Office of Consumer Protection Montgomery County, Maryland IN RE THE MATTER OF: Heroes United PAC d/b/a ?Volunteer Firefighters Association" ASSURANCE OF VOLUNTARY COMPLIANCE AGREEMENT Montgomery County, Maryland through its administrative agency, the Montgomery County Office of Consumer Protection (hereinafter referred to as and Heroes United PAC d/b/a ?VolunteerFire?g hters Association," and dlb/a ?Association of Police First Responders," and d/b/a (hereinafter collectively referred to as on this <19 clay of October, 2019, enter into this Assurance of Voluntary Compliance Agreement (the ?Agreement?) pursuant to Chapter 11, Consumer Protection, of the Montgomery County Code, as amended. l. Parties 1. OCP is an administrative agency of Montgomery County, Maryland responsible for the enforcement of Chapter 11, Consumer Protection, of the Montgomery County Code. 2. Eric S. Friedman is the Director of GOP and is authorized to sign this Agreement on behalf of OCP. 3. HU registered with the Federal Elections Commission on June 14, 2017 as a Political Action Committee (Identification Number 000647701) and listed Zachary Bass as the Treasurer, Custodian of Records, and Designated Agent. Matthew Greenlee has been identified as the HU Director. The mailing address for HU is 451 Hungerford Drive, Suite 1 19-339, Rockville, MD 20850; and 1629 Street NW, Suite 300, Washington, DC. 20006. Zachary Bass and Matthew Greenlee are jointly authorized to sign this Agreement on behalf of HU. 52/5 ll. Facts 4. HU engaged in fundraising activity directly, and indirectly by paying vendors to engage in fundraising activity on behalf of HU in Montgomery County, Maryland. 5. Based upon information received from the Montgomery County Volunteer Firefighters Responders Association and based upon information provided by consumers in Montgomery County. Maryland, and pursuant to Section of the Montgomery County Code, OCP initiated an investigation regarding acts and representations by HU and its vendors, which may have the ?capacity, tendency, or effect of misleading consumers" (Case No. 19-00-064678). 6. Consumers allege that they received telephone fundraising solicitation calls from HU and its vendors seeking monetary ?donations" and "pledges" to support ?Volunteer Firefighters." Consumers stated that these telemarketing callers engaged in telephone identification spoofing in which these calls deceptively appeared to be coming from area code locations in Montgomery County, Maryland. The consumers also stated that their telephone numbers were registered with the Federal Trade Commission?s Do Not Call List. 7. HU does not operate or provide any services in Montgomery County, Maryland as a volunteer firefighters association. HU is an independent expenditure-only committee registered with the Federal Election Commission, Washington, D.C. 20463. HU's stated mission is to educate Members of Congress about issues important to fire fighters and emergency medical personnel, and to help elect candidates to of?ce who support those issues. HU has not provided any payments to any political candidate in Maryland or to any volunteer firefighter association in Maryland. 8. HU denies any liability under the Montgomery County Code and entering this Agreement shall not constitute or be construed as an admission of liability whatsoever. Agreement 9. HU hereby agrees to immediately and permanently cease and desist from making, directly or indirectly, any telephone, electronic or direct mail solicitations to any consumers in Montgomery County, Maryland. 10. HU has on file with the Federal Election Committee its list of donors pursuant to 11 CFR 102.9 (52 U.S.C. 30102(c)). 11. Within thirty (30) calendar days from the date of this Agreement, HU shall provide the written offer for full refund attached hereto as Exhibit A sent via regular mail postage prepaid to all consumers in Montgomery County. Maryland who made a donation to HU f; regardless of the amount, directly or indirectly, from June 14, 2017, to the date HU terminated all fundraising activity in Montgomery County, Maryland, at 451 Hungerford Drive, Suite 119-339, .Rockville, MD 20850. HU shall provide a mailing list of all such individuals who shall receive said offer for full refund to GOP prior to mailing. HU shall provide a full refund to any consumer in Montgomery County, Maryland who requests a refund, regardless of the amount, within fourteen (14) calendar days of receiving such request. 12. HU agrees to pay $1,000 to GOP within ten (10) calendar days of the execution of this Agreement. The payment will be deposited and used for consumer education. 13. GOP accepts the consideration in the forgoing paragraphs as the sole consideration for the complete and total compromise and release of all claims against HU subject to Paragraph 15 below. 14. The parties acknowledge that the below signatures transmitted electronically or via facsimile shall be deemed the equivalent of original signatures, and that this Agreement may be executed in counterparts with each counterpart deemed an original. 15. This Agreement is made pursuant to Chapter 11, Consumer Protection. of the Montgomery County Code, and any violation of this Agreement shall be considered a violation of Chapter 11 and subject to all of the remedies contained therein. gay/6 c, 00%? Hero Un' [Date Notary (1.9m J57 46W/mr.? NOTARY Za ary Bass Treasurer Custodian of Records Designated Agent ?ag? 721% (M, Heroes United PAC /Dat Notary 3 Can?t/hf . Matthew Greenlee 4477?? Director 41/5? Montgomery County Office Of Consumer Protection BY: Eric S. Friedman Director Date NOTARY PUBLIC MONTGOMERY COUNTY - MARYLAND EXPIRES ware-25 L3 A VOLUNT FIREFIGHTERS . ASSOCIATIO Formonrinfnma?nu?111301-355me m?elpmre?ghtenmtg HERESUNITED PAC Date Dear [consumer] gym: a re o?f'your donation. If you i As a result of this agreement. - ow an return it in provided would like to receive are_r__: . - .. re enforce consumer protection laws ensurea'fau marketplace for consumers and prohibiting unfair and deceptive ., ?6 baby .em'ai it businesses The)! can; be reached at 249 Thank you again for your support' Sincerely, . Heroes United PAC oiunteer Fire?ghters Association ,4 1629 St. NW. Suite 300 Washington 0.0. 20006 Heroes United FAB Volunteer Fire?ghters Association 1829 St. N. suite 300 Weanington 13.0. 20606 EXHIBIT A