2949334811323 9 I OMB No. 1545-0047 2?1 8 Open to Public Fm 990 ?Return of Organization Exempt From Income Tax Under section 501(c), 527, or 4947(a)(1) of the Internal Revenue Code (except private foundations) Do not enter social security numbers on this form as it may be made public. Go to for instructions and the latest information. Inspection A For the 2018 calendar ear or tax ear innin and endin Check if applicable Name of organization RULE.OF LAW TRUST Employer identi?cation number Address change Doing 5990355 35 Name chart a Number and street (or 0. box it mail is not delivered to street address) Roomisune 83-104772? 8300 BOONE AVENUE 5 ggomd Tetephone number Initial return City or town tate PM VIENNA VA 22182 54? 341%? Foreign country name Foreign plownoelstateloounty Foreign postal code Amended return 6 Gross receipts 5 80,451,470 '3 Application pending Name and addr?s 0f pnncipal Of?cer H(a) ts ttus a group return for subordinates" DYes- No Leonard Leo 8300 Boone Ave. Ste. 500, Vienna, VA 22182 LP H(b) Are all subordinates induded? No Tax-exempt status I: 501(c)(3). 501(c) I 4 (insert no) 4947(a)(1)orUZl ?27 Website: nla I Hjc) Group exemption number 5 Form of organization' Corpolation Trust Assoaatlon Other [LYearottormatlon' 2018 I State otlegal domicile. VA Summary 0 1 Brie?y describe the organization's mission or most signi?cant actiVlties: 2519.59.3i 399.119 D. EQUPIE [9.5.99599. $93132! .5109. 9.919! I'll I: 2 Check this box if the organization discontinued its operations or disposed of more than 25% of its net assets- 0 3 Number of voting members of the govemlng body (Part VI, line 13Number of independent voting members of the governing body (Pait VI, line 1bTotal number of individuals employed in calendar year 2018 (Part V, line ZaTotal number of volunteers (estimate if necessaryTotal unrelated business revenue from Part column (C) line 12 7a 0 Net unrelated business taxable income from . . . . . . . . . 7b 0 El VLV (.3 Prior Year Current Year 3 8 Contributions and grants (Part thI, tine 1h79,999,550 5 9 Program service revenue (Part line 29). L33 . W19. 2mg at). 0 0 3 10 Investment income (Part column (A), line 4 (1) .lm . 0 451,920 11 Other revenue (Part column (A) lines 5 d, 3" 1 2 Total revenue?add lines 8 through 11 (must egu I Part ?mitt-DNA). J1 0 80,451 ,470 13 Grants and similar amounts pald (Part ix 14 Bene?ts paid to or for members (Part IX, column (A), line 4). . 0 0 15 Salaries, other compensation, employee bene?ts (Part IX column (A), lines 5-10). 0 0 ?3 16a Professional fundraising fees (Part IX, column (A), line 11a) . . . 0 0 Total fundraising expenses (Part IX, column (D), line 25) 9 l" 17 Other expenses (Part IX, column (A), lines . . . 0 2,736,293 18 Total expenses. Add lines 13?17 (must equal Part IX, column (A), line . 0 2,736,293 19 Revenue less expenses Subtract line 18 from line 77,715,177 3 Beginning of Current Year End of Year ES, 20 Total assets (Part x, line 1578,215,187 {3g 21 Total liabilities (Part x, line 264,324 22 Net assets or fund balances. Subtract line 21 from line 2078,210,863 Signature Block Under penalties oi penury, I declaret ve examined this urn, in mpanying schedules and statements, and to the best of my knowledge and belief, it is true, garbeclaratlon er Jhan of?cer)? is based on all information of which preparer has any knowledge Sign a Signature orig/C ate 721/5775: Type or print name and title I 1 . PnntIType preparers name Preparers Signature Date Check I: it 13:12: arer Raymond Conton mama] 1111312019 self-emuloved P01486002 Use Only Finn's name Conlon and Associates LLC Finn's EIN . Finn's address PO Box 6213, Silver SpringiIID 20916-6213 Phone no (301) 509-4220 May the IRS dgisuss this return with the preparer shown above? (see instructionsFor Papenivork Reduction Act Notice, see the separate instructions. Form 990 (2018) HTA Form 990 (2018) RULE OF LAW TRUST 83-1047727 Page 2 . Part Statement? of Program Service Accomplishments .. Check If Schedule 0 contains a response or note to any line in Part Ill . . . . . . . 1 Briefly describe the organization's missuon IQ EQYEQQE .999] _r_esea_r_c_h,_ 9.1953}. 2 the organization undertake any Signi?cant program servrces during the year which were not listed on the prior Form 990 or Yes No If "Yes." describe these new servuces on Schedule 0 3 the organlzatlon cease conducting, or make Signi?cant changes In how It conducts. any program serVIces"Yes," describe these changes on Schedule 0 4 Describe the organization's program serVIoe accomplishments for each of Its three largest program serVIces. as measured by expenses Sectlon 501(c)(3) and 501(c)(4) organizations are requnred to report the amount of grants and allocations to others, the total expenses, and revenue, If any. for each program servrce reported 4a (Code (Expenses Includlng grants of (Revenue 0_ .3. QPRQEEQQPE 91?? 9E .53 99]] 99.9%? _a_r_1 g. 99_m_r1_1_ur_u_cat_lp_n_? Illa}. id)! .3391? 4b (Code (Expenses Including grants of (Revenue 4c (Code (Expenses Including grants of (Revenue 4d Other program servnces (Describe In Schedule 0) (Expenses 0 Including grants of 0 )(Revenue 0 4e Total program servnce expenses 2,705,154 Form 990 (2018) . lat/O Form 990 (2018) RULE OF LAW TRUST 83-1047727 Page 3 Checklist of Required Schedules Yes No 1 Is the organization described in section 501 or 4947(a)(1) (other than a private foundation)? If "Yes, complete Schedule A . 