FOIAengine: SEC’s$2.5 Billion Outsourcing Contract Explained
The Securities and Exchange Commission, which signed a staffing contract potentially worth $2.5 billion with a Texas-based Alaska Native corporation, appears to have relied heavily on the outside contractor to rebuff an unprecedented wave of Freedom of Information Act requests all centering on a controversial stock-trading case.
The case in question relates to preferred shares of a company called Meta Materials that owned oil and gas leases and traded over-the-counter until late 2022. Retail investors who bought the stock believed they would receive new shares – and later, a big payout – from a successor company that would own Meta Materials’ spun-off oil and gas assets and distribute proceeds to preferred stockholders. The new stock (and, later, the resultant cause célèbre when the plan fell through) would be known as MMTLP, its ticker symbol.
The outsourcing contractor that the SEC has been using since 2021 is C2 Alaska, LLC. The San Antonio-based company is an 8(a) “small disadvantaged business” and a wholly owned subsidiary of Chenega Corporation, an Alaska Native corporation.
C2 Alaska generates roughly $150–$200 million in annual federal contract revenue, much of that coming from the SEC, where C2 Alaska has a potential $2.5 billion contract covering outsourcing of legal, administrative, and technical jobs at the SEC. C2 Alaska’s parent, Chenega Corporation, reports well over $1 billion in combined annual revenue across dozens of subsidiaries in defense, healthcare, and professional-services federal contracting.
Each Chenega subsidiary, including C2 Alaska, qualifies as a “small business” under the Small Business Administration’s 8(a) program because of a statutory exemption: When a firm is wholly owned by an Alaska Native Corporation, the parent’s size and revenues are not aggregated with the subsidiary’s. That status allows ANC-owned 8(a) companies to receive sole-source federal awards far above normal thresholds without open competition.
According to the website GovTribe.com, the SEC is using C2 Alaska to support “various SEC offices and programs such as Enforcement, Freedom of Information Act, Office of Ethics Counsel, Office of Credit Ratings, and Office of Human Resources [for] legal support, administrative assistance, data analytics, and program management.” A 2024 report from the SEC’s FOIA office said the agency had 30 contractors processing FOIA requests.
When we reached out to the SEC to verify details of C2 Alaska’s outsourcing work, an SEC spokesperson said the agency wasn’t able to respond to our query because of the government shutdown.
SEC internal emails produced in a federal court case reveal a frenzied back and forth between SEC staff members and the C2 Alaska contract employees as hundreds of panicked MMTLP investors reached out for help.
Investors who owned MMTLP never got their expected payout, because the SEC called the complex, and highly unusual, corporate spinoff scheme a fraud. Instead of letting the plan move forward, the Financial Industry Regulatory Authority (FINRA) — the SEC-supervised self-regulatory organization that oversees U.S. broker-dealers — abruptly halted trading and canceled further settlements. The move, which FINRA said was required to prevent market disruption, effectively stranded thousands of investors with illiquid shares. Many accused regulators and market participants of mishandling a suspected “short-squeeze” situation, and began filing FOIA requests seeking the SEC’s internal communications.
We wrote about this massive grassroots FOIA campaign a month and a half ago, in our story, “A Grassroots FOIA Campaign Swarms the SEC.” PoliScio Analytics’ competitive-intelligence database FOIAengine, which tracks FOIA requests in as close to real-time as their availability allows, counts more than 1,400 FOIA requests to the SEC mentioning MMTLP – with nearly 800 filed so far this year.
We’re returning to the controversy now because, based on a review of FOIA documents produced in the ongoing MMTLP litigation, it appears that the SEC, aided by C2 Alaska, used privacy and law-enforcement exemptions to deflect and summarily dispose of almost all of the requests filed by the irate investors. The success rate for MMTLP FOIA requesters is vastly lower than that for FOIA requesters overall.
According to statistics compiled by a group of MMTLP investors, the SEC received 33,303 FOIA requests from December 2022 through September 2025. Most FOIA requests to the SEC are disposed of quickly because there are no records to be found. However, about 11 percent of the time, the SEC did find disclosable records, releasing documents either in full or in part in 3,666 instances, according to the MMTLP investor group.
During the same period, December 2022 through September 2025, the investor group counted 1,821 MMTLP-related requests to the SEC – a mere 21 of which resulted in full or redacted disclosure. The ratio of approved-to-filed MMTLP requests was 1 in 87, for a release rate of 0.0115 percent.
By issuing blanket denials and invoking FOIA exemptions that precluded meaningful disclosure, the agency nevertheless reported an administrative success: it cut its year-end backlog of FOIA requests nearly in half. As of the end of fiscal 2024 (the most recent figures available), the SEC listed 475 pending requests out of 3,068 in which records were located. That was a big drop from a backlog of 819 the prior year.
Those behind the grassroots MMTLP FOIA campaign don’t believe the 1,000-fold difference between their FOIA success and all others at the SEC is a coincidence.
