Filing Summary

On April 26, 2019, the OAG informs the NRA that it is investigating improper conduct by the NRA, including: (1) related party transactions between the NRA and its board members; (2) unauthorized political activity; and (3) potentially false or misleading disclosures in the NRA’s regulatory filings. The OAG commands the NRA to preserve any documents that may be relevant to the OAG’s investigation.

Key Points

• The OAG notifies the NRA that it is “currently investigating conduct by the [NRA] and affiliated entities, including related party transactions between the NRA and its board members; unauthorized political activity; and potentially false or misleading disclosures in regulatory filings.” (Pg. 2.)
• The OAG requests that the NRA “preserve all physical electronic data and records, including documents and correspondence … pertaining to matters that are the subject of [the OAG’s] investigation.” (Pg. 2.) The preservation request extends to records going back as far as January 1, 2012. (Pg. 3.)
• The OAG requests that the NRA preserve, among other things, records relating to: (1) payments made to board members, other NRA personnel, and family members; (2) contracts relating to fundraising and marketing activities; (3) membership recruitment or promotional programs; (4) all financial transactions among NRA affiliated entities; (5) financial audits, regulatory disclosures, and legal compliance; (6) all communications between the NRA or its affiliates with any campaign for elected office; (7) conflict of interest policies; and (8) whistleblower policies or complaints. (Pg. 3.)