By Ekewaka Lono | Oahu Underground
Third in a series. “The Federal Layer” mapped domestic federal positions. “The Bridges” mapped PRC-facing institutional relationships. This article examines the financial record and disclosure surfaces.
Series Navigation
- Series: The Architecture of Access
- Read Part I: The Federal Layer (domestic federal)
- Read Part II: The Bridges (international / PRC-facing)
- Part III (this page): The Ledger
- The Two Questions: federal investigative roadmap
- Investigations index
Executive Summary
What this is: a public‑record compliance review of CCCH Form 990 filings and documented public events. What this is not: an allegation of foreign control or illegal conduct, or a claim about donor identities. Not legal advice.
Key Judgments
Confidence labels: High = directly supported by cited primary records; Moderate = supported by records but with plausible alternate explanations; Low = inference or threshold‑dependent with limited data.
- [High] FY2024 (period end 2024‑05‑31; IRS tax year 2023) Form 990 reports contributions of $237,712 and grants of $175,970 to individuals; Schedule I lists grant type “GOFUNDME,” recipient count 1, and the records‑maintained indicator is marked “No” (self‑reported). This entry does not, by itself, establish noncompliance.1
- [High] FY2021–FY2025 filings report no foreign offices, foreign activities, or foreign financial accounts and include no Schedule F attachment; this is self‑reported in the filings.1
- [Moderate] The FY2024 contribution spike is a one‑year anomaly relative to FY2021–FY2023 and returns to baseline in FY2025.1
- [Low] Public reporting documents CCCH delegations to China and hosting of a Fujian vice governor; whether those activities meet Schedule F thresholds cannot be determined from public filings alone.234
Summary
- Form 990 data (FY2021–FY2025; period ends 2021‑05‑31 through 2025‑05‑31) show a one‑year contribution spike in FY ending 2024‑05‑31 (IRS tax year 2023) and first‑time grants in that year.1
- FY2025 revenue mix is dominated by program service revenue ($421,124; 70.5% of total).1
- Schedule B donor identities are not publicly disclosed for 501(c)(6) organizations; donor sources for FY2024 contributions are therefore not public.51
- A Fujian Provincial Government account states that “agreements” were inked during meetings in the U.S., including Honolulu; the underlying documents are not included among the sources reviewed here.4
- Hawaii DCCA lists CCCH as Active but “Not in good standing,” and its purpose statement emphasizes business development focused on China and Southeast Asia, cultural preservation, and civic responsibility; the DCCA annuals status endpoint shows a pending 2025 annual report received 2026-01-07.67
Outline: Findings
- FY2024 Form 990 shows a one‑year contribution spike and first‑time grants; Schedule I lists “GOFUNDME,” recipient count 1, and records‑maintained indicator marked No (self‑reported).
- FY2021–FY2025 filings report no foreign offices/activities/financial accounts and include no Schedule F attachment (self‑reported).
- DCCA lists CCCH as Active but “Not in good standing,” with a stated purpose focused on China/Southeast Asia business development and cultural preservation; the annuals status endpoint shows a pending 2025 annual report received 2026-01-07.67
- Public reporting documents the Jan 2024 delegation and March 2024 reception; Fujian’s government account says agreements were inked in U.S. cities including Honolulu.
- Documented contacts with CAIFC appear in the 2010 symposium program and a 2018 CAIFC release.
Outline: Recommendations
- ProPublica’s listing for FY2024/FY2025 provides XML and an e‑file viewer but does not display downloadable IRS page‑image PDFs; obtain a public inspection copy from CCCH or IRS to reconcile Part IX/Schedule I with the XML.1
- Confirm whether the FY2024 “GOFUNDME” grant corresponds to the identified GoFundMe campaign or another recipient; seek documentary support.8
- Obtain any “agreements inked” referenced by the Fujian government account via DBEDT, City & County records, or party releases.4
- Monitor DCCA annuals status for resolution of the pending 2025 filing and “Not in good standing” designation.7
- Re‑run DCCA name searches for HFBA/HFFA and FARA/LDA checks periodically as databases update; archived results are in the Negative Findings Log.
