BEFORE THE FEDERAL ELECTION COMMISSION Brad Woodhouse American Democracy Legal Fund 455 Massachusetts Avenue, NW Washington, DC 20001 Complainant, National Rifle Association of America 11250 Waples Mill Road Fairfax, VA 22030 National Rifle Association Institute for Legislative Action 11250 Waples Mill Road Fairfax, VA 22030 Respondents, COMPLAINT Complainant files this complaint with the Federal Election Commission (the “FEC” or Commission”) under 52 U.S.C. § 30109(a)(1) against the National Rifle Association of America (“NRA”) and the National Rifle Association Institute for Legislative Action (“NRA- ILA”) (collectively, “Respondents”) for violating the Federal Election Campaign Act of 1971, as amended (the “Act”) and Commission regulations, as described below. According to news sources, the Federal Bureau of Investigations (“FBI”) is currently investigating whether Respondents received illegal contributions from foreign nationals in connection with the 2016 presidential election. Given the severity of these allegations, we request an immediate investigation by the Commission into these claims, both to determine the scope of any violations and to take appropriate remedial action against Respondents. A. Factual BackgroundOrganized as a nonprofit corporation under Section 501(c)(4) of the Intemal Revenue Code," the NRA considers itself “the premier firearms education organization in the world.” ‘The NRA’s separate segregated find—the National Rifle Association of America Political Victory Fund (“NRA-PVF")—is currently registered with the FEC as a political committee, financing political activity in connection with federal and nonfederal elections around the country.’ The NRA-ILA is the lobbying arm of the NRA — its legislative programs and activities are reported each year on the NRA’s Form 990 tax returns.* The NRA, NRA-ILA, and NRA-PVF spent nearly $55 million dollars in connection with federal elections in 2016.’ Of that $55 million, $30 million was spent in support of Republican candidate Donald Trump, which is “triple what the group devoted to backing Republican Mitt Romney in the 2012 presidential race.” The majority of money spent by the NRA in connection with the 2016 presidential election was reportedly spent by the NRA-ILA, which is not required to disclose its donors to the public.” According to news sources, “links between Russia and the NRA have drawn the attention of federal investigators” raising the question of “whether a top Russian banker with ties to the Kremlin illegally funneled money to the National Rifle Association to help Donald Trump win the presidency.”" The Russian banker in question, Alexander Torshin, currently serves as the ' National Rifle Assaciation of America, 2015 Form 990 (excerps atached as Exhibit A). A Brief History ofthe NRA, National Rifle Association, available at https -home.nta.org/about-thenral. ® National Rifle Association of America Political Victory Fund, FEC Statement of Organization (fled Nov. 19, 2015), «See 2015 Form 990, supra note 1, Part Il, Line 4e (reporting more than $24 million on legislative programs). » Peter Stone & Greg Gordon, FB/ Investigating Whether Russian Money Went to NRA to Help Trump, McClatchy an, 18, 2018), available at hup:/hvww.mcclatchyde,conv/aews/nation-world/nationalfarticle195231139.html; see «also NRA Outside Spending Summary 2016, OpenSecrets.org, available at hhupsz/ wow opensecres org/outsidespending/ detail php ?emte"National%20Rifle’420Assnécycle=2016 (last accessed Jan. 21, 2018). * Stone & Gordon, supra note 5; see also NRA Outside Spending Summary 2012, OpenSecrets.org, available at dnapssfivww.opensecrets.org/outsidespending/detal php ?eycle=2012&emte-National=RifletAsen (last accessed Jan, 21, 2018) » Stone & Gordon, supra note 5; see also General Instructions for Schedule B, Form 990, available at ups: /www.jrs.2ov/pubvirs-pdP(990ex pdfdeputy governor of Russia’s central bank and “is known for his elo: relationships with both Russian President Vladimir Putin and the NRA.”* Mr. Torshin’s ties to the NRA date back to 2011, when he was introduced to the organization's president and invited to attend subsequent NRA conventions in the United States." With his so-called protégé, Maria Butina, Torshin eventually helped create a similar gun rights group in Moscow called the “Right to Bear Arms.” Through this organization, Torshin and Butina met fellow NRA member and conservative operative Paul Erickson — an adviser to the Trump transition team who helped raise money for the NRA."