RIRA’s Return: Transparency Amid a Fog of Exceptions
RIRA followed the process—but the system that allowed it remains unclear, unequal, and overdue for reform.
The rules weren’t vague. They weren’t unwritten. They weren’t hidden in fine print. They were clear: to receive a Public Purpose Fund grant administered by the New York Community Trust, your organization must be a 501(c)(3) public charity. Not a lobbying group. Not a neighborhood association. Not a 501(c)(4).
And yet, in 2025, the Roosevelt Island Residents Association (RIRA) received a $10,000 grant.
One Rule for All, One Technical Pass
The Public Purpose Fund’s rules exist for a reason: to prevent public money from flowing to organizations engaged in lobbying or political activity. That’s why only 501(c)(3) charities—or entities fiscally sponsored by one—are eligible.
RIRA is not a 501(c)(3). It’s a 501(c)(4)—a classification that allows for advocacy, political organizing, and lobbying. The distinction isn’t minor; it’s foundational. That’s why the only permissible workaround is fiscal sponsorship: when a verified 501(c)(3) assumes legal and financial responsibility for the project.
RIRA President Frank Farance confirmed that RIRA used such a sponsor—RISA/Good Life, and that the process was disclosed to NYCT. He answered when others didn’t. That kind of transparency is a welcome departure from the norm and should be commended.
But the deeper question remains unanswered: Is this a workaround that preserved accountability—or sidestepped it? If RISA is the fiscal sponsor, then RISA—not RIRA—is the legal recipient. That means RISA’s total grant allocation this year may be significantly higher than reported. It also means that an organization with a felony fraud history may be quietly responsible for overseeing funds directed at others.
We can’t say for certain, because NYCT won’t clarify, and RISA has not responded. The structure may be technically compliant—but it fails the spirit of the law. And without public oversight, technical compliance isn’t enough.
In a funding cycle defined by silence, Farance's transparency stood out.
From Allocator to Applicant
RIRA once helped decide who received Public Purpose Fund grants. That role ended in 2022, when NYCT took over. In 2025, RIRA returned—not as a decision-maker, but as a recipient.
The IRS lists RIRA as a 501(c)(4), with its last detailed financial disclosure filed in 2015. From 2016 through 2023, it submitted only short-form filings. In 2024, leadership changed, with Frank Farance now serving as president.
Frank has taken on the challenge of reviving an organization that, after years of decline, risks becoming irrelevant. His bid to secure PPF funding was part of a broader attempt to reinvigorate RIRA's community impact.
The CERT Connection and a Familiar Name
The grant’s stated purpose was to develop a Community Emergency Response Team (CERT) on Roosevelt Island—an initiative led by RIRA and spearheaded by Howard Polivy, a current RIOC board member. Polivy’s official RIOC bio confirms his role as CERT chief and past RIRA representative.
“Mr. Polivy has a history of civic activism. He presently is Chief of the Roosevelt Island Community Emergency Response Team (CERT) and a trustee of his local congregation. He has served the Roosevelt Island Residents Association (RIRA) as an alternate representative for his building and prior to coming to Roosevelt Island had been a coop board president.”
There’s no allegation of wrongdoing. But when a sitting board member is connected to both the applying organization and the funded project, the need for transparency becomes more pronounced.
Sources have suggested that Mr. Polivy’s wife may be involved in RISA, the fiscal sponsor used by RIRA. We have not been able to verify this information, nor have we received a response from Mr. Polivy himself. These unconfirmed reports raise further questions—especially given RISA’s expanded role this grant cycle and its troubling history. As of publication, Mr. Polivy has not updated his official RIOC biography to reflect any current involvement with RISA, CERT, or RIRA beyond what was previously listed.
In a system where personal affiliations and public funding can intertwine, transparency isn’t just preferred—it’s necessary.
