Comment on FR Doc # 2012-09468

This particular proposed rule exhibits various examples for program-related investments (PRIs) by private foundations and in doing so attempts to define the types of investments that may qualify as PRIs. As noted in the report, “the primary purpose of a program-related investment must be the accomplishment of a charitable purpose.” In elaborating upon the qualifications an investment must possess to further a charitable cause, it is my opinion that this proposed rule aptly widened the sphere for such investments. In particular, there are several principles that I agree with most fervently. For example, number 4, which denotes that a “high rate of return does not automatically prevent an investment from qualifying as program-related”, is especially important in dispelling the type of black and white thinking that often accompanies charitable considerations. It is most definitely possible for a private foundation to make an investment that has both spectacular returns and a charitable function. Next, I was equally in agreement with principle 5, which denotes that “PRIs can be achieved through a variety of investments,” including but not limited to loans and equity investments. Again, this broadens the scope of PRIs, allowing for a freer investment philosophy. Lastly, though I do not disagree with the 1st principle, which is that an activity conducted in a foreign country can also qualify as a PRI, I believe rule-makers should be cautious in this regard. As seen throughout the past decade, Americans are increasingly wary of both outsourcing and providing monetary aid to other countries. Though reports have shown that perception is grossly exaggerated, this specific principle may cause controversy among certain constituencies. Thus, it would be prudent to clarify that the proposed rule does not encourage such investments but simply allows for them. If needed, a possible compromise could be to cap the value for PRIs conducted in foreign countries.