Donor Advised Funds
Comments
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Daphne-Ann,
This question is posted almost weekly. Please search the forums for the responses many users have already taken the time to write. You could search for 'donor advised', 'DAF', etc. and you should come up with quite a number of threads.6 -
Daphne-Ann Singleterry:
I am curious to learn how other organizations are processing Donor Advised Fund gifts in the Raise'rs Edge? Since the gift is being recommended by the donor, and technically is the donors money, who's record are you applying the gitt to and who is being soft credited - if anyone?We hard credit the DAF and send tax receipts there (if the fund address is different than the donors' address), and soft credit the donors and send them a non-tax thank you letter to their home address.
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Thank you Kendall. Seems every organization handles this a bit different.1
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Technically, it is NO LONGER the donor's money. By setting up the fund, the donor has transferred the money to the institution that holds the fund. They may have some influence/recommendation as to how the money is distributed (based on the language in their fund agreement). So we typically hard credit the institution that holds/owns the fund, and soft credit the donor who is associated with the fund.18
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Absolutely correct Gina Gerhard and if you send an acknowledgement to the soft credit you don't include receipt language. It is merely a thank you.
6 -
I agree with those who are reminding everyone that it is NO LONGER the donor's money. There are tax laws about how these gifts can be treated so, while some places handle things slightly differently they ALL must be aware of the restrictions on how these gifts can be used (not toward pledges, not toward anything with benefits, etc.) and how they are thus receipted.7
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It used to be that DAF's were lax concerning goods and services and would allow their donors to write a personal check to cover the non tax-deductible amount. I have received several calls in the past month concerning gifts to us for a gala. They have told me that the donor must pay the full cost of seats. For example a $25,000 table includes 10 seats and 4 tickets to the Patron Party 2 days prior to the event. Individuals can purchase Patron Tickets for $1,500 and individual tickets for $650. Fidelity Charitable told me that the donor would have to write a personal check for $9,900 to cover the cost of 4 Patron tickets and 6 individual tickets. They did say that they would inform the donor.
The long over due crack down begins. Winter is coming.
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I'll put my neck on the chopping block to say that with DAF gifts I break all the rules everyone else has mentioned and I'll add that Bill Connors agrees with me.
It is true that DAF funds do not belong to the donor and cannot legally pay off a pledge from a donor. If your organization's auditors audit the Raiser's Edge for tax compliance you will not be able to follow the practice I'm about the describe. Bill Connors has often said that Raiser's Edge is not accounting software, but rather fundraising software and as such our database needs to support our fund raising and stewardship efforts. At my organization if the IRS shows up to audit us, they are going to audit our Business Office books, not the Raiser's Edge database.
Given that, when we receive a check from a DAF we, unlike everyone else, hard credit the donor that directed the funds and soft credit the DAF. We also use a Gift Attribute of Name on Check so we can capture the legal entity that gave us the donation. This practice better supports stewardship in that when we produce a list of donors Fidelity is not one of them. Additionally, because the donor that directed the funds did not legally own the money we received, we mark the Gift Receipt Amount as zero dollars and we do not issue a receipt to the constituent, only an acknowledgement letter and we recognize the DAF in that acknowledgement letter. If the DAF requires a receipt we will send them one, but we don’t run into that request very often.
Quote from Bill Connors book "Fund Raiding with the Raiser's Edge: A Non-Technical Guide" pg. 27
"Many fundraising database users in the United States say, ‘The IRS requires that the name on check be entered as the hard credit constituent in our database.’ My research and experience have shown this is not the case. The IRS requires acknowledgement letters clearly indicate the name of the true donor. However, the IRS does not dictate how we set up our database and who the constituents are. Correct this belief among your data entry staff to avoid duplicates and difficulty retrieving data."
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Aaron - Thanks for your great comment on this.
Just interesting - I work for a community foundation and we do NOT primarily use Raiser's Edge for fundraising. We use RE primarily to hold our core information about constituents who have established funds with our foundation. So our focus is more on the financial and legal relationships our constituents have with the foundation and their funds.
