32: Policy or Documented Procedures for Due Diligence

Confirming
Reconfirming

Community foundations submit their due diligence process to ensure that grants will be used for charitable purposes. The foundation should provide its process for determining which grants from funds legally defined as donor advised funds require the exercise of expenditure responsibility. The procedure for exercising expenditure responsibility, when required for grants from these funds, should also be submitted.

Key Elements 
  1. Description of the process for ensuring that the grant will be used for charitable purposes consistent with the nature of the grant and the nature of the fund from which the grant is made (Information submitted should address grants from all fund types).
  2. A process for determining which grants from funds legally defined as donor advised funds require the exercise of expenditure responsibility.*
  3. A policy or procedure for exercising expenditure responsibility when required for grants from funds legally defined as donor advised.*

*Pension Protection Act requirement

Material Changes

For the purposes of reconfirmation, a material change is any change that affects any of the key elements. If you have had material changes, you will need to resubmit any documentation related to material changes. Review all key elements for this requirement by clicking the "confirming" toggle in the upper left corner of this page.

Core Materials 

Required Document

  • Due diligence policy*

*Pension Protection Act requirement

No documents required for reconfirmation unless your original binder submission was prior to August 2006 and you have yet to meet the Pension Protection Act requirements.