Fiscal Sponsorship and the Missing Standards
RIRA applied through RISA/Good Life, a 501(c)(3) fiscal sponsor. Fiscal sponsorship is a legitimate pathway used by some nonprofits, though it is relatively rare. When done correctly, it provides a legal framework for projects that lack their own 501(c)(3) status to receive funding under the oversight of an established public charity.
A clear example of this model working properly is iDig2Learn, a long-time Public Purpose Fund recipient. iDig2Learn is not a standalone legal entity—it operates as a project under the Open Space Institute (OSI), a registered 501(c)(3). In that case, OSI assumes legal and financial responsibility, provides oversight, and ensures accountability for the use of public funds.
That is not the case here—at least not transparently. While RIRA, to its credit, responded when questioned, its sponsor—RISA—has remained silent. In a follow-up, Farance explained that the funds were distributed to RISA, which in turn disburses them to RIRA. He described the fiscal sponsor’s role as ensuring the funds are used as intended, with RIRA providing documentation and close-out reporting—effectively mirroring the accounting responsibilities of a direct grantee. There is no public documentation showing that RISA has formally assumed oversight or legal responsibility for the grant.
RISA was previously implicated in a felony fraud conviction. There has been no formal acknowledgment of restitution, and yet the organization reappeared this year both as a grant recipient and as a fiscal sponsor.
Without confirmation that RISA is fulfilling its legal obligations as a sponsor, and with no public disclosures to back it up, this case risks appearing less like a sponsorship—and more like a circumvention. In that context, transparency is not just a courtesy—it’s essential to public trust.
Loopholes and Uneven Knowledge
What’s becoming clear is that certain nonprofits—those familiar with the process—identified ways to maximize their Public Purpose Fund awards by using structural workarounds.
Two strategies stand out:
Focusing on events, which are more fundable and harder to audit.
Breaking out recurring programs into discrete allocations under different names or sponsors.
This tactic appears to benefit organizations that know the system well. Instead of bundling all their community work into a single application, they diversify their ask—splitting projects into multiple line items to increase funding opportunities.
RIVAA, for example, received two separate grants totaling $40,000. Tango classes appear to have secured their own allocation, rather than being housed under an existing nonprofit. And now, with the sponsorship pathway, RIRA’s $10,000 grant arguably expands RISA’s financial reach.
Meanwhile, nonprofits not in the loop—those unaware of these tactics—submitted more traditional applications and received less. Some were denied entirely.
Whether intentional or not, the disparity points to an ecosystem where insider knowledge determines outcomes. And that, more than anything, threatens the public trust these funds are meant to uphold.
A System in Need of Reform
Public funds require public accountability. The NYS Attorney General’s Charities Bureau, the State Comptroller, and the Office of the Inspector General all have jurisdiction here. Yet when we requested clarification from NYCT, RIOC, and other involved parties, we received little more than silence. RIOC offered a non-substantive reply. The Trust declined to provide further information on several grants. Some questions remain unanswered.
RIRA, as it seems, followed the process. Yet the spirit of the rules—the intent behind excluding 501(c)(4) organizations from benefiting directly from public purpose funds—remains valid. And if, as the process requires, RISA received those funds on RIRA's behalf, that would suggest RISA received an even larger allocation than previously understood. Unfortunately, we cannot confirm this because the Trust has declined to clarify and RIOC has shielded itself behind legal counsel.
We do not expect public funding to operate smoothly without clear oversight and full transparency. And in the absence of both, it is often the most vulnerable and mission-critical nonprofits—those least positioned to game the system—that are left out. That failure harms not only the organizations, but the causes and communities they serve.
RIRA, under the leadership of Frank Farance, is clearly fighting to make a comeback. We respect that. We also respect and acknowledge his open and direct communication—an example of civic engagement that others in positions of power would do well to follow. We further appreciate that RIOC CFO Dhruvika Patel Amin advocated to increase overall allocations in a tough funding cycle.
But good intentions are not enough. The system must be rebuilt to ensure clarity, equity, and integrity. Until then, we’ll keep documenting.
