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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 is not . 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 . 10. Political Activities . Organizations 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 taxwexempt status. 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. Political Campaign Activity Guidance for Catholic Organizations (March 15, 2004) available at www. usccb.orglogc, contains detailed information regarding the political activity prohibition . If you have any questions in this regard , please refer them to your attorney. 11 . Public Charity Status . The latest Group Ruling affirms that organizations included in the OCD are net private foundations under section 509(a ) of the Code . However, the Group Ruling does not identity the subsection of section 509(x) 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 USCG is 928 or 0928 . This number must be included on each Form 990, , Form 990- T, and Form 5578 required to be filed by any organization exempt under the Group Ruling. ' We recommend against using the group exemption number on Form SSA 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 . 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, partkularly the initial filing, 5