09.100 Organization and Administration of Fund Raising

Vice Chancellor, University Advancement

Revised September 9, 2025, supersedes former Administrative Policies ADV 09.100 “Organization and Administration of Fundraising” August 28, 2006

N/A

UNC Policy Manual 600.2.1 "Endowment Funds"

University Advancement

Policy Details:

1. Purpose

   Explains university policy and procedures concerning the solicitation and acceptance of private gifts to the university, including cash, stocks, securities, deferred gifts, gifts in kind, and non-specific grants.

2. Scope

   Includes all donations to the university, or any division or department of the university.

3. Policy

   The university values the solicitation and acceptance of private gifts and grants which enable it to fulfill its mission of teaching, scholarship, and community service.

   Gifts may be sought from individuals, corporations, and foundations. However, they may be sought only for purposes, positions, and programs that foster the strategic plan, including its mission and values, and have appropriate academic or administrative approval.

   The university values and will protect its integrity, its independence, and the academic freedom of the university community. Gifts that could expose the university to adverse publicity, require expenditures beyond the university’s resources, or involve the university in unexpected responsibilities because of their source, condition, or purposes, or are not consistent with the strategic plan, including the mission and values of the university will not be accepted.

   The university is unable to accept gifts too restrictive in purpose or inconsistent with its stated academic purpose and priorities. Gifts received by the university must not inhibit it from accepting gifts from other donors. Further, no gift can be received which limits, beyond a general definition of a subject area, the research that a faculty member or student can perform.

   The university cannot accept gifts that may involve unlawful discrimination based upon race, sex, age, religion, national origin, color, disability, or any other basis prohibited by federal, state, and local laws and regulations. Nor can the university accept gifts that obligate it to violate any other applicable law or regulation.

   This policy is designed to provide guidance to the university community and the public so as to facilitate the gift giving process. The university encourages philanthropic creativity; therefore, this policy is to be interpreted liberally so that prospective donors may enjoy the greatest freedom possible in formulating their gifts.

4. Procedure

   1. Gift Acceptance Committee

      Consistent with applicable law, the university adheres to the valid terms and conditions of every gift agreement.

      The Gift Acceptance Committee (GAC), at the request of the Vice Chancellor for University Advancement, is responsible for reviewing and making recommendations regarding gifts in which present and/or future encumbrances may be incurred and in cases involving certain types of unusual non-cash gifts.

      Committee members should include the Director Advancement Services, university counsel, director of investments and endowments, Vice Chancellor of University Advancement, and Associate Vice Chancellor of Business Affairs.

      Types of gifts reviewed by the committee may include, but are not limited to:

      1. Gifts of real property or an interest therein.
      2. Gifts of closely held securities (ownership shares of companies that are not publicly traded on a stock exchange), promissory notes, partnership interests, stock options, or other negotiable instruments.
      3. Gifts of undivided interest or future interests.
      4. Bargain sales or gifts subject to any encumbrance.
      5. Gifts of tangible personal property such as paintings, sculpture, furniture, other works of art, or collections of such, if made on the condition or expectation that the items will be permanently exhibited, or that the collections will be maintained and shown as such.
      6. Gifts that, because of their unusual nature present questions as to whether they are within the role and scope of the university.
      7. Gifts that, because of their size or nature, present questions as to their impact on the university, or a particular program or area.
      8. Gifts that might raise questions about the university’s integrity, independence, or academic freedom, or potentially expose the university to reputational or financial risk, or litigation; and
      9. Gifts that present the potential for an obligation on the university under local, state, or federal law that it may be unwilling or unable to assume.

      It is the responsibility of any major gift officer, departmental representative, or other university administrator, when presented with a gift or while working with an estate, to bring all the gifts that meet the above guidelines to the attention of the Vice Chancellor of University Advancement prior to accepting such gifts.

   2. Definition of a Gift

      For tax purposes, a gift is defined as a voluntary transfer of assets from a person or an organization to the university where no goods or services are expected, implied, or forthcoming for the donor. Gifts usually take the form of cash, securities, real property, or personal property. The following criteria generally identify a gift:

      1. A gift is motivated by charitable intent.
      2. Gifts are an irrevocable transfer of assets. The university is not obliged to return unexpended funds. (If, for some reason, the university is unable to comply with the donor’s intent, or if the gift has been misdirected to the university, a return of the gift may be issued at the university’s discretion. Out-of-pocket expenses may be deducted from the gift before it is returned. The Vice Chancellor for University Advancement is authorized to approve the return of a gift if the university is unable to comply with the donor’s intent or if the gift has been misdirected to the university. The return of a gift for any other reason must be reviewed and approved.)
      3. Gifts are not generally subject to an exchange of consideration or other contractual duties between the university and the donor, except for certain deferred gifts as set out in this policy.
      4. A period of performance is not specified.
      5. Formal financial accounting to the donor is not required as it would be, for example, with a research grant.
      6. Generally, funds received from individuals, closely held corporations, and family foundations, nonprofit associations, or commodity groups with no expectation of a benefit, return of unspent funds, or compensation in exchange for funding are classified as gifts.
      7. A gift is not completed until it has been accepted by the university.

