Terms of Program-Related Investments: Private Foundation Expenditure Responsibility


To meet the expenditure responsibility requirements in making a program-related investment, a private foundation must require that each investment be made subject to a written commitment signed by an appropriate officer, director, or trustee of the recipient organization.

The commitment should specify the purpose of the investment and should contain an agreement by the organization:

  1. To use all amounts received from the private foundation only for the purposes of the investment and to repay any amount not used for those purposes, provided that, for equity investments, the repayment is within the limitations concerning distributions to holders of equity interests,
  2. To submit, at least once a year, a full and complete financial report of the type ordinarily required by commercial investors under similar circumstances and a statement that it has complied with the terms of the investment,
  3. To keep adequate books and records and to make them available to the private foundation at reasonable times, and
  4. Not to use any of the funds to carry on propaganda, influence legislation, influence the outcome of any public elections, carry on voter registration drives, or, when the recipient is a private foundation, to make grants that do not comply with the requirements regarding grants to individuals or expenditure responsibility.

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