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In 2019, Assal Ravandi appeared to be riding high, and in especially glamorous company. 

The “Vettys,” her glitzy awards show recognizing some of the most respected veterans’ advocates in America, had all the trappings of a Hollywood awards show, as well as a historic new venue: the Watergate Hotel in Washington, D.C. A parade of special guests graced the red carpet that year, including CNN anchor Jake Tapper, actor Casey Affleck, and then-Acting Navy Under Secretary Thomas Modley. Financial underwriters included Goldman Sachs, Koch Industries, and Mark L. Rockefeller, an Air Force veteran and CEO of StreetShares.

The Vettys, and Ravandi’s related non-profit, the Academy of United States Veterans (AUSV), are meant to support the military and veteran community’s most respected advocates and allies. This is accomplished chiefly through the Vettys, which signal- boosts worthy figures and organizations, as well as other social and philanthropic activities. But behind the scenes, multiple current and former employees tell Task & Purpose they labored through internal chaos for an organization with sometimes questionable financial practices, and whose actual impact on the veterans’ community appears to be dubious. 

WASHINGTON, DC - JANUARY 20: Assal Ravandi, Founder & CEO, The Academy of United States Veterans Foundation, speaks during the 3rd Annual Vetty Awards at The Mayflower Hotel on January 20, 2018 in Washington, DC.  (Photo by Paul Morigi/Getty Images)
Assal Ravandi, Founder & CEO, The Academy of United States Veterans Foundation, speaks during the 3rd Annual Vetty Awards at The Mayflower Hotel on January 20, 2018, in Washington, DC. (Photo by Paul Morigi/Getty Images)

“After working there for six months, I still don’t know what the non-profit does to help veterans,” one former employee said. They and others added that Assal’s treatment of employees was a constant concern. 

“Assal, on more than one occasion, screamed at her employees over trivial matters,” said Connor Dalton, an Army veteran and former AUSV employee. “These extreme outbursts resulted in many of the staff complaining of a hostile work environment. Instead of confronting the legitimate claims by the staff, these complaints were met with contempt and were subsequently disregarded.”

Today, there are exponentially more veteran-focused non-profits than there are U.S. service members deployed in the Middle East. Many sprung up in the wake of 9/11 and provide acts of charity, community service, and aid to those who served. Camouflaged amidst the legitimate organizations, however, are dozens of disreputable actors that exploit public gratitude towards veterans for their own dubious purposes.

In the Vettys, Ravandi established an organization that promised to distinguish the good entities from the questionable ones. But instead, veterans’ advocates, philanthropy experts, and 17 former employees say the Vettys and AUSV have skirted charity best practices and, often served as a vehicle for its founder to burnish her public profile. The organization has allowed Ravandi to hobnob with movie and television stars and become a prominent veteran voice featured on programs like Tapper’s CNN show “The Lead”.

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In an interview, Stephanie Kalivas, an analyst at the non-profit watchdog group CharityWatch, described some of AUSV’s activity detailed in this story as “highly suspicious.” She also raised red flags and potential conflicts of interest over the information provided in the non-profit’s public disclosures, some of which could incur penalties from various bodies that regulate nonprofits. “[Ravandi] doesn’t seem like she’s on top of what she should be doing,” Kalivas said. 

Many of what ex-employees describe as the organization’s deep-seated issues played out during the 2019 Vettys. As logistical problems arose throughout the night, Ravandi lashed out at staff in text messages, threatening at one point to “fire everyone,” according to an exchange obtained by Task & Purpose.

“Can you guys grow up and actually do what you were supposed to be doing because this is a complete shit show,” read another message from her.

Numerous problems stemmed from Ravandi’s loose management of money, according to former staffers and internal documents obtained by Task & Purpose. Hours before the 2019 festivities began, she texted staff that a bank had “blocked” her card, according to one message. According to budget documents, event costs had ballooned, in part for expenses that reflected the gilded nature of the event: $12,000 worth of champagne, $11,000 in celebrity air travel, and silver and gold statuettes depicting “boots on the ground” that cost $7,000. (The organization’s most recent financial data, from 2019, reports less than $500,000 in revenue.) In an e-mail, Ravandi said that event-related expenses have often triggered her bank to freeze her business account so as to “ensure our card is not stolen.”

