Gift Acceptance Guidelines

(Adopted May 24, 2023)

INTRODUCTION 

The Board of Directors of Denison Ministries has promulgated these guidelines to maximize the interests of Denison Ministries (“the Ministry”) and the donors who support its causes, so that all gifts are efficiently and effectively used for the religious and charitable purposes of the Ministry.

These guidelines supersede and replace any and all prior gift acceptance policies or guidelines of the Ministry.

GUIDING PRINCIPLES

The Ministry actively welcomes and encourages gifts of cash, appreciated assets, retirement assets, and other non-cash gifts as part of its strategic, asset-based giving program. Many donors find that non-cash gifts allow them to make a greater impact than they could through cash alone, while also aligning with their broader tax, stewardship, and estate planning goals. 

These guidelines exist to ensure that every gift — however it is given — can be received, administered, and used efficiently in support of the Ministry’s mission. Giving to the Ministry should be structured in a manner that does not encumber the Ministry with gifts that (i) cost materially more to administer than the benefit received by the Ministry, or (ii) cannot reasonably be converted to cash or otherwise put to use within a reasonable time. Complexity alone is not a reason to decline a gift; the Ministry maintains the due-diligence processes described below specifically so that complex gifts can be evaluated thoughtfully and, where appropriate, accepted.

Prior to accepting any non-cash donation, the Ministry may in its sole discretion consider whether the donor engages in an activity or cause that would be inconsistent with the Ministry’s nonprofit purposes, mission, sincerely held religious beliefs, or conduct expectations.

Prospective donors are encouraged to seek their own legal and/or tax counsel advice in matters relating to their charitable gifts, taxes, and estate plans. Likewise, the ministry should not enter into any giving agreement without the advice of the ministry’s legal counsel and tax accountants.

No finder’s fee or commission will be paid to anyone as consideration for directing a gift to the Ministry. The Ministry may, however, work alongside outside gift-planning partners (such as donor-advised fund sponsors or gift-planning organizations) to help donors structure complex gifts, consistent with these guidelines.

SPECIFIC GIFT GUIDELINES

A. Cash 

1. Cash gifts are the most straightforward way to give to the Ministry, since they require no valuation, appraisal, or liquidation before the Ministry can put them to use; provided, however, the Ministry may only accept cash gifts denominated in U.S. dollars. If a question arises at the time of the gift as to (a) legal title to the donated funds, or (b) legal capacity of the donor to donate the funds, then the Ministry may reconsider its acceptance of a cash donation.

2. Generally, donors should make cash gifts by a banking transfer [such as ACH, wire, or check] or credit card, and in either such event payable solely to Denison Ministries. The Ministry may not accept a donation payable to (a) more than one payee, (b) an employee, director, agent, or volunteer of the Ministry, or (c) another individual or entity regardless of whether, in any such case, the donation is for the credit or benefit of the Ministry.

B. Publicly Traded Securities

1. The Ministry welcomes gifts of publicly traded securities — stocks, bonds, and mutual fund shares — that are readily marketable on a U.S. exchange such as the NYSE or NASDAQ. Unless the Board of Directors determines that a specific security should be retained for a defined period, the Ministry’s standard practice is to sell donated securities promptly upon receipt through its brokerage arrangements. Donors should be informed of this practice at the time of the gift.

2. The donor team should be notified in advance of a securities transfer whenever practical, to help ensure the gift is identified promptly and acknowledged accurately.

C. Cryptocurrency and Other Digital Assets

1. The Ministry may accept gifts of cryptocurrency and other digital assets (such as Bitcoin or Ethereum) on a case-by-case basis, coordinated in advance with the donor team.

2. Prior to acceptance, the Ministry should confirm that the asset can be (i) received through the Ministry’s approved custody or exchange arrangement, and (b) converted to cash within a reasonable time following receipt. Absent a Board of Directors determination to the contrary, digital assets should be liquidated promptly upon receipt.

