The National Rifle Association spent $30 million to help elect Donald Trump—more than any other independent conservative group. Most of that sum went toward television advertising, but a political message loses its power if it fails to reach the right audience at the right time. For the complex and consequential task of placing ads in key markets across the nation in 2016, the NRA turned to a media strategy firm called Red Eagle Media.
One element of Red Eagle’s work for the NRA involved purchasing a slate of 52 ad slots on WVEC, the ABC affiliate in Norfolk, Virginia, in late October 2016. The ads targeted adults aged 35 to 64 and aired on local news programs and syndicated shows like Jeopardy! and Wheel of Fortune. In paperwork filed with the Federal Communications Commission, Red Eagle described them as “anti-Hillary” and “pro-Trump.”
The Trump campaign pursued a strikingly similar advertising strategy. Shortly after the Red Eagle purchase, as Election Day loomed, it bought 33 ads on the same station, set to air during the same week. The ads, which the campaign purchased through a firm called American Media & Advocacy Group (AMAG), were aimed at precisely the same demographic as the NRA spots, and often ran during the same shows, bombarding Norfolk viewers with complementary messages.
The two purchases may have looked coincidental; Red Eagle and AMAG appear at first glance to be separate firms. But each is closely connected to a major conservative media-consulting firm called National Media Research, Planning and Placement. In fact, the three outfits are so intertwined that both the NRA’s and the Trump campaign’s ad buys were authorized by the same person: National Media’s chief financial officer, Jon Ferrell.
“This is very strong evidence, if not proof, of illegal coordination,” said Larry Noble, a former general counsel for the Federal Election Commission. “This is the heat of the general election, and the same person is acting as an agent for the NRA and the Trump campaign.”
Reporting by The Trace, which has teamed up with Mother Jones to investigate the NRA’s political activity, shows that the NRA and the Trump campaign employed the same operation—at times, the exact same people—to craft and execute their advertising strategies for the 2016 presidential election. The investigation, which involved a review of more than 1,000 pages of Federal Communications Commission and Federal Election Commission documents, found multiple instances in which National Media, through its affiliates Red Eagle and AMAG, executed ad buys for Trump and the NRA that seemed coordinated to enhance each other.
Individuals working for National Media or its affiliated companies either signed or were named in FCC documents, demonstrating that they had knowledge of both the NRA and the Trump campaign’s advertising plans.
Experts say the arrangement appears to violate campaign finance laws.
“I don’t think I’ve ever seen a situation where illegal coordination seems more obvious,” said Ann Ravel, a former chair of the Federal Election Commission, who reviewed the records. “It is so blatant that it doesn’t even seem sloppy. Everyone involved probably just thinks there aren’t going to be any consequences.”
National Media, the NRA, the Trump campaign, and the White House did not respond to multiple requests for comment. AMAG does not appear to have any employees or contacts independent of National Media; a lawyer who has been identified in news accounts as representing AMAG did not respond to multiple requests for comment.
The web site for National Media, which is based in Alexandria, Virginia, describes it as “a nationally recognized leader in media research, planning, and placement for issue advocacy, corporate, and political campaigns,” and says that its “goal is to maximize every dollar that our clients spend on their media.” Those clients have included the Republican National Committee as well as the GOP’s congressional and senatorial campaign committees.
Publicly available corporate documents do not indicate who owns or runs AMAG, but a lawyer representing the company acknowledged to the Daily Beast in 2016 that it was affiliated with National Media. PBS has described AMAG as an “offshoot” of National Media. The Trump campaign paid AMAG more than $74 million for “placed media” in September and October of 2016.
Red Eagle Media, the firm that the NRA used to place its pro-Trump ads, is merely an “assumed or fictitious name” used by National Media, according to corporate records. Corporate, FEC, and FCC records for all three entities list the addresses of 815 Slaters Lane or 817 Slaters Lane, a pair of adjacent brick buildings that share a parking lot in the historic Old Town section of Alexandria.
The NRA was free to spend as much money as it wanted on behalf of Trump in 2016. But under federal election law, if an independent group and a campaign share election-related information, then the group’s expenditures no longer qualify as independent and are instead treated as in-kind donations, subject to a $5,000 limit.
When an outside group and a candidate use the same vendor, staffers working for either client are prevented by law from sharing information with each other. Typically, such vendors make staffers sign a company “firewall” policy, which functions as a pledge not to coordinate and an acknowledgment that there are civil and criminal penalties for doing so. Under the law, National Media staffers working for Trump should have been siloed from those working for the NRA. Documents suggest, instead, a synchronized effort.
Records in the FCC “public inspection files”—files that television stations maintain in order to comply with transparency regulations around political advertising—show that Red Eagle and AMAG often bought ads around the same time, on the same stations, for the NRA and the Trump campaign, respectively. During…