Spalding shall seek the advice of legal counsel in matters relating to acceptance of gifts when appropriate. Review by counsel is recommended for:

1. Closely held stock transfers that are subject to restrictions or buy-sell agreements;

2. Gifts involving contracts, such as bargain sales or other documents requiring Spalding to assume an obligation;

3. Transactions with potential conflicts of interest or that may invoke IRA sanctions; and

4. Other instances of a gift based on complex facts or issues in which use of counsel is deemed appropriate by the University President.