Gettysburg College Gift Acceptance Policy

• Policy Owner: Tres Mullis, Vice President for College Advancement and Matthew Price, Chief Financial Officer
• Contact Information: Anne Cherry, Assistant Vice President Advancement Systems and Prospect Research
• Approval Authority: Board of Trustees
• Approved By: Amanda Dolan, Secretary of the Board of Trustees
• Approval Date: October 17, 2026
• Effective Date: October 17, 2026
• Date of Last Review: 9/23/23
• Date of Next Review: July 2029

1. Purpose of Policy

Gettysburg College has achieved its current distinction thanks in significant part to gifts and other contributions in support of its educational mission. The Gift Acceptance Policy’s purpose is to give guidance and counsel to those individuals within the Gettysburg College community concerned with soliciting or accepting gifts.

In general, all gifts will be accepted or rejected in accordance with the policies set forth herein. Any proposed gifts that fall outside this Gift Acceptance Policy are required to be reviewed and approved before acceptance by the Gift Acceptance Committee, and under certain circumstances, by the Board of Trustees.

2. Scope of Policy

This Policy applies to all gifts offered to the College.

3. Definitions

Assets:

• LIQUID ASSETS: Assets which can be quickly and easily converted to cash or traded on the public market. Marketable securities are examples of Liquid Assets.
• ILLIQUID ASSETS: Securities, closely held stock, partnership agreements, Real Property or other properties not currently traded on the open market, including pre-IPO (pre-initial public offering) stock that might one day be publicly traded or that might be eventually acquired by another company via a merger. Such Assets are often volatile and difficult to value and/or convert to cash.

Alternative Use Clause: A clause stating that, if, in the opinion of the Board of Trustees of Gettysburg College, all or part of the funds cannot be applied in strict conformance with the purposes previously stated, Gettysburg College may use these funds for other appropriate purposes as nearly aligned to the original intent of the donor as good conscience and need dictate within the authorized powers of Gettysburg College.

Bargain Sale: The sale of property to a charitable organization at a price below fair market value. If the property has appreciated in value, the donor’s basis is allocated between the portion of property sold and the portion of property donated. The donor pays tax on any gain on the portion of property sold and deducts the remaining portion as a charitable contribution, subject to charitable contribution rules. Different rules apply to inventory and property held for sale in the ordinary course of business.

Beneficiary Designation: A way to transfer certain Assets after one’s lifetime that fall outside of a Last Will & Testament or Living/Revocable Trust. Assets passing by Beneficiary Designation include: IRAs and retirement plans; Life Insurance policies; commercial annuities; bank or brokerage accounts, transfer on death accounts, etc.

Bequest: Bequests are broadly interpreted for the purposes of this policy statement as gifts which come to Gettysburg College because of a donor’s death. They may be provided through wills, trusts, retirement plan assets (401(k) and 403(b) plans and individual retirement accounts), Life Insurance, commercial annuities, payable on death (POD) designations and other vehicles.

Budget-Enhancing or Unusual Restrictions: Donor-imposed gift Restrictions that are not aligned with institutional priorities or go beyond current priorities which, if accepted, require new programs or activities, require matching funds, or do not clearly replace expenditures already being made from Gettysburg College’s unrestricted funds.

Budget-Relieving: Gifts which help pay for costs and expenses in the annual budget.

Campaign Crediting: The dollar credit and recognition donors receive from Gettysburg College for gifts and commitments documented during a campaign. Because they are done for different purposes, campaign credit amounts may differ from those used for financial and campaign reporting, or for income tax charitable deductions. See Exhibit E Campaign Crediting Guidelines.

Campaign Reporting: The amounts and formats by which the results of fundraising activities are reported. Gettysburg College follows a common set of definitions and procedures promulgated in the CASE Global Reporting Standards 1^st Edition. See Exhibit E Campaign Crediting Guidelines.

Charitable Gift Annuity: An irrevocable contract between a charitable organization such as Gettysburg College and a donor(s). In return for a transfer of cash, Marketable Securities or other Assets, Gettysburg College agrees to pay a fixed amount of money at regular intervals to one or two income beneficiary(ies) for the life of the beneficiary(ies) (who may or may not be the donor). Gift annuities are general obligations of Gettysburg College. Assets donated for gift annuities become the property of Gettysburg College as soon as the contract is signed and the Assets are transferred. Annuity reserve funds are calculated, segregated, and invested in accordance with state laws. Annuity Assets above state reserve requirements are separately designated in Gettysburg College’s financial records and released for the intended purpose when the obligation to the beneficiary expires. See EXHIBIT C for relevant minimums and requirements. There are three primary types of Charitable Gift Annuities offered by Gettysburg College:

• CURRENT (IMMEDIATE): First payment is made within 12 months of the gift, at the end (or the beginning) of the payment period immediately following the contribution.
• DEFERRED: First payment is made more than 12 months after the gift. This date is chosen by the donor and must be more than one year after the date of the contribution.
• FLEXIBLE DEFERRED: The donor does not have to choose the payment starting date at the time of the contribution. Instead, the donor selects a range of years during which he or she can later elect to receive income. The earliest date in the range determines the charitable deduction.

