Donald Trump Andrew Harrer | Bloomberg | Getty Images

America First Policies, a nonprofit group with close ties to President Donald Trump, has hired Trump's pollsters to conduct a wide range of political polling and research that experts say resembles the kind of expensive work the Republican National Committee has performed for prior GOP administrations. Such a practice breaks with decades of tradition and raises concerns about potential coordination between the pro-Trump dark money group, the White House and the RNC. America First Policies and the RNC have denied coordinating. The White House did not respond to multiple requests for comment. Over the past six months, CNBC has obtained more than 50 documents through an obscure portal on the America First Policies website. Much of what the group polls and surveys would be standard work for a presidential campaign or a major political party. But America First Policies, which was founded days after Trump's inauguration, is not a campaign or a party. It's what the IRS calls a "social welfare organization," permitted to operate tax-free and keep its donors secret as long as its main focus isn't politics and it doesn't coordinate with candidates. Election lawyers typically interpret this to mean 51 percent of a group's activities must be issue related. "Our primary purpose has to be issue related, but that doesn't mean we can't throw in questions that are news related or political [in our polling]," said Erin Montgomery, communications director for America First Policies.

Last summer, America First Policies took an unprecedented step for a politically allied nonprofit: It started using three top polling firms from Trump's 2016 presidential campaign to produce a steady stream of Trump-focused polls, strategy memos and reports that continue to this day. The three firms initially put their own logos on the polling they did for the group, but over time the America First Policies logo gradually replaced theirs on some of the documents. America First Policies, which actively advocates for policies favored by Trump, denied that any of the documents, many of which are labeled "confidential," were intended to benefit the White House or the president. "We have very clear lines and high walls between us and the RNC or the administration or the Trump campaign," Montgomery said. Yet the lines between the group, the White House and Trump's campaign are often blurred. This week, Trump announced that Brad Parscale, a founder of America First Policies and a senior advisor to the group who also ran digital operations for Trump's 2016 campaign, will lead his 2020 re-election bid. Former Trump campaign manager Corey Lewandowski, who is known to stay in close contact with Trump, is also a senior advisor to America First Policies. Last week, Lewandowski reportedly met with the president and chief of staff John Kelly in the Oval Office, two days before Trump gave a freewheeling, campaign-style speech at the annual CPAC conference. Another key advisor to America First Policies, former Trump campaign spokeswoman Katrina Pierson, recently posted this photo of herself with the president online, from a White House reception ahead of Trump's first State of the Union address on Jan. 30.

This was three months after a group of senior advisors to America First Policies, including Lewandowski, Parscale and Executive Director Brian O. Walsh huddled with top Trump administration officials in the White House in late October, plotting strategies to push tax reform. Montgomery and Walsh both told CNBC that America First Policies gives its polling data to its allies while abiding by the "high walls and clear lines" separation from Trump. In January alone, this data included more than a dozen surveys and memos on topics that ranged from marijuana legalization to how the White House handled the release of "Fire and Fury," a tell-all book about the Trump administration. Some of these documents were posted online and then removed, while others remained posted. "We share our polling with lots of outside groups and elected officials, and we put all of them up online," said Montgomery. "I don't know if this information is ever shared with the White House. Anyone can see it." "In the old world [of political polling], things were kept secret. In the new world, you make everything public," Walsh said. Yet after CNBC spoke to Walsh and Montgomery on Wednesday, several of the research documents from January appeared to have been removed from the site by Thursday morning, including the results of polling on marijuana, analysis of how women view Trump, and January's polling results. Dozens of other documents have also been removed from the site but left up on the web, apparently by accident. Walsh was under the impression that they had all been permanently deleted, and he accused CNBC of acquiring the reports from someone inside the group's network. Walsh also refused to share several additional documents that CNBC requested. A lot of what America First Policies has learned from its polling is not flattering to the Trump White House. Moreover, a significant portion of the polling shows that issues important to Trump are not necessarily important to voters. Below are some of the key details spread throughout the group's research and polling: Building a wall along the southern border is not only unpopular with Democrats and independents. Even Trump's base voters ranked the construction of a wall as their least important policy issue in a January survey.

