brief Lott, Cindy M., Nathan Dietz, and Marcus Gaddy. “Bifurcation of State Regulation of Charities.” Washington, DC: Urban Institute, 2018.
Research Brief Adelstein, Shirley, and Elizabeth T. Boris. “State Regulation of the Charitable Sector: Enforcement, Outreach, Structure, and Staffing.” Washington, DC: Urban Institute, 2018.
Journal Article Pettijohn, Sarah L., and Elizabeth T. Boris. “Testing Nonprofit State Culture: Its Impact on the Health of the Nonprofit Sector.” Nonprofit Policy Forum 9, no. 3 (2018). https://doi.org/10.1515/npf-2018-0012.
Journal Article Lott, Cindy M., Mary L. Shelly, Nathan Dietz, and George E. Mitchell. “The Regulatory Breadth Index: A New Tool for the Measurement and Comparison of State-Level Charity Regulation in the United States,” Nonprofit Management and Leadership 33, no. 3 (2022): 633–45. https://doi.org/10.1002/nml.21536.
Open Dataset Charity Regulatory Breadth Index
Dataset Legal Compendium - Version 3.0



Background and Support

This project brings together cross-disciplinary groups of scholars and experts to document and understand how regulation affects nonprofit organizations and philanthropy through empirical research. This work is a partnership of the Center on Nonprofits and Philanthropy and its National Center for Charitable Statistics (NCCS) at the Urban Institute, and the Lilly Family School of Philanthropy at Indiana University, with support from the Mott Foundation.

Project Advisors:

Project History

The Center on Nonprofits and Philanthropy at the Urban Institute and Columbia University’s Charities Regulatory and Oversight Project joined forces in 2015 to create and colead the Regulation of Nonprofits and Philanthropy Project at the Urban Institute with funding by the Mott Foundation. Both entities promoted research and knowledge sharing and had programs that brought together charities officials to discuss issues affecting the nonprofit sector.

Shortly after its founding by Elizabeth Boris in 1996, the Center on Nonprofits and Philanthropy (CNP) and its flagship program, the National Center for Charitable Statistics (NCCS), began to host twice-yearly meetings with state charities officials and Internal Revenue Service officials, primarily to discuss data and reporting issues on Form 990 affecting the nonprofit sector. These sessions were augmented by Emerging Issues Seminars on a variety of policy issues facing the nonprofit sector that were cohosted by CNP and the Hauser Center for Nonprofit Organizations at Harvard University.

Inaugurated with the first conference to convene state attorneys general, foundations, and nonprofit leaders, in 2006 Columbia University launched the Charities Regulatory and Oversight Project as part of the National State Attorney’s General Program. The conference and project were at the time supported by the Ford Foundation, C.S. Mott Foundation, New York Community Trust, and the Surdna Foundation. Hosting regular meetings and trainings for state charities officials, the project developed conferences with state and federal regulators, practitioners, and academics in attendance. In 2013, the project hosted a major research conference on the future of state charities regulation; those papers can be found here.

Cindy M. Lott, founder and director of the Columbia University project within the National State Attorneys General Program, initiated a research collaboration with CNP led by Boris to conduct a groundbreaking study of state charity offices, resulting in the report State Regulation and Enforcement in the Charitable Sector.

Timeline


  • 2025
    Legal compendium expanded with legal text of statutes provided by Teresa Harrison (Drexel University), with assistance from Jesse Lecy (Arizona State University) and NCCS.
  • 2025
    Digitized legal compendium published.
  • 2024
    Legal compendium updated to version 3.0.
  • 2024
    Symposium: "The Future of Nonprofit Regulation in the United States."
    • Papers prepared for the symposium will be available in a special issue of Nonprofit Policy Forum in early 2026.
    • Individual papers are listed under Select Publications below.
  • 2021
    Symposium: "Data and Technology: Resources and Implications for Nonprofit Regulation and Oversight."
  • 2019
    Legal compendium updated (version 2).
  • 2016
    Symposium: "State Regulation and Enforcement in the Charitable Sector."
  • 2016
    "Legal Compendium to the Regulation of Nonprofits and Philanthropy Project" created and published.
  • 2015
    Symposium: "Data Collection, Sharing, and Transparency in the Tax-Exempt Sector."
  • 2015
    Regulation of Nonprofits and Philanthropy Project launched at the Urban Institute under the leadership of Elizabeth T. Boris (Urban Institute) and Cindy M. Lott (Columbia University).