Charitable Remainder Trust: A tax-exempt, irrevocable trust designed to make a charitable donation to Gettysburg, reduce estate and capital gains taxes and/or to reduce the taxable income of the donor(s). An individual transfers Assets to the trust which then disperses payments to the designated income beneficiaries for a specified period of time, generally the lifetime of the income beneficiary(ies) or a term of no more than twenty years, after which the trust is dissolved and the remaining trust assets are donated to Gettysburg. Gettysburg College may serve as trustee on a case by case basis. See EXHIBIT C for relevant minimums and requirements. There are several types of Charitable Remainder Trusts:

• STANDARD UNITRUST: Beneficiary payment is equal to a fixed percentage of the trust’s value, determined annually.
• NET INCOME UNITRUST: Beneficiary payment is equal to the net income of the trust, excluding gains, capped by a stated payout percentage.
• NET INCOME UNITRUST WITH MAKE UP PROVISION: Beneficiary payment is determined as for a standard net income unitrust but includes a “make up” provision which allows the trust to make up any past income deficiencies whenever the trust income exceeds the stipulated payout percentage.
• FLIP TRUST: Such a trust is normally funded with Assets that are difficult to sell, such as real estate, and pays out income from the trust excluding gains, then is flipped to a regular charitable remainder unitrust upon the sale of the Asset and begins to make payments equal to a fixed percentage of the trust’s value, determined annually, in the next taxable year. Flip trusts are also used to supplement retirement income. Gifts can be made during income-earning years when the income tax deduction is most beneficial, and then payments start later when the trust “flips” at a pre-determined date.
• ANNUITY TRUST: Beneficiary payments are fixed dollar amounts which are set at the outset for the entire trust term. Gettysburg College does not serve as Trustee for charitable annuity trusts.

Charitable Lead Trust: An irrevocable trust designed to make a charitable donation to Gettysburg College and reduce gift and estate taxes. The donor transfers Assets to the trust which then disburses payments to Gettysburg College for a specified period of time. At the end of the term of the trust, the remaining Assets are distributed to taxable remaindermen, normally the donor’s heirs. A Charitable Lead Trust is the opposite of a remainder trust in that Gettysburg College receives the regular payments for the specified period of time and the named beneficiaries receive the remaining trust assets at the dissolution of the trust. Gettysburg College may serve as trustee on a case by case basis. See EXHIBIT C for relevant minimums and requirements. There are two types of Charitable Lead Trusts:

• CHARITABLE LEAD UNITRUST: Gettysburg College receives a fixed percentage of the trust’s value, determined annually.
• CHARITABLE LEAD ANNUITY TRUST: Gettysburg College receives a fixed dollar payment.

Cryptocurrency: Any form of currency that exists digitally or virtually and uses cryptography to secure transactions. Cryptocurrencies don't have a central issuing or regulating authority, instead using a decentralized system to record transactions and issue new units.

Donor Advised Fund: Similar to a charitable savings account, a donor establishes the fund by written agreement at a sponsoring organization with a minimum gift to the fund which is invested by the sponsoring organization. The donor can make contributions to the fund at any time and makes recommendations that various amounts be distributed to charitable organizations of their choosing. The donor qualifies for a federal income tax charitable deduction or gifts to the donor advised fund.

Gift Acceptance Committee: Comprised of Vice President of College Advancement or their designee and Chief Financial Officer or their designee. Makes determination of gift acceptance for gifts that fall outside of the policies defined in this document.

IRA Charitable Rollover or Qualified Charitable Distribution (QCD): A way for those who are 70.5 years old or older to transfer up to $100,000 per year from their IRA directly to qualified organizations without having to pay income taxes on the money.

Last Will and Testament: A legal document that transfers some of the Assets held in one’s individual name to their beneficiaries, including charities, when they pass away.

Life Income Gifts: Charitable gift annuities and charitable remainder trusts, which can provide payments for life to one or more persons.

Life Insurance: Gifts of Life Insurance tend to fall into three broad categories. (1) Donors can give policies they no longer need for Gettysburg College to cash in immediately to collect their current (or cash) value. (2) A living donor can give a policy with cash value expecting it to be held as an Asset with Gettysburg College until maturity. This makes Gettysburg College the owner of the policy. Sometimes those policies have premiums that are fully paid; sometimes premiums continue to be due and the donor will commit to providing gifts to Gettysburg College to cover the premium payments. (3) Donors can name Gettysburg College as a beneficiary of a policy but continue to own it, using the death benefit to provide an ultimate gift (treated as a Bequest) to Gettysburg. Proposed gifts of Life Insurance should be discussed with a gift planning officer who can then move the gift through the acceptance process where appropriate.

Living Trust: a trust established during one’s lifetime that can continue after their lifetime for the benefit of their family or others. While it can operate similarly to a Last Will & Testament, the trust assets avoid the costs and delays of probate.

Marketable Securities: Securities that are publicly traded and that can generally be converted into cash quickly and easily. Examples of Marketable Securities include publicly traded stock or mutual fund shares, Treasury bills, and other money market instruments.

Non-marketable Securities: Securities that cannot be easily converted into cash or are not publicly traded. Examples of Non-marketable Securities include privately held stock, stock in closely held corporations, or shares of limited liability corporations (LLCs).

President’s Council: The senior executives who report to the president.

Real Property: Land and any permanent fixtures on it, including buildings, trees, etc. Land, residences, condominiums, rental property, farms, timberland, and any form of real estate are all types of Real Property.

Restricted Stock: Legal restrictions may exist on stock that is publicly traded, as in the case where a security is subject to lock-up imposed by the Securities and Exchange Commission and cannot be sold for a period of days, weeks, or months. During the lock-up period, the value of the security may rise or fall.

Restriction: A donor- or grantor-imposed stipulation and limitation on the use of contributed Assets. Restrictions can be limited as to purpose, time, or both. Gettysburg College has a legal obligation to use such gifts in accordance with those Restrictions.

Retained Life Estate: A Retained Life Estate contract enables a donor to gift a personal residence or farm and preserve the right to remain in the property for life. The donor qualifies for a charitable deduction in the year of the contract.

Tangible Personal Property: Personal property that can be felt or touched. Examples include furniture, cars, jewelry, and artwork. All gifts of Tangible Personal Property are reviewed by the Gift Acceptance Committee. Cash and checking accounts are not Tangible Personal Property.