   3. Gift Acceptance Conditions

      1. The university will accept only gifts that are consistent with the strategic plan, including its mission and values, of the university and meet the following criteria:
         1. Compatible with the mission of the university and of its individual programs.
         2. In compliance with the Internal Revenue Code of 1986, as amended, and other federal statutes, regulations, rulings, or court decisions that stipulated the conditions under which contributions can be tax-favored.
         3. In compliance with UNC System Office regulations and other university policies that stipulate the conditions under which contributions can be given and received; and
         4. In compliance with all federal and state laws and regulations.
      2. Unless a specific exception is granted by the Chancellor, the university will not accept gifts that include any of the following criteria:
         1. Violate any federal, state, or local statute or ordinance.
         2. Create a fund to provide for scholarships, fellowships, professorships, or lecture series with restrictive clauses that could cause reputational risk to the university, or gives to the donor or his/her representative the right to designate the recipient.
         3. Contains a condition that requires any action on the part of the university that may be unacceptable to university administration.
         4. Commits the university to name a fund where the gift is potentially revocable in any way.
         5. Requires the university and its administration to employ or consider employing a specific person at a future date.
         6. Contains unreasonable conditions (i.e., a lien or other encumbrance) on gifts of partial interests and real property.
         7. Requires tuition payments for a family member.
         8. Exposes the university to potential litigation or other potential liabilities.
         9. Requires the payment of maintenance costs or other expenses (e.g., debt service) for which no specific provision has been made.
         10. Generates unrelated business income tax; or
         11. Appears to be financially unsound.
      3. Unless a specific exception is granted by the university, the university will immediately sell all gifts of stock or property so that it can invest the proceeds in accordance with the university’s investment policies.

   4. Fees

      1. Finder’s Fees or Commissions

         Consistent with the codes of ethics of the Association of Fundraising Professionals and the National Committee on Planned Giving, no finder’s fee or commission of any type will be paid by the university to any party in connection with the completion of a gift to the university without the prior written approval of an authorized representative of the university.

      2. Professional Fees

         Reasonable costs of gift acquisition, such as transaction costs, appraisals, and professional fees, will normally be borne by the donor. However, there may be occasions when a prospective donor conditions the gift on the university’s agreement to pay such costs. The university will verify the reasonableness of the costs and the cost reimbursement complies with the market, and state and federal requirements including, but not limited to, tax laws and professional ethical guidelines. If appropriate, the university may agree to cover gift acquisition costs from its operating budget.

      3. Administrative Fees

         To the extent permitted by law or policy, the university reserves the right to levy an administrative or trustee fee on endowment accounts, life income plans, charitable trusts, and similar funding structures as it deems appropriate. University Advancement, in conjunction with Business Affairs, may establish fees annually based on the university’s actual cost of administration of gifts.

      4. Appraisals

         All appraisals of real and personal property contributed to the university shall be conducted in accordance with IRS Publication 561, "Determining the Value of Donated Property." A real property valuation should be prepared by a Master Appraisal Institute appraiser. Personal property should be appraised by a qualified appraiser acceptable to the university.

         Expenses incurred obtaining an appraisal shall be the responsibility of the donor unless exceptional circumstances exist that make it appropriate for the university to share the cost. Any appraisal borne by the university must have prior approval of the Chancellor or chancellor’s designee.

      5. Professional Advisors

         All prospective donors will be urged to seek their own counsel in matters of estate planning, taxes, and planned gifts, who alone must bear responsibility for all legal conclusions and advice. It is not within the province of the university to give legal advice to donors. Prior to accepting any gift, the university shall advise the prospective donor to seek professional advice from their attorney and/or accountant, particularly if the prospective donor intends to make a deferred gift through the use of a will, trust, annuity contract, or other instrument.

      6. Legal Counsel Review

         All form agreements of the university shall be reviewed for legal sufficiency by the university general counsel’s office upon adoption of this gift acceptance policy.

