DIRECT IMPACT FUND | FIELD OF INTEREST FUND | PROGRAM POLICIES

These Program Policies describe how the Direct Impact Fund field of interest funds work. Please review these policies carefully.

WHAT IS A FIELD OF INTEREST FUND?

A field of interest fund is a fund established on the books of Direct Impact Fund that is dedicated to supporting a particular “field of interest”. Donors contribute money or other property to the Direct Impact Fund, which holds the contributions in a segregated fund. The Direct Impact Fund, working with an advisory committee for the fund, then makes expenditures from the fund in support of the particular field of interest. Such expenditures can include grants to further the charitable interests of the fund, whether to organizations or to individuals, or direct expenditures in support of the field of interest.

CONTRIBUTIONS TO THE FUND

To establish a field of interest fund (a “Fund”) at the Direct Impact Fund, one or more donors must contribute $5,000 or more. Once established, the Fund can receive donations from other donors, including donors on a crowdfunding site, at any time. The Direct Impact Fund’s gift acceptance policy, if any and as amended from time to time, applies to all contributions to the Fund. The Direct Impact Fund may reject, in its sole discretion, any contribution.

All contributions to the Fund are irrevocable gifts to the Direct Impact Fund. The Fund is the property of the Direct Impact Fund, and the Direct Impact Fund has ultimate discretion and control over all property in the Fund, including any income the Fund earns. All contributions to the Fund are subject to the Direct Impact Fund’s variance power, which means that at all times the Direct Impact Fund retains full discretion and control over the Fund. However, the Fund can only be used for the restricted purposes set forth in the Field of Interest Fund Statement establishing a particular Fund.

ADVISORY COMMITTEE

The Field of Interest Fund Statement names an initial Advisory Committee that works with the Direct Impact Fund to determine appropriate expenditures from the Fund to further the purposes of the Fund. Any Advisory Committee member may relinquish his or her participation on the Advisory Committee at any time by notifying the Direct Impact Fund in writing. The Direct Impact Fund may, in consultation with existing Advisory Committee members, appoint additional members to the Advisory Committee. Notwithstanding the existence of the Advisory Committee, the Direct Impact Fund has at all times full discretion and control over how to direct money from the Fund, within the restricted purposes of the Fund.

DISTRIBUTIONS FROM THE FUND

All grants and distributions from the Fund must be exclusively for charitable or educational purposes, as those terms are used in Section 170(c)(2) of the Internal Revenue Code (the “Code”). All grants and distributions must also further the Direct Impact Fund’s charitable and educational purposes, as determined by the Direct Impact Fund in its sole discretion. Grants and distributions may not benefit any member of the Advisory Committee, directly or indirectly.

MANAGEMENT OF THE FUND

Investment of the Fund. The Direct Impact Fund has full discretion and control over the investment of Fund assets. Funds may be pooled with other Impact Fund assets for investment purposes. Fund investment activity will be tracked separately, regardless of how the assets are held.

Income. All income (including gains) earned on assets held in the Fund will be allocated to the Fund.

Administrative Fees. The Direct Impact Fund may assess an administrative fee against the Fund based on the amount of donations to the Fund.

Other Expenses. The Direct Impact Fund may in its sole discretion deduct from the Fund any costs, including legal fees, that the Direct Impact Fund incurs with respect to the Fund.

Reporting. The Direct Impact Fund will provide to each Advisory Committee member on a quarterly basis a report on the status of the Fund. The report will include information on donations to the Fund, earnings on investments, expenditures from the Fund, and fees deducted. The Direct Impact Fund may provide additional reports upon request.

 

DONOR ADVISED FUND PROGRAM POLICIES

The policies outlined below (these “Program Policies”) describe how Direct Impact Fund donor advised funds work. Please review these policies carefully.

WHAT IS A DONOR ADVISED FUND?

A donor advised fund permits future grants for charitable purposes while maximizing the donor’s current tax benefits. The donor contributes money or other property to the Direct Impact Fund, which holds the contributions in a segregated fund. The donor (or others named by the donor) may then recommend grants from the donor advised fund.

CONTRIBUTIONS TO THE FUND

To establish a donor advised fund (a “Fund”) at the Direct Impact Fund, a donor must contribute $5,000 or more. The primary donor (or anyone else, including donors on a crowdfund site) may make additional contributions into the Fund at any time. The Direct Impact Fund’s gift acceptance policy, if any, and as amended from time to time, applies to all contributions to the Fund. The Direct Impact Fund may reject, in its sole discretion, any contribution.
All contributions to the Fund are irrevocable gifts to the Direct Impact Fund. The Fund is the property of the Direct Impact Fund, and the Direct Impact Fund has ultimate discretion and control over all property in the Fund including any income the Fund earns. All contributions to the Fund are subject to the Direct Impact Fund’s variance power, which means that at all times the Direct Impact Fund retains full discretion and control over the Fund and that the Direct Impact Fund is not bound by the grant recommendation of any Advisor. However, if the Donor Advised Fund Agreement or communications to donors to the Fund indicate that the funds can only be used for certain restricted purposes, that purpose restriction will apply to all grants from the Fund.

