compass LegaL
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JUL 2025
Insurrectionist and voter suppression advocate Cleta Mitchell formed a new dark money group in 2023 to channel funds to organizations that promote the Big Lie of a stolen 2020 election and spread misinformation about the threat of widespread noncitizen voting.
Housed in the offices of the Conservative Partnership Institute (CPI), the Foundation for Accountability Integrity & Research in Elections Fund (FAIR Elections Fund) brought in $3.9 million between July 1, 2023 and June 30, 2024, and disclosed $2.1 million in expenses, more than three-quarters of which was disbursed in grants to other organizations.
The FAIR Elections Fund has no website as of publication. A Center for Media and Democracy (CMD) analysis of the group’s first tax filing, recently made public, offers the first internal look into Mitchell’s group since she disclosed leading it in biographies and news reports.
The group’s IRS filing says that it made no payments for salaries or other compensation, while claiming Mitchell is working 50 hours per week for the group. This raises the question of who is paying Mitchell for her work.
Mitchell has worked to manufacture a crisis around noncitizens voting and partnered with the American Legislative Exchange Council (ALEC) to push for model bills and amendments to state constitutions banning it — despite the fact that evidence of noncitizen voting is scarce. “Every legitimate study ever done on the question shows that voting by noncitizens in state and federal elections is vanishingly rare,” the Brennan Center reported in 2024.
A senior legal fellow at CPI, Mitchell launched her previous project, the Election Integrity Network (EIN), with the help of the right-wing group, which was founded and led by former U.S. senator and congressman Jim DeMint and Trump’s former chief of staff Mark Meadows (also an insurrectionist). In 2023, EIN moved out of the CPI constellation of nonprofits and is now “administered and managed by the Virginia Institute for Public Policy with Virginia Institute president Lynn Taylor also serving as EIN’s Chairman as Cleta Mitchell retains an active EIN role as its founder,” according to a 2023 booklet obtained by CMD.
EIN’s latest IRS filing shows that as of December 2023 it was still registered at CPI’s office address, with just $213 left in the bank.
Serving on the FAIR Elections Fund board of directors alongside Mitchell, its president, are Vice President Heather Honey, Vice President Daniel Bean, Secretary Don Workman, and Treasurer Pat Corrigan.
Honey, also an executive director at the Election Research Institute, is a close ally of Mitchell who worked with her to sow doubt about the efficacy and trustworthiness of the nonpartisan Electronic Registration Information Center, or ERIC, which has resulted in many states opting out of this interstate effort to help ensure accurate voter rolls.
A 2024 analysis by Votebeat and Spotlight PA found that conclusions in Honey’s report on ERIC “are false, often based on out-of-context examples, and… are frequently not backed by the data she presents.”
The IRS filing shows that the FAIR Elections Fund paid $121,284 to Honey’s organization Verity Vote LLC for “consulting.”
Vice President Daniel Bean is an attorney who represented Trump advisor Andy Surabian when he was subpoenaed by the House Select Committee investigating the January 6 attack on the Capitol.
Secretary Don Workman is a partner at Baker & Hostetler and was a partner at Foley & Lardner, the Washington-based law firm that Mitchell was forced to resign from after she participated in the infamous post-2020 election phone call in which Trump urged Georgia’s secretary of state to “find” enough votes for him to claim victory in that swing state.
Treasurer Pat Corrigan runs Compass Direct LLC, a fundraising company that works for CPI, where his brother Edward is president. Given Corrigan’s role as treasurer, he is likely the one tasked with raising funds for the organization.
$1.6 Million in Grants
The FAIR Elections Fund distributed $1.6 million in grants in 2023-24 to 10 allied groups.
The FDRLST Media Foundation, which publishes the right-wing web magazine The Federalist, received $400,000, the largest grant. In 2020, The Federalist falsely accused Democrats of trying to steal the election in Michigan, Wisconsin, and Pennsylvania during extended vote counting in the days following the presidential election.
The pro-Trump outlet also published a column EIN’s Kerri Toloczko misinforming readers that noncitizen voting is a crisis that needs to be addressed through federal legislation. Since 2019 it has run nine pieces by Mitchell on noncitizen voting, purging voter rolls, and voting by mail.
