Policy Number: 4-003


Category: Business Affairs

Responsible Executive: Vice President for Business Affairs

1.    Policy Statement

This Fronting Policy describes the University of Florida’s prohibitions against Fronting.  The University of Florida (“University”) grants to certain Primary Users access to University assets, services, and reduced rates not otherwise provided to other Primary or Select Users.  Fronting prohibitions are designed to prevent Primary Users from helping other individuals or groups gain access to University assets, services, or reduced rates those individuals or groups could not otherwise access.

2.     Applicability

This Policy applies to each individual and every group or organization attempting to obtain access to University Space, assets, services, or reduced rates.

Events held on Campus are subject to Regulation 2.004, the Use of University Space Policy, and all other applicable University regulations, policies, procedures, rules, requirements, and standards promulgated in order to implement the Regulation and its related Policy, including but not limited to those pertaining to commercial activity.

3.    Definitions (For purposes of this and any other Space Use policies only):

Campus:  all University-owned, -occupied, or -controlled lands and buildings located within the state of Florida.

Co-hosting:  when one or more Users share decision-making, planning, managing, and supervising responsibilities regarding an Event; Co-hosting Users may, but are not required to, share the financial responsibility for the Event.

Event:  without limitation, any function, gathering, occasion, and party. This definition specifically excludes activities conducted by Primary Users for Academic Purposes or Administrative Purposes not requiring a risk review.  For clarification of the risk review requirement see Use of University Space Policy section 3(a).

Event Permitting System:   the system used by the Vice President for Student Life and the Vice President for Business Affairs for registering and permitting Events on Campus (this system is also known as GatorConnect).

•    Student Life Event Permitting System
•    Business Affairs Event Permitting System

Fronting:  occurs when, on behalf of another individual or group, a Primary User reserves University Space, obtains a University service (including obtaining access to University students, staff, or faculty), or receives a reduced rate for University Space or services that the other individual or group could not have otherwise accessed.

Permitting Authority:  the University unit responsible for approving Event and permit requests in accordance with the University’s Event Permitting System.  The Permitting Authority for Events sponsored by Registered Student Organizations is the Vice President for Student Life or a designee.  The Permitting Authority for Events sponsored by Primary or Select Users other than Registered Student Organizations is the Vice President for Business Affairs or a designee.

Primary Space:  Space that is only available for use by Primary Users and, unless otherwise specifically identified on the University’s list of Select Space, includes all Instructional Space, Administrative Space, and Primary Outdoor Areas.

Primary User:  refers to the following types of Users:

•    Any University-recognized and officially constituted college, school, department, division, institute, center, office, or other University organizational unit;
•    Any University employee when performing functions within the scope of their employment;
•    Any University student engaged in activities directly related to their current course curricula, such as studying (individually or with a group of individuals all of whom are University students) and working on course-related projects or experiments;
•    Any University-certified Direct Support Organization organized and operated in accordance with Section 1004.28, Florida Statutes, and their employees when performing functions within the scope of their employment;
•    Shands Teaching Hospital and Clinics, Inc. and any University Health Science Center Affiliate, and their respective employees when performing functions within the scope of their employment; and
•    Any Registered Student Organization when utilizing Space solely to conduct activities related to the Registered Student Organization’s stated mission or purpose.

Registered Student Organization (RSO): a voluntary group of students joined together by interest, cause, or mission that is registered with the Department of Student Activities and Involvement (SAI).  RSO must meet SAI criteria and requirements to remain active and receive RSO benefits and Campus privileges.

Select User:  any individual, group, or organization not meeting the definition of Primary User.

Select Space:  Indoor and outdoor Space that is eligible for reservation and use by both Primary Users and Select Users, a current list of which is available at https://businessaffairs.ufl.edu/events/select-space/.  This definition specifically excludes Instructional Space, Administrative Space, and Primary Outdoor Areas unless otherwise identified on such list.

Space:  any University-owned, -occupied or -controlled building, structure, facility, outdoor area, or indoor location on Campus, but specifically excludes: fraternity and sorority houses located on Campus, and buildings, facilities, and Space controlled by a Direct Support Organization.

Sponsorship:  When a third-party agrees to provide financial support (either monetary support or a donation of goods or services) for an Event either gratuitously or in exchange for notation of the support on the Event materials.  Sponsorship of an Event allows the third-party no decision-making, planning, managing, or supervising responsibilities regarding the Event.  University colleges and departments are prohibited from sponsoring student organizations that are not classified as University Sponsored Registered Student Organizations (USRSO) in accordance with the RSO Classification Policy.

User:  means both Primary Users and Select Users.

4.    Policy Specifics

4.1 Fronting is Prohibited

Primary Users are prohibited from engaging in Fronting.

4.2 Acceptance of Financial Assistance

The University recognizes that multiple organizations and entities sometimes collaborate to hold Events.  To avoid engaging in Fronting, when one or more Primary Users collaborate on Events with one or more other entities, the Primary User must:

•    Fully plan and supervise the Event;
•    Assume and retain ownership of the Event;
•    Make up the majority of the attendees at the Event, except when the general public is invited;
•    Fund substantial portions of the Event;
•    List itself on Event advertisement; and
•    Receive prior University approval through the Event Permitting System.

5.    Review and Adjudication

The appropriate Permitting Authority or designee will determine whether the allegation of Fronting by the Primary User is valid based on a review of all relevant facts including, but not limited to:

•    The nature of the Event;
•    How active the Primary User is in planning, attending, and executing the Event;
•    Any prior history of Fronting by the Primary User;
•    Any prior history of the Event;
•    The types of attendees at the Event; and
•    Any other facts the Permitting Authority deems relevant.

6.    Consequences for Policy Violations

The University may take the following actions against a Primary User that fails to comply with this Policy or with any other University regulation or policy by engaging in Fronting:

•    Deny or rescind the Primary User’s permission to use the Space (even if the Event has already started);
•    Allow the Event to proceed, but adjust all fees related to the Event to the appropriate rates (e.g., if a Primary User engaged in Fronting and helped a Select User obtain reduced rates, the rate would be adjusted to the Select User rate);
•    Restrict any involved Primary Users from reserving Space either at the specific venue where the Fronting took place or, if the conduct was egregious, anywhere on Campus;
•    Restrict any involved Select User from reserving Space on Campus; and
•    Refer any involved RSO to the Office of Student Conduct and Conflict Resolution for potential action under the Student Conduct Code and to Student Activities and Involvement for any additional actions against the RSO’s organizational status.

7.    Questions

Questions about this policy or reports of suspected violations should be directed to:
Office of the Vice President for Business Affairs
(352) 392-1336


History: New 5-5-2022