Comment from New Venture Fund and Adler & Colvin

Summary: The New Venture Fund and the law firm Adler & Colvin are opposing the proposed regulations because they believe the expanded definition of Donor Advised Funds (DAFs) would sweep in and effectively destroy the fiscal sponsorship model. They argue that the regulations impose undue compliance burdens on charitable projects that rely on donor advice and reporting, and they recommend specific exemptions to protect these philanthropic structures.