Details from Kellyanne Conway’s Public Financial Disclosure Report

ProPublica sent out an appeal on Facebook to help out with their reporting related to a bunch of White House staffers’ financial disclosure forms released by the Trump Administration on Friday, March 31st, 2017. I’m not a journalist but I’ve been spending a lot of time worrying about rampant corruption in the Trump Administration so I thought I would try to lend a hand. If you notice any errors or inaccuracies please leave me a comment so I can look into it. The first OGE Form 278e I looked at was the filing by Kellyanne Conway who is currently serving as Counselor to President Donald Trump.

Section 1: Filer’s Positions Held Outside United States Government

Conway’s filing discloses that she was President and CEO of “the polling company/WomenTrend” for 22 years until January 2017. I couldn’t find anything online about this company other than a shell Facebook page with no activity.

In an article entitled “Kellyanne Conway’s Political Machinations” published in The New Yorker in October 2016, Ryan Lizza writes:

Conway founded her own firm, the Polling Company, in 1995, and developed a niche advising corporations—American Express, Hasbro, Vaseline, and others—about consumer trends, especially among women. Her most well-known political clients, including Gingrich, Mike Pence, and Dan Quayle, have been socially conservative Republicans who needed help reaching female voters. “She spent most of her career looking at polling data, with a particular emphasis on consumers and on women,” Gingrich said. “So she sees them more holistically than a lot of political pollsters.”

One interesting side note from this article, Conway identified Charlie Black as a mentor. Black was a partner in Black, Manafort, Stone & Kelly., a Washington DC lobbying firm with extensive connections with the Reagan, George H. W. Bush and Clinton administrations, as well as with corrupt foreign government officials from Somalia, the Philippines, Zaire and Angola.

The other partner of note from this same firm is Paul Manafort, who served as Trump’s campaign manager in 2016. Manafort’s ties with exiled Ukrainian President Viktor Yanukovych are currently under scrutiny by the media and are likely being investigated by the FBI as part of their Russian counter-intelligence probe. So at the very least one could draw the conclusion that Conway’s career was heavily influenced by powerful Washington DC lobbyists who did business with corrupt foreign officials.

Section 2: Filer’s Employment Assets & Income and Retirement Accounts

Conway’s financial disclosures in Section 2 include $800K of “business income” in 2016 and two 401Ks that could be worth as much as $750K, both from from “the polling company/WomenTrend”.

Section 3. Filer’s Employment Agreements and Arrangements

Conway did not disclose anything in this section.

Section 4: Filer’s Sources of Compensation Exceeding $5,000 in a Year

Conway disclosed income from an extensive list of 75 different consulting and speaking engagements including:

• Political lobbyists, think tanks, PACs etc.
  • The 2016 Committee – A super PAC formed to raise funds for the presidential campaign of Republican Ben Carson.
  • Alabama Policy Institute (API) – A conservative policy think tank.
  • American Conservative Union – A conservative lobbyist organization.
  • American Principles Project – A conservative think tank.
  • Americans for Prosperity Foundation / Americans for Prosperity – Michigan / Americans for Prosperity – Ohio – An influential conservative political advocacy group funded by David H. Koch and Charles Koch.
  • Catholic League for Religious and Civil Rights (The Catholic League) – An American Catholic anti-defamation and civil rights organization.
  • Center for Security Policy – A conservative think tank associated with Frank Gaffney Jr identified by the Southern Poverty Law Center as an anti-muslim hate group.
  • Center for Medical Progress – A controversial anti-abortion organization founded by David Daleiden that infiltrated Planned Parenthood under false pretenses and secretly recorded executives during meetings. Daleiden and an associate were charged with 15 felonies for filming without consent and criminal conspiracy to invade privacy. Planned Parenthood was cleared of any wrongdoing.
  • Citizens United / Citizens United Political Victory Fund / Presidential Coalition – A controversial political advocacy group focused on loosening rules governing campaign finance associated with political activist David Bossie who served as Deputy Campaign Manager for Donald Trump’s presidential campaign.
  • Concerned Women for America (CWA) – a conservative Christian activist group that promotes an anti-feminist approach to politics.
  • The Ending Spending Fund – A PAC associated with Joe Ricketts focused on curbing earmark spending policies in Congress.
  • Fieldstead and Company – Personal donor organization funded by wealthy evangelical Christian activist Howard Ahmanson Jr. which contributed over a million dollars to the campaign to pass California Proposition 8 opposing same sex marriage.
  • Freedom Partners / Association for American Innovation – A political advocacy group structured as a chamber of commerce associated with David H. Koch and Charles Koch which sponsors various Republican politicians and conservative groups.
  • FreedomWorks of America – A political advocacy group associated with the Tea Party movement.
  • Independent Women’s Voice – A conservative political advocacy group focused on advocating conservative policies to female voters who identify as independents, sister organization to Independent Women’s Forum.
  • John Locke Foundation – a conservative think tank in North Carolina funded by the family of Art Pope.
  • Judicial Crisis Network – A conservative political campaign organization that promotes judicial appointees. In an article entitled “Conservative group launches ad blitz pressuring Senate Dems to back Neil Gorsuch“, Daniel Bush and Geoffrey Lou Guray from PBS document the $1 million spent by JCN to promote the Gorsuch nomination with Senate Democrats.
  • Judicial Crisis Network (JCN) / Judicial Education Project – A political campaign organization associated with Carrie Severino, Not to be confused with the NJEP program sponsored by Legal Momentum.
  • Keep the Promise, Inc / KTP PAC / Trusted Leadership PAC – These are a collection of super PACs formed to raise money for the Presidential campaign of Republican Ted Cruz. In an article entitled “Meet Ted Cruz’s Billionaire Donors“, Eliana Johnson from the National Review documents a  collection of PACs that unified into a single super PAC called Keep the Promise PAC. In an article entitled “First look: Ted Cruz allies launch new super PAC“, Fredreka Schoulen of USA Today describes the formation of Trusted Leadership PAC.
  • Michigan Prosperity Project – A non-profit organization associated with Evan Cruse whose LinkedIn page describes himself as a Legislative Assistant at the Michigan House of Representatives. The stated goal of the organization is to “… advocate for freer markets and a more efficient economy.” Given he just graduated from Michigan State in 2016, this site seems like an effort to position himself as an up and coming political operative in hopes of starting a career as a policy analyst at some conservative think tank. Why he would be paying Kellyanne Conway for consulting services with money he raised from donations to his nonprofit is unclear.
  • National Republican Senatorial Committee (NRSC) – Republican Hill Committee for the United States Senate that works to elect Republicans to the Senate. Why the NRSC is spending taxpayer money to pay lobbyists like Kellyanne Conway is unclear.
  • National Republican Congressional Committee – A political committee devoted to increasing the Republican majority in the U.S. House of Representatives.
  • National Rifle Association (NRA) – a non-profit organization that advocates for gun rights.
  • National Right to Life Committee (NRLC) – The oldest and largest anti-abortion organization in the United States which is associated with the National Conference of Catholic Bishops (NCCB).
  • National Federation of Republican Women (NFRW) – Grassroots political organization that works to recruit and elect Republican candidates, to advocate the Republican philosophy and initiatives, and to advance women in the political process.
  • National Foundation for Women Legislators (NWFL) – Tax exempt foundation that assists women legislators with public opinion and legislative issues.
  • Open Primaries – an advocacy organization promoting open primaries and discouraging closed primaries.
  • Reclaim New York (Reclaim NY) – non-profit organization focused on civic engagement with the government.
  • Republican Governors Association (RGA) – a tax-exempt 527 group consisting of Republican governors currently chaired by Governor of Wisconsin Scott Walker.
  • Students for Life of America (SFLA) – An anti-abortion organization focused on training and equipping college, high school, medical and law school students to “defend the preborn and help their mothers”.
  • Susan B. Anthony List – an anti-abortion organization that supports pro-life politicians, primarily women, through its SBA List Candidate Fund PAC.
  • Tea Party Patriots – a conservative American political organization that promotes fiscally responsible activism as part of the Tea Party movement.
  • Young America’s Foundation (YAF) – A conservative organization that sends conservative speakers to colleges and universities.
• Political campaigns
  • Donald J. Trump for President / Trump for America, Inc.
  • Eric Holcomb – Republican Governor of Indiana, formerly lieutenant Governor under Mike Pence.
  • Gary Palmer – Republican currently serving as U.S. Representative from Alabama’s 6th congressional district and President of the Alabama Policy Institute (API).