Testamentary Clause: Testamentary Clause: A donor's statement in a will or Living Trust document. For a pledge to be a binding commitment, it must be collectible from the estate of the donor.:

“In order to provide for the fulfillment of this pledge, I promise to provide, by an effective testamentary disposition, for the payment of the balance of this pledge that remains unpaid at the time of my death. If for any reason this testamentary disposition is not made, or is not effective, the balance of this pledge shall be a debt due from me and payable by my estate at the time of my death.”

Underwater Endowments: When the fair market value of a true (donor-restricted) endowment fund drops below the historic gift value, the fund is considered “underwater.”

4. Policy Description

4.A. Principles

Gettysburg College’s fundraising activities are guided by the following principles:

i. CONFIRM GIFTS ARE BENEFICIAL TO GETTYSBURG COLLEGE

Gifts solicited and accepted by Gettysburg College are required to be all of the following:

1. Authorized: Gettysburg College’s fundraising policies and priorities are established by the Board of Trustees and the president in consultation with the President’s Council. All fundraising initiatives conducted in the name of Gettysburg College shall have the president’s approval; responsibility for designing and executing fundraising strategies is primarily delegated to the vice president of College Advancement within the provisions of the approved gift acceptance policy. Special fundraising initiatives intended specifically for a particular department or program may also require the approval of the appropriate division head/provost, at the discretion of the vice president of College Advancement.
2. Related to mission: Gettysburg College will solicit and accept gifts in support of its mission.
3. Providing benefit: Gettysburg College will not seek or accept gifts that provide insufficient financial benefit to Gettysburg College, might reasonably harm its reputation or assets, violate Gettysburg College policies, or are prohibited by law.
4. Given with minimal Restrictions and alternative uses: Donations of unrestricted gifts and those with minimal Restrictions are encouraged because of the flexibility they provide in meeting the most pressing needs of Gettysburg College. When working with donors on a gift agreement, College representatives should strive in every instance to include an Alternative Use Clause that will provide Gettysburg College with further flexibility.
5. Given without compromising Gettysburg College’s independence: Gettysburg College will not accept gifts that compromise academic freedom or the institution’s authority over admissions, faculty appointments, teaching, research, investment policies, or its other activities.

ii. CONFIRM DONORS ARE RESPECTED AND FULLY INFORMED

Donors are to be respected and fully informed by all of the following:

1. Consistent adherence to ethical standards: Gettysburg College seeks to confirm that gifts are in the best interests of the donor as well as Gettysburg College Representatives of Gettysburg College are expected to comply with Gettysburg College policies, including but not necessarily limited to this policy, the Employee Standards of Conduct, and the Conflict of Interest Policy. Representatives of Gettysburg College are also expected to abide by relevant laws and appropriate ethical codes and donor bills of rights developed by relevant professional organizations, including the Council for Advancement and Support of Education (CASE) and the National Association of Charitable Gift Planners (CGP).
2. Clear communications regarding use: Donors should be clearly informed about the intended use of their gifts. Gettysburg College staff and volunteers will represent the expected use and impact of proposed gifts accurately while striving to maintain flexibility in Gettysburg College’s commitment to donors so that Assets can be used effectively by Gettysburg College over time.
3. Donors are encouraged to consult with their own personal advisors (accountants, certified estate or financial advisors, attorneys, investment brokers, etc.) prior to making any major gift to Gettysburg College, particularly a deferred gift.
4. Full disclosure regarding life income agreements: Prospective donors of life income agreements will be provided, in advance, with essential disclosure statements and information about the terms and operations of the gift. Gettysburg College will encourage donors to consult with their families, their financial advisors and other personal advisors; staff must be clear that they represent Gettysburg College and its interests and are not in a position to offer tax, investment, or legal advice to the donor.
5. Written documentation of donor Restriction: Donors may occasionally make gifts or pledges to Gettysburg College while reserving the right to identify their preference for the purpose or use of the gift at a later time. Advancement staff will work closely with donors to secure donor preferences or Restrictions in writing within one calendar year and ideally before the end of the fiscal year in which the gift or pledge is made. Unless the Gift Acceptance Committee grants an exception, if a donor reserves the right to identify a Restriction for a gift, but a Restriction is not agreed-upon within one year, the gift will be placed in the College’s annual fund without any Restriction.
6. Compliance with laws and regulations: Gettysburg College shall accept, process and report gifts in accordance with current state and federal laws and regulations.

iii. CONFIRM APPROPRIATE STEWARDSHIP OF GIFTS

Donor stewardship serves as the foundation for building and maintaining lasting relationships between Gettysburg College and its supporters. The College will provide stewardship of gifts by the following:

1. Gift acknowledgement: Gettysburg College shall acknowledge donor generosity by thanking them in a timely manner, updating donors on the impact of gifts, and providing appropriate and meaningful recognition of their philanthropy while respecting their privacy;
2. Administration of gifts: Gettysburg College will administer gifts in accordance with donor-imposed Restrictions.
3. Investment of gifts: Gettysburg College will invest gift proceeds in accordance with relevant investment policies. These policies and objectives are established and monitored by Gettysburg College’s Board of Trustees.

4.B. RESPONSIBILITIES

i. Responsibility For Setting Policy and Priorities

Board of Trustees and President: Gettysburg College’s fundraising policies and priorities are established by the Board of Trustees and by the president in consultation with the President’s Council.

Board of Trustees Committees: The College Advancement Committee and the Finance Committee of the Board of Trustees are responsible for reviewing this Gift Acceptance Policy periodically, acting upon recommendations brought forward by the Gift Acceptance Committee or other board committees, and confirmation that the Policy is being effectively implemented through the Gift Acceptance Committee.

