Risk Management

Managing Risks at the National Rifle Association

The NRA’s risk manager is a true believer in the gun lobby’s mission.
David KatzApril 22, 2016

“It’s such a significant part of what we’re doing for the future,” Emily Cummins, the risk manager of the National Rifle Association, says, enthusiastically describing the NRA’s charitable gift annuity program.

The focus of the NRA “is always on training, education, and safety of the next generation: the grandparents taking their grandkids out to learn to shoot safely and responsibly and to love the outdoors,” she said in an interview at the recent Risk and Insurance Management Society conference in San Diego.

Cummins, whose actual title is managing director of tax and risk management, began working on the NRA’s annuity when she was assistant vice president and planned giving adviser at Wachovia before the bank was acquired by Well Fargo in 2008.

Emily Cummins

Emily Cummins

As she does with other aspects of finance and risk management, Cummins speaks about the annuity in terms of the NRA’s mission — a mission she indicates she’s personally committed to. Thus the annuity is part of the powerful lobbying group’s goal of having the financial resources to preserve gun rights for future generations and to provide current gun owners the opportunity to create a “heritage” of support for those rights.

After her four-year stint at Wachovia, which followed four years as an Ernst & Young accountant, Cummins joined the NRA in 2006 and became the association’s first risk manager. An edited and excerpted version of the interview follows.

What’s the approach to enterprise risk management at the NRA?
When I was brought aboard, the perspective was: How can we start from the top? We’re not developing individual programs and trying to get people to buy into them. We’re starting at the C-suite in setting strategic risk priorities and then working down from there. So it’s not me pushing up; it’s the executives pushing throughout the whole organization. The goal is to make sure that it’s measurable, it’s replicable, that you’ll leave a legacy beyond yourself that the next set of risk managers at the NRA will be able to follow as well.

The model we use means defining very precisely who and what you are. For us, the mission is so central every day. We have this two-part mission. We’re the world leader in firearms education, safety, and training. And on the political side, we’re a leading defender of civil rights. Frankly, when you work with firearms, every individual is a risk manager.

What are your goals as risk manager?
All of our hires have their own area of specialty. You might have, for instance, teams that specialize in hosting our shows and events, in supply chain, financial risk, internal audit, compliance functions, and investment risk. As the risk manager my goal is to make sure that we’re not siloed but are collaborating and talking with each other. The enjoyable job that a risk manager has is as an educator and a persuader. We’re judged professionally by the actions of people who don’t necessarily report to us, people we can’t control. But they’re people that we influence through persuasion. That collaboration is the power of being a risk manager. And it’s an incredible privilege to do it.

You seem very excited about that.
Oh, I love it.

What do you love most about the job?
The people. The people who work with me are so passionate. Everyone who works at the NRA is there for a reason. Their lives have been touched by the mission. They’re mission-driven. We wake up each day and we know that what we do matters. And so when I’m seeking buy-in for, say, an initiative, I’m completely confident I will achieve it because my colleagues share my vision. I don’t have to question whether that team going to second-guess the ultimate goal. No. We might disagree on the small steps, but ultimately we’re all going in the same direction.

How has the mission touched your life?
I really believe in what we do everyday. And I joined the NRA from the banking world and devote my career to it. I don’t talk about myself personally.

As a risk manager, do you work closely with the CFO?
Oh yes. I report to the CFO, Woody Phillips. He’s a fantastic leader. Inspirational. Woody is not just a shooter and a gun collector himself. He has a lot of fun doing the technical, hard work of running a major institution like the NRA. It’s a lot of detailed work with a grand vision, and he’s right there.

What’s your role been in terms of preserving the NRA’s future income?
When I was at Wachovia my role there involved the NRA Foundation’s planned giving assets.
 And a neat aspect of that dimension is the charitable gift annuity program. With charitable gift annuities, a public charity like the NRA Foundation can offer gift annuities to older people in exchange for a live income stream. Let’s say a typical gift is $75,000 and that a gentleman and his wife in their 60s or 70s donate that dollar amount in exchange for a charitable gift annuity with NRA Foundation. It pays out to them for the rest of their lives, including the second the first person, and then the remaining person, dies. Upon the death of the second person, the residuum of that gift is free to serve the charitable purpose. In other words, the role of the charitable gift annuity program is to invest those assets in the NRA and in the meantime provide monthly annuity payments to the donor. It’s called a “split-interest gift.”

The donors have the assurance that when they pass away, the rest of those assets have been preserved and will immediately go to fund the purpose that they have for it, whether it’s a named scholarship program, or a hunting leadership endowment, or a women’s leadership forum. So these different charitable purposes are served. 

What portion of your membership is buying the annuities?
Only a small percentage of members would have the resources and the interest to fund the charitable gift annuity. They’re part of a very special group of people that we call the NRA Ring of Freedom Heritage Society. “Heritage Society,” which refers to legacy giving, is for people that have mentioned the organization in their will, trust, or estate. The gift annuity is such a profoundly meaningful program because those donors have not only shown the commitment and the investment but they’re giving you the dollars in their lifetime. They’re not even waiting until they pass away.

What’s your take on the NRA’s reputational risk?
The best response I give when I’m asked about reputation risk is that when our organization’s leadership is doing what’s right for the mission to protect law-abiding gun owners and looking at the big picture, [the organization] will succeed in the long term.