ADVISORY PRIVILEGES

As the primary donor to the Fund, you have the privilege to recommend grants from the Fund. You may also name up to three other individuals who may recommend grants from the Fund. These Program Policies refer to you and each of the named individuals as an “Advisor.” Any single Advisor may recommend grants from the Fund.

To name an Advisor, or to revoke an Advisor’s advisory privileges, please submit a letter to the Direct Impact Fund signed by the original donor(s). Only the primary donor(s) may name Advisors or revoke an Advisor’s advisory privileges. Any Advisor may relinquish his or her own advisory privileges at any time by notifying the Direct Impact Fund in writing.

GRANTS FROM THE FUND

The recommended minimum grant amount is $5,000.

Eligible Grant Purposes. All grants from the Fund must be exclusively for charitable or educational purposes, as those terms are used in Section 170(c)(2) of the Internal Revenue Code (the “Code”). All grants must also further the Direct Impact Fund’s charitable and educational purposes, as determined by the Direct Impact Fund in its sole discretion. In addition, if the Donor Advised Fund Agreement or communications to donors to the Fund indicate a specific purpose for the Fund, then all grants from the Fund must comply with the stated purpose restriction. The Direct Impact Fund may, from time to time, notify the Advisors of suitable grant recipients.

Eligible Grant Recipients. The Direct Impact Fund will only make grants from the Fund to U.S. charitable organizations that are tax-exempt public charities; U.S., state, or local government organizations qualified to receive tax deductible charitable contributions, such as state colleges or universities; private operating foundations; or certain non-U.S. organizations. The Direct Impact Fund will not make grants from the Fund to individuals.

Restricted Organizations and Purposes. The Direct Impact Fund will not approve recommendations for grants:

  • to non-functionally integrated Type III supporting organizations;
  • to supporting organizations that are controlled by or that provide support to organizations controlled by any Advisor, or certain family members or affiliates (as defined below) of such people;
  • to private non-operating foundations;
  • that are for lobbying, political campaigns or other political activities; or
  • that are for any purpose that is not entirely charitable.

Enforceable Pledges. In general, no Advisor may recommend a grant that would discharge or satisfy (in whole or in part) a legally enforceable pledge or other obligation, including a pledge or other obligation of any Advisor or their family members or affiliates.

“Family members” means spouses, registered domestic partners, ancestors, children, grandchildren, great grandchildren, brothers and sisters, as well as the spouses or registered domestic partners of children, grandchildren, great grandchildren, brothers, and sisters.

An entity is an “affiliate” of a person if it is a corporation at least 35% owned (by voting stock), or a partnership at least 35% owned (by profits interest), or a trust at least 35% owned (by beneficial interest) by such person and/or such person’s family members.

Return Benefits. No Advisor may recommend a grant that would cause or enable any Advisor or family members or affiliates of such people, to receive a return benefit, such as the opportunity to attend a fundraising dinner or event. Grants with prohibited return benefits include so-called “bifurcated” grants, in which attendance at an event (or the receipt of any other benefit) is paid for separately but contingent on receipt of a charitable contribution or grant.

MANAGEMENT OF THE FUND

Investment of the Fund. The Direct Impact Fund has full discretion and control over the investment of Fund assets. Funds may be pooled with other Direct Impact Fund assets for investment purposes. Fund investment activity will be tracked separately, regardless of how the assets are held.

Income. All income (including gains) earned on assets held in the Fund will be allocated to the Fund.

Administrative Fees. The Direct Impact Fund may assess an administrative fee against the Fund.

Other Expenses. The Direct Impact Fund may in its sole discretion deduct from the Fund any costs, including legal fees, that the Direct Impact Fund incurs with respect to the Fund. Certain grants, intensive due diligence, or Advisor-requested research may incur extra fees.

Reporting. The Direct Impact Fund will provide to each Advisor on a quarterly basis a report on the status of the Fund. The report will include additional contributions by the initial donor or other donors, earnings on investments, charitable grants from the Fund, and fees deducted. The Direct Impact Fund may provide additional reports upon request.

TERMINATION

Upon termination of the Fund any remaining advisory privileges will end. However, prior to termination, the primary donor may express his or her recommendation to the Direct Impact Fund at any time regarding the distribution of Fund assets upon termination of the Fund.

No Remaining Advisors. The Fund will terminate if at any point there is no Advisor to the Fund.

Fund Minimum Balance. If the Fund balance remains below $5,000 for three consecutive months, the Direct Impact Fund will attempt to notify the Advisor(s). If the Direct Impact Fund does not receive either a grant recommendation or additional funds for contribution into the Fund within 90 days of such attempted notification, the Impact Fund may in its sole discretion terminate the Fund.

Minimum Activity. When the Direct Impact Fund has received no grant recommendations from any Advisor to a Fund for 12 consecutive months, the Direct Impact Fund will request grant recommendations in each quarterly statement thereafter. If 18 consecutive months pass with no grant recommendations from any Advisor, the Direct Impact Fund may in its sole discretion terminate the Fund.