So Rira,the supplicant without much clout or effective history, went to Risa to borrow some
creds in the grant dept. Risa obliged but, might have questionable parentage, shadowing the transaction. Who cares? Nobody. Why shouldn't good money just go to those who ask or simply take? Money is up for grabs and whoever has the longest arm, gets it. Just shut up and deal with it.
I read your article, and I'd like to add some history and some clarity.
- The Public Purpose monies don't necessarily go towards 501(c)(3) corporations, they go to efforts that serve the Public Purpose. This has been the case since the 1980s and through the 1990s and up to the present.
- In the 2000s RIOC clarified this (see amended Board Resolution of December 11, 2014), that both 501(c)(3) and 501(c)(4) organizations were permitted with the provision "[...] certified as tax exempt under Internal Revenue Code (IRC) section 501(c)(3) or 501(c)(4). Please note that organizations recognized under IRC section 501(c)(4) as tax-exempt social welfare organizations, may apply for PPF only if the requested funds are: (i) not intended or used for lobbying or other political activities; and (ii) are intended and used for an activity that directly relates to a power, duty or purpose of RIOC.". The RIRA PPF Grant for developing a CERT team complies with this provision. See "https://rioc.ny.gov/DocumentCenter/View/471".
- The RIRA PPF grant to develop a Community Emergency Response Team (CERT) is NOT related to NYC Emergency Management's (NYCEM) City-wide CERT program. NYCEM is the sponsor of that program, and completely independent of our work. Precisely, FEMA authorizes several kinds of CERT programs: one sponsored by local law enforcement or emergency services (like NYCEM), one for teenagers (Teen CERT) as a "feeder" program into adult CERTs, one for college campus (Campus CERT), and one for workplaces (Workplace CERT). Our CERT program is a Workplace CERT where RIRA (whose footprint and membership) includes the Island and its residents. We RIRA do not intend to deploy outside of Roosevelt Island and vicinity, and this addresses one of the reasons why the NYCEM-sponsored CERT team had withered: Roosevelt Islanders only wanted to deploy and support their own community here, not the rest of Manhattan or New York City. We had 40 people sign up for the Roosevelt Island CERT on Roosevelt Island Day.
- The original RISA had numerous problems with its executive director taking money, and many of their board went to RIDA. The RISA organization (now branded as RIRA/Good Life) has reinvented itself with new leadership and a board. I have worked with Andrea Jackson for many years, her approach to the organization is very professional and ethical, we are finalizing the formalities to make sure we've satisfied all legal and ethical obligations, and I look forward to a productive collaboration - a very different RISA than the one that existed a decade ago. Likewise, as RIRA President, I take my own responsibilities seriously, and I believe this collaboration with RISA/Good Life will be good for RIRA and our community.
- Regarding the RISA/Good Life fiscal sponsorship for RIRA, I don't believe that money should be counted towards allocating to RISA/Good Life as this money is NOT being spent on RISA/Good Life's priorities/direction, it is spent on RIRA's priorities/direction. RISA/Good Life is merely serving an administrative function to make sure the money is being spent correctly, i.e., on RIRA priorities/direction per the RIRA PPG grant application, which is why RIRA signed documents with NYCT on the grant, and RISA/Good Life is not controlling or directing this $10,000 grant, RIRA is controlling and directing this grant per our grant proposal.
- Regarding Howard Polivy, he was involved as Team Chief in the NYCEM-sponsored "MN8 RI" (Manhattan CB8 Roosevelt Island) team 2006-2019. In 2019, there was a NYCEM City-wide reorganization and Manhattan's 15-20 CERTs were reorganized into 5 divisions, Roosevelt Island was part of Manhattan Division 3, and Howard had a marginal role - and there were only 2 CERTs from Roosevelt Island who participated regularly in a Division 3's approx 50 CERTs, i.e., the Roosevelt Island team has severely withered (as explained above). Regardless, since 2004, Howard, Matt Katz (former RIRA President), and I were the three-some for years who advised on Roosevelt Island's infrastructure, services, and emergency preparedness. Howard is very very knowledgeable, I'm glad he's on the RIOC board, and Howard and I collaborate well - which is of good benefit for Roosevelt Island as I plan on working with Howard in our efforts on the Roosevelt Island CERT team. To my knowledge, Howard's wife Ellen is not involved at all - she has not been part of or referenced in ANY aspect of the RISA/Good Life and RIRA collaboration.
