(Personal note, not reflecting the views of organisations Iām working for)
I assume organisations and groups considering signing up for this program have been doing donor due diligence on the legal and reputational risks of this funding opportunity, and it might be interesting to exchange information as this organisation seems new to funding projects in the EA community.
Concerning potential reputational risks, the source of funding stands out:
Where did this $200k come from?
An anonymous individual in the EA community. Manifund would love to thank them publicly, but alas, the donor wishes not to be named for now. (Itās not FTX.)
Accepting money from an anonymous donor shifts the due diligence of this donor to Manifund, so as a recipient of the funding, you are trusting them to have acted in a way that you would have when you would have decided to accept the money.
Manifund is also a co-organiser of Manifest, one of the example projects mentioned above. Being associated with it might not be in the interest of all community members. For example, this comment by Peter Wildeford had many upvotes:
Itās your right to have your conference your way, and itās others right to attend and have fun. But I think Manifest seriously underrates how much they are losing out on here by being āedgyā and āfunā, and I really donāt want to be associated with it.
While groupsā preferences will determine whether or not to apply for funding through this source, I hope organisations in the EA community have learned from FTX to do donor due diligence and consider potential reputational risks.
Itās hard to say much about the source of funding without leaking too much information; I think I can say that theyāre a committed EA who has been around the community a while, who I deeply respect and is generally excited to give the community a voice.
FWIW, I think the connection between Manifest and āreceiving funding from Manifund or EA Community Choiceā is pretty tenuous. Peter Wildeford who you quoted has both raised $10k for IAPS on Manifund and donated $5k personally towards a EA community project. This, of course, does not indicate that Peter supports Manifest to any degree whatsoever; rather, it shows that sharing a funding platform is a very low bar for association.
I assume organisations and groups considering signing up for this program have been doing donor due diligence on the legal and reputational risks of this funding opportunity
Perhaps I am being dense here butā¦ do you literally mean this? Like you actually think it is more likely than not that most groups and orgs considering signing up have been doing legal due diligence? Given the relatively small amounts of dollars at play, and the fact that your org might get literally zero, I would expect very few orgs to have done any specific legal due diligence. Charitable organisations need to be prudent with their resources and paying attourneys because of the possibility you might get a small grant that might have some unspecified legal issueāthough you are not aware of any specific red flagsādoes not seem like a good use of donor resources to me.
I donāt think most will do this, nor do I believe due diligence has to be very extensive. In most cases this is delegated to the grant maker if there is enough prior information on their activities. For individuals it can be a short online search or reaching out to people who know them. For organisations it can also be asking around if others have done this, what I was doing hereāhaving a distributed process can reduce the amount of work for all.
In this case Manifund has a lot of information online, so as others havenāt chimed in Iāll do this as an example.
Then went into their notes to find out about their compliance processes, especially concerning donor and grantee due diligence.
I found this note with āgetting a better sense of manifundās due diligence for individual projectsā linking to an ops document without any due diligence checks.
Thereās a doc about international payments and fiscal sponsorship that raises questions if they are aware of the steps needed to vet foreign entities as well as if they have the resources needed (probably not needed now but in case foreign orgs take part in the program). One remarkable quote:
Places Iām worries we (would) fall short (if we did this for LTFF):
money management/āaccounting
weāre just pretty loose about this right now: we have one big pot, and track things in our txns table in a way that basically works but we probably want to refine if we have more different pots that shouldnāt mix
I am personally bad about this in my own life as well, wary of having millions of dollars controlled by my 21 year old self + Austin whoās VERY āmove fast and break thingsā
Their main donor last year was anonymous: āWe decided to do a regranting program after we were introduced to an anonymous donor, āDā, in May 2023. D liked Future Fundās regranting setup, and wanted to fund their own regrantors, to the tune of $1.5m dollars across this year.ā
So just looking at these documents my quick takes:
Seems pretty transparent, including publishing mistakes and not so favourable notes
No red flags in terms pointing to major criminal behaviour
Yellow flag concerning taking bigger anonymous donations in combination with weak governmence and compliance processes
Overall I would see a moderate chance of the organisation failing to pay out user assets due to underfunding, seeing serious risks to their charitable status or failing IRS checks on grantmaking. However I donāt see the level of professionalism I would like to see in organisations in the EA ecosystem post FTX and OpenAI board discussions, which is why I wouldnāt want to partake in a Manifund project with an EA branding and an anonymous donor.
