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September 2017 (2 posts)

Trend to Watch: Using SDGs to Improve Foundation Transparency
September 19, 2017

(Janet Camarena is director of transparency initiatives at Foundation Center. )

Janet Camarena PhotoAs Foundation Center's director of transparency initiatives, one of the most interesting parts of my job is having the opportunity to play "transparency scout," regularly reviewing foundation websites for signs of openness in what is too often a closed universe. Some of this scouting leads to lifting up practices that can be examples for others on our Transparency Talk blog, sometimes it leads to a new transparency indicator on our assessment framework, and sometimes we just file it internally as a "trend to watch. "

Today, it's a combination of all three; we are using this blog post to announce the launch of a new, "Trend to Watch" indicator that signals an emerging practice: the use of the Sustainable Development Goals to improve how foundations open up their work to the world.

Sustainable Development GoalsThe United Nations' Sustainable Development Goals (SDGs), otherwise known as the Global Goals, are a universal call to action to end poverty, protect the planet and ensure that all people enjoy peace and prosperity. There are a total of 17 goals, such as ending poverty, zero hunger, reduced inequalities, and climate action. Written deliberately broad to serve as a collective playbook that governments and private sector alike can use, they can also serve as a much needed shared language across philanthropy and across sectors to signal areas of common interest, and measure shared progress.

And let's face it, as foundation strategies become increasingly specialized and strategic, explaining the objectives and the nuances can become a jargon-laden minefield that can make it difficult and time consuming for those on the outside to fully understand the intended goal of a new program or initiative. The simplicity of the SDG iconography cuts through the jargon so foundation website visitors can quickly identify alignment with the goals or not, and then more easily determine whether they should devote time to reading further. The SDG framework also provides a clear visual framework to display grants and outcomes data in a way that is meaningful beyond the four walls of the foundation.

Let's take a look at how some foundation websites are using the SDGs to more clearly explain their work:

Silicon Valley Community Foundation (SVCF)

One of my favorite examples is from a simple chart the Silicon Valley Community Foundation shared on its blog, because it specifically opens up the work of its donor-advised funds using the SDGs. Donor-advised funds are typically not the most transparent vehicles, so using the SDGs as a framework to tally how SVCF's donor-advised funds are making an impact is particularly clever, refreshing, and offers a new window into a fast-growth area of philanthropy.

A quick glance at the chart reveals that quality education, good health and well-being, and sustainable cities and communities are the most common priorities among Silicon Valley donors.

GHR Foundation

A good example of how the SDGs can be used as a shared language to explain the intended impact of a grant portfolio is from GHR Foundation in Minnesota. I also like this example because it shows how the SDGs can be effectively used in both global and domestic grant portfolios. GHR uses the SDG iconography across all of its portfolios, as sidebars on the pages that describe foundation strategies. GHR's "Children in Families" is a core foundation grantmaking strategy that addresses children and families in need on a global scale. The portfolio name is a broad one, but by including the SDG iconography, web visitors can quickly understand that GHR is using this program area to address poverty, hunger, as well as lead to outcomes tied to health and well-being:

GHR is also able to use the SDG framework to create similar understanding of its domestic work. Below is an example from its Catholic Schools program serving the Twin Cities:

Through the visual cues the icons provide, I can quickly determine that in addition to aligning with the quality education goal, that this part of GHR's portfolio also addresses hunger and economically disadvantaged populations through its education grantmaking. This could also signal that the grantmaker interprets education broadly and supports the provision of wrap-around services to address the needs of low-income children as a holistic way of addressing the achievement gap. That's a lot of information conveyed with three small icons!

Tableau Foundation

The most sophisticated example comes to us from the tech and corporate grantmaking worlds--the Tableau Foundation. Tableau makes data visualization software, so using technology as a means to improve transparency is a core approach, and they are using their own grantmaking as an example of how you can use data to tell a compelling visual story. Through the interactive "Living Annual Report" on its website, Tableau regularly updates its grantmaking tallies and grantee data so web visitors have near real-time information. One of the tabs on the report reveals the SDG indicators, providing a quick snapshot of how Tableau's grantmaking, software donations, and corporate volunteering align with the SDGs.

