Hi Valeri,
It might be helpful to take one step back from your question and focus on what the IRS is trying to prevent. In this case it is self-dealing.
https://www.irs.gov/charities-non-profits/private-foundations/self-dealing-by-private-foundations-providing-goods-services-or-facilities
Because foundations are giving their donors a charitable receipt for their contributions it is particularly important that they don't allow direct benefits to their donors after the fact related to their gift. The reason private foundations and DAF's are the focus of this is that those are the instances where the donor has the most control over how the funds are allocated and, therefore, the best opportunity to engage in self-dealing.
If you start with that, then you can apply it to future iterations or brandings of this same concept. They already exist with some programs that are marketed as matching gift or payroll deduction services but a really just evolutions of donor advised funds.
Best,
John Smilde
Director of Gifts and Records Administration
Advancement and Alumni Relations
George Mason University
4400 University Drive, MSN 1A3
Fairfax, VA 22030
703.993.8680
jsmilde@gmu.edu
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