3. For gifts of digital assets, the Ministry will request any documentation necessary for the donor’s tax reporting (such as IRS Form 8283) and may require an independent qualified appraisal for larger gifts, consistent with applicable IRS substantiation rules.

D. Closely-Held Business Interests and Non-Publicly Traded Securities

1. The Ministry recognizes that gifts of closely-held or non-publicly traded business interests — often made in advance of a sale or ownership transition — can represent some of the most significant gifts a donor is able to make, and the Ministry welcomes an early conversation about these opportunities.

2. Because these gifts require individualized review, acceptance is subject to advance approval by the Board of Directors (or a committee designated by the Board for this purpose) and generally requires:

  • A reasonably clear path to eventual marketability or liquidity for the interest (e.g., an anticipated sale, redemption, or buy-back arrangement);
  • Confirmation that the interest is not encumbered or restricted in a manner that would create an ongoing obligation, duty, or liability for the Ministry;
  • Independent legal and valuation review, coordinated with the donor’s own advisors; and
  • Consideration of any unrelated business income or other tax exposure the Ministry may incur.

3. Because timing is often critical to these gifts (the transfer generally must occur before a sale or liquidity event), the donor’s team should engage as early as possible in the process.

E. IRA Charitable Rollover / Qualified Charitable Distributions (QCDs)

1. The Ministry welcomes Qualified Charitable Distributions made directly from a donor’s IRA custodian, consistent with applicable IRS rules for donors who have reached the eligible age.

2. To be accepted as a QCD, the distribution must be transferred directly from the IRA custodian to the Ministry; distributions received personally by the donor and then re-gifted do not qualify, though they may still be accepted as a cash gift under Section A.

3. The Ministry should be notified in advance where practical, so that incoming QCD transfers (which often arrive without full donor identifying information) can be matched and acknowledged accurately.

F. Donor-Advised Fund (DAF) Grants

1. The Ministry welcomes grant recommendations from donor-advised funds sponsored by qualified public charities (such as Fidelity Charitable, Schwab Charitable, National Christian Foundation, or similar sponsoring organizations).

2. Because a DAF grant is a gift from the sponsoring organization rather than the individual donor, the Ministry’s charitable acknowledgment practices for DAF grants will follow applicable IRS guidance.

3. The Ministry does not issue a personal tax-deductible receipt to the individual donor for a DAF grant.

4. The Ministry may accept a donor’s non-binding designation or recommendation accompanying a DAF grant, subject to Section N (Restricted Gifts) below.

G. Real Property

1. The Ministry welcomes gifts of real property and maintains the following process to evaluate them responsibly. Acceptance of real property requires the prior approval of the Ministry’s Board of Directors (or a committee designated by the Board for this purpose).

2. The Ministry should engage an independent realtor licensed in the locale of the real property to analyze the feasibility of accepting a donation of the real property. Legal counsel for the Ministry should also be involved in the process, including preparation of the Bill of Donation and associated conveyance of title documents.

3. In addition to normal due diligence associated with a real estate transaction, the Ministry should obtain and analyze the following:

  • An appraisal of the real estate prepared by an independent licensed appraiser.
  • Governmental documentation (such as IRS Form 8283) necessary for the donation of the real property to the Ministry.
  • Liens, encumbrances, reservations, deed restrictions, zoning, environmental matters, and other conditions affecting the marketability or title insurability of the real property.
  • The commercial or residential nature of the real property and associated revenue generation and operating expenses, including whether the Ministry would incur unrelated business income should the donation be accepted.
  • Costs and expenses related to the due diligence investigation of the real property and the obligations of the Ministry to bear those costs and expenses.

4. The Ministry’s standard practice, absent a Board of Directors determination to the contrary, is to sell donated real property promptly following receipt.