Methodology & Standards
- Primary-source bias: IRS Form 990 XML filings, Hawaii DCCA records, and official government releases are treated as primary; news reporting is labeled as secondary.61234
- Fact vs inference: Documented facts are stated explicitly; analytic judgments are labeled and scoped.
- Uncertainty: Threshold-based disclosures (e.g., Schedule F) cannot be resolved without internal expense data.9
- Alternatives: Plausible non‑malicious explanations are listed with evidence needed to confirm or refute.
- Reproducibility: Retrieval dates and archival copies are provided for all sources; calculations are documented in the Appendix.
Findings
1) Form 990 Filing Summary (FY2021–FY2025)
Fiscal-year labels below are aligned to the tax-period end date in each Form 990 XML (see Appendix).
| Fiscal Year (period end) | Revenue | Contributions | Contributions % | Grants paid |
|---|---|---|---|---|
| FY2021 (2021-05-31) | $139,850 | $91,150 | 65.2% | $0 |
| FY2022 (2022-05-31) | $410,094 | $106,802 | 26.0% | $0 |
| FY2023 (2023-05-31) | $293,685 | $44,381 | 15.1% | $0 |
| FY2024 (2024-05-31) | $593,843 | $237,712 | 40.0% | $175,970 |
| FY2025 (2025-05-31) | $597,135 | $84,943 | 14.2% | $12,657 |
Source: IRS Form 990 XML filings via ProPublica (EIN 99-0035507).1
FY2025 program service revenue totals $421,124 (70.5% of total revenue), which provides context for the contribution spike discussion.1
2) FY2024 Contribution Spike (Documented)
The FY2024 return (tax year 2023, period end 2024-05-31) reports contributions of $237,712, up from $44,381 in FY2023 — a 435.6% increase.1 The prior three‑year average (FY2021–FY2023) was $80,778; FY2024 exceeded that by $156,934.1
By FY2025, contributions returned to $84,943, within the prior range.1 The spike is concentrated in a single fiscal year.
The Form 990 indicates 501(c)(6) status, and Schedule B donor names and addresses are not required to be publicly disclosed for organizations other than 501(c)(3) and 527 entities.51 Donor identities for the FY2024 contributions are therefore not public.
3) Grants and Schedule I (Documented)
FY2024 is the first year in FY2021–FY2025 filings that reports grants and similar assistance ($175,970).[^6] The FY2025 return reports $12,657 in grants.1
Schedule I in the FY2024 and FY2025 XML filings indicates grants to individuals (not organizations), with grant type listed as “GOFUNDME,” recipient count 1, and cash grant amounts matching the totals above.1 The Schedule I “records maintained” indicator is marked No in both filings (self‑reported); this entry does not, by itself, establish noncompliance.1
Schedule I instructions for grants to individuals require the type and number of recipients, not necessarily public identification of each recipient; the public XML does not list recipient names.10
A GoFundMe campaign titled “Help Needed for a Chemical Attack Victim” includes a description signed “Chinese Chamber of Commerce of Hawaii” and addresses “Chamber Members and Friends.”8 This provides a possible public context for a GoFundMe‑type disbursement; the filing itself does not identify the recipient or connect the grant to any specific campaign.1
4) Schedule F Thresholds and Reported Foreign Activity (Documented)
Schedule F is required if Form 990 Part IV indicates foreign activities with aggregate revenues or expenses over $10,000, foreign investments with book value of $100,000 or more, or more than $5,000 in grants to foreign organizations or individuals.9
Across FY2021–FY2025 filings, CCCH reports No for foreign offices, foreign activities, and foreign financial accounts, and the XML filings include no Schedule F attachment.1 These are self‑reported entries; they do not by themselves establish whether foreign activity occurred or what it cost.