1 2 IS the organization reqwred to complete Schedule B, Schedule of Contributors (see Instructions)? . . 2 3 Did the organization engage in direct or indirect political campaign actIVItieS on behalf of or in oppOSition to candidates for public of?ce? If "Yes, complete Schedule C, Partl 3 4 Section 501(c)(3) organizations. Did the organization engage in lobbying actiwties, or have a section 501(h) election in effect during the tax year? If "Yes, complete Schedule C, Part II . 4 5 Is the organization a section 501(c)(4), 501(c)(5), or 501(c)(6) organization that receives membership dues, assessments, or Similar amounts as de?ned in Revenue Procedure 98-197 If "Yes, complete Schedule C, Part 5 6 Did the organization maintain any donor adVIsed funds or any Similar funds or accounts for which donors have the right to prowde adwce on the distribution or investment of amounts in such funds or accounts? lf "Yes, complete Schedule D, Partl 6 7 Did the organization receive or hold a conservation easement, including easements to preserve open space, the enVIronment, historic land areas, or historic structures? If "Yes, complete Schedule D, Part ll 7 8 Did the organization maintain collections of works of art, historical treasures, or other Similar assets? If "Yes, complete Schedule D, Part Ill 8 9 Did the organization report an amount in Part line 21 for escrow or custodial account liability serve as a custodian for amounts not listed in Part X, or prowde credit counseling, debt management, credit repair, or debt negotiation services? If ?Yes, complete Schedule D, Part IV 9 10 Did the organization, directly or through a related organization, hold assets in temporarily restricted endowments, permanent endowments, or quad-endowments? If "Yes, complete Schedule D, Part . 10 11 If the organization's answer to any of the followmg questions is "Yes." then complete Schedule D, Parts VI, VII, IX, or as applicable 3 Did the organization report an amount for land, bwldings, and eqUipment in Part X, line 10'? If "Yes, complete Schedule D, Part VI 11a Did the organization report an amount for investments?other securities in Part X, line 12 that iS 5% or more of its total assets reported in Part X, line 167 If "Yes, complete Schedule D, Part VII 11b Did the organization report an amount for investments?program related in Part X, line 13 that is 5% or more of its total assets reported in Part X, line 16'? If "Yes, complete Schedule D, Part 11c Did the organization report an amount for other assets in Part X, line 15 that is 5% or more of its total assets reported in Part X, line 16?? If "Yes, complete Schedule D, Part IX 11d Did the organization report an amount for other liabilities in Part X, line 25'? If ?Yes, complete Schedule D, PartX 11e Did the organization's separate or consolidated nanCIal statements for the tax year include a footnote that addresses the organization's liability for uncertain tax posmons under FIN 48 (ASC 740)? If "Yes, complete Schedule D, Pan?X 11f 12a Did the organization obtain separate, independent audited ?nanCIal statements for the tax year? If "Yes, complete Schedule D, Parts XI and 1 2a Was the organization included in consolidated, independent audited nanCIaI statements for the tax year? If ?Yes, and if the organization answered "No" to line 123, then completing Schedule D, Parts XI and is optional 12b 13 Is the organization a school described in section If "Yes, complete Schedule 13 14a Did the organization maintain an of?ce, employees, or agents outSide of the United States? 14a Did the organization have aggregate revenues or expenses of more than $10,000 from grantmaking, fundraiSing, busmeSS, investment, and program serVice actiwties outSIde the United States, or aggregate foreign investments valued at $100,000 or more? If "Yes, complete Schedule F, Parts I and IV 14b 15 Did the organization report on Part IX, column (A), line 3, more than 000 of grants or other assmtance to or for any foreign organization? If "Yes, complete Schedule F, Parts ll and . 15 16 Did the organization report on Part IX, column (A), line 3, more than 000 of aggregate grants or other a85istance to or for foreign indiwduals9 If ?Yes, complete Schedule F, Parts Ill and 16 17 Did the organization report a total of more than $15,000 of expenses for profeSSionaI fundraiSing serVices on Part IX, column (A), lines 6 and 11e?? If "Yes, complete Schedule G, Part I (see instructions) 17 18 Did the organization report more than $15, 000 total of fundraiSing event gross income and contributions on Part lines 1c and Be? If "Yes, complete Schedule G, Part II 18 19 Did the organization report more than $15,000 of gross income from gaming actiVities on Part line 9a? If ?Yes, complete Schedule G, Part 19 20a Did the organization operate one or more hospital If "Yes, complete Schedule 20a If "Yes" to line 20a, did the organization attach a copy of its audited ?nanCial statements to this return? 