Policy & Procedure Updates as of October 28, 2020

October 28, 2020

The following policy documents are now published and effective.  Please discuss the documents with the appropriate people in your department and send any questions to controllers.office@yale.edu.

Policy 1107 Reporting Foreign Gifts and Contracts

Related Documents:

  • Policy 1107 Reporting Foreign Gifts and Contracts – New
  • Form 1107 FR.01 Reporting Template for Foreign Gifts and Contracts – New

Earlier this year, the Department of Education published an Information Collection Request pursuant to Section 117 of the Higher Education Act (20 U.S.C. 1011f) (hereinafter, “Section 117”).  While Section 117 is not a new law, and Yale has long been required to report semiannually information regarding certain gifts and contracts from foreign sources, this ICR imposed new reporting requirements.

Yale met its first semiannual reporting deadline under the new ICR on July 31, 2020. Given the University’s decentralized organizational structure, continuing to meet Section 117 reporting requirements as implemented via the ICR requires the assistance and cooperation of a number of units across the institution.  To coordinate this effort and ensure the University’s compliance, the Section 117 Compliance Committee was chartered. As part of its charge, the Section 117 Compliance Committee created Policy 1107 Reporting Foreign Gifts and Contracts to formalize and memorialize the University’s obligations and the various roles and responsibilities supporting them.

The policy is structured around the University’s federal reporting obligations, specifically:

  •  “Whenever any institution is owned or controlled by a foreign source or receives a gift from or enters into a contract with a foreign source, the value of which is $250,000 or more, considered alone or in combination with all other gifts from or contracts with that foreign source within a calendar year, the institution shall file a disclosure report with the Secretary on January 31 or July 31, whichever is sooner.”

To support these obligations, the Section 117 Compliance Committee is charged with oversight of the University’s policy and processes. The policy also explains that all units receiving gifts and entering into contracts share responsibility for accurately recording those funds.  In addition, the policy identifies a list of specific units charged with producing Section 117-reportable data by certain deadlines on a semiannual basis.

The responsibilities enumerated in this policy are critical for ensuring Yale’s continued compliance with its Section 117 obligations.


Always check the Policies & Procedures website for the latest revisions of all documents. This will ensure you that are utilizing the most up-to-date version.

If you have any questions, please contact Policy & Compliance Services at controllers.office@yale.edu.