“That is the crux of the matter on FOIA,” said Christopher Gruber, an exasperated member of the MMTLP investor group. “We continue to request for our search for the truth. Facts matter.”
Another of the disgruntled investors, Jason Rolo, owns Patriot Taxi in Torrington, Conn. Rolo is representing himself in ongoing litigation against the SEC and FINRA. Rolo’s lawsuit in federal district court in Hartford alleges regulatory negligence, manipulative trading practices, breaches of fiduciary duty, and constitutional violations.
Documents produced in Rolo’s case show that the SEC relied on broad privacy and law-enforcement exemptions to reject or heavily redact nearly all MMTLP requests. In numerous emails, agency staffers sought to shunt complainants to FINRA.
The same documents, although heavily redacted, also revealed how SEC personnel in the Office of the Ombudsman and elsewhere within the agency were scrambling in late 2022 to decide how to respond to the mushrooming MMTLP controversy. Internal emails show at least 486 investor complaints immediately following the trading halt, with panicked SEC staff and contractors trying to figure out how best to respond to them all.
“Apparently, we got a tsunami of calls. There are 145 in the cue,” an unidentified contractor emailed to an SEC staffer late in the day on December 15, 2022. The names of both the sender and the recipient were redacted by the SEC. The two agreed to talk the following morning “about how to tackle these together.”
Around the same time, other SEC staffers were reaching out. “Hey there,” an unidentified SEC staffer wrote. “We have seen a huge wave of intake items coming in regarding a FINRA trading halt for Meta Materials (ticker MMTLP) an OTC company. We are now getting yet more of those items alleging that the company has issued to investors counterfeit shares. Do you have time for a call to discuss?”
Later that same evening, another email was sent around to various SEC staffers, including to SEC attorneys Katherine Shiu and Lisa Skrzycki (now the agency’s acting Ombudsman).
“Hello from the Investor Advocate’s office,” the email began. “We are currently buried knee deep in intake items (mostly voicemails) from investors concerning Meta Materials (ticker MMTLP). FINRA issued a trading halt earlier in the week and some of the items we received relate to the trading halt but others relate to the issuance of counterfeit shares concerning a merger.” Another meeting was planned for the next day.
By early afternoon the following day, there was an email circulating with boilerplate language to be used as a response to complainants. The two-page single-spaced statement was the SEC’s long-form way of telling the MMTLP investors to contact FINRA instead. The SEC appeared to be washing its hands of the matter.
“To the extent you have concerns regarding FINRA’s actions,” the statement said, “you should consider reporting your concerns to FINRA’s Office of the Ombudsman. . . . Please follow up with the SEC Ombudsman if you feel that your concerns have not been addressed by the FINRA Ombudsman. Thank you again for contacting the SEC Ombudsman. We appreciate your views.”
The broader MMTLP legal battle continues. Investors have transformed their frustration into a coordinated transparency campaign and multiple lawsuits demanding a full account of how and why the trading halt occurred. And the two executives who once ran Meta Materials, John Brda and George Palikaras, are still facing civil fraud charges filed by the SEC for their part in the alleged scheme. The proceedings against the duo, in the Eastern Texas federal district court, were put on indefinite hold during the government shutdown.
FOIAengine is the only source for the most comprehensive, fully searchable archive of FOIA requests across over 40 federal departments and agencies. FOIAengine has more robust functionality and searching capabilities and standardizes data from different agencies to make it easier to work with. Learn more about FOIAengine here. Sign up here to become a trial user of FOIAengine.
PoliScio now offers everyone free daily FOIAengine Email Alerts when a new FOIA request matches one of your personal keywords. Sign up here to create your account and identify your keywords.
FOIAengine access now is available for all professional members of Investigative Reporters and Editors, a non-profit organization dedicated to improving the quality of journalism. IRE is the world’s oldest and largest association of investigative journalists. PoliScio Analytics is proud to be partnering with IRE to provide this valuable content to investigative reporters worldwide.
To see all the requests mentioned in this article, log in or sign up to become a FOIAengine user.
Next: The latest hedge fund requests to the SEC, FTC, and FDA.
John A. Jenkins, co-creator of FOIAengine, is a Washington journalist and publisher whose work has appeared in The New York Times Magazine, GQ, and elsewhere. He is a four-time recipient of the American Bar Association’s Gavel Award Certificate of Merit for his legal reporting and analysis. He is the author, most recently, of The Partisan: The Life of William Rehnquist, and the forthcoming Summer of ’71, about fateful events in the year before Watergate. Jenkins founded Law Street Media in 2013. Prior to that, he was President of CQ Press, the textbook and reference publishing enterprise of Congressional Quarterly. FOIAengine is a product of PoliScio Analytics (PoliScio.com), a new venture specializing in U.S. political and governmental research, co-founded by Jenkins and Washington lawyer Randy Miller. Learn more about FOIAengine here. To review FOIA requests mentioned in this article, subscribe to FOIAengine.
Write to John A. Jenkins at JAJ@PoliScio.com.
