By Meredith Lerner, Caitlin Moniz and Walker Davis
July 31, 2020

The Office of Government Ethics released President Trump’s public financial disclosure (PFD) covering 2019 on Friday, providing a narrow and opaque window into the president’s finances. The form shows the president’s businesses took in at least $446 million last year, up from at least $434 million in 2018. It is possible that Trump’s businesses earned significantly more than this sum, however, because Trump reported income from several sources in ranges and was not required to specify amounts received from particular assets above $5 million. The president spent much of 2019 visiting his properties and praising them during official remarks, and some of the properties he promoted the most saw financial gains.

While the form shows hundreds of millions of dollars in revenue, it provides no information about where all that money came from. President Trump’s refusal to divest from his business empire created a situation where special interests, foreign governments, and others are trying to curry favor with his administration by patronizing and spending more at his properties. Trump’s stake in these businesses has led him to amass more than 3,200 conflicts of interest since taking office.

Revenues jumped

Trump frequently makes promotional visits to his Trump Organization properties, and many of the properties that he visited the most in 2019 saw an uptick in revenue. Trump’s Bedminster golf resort, which he visited 19 times, saw a jump of about $2 million compared to the year before, taking in $17.7 million. His Doral and Washington, DC golf resorts, which he visited twice and 34 times respectively, both saw revenue increase by more than a million dollars, and revenue also went up at his West Palm Beach course. In total, his domestic golf courses took in more than $200 million in 2019, a more than $10 million increase over the previous year. This boost in revenues more than made up for the comparatively slight dips in revenue at Mar-a-Lago and his Washington, DC hotel.

International golf properties that President Trump owns appear to have done well on the whole, too. His golf courses in Ireland and Scotland reported a total of nearly $2 million more in total revenue compared to 2018. He reported a boost for both of his Scottish resorts, while his Irish resort saw a decline in revenue. President Trump and Vice President Mike Pence separately visited Trump’s Ireland resort during 2019, and both drew criticism over the appearance that they were doing so to promote it. 

While 2019 largely appears to have been a better year for the Trump Organization than 2018, it is important to note that the income Trump reported in his financial disclosure report does not appear to take into account expenses or debts associated with his properties. For example, while the form shows revenues from Trump’s Doonbeg and Turnberry resorts, Turnberry has reportedly never turned a profit and Doonbeg reported its first-ever operating profit of just €2,939 last year.

More good news for Trump

Another bright spot in Trump’s 2019 finances was T Retail LLC, an online store established after Trump became president that sells Trump-branded merchandise. The LLC made $930,869 in sales in 2019, which is a big jump from the $520,305 in sales that Trump reported in his previous financial disclosure.

One of the liabilities that Trump previously reported was due to mature in 2019 instead appears to have been refinanced to give the Trump Organization an additional 10 years to pay off the mortgage for its Seven Springs property in New York. Trump did not report any income from the property in the disclosure. The interest rate on the $5,000,001 – $25,000,000 loan increased from 4.0% to 4.5%. Mother Jones wrote about the possible conflicts of interest stemming from Trump’s liabilities, and the specific risk of Trump or his company getting sweetheart deals if any loans were refinanced while he was in office, as may have been the case with the Seven Springs mortgage.

Deficient disclosure

Last year, CREW found that President Trump failed to disclose a gift from Rudy Giuliani for pro bono legal services in his financial disclosure report covering 2018 as well as a £40.6 million personal loan Trump made to his resort in Aberdeen, Scotland in his disclosures covering 2016, 2017, and 2018. Giuliani’s pro bono representation of Trump continued through 2019 according to news reports

In his latest financial disclosure report, Trump resisted recognizing Giuliani’s pro bono services as a “gift” for reporting purposes. Instead, at the Office of Government Ethics’s (OGE) request, Trump confirmed in the “gift” section of the report that Giuliani provided him with pro bono counsel in 2018 and 2019, but wrote that he and his lawyers did not believe the pro bono services were reportable as a gift. Trump did not assign a value to the services Giuliani provided him, writing that Giuliani was unable to “estimate” their value. 

By letting Trump rely on Giuliani’s questionable explanation that he was unable to estimate the value of his pro bono legal services, OGE appears to have allowed him to avoid public scrutiny of the scale of Giuliani’s legal help. Trump again failed to disclose a receivable related to the personal loan he made to his Aberdeen resort. It is not yet clear whether Aberdeen continued to hold the loan in 2019, but Trump’s repeated failure to disclose the receivable in his previous financial disclosure reports underscores Trump’s lackluster record with transparency. 

CREW previously filed complaints with the Department of Justice and the OGE over Trump’s failure to disclose a loan he received from Michael Cohen. According to Cohen, the loan related to a “hush money” payment to Stephanie Clifford, who claimed to have had an affair with Trump. In response to CREW’s complaints, OGE determined that Trump was required to disclose the loan on his financial disclosure report covering 2017.

Unknown revenue sources

While Trump’s financial disclosure form shows how much money the president’s businesses took in, it provides no information about who paid it to him. Some sources of revenue in particular stand out as mysterious.

Trump received nearly $12 million for condo sales in buildings he owns and co-owns. A large portion of this sum came from anonymous LLCs. In fact, all of the $7.4 million paid to Trump for condo sales in Trump Parc were from unknown buyers. For example, in October 2019, a Wyoming-based company called Art Gardens LLC paid $2.4 million for a unit. The LLC was formed months before the purchase and has a generic registered agent. The true source of the funds are unknown. 

Trump also disclosed two payments for “other contract payments” related to international properties that are not operational. He reported receiving $750,000 from Trump Marks Puerto Rico I LLC, an entity whose underlying asset is a license deal associated with a former Trump-branded golf course in Puerto Rico that declared bankruptcy in 2015. He reported getting another $275,000 from an entity associated with a hotel in Panama that severed its ties to the Trump Organization in 2018. Neither source of revenue was disclosed as having any value on Trump’s previous disclosure. 

More than anything, President Trump’s annual disclosure is a reminder that a president who routinely promotes his businesses in an official capacity while they haul in hundreds of millions of dollars from mostly unknown sources is a clear case of corruption.

Read President Trump’s personal financial disclosure here.