Gift Acceptance Committee: The Gift Acceptance Committee or their designees will review this Gift Acceptance Policy periodically and recommend changes to the president and Board of Trustees for approval.

ii. Responsibility FOR EXECUTING Policy

Board of Trustees: The Finance Committee of the Board of Trustees oversees and evaluates potential gifts of real estate and will recommend acceptance to the full board for approval. Gifts of closely held stock or private company stock require approval of the Finance Committee of the Board of Trustees.

President: The president is responsible for overseeing the implementation of the Gift Acceptance Policy, keeping the Board of Trustees informed on appropriate matters, and consulting with the Board in a timely manner on issues pertaining to this policy. The president establishes the Gift Acceptance Committee and makes a final determination, after consultation with the Chair of the Board of Trustees, when consensus is not reached by the Gift Acceptance Committee. The president will sign all endowment agreements.

Gift Acceptance Committee: The Gift Acceptance Committee is designed to facilitate the acceptance of a broad range of gifts, while ensuring that gifts conform to this Gift Acceptance Policy. Gifts that require special action or change shall be reviewed for approval by the Gift Acceptance Committee.

The Gift Acceptance Committee is responsible for evaluating and approving all potential gifts (including current use, endowment, capital, and deferred) that fall outside accepted parameters as prescribed in this Policy and Exhibits A to E. These include, for example, gifts that: (a) are funded with Assets other than cash or Marketable Securities; (b) have Restrictions that are not aligned with institutional priorities, require new programs or activities, require matching funds, or do not clearly replace expenditures already being made from Gettysburg College’s unrestricted funds; (c) may not provide sufficient financial benefit to the Gettysburg College; (d) may place Gettysburg College’s reputation at risk; or (e) require the approval of either the president and/or the Board of Trustees prior to acceptance.

The Gift Acceptance Committee shall consider the advice of College staff, general counsel or other outside consultants in matters relating to acceptance of gifts when appropriate. Review by counsel and/or other outside consultants is recommended for: (a) nonmarketable securities, including closely held stock, private company stock, and/or other stock or business interests that are subject to restrictions or buy-sell agreements;(b) documents naming Gettysburg College as trustee; (c) gifts involving contracts other than Charitable Gift Annuities and grants, such as Bargain Sales or other documents requiring Gettysburg College to assume an obligation; (d) transactions with potential conflicts of interest; and, (e) other instances deemed appropriate by the Gift Acceptance Committee.

Decisions of the Committee will be made by consensus. If consensus cannot be reached, gift proposals will be forwarded to the president for review and decision, in consultation with the chair of the Board of Trustees. Committee decisions will be shared with the Assistant Vice President for Advancement Systems and Prospect Research who will document the decision and have it entered into the Advancement CRM and then forward to the Director of Financial Services/Controller.

Vice President for College Advancement: The vice president for College Advancement is responsible for developing fundraising plans and for translating fundraising priorities into specific gift opportunities. These activities are conducted in the context of broad consultation with the president, the chief financial officer, other President’s Council members, staff of College Advancement, and the Board of Trustees.

The Vice President for College Advancement is responsible for overseeing:

1. the College Advancement staff in identifying, cultivating, and soliciting donors; acknowledging benefactors and building and maintaining strong relationships with them; explaining the benefits and limitations of various gift opportunities available to donors including outright gifts, deferred gift arrangements, estate gifts and other gift vehicles; confirming that the use Restrictions and structures of gifts are in accordance with Gettysburg College’s policies and applicable laws and are properly documented; and, gathering data from donors and providing analysis of offered Assets to allow Gettysburg College to make informed decisions regarding the acceptability of any proposed gift;
2. communication with donors on ongoing stewardship activities including, when applicable, preparing reports on the use of gift funds, and communicating endowment performance and valuation;
3. the administration of the Gift Acceptance Policy; and
4. compliance with applicable state registration requirements including initial registration, annual filings and required contract language (where applicable).

Chief Financial Officer: The Chief Financial Officer or a designee from Finance is responsible for coordinating the approval of potential gifts of real estate, closely held stock, and private company stock with the Finance Committee of the Board of Trustees; execution of trust documents on behalf of Gettysburg College; and reporting of endowment performance and valuation and the annual endowment report.

4.C. ADVANCEMENT SYSTEMS (COLLEGE ADVANCEMENT) AND FINANCIAL SERVICES

Valuation of gifts: Generally accepted accounting principles (GAAP) shall govern the recording of gifts to Gettysburg College.

Campaign reporting: Gettysburg College’s reporting of campaign fundraising activities will follow the CASE Global Reporting Standards, 1^st Edition, Published 2021

Campaign crediting: Donor crediting and recognition guidelines will be developed for each campaign. Current guidelines are in EXHIBIT E.

Financial recordkeeping: Advancement Systems and Financial Services shall coordinate recording and recordkeeping of gifts.

Receipting: Advancement Systems shall coordinate gift receipting. Acknowledgments are under the purview of the department of donor relations and stewardship.

4.D. GIFT ACCEPTANCE GUIDELINES

i. Asset Acceptance

Many types of Assets may be donated to Gettysburg College, but gifts take one of three general forms: outright gifts, pledges, or deferred (planned) gifts. Conditions and authorizations for acceptance vary according to the form of the gift and are specified in the approval matrices in Exhibit B and C.

ii. Pledges

Donors wishing to make gifts in installments over time will be asked to document their commitment in a gift agreement.

iii. Gifts with Restriction

Implicit in the acceptance of an Asset or gift vehicle is an agreement between Gettysburg College and the donor that Gettysburg College will expend or invest the gift in accordance with the donor’s Restriction(s), if any. No Asset can be accepted for a gift or pledge when the donor’s Restriction is not approved by Gettysburg College. Gettysburg College does not accept gifts with Restrictions that violate Gettysburg College’s policies, values, or standards, or which are so narrow as to compromise the usefulness of the gift. In cases where the suitability of a restricted gift is not clear, the Gift Acceptance Committee will evaluate the proposed Restriction and if approved, document the Restriction in the gift agreement. See EXHIBIT D for gift Restriction approval guidelines.

iv. Gifts without Restriction

Generally, all current-use gifts received without donor-imposed restrictions, except deferred gifts and Bequests, are considered gifts to the annual fund.