Phase One

The first phase of the research focused on the jurisdiction of state attorneys’ general over the charitable sector but expanded the scope to encompass the entire regulatory framework of the charitable sector, including all state and federal charities officials and jurisdiction.

A comprehensive survey was fielded to state charity officials about their activities and identified research gaps, reported in State Regulation and Enforcement in the Charitable Sector by Cindy M. Lott, Elizabeth T. Boris, and coauthors. With the data from the study serving as the foundation, the project hosted a symposium, “State Regulation and Enforcement in the Charitable Sector,” that resulted in reports, articles, and a regulatory conference organized in collaboration with the Federal Trade Commission.

Phase Two

In the second phase of the project, parts of the legal compendium were updated and research included two briefs, "Bifurcation of State Regulation of Charities: Divided Regulatory Authority Over Charities and Its Impact on Charitable Solicitation Laws," and "State Regulation of the Charitable Sector: Enforcement, Outreach, Structure, and Staffing." Research was presented at major sector, regulatory, and legal education venues, and the work was also disseminated through blog posts.

Phase Three

In the third phase, the project held a symposium, “The Future of Regulation in the United States,” with research papers presented by scholars and practitioners that are available online at the journal Nonprofit Policy Forum. Those papers will be published in a special issue of the journal in early 2026. Questions about nonprofit regulation were added to Urban’s National Survey of Nonprofit Trends and Impacts to learn about interactions between nonprofits and government and the impact of regulations on nonprofit organizations. Those findings were first reported in a 2025 brief, “Nonprofits’ Contact with Offices or Agencies That Regulate Charities, 2024.”

In addition, the legal compendium is being expanded by Teresa Harrison (Drexel University) with digital text of the statutes affecting nonprofits. The expanded compendium will be available in early 2026 and will enable more detailed research on regulatory issues.

The Database

The legal compendium was created as a downloadable Excel spreadsheet with statutory citations showing the following information for each of the 56 jurisdictions featured in this research: the grant of jurisdiction to attorneys general and other state agencies, the registration and reporting requirements applicable to charitable entities and their fundraisers, the oversight responsibilities of state charity regulators in connection with certain transactions involving charitable entities, the obligations of charities to notify the attorney general of those transactions, and some enforcement remedies available to charity regulators.

In the current phase, the Legal Compendium has been updated with the most current data available and is being enhanced with digital text data that will be available in late 2025.

An interactive version of the compendium can be accessed via the link below. Users can explore the compendium by grouping, filtering, and sorting the records. It comes prepopulated with a record of all nonprofit regulations grouped by state. Instructions are as follows:

Digitized Legal Compendium Legal Compendium Version 3.0 - Source Data Research Guide and Data Dictionary
Citing the Database

Cindy M. Lott, Elizabeth T. Boris, Karin Kunstler Goldman, Belinda Johns, Marcus Gaddy and Maura R. Farrell, "Legal Compendium to the Regulation of Nonprofits and Philanthropy Project," National Center of Charitable Statistics, Urban Institute, https://nccs.urban.org/nccs/resources/regulation-of-np-sector/."



Events


2024: The Future of Nonprofit Regulation in the United States

This two-day hybrid symposium featured 21 presentations of papers written for the meeting on topics including the first amendment and political activities, civic engagement, improving regulatory structures, global perspectives, and commentaries on the future of regulation. These papers were peer reviewed and edited for inclusion in a special issue of Nonprofit Policy Forum available in early 2026. The agenda for the symposium is available here. Papers are listed under Select Publications below.

2021: Data and Technology: Resources and Implications for Nonprofit Regulation and Oversight

This event focused on data and technologies state and federal charities regulators need to succeed in their oversight roles. Researchers, leaders from data-providing organizations, and state and federal charities regulators explored how to promote data-informed nonprofit regulation.

