Comment from Renaissance Charitable Foundation Inc.

Summary: Renaissance Charitable Foundation Inc., a sponsoring organization for over 20,000 donor-advised funds (DAFs), opposes the proposed regulations because they increase compliance costs, create unreasonable administrative burdens, and expand the definition of DAFs beyond what is authorized by the Internal Revenue Code. Specifically, they argue against the inclusion of "Personal Investment Advisors" as donor advisors and request a multi-year transition period to implement the changes.