H. Other Tangible Personal Property

1. Generally, tangible personal property such as vehicles, jewelry, artwork, collections, antiques, and other personal property with an estimated value less than $1,000 should not be accepted by the Ministry as a donation. For tangible personal property with an estimated value of $1,000 or more the Ministry should consider the following prior to accepting the donation:

  • The personal property should be readily convertible into cash.
  • The personal property should not be perishable or require special facilities or security to safeguard it.
  • The appraised value of the personal property as determined by an independent appraiser.
  • Legal counsel for the Ministry should also be involved in the process, including preparation of a Bill of Donation and associated conveyance of title documents.
  • Any required governmental documentation (such as IRS Form 8283) necessary for the donation of the personal property to the Ministry.

I. Other Personal Property

1. Gifts of other personal property, whether tangible or intangible (such as mortgages, notes, copyrights, royalties, or other intellectual property), will be considered following due diligence appropriate to the nature of the asset, coordinated between the donor team, finance and accounting, and legal counsel.

J. Deferred and Testamentary Gifts (Wills, Trusts, and Beneficiary Designations) (formerly part of Section G; revised)

1. The Ministry actively welcomes and encourages gifts made through wills, living trusts, and beneficiary designations on retirement accounts or insurance policies, and maintains sample bequest language available to donors and their advisors upon request.

2. These guidelines still apply to the ultimate acceptance of a testamentary gift. Restrictions accompanying a bequest or beneficiary designation will be evaluated consistent with Section N (Restricted Gifts) below. Where a gift is unrestricted and the Ministry maintains an active endowment fund, the Ministry’s default practice may be to direct the gift to that fund unless the Board of Directors determines otherwise.

K. Life Estate Gifts

1. The Ministry will discuss gifts of a remainder interest in property where the donor retains a life estate on a case-by-case basis. Because the value of a retained life estate can decline meaningfully if the donor needs to sell or vacate the property during their lifetime, the Ministry will ensure the donor’s advisors have addressed this consideration before the gift is finalized.

L. Life Insurance

1. The Ministry welcomes being named as a beneficiary for all or a portion of a donor’s life insurance policy, and separately welcomes gifts of ownership of an existing whole life policy that is fully paid up and no longer needed by the donor.

2. The Ministry will not accept gifts intended to fund the purchase of a new life insurance policy on the donor’s life, and will not endorse specific life insurance products for use in funding gifts to the Ministry.

M. Life-Income Gifts (Charitable Remainder Trusts and Charitable Gift Annuities)

1. The Ministry welcomes conversations about life-income arrangements, including Charitable Remainder Trusts (CRTs) and Charitable Gift Annuities (CGAs), for donors who wish to combine charitable giving with an ongoing income need.

2. Because these arrangements are individualized and involve legal agreements, acceptance requires:

  • Engagement of the donor’s own legal, tax, and financial advisors;
  • Board of Directors approval of the specific arrangement, including payout rate, term, and funding asset; and
  • For CGAs, adherence to the Ministry’s minimum gift amount and payout rate guidelines then in effect (or, where the Ministry issues CGAs through a reinsurance or partner arrangement, the terms of that arrangement).

3. The Ministry does not provide illustrations or projections as a substitute for the donor’s own professional advice, but may assist advisors with information needed to prepare such illustrations.

N. Restricted Gifts and Gift Designations

1. The Ministry will include a statement substantially in the following form in its fundraising and solicitation materials, and donor receipts:

“Denison Ministries has promulgated Gift Acceptance Guidelines. These address various cash and non-cash methods of giving. Acceptance of a donation by Denison Ministries is subject to these guidelines. Denison Ministries will treat any donor gift restrictions and/or designations as a suggestion, unless the ministry’s Board of Directors has approved the restriction and/or designation in advance of receiving the gift.”

2. In the event a restricted or designated gift is approved in advance of receiving the gift, then the restricted or designated gift may only be used for the purpose(s) for which they are restricted or designated. The Ministry’s President will determine if a segregated account will be established for the gift. If the Ministry does not use the restricted or designated funds, in whole or in part, for the purpose(s) restricted or designated, then the Ministry will return the remainder of the gift to the donor unless the donor releases the restriction or designation.

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