2019: What We Know; What We Need to Know and the Future of Nonprofit Regulation


2016: State Regulation and Enforcement in the Charitable Sector

In this symposium, participants discussed State Regulation and Enforcement in the Charitable Sector, a report that provided a primer and road map on the state regulatory structures that oversee the charitable and nonprofit sector, toward the goal of more effective and efficient charity regulation. Topics included a summary and discussion of the report findings, the status of state charitable regulatory and enforcement activity, and next steps in formulating a research agenda.

2015: Data Collection, Sharing, and Transparency in the Tax-Exempt Sector

The goals of this convening were to discuss the ripple effects of regulatory changes regarding data collection, sharing, and transparency; discuss opportunities and challenges in the nonprofit sector resulting from these challenges; and explore inefficiencies and redundancies in data transfer that might be eliminated in the future among the sector’s stakeholders.


Select Publications


Framework Development

Lott, Cindy M., and Marion Fremont Smith. “State Regulatory and Legal Framework.” In Nonprofits and Government: Collaboration and Conflict, edited by Elizabeth T. Boris and C. Eugene Steuerle, 163–90. Lanham, MD: Rowman & Littlefield, 2017.

Boris, Elizabeth T., and Cindy M. Lott. “Reflections on Challenged Regulators.” In Regulating Charities: The Inside Story, edited by Myles McGregor Lowndes and Bob Wyatt, chapter 6. New York: Routledge, 2017. https://doi.org/10.4324/9781315563923-6.

Lott, Cindy M., ed. Conference Papers for The Future of State Charities Regulation: Charities Regulation and Oversight. Columbia Law School: National State Attorneys General Program, 2013.

Lott, Cindy M., Elizabeth T. Boris, Karin Kunstler Goldman, Belinda J. Johns, Marcus Gaddy, and Maura Farrell. State Regulation and Enforcement in the Charitable Sector. Research Report. Washington, DC: Urban Institute, September 2016.


Applications of the Framework and Related Research

Martin, Hannah, Elizabeth T. Boris, Katie Fallon, and Cindy M. Lott. 2025. Nonprofits’ Contact with Officers or Agencies That Regulate Charities, 2024. Washington, DC: Urban Institute.

Bushouse, B. K., C. M. Schweik, S. Siddiki, D. Rice, and I. Wolfson. 2023. “The Institutional Grammar: A Method for Coding Institutions and Its Potential for Advancing Third Sector Research.” Voluntas 34 (1): 76–83. https://doi.org/10.1007/s11266-021-00423-w

Mitchell, George E. 2023. “Three Models of US State-Level Charity Regulation.” Nonprofit Policy Forum 15 (1): 1–25. https://doi.org/10.1515/npf-2022-0051.

Lott, C. M., M. L. Shelly, N. Dietz, and G. E. Mitchell. 2023. “The Regulatory Breadth Index: A New Tool for the Measurement and Comparison of State-Level Charity Regulation in the United States.” Nonprofit Management and Leadership 33 (3): 633–45. https://onlinelibrary.wiley.com/doi/full/10.1002/nml.21536.

Lott, Cindy M., Mary Shelly, and Nathan Dietz. 2019. Regulatory Breadth Index: A New Measurement of State-Level Charity Regulation. Presentation.

Lott, Cindy M., Mary L. Shelly, Nathan Dietz, and Marcus Gaddy. 2018. Bifurcation of State Regulation of Charities: Divided Regulatory Authority Over Charities and Its Impact on Charitable Solicitation Laws. Washington, DC: Urban Institute. https://www.urban.org/research/publication/bifurcationstate-regulation-charities.

Adelstein, Shirley, and Elizabeth T. Boris. 2018. State Regulation of the Charitable Sector: Enforcement, Outreach, Structure, and Staffing. Washington, DC: Urban Institute. https://www.urban.org/research/publication/state-regulation-charitable-sector.

Adelstein, Shirley, and Elizabeth T. Boris. 2018. “Why Do Some States Enforce Charity Regulations More than Others?” Urban Wire, June 18, 2018. https://www.urban.org/urban-wire/why-do-some-states-enforce-charityregulations-more-others.

Pettijohn, Sarah L., and Elizabeth T. Boris. 2018. “Testing Nonprofit State Culture: Its Impact on the Health of the Nonprofit Sector.” Nonprofit Policy Forum 9 (3): 20180012.

