pursuant to provisions in the new rules, a 16.5% distribution fee (totaling $16,772,233) would be charged on donations to cover the cost of the CFC. Early reports are that the number of charities participating in 2018 will drop by approximately 9% Screening of Charities The CFC requires participating charities to meet certain requirements. From time to time, the CFC has been criticized both for requirements both too restrictive and too lenient. Terrorist screening controversy In 2004, the program added a new requirement that all organizations participating in the CFC must certify that they screen all of their employees against government-created blacklists, intended to identify people involved in "terrorist activities". This resulted in the American Civil Liberties Union (ACLU) resigning from the CFC July 31, 2004, because such checks violate their principles. In November 2004, the ACLU and 12 other non-profit organizations filed a lawsuit challenging this policy. Since then, in November 2005, the OCFCO has put out revised requirements. The new regulation requires that each federation, federation member, and un-affiliated organization applying for participation in the CFC must, as a condition of participation, complete a certification that it is in compliance with all statutes, Executive orders, and regulations restricting or prohibiting U.S. persons from engaging in transactions and dealings with countries, entities, or individuals subject to economic sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC). In essence, the charities have to certify that the organizations that they support are not considered terrorist organizations by the US Government. While the ACLU was not in the CFC for 2005, these revised requirements seem to have satisfied most of the charities who complained. In 2007, the ACLU returned to the CFC. Charities failing to pay taxes In 2006, Federal regulators released a report finding the CFC had allowed charities to participate despite being behind on payroll taxes or otherwise engaging in illegal activities. The CFC said a federal law prevented it from screening charities for tax compliance, however in 2006 it said it was taking steps to assure participating charities actually were recognized by the IRS as tax exempt. Charities with high overhead costs Prior to 2006, the CFC restricted charities with fundraising and other overhead costs exceeding 25% of revenue. It did not prohibit such charities from participating, but required them to explain those costs. Starting in 2006, it dropped this screening, citing burden administering