  • John Fleming – Republican currently serving as deputy assistant secretary for health technology in HHS, formerly U.S. Representative from Louisiana’s 4th district. In an article entitled “Louisiana’s Fleming and the ‘one-party-state’ conspiracy“, Steve Benen from MSNBC documents Fleming’s affinity for far-right conspiracy theories.
  • Lee Zeldin – Republican currently service as U.S. Representative for New York’s 1st District.
  • Mike Pence – Republican currently serving as Vice President of the U.S., and previously as Governor of Indiana and U.S. Representative for Indiana’s 2nd congressional district. Known as a supporter of the Tea Party.
  • Rod Blum – Republican currently serving as U.S. Representative from Iowa’s 1st district. Known as a supporter of the Tea Party, he supports anti-abortion policies and the defunding of Planned Parenthood.
  • Steve King – Republican currently serving as U.S. Representative from Iowa’s 4th District. King supports banning the use of federal funding for abortions including for victims of statutory rape or incest, and defended Todd Akin’s controversial statement about “legitimate rape“.
  • Tim Huelskamp – Republican who served as U.S. Representative from Kansas’s 1st District. He was rumored to have been a candidate for Secretary of Agriculture for the Trump Administration.
• Corporations, Industry Groups and Trade Associations
  • American Association for the Advancement of Science (AAAS) – the worlds largest general scientific society and publisher of the journal Science.
  • American Road & Transportation Builders Association (ARTBA) – a federation whose goal is to aggressively grow and protect transportation infrastructure investment and provide a global competitive edge to its 7,700 public and private sector members.
  • Biospringer North America – Yeast producer and subsidiary of French company Lesaffre.
  • Cambridge Analytica – Technology company that provides audience insight and engagement products and services.
  • Consumer Healthcare Products Association – A trade association representing over-the-counter drugs and nutritional supplements.
  • CRC Public Relations – A PR firm that specializes in media relations, social media and issues management for a wide variety of companies including Visa, Chevron and Microsoft.
  • Duane Morris – A Trenton, NJ law firm with a global presence in the U.S., UK and Asia.
  • Hellerman Baretz Communications, LLC – A New York based communications firm that split up in 2016. One group of partners left to form Baretz+Brunelle and the other partner is at Hellerman Communications.
  • Highfive – A technology company providing video conferencing solutions.
  • Indeed – A technology company with a popular job site.
  • Indiana Energy Association – Trade group representing Indiana utilities.
  • Innovative Advertising (INN) – Advertising agency located in Louisiana, a division of People Who Think which also has a division called Innovative Politics whose website states: “Innovative Politics is proud to have been a part of President-elect Donald J. Trump’s historic victory. Innovative Politics served a key role in the advertising team following the Republican National Convention.”
  • Jobvite, Inc. – Provider of recruiting services to corporations.
  • Laffer Associates – An economic research and consulting firm run by libertarian Arthur Laffer who is known for stating in 2006 that  “The US economy has never been in better shape“.
  • MarketCounsel – a regulatory compliance consulting firm serving investment advisors. See “MarketCounsel Summit weathers Trump mayhem as Scaramucci and Priebus bail and Kellyanne Conway makes a night flight to Miami” for coverage of one of her speaking engagements.
  • National Multifamily Housing Council (NMHC) – Industry advocacy group serving the apartment industry.
  • National Ocean Industries Association (NOIA) – Trade association representing domestic offshore entery and related industries.
  • The Olson Group (OLG) – An Alexandria VA based consulting firm that serves public safety professionals.
  • Point72 Asset Management – A family controlled investment company founded by Steven A. Cohen which is the successor to SAC Capital Advisors, a hedge fund which pleaded guilty to federal insider trading charges and paid a $1.8 billion fine.
  • Women’s Conference for Florida – a conference for “accomplished women … to expose topics of interest to professional women”. Conway was a keynote speaker for the 2016 conference along with many other women from across the political spectrum. I found one blogger’s account of her talk here.
• Educational Organizations and Institutions
  • Arlington County Public Schools – Public school district in Arlington, VA.
  • Catholic University of America – Catholic university located in Washington DC that is affiliated with Trinity Washington University (formerly Trinity College) from which Conway received a BA degree in political science in 1992.
• Unknown sources of compensation
  • NUSA, Arlington VA –  Section 4, #67 references “NUSA, Arlington VA”. I was unable to definitively determine the identity of this organization. Here are some possibilities:
    • NumbersUSA – An anti-immigration organization located in Arlington, VA associated with Roy Beck.
    • Nestlé USA – The U.S. subsidiary of Swiss food conglomerate Nestlé. According to this press release, Nestlé is moving it’s U.S. headquarters to Arlington VA.
    • There is also usage of the term “Nusa” associated with the U.S. Navy and/or U.S. Marine Corps but I was unable to determine what it means.

Section 5: Spouse’s Employment Assets & Income and Retirement Accounts

Section 5 cover’s financial disclosures related to Conway’s spouse George T. Conway III, a Harvard graduate and partner in Wachtell, Lipton, Rosen & Katz, which is known as one of the most profitable law firms in the U.S. His practice focuses on litigation involving securities, mergers and acquisitions, contracts, and antitrust. His partnership share is valued in excess of $1 million, and his 401K is also valued in excess of $1 million. He can be characterized as a multi-millionaire at a minimum.

In an interesting twist, he was one of the lawyers who represented Paula Jones in her lawsuit against Bill Clinton,  the legal precedents for which may allow similar lawsuits to proceed against President Donald Trump.

He has been rumored to be a candidate for a variety of high level positions in the U.S. Department of Justice including Solicitor General and Assistant Attorney General.

Section 6: Other Assets and Income

Conway disclosed a variety of assets including cash, money market funds and securities that are valued between $6.5 million and $31 million. The majority of these assets are liquid (cash or money market accounts). They own stock in Altria / Phillip Morris, Kraft, Phizer, and Modelez.