The Pew Charitable Trusts

How it makes and monitors grants (Schedule I, Part IV)

Pew's procedures for monitoring the use of grant funds inside the United States by unrelated organizations are modeled after the "expenditure responsibility" rules (see Treas. Reg. 53.4945-5) and are designed to fulfill the purposes of expenditure responsibility, namely that grant funds are expended solely for their intended charitable purpose, that Pew receives complete reports regarding how the funds were spent, and that Pew is able to provide full reports to the IRS regarding the granted funds. First, to help assure that the grantee will use the grant for proper purposes, Pew conducts a pre-grant inquiry into each potential grantee, which includes diligence regarding the grantee's programs, experience, finances, management, and reputation; verification of the grantee's corporate and tax status; and a search of the U.S. Treasury Department Office of Foreign Asset Control's (OFAC) sanctions program listings to confirm that the grantee is not a prohibited or otherwise restricted party. Second, Pew enters into a written grant agreement with each grantee, in which Pew secures the grantee's commitments: (i) to use the grant funds solely for purposes consistent with Pew's tax-exempt status under section 501(c)(3) of the Internal Revenue Code; (ii) not to use any grant funds directly or indirectly to support or oppose any candidate for public office, or to provide a benefit to any political party or candidate; (iii) to maintain records of the grantee's receipts and expenditures an