Foundations submit corporate records or minutes for the most recent 12-month period. Not all key elements require annual discussion or approval by the board. For those elements, the foundation should submit the most recent minutes that cover discussion or approval of a pertinent policy. For all submitted minutes, highlight or flag the dates and specific sections that describe the board’s approval of the policies satisfying the key elements
Material Changes: For the purposes of reconfirmation, a material change is any change in policy that necessitated the board’s approval of a new document or policy referenced in the above key elements. For example, if the organization adopted a new conflicts of interest policy, documentation of board approval of the new policy should be submitted.
For more information, review Core materials, FAQs and a glossary of important terms
Related Standards
II. Mission, Structure and Governance
II.F.1 A community foundation's governing body is responsible for the mission, strategic direction, and policies of the organization.
II.F.3 A community foundation's governing body approves and monitors policies regulating the ethical operations of the community foundation.
II.F.6 A community foundation's governing body is responsible for the financial health and sustainability of the organization, including ensuring adequate revenue, monitoring expenses, and overseeing investment and spending practices.
II.F.8 A community foundation's governing body ensures that the community foundation reflects and serves the breadth and diversity of the community.
II.F.10 A community foundation's governing body approves all grants.
III. Resource Development
III.E A community foundation adopts appropriate gift and fund acceptance policies and makes these policies available upon request.
IV. Stewardship and Accountability
IV.G A community foundation has an annual audit (or financial review, when assets total less than $5 million) that is performed by an independent public accountant, reviewed and accepted by the governing body, and made available to the public upon request.
Key Elements
- The board’s exercise of authority over mission, strategic direction, and policies. Examples may include a strategic plan, evidence of benchmarking, and/or documentation of discussion of foundation policies.
- The board’s approval of the annual budget.
- The board’s approval of all grants or the board’s delegation of this authority.
- Where the donor, the donor’s appointee, or a related party has some participation on a selection committee of a fund established to provide assistance to individuals for travel, study, or similar purposes, provide:
- the board’s approval (or the board’s delegation of that authority) of selection committees and
- the board’s approval of procedures.
- The board’s approval of the conflicts of interest policy.
- The board’s approval of the whistleblower policy.
- The board’s approval of the document retention policy (electronic and paper documents).
- The board’s approval of the confidentiality policy.
- The board’s review and acceptance of audit or financial review.
- Evidence that the foundation reflects the community’s breadth and diversity. For this key element, community foundations should submit materials demonstrating how the foundation, broadly speaking, reflects the community’s diversity through, for example, its staff, volunteers, grantees, donors, partners, vendors, etc. Sample characteristics/qualities that might be demonstrated include age, gender, race, ethnicity, geography, socioeconomic background, skill sets, profession/occupation, and political affiliation.
- Evidence of the board’s oversight of a development strategy for operations and funds.
- Documentation of the board’s approval (or the delegation of such approval) of the investment and spending policies.
The governing body has responsibility for grant approval, which may be exercised through delegation of the decision-making process. If the board has delegated the authority, provide evidence of that delegation. If the board approves some grants as part of a consent agenda, be sure to provide the materials references in the consent agenda.
The Pension Protection Act (PPA) prohibits distributions from donor advised funds to individuals. However, the act also provides an exception for grants that provide assistance to individuals for scholarships and awards. To qualify for such an exception, a fund that otherwise would be classified as a donor advised fund must, in part, have board approval of the fund's selection committee and procedures.
To fulfill the key element number 4, your foundation should identify those funds that meet the legal definition of a donor advised fund and that award grants to individuals for scholarships or awards. To continue providing scholarships or awards to individuals out of such funds, the foundation is required to make sure that the funds conform to the new requirements set forth in the PPA. Two of these requirements are the community foundation's approval of the selection committees and the board's approval of the procedures for selecting the recipients of grants. This process should be documented in the board's minutes.
Note that grants to individuals include both direct grants to individuals and grants to a charity, such as a school, for the benefit of a specified individual. As with other fund-specific key elements, the community foundation need not provide evidence for each and every fund that procedures have been followed. Rather, the community foundation must demonstrate for a representative sample of funds that it has appropriate policies in place and that it has followed them.
Please provide all corporate records or minutes for the most recent 12-month period and submit the most recent records or minutes for elements above that do not require annual discussion by the board. For example, the conflict-of-interest policy does not require annual approval, so please submit a highlighted copy of the board minutes for when the conflict-of-interest policy was approved.
Review all key elements and consider if your organization has made changes to your policies, powers or practices.
Pay special attention to key elements and core materials marked with
and a
. These represent minimum requirements for reconfirmation as well as Pension Protection Act requirements. Items marked with a
are particularly critical for those who submitted record books prior to January 2007.
Document your compliance with each of these items as well as with all other key elements where support materials may have changed.