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A “Vetty” award (Photo by Willjfowler/Wikimedia Commons)

Staff members often weren’t always clear whether charges were going on one of her company cards or a personal one. As with at least one previous AUSV event, Ravandi had a hair and make-up team. She also purchased herself and staff glitzy dresses and hotel rooms. (For the 2019 Vettys, Ravandi reserved herself the Watergate’s presidential suite.) Yet some had previously seen troubling company expenses or heard Ravandi complain about being broke. 

An internal text message from the time mentions an “allotted dress budget” of $400 per employee. In addition, a source said that after she bought a dress for the occasion, it was reimbursed with a check from the non-profit. (Another source provided a text in which her then-supervisor requested a receipt for her dress to secure reimbursement.)

Ravandi acknowledged to Task & Purpose that she used organizational funds for hotel rooms, travel, and formalwear, but described these expenses as necessary and “very nominal.” She estimated, for instance, that less than $2,000 in non-profit money had been spent on staff clothing over the last six years and defended such purchases as critical to ensuring an event’s formal atmosphere. 

Meanwhile, guests who dropped hundreds or thousands of dollars on tickets were frustrated by the event’s slapdash seating chart. Others complained that a promised sit-down dinner was subpar, with one attendee describing it to Task & Purpose as “a buffet of shitty food.” Ravandi contended that there weren’t issues over the quality of food, but rather the quantity. “Food was consumed beyond the amount we had ordered,” she said.

There were other bizarre moments that evening. During the ceremony, for instance, one of the two models tasked with ushering award-winners offstage fainted. 

WASHINGTON, DC - JANUARY 20:  Actor Casey Affleck and the Founder and CEO of the Academy of United States Veterans Assal Ravandi at the 4th Annual Vetty Awards at The Watergate Hotel on January 20, 2019 in Washington, DC.  (Photo by Shannon Finney/Getty Images)
Actor Casey Affleck and the Founder and CEO of the Academy of United States Veterans Assal Ravandi at the 4th Annual Vetty Awards at The Watergate Hotel on January 20, 2019, in Washington, DC. (Photo by Shannon Finney/Getty Images)

Meanwhile, Ellen Haring of the Service Women’s Action Network (SWAN), an awardee that night, said she was privately fuming over Ravandi’s decision to invite Affleck, an accused sexual harasser. SWAN’s chief mission is to end military sexual assault. Ravandi said she provided Haring with significantly more time than initially allotted to discuss SWAN’s mission, and defended Affleck.

“When an Oscar-winning actor — who was not even convicted of a crime and who has shown a great deal of compassion for our community — agrees to join us to share his spotlight with our community, we welcome him,” she said of Affleck, who apologized for contributing to an “unprofessional environment” on set and, in 2010, settled two lawsuits out of court alleging sexual harassment. “Veterans more than any other groups in our country know the power of second chances and also the negative power of assumption and perception.” (While SWAN was supposed to be involved in the next Vettys, it later backed out. Haring said one reason for this was that Ravandi tried to broker a merchandising deal between the non-profit and the veteran t-shirt brand Ranger Up, whose t-shirts include slogans like “In my defense, I was left unsupervised” and “I am comfortable with violence.”)

As these and other issues collided, ticket-holders and special guests felt that Ravandi had over-promised and under-delivered. Some asked for their money back, according to two sources who worked the event, as well as Ravandi, who said she provided some guests credit for future gatherings and refunded a total of $2,500 to others. 

Over the following weeks, according to interviews, e-mails, and text messages, Ravandi struggled to compensate vendors and staff, including the fainting model, who told Task & Purpose that she was never paid. (The model, like most sources for this story, requested anonymity for fear of adverse professional consequences.) 

While Ravandi had previously used AUSV funds to take staff on a three-day post-Vettys “recovery” trip to Las Vegas, she made clear that year that money was scarce, and any attendee would have to foot their own bills, according to three former employees.

WASHINGTON, DC - JANUARY 20: Seda Goff (L) is presented with a Vetty Award by Mark Rockefeller and Sofia Pernass during the 3rd Annual Vetty Awards at The Mayflower Hotel on January 20, 2018 in Washington, DC.  (Photo by Paul Morigi/Getty Images)
Seda Goff (left) is presented with a Vetty Award by Mark Rockefeller and Sofia Pernass during the 3rd Annual Vetty Awards at The Mayflower Hotel on January 20, 2018, in Washington, DC. (Photo by Paul Morigi/Getty Images)

By this point, many staffers said they felt mistreated and weren’t interested in a trip with Ravandi. In the wake of the 2019 event, some quit. Rockefeller also severed ties with AUSV. In an interview with Task & Purpose, Haring called Ravandi’s organization “questionable and sketchy,” adding that “she talks a big game, but she doesn’t come through, as far as I can tell.”

