The $100M Mirage: “More for Memphis” Exposed in Flawed Responses to Public Inquiry

OPINION

Public Affairs Staff on December 11, 2024

MEMPHIS, TN ——  Full of talking points but again- no substance, the responses provided by Seeding Success to a series of pointed questions from Rev. Stephanie Williams and other community members provided to the Shelby County Commissioner on Tuesday December 10, 2024, reveal significant flaws, evasions, and contradictions. These answers demonstrate a lack of transparency and accountability while undermining the credibility of the “More for Memphis” initiative. 

 

1. Failure to Provide Evidence of Secured $100M Funding

Response: “Current funders have requested to remain anonymous at this time. Quarterly reports will foster transparency.”

Flaw:

The claim of “secured” $100M funding is unverifiable, as no documentation or proof has been provided. The inability to disclose funds undermines the validity of the ordinance and demonstrates a deliberate attempt to mislead the public, violating Tennessee Code Annotated § 39-14-121 (Criminal Fraud). Public funds or governance should not be based on anonymous, unverified claims. The absence of evidence indicates that the ordinance’s language was designed to deceive voters into believing substantial resources had been secured when they had not.

 

2. Misrepresentation About Taxpayer Funding

Response: “This ordinance requires no taxpayer funding.”

Flaw:

While Seeding Success asserts no taxpayer funding is required, the ordinance allows for public resources to be funneled into a governance structure largely controlled by the private entity – More for Memphis. This is a deceptive tactic to obscure the potential misuse of taxpayer funds, violating Tennessee Code Annotated § 39-16-402 (Official Misconduct). Misleading the public into believing there is no public cost while creating avenues for public funds to subsidize private initiatives constitutes material misrepresentation.

 

3. Lack of Transparency on Allocation of Funds

Response: “The More for Memphis plan outlines over 30 evidence-based strategies… Once established, the governance board will determine which strategies are funded.”

Flaw:

No specifics are provided about how the alleged $100M is allocated, and there is no proof that the funds even exist. Deferring decision-making to a governance board after the ordinance’s passage further obscures accountability. This is an attempt to secure public approval without transparency, violating Tennessee Code Annotated § 39-16-504 (False Reporting by Public Officials) if public officials knowingly endorse these claims.

 

4. Refusal to Publicly Disclose Donors

Response: “Current funders have requested anonymity… Leadership names are listed on the website.”

Flaw:

The refusal to disclose funders while claiming $100M is “secured” constitutes fraudulent concealment under Tennessee Code Annotated § 39-16-403 (Tampering with Government Records). Public initiatives require full transparency about donors and leadership, especially when public governance structures are involved. The website lists vague roles but omits specifics about financial backers, perpetuating secrecy.

 

5. Misleading Statements About Minority Inclusion

Response: “More for Memphis has included directing resources toward established, minority-led organizations.”

Flaw:

This claim is speculative and unsupported by any evidence. No details are provided about which minority-led organizations will receive funding or how much. Promises of future actions without guarantees are classic bait-and-switch tactics designed to pacify critics without genuine accountability. This tactic violates public trust and highlights a failure to address systemic inequality credibly.

 

6. Discrepancies in Allocation of Funds

Response: “$75M for direct services and $25M for operations.”

Flaw:

These figures are unsupported by evidence. There is no explanation of how the amounts were calculated, who controls the funds, or how they will be distributed. The vague financial breakdown raises red flags for potential misuse or mismanagement, violating Tennessee Code Annotated § 39-14-105 (Theft of Property) if funds are misallocated.

 

7. Weak Conflict of Interest Policy

Response: “Board members shall recuse themselves from votes on matters involving conflicts of a direct economic nature.”

Flaw:

The conflict of interest policy is insufficient, as it relies on self-disclosure and voluntary recusal. There are no mechanisms for enforcement or independent oversight, creating opportunities for corruption. This approach violates Tennessee Code Annotated § 39-16-402 (Official Misconduct), as it enables governance board members to exploit their positions for personal or political gain.

 

8. Admission of Vague Accountability Measures

Response: “The fiscal agent will provide quarterly public reporting alongside the governance board.”

Flaw:

Relying on a fiscal agent and governance board for accountability lacks independent oversight. Without a third-party audit, these reports cannot be trusted, especially when the same entities control the narrative. This raises concerns under 18 U.S.C. § 1962 (RICO), as it suggests a coordinated effort to deceive and misappropriate funds.

 

Violations of Tennessee and Federal Law

The deliberate attempt to mislead the public and obscure critical details about the funding, governance, and allocation of resources for “More for Memphis” constitutes multiple legal violations:

1. Tennessee Code Annotated § 39-14-121 (Criminal Fraud): Misrepresentation of secured funding and misuse of public resources.
2. Tennessee Code Annotated § 39-16-402 (Official Misconduct): Abuse of public office to advance a private initiative under false pretenses.
3. Tennessee Code Annotated § 39-16-504 (False Reporting): Dissemination of false or misleading information about public initiatives.
4. Tennessee Code Annotated § 39-16-403 (Tampering with Government Records): Concealment of donor identities and funding sources.
5. 18 U.S.C. § 1962 (RICO): Coordinated efforts to deceive the public and misuse governance structures for private gain.

