V COUNCIL on FOUNDATIONS Grants to Organizations from Donor Advised Funds: Is Expenditure Responsibility Required? I Is the grantee a Section 501(c)(3) organization? No Is the grantee a unit of No Grant is not to a charity or governmental unit. Sources for determination: • IRS Publication 78 government? Expenditure responsibility required. • IRS Business Master File • IRS Letter of Determination • Third-party provider' Yes K Yes [ Expenditure esponsibility not required. Is the grantee a private foundation? Is the grantee a Section 509(a)(1) or 509(a)(2) public charity? Is the grantee a Section 509(a)(4) public charity? Sources for determination: • IRS Publication 78 No --0. Sources for determination: No Sources for determination: • IRS Business Master File • IRS Letter of Determination • Third-party provider' • IRS Business Master File • IRS Letter of Determination • Third-party provider' • IRS Business Master File • IRS Letter of Determination • Third-party provider* Yes K Yes I Yes Is the grantee a private operating Expenditure responsibility Expenditure esponsibility foundation under Section 4942(j)(3)? not required. required. Sources for determination: • IRS Publication 78 • IRS Business Master File • IRS Letter of Determination • Third-party provider' No '[ Grant is to a private non-operating foundation. Expenditure responsibility required.** 1 Yes Expenditure esponsibility not required. No The grantee is a Section 509(a)(3) supporting organization.*** Continue analysis on next chart. ' A sponsoring organization may rely on a third-party provider if the provider pulls the information from the most currently available monthly update to the business master file. and the sponsoring organization retains a report with particular required information. • The Council on Foundations continues to recommend against grants to private non- operating foundations from donor advised funds. •