But Iām probably missing information and context and happy to update with further facts.
Note that Manifund know who the donor is (as do I, and can vouch that I see no red flags), the donor just doesnāt want their identity to be public. I think this is totally fine and should not be a yellow flag.
EDIT: To clarify, Iām referring to the regranting donor, who may not be the same as the community choice donor
Itās still a yellow flag in my book. A would-be grantee org would be delegating its responsibility to assess the donor for suitability to Manifund. I donāt think Manifund keeps its high degree of risk tolerance a secret (and I get the sense that it is relatively high even by EA standards). I also think it is well-understood that Manifund gives little weight to optics/āPR/āetc. And itās hard for a young charity (or other org) to say no to a really big chunk of mone, which might further increase risk tolerance over and above the Manifund folks having a higher risk tolerance out of the gate.
So the would-be grantee is giving up the opportunity to evaluate donor-associated risks using its own criteria. We canāt evaluate the actual level of risks from Manifundās major donors, but its high risk tolerance + very low optics weighting means that the risk could be high indeed. That warrants the yellow flag in my book.
OK, I donāt believe that this is a yellow flag about, eg, Manifundās judgement. But I can agree this should be a yellow flag when considering whether to accept Manifundās money.
(fwiw, I think Iām much less risk tolerant than Manifund, and disagree with several decisions theyāve made, but have zero issues with taking money from this donor)
I read Patrick as saying that he didnāt see evidence of the ālevel of professionalismā that he would find necessary to āpartake in a Manifund project with . . . an anonymous donor.ā In other words, donor anonymity requires a higher level of confidence in Manifund than would be the case with a known source of funds. I donāt read anyone as saying that taking funds from a donor whose identity is not publicly known is a strike against Manifundās judgment.
Yes, thank you for putting it this way, that was what I want to convey. For example I would be more comfortable with taking a grant funded by an anonymous donation to Open Phil as they has a history of value judgments and due diligence concerning grants and seem to be a well-run organisation in general.
I donāt know your organization, of course, but I donāt see how some of this stuff would impact the average EA CC grantee very much (at least in expectancy). The presence of allegedly weak internal controls and governance would be of much more concern to me as a potential donor to Manifund than it would be as a potential grantee.
I want to be very clear that I have not done my own due diligence on Manifund because I am not planning to donate to or seek money through them. Iām jumping to some extreme examples here merely to illustrate that the risk of certain things depends on what oneās relationship to the charity in question is.
In extreme cases, IRS can strip an organization of its recognition under IRC 501(c)(3), or another paragraph of subsection (c). This certainly has adverse consequences for the organization and its donors, the most notable of which include that donors canāt take tax deductions for donations to the ex-501(c)(3) going forward and that the nonprofit will have to pay taxes on any revenues realized as a for-profit. However, I am not coming up with any significant consequences for organizations that had received grants from the non-profit in the past, at least not off the top of my head. States can also sue to take over nonprofits, but it takes a lotāusually significant self-dealing like at the Trump Foundation or the National Rifle Associationāto trigger such a suit. They arenāt quick, and the state still has to spend the monies consistent with the charityās objectives and/āor donor intent. So consequences that sound really bad in the abstract may not be on a granteeās radar at all, because the consequences would not actually hit the grantee.
I think Manifund ās internal affairs would have some relevance to the risk that a grantee organization might not get money it was expecting. But to the extent that an organization would be seriously affected by non-receipt of an anticipated $5-$10K, the correct answer is usually going to be just not counting on the money before it hits the orgās bank account. Maybe thereās an edge case in which investing resources to better quantify that risk would be worthwhile, though. It seems unlikely here, where the time between application and expected payment is a few months.
