Comment from COMMUNITY FOUNDATION FOR NORTHEAST MICHIGAN
COMMUNITY FOUNDATION FOR NORTHEAST MICHIGANOpposeAdvocacy
Summary: The Community Foundation for Northeast Michigan opposes the proposed regulations, arguing that they are overly broad, create unnecessary compliance costs, and lack evidence of the abuses they aim to prevent. The organization specifically requests the removal of "personal investment advisors" from the donor-advisor definition, the inclusion of specific exceptions for advisory committees and scholarship funds, and a delayed effective date to allow for implementation.
This comment letter is written on behalf of the Community Foundation for Northeast Michigan (the “Community Foundation”) in response to Notice of Rulemaking (REG–142338-07) regarding “Taxes on Taxable Distributions from Donor Advised Funds under Section 4966”.
This letter discusses issues and concerns raised by the Community Foundation, which is a sponsoring organization with various DAF and other programs to which the Proposed Regulations would negatively impact if made final. Below is a summary of the issues and concerns provided in this comment letter response:
Expansion of the definition of “donor advisor” to include “personal investment advisor”;
Default treatment of certain “financial advisors” as “donor-advisors”;
Overly broad definition of “donor advised fund”;
Economic impact of the proposed regulations on sponsoring organizations;
Scope of the scholarship fund exception, and
Effective date.
These comments are more fully presented in the attached comment letter.