Public Law 95-507, in conjunction with IRS codes 26 U.S. Code §38, §41 (Research), and §46 (Investment Credit), is executed via the SMaRTi system’s Optimized Standard Schema Digital Invoice Format (O-DIF).
- The framework applies a robust compliance structure across CFR, Treasury, and Federal Reserve regulations to transform QREs from invoices into immediate, defensible tax credit liquidity.
- The process is designed to achieve zero tax liability and real-time liquidity, with every step legally traceable and machine-auditable.
- Public Law 95-507 mandates pre-certification of contract spending with small and disadvantaged businesses through DUNS/UEI validation.
- The SMaRTi system utilizes invoice metadata as legal proof and as the basis for future liquidity and credit conversion.
26 U.S. Code §38 (General Business Credit) and §41 (Research Credit)
- Require invoices to explicitly break out QREs—wages, supplies, contract research—itemized and validated at the invoice level.
- §46 provides rules for applying investment credit formulas to QRE-tagged line items, so each compliant invoice creates dollar-for-dollar credits that reduce tax liability instantly instead of relying on deferred reconciliation.
Precision Mapping to Compliance Workflow
Pre-Validation and Flagging
- 2 CFR Part 25: DUNS/UEI pre-validation in SMaRTi triggers integrity checks within 24 hours.
- QRE line items are auto-flagged for “instant credit conversion” at the invoice entry point.
- No further processing occurs for non-compliant entities. Metadata and digital signatures seal the audit trail.
Subaward/Reporting and Liquidity Triggers
- 2 CFR Part 170: Subaward payments over $25K are reported in DUNS-tagged XML, allowing same-day liquidity effect once reported.
- The XML output is integrated with transactional banking instructions to release funds immediately upon regulatory clearance.
Payment Holds, Exclusion Checks, and Audit Controls
- 2 CFR Part 180: Any DUNS/LEI-flagged exclusion enforces a 5-day payment hold and blocks liquidity for non-compliant parties.
- 2 CFR § 200.334: Noncompliance flags trigger a 90-day credit suspension, safeguarding QRE liquidity integrity.
Financial Management, Drawdown, and Real-Time Disbursement
- 2 CFR § 200.302: Drawdowns are only processed for DUNS-validated invoices; QRE credits are disbursed within 15 days of submission.
- 2 CFR § 200.305: Cost-sharing and matching rules tag R&D line items for immediate credit issuance through smart ledgering at time of invoice.
Income Events and Insurance Controls
- 2 CFR § 200.307: Program income must be invoiced within 60 days to qualify for QRE credit conversion.
- 2 CFR § 200.310: Policy certificates linked to DUNS must be uploaded before invoices are accepted.
Liquidity, Settlement, and Banking Controls
Bank Eligibility and Fedwire/ACH
- 12 CFR Part 9: SMaRTi-issued QRE credits are recognized as eligible liquidity under bank risk rules, classified as High-Quality Liquid Assets (HQLA) for liquidity coverage ratio (LCR) compliance.
- 12 CFR Parts 204, 229, 227, 307, 360: Mandate exact timing for settlements—Fedwire for same-day, ACH for T+1.
- All transfers must carry LEI/DUNS metadata for regulatory traceability.
Treasury and Repo Facilities
- 31 CFR Parts 203, 205, 356: QRE credits can be repo-financed, participate in Treasury auctions, and be reconciled for cash flow assurance.
- Overnight repo enables short-term liquidity, and daily reconciliation ensures visibility.
Banking, Prepaid Accounts, and IRS Settlement
- 12 CFR Part 370: QRE credits are treated as available funds for immediate redemption upon settlement.
- 31 CFR 351, 355, 357, 358: Credit disbursements can offset federal debts, be invested overnight, held as securities, or routed into government revenue accounts.
Contractor Invoicing, Payment, and Interest
- 48 CFR § 32.903-909: All invoices must retain DUNS/LEI and timestamp metadata for 3 years; fund reservation is automatic when invoices pass LEI validation.
- Automated credit issuance occurs at day 16 if no rejection is logged, and interest for late payments is calculated and credited in real time.
- 52.232-34, 52.216-18: EFT payments use LEI-encoded identifiers ensuring no delay; QRE triggers are embedded in purchase orders to convert shipped R&D immediately.
Securities and Regulatory Controls
- 17 CFR § 240.15c3-3, 240.17Ad-22, 242.612: Brokerage firms can count QRE credits as liquid assets for capital calculations.
- Every invoice’s metadata is stored with nanosecond precision, ensuring audit symmetry for transaction reporting and clearing.
- 21 CFR Part 11: Electronic invoices are hardened with layered e-signature and immutable audit controls, binding each transaction to its legal and regulatory record.
Environmental and Permit Fee Integration
- 40 CFR Part 60, Part 70: Fee and permit invoices tied to DUNS must be paid on regulated schedules, with QRE credits offsetting cash due.
- SMaRTi automatically converts and applies credits upon approval.
Outcome in O-DIF Format
Every original invoice processed via The Ford Enterprises Group, LLC's SMaRTi system passes through the O-DIF logic:
- Itemized, digitally signed QRE line items (with DUNS/LEI)
- Automated regulatory validation for every compliance domain
- Direct conversion of QRE values into dollar-for-dollar tax credit liquidity
- Bank, Treasury, and IRS approval through instant machine schema validation and audit-proof records
- Same-day or next-day liquidity delivered to the beneficiary
Bullet-Proof Compliance Features
Legal Precedent:
- Public Law 95-507 and all referenced statutes are directly embedded in both the invoice data structure and the system workflow.
Real-Time Audit Trail:
- Nanosecond timestamps, digital signatures, and retention, fulfilling CFR/SEC/FAR audit requirements.
Liquidity and Tax Neutrality:
- Credits offset tax liability and are recognized by banks as eligible liquidity under OCC and Basel standards.
Systemic Defensibility:
- All conversions, holds, releases, and transfers are strictly gated by machine-verified regulatory constraints.
Summary:
The SMaRTi O-DIF process transforms each legally compliant invoice into a tax-credit-bearing liquidity instrument, defensible from invoice origination through IRS audit and Treasury settlement, with every step mapped to CFR, FAR, and financial regulatory obligations