   5. Types of Acceptable Gifts

      Gifts are either outright or deferred. The most common gifts to the university are outright gifts. The university accepts cash gifts as well as gifts of securities, real property, and personal property. Deferred gifts, also called planned gifts, are arranged with the university during the donor’s lifetime, but do not accrue benefits to the university until a later time (usually after the death of the donor or his/her beneficiaries). Bequests are the most common type of deferred gift. Other such gifts include life insurance policies that name the university as a beneficiary, charitable gift annuities, and life income agreements.

      The university has approved the following types of gifts subject to the guidelines and policies set forth below and established policies to be followed in the solicitation and acceptance of gifts to the university.

      1. Outright Gifts
         1. Cash and Checks

            Cash and checks shall be accepted regardless of the amount. Guidelines: Checks shall be made payable to the University of North Carolina at Wilmington or designated affiliated entities. The value of any cash or check gift is its face value.

         2. Securities and Mutual Funds
            1. Publicly Traded Securities

               Securities that are traded on the New York and American Stock Exchanges, as well as other major U.S. foreign exchanges and the NASDAQ; corporate bonds; government issues and agency securities may all be accepted by the university, except as related to restricted securities (see section below).

               Guidelines: The university sells such securities as soon as possible after the securities have been transferred to the University.

               The value of a gift of securities is the mean (average) of the high and low of the stock(s) or bond(s) on the day the transfer is affected by the donor to the University. The value of less actively traded securities, rarely traded securities or a security that does not trade on the gift date should be determined according to IRS Publication 561.

            2. Closely Held Securities

               Closely held or non-publicly traded securities, sole proprietorships, general or limited partnership interests, Corporation securities, interests in real estate investment trusts ("REITs") and limited liability company interests may be accepted only after prior review and approval by the University.

               Guidelines: Valuation of closely held securities may be difficult due to infrequent trading which makes it difficult to establish fair market value. If a donation of closely held stock is being considered, IRS Publication 561 should be followed in valuing this type of security. Unless there is an active market for a security, if the value of the gift is estimated to be $5,000 or more, the donor shall provide a documented appraisal prepared by a qualified appraiser.

               The University will consider the marketability of closely held securities before accepting such a gift. It is the intention of the University to sell all securities as soon as possible after the transfer from the donor. If it appears that a gift of closely held securities will take longer than eighteen months to sell, the University may decline the gift.

            3. Restricted Securities

               Restricted securities (also known as unregistered securities, investment letter stock, control stock or private placement stock) are infrequently given as gifts because of the difficulty in transferring ownership and determining fair market value. They may be accepted only after approval by the University.

               Guidelines: If restricted securities are being considered as a gift to the University, IRS Publication 561 should be consulted when determining the value of the securities. If the value of the gift is estimated to be $5,000 or more, the donor shall provide an appraisal report prepared by a qualified appraiser.

            4. Mutual Fund Shares

               Mutual fund shares may be accepted by the University.

               Guidelines: The fair market value of mutual fund shares can be determined by the public redemption price of the share on the valuation date of a gift of this nature. If such a price is not readily available, then the value shall be determined as if the share were untraded securities in IRS Publication 561.

         3. Real Property

            The University may accept gifts of real property, both improved and unimproved, only after review and approval by the University and in consultation with legal counsel.

            Guidelines: The University will require the following items to review a gift of real property:

            1. A preliminary title report clear of unacceptable encumbrances, performed by a reputable title insurance company.
            2. An MAI appraisal by a qualified appraiser.
            3. A phase one environmental audit indicating that ownership will not expose the University to environmental liabilities. The University may waive the phase one requirement for non-farm residential properties.
            4. A market feasibility study for purposes of liquidation.
            5. An on-site evaluation by the University’s major gifts officer.
            6. Evidence of compliance with the Americans with Disabilities Act and any state or federal regulations (where applicable).
            7. A structural engineering report (when applicable).
            8. A review of leases (for commercial properties).
            9. A disclosure statement for residential properties (where applicable).

            Under Treasury regulations, a donor must pay for any initial appraisal made on the property. Unless waived by the University, it is the responsibility of a donor to cover all costs involved in an environmental impact study, title search and any other relevant due diligence.

         4. Real Property with Retained Life Estates or other Restrictions or Limitations Policy

            The University may accept either a gift of real property with a retained life estate or subject to other interest(s) for a term of years, or other limitations as to timing of the interest or use or sale restrictions only after review and approval by the university.

            Description - A gift of real property with a retained life estate involves the transfer of the title to a personal residence, farm, or timberland to the University whereby the donor or another person retains use of the property for a term of years or the life/lives of the donor and/or another person.

