Does the PPA expand the definition of disqualified persons under the intermediate sanction rules?
Yes. The PPA expands the class of disqualified persons in several ways. Most relevant to all supporting organizations is the provision that treats disqualified persons of a supporting organization as disqualified persons of the organization(s) it supports. For example, a board member of a supporting organization that supports a community foundation is also a disqualified person of the community foundation even if the board member has no other relationship with the community foundation. The community foundation cannot enter any transaction with the board member that provides the board member—a disqualified person—with an excess benefit. Note that when the payment is made by the community foundation for services provided to the community foundation, penalties apply only if the amount paid is excessive. A stricter rule applies to payments by the supporting organization to its substantial contributor and related parties. This stricter rule may also apply to payments by the community founda