EIN’s administrator, the Virginia Institute for Public Policy, received the next largest grant of $325,000. The Institute held its fifth Election Integrity Summit on May 16, and holds “infrastructure trainings” twice a month.
The FAIR Elections Fund funneled its third largest grant of $300,000 to the State Freedom Caucus Foundation, the sister organization of the State Freedom Caucus Network (SFCN). CPI incubated SFCN, which Meadows launched in 2021. From the beginning, the group has touted “election integrity” as a priority.
The network has been deployed to ban noncitizens from voting at the federal level as well as at the state level in places like Missouri.
Mitchell also spoke at the 2024 State Freedom Caucus Network Summit, where Wyoming State Freedom Caucus Chair Rachel Rodriguez-Williams (R) said she “shared some shocking statistics about American elections and illegal immigration.”
The Immigration Accountability Project (IAP) received $150,000 from the FAIR Elections Fund, the IRS filing shows. IAP President Chris Chmielenski collaborated with Mitchell and Ken Cuccinelli, national chairman of the Election Transparency Initiative, to work a room of 150 attendees at ALEC’s 2024 Annual Meeting to approve an Only Citizens Vote Coalition model bill banning noncitizen voting, The Guardian reported.
The FAIR Elections Fund, Immigration Accountability Project, and Election Transparency Initiative are all members of the Only Citizens Vote Coalition, with Mitchell serving as a “co-convener.”
Also receiving FAIR Elections Fund grants between July 1, 2023 and June 30, 2024 were the Tea Party Patriots Foundation ($100,000); Citizen Outreach Foundation ($89,100); John K MacIver Institute for Public Policy ($75,000); Strong Communities Foundation of AZ ($75,000); Wisconsin Institute for Law & Liberty ($75,000); and Wisconsin Voter Alliance Corp ($25,000).
In November, Wisconsin voters passed a ballot measure to change one word in the state constitution to prevent non-U.S. citizens from voting in any local, state, or federal election. The right-wing MacIver Institute and Wisconsin Institute for Law & Liberty were proponents of its passage.
Funding is Dark
Despite the new IRS filings, funding information about the FAIR Elections Fund is scarce. The organization is not required to disclose its donors, and a CMD search of the filings only identified a single contribution of $795,000 from CPI, which does not note the original source of the funds. A CMD analysis of CPI’s known funders is available here.
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NYT
Pro-Trump Nonprofit Paid Millions to Companies Tied to Its Own Leaders
The Conservative Partnership Institute’s three highest-paid contractors had connections to the group’s leaders or their relatives, raising concerns about self-dealing.
Two men in dark suits shaking hands across a table.
A job fair sponsored by the Conservative Partnership Institute on Capitol Hill in June 2018. The group was founded the year before and aims to help conservatives wield power.Credit...Al Drago for The New York Times
David A. Fahrenthold
Reporting from Washington
May 6, 2024
The Conservative Partnership Institute, a nonprofit whose funding skyrocketed after it became a nerve center for President Donald J. Trump’s allies in Washington, has paid at least $3.2 million since the start of 2021 to corporations led by its own leaders or their relatives, records show.
In its most recent tax filings, the nonprofit’s three highest-paid contractors were all connected to insiders.
One was led by the institute’s president, Edward Corrigan, and another by its chief operating officer. At a third contractor, the board members included the group’s senior legal fellow Cleta Mitchell, a lawyer who supported Mr. Trump’s efforts to overturn the 2020 election.
Last year, the Conservative Partnership Institute hired a fourth company connected to an insider: a fund-raising firm run by Mr. Corrigan’s brother, Patrick Corrigan. Public filings show the company received a contract three weeks before the firm was legally formed.
The Conservative Partnership Institute applied to the Internal Revenue Service as a tax-exempt nonprofit, and the agency approved. That means donations to the group are tax deductible, like gifts to a food bank or the American Red Cross. It also means that, by law, its money must serve the public good rather than private interests.
The nonprofit has pushed those limits by entwining itself with only one faction of American politics. It pays high salaries to some of Mr. Trump’s former officials, hosts retreats for Republican lawmakers at a rural compound and funds efforts to vet people and ideas for a second Trump term.
