Gift Acceptance Policy

The Sunlight Foundation (EIN 20-3903427) greatly values the financial support that it receives from individuals, foundations and corporate giving programs. Those generous donations – large and small – are critical in sustaining and expanding Sunlight’s efforts to foster and promote greater government transparency and openness.

The following gift acceptance policy summarizes what gifts are, and are not, acceptable at Sunlight. It also enables volunteers, consultants and staff to respond to donors in a timely and consistent manner and to accommodate novel or complex donations that may require consideration of several interrelated factors. It is not a substitute for flexibility and independent judgment by the Executive Director.

This policy pertains to all cash donations of $250 or more, as well as donations of life income gifts, real estate, insurance policies, etc. Sunlight accepts gifts of cash, stock, mutual fund shares, bonds, tangible properties, and insurance policies. Sunlight reserves the right to place conditions on accepting the gift or, if it deems it necessary, to decline the gift.

  1. General Gift Acceptance Any contribution from any source in excess of $100,000 will be reviewed and approved before acceptance by the Sunlight Foundation Board of Directors.

  2. Designated Support Should a donor wish to provide designated support for a specified project, the relationship between the donor’s personal views and the nature of the project requires special scrutiny to assure that there is not a conflict of interest. Approval by the Executive Director is required before any gift from an individual, foundation, or family foundation in support of a particular project can be accepted.

  3. General Support

    1. Under $250 Sunlight accepts donations from any source under $250 as such amounts are not significant enough to be perceived as influencing, unless the Director of Development or Executive Director identifies the donation as being inappropriate.

    2. $250 or more: Individuals

      1. Any gift of $250 or more must not have nor create a conflict of interest with the mission of the Sunlight Foundation.

      2. No project support will be accepted that could potentially provide tangible benefit to the donor nor enhance his/her professional or personal interests.

      3. Any concern or question about the appropriateness of a potential donor or the source of donation will be reviewed and determined by the Director of Development and the Executive Director.

    3. Corporations

      1. Sunlight will only accept contracts or grants from businesses with which there is no real or perceived conflict of interest.

      2. Any concern or question about the appropriateness of a potential donor or the source of donation will be reviewed and determined by the Director of Development and the Executive Director.

    4. Foundation Grants

      1. Sunlight may solicit and accept donations from national, local, community, or family foundations including those directly connected to a business entity or a business/professional association.

      2. Donations from foundations with only one director shall be reviewed as if the donation came from an individual donor.

      3. Foundation donations are subject to approval by the Development Director and Executive Director.

    5. Gifts of Stock Publicly traded securities are sold as soon as feasible by Sunlight and are valued and acknowledged on the date the securities are irrevocably transferred to Sunlight.

    6. Gifts of Tangible Personal Property Personal property should not be accepted by Sunlight unless it can be disposed of quickly and has a minimum value of $5,000. A qualified appraisal must be supplied by the donor along with the gift. Final acceptance of any gift of tangible personal property will be made by the Development Director and the Executive Director.

    7. Tangible Gifts to Staff Any tangible gift to staff with a value of $25 or more will only be accepted if approved by the Executive Director (including meals). Such gifts will be posted on the Sunlight website.

  4. Deferred Donations The rules for structuring deferred gifts can often be complex. Sunlight will encourage the donor to consult his/her own legal and financial advisors so as to avoid creating any undesirable tax consequences for the donor’s estate or heirs.

    1. Bequests In the event of an inquiry about a prospective bequest, acceptability of an existing bequest, or assets left or proposed to be left in a will may be made only in accordance with the terms outlined in the General Donations section, above.

    2. Gifts of Life Insurance Sunlight may be named as the beneficiary of life insurance or commercial annuities. Sunlight will not, however, encourage the purchase of life insurance policies to benefit its programs.

    3. Donations of Retirement Plans Sunlight may be named the beneficiary of a qualified retirement plan, an individual retirement account (IRA), and other types of retirement plans.

    4. Donations of Real Estate

      1. All donations of real estate are subject to immediate sale except in the case of a Retained Life Estate.

      2. Donations of real estate may include developed or undeveloped property.

      3. Sunlight will not accept property with multiple owners unless there is an acceptable preceding legal agreement with the other owners regarding ultimate disposition of the property.

      4. Property may be given in the following ways:

        • An outright donation of property.
        • To establish a Charitable Remainder Trust.
        • To establish a Retained Life Estate that allows the donor to live in the property during his/her lifetime. Expenses for maintenance, real estate taxes, and any property indebtedness will be paid by the donor.
        • As a bequest in a will.
      5. Sunlight will only consider donations of real estate that are above the following market values:

        • Outright donation – $50,000
        • Charitable Remainder Trust – $100,000
        • Retained Life Estate – $100,000
        • Bequest – $50,000
      6. Donations of real estate must be reviewed prior to acceptance and will require the following documentation and information:

        • General description of the property;
        • A demonstration of clear title of ownership. No donation of real estate will be accepted until all mortgages, deeds of trust, liens and other encumbrances have been discharged;
        • Value of the property – while it is the donor’s responsibility to obtain an independent appraisal of the property, Sunlight will obtain its own appraisal of the fair market value and marketability of the property. The Director of Development will inform the donor that the IRS will require an appraisal within a period that begins sixty days before the date of the donation and ends on the day before the due date (including extensions) of the federal income tax return on which the donation is first claimed as required by law; and
        • Sunlight will calculate the costs to maintain, safeguard, and insure the property (including property tax, if applicable) during the holding period.
      7. The Director of Development will prepare a written summary of the real estate donation proposal and submit that summary to the Executive Director for review. It will include:

        • A description of the property including title of ownership and tenant information, if any;
        • The proposed arrangement of the donation and its value;
        • The purpose of the donation, what program/s it will benefit, and whether it is a cash or endowment gift;
        • An estimate or appraisal of the property and the property’s fair market value and marketability;
        • Expenses, encumbrances, and carrying costs prior to disposition and income potential;
        • Environmental risk assessment;
        • Zoning restrictions;
        • Any special arrangements requested by the donor; and
        • A description of the donor and any potential conflicts of interest.
      8. The donor should not engage with potential buyers of the property.

  5. Cy Pres and Other Legal Settlement Awards Sunlight may apply for and accept cy pres funds or funds from out-of-court settlements of legal disputes. Sunlight will report as directed on the use of the funds.

  6. Government Sunlight grants will only be accepted if the gift is politically neutral and is approved for acceptance by the Executive Director.

  7. Transparency Sunlight does not accept anonymous gifts over $250.