20b 21 Did the organization report more than $5,000 of grants or other aSSistance to any domestic organization or domestic government on Part IX, column (A), line If "Yes, complete Schedule I, Parts I and II 21 Form 990 (2018) Form 990 (2018) . RULE OF LAW TRUST 83-1047727 Page 4 Checklist of'Required Schedules (continued) Yes No 22 Did the organization report more than $5,000 of grants or other aSSIstance to or for domestlc IndIVIduals on Part IX, column (A), ?ne If "Yes, complete Schedule I, Parts I and Ill 22 23 the organIzatIon answer "Yes" to Part VII, SectIon A, ?ne 3, 4, or 5 about compensatIon of the organIzatIon's current and former of?cers, dIrectors, trustees, key employees, and hIghest compensated employees? If "Yes, complete Schedule 23 24a the organIzatIon have a tax- -exempt bond Issue WIth an prIncipal amount of more than $100,000 as of the last day of the year that was Issued after December 31, 20027 If "Yes, answer lInes 24b through 24d and complete Schedule If "No, go to ?ne 25a . 24a the organIzatIon Invest any proceeds of tax- -exempt bonds beyond a temporary perIod exception? . 24b the organIzatIon maIntaIn an escrow account other than a refundIng escrow at any tIme durIng the year to defease any tax- -exempt bonds? . 24c the organIzatIon act as an "on behalf of" Issuer for bonds outstanding at any time durIng the year? . 24d 25a Section 501(c)(3), 501(c)(4), and 501(c)(29) organizations. the organIzatIon engage In an excess bene?t transactIon WIth a dIsqualI?ed person dunng the year? If "Yes, complete Schedule L, Partl 25a Is the organIzatIon aware that It engaged In an excess bene?t transactIon With a dIsquaII?ed person In a prIor year, and that the transactIon has not been reported on any of the organIzatIon's prIor Forms 990 or If "Yes, complete Schedule L, Part I . 25b 26 the organIzatIon report any amount on Part X, ?ne 5, 6, or 22 for receivables from or payables to any current or former of?cers, dIrectors, trustees, key employees, hIghest compensated employees, or dIsqualI?ed persons? If "Yes, complete Schedule L, Part ll 26 27 Old the organIzatIon prowde a grant or other aSSIstance to an of?cer, dIrector, trustee, key employee, substantial contrIbutor or employee thereof, a grant selectIon commIttee member, or to a 35% controlled mm or family member of any of these persons? If "Yes, complete Schedule L, Part 27 28 Was the organIzatIon a party to a busmess transactIon WIth one of the followmg partIes (see Schedule L, . II. Part IV InstructIons for applIcabIe ?lIng thresholds, condItIons, and exceptIons) a A current or former of?cer, dIrector, trustee, or key employee? If "Yes, complete Schedule L, Part IV 28a A famIly member of a current or former of?cer, dIrector, trustee, or key employee? If "Yes, complete Schedule Partlv . 28b An entIty of a current or former of?cer, dIrector, trustee, or key employee (or a famIIy member thereof) was an of?cer, dIrector, trustee, or dIrect or IndIrect owner? If "Yes, complete Schedule L, Part IV . 28c 29 Old the organIzatIon recere more than $25,000 In non-cash contrIbutIons?? If "Yes, complete Schedule 29 30 the organIzatIon recere contrIbutIons of art, hIstorIcal treasures, or other srmIlar assets, or quaII?ed conservatlon contrIbutIons? If "Yes, complete Schedule 30 31 Old the organIzatIon IIqUIdate, termInate, or dIssolve and cease operatIons'? If "Yes, complete Schedule N, Part! 31 32 the organIzatIon sell, exchange, dIspose of, or transfer more than 25% of Its net assets? If "Yes, complete Schedule N, Part ll 32 33 the organIzatIon own 100% of an entIty dIsregarded as separate from the organIzatIon under RegulatIons sectIons 301 7701 -2 and 301 7701-3? If ?Yes, complete Schedule R, Part! . 33 34 Was the organIzatIon related to any tax-exempt or taxable entIty?? If "Yes, complete Schedule R, Part II, or IV, and Part V, line 1 34 35a the organIzatIon have a controlled entIty WIthIn the meanIng of section 35a If "Yes" to ?ne 35a, dId the organIzatIon recere any payment from or engage in any transactIon WIth a controlled entIty WIthIn the meanIng of section If "Yes, complete Schedule R, Part V, 2 35b 36 Section 501(c)(3) organizations. the organIzatIon make any transfers to an exempt non-charItable related organIzatIon'? If "Yes, complete Schedule R, Part V, line 2 . . 36 37 the organIzatIon conduct more than 5% of Its actIVItIes through an entIty that Is not a related organIzatIon and that IS treated as a partnershIp for federal Income tax purposes? If "Yes, complete Schedule R, Part VI 37 38 Old the organIzatIon complete Schedule 0 and prowde explanatIons In Schedule 0 for Part VI, IInes 11b and 19?? Note. All Form 990 ?lers are reqUIred to complete Schedule 0 38 Statements Regarding Other IRS Filings and Tax Compliance Check if Schedule 0 contaIns a response or note to any line in this Part . . . . . . . Yes No 1a Enter the number reported In Box 3 of Form 1096 Enter -0- If not appIIcable . 1a Enter the number of Forms W-ZG Included In line 1a Enter -0- If not applIcabIe 1b the organIzatIon comply WIth backup WIthholdIng rules for reportable payments to vendors and reportable gamIng wmnIngs to prize wmners'? . 1c Form 990 (2013) Form 990 (2018) RULE OF LAW TRUST 83-1047727 Page 5 Statements Regarding Other IRS Filings and Tax Compliance (continued) Yes No 2a Enter the number of employees reported on Form W-3, Transmittal of Wage and Tax Statements, ?led for the calendar year ending With or Within the year covered by this return 2a 0 If at least one is reported on line 2a, did the organization ?le all reqUIred federal employment tax returns? . 2b Note. If the sum of lines 13 and 2a is greater than 250, you may be requned to e-file (see Instructions) 3a Did the organization have unrelated busmess gross income of $1,000 or more during the year? 3a If "Yes," has it ?led a Form 990-T for this year? If "No" to line 3b, prowde an explanation in Schedule 0 . 