As far as the risk of a FTX-style clawback . . . yeah, itās possible that some donations to Manifund could be fraudulent conveyances (which donāt, contrary to the name, have to involve actual fraud). Since we donāt know who the major donors are, thatās hard to assess. However, under a certain dollar amount, litigation just isnāt financially viable for the estate. That being said, many of us (including myself) would feel an ethical obligation to return donations in some cases involving actual capital-F Fraud. So that would be a relevant consideration, but the base rate is low enough that itās hard to justify spending a lot of time on this at moderate donation levels.
It sounds like āDā is anonymous in the sense that Manifund isnāt going to tell the world who they are, but not in the sense that their identity is unknown to Manifund (or IRS, which would receive the information on a non-public schedule to Form 990). Although extreme reliance on a single non-disclosed donor is still a yellow flag, that would be an important difference.
All that is to say that I expect that the significant majority of organizations would not find those yellow flags enough to preclude participation at the funding level at play here. (Whether they would find the connection between Manifund and Manifest a barrier is not considered here.) Nor would I expect most orgs to have done more than a cursory check at the $5-10K level. But again, youāre the expert on your organization and I donāt want to imply you are making the wrong decision for your own org!
Thank you for that assessment! I agree that the legal risk is low, and for this reason, I wouldnāt refrain from participating in the project.
On the reputation side, I might have updated too much from FTX. As an EA meta organisation, I want a higher bar for taking donations than a charity working on the object level. This would be especially the case if I took part in a project that is EA branded and asked me to promote the project to get funding. Suppose Manifund collapses or the anonymous donor is exposed as someone whose reputation would keep people from joining the community. In that case, I think it would reflect poorly on the ability of the community overall to learn from FTX and install better mechanisms to identify unprofessional behaviour.
Perhaps the crux is whether I would actually lose people in our target groups in one of the scenario cases or if the reputational damage would be only outside of the target group. In the last Community Health Survey, 46% of participants at least somewhat agreed with having a desire for changes post-FTX. Leadership and scandals were two of the top areas mentioned, which I interpret as community members wanting fewer scandals and better management of organisations. Vetting donors is one way that leaders can learn from FTX and reduce risk. But there is also the risk of losing out to donations.
I understand your concern, thanks for flagging this!
To add a perspective: As a former EA movement builder who thought about this a bunch, the reputation risks of accepting donations from a platform by an organization that also organizes events that some people found too āedgyā seem very low to me. Iād encourage EA community organizers to apply, if the money would help them do more good, and if theyāre concerned about risks, ask CEA or other senior EA community organizers for advice.
Generally, I feel many EAs (me included) lean towards being too risk-averse and hesitant to take action than too risk-seeking (see omission bias). Iām also a bit worried about increasing pressure on community organizers not to take risks and worry about reputation more than they need to. This is just a general impression, I might be wrong, and I still think there are many organizers who might be not sufficiently aware of the risks, so thanks for pointing this out!
Accepting money from an anonymous donor shifts the due diligence of this donor to Manifund, so as a recipient of the funding, you are trusting them to have acted in a way that you would have when you would have decided to accept the money.
This is an interesting and insightful viewpoint, but Iām not sure how it applies at the expected donation size. Although the size of the potential grant oneās organization might receive is unknown, the use of a quadratic funding mechanism and wide eligibility criteria makes me think most potential applicants are looking at an expected value of funding of $10,000 or less. I donāt think it is the current standard of care in the philanthropic sector to generally vet donations of this size (especially to the extent you think they are likely to be one-off). So most orgs wouldāreasonably! -- just cash a ~$5,000 check that came in without investigating the drawer of the check. The exception would be a donor-identity problem that was obvious on its face; I expect most orgs would investigate and likely shred a check if drawn on the account of one of SBFās immediate family members! But otherwise, it seems that the amount of due diligence investigation one is arguably ādelegatingā to Manifund is close to zero.