5) Public-Record Event Context (Secondary reporting and primary government accounts)
- January 2024 delegation (secondary reporting). Hawaii News Now reported that CCCH resumed its annual trips to China for the first time since the pandemic and visited sister cities including Fuzhou, Zhangzhou, and Zhongshan.2
- March 2024 reception (secondary reporting). Hawaii News Now reported that Fujian Vice Governor Guo Ningning met with local officials and the Chinese community; the welcome reception was hosted by CCCH, with Honolulu City Councilmember Calvin Say and State Rep. Sean Quinlan in attendance.3
- State of Hawaii Office in Beijing (primary). A DBEDT Business Development and Support Division (BDSD) overseas activities report states that the State of Hawaii Office in Beijing (SHOB), in partnership with the Hawaii Fujian Business Association, facilitated a March 16, 2024 visit by Fujian Vice Governor Guo Ningning and held discussions with Lt. Gov. Sylvia Luke, Senate leadership, and Honolulu City and County representatives.11
- Fujian government account (primary). The Fujian Provincial Government’s English-language account states the delegation met officials in Hawaii, Oregon, Honolulu, and Tacoma; invited U.S. counterparts to trade shows in Fujian; and reported that agreements were inked on investment, trade, and procurement in Los Angeles, Portland, and Honolulu.4
- Historical context (secondary). China Daily reported in 2011 that CCCH hosted an average of 20 delegates from China each year at that time.12
These accounts provide context for the organization’s publicly reported activities but do not, on their own, establish whether Schedule F thresholds were met.
6) Documented Contacts With CAIFC (Primary)
A 2010 symposium program lists the Chinese Chamber of Commerce of Hawaii, the Earthquake Engineering Research Institute, and the University of Hawaii as U.S. organizing co‑sponsors, and lists the China Association for International Friendly Contact (CAIFC) among Chinese‑side planning and support organizations.13
A 2018 CAIFC release reports that CAIFC Vice Chairman Xin Qi met with the CCCH Narcissus Queen Goodwill Delegation at the Diaoyutai State Guesthouse in Beijing.14
These are documented contacts with a PRC organization; no conclusions about intent or control are inferred here.
7) Organizational Status (Primary)
Hawaii DCCA lists CCCH as an Active domestic nonprofit corporation, with a registration date of December 27, 1947, and a standing of “Not in good standing.”6 The DCCA purpose statement emphasizes business and economic development with focus on China and Southeast Asia, cultural preservation, and civic responsibility.6
The DCCA annuals status endpoint shows the 2025 annual report marked Pending, with a received date of 2026-01-07; this may explain the current standing designation.7
The Form 990 indicates CCCH is a 501(c)(6) organization.1
Alternative Explanations (Non‑Malicious)
- One‑time domestic pass‑through fundraising. The FY2024 Schedule I lists a single recipient and “GOFUNDME,” which could reflect a one‑off domestic fundraising campaign. Confirmation would require identifying a specific campaign or an explanatory Schedule I narrative.1
- Accounting timing or reclassification. The spike could reflect recognition of pledges or reclassification of revenue lines. Confirmation would require audited financial statements or detailed Part VIII/IX reporting.
- Foreign‑related costs paid by participants or third parties. If travel or hosting costs were paid directly by participants or sponsors, Schedule F thresholds might not be met. Confirmation would require invoices, reimbursements, or sponsorship agreements.
Indicators & Collection Tasks
- ProPublica’s listing for FY2024/FY2025 provides XML and an e‑file viewer but does not display downloadable IRS page‑image PDFs; obtain a public inspection copy from CCCH or IRS to reconcile Part IX/Schedule I with the XML.1
- Confirm whether the FY2024 “GOFUNDME” grant corresponds to the identified GoFundMe campaign or another recipient; seek documentary support.8
- If the GoFundMe campaign is the same recipient, reconcile the delta between the campaign total displayed ($193,774) and the FY2024 grant amount ($175,970) (fees, partial disbursement timing, multiple recipients, or partial payouts).81
- Obtain any “agreements inked” referenced by the Fujian government account through DBEDT, City & County of Honolulu records, or the parties to the meetings.4
- Monitor DCCA annuals status for resolution of the pending 2025 filing and “Not in good standing” designation.7
- Re‑run DCCA name searches for HFBA/HFFA and FARA/LDA checks periodically as databases update; archived results are in the Negative Findings Log.
