- Subject
- Cleta Mitchell
- File type
- Investigation
- Status
- PUBLISHED
- Record
- 12 FACTS · 12 PRIMARY
- Sources
- 86
- Filed
- May 21, 2026
The CPI Hub
One Washington address, eleven entities, and a self-dealing pattern flagged by the NYT and POLITICO. The Conservative Partnership Institute is built on a ring of vendors it pays for services, all controlled by its own senior legal fellow.
The Conservative Partnership Institute is a 501(c)(3) operating from 300 Independence Avenue SE in Washington DC, with a 2024 annual budget of approximately $36 million. The same address houses three Delaware Compass entities (Compass Professional Inc., Compass Legal Group LLC, Compass Property Management LLC), all founded in 2021 or 2022, and all with Cleta Mitchell, CPI's Senior Legal Fellow, listed as officer, managing member, or principal. CPI pays the Compass entities for services. NYT and POLITICO have both flagged the arrangement as a self-dealing pattern, with combined CPI payments to the affiliated vendors exceeding $2.4 million in a single year. The same address is also the formal home of America First Legal (Stephen Miller) and the Center for Renewing America (Russell Vought), both classified as CPI affiliates in CPI's own filings.
The investigation
Drag to pan. Click a node to focus its relationships. Use the +/− controls (or ⇧/⌘ + scroll) to zoom.
Curated subgraph drawn from CPI's 2022 and 2023 IRS Form 990s, Delaware corporate filings on the Compass entities, the entity dossiers in internal entity research dossiers, and FEC expenditure data on the Datwyler / 9Seven money flow.
The address
300 Independence Avenue SE in Washington DC is the operating address of the Conservative Partnership Institute, a 501(c)(3) founded in 2017 by former Senator Jim DeMint. CPI is run day-to-day by Ed Corrigan as President and CEO, with Mark Meadows on staff as Senior Partner (compensation reported at $847,000 per year) and Cleta Mitchell on staff as Senior Legal Fellow. The same physical address appears in the corporate filings of three other entities. Compass Professional Inc., Compass Legal Group LLC, and Compass Property Management LLC are all Delaware companies, founded between 2021 and 2022, and all share both the CPI building and the same controlling figure.
The Compass ring
Cleta Mitchell is listed as Officer and co-founder of Compass Professional Inc. in its 2021 formation paperwork. She is listed as Managing Member and beneficial owner of Compass Legal Group LLC, also formed in 2021. She is listed as Principal and Manager of Compass Property Management LLC, formed in 2022. The three entities are operationally and physically tied to CPI, share its address, and are described in subsequent reporting by NYT and POLITICO as vendors that CPI then pays for accounting, legal, and property management services.
POLITICO Influence reported in November 2024 that CPI paid more than $2.4 million in a single year to the three Compass vendors. The 2023 figure for Compass Professional Inc. alone was approximately $900,000. Compass Property Management LLC received approximately $550,000 from CPI in 2022. The arrangement is the textbook fact pattern that triggers IRS self-dealing scrutiny on a 501(c)(3): a nonprofit paying for services from companies controlled by its own officers.
The financial-compliance layer
Compass Professional Inc. is the staffing and FEC-compliance arm of the cluster. Thomas Datwyler is listed in CPI-adjacent reporting as Compass Professional's FEC Compliance Counselor, and in FEC committee master records as the treasurer of record on 714 federal political committees. The candidates served by those committees number 245, all Republican. The combined expenditures of the Datwyler-network committees from 2019 through 2026 total approximately $1.16 billion.
The single largest payee across the Datwyler-network committees is a company called 9Seven Consulting, which received approximately $4.14 million from 343 distinct FEC committees between 2019 and 2025. Compass Legal Group received approximately $830,500 from 44 committees over the same period. Conservative Partnership Center LLC, a separate CPI operating entity, received approximately $778,000 from 23 committees. Compass Professional Inc. itself received approximately $302,000 directly from 13 committees. The CPI 501(c)(3) received approximately $237,000 from 33 committees. The combined inbound revenue across the CPI vendor cluster from FEC-regulated committees is approximately $6.4 million.
Why the architecture matters
Read as separate entities, none of the items above are individually unusual. A think tank can share office space with affiliated nonprofits, and a treasurer can serve multiple committees, and a 501(c)(3) can buy services from a vendor. Read together, the architecture concentrates a substantial share of Republican federal campaign compliance and CPI back-office services in a small set of co-located entities controlled by a small set of people. The single shared address, the single shared controlling officer across three Compass entities, and the single shared treasurer of record across 714 committees are facts that no individual filing surfaces on its own.
What is not (yet) in this diagram
Russell Vought's Center for Renewing America is shown as a tenant of the same address because CPI lists it as an affiliated organization in CPI's own materials. Specific claims that have circulated about Vought's involvement in the founding and later removal from Compass Professional's filings are not yet supported by source documents in the research vault, and are therefore omitted from the diagram. Similarly, the Conservative Partnership Center LLC, Conservative Partnership Campus Inc., American Voting Rights Foundation, American Accountability Foundation, and other CPI affiliates listed in CPI's published materials are not yet rendered as nodes. The next pass of this investigation will add them as each is sourced to a specific filing.
Cleta Mitchell
Senior Legal Fellow, CPI. Officer or controlling figure across all three Compass entities.
Election lawyer. Founded the Election Integrity Network at CPI. Listed on CPI's own staff page as Senior Legal Fellow. Named in 2021 formation paperwork as Officer / co-founder of Compass Professional Inc., as Managing Member of Compass Legal Group LLC, and in 2022 as Principal / Manager of Compass Property Management LLC. The single individual common to the three CPI-paid vendors and to CPI itself.
Ed Corrigan
President and CEO, Conservative Partnership Institute.
President and CEO of CPI. Listed in the Compass Professional Inc. dossier as the source through which CPI service contracts flow into Compass Professional. Vice Chairman of the Conservative Action Project.
Mark Meadows
Senior Partner / Advisor, CPI.
Former White House Chief of Staff under Donald Trump. Joined CPI in January 2021. Compensation reported in CPI's IRS 990 filings at approximately $847,000 per year. Primary responsibility documented in reporting is fundraising.
Thomas Datwyler
FEC Compliance Counselor at Compass Professional Inc.
Listed as treasurer of record on 714 FEC-registered political committees per the FEC committee master, including 245 Republican federal candidates. Combined expenditures of his committee network total approximately $1.16 billion from 2019 through 2026.
Jim DeMint
Chairman and founder, CPI.
Former United States Senator from South Carolina. Former President of the Heritage Foundation. Founded CPI in 2017.
Stephen Miller
Founder, America First Legal.
Founded America First Legal in 2021, after the Trump first-term loss. AFL is listed as a CPI affiliate in CPI's own materials. Now serves as Deputy Chief of Staff for Policy and Homeland Security Advisor in the Trump second term.
Network map
- Person
- Organization
- PAC
- Government body
- Recorded relationship
- ● a verified primary record or stored query backs it
- ○ reported only
Map data as a table
Series and data
Data
Records from FEC filings
Chart data as a table
| Yr | Txns | Total |
|---|---|---|
| 2019 | 11 | 349456.2 |
| 2020 | 42 | 1817806.88 |
| 2021 | 30 | 3526312.77 |
| 2022 | 66 | 15748207.7 |
| 2023 | 55 | 5433882.41 |
| 2024 | 137 | 42380971.25 |
| 2025 | 10 | 934701.73 |
| 2026 | 5 | 2158979.01 |
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT toYear(transaction_dt) AS yr, count() AS txns, sum(transaction_amt) AS total FROM politics_vault.fec_operating_expenditures_2019_2026 WHERE upper(name) IN ('EVENT STRATEGIES, INC.','EVENT STRATEGIES INC.','EVENT STRATEGIES','EVENT STRATEGIES INC','EVENT STRATEGIES, INC') GROUP BY yr ORDER BY yrRetrieved Oct 26, 2026
Data
Records from IRS Form 990 filings
Chart data as a table
| Tax year | Total to flexpoint | Count | N orgs |
|---|---|---|---|
| 2017 | 141550 | 1 | 1 |
| 2018 | 1888819 | 1 | 1 |
| 2020 | 1400000 | 2 | 2 |
| 2021 | 1116500 | 1 | 1 |
| 2022 | 62710000 | 1 | 1 |
| 2023 | 1000000 | 1 | 1 |
Source: IRS Form 990 filings · retrieved Jul 16, 2026
How these rows were pulled
SELECT tax_year, sum(compensation) AS total_to_flexpoint, count(*) AS n, count(DISTINCT ein) AS n_orgs FROM politics_vault_archive.ein_990_contractors WHERE upperUTF8(name) LIKE '%FLEXPOINT%' GROUP BY tax_year ORDER BY tax_year
Retrieved Jul 16, 2026
Data
Records from IRS Form 990 filings
Chart data as a table
| EIN | Organization | Tax year | Total to flexpoint | Count |
|---|---|---|---|---|
| 882968375 | Citizens for Sanity | 2022 | 62710000 | 1 |
| 882968375 | Citizens for Sanity | 2023 | 1000000 | 1 |
Source: IRS Form 990 filings · retrieved Jul 16, 2026
How these rows were pulled
SELECT ein, org_name, tax_year, sum(compensation) AS total_to_flexpoint, count(*) AS n FROM politics_vault_archive.ein_990_contractors WHERE upperUTF8(name) LIKE '%FLEXPOINT%' AND upperUTF8(org_name) = 'CITIZENS FOR SANITY' GROUP BY ein, org_name, tax_year ORDER BY tax_year
Retrieved Jul 16, 2026
Data
Records from FEC filings, FEC C00771246
Chart data as a table
| Yr | Total | Count |
|---|---|---|
| 2024 | 97419.81999999999 | 11 |
| 2025 | 143336.9 | 12 |
| 2026 | 167990.7 | 7 |
Source: FEC filings, FEC C00771246 · retrieved Oct 26, 2026
How these rows were pulled
SELECT toYear(toDate(transaction_dt)) AS yr, sum(toFloat64OrZero(toString(transaction_amt))) AS total, count() AS n FROM politics_vault.fec_operating_expenditures_2019_2026 WHERE cmte_id='C00771246' AND upper(name) LIKE '%COMPASS PROFESSIONAL%' AND upper(purpose) LIKE '%CAGING%' GROUP BY yr ORDER BY yr
Retrieved Oct 26, 2026
Data
Records from IRS Form 990 filings (Schedule I grants), EIN 522166327
Chart data as a table
| Tax year | Total from dt |
|---|---|
| 2022 | 25000 |
| 2023 | 129250 |
| 2024 | 3191074 |
Source: IRS Form 990 filings (Schedule I grants), EIN 522166327 · retrieved Jul 16, 2026
How these rows were pulled
SELECT tax_year, SUM(cash_grant_amt) AS total_from_dt FROM politics_vault_archive.ein_990_grants WHERE ein='522166327' AND recipient_ein='862190372' GROUP BY tax_year ORDER BY tax_year
Retrieved Jul 16, 2026
Data
Records from public filings
Show the table (12 rows)
| Tax year | Orgs that year | Arraystringconcat(arraysort(groupuniqarray(any org)), ' | ') |
|---|---|---|
| 2013 | 3 | FOUNDATION FOR GOVERNMENT ACCOUNTABILITY INC | STATE POLICY NETWORK | University of Dallas |
| 2014 | 3 | FOUNDATION FOR GOVERNMENT ACCOUNTABILITY INC | STATE POLICY NETWORK | University of Dallas |
| 2015 | 3 | FOUNDATION FOR GOVERNMENT ACCOUNTABILITY INC | STATE POLICY NETWORK | University of Dallas |
| 2016 | 3 | FOUNDATION FOR GOVERNMENT ACCOUNTABILITY INC | STATE POLICY NETWORK | University of Dallas |
| 2017 | 7 | Children's Center Early Intervention & Family Support | FOUNDATION FOR GOVERNMENT ACCOUNTABILITY INC | INTERCOLLEGIATE STUDIES INSTITUTE INC | STATE POLICY NETWORK | State Financial Officers Foundation Inc | THE HERITAGE FOUNDATION | University of Dallas |
| 2018 | 7 | Children's Center Early Intervention & Family Support | FOUNDATION FOR GOVERNMENT ACCOUNTABILITY INC | INTERCOLLEGIATE STUDIES INSTITUTE INC | STATE POLICY NETWORK | State Financial Officers Foundation Inc | THE HERITAGE FOUNDATION | University of Dallas |
| 2019 | 5 | INTERCOLLEGIATE STUDIES INSTITUTE INC | STATE POLICY NETWORK | State Financial Officers Foundation Inc | THE HERITAGE FOUNDATION | University of Dallas |
| 2020 | 7 | FOUNDATION FOR GOVERNMENT ACCOUNTABILITY INC | INTERCOLLEGIATE STUDIES INSTITUTE INC | STATE POLICY NETWORK | State Financial Officers Foundation Inc | THE HERITAGE FOUNDATION | University of Dallas | William A and Genevieve H Strong Foundation Trust |
| 2021 | 7 | FOUNDATION FOR GOVERNMENT ACCOUNTABILITY INC | INTERCOLLEGIATE STUDIES INSTITUTE INC | STATE POLICY NETWORK | State Financial Officers Foundation Inc | THE HERITAGE FOUNDATION | University of Dallas | William A and Genevieve H Strong Foundation Trust |
| 2022 | 7 | FOUNDATION FOR GOVERNMENT ACCOUNTABILITY INC | INTERCOLLEGIATE STUDIES INSTITUTE INC | STATE POLICY NETWORK | State Financial Officers Foundation Inc | THE HERITAGE FOUNDATION | University of Dallas | William A and Genevieve H Strong Foundation Trust |
| 2023 | 6 | FOUNDATION FOR GOVERNMENT ACCOUNTABILITY INC | STATE POLICY NETWORK | State Financial Officers Foundation Inc | THE HERITAGE FOUNDATION | University of Dallas | William A and Genevieve H Strong Foundation Trust |
| 2024 | 5 | KNIGHTS OF COLUMBUS CHARITABLE FUND INC | STATE POLICY NETWORK | State Financial Officers Foundation Inc | THE HERITAGE FOUNDATION | William A and Genevieve H Strong Foundation Trust |
Source: public filings · retrieved May 30, 2026
How these rows were pulled
SELECT tax_year, countDistinct(ein) orgs_that_year, arrayStringConcat(arraySort(groupUniqArray(any_org)),' | ') FROM (SELECT tax_year, ein, any(org_name) any_org FROM politics_vault.v_990_officers_unified WHERE upper(person_name) LIKE '%WAGNER%' AND upper(person_name) LIKE '%BRIDGET%' GROUP BY tax_year, ein) GROUP BY tax_year ORDER BY tax_year
Retrieved May 30, 2026
Data
Records from public filings
- Distinct orgs
- 9
- Mn
- 2013
- Mx
- 2024
- Total filings
- 63
- Total comp all orgs
- 2055272
Source: public filings · retrieved May 30, 2026
How these rows were pulled
SELECT countDistinct(ein) distinct_orgs, min(tax_year) mn, max(tax_year) mx, count() total_filings, round(sum(reportable_comp_from_org)) total_comp_all_orgs FROM politics_vault.v_990_officers_unified WHERE upper(person_name) LIKE '%WAGNER%' AND upper(person_name) LIKE '%BRIDGET%'
Retrieved May 30, 2026
Data
Records from public filings
Show the table (11 rows)
| Person key | N orgs | Arraystringconcat(orgs, ' | ') |
|---|---|---|
| BRIDGETT WAGNER | 3 | Heritage Foundation | Foundation for Government Accountability | SFOF |
| LEONARD LEO | 2 | Rule of Law Trust | Marble Freedom Trust |
| REBEKAH MERCER | 2 | Manhattan Institute | Heritage Foundation |
| ROBERT LEVY | 2 | Foundation for Government Accountability | Cato Institute |
| EDWIN MEESE III | 2 | Heritage Foundation | Federalist Society |
| DONALD G SMITH | 2 | Manhattan Institute | Cato Institute |
| TODD GRAVES | 2 | The 85 Fund | Lucy Burns Institute / Ballotpedia |
| GARY MARX | 2 | Concord Fund | The 85 Fund |
| LEONARD A LEO | 2 | Federalist Society | Marble Freedom Trust |
| RICHARD W GRABER | 2 | Bradley Impact Fund | Lynde and Harry Bradley Foundation |
| ANN CORKERY | 2 | Concord Fund | The 85 Fund |
Source: public filings · retrieved May 30, 2026
How these rows were pulled
SELECT person_key, n_orgs, arrayStringConcat(orgs,' | ') FROM politics_vault.v_officer_interlock ORDER BY n_orgs DESC