I expect the amount of due diligence to vary based on funding, project size, and public engagement levels. Even a small amount might be a significant part of the yearly income of a small EA group that might have to deal with increased scrutiny or discussions based on the composition of its existing and potential group members.
(Personal note, not reflecting the views of organisations Iām working for)
I assume organisations and groups considering signing up for this program have been doing donor due diligence on the legal and reputational risks of this funding opportunity, and it might be interesting to exchange information as this organisation seems new to funding projects in the EA community.
Concerning potential reputational risks, the source of funding stands out:
Accepting money from an anonymous donor shifts the due diligence of this donor to Manifund, so as a recipient of the funding, you are trusting them to have acted in a way that you would have when you would have decided to accept the money.
Manifund is also a co-organiser of Manifest, one of the example projects mentioned above. Being associated with it might not be in the interest of all community members. For example, this comment by Peter Wildeford had many upvotes:
While groupsā preferences will determine whether or not to apply for funding through this source, I hope organisations in the EA community have learned from FTX to do donor due diligence and consider potential reputational risks.
Itās hard to say much about the source of funding without leaking too much information; I think I can say that theyāre a committed EA who has been around the community a while, who I deeply respect and is generally excited to give the community a voice.
FWIW, I think the connection between Manifest and āreceiving funding from Manifund or EA Community Choiceā is pretty tenuous. Peter Wildeford who you quoted has both raised $10k for IAPS on Manifund and donated $5k personally towards a EA community project. This, of course, does not indicate that Peter supports Manifest to any degree whatsoever; rather, it shows that sharing a funding platform is a very low bar for association.
Thanks. I think linking to your internal notes might have helped; at least it gave me more insight and answered questions.
Perhaps I am being dense here butā¦ do you literally mean this? Like you actually think it is more likely than not that most groups and orgs considering signing up have been doing legal due diligence? Given the relatively small amounts of dollars at play, and the fact that your org might get literally zero, I would expect very few orgs to have done any specific legal due diligence. Charitable organisations need to be prudent with their resources and paying attourneys because of the possibility you might get a small grant that might have some unspecified legal issueāthough you are not aware of any specific red flagsādoes not seem like a good use of donor resources to me.
I donāt think most will do this, nor do I believe due diligence has to be very extensive. In most cases this is delegated to the grant maker if there is enough prior information on their activities. For individuals it can be a short online search or reaching out to people who know them. For organisations it can also be asking around if others have done this, what I was doing hereāhaving a distributed process can reduce the amount of work for all.
In this case Manifund has a lot of information online, so as others havenāt chimed in Iāll do this as an example.
First I had a cursory look at the Manifund website reading through their board of director meeting notes. What stood out:
āTechnically underwater, after pending Manifold for Charity donationsā
Seems like they had -$42,789
In the overview sheet the deficit is gone now but probably because asset numbers were not updated
Seems like the only grant in the last year was from SFF, so not sure how extensive grantmaker oversight was
More details about their structure in the SFF application
Seemingly no independent board oversight
Then went into their notes to find out about their compliance processes, especially concerning donor and grantee due diligence.
I found this note with āgetting a better sense of manifundās due diligence for individual projectsā linking to an ops document without any due diligence checks.
Thereās a doc about international payments and fiscal sponsorship that raises questions if they are aware of the steps needed to vet foreign entities as well as if they have the resources needed (probably not needed now but in case foreign orgs take part in the program). One remarkable quote:
There is a process for selecting grantees
Their main donor last year was anonymous: āWe decided to do a regranting program after we were introduced to an anonymous donor, āDā, in May 2023. D liked Future Fundās regranting setup, and wanted to fund their own regrantors, to the tune of $1.5m dollars across this year.ā
So just looking at these documents my quick takes:
Seems pretty transparent, including publishing mistakes and not so favourable notes
No red flags in terms pointing to major criminal behaviour
Yellow flag concerning taking bigger anonymous donations in combination with weak governmence and compliance processes
Overall I would see a moderate chance of the organisation failing to pay out user assets due to underfunding, seeing serious risks to their charitable status or failing IRS checks on grantmaking. However I donāt see the level of professionalism I would like to see in organisations in the EA ecosystem post FTX and OpenAI board discussions, which is why I wouldnāt want to partake in a Manifund project with an EA branding and an anonymous donor.
