Endnotes

Endnote 1: 
In this report, we regularly state that PRIs must be made with “below-market” or “concessionary” financial terms. We use this terminology because it quickly and accurately captures what is articulated in Treasury Regulations Section 53.4944-3 with regard to the second test of a PRI, “In determining whether a significant purpose of an investment is the production of income or the appreciation of property, it shall be relevant whether investors solely engaged in the investment for profit would be likely to make the investment on the same terms as the private foundation.” In essence, the clearer it is that a for-profit investor would not make the investment on the same terms as the private foundation (i.e. the more “below-market” or “concessionary” the financial terms of the investment), the more clear it is that the investment under analysis meets the second PRI test. We do recognize that there exists some legal ambiguity and debate about what terms in what contexts qualify PRIs as meeting the second PRI test.

Endnote 2: 
“Total granting by MN private foundations and corporate grantmakers from 1998 to 2016” and “Total charitable giving in Minnesota by all sources from 1998 to 2016” were calculated using statistics provided by the Minnesota Council on Foundations in their series of reports entitled “Giving in Minnesota,” which were routinely published from 1976 to 2014. Dollar values for these calculations were carefully adjusted for inflation to 2016. The most recent data provided in this series of reports was for fiscal year 2012. Reasonable, conservative estimates were made for fiscal years 2013 through 2016 based on prior year data and trends.
 

Endnote 3:
“From the Margins to the Mainstream: Assessment of the Impact Investing Sector and Opportunities to Engage Mainstream Investors.” World Economic Forum. September 2013.

Endnote 4:
“Private Foundations: ‘Jeopardizing Investments’ Defined.” IRS. Web. January 6, 2018.<https://www.irs.gov/charities-non-profits/private-foundations/private-foundation-jeopardizing-investments-defined>

Endnote 5:
“Form 990-PF.” IRS. Web. January 6, 2018. <https://www.irs.gov/pub/irs-pdf/f990pf.pdf>

Endnote 6:
“FAQs: Form 990.” GuideStar. Web. January 6, 2018. <http://www.guidestar.org/GenericPage.aspx?path=/rxg/help/faqs/form-990/index.aspx#faq1947>

Endnote 7:
“Instructions for Form 990-PF.” IRS. Web. January 6, 2018. <https://www.irs.gov/pub/irs-pdf/i990pf.pdf>

Endnote 8:
“Foundation Stats.” Foundation Center. Web. May 30, 2017. <http://data.foundationcenter.org/>

Endnote 9: 
“Members.” Minnesota Council on Foundations. Web. May 30, 2017. <https://mcf.org/members>

Endnote 10: 
“Philanthropy Classification System.” Foundation Center. Web. January 6, 2018. <http://taxonomy.foundationcenter.org/subjects>

Endnote 11:
“CPI Inflation Calculator.” United States Bureau of Labor Statistics. Web. December 1, 2018. <https://www.bls.gov/data/inflation_calculator.htm>

Endnote 12:
“Philanthropy Classification System.” Foundation Center. Web. January 6, 2018. <http://taxonomy.foundationcenter.org/organization-type>

Endnote 13:
“Members.” Minnesota Council on Foundations. Web. May 30, 2017. <https://mcf.org/members>

Endnote 14:
“Foundation Stats.” Foundation Center. Web. May 30, 2017. <http://data.foundationcenter.org/>

Endnote 15:
Gelles, David. “Big Companies Put Their Money Where the Trash Is.” New York Times. November 28, 2015.  <https://www.nytimes.com/2015/11/29/business/energy-environment/big-companies-put-their-money-where-the-trash-is.html?_r=1>

Endnote 16:
“Impact Report.” Closed Loop Fund. June 2017. <http://www.closedlooppartners.com/wp-content/uploads/2017/06/CLF-EOY2016-Public-Progress-Report_FINAL-1.pdf>