C.9. Pool of Potential Grantees

(1) The pool of potential grantees must ordinarily be selected on criteria reasonably

related to the purposes of the grants and must be sufficiently broad to ensure that the giving of grants would further a Section 170(c)(2)(B) purpose. The pool ordinarily must be sufficiently large to constitute a charitable class.

(2) However, selection from a pool is not necessary, where taking into account the

purposes of the grant, one or several persons are selected because they are exceptionally qualified to carry out these purposes; or it is otherwise evident that the selection is particularly calculated to accomplish the charitable purpose of the grant rather than to benefit particular persons or a particular class of persons. Hence, a private foundation may impose reasonable restrictions on the pool of potential grantees. See Treas. Reg. 53.4945-4(b)(2).