But Iām probably missing information and context and happy to update with further facts.
Note that Manifund know who the donor is (as do I, and can vouch that I see no red flags), the donor just doesnāt want their identity to be public. I think this is totally fine and should not be a yellow flag.
EDIT: To clarify, Iām referring to the regranting donor, who may not be the same as the community choice donor
Itās still a yellow flag in my book. A would-be grantee org would be delegating its responsibility to assess the donor for suitability to Manifund. I donāt think Manifund keeps its high degree of risk tolerance a secret (and I get the sense that it is relatively high even by EA standards). I also think it is well-understood that Manifund gives little weight to optics/āPR/āetc. And itās hard for a young charity (or other org) to say no to a really big chunk of mone, which might further increase risk tolerance over and above the Manifund folks having a higher risk tolerance out of the gate.
So the would-be grantee is giving up the opportunity to evaluate donor-associated risks using its own criteria. We canāt evaluate the actual level of risks from Manifundās major donors, but its high risk tolerance + very low optics weighting means that the risk could be high indeed. That warrants the yellow flag in my book.
OK, I donāt believe that this is a yellow flag about, eg, Manifundās judgement. But I can agree this should be a yellow flag when considering whether to accept Manifundās money.
(fwiw, I think Iām much less risk tolerant than Manifund, and disagree with several decisions theyāve made, but have zero issues with taking money from this donor)
I read Patrick as saying that he didnāt see evidence of the ālevel of professionalismā that he would find necessary to āpartake in a Manifund project with . . . an anonymous donor.ā In other words, donor anonymity requires a higher level of confidence in Manifund than would be the case with a known source of funds. I donāt read anyone as saying that taking funds from a donor whose identity is not publicly known is a strike against Manifundās judgment.
Yes, thank you for putting it this way, that was what I want to convey. For example I would be more comfortable with taking a grant funded by an anonymous donation to Open Phil as they has a history of value judgments and due diligence concerning grants and seem to be a well-run organisation in general.
Sure, this seems reasonable
I donāt know your organization, of course, but I donāt see how some of this stuff would impact the average EA CC grantee very much (at least in expectancy). The presence of allegedly weak internal controls and governance would be of much more concern to me as a potential donor to Manifund than it would be as a potential grantee.
I want to be very clear that I have not done my own due diligence on Manifund because I am not planning to donate to or seek money through them. Iām jumping to some extreme examples here merely to illustrate that the risk of certain things depends on what oneās relationship to the charity in question is.
In extreme cases, IRS can strip an organization of its recognition under IRC 501(c)(3), or another paragraph of subsection (c). This certainly has adverse consequences for the organization and its donors, the most notable of which include that donors canāt take tax deductions for donations to the ex-501(c)(3) going forward and that the nonprofit will have to pay taxes on any revenues realized as a for-profit. However, I am not coming up with any significant consequences for organizations that had received grants from the non-profit in the past, at least not off the top of my head. States can also sue to take over nonprofits, but it takes a lotāusually significant self-dealing like at the Trump Foundation or the National Rifle Associationāto trigger such a suit. They arenāt quick, and the state still has to spend the monies consistent with the charityās objectives and/āor donor intent. So consequences that sound really bad in the abstract may not be on a granteeās radar at all, because the consequences would not actually hit the grantee.
I think Manifund ās internal affairs would have some relevance to the risk that a grantee organization might not get money it was expecting. But to the extent that an organization would be seriously affected by non-receipt of an anticipated $5-$10K, the correct answer is usually going to be just not counting on the money before it hits the orgās bank account. Maybe thereās an edge case in which investing resources to better quantify that risk would be worthwhile, though. It seems unlikely here, where the time between application and expected payment is a few months.