® In 2015, Torshin and Butina “hosted a luxurious trip to Russia for NRA leaders” including Mr. Erickson and other top-level NRA donors.” The following year, Ms. Butina and Mr. Erickson incorporated a company together in Mr. Erickson’s home state of South Dakota: Bridges LLC." While it is not clear what the company does and “[p]ublic records don’t reveal any financial transactions involving Bridges [LLC]...Erickson said the firm was established in case Butina needed any monetary assistance for her graduate studies.” * Stone & Gordon, supra note 5; Lois Beckett, FBI Investigates Whether Russia Banker Used NRA to Fund Trump Campaign - Report, The Guardian (Jan. 18, 2018), available a htps:/wwwsheguardian.com/us- news/2018/fan/18/rump-nra-fbi-alexander-torshin-russia-invesijgation, * Stone & Gordon, supra note 5; see also Rosalind 8. Helderman & Tom Hamburger, Guns and Religion: How American Conservatives Grew Closer to Putin's Russia, Wash. Post (Apr. 30, 2017), available at Jhups:/www.wwashingtonpost.com/politioshow-the-republican-rght-found-allies-n-russia/2017/04/30/e248376- 20U3-Le7-2616-7¢8068c1466 story himl?utm_torma.43850901 7303, * Helderman & Hamburger, supra note 9; Stone & Gordon, supra note. " Stone & Gordon, supra note 5; Helderman & Hamburger, supra note 9 # Stone & Gordon, supra note 5; see also Michelle Goldberg, Is Ths the Collusion We Were Waiting For?, N.Y. ‘Times (Jan. 19, 2018), available at htps:/www.nytimes.com/2018/01/19/opinion/nra-russia-investgation- trump .html; Michael Isikoff, White House Pulled out of Meet and Greet with ‘Conservatives’ Favorite Russian Over ‘Suspected Mob Ties, Yahoo News (Apr. 2, 2017), available at tips:/wwu. yahoo.convnews/white-house-pulled- ‘ut-of-meet-and-greet-with-conservatives-favorite-russian-a-suspected-mabster-060026495 unl " Helderman & Hamburger, supra note 9; Goldberg, supra note 12. « Stone & Gordon, supra note 5; Nicholas Fandos, Operative Offered Trump Campaign ‘Kremlin Connection’ Using N.R.A. Thes, N.Y. Times (Dee. 3, 2017), available at ttps-//www.nytimes.com/201 7/12/03/usiplitiestrump: putin-russia-nta-campnign html; see also Bridges LLC Business Entity Detail, S.D. Sec'y of State, available at Jnupsi/sosenterprise.sd.zov/BusinessServices/Business/FilingDetail aspx?CN~064236191089001247030098158165 155023024203221 157 (last accessed Jan. 21, 2018), * Stone & Gordon, supra note 5Relying on his NRA connections, news sources report repeated attempts by Mr. Torshin to contact the Trump campaign in 2016, specifically seeking a one-on-one meeting with Donald ‘Trump.'* For example, in May of 2016, Mr. Erickson sent an email on Torshin’s behalf to a Trump campaign advisor, “tr{ying] to arrange a personal meeting with Trump [in connection with] the NRA convention” in Louisville, Kentucky.” According to news sources, the email from Erickson “bore the subject line ‘Kremlin Connection’ and explained that “Russia...was ‘quietly but actively seeking dialogue with the U.S.” and would attempt to use the NRA’s annual convention...to make ‘first contact.’"" While the Trump campaign declined Mr. Torshin’s meeting request, Mr. Torshin did reportedly share a table with Donald Trump, Jr. during a private dinner at the convention that year, just before the NRA officially endorsed Donald Trump for president.” In June of 2016, Torshin tried to set up another “backchannel meeting between Trump and Torshin” but the campaign declined his request again.” Even after the election, Mr. Torshin continued to seck a meeting with now-President Trump, and was finally successful in scheduling. a meet-and-greet with the President in connection with the National Prayer Breakfast in February of 2017." That meeting was canceled at the last minute, reportedly due to recent allegations made by the Spanish Civil Guard that Mr. Torshin “directed dirty money” and aided in the money laundering of “ill-gotten gains through banks and properties in Spain.” * Jd; Helderman & Hamburger, supra note 9; Goldberg, supra note 12 ® Stone & Gordon, supra note S; see also Fandos, supra note 14, * Fandos, supra note Ld. Stone & Gordon, supra note 5; Helderman & Hamburger, supra note 9; Esteban Duarte, Henry Meyer & Evgenia Pismennaya, Mobster or Central Banker? Spanish Cops Allege This Russian Both, Bloomberg Markets (Aug. 9, 2016), available at htps:/www bloomberg. con/news/articles/2016-08-09/mobster-or-central-banker-spanish-cops- allege-this-russian-both, © Sam Thielman, NRA's Ties to Putin Allies Go Back Years, Talking Points Memo (Ian, 19, 2018), available at ‘npsi/talkingpointsmemo,conn/muckraker/nras-tiesto-putin-llies-go-back-yonrs * Stone & Gordon, supra note 5. * Duarte, Meyer & Pismennaya, supra note 19.In describing the ongoing relationship between Mr. Torshin, Ms. Butina, and the NRA in the lead up to the 2016 presidential election, Glenn Simpson of Fusion GPS succinctly explained that “the Russians. .