Legal experts say these insider transactions also raise concerns about self-dealing. While hiring insiders is permitted when certain safeguards are in place, the payments moved money out of daylight and into opaque entities that the nonprofit’s leaders helped control.
“There’s no checks and balances,” said Michael West, a lawyer at the New York Council of Nonprofits. Because there is no real third party to determine whether the insider-led companies were charging the nonprofit a fair price, Mr. West said, “the potential for overpayment here is epic.”
Mr. Corrigan, the institute’s president, did not respond to questions about what steps the group took to assure that it was not overpaying the insiders’ companies. The companies did not say what rates they charged.
Image
A close-up frame of Edward Corrigan. He is smiling.
Edward Corrigan, the president and chief executive of the Conservative Partnership Institute, at a panel discussion in National Harbor, Md., last year. His group applied to the Internal Revenue Service as a tax-exempt nonprofit and was approved.Credit...Leigh Vogel for The New York Times
Of the insiders who had dual roles at the nonprofit and its vendors, only one responded to questions from The New York Times. Wesley Denton, the institute’s chief operating officer and a former Trump administration official, said he also had been paid by Compass Professional, one of the vendors.
Mr. Denton’s annual compensation, with benefits, from the institute was $391,735. He declined to say how much he received from Compass Professional. He was on the board of both the vendor and the institute.
“We’re proud to have helped launch new, independent, nonprofit service providers that provide high-quality professional services,” Mr. Denton said in a written statement.
The institute’s donors include several Republican political campaigns, as well as conservative businesspeople. One major donor, the retired Texas aviation entrepreneur Robert Bruce, said the nonprofit’s leaders had not told him about their use of vendors with insider connections.
“I’ve never had a conversation like that,” Mr. Bruce said in a phone interview.
He estimated he had given “several hundred thousand” dollars to the institute. Mr. Bruce said he had no concerns that the nonprofit’s leaders were misusing money. “I’ve known them a long time,” he said. “They’re good people.”
The Times traced the relationships between the group’s leaders and their vendors by examining charity and corporate filings with the federal government, five states and the District of Columbia.
The records do not show what share of the $3.2 million went to the institute’s top leaders and their family members — only that the money flowed to companies where they served as an owner or a director. In at least one case, a company failed to flag that connection as required in a state filing.
Image
Two people wearing Trump 2024 hats and clothing.
The Conservative Partnership Institute pays high salaries to former Trump officials, hosts retreats for Republican lawmakers at a rural compound and funds efforts to vet people and ideas for a second Trump presidency.Credit...Jamie Kelter Davis for The New York Times
The Conservative Partnership Institute was founded in 2017 by former Senator Jim DeMint, Republican of South Carolina, after he was ousted as the president of the Heritage Foundation, a conservative nonprofit. The group’s aim was to help conservatives wield power, shepherding them “through the Washington swamps without being infected with Potomac Fever,” Mr. DeMint said in 2017.
The institute’s fund-raising actually improved when conservatives lost power.
In 2021, with Democrats in charge in Washington, the institute hired former Trump staff members, including Mark Meadows, the former White House chief of staff. It began courting donors as the voice of Mr. Trump’s allies and ambitions.
Fund-raising jumped to $45 million in 2021 from $7 million in 2020. The nonprofit, newly flush, bought a 2,200-acre retreat on the Eastern Shore of Maryland and a series of commercial buildings near the U.S. Capitol, with plans for a restaurant, a school and TV studios. The group also began convening workshops and seminars for conservative lawmakers and staff members as well as seeding new conservative nonprofits.
As the money flowed, the institute’s leaders began to found a series of companies in Delaware.
The first was Compass Professional. Its first annual report listed a slate of directors, including Edward Corrigan and Mr. Denton.
Next was Compass Legal Services. Its initial filing listed directors, including Ms. Mitchell and Charlotte Davis, one of the institute’s board members.
By the end of 2021, the group had paid its companies a combined $639,259, according to an audit that it filed with state-level charity regulators.
Federal law allows nonprofits like this one to hire insiders as long as they properly disclose the payments and ensure the insiders do not overcharge. Legal experts still advise against it because of the temptation for insiders to abuse their power over charity funds.