As far as the risk of a FTX-style clawback . . . yeah, itās possible that some donations to Manifund could be fraudulent conveyances (which donāt, contrary to the name, have to involve actual fraud). Since we donāt know who the major donors are, thatās hard to assess. However, under a certain dollar amount, litigation just isnāt financially viable for the estate. That being said, many of us (including myself) would feel an ethical obligation to return donations in some cases involving actual capital-F Fraud. So that would be a relevant consideration, but the base rate is low enough that itās hard to justify spending a lot of time on this at moderate donation levels.
It sounds like āDā is anonymous in the sense that Manifund isnāt going to tell the world who they are, but not in the sense that their identity is unknown to Manifund (or IRS, which would receive the information on a non-public schedule to Form 990). Although extreme reliance on a single non-disclosed donor is still a yellow flag, that would be an important difference.
All that is to say that I expect that the significant majority of organizations would not find those yellow flags enough to preclude participation at the funding level at play here. (Whether they would find the connection between Manifund and Manifest a barrier is not considered here.) Nor would I expect most orgs to have done more than a cursory check at the $5-10K level. But again, youāre the expert on your organization and I donāt want to imply you are making the wrong decision for your own org!
Thank you for that assessment! I agree that the legal risk is low, and for this reason, I wouldnāt refrain from participating in the project.
On the reputation side, I might have updated too much from FTX. As an EA meta organisation, I want a higher bar for taking donations than a charity working on the object level. This would be especially the case if I took part in a project that is EA branded and asked me to promote the project to get funding. Suppose Manifund collapses or the anonymous donor is exposed as someone whose reputation would keep people from joining the community. In that case, I think it would reflect poorly on the ability of the community overall to learn from FTX and install better mechanisms to identify unprofessional behaviour.
Perhaps the crux is whether I would actually lose people in our target groups in one of the scenario cases or if the reputational damage would be only outside of the target group. In the last Community Health Survey, 46% of participants at least somewhat agreed with having a desire for changes post-FTX. Leadership and scandals were two of the top areas mentioned, which I interpret as community members wanting fewer scandals and better management of organisations. Vetting donors is one way that leaders can learn from FTX and reduce risk. But there is also the risk of losing out to donations.
I understand your concern, thanks for flagging this!
To add a perspective: As a former EA movement builder who thought about this a bunch, the reputation risks of accepting donations from a platform by an organization that also organizes events that some people found too āedgyā seem very low to me. Iād encourage EA community organizers to apply, if the money would help them do more good, and if theyāre concerned about risks, ask CEA or other senior EA community organizers for advice.
Generally, I feel many EAs (me included) lean towards being too risk-averse and hesitant to take action than too risk-seeking (see omission bias). Iām also a bit worried about increasing pressure on community organizers not to take risks and worry about reputation more than they need to. This is just a general impression, I might be wrong, and I still think there are many organizers who might be not sufficiently aware of the risks, so thanks for pointing this out!
This is an interesting and insightful viewpoint, but Iām not sure how it applies at the expected donation size. Although the size of the potential grant oneās organization might receive is unknown, the use of a quadratic funding mechanism and wide eligibility criteria makes me think most potential applicants are looking at an expected value of funding of $10,000 or less. I donāt think it is the current standard of care in the philanthropic sector to generally vet donations of this size (especially to the extent you think they are likely to be one-off). So most orgs wouldāreasonably! -- just cash a ~$5,000 check that came in without investigating the drawer of the check. The exception would be a donor-identity problem that was obvious on its face; I expect most orgs would investigate and likely shred a check if drawn on the account of one of SBFās immediate family members! But otherwise, it seems that the amount of due diligence investigation one is arguably ādelegatingā to Manifund is close to zero.
I expect the amount of due diligence to vary based on funding, project size, and public engagement levels. Even a small amount might be a significant part of the yearly income of a small EA group that might have to deal with increased scrutiny or discussions based on the composition of its existing and potential group members.