[had] infiltrated the NRA.”® Representative Adam Schiff of California later explained that “[t]he issue of whether there was an effort to ether create a back channel through the NRA, or provide funding through the NRA, has been an issue of concern for the [House Intelligence] committee, and something we've endeavored to look into with the limited resources, we have,” B. Legal Analysis Federal law prohibits foreign nationals from making any contribution or expenditure in connection with an election to public office.” A foreign national is defined as an “individual who is not a citizen of the United States and who is not lawfully admitted for permanent residence.” The Act further prohibits persons from (i) knowingly soliciting, accepting, or receiving a contribution or donation from a foreign national and (ii) “knowingly provid[ing] substantial assistance in the solicitation, making, acceptance, ot receipt” of a contribution from a foreign national.” To make such a violation to “knowingly” a person must (i) have actual knowledge the person solicited is a foreign national, (i) be aware of facts that would lead a reasonable person to conclude there is a substantial probability that the person solicited is a foreign national, or (ii) be aware of facts that would lead a reasonable person to inquire whether the person solicited is a foreign national, but fail to make such an inquiry. » Hearing Before the H. Permanent Select Comm. On Intelligence, 115th Cong, (2018) (statement of Glenn ‘Simpson, Co-Founder of Fusion GPS), available at |hup:/docs house. gov/meetings/1G/1G00/20 1801 18/106796/HMTG-115-1G00-20180118-SD002.pdF (“Simpson Testimony” herein. * Goldberg, supra note 12. *IICER. § 110.20(b); 52 US.C. § 3012100). S11 CER, § 110.20(a)(3)i). "fd. § 110.20(g), (hi), 52 US. § 30121(@\2).In implementing the prohibition against providing substantial assistance to foreign nationals, the Commission determined the rule was “necessary...to prevent foreign national funds from influencing elections.” For these purposes, “substantial assistance” means “active involvement in the solicitation, making, receipt or acceptance of a foreign national contribution or donation with an intent to facilitate successfial completion of the transaction.” In making this, rule, the Commission made clear that the prohibition “covers, but is not limited to, those persons who act as conduits or intermediaries for foreign national contributions or donations.””" Finally, the Act prohibits participation by foreign nationals in decisions involving election-related activi s, including a prohibition on foreign nationals directing, dictating, controlling, or directly or indireetly participating in the decision-making process of any corporation, political organization or political committee with regard to that entity’s election- related activities.” This prohibition extends to decisions concerning the making of contributions, donations, expenditures or disbursements in connection with elections.” Persons guilty of using foreign money to influence an American election through any of the methods described herein could be subject to both civil fines and criminal prosecution under federal law." As a 501(¢)(4) organization, the NRA (and the NRA-ILA by extension) can generally ‘accept contributions from foreign nationals to support its non-electoral activities and is not required to disclose its donors to the public when filing its annual Form 990 with the Internal Revenue Service." However, neither the 501(c)(4) nor its political committee, NRA-PVF, can * 11 CER. § 120(a)(4); FEC Adv, Op. 2016-10 (Parker) * Explanations and Justification, Assisting Foreign National Contributions or Donations, 67 Fed, Reg, 69,928, 169,945 (Nov. 19, 2002), ma » 67 Fed, Reg. at 69,945-46, 11 CER. § 110.200) ” 67 Fed, Reg. at 69,945. * See 52U.S.C. § 30109(a)(6), (d) (providing for civil and criminal penalties for knowing and willful violations) » General Instructions for Schedule B, Form 990, available at hitys://www irs govipubins-pdf/1990erb pal.