A September poll showed that America First Policies was exploring ways to defeat Arizona Republican Sen. Jeff Flake in a primary, a month before Flake, a Trump critic, announced his retirement.

When "Fire and Fury" came out in January, an America First Policies social media report noted that few people seemed to notice that the White House banned personal cell phones in the West Wing that same week.

According to the group's February polling, the largest percentage of voters agreed with Nancy Pelosi's comment that worker bonuses stemming from the GOP tax bill were "crumbs" compared with corporate windfalls.

The February survey also found that only half of respondents agreed with Trump's plan for a military parade, while voters disagreed with the way he handled a scandal involving a senior White House aide accused of domestic abuse. "AFP is doing the type of polling that would typically be done by a presidential campaign or a major party committee like the RNC or the DNC," said Brendan Fischer, an election law expert at the nonprofit Campaign Legal Center. "So even though they claim to be committed to a set of issues, the available evidence here indicates that they're operating as a polling shop for the president."

A door to a treasure trove of data

America First Policies reportedly raised $26 million last year for issue advocacy, but the "Issue" pages on its website do not appear to have been updated for months. "This is supposed to be an organization dedicated to informing the public about issues, and yet its issue pages contain stale news stories and reports borrowed from other outlets," said Fischer. But these pages of recycled reports are not where the real action is happening for America First Policies. Buried at the bottom of the group's homepage is a tiny, easily overlooked link labeled "Data."

Behind this link lies an entirely separate section of the website, divided into "Survey Research," "Social Media Reports" and "Other." America First Policies posts new reports under Survey Research nearly every week. Sometimes there are social media reports on the page, and, other times, the group posts strategy memos and large collections of public polling and news articles. The latest addition to the survey research page was uploaded earlier this week: An 84-page summary of America First Policies' February national polling, available for download in a document format called Keynote, which can be converted to a PDF. Asked why the "Data" link was so small and difficult to see, while other tabs on the website were large and prominent, Montgomery responded, "It's there on the homepage." She also said she plans to update the issue pages, but has been too busy with other tasks. "We're not hiding anything," she said. "I just put the link at the bottom of the page so I can find it easily," said Walsh, who said he notifies other like-minded groups when new data is posted to the site. "We want to make sure it's publicly available," he said. Walsh refused to share additional polling that CNBC requested. "If things get taken down [from the site], it's for server space," he added. The group removed several documents from the site after speaking to CNBC. In February, the group measured support for Trump's proposed military parade; whether voters agreed with Trump's defense of former White House staff secretary Robert Porter, who is accused of spousal abuse; and whether voters believe the claims contained in the Nunes memo, in addition to other topics. (Half support the parade; voters don't agree with Trump about Porter, and voters don't believe the Nunes memo).

White House Staff Secretary Rob Porter (L) reminds U.S. President Donald Trump he had a bill to sign after he departed quickly following remarks at his golf estate in Bedminster, New Jersey U.S.., August 12, 2017 Jonathan Ernst | Reuters

"So much of the information they're gathering is focused on the president himself and not necessarily his policies," said Geoffrey Skelley, associate editor of the nonpartisan campaign newsletter Sabato's Crystal Ball from the University of Virginia Center for Politics. Skelley questioned whether this could run afoul of campaign finance laws, which require nonprofit groups to disclose money they spend directly to benefit candidates. Stephen Spaulding, a former special counsel at the Federal Election Commission and now director of strategy for the nonpartisan watchdog group Common Cause, agreed. "There are ample grounds here to investigate whether America First Policies has been raising money that's subject to limits and disclosure requirements because it's being used for political purposes," he said. Asked specifically about the group's September poll that tested the best candidates in Arizona to knock out Flake in a GOP primary, Walsh said he was just "scratching an itch" when he commissioned it. The poll was conducted a few weeks after Trump openly called on Republicans to challenge Flake in a primary. At a Phoenix rally in August, he surprised aides by meeting backstage with two potential challengers and encouraged them to run. The America First Policies polling effort operates as a network of coordinated groups, with two lesser-known firms, National Research Inc. and Baselice & Associates, working alongside a well-known Washington firm, The Polling Company, which was founded by former Trump campaign manager-turned-White House counselor, Kellyanne Conway.

