GIFT ACCEPTANCE POLICY
Commemorative Air Force | GIFT ACCEPTANCE POLICY | Adopted AS OF May 6, 2018
This policy statement is developed to establish standards and policies pursuant to which all gifts to the Commemorative Air Force ("CAF") will be evaluated, as well as a formal process for carrying out such evaluations. This policy is intended as a guide and allows for some flexibility on a case-by-case basis.
ORGANIZATION AND COORDINATION
It is the responsibility of the Commemorative Air Force (CAF) and the Development Office to organize, implement and manage programs for obtaining gift support from donors including individuals, members, board members, volunteers and staff, corporations and foundations for the annual fund, restricted funds, capital purposes, special events and planned gifts to support the CAF. Within the overall fundraising efforts of the CAF, CAF Units organize, implement and manage programs for obtaining gifts that support their Unit’s efforts to fulfill the CAF’s mission. Guidance is provided to CAF Units related to fundraising in the CAF Unit Manual.
The CAF or the Gift Acceptance Committee is responsible for overseeing the implementation of the Gift Acceptance Policy. The Committee is comprised of the President/CEO, the Secretary/Treasurer, and the Vice President of Philanthropy and Development. The Committee will meet as needed to address and resolve issues that relate to gift acceptance. The Committee reserves the right to not accept voluntary gifts of any type in its sole discretion. The Committee may request the help of advisors as needed. No staff member of the CAF will execute an agreement, contract or other legal document with any donor that differs from the Gift Acceptance Policy without prior approval of the Gift Acceptance Committee. Any amendments to the Gift Acceptance Policy will first be submitted to the CAF Gift Acceptance Committee for approval and then to the CAF’s General Staff for final acceptance.
The task of all CAF staff and those involved in gift acceptance on behalf of the CAF, is to inform, guide or otherwise assist the donor in fulfilling his/her philanthropic wishes, but never to pressure or unduly influence such a decision. All prospective donors are advised to consult their own attorney and/or tax advisor regarding all aspects of their proposed gifts, whether as an outright gift or by bequest, trust agreement, contract or by other means. The CAF’s staff and counsel will not act as an advisor to the donor regarding the drafting of wills, trust agreements or other estate planning issues because of the potential conflict of interest.
Commitments will be publicly recognized and/or commemorated consistent with the donor’s wishes and the guidelines approved by the Gift Acceptance Committee. Requests by donors for anonymity will be honored. Permission to publicly recognize a donor and his/her gift will be assumed unless otherwise requested.
Gifts will not be accepted where there is no charitable intent on the part of the donor.
No verbal pledges will be recognized as having been made. Either a signed pledge or letter of intent must be in the possession of the CAF before a pledge is recorded. The normal pledge payment period for gifts to a campaign will be three to five years. Permanent donor recognition will be based upon the full payment of pledge commitments within the allotted pledge period.
PLANNED GIVING WEBSITE
The CAF maintains a section on giving on its website at www.commemorativeairforce.org to provide a comprehensive resource regarding estate and gift planning for potential donors and their advisors.
TYPES OF GIFTS
A. Unrestricted (Annual Fund)
Unrestricted gifts to the CAF are to be used or made available for current operations and are included as part of the CAF's overall budget that is approved by the Finance Committee and then the General Staff. The Annual Fund Campaign is the fundraising effort responsible for securing unrestricted gift income. Only funds received during the fiscal year, January 1 – December 31, will be reported in the Annual Report for the applicable year. Annual Fund dollars are generally spent in the year in which they are raised. Annual Fund goals are approved by the General Staff.
B. Restricted Gifts
Restricted gifts are accepted if they are consistent with the CAF's mission, goals, and programs. Restricted gifts are placed in restricted accounts and used only for the designated purpose of the gift. Due to their restriction, these gifts are not counted toward the Annual Fund goal.
If money, securities, or other property is paid (“donated”) to the CAF with an expectation by the donor that the proceeds will be used to benefit a designated or identifiable individual, the transaction receipt issued by the CAF must state that goods and services of equal amount were received by the donor.
Gifts from any donor made on the condition or with the understanding that the award will be made to benefit an individual of the donor's choice will not be accepted.
The terms of any gift should be as general and flexible as possible to permit the most productive use of the funds for the life of the CAF.
Gifts (including bequests) are monies or property voluntarily given to the CAF without expectation of return or compensation on the part of the donor.