(i provide substantial assistance to facilitate the spending of foreign money to influence an American election, (fi) act as a conduit for an otherwise illegal foreign political contributions, or (iii) allow for a foreign national to participate in election-related decisions regarding the organization’s activities. NRA-PVF is further prohibited from soliciting, accepting, or receiving a contribution or donation from any foreign national and is required to disclose its donors to the FEC.” According to sources, the NRA spent at least $55 million dollars in connection with the 2016 election. Only contributions received by the NRA-PVF in connection with the 2016 election will be disclosed to the public. To put it another way, at least $33 million was spent to influence federal elections in 2016, but the public will never learn the source of those contributions. This is particularly problematic given the news reports detailed above and the longstanding relationship between the NRA and prominent foreign nationals in Russia whose interests in influencing the outcome of the 2016 presidential election cannot be denied. News sources indicate that Mr. Totshin was deliberately if not exclusively interested in the electoral activities of the NRA.” His repeated attempts at contacting the Trump campaign and meeting with Donald Trump demonstrate an obvious interest in participating in and influencing the 2016 election, Moreover, Mr. Torshin used his NRA contacts to facilitate these conversations and meeting requests with the Trump campaign.” In fact, Mr. Torshin was so deeply involved in the NRA's organization that Glenn Simpson of Fusion GPS—the research company hired to do opposition research on candidate Donald Trump—told Congress that the * 11 CER. § 110.20(2), (, (0. * Hd. § 104,3(@)2), 110.2000), ® Stone & Gordon, supra note S * Id; Helderman & Hamburger, supra note 9. Stone & Gordon, supra note 5; Helderman & Hamburger, supra note 9Russians had “infiltrated” the NRA, specifically naming Alexander Torshin and Maria Butina in his testimony.“ By infiltrating the NRA and gaining unfettered access to NRA donors and leaders, Mr. Torshin and Ms. Butina would have participated in the NRA’s decision-making process regarding election-related activities — certainly indirectly if not directly. ‘This relationship goes farther than simply attending NRA meetings. Mr. Torshin and Ms, Butina hosted a large group of top-level NRA donors in Moscow, and Ms. Butina then teamed up with NRA member and fundraiser Paul Erickson to form an LLC in advance of the 2016 election. While Mr. Erickson claims he and Ms. Butina formed this LLC to provide Butina with money for her graduate studies, news sources correctly characterize that as “an unusual way to use an LLC."° In. discussing the Butina-Erickson LLC, a different news source adds: “Here's another way LLCs could be used: as an intermediary between foreign agents and tax-exempt organizations that are not required by law to disclose their donors.“ Given allegations made against Mr. Torshin by the Spanish Civil Guard,* this would not be the first time Mr. Torshin or those associated with him were accused of funneling money illegally. Mr. Torshin and Ms. Butina had approximately 33 million opportunities to funnel foreign funds through the NRA, either directly through the NRA-ILA or indirectly through Bridges LLC and then the NRA. Because the NRA had reason to know of Mr. Torshin’s objectives in influencing the 2016 presidential election, and had reason to know that any funds solicited by Mr. Torshin or Ms. Butina on behalf of the NRA would be solicited impermissibly from foreign impson Testimony, supra note 23. * Fandos, supra note 14; Stone & Gordon, supra note 5; Bridges LLC Business Entity Detail, S.D. Seo’y of State, available at nips/sosenterprise.sd gov/BusinessServices/Business FilingD etal aspx?CN=06423619108900 1247030098158 165 155023024203221157 (last accessed Jan. 21, 2018). * Stone & Gordon, supra note 5, « Goldberg, supra note 12. © Duarte, Meyer & Pismennaya, supra note 19,nationals, Respondents are complicit in any scheme that took place in connection with these individuals. The FEC purposefully added conduits and intermediaries to the prohibition on substantial assistance to prohibit such an arrangement. While the FBI and U.S. House of Representatives are both investigating the potential money trail from Torshin to the NRA, this question falls squarely within the FEC’s jurisdiction and should be investigated by the Commission, REQUESTED ACTION We respectfully request that the Commission investigate these claims and any additional coordination between Respondents and foreign nationals in connection with the 2016 presidential election. We also ask the Commission to enjoin Respondents from any farther violations of the Act and assign the maximum fines permitted by law should the investigation lead to evidence of illegal foreign contributions or the facilitation thereof. Sincerely, fOr SUBSCRIBED AND SWORN to before me this 2D. day of January of 2018. 