Trump campaign manager Kellyanne Conway. Mandel Ngan | AFP | Getty Images

When Conway sold her firm in September 2017, The Polling Company had already been working for America First Policies for more than two months, judging from the company's logo on polls that it conducted for the group in June and July. Conway was granted a special ethics waiver last June so she could engage in "communications and meetings" with former clients of The Polling Company without violating Trump's two-year ban on communications with former employers or clients. Conway has been called the "Trump whisperer" for her ability to influence the often mercurial president. In a 2016 interview with MSNBC, she described herself as a "discreet advisor" to Trump who was expected to use her data and strategy experience to help Trump craft his message.

A break from the norm

For decades, White House pollsters for Republican presidents have been paid by the RNC, while the Democratic National Committee has paid for presidential polling during Democratic administrations. But the prolific output of polling data from America First Policies has coincided with a steep drop in the amount of money the RNC spends on presidential pollsters, as compared with the first 12 months of previous Republican administrations dating back to the Reagan White House. According to FEC reports, the total amount that the RNC spent on Trump's campaign pollsters in 2017 amounts to just 5 percent of what the committee spent on Ronald Reagan's White House polling in 1981, adjusted for inflation, and around 12 percent of what it spent for President George W. Bush's pollsters in 2001. This is partly due to a shift in the type of data system that is used by the RNC, away from traditional polling and toward a scoring system, according to an RNC official who spoke to CNBC on the condition of anonymity. "Since 2013, we've spent $250 million to gather information through voter scoring, and we have a huge amount of information that informs these scores," the RNC official said. "So, we don't really pay for traditional polling anymore. We rely on this data, instead." On the rare occasions that traditional White House polling is needed, the RNC official said, the committee still relies on the president's preferred polling firms. This happened twice in 2017 and once again in January. Trump's top polling firms, meanwhile, do not come cheap. The three firms currently identified on some of America First Policies' documents charged the Trump campaign a combined $2.1 million for just two months' worth of polling during the final stages of Trump's 2016 presidential campaign, according to FEC filings. At these rates, the cost of the polling these firms have produced for America First Policies since last summer could easily be in the seven figures. Yet ever since Trump was inaugurated, these same filings reveal that the rebooted Trump 2020 campaign has not spent any money on polling, despite raising $17 million last year. "This looks like a million-dollar polling operation," said Spaulding, the former FEC special counsel, who reviewed the documents that CNBC downloaded. "And this isn't the kind of issue polling you'd expect to see from an outside nonprofit: This is more like a shadow campaign on behalf of the president." Much of the polling itself is deeply flawed, however, according to polling experts who reviewed the documents uncovered by CNBC. For example, America First Policies' pollsters frequently use leading questions, which make it clear that one answer is much better than other possible answers. The group also employs leading questions to test public opinion, skewing their own results and painting an incorrect picture of how voters feel about certain policy issues, like immigration and infrastructure. "If you want to test a position, you test a position. If you want to test a message, you test a message. There's a time for both. But you don't deliberately f--- up the results of your position survey by dumping a message in front of it," said a veteran political pollster who spoke on the condition of anonymity. "If you're trying to gauge a person's stance on asylum seekers, you don't taint your question with some bull---- about how violent MS-13 can be before you ask it. I mean, what good does that do? All it shows you is that scary things can scare people." America First Policies' Montgomery acknowledged that some of the questions were leading, but said the ones she had helped to write were not leading. Walsh said the leading questions were actually just message testing. But message testing typically occurs only after public opinion has already been measured without the use of leading messages. Many of America First Policies' questions contain leading language the first time they appear on a survey. One recent example of leading language was in a February poll's description of Trump's proposed military parade. Here, voters were asked whether they supported or opposed "a military parade that honors our nation's veterans and the troops and families who sacrificed their lives for our country, as well as the strength of our military."