Retrieved May 30, 2026
Data
Records from FEC filings, FEC C00867937
Show the table (10 rows)
| Transaction dt | Transaction amt | Stated purpose |
|---|---|---|
| 2024-10-31 | 4053309.9999999995 | AUDIO VISUAL SERVICES, EVENT STAGING EXPENSE, & TRAVEL EXPENSES |
| 2024-11-12 | 2324200 | AUDIO VISUAL SERVICES, EVENT STAGING EXPENSE, & TRAVEL EXPENSES |
| 2024-10-24 | 2216200 | AUDIO VISUAL SERVICES, EVENT STAGING EXPENSE, & TRAVEL EXPENSES |
| 2024-10-23 | 1842560 | AUDIO VISUAL SERVICES, EVENT STAGING EXPENSE, & TRAVEL EXPENSES |
| 2024-11-04 | 1802360 | AUDIO VISUAL SERVICES, EVENT STAGING EXPENSE, & TRAVEL EXPENSES |
| 2024-11-18 | 1478520 | AUDIO VISUAL SERVICES, EVENT STAGING EXPENSE, & TRAVEL EXPENSES |
| 2024-10-28 | 1321600 | AUDIO VISUAL SERVICES, EVENT STAGING EXPENSE, & TRAVEL EXPENSES |
| 2024-10-11 | 1212830 | AUDIO VISUAL SERVICES, EVENT STAGING EXPENSE, & TRAVEL EXPENSES |
| 2024-08-22 | 1146900 | AUDIO VISUAL SERVICES, EVENT STAGING EXPENSE, & TRAVEL EXPENSES |
| 2024-10-22 | 1077300 | AUDIO VISUAL SERVICES, EVENT STAGING EXPENSE, & TRAVEL EXPENSES |
Source: FEC filings, FEC C00867937 · retrieved Oct 26, 2026
How these rows were pulled
SELECT transaction_dt, transaction_amt, purpose FROM politics_vault.fec_operating_expenditures_2019_2026 WHERE cmte_id='C00867937' AND upper(name) IN ('EVENT STRATEGIES, INC.','EVENT STRATEGIES INC.','EVENT STRATEGIES','EVENT STRATEGIES INC','EVENT STRATEGIES, INC') ORDER BY transaction_amt DESC LIMIT 10Retrieved Oct 26, 2026
Data
Records from FEC filings
Show the table (10 rows)
| Cmte id | Committee | Txns | Total | First dt | Last dt |
|---|---|---|---|---|---|
| C00867937 | TRUMP 47 COMMITTEE, INC. | 77 | 36827044.06 | 2024-05-08 | 2025-02-12 |
| C00762591 | SAVE AMERICA | 55 | 14782701.25 | 2021-03-05 | 2024-02-14 |
| C00828541 | NEVER SURRENDER, INC. | 93 | 9262757.55 | 2022-12-22 | 2025-07-22 |
| C00075820 | NRCC | 14 | 3160056.77 | 2021-04-30 | 2025-04-15 |
| C00580100 | DONALD J. TRUMP FOR PRESIDENT, INC. | 42 | 1428841.14 | 2019-04-08 | 2020-12-15 |
| C00825851 | MAKE AMERICA GREAT AGAIN INC. | 15 | 1294238.17 | 2022-10-07 | 2024-11-25 |
| C00790477 | MAKE AMERICA GREAT AGAIN, AGAIN! INC. | 9 | 1166630.27 | 2022-02-02 | 2022-09-22 |
| C00618389 | TRUMP VICTORY | 3 | 357902.43 | 2019-12-12 | 2020-11-18 |
| C00771477 | MAKE AMERICA GREAT AGAIN ACTION INC | 5 | 289365.87 | 2021-05-28 | 2021-09-20 |
| C00834630 | BUCKEYE VALUES PAC | 2 | 250000 | 2024-03-12 | 2024-03-18 |
Source: FEC filings · retrieved Jun 10, 2026
How these rows were pulled
SELECT cmte_id, cmte_nm, tres_nm, cmte_dsgn, cmte_tp, cmte_pty_affiliation FROM politics_vault.fec_committee_master_2019_2026 WHERE cmte_id IN ('C00867937','C00828541','C00762591','C00580100')Retrieved Jun 10, 2026
Data
Records from public filings
Show the table (10 rows)
| Cmte id | Committee | Txns | Total | First dt | Last dt |
|---|---|---|---|---|---|
| C00867937 | TRUMP 47 COMMITTEE, INC. | 77 | 36827044.06 | 2024-05-08 | 2025-02-12 |
| C00762591 | SAVE AMERICA | 55 | 14782701.25 | 2021-03-05 | 2024-02-14 |
| C00828541 | NEVER SURRENDER, INC. | 93 | 9262757.55 | 2022-12-22 | 2025-07-22 |
| C00075820 | NRCC | 14 | 3160056.77 | 2021-04-30 | 2025-04-15 |
| C00580100 | DONALD J. TRUMP FOR PRESIDENT, INC. | 42 | 1428841.14 | 2019-04-08 | 2020-12-15 |
| C00825851 | MAKE AMERICA GREAT AGAIN INC. | 15 | 1294238.17 | 2022-10-07 | 2024-11-25 |
| C00790477 | MAKE AMERICA GREAT AGAIN, AGAIN! INC. | 9 | 1166630.27 | 2022-02-02 | 2022-09-22 |
| C00618389 | TRUMP VICTORY | 3 | 357902.43 | 2019-12-12 | 2020-11-18 |
| C00771477 | MAKE AMERICA GREAT AGAIN ACTION INC | 5 | 289365.87 | 2021-05-28 | 2021-09-20 |
| C00834630 | BUCKEYE VALUES PAC | 2 | 250000 | 2024-03-12 | 2024-03-18 |
Source: public filings · retrieved Jun 10, 2026
How these rows were pulled
SELECT gj_subpoena_id, doc_name, date_issued, recipient, recipient_type FROM politics_vault.arctic_frost_subpoenas WHERE positionCaseInsensitive(subject_text, 'Event Strategies') > 0 OR positionCaseInsensitive(recipient, 'Event Strategies') > 0 ORDER BY date_issued
Retrieved Jun 10, 2026
Data
Records from FEC filings
Show the table (2 rows)
| Era | Txns | Total | Committees |
|---|---|---|---|
| before | 146 | 21032646.11 | 23 |
| after_GJ392 | 208 | 50037087.83 | 13 |
Source: FEC filings · retrieved Jul 16, 2026
How these rows were pulled
SELECT if(transaction_dt > toDate('2022-12-01'),'after_GJ392','before') AS era, count() AS txns, sum(transaction_amt) AS total, uniqExact(cmte_id) AS committees FROM politics_vault.fec_operating_expenditures_2019_2026 WHERE upper(name) IN ('EVENT STRATEGIES, INC.','EVENT STRATEGIES INC.','EVENT STRATEGIES','EVENT STRATEGIES INC','EVENT STRATEGIES, INC') GROUP BY eraRetrieved Jul 16, 2026
Data
Records from IRS Form 990 filings
Show the table (25 rows)
| Payee | Organization | Tax year | Compensation | Description |
|---|---|---|---|---|
| FLEXPOINT MEDIA INC | Citizens for Sanity | 2022 | 62710000 | Advertising and promotion |
| MENTZER MEDIA SERVICES | ONE NATION | 2020 | 22312717 | MEDIA SERVICES |
| MENTZER MEDIA | The Concord Fund | 2018 | 12322297 | communication promotion |
| MENTZER MEDIA | The Concord Fund | 2020 | 6194131 | Advocacy |
| MENTZER MEDIA | The Concord Fund | 2021 | 5719496 | Advocacy |
| MENTZER MEDIA | The Concord Fund | 2022 | 3801690 | Advocacy |
| MENTZER MEDIA SERVICES | Consumers Research Inc | 2021 | 3512300 | Public Relations |
| MENTZER MEDIA | AMERICAN FUTURE FUND | 2018 | 2693425 | RADIO AND DIGITAL BUYS |
| MENTZER MEDIA SERVICES | ONE NATION | 2022 | 2586829 | MEDIA SERVICES |
| MENTZER MEDIA SERVICES | Consumers Research Inc | 2022 | 2333877 | Media |
| MENTZER MEDIA | THE 85 FUND | 2021 | 1947570 | Advertising |
| FLEXPOINT MEDIA INC | CLA INC | 2018 | 1888819 | MEDIA PLACEMENT |
| MENTZER MEDIA SERVICES INC | NATIONAL ASSOCIATION OF MANUFACTURERS OF THE UNITED STATES OF AMERICA | 2015 | 1867890 | MEDIA ADS & SERVICES |
| MENTZER MEDIA SERVICES | Consumers Research Inc | 2024 | 1686845 | MEDIA PLANNING & PLACEMENT |
| MENTZER MEDIA SERVICES | TURNING POINT USA INC | 2020 | 1500000 | TELEVISION ADS |
| MENTZER MEDIA SERVICES | Americans for Public Trust | 2021 | 1370000 | Media |
| FLEXPOINT MEDIA INC | HERITAGE ACTION FOR AMERICA | 2021 | 1116500 | MEDIA STRATEGY |
| FLEXPOINT MEDIA INC | Citizens for Sanity | 2023 | 1000000 | Advertising and promotion |
| MENTZER MEDIA SERVICES INC | HERITAGE ACTION FOR AMERICA | 2021 | 900000 | MEDIA & MARKETING |
| FLEXPOINT MEDIA | STATE GOVERNMENT LEADERSHIP FOUNDATION | 2020 | 800000 | DIGITAL MEDIA |
| MENTZER MEDIA | AMERICAN FUTURE FUND | 2014 | 715358 | MEDIA SERVICES |
| MENTZER MEDIA SERVICES INC | STATE GOVERNMENT LEADERSHIP FOUNDATION | 2018 | 685000 | MEDIA PLACEMENT |
| MENTZER MEDIA | AMERICAN FUTURE FUND | 2019 | 632068 | RADIO AND DIGITAL BUYS |
| FLEXPOINT MEDIA INC | CLA INC | 2020 | 600000 | media advocacy |
| FLEXPOINT MEDIA INC | STATE GOVERNMENT LEADERSHIP FOUNDATION | 2017 | 141550 | MEDIA PLACEMENT |
Source: IRS Form 990 filings · retrieved Jul 16, 2026
How these rows were pulled
SELECT upperUTF8(name) AS payee, org_name, tax_year, compensation, description FROM politics_vault_archive.ein_990_contractors WHERE upperUTF8(name) LIKE '%FLEXPOINT%' OR upperUTF8(name) LIKE '%JAMESTOWN ASSOC%' OR upperUTF8(name) LIKE '%MENTZER MEDIA%' OR upperUTF8(name) = 'CONSERVATIVE PARTNERSHIP INSTITUTE' ORDER BY compensation DESC LIMIT 100
Retrieved Jul 16, 2026
Data
Records from public filings
The 15 largest of 30 rows by Fec total amount. The table has every row.
Show the table (30 rows)
| Payee name | Fec total amount | Fec transaction count | Fec distinct committees paying | N990 total amount | N990 transaction count | N990 distinct orgs paying | Total combined revenue |
|---|---|---|---|---|---|---|---|
| TARGETED VICTORY | 317851394.3900002 | 9105 | 220 | 1204507 | 4 | 2 | 319055901.3900002 |
| TARGETED VICTORY LLC | 202064638.38000023 | 2949 | 107 | 6554115 | 4 | 2 | 208618753.38000023 |
| ONMESSAGE INC. | 185602727.26999992 | 3075 | 90 | 9467327 | 6 | 2 | 195070054.26999992 |
| FLEXPOINT MEDIA INC. | 112113766.24 | 889 | 64 | 75768050 | 7 | 4 | 187881816.24 |
| ADP, INC. | 140466199.09999985 | 11787 | 89 | 448468 | 2 | 1 | 140914667.09999985 |
| SOUTHWEST PUBLISHING AND MAILING CORPORATION | 111499475.91000003 | 2247 | 86 | 1091240 | 2 | 1 | 112590715.91000003 |
| 109345042.49999999 | 51411 | 1549 | 2705602 | 7 | 1 | 112050644.49999999 | |
| MENTZER MEDIA | 60230467.87999998 | 352 | 38 | 35611035 | 10 | 5 | 95841502.87999998 |
| MEDIUM BUYING LLC | 90258415.02 | 248 | 34 | 4603996 | 2 | 2 | 94862411.02 |
| COMMUNICATIONS CORPORATION OF AMERICA | 91006233.36000001 | 611 | 28 | 811650 | 2 | 1 | 91817883.36000001 |
| EVENT STRATEGIES, INC. | 63439339.239999995 | 326 | 26 | 883870 | 2 | 1 | 64323209.239999995 |
| THE LUKENS COMPANY | 54137954.37999996 | 1413 | 99 | 1910166 | 5 | 3 | 56048120.37999996 |
| GEORGE WASHINGTON UNIVERSITY | 202972.18 | 18 | 9 | 54532291 | 41 | 7 | 54735263.18 |
| JAMESTOWN ASSOCIATES | 29075725.990000006 | 993 | 99 | 23712130 | 2 | 1 | 52787855.99000001 |
| FELLOWSHIP OF CHRISTIAN ATHLETES | 233014.95000000007 | 269 | 7 | 48014931 | 158 | 17 | 48247945.95 |
| MDS COMMUNICATIONS CORPORATION | 11117230.609999994 | 434 | 6 | 36921282 | 21 | 2 | 48038512.60999999 |
| MEDIA MATTERS FOR AMERICA | 167800.44 | 16 | 1 | 46040050 | 31 | 3 | 46207850.44 |
| GLOBAL STRATEGY GROUP, LLC | 43987588.81999997 | 1706 | 224 | 176000 | 1 | 1 | 44163588.81999997 |
| PG PLACEMENTS | 14661749.030000001 | 109 | 12 | 25498160 | 2 | 1 | 40159909.03 |
| DETROIT PUBLIC SCHOOLS COMMUNITY DISTRICT | 137568.47 | 7 | 2 | 40020000 | 4 | 2 | 40157568.47 |
| BRABENDERCOX | 28017615.80000001 | 653 | 40 | 10308671 | 1 | 1 | 38326286.80000001 |
| CONSERVATIVE PARTNERSHIP INSTITUTE | 997918.19 | 336 | 51 | 35663238 | 116 | 27 | 36661156.19 |
| OLYMPIC MEDIA | 19545756.639999997 | 6069 | 139 | 13251807 | 13 | 3 | 32797563.639999997 |
| HSP DIRECT LLC | 25014806.59 | 3873 | 146 | 3574872 | 5 | 2 | 28589678.59 |
| JONES DAY | 22710790.69999999 | 968 | 82 | 4236190 | 5 | 3 | 26946980.69999999 |
| RST MARKETING | 26715572.789999995 | 1313 | 111 | 161418 | 1 | 1 | 26876990.789999995 |
| FABRIZIO, LEE & ASSOCIATES, LLC | 26443906.549999997 | 233 | 34 | 274580 | 1 | 1 | 26718486.549999997 |
| TMA DIRECT | 25679397.260000005 | 6760 | 186 | 640871 | 3 | 1 | 26320268.260000005 |
| HOWARD UNIVERSITY | 141814.98 | 24 | 21 | 25417815 | 45 | 7 | 25559629.98 |
| THE PROSPER GROUP | 22616868.040000007 | 3203 | 167 | 2293000 | 3 | 1 | 24909868.040000007 |
Source: public filings · retrieved May 30, 2026
How these rows were pulled
SELECT payee_name, fec_total_amount, fec_transaction_count, fec_distinct_committees_paying, n990_total_amount, n990_transaction_count, n990_distinct_orgs_paying, total_combined_revenue FROM politics_vault.payee_intersection_analysis WHERE fec_total_amount > 100000 AND n990_total_amount > 100000 ORDER BY total_combined_revenue DESC LIMIT 30
Retrieved May 30, 2026
Data
Records from FEC filings
Show the table (12 rows)
| Committee | Total | Txns |
|---|---|---|
| JD VANCE FOR SENATE INC. | 8156891 | 16 |
| BOGNET FOR CONGRESS | 2038616 | 25 |
| TOM BARRETT FOR CONGRESS | 1277340 | 19 |
| MARC FOR US INC. | 975171 | 12 |
| NRCC | 682419 | 6 |
| ESSHAKI FOR CONGRESS | 477518 | 12 |
| COMMITTEE TO ELECT CHRISTIAN CASTELLI/CASTELLI FOR CONGRESS | 305000 | 6 |
| BROG FOR NEVADA | 219057 | 8 |
| LISA MCCLAIN FOR CONGRESS | 200000 | 1 |
| COLEMAN FOR CONGRESS | 159150 | 1 |
| ALAN SIMS FOR CONGRESS | 116508 | 2 |
| J.R. MAJEWSKI FOR CONGRESS | 54084 | 1 |
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT cm.cmte_nm AS committee, round(sum(e.transaction_amt)) AS total, count() txns FROM politics_vault.fec_operating_expenditures_2019_2026 e LEFT JOIN politics_vault.fec_committee_master_2019_2026 cm ON e.cmte_id=cm.cmte_id WHERE e.resolved_canonical_vendor='PG PLACEMENTS' GROUP BY committee ORDER BY total DESC
Retrieved Oct 26, 2026
Data
Records from FEC filings
- Party
- REP
- Committees
- 12
- Total
- 14661754
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT cm.cmte_pty_affiliation AS party, count(DISTINCT e.cmte_id) AS committees, round(sum(e.transaction_amt)) AS total FROM politics_vault.fec_operating_expenditures_2019_2026 e LEFT JOIN politics_vault.fec_committee_master_2019_2026 cm ON e.cmte_id=cm.cmte_id WHERE e.resolved_canonical_vendor='PG PLACEMENTS' GROUP BY party ORDER BY committees DESC
Retrieved Oct 26, 2026
Data
Records from FEC filings
Show the table (3 rows)
| Party | Committees | Total |
|---|---|---|
| REP | 142 | 22602303 |
| · | 26 | 1180532 |
| OTH | 1 | 4000 |
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT cm.cmte_pty_affiliation AS party, count(DISTINCT e.cmte_id) AS committees, round(sum(e.transaction_amt)) AS total FROM politics_vault.fec_operating_expenditures_2019_2026 e LEFT JOIN politics_vault.fec_committee_master_2019_2026 cm ON e.cmte_id=cm.cmte_id WHERE e.resolved_canonical_vendor='THE PROSPER GROUP' GROUP BY party ORDER BY committees DESC
Retrieved Oct 26, 2026
Data
Records from FEC filings
Show the table (3 rows)
| Cmte nm | Tres nm | Vendor | Payments | Total |
|---|---|---|---|---|
| JOHNSON LEADERSHIP FUND | LISKER, LISA | COMPASS PROFESSIONAL INC. | 30 | 408747.4199999999 |
| SENATE CONSERVATIVES FUND | KILGORE, PAUL | COMPASS CAGING LLC | 16 | 28458.27 |
| TIM SHEEHY FOR MONTANA | WENETTA, KATIE | COMPASS CAGING, LLC | 2 | 8236.75 |
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT c.cmte_nm, c.tres_nm, upper(d.name) AS vendor, count() AS payments, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total FROM politics_vault.fec_operating_expenditures_2019_2026 d JOIN politics_vault.fec_committee_master_2019_2026 c ON c.cmte_id = d.cmte_id WHERE (upper(d.name) LIKE '%COMPASS PROFESSIONAL%' OR upper(d.name) LIKE '%COMPASS CAGING%') AND (upper(d.purpose) LIKE '%CAGING%') GROUP BY 1,2,3 ORDER BY total DESC
Retrieved Oct 26, 2026
Data
Records from FEC filings
The 15 largest of 23 rows by Total. The table has every row.
Show the table (23 rows)
| Stated purpose | Count | Total |
|---|---|---|
| LEGAL CONSULTING | 118 | 465810.58999999997 |
| CAGING | 30 | 408747.4199999999 |
| LEGAL | 106 | 197196 |
| LEGAL CONSULTING & TRAVEL EXPENSES | 4 | 96152.40000000001 |
| COMPLIANCE CONSULTING | 47 | 50537.81 |
| PAC CAGING SERVICES | 16 | 28458.27 |
| LEGAL SERVICES | 13 | 20107.5 |
| LEGAL CONSULTING / REGISTRATION FEES | 1 | 19396.2 |
| POLITICAL LAW RETAINER | 7 | 13500 |
| LEGAL FEES | 2 | 10688.75 |
| CAGING SERVICES | 2 | 8236.75 |
| PAC LEGAL CONSULTING | 2 | 6467.5 |
| POLITICAL LAW COMPLIANCE | 2 | 5000 |
| LODGING | 1 | 3000 |
| LEGAL FEES/ LEGAL SERVICES | 1 | 2162.5 |
| DEPOSIT | 1 | 1500 |
| COMNPLIANCE CONSULTING | 1 | 875 |
| FEC COMPLIANCE SERVICES | 1 | 875 |
| PAC LEGAL SERVICES | 2 | 850 |
| COMPLIANCE SERVICES | 3 | 835.16 |
| PAC LEGAL FEES | 2 | 743.75 |
| AMEX PMT [SB17.44008] LEGAL CONSULTING | 1 | 500 |
| ACCOUNTING SERVICES | 1 | 324.78 |
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT upper(d.purpose) AS purpose, count() AS n, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total FROM politics_vault.fec_operating_expenditures_2019_2026 d WHERE (upper(d.name) LIKE '%COMPASS PROFESSIONAL%' OR upper(d.name) LIKE '%COMPASS LEGAL%' OR upper(d.name) LIKE '%COMPASS PROPERTY%' OR upper(d.name) LIKE '%COMPASS CAGING%') GROUP BY 1 ORDER BY total DESC LIMIT 25
Retrieved Oct 26, 2026
Data
Records from FEC filings
The 15 largest of 24 rows by Total. The table has every row.
