Grants Management Manual Chapter 3 - Compliance ReviewDetermining Funding Source for Grants.

Determining Funding Source for Grants.

U.S. sourcing vs. non-U.S. sourcing

Generally determined by grant amount and the activities described in the proposal.

Each funding source has its own set of criteria in terms of how a grant is set up.

U.S. sourcing considerations:

Does the project contain activities that are prohibited under Expenditure Responsibility (“ER”) or require other special treatment? (Definition of ER and ER restrictions are discussed below in Expenditure Responsibility Section.)

Does the proposal contain activities that might be considered lobbying under the U.S. tax code? (Discussed later in Lobbying Section.)

Funding a grant using U.S. and non-U.S. funds

Based on the current thresholds for using U.S. funds, a grant that contains some activity that cannot be funded using U.S. funds but also contains other activity that could be funded with U.S. funds may be able to be funded using a combination of both U.S. and non-U.S. funds.

The funding source for these grants should be Open Society Institute Budapest Foundation, an entity that has both U.S. and non-U.S. funds available for regranting.

Funding Sources available for use only in New York

Alliance for Open Society International, Inc. or AOSI (public charity) sourcing used for:

The regranting of third-party funding (that may or may not also include OSF/Soros funds as well) to either organizations or individuals, with Legal department’s approval.

Foundation to Promote Open Society or FPOS (U.S. 501(c)(3) private foundation) sourcing used for:

Grants to U.S. 501(c) (3) public charities

Expenditure Responsibility (ER) Grants to U.S. entities

Includes supporting organizations, non-public charities, fiscal agent grants, entities in the process of getting a determination letter, U.S. for-profits

Expenditure Responsibility (ER) Grants to non-U.S. entities (subject to U.S. sourcing criteria)

Equivalency Determination (ED) grants

Open Society Institute or OSI (private operating foundation) sourcing used for:

Grants to individuals, including grants paid through an organization if the grant is earmarked for that individual

Grants to entities operating in sanction regimes as determined by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) for which OSI holds an applicable OFAC license

As of April 16, 2014 OSI currently has an OFAC license to support humanitarian work in Sudan. This license expires on June 30, 2016. As of July, 2014 no other U.S. OSF entity has an OFAC license (e.g., FPOS, AOSI), and OSI’s license is non-transferrable .
Legal department should be contacted if a program wishes to make a grant to or with activities in Cuba, Iran, North Korea, Sudan, or Syria.

Funding sources available for use only in Budapest

Open Society Foundation – London or OSF-London sourcing used for:

Third party funding when OSF London has agreed to receive funds from the third party and distribute funds to final beneficiary

Project purpose fits well with the charitable object of OSF

Funding sources available for use in Budapest and for referral from New York to Budapest prior to approval:

Open Society Institute Budapest Foundation or OSI-BP sourcing used for:

Grants to U.S. public charities originating from Budapest office (using U.S. funds)

Grants over $100,000 to a non-U.S. organization originating from Budapest or New York office, in which all or part of the grant can be subjected to Expenditure Responsibility restrictions (using U.S. funds)

Includes bifurcated grants referred from New York using U.S. and non-U.S. funds, as well as grants originating in Budapest using only U.S. funds

Grants originating in Budapest to organizations for which FPOS has performed an Equivalency Determination (ED) (using U.S. funds)

Grants to organizations located in Hungary (generally NOT using U.S. funds; Budapest Legal should be consulted)

If OSI-BP is selected as the funding source on the proposal record by a GO in New York, the grant will go through a referral process after the grant has been approved.

The referral has to be approved by Grants Management in Budapest.
If approved, the grant will be managed by a GO in Budapest from that point on.

Foundation Open Society Institute or Zug/FOSI (Swiss entity) sourcing used for:

Grants under $25,000 to non-US organizations (except for public charity equivalents: EDs)

Grants $100,000 or under with activities potentially prohibited under ER restrictions to non-U.S. organizations

If FOSI is selected as the funding source on the proposal record by a GO in NY, the grant will go through a referral process after the grant has been approved.

The referral has to be approved by Grants Management in Budapest.

If approved, the grant will be managed by a GO in Budapest from that point on.

OSI – Assistance Foundation or OSI-AF (Liechtenstein entity) sourcing used for:

Grants to entities without ED status in: the Russian Federation (although OSF is currently not awarding any grants inside the Russian Federation), Turkey, Armenia, Azerbaijan, Tajikistan, and Uzbekistan.

1 Comments

Joe Behaylo

Where should we cover OSPC enabling for lobbying referrals? Here?

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