            Guidelines: Such gifts are subject to both the general conditions and the guidelines for acceptance of outright gifts of real property as set forth in subsection C (Real Property). The University shall encourage donors to consult independent tax and/or legal counsel prior to making the life interest must provide that the donor and/or life tenant shall remain responsible for the payment of mortgages, taxes, insurance, utilities, maintenance/repairs, and other costs associated with the property, unless other specific provisions are made for the payment of these expenses. Donor(s) shall not violate or allow to be violated any environmental laws/ordinances covering this property.

         5. Charitable Gift Annuities

            Charitable Gift annuities shall not be accepted by the university without prior review and approval by the Ad-Hoc GAC.

            Description - A Charitable Gift annuity is a contract between the university and the donor. The university agrees to pay the donor (or other person named by the donor) a lifetime annuity in return for a gift of cash, securities, or other property. The payment may continue for the life of a second individual, such as a spouse.

            The annual payment is a fixed sum, the amount of which is based on the gift size and the number and ages of the beneficiaries. Rates of return under a charitable gift annuity are lower than the rates offered by commercial insurance companies so that a significant residuum will remain for the university.

            Guidelines: The minimum contribution amount for a gift annuity is $10,000.

            The Rates of return payable to annuitants shall not exceed those recommended by the American Council on Gift Annuities as of the date of contribution. Annuity Agreements shall be limited to two lives.

            Generally, the minimum age for the annuitants shall be 60 for immediate annuities and 45 for deferred annuities. Exceptions may be made subject to the prior approval of the Ad-Hoc GAC.

            Gift annuities shall be managed by the university, and the university may employ agents and advisors to assist with administration and investment of gift annuity assets.

         6. Charitable Remainder Trusts

            The university shall not accept a charitable remainder trust without prior review and approval of the trust agreement by the Ad-Hoc GAC. Where the trust is testamentary, that is, one that arises upon the death of the donor, the university reserves the right to disclaim any interest that would be in violation of this gift acceptance policy.

            Description - A charitable remainder trust is an irrevocable trust created either during the life of the donor or through the donor’s will or trust. The trust must provide that a specified sum (not less than 5%) of the trust’s value is paid to one or more beneficiaries on an annual or more frequent basis. At least one beneficiary must be noncharitable. In order to qualify as a charitable remainder unitrust, the trust must meet all the requirements set for in IRC Section 664, and related regulations.

            Guidelines: The university may agree to serve as the trustee of charitable remainder trusts that meet the requirements set forth below.

            The initial contribution to the charitable remainder trust shall be at least $100,000 unless the Ad-Hoc GAC waives this requirement. The university may serve as trustee of any charitable remainder trust to which the initial contribution is at least $100,000 unless the Ad-Hoc GAC approves a smaller amount. If the income interest is for life, the beneficiary (ies) must be at least 45 years of age for a NIMCRUT, NIMCRUT or FLIPCRUT and 60 for a standard or straight charitable remainder trust unless the Ad-Hoc GAC approves a younger age.

            Where payments are to be made for the lives of multiple beneficiaries, there may be no more than two.

            The university will not serve as trustee of a charitable remainder trust interest unless the trust is designed so that its net present value at the time of future distribution to the university is not less than 50% of the initial gift. Calculation of net present value will consider a reasonable return over time, growth of trust assets, allowance for management expenses, and discount (inflation) factor in accord with practices of similar charitable organizations. Exceptions may be recommended by the Ad-Hoc GAC in light of such factors as assets involved, size of gift, potential for additional gifts or additions to the unitrust, age, and life expectancy.

            Any donor who wishes to create a charitable remainder trust must choose between an annuity and unitrust format. No blending is allowed.

            1. Charitable Remainder Annuity Trusts (CRATS)

               A CRAT is an irrevocable trust that provides for paying a fixed sum (not less than 5%) but not more than fifty (50%) percent of the initial fair market value of the trust corpus; at least annually; to one or more persons, at least one of whom is not a charitable beneficiary; for life or the lives of a named individual(s) or for a term of years not to exceed 20; after which the entire trust principal will be retained for the use of the university (a qualifying Charity); and the value of the charitable remainder being at least 10% of the trust’s net fair market value of property transferred in trust on the date of transfer to trust.

               Since the amount is stated as a fixed sum, that fixed amount cannot be changed regardless of fluctuations in portfolio value. For this reason, additional contributions are not allowed.

            2. Charitable Remainder Unitrusts (CRUTS)

               A CRUT is an irrevocable trust that provides for paying a stated percentage (not less than 5%) of the net fair market trust principal; determined and paid at least annually; to one or more persons at least one of whom is not an IRC Section 170 (c) organization; for life or the lives of a named individual(s) or for a term of years not to exceed 20; after which the entire principal is irrevocably transferred or retained for the use of, in this case, the university; and the value of the charitable remainder being at least 10% of the trust’s net fair market value of property transferred in trust on the date of transfer to the trust. Unlike an annuity trust, additional contributions may be made to a unitrust.