Not all Raiser's Edge clients use the system in the same way.3 -
Um - I think that DAF is using a very liberal interpretation as many would say they should not even allow the 9,900 to be allowed to go to the sponsorship. This is called bifurcation and many interpret IRS law to not allow it at all. Don't have time to add more now but there has been a lot of discussion and resources posted on fundsvcs.org which has an extensive archive and downloads section.1
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Aaron Rothberg:
I'll put my neck on the chopping block to say that with DAF gifts I break all the rules everyone else has mentioned and I'll add that Bill Connors agrees with me.
It is true that DAF funds do not belong to the donor and cannot legally pay off a pledge from a donor. If your organization's auditors audit the Raiser's Edge for tax compliance you will not be able to follow the practice I'm about the describe. Bill Connors has often said that Raiser's Edge is not accounting software, but rather fundraising software and as such our database needs to support our fund raising and stewardship efforts. At my organization if the IRS shows up to audit us, they are going to audit our Business Office books, not the Raiser's Edge database.
Given that, when we receive a check from a DAF we, unlike everyone else, hard credit the donor that directed the funds and soft credit the DAF. We also use a Gift Attribute of Name on Check so we can capture the legal entity that gave us the donation. This practice better supports stewardship in that when we produce a list of donors Fidelity is not one of them. Additionally, because the donor that directed the funds did not legally own the money we received, we mark the Gift Receipt Amount as zero dollars and we do not issue a receipt to the constituent, only an acknowledgement letter and we recognize the DAF in that acknowledgement letter. If the DAF requires a receipt we will send them one, but we don’t run into that request very often.
Quote from Bill Connors book "Fund Raiding with the Raiser's Edge: A Non-Technical Guide" pg. 27
"Many fundraising database users in the United States say, ‘The IRS requires that the name on check be entered as the hard credit constituent in our database.’ My research and experience have shown this is not the case. The IRS requires acknowledgement letters clearly indicate the name of the true donor. However, the IRS does not dictate how we set up our database and who the constituents are. Correct this belief among your data entry staff to avoid duplicates and difficulty retrieving data."I basically wrote the same thing a week ago when this topic was brought up (audit season, anyone? :P). We don't use this system, but if I were setting something up from scratch, I would absolutely do things this way. It just makes things easier insofar as stewardship is concerned, and also insofar as reporting is concerned (soft credits get tangled very quickly).
We are in fact undergoing our audit right now. Our auditors like me to pull reports from RE just for investigation purposes, but they are indeed auditing primarily FE, other accounting documentation, and information on specific proposals made to our major gift donors. If we were to put these gifts on the donor records (and they were above a ceratin threshold), then they may ask to see the paper backup for them, which is what I'd do for them anyway, and they use that paper backup to verify with our finance department that the money was handled appropriately. They've never inquired about our tax language, though we do make sure not to include tax language with DAF acknowledgements.
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The DAF Tax rules do not apply to you - they apply to the donor and the sponsoring organization. They are the ones who you are putting on the line if you do not properly handle their gifts. All penalties go to them - not you. Your own auditors would, therefore, never be looking for this. But in my professional opinion you owe it to your donors to help protect them from potential problems by handling their gift properly. Now I am not talking about where to track the gift - either system works, but allowing benefits or applying to pledges - another issue altogether.4
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Thanks for that clarification. I come from an education background and tax laws are still very murky to me.0
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Hi - I've said it before and I'll say it again - there's a cleaner way. We call DAF donations "Pass-throughs" because we don't use soft credits anymore. I agree with Bill Connors - this is fundraising and constituent management software. Yes, we have to demonstrate that we didn't give the donor a tax receipt and that we applied it as instructed and that it didn't go towards "benefits" (gala tickets, for us). Beyond that, it's all about the person who directed the gift and designated it - the donor, not the check writer. We have a separate master batch that we load for these gifts, with a $0 receipt amount defaulted, and a letter that says "Thank you for designating a gift from [Fidelity, Schwab, whatever] of <Gift Amount> for the <Fund Name>. The gift was received on <Gift Date>." Our relationship is with the donor, not the DAF organization. Same with United Way, Benevity, whatever. We use the otherwise never-used Gift Code field for a list of the most common DAF and passthrough donors and insert it into the letter.