“You have an obligation to behave in the interest of that organization,” said Linda Sugin, a professor of nonprofit law at Fordham University. “The problem is, when you’re on both sides of the transaction, then we’re skeptical that you’re going to put the organization’s interests before your own.”
Ms. Sugin said the institute could have reduced its risk by soliciting bids from competing firms to gauge whether the insiders were charging market rates. The institute could have asked its leaders to recuse themselves from the decision to hire their own companies, she said.
Mr. Corrigan and other leaders did not respond to questions about whether their group took those steps.
If a nonprofit is found to have given improper benefits to insiders, the insiders could face financial penalties from state or federal regulators. In extreme cases, the I.R.S. could revoke the group’s tax exemption.
In 2022, a third Delaware company was formed: Compass Property Management. Its corporate filings show Mr. Denton as president.
During that year, the nonprofit paid the three insider-connected companies a combined $2.6 million, according to the audit that it filed with states. The institute said those payments were “for the use of facilities, personnel, human resources and other professional services.”
How much of that flowed to the insiders on those vendors’ boards of directors?
Mr. Denton offered only a partial answer.
He said the vendors did not pay their board members solely because they were board members.
However, as in his case, Mr. Denton said the companies could pay their board members for other reasons, for “doing employment work for these organizations, outside of their board duties.” The president of Compass Legal issued a statement saying his company did not pay “outside directors” but did not specify which directors were counted as “outside.”
Compass Professional and Compass Legal have worked for other clients, including Mr. Trump’s 2024 presidential campaign and Gun Owners of America, according to federal campaign and charity filings. The companies’ leaders did not respond to queries about how much of their business came from the Conservative Partnership Institute.
The most recent data on what the institute paid the three original insider-connected companies is from 2022. Since then, corporate filings show, the companies’ board members have shifted, but Conservative Partnership Institute leaders or their family members remained on the boards of each.
Last year, the institute also hired a company that was partly owned by Patrick Corrigan, Compass Direct LLC, to a fund-raising contract, paying $180,000 over the next year.
In a filing in North Carolina, the institute said that contract began on July 1, 2023. But Patrick Corrigan’s company was not founded until July 24, three weeks after it won the contract.
In its own filings with North Carolina, Patrick Corrigan’s company was asked if he was related “as parent, spouse, child or sibling to ANY officer, director, trustee or employee” as his client, which was his brother’s nonprofit.
In filings for 2023 and 2024, the company answered “no.” Patrick Corrigan signed the forms.
After The Times pointed this out, Patrick Corrigan responded with a one-line email: “The NC filing has been updated,” he wrote. He did not respond to other questions.
Robert Draper and Julie Tate contributed reporting.
David A. Fahrenthold is an investigative reporter writing about nonprofit organizations. He has been a reporter for two decades. More about David A. Fahrenthold
:{A version of this article appears in print on May 7, 2024, Section A, Page 15 of the New York edition with the headline: Trump-Allied Nonprofit Paid Millions to Firms With Ties to Insiders.
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https://www.exposedbycmd.org/2022/09/13/maga-group-grooms-members-of-congress-and-their-staff-for-america-first-movement/
CPI hit squad:
CPI has also launched a number of spin-offs to further right-wing causes, including the American Accountability Foundation (AAF), America First Legal, Center for Renewing America, American Cornerstone Institute, American Moment, and the State Freedom Caucus Network.
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Staffers Coached in Conservative Oversight
From May 5–6, seven House Republican staffers and three Senate Republican staffers attended an Effective Oversight Training Retreat paid for by AAF and led by CPI, AAF, and the Heritage Foundation—all ostensibly nonpartisan 501(c)(3) organizations.
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Attendees participated in six training sessions, according to an agenda obtained by CMD, including on “how to work with legal experts to leverage research and advance conservative priorities in the courts,” “working with outside groups involved in oversight,” and “how to conduct effect research into Presidential appointees and nominees” to “help congressional staff perform proper oversight.”
The latter session was led by AAF’s founder Tom Jones, who is credited with leading GOP opposition to Justice Ketanji Brown Jackson’s confirmationand for sinking the nomination of Sarah Bloom Raskin for vice chair for supervision of the Federal Reserve Board of Governors, among others.