               Unitrust options include:

               1. Standard or straight Unitrusts

                  A Standard unitrust requires a payout or distribution of an amount of at least 5%, and no more than 50%, of the annual value of trust assets.

               2. Net Income Unitrusts (NICRUTS)

                  A Unitrust requires the trustee to pay, for any year, the lesser of the full unitrust amount and trust income (as defined in IRC Section 634 (b) and related regulations). This type is commonly referred to as a Net Income, Income only option.

               3. Net Income with Make-up Unitrusts (NIMCRUTS)

                  If a net income option is selected, the trust will pay income in excess of the full unitrust amount to the extent the aggregate amounts paid in prior years were less than the aggregate of the fixed percentage amounts for those prior years. In other words, the trust can make up past deficiencies. This type of format is called a net income with make-up unitrust.

               4. Flip Unitrusts (FLIPCRUTS)

                  The decision to create a unitrust with a net income option is, in most cases, based on the fact that funding assets (often real estate) does not produce enough initial income to pay the annual unitrust amount. A unitrust can be drafted to allow a switch or FLIP from a net income option to a standard income provision upon the occurrence of a specific event such as the sale of the real estate.

         7. Charitable Lead Trusts

            Charitable lead trusts shall not be accepted by the university without prior review and approval of the trust agreement by the Ad-Hoc GAC. Where the trust is testamentary, this is, one that arises upon the death of the donor, the university reserves the right to disclaim any interest that would be in violation of this gift acceptance policy.

            Description - A Charitable lead trust is a trust in which the income, or "lead" interest is given to one or more non-charitable beneficiaries, who could be either the donor or family members. The amount paid to the university may be either a fixed sum (an "annuity trust" interest) or a percentage of the trust assets as valued each year (a "unitrust" interest).

            At the conclusion of the payment period, the trust assets are returned either to the donor or to someone designated by the donor.

            Guidelines: The university may serve as trustee of a charitable lead trust to which the initial contribution is at least $100,000. A trust may be funded with a smaller amount, subject to the approval of the Ad-Hoc GAC.

            The trust term may be at the discretion of the donor, subject to the approval of the Ad-Hoc GAC.

         8. Bargain Sales

            The university, upon review and approval of the Ad-Hoc GAC and legal Counsel, may purchase real estate, securities, or other property on a bargain sale basis in accordance with State of North Carolina regulations for such purchases.

            Description - A "bargain sale" is a sale of property to the university for an amount less than or equal to fifty percent (50%) of the property’s current fair market value. The excess of the value over the sales price represents a contribution.

            Guidelines: The purchase price for the property is subject to prior approval of the Ad-Hoc GAC. The bargain sale price may be paid either in a lump sum or in installments. If the property being sold is real property, the guidelines for the acceptance of such a gift as set forth above shall apply.

         9. Tangible Personal Property

            The University will consider gifts of tangible personal property, including but not limited to works of art, manuscripts, literary works, boats, motor vehicles, and computer hardware, only after a review indicates that the property is readily marketable, free of encumbrance. The actual use of a gift of tangible personal property will determine whether the University accepts the gift. Gifts of tangible personal property used by the university should be donated directly to the university.

            Authority to accept gifts of tangible personal property estimated at less than $5,000 has been delegated to the Associate Vice Chancellor for University Advancement. Gifts of tangible personal property valued at more than $5,000 must be reviewed and approved by Vice Chancellor for University Advancement.

            Guidelines: No gift of personal property subject to the requirement of ownership in perpetuity shall be accepted without prior approval of the university. No perishable property or property that would require special facilities or security to be properly safeguarded shall be accepted without prior approval.

            Prior to the donation of personal property with an estimated fair market value over $500, the donor must furnish the University, with procedure-related documents and an independent evaluation from a qualified appraiser of the donated asset.

         10. Other Personal Property

             Other personal property of any description, including mortgages, notes, copyrights, royalties, partnership interests, closely held business interests, undivided interests in property, future and partial interests and other liquid financial assets may be accepted upon prior review and approval of the Ad-Hoc GAC.

      2. Deferred Gifts

         Any planned giving agreement that requires execution by the university shall first be reviewed and approved as to form and substance by the university’s legal counsel.

         1. Bequests

            The Foundation may accept direct, unencumbered bequests without prior approval of the Ad-Hoc GAC if the underlying assets conform with the guidelines set forth in Section E, Outright Gifts. If the underlying assets are not in conformance with the guidelines, the bequest shall be referred to the Ad-Hoc GAC for review. The Foundation reserves the right to disclaim gifts from the estates or trust of deceased donors that are not in keeping with the terms of this policy.

