No one can say with certainty about any of these proposals. Even if the community believes something is not, the SEC could chose to pursue it, which could be very expensive and cause damage regardless.
I don’t believe Sonya is correct based upon our consultations. Nonprofit and for-profit have no bearing. Direct funding (regardless of who receives it), if I understand your proposal correctly, would likely result in this type of model being presented to SEC.gov | Strategic Hub for Innovation and Financial Technology (FinHub) for feedback.