Date:    12/8/97  9:49 AM
Subject: s7-26-97 

Thank you for the opportunity to provide public comment to the proposed 
bills relating to corporate philanthropy, H.R. 944 and 945.  I am 
commenting from the perspective of a Regional Association of Grantmakers 
serving the Commonwealth of Massachusetts.  Our organization provides 
extensive public philanthropic information services to nonprofits, 
corporate, private, community foundation and other grantmakers, and the 
general public interested in philanthropy.  We are well aware of the 
importance and value of clear, current, public information about 
philanthropy.
     
Indeed the 100 grantmaking member organizations of this Regional 
Association of Grantmakers, roughly 43% of whom are Corporate 
Grantmakers, actively support the extensive, free, very accessible 
public information resources that we, Assocated Grantmakers of 
Massachusetts, provide to thousands of users via hardcopy and online 
resources.
     
Many corporations clearly see the value of clear, effective, public 
guidelines for their philanthropic engagement, and turn such 
philanthropic activity into a strong business and community asset.  I do 
not think that regulation needs to impose what market forces and 
positive, community-building corporate values logically create.
     
My thoughts about the two proposed bills are as follows:
     
Public information about philanthropic activity certainly benefits 
multiple constituencies (among them, employees, communities, nonprofits, 
shareholders) and does generally assume a baseline of well-thought out, 
rationally directed philanthropic activity.  Indeed we see the 
prevailing trend among corporate grantmakers in our region as being 
pro-active and public in nature, given that there is careful integration 
of philanthropic activity into the overall business strategy and plans. 
Corporate grantmakers usually take their philanthropic responsibility to 
invest in their communities quite seriously, and they do so in ways that 
add value to nonprofits of extraordinary diversity, focus and scope; to 
corporate employees, and, to the general health and profitability of 
their corporations.
     
 I do not support specific, directive, legislation of the nature
outlined in H. R. 944 and 945. Corporate philanthropy is a key business 
decision and as such I cannot agree with the apparent interest to break 
this particular function out from other business functions for 
shareholder review and direction.  Effective philanthropy adds value in 
my opinion to corporations, thus benefitting shareholders directly, as 
one of many critical management responsibilities and functions. Indeed, 
corporate philanthropy would likely be strengthened by more shareholders 
sending the message that they value management focus on and allocation 
of resources to effective philanthropic activity that benefits corporate 
health. However, this is not best achieved by the proposals in this 
legislation.
     
Other respondents have commented well on the potential management 
problems from opening up shareholder participation in corporate 
philanthropy given the global nature of shareholders locations and 
interests. There is potential conflict between multiple shareholder 
personal philanthropic interests and focused, well thought out corporate 
philanthropy seeking to make a focused, accountable impact.  Corporate 
staff do bring substantial expertise relating to the depth of issues in 
a given community or issue area, and can direct philanthropic resources 
to effective nonprofits with missions concurrent with corporate 
philanthropic interests. 
     
I have a concern about the potential deleterious effect that such 
regulation could have on new or emerging corporate givers, particularly 
small and mid-sized companies who are interested in philanthropy, but 
concerned with developing effective giving programs.   They benefit from 
having a range of choices and incentives for engaging in philanthropic 
giving, not from regulation that could render the process cumbersome and 
not of direct benefit to customers, communities, employees.  Effective 
philanthropy is often not simple, from-the-heart activity, given the 
range of issues, needs and possible options for directing philanthropic 
resources within American society. 
     
We all have increased challenges around broadening, not dampening, 
sources of philanthropic resources.  I see many potential complicating 
and deleterious effects of the proposed legislation on corporate 
philanthropy, which is after all voluntary.  I do not think the 
legislation takes into account either the complex, strategic realities 
of corporate philanthropy today, or the range of public and proactive 
ways that corporations engage in effective philanthropic giving.
     
Sally Peabody
President
Associated Grantmakers of MA
294 Washington Street
Boston, MA 02108
     
speabody@agmconnect.org