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Dat ne organization engage obbying actwties, orhavea section 504(h) election eect during the tax yea? It "Yes,*complete ScheduleG Part IT... ee ts : dg 5 Is the organization a section 504 (c)(, $01(6)(5), 0501 (eX) arganvzation that receives membership dues, assessments, or similar amounts as defined in Revenue Procecure 98-19? ¥ Af "Yes," complete ScheduleG Partll . . . ee ee woe a oe © Did the organization maintain any donor advised funds or any similar funés er accounts for which donors have the right to provide advice on the distribution ar investment of arnounts in such funes or accounts? If "¥es,"complete ScheduleD, Part ss ev ent tee tet 6 i 7 Did the organization receive or hold a conservation easement, including easements to preserve epen space, the environment, histone land areas, or historic structures? If "Yes," complete Schedule D, Part I. + z wo 8 Did the organization maintain collections of works of art, historical treasures, of other simular assets? Y IO "Yes," complete Schedule D, Pare 111%) ee toe 7 3 | ves 9 id the organization report an amount n Part X; line 24 for escrow or custodial account habiity, serve as a 5 se No F-¥es,* has i filed a Form 720 to report these payments7IF "No, provie an explanation in Schedule. | aab Form 950 (2055)Form 990 (2015) Governance, Management, and Disclosure Page 6 For each "Yes" response to lines 2 through 7b below, and for a °No" response to lines a, 8b, or 10b below, describe the circumstances, processes, or changes in Schedule O. See mstructons. Check i Schedule 0 contains a response or note to any ine in th Part V1 paeaeeea Section A. Governing Body and Management Yer | No 1¢ number of voting members ofthe governing body atthe end ofthetax | 4 al If there are matonal diferences 1n voting nghts among members ofthe governing body, orifthe governing boay delegated broad authorty to an executive committee] (or simiar commitee, explain n Schedule 0 b Enter the number of voting members included in ine 12, above, wine are Independent » a 2 Did any oficer, director, trustee, or key employee have a family relationshup ora business Felavonship wih any other oicer, director, tustee, or key employee? wes aaa ae |e No 13. Did the organzation delegate control over management dates customanly performed by or under the direct 3 No supervision officers directors or trustees, or Key employees toa management company orather person? « 4 Did the organzation make any significant changes to its governing documents since the pnor Form 990 was fled ss cc en eee ‘ No '5-_Did the organzation become aware during the year of signficant diversion of the organization's assets? 5 Ne 6 Did the oxganzation have members or stockholders? ee - ee 7a Did the organization have members, stockholders, or other persons who had the power to elect or appoint one or more members ofthe governing Body? eee a eave bb Are any governance decisions of the organtzation reserved to (or subject to approval by) members, stackholders,| 7b | Yes corpersons other than the governing boy? ss ee ee ws 7 5 '8 bic the organization contemporaneously document the meetings held oF writen actions undertaken dunng the yearby the flloning 2 The governngbody? . 5. fi 300d05050590000 ves bb Each committee with authonty to act on behalf ofthe governing body? . 