Cynics view AUSV as a non-profit used almost entirely as a vehicle for Ravandi to secure clout. While six years old, AUSV has only offered detailed financial information for one year — 2019 — even as its finances likely mandated more public reporting. Unlike many non-profits, AUSV also doesn’t release donor information or annual reports. Instead, AUSV has sketched out vague accomplishments like the “number of new champions or stakeholders” it has “recruited.” 

After being presented with the findings of Task & Purpose’s investigation, Ravandi, herself a U.S. Army veteran, argued that “if someone who is no longer here claims they do not know what we do, it is only because they never cared about the cause.” While she acknowledged certain allegations were true, she disputed others. She further cast critical sources as “unreliable” actors who “must have really gotten their feelings hurt” or “cannot keep up with the pace that is required to keep an organization going.” 

“AUSV is a cause-based and mission-based organization,” she added. “It is a way of life.” 

‘I can safely say what we do here saves lives’

WASHINGTON, DC - JANUARY 20:  Jake Tapper receives a People's Choice Vetty during the 3rd Annual Vetty Awards at The Mayflower Hotel on January 20, 2018 in Washington, DC.  (Photo by Paul Morigi/Getty Images)
CNN Anchor Jake Tapper receives a People’s Choice Vetty during the 3rd Annual Vetty Awards at The Mayflower Hotel on January 20, 2018 in Washington, DC. (Photo by Paul Morigi/Getty Images)

Ravandi sometimes used her second last name, Masomi, including while working in Hollywood in the early 2000s. The decision to go by this other name, she said, was mainly meant to distance her from uncomfortable family memories from her birth country, Iran. (She also said that the true spelling of her second last name is Masoumi, but that it was misspelled on paperwork by Immigration and Naturalization Services.)

In 2005, she joined Paramount Pictures where she worked in a variety of roles, including as an assistant to the company’s former chief, Jonathan Dolgen. She became a freelance publicist in 2008, and during former President Barack Obama’s first inaugural weekend, Ravandi hosted “The Purple Ball,” an unofficial event focused on bipartisanship. 

But as her career accelerated, her personal financial problems did, too. In 2009 and 2010, Masomi was sued in Los Angeles small claims court by two separate limousine companies for alleged contract breaches, according to court records. Then, in 2011, Bank of America filed a collections case against her. The suits were all filed under her “Masomi” moniker. Ravandi said that the limo charges had been paid and claimed that financial institutions exploited her monetary issues. “I do not believe I should apologize for being poor,” she said.

According to LinkedIn, Ravandi joined the Army in 2010 and served for four years. While she claims on her LinkedIn profile to have been an intelligence analyst, an Army spokesperson said she was, in fact, an automated logistical specialist, a role mostly focused on supervising equipment and other Army infrastructure. Ravandi deployed to Afghanistan between March and November 2013, according to Army records. Her awards and decorations include the Army Commendation and Achievement Medals and the Combat Action Badge.

"Cottonbalers" from 3rd Battalion, 7th Infantry Regiment, 4th Infantry Brigade Combat Team, 3rd Infantry Division, raise their hands to answer a vocabulary question from Spc. Assal Ravandi, an automated logistics specialist with Headquarters and Headquarters Company, 3rd Bn., 7th Inf. Regt., Aug. 30, in a classroom on Fort Stewart, Ga. The vocabulary competition was part of a presentation the Soldiers created for battalion leadership to show their grasp of the Dari language after having spent five weeks in an intensive language training program created by Ravandi, a native Dari speaker.
“Cottonbalers” from 3rd Battalion, 7th Infantry Regiment, 4th Infantry Brigade Combat Team, 3rd Infantry Division, raise their hands to answer a vocabulary question from Spc. Assal Ravandi, an automated logistics specialist with Headquarters and Headquarters Company, 3rd Bn., 7th Inf. Regt., Aug. 30, in a classroom on Fort Stewart, Ga. The vocabulary competition was part of a presentation the Soldiers created for battalion leadership to show their grasp of the Dari language after having spent five weeks in an intensive language training program created by Ravandi, a native Dari speaker. (Photo by Sgt. Mary Katzenberger/U.S. Army)

Shortly after she got out as a specialist in 2015, she held the first Vettys in a modest space at George Washington University, her alma mater. She told Task & Purpose that the organization was initially funded by her military savings and VA disability funds. “I skipped paychecks so the organization can survive,” she said.

