Donald Trump used donations from his personal foundation to establish relationships with right-wing groups ahead of his candidacy for president, says a new report. Individuals with ties to Trump say that he began making “strategic donations” as far back as 2011 in order to ingratiate himself to organizations that might be skeptical of his conservative bona fides should he make a presidential run.

ADVERTISEMENT

While the report published Tuesday by Real Clear Politics was careful not to explicitly call the relationships a quid pro quo “pay-to-play” arrangement, Trump was using funds from the Trump Foundation in ways that may violate IRS rules.

RCP’s Rebecca Berg wrote that Trump began making donations to conservative groups around the same time he began appearing at their conferences and fundraisers. The groups include pro-Christian lobbying shop the Palmetto Family Council, the Billy Graham Evangelistic Association, anti-choice zealots The Family Leader, Citizens United and the American Conservative Union Foundation, the group which sponsors and organizes the annual Conservative Political Action Conference (CPAC).

Tax filings by the Trump Foundation show $286,000 in donations to influential conservative groups between 2011 and 2014.

“In many cases, this flow of money corresponded to prime speaking slots or endorsements that aided Trump as he sought to recast himself as a plausible Republican candidate for president,” said Berg.

“He was politically active starting in 2011,” said a source with ties to Trump. It was during this period that Trump “started to make strategic donations.”

ADVERTISEMENT

In 2013, the same year that Trump scored a prime CPAC speaker slot, he made a $50,000 donation to the American Conservative Foundation, but, in the words of one source, “Everyone’s too smart to say, ‘Donate and we’ll let you speak.’ It was kind of understood.”

South Carolinian Oran Smith of the Palmetto Family Council told Berg that Trump invited him to his office in New York in 2011 after Smith appeared on the Christian Broadcasting Network and expressed skepticism about Trump’s ability to connect to evangelical voters.

“It probably had something to do with, I was in an early primary state,” Smith said. The reality TV star was “laying the foundation” to run for office.

ADVERTISEMENT

While Smith said “it was difficult trying to tell if he was serious about running for president or not,” Trump donated $10,000 of Trump Foundation money to Smith’s group.

Berg said that this were just two of several donations made by Trump personally and by the Trump Foundation — which Washington Post reporter David Farenthold revealed receives almost no money from Trump himself, but instead relies on funds Trump convinces others to donate — in order to “launch and fuel his political ambitions.”

ADVERTISEMENT

“Such contributions, if they were made solely for Trump’s benefit, could violate federal self-dealing laws for private foundations,” she wrote.

Trump made donations from the foundation when it was legal and reached into his own pocket when he could not.

“If he could do 501(c)(3) to 501(c)(3), he did it that way,” said the source.

ADVERTISEMENT

Berg said, “But Trump has not donated to the foundation that bears his name since 2008,CNN reported last month, which means other donors bore the cost of his giving.”

Charity law specialist Rosemary Fei of San Francisco’s Adler & Colvin law firm told RCP, “Getting the right to speak or access to networking events, that’s definitely starting to push into self-dealing, where you’re using the private foundation assets to benefit Mr. Trump.”

On Monday, New York Attorney General Eric Schneiderman (D) served the Trump Foundation with a cease and desist order after the Washington Post revealed that the foundation had not received proper certification as a charity.

Trump’s 2013 donation of $10,000 to the Family Leader is problematic in that the group is a lobbying organization that seeks to affect national policy and as such is subject to more stringent regulations. The Family Leader has an affiliated nonprofit, but if the Trump Foundation’s payment went to that group, it was not noted in the foundation’s tax records as such or earmarked for charitable purposes.

ADVERTISEMENT

“There’s a mistake somewhere,” Fei told RCP. “It might be a really substantive mistake, or it could just be a reporting error or sloppiness. But improper reporting is still a violation of tax law. That’s something the IRS would look at.”

[Hat-tip to Talking Points Memo]