As you are aware, the IRS has adopted a position that non-profit programs should not participate in down payment assistance, and those that do will have their non-profit status revoked making them ineligible to provide gift funds under HUD guidelines.
We are a government grant program, which eliminates this concern. HUD handbook 4155.1 Rev-5, CHG-1 Paragraph 2-10(c) indicates that government entities are included among the organizations that may provide secondary financing:
Gift Funds. An outright gift of cash is acceptable if the donor is (1) the borrower's relative, (2) the borrower's employer or labor union, (3) a charitable organization (non-profit), (4) a governmental agency or public entity that has a program to provide homeownership assistance to low- and moderate-income families or first-time homebuyers, (5) or a close friend . . ..
For more information on Sovereign Grant Alliance, please click HERE.