Investment & Spending Policy of the Foundation
Donors thinking about making gifts to the Foundation may
have questions about how their gifts will be managed to
ensure their community legacy. Questions about the
Foundation may include:
While the answers can get technical, these are important
questions to ask. The Foundation's
Investment & Spending
Policy is carefully designed with both the
present and the future in mind. Watchful growth and
responsible spending ensure that the donations provided
by our donors will continue to make a difference in
perpetuity.
Unlike organizations that raise funds each year to carry
on daily operations, the objective of a community
foundation is to build funds that will grow with
community needs, and continue to provide funding for
opportunities for generations to come.
Investment Return
- Overall return on investment for 2007: 7.71%
- Five-year annualized return on investment:
10.90%
Investment Consultant
- Mason Investment Advisory Services, Inc.
Local Advisors
- FNB Bank
- Merrill Lynch
- Mifflinburg Bank & Trust
- MTB Investment Advisors
- Sovereign Bank
- Susquehanna Trust and Investment Company
- The Muncy Bank and Trust Company
- Wachovia Bank, N.A.
- Woodlands Bank
Purpose and Background
The purpose of the First Community Foundation of
Pennsylvania's Investment and Spending Policies (IS
Policies) is to support current as well as future
grantmaking and administrative needs while ensuring the
inflation-adjusted spending power of the Foundation's
charitable assets over time.
Fiduciary Responsibility
The Board of Directors has fiduciary responsibility for
all funds of the Foundation, which are held subject to
and in accordance with the Foundation's governing
documents (namely its articles of incorporation and
bylaws, as may be further amended from time to time).
The Foundation holds all of its assets in corporate
form, whether managed as part of the Foundation's pooled
investments or separately managed by a financial
institution preferred by a donor.
All
investment firms and banking institutions must be
willing to manage assets subject to the Foundation's
governing documents, IS Polices, and the fiduciary
oversight of the Board of Directors to assure that our
donor's funds, whether part of the Foundation's
investment pool or separately managed, will qualify as a
"component fund" of our community foundation as defined
by the Department of Treasury and Internal Revenue
Service (IRS).
Finance Committee
The Board of Directors has delegated supervisory
authority over its financial affairs to the Finance
Committee of the Board. In
carrying out its responsibilities, the Finance Committee
and its agents will act in accordance with IS Policies
and all applicable laws and regulations. The Board
reserves to itself the exclusive right to revise IS
Policies, though it will look to the Finance Committee
for counsel and guidance.
The Finance Committee will include at least three
Board directors, at least two representatives from the
community at large, the Board
Chairman as an ex-officio member, and the President as
an ex-officio member. Members will be appointed by the
Board with the goal of creating a diverse committee with
expertise in both the financial and charitable fields.
The Finance Committee has the following
responsibilities:
- Submit to the Board, for approval, IS Policies
outlining the objectives and guidelines for the
Charitable Pool.
- Periodically review the Investment and Spending
Policies and recommend appropriate changes to the
Board.
- Include in its IS Policies a list of investment
restrictions that the Committee believes are not
appropriate for the Foundation.
- Recommend to the Board a spending policy for the
Charitable Pool, taking into account sustainable
payout rates.
- Monitor the Foundation's Charitable Pool on a
quarterly basis and report to the Board at least
annually on the status of investments.
- The Committee has chosen to hire an Investment
Consultant and shall review them periodically.
In general, the purpose of the IS Policy is to
outline a philosophy and attitude that will guide the
investment management of the Foundation's funds toward
the desired results. It is intended to be
sufficiently specific to be meaningful, yet flexible
enough to be practical. The Committee has considered the
financial implications of a range of policies, and this
statement describes the prudent investment process that
the Committee deems appropriate.
Certain italicized terms in this document are more
specifically defined in the Definitions section.
Total Return Approach
The Foundation utilizes a "Total Return" approach to
guide its investing and spending, as allowed by
Pennsylvania Codes 5547, 5548, and 5549 pertaining to
the use and management of trust assets by nonprofit
corporations, and as permitted by its governing
documents. This approach allows the Board to establish
an annual payout rate based on a percentage of the asset
base over a five-year period. The payout amount may be
more or less than the actual income earned by interest
and dividends, with capital appreciation (and in rare
cases principal) used to help meet the established
payout when necessary. By using the total return
approach, the Foundation is able to maintain and
increase the value of donated assets while funding
current needs at an appropriate level.