Dietz, Nathan, Cindy M. Lott, Putnam Barber, and Mary Shelly. 2017. “State Charitable Solicitations Registration Regulations and Fundraising Performance: Theoretical Considerations and Preliminary Results.” Nonprofit Policy Forum 8 (2): 183–204.

Dietz, Nathan, Putnam Barber, Cindy M. Lott, and Mary Shelly. 2017. Exploring the Relationship between State Charitable Solicitation Regulations and Fundraising Performance. https://www.degruyterbrill.com/document/doi/10.1515/npf-2017-0009/html?srsltid=AfmBOoqsOEKxCwRYxgMwvT34yvHhfRx5tpLjTkgBnUIA32hJbgjNENEp

Lott, Cindy M., and Marion Fremont-Smith. 2017. “State Regulatory and Legal Framework.” In Nonprofits and Government: Collaboration and Conflict, edited by Elizabeth T. Boris and C. Eugene Steuerle, 163–90. 3rd ed. Maryland: Rowman & Littlefield.

Lott, Cindy M., Elizabeth T. Boris, Karin Kunstler Goldman, Belinda Johns, Marcus Gaddy, and Maura R. Farrell. 2016. State Regulation and Enforcement in the Charitable Sector. Washington, DC: Urban Institute.


The Future of Nonprofit Regulation in the United States

The papers from this 2024 symposium will be published in a special issue of Nonprofit Policy Forum in early 2026.


I. First Amendment and Political Activity

Faulk, Lewis, Mirae Kim, and Heather MacIndoe. “Bounded Rationality: The Role of Knowledge of Regulations in Nonprofits’ Engagement in Policy Advocacy.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0044.

Gazley, Beth, and Jennifer Alexander. “Authoritarianism in US State Policy and Its Impact on Nonprofit Civil Liberties.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0022.

II. Civic Engagement

Aprill, Ellen P., and Jill R. Horwitz. “Fiduciaries, Constituencies, and the Duty of Loyalty in Modern Nonprofits.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0036.

Flannery, Helen, and Brian Mittendorf. “Are Donor-Advised Funds Facilitating Opaque Giving to Politically Engaged Charities?” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0028.

Murray, Ian, Dan Heist, and Kendra Stone. “Donor Advised Fund Policies and Intergenerational Justice.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0024.

III. Improving Regulatory Structures

Atkins, Lynda, Karin Kunstler Goldman, Jonathan Green, Brien Winfield Heckman, Janet M. Kleinfelter, Hanna Rubin, Beth Short, Tracy Thorleifson, Heather L. Weigler, and Josaphine Yuzuik. “Charitable Oversight: Insight from Regulators and Enforcers.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0029.

Gano, Karen, and Karl Emerson. “Toward the Ideal of Uniformity, Transparency and Efficiency in State Regulation of Charitable Activity in the United States.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0042.

IV. Global Perspectives

Lackritz-Peltier, Martha Bird. “Furthering Unrestricted Grantmaking Across Borders: Proposals for Updated Tax Law Guidance.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0037.

Tyler, John. “Regulation and Incentives for ‘Social Enterprise’ in the United States: But First Greater and More Substantive Differentiation.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0026.

Gugerty, Mary Kay, and George Mitchell. “Can Nongovernmental Regulation Resolve NGO Trust Deficits? Policy Considerations for the United States.” Nonprofit Policy Forum, 2026. https://doi.org/10.1515/npf-2024-0052.

V. Data and Research Tools

Harrison, Teresa, and Jesse Lecy. “Advancing an Understanding of the Regulatory Environments in Which Nonprofits Operate through the Creation and Digitization of an Open-Source Legal Compendium of Nonprofit Law.” Nonprofit Policy Forum, 2026.

Bushouse, Brenda K., Santiago Virgüez-Ruiz, Mahasweta Chakraborti, and Seth Frey. “Advancing Text Analysis for Nonprofit Research: Using Semantic Role Labeling to Automate Institutional Grammar Coding of Nonprofit Laws and Policies.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0048.

VI. Commentary

Mayer, Lloyd Hitoshi. “The Future of Nonprofit Regulation in the United States: Three Dynamic Trends.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0034.