That being said, we had to add a notice to our solicitation for gala table sponsorships to indicate that DAF monies could not be used for the benefit portion of the sponsorship. We also don't post pledges - we consider them an "intent to donate". If your organization does post pledges, that naturally gets very sticky. Our auditors are only looking at cash and gifts-in-kind. And our annual reports to the donor show the amount of the DAF donation, but don't count it in the potentially tax-deductible portion because of the $0 receipt amount.2 -
Hi Gracie-
Sounds like you and I are following two variants of the same process. I store the DAF name in a Gift Attribute for capture in the Ack letter and you store the DAF name in Gift Code for the same purpose. You bring up an interesting idea, that is to not soft credit the DAF since you already have their name in the Gift Code field. Have you ever encountered a need to report on total dollars coming from DAFs and if so, is your Gift Code dimension enough to calculate summaries? I'm guessing it is because Gift Code prevents free text entry which would allow you to summarize DAF gifts in Excel. You've even got me tempted to drop the soft crediting, but I'm wondering if there's a scenario neither of us have considered that would make soft crediting beneficial?
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You all have very iintersting takes on how you handle DAF's and your logic for doing so. Gracie and Aaron, y'all are thinking more in line of what I was hoping to hear.
Have you run into any problems with Donor's, Finance Departments, reporting or Auditor's that lead you to modify some of your processes? I'm currently restructering and the process here and I'd like it make sense to everyone in my Department without any pushback.0 -
Hi Daphne-Ann-
This is a brand new process I'm just starting at our organization so I'll let you know if the cops show up.
The way I think about DAF gifts is like this. Let's imagine we don't have any DAF constituent records in our database and we handle all DAF donations as though they came from the donor. What problems do we need to overcome?
We need to ensure our Donor Ack letter clearly states the money came from the DAF
We need sufficient evidence to demonstrate to auditors we did this
We need a record of the legal donor's name (the DAF) that was on the check
We need to make sure the donor isn't getting any benefits in return
That's all I can think of and as such this is why Gracie now has me thinking about ditching DAF soft crediting as well. If we design a means to record which DAF the gifts come from (Gift Attr in my case, Gift Code in Gracie's) then why bother with soft credit for an Org we otherwise don't care about? I can't think of a good reason.2 -
Do you have a pledge on the record anticipating a personal payment but then get the DAF? Not a problems but just an aspect to plan for. Will you enter as pledge payment or a cash gift?0
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We don't allow DAF gifts to pay off donor pledges. We can't defend that paper trail since it's very clear DAF money doesn't belong to the donor. If I were faced with that situation I think I would either write off the pledge or adjust it to zero and then follow the same process above, that is to hard credit the donor with a Cash gift (including DAF Name on Check) and thank them with an ack letter that acknowledges the donation came from the DAF. I'd probably adjust it to zero versus a wrtite off since Write Offs seem to be more trouble than they're worth in Raiser's Edge reporting.2
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Daphne-Ann Singleterry:
I am curious to learn how other organizations are processing Donor Advised Fund gifts in the Raise'rs Edge? Since the gift is being recommended by the donor, and technically is the donors money, who's record are you applying the gitt to and who is being soft credited - if anyone?OK, I have a fascinating (to me) update on this situation: I did NOT post DAF money to a pre-existing pledge due to the strong language included in the letter stating not to. Anyhow, my fund-raising team went bizonkers (yes, you have my permission to use this term), and our Finance team asked for back-up documentation of course in WRITING for auditing purposes if the team wanted this money to be posted to the pledge. This link provided that back up and I was able to post the DAF check to a pre-existing pledge with blessings from all: https://www.uscharitablegifttrust.org/ questions-and-answers.php
Never a dull moment...and I get to keep my job another day:-)
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Sort of goes back to interpretation of legal enforceable..."Many pledges however, are considered to be enforceable and are legally binding debt obligations of the donor. These pledges cannot be fulfilled by grants from a DAF."