The use of donated funds for a purpose other than that stipulated by the donor is prohibited. However, if another use is deemed necessary by the CEO and/or the General Staff, consent for using the funds in a different manner may be sought from the donor or decedents. The purpose may be altered in accordance with the terms of the gift agreement.
For a donor to change the originally stated use of donated funds, the change must be agreed to first by the Vice President of Philanthropy and Development and President/CEO.
C. Capital Gifts
The CAF periodically conducts capital campaigns to meet emerging needs for new construction, renovation, and major equipment. The President/CEO establishes the goals for each campaign.
D. Special Events
The CAF periodically conducts special fundraising events to benefit established programs at the CAF. These events require prior approval by the CFO or VP of Operations.
E. Endowment Gifts
The AAHF is a separate Internal Revenue Code section 501(c)(3) organization. The Foundation accepts gifts, in its discretion, for general and for specific purposes. When no purpose is specified, gifts are placed in the Foundation's fund for unrestricted purposes. The specified endowed funds currently are for: AAHM Greathouse Education Endowment, AAHM Nose Art Endowment, CAF Endowment, AAHM 49th Fighter Squadron Endowment, AAHM Footlocker Endowment, AAHF Diamond Endowment, and various Unit and Aircraft Endowments. Guidelines for gifts of specific levels to effectively sustain these programs are established and are periodically reviewed by the Gift Acceptance Committee. The terms of any endowed fund must be documented in writing and must include language to permit the President/CEO and/or the General Staff to assign a different but related use of the funds if changing conditions (such as if the purpose becomes obsolete or non-existent) indicate the need.
Newly created endowment funds will be reviewed and approved by the Gift Acceptance Committee.
Endowment funds are managed by the AAHF Board of Directors.
Presently, a minimum of $25,000 is required to establish a restricted named fund. Memorial or special occasion gifts may be restricted to the purpose intended by the surviving family, although the Gift Acceptance Committee or Foundation, as applicable, reserves the right of refusal.
The terms of all endowment gifts of $25,000 and above will be specified in a written gift agreement that outlines the program to be supported. The gift agreement should be signed by the President/CEO and the donor(s).
F. Corporate Matching Gifts
Through corporate matching gift programs, a donor's employer may double, and in some cases triple, a donor's personal gift. Matching gifts from employers will be combined with a donor's personal gift for purposes of recognition, gift club membership and named gift opportunities, unless it is against the stated policy of the employer. Employers will also be receipted and recognized for their matching contributions.
The following procedures relate to the types of gifts typically received by the CAF. It is understood that special gifts or circumstances may require a case-by-case review and may not be covered by this policy. The CAF encourages gifts in addition to cash or in lieu of cash. When tax consequences are a factor, donors will be advised to contact their own legal and/or tax counselors.
## A. Cash
Unrestricted gifts in the form of cash and checks shall be accepted by the CAF regardless of amount unless, as with any gift, there is a question as to whether the donor has sufficient title to the assets or is mentally competent to legally transfer the funds. Checks can be made payable to “Commemorative Air Force” or “CAF”. In no event shall a check be made payable to an employee, agent or volunteer who represents the CAF.
The Accounting Office processes all gifts of securities given to the CAF for any purpose and the Development Office records and acknowledges all gifts of securities. The CAF has a relationship with a local brokerage firm that handles the transfer of securities to the CAF. It is generally the CAF's policy to sell marketable securities immediately after receipt.
Many gifts of securities are made to the CAF via electronic transfer. A gift of transferred securities is considered complete on the date it is received in the CAF's account. If actual shares are delivered to the CAF for sale, the gift is considered complete on the post-marked date of the mailing or the date of delivery.
The CAF values securities by averaging the high and low sales price of the security on the date of a gift in accordance with applicable U.S. federal income tax law. This averaging can cause the value of a gift to be slightly different from the actual sales price.
Upon written request by the donor of securities and the approval of the Gift Acceptance Committee, the CAF may agree to hold the stocks as transferred for a designated period of time. In this case, the CAF willingly assumes all risks concerning potential benefit or loss due to changing stock values as the stock is retained rather than sold.
C. Gifts in-Kind
Gifts in-kind are generally accepted if they are consistent with the mission of the CAF.
D. Gifts in Service
Gifts of service are contributions of actual, billable service directly related to the business or profession of the provider. Gifts of services will be recognized at the level of actual expenses invoiced but not to be paid.