AUSV is technically composed of two separate entities: a 501(c)(6) called the Academy of United States Veterans and a related 501(c)(4): the Academy of United States Veterans Foundation. 

The foundation emerged first, in 2017. For 2017 and 2018, the foundation didn’t file exhaustive 990 reports but rather “e-Postcards,” which provide little information and are only permitted for groups that receive less than $50,000 annually. Yet the organization didn’t qualify for these limited disclosure requirements. 

Ravandi herself said the foundation brought in more than $500,000 in its maiden year. (AUSV’s website lists at least $65,000 in donations made by the foundation to other non-profits in 2017.)

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Ravandi said the organization’s IRS filings were complicated by arcane rules and a long delay in getting the non-foundational 501(c)(6) approved. (In 2018, the IRS revoked the organization’s 501(c)(6) status due to a lack of documentation. The status was reinstated earlier this year.) 

“We are filing our first two years now that we have the correct determination letter from IRS,” Ravandi told Task & Purpose, adding that they will correctly note fundraising totals on these new, more thorough forms. 

Roughly a third of the money raised by the foundation during its first year went to The Coalition to Salute America’s Heroes, one of the first post-9/11 veterans’ charities to face scrutiny in Congress and the press. The group’s founder, Roger Chapin, paid out generous salaries, bonuses, and reimbursements to himself and his wife. In Congressional testimony in 2008, Chapin also admitted to spending charity dollars on a $17,000 golf club membership, a six-figure personal loan to settle his divorce, and reimbursement of more than $43,000 for the down payment on a condo Chapin invested in for his personal benefit. (On LinkedIn, Ravandi lists herself as a volunteer for the coalition, which currently has two out of four stars on the non-profit assessment guide Charity Navigator.)

Another non-profit with some ties to Ravandi is The Independence Fund. The Fund’s CEO, Sarah Verardo, has diverted non-profit dollars to support her family’s lavish lifestyle, from a Disney World retreat to a personal nanny and first-class air travel. (The Fund has previously sponsored the Vettys, and Verardo received an award in 2018.)

In 2019, AUSV filed more detailed financial disclosures with the IRS. They showed that each organization paid Ravandi $55,000 for a total income that year of $110,000. The (c)(3) paid out an additional $10,000 for “planning” and “management” services to a business connected to Ravandi. In an email, Ravandi described this work as focused on social media and outreach. She said that she did this work on the cheap and claimed it would have cost $60,000 at another company. 

Chairwoman of Vettys Inaugural Ball Assal Ravandi, Duane 'Dog the Bounty Hunter"  Chapman, and Beth Chapman attend the Vettys Presidential Inaugural Ball at Hay-Adams Hotel on January 20, 2017 in Washington, DC.  (Photo by Teresa Kroeger/Getty Images)
Chairwoman of Vettys Inaugural Ball Assal Ravandi, Duane ‘Dog the Bounty Hunter” Chapman, and Beth Chapman attend the Vettys Presidential Inaugural Ball at Hay-Adams Hotel on January 20, 2017 in Washington, DC. (Photo by Teresa Kroeger/Getty Images)

In an email, Kalivas called the (c)(3)’s board reporting “lacking.” And Charity Navigator’s Chief Relationship Officer, Kevin Scally, similarly noted that AUSV “does not list adequate information about its board of directors, which we see as a transparency issue for donors and stakeholders.” 

Kalivas noted that while documents claim three board members, only two names are listed. (One of them, the board chair, is Ravandi’s mother, which raises a potential conflict of interest. Ravandi said that due to health issues, her mother is no longer involved in the organization. Ravandi is herself now president and treasurer, moves that nonprofit experts generally advise against, arguing that separation between leadership and the board promotes better oversight and independence.)