While signed pledge documents for most organizations could be considered enforceable, many are not going to enforce them. Too much bad PR.2 -
Jill,
This is really useful information. Thanks to all of you who took the time to respond to my query. Now the DAF ball is in our court!1 -
Hi Jill-
Help! I'm confused. Looking at this language:
May I recommend grants from the DAF to complete a pledge to charity that I have already made?
In rare circumstances, a grant from a DAF account may be used to fulfill a pre-existing pledge"
You state, “This link provided that back up and I was able to post the DAF check to a pre-existing pledge with blessings from all”
Where I’m lost is how did your team determine this particular circumstance was an acceptable “rare circumstance”? The US Charitable Gift Trust doesn’t even try to define what a “rare circumstance” is or when it is or isn't appropriate. They just say, “Yeah, it’s ok sometimes, but mostly not.”
Can you share your team’s justification for allowing this DAF gift to pay off a donor pledge?
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Melissa Graves:
Um - I think that DAF is using a very liberal interpretation as many would say they should not even allow the 9,900 to be allowed to go to the sponsorship. This is called bifurcation and many interpret IRS law to not allow it at all. Don't have time to add more now but there has been a lot of discussion and resources posted on fundsvcs.org which has an extensive archive and downloads section.Melissa, I think what I wrote may be a little confusing. The $9,900 is not the value of goods and services it is the public cost of the 10 seats so there is no bifurcation.
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Aaron - insofar as pledges go, here's my interpretation of what's going on based on my own experience.
There tend to be two different use cases for pledges in RE; I'll call them "traditional" and "work flow." A traditional pledge is an agreement between the donor and the organization, typically formalized in writing, and logged as income by finance on the date of the pledge (preferably by posting the pledge directly to FE, if you have FE and it's integrated with RE). Based on the language being tossed around here on the forum, I would say that DAF money cannot and should not be used to pay this kind of pledge.
But "work flow" pledges are different. These pledges are far less formal. They may be promises made verbally or in email, the timeframe for payment isn't usually all that consequential (e.g., so long as it's paid this fiscal year, we're good), and the amounts are typically lower than big formalized pledges (though this doesn't have to be true). These pledges are NOT logged by finance and are NOT posted to FE (if applicable). In these cases, a gift officer may put in a pledge for the donation so that when the gift comes in, our data entry person can see that there's a pledge on the record, apply it, and allow the campaign/fund/appeal/package from the pledge flow to the payment. This keeps the data entry person moving along without much interruption because s/he is sure that the data is what the solicitor expects.
I would say that in this case, a DAF gift can go ahead and be applied to the pledge, no problem. The pledge is just a record keeping tool at this point and doesn't reflect a formal, legally binding agreement. So if you were putting the DAF gift directly on the constituent record, then really this would just make the whole thing easier to manage.
I can see some folks being uncomfortable with this process, but I wouldn't flinch at it myself.7 -
Thanks Ryan. That makes sense. As JoAnn said and you reiterated it often comes down to interpretation, but your answer helps me think through how we should handle those gifts at our organization.1
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Ryan's post is a good way to say what I've experienced at most of my former orgs. We used RE pledge records to track intent, even without a binding document. This allowed us to record a pledge when we knew the donor had made the request to the DAF and move the donor into the stewardship phase regardless of whether or not the actual gift was received yet. We had several donors who would send us a copy of the form submitted to the DAF, as an alert that the request had been made, and therefore the solicitation process was complete. In one case, this saved us a potentially lost gift, because the DAF misplaced the paperwork and we were able to follow up with the donor when approaching the end of the year and we had a "balance" on their pledge.
Essentially, we used a Pledge as a placeholder for an intended gift (similar to sending an LOI to a foundation before compiling the proposal). The fundraisers often wanted to count the gift in the month the "pledge" was made or intention declared because that's when their work shifted from solicitation to stewardship and they wanted their performance indicators to be accurate to the work they were doing, not to the timing of the DAF's checks arriving.