AAF runs the website bidennoms.com,which currently features opposition campaigns against Phillip Washington for administrator of the Federal Aviation Administration (FAA); Gigi B. Sohn to be a member of the Federal Communications Commission (FCC); Kalpana Kotagal to be a member of the Equal Employment Opportunity Commission (EEOC); and Dilawar Syed for deputy administrator of the Small Business Administration (SBA).
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Kotagal appears to be a top target of AAF, prompting it to create the separate website kalpanakotagal.com, where she is labeled a “radical leftist” who is “poised to weaponize the Equal Employment Opportunity Commission with an anti-American agenda.”
SCREENSHOT FROM WWW.KALPANAKOTAGAL.COM
Kotagal is actually an accomplished employment and civil rights plaintiffs’ litigator, perhaps best known for co-authoring the “Inclusion Rider,” a contract provision in Hollywood designed to increase diversity in casting and production staff.
In addition to staffers from CPI, AAF, and Heritage, others from the right-wing Capital Research Center, the Republican Study Committee, and Compass Legal also led training sessions. CPI launched Compass Legal to take “care of things like legal filings” and help nonprofits “to comply with federal tax law so they can keep their nonprofit status,” according to its 2021 Annual Report.
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Scott Gast
CHIEF COUNSEL
Scott Gast has practiced political law for nearly twenty years. He most recently spent four years in the Trump Administration’s White House Counsel’s Office, overseeing the ethics and compliance portfolio as Deputy Counsel to the President. Prior to that, he served as investigative counsel at the Office of Congressional Ethics, where he conducted ethics investigations into Members of Congress and congressional staff. He spent several years in private practice, focusing on political law and white-collar defense and investigations, at the Washington, DC firm of Covington and Burling LLC. In addition to his legal experience, he has held senior positions on Capitol Hill and in congressional campaigns. Scott is a graduate of the University of Michigan and the University of Virginia School of Law, and clerked on the United States Court of Appeals for the Seventh Circuit.
William M. Klimon
SENIOR COUNSEL
William Klimon has advised over 700 nonprofit organizations on a complete range of issues from formation to dissolution. He has worked with many of the nation's most prominent private foundations, public charities, political campaigns, schools, and churches. For more than 20 years he was a member of the tax-exempt-organizations group at the Washington, D.C. law firm Caplin & Drysdale. He also chaired the American Bar Association’s Nonprofit Organizations Committee (2018-20). Mr. Klimon served in the U.S. Army from 1987-90, during which time he was assigned to the U.S. Army Field Station in Berlin. Later, he was a Claude R. Lambe Fellowand a Philip Merrill Fellow in the history department of the graduate school at Cornell University. He has degrees from the University of Pennsylvania, the University of Maryland School of Law, and the Georgetown University Law Center.
Derek Ross
SENIOR COUNSEL
Derek Ross assists political candidates and elected officials in navigating the areas of state and federal campaign finance laws and ethics rules. He also advises corporations and nonprofit groups wishing to engage in the electoral process. National political organizations rely on Derek’s knowledge and experience to guide them from inception to election day. Derek previously worked as an enforcement attorney at the Federal Election Commission and regularly represents clients before the FEC, the Office of Congressional Ethics, and state ethics commissions. Derek is a graduate of the University of Oklahoma and the University of Oklahoma College of Law, and he served as a law clerk on the United States District Court for the Western District of Oklahoma.
Patrick Sternal
cOUNSEL
Patrick Sternal has extensive experience in tax-exempt and nonprofit organization law. For nearly ten years he worked in the federal government as a Tax Law Specialist in the IRS Office of Tax Exempt and Government Entities, Rulings and Agreements, where he focused on exempt organization determinations and compliance, and as an Attorney Advisor at the IRS Office of Chief Counsel, Exempt Organizations, where he worked on drafting guidance and advising the IRS operating division. Before entering the IRS, he practiced law in Los Angeles, working primarily with exempt organization and nonprofit clients. He is a graduate ofThomas Aquinas College, Ave Maria School of Law, and Loyola Law School. Not a member of the DC Bar. Practicing under the direct supervision of a DC Bar member.
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