In another question from February, as shown in the above screenshot from one of the group's reports, respondents were reminded that large companies had given out employee bonuses before they were asked if they agreed with House Minority Leader Nancy Pelosi's comment that worker bonuses were "crumbs" compared with corporate windfalls. The results were surprising: A plurality of voters agreed with Pelosi, despite the lopsided question. This would suggest that for Republicans, using the "crumbs" comment as an attack line against Democrats in 2018 campaigns, which Trump has suggested they do, may not be a good idea. Over the past six months, CNBC monitored America First Policies' website and found hundreds of pages of polling and research paid for by donors whose names are permitted to be kept secret. Much of this polling has since been removed from the site, but a portion of the removed documents are still available online. America First Policies is not the first nonprofit group created to advance a president's priorities, nor is it the first to conduct intensive polling. Two Obama-linked groups, Priorities USA and Organizing for Action, did the same thing. Priorities USA did not disclose its donors, but OFA did voluntarily, releasing quarterly donor lists. But by hiring the Trump campaign's pollsters to conduct such a large and secretive Trump-focused data operation, and paying for it with dark money, America First Policies is going well beyond what previous outside nonprofit groups have done. While a political committee such as the RNC is designed and expected to collect information that helps to win elections, a nonprofit group such as America First Policies — permitted to operate tax-free and accept unlimited donations from donors whose names can be kept secret — is not. "So you have a situation where large donors are contributing to America First Policies with the understanding that their secret donations are going to be seen as valuable by the president, because this group appears to work so closely with the White House," said Campaign Legal Center's Fischer. "And because these donors are secret, the public and Congress will never know if the White House later took action to advance a donor's interests." In addition to a slew of senior advisors with ties to Trump, America First Policies has three board members, all of whom are also close to the Trump White House. Its chairman, Tommy Hicks Jr., is the son of a billionaire and a good friend of Donald Trump Jr. He has also reportedly brokered White House introductions for companies seeking business with the Trump administration. Another board member, Dallas financial executive Roy Bailey, serves as managing director and founding partner of Giuliani Partners LLC, along with former New York City mayor and longtime Trump ally Rudy Giuliani. The newest board member is Harold Hamm, a shale oil billionaire who was Trump's top pick for energy secretary but reportedly turned down the job.

Harold Hamm, chief executive officer of Continental Resources Inc., speaks during the Republican National Convention (RNC) in Cleveland, July 20, 2016. Andrew Harrer | Bloomberg | Getty Images

CNBC sent detailed questions to the White House about its relationship with America First Policies and asked what, if any, polling firms the Trump administration relies on to track public opinion and information for the president. The White House did not respond to multiple requests for comment.

A murky new era of campaigning

In recent years, the laws that govern political spending and disclosure requirements have come under attack. "Judicial rulings like [2010's] Citizens United and the explosion of outside funding groups that followed it have had a cumulative effect, loosening the rules around money in politics," said Skelley. "The result is that there are a lot of gray areas in the law today, and there are a lot of different groups all trying to fill in the gray." In this brave new world of often unlimited political money, some groups risk being left behind — and few more so than the two major party committees, the DNC and the RNC. The case of America First Policies only underscores how easy it is for one of the newer, less-constricted political groups to take over what had once been a core party function. Yet the shift away from the traditionally intertwined relationship between the RNC and the president's pollsters is also part of a bigger trend, Skelley said. "We've seen the political parties weakened in recent years, in terms of their control over their members and their policy agendas. America First Policies represents just another step in the waning influence of the party committees over how political activity in America is actually being conducted." Increasingly, top-down party bureaucracies like the RNC and DNC are giving way to loosely aligned networks of dark money groups, super PACs, political campaigns and charities that may look distinct, but often share staff, vendors and office space with one another. The nonprofit America First Policies has a sister political action committee, America First Action, which is also run by Walsh. As a super PAC, America First Action must report its donors to the FEC, but in return for that transparency, it is permitted to spend all of its money helping to win elections. In October of last year, America First Action launched a $100 million fundraising campaign with a series of events in Texas, including a donor meeting at the ranch of oil magnate T. Boone Pickens. There, Walsh reportedly made a pitch to donors about how America First Action was the only pro-Trump super PAC that had the president's blessing. Among the attendees was Donald Trump Jr., who told the other guests that America First Action was the only outside group to which he would be donating. Between America First Action and America First Policies, Walsh said, more than $25 million had been raised so far that year. "All these entities are indistinguishable from one another on the ground level," said Campaign Legal Center's Fischer. "We have rules to guard against corruption and rules to help ensure transparency when money is being spent to influence elections. And it seems that there are grounds here to ask whether this group is just flouting those rules."

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