SC (Kim Laughton)

Summary: Schwab Charitable, a tax-exempt public charity, opposes the proposed regulations in Notice 2017-73 that would impose additional regulatory burdens on donor-advised funds (DAFs) similar to those on private foundations. They argue that DAFs are already compliant, and that the proposed rules—specifically regarding "bifurcated gifts," pledges, and public support—would create unnecessary administrative burdens, undermine donor privacy, and reduce the efficiency of charitable giving.