Comment from Schell Bray PLLC

Schell Bray PLLCOpposeBusiness
Summary: Schell Bray, PLLC, a law firm representing philanthropic organizations, opposes several provisions of the proposed regulations as being overly broad, inconsistent with existing law, and potentially chilling First Amendment rights. They specifically argue against the retroactive application of the rules, the expanded definition of "donor-advisor," and the restrictive treatment of program-related investments.
See attached file(s) from Schell Bray PLLC

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