3b 4a At any time during the calendar year, did the organization have an interest in, or a Signature or other authority over, a ?nanCIal account in a foreign country (such as a bank account, securities account, or other ?nanCial account)? 4a If "Yes," enter the name of the foreign country See instructions for ?ling reqwrements for Form 114, Report of Foreign Bank and Financial Accounts (FBAR). 5a Was the organization a party to a prohibited tax shelter transaction at any time during the tax year? . . Sa Did any taxable party notify the organization that it was or is a party to a prohibited tax shelter transaction? . 5b If "Yes" to line 5a or 5b, did the organization ?le Form . 5c 6a Does the organization have annual gross receipts that are normally greater than $100 000 and did the organization sohcnt any contributions that were not tax deductible as charitable contributions? . 6a If "Yes, did the organization include With every soIICItation an express statement that such contributions or gifts were not tax deductible? . . 6b 7 Organizations that may receive deductible contributions under section 170(c). a Did the organization receive a payment in excess of $75 made partly as a contnbution and partly for goods and serwces prowded to the payor? . 7a If "Yes," did the organization notify the donor of the value of the goods or serwces provided? . 7b Did the organization sell, exchange, or othenivise dispose of tangible personal property for which it was reqUIred to ?le Form 82829 . . . 7c If "Yes," indicate the number of Forms 8282 ?led during the year . I 7d I I Did the organization receive any funds, directly or indirectly, to pay premiums on a personal bene?t contract? 7e Did the organization, during the year, pay premiums, directly or indirectly, on a personal bene?t contract? 7f 9 If the organization received a contribution of quali?ed intellectual property, did the organization ?le Form 8899 as required? _Lq if the organization received a oontnbution of cars, boats, airplanes, or other vehicles, did the organization ?le a Form 1098-07 7h 8 Sponsoring organizations maintaining donor advised funds. Did a donor adVIsed fund maintained by the I sponsoring organization have excess busmess holdings at any time during the year? 8 9 Sponsoring organizations maintaining donor advised funds. I 3 Did the sponsoring organization make any taxable distributions under section 4966'? 9a Did the sponsoring organization make a distribution to a donor, donor adVisor, or related person? 9b 10 Section 501(c)(7) organizations. Enter a Initiation fees and capital contributions included on Part Vill, line 12 10a Gross receipts, included on Form 990, Part Vill, line 12, for public use of club faCiIities 10b 11 Section 501(c)(12) organizations. Enter a Gross income from members or shareholders . . 11a Gross income from other sources (Do not net amounts due or paid to other sources against amounts due or received from them 11b 12a Section 4947(a)(1) non-exempt charitable trusts. Is the organizationi ling Form 990 in lieu of Form 1041'? 123 If "Yes," enter the amount of tax- e-xempt interest received or accrued during the year 12b 13 Section 501(c)(29) quali?ed nonprofit health insurance issuers. a Is the organization licensed to issue quali?ed health plans in more than one state? 13a Note. See the instructions for additional information the organization must report on Schedule 0 Enter the amount of reserves the organization is reqUIred to maintain by the states in which the organization is licensed to issue quali?ed health plans . 13b Enter the amount of reserves on hand 13c 14a Did the organization receive any payments for indoor tanning services during the tax year? 14a If "Yes," has it ?ied a Form 720 to report these payments? If "No, "provrde an explanation in Schedule 0 14b 15 Is the organization subject to the section 4960 tax on payment(s) of more than $1,000,000 in remuneration or excess parachute payment(s) during the year 15 If "Yes," see instructions and ?le Form 4720, Schedule I 16 is the organization an educational institution subject to the section 4968 eXCise tax on net investment income? 16 if "Yes," complete Form 4720, Schedule 0 I Form 990 (2018) Form 990 (2018) RULE OF LAW TRUST 83-1047727 Page 6 . Governance, 'Management, and Disclosure For each ?Yes" response to lines 2 through 7b below, and for a "No" response to line 83, 8b, or 10b below, describe the circumstances, processes, or changes in Schedule 0. See instructions. Check if Schedule 0 contains a response or note to any line in this Part VI . . . . . Section A. Governing Body and Management Yes No 1a Enter the number of voting members of the governing body at the end of the tax year 13 1 If there are material differences in voting rights among members of the governing body, or if the governing body delegated broad authority to an executive committee or Similar committee, explain in Schedule 0 Enter the number of voting members included in line 1a, above, who are independent 1b 1 2 Did any of?cer, director, trustee, or key employee have a family relationship or a busmess relationship With any other of?cer, director, trustee, or key employee? 2 3 Did the organization delegate control over management duties customarily performed by or under the direct of of?cers, directors, or trustees, or key employees to a management company or other person? 