20000500 Yes 9 1s theve any office, director, trustee, or key employee listed tn Part VIL, Section A, who cannct be reached atthe organization's mang address? Jf "Yes," provide the names and addresses in Schedules vs = ~ Le No Section B. Policies (This Section B requests information about poles not required by the Internal Revenue Code 408 Did tne organization have local chapters, branches, orafiiates? Done aoo [ee Ne b I1*¥es," aid the organization have witten policies and procecures governing the activities of such chapters, aiiates, and branches to ensure their operations are consistent with the organization's exempt purposes?” | 200 4a Has the organization provided a complete copy of this Form 990 to all members oft governing body before fling the form? a Seca) aa ae eee ave b Describe in Schedule O the process, sf any, used by the organization to review this Form 990. + + + + 322 Did the orgamzation have a wntten confict fmterest policy? If "Noy"gotolmel3 . + sv ve a | ves Were oftcers, directors, trustees, and key employees required to disclose annually interests that could give nsetocomfiets? yrs tt ee ea see [aR | ves Did the organization regularly and consistently monitor and enforce compliance withthe policy? Jf "Yes," descnbe Schedule Chow this was dates een ee eee azc| ves 43. Didthe organization have a wntten whistieblower policy? << + vc ev es ts ww ee [asp ¥er 44 bid the organization have a written document retention and destruction policy? ss fo 6 5 UIE 25 Did the process for determining compensation ofthe following persone include a review and approval by Independent persons, comparabiity data, and contemporaneous substantiation ofthe deliberation and decision? ‘8 The organizations CEO, Executive Ditector,ortop managementofficial . . . . s+ ss + |a5a| ves b other officers or key employees ofthe organization. ve ee ee 156 | Yes 1f°Yes" to ine 15a or 15b, desenbe the process in Schedule O (see instructions) T 46a Did the organization nvest in, contribute assets to, or participate in aint venture or similar arrangement with 2 taxable entity dung theyear? ses ste ea anne Ty No b_1f°¥es," did the organization follow a witten policy or procedure requirng the organization to evaluate rts participation in joint venture arrangements under applicable feceal tax law, and take steps to safeguard the DBiganzations exempt status with respect to such arrangements? ss ‘i - [aw Section C. Disclosure 17 List the States with whieh a Copy of tis Farm 990 16 requred tobe flea AK AL AR, AZ,CA ,CO CT ,DC /FL.GA ,IL, KS, KY, LAIMA MD ME, MN, MO ,4S,NC HO WH A, 4m NY LOH OK /OR PARE, SC, TN, UT,VA 88 Section 6104 requires an organization to make rs Form 1023 (or 1024 \Fappicable), 990, and 990-7 (SO4Te) (2)s only) availabe for publie mspection Indicate hon you made these avarlable Check al that apply Townwebsite [Another's website [Upon request [other (explain in Schedule ) 49 Describe in Schedule O whether (and iso, Row) the organization made Its governing documents, confit ot Interest policy, and fnancial statements avaiable tothe public during te tox year 20 state the name, adcress, and telephone numberof the person who possesses the organization's books and record Divison H Phlips Ir Treasurer Nati 11250 Wapies Mill Road Faurfox, VA 220307400 (703) 267-1000 Form 990 (2075)form 990 (2015) page 7 [ERI compensation of Officers, Directors, Trustees, Key Employees, Highest Compensated Employees, and Independent Contractors Check t Schedule O contains a response or note to any ine this Part VI Section A, Officers, Directors, Trustees, Key Employees, and Highest Compensated Employees 4 Complete this fle forall persons requred tbe listed Report compensation forthe calendar year ending wh ar win the argantavan tan year ast all othe organzation’scurentoficers, directors, tustes (whether induidvals or organzotion), egertess of amount ot compensation Enter-0- in columns (0) (E), and (no compensation nas avd i of he organations current Key employees, Fany See instructions for definition oF key employee * List tre organizations fvecument highest compensated employees (other han an office, director, tse or key employee) wha received reportable compensation (Sox 5 of Form W-2 and/or Box ? of Ferm 1099-MISC} af mare shan $100,000 fom te Sryonzotion and any elated rpanvatons List all ofthe oraniations former oficers, key employees, or highest compensated employees who received more than $100,000 of feparable compensetion fom tre srganvaton and any related ergonsoone # stall ofthe organizations former directors or trastees tat recived nthe capacity 28a former director or trustee ofthe organztion,more than $10,000 ofrepotablecompensotion rom the orponzation nad ony releed oganeatons List person in the long ofder individual trustees or diectors, institutional trustees, oMcers Key employees, highest Compensated employees, and former such persons check hie box f neither the organization nor any related organvaton compensated any curet ofr, direct, o