Close The Gap Gifts-In-Kind Policies, Procedures, and Guidelines

Close The Gap Foundation (“CTG”), a registered 501(c)(3) nonprofit organization in the State of California, encourages the solicitation and acceptance of gifts to or for the benefit of CTG for purposes that will help CTG to further and fulfill its mission.

The mission of CTG is to bridge the gap to give every FGLI (First Generation and Low-Income) student a chance to reach their potential despite their socioeconomic upbringing.

CTG’s Board of Directors has a fiduciary duty to assure that CTG’s assets are used efficiently and protected from potential liabilities and diversion to purposes other than those that further CTG’s goals. The following policies and guidelines govern the acceptance of gifts made to CTG or for the benefit of any of its programs.

I. Purpose of Policies and Guidelines

The Board of Directors of CTG and its staff solicit current and deferred gifts from individuals, corporations, and foundations to secure the future growth and mission of CTG. We appreciate donors’ consideration of any gift to CTG. In all matters involving current and prospective donors, the interest of the donor is important to CTG. Please contact us at [email protected] if you have any questions or if you wish to discuss any aspect of this Policy.

These policies and guidelines govern the acceptance of gifts by CTG and provide guidance to prospective donors and their advisors when making gifts to CTG. The provisions of these policies apply to all gifts to CTG for any of its programs. Gifts will be accepted only if they do not interfere with CTG’s mission, purpose, and procedures.

CTG shall accept only such gifts as are legal and consistent with organizational policy. While CTG does not provide tax advice, every effort will be made to assist donors in complying with the intents and purposes of the Internal Revenue Service in allowing charitable tax benefits.

Key principles include safeguarding the confidentiality of the donor relationship, providing full disclosure to the donor, and ensuring that gifts are recorded, allocated and used according to the donor intent and designation.

II. General Policies Relevant to All Gifts

1. Use of Legal Counsel

   CTG shall seek the advice of legal counsel in matters relating to the acceptance of gifts when appropriate. Review by counsel is recommended for:

   • Closely held stock transfers subject to restrictions or buy-sell agreements.
   • Documents naming CTG as Trustee.
   • Gifts involving contracts or other documents requiring CTG to assume an obligation.
   • Transactions with a potential conflict of interest that may involve IRS sanctions.
   • Other instances in which use of counsel is deemed appropriate by the gift acceptance committee.

2. Conflict of Interest

   CTG will urge all prospective donors to seek the assistance of independent personal legal and financial advisors in matters relating to their gifts and the resulting tax and estate planning consequences. CTG and its employees and agents are prohibited from advising donors about the tax consequences of their donations. Gifts are also subject to the provisions of other CTG policies, including adopted Conflict of Interest policies.****

3. The Gift Acceptance Committee

   The gift acceptance committee shall consist of:

   • The Chair of the Board of CTG;
   • Chair of the Finance Committee of CTG; and
   • Executive Director of CTG.

   The gift acceptance committee is charged with the responsibility of reviewing all gifts proposed to be made to CTG, properly screening, accepting or rejecting those gifts, and making recommendations to the board on gift acceptance issues when appropriate.

4. Establishing the Value of Donated Property

   It is the policy of CTG to comply fully with the valuation rules set out in Publication 561 of the Internal Revenue Service and the relevant income, gift, and estate tax laws and regulations. Copies of Publication 561 are available at www.irs.gov. CTG reserves the right to alter the value of property contributed to it on the books and records of CTG for accounting, tax-reporting, annual fund record-keeping, or any other purpose if developments after the completion of the gift or information that comes to the attention of CTG after the gift is completed are determined, in the discretion of the Committee or CTG’s auditors, to merit such an alteration.

5. Tax Compliance

   CTG’s policy is to comply with Internal Revenue Service reporting requirements and all other aspects of state and federal tax law.

III. Types of Gifts

1. CTG solicits and accepts gifts that are consistent with its mission. This includes
   • Items that can be used directly by our staff or students.
   • Items that may be used in support of our fundraising events.
2. Donations will generally be accepted from individuals, partnerships, corporations, foundations, government agencies, or other entities, without limitations.
3. In the course of its regular fundraising activities, CTG will accept donations of money, stock, and in-kind services.
4. Certain types of gifts must be reviewed prior to acceptance due to the special liabilities they may pose for CTG. Gifts for purposes that are not consistent with CTG’s mission or consonant with its current or anticipated future programs cannot be accepted. Examples of gifts that are too restrictive are those that violate the terms of the corporate charter, gifts that are too difficult to administer, or gifts that are for purposes outside the mission of CTG.