            Description - A bequest to the university is made in the donor’s will, revocable trust, Letter of Intent or gift agreement. The donor can designate a specific amount, a percentage, or the remainder of an estate to the university.

         2. Designating the University as Beneficiary

            The university will accept any proceeds that it receives as a designated beneficiary (or an alternate beneficiary) of a life insurance policy, a deferred annuity contract, an IRA, a defined benefit plan, a 401 (k) plan, a defined contribution (profit sharing) plan, donor-advised fund (DAF) or other qualified plan without prior review and approval of the Ad-Hoc GAC, unless the designation imposes restrictions or trust arrangement, in which case, Ad-Hoc GAC Prior Review and approval is required.

         3. Life Insurance Policies

            The university will accept, without the necessity of prior review and approval by the Ad-Hoc GAC, gifts of life insurance policies, including whole life, variable, and universal life policies, which meet the guidelines specified below.

            Guidelines: Gifts of life insurance policies that meet the following three criteria may be accepted without prior Ad-Hoc GAC approval. If a Proposed life insurance Policy gift does not meet the criteria listed below it must be reviewed by the Ad-Hoc GAC before being accepted.

            1. The Policy is paid.
            2. The university is designated as the Owner and the Beneficiary of the Policy. (While the policy will identify the university as the beneficiary, the development officer should work with the donor to clarify the purpose of the gift by attachment of a memorandum, letter, or account agreement to the policy).
            3. If intended for endowment purposes, the face value of the policy meets the minimum funding standards for endowments for its stated purpose(s) established by the university and in effect at the time of the gift of the policy.

   6. Pledge Policy

      All Pledges other than annual fund telephone pledges are required to be in writing. Documented pledges are recorded on the University database and included in financial reporting. Annual Pledges are cancelled (written off) annually in July. Any annual pledges remaining at this time are due to exceptional circumstances and are documented and procedures noted below are followed.

      Description – Pledges are commitments to give a specific dollar amount according to a fixed time schedule.

      1. Legally Binding Pledge Form

         A Legally Binding Pledge Form is appropriate where the Foundation or university is taking on financial or other obligations in reliance on the anticipated gift (e.g., to start a capital construction, to initiate a name program, to hire faculty for a specified position, etc.). In such cases, the Development Officer must consult with the Vice Chancellor for Advancement or the university General Counsel to appropriately modify/use the Legally Binding Pledge Form attached to these policies. In cases where a legally binding pledge is needed in the creation of a new fund, the language from the Legally Binding Pledge Form can be incorporated into the Gift Agreement with the aid of either the Vice Chancellor for University Advancement or the university General Counsel.

      2. Non-Legally Binding Pledge Language within the Funding Section of a Gift Agreement

         Where no legally binding pledge is being used to establish a current or endowed fund, the necessary pledge language may be incorporated into the Funding section of the gift agreement. In such cases, a copy of the gift agreement MUST be sent to Advancement Services so that the pledge can be booked in the Advancement database.

      3. Other

         All other pledges may be documented on materials prepared by University Advancement.

      4. Pledge Payments
         1. Pledges typically will be fulfilled through payments of cash or publicly traded securities.
         2. If real estate or other non-marketable assets are used as payment, the initial value recorded against the pledge shall be the fair market value of the real estate or assets as determined by an independent qualified appraisal supplied by the donor. If, upon sale of the real estate or asset, the sale proceeds net of all expenses is less than the amount booked against the pledge, an additional pledge shall be booked in an amount equal to the difference between the amount initially booked against the pledge and the net sales price.
         3. If publicly traded securities are used as payment, the amount booked against the pledge shall be valued at the mean of the high and low prices on the date of receipt.
         4. Expected matching gifts amounts (such as from employers) are not included in posting pledges. That is, matching gifts do not satisfy pledges.
      5. Canceling (Writing Off) Pledges
         1. Telephone pledges and annual pledges will be written off annually.
         2. Multi-year pledges will be written off after proper notification of the Development Officer and in consultation with appropriate department head, dean or Vice Chancellor and a response in writing.

   7. Premiums or Goods/Services Rendered

      The IRS requires nonprofits to verify that no goods or services were received in exchange for a contribution, in order for the gift to qualify for a full charitable deduction. Standard receipts verify this qualification. Where premiums or services are offered, only the qualifying gift amount is receipted.

   8. Trade and Barter Gifts

      When services are provided to the university and athletic tickets or other deliverables are offered in return, no gift transaction is considered to have occurred, even if the value of the service exceeds that of the traded/bartered item.

