DAF Sponsor
Due Diligence Package

Program-Related Investment evaluation materials for DAF sponsors, advisors, and investment committee members.


Dear DAF Sponsor:

One of your account holders has requested that their donor-advised fund make a Program-Related Investment (PRI) into the Civic Engine Guaranty Fund LLC, a Delaware limited liability company.

This package provides the information your investment committee needs to evaluate and approve this PRI. The Fund is designed specifically to be compatible with DAF-sourced PRIs and is designed to satisfy all four tests under IRC Section 4944(c), subject to confirmation by your tax counsel.

How the Investment Works
  • Your account holder advises a PRI from their DAF into the Fund
  • 100% of capital is invested in U.S. Treasury securities (~4.35% net annually)
  • The Treasury portfolio backs construction loan guarantees for affordable housing in Kansas City
  • Returns are retained and compound inside the Fund — growing guarantee capacity over time
  • At fund termination (15 years + optional extensions), principal + all compounded returns return to the DAF
  • No UBTI — Treasury interest excluded under IRC 512(b)(1)
Why This Qualifies as a PRI

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% net return is well below market for comparable development risk (8–12%), confirming investment return 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 have prepared a detailed PRI Qualification Opinion (Document 1.9) for your legal team's review.

We have designed this fund to be the most straightforward PRI a DAF sponsor will ever review: 100% U.S. Treasury collateral, no active portfolio management, no equity risk to the underlying investments, and a clear charitable purpose that satisfies all four statutory tests. We welcome a direct conversation with your investment committee at any stage of your review.

Jonathan Arnold
Managing Member, Civic Engine Fund Management LLC

Supporting Materials

The following documents are available for your investment committee's review.

DAF Sponsor Due Diligence Package
Document 4.7
Complete due diligence materials for DAF sponsor review, including PRI eligibility analysis.
PRI Qualification Opinion Template
Document 1.9
Legal analysis of all four IRC 4944(c) tests with supporting citations.
Fund Overview
Document 1.10
Offering terms, fee structure, entity organization, risk factors in summary format.
Impact Summary Table
Document 2.3
Quantified social and environmental impact metrics aligned with IRIS+ standards.

Fund Summary

Fund Civic Engine Guaranty Fund LLC (Delaware)
Manager Civic Engine Fund Management LLC
Initial Fund Size $30,000,000 (scalable to $200M)
Minimum Investment $250,000 (DAF/Foundation PRI) · $1,000,000 (other accredited investors)
Collateral 100% U.S. Treasury securities
Net Return ~4.35% (retained, compounding; based on current Treasury rates)
PRI Eligible Yes — all four IRC 4944(c) tests addressed (subject to tax counsel confirmation)
UBTI None (IRC 512(b)(1))
Fund Term 15 years + two 2-year extensions
Effective Cost ~0.15% (cost-recovery management fee; excess returned)
Carried Interest None
Performance Fee None
Leverage 5.75:1 (development enabled per fund dollar)

What Your Donor's Capital Enables

~4,000
homes across
two KC districts
~1,600
affordable units
30–80% AMI
~8,000
tons CO₂
avoided annually
$9.6M
annual rent
savings for families
$4.8M
annual energy
savings
5.75:1
leverage
ratio
51×
development leverage
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.

If your platform does not currently offer PRI options, we can provide additional materials to support an approval process.