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3` all schools listed in the OCD . Diocesan or school officials should insure that the requirements of Rev. Proc. 75-50 are met since failure to do so could jeopardize the exempt status of the school and, in the case of a school operated by a church, the exempt status of the church itself. 9 . Lobbying Activities . Organizations included in the OCD may lobby for changes in the law, provided such lobbying is not more than an insubstantial part of their total activities . Attempts to influence legislation both directly and through grassroots lobbying are subject to this restriction . The term "lobbying" includes activities in support of or in opposition to referenda , constitutional amendments , and similar ballot initiatives : There is no distinction between lobbying activity that is related to an organization's exempt purposes and lobbying that isnot. There is no fixed percentage that constitutes a safe harbor for "insubstantial " lobbying . Please refer to your attorney any questions you may have about permissible lobbying activities . 1p . Political Activities . Organizat'ons included in the Group Ruling may not participate or intervene in any political campaign on behalf of or in opposition to any candidate for public office. Violation of the prohibition against political activity can jeopardize the organization 's tax-exemptstatus. In addition to revoking exempt status , IRS may also impose excise taxes on an exempt organization and its managers on account of Political expenditures. Where there has been a flagrant violation , IRS has authority to seek an injunction against the exempt organization and immediate assessment of taxes due. If you have any questions in this regard , please refer them to your attorney. (See OGC Memo dated February 29 , 2000 , which is available at www. usccb. org/ogc . ) 11 . Public Charity Status . The latest Group Ruling affirms that organizations included in the OCD are not private foundations under section 509(a) of the Code. However, the Group Ruling does not identify the subsection of section 509(a) under which a particular organization is classified as a public charity. Organizations must determine for themselves whether they qualify for such status under the provisions of section 509(a)( 1 ), (a)(2) or (a)(3). Newly-created or newly-affiliated organizations must establish that they are not private foundations as a condition of inclusion in the Group Ruling and OCD. 12 . Group Exemption Number. The group exemption number assigned to USCC is 928 or 0928 . This number must be included on each Form 990, Form 990-T, and Form 5578 required to be riled by any organization exempt under the Group Ruling,151 We recommend against using the group exemption number on Form SS4, Request for Employer Identification Number, because in the past this has resulted in IRS including USCCB as part of the organization's name when it enters the organization in its database. If you have questions concerning the Group Ruling or this memorandum , please contact Deirdre Dessingue at 202-541 -3300 or by e-mail at ddessingue@usccb. org. 15 IRS has expressed concern about organizations covered under the Group Ruling that fail to include the group exemption number, 0928, on their Form 990 filings, particularly the initial riling. -5-