April 26, 2019 Document Preservation Letter (Exhibit 1 to 8/16 MOL)
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.
- 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.)