 

Proof of Funds More Important Than Donors’ Names—

Seeding Success’s repeated invocation of donor anonymity is a strawman argument that obscures the real issue: accountability for public claims of secured funding. The request is simple: audited financial statements verifying the existence of the $100 million that Commissioner Whaley and others claimed had been secured.

This deliberate conflation of donor privacy with financial transparency is a red herring that further erodes public trust. It also reveals a deeper issue: “More for Memphis” appears unwilling or unable to back up its financial claims with any credible evidence.

 

$100 Million Claim Collapses: No Proof of Funds Secured

The ordinance for “More for Memphis,” championed by Shelby County Commissioner Michael Whaley, proudly states that the initiative has “secured” $100 million in private funding. However, Seeding Success, the backbone organization behind the initiative, failed to produce any evidence verifying this claim in its responses.

Instead of providing audited financial statements—or even basic financial documentation such as a 990 —Seeding Success offered vague assurances that donors “wish to remain anonymous.” This excuse is a blatant deflection. The demand is for verification of the funds through audited financial statements, as required by basic standards of accountability and transparency. The refusal to produce such verification undermines the credibility of the initiative and raises serious questions about whether the funds exist at all.

If the funds truly exist, audited financial statements would be simple to produce. Based upon the rules of probability, absence of such documentation points to a disturbing conclusion: there are no secured funds.

 

Ordinance Language: Intent to Deceive the Public?

The ordinance’s language unequivocally states that $100 million in private philanthropic capital has already been “secured”. This false claim was designed to win public trust and legislative approval. However, the deliberate use of the word “secured” without any proof constitutes a potential violation of Tennessee Code Annotated § 39-14-121 (Criminal Fraud) and 18 U.S.C. § 1962 (RICO).

Legal experts argue that the ordinance’s false claim demonstrates an intent to deceive the public and could serve as evidence of a broader scheme to defraud taxpayers and secure influence under false pretenses. The potential legal implications for public officials who knowingly endorsed this ordinance are significant, including charges of fraud, official misconduct, and conspiracy.

 

Contradictions from Seeding Success and the Ordinance

The contradictions between the statements of Seeding Success and the language of the “More for Memphis” ordinance are glaring and deeply troubling. Seeding Success has repeatedly claimed that the initiative is “not seeking public funds,” but the ordinance itself directly contradicts this assertion. The ordinance explicitly outlines a framework for both the City of Memphis and Shelby County to provide public funds to support the initiative’s goals.

This discrepancy is not a simple oversight—it is a deliberate attempt to obscure the initiative’s true financial intentions. Seeding Success statement that “no public funding is being sought” flies in the face of the ordinance’s language, which commits local governments to participate financially. This blatant contradiction further supports claims of intent to deceive the public, raising the stakes for potential legal repercussions under state and federal fraud statutes. If public funds are indeed part of the plan, as the ordinance suggests, the public deserves to know the full extent of the financial obligations being imposed on taxpayers.

 

$25 Million for Salaries and Overhead: A Shocking Misallocation of Funds

Another deeply troubling revelation is the allocation of $25 million—25% of the so-called “secured” $100 million—for salaries and operational costs. This staggering figure is not only disproportionate but also an affront to Memphis’s minority-led nonprofits, which have historically been underfunded.

To put this into perspective: the $25 million earmarked for administrative expenses is more than the top 10 minority-led nonprofits in Shelby County have received from the County government combined over the past five years. These organizations, which are on the frontlines of fighting poverty and addressing systemic inequities, have been repeatedly overlooked in favor of initiatives like “More for Memphis” that prioritize bureaucracy over direct community impact.

The allocation of such a significant portion of funds for salaries and operations raises serious ethical and practical questions. Who exactly is benefiting from these administrative costs? How are these salaries justified when so many grassroots organizations struggle to keep their doors open? And why is such a large percentage of funds being diverted from the very communities that the initiative claims to serve?

 

A System Rigged Against Minority-Led Nonprofits

The comparison between “More for Memphis” and minority-led nonprofits is stark and damning. The County’s failure to adequately fund grassroots organizations over the years reflects a systemic bias, while initiatives like “More for Memphis” enjoy institutional support despite their lack of transparency and accountability. This inequity further underscores the need for independent oversight and raises questions about how public funds are being allocated in Memphis.

 

RICO Implications: A Deliberate Scheme to Defraud?

Legal analysts suggest that the false claims embedded in the ordinance could meet the criteria for a federal RICO indictment under 18 U.S.C. § 1962. The elements of a RICO case—fraud, conspiracy, and a pattern of deceptive practices—appear to align with the actions of Seeding Success and its affiliated parties.

By promoting a public ordinance based on unverified financial claims, the organization and its supporters may have engaged in a coordinated effort to deceive the public, secure political support, and funnel taxpayer resources into an initiative that lacks credibility. If proven, this could lead to criminal charges against those involved, including public officials who knowingly endorsed the false claims.

 

Public Trust Eroded

The refusal to provide audited financial statements or even a 990 has undermined the credibility of “More for Memphis” and cast doubt on the integrity of its proponents. By failing to substantiate its financial claims, the initiative has exposed itself as a potential vehicle for fraud and mismanagement, leaving Memphis residents to wonder: If the $100 million doesn’t exist, what else are they hiding?

Shelby County deserves better than unverified promises and vague assurances. The public has a right to demand transparency, accountability, and proof—not empty rhetoric and potential legal violations.