Comment from Association of Fundraising Professionals

Summary: The Association of Fundraising Professionals (AFP) provides a mixed response to the proposed regulations, expressing concern that the expanded definition of Donor-Advised Funds (DAFs) could negatively impact various types of giving and disrupt existing community foundation programs. While they support certain exemptions and the provision for equivalency determination for foreign grants, they urge caution regarding the potential for "chilling effects" on investment advisors and the lack of grandfathering for existing funds.