3 4 Did the organization make any Signi?cant changes to its governing documents since the pn'or Form 990 was ?led? 4 5 Did the organization become aware during the year of a signi?cant diversion of the organization's assets? 5 6 Did the organization have members or stockholders? 6 7a Did the organization have members, stockholders, or other persons who had the power to elect or appomt one or more members of the governing body? 7a Are any governance of the organization reserved to (or subject to approval by) members, stockholders, or persons other than the governing body? 7b 8 Did the organization contemporaneously document the meetings held or written actions undertaken during the year by the followmg a The governing body? 8a Each committee With authority to act on behalf of the governing body? 8b 9 Is there any of?cer, director, trustee, or key employee listed in Part VII, Section A, who cannot be reached at the organization's mailing address? If "Yes, provide the names and addresses in Schedule 0 9 Section B. Policies 1T his Section requests information about polrcres not required by the Internal Revenue Code Yes No 10a Did the organization have local chapters branches. or af?liates? 10a If "Yes, did the organization have written polices and procedures governing the activmes of such chapters, af?liates, and branches to ensure their operations are con3istent With the organization's exempt purposes? 10b 11a Has the organization provided a complete copy of this Form 990 to all members of its goveming body before ?ling the form? 11a Describe in Schedule 0 the process, if any, used by the organization to rewew this Form 990 1 12a Did the organization have a written con?ict of interest policy? if "No, go to line 13 12a Were officers, directors, or trustees, and key employees reqUIred to disclose annually interests that could give nse to con?icts? 12b Did the organization regularly and con3istently monitor and enforce compliance With the policy? if "Yes, describe in Schedule 0 how this was done . 12c 13 Did the organization have a written whistleblower policy? . 13 14 Did the organization have a written document retention and destruction policy? . 14 15 Did the process for determining compensation of the followmg persons include a reVIew and approval by independent persons, comparability data, and contemporaneous substantiation of the deliberation and deCision'? a The organization's CEO, Executive Director, or top management of?mal 15a Other of?cers or key employees of the organization 15b If "Yes" to line 15a or 15b, describe the process in Schedule 0 (see instructions) 16a Did the organization invest in, contribute assets to. or partICipate in a pint venture or similar arrangement with a taxable entity during the year? . . 16a If "Yes, did the organization follow a written policy or procedure requmng the organization to evaluate its partICIpation in mint venture arrangements under applicable federal tax law, and take steps to safeguard the organization's exempt status With respect to such arrangements? 16b Section C. Disclosure 17 List the states With which a copy of this Form 990 is reqUIred to be ?led 18 Section 6104 reqUIres an organization to make its Forms 1023 (1024 or 1024-A if applicable), 990. and 990-T (Section 501(c) 3 only) available for public inspection Indicate how you made these available Check all that apply Own web5ite El Another's web3ite Upon request El Other (explain in Schedule 0) 19 Describe in Schedule 0 whether (and if so, how) the organization made its governing documents, con?ict of interest policy, and Manual statements available to the public during the tax year 20 State the name, address, and telephone number of the person who possesses the organization's books and records Form 990 (2018) Form 990 (2018) RULE OF LAW TRUST 83-1047727 Compensation of Of?cers, Directors, Trustees, Key Employees, Highest Compensated Employees, and Independent Contractors Check if Schedule 0 contains a response or note to any line in this Part VII Section A. organization's tax year Officers, Directors, Trustees, Key Employees, and Highest Compensated Employees 1a Complete this table for all persons requrred to be listed Report compensation for the calendar year ending With or Within the Page 7 0 List all of the organization's current of?cers, directors, trustees (whether indiVIduals or organizations), regardless of amount of compensation Enter -0- in columns (D), (E), and (F) if no compensation was paid List all of the organization's current key employees, if any See instructions for de?nition of "key employee 0 List the organization's ?ve current highest compensated employees (other than an of?cer, director, trustee, or key employee) who received reportable compensation (Box 5 of Form andlor Box 7 of Form 1099-MISC) of more than $100,000 from the organization and any related organizations 0 List all of the organization's former of?cers, key employees, and highest compensated employees who received more than $100,000 of reportable compensation from the organization and any related organizations 0 List all of the organization's former directors or trustees that received, In the capacrty as a former director or trustee of the organization, more than $10,000 of reportable compensation from the organization and any related organizations List persons in the following order indivrdual trustees or directors. institutional trustees. of?cers, key employees, highest compensated employees, and former such persons Check