the recommendations are as the donation is made (not after which is the case with a DAF and is why the donation gift card might be difficult as the allocation comes afterward)
the programs are restricted (whereas DAFs give unrestricted funding)
A DAF let’s you donate to a fund that you ~control so you can later make unrestricted donations from to charities registered in the same country that the DAF is registered in, whereas GWWC/LTYCS/GiveWell etc can receive donations to program restrictions (eg bednets) and then make restricted grants based on the allocations of donors made at the time of donation to programs that are delivered by partners located ~anywhere.
Treasury just came out with proposed regulations defining a DAF—and I must say, I find them pretty badly done for something that has been in the works for seventeen years!
The temporal difference could be outcome-determinative here. But I’m having a hard time distinguishing gift cards from allowing the donor to amend a recommendation (e.g., the intervention was proven ineffective after the donation but before the disbursement) or to supply one if originally omitted (e.g., I forgot to fill out GiveWell’s allocation form prior to sending a check or authorizing an ACH).
I don’t think it’s inherent to a DAF that the regrant is unrestricted to specific purposes or that the donor’s options for a recommendation are pretty wide open. The statute and proposed regs tell us that an org that regrants to only a single identified organization that meets certain criteria isn’t a DAF, which suggests that an org that regrants to two or more could be.
One plausible reading of the proposed regs would be that any regranting organization that allowed donors to change recommendations, or consulted donors post-donation to the extent that consultation would rise to the level of “advisory privileges,” would be a DAF.
In other words, if a gap in time between donation and recommendation makes a regranting organization a DAF, then a lot of regranting orgs may need to tighten up their policies and practices if they don’t want to be a DAF. I’m not sure whether to blame Treasury or Congress more for this mess.
Yep. Plus:
the recommendations are as the donation is made (not after which is the case with a DAF and is why the donation gift card might be difficult as the allocation comes afterward)
the programs are restricted (whereas DAFs give unrestricted funding)
A DAF let’s you donate to a fund that you ~control so you can later make unrestricted donations from to charities registered in the same country that the DAF is registered in, whereas GWWC/LTYCS/GiveWell etc can receive donations to program restrictions (eg bednets) and then make restricted grants based on the allocations of donors made at the time of donation to programs that are delivered by partners located ~anywhere.
(Excuse my brevity, typing on the phone.)
Treasury just came out with proposed regulations defining a DAF—and I must say, I find them pretty badly done for something that has been in the works for seventeen years!
The temporal difference could be outcome-determinative here. But I’m having a hard time distinguishing gift cards from allowing the donor to amend a recommendation (e.g., the intervention was proven ineffective after the donation but before the disbursement) or to supply one if originally omitted (e.g., I forgot to fill out GiveWell’s allocation form prior to sending a check or authorizing an ACH).
I don’t think it’s inherent to a DAF that the regrant is unrestricted to specific purposes or that the donor’s options for a recommendation are pretty wide open. The statute and proposed regs tell us that an org that regrants to only a single identified organization that meets certain criteria isn’t a DAF, which suggests that an org that regrants to two or more could be.
One plausible reading of the proposed regs would be that any regranting organization that allowed donors to change recommendations, or consulted donors post-donation to the extent that consultation would rise to the level of “advisory privileges,” would be a DAF.
In other words, if a gap in time between donation and recommendation makes a regranting organization a DAF, then a lot of regranting orgs may need to tighten up their policies and practices if they don’t want to be a DAF. I’m not sure whether to blame Treasury or Congress more for this mess.