RESOURCES

Granting Guidelines
& Key Takeaways

AEF created the following specific grant guidelines, based on IRS regulations, that will assist you in making grant recommendations.

For full details, visit AEF’s Granting Policy.

Here are some of the most popular questions and concerns advisors and donors have.

approved charity
What’s an approved charity or cause?
AEF approves most grant recommendations to U.S. charitable organizations recognized as a 501(c)(3) organization. Potential grant recipients may include churches, educational institutions and governments.
GRANT MINIMUM
What’s the minimum grant amount allowed?
AEF has a set minimum grant amount of $250.
incidental benefits
What is okay to receive?
Coffee mugs, water bottles, keychains, T-shirts and other minimal value collectibles are acceptable to receive in conjunction with a grant from a donor-advised fund. So are intangible religious benefits, newsletters and calendars.
more than incidental benefits
What is not okay to receive?
Tuition, monetary rewards, tickets or meals are considered more than incidental benefits and cannot be accepted in conjunction with a grant from a donor-advised fund.
events and galas
Can funds be used to pay the price of attendance for charitable events, galas or ticket purchases?
If all or any portion of the attendance costs is nondeductible, a donor-advised fund may not be used to pay all or any portion of the attendance cost. This is called a bifurcated grant and is considered a more than incidental benefit to the donor-advisor. This is because the IRS considers the relief of the donor’s obligation to pay full price of a ticket/admission to a charity-sponsored event a direct benefit that is more than incidental.
 
Bifurcated grants are any grants where the total grant is split into a tax deductible and non-tax deductible portion. Grants from a donor-advised fund cannot be used to pay any portion of a donation split into tax-deductible and nondeductible portions.
 
AEF will not approve the recommendation if the receipt of any benefit (such as attendance at a charitable event) is contingent upon the grant from the donor-advised fund as part of a larger donation. In other words, a grant from a donor-advised fund cannot be used to attend an event where a portion of the attendance cost is nondeductible and/or a more than incidental benefit is received, even if the donor-advisor pays for the nondeductible portion of attendance out of their own pocket.
 
A donor may make a grant to support or sponsor a charitable event or gala and receive acknowledgement for that support.
 
However, if in exchange for the grant, the charity offers a ticket to the event (such as tickets to a sporting event) or anything more than an incidental benefit, the donor must decline it.
memberships
Can a grant be used to pay for a membership?
No. Similar to Events and Galas, grants may not be used to satisfy the cost of a membership if the membership offers more than the incidental benefits to the donor.
individual benefits
Can grants benefit an individual and not a charity or cause?
No. Grants from a donor-advised fund cannot be used to benefit an individual.

However, the grant can be used to support missionaries. If a donor recommends a grant to an eligible charity to support the missionary work of an individual who is not a direct descendant or in the immediate family to the donor, the grant will be approved with a special statement added to the letter.
scholarships
What scholarship-specific restrictions are there?
Donors may recommend a grant to a scholarship fund administered by an eligible charity or school, but it cannot be made payable to an individual.
 
The donor may indicate the grant is for the recipient of the named scholarship but not designate or reference the specific individual by name. The grant check must be sent to and made payable to the organization sponsoring the scholarship for the benefit of the scholarship fund.
 
The donor and other members of the donor’s family may participate on the independent scholarship selection committee but may not represent the majority of the committee.
fundraisers
Can a donor give to “GoFundMe” or other fundraisers?
Donors may recommend a grant for a charitable fundraising campaign, including a fundraiser where an individual is responsible for fundraising, but the individual fundraiser may not receive more than incidental benefit from the fundraising. Grants from a donor-advised fund to support a “GoFundMe” or similar online giving portal are not permissible.
pledge fulfillment
Can a grant be used to fulfill a pledge?
A grant can be used to fulfill a pledge to a charitable organization provided that:

  • AEF makes no reference to the existence of the pledge when the grant is made.
  • The donor does not receive anything more than an incidental benefit.
  • The donor does not attempt to claim an additional charitable deduction from the grant.
grant distribution
How are the grants distributed? Can a donor deliver the check?
Donors may not deliver grant checks. The preferred method of grant payment is also the quickest and most secure, by ACH transfer.

In the event a grant check is issued, it will be sent by AEF directly to the charitable organization.
dormant or unused funds
What happens if a fund goes unused or sits dormant?
If a donor-advised fund does not submit a grant recommendation for 36 months, and a long-term granting strategy has not been submitted to AEF, AEF will contact the donor-advisors and request a grant recommendation. If a grant recommendation is not submitted, AEF will make a grant to the last charity to which the donor-advised fund granted.