Three key changes from the draft guidelines released in January should be noted:
- The Corporation reduced the minimum grant award to intermediaries from $5 million to $1 million, responding to concerns about the required matching for the higher amount.
- The notice eliminates a preference for pre-identified subgrantees in the intermediary’s application for funds. Intermediaries can apply with “pre-selected” subgrantees, but these subgrantees be selected through a competitive grant process and comply with the other relevant criteria in the notice.
- The notice provides two scenarios in which an entity would not qualify as an intermediary. A national nonprofit organization that grants only to local affiliates that then carry out the central work of the national organization would be ineligible as a grantmaking institution because grantmaking is only collateral to the national organization’s mission and the grants are exclusively made to the affiliates. However, if the local affiliate is also a grantmaking entity and the principal work of the local affiliate is to make grants to a broad range of nonprofits, thereby having a “diverse portfolio,” two or more local affiliates could form a partnership that would be eligible as intermediary
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