Driving Impact Through Donor Advised Funds

Impact investing includes a broad spectrum of tools and emerging strategies. The oldest, most established tool is the program-related investment (“PRI”). For over 30 years, PRIs have been used by private foundations to increase programmatic impact and to leverage more of their asset base. Federal tax code provides clear guidance for private foundations on definition and qualification of program-related investments. Namely, the primary purpose must be charitable and not for investment gain. There is much written on the art and craft of PRIs. Less clear, however, in both the tax code and literature is the practice of making program-related investments from donor advised funds (“DAFs”). Past precedents and legal guidance are sparse. Despite this, donor interest in all forms of impact investing is growing and, in response, interest is also growing among community foundations and other types of DAF providers in helping donors achieve their philanthropic goals. These organizations are increasingly viewing impact investing through donor advised funds as a strategy for deeper donor engagement and greater programmatic impact.