   9. Establishing Scholarships and Awards

      1. Establishing Endowed Scholarships

         An endowed scholarship is a scholarship that has no less than $25,000 ($25,000 is the current amount needed, this amount has been less in the past, and may be adjusted in the future to a higher level, due to the rising costs of education). The principal $25,000 will be deposited into an interest-bearing account. The principal amount will remain untouched, $25,000, while the interest generated from investing the principal will be used to fund an annual scholarship. Interest generated from the principal once the $25,000 minimum has been reached, will be awarded, managed, and distributed according to university policy and subject to market conditions.

      2. Establishing an Annual Scholarship

         An Annual Scholarship is a scholarship that is renewable by a donor(s). These monies are not invested; they are awarded on a yearly basis, provided donations are in place by December 31 of the year prior to awarding so that the funds may be processed by Financial Aid.

         1. The annual scholarship must be funded at the minimum level set by the Office of Scholarships & Financial Aid, by the deadline listed above, for the scholarship to be awarded for the next academic year.
         2. Donors/Stewardees will be appropriately stewarded in accordance with their contributions.
      3. Establishing an Award

         An award is any gift of less than $1000 allocated to a student to defray the cost of their education. These types of awards will not be processed through Financial Aid, although these awards will be made known to the Office of Scholarships & Financial Aid, OSFA will not be responsible for administration. These awards will not receive their own account number and will be deposited into the trust account for the department. It will be the department’s responsibility to track the award, make the award and be responsible for any stewardship of the donor, beyond a gift receipt. Donors will not be included in stewardship activity associated with scholarships.

   10. Inclusion and Belonging Gifts

       Gifts designated to support the university’s strategic plan, including ensuring belonging or inclusion, are available if they meet the university’s definition and are in accordance with applicable university policies, and federal and state law.

   11. Gifts on Behalf of Others (Memorial and Honorary Gifts)

       Memorial and honorary gifts are encouraged by the university as generous and thoughtful ways to recognize people’s lives and accomplishments. When a memorial gift is made the decedents next of kin is notified by the university. Such notifications must not specify gift amounts. The next of kin will be consulted about the designated use of memorial monies, including whether the funds will be endowed or spent as current funds. See Endowment Management Procedures Policy, number 09.160, for required levels and other details. In the case of honorary gifts, the honored person is notified, again without detail about gift amounts.

   12. Gifts for the Benefit of Specific Individuals

       A gift that is made with the condition that the proceeds will be spent by the university for the Personal Benefit of a named individual, or individuals is not deductible as a charitable contribution. The university Ad-Hoc GAC shall review and view with caution gifts that are inappropriately targeted toward the benefit of particular individuals. The Ad-Hoc GAC will also review all proposals for endowed student aid funds that contain unusual restrictions, and proposed gifts for research projects or other scholarly activities undertaken by named individuals.

   13. Matching Gifts

       The university honors each organization’s matching gift rules while optimizing matching opportunities as fully as possible. If the university has reason to believe that a donor is not in compliance with a matching entity’s policies, staff will contact the donor for clarification. Examples may be gifts directed to non-qualifying programs (in some cases, Athletics) or pooling of gifts with non- employee donors. The university will not submit claims for non-qualifying gifts.

       The Director of Advancement Services is the agent designated by the university to ensure compliance and process all matching gift forms for return to the matching entity.

   14. Gifts from University Employees or Fund Managers

       Gifts to the university from university employees are encouraged and may be accepted if the purpose of the gift is to support bona-fide university activities and/or purchases. Such gifts are subject to the university policies and procedures for expenditure. However, because a gift to support an employee’s own research account, business travel account, or any account in which the employee is an authorized signer may have potential for abuse or for conflicts of interest, an appropriate third party (such as the dean, department chair, chancellor, or other person in a supervisory role to the employee) must be the fund administrator on any such account and must take exceptional care in approving expenditures to ensure that the university’s use of the gift supports its charitable purposes. If the donor does not wish to change the signature authority on the primary account, the donor may choose to have the gift deposited into a separate account earmarked for their area/department managed by the donor’s supervisor.

   15. Events with a Donor Component

       Any event organized by an agent of the university and advertises the purpose of the event to be fundraising for the university must receive prior approval on the fundraising aspect by the Associate Vice Chancellor for University Advancement.

       While all ticket monies will need to be processed through Advancement Services, provided there is a donation portion, Advancement Services will process the monies into the funds as designated by the event organizer.

