•Fundraising cannot result in an
unacceptable or undue private benefit
(any benefit provided to a person or
organization that is not a charitable beneficiary,
or a benefit to a charitable beneficiary that exceeds the bounds of charity)
•Ex: Non-arm’s length fundraising
contracts without proof of FMV
•Incidental private benefits will be
acceptable where it is necessary,
reasonable, and proportionate to the public
benefit achieved