REPORT: Who Is Lobbying against Common-Sense Charity Reform?

In total, those lobbying against DAF reform outside of the ACE Act spent $7,990,000 on lobbying efforts over the past five and a half years.

Note that not all of these revenue amounts are necessarily directed towards DAF lobbying. This is because when an organization lists multiple issues or bills in their lobbying disclosures, we do not know how much money was spent by these organizations on each specific issue or bill. For this reason, the amounts shown here represent the amount spent in total on each lobbying disclosure that mentions DAFs, whether or not that entire amount was directed towards DAF-related lobbying efforts.

Most of the organizations lobbying on donor-advised funds in general, and the ACE Act in particular, are nonprofit donor-advised fund sponsors that have a financial interest in maintaining the current rules governing DAFs and charitable giving. But reform opponents are also supported by for-profit firms of DAF sponsors that lobby on their behalf.

One of the most active of these firms is the Community Foundation Awareness Initiative, or CFAI. The issues lobbied by the CFAI generally revolve around community foundation and donor-advised fund regulation and tax policy. The CFAI has employed one lobbying firm, Van Scoyoc Associates, which has engaged three lobbyists over the years — Jeff Hamond, Susie Gorden, and Robin Rubin. In total, from 2018 to the second quarter of 2023, the CFAI has spent $4,440,000 on lobbying efforts, much of which has been directed towards either the ACE Act or donor-advised funds more generally. They have also worked with a media firm called Turn Two Communications on a national public relations campaign promoting their anti-reform platform.

The CFAI was originally set up with the IRS as a tax-deductible charity in 2020. But the organization filed none of the appropriate tax returns to maintain that status, and their charitable status was eventually revoked in 2023.