Owens, Marcus S. “Lessons from the Unintentional Fifty-Year Longitudinal Study: The Nonprofit Regulatory Structure in the US.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2025-0017.

Schmidt, Elizabeth. “Designing a Legal Framework to Encourage Nonprofit Success.” Nonprofit Policy Forum, 2025. https://doi.org/10.1515/npf-2024-0038.


Charity Regulation and Oversight Conference: February 26, 2013

Lott, Cindy M., Ed., Conference Papers for The Future of State Charities Regulation, Charities Regulation and Oversight Project, National State Attorneys General Program. Published online, Columbia University’s Academic Commons, New York.

Marcus S. Owens (2013): "Charity Oversight: An Alternative Approach." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8154F1D

Marion R. Fremont-Smith (2013): "The Future of State Regulation of Charities." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D82R3PQ2

Douglas M. Mancino (2013): "The Affordable Care Act and State Charities Regulators." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8J38QG1

Mark E. Chopko (2013): "Some Thoughts About Regulating Religious Charity." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8DB7ZSR

Mary Beckman, Eric Carriker (2013): "State Charities Regulation In A Dynamic Health Care Market." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8ZC80T9

Rick Cohen (2013): "A New Ethic of Transparency in Charities: The Shared Goal of Journalists and State Regulators." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8WD3XJQ

George Jepsen (2013): "The Role of State Charities Regulators in Protecting Public Trust in Charitable Responses to Disaster." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8251G5S

Linda Sugin (2013): "Improving Charity Governance with Advance Rulings." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8MW2F32

Putnam Barber (2013): "The Official Word: What State Charities Webpages Tell The Public." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8348H9M

Dana Brakman Reiser (2013): "Regulating Social Enterprise." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8TM7830

Karin Kunstler-Goldman; Belinda Johns (2013): "Evolving State Regulation: From Index Cards To The Internet." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8NV9G6F

WIlliam P. Marshall (2013): "Government Regulation of Religious Organizations: The Example of Religious Fraud." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D88P5XGR

Robert A. Wexler (2013): "Attorney General Regulation of Hybrid Entities as Charitable Trusts." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8Z03661

Hugh R. Jones (2013): "The Importance of Transparency in the Governmental Regulation of the Nonprofit Sector: Room for Improvement?" The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D86H4FG7

Frances R. Hill (2013): "Exempt Entities as Government Contractors: Regulation Through Cooperative Federalism." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8FB50W2

Lloyd Hitoshi Mayer (2013): "Limits On State Regulation Of Religious Organizations: Where We Are And Where We Are Going." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D84X55SV

David Edward Spenard (2013): "Crashing The Party: A State Regulator’s Observations and Suggestions Regarding The Near-Term Supervision of The Simultaneous Pursuit of Margin And Mission." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8RN35TC

James J. Fishman (2013): "Strange Silence: Attorneys General Reaction to The Internal Revenue Service’s Corporate Governance Initiative." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8K35RMD

Tim Delaney (2013): "Advocacy by Charitable Nonprofits: Flipping The Accountability Lens To Focus On Government Actions." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8PV6HBT

Scott Harshbarger (2013): "The Case For A Renewal Of Civic Capitalism In The Independent Sector." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D85X26WS

James J. Fishman (2013): "Strange Silence: Attorneys General Reaction to The Internal Revenue Service’s Corporate Governance Initiative." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8K35RMD

Scott Harshbarger (2013): "The Case For A Renewal Of Civic Capitalism In The Independent Sector." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D85X26WS

Elizabeth M. Grant (2013): "Hybrid Enterprises and the Application of State Charitable Regulatory Principles as a Guide Toward an Effective Regulatory Framework." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8SN06X9

Anthony Johnstone (2013): "Politics and The Public Benefit Corporation." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D8XD0ZNN

Karen Gano (2013): "The Fundamental Role of The States In Governance Issues." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D89K4866

Robert Cooper (2013): "Deaccessioning and Donor Intent – Lessons Learned from Fisk’s Stieglitz Collection." The Future of State Charities Regulation Conference, Columbia University Law School, NY. DOI: https://doi.org/10.7916/D86T0JMV




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