Cummins explained to the board that Ackerman and other vendors were generating enormous expenses and getting paid through multiple entities, in a way that obscured payments. One such arrangement involved a company called Membership Marketing Partners, which provides direct-mail fundraising. In 2017, the NRA paid MMP nearly $12 million. At the same time, it directed almost $800,000 to a firm called Allegiance Creative Group, for “fundraising counsel.” Allegiance doesn’t have a web site, but, according to state filings, at least 10 of its 15 employees also work at MMP. The president and CEO of both companies is Gurney Sloan, who previously worked as a senior vice-president at Ackerman McQueen. This kind of arrangement is not illegal, but, as the former IRS manager Marc Owens told me, “multiple names for the same entity suggest an effort to disguise the extent of contact. Most organizations have centralized accounting so they can track how much is owed.”

After Cummins’s presentation ended, Brewer took over to discuss what the agenda from the meeting refers to as “related party transactions” —  arrangements that could improperly enrich NRA leaders or their associates. Before he spoke, most of the staff members were asked to leave the room. But the memos suggest some of the concerns. They assert that about a quarter of the organization’s staff is “now managed by former employees” of Ackerman who have been hired by the NRA, creating “financial conflicts of interest.” As an example, the documents note $2.6 million paid to a corporate entity called Under Wild Skies, whose annual reports list Tony Makris as president, the same position he holds with the Mercury Group. “Under Wild Skies” is also the name of a TV show, broadcast on the Outdoor Channel, that features Makris and his guests, including Revan McQueen, tracking big game in such far-flung locales as Botswana’s Okavango Delta. (“Under Wild Skies” used to appear on mainstream TV, but NBC Sports ended its run after Makris, on camera, shot an elephant in the face.) According to a recent article in The New York Times, the NRA has paid Under Wild Skies some $18 million since 2010. Until recently, Tyler Schropp, who runs the NRA’s advancement team, the large-donor program, also served as the treasurer of Under Wild Skies. Brewer, the lawyer, told the Times that Schropp had “a minuscule interest” in the company, and that he had relinquished his stake. But NRA officials were evidently concerned; in documents filed soon after the audit committee met in July, Schropp’s name was listed among the officers of Under Wild Skies, but had been crossed out by hand.