How Make the Road New York Uses Legal Loopholes to Transform Public Funds into Political Power

Executive Summary

New York City taxpayers are unknowingly subsidizing partisan political activities through a sophisticated legal loophole that allows publicly funded nonprofits to directly transfer money to political action committees. Our investigation reveals how Make the Road New York (MRNY), which has received over $27 million in taxpayer funds since 2010, operates a dual structure with its political affiliate Make the Road Action (MRA) that creates a direct pipeline from public coffers to campaign activities.

In 2023 alone, MRNY received $16.1 million in government grants and then transferred $165,000 of taxpayer money directly to its political affiliate MRA for “workplace justice”—money that flows into a political network supporting specific candidates (MRNY IRS Form 990, Schedule I, Page 36/43). The same individuals who manage the taxpayer-funded nonprofit also run the political organization, with shared personnel including executive directors who work for both entities simultaneously.

The most damning evidence of coordination came on June 11, 2025, when identical transactions of $45,697.14 flowed in opposite directions between MRA and WFP National PAC on the same day—a circular financial maneuver that provides strong evidence these supposedly independent organizations may be actively coordinating their activities. This same-day, penny-identical pattern appears impossible to achieve without pre-planning and demonstrates how the network may use technical compliance to mask substantive political coordination.

This investigation reveals a blueprint that appears to be replicated across the nonprofit sector, with similar taxpayer-funded political networks operating throughout New York City, suggesting this represents a systematic approach to circumventing campaign finance transparency rather than an isolated case.

The Smoking Gun: $45,697 in Circular Coordination

On June 11, 2025, two transactions occurred that may expose the coordinated nature of this supposedly “independent” network:

Transaction 1: MRA contributes $45,697.14 to WFP National PAC
Transaction 2 (Same Day): WFP National PAC records a $45,697.14 “In-Kind” expenditure for “PHONE” services paid back to MRA

Why This Pattern Suggests Coordination

The identical amounts and same-day timing appear difficult to explain as coincidence. For these transactions to be legitimate and independent:

• WFP would need to process MRA’s contribution, determine they needed phone services, negotiate a contract with MRA, and execute payment—all within hours
• The service contract would need to cost exactly the same amount as the contribution, calculated to the penny
• Both organizations would need to independently decide on the same dollar figure and timing

What NYC Law Says: NYC Campaign Finance Board Rule 5-03(e) defines coordination as when organizations “authorize, request, suggest, foster or cooperate” in campaign activities. The CFB looks for “indicia of cooperation” and determines coordination when organizations show evidence of coordinated planning or execution. Same-day, identical-amount transactions may constitute evidence requiring examination.

Potential Investigation: Rather than MRA contributing $45,697 and separately purchasing $45,697 in services, this pattern suggests MRA may be purchasing services from WFP with the understanding that the payment would be structured as a contribution-plus-payment-back to potentially obscure the true nature of the relationship.

This coordination evidence warrants investigation by the NYC Campaign Finance Board under their authority to examine potential violations of independent expenditure rules and determine whether these organizations may be improperly coordinating political activities.

How the Network Operates: Following the Money

To understand this investigation, readers need to grasp how three key organizations work together while maintaining legal separation:

The Players:

• Make the Road New York (MRNY) – 501(c)(3) nonprofit that receives $27+ million in NYC taxpayer funds for community services
• Make the Road Action (MRA) – Political organization that campaigns for candidates and makes political contributions
• Working Families Party National PAC (WFP) – Independent expenditure committee that spends money supporting/opposing candidates

The Coordination:

• Shared Leadership – The same people run both MRNY and MRA (Theo Oshiro, Daniel Altschuler)
• Financial Pipeline – MRNY transfers money to MRA ($165,000 in 2023)
• Political Integration – Make the Road Action is one of the top three donors to WFP National PAC, led by National WFP Deputy Director Joe Dinkin

The Money Flow:

Why This Matters: Taxpayer money intended for community services appears to flow through this network to support specific political candidates, while the organizations maintain they operate independently. The June 11th circular transaction provides evidence suggesting this coordination may extend to active financial coordination.