this box if neither the organization nor any related organization compensated any current of?cer, director, or trustee (Cl Posrtion (A) (B) (do not check more than one (D) (E) (F) Name and Title Average box, unless person is both an Reportable Reportable Estimated hours per of?cer and a director/trustee) compensation compensation amount of week (list any 0 5 5 a, 31 from from related other hours for a 3 53 3 the organizations compensation related 5 a 8; 8 2 organization (W-ZI1099-MISC) from the organizations 8? a: (W-211099-MISC) organization below dotted a .2 3 and related line) organizations Trustee 0 00 0 0 0 "(all 11.9) 11.1.1 11.1.31 Form 990 (2018) Form 990 (2018) RULE OF LAW TRUST 83-1047727 Page 8 . Part VII Section A. Officers, Directors, Trustees, Key Employees, and Highest Compensated Employees (continued) (Cl Posmon (A) (B) (do not check more than one (D) (E) (F) Name and title Average box, unless person is both an Reportable Reportable Estimated hours per ol?cer and a director/trustee) compensation compensation amount of week (list any 0 5- a, I 'n from from related other hours for 3. 3 2 the organizations compensation related a 8; a 9; organization from the organizations 8- (W-211099-MISC) organization below dotted 3 2 3 and related line) cu organizations 01 :3 CD a a 11.5) 11.6) 11.9) it?) (2.9) 12.1) til-ill (2.5) 1b Sub-total . . 0 0 0 Total from continuation sheets to Part VII, Section A 0 0 0 Total (add lines Total number of indiwduals (including but not limited to those listed above) who received more than $100,000 of reportable compensation from the organization 0 Yes No 3 Old the organization list any former of?cer, director, or trustee, key employee, or highest compensated I employee on line 1a? If "Yes, complete Schedule for such indiwdual . 3 4 For any indiVIdual listed on line 1a, is the sum of reportable compensation and other compensation from the organization and related organizations greater than $150,000? If "Yes, complete Schedule for such indiwdual . 4 5 Did any person listed on line 1a receive or accrue compensation from any unrelated organization or indiwdual for serwces rendered to the organization? If "Yes, complete Schedule for such person 5 Section B. Independent Contractors 1 Complete this table for your five highest compensated independent contractors that received more than $100,000 of compensation from the organization Report compensation for the calendar year ending With or Within the organization's tax year (Al (B) (C) Name and busmess address Description of services Compensation Jonathan Bunch Box 11338 McLean, VA 22102-1338 Consulting 1.540.000 YAS, LLC PO Box 28041 Washington, DC 20038 Consulting 300.004 The Library of Congress 101 Independence Ave SE Washington, DC 20540 Research 250,000 ?gnemPublishing 300 New Jersey Ave NW Washington, DC 20001 Research 230,000 Holtzman Vogel 45 North Hill Drive Ste 100 Warrenton, VA 20186 Legal 172,945 2 Total number of independent contractors (including but not limited to those listed above) who received more than $100,000 of compensation from the organization 7 Form 990 (2018) RULE OF LAW TRUST Form 990 (2018) 83-1047727 Page 9 . Statement of Revenue Check If Schedule 0 contains a response or note to any lme In thIS Part El (A) (B) (C) (D) Total revenue Related or Unrelated Revenue exempt busmess excluded from functlon revenue tax under secuons revenue 512?514 ?2 3 1a Federated campaigns . 1a 0 Membership dues 1b 0 Fundralsmg events 1c 0 5 Related organizations 1d 0 g' Government grants (contributions) 1e 0 a All other gll?ts. grants, and 5 Similar amounts not Included above 1f 791999.550 Noncash contnbutlons Included In Ilnes 1a?1f 0 Total. Add lines 1a?1f 79,999,550 Busmess Code All other program servnce revenue 0 Total. Add ?me 2a?2f . . I 3 Investment Income (Including Interest. and other sumllar amounts) . 451,920 451,920 4 Income from Investment of tax-exempt bond proceeds 0 5 Royalties 0 (I) Real (In) Personal 6a Gross rents Less rental expenses Rental Income or (loss) . 0 0 Net rental Income or (loss) 0 7a Gross amount from sales of (I) Secunhes We" assets other than Inventory 0 0 Less cost or other basrs and sales expenses 0 0 Gain or (loss) 0 0 Net gain or (loss) 0 0 3 8a Gross Income from fundralsmg events (not Including 0 of contributions reported on lune 1c) '5 See Part IV, line 18 a 0 5 Less direct expenses 0 Net Income or (loss) from fundralsmg events 0 9a Gross Income from gaming See Part IV, lme 19 a 0 Less direct expenses 0 Net Income or (loss) from gammg actuvutles 0 10a Gross sales of Inventory, less returns and allowances a 0 Less cost of goods sold I) 0 Net Income or (loss) from sales of Inventory 0 Miscellaneous Revenue Business Code 11a 0 0 0 All other revenue 0 Total. Add lines 11a?11d 0 1 12 Total revenue. See 80,451,470 451,920 Form 990 (2018) Form 990 (2018) RULE OF LAW TRUST 83-1047727 Page 10 - Statement of Functional Expenses Section 501(c)(3) and 501(c)(4) organizations must complete all columns All other organizations must complete column (A) Check if Schedule 0 contains a response or note to any line in this Part lX DO "at incmde amounts reported on lines 6b' 7b? Total e?xenses and Fundgismg 8b, 9b! and 10b Of Part expenses general expenses expenses 1 Grants and other assistance to domestic organizations domestic governments See Part IV, line 21 0 0 2 Grants and other assistance to domestic indiwduals See Part IV, line 22 0 0 3 Grants and other aSSistance to foreign organizations, foreign governments. and foreign See Part IV, lines 15 and 16 0 4 Bene?ts paid to or for members . 