NYDFS Examination Finds Emma Willard School's Gift Annuity Fund Repeated Governance Lapses
The New York Department of Financial Services examined the Segregated Gift Annuity Fund of the Emma Willard School for 2020–2024 and found that the Fund failed to correct governance deficiencies cited in its prior 2019 report, including a lack of documented board oversight of investment policy and delegated management. The report also identifies form-use errors in gift annuity agreements, underscoring recurring weaknesses in both governance recordkeeping and product documentation controls relevant to charitable annuity issuers.