As you mouse over any bar on the left, near real-time data appears, tallying how much of Tableau's funding has gone to support each goal. The interactive bar chart on the right lists Tableau's grantees, and visitors can quickly see the grantee list in the context of the SDGs as well as know the specific scale of its grantmaking to each recipient.

If you're inspired by these examples, but aren't sure how to begin connecting your portfolio to the Global Goals, you can use the SDG Indicator Wizard to help you get started. All you need to do is copy and paste your program descriptions or the descriptive language of a sample grant into the Wizard and its machine-learning tools let you know where your grantmaking lands on the SDG matrix. It's a lot of fun – and great place to start learning about the SDGs. And, because it transforms your program language into the relevant SDG goals, indicator, and targets, it may just provide a shortcut to that new strategy you were thinking of developing!

What more examples? The good news is we're also tracking SDGs as a transparency indicator at "Who Has Glasspockets?" You can view them all here. Is your foundation using the SDGs to help tell the story of your work? We're always on the lookout for new examples, so let us know and your foundation can be the next trend setter in our new Trend to Watch.

-- Janet Camarena

Is Your 990-PF Working Against You?
September 12, 2017

Lauren Haverlock has practiced public accounting since 2004. As a senior manager at Moss Adams LLP, she provides compliance and consulting services to all types of exempt organizations, including public charities and private foundations.

This post is part of a Transparency Talk series, presented in partnership with the Conrad N. Hilton Foundation, examining the importance of the 990-PF, the informational tax form that foundations must annually file. The series will explore the implications of the open 990; how journalists and researchers use the 990-PF to understand philanthropy; and its role, limitations, and potential as a communications tool.

Join us at a session about the Open 990PF in partnership with Grantmakers of Oregon and Southwest Washington. Learn more or register here.

Lauren HaverlockAs a CPA specializing in tax exempt organizations, the annual 990-PF form that private foundations must file with the Internal Revenue Service (IRS) is the source of many questions I receive. And now that this data is not just publicly available, but open, it is wise for us all to take a closer look at whether your 990-PF may unintentionally be working against you.

Of course, the IRS has been gathering data on 990-PF filers for years. It has used this data to better identify and investigate anomalous and non-compliant private foundations. But now, all electronically filed Form 990-PF data is available to the general public in machine readable formats opening up the investments, portfolio performance, grant recipients, expenses, and transactions of foundations like never before.

Now that this information is publicly available in machine readable format, it can be easily aggregated to provide valuable insight into the industry as a whole. It can also highlight outliers. Ultimately, the availability of this data provides a window into private foundations, many of which were previously used to operating outside the public eye. As Glasspockets has reported, currently only 10% of U.S. foundations even have a website, so if your foundation is among the 90% that do not, that means that your 990-PF is the only source of intelligence about your organization. 

In the new world of readily available machine-readable Form 990s, private foundations will want to verify their tax filings—the source of their data—are prepared completely and accurately. Common mistakes to watch out for when filing the Form 990-PF are detailed in this article.

Transactions

Private foundations face more burdensome regulations on investments and expenses than 501(c)(3) public charities:

  • Restrictions on how money is spent
  • Requirements as to how much money is used for charitable purposes
  • Rules regarding how endowments can be invested

The consequences for noncompliance in regards to the above transactions can range from excise-tax penalties assessed on the foundation or its managers to revocation of exempt status.

Specific items to be aware of include the following:

  • Prohibited transactions with a disqualified person, including trustees, directors, and foundation managers as well as certain family members and businesses of the aforementioned.
  • Failure to meet the minimum distribution requirement in a previous year
  • Excess business holdings of an active trade or business
  • Risky asset investments that could jeopardize a foundation’s charitable purpose (for example, not having a diversified portfolio of investments)
  • Certain types of expenditures, such as foreign grants, grants to for-profit entities, unapproved scholarships, or lobbying and political activities, are either prohibited outright or require extra diligence to be permissible. 

For example, foundations are permitted to reasonably compensate a disqualified person for personal services. And an organization can grant funds to foreign or for-profit organizations if expenditure responsibility is exercised. And more details about what is permissible in regards to political funding appears below. But the main point here is just the affirmation of these closely scrutinized transactions could raise the risk profile of a private foundation.