All unrestricted Bequests are recorded as gifts to the campaign reserve fund. Any exceptions to the policy for unrestricted Bequests of $250,000 or less may be approved by the president and reported to the Board of Trustees. Any exceptions to the policy for unrestricted Bequests greater than $250,000 are subject to the approval of the Board of Trustees. Notes: Separate remittances from a donor’s estate will be totaled for purposes of this policy. Unrestricted Bequests include deferred gifts for purposes of this policy.

At the request of the donor and with the approval of Vice President of College Advancement, Assets can be accepted without restriction but held for future restriction for no more than one year with a preference for a decision to be made before the fiscal year end. In these cases, the gifts are placed in a holding fund until a restriction is determined. Unless the Gift Acceptance Committee grants an exception, if a donor reserves the right to identify a restriction for a gift, but a restriction is not agreed-upon within one year, the gift will be placed in the College’s annual fund without any restriction or preference.

v. Donor Intent and Restrictions

Clarification of Donor Intent: When there is no indication of the donor’s intended use of the gift, the appropriate advancement officer will contact the donor to clarify and document their intentions.

Unacceptable Restrictions: When a donor makes an unsolicited outright gift for an intended use that is not acceptable to Gettysburg College, the vice president for College Advancement (or designee) will contact the donor to negotiate an acceptable use of the gift. If a mutually agreeable use for the gift cannot be determined, the gift will be returned.

Restricted Bequests: Bequests with donor-imposed restrictions are subject to Gettysburg College’s policy on named gifts and minimum funding levels. See Exhibit A – Minimum Funding Levels and Naming Opportunities.

Restricted Endowments: Endowments that support professorships, scholarships, student and faculty research funds, fellowships, and other Gettysburg College fundraising priorities generally require different funding levels, which are set by the College Advancement Committee of the Board of Trustees and promulgated to prospective donors in case statements, brochures, and conversations with advancement officers and volunteers. Changes in funding levels will not affect pre-existing endowment agreements or pledges in the process of being fulfilled see Exhibit A – Minimum Funding Levels and Naming Opportunities.

Budget-Enhancing or Unusual Restrictions: Prospective donors will sometimes suggest gift restrictions that are not aligned with institutional priorities or go beyond current priorities which, if accepted, require new programs or activities, require matching funds, or do not clearly replace expenditures already being made from Gettysburg College’s unrestricted funds. The costs and benefits of such gifts must be carefully weighed before they are accepted. Responsibility for acceptance of such gifts is assigned to the Gift Acceptance Committee. Committee decisions will be shared with the Assistant Vice President for Advancement Systems and Prospect Research who will document the decision and have it entered into the Advancement CRM and then forward to the Director of Financial Services/Controller. The criteria used in deciding the suitability of such gifts will typically include:

(a) the ability to administer the gift without additional staffing or other expense that would render the gift a net cost to Gettysburg College;

(b) the compatibility of the gift’s purpose with Gettysburg College’s mission and values; and

(c) the gift’s potential to enhance the College’s ability to serve its constituents and improve the overall quality of Gettysburg College.

vi. ENDOWMENT NAMES

Names of endowment funds may be changed by written request of the donor(s) and agreement of Gettysburg College. The vice president for College Advancement is authorized to execute the agreement for Gettysburg College. (See Exhibit A – Minimum Funding Levels and Naming Opportunities.)

vii. SUBSEQUENT CLARIFICATION OF PURPOSE

Donor-specified purposes (uses) of existing endowment funds may be clarified by mutual agreement between the donor (or designee) and Gettysburg College. Any changes must be documented in writing, approved by the Gift Acceptance Committee, and signed and dated by the donor (or designee) and the president.

viii. HONORARY AND MEMORIAL GIFTS

Gifts in honor or in memory of individuals are credited to the annual fund unless another existing fund or purpose is specified by the donor (e.g., endowment).

ix. PHYSICAL PLANT ADDITIONS AND IMPROVEMENTS

Gettysburg College welcomes gifts to enhance the physical plant. Such funds are used to support specific building and renovation projects, equipment, and other campus enhancements. As such, they are fully expended over the course of a project. Donors may make gifts for such purposes in their own names or in memory or honor of another person selected by the donor.

Generally, naming recognition for a facility or equipment requires a gift equal to at least fifty percent of the cost of the facility or project. Smaller physical enhancements or equipment purchases may require full funding. Naming for equipment will persist for the useful life of the equipment. Naming opportunities for individual spaces in buildings are established when the scope of the project is determined. Specific dollar amounts to name individual spaces are determined in relation to the square footage of the individual spaces or other enhancements and the project as a whole and will vary from project to project. Naming will persist for the life of the space until the configuration is substantially altered, unless the naming arrangement is terminated pursuant to Policy for Renaming. Specific details for each naming gift will be outlined in the signed gift agreement.

4.E. Spending Distributions from Restricted Funds

i. RESTRICTIONS FOR ILLIQUID ASSETS

An Asset other than cash or Marketable Securities is considered illiquid. When donors make illiquid gifts to start new programs or initiatives, the new program or initiative may not be implemented until the asset is liquidated. In these cases, donors can choose to make operating fund gifts to initiate programs until the gifted asset has been liquidated. There are rare exceptions to this which occur when Gettysburg College decides to retain an illiquid asset. When the decision to NOT liquidate an asset is made, the new program or initiative will be established with other resources.

ii. SPENDING DISTRIBUTIONS FROM ENDOWMENT FUNDS

Annual earnings available for funding an endowment’s purpose are calculated in accordance with the annual spending draw formula established by the Board of Trustees. An endowment draw is generally available for use the following fiscal year for gifts received by November 1st. Spending on Underwater Endowment funds is assessed on an annual basis.