trustee oust (A) (8) (cy (0) ce) (F) Name and Tile Average | positon (donot check eportasie | Reportable | Estimeted nours per |_moretnan one 90«, unless | compensation | compensation | amount other week (ist | "person's bth an offcer fromthe. | fromvelsted” | “compensation arynours | ‘andarectornrustee) | organation(W- | orgeniations |“ nomthe forrelated [= SEE Ta] 21099-misc) | fwe2/s099- | orpanation ane otsonsstons [22 [= [8 BE | wise) vated veiw (22 1312 le Be |S erganizatons dotted tine) [RE | |* |Z 28 |E BE le] |b lee Zs! lel _ i i a a ‘Se paral Gata Table rar 950 OTS)Form 990 (2015) DEMIR Section A. OFficers, Directors, Trustees, ™ @ © ©) © © namelerd The average | _vosiuon fo not eneck neportavie | neportabie | estmated tours per | moretnan one box uness | compensation | compensation | amount a other weet (ist_| "persone bots an afcer Tomthe.” | ‘romreates” | “compensation anv ours | “ina drectortnstec) | erganzaton qw- |oxgonatons w-| “rom the foisted eS a Te BE pT wose-mise) | 2/t098-mise) | organaaten ana Meow (BE | 2/2 [a (EE 2 orgenztons dottedine) [BE | E BE |e yee |g Be Pe lel ys eiz| Fle BE 3 ‘ & Wb subtotal. Sao *) ] {© Total rom continuation sheets to Part VIE Section A» > | Total (add tes wand te) = vo aT Sa 2 Total number ofmaviduals (ncluding but ok hited to those hated above) whe recened more than $100,000 afreortabie compensssan om the ergenzationP 10h Yer | vo 3 Did theorgenzation st any former ofcer, crector or trustee, key employee, or highest compensated employee online ta? If "es, "complete Schedule} ay suchIndvididl vw se en ns ts we ee |g tte 4 For any indvual listed on ie 10,1 the sum of eportate compensation and other compensation rom the brgarigetion an related erganzations greater than #150,0009 ff “Yes,-conpltte Schedule) or such 5 Did any person listed on ine 19 receve or acer compensation fom any unrelated erganaton or nda for services rendered tothe organization? "es, conplete Schedule Tar such poor es st esr ss | y rs Section 6, Independent Contractors Complete ts table fr your five highest compensated dependent contractors that recewed more than $100,000 oF ‘compensation from the organization Report compensation for the calendar Year ending wth or mrhn the erganvzation’ tax year a a © Bears HAASE Form 3900075)Saiamen Rove reuttene | aSeew | vane | act 7 ee SE |e rtrasngevens . te BS | 6 netated ocanzatons « ae | i =] G8 | ¢ cecciestmctors BA. eres = | BY & teescawr svar. — a |» [eer atone ane z > i oe} aa 3 . & 1g Total Addines 2a-2/ > 380.255 185] . | t eeteeeeeee se na Total revenue, See Lnseructons al 326,709,239 195,764,313 27,206 93) 19,675,33) Tam OTS)Foum 990 (2015) ‘Statement of Functional Expenses Sectuon $07(e}(3) ang 507(c)id) rgenizations must complete all columns Allather crgatimitions must comblete column (Al (Check if Schedule © contains a response or note to any linen this Part IX Page 10 Z ono nce aunts reported on es 6b ne ee 75 bot ant Sob Pon Wite ron ance | Poggintevee | Haagen and | futns 1 Grants and other assistance fo dameste organzators and Sogute geminal cer ae ieee A a 2 Grants and otter assistance to domestic Induidils See Part vetne ea fe a 3 Grants and ther assistance tofreanoranzatins reign Governments, and rcgn wainduale See Por We iies 1 Benes jaidtoorormembers : 5 compensation of curen: ofcers, directors, trustees, ans teporloycan ome sams] szaseos|_——_ rss © Compensation notnc led above to disqualiedpersors (er detnea unécr sector 438(njup and persone deserted msecton49380)300) a 7 Othersalanes andwages = tama] same] emer] ae @ Penson plan aceruas and contributions (clude section 40100) @ Otherenployceerefts ss sapuns| santo] —sowasso] aut 10 ayrlicones peewee ree aaosana| _ayoneni| stor] _—_—_avigm 11 Fees orseruces (ron-employees) 2 Manageme se es a Dee "auaa| sas] seer € Account Tas7 70 @ Uobopng see ee ee ee T0o]| ao Professional findrasing services See Par IV ne 17 1397.05 ra 7] cece ee ia a 9. Other (ine 119 amount exceeds 10% of te 25, column (A) DeeeiLustine ig coemerontemadcey eae ne 7 12 Advertsing and promote ss semana] soso cama 13 oficeenpenses vv vv asm] suns] aa eee ee Teassatel ——srenave] ears Ss oie a 28 Payers of travel or ntertarrment expen for any fdr ica be pecee meme ar ae a 19 Conferences, conventions, and mechngs Tax] eae] ae woimenst se ee zaman] aisox| ae Bi payments oattiates 7 22 Depreciation depletion, and amortiation = =. « sasnzeo| aso] saa 2A other expenses Itemae expenses not covers above (st inscelaneousexpenves