Comment from American Endowment Foundation
American Endowment FoundationOpposeAdvocacy
Summary: The American Endowment Foundation (AEF) opposes the proposed regulations because they expand the definition of "donor-advisor" to include personal investment advisors, which they argue will impose undue costs and deter investment expertise in donor-advised funds (DAFs). They contend that DAF sponsoring organizations are already sufficiently regulated under UPMIFA and FINRA, and that the new excise taxes will negatively impact philanthropy and small sponsoring organizations.
Please accept this submission of the American Endowment Foundation's comment letter, originally submitted February 12, 2024, which was revised to exclude an internal note to the drafter.