Show the table (24 rows)
| Tres nm | Committees | Payments | Total |
|---|---|---|---|
| CRATE, BRADLEY T. | 2 | 28 | 415565.93999999994 |
| LISKER, LISA | 1 | 30 | 408747.42 |
| BOLES, JASON D | 11 | 115 | 222853.5 |
| DATWYLER, THOMAS | 19 | 95 | 138016.41 |
| KILGORE, PAUL | 2 | 18 | 34925.77 |
| PLISHKA, JOHN | 1 | 3 | 33056.2 |
| MAJEWSKI, JR | 3 | 19 | 25722.21 |
| RUTLAND, JANNA | 1 | 2 | 10688.75 |
| CRATE, BRADLEY T. MR. | 2 | 8 | 9364 |
| WENETTA, KATIE | 1 | 2 | 8236.75 |
| TARNOWSKI, SEAN | 2 | 6 | 4849.78 |
| CORRIGAN, PATRICK | 4 | 11 | 4522.400000000001 |
| O'SHEA, JOHN | 1 | 5 | 4250 |
| SIFERT, TIM | 1 | 6 | 3210 |
| NAGEL, RICK | 1 | 2 | 3000 |
| GIARRAPUTO, HOLLY | 1 | 1 | 3000 |
| SLATER, JEN | 1 | 2 | 2537.5 |
| WOJCIECHOWSKI, MARIA | 1 | 2 | 2525 |
| KIGER, ROBERT SCOTT | 1 | 1 | 2162.5 |
| GOBLE, JONATHAN | 1 | 1 | 1500 |
| THOMAS, DATWYLER, | 1 | 1 | 1000 |
| MCMICHAEL, COLLIN | 1 | 2 | 850 |
| BROWN, MEGAN | 1 | 2 | 743.75 |
| WOODFIN, CHRISTOPHER MONTGOMERY MR. | 1 | 2 | 637.5 |
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT c.tres_nm, count(DISTINCT c.cmte_id) AS committees, count() AS payments, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total FROM politics_vault.fec_operating_expenditures_2019_2026 d JOIN politics_vault.fec_committee_master_2019_2026 c ON c.cmte_id = d.cmte_id WHERE (upper(d.name) LIKE '%COMPASS PROFESSIONAL%' OR upper(d.name) LIKE '%COMPASS LEGAL%' OR upper(d.name) LIKE '%COMPASS PROPERTY%' OR upper(d.name) LIKE '%COMPASS CAGING%') GROUP BY 1 ORDER BY total DESC
Retrieved Oct 26, 2026
Data
Records from FEC filings
Show the table (40 rows)
| Cmte nm | C.cmte id | Tres nm | Payments | Total |
|---|---|---|---|---|
| JOHNSON LEADERSHIP FUND | C00771246 | LISKER, LISA | 30 | 408747.42000000004 |
| NEVER SURRENDER, INC. | C00828541 | CRATE, BRADLEY T. | 19 | 275298.74 |
| SAVE AMERICA | C00762591 | CRATE, BRADLEY T. | 9 | 140267.2 |
| PUTTING PEOPLE BEFORE POLITICIANS INC | C00708289 | BOLES, JASON D | 31 | 66606.25 |
| SAVE AMERICA STOP SOCIALISM PAC | C00755199 | BOLES, JASON D | 26 | 54425 |
| MARY MILLER FOR CONGRESS | C00723916 | BOLES, JASON D | 21 | 52789.5 |
| CONSTANTINO FOR CONGRESS, INC. | C00892737 | PLISHKA, JOHN | 3 | 33056.2 |
| JOHN GIBBS FOR CONGRESS, INC. | C00793166 | BOLES, JASON D | 12 | 30440 |
| SENATE CONSERVATIVES FUND | C00448696 | KILGORE, PAUL | 16 | 28458.27 |
| ANDY OGLES FOR CONGRESS | C00811844 | DATWYLER, THOMAS | 11 | 27952.55 |
| FRIENDS OF MIKE LEE INC | C00473827 | DATWYLER, THOMAS | 21 | 19512.5 |
| J.R. MAJEWSKI FOR CONGRESS | C00770636 | MAJEWSKI, JR | 12 | 19412.05 |
| BRIDGE PAC | C00790915 | DATWYLER, THOMAS | 11 | 15143.36 |
| SKOL PAC | C00732925 | DATWYLER, THOMAS | 9 | 12125 |
| STICKER PAC | C00887703 | RUTLAND, JANNA | 2 | 10688.75 |
| LALOTA FOR CONGRESS | C00806018 | DATWYLER, THOMAS | 4 | 10518.75 |
| WOMEN FOR AMERICA'S FREEDOM | C00832626 | DATWYLER, THOMAS | 5 | 9418.75 |
| TIM SHEEHY FOR MONTANA | C00844159 | WENETTA, KATIE | 2 | 8236.75 |
| MARJORIE TAYLOR GREENE'S PEOPLE OVER POLITICIANS COMMITTEE | C00766774 | BOLES, JASON D | 8 | 8225 |
| DESPOSITO FOR NEW YORK | C00809426 | DATWYLER, THOMAS | 5 | 8075 |
| SARAH FOR ALASKA | C00811323 | CRATE, BRADLEY T. MR. | 7 | 6800 |
| TEA PARTY PATRIOTS CITIZENS FUND | C00540898 | KILGORE, PAUL | 2 | 6467.5 |
| RESTORE OUR FREEDOM PAC | C00789552 | DATWYLER, THOMAS | 3 | 6024 |
| RIGHT WOMEN PAC | C00718841 | DATWYLER, THOMAS | 8 | 5950 |
| J.R. MAJEWSKI VICTORY FUND | C00818237 | MAJEWSKI, JR | 6 | 5560.2 |
Show 15 more rows
| Cmte nm | C.cmte id | Tres nm | Payments | Total |
|---|---|---|---|---|
| STOP SOCIALISM NOW PAC | C00755629 | BOLES, JASON D | 2 | 5000 |
| NEHLS FOR CONGRESS | C00730150 | DATWYLER, THOMAS | 3 | 4393.75 |
| JOHN O'SHEA FOR CONGRESS | C00836718 | O'SHEA, JOHN | 5 | 4250 |
| TOMMY FOR VIRGINIA | C00780544 | DATWYLER, THOMAS | 3 | 4037.5 |
| TRES WITTUM FOR TENNESSEE | C00811943 | TARNOWSKI, SEAN | 4 | 3650 |
| OUR FREEDOM, OUR FUTURE | C00693713 | DATWYLER, THOMAS | 2 | 3293.75 |
| JERONE DAVISON FOR CONGRESS | C00788356 | SIFERT, TIM | 6 | 3210 |
| ALASKANS FOR MARY | C00933978 | GIARRAPUTO, HOLLY | 1 | 3000 |
| COLE FOR CONGRESS | C00379735 | NAGEL, RICK | 2 | 3000 |
| CONSTITUTIONAL CONSERVATIVES FUND | C00833566 | DATWYLER, THOMAS | 1 | 2870 |
| SARAH PAC | C00845305 | CRATE, BRADLEY T. MR. | 1 | 2564 |
| FRIENDS OF HEIDI ST. JOHN | C00770008 | SLATER, JEN | 2 | 2537.5 |
| BUCKEYE FREEDOM FUND | C00796177 | WOJCIECHOWSKI, MARIA | 2 | 2525 |
| ARIZONA FIRST PAC INC. | C00846766 | DATWYLER, THOMAS | 1 | 2399 |
| SCOTT PRUITT FOR SENATE | C00813774 | DATWYLER, THOMAS | 1 | 2250 |
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT c.cmte_nm, c.cmte_id, c.tres_nm, count() AS payments, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total FROM politics_vault.fec_operating_expenditures_2019_2026 d JOIN politics_vault.fec_committee_master_2019_2026 c ON c.cmte_id = d.cmte_id WHERE (upper(d.name) LIKE '%COMPASS PROFESSIONAL%' OR upper(d.name) LIKE '%COMPASS LEGAL%' OR upper(d.name) LIKE '%COMPASS PROPERTY%' OR upper(d.name) LIKE '%COMPASS CAGING%') GROUP BY 1,2,3 ORDER BY total DESC LIMIT 40
Retrieved Oct 26, 2026
Data
Records from FEC filings
Show the table (15 rows)
| Vendor | Payments | Total | Transaction dt, earliest | Transaction dt, latest | Distinct payers |
|---|---|---|---|---|---|
| COMPASS LEGAL GROUP | 97 | 436235.24 | 2022-05-02 | 2025-11-04 | 24 |
| COMPASS PROFESSIONAL INC. | 42 | 428159.47 | 2022-03-22 | 2026-08-12 | 2 |
| COMPASS LEGAL SERVICES, INC. | 40 | 185630.35 | 2021-10-01 | 2024-08-07 | 10 |
| COMPASS LEGAL SERVICES INC. | 69 | 143184.85 | 2021-10-01 | 2023-09-08 | 8 |
| COMPASS LEGAL SERVICES | 35 | 51328.5 | 2021-10-05 | 2025-01-20 | 3 |
| COMPASS CAGING LLC | 16 | 28458.27 | 2024-09-13 | 2026-08-04 | 1 |
| COMPASS PROFESSIONAL, INC. | 29 | 22403.86 | 2022-05-10 | 2022-10-28 | 8 |
| COMPASS PROFESSIONAL | 10 | 13396.68 | 2022-08-08 | 2023-09-28 | 2 |
| COMPASS LEGAL SERVICES, INC | 8 | 9050 | 2022-05-04 | 2023-01-30 | 2 |
| COMPASS CAGING, LLC | 2 | 8236.75 | 2024-10-10 | 2024-10-25 | 1 |
| COMPASS PROFESSIONAL INC | 7 | 6310.16 | 2022-09-20 | 2023-02-14 | 2 |
| COMPASS PROPERTY MANAGEMENT | 1 | 3000 | 2026-04-17 | 2026-04-17 | 1 |
| COMPASS LEGAL SERVICES INC | 2 | 2537.5 | 2021-12-02 | 2022-05-02 | 1 |
| COMPASS LEGAL | 5 | 2533.75 | 2022-06-02 | 2024-11-05 | 3 |
| COMPASS PROPERTY GROUP LLC | 1 | 1500 | 2022-07-22 | 2022-07-22 | 1 |
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT upper(d.name) AS vendor, count() AS payments, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total, min(d.transaction_dt), max(d.transaction_dt), uniq(d.cmte_id) AS distinct_payers FROM politics_vault.fec_operating_expenditures_2019_2026 d WHERE upper(d.name) LIKE '%COMPASS PROFESSIONAL%' OR upper(d.name) LIKE '%COMPASS LEGAL%' OR upper(d.name) LIKE '%COMPASS PROPERTY%' OR upper(d.name) LIKE '%COMPASS CAGING%' GROUP BY vendor ORDER BY total DESC
Retrieved Oct 26, 2026
Data
Records from FEC filings
Show the table (13 rows)
| Cmte nm | C.cmte id | Cmte pty affiliation | Cmte tp | Tres nm | Payments | Total | Transaction dt, earliest | Transaction dt, latest |
|---|---|---|---|---|---|---|---|---|
| JOHNSON LEADERSHIP FUND | C00771246 | · | N | LISKER, LISA | 30 | 408747.4199999999 | 2024-02-14 | 2026-08-12 |
| J.R. MAJEWSKI FOR CONGRESS | C00770636 | REP | H | MAJEWSKI, JR | 12 | 19412.05 | 2022-03-22 | 2023-02-14 |
| BRIDGE PAC | C00790915 | REP | N | DATWYLER, THOMAS | 11 | 15143.36 | 2022-06-15 | 2022-09-29 |
| DESPOSITO FOR NEW YORK | C00809426 | REP | H | DATWYLER, THOMAS | 5 | 8075 | 2023-06-06 | 2023-09-28 |
| J.R. MAJEWSKI VICTORY FUND | C00818237 | · | N | MAJEWSKI, JR | 6 | 5560.2 | 2022-09-20 | 2023-02-14 |
| TRES WITTUM FOR TENNESSEE | C00811943 | REP | H | TARNOWSKI, SEAN | 4 | 3650 | 2022-08-08 | 2022-08-31 |
| JERONE DAVISON FOR CONGRESS | C00788356 | REP | H | SIFERT, TIM | 6 | 3210 | 2022-08-08 | 2022-10-28 |
| FRIENDS OF SONIA MORRIS FOR CONGRESS | C00808493 | REP | H | CORRIGAN, PATRICK | 4 | 2045.01 | 2022-06-01 | 2022-09-29 |
| RHONDA PALAZZO FOR CONGRESS 2022 | C00799932 | REP | H | CORRIGAN, PATRICK | 3 | 1250 | 2022-05-13 | 2022-08-26 |
| DAVISSON FOR CONGRESS | C00803023 | REP | H | TARNOWSKI, SEAN | 2 | 1199.78 | 2022-05-10 | 2022-08-08 |
| CECI TRUMAN FOR CONGRESS | C00780668 | REP | H | CORRIGAN, PATRICK | 1 | 802.69 | 2022-08-08 | 2022-08-08 |
| THE AMERICAN TRANSFORMATION PAC | C00815738 | · | N | MAJEWSKI, JR | 1 | 749.96 | 2023-02-14 | 2023-02-14 |
| PAUL BERRY III FOR CONGRESS | C00799254 | REP | H | CORRIGAN, PATRICK | 3 | 424.70000000000005 | 2022-08-08 | 2022-09-02 |
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT c.cmte_nm, c.cmte_id, c.cmte_pty_affiliation, c.cmte_tp, c.tres_nm, count() AS payments, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total, min(d.transaction_dt), max(d.transaction_dt) FROM politics_vault.fec_operating_expenditures_2019_2026 d JOIN politics_vault.fec_committee_master_2019_2026 c ON c.cmte_id = d.cmte_id WHERE upper(d.name) LIKE '%COMPASS PROFESSIONAL%' GROUP BY 1,2,3,4,5 ORDER BY total DESC
Retrieved Oct 26, 2026
Data
Records from FEC filings
- Compliance n
- 7649
- Total n
- 7846
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT countIf(upperUTF8(purpose) LIKE '%COMPLIAN%' OR upperUTF8(purpose) LIKE '%ACCOUNT%') AS compliance_n, count() AS total_n FROM politics_vault.fec_operating_expenditures_2019_2026 WHERE upperUTF8(name) LIKE '9SEVEN CONSULTING%' OR upperUTF8(name) LIKE 'AXCAPITAL%'
Retrieved Oct 26, 2026
Data
Records from FEC filings
- Total exp from dat universe
- 366675984.45
- To captive compliance
- 6918201.169999999
- N cmtes paying captive
- 424
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
WITH dat_cmtes AS (SELECT DISTINCT cmte_id FROM politics_vault.fec_committee_master_2019_2026 WHERE upperUTF8(tres_nm) LIKE '%DATWYLER%') SELECT sum(transaction_amt) AS total_exp_from_dat_universe, sumIf(transaction_amt, upperUTF8(name) LIKE '9SEVEN CONSULTING%' OR upperUTF8(name) LIKE 'AXCAPITAL%') AS to_captive_compliance, count(DISTINCT if(upperUTF8(name) LIKE '9SEVEN CONSULTING%' OR upperUTF8(name) LIKE 'AXCAPITAL%', cmte_id, NULL)) AS n_cmtes_paying_captive FROM politics_vault.fec_operating_expenditures_2019_2026 WHERE cmte_id IN (SELECT cmte_id FROM dat_cmtes)
Retrieved Oct 26, 2026
Data
Records from FEC filings
Show the table (5 rows)
| Zip code | Count | Transaction amt, total |
|---|---|---|
| 50416 | 17 | 11709.28 |
| 53711 | 1 | 535.95 |
| 54016 | 1019 | 919881.9400000002 |
| 540161783 | 4 | 4087.5 |
| 540160183 | 430 | 581664.9199999999 |
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
SELECT zip_code, count(*) AS n, sum(transaction_amt) FROM politics_vault.fec_operating_expenditures_2019_2026 WHERE upperUTF8(name) LIKE '9SEVEN CONSULTING%' AND state='WI' GROUP BY zip_code
Retrieved Oct 26, 2026
Data
Records from FEC filings
The 15 largest of 27 rows by Total. The table has every row.
Show the table (27 rows)
| Upperutf8(purpose) | Count | Total |
|---|---|---|
| COMPLIANCE CONSULTING | 2514 | 3167100.0099999993 |
| LEGAL FEES | 3 | 19184.05 |
| CAMPAIGN CONSULTING | 10 | 14536.15 |
| COMPLIANCE CONSUTLING | 7 | 14263.41 |
| ACCOUNTING CONSULTING | 11 | 11861.279999999999 |
| WEBSITE | 1 | 4570 |
| COMPLIANC CONSULTING | 5 | 2409.75 |
| COMPLAINCE CONSULTING | 4 | 1832.95 |
| COMPLIANCE CONSULTIGN | 2 | 1750 |
| COMPLIANCE CONUSULTING | 2 | 1400 |
| CAMPAIGN COMPLIANCE | 3 | 1350 |
| CAMPAING CONSULTING | 1 | 1289.95 |
| COMPLIANCE CONSLTING | 2 | 1225 |
| COMPLINACE CONSULTING | 3 | 1000 |
| ACCOUNTING AND REPORTING | 1 | 850 |
| COMPLIANCE CONUSLTING | 1 | 800 |
| COMPLIANE CONSULTING | 1 | 800 |
| CONSULTING - COMPLIANCE CONSULTING | 1 | 631.25 |
| COMPLIANCE / ACCOUNTING | 1 | 589.95 |
| POLITICAL CONSULTING | 1 | 450 |
| POSTAGE | 2 | 381.9 |
| COMPLINANCE CONSULTING | 1 | 350 |
| COMPLIANCE CONSUTING | 1 | 300 |
| CAMPAIGN CONSUTLING | 1 | 300 |
| COMPLIAN CONSULTING | 1 | 150 |
| BANK FEES | 2 | 28.14 |
| COMPLIANCE CONSULING | 1 | 7.15 |
Source: FEC filings · retrieved Oct 26, 2026
How these rows were pulled
WITH dat_cmtes AS (SELECT DISTINCT cmte_id FROM politics_vault.fec_committee_master_2019_2026 WHERE upperUTF8(tres_nm) LIKE '%DATWYLER%') SELECT upperUTF8(purpose), count(*) AS n, sum(transaction_amt) AS total FROM politics_vault.fec_operating_expenditures_2019_2026 WHERE upperUTF8(name) LIKE '9SEVEN CONSULTING%' AND cmte_id IN (SELECT cmte_id FROM dat_cmtes) GROUP BY purpose ORDER BY total DESC
Retrieved Oct 26, 2026
Data
Records from IRS Form 990 filings (Schedule I grants), EIN 454678325
The 15 largest of 30 rows by Grant amount. The table has every row.
Show the table (30 rows)
| Tax year | Recipient | Grant amount |
|---|---|---|
| 2024 | TURNING POINT USA | 10389921 |
| 2024 | MILWAUKEE SYMPHONY ORCHESTRA INC | 5000000 |
| 2024 | LEADERSHIP INSTITUTE | 3014050 |
| 2024 | COUNTY CITIZENS DEFENDING FREEDOM USA FOUNDATION INC | 2475000 |
| 2024 | EVERGREEN FREEDOM FOUNDATION | 1924654 |
| 2024 | MOMS FOR AMERICA | 1701000 |
| 2024 | BLACK PASTORS UNITED FOR EDUCATION | 1516399 |
| 2024 | FOUNDATION FOR EXCELLENCE IN HIGHER EDUCATION | 1078847 |
| 2024 | DO NO HARM | 1010000 |
| 2024 | GEORGIA STATE UNIVERSITY RESEARCH FOUNDATION INC | 900000 |
| 2024 | SPEECH FIRST | 700000 |
| 2024 | ALLIANCE DEFENDING FREEDOM | 650000 |
| 2024 | MACKINAC CENTER FOR PUBLIC POLICY | 607000 |
| 2024 | TORCH OF FREEDOM FOUNDATION | 600000 |
| 2024 | PUBLIC INTEREST LEGAL FOUNDATION | 514953 |
| 2024 | ADVANCE COLORADO | 500000 |
| 2024 | PARENTS DEFENDING EDUCATION | 500000 |
| 2024 | CANTINAS ARTS FOUNDATION | 450000 |
| 2024 | FRANKLIN NEWS FOUNDATION | 446700 |
| 2024 | ACTON INSTITUTE FOR THE STUDY OF RELIGION AND LIBERTY | 435000 |
| 2024 | WISCONSIN INSTITUTE FOR LAW & LIBERTY | 405750 |
| 2024 | WALKAWAY FOUNDATION | 357500 |
| 2024 | THREEFOLD EDUCATION ASSOCIATION | 330000 |
| 2024 | THOMAS AQUINAS COLLEGE | 300000 |
| 2024 | CENTRAL FUND OF ISRAEL | 300000 |
| 2024 | YOUNG AMERICA'S FOUNDATION | 294400 |
| 2024 | JACK MILLER CENTER FOR TEACHING AMERICA'S FOUNDING PRINCIPLES AND HISTORY | 259333 |
| 2024 | LIBERTY JUSTICE CENTER | 250000 |
| 2024 | NATIONAL CENTER FOR JUSTICE AND LIBERTY INC | 250000 |
| 2024 | ST AUGUSTINE PREPARATORY ACADEMY | 250000 |
Source: IRS Form 990 filings (Schedule I grants), EIN 454678325 · retrieved Jul 16, 2026
How these rows were pulled
SELECT tax_year, recipient_name, cash_grant_amt FROM politics_vault_archive.ein_990_grants WHERE ein='454678325' AND tax_year IN ('2022','2023','2024') ORDER BY tax_year DESC, cash_grant_amt DESC LIMIT 30Retrieved Jul 16, 2026
Data
Records from IRS Form 990 filings (Schedule I grants), EIN 522166327
The 15 largest of 25 rows by Total. The table has every row.
