fiscal sponsorship eligibility & restrictions

Effective Date: August 1, 2025
Legal Entity: Equity Impact Fund, an Arkansas nonprofit corporation (“EIF,” “we,” “us,” or “our”).
Contact: help@equityimpactfund.org • 1720 S Walton Blvd, Ste 4 #155, Bentonville, AR 72712

purpose

This policy defines who may be sponsored by Equity Impact Fund (EIF) and the activities that are permitted under EIF’s 501(c)(3) charitable status. All funds raised for sponsored projects are assets of EIF and are spent at EIF’s discretion for its charitable purposes, with full variance power.

sponsorship models

EIF offers two standard models:

  1. Comprehensive (Model A): Project operates as a program of EIF. Staff and contractors are engaged by EIF. EIF provides fiduciary control, financial management, HR, and compliance.
  2. Pre-approved grant relationship (Model C): EIF raises or receives charitable funds restricted for a project and makes grants to a separate entity or individual to carry out charitable activities under an approved grant agreement with clear deliverables and reporting.

EIF decides the appropriate model during review.

minimum eligibility criteria

An applicant must meet all of the following:

  1. Charitable purpose: The proposed work is exclusively charitable under IRC 501(c)(3) and aligns with EIF’s mission.
  2. Public benefit: Activities primarily benefit the public, not private parties. No private inurement or excess benefit to insiders.
  3. Clear plan and budget: Defined objectives, timeline, beneficiaries, and a responsible budget and funding plan.
  4. Leadership and governance: Identified project lead and advisory group, with safeguards to avoid conflicts of interest.
  5. Operational capacity: Demonstrated ability to carry out the work responsibly, including program oversight, basic financial literacy, and willingness to follow EIF policies.
  6. Compliance readiness: Agreement to use EIF systems and comply with EIF policies for finance, grants, HR, data privacy, safeguarding, brand, fundraising, and reporting.
  7. Fundraising integrity: Agreement to truthful, non-deceptive solicitations; proper treatment of restricted gifts; timely donor acknowledgments; and adherence to EIF’s Gift Acceptance Policy.
  8. Risk profile: Acceptable legal, financial, reputational, and operational risk based on EIF due diligence.
  9. Geography: Activities restricted to the U.S. with appropriate controls for cross-border giving, anti-terrorism checks, and local legal compliance.
  10. Non-discrimination: Commitment to lawful non-discrimination in beneficiaries and services, consistent with EIF policy and applicable law.

documentation required

  • Application describing purpose, activities, beneficiaries, and anticipated outcomes
  • Itemized budget and first-year cash flow plan
  • Bios of key personnel and any advisory board members
  • Draft communications or fundraising language and channels to be used
  • If Model C: the legal name and EIN of the grantee, or government-issued ID for individuals, plus a grant plan with deliverables and reporting
  • If working with minors or vulnerable populations: safeguarding plan and background check procedures

restricted and prohibited activities

Projects are not eligible for fiscal sponsorship with Equity Impact Fund if they engage in, plan to engage in, or have a history of engaging in any of the following:

