Comment from Vanguard Charitable
Vanguard CharitableSupportBusiness
Summary: Vanguard Charitable, a sponsor of donor-advised funds (DAFs), supports the proposed regulations but requests specific modifications to ensure practical implementation. They advocate for a non-retroactive applicability date, a clearer definition of "distribution" that excludes reasonable DAF-specific administrative expenses, and specific guidance on grant-related expenses and expenditure responsibility.
Please see the attached comment letter.