4.F. Professional Advisors, Fees and Appraisals

i. PROFESSIONAL ADVISORS

College Employees/Agents: No College employee or agent of Gettysburg College may serve as an advisor or counsel to donors or prospective donors on matters related to contributions to Gettysburg College.

Donor’s Use of Professional Advisors: Gettysburg College encourages each donor to consult with independent tax, financial, and/or legal counsel prior to making a contribution to Gettysburg College. It is the donor’s responsibility to directly employ and compensate independent counsel in these transactions.

College’s Use of Professional Advisors: Gettysburg College retains the right to engage its own legal counsel, appraisers, or financial advisors in any gift acceptance decision. Specifically, prior to the acceptance of a gift of real estate or illiquid assets, the Gift Acceptance Committee or its designees shall complete due diligence to include, at a minimum:

1. marketability review;
2. property appraisal or broker’s market assessment;
3. title review;
4. Environmental assessment;
5. Property inspection;
6. Review for strategic and/or reputation issues; and
7. Donor self-disclosure.

ii. FEES AND COSTS

Finder’s Fees or Commissions: No finder’s fee or commission of any type will be paid by Gettysburg College to any party in connection with the completion of a gift to Gettysburg College.

Professional Fees: Fees associated with any conditions of gift acceptance are the responsibility of the donor. Gettysburg College encourages each donor to consult independent tax, financial, and/or legal counsel prior to making a contribution to Gettysburg College. It is the donor’s responsibility to directly employ and compensate independent counsel. With the exception of electronic transfer fees (such as credit card fees or wire transfer fees), fees associated with the transfer of assets to Gettysburg College are the responsibility of the donor. Once an asset is transferred to Gettysburg College’s ownership, Gettysburg College has the sole responsibility to determine the timing and method of sale of non-cash gifts (such as stocks, bonds, collections, etc.). Any fees associated with Gettysburg College’s sale of non-cash gifts are the responsibility of Gettysburg College.

Administrative and Investment Management Costs: Fiduciary, management, accounting, and similar costs of charitable trusts and other gifts shall be borne by the trust or other vehicle and not by Gettysburg College. Effective June 2022, the Board established an annual administrative fee to recover oversight and administrative costs in managing the pooled endowment fund. The fee is based on 0.08% (8 basis points) of the 12-quarter average endowment market value as of December 31^st of the preceding calendar year.

iii. APPRAISALS

Donors shall secure and pay for their own appraisals to substantiate charitable deduction claims. Gettysburg College may also secure and pay for appraisals for its own purposes.

4.G. Legal and Ethical Considerations

i. TITLE, COMPETENCE AND GIFTS AS INVESTMENTS

Gettysburg College will not participate in gift discussions if there is a question as to whether the donor has unclouded title to the assets (including illegally obtained but legally purchased cultural property and antiquities) or whether the donor is mentally competent to legally transfer the property as a gift to Gettysburg College (unless the donor is properly represented). Consideration shall be given to evidence that demonstrates suspicious origins of a prospective donor’s wealth. Gettysburg College does not solicit gifts as investments.

ii. LEGAL

Gettysburg College shall comply with all local, state and federal laws and regulations concerning every charitable gift it encourages, solicits, or accepts. All required disclosures, registrations, and procedures (such as those required for gift annuities, pooled income funds, and other arrangements) shall be made and/or followed in a thorough and timely manner.

iii. GETTYSBURG COLLEGE EMPLOYEE AS EXECUTOR OR TRUSTEE

Except in the case of a family member, College employees may not serve as the executor or trustee under a will or trust or in any other way act as a fiduciary in any matter in which Gettysburg College is a beneficiary under that instrument. The Gift Acceptance Committee may approve exceptions to this policy.

iv. GETTYSBURG COLLEGE AS EXECUTOR OR TRUSTEE

Gettysburg College prefers not to serve as executor of donors’ wills or as trustee of donors’ Living Trusts. It will serve as trustee of Charitable Remainder and Charitable Lead Trusts in accordance with policy guidelines set forth in Exhibit C. Exceptions to the policy require the approval of the Gift Acceptance Committee.

4.H. Grants

Gettysburg College frequently responds to grant initiatives proposed by various charitable foundations and other entities and encourages faculty and, when appropriate, staff members to seek grants from corporations, foundations, and government granting agencies. Because such grants often incur an obligation on the part of the College to match or supplement grant expenditures or to sustain initiatives seeded by grants, such proposals must have the support of the applicable President’s Council member and must receive the written approval of the Chief Financial Officer (or their designated financial officer) prior to submission. The application and approval process for both private and public source grants is detailed in the Grants Guidebook maintained by the office of college grants.

The Gettysburg College president designates the Authorized Organizational Representative (AOR) to submit electronic proposals on behalf of Gettysburg College. The proposal budget must have prior sign off by the Director of Financial Services/Controller or the Director of Treasury Management and the Dean/Vice President of the relevant division. This sign-off procedure is detailed in the Gettysburg College Grants Guidebook.

The AOR at Gettysburg College is the Director of College Grants. The back-up AOR is the Director of Financial Services/Controller and the Director of Treasury Management. When required by the funder, acceptance of awards will be authorized by the President or Provost.

5. Policy Management

This policy is jointly owned by College Advancement and Finance.

The Director of Financial Services, Director of Treasury Management and the Assistant Vice President of Advancement Systems and Prospect Research are responsible for implementing and enforcing this policy.

