Investments & Wealth Foundation Gift Acceptance Policy

Purpose

This policy is intended to ensure that all gifts to, or for the use of, the Investments & Wealth Foundation are structured to support the Foundation’s charitable purposes and do not create burdens, risks, or restrictions inconsistent with those purposes.

The Foundation seeks to respond promptly and affirmatively when possible, to gift opportunities. Because some gifts involve legal, tax, operational, or reputational considerations, each gift must be reviewed in accordance with this policy before acceptance.

Scope

This policy applies to all gifts proposed for the Foundation, including current gifts, deferred gifts, restricted gifts, and gifts of non-cash property.

Management may adopt procedures to implement this policy, provided those procedures are consistent with this policy and any actions reserved to the Board or Finance & Investment Committee.

Standards of Conduct

The Foundation will comply with its conflict-of-interest policies and all applicable laws in evaluating and accepting gifts.

Staff, directors, and volunteers involved in gift planning or acceptance should act ethically, avoid conflicts of interest, and encourage prospective donors to consult their own legal, tax, and financial advisors regarding the consequences of any proposed gift.

Acceptance Authority

The Foundation reserves the right to refuse any gift.

Authority to approve the gift acceptance policy shall rest with the Foundation’s Board of Directors. The delegation of authority for gift acceptance is as follows:

Gift Type

Authorized Approvers

Notes

Unrestricted cash and cash equivalents, publicly traded securities, unrestricted bequests

Director level and above Foundation Staff

All gifts with restrictions, gifts with questionable donor or source issues, Gifts of life insurance proceeds

Foundation Treasurer

Includes gifts where it is unclear whether:

  • Donor has sufficient legal title to the property.

  • Donor is legally competent to make the gift.

  • Any legal, tax, environmental, or other impediment exists.

  • The gift could expose the Foundation to liability, reporting obligations, or excessive administrative burden.

Split beneficiary designations, any gift type specifically prohibited by the policy; endowments

Foundation Board of Directors

Gifts Requiring Board Approval

The Foundation will not normally accept the following types of gifts:

  • Non-publicly traded securities.

  • Cryptocurrency or other digital assets.

  • Real property.

  • Tangible personal property.

Interests in privately held entities; restricted or non-publicly traded securities; intellectual property; mineral, royalty or contractual rights; promissory notes; partial interests in property; and other assets for which there is no readily available market, reliable valuation, or reasonable means of disposition.

  • Assets involving significant holding costs, liabilities, transfer restrictions, capital calls, environmental exposure, or administrative burden.

  • Gifts from a person or entity whose reputation could damage the credibility of the Foundation and hinder its mission.

The Foundation may consider an exception only if the gift is reviewed in advance and approved in writing by the Foundation’s Board of Directors, as applicable under this policy.

Cash and Cash Equivalents

Cash gifts, checks, money orders, wires, and similar cash equivalents may be accepted if they are consistent with this policy and any internal procedures established by management.

All checks should be made payable to the Foundation and must not be made payable to any employee, agent, or volunteer for the credit of the Foundation.

A gift of physical USD or Foreign currency exceeding $10,000 USD, whether received in a single transaction or a series of related transactions, will be subject to enhanced donor identification, source-of-funds review, and other due diligence required by Foundation procedures before acceptance.

For purposes of this provision, physical currency does not include checks, cashier's checks, money orders, wire transfers, ACH transfers, credit or debit card payments, or other electronic forms of payment.

The Foundation will not knowingly accept a gift that would violate applicable economic sanctions or other applicable law. Management will maintain donor due-diligence and sanctions-screening procedures appropriate to the nature, amount, source, and circumstances of gifts received.

Qualified charitable distributions from IRAs may be accepted if they are made in compliance with applicable law and internal procedures.

Publicly Traded Securities

The Foundation may accept publicly traded securities, including mutual fund shares and bonds, for which a readily available market exists.

Unless otherwise approved in writing, such securities should be liquidated promptly after receipt by the Foundation’s Treasurer. No employee, agent, or volunteer may promise a donor that a specific security will be retained by the Foundation.

Restricted Gifts

Restricted gifts will be accepted only if the restriction is consistent with the Foundation’s mission, governing documents, and applicable law.

Any donor restriction must be clearly documented and approved by the Foundation’s Treasurer before acceptance. The Foundation may decline any restriction that is impractical, vague, excessively burdensome, or inconsistent with the Foundation’s purposes.

Endowed Funds and Scholarships

Endowed funds may be established only with advance approval of the Foundation’s Board of Directors.

