Comment from Venn Foundation

Summary: The Venn Foundation, a 501(c)(3) public charity and DAF sponsoring organization, argues that the proposed rules create confusion by removing established standards for Program-Related Investments (PRIs) and suggests incorporating existing PRI definitions for clarity. They also oppose the proposed retroactive applicability date, requesting a future applicability date and grandfathering provisions to allow for a smooth transition and to preserve existing charitable impacts.