E. Gifts of Tangible Personal Property
Gifts of tangible personal property should be reviewed with special care to ensure that they will not involve any financial or contingent liability, and such gifts may require the approval of the Gift Acceptance Committee. As stipulated in current federal or state tax law, the CAF will issue a receipt for the item donated, but it is the responsibility of the donor to place a value on the gift. In order for property gifts to be recognized, complete transfer of ownership must have occurred. The donor is required to complete IRS Form 8283 in order to claim income tax deductions.
F. Life insurance
Gifts of life insurance will be accepted upon approval of the Gift Acceptance Committee. The CAF must be named both beneficiary and irrevocable owner of a paid-up insurance policy before it can be recorded as a gift. The CAF will recognize a donor for the cash surrender value of the policy.
G. Oil and Gas Interests
Gifts of oil and gas interests such as minerals or interests arising from royalty interests and overriding royalty interests will customarily be handled through the CAF and must be approved by the Gift Acceptance Committee.
H. Real Property
The CAF welcomes gifts of real property as a means of providing for the current and future support of the CAF. The CAF wishes to allow maximum flexibility for itself and donors in the acceptance of gifts of real property, but also recognizes that certain unique issues associated with real property require the establishment of clear guidelines for acceptance of such gifts. As such, gifts of real property will customarily be handled through the Gift Acceptance Committee.
Gifts of real property may be accepted after a thorough review by the Gift Acceptance Committee of the following relevant facts:
- Marketability of the property as determined by, among other things, the ability to sell within a reasonable period of time;
- Liability for environmental risks associated with the property;
- The existence of public and private restrictions, reservations, easements, and other limitations;
- The existence of any encumbrances such as mortgages and mechanics liens;
- Donor must fund continuing carrying costs such as property owners' management, association dues, maintenance, taxes, and insurance;
- Fair market value in relation to the factors listed above;
- The usefulness of the property for the CAF's purposes; and
- Such other factors that may be relevant to the particular property of the CAF.
- Marketability of the property as determined by, among other things, the ability to sell within a reasonable period of time;
The fair market value of any proposed real property gift will be determined by a qualified appraisal in accordance with IRS standards. The donor will pay the cost of the appraisal unless otherwise agreed upon.
Donor will provide copies of all available surveys.
Donor will provide appropriate evidence of title ownership, including title insurance, if required by the CAF.
The donor is required to complete IRS Form 8283 in order to claim income tax deductions.
The CAF is required to complete IRS Form 8282 if the property is sold within three years after the date of gift. All IRS forms requiring execution by the CAF will be signed by the Secretary/Treasurer.
The gift will be completed by the execution and delivery of a deed of gift or other appropriate conveyance and written acceptance by the CAF, together with such other instruments, releases, consents and deliveries as may be required by the CAF. The costs associated with the conveyance and delivery will be paid by the donor unless otherwise agreed upon.
At the time of sale of the property, the CAF shall use the sale proceeds, net of any costs of selling, holding or maintaining the property, as directed by the terms of the gift, if applicable.
In order for property gifts to be recognized, complete transfer of ownership must have occurred.
All property gifts will be subject to environmental evaluation in favor of the CAF by an approved vendor prior to acceptance by the CAF. The extent of that review will be determined for each property, and the expense will be paid by the donor.
I. Life Estate
Gifts of property with retained life interests for up to two people may be accepted in accordance with the terms above for Real Property. A charitable contribution deduction for a gift of a life estate is available only for a gift of a personal residence or interest in a farm. It is the responsibility of the donor to pay all property taxes, insurance, maintenance, and upkeep on the gifted property.
1. Appraisal Requirements
a. Gifts of property, other than publicly traded securities, must be accompanied by an appraisal if the estimated value exceeds $5,000. A qualified independent appraiser must provide the appraisal. The appraiser cannot be associated with the CAF or any of its employees. When the gift is to fund a specific recognition opportunity, donors agree to make up any short falls upon conversion to cash. (See IRS Form 8283)
b. Donors of property gifts must seek their own legal and tax counsel in regards to all property gifts. The CAF reserves the right to refuse gifts of property when it is determined that the donor has not complied with IRS appraisal requirements or that the advice of the independent counsel is not being obtained.
c. Donors of property gifts will receive an acknowledgment of the gift only when complete transfer has occurred. The acknowledgment will not include any reference to the value of the gift, only a description of the property.
d. All costs associated with obtaining a qualified appraisal will be paid by the donor.