6. Related Materials

• Exhibit A – Minimum Funding Levels and Naming Opportunities
• Exhibit B – Asset Acceptance Approval Guidelines
• Exhibit C – Deferred Giving Guidelines
• Exhibit D – Gift Restriction Approval Guidelines
• Exhibit E – Campaign Crediting Guidelines

Exhibit A – Minimum Funding Levels and Naming Opportunities

+For funds established with life-income gifts, the naming minimum must be met with no more than 50% of the face value of the gift. In addition, the fund agreement will include language providing an alternative if the minimum funding level is not reached at the end of the split-interest term. For example: If contributions to the Scholarship meet or exceed the naming minimum as of the date of this agreement ($100,000), all gifts will be placed in an endowed fund with only the annual earnings available for funding the Scholarship, according to the formula established by the Board of Trustees. If the minimum is not reached and no further contributions are expected, contributions will be used for general endowed scholarship [or, based on donors’ preference, used for current scholarship support in the donors’ names].

*Smaller physical enhancements or equipment purchases may require full funding. Exceptions to Exhibit A require the approval of the Gift Acceptance Committee

Exhibit B – Asset Acceptance Approval Guidelines

(A) Includes cash and cash equivalents, foreign currency, credit cards, and payroll deductions.

(B) Includes patents, royalties, trademarks, and copyrights.

(C) Donations of Tangible Personal Property to the library are coordinated with the library director.

(D) Including works of art, beautification / landscaping, hardscaping, indoor and outdoor statues, and technology.

Note: Upon receipt of an IRS Form 8283, Noncash Charitable Contributions, from a donor, an authorized representative of Gettysburg College Advancement may sign the form to acknowledge receipt of the donated property. The College's signature acknowledges receipt only and does not represent agreement with the donor's valuation of the property. A copy of the completed Form 8283 must be provided to Financial Services to monitor the disposition of the donated property and comply with IRS reporting requirements, including the filing of IRS Form 8282 if the property is sold, exchanged, or otherwise disposed of within the applicable IRS reporting period. Assets not described here require the approval of the Gift Acceptance Committee.

Exhibit C – Deferred Giving Guidelines

ACGA—American Council on Gift Annuities

*—Applies to gifts of Life Insurance to be owned/held by Gettysburg College and not those given with the intent that they be cashed in immediately.

**—Applies to gifts for which Gettysburg College serves as administrator or trustee. Gettysburg College will not serve as administrator or trustee of Charitable Annuity Trusts

***—ACGA rates assume a 50% residuum realized by the charity.

NOTE: Gettysburg College has accepted Pooled Life Income Funds in the past but new PIFs are not solicited.

Exceptions to these guidelines require the approval of the Gift Acceptance Committee.

Exhibit D – Gift Restriction Approval Guidelines

* Special donor purpose (i.e., Budget-Enhancing) includes all contributions that are not for general operating support, an addition to an existing restricted gift or endowment, an identified fundraising priority as determined by the President, or other physical enhancements such as trees, benches or equipment

Exceptions to these guidelines require the approval of the Gift Acceptance Committee.

Exhibit E – Campaign Crediting Guidelines

Campaigns beginning on or after June 1, 2011, adhere to national guidelines for the crediting of gifts in campaigns in accordance with standards established by the Council for the Advancement and Support of Education (CASE). The following document and reporting chart establish the giving categories for Campaign Crediting and how those categories are reported at Gettysburg College.

Cash

All gifts of cash made during the established campaign period are credited to the campaign.

Pledges

All pledged gift amounts made during the established campaign period are credited to the campaign.

Matching Gifts

Matching gifts made during the established campaign period are credited to the campaign.

Marketable Securities

Gifts of public securities made during the established campaign period are credited to the campaign. Stock is valued based on the average of the high and low quoted trading price on the legal date of gift.

Non-marketable Securities

Gifts of closely or privately held stock made during the established campaign period are credited toward the campaign if valued by an independent appraiser and accepted by the Gift Acceptance Committee and the Finance Committee of the Board of Trustees.

Other Assets

Gifts of Tangible Personal Property, gifts-in-kind, intellectual property, mineral rights and other assets made during the established campaign period are credited toward the campaign based on the independently appraised value of the property. Gifts must be accepted by the Gift Acceptance Committee.

Real Estate

Gifts of real estate made during the established campaign period are credited at the independently appraised value of the property. Real estate cannot be encumbered with a mortgage and must be accepted by the Gift Acceptance Committee and the Board of Trustees of Gettysburg College. Gifts of real estate can be made outright, as Bargain Sales, or to fund Life Income Gifts.

Bargain Sale

The gift portion of Bargain Sales made during the established campaign period is credited toward the campaign. This is the difference between the independently appraised fair market value and Gettysburg College’s purchase price for the real estate or other asset. The Gift Acceptance Committee and the Board of Trustees must approve all gifts of Bargain Sales of real estate.

Example: Mr. and Mrs. Harris want to make a gift of their home as a Bargain Sale to Gettysburg College. They purchased their house for $50,000. The appraised value of the house is now $250,000. Gettysburg College offers to buy their house for $50,000, or their cost basis. Mr. and Mrs. Harris are entitled to a charitable deduction of $200,000. This amount would be considered a gift credit to the campaign.

Bequests

Realized Bequests

Gifts received through a will or Living Trust, during the established campaign period, are credited as outright gifts at face value as long as they have not been credited toward a prior campaign. If so, and the amount is greater than previously credited, the difference will be credited.

Bequest Expectancies

1. Bequests in wills or Living Trusts where the donor is age 65 or older, documented during the established campaign period, are credited toward the campaign at face value of the Bequest. If the will or Living Trust represents more than one donor, all donors must be age 65 or older during the course of the campaign. Gettysburg College must receive documentation of the Bequest, including the amount of the gift or, if it is a percentage Bequest, the donor’s good faith estimate of the current value of the Bequest. Bequests are revocable and, as such, will be credited as Bequest expectancies.
2. Bequests in wills or Living Trusts where the donor, or donors, do not attain age 65 during the course of the campaign, will not be credited to the campaign.

