Asks Office of Personnel Management to Investigate and Expel the NRA Foundation from Participation in Combined Federal Campaign
NEW YORK — Today, as new details continue to emerge about questionable financial activity by NRA leadership and its board of directors, Everytown for Gun Safety has filed a complaint with the Office of Personnel Management (“OPM”) about the participation of the NRA Foundation, a 501(c)(3) organization controlled by the NRA, in the Combined Federal Campaign, the workplace giving program for federal government employees.
The Combined Federal Campaign allows federal government employees to designate a portion of their paycheck to an approved and qualifying charitable organization. The NRA Foundation has participated in the Combined Federal Campaign for many years, and has received hundreds of thousands of dollars through the program. To gain access to the program, and in accordance with federal regulations, the NRA Foundation has repeatedly and explicitly certified that it “effectively uses the funds contributed for its announced programs” and that members of the “governing body” of the organization “have no material conflicts of interest.” Everytown’s complaint takes issues with both of these claims and calls on OPM to investigate, and ultimately expel, the NRA Foundation from the Combined Federal Campaign.
“The NRA and its Foundation are under investigation and facing very credible allegations relating to conflicts of interest, self-dealing, and wasteful and extravagant spending,” said Justin Wagner, senior investigations counsel for Everytown for Gun Safety. “This is not the type of organization that the federal government’s Combined Federal Campaign was designed to support, and it’s time the NRA was expelled from participating in it.”
“Over the past several months there has been a series of public disclosures and reports revealing substantial evidence of serious and wide-ranging financial impropriety at the National Rifle Association (“the NRA”) – a 501(c)(4) organization that according to its own regulatory filings controls CFC participant the NRA Foundation (which is a 501(c)(3) organization) – including self-dealing, improper enrichment of organization insiders, conflicts of interest, and violations of the not-for-profit laws. As a result, there are now active regulatory investigations by the Attorney General of the District of Columbia as to CFC participant the NRA Foundation and the NRA, and by the Attorney General of New York as to the NRA and its affiliated not-for-profit entities. These allegations and investigations of serious potential misconduct at the NRA are particularly troubling because, in the last two reported years, the NRA Foundation has sent over half of its revenue to the NRA, meaning that over $0.50 of every dollar raised through the federal government’s CFC for the NRA Foundation ended up in the coffers of the NRA.
We strongly believe that a review and investigation by OPM will confirm that the NRA Foundation does not live up to the CFC standards of integrity, accountability, and transparency, and accordingly should be expelled from participating in the CFC program. More specifically, the facts described above and further detailed below raise a number of deeply concerning questions, including: (1) whether the NRA Foundation has falsely certified to the CFC that its governing body has “no material conflicts of interest,” (2) whether the NRA Foundation has falsely certified to the CFC that its “contributions are effectively used for the announced purposes of the charitable organization,” and (3) whether the NRA Foundation is in violation of the core requirement for participation in the CFC – i.e., that it have “a high degree of integrity and responsibility in the conduct of [its] affairs.”
…For all of these reasons, and pursuant to the legal requirement that you, as OPM Director, “shall review the applications for accuracy, completeness, and compliance with the regulations,” we respectfully request that you immediately commence an investigation into the facts described above and in further detail below, and determine whether – as we believe – the NRA Foundation should be expelled from participation in the CFC. The CFC began just this month and we urge you to immediately suspend the NRA Foundation’s participation in this year’s CFC campaign pending the outcome of that investigation. Alternatively, and at a minimum, federal employees should be notified that the NRA Foundation is under law enforcement regulatory investigation so that each federal employee can make an informed decision as to whether to contribute.”
In April 2019, Everytown filed a complaint about the NRA’s tax-exempt status with the IRS, and called for federal and state investigations into the NRA’s operation as a charity. Since then, a number of public reports have detailed even more questionable practices by the NRA, including several board members receiving compensation from the NRA, revelations that NRA CEO Wayne LaPierre billed the NRA’s ex-public relations firm nearly half a million dollars on high-end suits and travel, and reports that the NRA inquired about purchasing a $6.5 million mansion for LaPierre’s use, among several other reports.