A. Charitable Trusts
The CAF will accept gifts of a beneficial interest in charitable trusts upon the approval of the Gift Acceptance Committee. The Committee may seek the advice of legal counsel before entering into an agreement with a donor or accepting a gift of this nature. The CAF will not act as trustee of a charitable trust. Deferred gifts will be counted at the present value of the CAF's interest.
B. Charitable Gift Annuities
The CAF will accept charitable gift annuities upon the approval of the Gift Acceptance Committee. Under a charitable gift annuity, a donor makes a gift to the CAF in exchange for annual payments of a fixed amount from an insurance company and/or third party administrator for the life of an individual(s).
A gift annuity shall be issued by the CAF for an amount of $25,000 or more and any beneficiary shall be 60 years or older. A gift annuity agreement shall be for one or two lives.
No gift annuity agreement shall be issued unless the charitable gift, as computed by using government tables, exceeds 10% of the amount transferred for the annuity.
The CAF will accept testamentary bequests. Unless otherwise restricted, all gifts from bequests will be reviewed by the Secretary/Treasurer and may be placed in the general CAF Endowment Fund of the AAHF. Upon notification of a bequest intention, the donor will be identified as a member of the CAF Legacy Society.
A contingent bequest plans for the situation in which the beneficiary of a bequest dies before the donor or disclaims the property. In anticipation of such an occurrence, the donor names the CAF as the alternate or contingent beneficiary. This will ensure that the property will pass to the CAF rather than to unintended beneficiaries.
A restricted bequest is for a specific purpose and should be made in the broadest terms possible consistent with the donor’s interests to guard against the possibility of the purpose of the gift becoming obsolete.
GIFT ACKNOWLEDGMENT AND RECEIPTS
It is the responsibility of the CAF to officially record, receipt and acknowledge all gifts to the CAF. All gifts should be processed by the CAF before being deposited to any CAF account. Gift and pledge receipts will be dated, recorded, and mailed to the donor. The Development Office and the Accounting Office will reconcile monthly accounts. Donor anonymity will be respected whenever desired. The Vice President of Philanthropy and Development or the CEO/President personally acknowledges all annual fund and capital campaign gifts, and depending on the level of gift, volunteers also assist with thanking the donor. Special event contributions are acknowledged by the CAF.
The CAF will comply with current U.S. tax laws regarding tax deductibility. Receipts will be provided for all donors and any benefits provided to the donor that exceed the IRS' "insubstantial benefit" definition will be clearly stated. When other tax consequences are a factor, donors will be advised to contact their own legal and/or tax counselors.
A. Memorial and tribute gifts are acknowledged via a special acknowledgement to the donor and an acknowledgement to the next of kin or the tribute honoree, if requested.
B. Gifts of real or personal property are acknowledged by letter that describes the property.
C. Standardized communication formats are used wherever possible, with appropriate personalization depending on signatory.
D. When necessary, individualized or unique communication will be sent.
E. Each acknowledgement includes:
Name and location of the CAF;
Amount of cash contribution;
Description (but not value) of non-cash contribution, unless an appraisal accompanied the gift;
Description of the gift designation or purpose;
Statement that no goods or services were provided by the organization, if that is the case;
Description and good faith estimate of the value of the goods or services, if any, that organization provided in return for the contribution.
# COMPLIANCE WITH IRS RULES
A. Form 8283 and Qualified Appraisals
Donors must file IRS Form 8283 with their income tax returns if the amount of their income tax deduction for all noncash gifts is more than $500. A qualified appraisal generally is required if a claimed deduction for an item or group of similar items is valued at more than $5,000. The donor will pay for all such appraisals. The CAF will require a qualified appraisal for all gifts of real property.
B. Form 8282
The CAF will file IRS Form 8282 if any charitable deduction property (which is defined as property valued at $5,000 or more per item or group of similar items and does not include publicly traded securities) is sold, exchanged or disposed of by the CAF within three years after the donor contributed such property. The Secretary/Treasurer will sign all IRS Forms requiring execution by the CAF.
A. CAF’s Legacy Society
Donors who desire will be identified as members of the CAF’s Legacy Society, an organization established to recognize and thank individuals who have created provisions in their wills or estate plans to benefit the CAF and have informed the CAF of their commitments.
All donors to the CAF may be recognized in CAF Development publications and other CAF publications unless anonymity is requested.
C. Plaques, etc.
When appropriate (e.g. after a capital campaign) donors will be notified that their names will be displayed, unless anonymity is requested, in appropriate locations to commemorate their gift.