The benefits of total return include:
- The Foundation and its financial partners are not
forced to focus investment strategies on required
distributions from income alone.
- Because investments can be managed for both growth and
income, the Foundation can better focus on current needs
while assuring adequate funding for future needs.
- A larger and more predictable flow of funds will be
available since distribution will not be determined
solely by changes in current investment income, interest
rates, etc.
The annual cash payout of all funds, except those
funds containing illiquid assets (such as certain real
estate or other property) will be 5.0% of the average
market value, using a 20-quarter or 5-year trailing
average and net of financial management fees. For funds
less than five years old, the market value will be the
average of all quarterly market values to date. This
payout will be used to meet both grantmaking and
administrative needs per schedule.
Investment Objectives
The investment objective of the Foundation's
Charitable Pool is to meet the payout percentage, plus
inflation, plus 0.5% of underlying growth in the pool.
This is an investment objective that attempts to grow
the portfolio, after distributions and after inflation.
The Committee has agreed to tolerate the volatility of a
growth oriented asset allocation strategy that may offer
the potential for greater Charitable Pool values and
greater payouts in the future, understanding that this
may result in a less stable payout from year to year.
As is consistent with a growth-oriented portfolio,
the investment time horizon is over ten years. For
evaluation purposes, discussed more fully in the Asset
Allocation Section, the Committee will monitor
performance and peer group rankings over the trailing
three, five, and ten year periods.
The Foundation's current Spending Policy of 5%, which
includes the payout for grantmaking and the annual
administrative fee, implies a target rate of return,
before inflation, of 5.5% per year for the Charitable
Pool.
To assist the Foundation in gauging the success of
the return on investments, the Foundation shall employ
as its investment return goal the following formula:
5 yr Annualized CPI + Spending Policy (5.0%) +
0.5%
This target return is an average annualized return to
be measured on a five year trailing basis. This is
the time period used to judge whether or not the
portfolio is meeting its objective. Each
individual year may be more or less than target.
Asset Allocation
The Charitable Pool's risk and liquidity posture are,
in large part, a function of asset class mix. The Asset
classes are listed in the Asset Allocation Targets chart
in this section.
Considering the Charitable Pool's investment
objective, time horizon, risk tolerances, performance
expectations, and asset class preferences, an
appropriate portfolio allocation was identified.
After the allocation strategy is implemented, the
percentage allocation to each asset class sub-category
may vary by as much as plus or minus 20% of the target.
These ranges are illustrated in the following Asset
Allocation Targets chart in this section.
Significant capital market movements, as well as
relative manager performance, can lead to the asset
allocation moving beyond the allowable ranges of 20%.
The Investment Consultant shall monitor the
effectiveness of the asset allocation targets and assure
that the allocation is staying within the established
ranges by rebalancing the portfolio as needed. Asset
allocation targets will not be changed without Committee
approval.
The Foundation desires to maintain positions with
certain Local Advisors. This may result in a
portfolio that, in the early years, does not follow,
exactly, the asset allocation targets and due diligence
criteria as outlined in this policy. This policy sets
targets and due diligence criteria to work toward over
time. New gifts and agency funds will be used to
continue to work toward the investment policy asset
allocation over time while coordinating the Local
Advisors for their best fit into the desired asset
allocation strategy.