Regarding Public Purpose Funds and Grants, I'd like to add some precision. There were Public Purpose Payments from Manhattan Park's construction in the 1980s. In essence, rather than state taxes collected on the local construction (e.g., sales taxes), those payments would be made directly to the benefit of Roosevelt Island. At the time, it was believed that there would be more efficiency in redirecting the taxes directly - rather than collecting the state tax revenues in one big pot, and then depending upon legislators to distribute directly to Roosevelt Island (this seemed unlikely). Thus, these Public Purpose Payments (see section 3.07 in the Manhattan Park ground lease) would come directly. By the early 1990s (after Manhattan Park had been completed), there was approximately $2 million in available Public Purpose Payments. The document cited above (RIOC Board resolution) provides some history. I've been familiar with the Public Purpose fund distribution since 1996.
In the early 2000s, it appeared that the money was running out from its initial source, RIOC assigned PPF grant evaluation to RIRA in 2008, (I believe) RIOC President Steve Shane sought $100,000 annual funding to assure continuity (annual funding increased since), and Senator Serrano proposed legislation in 2015-2016 (Senate Bill S5813B), which was approved, that provided up to 3% of RIOC's annual operating budget for public purpose distribution:
"Not-For-Profit Grant Distribution. 1. The corporation is authorized to provide financial assistance in the form of grants to not-for-profit corporations or governmental agencies that provide direct services or benefits to the residents of Roosevelt Island, not to exceed 3% of the operating budget of the corporation, and upon the approval of a majority of the entire board of the corporation."
Since then there has been much griping that RIOC is not spending all of the 3% on community benefits and services. Here is some more precision on terminology:
- Public Purpose Payment: the original funding from Manhattan Park's construction, there are no more payments
- Public Purpose: as constructed from the legislation "provid[ing] direct services or benefits to the residents of Roosevelt Island"
- Public Purpose Fund: a separate accounting mechanism withing RIOC to track monies belonging to Public Purpose
- Public Purpose Grant: monies from the Public Purpose Fund that are awarded based upon Public Purpose Grant applications (previously reviewed by RIRA, now administered separately by NYCT)
Although RIOC can spend up to 3% on Public Purpose Funds, it seeks to "color" (an accounting term of art) as much spending as "Public Purpose", e.g., the Roosevelt Island Day, Fall Festival for the Arts, Holiday Tree lighting, the RIOC's Youth Program, RIOC's Youth Program summer camp, and some Public Safety activities as "Public Purpose". Thus, although there are 3% funds available, in fact, some portion is spent upon RIOC itself (a governmental agency) so that is shows that RIOC is complying with the law, but it's not all coming to community not-for-profits. Both 501(c)(3) and 501(c)(4) organizations are considered not-for-profit (see NYS Attorney General's Charities Bureau), and a separate RIOC Board Resolution (cited above) PROHIBITS lobbying and political activities:
"[...] (i) not intended or used for lobbying or other political activities; and (ii) are intended and used for an activity that directly relates to a power, duty or purpose of RIOC. [...]"
Thus, while your statement about 501(c)(4) might be true:
"RIRA is not a 501(c)(3). It’s a 501(c)(4)—a classification that allows for advocacy, political organizing, and lobbying."
A careful reading (via construction) shows that PPF grants do NOT allow for "advocacy, political organizing, and lobbying".
Several other Community Leaders have presented the same concerns: the 3% is not being spent, and it's not being spent on community not-for-profits but government agencies (e.g., RIOC). This is still a concern, and I hope you can shine a light upon this.