Appendix
Data Extraction Notes
- Primary data source: IRS Form 990 XML filings downloaded via ProPublica Nonprofit Explorer (EIN 99‑0035507).1
- Fiscal-year mapping: The article labels each fiscal year by the Form 990 tax period end date (e.g., FY2024 corresponds to tax year 2023, period end 2024‑05‑31).1
- PDF availability: ProPublica’s listing for FY2024/FY2025 provides XML and an e‑file viewer but does not display downloadable IRS page‑image PDFs; the API response lists
pdf_url: nullfor those years.115 - Contribution percentage:
Contributions % = (CYContributionsGrantsAmt / CYTotalRevenueAmt) * 100.1 - FY2024 spike calculation:
((237,712 - 44,381) / 44,381) * 100 = 435.6%.1 - Prior 3‑year average:
(FY2021 + FY2022 + FY2023 contributions) / 3 = 80,778.1
Negative Findings Log (Preliminary)
This review reports negative findings only with reproducible search methods and archived search outputs.
| Negative finding (as of 2026-03-04) | Where searched | Exact query terms | Date searched | Scope limits | What would change the finding | Source(s) |
|---|---|---|---|---|---|---|
| No DBEDT site results for Guo Ningning or Fujian delegation; no Honolulu.gov site results for Guo Ningning, Fujian, or MOU | DBEDT site search (dbedt.hawaii.gov/?s=) and Honolulu.gov site search (honolulu.gov/?s=) | “Fujian”, “Guo Ningning”, “MOU” | 2026-03-04 | DBEDT site‑search only; does not include files.hawaii.gov PDFs or non‑indexed docs | Any DBEDT/Honolulu posting referencing the delegation or agreements | DBEDT_Fujian; DBEDT_Guo; Honolulu_Fujian; Honolulu_Guo; Honolulu_MOU |
| No DCCA business record located for “Hawaii Fujian Business Association” or “Hawaii Fujian Friendship Association” | DCCA business name search (POST to hbe.ehawaii.gov/documents/search.html) | “Hawaii Fujian Business Association”; “Hawaii Fujian Friendship Association” | 2026-03-04 | Name‑based search only; DCCA warns results are not definitive for availability | Any DCCA record matching the association names | DCCA_Search_HFBA; DCCA_Search_HFFA |
| No FARA registrant name match for CCCH or listed terms | FARA registrant lists (Active + Terminated) | “Chinese Chamber of Commerce of Hawaii”; “Chinese Chamber of Commerce”; “CCCH”; “Gifford Chang”; “Warren Luke” | 2026-03-04 | Name‑match only; does not cover undisclosed agency relationships | Any FARA registrant with matching name | FARA_Registrants_Active; FARA_Registrants_Terminated |
| No LDA filings returned for CCCH or named terms | Senate LDA API search (lda.senate.gov/api/v1/filings/) | “Chinese Chamber of Commerce of Hawaii”; “CCCH”; “Warren Luke” | 2026-03-04 | API search by registrant/client name only | Any LDA filing matching terms | LDA_registrant_ccch; LDA_client_ccch; LDA_registrant_ccch_abbrev; LDA_client_ccch_abbrev; LDA_registrant_warren_luke; LDA_client_warren_luke |
Right of Reply
The Chinese Chamber of Commerce of Hawaii, its officers, and all individuals and organizations named in this article are invited to respond. Corrections, clarifications, and additional context will be incorporated promptly. Contact: [email protected].
