FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

STATEMENT OF REASONS OF VICE CHAIR STEVEN T. WALTHER AND 

COMMISSIONERS SHANA M. BROUSSARD AND ELLEN L. WEINTRAUB

This matter arose from a Complaint that NRA Victory Fund, Inc. (“the Committee”), a 

super PAC,1

 failed to collect or report employer and occupation information2 for 40 of its 42 

total contributors between its formation in early 2020 and the end of the 2020 election cycle, 

representing roughly $500,000 of the $510,500 it raised altogether during that period.3 After 

receiving the Complaint, as well as a Request for Additional Information (“RFAI”) from the 

Reports Analysis Division, the Committee amended its 2020 Year-End Report to add the missing 

information for nearly all contributors.4 The Committee also represented to the Commission that 

it had implemented a new policy that requires contributors to provide their occupation and 

employer information before their contribution will be deposited in the Committee’s bank 

account.5

 

The Commission’s Office of General Counsel (“OGC”) concluded that these actions by 

the Committee address the reporting failures raised by the Complaint, while also vindicating the 

Commission’s interest in ensuring transparency through accurate campaign finance reporting.6

As a result, OGC recommended that the Commission dismiss the allegations against the 

1 NRA Victory Fund, Inc., Amended Statement of Organization (Oct. 20, 2021).

2 See 52 U.S.C. § 30104(b)(3)(A); 52 U.S.C. § 30101(13)(A).

3 Compl. ¶¶ 1-2, 7-8; FEC Receipts: Filtered Results, FEC.GOV, https://www.fec.gov/data/receipts/?%E2%

80%8Ccommittee_id=C00741710&data_type=processed&committee_id=C00741710&two_year_transaction_perio

d=2020&line_number=F3X-11AI (last visited July 14, 2022) (showing contributions to NRA Victory Fund during 

the 2020 election cycle).

4 NRA Victory Fund, Amended 2020 Year-End Report at 6-22 (Mar. 9, 2021); Resp. at 1 (Mar. 22, 2021).

5 Resp. at 2.

6 First General Counsel’s Report (“FGCR”) at 8, MUR 7879 (NRA Victory Fund).

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of

NRA Victory Fund, Inc. and 

Christina M. Majors in her official 

capacity as treasurer 

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 ) 

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MUR 7879 

MUR787900053
MUR 7879 (NRA Victory Fund) 

Statement of Vice Chair Steven T. Walther and Commissioners Shana M. Broussard and Ellen L. Weintraub

Committee as a matter of prosecutorial discretion,7 but send a letter of caution reminding the 

Committee of its duties under the Federal Election Campaign Act of 1971, as amended (“the 

Act”).8 We disagreed that the issuance of a caution letter vindicates the Commission’s interest in 

ensuring transparency in campaign finance. We therefore voted to find reason to believe that the 

Committee violated the Act and to instruct OGC to negotiate a conciliation agreement with an 

appropriate civil penalty.9 Our colleagues voted against our motion.10

Caution letters can serve as a helpful reminder to a wayward committee of its duties 

under the Act.11 However, this Committee cannot reasonably be said to have carelessly lapsed in 

its duties. The Committee is closely related to another political committee that responded to an 

identical charge as recently as 2016.12 The Committee has shared a treasurer with the National 

Rifle Association of America Political Victory Fund (“the Political Victory Fund”) since the 

former’s creation.13 When the Committee enlisted Robert Owens as treasurer at its founding in 

early 2020, he had already been serving as treasurer to the Political Victory Fund since August 

2018.14 Owens joined the Political Victory Fund just two years after it successfully rebutted a 

charge that it, too, had failed to collect or report employer and occupation information. It did so 

by providing substantial evidence that it had used best efforts to obtain the information as 

required by the Act.15

There are no “best efforts” in evidence here. In fact, the Committee appears to have made 

virtually no effort to obtain employer and occupation information despite the relatively small 

number of contributors and the relatively large amount they each contributed.

16 Those 

7 See Heckler v. Chaney, 470 U.S. 821 (1985).

8 FGCR at 8-9, MUR 7879 (NRA Victory Fund).

9 Certification, MUR 7879 (NRA Victory Fund) (June 22, 2022); Certification, MUR 7879 (NRA Victory 

Fund) (June 23, 2022).

10 Id. 

11 See Certification, MUR 7594 (Enbridge) (July 2, 2020) (approving, inter alia, a recommendation that the 

Commission issue a caution letter to a group whose policy for making political contributions “suggest[ed] it may 

believe it may legally make contributions in connection with state and local elections”); Notification to Enbridge, 

Inc., et al. (July 27, 2020) (cautioning the group that such contributions would violate 52 U.S.C. § 30121).

12 Factual and Legal Analysis (“F&LA”) at 6-7, MUR 7879 (NRA Victory Fund).

13 Compare NRA Victory Fund, Original Statement of Organization (Mar. 10, 2020) (listing Robert Owens as 

treasurer); and NRA Victory Fund, Amended Statement of Organization (Oct. 20, 2021) (listing Christina M. 

Majors as treasurer); with National Rifle Association of America Political Victory Fund, Amended Statement of 

Organization (Jan. 31, 2020) (listing Robert Owens as treasurer); and National Rifle Association of America 

Political Victory Fund, Amended Statement of Organization (Oct. 20, 2021) (listing Christina M. Majors as 

treasurer).

14 National Rifle Association of America Political Victory Fund, Amended Statement of Organization (Sept. 

5, 2018).

15 F&LA at 10–11, MUR 6941 (National Rifle Association of America Political Victory Fund, et al.).

16 F&LA at 6, MUR 7879 (NRA Victory Fund); Statement of Policy Regarding Treasurers’ Best Efforts To 

Obtain, Maintain, and Submit Information as Required by the Federal Election Campaign Act, 72 FR 31438, 31439-

MUR787900054
MUR 7879 (NRA Victory Fund) 

Statement of Vice Chair Steven T. Walther and Commissioners Shana M. Broussard and Ellen L. Weintraub

contributions exceeded half a million dollars, which flowed into the 2020 general election 

without the transparency Congress has deemed necessary to our electoral processes.17 

The Committee waited until approximately five months after the election to disclose this 

information, long after that information would have aided members of the public in weighing 

their choices at the ballot box, and only at the urging of both an enforcement complaint and an 

RFAI. The Committee was or should have been aware of its obligations to collect and report—

or, at the very least, to make a good faith effort to obtain—this information.18 They chose not to 

do so. The Commission should have sought a civil penalty as a consequence of that choice. 

July , 2022 _________________________ 

Date Steven T. Walther 

Vice Chair 

July , 2022 _________________________ 

Date Shana M. Broussard 

Commissioner 

July 28, 2022 _________________________ 

Date Ellen L. Weintraub 

Commissioner

40 (June 7, 2007) (“The Commission does not intend to consider the best efforts defense . . . unless a respondent or 

audited committee asserts the facts that form the basis of that defense.”).

17 See supra, n. 2; see also Buckley v. Valeo, 424 U.S. 1, 66-67, 82-84 (1976) (upholding the part of the Act 

requiring disclosure of employer and occupation information, and saying of disclosure generally that it serves to, 

among other things, “alert the voter to the interests to which a candidate is likely to be responsive and thus facilitate 

predictions of future performance in office,” “deter actual corruption and avoid the appearance of corruption by 

exposing large contributions and expenditures to the light of publicity,” and “detect violations of the contribution 

limitations”). 

18 See supra, n. 16. 

MUR787900055