Unless otherwise approved in writing, the minimum gift amount to establish a new endowed fund shall be $40,000.

Endowed scholarships may be created only if the donor executes a fund agreement approved by the Foundation and the restriction is consistent with the Foundation’s mission, selection criteria, and administration procedures as they may be amended from time to time.

Planned Gifts

Bequests

Bequests are encouraged.

If a prospective donor asks whether the Foundation would accept a particular type of property through a will, trust, beneficiary designation, or other deferred gift arrangement, any response must be consistent with this policy and should not promise acceptance of property that the Foundation would not ordinarily accept.

If property passing from a decedent’s estate is not acceptable under this policy, the Foundation may refuse the gift, and legal counsel or authorized Foundation representatives may communicate that decision to the estate.

Life Insurance

A donor may name the Foundation as beneficiary of all or a portion of a life insurance policy on the donor’s life, subject to any administrative requirements the Foundation establishes.

The Foundation will not accept ownership of a life insurance policy unless the policy is reviewed and approved by the Foundation’s treasurer in advance under this policy.

Split-Beneficiary Designations

The Foundation may accept a gift or beneficiary designation naming multiple charitable beneficiaries only if the Foundation is designated to receive at least 50 percent of the charitable remainder or other charitable interest, unless the Foundation’s Board approves a different allocation in writing.

Any split-beneficiary arrangement must be approved in advance by the Foundation’s Board of Directors, as applicable.

Professional Fees and Commissions

The Foundation will not pay any finder’s fee or commission to any person in connection with the solicitation or completion of a gift.

The Foundation may pay reasonable professional fees for services directly related to the completion of a gift only if those fees are approved in advance by the Foundation’s Board of Directors or another authority specifically designated by the Board.

Professional fees may include legal fees, appraisal fees, accounting fees, and other fees necessary to complete the gift, provided they are reasonable, documented, and not contingent on the amount of the gift.

If the Foundation pays fees that would otherwise be the donor’s responsibility, the donor should be advised that such payment may create taxable income to the donor or other tax consequences.

If advisors retained by the Foundation provide services or advice in connection with a gift, the donor must be informed that those advisors are acting for the Foundation and not for the donor.

Anonymous Gifts

Donors may request anonymity in public recognition materials, including the Foundation’s website and annual report.

However, the Foundation must know the identity of the donor and confirm that the donor has lawful authority to make the gift. The Foundation will maintain donor information in confidence to the extent permitted by law and consistent with its recordkeeping, tax, audit, and compliance obligations.

Reputational and Naming Considerations

If at any time a donor or their name may compromise the public trust or the reputation of the Foundation, including acts of moral turpitude, the Foundation’s Board of Directors has the right to remove the name from an endowed scholarship or return the donations received from that donor to the extent legally permissible and consistent with the applicable gift agreement.

Exceptions

Any exception to this policy must be approved in writing by the Foundation’s Board of Directors.

Staff may review unusual gift proposals and may recommend approval, but staff may not approve exceptions unless expressly authorized to do so by the Foundation’s Board of Directors.

Gift Acknowledgment and Reporting

The Foundation will provide written acknowledgments for gifts as required by law and internal policy.

For gifts of cash or cash equivalents, the acknowledgment will include:

  • The amount of the gift.

  • The date received.

  • A statement that no goods or services were provided in exchange for the gift.

For non-cash gifts, the acknowledgment will include:

  • A description of the donated property.

  • The date received.

  • A statement that no goods or services were provided in exchange for the gift, if applicable, or a description and good-faith estimate of any goods or services provided.

The Foundation will not state a value for non-cash gifts in its acknowledgment.

Appraisals are the donor’s responsibility. If required, the donor is responsible for preparing and filing any applicable donor tax forms. The Foundation will sign donor forms when required and will file any Foundation tax forms required by law, including forms required if the Foundation disposes of qualifying donated property within the applicable reporting period.

Recordkeeping and Administration

The Foundation will maintain gift records consistent with legal, audit, tax, and administrative requirements.

Management may adopt procedures governing receipt, review, deposit, acknowledgment, and reporting of gifts, provided those procedures remain consistent with this policy.

Enforcement

Violations of this policy by employees may result in disciplinary action under the applicable employee handbook or policies.

Violations by directors or volunteers may result in removal from a board, committee, or other service role, subject to governing documents and applicable law.

Policy Review

This policy should be reviewed biennially and updated as needed to reflect changes in law, tax guidance, Foundation operations, or Board governance.

Approved by IWI Board 8/2026