Unlike many other non-profits, AUSV also hasn’t released annual reports featuring tangible accomplishments. “Our accomplishments are intangible,” Ravandi said after being asked to list them. “How do you measure mental health? How do you measure valuable relationships? How do you measure the impact an organization has on a community’s long-term sustainability and well-being?” Later, Ravandi said that the AUSV has provided her with a sense of purpose and stability as she copes with post-traumatic stress disorder. 

“I remember saying to myself the night of the first Vettys: ‘If they continue to show up every year, I think I will survive.’ And survive I did,” she said. “Therefore, I can safely say what we do here saves lives.” 

And yet numerous staffers quit after facing burnout, anxiety, and low pay. “The environment became too dangerous for the mental health of myself and others,” said Mackenzie Norris, who worked for AUSV between 2018 and 2019. “A lot of us were too young to understand workplace boundaries and employer respect to know that what we were experiencing was wrong.”

‘She said it didn’t matter, that it was a company expense’

Nine former staffers said Ravandi has long run AUSV on a fleet of low-paid and poorly-treated interns. Norris and three other former employees said many staff began as interns, either being paid a small stipend or minimum wage. “Assal likes to exploit people who are too young to understand what’s even going on,” said Melinda Jenkins, an early AUSV employee who served with Ravandi in the Army. 

On the job review site Glassdoor, staff have anonymously complained that Ravandi is verbally abusive, “manipulative,” and “downright mean.” In texts obtained by Task & Purpose, Ravandi bragged about warning interns on their first day that they could easily get in trouble or be fired. In texts, Ravandi also urged one of her employees not to comfort an intern whom she’d become angry with. “Don’t make him feel better,” Ravandi wrote. “He needs to learn to pay attention.” In another, she confronted an employee who had felt mistreated and was leaving AUSV. “If I quit every time someone yelled at me for a mistake I made I wouldn’t have learned a thing,” Ravandi wrote. In an e-mail, Ravandi said she treats her subordinates far better than most organizations. “Multibillion-dollar companies have unpaid interns that they treat like garbage,” she contended.

Ravandi’s poor reputation has long been countered by her purchasing for AUSV employees expensive meals, designer goods, and all-inclusive trips to New York and Las Vegas. Ravandi described the all-inclusive Vegas trip as a “recovery gesture to give [staff] time off.” She added: “AUSV paid for their hotel and travel and they were responsible for their food and expenses in Vegas.”

WASHINGTON, DC - JANUARY 20: General John F. Kelly attends the 3rd Annual Vetty Awards at The Mayflower Hotel on January 20, 2018 in Washington, DC.  (Photo by Paul Morigi/Getty Images)
Retired Marine Gen. John F. Kelly attends the 3rd Annual Vetty Awards at The Mayflower Hotel on January 20, 2018 in Washington, DC. (Photo by Paul Morigi/Getty Images)

Jenkins provided photos from an all-inclusive 2016 trip that she and Ravandi took to Baja, Mexico that didn’t involve AUSV work at all. She said that she long wondered about the organization’s finances, and said Ravandi gifted her with various Apple products, clothing, food, and hotel rooms. “It wasn’t really adding up,” she said in an interview, adding that Ravandi rarely clued her into the organization’s inner workings. “She would tell me enough for me to not ask a lot of questions. And if you did ask questions, it would get dismissed. Or she would belittle you.” Ravandi said all gifts came from her personal bank account. She said the most expensive bag ever gifted was designed by Ralph Lauren, and cost $100. 

Two others recalled a lavish Christmas Party during which Ravandi disputed payment with the caterer (a claim Ravandi denied), then distributed expensive gifts to staff and the children of veterans. “I don’t know where this money was coming from,” a source said. “It was strange.”

Few had any insight into AUSV’s finances, and it was often hard to tell whether purchases were being made on Ravandi’s personal card or one of her numerous business cards. Eight former employees said Ravandi frequently took herself and staff out for luxurious (and sometimes boozy) lunches and dinners. (While some non-profit dollars going towards food is generally seen as acceptable, alcohol is seen as harder to justify as a business expense.) 

During one of Ravandi’s meals, in late 2018, a former employee said he asked Ravandi whether it was okay for her to be purchasing alcohol with the business card. “She said it didn’t matter, that it was a company expense,” this source recalled. “Treating our team to lunch and dinner comes from my dignified training in the military,” Ravandi said. “We treat all people the same. Leaders don’t eat better food and leaders don’t have better accommodations due to their rank and status.” (She maintained that all alcohol purchases have come out of her personal account.)