Show the table (25 rows)
| Recipient | Recipient EIN | Total |
|---|---|---|
| Dechomai Asset Trust | 260724604 | 100650000 |
| Legion of Christ | 060923895 | 25000000 |
| State Policy Network | 570952531 | 10510292 |
| Catholic University of America | 530196583 | 8102500 |
| Consumers' Research Inc | 221500498 | 6511000 |
| Real Clear Foundation | 522128875 | 5807000 |
| Institute for Justice | 521744337 | 5409005 |
| Reason Foundation | 953298239 | 5219585 |
| Federalist Society | 363235550 | 5192200 |
| Texas A&M Foundation | 742245072 | 5000000 |
| GMU Foundation | 541603842 | 4850500 |
| Cato Institute | 237432162 | 4363155 |
| Teneo Network Inc | 832151429 | 4261350 |
| Constitutional Defense Fund | 823203438 | 4050000 |
| With Angels Foundation | 870928457 | 3975000 |
| Lucy Burns Institute | 208036372 | 3905800 |
| ACANI Inc | 262387657 | 3685000 |
| Green Light Project | 464631639 | 3680000 |
| America First Legal Foundation | 862190372 | 3191074 |
| Pacific Legal Foundation | 942197343 | 2934885 |
| Competitive Enterprise Institute | 521351785 | 2708650 |
| Foundation for Government Accountability | 452637507 | 2560100 |
| Discovery Institute | 911521697 | 2505000 |
| Passages America Israel Inc | 812453820 | 2500000 |
| Middle East Forum | 237749796 | 2350000 |
Source: IRS Form 990 filings (Schedule I grants), EIN 522166327 · retrieved Jul 16, 2026
How these rows were pulled
SELECT recipient_name, recipient_ein, SUM(cash_grant_amt) AS total FROM politics_vault_archive.ein_990_grants WHERE ein='522166327' AND tax_year='2024' GROUP BY recipient_name, recipient_ein ORDER BY total DESC LIMIT 25
Retrieved Jul 16, 2026
The record
a verified primary record or stored query backs the row. reported by a secondary source only.
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- ●DHS gave a June 2025 briefing to Cleta Mitchell's Election Integrity Network on the federal citizenship verification database, direct executive-branch coordination with a private voter-suppression organization
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- ●Jack Smith's 'Arctic Frost' investigation issued 197 grand jury subpoenas targeting 430+ named Republican individuals and entities, the Conservative Partnership Institute (CPI) was directly subpoenaed at least 4 separate times as a target
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- ●Mark Meadows stated in special counsel interview that he had 'never seen Jim Jordan scared of anything' regarding Jordan's White House call during the January 6 afternoon
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- ●CPI paid $2.96M in 2024 to its Compass-network of sole-source related-party contractors (Compass Professional, Compass Legal, Compass Property Management), the Cleta-Mitchell/Russ-Vought operational shell described in the existing 'Command Node' targets
- ●Only three FEC committees in the entire 2019-2026 filing universe have ever booked an itemized Schedule B payment to a Compass entity with the explicit purpose label CAGING: Mike Johnson Leadership Fund ($240,756.89, 23 payments), Senate Conservatives Fund ($22,342.23, 11 payments), Tim Sheehy for Montana ($8,236.75, 2 payments); Johnson grew his caging spend 47% YoY (2024 $97,419.89 to 2025 $143,337.00) with the single largest line, $23,162.25, posted 2025-11-04, one day before the 2025 off-year elections
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Sources · 86
- Primary 40
- Derived 29
- Reported 17
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714 committees in the FEC committee master listing Datwyler in the treasurer field. Combined 1,126 rows when name variants are included.
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CPI's 2022 IRS Form 990 with vendor disclosures.
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EIN 82-1470217. Full 990 filings for CPI from 2017 onward.
- [34]
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- [36]
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- [41]Records from FEC filings
- [42]Records from FEC filings
- [43]Records from FEC filings
- [44]Records from FEC filings
- [45]Records from FEC filings
- [46]Records from FEC filings
- [47]Records from FEC filings
- [48]Records from FEC filings
- [49]Records from FEC filings
- [50]Records from FEC filings
- [51]Records from FEC filings
- [52]Records from FEC filings
- [53]Records from FEC filings
- [54]Records from FEC filings
- [55]Records from FEC filings
- [56]Records from FEC filings
- [57]Records from FEC filings, FEC C00771246
- [58]Records from FEC filings, FEC C00867937
- [59]Records from IRS Form 990 filings
- [60]Records from IRS Form 990 filings
- [61]Records from IRS Form 990 filings
- [62]Records from IRS Form 990 filings (Schedule I grants), EIN 454678325
- [63]Records from IRS Form 990 filings (Schedule I grants), EIN 522166327
- [64]Records from IRS Form 990 filings (Schedule I grants), EIN 522166327
- [65]Records from public filings
- [66]Records from public filings
- [67]Records from public filings
- [68]Records from public filings
- [69]Records from public filings
- [70]
- [71]
- [72]
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CPI's own confirmation that Mitchell holds the Senior Legal Fellow role.
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Documents Compass Legal's representation of Valid Vote / EagleAI NETwork.
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Affiliated-organization list and key personnel roster.
- [80]
- [81]
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Identified Compass Professional Inc. as one of three CPI-paid vendors owned or operated by CPI insiders.
- [83]
Mark Meadows compensation analysis from CPI's 2023 990.
- [84]
Reported $2.4M+ in payments from CPI to the three Compass-affiliated vendors in a single year.
- [85]
- [86]
Derived means a stored database query with its result rows and the filing key they trace to. How the facts are checked
Showing this section as of the last site build. It updates to the latest saved edits when the live copy loads.
Research notes · 7
Research notes from the 10Reports archive that the findings were developed from.
10Reportscorroborating24.4 KB · markdownretrieved Mar 13, 2026300 Independence Ave - The Hive
Address-level analysis of the CPI / Compass / AFL / Center for Renewing America co-location at 300 Independence Ave SE.
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The Hive at 300 Independence Avenue
How a single address in Washington, D.C. became the command center of the modern conservative movement, and a remarkably profitable one at that.
There is a building in Washington, D.C. that most Americans have never heard of.
It sits on a quiet stretch of Independence Avenue SE, a few blocks from the Capitol dome, unremarkable from the outside. Just another row of offices in a city full of them. No crowds gather on its steps. No television cameras park outside its doors. The people who work there prefer it that way.
But inside 300 Independence Avenue, the architecture of American politics is being quietly, methodically, and lucratively rebuilt.
This is the story of that building. Of the money that flows through it. Of the people who built it and who profit from it. And of why it may represent something entirely new in American political life, something that existing rules were never quite designed to catch.
The Origin Story: From Think Tank to War Room
To understand what 300 Independence Avenue is, you first have to understand what it replaced.
For decades, the conservative intellectual infrastructure was defined by organizations like the Heritage Foundation, the grand old temple of right-wing policy. Heritage published white papers. It hosted symposia. It produced scholars who wrote dense analyses of tax policy and foreign affairs. It was, in the language of the nonprofit world, a think tank.
Jim DeMint understands the Heritage model better than almost anyone. He ran it. From 2013 to 2018, the former Senator from South Carolina drew a salary there that totaled, over those six years, approximately $5.4 million. He was well-compensated for his role as the standard-bearer of a certain kind of conservatism, the kind that lived in policy papers and C-SPAN panels.
And then he had a different idea.
DeMint left Heritage and, in 2017, founded the Conservative Partnership Institute, a 501(c)(3) nonprofit, technically a charity, housed at 300 Independence Avenue SE. From the outside, it looked like just another think tank. From the inside, it was something else entirely: a machine.
Where Heritage made arguments, CPI would make operatives. Where Heritage published ideas, CPI would build infrastructure. The think tank model was, in DeMint's apparent view, a relic, a passive posture in an era that demanded aggression. CPI would be different. CPI would be a hub. A hive. A place where the work of winning, really, permanently winning, would get done.
Since its founding, DeMint has drawn approximately $2.8 million in compensation from CPI. Combined with his Heritage earnings, his career total from these two nonprofit organizations now stands at roughly $8.2 million. Not bad for a former Senator who now runs what is legally classified as a charity.
The Architecture of a Closed World
To truly appreciate what has been constructed at 300 Independence Avenue, you need to understand the ecosystem. Not just the nonprofit at its center, but the constellation of for-profit companies that orbit it.
They're called the Compass entities, and they are, in their own way, a masterpiece of organizational design.
Picture it this way: CPI, the 501(c)(3) charity, sits at the center. It receives tax-exempt donations from a network of foundations and wealthy individuals. It incubates new organizations and trains political talent. It is the mother ship.
Around it, sharing the same physical address at 300 Independence Avenue, are four for-profit companies: Compass Legal Group Inc., Compass Professional Inc., Compass Direct LLC, and Compass Property Management Inc. These companies provide "services" to CPI, legal work, HR and payroll, fundraising, facilities management. And CPI pays them, generously, for those services.
From 2021 through 2024, CPI paid these four Compass entities a combined total of $6,987,171.
That is not a typo. Nearly seven million dollars, flowing from the nonprofit to the for-profit cluster, over four years.
Now here is where it gets interesting.
The people who own the Compass companies are the same people who run CPI.
Cleta Mitchell, the most powerful lawyer in the modern voter-integrity movement, serves as a Senior Legal Fellow and officer at CPI, drawing a direct salary of $230,680 in 2021. She is also, according to investigative data, the beneficial owner and managing member of Compass Legal Group Inc., which received $1,464,065 in CPI contractor payments from 2021 to 2024.
Russell Vought, the former Office of Management and Budget Director who went on to lead CPI's incubated think tank the Center for Renewing America and architect much of Project 2025, is documented as a beneficial owner of Compass Professional Inc., which captured $2,148,862 from the CPI cluster over the same period.
In other words: the nonprofit pays the companies. The companies are owned by the nonprofit's leadership. The leadership, therefore, collects money twice. Once as salaried employees, and once as the private owners of the vendors being hired.
This arrangement has a legal name in IRS parlance. It is called a dual-income structure, and it sits at the very heart of what Section 4958 of the Internal Revenue Code was designed to prevent. Under that provision, nonprofits are prohibited from allowing their net earnings to "inure," to flow, to the benefit of "disqualified persons," which is the IRS's term for organizational insiders. The potential violation is called an excess benefit transaction, and it can result in substantial personal tax liability for the individuals involved.
The critical question, one that the IRS would need to answer, is whether these payments were made at fair market value: did the Compass companies provide services actually worth millions of dollars, priced as an independent vendor would price them? There is no way to know. Across all of these multi-million dollar transactions, CPI's IRS filings list the service descriptions as "N/A," "Blank," or the single vague phrase "Administrative Services."
Seven million dollars. Zero explanations.
Mark Meadows, and the Business of Keeping People Close
There is a second dimension to this financial architecture that is, in its own way, just as striking: CPI's role as a post-government income vehicle for the most senior figures in Trumpworld.
Mark Meadows was Donald Trump's White House Chief of Staff. He was the man in the room for some of the most consequential events of the Trump administration, and as federal prosecutors later determined, consequential in a criminal sense as well.
After leaving the White House, Meadows did not immediately disappear from political life. He joined CPI as a "Senior Partner." By 2024, his annual compensation had reached $872,000, a 67% increase from his starting salary of $523,000 in 2021. Over roughly three years, his total reported compensation was approximately $1.95 million.
To be clear about what that means: a 501(c)(3) charitable organization, funded by tax-exempt donations, was paying a former White House Chief of Staff nearly $900,000 per year.
CPI's top-heavy compensation structure is not confined to Meadows. The organization's total payroll runs approximately $6.5 million annually. Of that, roughly $4 million, more than 60%, flows to the top ten executives. This is not the compensation structure of a think tank engaged in charitable education. It is the compensation structure of a high-dollar law firm or political consultancy, built using money that, by virtue of the tax-exempt subsidy, belongs in some sense to all of us.
The logic of this structure, laid bare: by keeping political operatives on generous nonprofit salaries, the movement ensures they remain available, motivated, and free from the financial pressures that might push them into private lobbying or, worse, toward ambivalence. CPI is, among other things, a retention mechanism for the conservative movement's most valuable human capital.
The Bradley Problem, and How Conflicts of Interest Become a Feature
Now add one more layer.
Cleta Mitchell is not only a CPI officer and the owner of a company that receives CPI money. She also served, simultaneously, on the board of directors of the Bradley Foundation, one of the most influential conservative grantmaking institutions in America, headquartered in Milwaukee.
The Bradley Foundation gave CPI approximately $150,000 in direct grants in 2022. The associated Bradley Impact Fund added another $712,310 to CPI in that same year. Total Bradley-network funding to CPI in a single year: over $862,000.
Think through the loop: Mitchell sits on the board that approves the grants. The grants go to CPI. CPI pays Mitchell a salary. CPI also pays Compass Legal, which Mitchell owns, nearly $1.5 million in contractor fees. The grants thus help capitalize the very organization that funnels money back to Mitchell both directly and through her private company.
This is what investigators call a "porous membrane." Capital that is supposed to flow from a charitable foundation toward the public good instead circulates within a tight-knit cadre of insiders, enriching the very people who control the flow.
Standard nonprofit governance requires board members to recuse themselves from decisions in which they have a personal financial interest. Whether Mitchell recused herself from Bradley's discussions about CPI grants is not publicly known. What is known is that neither the Bradley Foundation nor CPI has disclosed any such recusal.
The Dark Money Artery: Where the Money Comes From
You might reasonably wonder: who funds all of this?
The answer, to the extent one exists, runs through Donors Trust, one of the most important and least-understood financial instruments in American political life.
Donors Trust is a "donor-advised fund," or DAF. Here is how it works: a wealthy individual donates money to Donors Trust and receives an immediate tax deduction. Donors Trust then distributes that money to various conservative nonprofits at the donor's direction, but because the money has already passed through Donors Trust, the connection between the original donor and the ultimate recipient is legally severed. The original donor's identity is never publicly disclosed. This is sometimes called a dark money conduit, and it is entirely legal.
Between 2020 and 2023, Donors Trust channeled approximately $3.4 million to CPI. The stated purposes of these grants range from "General Operations" ($1,027,500 in 2021) to "Voter Integrity Efforts" ($135,000 in 2023) to the "CPI Academy" ($12,000 in 2023).
But one grant stands out from all the others.
In 2023, Donors Trust issued a $10,000 grant earmarked for one specific purpose: "Cleta Mitchell's Fair Election Fund."
A donor-advised fund is not supposed to benefit specific named individuals. That would undermine the legal premise of DAF independence, the fiction that the original donor has given up control of the money. A grant explicitly earmarked with one person's name suggests that someone, somewhere, directed a specific sum of money to a project controlled by a specific person. Investigators who reviewed the filings called this an "earmarking anomaly" and flagged it as a potential violation of DAF independence rules.
The identity of the donor who directed that $10,000? Legally shielded. Permanently unknown.
Jim DeMint's personal donor network includes names familiar from the broader conservative donor universe: Dick Uihlein of Uline Corporation, the Koch family, Charles Schwab, Erik Prince of Blackwater. These are the people who fund the movement. Whether any of them directed money specifically to CPI through Donors Trust is, by design, impossible to confirm.
The Incubator: Building a Shadow Bureaucracy
Of all the things CPI does, its role as a strategic incubator may be the most consequential and the least understood.
The model works like this: CPI identifies a strategic gap, a policy area where the right needs a dedicated organization, a legal front, a talent pipeline, an opposition research shop. CPI provides startup capital, office space at 300 Independence Avenue, administrative support, and legal infrastructure through Compass Legal. A new organization is born. It is, technically, independent. In practice, it is tethered.
The tether is the "Mandatory Vendor" relationship: newly incubated organizations are steered toward the Compass cluster for their back-office needs. America First Legal, the "lawfare" organization led by Stephen Miller, paid Compass Professional Inc. $117,859 shortly after its founding. Tax-exempt donations made to a new charity, flowing immediately into the private company owned by CPI's leadership. The closed loop closes.
The organizations CPI has incubated or co-created include:
America First Legal (AFL): Stephen Miller's litigation machine, targeting DEI programs, immigration enforcement, and government agencies with a constant barrage of legal challenges. AFL functions, among other things, as a revenue generator for the Compass cluster.
Center for Renewing America (CRA): Russell Vought's policy development shop, which served as one of the primary architects of Project 2025, the 900-page blueprint for a second Trump administration. Vought, remember, also owns a piece of Compass Professional.
American Moment: A talent pipeline organization that recruits and vets young conservatives for positions in a future administration, screening for ideological reliability. The people being trained here are the ones who will staff the government.
Election Integrity Network (EIN): Led by Cleta Mitchell herself, EIN trains activists to challenge voter rolls and election administration at the local level. Its primary tool is a piece of software called EagleAI.
American Accountability Foundation (AAF): An opposition research organization that investigates federal employees and Biden administration nominees. In a notable twist, LittleSis, the investigative relationship-mapping database, lists AAF as a "direct controlling entity" of CPI itself, which would invert the standard nonprofit independence model in a remarkable way.
The constellation of organizations sharing this address, this infrastructure, and this leadership cadre represents something the nonprofit sector has rarely seen: a shadow bureaucratic state, ready to be activated, already staffed with vetted personnel, and tethered to a private financial ecosystem that profits from every expansion.
The EagleAI Loop: When Tax-Exempt Money Becomes Election Infrastructure
Of all the operations running through 300 Independence Avenue, the one with the most direct implications for American democracy is probably the least reported on.
EagleAI is a software tool designed for mass voter roll challenges. Using publicly available data, property records, address databases, motor vehicle records, it generates lists of voters whose registrations it flags as potentially invalid: people who may have moved, who may be deceased, who may appear to be registered at addresses they no longer use. Those lists are then used to submit mass challenges to local election boards, demanding that the flagged voters be removed from the rolls.
The Georgia Elections Director has publicly condemned EagleAI, stating that it draws "inaccurate conclusions" and provides "zero value" to official election maintenance. State officials in multiple states have described being inundated with thousands of challenges generated by the software, overwhelming local boards with work to verify or reject each one.
Now trace the money...
CPI pays Compass Legal, Mitchell's firm, millions in contractor fees. Compass Legal provides legal structuring for Valid Vote, a 501(c)(3) established to support EagleAI's development and promotion. The Election Integrity Network, led by Mitchell and incubated by CPI, trains activists across the country to use EagleAI to generate challenges. The original funding, filtered through Donors Trust, including that $10,000 earmarked specifically for "Cleta Mitchell's Fair Election Fund," pays for all of it.
The loop: anonymous donor, Donors Trust, CPI revenue, Compass Legal (Mitchell-owned), Valid Vote/EagleAI, voter challenges in counties across America.
At each step, the money is legal. At each step, the source is obscured. And at the end of the loop, what has been built using tax-exempt infrastructure, private for-profit companies, and dark money conduits is a privately controlled apparatus for contesting American elections.
CPI's simultaneous campaign to dismantle ERIC, the Electronic Registration Information Center, the bipartisan system that had been the gold standard for interstate voter roll maintenance, fits the same strategic frame. Destroy the legitimate system. Replace it with your own. Control the data. Control the challenges. Control, ultimately, who gets to vote.
The $846,000 Question Nobody Has Answered
In 2023, CPI paid $846,525 to a Washington law firm called Zuckerman Spaeder LLP.
Zuckerman Spaeder does not specialize in general corporate law or real estate. It specializes in white-collar criminal defense.
CPI's 990 filing lists no description for what this nearly $850,000 in legal fees was for. No explanation. No context.
This single data point, the largest non-Compass contractor payment in any year reviewed, raises a question that the public filing system was designed to make answerable and that CPI has chosen to leave unanswered: What, exactly, did CPI need nearly a million dollars in white-collar criminal defense for in 2023?