0 5 Compensation of current of?cers, directors, trustees and key employees 0 0 0 0 6 Compensation not included above to disquali?ed persons (as de?ned under section 4958(0(1)) and persons described in section 4958(c)(3)(B) . 0 7 Other salaries and wages 0 I 8 Pen5ion plan accruals and contributions (include I section 401(k) and 403(b) employer contributions) 0 I 9 Other employee bene?ts 0 10 Payroll taxes 0 11 Fees for serwces (non- employees) a Management . 0 Legal 189,978 172,945 17,033 0 Accounting . 3,800 0 3,800 0 Lobbying 0 Professional fundraismg services See Part IV, line 17 0 Investment management fees 4,587 0 4,587 0 9 Other (If line 119 amount exceeds 10% of line 25. column (A) amount. list line 119 expenses on Schedule 0) 2,532,059 2,532,059 0 0 12 Advertismg and promotion . 0 13 Of?ce expenses . . . 171 150 21 0 14 Information technology 0 15 Royalties . 0 16 Occupancy 149 0 149 0 17 Travel . . 0 18 Payments of travel or entertainment expenses for any federal, state, or local public of?CIaIs 0 19 Conferences, conventions, and meetings 0 20 Interest 0 21 Payments to af?liates 0 22 Depreciation, depletion, and amortization 0 0 0 0 23 Insurance 0 I 24 Other expenses Itemize expenses not covered I above (List miscellaneous expenses in line 24e If line 24e amount exceeds 10% of line 25, column 1 (A) amount, list line 24e expenses on Schedule 0 I a 5.549 5.549 I I 0 I 0 I All other expenses 0 I 25 Total functional expenses. Add lines 1 through 24e 2,736,293 2,705,154 31,139 0 26 Joint costs. Complete this line only if the I organization reported in column (B) iomt costs from a combined educational campaign and fundraismg soIiCItation Check here if followmg SOP 98-2 (ASC 958-720) I Form 990 (2018) Form 990 (2013) RULE OF LAW TRUST 83-1047727 Page 11 Balance She'et Check If Schedule 0 contains a response or note to any ltne In Part . I: (A) (B) Beginning of year End of year 1 Cash?non-Interest?beartng . 0 1 23,621,985 2 and temporary cash Investments 0 2 52,905,461 3 Pledges and grants receivable, net 0 3 4 Accounts receivable, net 0 4 0 5 Loans and other receivables from current and former of?cers, directors, trustees, key employees. and highest compensated employees Complete Part II of Schedule 0 5 6 Loans and other receivables from other disquali?ed persons (as de?ned under section 4958(f)(1)), persons descnhed tn section 4958(c)(3)(B), and employers and sponsonng organizations of section 501(c)(9) voluntary employees' bene?crary organizations (see instructions) Complete Part II of Schedule 0 6 7 Notes and loans receivable, net 0 7 0 8 Inventones for sale or use . . 8 9 Prepaid expenses and deferred charges 0 9 1,639,996 10a Land, and equrpment cost or other basis Complete Part VI of Schedule 10a 0 Less accumulated deprecratlon . 10b 0 0 11 Investments?publicly traded securities 0 11 12 Investments?other securities See Part IV, line 11 . 0 12 0 13 lnvestments?program-related See Part IV, line 11 13 0 14 Intangible assets 0 14 0 15 Other assets See Part IV, line 11 0 15 47,745 16 Total assets. Add lines 1 through 15 (must equal line 34) 0 16 78,215,187 17 Accounts payable and accrued expenses 0 17 4,324 18 Grants payable 0 18 19 Deferred revenue 0 19 20 Tax-exempt bond liabilities 0 20 21 Escrow or custodial account liability Complete Part IV of Schedule 0 21 3 22 Loans and other payables to current and former of?cers, directors. ?13 trustees, key employees, highest compensated employees, and disquali?ed persons Complete Part II of Schedule 0 22 :1 23 Secured mortgages and notes payable to unrelated third parties 0 23 0 24 Unsecured notes and loans payable to unrelated third parties . 0 24 0 25 Other liabilities (including federal Income tax, payables to related parties, and other liabilities not Included on lines 17?24) Complete Part of Schedule . . 0 25 0 26 Total liabilities. Add lines 17 throggh 25 26 4,324 Organizations Iltal follow SFAS 117 (A30 953), check here and complete lines 27 through 29, and lines 33 and 34. 27 Unrestricted net assets 0 27 78,210,863 3 28 Temporarily restricted net assets 0 28 'g 29 Permanently net assets 0 29 if Organizations that do not follow SFAS 117 check here El and '6 complete lines 30 through 34. 30 Capital stock or trust or current funds 0 30 31 Paid?tn or capital surplus, or land, bUIldan, or equrpment fund 0 31 32 Retained earnings, endowment, accumulated Income, or other funds 0 32 33 Total net assets or fund balances 0 33 78,210,863 34 Total liabilities and net assets/fund balances . 0 34 78,215,187 Form 990 (2018) Form 990 (2018) RULE OF LAW TRUST Part XI Reconciliation of Net Assets Check if Schedule 0 contaIns a response or note to any Me In this Part XI . 