Why This Guide Exists

Donor-advised funds (DAFs) move hundreds of billions of dollars annually through the U.S. charitable sector, with a level of anonymity that makes it nearly impossible to follow the money. The Epstein files revealed that DAFs were central to a scheme to build a billionaire network operating above public scrutiny.

At the same time, a May 7, 2026 executive order designated 'radically pro-transgender' groups as national security threats, placing LGBTQ+ organizations and their supporters in the same counterterrorism category as drug cartels and Islamic extremists. Together, these developments create a direct threat to LGBTQ+ 501(c)(3) organizations, their donors, and the communities they serve.

This guide gives you practical, free tools to research who controls charitable and non-charitable organizations, where the money flows, and which political candidates are connected to this web, on both sides of the aisle.

Understanding the Three Entity Types

The tax status of an organization tells you how it is regulated, not whether it deserves your money or reflects your values. The same level of scrutiny applies regardless of 501(c) category.

A common misconception is that 'nonprofit' means an organization is inherently trustworthy. Nonprofits can pay executives high salaries, accumulate significant assets, and fund activities that conflict with your values. 501(c)(4) and 501(c)(5) organizations are not required to disclose their donors publicly, which makes independent research even more important.

The Threat Landscape

DAFs and Anonymous Giving

A donor-advised fund is a charitable account, often held at Fidelity Charitable, Vanguard Charitable, DAFgiving360 (formerly Schwab Charitable), or a community foundation, where donors contribute assets, receive an immediate tax deduction, and then recommend grants to nonprofits over time. Because the DAF sponsor legally owns the funds, the donor's identity is not disclosed to the receiving charity or the IRS.

This anonymity, designed for legitimate charitable privacy, has been documented as a vehicle for funding:

•        Anti-LGBTQ+ organizations (Alliance Defending Freedom, Family Research Council, Liberty Counsel)

•        Anti-immigrant groups (Center for Immigration Studies, Federation for American Immigration Reform)

•        Anti-Muslim organizations (David Horowitz Freedom Center, American Freedom Law Center)

•        Project 2025-affiliated groups, totaling $171 million via Fidelity, Vanguard, and DAFgiving360 since 2020

The May 2026 Executive Order

•        LGBTQ+ 501(c)(3) nonprofits and their boards

•        Financial advisors serving LGBTQ+ clients, including Planning For Good

•        DAF donors who recommend grants to LGBTQ+ organizations

•        Any person deemed to be supporting transgender ideology

The Due Diligence Framework

Apply the same four steps before making any contribution, regardless of entity type. Whether you are giving to a 501(c)(3) charity, a 501(c)(4) advocacy group, or a 501(c)(5) union or trade association, the same questions apply.

Step 1: Verify Legal Status and Basic Filings

Confirm the organization is legitimately registered and in good standing with the IRS.

Note: 501(c)(4) and 501(c)(5) organizations have more limited public disclosure requirements. The IRS search will confirm legal status, but detailed financials and board data may be harder to obtain than for 501(c)(3) organizations.

Step 2: Research Leadership and Board Members

Who runs the organization matters. Leadership ties to problematic networks, political funders, or hate groups can signal that your donation may not go where you intend. These questions apply to any recipient, regardless of tax status:

•        Do board members or executives serve on the boards of organizations on the SPLC hate map?

•        Do board members appear in the Epstein files or sit on boards of Epstein-connected organizations?

•        Do leaders have documented financial ties to anonymous dark money networks?

•        Are leadership ties to political figures consistent with the stated mission?

Step 3: Trace Political Activity and Funding Patterns

This step is especially important for 501(c)(4) and 501(c)(5) organizations, which can engage in significant political activity and lobbying without the same disclosure requirements as PACs or campaigns.

•        Has the organization endorsed candidates or funded political campaigns?

•        Does the organization's PAC align with your values?

•        Has the organization been identified as a dark money vehicle by investigative journalists?

•        Has the organization funded or endorsed candidates who have voted against LGBTQ+ protections?

•        Does the organization's lobbying record reflect your values?

Step 4: For DAF Giving, Research Grantmaking Patterns

If you are giving through a donor-advised fund, additional scrutiny of the DAF sponsor itself is warranted. While individual donor identity is protected, DAF sponsors' overall grantmaking is partially public via Form 990 Schedule I, which shows total grants by recipient organization.

Research for this guide found that all three major commercial DAFs, Fidelity Charitable, Vanguard Charitable, and DAFgiving360, have channeled donor funds to SPLC-designated organizations, including:

•        Fidelity Charitable: $8.7M to Alliance Defending Freedom; $4.6M total to 23 SPLC-designated groups (2017-2019)

•        Vanguard Charitable: millions to Center for Immigration Studies and Federation for American Immigration Reform

•        All three combined: $171M to 68 Project 2025-affiliated organizations since 2020

Questions to Ask About Your DAF Sponsor

•        Does any board member also serve on the boards of organizations on the SPLC hate map?

•        Has the DAF been documented granting funds to anti-LGBTQ+, anti-immigrant, or white nationalist organizations?

•        Has the DAF funded Project 2025-affiliated organizations?

•        Does the DAF have an explicit nondiscrimination policy?

•        Does the DAF publish its full grantmaking list annually?

Key Investigations to Review

•        New Republic: How Fidelity, Schwab, and Vanguard Fund Hate Groups

•        DeSmog: $171M in Dark Money to Project 2025 via Major DAFs

•        Sludge: America's Biggest Charities Funneling Millions to Hate Groups

•        Chronicle of Philanthropy: 351 Charities Directed Millions to Hate Groups

Values-Aligned DAF Alternatives

Not all DAFs are the same. For clients who want their charitable giving vehicle to align with their values, community foundations with local equity missions, LGBTQ+ community foundations, and smaller mission-aligned DAF sponsors often offer more transparent governance than the major commercial providers.

Quick Reference Checklist

Use this checklist before making any contribution, regardless of entity type.

At Planning For Good, we will not be intimidated. We are an LGBTQ+ firm and we are in this together with our community. We will continue to show up, advise our clients with our best interests at heart, and do the work that matters. No counterterrorism label and no anonymous dark money changes that.

This guide will be updated as the research develops. If you have questions about your DAF, your charitable giving strategy, or how to protect your organization in the current environment, please reach out.

DOWNLOAD A COPY HERE: PFG Consumer Action Guide - Charitable and Non-Charitable Giving

Research compiled by Planning For Good  |  May 2026  | 

Disclosures: All examples are hypothetical and for illustrative purposes only. All investments have the risk of loss, including total loss of principal. Saving more or spending less does not eliminate investment risk. Investments involve fees and expenses, which will impact the net results. Taxes can further impact net portfolio results. Consult with a tax advisor for your specific tax implications. Consult with a financial advisor before implementing or changing your investment strategy.

**Securities are offered through Registered Representatives of Cambridge Investment Research, Inc. a broker/dealer, Member FINRA/SIPC. Advisory services through Cambridge Investment Research Advisors, Inc., a Registered Investment Advisor. Cambridge and Planning for Good are separate entities.)