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b)Fundraising with a More Than Incidental Private Benefit
•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
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