33-1 047727 Page 1 2 a Total revenue (must equal Part column (A), Me 12) Total expenses (must equal Part IX. column (A), We 25) Revenue less expenses Subtract Me 2 from me 1 Net assets or fund balances at begInnIng of year (must equal Part X, Me 33, column Net unrealIzed gains (losses) on Investments Donated serVIces and use of faCIlItIes Investment expenses PrIor perIod adjustments . Other changes In net assets or fund balances (explaIn In Schedule 0) Net assets or fund balances at end of year CombIne ?ms 3 through 9 (must equal Part km 33 column 80,451,470 2,736,293 77,715,177 0 495,686 .5 78,210,863 Part XII Financial Statements and Reporting Check If Schedule 0 contaIns a response or note to any Me In this Part XII I3 2a 3a method used to prepare the Form 990' Cash Accrual Other If the organizatIon changed Its method of accountan from a prIor year or checked "Other," epraIn In Schedule 0 Were the organizatIon's ?nanCIal statements compIIed or reVIewed by an Independent accountant? If "Yes," check a box below to Indicate whether the ?nanCIaI statements for the year were compIIed or reVIewed on a separate basrs, consolIdated baSlS, or both Separate Consolidated '3 Both consolidated and separate Were the organlzatIon's ?nanCIal statements audIted by an Independent accountant? If "Yes," check a box below to IndIcate whether the Manual statements for the year were audIted on a separate baSIs, consolidated ham, or both I: Separate El ConsoIIdated El Both consolidated and separate If "Yes" to Me 2a or 2b, does the organIzatIon have a commIttee that assumes responSIbIlIty for overSIght of the audIt, reVIew, or compilatIon of Its ?nanCIaI statements and selection of an Independent accountant? If the organization changed eIther Its overSIght process or selectIon process durIng the tax year, explaIn In Schedule 0 As a result of a federal award, was the organIzatIon reqUIred to undergo an audIt or audIts as set forth In the SIngle AudIt Act and OMB CIrcular If ?Yes," dId the organizatIon undergo the reqUIred audIt or audIts? If the organIzatIon dId not undergo the reqmred audIt or audIts, epraIn why In Schedule 0 and descrIbe any steps taken to undergo such audIts Yes No 2a 2b 26 3a 3b Form 990 (2018) Transactions With Interested Persons 15450047 SCHEDULE (Form 990 or 990-EZ) Complete if the organization answered "Yes" on Form 990, Part IV, line 25a, 25b, 26, 27, 28a, 28b, or 28c, or Form QQO-EZ, Part V, line 38a or 40b. Department of the Treasury DAttach to Form 990 or Form 990-EZ. Open To Public Internal Revenue Semee Go to for instructions and the latest information. 'nSPECtlon Name of the organization Employer identi?cation number RULE OF LAW TRUST 83-1047727 Excess Bene?t Transactions (section 501(c)(3). section 501(c)(4). and 501(c)(29) organizations only) Complete if the organization answered "Yes" on Form 990, Part IV. line 25a or 25b. or Form 990-EZ, Part V, line 40b. Relationship between disquali?ed person and Corrected? Name of disqualr?ed person organization Description of transaction Enter the amount of tax incurred by the organization managers or disquali?ed persons during the year under section 4958 . . 3 Enter the amount of tax. if any. on line 2. above, reimbursed by the organization . . Loans to andlor From Interested Persons. Complete if the organization answered "Yes? on Form 990-EZ, Part V, line 383 or Form 990, Part IV, line 26. or if the organization reported an amount on Form 990. Part X, line 5. 6, or 22 Name of interested person Relationship Purpose of Loan to or Original Balance due (9) In Approved Written With organization loan from the pnnCIpal amount by board or agreement? organization? committee? To From Grants or Assistance Bene?ting Interested Persons. Complete if the organization answered "Yes" on Form 990, Part IV, line 27 Name of interested person Relationship between interested Amount of a55istance Type of assmtance Purpose of asSistance person and the organization 9 1 For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ. Schedule (Form 990 or 990-52) 2613 HTA I 5 Schedule (Form 990 or 990-EZ) 2018 RULE OF LAW TRUST 83-1047727 page 2 Part lV Business Transactions Involving Interested Persons. Complete if the organization answered "Yes" on Form 990, Part IV, line 28a, 28b, or 280 Name of interested person Relationship between Amount of Description of transaction Sharing of interested person and the transaction organization's organization revenues? Yes No (1) BH Group LLC See Part 4.345.000 See Part (Supplemental Information. Prowde additional information for responses to questions on Schedule (see instructions) .95). Pi'?t?r?sf?gf?rEQU- .3 .91'992 LB) -9959}! 5109. 9133.0 [2.99911 9.09?! I992 39.311 9! (9599.90! 52f. Q??q 9- .021 9 9.5.90 PILQDQE 0.3.3.9993 ft". 99. [9 S320 HIGHER 31?? [Elf 91 Bf LEW. Ir??t [19 ?993 9.3.0? {it 9f H19. 193?! .3. 920E FEOUQQEQE 939.3 9.091%. 99.4 .9010? 9.0.99 -5119 5352 .9199?. 521959.919. 919995! 10.91 152929 9.5.95} Schedule (Form 990 or BSD-E2) 2018 SCHEDULE 0, Supplemental Information to Form 990 or 990-EZ OMB No 15450047 (Form 990 or 990-EZ) Complete to provide information for responses to speci?c questions on Form 990 or 990-EZ or to provide any additional information. 5 Attach to Form 990 or 990-EZ. Open to Public Go to for the latest information. Inspection Name of the organization Employer identi?cation number RULE OF LAW TRUST 83-1047727 Ea .5. 99319 .3.- 9- 1 39. 1'19 ?919] 39.0.19 Rte. 99?99 99.991.99. E9 91'? 3999993991 9.99 919.5399. 13.99! 19. L99 9. .39. [99.9. [3.9 .599199. 9-9199. 3.9. In?? 1591919991: 1952902919999 9993-919 991999999. 9.99] [9 [5.9.9.9 - 99. 9999199995. 919. 9.99 19.919 '36! U. '25; LIFE .11. 9. 9111.9! 03.9! .92. -.5. 9.2.- 9.499.- 999. For Paperwork Reduction Act Notice. see the Instructions for Form 990 or 990-EZ. Schedule 0 (Form 990 or 990-EZ) (201a) HTA Schedule 0 (Form 990 or 990-EZ) (2018) page 2 Name of the organza?on a Employer Identx?cation number RULE OF LAW TRUST 83-1047727 Schedule 0 (Form 990 or 990-52) (2013)