The Direct Taxpayer-to-Politics Pipeline

Legal and Ethical Analysis:

The documented money flow raises significant questions about compliance with federal tax law and municipal funding restrictions. When a 501(c)(3) organization receiving substantial government grants makes direct cash transfers to political entities, it potentially violates IRS regulations governing tax-exempt status and allowable political activities.

Municipal Funding Restrictions: NYC contracts and grants typically include explicit restrictions on using public funds for political activities. The direct transfer from MRNY to MRA may violate these restrictions, particularly when the same personnel manage both organizations and coordinate activities supporting specific candidates.

Voter Deception Concerns: Citizens encountering MRNY organizers in their communities may not realize they’re interacting with representatives of an organization that simultaneously receives $27+ million in taxpayer funding and transfers money to political entities. This creates potential voter deception about the true sources of political support.

This isn’t theoretical—it’s documented in official filings. In 2023, Make the Road New York, flush with $16.1 million in government grants, made a direct $165,000 cash transfer to Make the Road Action designated for “WORKPLACE JUSTICE.” That money entered a political ecosystem where MRA actively campaigns for specific candidates, contributes to independent expenditure committees, and mobilizes thousands of volunteer hours for electoral activities.

The scale is staggering. NYC Checkbook records reveal that what appears to be a story about recent discretionary grants is actually a $27.4 million taxpayer investment in political infrastructure spanning 15 years. In just the past three years (2023-2025), MRNY received $6.39 million from New York City—creating a massive publicly funded foundation for what may be partisan political activities.

Public Subsidy, Private Influence

Make the Road New York has become one of NYC’s most heavily subsidized nonprofit organizations, receiving consistent funding across multiple administrations and agencies:

Recent NYC Disbursements:

• Fiscal Year 2023: $1,612,381.92
• Fiscal Year 2024: $3,269,189.69
• Fiscal Year 2025: $1,508,620.35 (as of June 10)

Major Funding Sources (2023-2025):

• Department of Education: $2,792,527.67
• Department of Social Services: $2,311,183.74
• Department of Youth and Community Development: $1,588,646.05
• Department of Cultural Affairs: $463,880.00

Source: Analysis of NYC Checkbook disbursement records by agency for fiscal years 2023-2025

Beyond broad disbursements, MRNY has secured consistent NYC Council discretionary grants, creating a reliable annual funding stream:

“Know Your Rights” Program Grants:

• 2024: $200,000 – Immigration protection program via Consortium for Worker Education
• 2023: $200,000 – Same program structure
• 2022: $200,000 – Same program structure
• 2021: $142,155 – Same program structure
• 2020-2015: $200,000 annually for similar programs

This cumulative public investment provides crucial operational infrastructure that directly benefits MRNY’s political affiliate through shared personnel, messaging, and organizational capacity.

The Political Action Engine

While MRNY builds community trust with taxpayer funds, Make the Road Action (MRA) converts that social capital into electoral power. MRA’s explicitly political mission statement declares its intent to “builds political power rooted in working-class Latinx communities” and “strengthens the movement for justice through electoral and grassroots organizing to advance progressive political and policy change.”

MRA’s Political Activities:

• 2022 Political Expenditures: $339,136 in campaign activities [2023 Form 990, Schedule C (Political Campaign and Lobbying Activities), Part I-C, line 1]
• 2022 Volunteer Mobilization: 3,444 volunteer hours for political campaigns [2023 Form 990, Schedule C (Political Campaign and Lobbying Activities), Part I-A, line 3]
• 2023 Revenue: Over $4.3 million in continued operations [2023 Form 990, Part I Summary, line 12]
• Direct Political Contributions: $45,697.14 to WFP National PAC (NYC Campaign Finance Board, June 2025)

The financial connection between these entities isn’t theoretical—it’s direct and documented. The $165,000 transfer from MRNY to MRA in 2023 represents taxpayer money flowing directly into political infrastructure, creating a pipeline that transforms public funds into partisan influence (MRNY IRS Form 990, Schedule I, Page 36/43).