Asset allocation Targets - "D"
Portfolio
|
Asset Category |
Rebalancing Trigger - Low End |
Portfolio Percentage Allocation |
Rebalancing Trigger - High End |
| |
|
|
|
|
I. Safety Assets |
0.8% |
1.0% |
1.2% |
| |
|
|
|
|
II. Income Assets |
|
|
|
| Taxable Bonds: |
|
|
|
|
Short Term Maturities (1-5 yrs)
|
5.2% |
6.5% |
7.8% |
|
Intermediate Term Maturities (5-10 yrs)
|
5.6% |
7.0% |
8.4% |
|
Long Term Maturities (10+ yrs)
|
5.6% |
7.0% |
8.4% |
|
International Bonds
|
4.4% |
5.5% |
6.6% |
|
Total Income Assets |
20.8% |
26.0% |
31.2% |
| |
|
|
|
|
III. Growth Assets |
|
|
|
|
Large Cap U.S. Stocks - Value
|
8.8% |
11.0% |
20.4% |
|
Large Cap U.S. Stocks - Growth
|
13.6% |
17.0% |
13.2% |
|
International Stocks - Value
|
6.0% |
7.5% |
9.0% |
|
International Stocks - Growth
|
6.0% |
7.5% |
9.0% |
|
Growth Real Estate
|
5.6% |
7.0% |
8.4% |
|
Total Growth Assets |
40.0% |
50.0% |
60.0% |
| |
|
|
|
|
IV. Aggressive Assets |
|
|
|
|
Small Cap U.S. Stocks - Value
|
5.6% |
7.0% |
8.4% |
|
Small Cap U.S. Stocks - Growth
|
4.0% |
5.0% |
6.0% |
|
International Small Cap
|
2.4% |
3.0% |
3.6% |
|
Energy/Natural Resources/Commodities
|
6.4% |
8.0% |
9.6% |
|
Total Aggressive
Assets |
18.4% |
23.0% |
27.6% |
Investment Restrictions
When selecting mutual funds and separate account
managers, the Investment Consultant will use due
diligence criteria prescribed in the IS policies (mutual
funds and separate account managers will be referred to
as "managers" unless specifically referenced).
With the exception of mutual funds chosen pursuant to
the due diligence criteria prescribed in the IS
Policies, separate account managers must seek permission
to use derivative instruments as described in the
definitions section of the IS Policies.
With the exception of strategies employed by mutual
funds that are chosen pursuant to the due diligence
criteria prescribed in the IS Policies, no securities
may be purchased on margin.
No "illiquid" investments may be purchased by a
separate account manager or the Investment Consultant,
such as private placements, limited partnerships, and
hedge fund vehicles, among others. The Committee
will consider illiquid investments on a case by case
basis.
Cash Management Policy
From time to time the Foundation may maintain large
cash balances in reserve for future needs and
contingencies or for Non-Endowed Funds. The Consultant
is authorized to manage these reserves for enhanced
yields consistent with a conservative cash management
policy. To manage credit risk, instruments used for cash
management will be limited to the following:
- Government issues (known as "Treasuries")
- Government-Sponsored Enterprise Securities
(known as "Agencies"), such as Farm Credit System,
Federal Home Loan Bank System, Federal National
Mortgage Association, and Student Loan Marketing
Association, some of which are not explicitly backed
by the full faith and credit of the U.S. Government.
- FDIC insured Certificates of Deposit, to be
bought only in $100,000 increments per bank to
assure insurance coverage and only at banks rated
165 ("Excellent") or higher, as rated by the Bank
Financial Quarterly, issued by IDC Financial
Publishing, Inc.
Usually, no instrument will have a maturity at issue,
or remaining maturity at purchase, of greater than
twelve months. Generally, and depending upon the
specific liquidity needs of the Foundation, a ladder
strategy will be employed to further minimize
interest rate risk.
Due Diligence Policy
Introduction
For an asset allocation strategy to be effective, each
asset class must be represented by using a manager that
will best represent the class objective. Otherwise, the
results will be much different than anticipated. This is
particularly true during times of adversity or crisis.
A qualifying manager must be a registered investment
advisor under the Investment Advisors act of 1940. In
most instances the Committee will use managers that have
established track records of at least five years. A ten
year track record is preferred, if possible.
Professional management must be in place, with few major
changes, for the period being evaluated. The Committee,
with the assistance and support of the Investment
Consultant, will decide which managers to use based upon
their particular contribution to the portfolio. This
often results in having more than one manager for the
same asset class, each with a different bias and
approach.
To identify managers who fit the implementation
objectives, a rigorous research process is followed. The
research process involves both a quantitative and
qualitative review.
Quantitative Analysis
The quantitative analysis attempts to distill a large
universe of managers into a small group of strong
performers. Managers who pass this phase of the research
process have a history of delivering above-average risk
adjusted returns, as measured against their peers who
fit the same asset class. Performance during multiple
market cycles is observed. The goal is to not chase
returns, but to look for consistent, long-term track
records of at least five and preferably ten years.
Also, a returns based style analysis is performed
to assure accurate asset class fit.