Life Insurance

Realized Gifts of Life Insurance

Realized gifts from Life Insurance policies, where the donor passes away during the course of the campaign, and where Gettysburg College is named beneficiary, will be credited at the total death benefit amount of the policy received by the college only if Gettysburg College has not previously recognized the gift in a prior campaign.

Non-Realized Gifts of Life Insurance

1. Gifts of irrevocable paid up Life Insurance policies made during the campaign, where Gettysburg College is made the owner and beneficiary of the policy, and the donor is age 65, or older, during the course of the campaign, will be credited at the death benefit amount of the policy if the Gift Acceptance Committee decides to hold until maturity. If the committee decides to convert the policy to cash, credit will be given at the cash surrender value. Gettysburg College must receive the policy for its records. The policy cannot have been counted in a prior campaign.
2. Gifts of irrevocable paid up Life Insurance policies made during the campaign, where Gettysburg College is made the owner and beneficiary of the policy, and the donor will not attain 65, during the course of the campaign, will be counted at the cash surrender value of the policy less any premium payments made by the donor through Gettysburg College and/or outstanding loans against the policy. Gettysburg College must receive the policy for its records.
3. Gifts of irrevocable non-paid up Life Insurance policies made during the campaign, where Gettysburg College is made the owner and beneficiary, and the donor does not plan to make additional premium payments, will be credited at the cash surrender value of the policy less any previous premium payments made by the donor through Gettysburg College and/or outstanding loans against the policy. Gettysburg College must receive the policy for its records. Gettysburg College will typically cash in this type of policy.
4. Gifts of irrevocable non-paid up Life Insurance policies made during the campaign, where Gettysburg College is made the owner and beneficiary, and the donor signs a pledge to complete premium payments to fully fund the policy, and the donor is age 65, or older, during the course of the campaign, will be credited at the death benefit amount of the policy. Gettysburg College must receive a copy of the beneficiary form from the insurance company designating it as a beneficiary and the amount of the death benefit.
5. Revocable gifts of Life Insurance where Gettysburg College is made the beneficiary of the policy, and the donor is age 65, or older, during the course of the campaign, will be credited at the death benefit amount of the policy if documented.

Gifts of Qualified Retirement Plans

Realized Gifts

Gifts of qualified charitable distributions from Individual Retirement Accounts (IRAs), and gifts from Beneficiary Designations from IRAs and other qualified retirement plans such as 401(k)s, 403(b)s, etc., during the time frame of the campaign will be credited at the gift amount as long as the donor has not received gift credit from a prior campaign. If a realized gift is more than a previously credited amount, the difference will be credited toward the current campaign.

Non-Realized Gifts

Donors who notify Gettysburg College they made Gettysburg College the beneficiary of their qualified retirement plans will receive gift credit as revocable gift expectancies at age 65, and above, as long as their gift commitments have not been previously credited. Gettysburg College must receive a copy of the Beneficiary Designation form and documentation of the expected amount of the gift. New gift commitments which are greater than earlier commitments to a prior campaign will be credited accordingly.

Life Income Gifts

Realized Gifts – Charitable Remainder Trusts (CRT)

Gifts received as remainder interests from previously established Charitable Remainder Trusts in which Gettysburg College is trustee are not credited toward the campaign, because gift credit was received at the time the gift was made. However, if gift credit was not given at that time, the donor would receive gift credit at the face value of the CRT during the current campaign. Realized gifts received as remainder interests from CRTs, with outside trustees, are credited at the face amount of the gift proceeds as long as they have not been previously credited by Gettysburg College in a prior campaign.

New Gifts of Charitable Gift Annuities, Charitable Remainder Trusts

Gifts to establish new Life Income Gifts such as Charitable Gift Annuities and charitable remainder trusts which irrevocably name Gettysburg College as beneficiary will be credited in the campaign at the face value of the gift.

Example: Mr. and Mrs. Jones make a gift of $100,000 to establish a gift annuity or Charitable Remainder Trust at Gettysburg College. They will receive gift credit of $100,000 in the campaign in spite of the fact that they will receive a lesser charitable federal income tax deduction and life income from their gift.

Gifts to establish new Charitable Remainder Trusts, where Gettysburg College is not the irrevocable beneficiary, will be credited as a revocable expectancy. Where the donor is age 65, or older, during the course of the campaign, they will receive gift credit at the face value of the trust. Gettysburg College needs to have a copy of the trust in order for it to count in the campaign.

Charitable Lead Trusts

Previously committed lead trust payments to Gettysburg College during the campaign are counted as annual gifts during the campaign years. New lead trust commitments will be counted as a pledge to Gettysburg College over the specified number of years of the trust. Gettysburg College will need trust documentation for this gift to count in the campaign.

Example: Mr. and Mrs. Smith establish a lead trust using a gift of $1M. They specified that Gettysburg College annually receive 4% from the trust over a period of 20 years. ($40,000 x 20 years = $800,000). The Smiths would receive gift credit during the campaign for a gift of $800,000.

NOTES:

1 Realized death benefits are reported as gift income only if Gettysburg College has never previously recorded the policy value or any donor-paid premiums, and if Gettysburg College has not been paying the premiums.

2 Realized death benefits are credited at face value as long as it has not been credited in an earlier campaign.

3 College is the owner and irrevocable beneficiary of the policy.

4 Expectancies are revocable instruments in which Gettysburg College is a named beneficiary. These include Bequests, (revocable) Life Insurance policies and non-realized qualified retirement plan assets.