Inside Risk with Emily Cummins, National Rifle Association

The NRA's Director of Tax and Risk Management explains how using the rules of gun safety helps her handle the challenges for this often-controversial nonprofit.

September 25, 2013 Photo

Though widely recognized as a major political force and America’s foremost defender of Second Amendment rights, the NRA’s goal is like most organizations when it comes to risk: stay out of the crosshairs. Director of Tax and Risk Management and CLM Fellow Emily Cummins explains how using the rules of gun safety helps her handle the challenges for this often-controversial nonprofit.

Q. Talk about your career and how you came to work in risk management at the NRA. 

A. Personal credibility is key when you represent an organization like the NRA during your career. Before moving in-house with the NRA seven years ago, I worked for Wachovia (now Wells Fargo) and Ernst & Young.

Q. What is your day-to-day life like as director of tax and risk management for the NRA?

Preferably on the move. Working in the field consistently provides greater value add. Even the tax work is not necessarily accomplished behind a desk.

Q. What is your overall approach to risk management? Do you employ enterprise risk management techniques?

A. This may surprise some readers of Claims Management, but a nonprofit’s greatest exposure is tax risk, which is generally uninsurable. The decisions that are made for all teams must promote the nonprofit’s primary exempt purposes. Consistent with its founding in 1871 in New York, the NRA is primarily an education, safety, and training organization.

The NRA’s corporate structure also includes four charities and its political action committee. To manage the tax risks of a complex organization, I sincerely value relationships of mutual warm respect with federal and state regulators. We share a vision for good governance, transparency, and accountability in the sector.

Getting back to insurable risks, let me illustrate just one of multiple coverage lines. An organization with more than five million current recorded members spotlights exposures such as data security and privacy liability. At the risk management society known as RIMS, I chair the technology advisory council where we focus on cyber risks. Applying the RIMS risk maturity model shows the NRA at level three for enterprise risk management implementation.

Q. Have you ever taken a risk and turned it into an opportunity?

A. A firearm is a tool controlled by the user’s mindset. I take any opportunity to explain the NRA’s gun safety priorities and to emphasize storing guns so that they are not accessible to unauthorized persons. Each day, and millions of times a year, guns are used to deter crime, to hunt, to participate in competitions, and to save lives.

Safety is the first and foremost priority. Trainers constantly drill the fundamentals of responsible storage and safe handling. The rules of gun safety are always these: keep the gun pointed in a safe direction, keep your finger off the trigger until ready to shoot, and keep the gun unloaded until ready to use.

Q. There is no such thing as bad press. As a risk manager, do you agree with that statement?

A. In light of the sensitivity of recent events, often the most appropriate public response is to maintain a compassionate silence.

Q. How does the renewed interest in gun legislation affect your risk management policy positions?

A. Proposals of mandatory liability insurance for gun buyers reveal poorly conceived tactics that would punish only the law-abiding, not the criminals. The flawed theories behind such ideas are inconsistent with how liability insurance is designed to function.

Related concerns include proposed higher taxes on firearms and ammunition and escalating costs for purchase permits and carry licenses. These sorts of schemes act as economic discrimination, as if only the wealthy should be able to exercise their inalienable rights.

Federal circuit court splits reflect unsettled interpretations of the law that will be resolved, ultimately, by the U.S. Supreme Court. Lawyers supported by NRA’s civil rights defense fund as well as other non-NRA organizations continually pursue these goals. At the heart of every case is a set of powerful human stories.

Q. What has been your biggest risk-related success?

A. The documented reduction in criminal violence due to safe and responsible firearms ownership.

Q. Can you discuss an interesting or unique claims experience?

A recent court filing connected the NRA to spaceships, X-ray beams, and anti-gravity technology. I referred that one to the fabulous media and entertainment lawyer Lincoln Bandlow.


About The Authors
Eric Gilkey

Eric Gilkey is vice president of content at the CLM, and serves as executive editor of CLM magazine, the flagship publication of the CLM.

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