Personnel Integration: Same People, Different Hats

The organizations maintain the legal fiction of independence while operating with extensively shared leadership:

Key Personnel Overlaps (Sources: MRNY Form 990 and MRA Form 990):

• Theo Oshiro: Co-Executive Director at MRNY (40 hrs/week, $157,447) and Executive Director at MRA (10 hrs/week, $8,619)
• Daniel Altschuler: Director of Politics and Policy at MRNY (40 hrs/week, $134,658) and Co-Executive Director at MRA (10 hrs/week, $42,704)
• Lucia Gomez Jimenez: Listed as Director of MRA (2 hrs/week, no compensation) with prior public affiliations with MRNY, though not disclosed in MRNY’s 2023 Form 990
• Joe Dinkin: National WFP Deputy Director, which lists Make the Road Action as one of its top three donors, creating a direct financial relationship within the broader political network

This personnel integration may ensure strategic coordination while maintaining plausible legal separation. The same individuals who manage $16+ million in taxpayer funds also direct political campaign activities—a coordination that potentially undermines any meaningful firewall between public and political functions. The June 11th circular transaction provides concrete evidence suggesting this coordination in action.

The Mamdani Connection: Taxpayer-Funded Political Success

The Make the Road network’s political effectiveness is demonstrated through its sophisticated ranked-choice voting strategy. After initially endorsing NYC Comptroller Brad Lander in March, the Working Families Party announced in May a strategic ranked slate with Mamdani #1, Lander #2, and NYC Council Speaker Adrienne Adams #3. This coordinated approach across the highest levels of NYC government exemplifies the strategic tactics described by critics.

Direct Support Infrastructure:

• MRA’s 3,444 volunteer hours for political activities (2022)
• Door-knocking and voter engagement programs
• Endorsement featured prominently on Mamdani’s campaign website

Financial Support Network:

• WFP National PAC spent $59,058 supporting Mamdani for mayor
• WFP strategically endorsed a coordinated slate including current NYC Comptroller Brad Lander and NYC Council Speaker Adrienne Adams
• MRA contributed $45,697.14 to WFP National PAC on June 11, 2025
• Same day, WFP National PAC paid MRA $45,697.14 for “PHONE” services

This circular financial relationship creates what appears to be a self-reinforcing system where taxpayer-funded organizations build the infrastructure that supports political committees that then contract back with those same organizations for campaign services. The coordinated support extends beyond individual candidates to encompass the highest levels of NYC government—the potential Mayor, current Comptroller, and Council Speaker—demonstrating how $27 million in taxpayer funds may have created political infrastructure capable of influencing multiple key city positions simultaneously.

The Broader Working Families Party Strategy

The Make the Road network operates within a larger WFP political ecosystem that has received criticism for exploiting legal loopholes. The WFP National PAC – NYS IE Committee, led by National WFP Deputy Director Joe Dinkin and counting Make the Road Action as one of its top three donors, reported:

2025 Financial Activity:

• Total Contributions: $703,475.05
• Supporting Candidates: $165,182 (including $59,058 for Mamdani)
• Opposing Candidates: $523,016 (primarily targeting Andrew Cuomo)

Critics argue that WFP leverages ranked-choice voting to “game” the electoral process and has a history of skirting campaign finance laws. According to the New York Post Editorial Board, the party “narrowly escaped criminal prosecution a decade ago” for allegedly circumventing finance laws through below-market pricing for campaign services via its for-profit arm Data and Field Services. The Post notes that the current campaign finance system “favors organized insiders like the WFP” and that the party continues “gaming the city’s ranked-choice voting system” through strategic multi-candidate endorsements.

Legal Loopholes, Ethical Questions

While this structure may be technically legal, it raises several ethical concerns that warrant investigation:

1. Potential Taxpayer Subsidy of Political Activities

The $165,000 direct transfer from MRNY to MRA, combined with the $45,697 circular transaction, suggests that taxpayer funds may directly subsidize political operations, regardless of the stated purpose.

2. Potentially Compromised Organizational Independence

Shared personnel across organizations receiving public funds and engaging in political activities may eliminate meaningful separation between taxpayer-funded community services and partisan political advocacy. The coordinated financial transactions provide evidence suggesting this integration.

3. Potentially Misleading Voter Information

Voters encountering Make the Road organizers may not be able to distinguish between taxpayer-funded community outreach and political campaign activities, potentially creating misleading messaging about grassroots versus government-subsidized support.