Sources and Notes
IRS Form 990 XML filings for CCCH (tax years 2020–2024; period ends 2021‑05‑31 through 2025‑05‑31), downloaded via ProPublica Nonprofit Explorer (EIN 99‑0035507). External: https://projects.propublica.org/nonprofits/organizations/990035507. Archival copies: (archival copy — 2021 XML) (archival copy — 2022 XML) (archival copy — 2023 XML) (archival copy — 2024 XML) (archival copy — 2025 XML) Retrieved 2026-03-04. ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎
Hawaii News Now, “Chinese Chamber of Commerce of Hawaii Returns to China for First Trip Since Pandemic,” January 30, 2024. External: https://www.hawaiinewsnow.com/2024/01/30/chinese-chamber-commerce-hawaiis-returns-china-first-trip-since-pandemic/. (archival copy) Retrieved 2026-03-04. ↩︎ ↩︎ ↩︎
Hawaii News Now, “Top Official from China’s Fujian Province in Hawaii for Goodwill Visit,” March 17, 2024. External: https://www.hawaiinewsnow.com/2024/03/17/top-official-chinas-fujian-province-hawaii-goodwill-visit/. (archival copy) Retrieved 2026-03-04. ↩︎ ↩︎ ↩︎
Fujian Provincial People’s Government, “Fujian Delegation Visits the US,” March 28, 2024. External: https://www.fujian.gov.cn/english/news/202403/t20240328_6420989.htm. (archival copy) Retrieved 2026-03-04. ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎
IRS, “Instructions for Schedule B (Form 990).” External: https://www.irs.gov/instructions/i990sb. (archival copy) Retrieved 2026-03-04. ↩︎ ↩︎
Hawaii Department of Commerce and Consumer Affairs (DCCA), Business Registration Division, CCCH entity status and purpose statement (File No. 3923 D2). External: https://hbe.ehawaii.gov/documents/business.html?fileNumber=3923D2. (archival copy) Retrieved 2026-03-04. ↩︎ ↩︎ ↩︎ ↩︎ ↩︎
Hawaii Business Express (DCCA Annuals), annuals status endpoint for File No. 3923 D2. External: https://hbe.ehawaii.gov/annuals/rest/annuals/3923D2/status. (archival copy) Retrieved 2026-03-04. ↩︎ ↩︎ ↩︎ ↩︎ ↩︎
GoFundMe, “Help Needed for a Chemical Attack Victim.” External: https://www.gofundme.com/f/help-needed-for-a-chemical-attack-victim. (archival copy) Retrieved 2026-03-04. ↩︎ ↩︎ ↩︎ ↩︎
IRS, “Instructions for Schedule F (Form 990).” External: https://www.irs.gov/instructions/i990sf. (archival copy) Retrieved 2026-03-04. ↩︎ ↩︎
IRS, “Instructions for Schedule I (Form 990).” External: https://www.irs.gov/instructions/i990si. (archival copy) Retrieved 2026-03-04. ↩︎
Hawaii DBEDT Business Development and Support Division (BDSD), “Overseas Activities Report 2024,” Part 4 (Sister‑State and Government Relations), March 16 entry (PDF p. 29 / printed p. 29). External: https://files.hawaii.gov/dbedt/annuals/2024/2024-bdsd-overseas.pdf. (archival copy) (Wayback snapshot 2025-03-08). Retrieved 2026-03-04. ↩︎
China Daily, feature on the Chinese Chamber of Commerce of Hawaii, November 14, 2011. External: http://usa.chinadaily.com.cn/epaper/2011-11/14/content_14092246.htm. (archival copy) Retrieved 2026-03-04. ↩︎
“CHINA/USA Symposium for the Advancement of Earthquake Sciences and Hazard Mitigation Practices,” symposium program (week of Oct. 18, 2010). External: https://lfestorage.s3.us-east-2.amazonaws.com/lfe/pdf/China-USASymposium.pdf. (archival copy) Retrieved 2026-03-04. ↩︎
China Association for International Friendly Contact (CAIFC), “Vice-chairman Xin Qi Meets with Narcissus Queen Goodwill Delegation from Hawaii,” June 7, 2018. External: https://www.caifc.org.cn/index.php?m=content&c=index&a=show&catid=41&id=924. (archival copy) Retrieved 2026-03-04. ↩︎
ProPublica Nonprofit Explorer API, organization summary for EIN 99‑0035507 (shows
pdf_url: nullfor recent filings). External: https://projects.propublica.org/nonprofits/api/v2/organizations/990035507.json. (archival copy) Retrieved 2026-03-04. ↩︎