It is worth noting that 2023 came after the January 6th investigations, after the Georgia election prosecution, after Cleta Mitchell's departure from Foley & Lardner following her participation in the now-infamous January 2, 2021 phone call in which Trump pressured Georgia officials to "find" him votes. CPI also paid Foley & Lardner $102,975 in 2021, Mitchell's former firm, in the immediate aftermath of her forced resignation.
The answers may exist in sealed court filings or confidential attorney-client communications. The public will likely never know.
The Invisible Giant: Envision Marketing
Here is a number that did not appear in most previous analyses of CPI's finances, because it was buried in the raw IRS data and required a canonical map audit to surface:
From 2019 to 2024, CPI paid a company called Envision Marketing a total of $3,861,502.
In 2024 alone, Envision received $1,536,248 from CPI, more than any single Compass entity payment in that year.
Envision Marketing is an outside firm, not co-located at 300 Independence Avenue, not part of the Compass cluster. Its role appears to be direct mail and printing, the physical infrastructure of fundraising appeals. Its service descriptions in CPI's filings? Blank. N/A.
Nearly four million dollars, over five years, to an outside marketing firm with no disclosed purpose.
The Compass cluster is not the whole story. There is an outer ring, an "external layer of the closed-loop economy," as one analyst put it, and Envision Marketing is its most significant known node. Who owns Envision Marketing? What is its relationship to CPI's leadership? Why did its payments surge from $361,552 in 2021 to $1,536,248 in 2024?
These questions remain unanswered.
The Council in the Shadows
One more thread, easily overlooked, that ties the 300 Independence Avenue network to the broader architecture of the American right.
Jim DeMint served as a director of the Council for National Policy from 2016 to 2021, a fact now confirmed not just by relationship databases but by six consecutive years of IRS 990 filings. Cleta Mitchell sits on the CNP's Board of Governors.
The Council for National Policy is not a household name, but among people who study conservative infrastructure, it is understood as the most important organization most Americans have never heard of: a secretive coordinating body that brings together major conservative donors, political operatives, religious leaders, and movement strategists for invitation-only meetings.
LittleSis describes it as a "secretive right-wing umbrella group for the U.S. Christian autocracy movement." Its membership has included people like Oliver North, Jerry Falwell, and a rotating cast of Republican political operatives and megadonors.
DeMint's and Mitchell's positions within CNP place them at the intersection of the funding network and the operational network, exactly the kind of coordination point that allows anonymous donor money to be translated into specific political programs at organizations like CPI.
DeMint's personal donor network, the people who funded his Senate campaigns and who now presumably support his nonprofit work, includes Dick Uihlein, David Koch, Charles Schwab, and Erik Prince. These are not small donors. They are the architects of a donor infrastructure that has reshaped American politics over decades.
Whether any of them directed money to CPI through Donors Trust is, by design, something we will never be able to prove. That is, in fact, the point.
What This Is
The Conservative Partnership Institute is not a think tank. It is not a school. It is not, in any meaningful sense, a charity.
It is a centralized capitalization vehicle for a political movement, one that uses the legal machinery of 501(c)(3) status to subsidize elite personnel, incubate organizations, develop election-related technology, build a talent pipeline for a future government, and generate private revenue for the insiders who run it.
The genius of the structure, and it is, in a perverse way, genuinely ingenious, is that it operates entirely within the boundaries of existing law, or close enough to those boundaries that enforcement remains uncertain. Each individual element has a legitimate explanation. The nonprofit pays vendors for services. The vendors happen to be owned by the nonprofit's officers. The officers receive competitive compensation. The donors prefer anonymity. Every step is defensible in isolation.
But zoom out and the picture is different. A tax-exempt organization, subsidized by the American public through the charitable deduction, has been engineered to ensure that its tax-exempt revenue flows, at multiple points, into the private wealth of its architects. The people at the top collect salaries from the nonprofit, revenue from the vendors they own, and strategic advantages from the organizations they incubate.
The public subsidizes all of it. The public can audit almost none of it.
What the IRS has enforcement tools to address, the Section 4958 excess benefit provisions, the private inurement prohibitions, requires the IRS to actually investigate. The agency is chronically underfunded, perpetually backlogged, and institutionally reluctant to target political organizations for fear of accusations of political bias. The filing requirement that is supposed to provide transparency, the Form 990, is only as useful as the disclosures it contains. "N/A" is a legal disclosure.
The people who built this structure understand all of that. They built it accordingly.
A Final Question Worth Sitting With
In 2023, somewhere in America, a wealthy person whose name we will never know donated money to Donors Trust. They directed some of that money, $10,000 of it, to be granted with a specific earmark: "Cleta Mitchell's Fair Election Fund."
That money, tax-deductibly donated by an anonymous benefactor, flowed through a donor-advised fund, into a nonprofit, and was directed by name to a specific person's specific project, a project designed, ultimately, to challenge the validity of other Americans' voter registrations.
This is not illegal. This is, in fact, a feature, a feature of a system designed to allow exactly this kind of anonymous, directed, politically purposeful capital deployment.
The building at 300 Independence Avenue SE is not the only place where this kind of work is done. But it may be the place where it has been done with the most sophistication, the most coordination, and the most careful attention to the distance between what is technically legal and what is actually right.
That distance, it turns out, is quite profitable.
All figures cited in this piece are drawn from IRS Form 990 filings (2019-2024), FEC expenditure data, LittleSis relationship network data, and cross-referenced canonical entity mapping. All financial figures are from primary source documents. Nothing in this piece is speculation; where questions are raised, they are explicitly identified as questions.
10Reportscorroborating2.9 KB · markdownretrieved Mar 14, 2026Compass Professionals - Caging - Mike Johnson
Working note on the three Compass-entity FEC payments tagged with the explicit purpose label 'CAGING'.
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300 Independence Ave SE is the "Patriot’s Row" hub, the nerve center for the Conservative Partnership Institute (CPI) and its massive constellation of entities.
While Lisa Lisker (the treasurer for the Mike Johnson Leadership Fund) often operates out of Alexandria, the Compass entities you are tracking are baked directly into the CPI infrastructure at that Independence Avenue address.
The Connection at 300 Independence Ave SE
This address isn't just an office building; it’s a vertically integrated political machine. Here is how the entities you mentioned stack up at that exact location:
- Compass Professional Inc. & Compass Legal Group: IRS filings (Schedule R) explicitly list both as "shared services" entities for CPI and America First Legal. They are for-profit arms designed to handle the "plumbing"—caging, accounting, and legal compliance—for the movement.
- The Election Integrity Network (EIN): Run by Cleta Mitchell, this is the project housed within CPI at this same address. Its primary goal is "mapping" the voter rolls and training citizens to challenge registrations.
- Mike Johnson Leadership Fund: By using Compass Professional for caging, the Speaker’s fund is essentially piping its donor data through the same physical and digital infrastructure that houses the EIN.
Why the "Returned Mailer" Theory Gains Weight Here
When you look at the $23,162 spike in November 2025 at this specific address, the "voter caging" theory becomes more than plausible—it looks like a built-in feature of the building’s ecosystem:
- The Intake: Compass Professional (at 300 Independence) receives the returned "undeliverable" mail from Mike Johnson’s massive national fundraising pushes.
- The Data Scrub: They record who moved or died to keep the Speaker's FEC filings clean.
- The "Integrity" Hand-off: Because Cleta Mitchell’s EIN is in the same building (and she is a beneficial owner of the legal arm), that "undeliverable" data is just a few desks away from the people building EagleAI or other voter-challenge databases.
- The Weaponization: A returned fundraising letter is a "verified" data point. If a donor's mail is returned to 300 Independence Ave, that address can be flagged in the EIN system as a "potential illegal registration" for a local activist to challenge.
The "One-Stop Shop" Strategy
By centralizing the Speaker’s money (caging) and the movement’s legal strategy (Mitchell) at 300 Independence, they’ve created a loop:
- Fundraising provides the names.
- Caging identifies who has moved.
- Election Integrity Network uses those "moves" to purge the rolls.
The high fees you are tracking are the cost of running that massive data-sorting machine. It’s not just "accounting"; it’s the administrative cost of identifying thousands of voters who can potentially be challenged before the next election.
10Reportscorroborating16 KB · markdownretrieved Mar 13, 2026CPI / Compass FEC Expenditures Registry
Ledger of itemized FEC Schedule B payments to the Compass entity cluster from 2019 onward, with committee identifiers.
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CONFIDENTIAL — INVESTIGATIVE RESEARCH REGISTRY
FEC Expenditures Paid TO: Conservative Partnership Institute / Center / Campus & Compass Professional Inc. | 2019 – March 2026
Data Source: FEC EFILE via politics_vault_standardized.fec_expenditures_2019_March2026_p | Deduplication: Original (N) and terminal (T) filings only; amendments (A) excluded to prevent double-counting | Generated: March 13, 2026
I. MASTER SUMMARY: FEC REVENUE TO CPI & COMPASS ECOSYSTEMS
The following table reflects all FEC-regulated payments flowing TO Conservative Partnership Institute/Center/Campus entities and Compass Professional Inc. from federal political committees, January 2019 through March 2026. Figures are deduplicated (N and T filings only).
| Entity Group | Total Paid (FEC) | # Committees | # Transactions | Date Range |
|---|---|---|---|---|
| Conservative Partnership Institute / Center / Campus (all variants) | $922,016.64 | 56 | 305 | Jan 2019 – Oct 2025 |
| Compass Professional Inc. (all variants) | $268,307.96 | 11 | 55 | May 2022 – Dec 2025 |
| COMBINED TOTAL | $1,190,324.60 | 67 (distinct) | 360 | Jan 2019 – Dec 2025 |
KEY FINDING: 56 distinct FEC-regulated committees — spanning House, Senate, and PAC committees — paid $922,016.64 to Conservative Partnership entities over 7 years. This represents political finance infrastructure revenue from the most powerful MAGA political machine in Congress. An additional $268,307.96 flowed to Compass Professional Inc. — the operations/caging vendor directly tied to CPI — from 11 committees, bringing combined confirmed FEC revenue for the CPI/Compass ecosystem to $1,190,324.60.
II. CPI / CONSERVATIVE PARTNERSHIP CENTER / CAMPUS — FULL CLIENT REGISTRY
Every federal political committee that paid any Conservative Partnership entity (CPI, CPC, Campus, Center, or bare 'Conservative Partnership') from January 2019 through March 2026. Sorted by total dollars paid.
* Lois Frankel (D-FL) and Tulsi Gabbard entries represent event-ticket/meal purchases, not membership dues. These are the only non-Republican entries in the dataset.
| Committee ID | Committee Name / Description | Type | # Pmts | Total Paid | First Pmt | Last Pmt | Purpose(s) |
|---|---|---|---|---|---|---|---|
| C00552851 | HOUSE FREEDOM FUND | PAC | 44 | $278,500.00 | Jan 2019 | Jun 2024 | PAC OFFICE RENT ($6,500/mo) |
| C00448696 | SENATE CONSERVATIVES FUND | PAC | 52 | $140,994.99 | Jan 2019 | Oct 2025 | PAC OFFICE RENT ($2,850/mo), MEMBERSHIP FEES |
| C00524181 | SENATE CONSERVATIVES ACTION | PAC | 49 | $73,500.00 | Jan 2019 | Jan 2023 | PAC OFFICE RENT ($1,500/mo) |
| C00662221 | HOUSE FREEDOM ACTION | PAC | 49 | $73,500.00 | Jan 2019 | Jan 2023 | PAC OFFICE RENT ($1,500/mo) |
| C00610451 | JIM JORDAN FOR CONGRESS | H | 6 | $19,940.43 | Nov 2020 | Jan 2025 | OFFICE SPACE RENTAL, CONFERENCE |
| C00662767 | CHIP ROY FOR CONGRESS | H | 6 | $19,841.67 | Feb 2021 | May 2025 | FACILITY RENTAL, FOOD/BEVERAGES, MEMBERSHIP |
| C00614776 | JOHNSON LEADERSHIP FUND* | PAC | 9 | $19,630.00 | Jan 2019 | Jul 2024 | MEMBERSHIP FEES, DONATION, ENTRANCE FEE |
| C00551374 | MARK MEADOWS / FREEDOM CAUCUS-LINKED | H | 4 | $18,000.00 | Mar 2021 | Nov 2024 | MEMBERSHIP DUES |
| C00492785 | NATIONAL REPUBLICAN CONGRESSIONAL CMTE-LINKED | H | 5 | $17,815.00 | Jan 2020 | May 2025 | RENT, FACILITY RENTAL, REGISTRATION FEE |
| C00655332 | TED CRUZ FOR SENATE | S | 4 | $16,000.00 | Mar 2022 | Nov 2024 | MEMBERSHIP DUES, CATERING, SUBSCRIPTION |
| C00784934 | MIKE JOHNSON LEADERSHIP (separate cmte) | H | 4 | $14,694.84 | Mar 2023 | Mar 2025 | MEETING EXPENSE, SPONSORSHIP |
| C00728238 | THE CONSERVATIVE PARTNERSHIP CENTER (PAC) | PAC | 4 | $14,458.80 | Apr 2022 | Nov 2024 | MEMBERSHIP DUES, EVENT CATERING |
| C00733329 | ERIC BURLISON / HOUSE FREEDOM-LINKED | H | 3 | $14,000.00 | Jan 2021 | Sep 2024 | FACILITY RENTAL, MEMBERSHIP DUES |
| C00812974 | ANDY OGLES FOR CONGRESS | H | 3 | $14,000.00 | Jan 2023 | Jan 2025 | DONATION, MEMBERSHIP FEE, POLITICAL SPONSORSHIP |
| C00409276 | RON JOHNSON FOR SENATE | S | 3 | $13,000.00 | Oct 2020 | Sep 2023 | MEMBERSHIP FEE |
| C00600718 | RAND PAUL FOR US SENATE | S | 2 | $10,144.99 | May 2023 | Sep 2025 | MEMBERSHIP DUES, FOOD/BEVERAGE |
| C00737767 | MARJORIE TAYLOR GREENE-LINKED | H | 2 | $10,000.00 | Oct 2024 | Nov 2024 | MEMBERSHIP DUES |
| C00633610 | VICTORIA SPARTZ FOR CONGRESS | H | 2 | $10,000.00 | May 2023 | May 2024 | MEMBERSHIP DUES |
| C00723916 | MIKE LEE FOR SENATE | S | 2 | $10,000.00 | Oct 2024 | Jan 2025 | ANNUAL DONATION, DUES |
| C00718239 | TED BUDD FOR CONGRESS/SENATE | S | 2 | $10,000.00 | Feb 2024 | Jan 2025 | MEMBERSHIP DUES |
| C00788414 | BRANDON GILL FOR TEXAS | H | 2 | $10,000.00 | Jan 2024 | Jan 2025 | MEMBERSHIP FEES, EVENT ATTENDANCE |
| C00548289 | HOUSE FREEDOM CAUCUS FUND | PAC | 2 | $8,000.00 | Apr 2021 | Oct 2022 | MEMBERSHIP DUES, MEMBERSHIP FEE |
| C00496075 | RALPH NORMAN FOR CONGRESS | H | 2 | $7,000.00 | Jan 2024 | Apr 2025 | CATERING, FACILITY RENTAL |
| C00692327 | JOSH BRECHEEN FOR CONGRESS | H | 2 | $6,000.00 | Dec 2023 | Feb 2024 | REGISTRATION FEE |
| C00834507 | NEW CMTE (2025) | H | 1 | $6,000.00 | Jun 2025 | Jun 2025 | PAC DONATION, FOOD/BEVERAGE, SITE FEE |
| C00850404 | NEW CMTE (2025) | H | 1 | $5,000.00 | May 2025 | May 2025 | MEMBERSHIP DUES |
| C00762682 | STEER PAC / BUCK-LINKED | PAC | 2 | $5,000.00 | Apr 2021 | Feb 2024 | MEMBERSHIP DUES, EVENT CATERING |
| C00811844 | NEW 2023 HOUSE CMTE | H | 1 | $5,000.00 | Apr 2025 | Apr 2025 | MEMBERSHIP DUES |
| C00573378 | ANNA PAULINA LUNA FOR CONGRESS | H | 1 | $5,000.00 | Nov 2023 | Nov 2023 | MEMBERSHIP DUES |
| C00828483 | JFC EVENT CMTE | PAC | 1 | $5,000.00 | Oct 2023 | Oct 2023 | JFC EVENT SPACE FEE & MEMBERSHIP |
| C00857359 | 2024 NEW CMTE | H | 1 | $5,000.00 | Dec 2024 | Dec 2024 | MEMBERSHIP FEES |
| C00796086 | 2025 NEW CMTE | H | 1 | $5,000.00 | Jan 2025 | Jan 2025 | RENTAL EVENT VENUE |
| C00706747 | THOMAS MASSIE FOR CONGRESS | H | 1 | $5,000.00 | Feb 2024 | Feb 2024 | MEMBERSHIP DUES |
| C00708289 | ELI CRANE FOR CONGRESS | H | 1 | $5,000.00 | Aug 2023 | Aug 2023 | DONATION |
| C00461806 | PAUL GOSAR FOR CONGRESS | H | 1 | $5,000.00 | Apr 2025 | Apr 2025 | MEMBERSHIP DUES |
| C00699660 | LAUREN BOEBERT FOR CONGRESS | H | 1 | $4,000.00 | Apr 2022 | Apr 2022 | MEMBERSHIP DUES |
| C00641142 | PATRIOTS FOR PERRY / FLORIDA PAC | PAC | 1 | $4,000.00 | Sep 2022 | Sep 2022 | PAC DUES |
| C00416594 | MARY MILLER FOR CONGRESS | H | 1 | $4,000.00 | May 2022 | May 2022 | MEMBERSHIP DUES |
| C00510164 | MAKING A RESPONSIBLE STAND PAC | PAC | 5 | $2,440.24 | Sep 2023 | Sep 2025 | CONFERENCE FEES, REIMB CAUCUS DINNER |
| C00376939 | MARCO RUBIO FOR SENATE | S | 3 | $2,315.00 | Oct 2022 | May 2025 | VENUE RENTAL, EQUIPMENT INSTALLATION, FOOD |
| C00482984 | CHIP ROY LEADERSHIP-LINKED | H | 2 | $2,029.00 | Jan 2024 | Apr 2025 | FACILITY RENTAL |
| C00762260 | NEHLS FOR CONGRESS | H | 2 | $2,029.00 | Mar 2024 | May 2025 | CATERING |
| C00547893 | ERIC SCHMITT FOR SENATE | S | 1 | $2,000.00 | Feb 2022 | Feb 2022 | REGISTRATION FEE |
| C00570945 | MIKE BRAUN FOR INDIANA | S | 1 | $2,000.00 | Feb 2022 | Feb 2022 | REGISTRATION FEE |
| C00460550 | BERNIE MORENO FOR SENATE | H | 1 | $1,500.00 | May 2019 | May 2019 | STAFF DEVELOPMENT |
| C00503094 | LOIS FRANKEL FOR CONGRESS* | H | 1 | $1,500.00 | May 2019 | May 2019 | MEMBERSHIP FEE |
| C00461046 | JASON SMITH FOR CONGRESS | H | 2 | $1,315.00 | May 2021 | Nov 2022 | MEETING EXPENSE |
| C00653147 | BYRAN DONALDS / FREEDOM CAUCUS | H | 1 | $1,000.00 | Mar 2021 | Mar 2021 | FUNDRAISING EVENT FEES |
| C00473827 | LIBERTY PAC / RAND PAUL-LINKED | PAC | 1 | $1,000.00 | Jan 2024 | Jan 2024 | DONATION |
| C00676965 | ERIC BURLISON (MO) | H | 1 | $1,000.00 | Apr 2025 | Apr 2025 | CATERING |
| C00826362 | 2024 NEW CMTE | H | 1 | $1,000.00 | Jan 2024 | Jan 2024 | CATERING |
| C00719971 | 2024 HOUSE CMTE | H | 1 | $1,000.00 | May 2024 | May 2024 | EVENT CATERING |
| C00443580 | MARSHA BLACKBURN FOR SENATE | S | 1 | $1,000.00 | Mar 2021 | Mar 2021 | STEERING DINNERS 2021 |
| C00620518 | RICK SCOTT FOR FLORIDA / NRSC-LINKED | S | 1 | $1,000.00 | Feb 2024 | Feb 2024 | MEETING EXPENSE |
| C00707794 | TULSI GABBARD FOR PRESIDENT* | P | 1 | $504.74 | Jul 2019 | Jul 2019 | EVENT FOOD/BEVERAGE |
| C00732958 | THE CONSERVATIVE PARTNERSHIP CENTER (JFC) | PAC | 1 | $362.94 | Apr 2022 | Apr 2022 | FOOD AND BEVERAGE |
RENT MACHINE FINDING: Four PACs maintained permanent office space inside the CPI/CPC building from at least January 2019 through January 2023: House Freedom Fund ($6,500/mo), Senate Conservatives Fund ($2,850/mo), Senate Conservatives Action ($1,500/mo), and House Freedom Action ($1,500/mo). This arrangement embedded the core House Freedom Caucus financial infrastructure directly inside CPI — the MAGA 'nerve center.'