4. Circular Financial Relationships & In-Kind Obscurity

The circular flow of money, where MRA makes a cash contribution to WFP National PAC, and WFP then records an identical in-kind expenditure back to MRA for services, creates what appears to be a self-dealing system. This structure may obscure the true sources and uses of political funding, as in-kind contributions can be less transparent than direct cash payments in real-time disclosure. The June 11th transactions exemplify this potential coordination and the use of in-kind reporting to mask the true nature of the financial relationship.

The Disclosure Gap: Hiding in Plain Sight

Current disclosure requirements create significant transparency gaps:

Delayed Reporting: MRA’s 2023 Form 990 wasn’t filed until March 2025, meaning the $165,000 transfer remained hidden from public view for over a year.

Independent Expenditure Loopholes: MRA’s volunteer activities, door-knocking, and organizing escape real-time disclosure requirements since NYC CFB rules exclude “personal phone calls, in-person communications, free website content, emails, text messages, and free social media posts” from independent expenditure reporting.

Membership Organization Exemption: The CFB explicitly excludes “any communication by a labor or other membership organization aimed at its members” from independent expenditure definitions, allowing extensive political activities to operate without disclosure.

Coordination Evidence Hidden & In-Kind Disclosure Ambiguity: The June 11th circular transactions, with their in-kind classification for phone bank services, only became visible through careful cross-referencing of multiple reporting systems. This demonstrates how coordination evidence and the true nature of services can remain hidden, especially when in-kind reporting is used, despite disclosure requirements.

Conclusion: Legal Form vs. Ethical Substance

The Make the Road model represents what may be the most sophisticated example of how legal structures can potentially be used to circumvent the spirit of campaign finance laws while remaining technically compliant. Through careful organizational design, shared personnel, direct financial transfers, and coordinated transactions like the June 11th circular payments, the network creates what appears to be a seamless pipeline from taxpayer funds to political activities while maintaining the fiction of independence.

The core concern: Voters see trusted community organizations funded by their tax dollars, potentially unaware that the same infrastructure may be simultaneously driving partisan political outcomes. The $45,697 circular transaction on June 11, 2025, provides evidence suggesting this isn’t theoretical coordination—it may be documented financial integration requiring advance planning and cooperation.

The scale of the issue: With over $27 million in taxpayer funding since 2010, this represents what may be the largest documented case of public funds creating political infrastructure. Recent years show acceleration, with $7.4 million flowing to MRNY in just 2023-2025.

The accountability gap: Current disclosure requirements appear designed for traditional campaign structures, not sophisticated nonprofit-PAC networks that can delay reporting for over a year while conducting extensive political activities under membership and communication exemptions. The coordination evidence only emerged through cross-referencing multiple reporting systems.

Policymakers must urgently address how these legally permissible structures may allow taxpayer-funded organizing to be systematically converted into partisan political influence. The circular transaction evidence suggests that coordination may extend beyond shared personnel to active financial coordination. Federal and local enforcement agencies have the tools to investigate these arrangements: the IRS can examine potential tax-exempt status violations, the NYC Campaign Finance Board can investigate potential coordination violations, and the NYC Comptroller can review compliance with public fund restrictions.

Voters deserve to know when their tax dollars may be funding the campaigns seeking their votes. Until laws reflect the substance rather than just the form of political spending, democratic transparency may be undermined by the illusion of grassroots support backed by hidden taxpayer subsidies.

What’s Next

Make the Road is not the only NYC-based nonprofit engaging in these practices. Our ongoing investigation has identified multiple organizations operating similar taxpayer-funded political networks throughout New York City. This investigation reveals a systematic blueprint that numerous organizations have replicated, potentially representing widespread subversion of campaign finance laws across the nonprofit sector.

The discovery of coordinated financial transactions like the June 11th circular payments suggests that similar evidence may exist in other nonprofit-political networks. Enforcement agencies should examine whether this model is being replicated across the nonprofit sector, potentially representing a systematic subversion of campaign finance laws.

In coming months, we will continue exposing this nonprofit industrial complex that may function as a shadow government, transforming taxpayer investments into political power while maintaining the appearance of community-based advocacy.

The Make the Road model may not just be a legal loophole—it could represent a systematic approach to campaign finance law compliance that demands immediate examination and potential reform.

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Written by,

Sam Antar

© 2025 Sam Antar. All rights reserved.