Kalivas said numerous AUSV expenditures — like gifts, trips, dresses, and alcohol —  raised questions about AUSV’s handling of non-profit dollars. “If donor funds aren’t being recorded properly or spent towards a charitable mission and are instead being spent for personal reasons, that’s illegal, basically,” she said. Indeed, the IRS has strict rules over how funds are to be tracked and spent, with all personal expenses expected to be fully reimbursed.

WASHINGTON, DC - JANUARY 20:  Chairwoman of the Vettys Inaugural Ball Assal Ravandi attends the Vettys Presidential Inaugural Ball at Hay-Adams Hotel on January 20, 2017 in Washington, DC.  (Photo by Teresa Kroeger/Getty Images)
Assal Ravandi attends the Vettys Presidential Inaugural Ball at Hay-Adams Hotel on January 20, 2017, in Washington, DC. (Photo by Teresa Kroeger/Getty Images)

Eleven former employees also described strange behavior around the organization’s payment system. Two said employees received checks that bounced, while others said they weren’t paid on time. In one 2019 email sent to an AUSV official and obtained by Task & Purpose, an employee claimed she wasn’t paid promised overtime. Eight former employees also said they didn’t receive proper tax forms from Ravandi. “I contacted the IRS and they could not find any record of taxes or any W-2 reporting from AUSV for me,” one of them wrote in a 2019 email, raising the prospect that Ravandi didn’t pay proper taxes for her employees.

Ravandi acknowledged three incidents where checks didn’t initially clear, but said that “if [staff] worked, they got paid.” She also said she is not in violation of any IRS rules. “If someone faced a discrepancy, we received a letter from the IRS and obviously such letters cannot be ignored,” she said. 

While Ravandi herself took in at least $120,000 from AUSV in 2019, her personal finances were apparently deteriorating. In 2019 and 2020, Equity Residential Management LLC repeatedly sought to evict Ravandi from her apartment over thousands of dollars in allegedly unpaid rent, according to court records. This February, Signature Federal Credit Union filed a civil claim contending Ravandi owes more than $23,000, according to court records. 

Despite this, and even with former staffers’ concerns over its actual impact, AUSV presents an outward appearance of a thriving operation. It seems set to benefit from the post-lockdown thirst for socializing. The organization has recently opened Vettys La Vie in Las Vegas, an exclusive “social club designed to bring together the most influential members of our community, veterans and non-veterans alike.” The group has also raised more than $40,000 to support military families affected by COVID-19 and has launched a veteran suicide initiative with raised funds covering expenses for various AUSV events, including the Vettys, that spotlight this pressing issue.

AUSV also hosted the 6th Annual Vettys in July at the Andrew Mellon Auditorium in D.C. The event featured a masked ball and celebrities, including Casey Affleck. Tickets ranged in price from $100 to $5,000. A guest said the event generally went smoothly, though it ended earlier than advertised.

“I welcome anyone who wishes to be read into our finances,” Ravandi said. “I am sure their minds will be blown when they discover how much we do with so little and the sacrifices I personally make to ensure the sustainability of the organization.” 

Task & Purpose subsequently asked for detailed financial documents. After extending our deadline, Ravandi said she would be “happy” to provide them were she less busy. “My priorities and organizational responsibilities are as equally time-sensitive as your deadline,” she said in September. “I apologize in advance if I cannot get them to you as per your request.” When contacted again prior to publication on Wednesday, Ravandi incorrectly claimed that the 2019 Vettys were not held at the Watergate Hotel despite photos and local news stories to the contrary, and said that everything would be on the website of the IRS, which only has detailed financial information about AUSV from 2019.

“As a nonprofit we are obligated to provide the IRS with our financial activities and such information is also available to the public,” she said. “That information is public and can be accessed on our website and through the IRS portal.”

Correction: This article was updated on Dec. 3 to note that Mark L. Rockefeller was a financial underwriter for the Vettys event, not Mark F. Rockefeller. He is not related to the former vice president. Task & Purpose regrets the error.

Editor’s Note: The Independence Fund disputes the allegations made in this article. The allegations are the subject of ongoing litigation.

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