However, opposite to what Ryan said, often our Finance department would also book a pledge in these cases. Because they needed to be able to track spend-down and many times that spend-down could start before the check arrived. Not to mention, the program staff preferred to see the amount hit their budget reports as available funds before they started spending. We always wanted to encourage responsible spending, but if they waited for the check, sometimes we would end up losing (needing to return) part of the money because it wasn't all spent within the specified timeframe in the agreement with the donor. Of course, if the pledge was "made" and then something changed and the DAF was not sending the check, the donor would likely use a different funding method/account, or we'd need to do some scrambling to fix it.
We also would not enter a Pledge without something in writing (email counted) from the donor. Not a scrap of paper from a fundraiser saying that Dr. Hernandez would be requesting a gift of $5k from his DAF, but an email from Dr. Hernandez with the intention stated. Phone calls and passing comments in the hallway after a board meeting could count as a verbal pledge on the Proposal Record (Proposal Status) but no Gift Record until follow-up with the donor resulted in something written.
I would say that you need to set up policies for your organization with input and approval from your Finance Dept and auditors (and, of course, Development Dept). Then document them and be consistent in applying them. And be sure that if you offer benefits, that the policies include how that is to be handled (which should be a separate payment from a non-DAF account, or agreement from the DAF about whatever the situation is). Cover the basics and then document with a Gift Note any exceptions or extenuating circumstances as they occur.3 -
Michael Sherman:
Melissa Graves:
Um - I think that DAF is using a very liberal interpretation as many would say they should not even allow the 9,900 to be allowed to go to the sponsorship. This is called bifurcation and many interpret IRS law to not allow it at all. Don't have time to add more now but there has been a lot of discussion and resources posted on fundsvcs.org which has an extensive archive and downloads section.Melissa, I think what I wrote may be a little confusing. The $9,900 is not the value of goods and services it is the public cost of the 10 seats so there is no bifurcation.
Download this document from fundsvcs and see page 10. http://fundsvcs.org/modules/wfdownloads/singlefile.php?cid=40&lid=4630 -
Jen Claudy:
We also would not enter a Pledge without something in writing (email counted) from the donor. Not a scrap of paper from a fundraiser saying that Dr. Hernandez would be requesting a gift of $5k from his DAF, but an email from Dr. Hernandez with the intention stated. Phone calls and passing comments in the hallway after a board meeting could count as a verbal pledge on the Proposal Record (Proposal Status) but no Gift Record until follow-up with the donor resulted in something written.At my previous org our business office often asked for "reverse confirmation", meaning our VP (or whoever the constituent's solicitor was) would send an email to the donor thanking them for the pledge of $XXXXX, print it out, and we would use that as documentation for the pledge. Of course, a reply from the donor confirming the pledge was best, but even our acknowledgement alone seemed to satisfy our auditors.
If the solicitor never did this, then I would create a proposal for the gift and enter whatever the "pledge" was as the Amount Expected. I would include these in reporting so that the solicitor would get credit for the gift, and we could project our funds for the year accurately, but this was safer for auditing purposes than entering a pledge.
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Melissa Graves:
Michael Sherman:
Melissa Graves:
Um - I think that DAF is using a very liberal interpretation as many would say they should not even allow the 9,900 to be allowed to go to the sponsorship. This is called bifurcation and many interpret IRS law to not allow it at all. Don't have time to add more now but there has been a lot of discussion and resources posted on fundsvcs.org which has an extensive archive and downloads section.Melissa, I think what I wrote may be a little confusing. The $9,900 is not the value of goods and services it is the public cost of the 10 seats so there is no bifurcation.
Download this document from fundsvcs and see page 10. http://fundsvcs.org/modules/wfdownloads/singlefile.php?cid=40&lid=463The DAF would send us a check for $25,000 and the donor would be recognized at that level but they would not get a table. If the donor wanted to invite 10 people to the event the donor would have to pay the full cost of the seat just the same as anyone off the street. Otherwise, the donor would not be attending the event. Is that clearer?
1
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