Net Investment Income

Although considered tax-exempt, private foundations are still required to pay an excise tax at a rate of 1% or 2% of the income they generate. As such, investment income is of intense focus when foundations file their tax returns. Foundations should remember that the calculation of taxable income should be undertaken with the same tax-reduction mindset that for profit entities and individuals undertake.   

“Ultimately, the availability of this data provides a window into private foundations, many of which were previously used to operating outside the public eye.”

The Form 990-PF reports income both on a book and on a tax basis on Page one. A foundation should ensure that it is properly capturing all taxable income from all sources and not simply assuming that taxable income is the amount reported on their financial statements. For example, private foundations with “alternative investments,” including private equity, hedge funds, managed futures, real estate, commodities and derivatives contracts, could receive a Schedule K-1 from their investments. Flow-through income from that Schedule K-1 should be reported in the foundation’s tax-basis income statement. 

Additionally, any excise tax a foundation pays could bring negative attention. If an entity consistently pays the higher excise tax of 2%, it could lead donors to question why the foundation is giving money to the IRS in the form of taxes rather than providing grants.  

 

Balance-Sheet Investments

Private foundations are required to report the details of their investments, including the number of shares and types of publicly traded stock held. Reporting this can often be burdensome and feel invasive, but failure to include this information could result in an incomplete Form 990-PF. An incomplete Form 990-PF is deemed to have never been filed in the first place, which could result in late-filing penalties or revocation of exemption if it occurs three years in a row.

Lobbying and Political Activities

Private foundations are prohibited from undertaking any lobbying or political activities, unlike 501(c)(3) public charities, which are permitted to undertake limited lobbying activities. However, not all actions related to politics are prohibited—private foundations can undertake certain bipartisan educational activities or support charities that undertake lobbying if they follow certain guidelines. For example, the specific project grant rule, when followed, could allow a private foundation to fund a project that explicitly has lobbying activities.

Grant Reporting

The grant reporting schedule seems innocuous, but it can weave a story of relationships that extend beyond grantor and grantee. The grant recipients of private foundations are public, which means the public can gather data regarding which organizations a foundation supports by using data-mining tools.

Open-990-borderAlthough this information can be valuable to fundraisers and your grantmaking peers, it can also reveal an informal or unclear grantmaking process and serve as an inadvertent disclosure of taxable expenditures. As such, a foundation should ensure that there is a due diligence process related to grant recipients that verifies if a recipient is a qualified 501(c)(3) public charity, and use the space provided in the 990-PF (Part XV) to explain its grantmaking process, deadlines, and eligibility requirements.

While grants to other types of entities are permitted, if certain expenditure responsibility procedures are not followed, this type of granting could possibly raise a red flag. Any grantee that reports a foreign address, appears to be a corporation, or otherwise stands out could still garner a foundation unwanted attention from the general public and IRS. Grantmakers making grants to foreign organizations also have the option of using a process called equivalency determination to demonstrate how they determined that a foreign organization is equivalent to a U.S. charity. The grantmaker is required to collect a specific set of data, as outlined in IRS Revenue Procedure 92-94, that provides details about the grantee’s operations and finances.

Private foundation contributor schedules are public, which means anyone can pull these donor lists. With open-source data, foundation support can be easily compiled and aggregated to better understand an ecosystem of donors and support—keeping a private foundation accountable to the community it serves.

Even though the Form 990-PF is a government filing, its public nature and the increased openness of its data may lead to both greater interest and scrutiny in the private foundations filing it. Take control of your financial story by filing timely, complete, and accurate Form 990 returns, paying special attention to the areas noted above, and ultimately what increases may be a greater understanding of the field itself.

--Lauren Haverlock

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About Transparency Talk

  • Transparency Talk, the Glasspockets blog, is a platform for candid and constructive conversation about foundation transparency and accountability. In this space, Foundation Center highlights strategies, findings, and best practices on the web and in foundations–illuminating the importance of having "glass pockets."

    The views expressed in this blog do not necessarily reflect the views of the Foundation Center.

    Questions and comments may be
    directed to:

    Janet Camarena
    Director, Transparency Initiatives
    Foundation Center

    If you are interested in being a
    guest contributor, contact:
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