Grant Making Guiding Principles

When Citizens Bank, N.A. (“Citizens”) serves as a Trustee of a grant making trust or foundation, we apply the following principles in our grant making decisions:

1. Citizens’ primary consideration is adherence to each trust or foundation document to define the types of organizations, purposes of grants and prescribed geography, if applicable, of eligible grant recipients.
2. Citizens will only provide charitable grants to IRS 501(c)(3) qualified charitable institutions unless the governing document provides otherwise. Charitable institutions are required to provide evidence of eligibility.
3. In considering grant applications, favor will be granted to requests that have a broad impact on the community served by the 501(c)(3) institution, consistent with requirements of the trust or foundation’s governing document.
4. In addition to the requirements of each document, Citizens will consider and weigh relevant community, state or national environmental, social and economic conditions, including those which have created an immediate need (e.g., a pandemic) and how the charitable institution's grant request would help address these needs. Barring extraordinary circumstances, grant requests for general purposes and/or overhead will be given minimal consideration.
5. Citizens will evaluate the financial condition of the entity to assess sustainable charitable purpose and ensure grant funds are used in furtherance of the proposed charitable purpose.
6. In each grant decision, Citizens will account for grant(s) to the prospective recipient from similar Citizens-managed trusts and corporate sponsorship in evaluating an applicant’s financial condition.
7. Each year’s applications will be assessed based on current year’s request without considering an applicant’s grants from prior years.
8. Citizens is committed to monitoring recipient charities to ensure grants are used for the purposes and manner as set forth in the award letter. These efforts will include and not be limited to follow up letters and/or site visits. Confirmation of past-year grant use will be required prior to any current-year grant’s consideration.
9. By serving as a Trustee of a grant making trust, charitable trust or foundation, Citizens Bank, N.A. may make decisions regarding disbursements to organizations with views that do not necessarily reflect those of Citizens Bank. Such disbursements, or denial of disbursements, should not be considered confirmation of its support or lack thereof for any political or social position. Those positions include but are not limited to controversial social or economic policies regularly debated among lawmakers and society in general. The presence of politicized topics in an organization's mission statement or purpose does not preclude the consideration of a grant request; however, organizations that allocate their requests to the delivery of goods and services that are apolitical in nature, or benefit the community at large, greatly increase chances of an award. Grant requests tied to the delivery of goods or services that the general public could perceive as forcing Citizens Bank, N.A., or any trust for which it serves as trustee, to support one side of a sensitive political debate risk specific restrictions regarding the use of grant money or immediate rejection by our Grant Making Group. Citizens Bank, N.A. immediately rejects all grant requests tied to a major or minor political party, PAC or any other organization deeply involved in the political process.
10. In the interest of a fair and consistent process, Citizens Bank, N.A. will not consider off-cycle emergency requests for funding that fall outside of or require a decision before our application periods.
11. To assist applicants, Citizens Bank, N.A. will review grant applications for completeness if received well in advance of the seasonal application deadline. These reviews are intended to ensure the minimum requirements for a grant application are met. However, Citizens Bank, N.A. will cease reviewing applications for completeness one week prior to our seasonal deadlines. Those submitting applications after that time risk disqualification if an application is incomplete. There will be no opportunity for submission of missing information or correction of application once the deadline has passed.
12. Due to expenditure responsibility requirements from the IRS regarding payments from a private foundation, Citizens Bank, N.A. will not consider expenditures related to “unreasonable administrative expenses, including compensation, consultant fees, and other fees for services rendered.” Applicants are encouraged to ear-mark the purpose of their asks for expenses that will avoid potential categorization in the manner referenced by IRC Section 53.4945–6.