[hundt]

No, that rule is only for donations to certain private foundations. If you give the "complex assets" directly to the charity you are entitled to a deduction of the fair market value[1].

However, donating such assets directly can be a hassle to do and relies on cooperation from the charity; the DAF has people who specialize in this and will take care of it for you. This allows you to get the biggest possible deduction with minimal hassle.

This is the gist of most of the tax law complaints in the article: the DAF doesn't enable you to do anything you couldn't already do, but it makes everything easier to do, including the things that the author wishes you couldn't do.

[1] https://www.irs.gov/publications/p526/ar02.html#en_US_2015_p...