III. COMPASS PROFESSIONAL INC. — FULL FEC CLIENT REGISTRY
All federal political committees that paid Compass Professional Inc. in any name variant (COMPASS PROFESSIONAL INC., COMPASS PROFESSIONAL, INC., COMPASS PROFESSIONAL) from January 2019 through March 2026.
| Committee ID | Committee Name / Description | Type | # Pmts | Total Paid | First Pmt | Last Pmt | Purpose | Notes |
|---|---|---|---|---|---|---|---|---|
| C00771246 | JOHNSON LEADERSHIP FUND (Speaker Mike Johnson) | PAC | 23 | $240,756.89 | Feb 2024 | Dec 2025 | CAGING (recurring monthly) | DOMINANT CLIENT — 89.7% of Compass FEC revenue |
| C00790915 | BRIDGE PAC (Patrick Corrigan, treasurer) | PAC | 6 | $9,821.68 | Jun 2022 | Sep 2022 | COMPLIANCE CONSULTING | Corrigan is also CRA board member |
| C00818237 | J.R. MAJEWSKI VICTORY FUND | H | 5 | $4,810.20 | Sep 2022 | Feb 2023 | COMPLIANCE SERVICES / CONSULTING | |
| C00811943 | TRES WITTUM FOR TENNESSEE | H | 4 | $3,650.00 | Aug 2022 | Aug 2022 | COMPLIANCE CONSULTING | |
| C00770636 | J.R. MAJEWSKI FOR CONGRESS | H | 3 | $2,797.05 | Dec 2022 | Feb 2023 | COMPLIANCE CONSULTING | |
| C00808493 | FRIENDS OF SONIA MORRIS FOR CONGRESS | H | 4 | $2,045.01 | Jun 2022 | Sep 2022 | COMPLIANCE CONSULTING | |
| C00799932 | RHONDA PALAZZO FOR CONGRESS 2022 | H | 3 | $1,250.00 | May 2022 | Aug 2022 | COMPLIANCE CONSULTING | |
| C00803023 | DAVISSON FOR CONGRESS | H | 2 | $1,199.78 | May 2022 | Aug 2022 | FEC COMPLIANCE / ACCOUNTING SERVICES | |
| C00780668 | CECI TRUMAN FOR CONGRESS | H | 1 | $802.69 | Aug 2022 | Aug 2022 | COMPLIANCE CONSULTING | |
| C00815738 | THE AMERICAN TRANSFORMATION PAC | PAC | 1 | $749.96 | Feb 2023 | Feb 2023 | COMPLIANCE SERVICES | |
| C00799254 | PAUL BERRY III FOR CONGRESS | H | 3 | $424.70 | Aug 2022 | Sep 2022 | COMPLIANCE CONSULTING |
STRUCTURAL FINDING: Compass Professional's FEC client base breaks into two distinct periods: (1) a 2022 cohort of small/fringe campaigns paying $500–$5,000 for generic compliance services under Patrick Corrigan's treasurer network, and (2) a 2024–2025 stream of large monthly 'CAGING' payments exclusively from Speaker Mike Johnson's Johnson Leadership Fund (C00771246), totaling $240,756.89 — representing 89.7% of Compass Professional's total documented FEC revenue.
IV. JOHNSON LEADERSHIP FUND → COMPASS PROFESSIONAL: FULL CAGING TRANSACTION LEDGER
Committee: JOHNSON LEADERSHIP FUND | FEC ID: C00771246 | Committee Type: PAC | Payee: COMPASS PROFESSIONAL INC. | Purpose Code: CAGING (all transactions)
| Payment Date | Amount | Purpose Code |
|---|---|---|
| 2025-12-19 | $15,375.25 | CAGING |
| 2025-11-04 | $23,162.25 | CAGING |
| 2025-10-22 | $6,802.00 | CAGING |
| 2025-09-05 | $18,557.25 | CAGING |
| 2025-08-30 | $10,556.95 | CAGING |
| 2025-07-18 | $19,151.00 (2 txns) | CAGING |
| 2025-06-04 | $16,321.90 | CAGING |
| 2025-05-07 | $16,794.65 | CAGING |
| 2025-04-07 | $5,191.65 | CAGING |
| 2025-03-14 | $10,192.65 | CAGING |
| 2025-02-10 | $1,230.45 | CAGING |
| 2024-12-09 | $3,164.20 | CAGING |
| 2024-11-15 | $6,655.35 | CAGING |
| 2024-10-18 | $8,205.60 | CAGING |
| 2024-09-05 | $5,902.65 | CAGING |
| 2024-08-23 | $25,240.70 (3 txns) | CAGING |
| 2024-05-14 | $15,808.65 | CAGING |
| 2024-04-28 | $27,913.82 (2 txns) | CAGING |
| 2024-02-14 | $4,528.92 | CAGING |
| TOTAL (Johnson → Compass) | $240,756.89 | All coded as CAGING |
INVESTIGATIVE FLAG: 'CAGING' in FEC disclosures refers to voter data management and list-processing operations — specifically the matching of returned mail against voter rolls to identify undeliverable/suspect voter registrations. Speaker Johnson's PAC is paying CPI's primary vendor for recurring caging operations. This intersects directly with CPI's Election Integrity Network, which simultaneously trains poll workers to challenge voters. The Speaker's caging payments to the CPI ecosystem warrant scrutiny as a potential coordination mechanism between congressional leadership and CPI's voter suppression infrastructure.
V. DATA METHODOLOGY & SOURCE CITATION
PRIMARY SOURCE: FEC Electronic Filing System (EFILE) via BigQuery table politics_vault_standardized.fec_expenditures_2019_March2026_p (7.2M rows; partitioned by transaction_dt). All queries included explicit partition filter: transaction_dt BETWEEN '2019-01-01' AND '2026-03-31'.
ENTITY MATCHING: Payee field (name) matched via REGEXP_CONTAINS(UPPER(name), 'CONSERVATIVE PARTNERSHIP') and REGEXP_CONTAINS(UPPER(name), 'COMPASS PROFESSIONAL'). All name variants captured: Conservative Partnership Institute, Conservative Partnership Center LLC, Conservative Partnership Campus Inc., The Conservative Partnership Center, Conservative Partnership (bare), Compass Professional Inc., Compass Professional, Inc., Compass Professional (bare).
DEDUPLICATION: The raw expenditure table contains duplicate entries due to amendment filings (amndt_ind field). This analysis includes ONLY original filings (amndt_ind = 'N') and terminal filings (amndt_ind = 'T'). Amended filings (amndt_ind = 'A') are EXCLUDED to prevent double-counting. This is the correct methodology per FEC EFILE data handling standards.
COMMITTEE NAME RESOLUTION: Committee names derived from field-level data and corroborated against prior BigQuery analysis of fec_committee_master_2019_2026. Several 2024-2025 committee IDs could not be resolved to named committees via the master table and are listed as 'NEW CMTE (YEAR)' pending manual FEC.gov lookup.
NON-REPUBLICAN ENTRIES: Lois Frankel (D-FL, C00503094) paid $1,500 in May 2019 coded as MEMBERSHIP FEE. Tulsi Gabbard's presidential committee (C00707794) paid $504.74 in July 2019 for EVENT FOOD/BEVERAGE. Neither represents ideological alignment with CPI; both likely reflect event ticket or catering purchases at a shared venue, not organizational membership.
COMPASS PROFESSIONAL / DESPOSITO DISAMBIGUATION: Prior research flagged Compass Professional payments to DeSposito for New York (C00809426, coded as LEGAL CONSULTING, 2023) listed at New York, NY. These rows carry amndt_ind = 'A' (amendments) and are excluded from this analysis. The New York address and 'legal consulting' purpose distinguish these from the Washington, DC-based Compass Professional Inc. compliance/caging vendor. These may represent a different entity and require independent verification.
CROSS-SECTOR CONTEXT: Compass Professional's FEC revenue of $268,307.96 represents a fraction of its total documented revenue. IRS 990 records show Compass Professional Inc. received $2,148,862 from the Conservative Partnership Institute and $117,859 from America First Legal Foundation across documented tax years — for a confirmed cross-sector total of approximately $3.9M. The FEC payments represent the political committee side of the same vendor relationship.
END OF DOCUMENT | Produced by Investigative Data Journalism Unit | politics_vault_standardized | March 13, 2026 | CONFIDENTIAL — For Authorized Investigative Use Only
10Reportscorroborating3.2 KB · markdownretrieved Feb 16, 2026CPI 2023 Financial Deep Dive (Analysis)
Tax-year-2023 financial deconstruction of CPI's grants, payroll, and Compass vendor payments.
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Financial Deep Dive: Conservative Partnership Institute (CPI) - 2023
Source: 2023 Form 990 Full XML | 2022 Form 990 PDF
Executive Summary
This report analyzes the 2023 financial activities of the Conservative Partnership Institute (CPI), based on newly retrieved tax filings.
- Total Revenue: (Pending Extraction)
- Total Expenses: (Pending Extraction)
- Net Assets: (Pending Extraction)
Key Findings
1. Connection to State Freedom Caucus Network
- Grant Confirmed: CPI granted $568,500 to the "State Freedom Caucus Foundation" in 2023.
- Purpose: "Mission and program support".
- Significance: This confirms the financial flow from CPI to the SFCN ecosystem, substantiating the $244k "Due From" claim found in SFCN's books (likely a subset or related transaction).
2. Major Contractors (The "Compass" Network)
Data reveals significant payments to entities likely controlled by inner-circle figures:
- Envision Marketing: $1,165,281
- Conservative Partnership Campus Inc: $928,460 (Real Estate/Internal)
- Zuckerman Spaeder: $846,525 (Legal/Defense)
- Compass Professional Inc: $813,590
- Compass Legal Group Inc: $706,069
Analysis: The "Compass" entities are frequently associated with Cleta Mitchell and the conservative legal network.
3. Officer Compensation
- James W DeMint (Chairman): $608,034
- Mark Meadows (Senior Partner): $552,254
- Edward Corrigan (President & CEO): $423,245
- Wesley Denton (COO): $395,197
The Bradley Foundation Connection (The Closed Loop)
We have now confirmed the complete financial circuit:
Inflow (The Source):
- $100,000 direct grant from Lynde and Harry Bradley Foundation to CPI in 2023 (Confirmed via Annual Report).
- ~$1 Million+ historic/ongoing support via Bradley Impact Fund (Donor-Advised Fund connected to Bradley Board).
- Control Node: Cleta Mitchell (Bradley Secretary / CPI Senior Fellow).
The Intermediary (CPI):
- Acts as the central node, anonymizing the source funds.
Outflow (The Recipient):
- $568,500 grant from CPI to State Freedom Caucus Foundation (SFCN).
- Conclusion: Bradley Foundation funds effectively subsidize the State Freedom Caucus Network, laundered through CPI to strip the specific attribution.
Governance Link (The "Cleta Nexus")
- Cleta Mitchell serves as Secretary of the Board for the Lynde and Harry Bradley Foundation.
- Cleta Mitchell simultaneously serves as Senior Legal Fellow for CPI.
Grant Recipients (Outflows)
- Personnel Policy Operations: $880,005
- FAIR Elections Fund: $795,000
- State Freedom Caucus Foundation: $568,500
- Virginia Institute for Public Policy: $330,000
Next Steps
- Verify "Compass" Ownership: Confirmed as likely Cleta Mitchell entities.
- Trace Intermediaries: If direct Bradley funding is hidden, look for pass-throughs via "Donors Trust" or similar.
10Reportscorroborating33 KB · markdownretrieved Mar 13, 2026CPI Full Investigation Dossier (v3)
Internal forensic dossier on the Conservative Partnership Institute hub, the canonical research note behind the cpi-hub investigation.
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OPPOSITION RESEARCH DOSSIER
CONSERVATIVE PARTNERSHIP INSTITUTE & THE COMPASS CLUSTER
A Dark Money Network Investigation
Classification: SENSITIVE — FOR INVESTIGATIVE USE ONLY
Prepared: March 2026 | Data Sources: IRS Form 990 (2019–2023), FEC Disclosures (2019–2026), LittleSis, USASpending API
Primary Target EIN: 82-1470217 | LittleSis Entity ID: 402960 | HQ: 300 Independence Ave SE, Washington DC
EXECUTIVE SUMMARY
The Conservative Partnership Institute (CPI) is not a think tank. It is a command node — a federally tax-exempt 501(c)(3) organization that functions as the financial mothership, staffing agency, legal infrastructure, and incubation lab for the hard-right MAGA political apparatus in Washington, D.C. What the public sees as a constellation of independent conservative organizations is, forensically, a closed-loop ecosystem centered at a single Capitol Hill address, 300 Independence Avenue SE, and controlled by an interlocking directorate of Republican operatives who pay themselves through multiple channels simultaneously.
This investigation, drawing on IRS Form 990 filings for tax years 2019–2023, FEC disbursement records through March 2026, LittleSis relationship data, and USASpending federal contract records, documents three interlocking findings:
The Compass Cluster — CPI has established four co-located for-profit LLCs (Compass Professional Inc., Compass Legal Group, Compass Direct LLC, Compass Property Management Inc.) that collectively extracted over $5.75M in contractor payments from CPI in 2021–2023 alone. These entities are owned or managed by CPI's own senior leadership, creating a textbook private inurement structure that exposes CPI to IRS penalty under IRC Section 4958.
The Incubation Machine — CPI seeded and funded at least eight major conservative organizations — including America First Legal, Center for Renewing America, Election Integrity Network, and State Freedom Caucus Network — disbursing over $7.4M in grants across documented years while ensuring those organizations retained CPI's Compass contractors as vendors, creating a captive client ecosystem.
The Compensation Extraction — CPI's leadership extracted over $12.4M in direct compensation from 2019–2023, while simultaneously routing millions more to their privately held LLCs. Mark Meadows, former Trump White House Chief of Staff, received $2.03M from CPI after leaving government. Cleta Mitchell received $530K+ in direct pay while her LLC received $1.24M+ in contractor fees from the same organization.
| ⚑ INVESTIGATIVE FINDING: CPI's revenue surged from $5.3M (2019) to a peak of $45.7M (2021) before settling at $19.5M (2023). This $40M+ surge tracks precisely with Trump's post-election fundraising and the January 6th period — raising serious questions about the source and purpose of that capital. |
|---|
SECTION 1: TARGET PROFILE — CONSERVATIVE PARTNERSHIP INSTITUTE
1.1 Organizational Identity
| Field | Detail |
|---|---|
| Legal Name | Conservative Partnership Institute |
| EIN | 82-1470217 |
| LittleSis Entity ID | 402960 |
| Classification | 501(c)(3) Public Charity |
| Registered Address | 300 Independence Ave SE, Washington, DC 20003 |
| Founded | 2017 |
| Mission (Stated) | Equipping principled conservatives to govern effectively |
| Peak Revenue | $45,707,730 (Tax Year 2021) |
| Total Revenue 2019–2023 | ~$113.1M (documented) |
1.2 Revenue Timeline
CPI's financial trajectory is not that of a policy organization. It is that of a political war chest activated by crisis.
| Tax Year | Total Revenue | YoY Change | IRS ObjectId (S3 XML) |
|---|---|---|---|
| 2019 | $5,322,860 | — | 202110639349300421 |
| 2020 | $6,202,407 | +16.5% | 202103199349318430 |
| 2021 | $45,707,730 | +637% | 202223199349329357 |
| 2022 | $36,397,454 | -20.4% | 202343199349307579 |
| 2023 | $19,498,478 | -46.4% | 202403199349305735 |
Source: IRS Form 990, all years. XML files retrieved from IRS public S3 bucket (gt990datalake-rawdata).
| ⚑ INVESTIGATIVE FINDING: The 637% revenue explosion in 2021 — the year of January 6th and Trump's departure from office — has never been publicly explained. Donor-advised funds (Fidelity, Schwab, National Philanthropic Trust) and pass-through foundations (Servant Foundation, Rydin Foundation) account for a substantial portion, deliberately obscuring the ultimate sources of capital. |
|---|
SECTION 2: EXECUTIVE COMPENSATION — THE $12.4M EXTRACTION
IRS Form 990 Part VII requires disclosure of compensation paid to officers, directors, and key employees. CPI's filings reveal a compensation structure that makes the organization one of the most lucrative employment vehicles in the conservative movement — for a small, interlocked leadership group.
2.1 Five-Year Compensation Summary (2019–2023)
| Officer | Title | 2019 | 2020 | 2021 | 2022 | 2023 | 5-Yr Total |
|---|---|---|---|---|---|---|---|
| Jim DeMint | Chairman | $500,000 | $541,059 | $545,400 | $669,953 | $625,461 | $2,881,873 |
| Mark Meadows | Senior Partner | — | — | $559,396 | $882,214 | $587,581 | $2,029,191 |
| Ed Corrigan | President & CEO | $349,858 | $390,154 | $382,429 | $396,882 | $440,238 | $1,959,561 |
| Wesley Denton | COO & Treasurer | $158,789 | $345,901 | $380,315 | $362,224 | $439,058 | $1,686,287 |
| Doug Stamps | Counselor to Chairman | $287,468 | $303,494 | $301,530 | $345,055 | $390,371 | $1,627,918 |
| Rachel Bovard | Sr. Director of Policy | $216,717 | $246,132 | $274,810 | $283,797 | — | $1,021,456+ |
| Cleta Mitchell | Sr. Legal Fellow & Sec. | $0 | $0 | $230,680 | $300,000 | — | $530,680+ |
| TOTAL | — | — | — | — | — | — | $11.7M+ |
Source: IRS Form 990, Part VII, all years. Retrieved from IRS public S3 XML files via BigQuery politics_vault_standardized.
2.2 The Mark Meadows Revolving Door
Mark Meadows served as White House Chief of Staff for Donald Trump through January 2021. He joined CPI as 'Senior Partner' immediately upon leaving government service. CPI paid Meadows $559,396 in 2021, $882,214 in 2022, and $587,581 in 2023 — a total of $2,029,191 over three years.
Meadows' 2022 compensation of $882,214 exceeds what CPI paid its President & CEO ($396,882) by more than 2:1.
Meadows simultaneously served as a board member of the Conservative Partnership Institute while on CPI payroll — a dual role that raises questions about self-dealing approvals.
Meadows was indicted in connection with Georgia election interference case in 2023, while still on CPI's payroll.
Source: IRS Form 990, Part VII, 2021–2023.
2.3 Cleta Mitchell: The Dual-Income Problem
Cleta Mitchell's compensation structure at CPI presents the clearest example of potential private inurement in the organization's history.
| Year | Direct CPI Compensation | CPI Payments to Compass Legal (her LLC) | Combined Total |
|---|---|---|---|
| 2021 | $230,680 | $149,012 | $379,692 |
| 2022 | $300,000 | $1,089,729 | $1,389,729 |
| 2023 | Undisclosed | $706,069 | $706,069+ |
Mitchell was simultaneously (a) CPI's Senior Legal Fellow and Secretary — a 'disqualified person' under IRC Section 4958 — and (b) the beneficial owner and managing member of Compass Legal Group, which received over $1.9M in CPI contractor payments across documented years. This is the textbook definition of a prohibited excess benefit transaction unless CPI can document contemporaneous conflict-of-interest recusal and independent fair-market-value assessment.
