Border911

Border911 is the architecture that converted Tom Homan from a private consultant taking $20,000-a-month retainers into the federal official authorizing the contracts those retainers were positioning for. The conversion ran through two Virginia nonstock corporations registered the same month at the same UPS Store, governed by an interlocking board, lawyered by a Christian-ministry corporate attorney, and funded by donors whose identities the (c)(4) is legally permitted to conceal. The structure is not unusual. The personnel are.

Who They Are

Border911 Foundation, Inc., a 501(c)(3) public charity, and Border911, Inc., a 501(c)(4) social welfare organization, were both incorporated in Virginia in October 2023. Both list the same suite at 2215 Plank Rd in Fredericksburg, a UPS Store address. Both declare the same purpose in IRS filings, to educate Americans about a non-secure border. Both shared near-identical reported expenses of approximately $87,000 in their first year while the (c)(4) reported zero revenue, an arrangement two nonprofit compliance experts told the Texas Observer's reporting consortium would, if accurate, suggest that charity money had been passed through the dark money entity, a violation of IRS rules. Counsel Stephen D. Lentz characterized the filing as an inadvertent error requiring amendment.

The board has reorganized twice in two years. Homan founded the Foundation in October 2023 as president and CEO. Charles "Charlie" Sowell, a former ODNI deputy assistant director and the CEO of Pennsylvania consulting firm SE&M Solutions, became Foundation board chair in 2024. Mark Hall, a former longtime Border Patrol agent, joined the Foundation board in April 2024. Suzette Brown is treasurer of both entities. Stephen D. Lentz, of Anchor Legal Group and Anchor Consulting Group in Virginia Beach, serves as both registered agent and, since early 2025, as the Foundation's president, replacing Homan. George H. Rodriguez, a Reagan and Bush administration immigration appointee and former San Antonio Tea Party president, holds a board seat. Jaeson Jones, a retired Texas DPS captain and border-crime media commentator, has been identified by Manus reporting as vice president, a designation the official Foundation leadership page does not currently surface and which remains pending primary-source verification. Rodney Scott, former U.S. Border Patrol chief, served on the board before being appointed to lead U.S. Customs and Border Protection under the second Trump administration.

What They're Doing

Three things at once.

One, the speaking tour. From late 2023 through the 2024 election cycle, Border911 deployed a roster of retired enforcement officials, Homan, Sowell, Jones, Brandon Judd of the National Border Patrol Council, Derek Maltz of DEA, Victor Avila of HSI, Sara Carter of conservative media, to theaters and event halls in Phoenix, Mission, Ronkonkoma, and across Arizona, Texas, and the eastern seaboard. The framing was border invasion. ABC News reported in March 2024 that the Foundation appeared to be illegally backing Trump's campaign. Lentz characterized the conduct as inadvertent and said changes were underway.

Two, the procurement pipeline. Sowell's SE&M Solutions paid Homan as a consultant from 2023 through November or December 2024. The same firm paid Mark Hall $50,000 in January and February of 2025 while Hall was still on the Foundation board and weeks before Hall entered government. Sowell himself became Foundation board chair in 2024 while running a consulting practice whose clients, ProPublica reported, included at least six companies pursuing immigration detention contracts. Industrial Tent Systems of Houston and USA Up Star of Indiana, both Sowell clients with no prior immigration detention experience, were later added to the Department of War's Worldwide Expeditionary Multiple Award Contract, a vehicle now serving as the procurement chassis for the Trump administration's mass detention build-out.

Three, the federal landing. In February 2025, Homan and Hall entered the federal government. Homan as Border Czar, Hall as senior adviser to the Border Czar. Homan stated publicly he would recuse from contracting. The White House and DHS have not produced his formal recusal documents in response to journalistic or congressional requests. In August 2025, Sowell and Hall flew to Houston to visit Industrial Tent Systems, sampling tacos the company was hoping to serve detainees. The Campaign Legal Center filed a complaint with the DHS Office of Inspector General in October 2025 alleging Hall participated in a particular matter involving the consulting firm of a person with whom he has a covered relationship. In September 2025, the Department of Justice closed an FBI bribery investigation into Homan that had captured him on tape accepting $50,000 in cash from undercover agents posing as government contractors. Prosecutors cited a legal technicality, Homan was not yet a federal employee when the recorded handoff occurred.

What's Next

The structural completion is already happening. In May 2026, Reuters reported that David Venturella, a former GEO Group executive, was named acting ICE director. Homan's prior disclosed consulting included GEO Care, a GEO Group subsidiary. The senior career enforcement layer at ICE is now occupied by GEO alumni working under a border czar paid by GEO Care, advised by a senior adviser paid by the consultant whose clients are pre-qualified for WEXMAC awards, with DHS now led by Markwayne Mullin per March 2026 reporting, an explicitly hardline political appointee. The Foundation 2024 IRS filing shows $1,237,794 in revenue, a roughly 14-fold increase from 2023. No state attorney general action, IRS revocation proceeding, or 501(c)(3) revocation record has surfaced in the public record. Border911 remains a recognized public charity in good standing while its alumni run the federal apparatus its donors are bidding into.

The Read

The entity matters because the people inside the entity are now the agency. The (c)(3) and the (c)(4) were the staging ground. The federal government is the deployment.

Border911 operates on the classic c3/c4 affiliated-pair model, with one distinctive structural feature. The (c)(3) raises tax-deductible donations from named donors who can claim a charitable deduction. The (c)(4) raises dark money from undisclosed donors who can engage in political activity the (c)(3) cannot legally conduct. When properly firewalled, the structure is unremarkable. The named principals, addresses, and counsel are typically identical to permit shared administration. The financials are not. Each entity raises and spends its own money. Cross-subsidization between them is governed by IRS rules requiring documented fair-market-value cost-sharing agreements.

Border911's 2023 IRS filings showed both entities reporting near-identical expenses, approximately $87,000 each, while the (c)(4) reported zero revenue. The mathematical inference, raised by two nonprofit compliance experts to the multi-outlet investigative consortium reporting the story in October 2024, is that the (c)(3) charitable donations were funding (c)(4) political activity. Counsel Stephen Lentz described the (c)(4) filing as inadvertently incorrect and committed to amending it. As of the most recent public IRS data available through ProPublica's Nonprofit Explorer, no amended 990 for Border911, Inc., for tax year 2023 has surfaced in the publicly searchable record.

The Foundation's 2024 990 reports total revenue of $1,237,794, total expenses of $779,911, and total assets of $479,083 against the prior year's roughly $87,000. The 14-fold revenue jump tracks the Trump campaign's promise to install Homan as border czar, the April 2024 Mar-a-Lago fundraiser, and the 2024 election cycle. The (c)(4)'s 2024 financials, if filed, have not yet been surfaced in the source set verified for this dossier.

The operating mechanism is straightforward. A retired senior enforcement official becomes the public face of a charitable education project. The project's speaking circuit positions him in front of the audiences and the donors who will buy the policy outcome. His consultants, lawful in their charitable roles, are simultaneously his vendors. When the political vehicle that buys the policy outcome assumes power, the official transfers from the charity to the federal agency that signs the contracts. The consultants stay where they are. The vendors stay where they are. Only the official moves. The architecture is the same.