PROGRAMMATIC INVESTMENTS Clinton Foundation: Programmatic Investments Do Not “Focus On Production Of Income Or The Appreciation Of The Asset,” But Instead Act “Like Grants…[And] Have As Their Primary Purpose The Achievement Of The Clinton Foundation’s Programmatic Mission.” “The primary purpose of the programmatic investments is to further the tax exempt objectives of the Clinton Foundation and not focus on production of income or the appreciation of the asset. Like grants, these financial instruments have as their primary purpose the achievement of the Clinton Foundation’s programmatic mission.” [Clinton Foundation, IRS Form 990, 11/19/14] Clinton Foundation: Programmatic Investments “Represent Ownership Interests In Other Organizations.” “These investments, which represent ownership interests in other organizations, are accounted for using the equity method of accounting, and are not subject to the fair value measurement requirements in ASC 958-320 due to these investments not meeting the definition of an equity security with readily determinable fair value. Investment return for the years ended December 31, 2013 and December 31, 2012 is comprised primarily of realized gains on programmatic investments.” [Clinton Foundation, IRS Form 990, 11/19/14] 2013: Clinton Foundation Lumped Programmatic Investments And Endowment Funds Under “Mutual Funds.” [Clinton Foundation, IRS Form 990, 11/19/14] 2013: Clinton Foundation Reported A $1,175,250 “Program-Related Investment” In Fondo Acceso SAS. [Clinton Foundation, IRS Form 990, 11/19/14]  2013: Clinton Foundation Board Chairman Bruce Lindsey Was The Director Of Fondo Acceso SAS. [Clinton Foundation, IRS Form 990, 11/19/14]  Clinton Foundation: “No Directors Of Fondo Acceso Are Paid Or Receive Any Share Of Profits.” [Clinton Foundation, IRS Form 990, 11/19/14] 2013: Clinton Foundation Reported A Loss Of $26,348 On Program Investments. [Clinton Foundation, IRS Form 990, 11/19/14]  2012: “As Of December 31, 2012, The Clinton Foundation Recorded Impairment Losses Of Approximately $345,000 On Programmatic Investments.” [Clinton Foundation, IRS Form 990, 9/10/13] DONOR INPUT Clinton Foundation Did Not Maintain Any Donor-Advised Funds. “Did the organization maintain any donor advised funds or any similar funds or accounts for which donors have the right to provide advice on the distribution or investment of amounts in such funds or accounts?...No” [Clinton Foundation, IRS Form 990, 11/19/14]15 Clinton Foundation Planned On Adopting Policies To “Ensure That Endowment Funds And Their Related Returns Are Spent In Accordance With UPMIFA And Donor’s Intent.” “During 2014, the Foundation’s newly formed Investment Committee will approve and adopt investment policies and procedures to ensure that endowment funds and their related returns are spent in accordance with UPMIFA and donor’s intent and maintain the appropriate amount of risk and return for the Foundation’s purposes. The Foundation has not used or invested any of the endowment funds received (or any net appreciation from these funds classified in temporarily restricted net assets) during 2013 and will not do so until the Investment Committee approves and adopts the appropriate investment policies. For this reason, all endowment funds received during 2013 are held in cash and cash equivalents.” [Clinton Foundation, IRS Form 990, 11/19/14] 15 This is true for every year for which 990s are available. (2003-2013). Commented [SL2]: More on this is included below