DAF Sponsor
Due Diligence Package
Program-Related Investment evaluation materials for DAF sponsors, advisors, and investment committee members.
One of your account holders has requested that their donor-advised fund make a grant or Program-Related Investment (PRI) to Civic Engine Fund, a Missouri nonprofit corporation applying for recognition as a 501(c)(3) public charity. Civic Engine Fund conducts its charitable guarantee program through a wholly-owned Delaware subsidiary, Civic Engine Guarantee Pool, LLC.
This package provides the information your grants or investment committee needs to evaluate and approve the contribution. For a PRI, the program is designed to satisfy all four tests under IRC Section 4944(c), subject to confirmation by your tax counsel; a grant is a charitable contribution to the nonprofit Parent.
- Your account holder advises a grant or PRI from their DAF to Civic Engine Fund (the nonprofit Parent)
- 100% of committed capital is held in U.S. Treasury securities (~4.35% at current rates); accrued interest is distributed pro rata to pre-funded supporters
- The Treasury pool backs construction-loan guarantees, issued by Civic Engine Guarantee Pool, LLC, for affordable housing in Kansas City
- Interest accrues alongside the guarantee pool — growing guarantee capacity over time
- After the program term (15 years), accrued interest is distributed pro rata and undrawn principal is returned to pre-funded supporters
- No UBTI — Treasury interest excluded under IRC 512(b)(1)
The Fund is structured to satisfy all four IRC 4944(c) tests:
1. Charitable Purpose
Primary purpose is charitable — 1,600 affordable housing units, 8,000 tons CO₂ reduction, comprehensive wraparound services addressing eight cost burdens.
2. No Significant Income Purpose
~4.35% in accrued Treasury interest is well below market for comparable development risk (8–12%), confirming that production of income is not a significant purpose.
3. No Lobbying Purpose
The Fund engages in zero lobbying activities. No portion of Fund capital is used for influencing legislation.
4. No Political Purpose
No political campaign activities of any kind. The Fund is exclusively focused on housing development and community impact.
We can provide a PRI qualification analysis for your legal team's review; the Master Guarantee Support Agreement and Program Guide are available in the data room.
We have designed this program to be straightforward for a DAF sponsor to review: 100% U.S. Treasury collateral, no active portfolio management, no equity risk to the underlying investments, and a clear charitable purpose. For a PRI, the structure is designed to satisfy all four statutory tests; a grant is a charitable contribution to the nonprofit Parent. We welcome a direct conversation with your committee at any stage of your review.
Supporting Materials
The following documents are available for your grants or investment committee's review.
Fund Summary
| Parent | Civic Engine Fund — Missouri nonprofit (501(c)(3) applicant) |
| Guarantee Entity | Civic Engine Guarantee Pool, LLC (Delaware; wholly owned) |
| Program Launch Threshold | $10,000,000 in total commitments (designed to scale) |
| Minimum Commitment | $1,000,000 per Guarantee Support Provider |
| Collateral | 100% U.S. Treasury securities (pre-funded commitments) |
| Interest to Supporters | Accrued Treasury interest distributed pro rata (~4.35% at current Treasury rates) |
| PRI / Grant Eligible | Foundations and DAFs may grant or PRI to the Parent — PRI addresses all four IRC 4944(c) tests (subject to tax counsel confirmation) |
| UBTI | None (IRC 512(b)(1)) |
| Program Term | 15 years (5-year origination period) |
| Program Administration | Cost-recovery; excess returned |
| Carried Interest | None |
| Performance Fee | None |
| Guarantee Coverage | Each dollar backs multiple dollars of construction lending (illustrative) |
What Your Donor's Capital Enables
two KC districts
30–80% AMI
avoided annually
savings for families
savings
per $1 committed
over 40 years through
capital recycling
Compatible DAF Structures
The Fund is structured to accept PRIs from a broad range of donor-advised fund platforms.
- Impact-focused sponsors (ImpactAssets)
- National sponsors (Fidelity Charitable, Schwab Charitable)
- Community foundations (Greater Kansas City Community Foundation)
- Custom PRI programs
If your platform does not currently offer PRI options, we can provide additional materials to support an approval process.