Qualitative Analysis
The qualitative analysis involves an in-depth review of
the manager and its history. Several years of all
published reports are reviewed for consistency of
management style and stability of professional staff. A
review of historical portfolios is performed for clues
about the true style and risk posture of the manager
over time. Personal interviews and on-site office visits
may be made, as necessary.
Managers are continuously monitored and new managers are
reviewed in an attempt to find the most effective
managers, in the judgment of the Investment Consultant.
Benchmarks (Reference
Points)
Several evaluation benchmarks are required. One to
measure the success of the allocation strategy and
others to measure the success of the managers used to
implement the allocation.
Growth Allocation Reference Point: This reference
point, produced by Morningstar as “Moderate Allocation”,
invests in both stocks and bonds and maintains a
relatively higher position in stocks. These managers
typically have 50%-70% of assets in equities and the
remainder in fixed income and cash.
The performance of the Foundation’s Charitable Pool may
be greater or less, depending upon how aggressive the
asset allocation strategy is relative to the reference
points.
Each manager will be
measured against its specific peer group, using a
category average of mutual funds with the same asset
class focus.
Accounts Managed
by Local Advisors
A list of allowable
and prohibited securities and transactions for equity
and fixed income accounts, managed by local financial
partners, is available on request.
The Foundation and
Investment Consultant are to be informed immediately by
telephone of any significant changes affecting the
investment management company or bank, its parent(s),
management personnel, ownership, structure, or key
personnel, including partners, principals, officers,
strategists, and individual portfolio managers. This
communication should be followed up in writing within
seven (7) business days.
Other
Considerations
In all cases,
performance evaluations will focus more on trailing
three, five, and ten year performance measures
(including risk and risk adjusted measures), rather than
short term variances from the benchmarks. Managers are
normally expected to perform at or above their peer
group averages.
Program-Related Investments
Definition & Background: A Program-Related Investment
(PRI) is an investment by a foundation to support a
project or activity, which is of a charitable or
community benefit nature, is typically beyond the scope
of traditional grantmaking, and is viewed as an asset
because the principal value of the investment (at a
minimum) is expected to be returned. A PRI is similar to
a recyclable grant: the repayment of a loan or the
return of equity can eventually be recycled for another
charitable purpose. PRI's may be made to a non-profit or
a for-profit entity engaged in activities that
demonstrate a clear community benefit within the
parameters identified by the IRS.
PRI's may include, but are not limited to, loans &
financing arrangements, loan guarantees to share risk
with a traditional lender, pooled or venture capital
funding, stock purchases in certain local enterprises,
and certificates of deposit with community reinvestment
banks. The Foundation may make PRI's directly or may
disburse funds to an intermediary organization that then
lends or invests the funds for the benefit of qualifying
projects. PRI's are not intended to compete with or
substitute for traditional for-profit financial
resources available within the area, but instead to
bridge the gap between traditional funding sources and
clearly identified financial needs within the community.
The IRS provides that all investments that qualify as
PRI's are exempt from classification as "jeopardizing
investments." The IRS defines a PRI as satisfying the
following three tests:
- Its primary purpose is to further some aspect of the
foundation's charitable mission;
- The production of income or the appreciation of
property is not a significant purpose of the PRI (i.e.
it is structured to produce lower-than-market returns on
a risk-adjusted basis); and
- It may not be used to support any lobbying or
political campaign activities.
PRI's are most frequently used to support economic and
community development projects, but can be used to
assist a wide range of public benefit and charitable
opportunities. Examples include: neighborhood
redevelopment projects, land conservation or historical
preservation efforts, job training & development,
small-business start-ups, sustainable farming
operations, nonprofit capital needs, etc.
The benefits to the Foundation of using PRI's include:
- Recycled Resources – PRIs can be used to advance
program goals and, once they are repaid, can be re-used
for new projects
- Large Projects – When a desirable project requires
funding that exceeds the Foundation's typical grant
size, PRIs can sometimes provide the needed capital
- Varied Partners & Leverage – PRIs may attract other
lenders to the project and leverage additional funds
from banks, corporations, or government.
- Visibility – PRIs may help support a particularly
important local project that requires capital
investment.
The benefits of PRIs for potential recipients include:
- Applicant Pool – Applicants that may not qualify to
apply for a grant from the Foundation, may qualify for a
loan or equity investment.