Source: IRS Form 990 2021–2023; State corporate filings for Compass Legal Group LLC; public reporting on Mitchell's role as managing member.
SECTION 3: THE COMPASS CLUSTER — PRIVATE CAPITAL EXTRACTION
The most structurally significant feature of CPI's financial architecture is its relationship with four co-located, for-profit limited liability companies operating under the 'Compass' trade name. These entities are not independent vendors selected through competitive bidding. They are private enterprises owned and managed by CPI's own leadership, co-located at CPI's registered address, and positioned as mandatory or default service providers for CPI's entire network of incubated organizations.
3.1 The Cluster Entities
| Entity | Service | CPI Connection | FEC Activity |
|---|---|---|---|
| Compass Professional Inc. | Administrative Services, HR, Caging | Russell Vought — beneficial owner; Ed Corrigan — related | JOHNSON LEADERSHIP FUND: $240,756 |
| Compass Legal Group LLC | Legal Services | Cleta Mitchell — managing member & beneficial owner | Trump 2024, Never Surrender, Save America: $500K+ |
| Compass Direct LLC | Direct Mail, Fundraising | Patrick Corrigan (Ed Corrigan's brother) — principal | No FEC payments identified; fundraising arm |
| Compass Property Management | Real Estate, Facilities | CPI leadership — related party | None identified |
| Conservative Partnership Campus | Event Space, Studio | CPI affiliate; 300 Independence Ave | None identified |
3.2 Contractor Payments — Year-Over-Year Escalation
The following figures are drawn directly from CPI's Form 990 Schedule O contractor disclosures:
| Contractor | 2021 | 2022 | 2023 | 3-Yr Total |
|---|---|---|---|---|
| Compass Professional Inc. | $349,224 | $949,443 | $813,590 | $2,112,257 |
| Compass Legal Group / Services | $149,012 | $1,089,729 | $706,069 | $1,944,810 |
| Compass Property Management | — | $550,000 | — | $550,000+ |
| Conservative Partnership Campus | — | — | $928,460 | $928,460+ |
| Compass Direct LLC | Undisclosed | Undisclosed | $90,000 (commission) | Undisclosed+ |
| CLUSTER TOTAL | $498,236 | $2,589,172 | $2,538,119 | $5,625,527+ |
Source: IRS Form 990, Schedule O (contractor disclosures), 2021–2023. Retrieved from IRS public S3 XML.
| ⚑ INVESTIGATIVE FINDING: In 2023, CPI's 990 lists five contractors by payment amount but OMITS THEIR NAMES from the public XML — a deliberate redaction not required by IRS regulations. Cross-referencing with 2022 disclosures and FEC data allows identification of the Compass entities as the likely beneficiaries. This is an active transparency suppression tactic. |
|---|
3.3 The Fundraising Commission Mechanism
CPI's 2023 Schedule G discloses that Compass Direct LLC served as CPI's professional fundraiser, generating $454,134 in gross receipts and retaining $90,000 (approximately 20%) as its fee. This arrangement:
Entitles a private LLC controlled by the President's brother to a recurring commission on all CPI fundraising it conducts.
Shields the specific vendor relationships and operational mechanics of CPI's fundraising from IRS scrutiny, since Compass Direct's internal books are not subject to public disclosure.
Creates a permanent revenue stream for Compass Direct that scales with CPI's donor base — a base that grew by 637% in a single year.
Source: IRS Form 990, Schedule G (Professional Fundraising Activities), 2023.
3.4 The Compass–FEC Connection: From Tax-Exempt to Campaign Finance
The Compass entities do not restrict their services to CPI and its nonprofit affiliates. FEC disbursement records through March 2026 reveal a sprawling campaign finance client base totaling at least 60 distinct political committees:
| Compass Entity | Top FEC Client | Amount | Purpose |
|---|---|---|---|
| Compass Professional Inc. | Johnson Leadership Fund (Speaker Mike Johnson) | $240,757 | CAGING |
| Compass Legal Group | Never Surrender, Inc. (Trump defense PAC) | $215,299 | Legal Consulting |
| Compass Legal Group | Donald J. Trump for President 2024 | $215,299 | Legal Consulting |
| Compass Legal Services | Save America (Trump PAC) | $95,267 | Legal Consulting |
| Compass Legal Group | Constantino for Congress | $33,056 | Legal Consulting |
| Compass Legal Group | Andy Ogles for Congress | $27,421 | Legal Consulting |
| Compass Legal Group | Friends of Mike Lee | $19,513 | Legal Consulting |
| Compass Legal Group | Greene for Congress | $15,606 | Legal Consulting |
| Compass Legal Group | Mary Miller for Congress | $14,290 | Legal Consulting |
Source: BigQuery fec_expenditures_2019_March2026_p, queried March 2026. Amounts are deduplicated unique-transaction sums.
Notable: 'Caging' is the process of managing returned mail from voter contact programs — a standard but politically sensitive voter file maintenance operation. Compass Professional is handling this function for the Speaker of the House's leadership PAC while simultaneously receiving $2.1M+ in contractor payments from a tax-exempt nonprofit.
3.5 The Hidden Fifth Entity: Conservative Partnership Center LLC
Separate from CPI the 501(c)(3), a distinct for-profit LLC called Conservative Partnership Center LLC operates as the physical landlord for the entire PAC ecosystem at 300 Independence Ave SE. FEC records 2019–2025 confirm it collected $778,495 in PAC office rent and membership fees from at least 23 distinct political committees — an operation that has run continuously since 2019 with no break in revenue. This entity does not appear on CPI’s Form 990 as a related organization, yet it shares the same address, brand, and operational staff. Key tenants:
House Freedom Fund (Q): $234,000/year in PAC office rent, 2019–2022; $19,500 in 2023 — total $955,500 over 5 years
Senate Conservatives Fund (Q): $122,800–$136,800/year, 2019–2022; membership fees continuing through 2024
Freedom Caucus Fund (V): $78,000/year, 2019–2022
House Freedom Action (O) and Senate Conservatives Action (O): $72,000/year each, 2019–2022
Source: BigQuery fec_expenditures_2019_March2026_p, all partitions 2019–2026. Conservative Partnership Center LLC confirmed as distinct FEC-registered payee, separate from CPI 501(c)(3).
3.6 Vought Strategies LLC: The Missing $968,595
Russell Vought — documented beneficial owner of Compass Professional Inc. and President of CPI-incubated Center for Renewing America — simultaneously operated Vought Strategies LLC as a PAC strategy consulting firm. FEC records spanning 2019–2024 show Vought Strategies collected $968,595 from just two clients: Senate Conservatives Fund and Senate Conservatives Action — the Jim DeMint-aligned PAC apparatus. This revenue stream ran continuously for six years, including the years Vought served as Trump’s OMB Director and while CPI was paying his nonprofit CRA $1.94M in grants.
Vought Strategies FEC Revenue by Year (Senate Conservatives Fund + Senate Conservatives Action):
2019: $492,000 (PAC Communications & Strategic Consulting)
2020: $672,556
2021: $711,330
2022: $725,705
2023: $948,590 (peak year; includes Senate Conservatives Fund, Senate Conservatives Action, Women for America’s Freedom, House Freedom Fund, Freedom Caucus Fund)
2024: $320,000
Source: BigQuery fec_expenditures_2019_March2026_p, all partitions. Vought Strategies LLC also received $60,000 from the Republican National Committee in 2024 for “Management Consulting” [FEC Sub ID verified].
3.7 Full CPI Ecosystem FEC Revenue Summary (2019–2026)
Across all entities in the CPI ecosystem, FEC-disclosed political committee payments total at least $3,245,818 from 2019 through March 2026 — queried against all 3,287 daily partitions of the complete FEC expenditure dataset. This is separate from and in addition to the $5.6M+ in contractor payments extracted from tax-exempt CPI itself.
The top 11 paying committees alone account for $8.9M+ in total payments into the ecosystem:
Senate Conservatives Fund: $2,548,691 (Vought Strategies + CPC LLC rent + memberships)
Senate Conservatives Action: $2,220,000 (Vought Strategies + CPC LLC rent)
House Freedom Fund: $974,884 (CPC LLC rent)
Johnson Leadership Fund (Speaker Mike Johnson): $722,271 (Compass Professional caging)
Never Surrender Inc. (Trump criminal defense PAC): $550,598 (Compass Legal)
Save America (Trump JFC): $420,802 (Compass Legal + Save America Stop Socialism PAC)
Freedom Caucus Fund: $324,962 (CPC LLC rent)
Greene for Congress: $304,176 (Compass Legal + CPI membership)
House Freedom Action: $294,000 (CPC LLC rent)
Mary Miller for Congress: $287,158 (Compass Legal + CPI membership)
Donald J. Trump for President 2024: $275,299 (Compass Legal)
Source: BigQuery fec_expenditures_2019_March2026_p queried 2019-01-01 through 2026-03-13, all 3,287 daily partitions; 7M+ rows. Figures are raw SUM(transaction_amt) by committee; deduplication across sub_id confirmed.
SECTION 4: THE INCUBATION MACHINE — GRANT NETWORK
CPI's core public-facing claim is that it serves as an 'incubator' for conservative organizations. The grant record confirms this is literally true — with the critical caveat that incubated organizations are not released into independence. They are retained as captive clients of the Compass vendor cluster, ensuring that CPI's leadership continues to profit from their operations after the initial grant period.
4.1 Confirmed Incubated Organizations
| Organization | EIN | LittleSis ID | CPI Role |
|---|---|---|---|
| America First Legal Foundation | 86-2190372 | 416495 | Founded/incubated; $1.33M in 2021 alone |
| Center for Renewing America | 85-4307005 | 423904 | Founded/incubated; Russell Vought as President |
| Election Integrity Network | 88-2166493 | 435739 | Directed by Cleta Mitchell; $545K documented grants |
| State Freedom Caucus Network | 88-3060056 | 424791 | Incubated; $568K+ documented grants |
| Personnel Policy Operations | 88-1773001 | 444147 | Incubated; $1.88M+ documented grants |
| American Moment Inc. | 85-1875789 | 444146 | Incubated; $364K documented grants |
| American Cornerstone Institute | 86-1545903 | 416746 | Ben Carson-led; $161K in 2021 |
| American Accountability Foundation | 85-4391204 | 424075 | Incubated; $335K in 2021 |
4.2 Grant Outflows by Year (EIN-Verified)
2021 Grants — $3.9M+ Documented
| Recipient | EIN | Amount |
|---|---|---|
| America First Legal Foundation | 86-2190372 | $1,334,105 |
| American Voting Rights Foundation | 87-1891209 | $1,005,000 |
| Center for Renewing America | 85-4307005 | $583,701 |
| American Moment Inc. | 85-1875789 | $336,000 |
| American Accountability Foundation | 85-4391204 | $335,100 |
| American Cornerstone Institute | 86-1545903 | $160,950 |
| Public Interest Legal Foundation | 45-4355641 | $50,000 |
2022 Grants — $2.94M+ Documented
| Recipient | EIN | Amount |
|---|---|---|
| Center for Renewing America | 85-4307005 | $1,347,000 |
| Personnel Policy Organization Inc. | 88-1773001 | $1,150,000 |
| Election Integrity Network Inc. | 88-2166493 | $525,000 |
| State Freedom Caucus Foundation | 88-3060056 | $463,748 |
| American Accountability Foundation | 85-4391204 | $210,000 |
| Virginia Institute for Public Policy | 54-1870848 | $175,000 |
| FDRLST Media Foundation | (undisclosed) | $175,000 |
| America First Legal Foundation | 86-2190372 | $30,298 |
2023 Grants — $2.66M+ Documented
| Recipient | EIN | Amount |
|---|---|---|
| Personnel Policy Operations | 88-1773001 | $880,005 |
| FAIR Elections Fund | 93-1870447 | $795,000 |
| State Freedom Caucus Foundation | 88-3060056 | $568,500 |
| Virginia Institute for Public Policy | 54-1870848 | $330,000 |
| American Moment Inc. | 85-1875789 | $28,000 |
| Election Integrity Network Inc. | 88-2166493 | $20,000 |
| America First Legal | 86-2190372 | $10,000 |
| Center for Renewing America | 85-4307005 | $10,000 |
Source: IRS Form 990, Schedule I (Grants and Other Assistance), 2021–2023. EINs verified from XML RecipientEIN fields.
SECTION 5: DARK MONEY DONOR NETWORK
CPI's donor base is dominated by donor-advised funds and private foundations that legally obscure the identity of ultimate individual donors. The following represents the documented inflow from disclosed sources only; the true donor universe is substantially larger.
5.1 Top Documented Donors
| Donor Organization | EIN | Amount | Years | Notes |
|---|---|---|---|---|
| The Rydin Foundation | Undisclosed | $6,500,000 | 2023 | Michael T. Rydin, CEO of HCSS (Sugar Land, TX) |
| Servant Foundation / Signatry | 43-1890105 | $9,498,890 | 2022–2023 | Pass-through DAF; ultimate donors obscured |
| The Dunn Foundation | Undisclosed | $5,250,000 | 2024 | Earmarked for 'The Academy' congressional training |
| Fidelity Investments Charitable Gift Fund | 11-0303001 | $2,151,500 | 2022 | Donor-advised fund; donors anonymous |
| Schwab Charitable Fund | 31-1640316 | $1,716,102 | 2022 | Donor-advised fund; donors anonymous |
| Natl. Christian Charitable Fdn. (NCC) | 58-1493949 | $1,639,611 | 2023 | Faith-linked DAF; donors anonymous |
| Donor Advised Charitable Giving Inc. | 27-0030587 | $1,078,725 | 2023 | Pass-through; donors anonymous |
| Bradley Impact Fund | 39-1555138 | $964,130 | 2023 | Linked to Lynde & Harry Bradley Foundation |
| WL Amos Sr Foundation | 58-2399470 | $600,000 | 2023 | Per BigQuery 990 inflow data |
| Robert S. & Star Pepper Foundation | 75-3034316 | $290,000 | 2018–2021 | Multi-year funder since founding |
Source: BigQuery financial_transactions_990_p (partitioned, ingestion_date >= 2026-02-24); IRS Form 990 Schedule B donor disclosures (where available).
| ⚑ INVESTIGATIVE FINDING: Over 60% of CPI's documented major donors are donor-advised funds or private foundations with no individual donor disclosure requirement. This is not coincidental — it is the standard architecture of dark money infrastructure. The Servant Foundation alone funneled $9.5M+ to CPI while its own donors remain completely anonymous under current law. |
|---|
SECTION 6: PERSONNEL NETWORK & GOVERNMENT INFILTRATION
6.1 Core Leadership Biographies
Jim DeMint — Chairman
| Field | Detail |
|---|---|
| Position at CPI | Chairman (founding) |
| CPI Compensation (2019–2023) | $2,881,873 |
| Prior Role | U.S. Senator (SC, 2005–2013); President of Heritage Foundation (2013–2017) |
| Networks | Council for National Policy (CNP) member; Federalist Society |
| LittleSis ID | 13241 |
Ed Corrigan — President & CEO
| Field | Detail |
|---|---|
| Position at CPI | President & CEO (founding) |
| CPI Compensation (2019–2023) | $1,959,561 |
| Notable | Brother Patrick Corrigan controls Compass Direct LLC |
| Patrick Corrigan detail | Compass Direct was hired by CPI approximately 3 weeks before it was legally incorporated |
| LittleSis ID | 34643 |
Wesley Denton — COO & Treasurer
| Field | Detail |
|---|---|
| Position at CPI | COO & Treasurer |
| CPI Compensation (2019–2023) | $1,686,287 |
| Role | Controls CPI's financial operations and vendor approvals |
| LittleSis ID | 430440 |
Russell Vought — Strategic Architect
| Field | Detail |
|---|---|
| CPI Role | Founder/President, Center for Renewing America (CPI incubate) |
| CPI-adjacent Income | $536K+ from CRA while CRA received $1.94M in CPI grants |
| Compass Connection | Documented beneficial owner of Compass Professional Inc. |
| Compass Professional role | Registered treasurer of Compass Professional in state filings |
| Other | Author of Project 2025 personnel chapter; Trump OMB Director |
| Entity | Vought Strategies LLC (separate consulting entity) |
Cleta Mitchell — Legal Strategist
| Field | Detail |
|---|---|
| CPI Role | Senior Legal Fellow & Secretary |
| CPI Direct Comp (2021–2022) | $530,680+ |
| Compass Legal Connection | Managing member and beneficial owner |
| Compass Legal Payments from CPI | $1,944,810 (2021–2023) |
| Other Roles | Directed Election Integrity Network (CPI incubate); on Trump's January 6th call to Brad Raffensperger |
| LittleSis ID | 24151 |
6.2 CPI Alumni in Federal Government Roles
CPI functions as a pipeline for personnel into federal government positions. The following CPI-networked individuals moved into consequential federal roles:
| Individual | CPI Connection | Federal Role |
|---|---|---|
| Matt Buckham | CPI staffer | Acting Chief of Staff, HHS (under RFK Jr.) |
| Heather Honey | CPI election integrity network | Deputy Director, DHS |
| Russell Vought | CRA President (CPI incubate) | OMB Director (Trump 2.0); Project 2025 author |
| Mark Meadows | CPI Senior Partner | Former White House Chief of Staff |
| Multiple DOGE affiliates | CPI/CRA network | Placed across federal agencies via DOGE |
Source: LittleSis relationship network (v_ls_relationship_network); DOGE Investigation Dossier (project file); public reporting.
6.3 Congressional Members Paying CPI Membership Fees
The following House members paid $5,000 each in CPI membership dues — documented via FEC disbursement records:
Rep. Chip Roy (TX)
Rep. Ralph Norman (SC)
Rep. Mary Miller (IL)
Rep. Andy Biggs (AZ)
Rep. Josh Brecheen (OK)
Rep. Eli Crane (AZ)
Rep. Eric Burlison (MO)
Rep. Marjorie Taylor Greene (GA)
Rep. Victoria Spartz (IN)
Source: BigQuery fec_expenditures_2019_March2026_p; FEC disbursement records.
SECTION 7: REGULATORY & LEGAL EXPOSURE ANALYSIS
7.1 IRC Section 4958 — Excess Benefit Transactions
Section 4958 of the Internal Revenue Code imposes excise taxes on 'excess benefit transactions' between a tax-exempt organization and 'disqualified persons' — individuals who exercise substantial influence over the organization. The tax is 25% of the excess benefit on the disqualified person, and 200% if not corrected.
CPI's structure presents the following specific exposure points:
Cleta Mitchell (Senior Legal Fellow & Secretary = disqualified person): Received $530K+ in direct compensation AND her LLC received $1.94M in vendor payments from the same organization in the same period. Unless CPI documented contemporaneous conflict-of-interest recusal, competing bids, and fair-market-value certification, this is presumptively an excess benefit transaction.
Russell Vought (CPI network insider = potential disqualified person): Beneficial ownership of Compass Professional while Compass Professional received $2.1M in CPI contractor payments creates the same exposure.
Ed Corrigan (President & CEO = disqualified person): CPI hired his brother's company (Compass Direct) approximately three weeks before that company was legally incorporated — a timeline that strongly implies the contract relationship preceded and drove the corporate formation.
7.2 Private Inurement — Non-Distribution Constraint
A 501(c)(3) organization's net earnings may not inure to the benefit of any private shareholder or individual. The closed-loop architecture of the Compass cluster — where tax-exempt CPI revenue flows to for-profit LLCs owned by CPI's own officers — is the textbook definition of private inurement. The IRS has revoked tax exemptions for organizations with less severe patterns.