  1. Political Campaign Activity – Any direct or indirect participation or intervention in a political campaign on behalf of, or in opposition to, any candidate for public office at the federal, state, or local level. This includes, but is not limited to:
    • Public endorsements or opposition statements;
    • Contributions of money, goods, services, or staff time;
    • Use of organizational resources for campaign-related purposes;
    • Distribution of campaign materials or statements prepared by or on behalf of a candidate;
    • Coordinated voter outreach or communications designed to favor or oppose a candidate.
  2. Lobbying in Excess of Legal Limits – Any lobbying or attempts to influence legislation that exceed IRS limits applicable to 501(c)(3) organizations. Limited, non-substantial lobbying may be permitted only with prior written approval from EIF and must remain within allowable limits.
  3. Private Benefit or Self-Dealing – Conferring more than incidental private benefit to insiders, donors, board members, staff, or related parties. Engaging in transactions that would violate IRS self-dealing rules or conflict-of-interest policies.
  4. Commercial or Profit-Distribution Aims – Activities that are primarily commercial in nature or that distribute net earnings to private individuals or entities.
  5. Illegal or High-Risk Activities – Any activities that are illegal, fraudulent, unsafe, or that expose EIF to unacceptable legal, financial, reputational, or safety risks.
  6. Hate, Violence, or Discrimination – Advocacy or activities that promote violence, harassment, or discrimination against any individual or group based on race, ethnicity, national origin, religion, sex, gender identity, sexual orientation, age, disability, or other protected class.
  7. Sanctions, Anti-Terrorism, and Anti-Money Laundering Violations – Transactions or relationships that violate U.S. Office of Foreign Assets Control (OFAC) sanctions, anti-terrorism laws, or anti-money laundering regulations.
  8. Gifts with Improper Donor Control – Accepting funds where the donor retains control over the expenditure of the funds, expects a private benefit, or where the project cannot honor EIF’s variance power over charitable assets.
  9. Clinical or Regulated Research without Approvals – Human subjects research, medical interventions, or other regulated activities conducted without required Institutional Review Board (IRB) approvals, government licenses, or appropriate insurance coverage.
  10. High-Liability Field Activities without Safeguards – Activities involving elevated safety risks that lack adequate training, insurance, supervision, and written safety protocols.

fundraising restrictions

  • All solicitations must state that donations are to EIF for the charitable purposes of the sponsored project and are subject to EIF’s variance power.
  • Donors may indicate a preference for a project but do not control expenditures.
  • No quid pro quo benefits beyond token acknowledgments unless properly disclosed and receipted.
  • Crowdfunding, raffles, or gaming require prior EIF written approval and must comply with applicable law.
  • Use of fiscal sponsors, sub-sponsors, or pass-throughs requires EIF approval and written agreements.
  • Use of the EIF name and logos must follow brand guidelines.

international activity

For projects with activities or payments outside the United States:

  • Grantees and vendors must pass anti-terrorism and sanctions checks.
  • Additional documentation may be required to verify charitable purpose and expenditure responsibility.
  • Currency controls, registration, or permits must be observed.
  • Extra monitoring, receipts, and site verification may be required.

HR and volunteers

For Model A projects:

  • Staff and contractors are engaged by EIF. Independent contractor status must meet legal tests.
  • Background checks and safeguarding training are required for work with minors or vulnerable populations.
  • Volunteers must sign EIF waivers and follow safety protocols.

data and privacy

Projects must comply with EIF’s Privacy Policy and data protection requirements, including secure handling of donor and beneficiary data, limited access, and prompt reporting of incidents.

insurance and safety

Depending on risk, EIF may require proof of general liability, professional liability, auto, workers’ compensation, or special event insurance, plus written safety plans.

review and approval process

  1. Screening: Eligibility check against this policy, mission fit, and initial risk screen.
  2. Due diligence: Verification of identities, background checks as needed, reference checks, budget review, and legal review of risks.
  3. Model selection: EIF assigns Model A or Model C, or declines.
  4. Agreement: Execution of a Fiscal Sponsorship Agreement that incorporates this policy, reporting, fees, and termination provisions.
  5. Onboarding: Training on finance, fundraising, communications, safeguarding, and reporting.

ongoing requirements

  • Quarterly financial and program reports, with outcomes and variance explanations
  • Pre-approval for changes in scope, geography, or budget reallocations above agreed thresholds
  • Immediate notice of incidents, complaints, media inquiries, or potential claims
  • Annual review for continued eligibility

grounds for denial or termination

EIF may deny or terminate sponsorship if any of the following occur:

  • Misrepresentation or material omission in the application or reports
  • Repeated policy violations or failure to follow EIF direction
  • Loss of mission alignment or public benefit
  • Legal, financial, safety, or reputational risk that EIF deems unacceptable
  • Failure to meet reporting, safeguarding, or insurance requirements
  • Sanctions, AML, or anti-terrorism concerns

required applicant acknowledgments

Applicants must agree that:

  • All funds raised are gifts to EIF and subject to EIF’s exclusive legal control and variance power.
  • Donors do not receive private benefit and do not control expenditures.
  • Project leadership will comply with EIF policies, laws, and reasonable directives.
  • EIF may decline any gift or disbursement and may suspend or terminate activity if compliance or safety concerns arise.