D. Naming Opportunities
Buildings.Gift levels to name buildings, classrooms, and other spaces will be determined in individual capital campaigns. In general, the naming of a building will require a gift of at least 50% of the cost of construction.
Endowment. A minimum of $25,000 is currently required to establish a named endowment.
Memorial Funds. A minimum of $25,000 is currently required for a restricted endowed memorial fund. Any gift which qualifies for a named endowment fund, commemorative fund, fellowship, or building may be recognized in Development publications and other appropriate places, unless the donor prefers not to be listed.
Pledge Payment and Recognition. All forms of permanent recognition will be based upon pledges paid. Conversely, those donors with pledge balances will not be given permanent recognition until such pledges are fulfilled.
Removal or Modification of Named Gift Opportunities
a. Escape Clause: When individuals, corporations, their senior officers, or other organizations being recognized through donor recognition, named programs, endowments, etc. are later found to have violated ethical behavior or broken laws in the judgment of the CAF’s General Staff, and their actions result in an unfavorable connection for the CAF, the General Staff reserves the right to remove such a name from the facility without reimbursing the donor for the gift.
b.Name Changes: If a donor wishes to change the wording on donor recognition signage due to circumstances such as death, divorce, or remarriage, the donor may provide the funds to change the recognition, provided such a change is feasible at the time.
c. Nonpayment: If a donor has not completed all pledge payments and has not made a pledge payment in the past 24 months, the Gift Acceptance Committee will review the situation and the donor may be notified that the name will be removed from the space, program, or endowment.
For fundraising initiatives and campaigns, the fundraising period will be the total time encompassed by the active planning, cultivation, solicitation, and payment of pledges on behalf of the fundraising initiative or campaign. The President/CEO will define the time period, both beginning and end date, for the counting of commitments.
Only those gifts and pledges actually received and/or committed during the specified period of time identified for the fundraising initiative or campaign will be counted in the program results.
Gifts and pledges will be counted in only one phase of the fundraising initiative or campaign. No commitments will be counted for the first and for subsequent phases of the program.
The value of any canceled, withdrawn, or unfulfilled pledge will be subtracted from the campaign totals when it is determined that the commitment will not be realized.
During a campaign some planned gifts will be counted toward the goal at either full face value, present fair market value or at a discounted rate. The CAF has counting guidelines that provide assistance for reporting a numeric summary of activity, results and progress toward goals during the campaign period. The full-face value of all gifts will be recorded for gift recognition/stewardship purposes, but the present value of split interest gifts will also be recorded and shown in the aggregate when reporting campaign gift totals. (See Campaign Counting Guidelines document)
NON GIFT REVENUE
The following types of funds may be designated to the fundraising initiative or campaign, but will be reported as non-gift income to the program. These forms of revenue will be shown as additions to the program from non-philanthropic sources:
A. Board-designated surplus income;
B. Donor or board-designated investment earnings on gifts; and
C. Governmental funds.
All fundraising events in which there is a publicized or inferred contribution element must comply with applicable tax laws concerning tax deductibility. It is the CAF's responsibility to disclose the deductible amount of any ticket price to attend an event. The CAF will assign a realistic fair market value, including entertainment, to the event. Donors of in-kind gifts or services will be issued receipts with no gift value assigned.
The confidentiality of donors and their records is a high priority for the CAF. Information regarding the amounts of individual gifts is confidential. Appropriate biographical and financial information will be shared with volunteers only when relevant to fundraising programs. All requests for anonymity will be respected. No individual other than authorized staff and authorized volunteers will have access to individual donor files.
The General Staff is empowered to grant any exception to these general policies to encourage significant gifts or improve benefactor relationships. Recommendation for exception can be made by the Gift Acceptance Committee and accepted by a majority vote by the General Staff.
A. General Review: The Gift Acceptance Committee shall periodically (but no less frequently than every five years) review these policies to ensure that they continue to accurately describe the policies of the CAF with respect to acceptance of charitable gifts, and shall propose to the General Staff for adoption those revisions that they shall determine to be necessary or appropriate for the Gift Acceptance Policy to accurately reflect the policies of the CAF.
B. Specified Review: As recommended by the Gift Acceptance Committee, these policies may be reviewed and ratified by the General Staff each time the President/CEO determines that the CAF will embark on a capital or other fundraising campaign. These policies shall also be reviewed upon the enactment or promulgation of legislation or regulatory rules affecting fundraising and gift acceptance by the CAF, to assure continued compliance by the CAF with relevant legislation and rules.