lve ae sfine See aroun exceeds Tome ate 25, oun (A) aroun Ist ne 2ae expenses cm Senedd} 2 Additonal member communcatons expenses axa aa ease b adivoet Warnng and communty serie coe sanenseo] __snanaso davon pring and pubicoTars expenses narase| 272.90) Allther expenses 3 Mo inangbleasses eee ek et ee ee es ” Be cuca ney yy can as ware 16 _TotalassetsAad ines 1 through 15 (must equaline 4)» - ss mrsraet| 16 Hanes ge nese pipet an ae de EE rernaail 47 e281 te Gantepbie se a 19 pelredeeveme ee ee ena a9 Bins A per rr gop soe eee ce 20 24 Escroworcuttodal account labity Complete Pan IV of Schedule. z & [22 Loans and other payacies to current and former oftcers, directors, tutes, 2 Key employees ghest comparaneed omployeer tnd dinate 3 persons Complete PartIlofScheduleL . . . . . . i 2 Jas securedmortgayes ond notes payabe to unelates tha partes. wees) a BAI 24 unsecured notes and leans payable to unreloted third pores ss « ™ 25. Otherlmblies (including federal come tx, payables to related third pares, tnd other abies rot eluded on nes 19:59) Complete Part x ofSehedule 9 aaa sus] a5 saxer0 26 Tota iabltlenAdétnes 47 though 2s vs sey se Texotora] 26 Teles: Organizations that follow SFAS 437 (ASC 950), check here [Gand complete 2 tne 27 through 25, ndings 33 ond 38 S |27 unvestrictednetassets 2. a 7 7 : 4,013,706) 27 27,802,714 SB |ae vemporariy restnctec netassets ss a aaa oe Tata B Jas permanentyrestncted net assets vs vs vv tv te ssersa01] 29 von on 2 Organization that donot follow SFAS 137 (ASC 358), checkhere® [and 8 complete lines 30 through 34, [20 conta stock or trust prcial or curent tunes 7 » J [a2 paw-nercaptat surplus, ortond bully orequpmenttind ee. at Jaz netamed enrngs, endowment, accumulated icome, or cter finds a ZB |33 — Totalnetassets or fund balances. A 42,599,724 33. 75,388,162 24 Total habites and net assetefundbalenets = vs sv vs mreweol 34 Fa. Form 990 (2015)Form 990 (2015) Page 12 Raconcilliation of Net Assets Check if Schedule © contains a response or note to any line in this Part XI Vv 1 Total revenue (must equal Part VIII, column (A), line 12) 1 336,709,238 2 Total expenses (must equal Part IX, column (A),line25) . . 6 6 ee ee ee 2 303,534,567 3 Revenue less expenses Subtract line 2 fromlmet . . 2 4 ee 3 33,174,671 4 Net assets or fund balances at beginning of year (must equal Part X, line 33, column (A) 4 42,599,724 5 Net unrealized gains (losses) on investments... 6 ew we ee 5 2,173,402 6 Donated services anduse offaciities «6. 6. 6 7 Investment expenses. es 7 8 Priorperiod adjustments ©... ee ee 8 9 Other changes in net assets or fund balances (explain in Schedule 0) s 1,757,169 40 Net assets or fund balances at end of year Combine lines 3 through 9 (must equal Part X, line 33, column (B)) 10 75,358,162 [ETEERHY Financial Statements and Reporting Check if Schedule © contains a response or note to any line in this Part X11. ie ves | No 4 Accounting method used to prepare the Form 990 Fcash accrual other {Fthe organization changed its method of accounting from a prior year or checked "0 ther," explain in Schedule © 2a Were the organization's financial statements compiled or reviewed by an independent accountant? 2 No 1F'Yes,’check a box below ta indicate whether the financial statements for the year were compiled or reviewed on a separate basis, consolidated basis, or both [Separate basis T Consoidated basis [Both consolidated and separate basis b Were the organization's financial statements audited by an independent accountant? ab | ves IfYes,’check a box below to indicate whether the financial statements for the year were audited on a separate basis, consolidated basis, or both I Separate basis Consolidated basis [¥ Both consolidated and separate basis © If*Yes," to line 2a oF 2b, does the organization have a committee that assumes responsibility for oversight of the audit, review, or compilation of its financial statements and selection of an independent accountant? 2c | ves Ifthe organization changed either its oversight process or selection process during the tax year, explain in Schedule 0 32 As a result ofa federal award, was the organization required to undergo an audit or audits as set forth in the Single Audit Act and OMB Circular A-1337 3a No b If "Yes," did the organization undergo the required audit or audits? If the organization did not undergo the required audit or audits, explain why in Schedule O and describe any steps taken to undergo such audits 3b Form 980 (2025)