Foreign Gift Reporting FAQs
The University of Denver is committed to transparency and compliance with federal regulations regarding funding from foreign sources. These FAQs are designed to help donors and university partners understand our obligations under Section 117 of the Higher Education Act of 1965 (HEA).
This federal mandate requires higher education institutions to report to the U.S. Department of Education certain contracts with and gifts from foreign sources. By adhering to these guidelines, we ensure the integrity of our financial operations while maintaining the trust of our global community of supporters. The following information outlines what constitutes a foreign source, reporting thresholds, and how DU protects donor privacy while fulfilling these legal requirements.
Why does DU collect information about the citizenship or country of origin of donors?
DU is required to comply with Section 117 of the Higher Education Act of 1965 (HEA), which necessitates the reporting of certain gifts and contracts originating from foreign sources. Collecting this information allows DU to fulfill federal obligations around transparency and reporting.
What qualifies as a “foreign source”?
Foreign source includes individuals who are not U.S. citizens or nationals, foreign governments or agencies, and any entity organized or incorporated outside the United States. For U.S.-based companies with a foreign parent or affiliate, DU may assess the degree of foreign control to determine reportability.
At what threshold is DU required to report gifts from foreign sources?
In accordance with Section 117 of the HEA, DU must report to the U.S. Department of Education when the value of gifts or contracts from a foreign source totals $250,000 or more within a single calendar year, whether as a single or aggregated gift or contract.
What are the designated reporting periods and deadlines?
Gifts received from July 1 to December 31 are reported by January 7.
Gifts received from January 1 to June 30 are reported by July 7.
Why does DU request information for gifts below the federal threshold?
To ensure compliance with federal regulations, DU starts tracking gifts at $40,000 to identify cases where cumulative, combined gifts or contracts from the same foreign source may later trigger federal reporting requirements.
What information is included in DU’s reports when required by law?
When disclosure is required, DU reports the aggregate value, the name and citizenship of individual donors (as required), or the entity’s country of origin. This information is privately and securely submitted to the U.S. Department of Education, and it is not made public.
What happens if I donate on behalf of someone else?
If you are making a gift on behalf of someone else or on behalf of an entity, DU requests that you identify the beneficial donor and provide their relevant citizenship or incorporation details.
Does DU make donor information public?
DU adheres to all privacy guidelines when handling donor information. Individual donor names are not made public unless specifically required by law, regulation, or with the donor’s explicit permission. To ensure public trust in philanthropy and to give donors full confidence in our institution, DU upholds the principles outlined in the Donor Bill of Rights.
What are the consequences if DU does not comply with these reporting requirements?
Failure to comply with applicable laws can result in federal enforcement actions, financial penalties, and additional compliance costs for the University. These consequences could divert resources away from academic programs, student services, and faculty support, ultimately harming the quality of education and opportunities available to both students and faculty.
Where can I find more information about DU’s foreign gift reporting and Section 117 of the Higher Education Act of 1965?
Contact Donor Relations with questions related to foreign gift reporting at donorrelations@du.edu or 303-871-4591. For information about the HEA, please visit the Library of Congress.