Internal Transfer: Scholarship fund to emergency assistance fund

Does anyone have any experience asking scholarship donors to contribute to an emergency assistance fund?

Some background: We launched our emergency assistance fund for students in July. It's actually been quite popular with our donor-advised fundholders and is a nice value-add that we can offer to scholarship fundholders as all of their recipients are eligible. However, we'd love to have our scholarship donors contribute as well--where I'm getting stuck is if a transfer from Scholarship Fund A to the Student Assistance Fund would be IRS-approved. It is ultimately going to students, and there is a selection process in place (and no funds would be restricted to just recipients of Scholarship Fund A), but the funds would be making an internal transfer rather than going directly to a student first, if that makes sense. We haven't yet offered this contribution option to scholarship donors (some have made a separate gift in) but I'd like to, if it were possible.



  • @SarahBattersby great question! I wonder if you have any certified CPA's or auditors you might be able to reach out to that could speak to the official IRS ramifications?

  • Thanks @SusanMiller ! The attorney we work with determined it IS permissible, as long as the donor agrees (which would be a prerequisite, as obviously we would not transfer any funds without a donor's permission!)

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