7.3 Coordination Risk — FEC
The fact that Compass Legal Group simultaneously (a) receives contractor payments from tax-exempt CPI, and (b) provides legal services to Trump campaign committees, Trump PACs, and Congressional campaigns raises coordination questions. If Compass serves as a de facto shared services provider linking the nonprofit universe to the campaign finance universe, the FEC's coordination rules may be implicated.
7.4 The 2023 Contractor Redaction
CPI's 2023 Form 990 XML deliberately omits contractor names while disclosing payment amounts — a suppression tactic with no IRS regulatory basis. The five unnamed contractors totaling $4,459,925 are identifiable through cross-referencing with prior year disclosures and FEC records as the Compass cluster. This pattern of opacity, if part of a deliberate strategy to avoid disclosure, may constitute a material misrepresentation on a federal tax filing.
SECTION 8: CHRONOLOGICAL EVENT TIMELINE
| Date / Period | Event | Significance |
|---|---|---|
| 2017 | CPI founded; EIN 82-1470217 registered | Jim DeMint departs Heritage Foundation under board pressure; immediately launches CPI |
| 2019 | CPI revenue: $5.3M | Baseline year; Compass entities not yet visible in contractor disclosures |
| Nov 2020 | Trump loses election | Triggers massive dark money mobilization into CPI and affiliated orgs |
| Jan 6, 2021 | Capitol breach | Cleta Mitchell is on Trump's Raffensperger call; EIN network activated |
| 2021 | CPI revenue explodes to $45.7M (+637%) | America First Legal receives $1.33M; CRA receives $583K; new Compass payments begin |
| Feb 2021 | Mark Meadows joins CPI as 'Senior Partner' | Begins $559K/year; continues through at least 2023 |
| 2021 | Compass Professional receives $349K from CPI | First documented Compass contractor payment |
| 2021 | Compass Legal receives $149K from CPI | First documented Compass Legal payment; Mitchell dual-income begins |
| 2022 | CPI revenue $36.4M | Compass payments surge: $2.58M to cluster in single year |
| 2022 | Compass Legal receives $1.09M | Exceeds all prior years; Mitchell dual-income fully operational |
| 2022 | Compass Legal begins serving Trump PACs | Save America pays $95K; integration of nonprofit and campaign finance clients |
| 2023 | Compass Legal serves Never Surrender + Trump 2024 | $215K each; Cleta Mitchell's LLC serving both CPI and Trump defense PACs simultaneously |
| 2023 | CPI 2023 990 redacts contractor names | Five contractors totaling $4.46M listed without names; active transparency suppression |
| 2023 | Meadows indicted (Georgia) | Still on CPI payroll receiving $587K that year |
| 2025–2026 | Compass Professional serves Johnson Leadership Fund | $240K in caging services for House Speaker's PAC |
| 2026 | This investigation | All data sourced and verified from public records |
SECTION 9: PRIMARY SOURCE DOCUMENTATION
9.1 IRS Form 990 XML Sources
| Tax Year | EIN | IRS ObjectId | S3 URL |
|---|---|---|---|
| 2023 | 82-1470217 | 202403199349305735 | https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202403199349305735\_public.xml |
| 2022 | 82-1470217 | 202343199349307579 | https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202343199349307579\_public.xml |
| 2021 | 82-1470217 | 202223199349329357 | https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202223199349329357\_public.xml |
| 2020 | 82-1470217 | 202103199349318430 | https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202103199349318430\_public.xml |
| 2019 | 82-1470217 | 202110639349300421 | https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202110639349300421\_public.xml |
9.2 BigQuery Data Sources
| Table | Purpose | Key Filter |
|---|---|---|
| financial_transactions_990_p | 990 grants, officers, contractors | ingestion_date >= '2026-02-24'; source_ein = '821470217' |
| fec_expenditures_2019_March2026_p | FEC disbursements | REGEXP_CONTAINS(UPPER(name), r'COMPASS') |
| fec_committee_master_2019_2026 | Committee name lookup | JOIN on cmte_id |
| v_ls_relationship_network | LittleSis personnel/org graph | entity_id = 402960 (CPI) |
| targets | Investigation target registry | id IN (7,8,9,10,11,12) |
APPENDIX: PENDING INVESTIGATION THREADS
The following threads were identified during this investigation but require additional data loading or research time to fully document:
A. Thomas Datwyler Treasurer Cluster
Thomas Datwyler serves as treasurer for 714 FEC committees with a combined $1.16 billion in total expenditures. Top clients include Jim Jordan ($36.5M), Mike Lee ($17.6M), and Tulsi Gabbard ($15.1M). His connection to CPI and the Compass network is identified but not yet fully documented. Full Datwyler dossier is the recommended next investigation.
B. Russell Vought Financial Traces
Vought Strategies LLC has not been fully traced through USASpending, state registries, or FEC records. Vought's simultaneous roles at CRA (CPI incubate), Compass Professional (beneficial owner), and OMB Director create a potentially significant self-dealing and revolving-door pattern that warrants dedicated analysis.
C. Cross-Cycle Compass FEC Revenue Analysis
The FEC expenditure table (fec_expenditures_2019_March2026_p) contains the complete universe of disclosed federal disbursements from January 2019 through March 2026 — over 7 million rows across 3,287 daily partitions, covering every election cycle in that window. Full-cycle Compass FEC revenue queried across all partitions: Compass Legal Group received $830,500 from 256 transactions across 44 distinct committees; Compass Professional received $302,280 from 81 transactions across 13 committees. Combined confirmed FEC revenue to the Compass cluster: $1,134,280+ — on top of the $5.6M+ extracted from tax-exempt CPI via contractor payments. Recommended next step: cross-cycle donor loyalty modeling to identify recurring funders whose dark money trails span multiple election cycles.
D. SFOF (State Financial Officers Foundation) Network
The sfof_exposed table exists in BigQuery but has not been deeply analyzed in this session. SFOF represents a parallel state-level dark money infrastructure with CPI overlap.
E. Recipient EIN Backfill — ACTION REQUIRED
The SQL file 'add_recipient_ein_RUNTHISTIME.sql' must be executed manually in the BigQuery console (gen-lang-client-0281053432). The BigQuery MCP tool is SELECT-only and cannot run DDL or DML. Once executed, 19+ grant rows will have verified EINs enabling lossless graph traversal.
10Reportscorroborating2.4 KB · markdownretrieved Feb 16, 2026CPI Self-Dealing Report (Analysis)
Pattern analysis of the CPI/Compass self-dealing relationship and the $2.96M in 2024 related-party payments.
Read full document [+]Collapse [-]download raw .md ↗
Investigation Phase 3: Strategic Self-Dealing & Insider Enrichment
Target Entity: Conservative Partnership Institute (CPI)
Date: 2026-02-16
Status: Confirmed High Confidence
Executive Summary
This phase investigated allegations of self-dealing within the CPI network. Analysis of 2023 financial records and corporate filings confirms that over $1.6 Million in contractor payments was directed to entities controlled by or deeply linked to CPI's own leadership.
Key Findings: The "Compass" Network
1. The Schematic
CPI utilized two primary vehicles for these payments:
- Compass Professional Inc (Function: Accounting/Compliance)
- Compass Legal Group Inc (Function: Legal Services)
Both share the same physical address as CPI: 300 Independence Ave SE, Washington DC.
2. The Financial Flows (2023 Data)
Data extracted from the 2023 Form 990 XML confirms the following payments:
| Contractor Entity | Amount Paid (2023) | Stated Service |
|---|---|---|
| Compass Professional Inc | $813,590 | Accounting/Consulting |
| Compass Legal Group Inc | $846,525 | Legal Services |
| Total to Compass Network | $1,660,115 |
3. The Insider Connections (Conflict of Interest)
- Cleta Mitchell (CPI Senior Fellow):
- Public records identify her as the attorney representing "Compass Legal Services" in FEC matters.
- She serves as Board Secretary for the Bradley Foundation (a major donor), creating a governance-level conflict.
- Russell Vought (Inner Circle):
- Identified as a beneficial owner and director of Compass Professional Inc (2021-2023).
- This confirms that funds paid by CPI for "compliance" are flowing directly to for-profit entities owned by key political allies.
Conclusion
The "Compass" entities function as a private enrichment mechanism. By outsourcing core functions (legal, accounting) to for-profit firms owned by insiders, CPI converts tax-exempt donations into private revenue for its leadership network, bypassing standard nonprofit compensation caps.
Next Steps
- Visualize the Flow: Add these nodes to the Knowledge Graph.
- FEC Cross-Check: Verify if "Compass" entities are also receiving payments from the political campaigns (SFOF, etc.) identified in the FEC scan.
10Reportscorroborating12.8 KB · markdownretrieved Mar 14, 2026Schedule O Deep Dive (Analysis)
Cross-org review of IRS Form 990 Schedule O disclosures across the CPI ecosystem.
Read full document [+]Collapse [-]download raw .md ↗
Schedule O & Financial Structure Deep Dive
Date: 2026-02-16
Status: HIGH CONFIDENCE — Multiple confirmed red flags
Executive Summary
Analysis of Schedule O narratives and full XML filings for [[Conservative Partnership Institute|CPI]] (2023), State Freedom Caucus Foundation (2024), and 1792 Exchange (2024) reveals a tightly interlocked financial network with circular money flows, shared service entities controlled by insiders, zero-employee structures, family relationships on governing boards, and governance red flags including explicit refusal of public transparency.
1. The "Compass Professional" Control Node
Finding: SFOF's own 990 XML confirms that its books and records are kept by Compass Professional Inc at 300 Independence Ave SE, Washington DC 20003.
This is the same entity that:
- [[Conservative Partnership Institute|CPI]] paid $813,590 in 2023 for "Accounting/Consulting"
- Is beneficially owned by Russell Vought (former OMB Director, [[Conservative Partnership Institute|CPI]] network leader)
- Shares [[Conservative Partnership Institute|CPI]]'s physical address
Implication: The Compass entity doesn't just service [[Conservative Partnership Institute|CPI]]—it functions as the shared back-office for the entire network, controlling financial records for multiple organizations while being owned by a network insider. This is the infrastructure of control.
2. The Circular Money Flow (CONFIRMED)
[[Conservative Partnership Institute|CPI]] → SFOF → [[Conservative Partnership Institute|CPI]] Loop
| Direction | Amount | Purpose | | :----------------------------------- | :------------------ | :------------------ | ----- | | [[Conservative Partnership Institute | CPI]] → SFOF | $568,500 (2023) | Grant | | SFOF → CPI | $244,944 (2024) | "Program Support" | | Net flow to SFOF | $323,556 | |
CPI grants over half a million to SFOF, and SFOF grants a quarter million back to [[Conservative Partnership Institute|CPI]]. This is a textbook circular funding pattern. While the net flow is to SFOF, the bidirectional grants create financial opacity—each org can claim larger revenue figures and grant totals than the actual net movement of money.
SFOF Also Grants to:
- Renew Massachusetts Coalition Foundation Inc — $100,000 ("Program Support"), also at 300 Independence Ave SE
Another org at the same address receiving grants from the network.
3. The Zero-Employee Structure
Finding (Schedule O, Part V): SFOF states:
"The Foundation does not issue W-2s under its EIN. The compensation reported on Part VII and Schedule J is allocated respectively to related filing organization, State Freedom Caucus Network."
SFOF reports 0 employees and 0 volunteers, yet reports $939,649 in salary expenses. All personnel are technically employed by the State Freedom Caucus Network (501c4, EIN 87-3648308), a related entity.
This structure means:
- SFOF (the 501c3 "educational" arm) has no direct employees
- All staff are employed by the Network (501c4 "social welfare" arm which can do political activity)
- Compensation is "allocated" back, creating a cost-sharing arrangement that obscures who is actually directing the work
SFOF Officer Compensation (Split Across Orgs)
| Officer | SFOF Comp | Related Org Comp | Title |
|---|---|---|---|
| Andrew Roth | $163,678 | $86,322 | President, Director |
| Justin Ouimette | $92,200 | $67,800 | Sr. VP, Director |
| Suanne Edmiston | $52,139 | $57,533 | AZ State Director |
| Connie Hair | $45,391 | $65,364 | LA State Director |
Officers split their time between the 501c3 and 501c4, with some spending more time on the Network than the Foundation.
4. The Corrigan Family (Board Governance)
Finding (Schedule O, Part VI): SFOF discloses:
"Ed Corrigan and Patrick Corrigan have a family relationship."
- Ed Corrigan — Director of SFOF, also COO of [[Conservative Partnership Institute|CPI]] (where he earns compensation)
- Patrick Corrigan — Treasurer of SFOF
A father-son (or sibling) pair controls both the Director and Treasurer seats on a 4-person board. With only 2 of 4 directors being independent (per the filing), the Corrigans effectively have outsized influence over financial decisions.
5. The Three-Headed Entity (Schedule R)
SFOF's Schedule R discloses two related organizations:
| Entity | EIN | Type | Address | Activity |
|---|---|---|---|---|
| State Freedom Caucus Network | 87-3648308 | 501(c)(4) | 300 Independence Ave SE | Social Welfare |
| State Freedom Caucus Action | 87-3542487 | 527 (PAC) | 316 Pennsylvania Ave SE Ste 201 | Political |
Shared operations confirmed:
- ✅ Sharing of facilities
- ✅ Paid employees sharing
- ✅ Reimbursement paid to other org
This is a three-entity structure: 501c3 (tax-deductible donations for "education"), 501c4 (political advocacy), and 527 (direct political spending). Money flows in through the c3, personnel are shared via the c4, and political action happens through the 527.
6. Financial Distress Indicators (SFOF)
| Metric | BOY | EOY | Trend |
|---|---|---|---|
| Net Assets | -$367,370 | -$428,400 | ⬇️ Deepening |
| Total Liabilities | $761,613 | $813,040 | ⬆️ Growing |
| Unsecured Notes | $430,000 | $430,000 | ➡️ Static |
| "Due to Network" | $316,356 | $365,538 | ⬆️ Growing |
SFOF is technically insolvent, with liabilities exceeding assets by $428k. It carries $430k in unsecured notes (source unknown—likely [[Conservative Partnership Institute|CPI]] or the Network) and owes $365k to its own related entity. The organization has been operating at a loss every year since formation (2022).
7. CPI Schedule O Analysis
CPI's Schedule O contains standard boilerplate governance claims:
- Conflict of interest disclosure required ✅ (but Compass payments suggest non-enforcement)
- Compensation "approved by the board" and based on "data from similar organizations" ✅
- No uncertain tax positions ✅
- 990 reviewed by board prior to filing ✅
- Documents made available "upon request, as required by law" ✅
Notable absence: No explanation for the $1.6M in payments to Compass entities. No disclosure of the Vought ownership connection. These are material omissions.
8. 1792 Exchange — The "Anti-ESG" Vehicle
Overview
1792 Exchange (EIN 27-3707886) is registered c/o Cleta Mitchell per ProPublica BMF data, based in Springboro, OH. The organization's stated mission is to fight "woke corporations" and ESG policies. It has experienced explosive revenue growth:
| Year | Revenue | Growth |
|---|---|---|
| 2021 | $225,000 | — |
| 2022 | $2,295,000 | +920% |
| 2023 | $5,800,308 | +153% |
| 2024 | $8,145,397 | +40% |
Leadership: Daniel Cameron
CEO is Daniel Cameron, former Kentucky Attorney General (2019-2023) and unsuccessful Republican gubernatorial candidate. Total compensation: $366,869 (base $283k + $50k bonus + benefits).
- First Black American independently elected statewide in Kentucky history
- Transitioned directly from AG office to 1792 Exchange CEO in January 2024
- Federalist Society affiliate
Governance Red Flags 🚩
The 1792 Exchange filing reveals four critical governance failures:
| Governance Policy | Required? | 1792 Exchange |
|---|---|---|
| Whistleblower Policy | Best practice | ❌ NO |
| Document Retention Policy | Best practice | ❌ NO |
| CEO Compensation Review Process | Best practice | ❌ NO |
| Other Officer Compensation Process | Best practice | ❌ NO |
| Public Document Availability | Required | ❌ "No documents are available to the public" |
Schedule O, Part VI, Line 19: "No documents are available to the public."
This is a remarkable statement. While the law allows organizations to make documents available "upon request," explicitly stating that no documents are available goes beyond the norm and signals a deliberate opacity posture.
Board composition: 5 voting members, only 2 independent. No family/business relationships disclosed (unlike SFOF).
Major Contractors — The Money Trail
| Contractor | Amount | Service | Location |
|---|---|---|---|
| Joseph David Advertising LLC (now JDA Worldwide) | $1,738,447 | "Program support" | Indianapolis, IN |
| Fusion Law PLLC | $1,093,602 | "Program support" | Phoenix, AZ |
| Beck & Stone Inc | $299,435 | Media services | St. Petersburg, FL |
| Campbell Mille Payne PLLC | $250,000 | "Legal services to further program" | Dallas, TX |
Total to top 4 contractors: $3,381,484 — 44% of total expenses
- JDA Worldwide is a faith-based advertising firm "built on Biblical values" that specializes in nonprofit fundraising
- Fusion Law PLLC represents Arizona Republican legislative leaders (Speaker Ben Toma, Senate President Warren Petersen) in suits against EPA
Financial Profile
Books kept by MLA Companies in Springboro, OH (not Compass—1792 operates outside the CPI back-office)
| Metric | BOY | EOY |
|---|---|---|
| Total Assets | $947,659 | $2,334,048 |
| Total Liabilities | $669,374 | $1,614,840 |
| Net Assets | $278,285 | $719,208 |
| Other Liabilities | $0 | $1,038,223 |
The $1M+ "Other Liabilities" is disclosed as an operating lease liability (office lease), not a suspicious intercompany loan. Revenue growth is strong and the org is in positive net asset territory, unlike SFOF.
Network Architecture Summary
Bradley Foundation ($100k+)
│
▼
┌─── CPI (Hub) ───────────────────────┐
│ │ │ │
│ $568,500 $813,590 $846,525
│ │ │ │
│ ▼ ▼ ▼
│ SFOF Compass Pro Compass Legal
│ ($244,944 (Vought) (Mitchell)
│ back to CPI)
│ │
│ ┌────┼────┐
│ │ │ │
│ ▼ ▼ ▼
│ c3 c4 527
│ Found. Network Action
│ (Educ) (Advoc) (PAC)
│
│ Books kept by Compass Pro
│ Board: Ed & Patrick Corrigan (family)
│ Employees: 0 (all via Network)
└──────────────────────────────────────┘
┌─── 1792 Exchange (Satellite) ────────┐
│ CEO: Daniel Cameron (fmr KY AG) │
│ Registered c/o Cleta Mitchell │
│ Revenue: $225k → $8.1M (4 years) │
│ $1.7M → JDA Worldwide (advertising) │
│ $1.1M → Fusion Law (AZ litigation) │
│ "No documents available to public" │
│ No whistleblower / retention policy │
└──────────────────────────────────────┘
Open Items
-
1792 Exchange Schedule O — Downloaded and analyzed. Registered c/o Cleta Mitchell. Major governance red flags. - $430k Unsecured Notes (SFOF) — Who is the lender? Likely [[Conservative Partnership Institute|CPI]] (matches the $244k loan noted in earlier filings).
- Compass Professional ownership — Russell Vought confirmed as beneficial owner 2021-2023. Current status unknown.
- JDA Worldwide / Fusion Law — Are these entities connected to 1792 Exchange officers? Need beneficial ownership research.
- Daniel Cameron → Cleta Mitchell link — Is Cameron connected to the [[Conservative Partnership Institute|CPI]] network beyond the c/o registration? Check FEC, Federalist Society events.
Network Context
For a broader analysis of how [[Conservative Partnership Institute|CPI]] and these entities fit into the larger Christian Nationalist network, see the [[Christian_Nationalism_Network_Report_2026]] located in 14DocsandFiles/Intelligence_Briefs.
How the facts are checked. Every fact on this page is tied to at least one document. Primary (40) is the filing or record itself. Derived (29) is a stored query over primary rows. Reported (17) stays marked open until a primary record is found. Read the method.
Provenance
- Filed
- May 21, 2026
- Last updated
- Oct 22, 2026
- Verified
- 12 findings by Oct 24, 2026
- Pipeline origin
- 12 human