- Administrative Strength – PRIs can help foster
management capacity and produce a more "bankable"
organization over time by helping to establish a credit
history.
- Large Projects – PRIs can help raise capital in
addition to grant resources for larger projects.
- Long-Term Relationships – PRIs help establish
productive relationships with the Foundation and/or an
intermediary funder by creating a partnership with
mutual financial and programmatic objectives.
Spending Limits: The Foundation may use up to 1.5%
(cumulative) of its assets to make Program-Related
Investments. In determining that percentage, the
Foundation will use a 20-quarter or 5-year trailing
average market value, exclusive of illiquid assets (such
as real estate and other property) and exclusive of any
designated funds where PRIs may, in the judgment of the
Board, be considered imprudent or impractical. Such
investments may be made from the annual payout used for
unrestricted grantmaking or may be made from the
invested corpus of its assets. Because PRIs funded from
corpus and in excess of the 5.0% annual payout may
affect the overall total rate of return, such PRIs will
not be included when calculating total return. However,
performance measures will be established and monitored
for all PRIs, and reported to the Board at least
annually.
Nature & Type of PRI: The decision to make a PRI will be
made on a case by case basis by the Board of Directors
and shall be consistent with IRS parameters for PRIs and
community priorities identified by the Foundation. When
necessary, the Foundation shall seek legal counsel from
an attorney or attorneys knowledgeable about federal and
state regulations as they pertain to PRIs.
Interest Rates, Terms, & Structures: Interest rates on
PRIs may vary from zero percent to just below the
prevailing market rate. The IRS requires rates to be
below-market on a risk-adjusted basis. Typically, rates
are calibrated to each borrower's capacity and to the
project's ability to make principal and interest
payments, return equity, etc. The Foundation's desire to
generate interest income from its PRIs may also
determine or affect rates, provided earnings are not a
significant reason for making the PRI. Generally PRIs
will only be made where there is a likelihood of 15% or
less that the PRI will default, although the Board may
approve a higher level of risk where warranted.
Re-Payment: PRIs are to be taken seriously and are
intended to be repaid. All applicants and projects will
be carefully screened, including review of financial
status, management capabilities, potential for long-term
self-sustainability, credit and community involvement
histories, other funding sources, proposed use of
funding and relation to identified community needs, risk
of default, etc. Written agreements shall be developed
for each PRI. When appropriate and possible, the
Foundation will work with an intermediary organization –
such as financial institution, governmental entity,
major nonprofit service provider, etc. – which can
reduce the level of risk by drawing on the
intermediary's expertise.
Accounting: Foundation staff will work with the
Foundation's auditor to track and report on PRIs. In the
year that a PRI is made, its entire value will be
reflected as a qualifying distribution from the
Foundation, as is the case with traditional grants.
Outstanding PRIs will remain on the Foundation's balance
sheet as a separate asset category until they are repaid
or forgiven. Periodically, adjustments may be made to
the carrying value of PRIs, based on the likelihood of
collection. Interest income from PRIs is treated like
interest on any other foundation investment.
Fee Schedule
Based on Average Market Value Determined at the Start of
Each Year
Administrative Fees
Permanent
Endowments

| Payout |
Admin. Fee |
Annual Payout (for grant distributions) |
| Up to $1 million |
1.00% |
4.00% |
| $1 million - $4
million |
0.75% |
4.25% |
| $4 million + |
0.50% |
4.50% |
Provisional (Non-Endowed) Funds
5% of market value of the fund or total gifts into the
fund annually, which ever is greatest depending upon
fund activity and anticipated duration of the fund. Pass-Through Gifts/Stock Gifts for Designated Charities
5% of the market value of the gift Trusteeship of Charitable Remainder Trusts
Use above endowment fee schedule as the basis, with the
understanding that fees will be negotiated based on the
anticipated value of the remainder interest to FCFPA as
well as the complexity and likely duration of the trust. Foundation Management Services
The Foundation will encourage, and as appropriate,
accept new or existing private foundations with assets
of at least $1 million as supporting organizations;
foundations with a lesser asset base may be accepted as
advised component funds. The above fee schedule will
serve as a basis for negotiating a fee structure in each
situation consistent with the philanthropic focus and
complexity of the foundation. At present, the Foundation
will not provide management services to private
foundations that do not affiliate with the Foundation.
Updated September 4, 2007
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