   16. Non-Specific Grants

       A non-specific grant is a gift from a donor (usually a philanthropic foundation or other non-profit organization) that designates or refers to a gift as a "grant." Nonspecific grants usually result from the submission of a proposal. Additionally, there may be an agreement between the parties, but it will not be a contract requiring consideration.

       Provided that the donor does not receive benefit beyond nominal value from such a grant, and provided that the provisions of the grant do not contain a set of terms and conditions such as, but not limited to, intellectual property, scholarly publications, or fiduciary obligations including detailed financial reporting, return of unused funds, or audit requirements, such grants are administratively handled the same way as a gift and are subject to the university’s gift acceptance policies and procedures delineated above. Stewardship or impact reporting can be a requirement of non-specific grants. If a proposal was submitted to the donor, the proceeds of the grant must be recorded in the entity in whose name the proposal was submitted.

       Nonspecific grants are generally processed through the Advancement Services and are counted in official fundraising totals. All gifts and nonspecific grants are subject to assessments.

       Please refer to the Attachment of this policy for more specific guidance regarding differentiation between Gifts and Grants .

   17. Mailings with an Appeal for Money

       Any mailings with an attached appeal for monies need to be approved by Advancement Services before final printing and mailing of any such appeal.

       1. Advancement Services will ensure the wording of the appeal is within IRS guidelines.
       2. Advancement Services will ensure that the reply vehicle (pledge card or business reply envelope) contains the appropriate verbiage to ensure donations are processed most efficiently into Banner Advancement.
       3. Advancement Services can also supply solicitation codes to be printed on a reply vehicle to track donations received by such an appeal.
       4. Departments who are mailing will be responsible for all costs associated with the mailing.

   18. Gift Handling and Delivery Policy

       1. All gifts to the university are to be deposited by Advancement Services.
       2. All gifts should be hand delivered in a locked gift bag, with a transmittal sheet itemizing the gifts being delivered, the designations for the gifts and the amounts.
       3. All gifts will be logged.
       4. All gifts of cash should be delivered, counted, and receipted in the presence of the person delivering.
       5. Gifts should never be delivered through interoffice mail.
       6. If the Advancement Services office is closed, deliverer may drop gifts in blue locked mailbox, labeled Advancement Services behind Alderman or adjacent to the Administrative Annex. In this case the deliverer should contact Advancement Services on the next business day to ensure gifts are received.

   19. Moving Gift Monies

       Any gift monies (monies with the object code of 10269) must be moved by Advancement Services or with the knowledge of Advancement Services. It is crucial that the donor’s gift record reflects the movement of their monies into the correct accounts.

       Normal transactions to move monies from the following do not fall under this policy:

       1. Endowment accounts into spending accounts.
       2. University accounts into foundation accounts (provided the account is the same account on the foundation side).

   20. Gift Acknowledgement

       The university will acknowledge the receipt of all gifts in writing and in a manner which satisfies the IRS’s substantiation requirements set forth in IRS section 170(f) for the deduction of charitable gifts by individual donors. It is the intent of the university to disclose appropriate information about the operation of annuities and trust arrangements to donors prior to and at the time of the gift.

   21. Gift Refunds

       The university does not, as a rule, refund gifts. However, when circumstances are compelling, a request to refund a gift must be documented. Requests for refunds under $500 must be sent to the Vice Chancellor for University Advancement, or designee, for consideration. Requests for refunds above $500 must be sent to the Vice Chancellor for University Advancement for consideration in partnership with the Ad-Hoc GAC. The tax implications of a returned gift will be made clear to the donor.

       Refund requests for cancelled or changed events require the approval of the Vice Chancellor for University Advancement, or designee. Requests must be received prior to the event unless circumstances (weather) dictate otherwise.

   22. Policy Effective Date

       All gift agreements in effect at the time these policies become effective shall continue in effect under the policies in place at the time the original gift was accepted.

ATTACHMENT – Distinction between Gifts, Sponsored Projects, and Contracts

The following table provides a guide to help determine which entity (UNCW or an associated entity) should be named as the applicant in a proposal for funding. Terms in letters, agreements, or checks may require review, and the accompanying documents (e.g., proposals and emails) determine how funds must be processed.

Common Indicators of Sponsored Program Funding

• Return of unspent funds
• Deliverables or benefits to the funder
• Funder's influence over fund management
• Extensive reporting requirements and audit rights
• IP rights requests or ownership of project results
• Publication review or indemnification provisions
• Indirect costs applied to the project

Common Triggers for Additional Review

• Employee requirements that are unmet by associated entities
• Foreign funding with potential influence considerations
• Terms on cashing checks that imply agreement to conditions
• Funder requests for charitable tax receipts
• Funding exclusively to official 501(c)3 entities