THE STEADY STATE
November 2, 2026
Todd Blanche
Attorney General
U.S. Department of Justice
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
Office of Inspector General
U.S. Department of the Interior
1849 C Street NW
Washington, DC 20240
Re: Request for Review of Freedom 250’s Advertising Arrangement with Trump Media & Technology Group and Federal Award Compliance
The Steady State is an organization of more than 450 former national security, intelligence, diplomatic, military, law enforcement, and homeland security officials. We ask the Department of the Interior Office of Inspector General to review whether federal award funds administered by the National Park Foundation (NPF) and its subsidiary, Freedom 250 LLC, have been used, or are to be used, for advertising services provided by Trump Media & Technology Group (TMTG). We also ask whether that arrangement complied with the conflict-of-interest and procurement requirements that apply to recipients and subrecipients of federal awards. We also ask the Attorney General to review whether these facts warrant inquiry under any applicable federal criminal statute, and to coordinate with the Inspector General as appropriate.
Background
On October 29, 2026, TMTG filed Amendment No. 1 to its Form S-4 registration statement with the Securities and Exchange Commission (File No. 333-299201). Under the heading “Freedom 250 Revenue” in its related-party disclosures, the filing states (p. 157):
“TMTG performed advertising services to Freedom 250 LLC, an entity created by, and administered by the National Park Foundation, the official charity of the National Park Service. Meredith O’Rourke, a member of TMTG’s Board of Directors, also serves on the Board of Directors of the National Parks Foundation. For the three and nine months ended September 30, 2026, TMTG earned revenue of $175.0 related to the advertisement of Freedom 250 events. As of September 30, 2026, TMTG had $175.0 of outstanding receivables from Freedom 250 LLC.”
The filing reports $175.0 in advertising revenue for both the three- and nine-month periods ended September 30, 2026, and a $175.0 receivable as of that date. The quoted disclosure does not state a unit. However, the section in which it appears is limited to transactions in which “the amounts involved exceeded or will exceed the lesser of $120,000 or 1% of the average of TMTG’s assets at year end for the last two completed fiscal years” (p. 157). Its inclusion therefore indicates that the figures are stated in thousands, or approximately $175,000. The disclosure does not establish that the receivable had been paid. These figures may describe the same underlying transaction and should not be added without confirmation from the underlying records.
The same filing states that the Donald J. Trump Revocable Trust holds 114,750,000 shares of TMTG common stock, “representing in the aggregate approximately 41% of the total outstanding shares.”
Freedom 250 is a wholly owned subsidiary of NPF. Under 54 U.S.C. § 101112, NPF’s board includes no fewer than six private citizens appointed by the Secretary of the Interior, with the Secretary and the NPS Director serving as non-voting ex officio members.
According to an interim staff report by the Democratic staff of the House Committee on Natural Resources, master cooperative agreement P26AM00099 between the National Park Service (NPS) and NPF, signed November 11, 2025, designates Freedom 250 “as the subrecipient and operational implementing entity for America250 projects executed under [the] Agreement.” The same report quotes a June 3, 2026 letter from NPF President and CEO Jeffrey Reinbold to Ranking Members Huffman and Dexter acknowledging that “the majority of Freedom 250’s operating funds come from federal funds appropriated by Congress specifically for the 250th anniversary commemorations.” The report identifies both documents as on file with the Committee; we have not located public copies.
NPF President and CEO Jeffrey Reinbold’s Truth in Testimony disclosure for the Committee’s February 10, 2026 hearing identifies P26AC00101 as a “DOI/NPS Task Agreement” under master cooperative agreement P26AM00099, awarded December 2, 2025. USAspending.gov lists the task agreement as “A250 Events.” The Committee report states that obligations under it reached $68 million after amendments in April 2026. USAspending.gov reports approximately $88.87 million in total obligations as of the award’s September 30, 2026 modification, with a period of performance running through December 31, 2028.
The Department of the Interior told NOTUS that “the Park Service has significant oversight over the spending.” (Anna Kramer, “America’s Bipartisan Birthday Commission Is Losing to Trump,” NOTUS, June 1, 2026.) The same article reports, citing a person familiar with the situation, that Freedom 250 submits event plans and budgets to NPF, which works with NPS to obtain approval before funding is released. The filing does not say whether any amount owed to TMTG will be paid from federal or private funds, or what NPS approval, if any, applied to this arrangement.
Applicable Standards
The Uniform Guidance at 2 C.F.R. § 200.318(c)(1) provides:
“The recipient or subrecipient must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. No employee, officer, agent, or board member with a real or apparent conflict of interest may participate in the selection, award, or administration of a contract supported by the Federal award. A conflict of interest includes when the employee, officer, agent, or board member, any member of their immediate family, their partner, or an organization that employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from an entity considered for a contract.”
The same paragraph requires that those standards “provide for disciplinary actions to be applied for violations by its employees, officers, agents, or board members.”
Section 200.318(i) further requires recipients and subrecipients to keep procurement records that include “the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price.”
Questions for Review
We respectfully ask the Inspector General to determine:
What amounts, if any, were invoiced, paid, remain payable, or were committed for TMTG’s advertising services, and what funds were used or are expected to be used.
How TMTG was selected, what procurement method was used, and what records document the selection and the basis for the price under the applicable award terms and procurement rules.
Whether Ms. O’Rourke participated in selecting, awarding, approving, or administering the arrangement; whether her concurrent service on the TMTG and NPF boards created a real or apparent conflict under the applicable standards; and, if so, what disclosure, recusal, or other mitigation occurred.
Whether NPF and Freedom 250 maintained and applied written conflict-of-interest standards as § 200.318(c)(1) requires, and whether any required corrective or disciplinary action followed.
What NPS approvals and fiscal oversight applied to this arrangement, including any approval of the event, budget, procurement, or expenditure.
Whether other federally funded contracts under the agreement involved a conflict covered by 2 C.F.R. § 200.318(c), including participation by an NPF or Freedom 250 employee, officer, agent, or board member with a relevant financial or other interest.
Records Preservation
We ask the Inspector General to preserve relevant Department and NPS records and, within its authority and the applicable award terms, to request preservation by NPF and Freedom 250. We ask the Department of Justice to take any preservation steps within its authority. Relevant records include solicitations, contracts, invoices, payment and accounting records, approvals, conflict disclosures, and communications.
We do not assert that any violation has occurred. The related-party disclosure comes from TMTG’s SEC filing. The federal-funding and oversight context described above comes from the public sources cited above. We believe the Inspector General is well positioned to review these federal-award and oversight questions, and the Department of Justice to determine whether any of them warrant criminal inquiry. We ask that each office refer any matter outside its jurisdiction to the appropriate office.
Sincerely,
Steven A. Cash
Executive Director The Steady State