Last fall, Boston Mayor Martin J. Walsh hosted a golf tournament for the MJW Charitable Foundation, a nonprofit he established to support causes that range from supporting substance abuse recovery to youth athletics to helping those afflicted with Alzheimer's.

The mayor’s golf game wasn’t great — but his fundraising efforts were more successful: the single event raised, according to later tax filings, nearly $420,000.

Those donations — which, unlike political contributions aren’t subject to limits or public disclosure — also sparked questions. In November, the foundation voluntarily released a list of donors.

But documents reviewed by WGBH News suggest that the sources of between one-third and as much as two-thirds of the funds the charity raised last year have not in fact been disclosed.

The voluntary disclosures came in response to questions first raised by the Boston Herald In November, the paper obtained – from the foundation – a list of 104 donations. That list, as the Herald reported, included developers, construction companies, labor unions, and other companies and organizations. 

A spokesperson for the Mayor said that Walsh does not personally solicit donations to his charity, and directed questions about fundraising for the charity to MJW Foundation president Elissa Flynn-Poppey.

Flynn-Poppey, an attorney for powerhouse Boston law firm Mintz Levin Cohn Ferris Glovsky and Popeo, PC, also serves as Walsh’s personal lawyer and does finance compliance work for his mayoral campaign. A spokesperson for Walsh’s mayoral campaign said that Flynn-Poppey does not solicit donations for that committee.

Flynn-Poppey acknowledged that the donor list to Walsh’s charity wasn’t entirely complete — but told WGBH News that it was missing “less than 10%” of donors, who hadn’t responded to a request that their donations be made public.

Flynn-Poppey also said that all “top” donors had been disclosed.

But when the list of disclosed donors is matched against the foundation's total take, the gap is bigger than Flynn-Poppey suggests. 

While the Foundation grouped donations by ranges, and not exact amounts (the largest ranging from $15,000 to $25,000), the donations it disclosed would only add up to a maximum $270,000 — significantly less than the nearly $420,000 the organization reported having raised in federal tax forms and to the Massachusetts Attorney General’s Office, which oversees charities.  

That’s a gap between what the Foundation reported raising and the actual donations it disclosed of between $153,000 and $266,000. Put another way, the disclosures do not account for between one-third and nearly two-thirds of all the donations the charity reportedly collected.

And if the missing donations were, in fact, made by the “less than 10%” of donors, those donations would seem to have been among the "top" donations the charity received — and which its president said had already been disclosed.

Walsh, through a spokesperson, declined an interview.

Flynn-Poppey did answer some questions by WGBH News about the foundation — but did not return multiple calls and emails over two weeks seeking clarity as to the number or amount of undisclosed donations.

Following initial publication of this report, Flynn-Poppey told WGBH News that, going forward, "all donors would be informed that all donations will be disclosed."

Presented with WGBH News’ findings, Pam Wilmot, executive director of the Common Cause Massachusetts, which advocates for government transparency, called on the foundation to release all of its donors or else return donations that donors won’t allow to be disclosed.  

“Transparency is absolutely critical when it comes to these kind of foundations,” Wilmot said, “where they’re using the influence of that political figure to raise money.”

That means disclosing “one hundred percent of donors,” Wilmot said.

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Document: MJW Charitable Foundation disclosures

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Wilmot acknowledged that Walsh’s charity appears to serve reputable causes and did not question the mayor’s charitable motivations.

But, she said, “This is a potential vehicle for currying favor, and it potentially creates the appearance of conflict of interest.”

A spokesperson for the Mayor’s Office said the foundation consulted the State Ethics Commission prior to founding his charity.

Walsh charity president Flynn-Poppey said in an email that the Foundation would “likely” disclose further donations.

Walsh isn’t the first mayor, here or elsewhere, to command a private charity — or to face scrutiny over doing so.

Former Boston Mayor Thomas Menino presided over the Boston Fund for Neighborhoods, a city-hall based charity overseen by city employees appointed to the charity’s board by the mayor.

Los Angeles Mayor Eric Garcetti faced scrutiny recently for donations to a charitable “Mayor’s Fund” over which he presides, and whose donors include big developers, including at least one firm barred from making donations to the Garcetti’s political campaign because it holds contracts worth more than $100,000 with the city (Boston has no such restriction).  

New York Mayor Bill De Blasio is currently facing a state ethics investigation into the activities of a nonprofit  he founded prior to becoming mayor, in part over whether the organization acted as an arm of his campaign.  

Updated: Following publication, Walsh met with WGBH News and the MJW Charitable Foundation subsequently offered clarification regarding donations that were and were not disclosed. 

A statement emailed by foundation president Flynn-Poppey on behalf of Walsh and the Foundation’s board of directors said that while the foundation had disclosed most larger corporate “sponsors” of the event, most of the difference between contributions the foundation raised and those it disclosed came from tickets purchased by participants in its annual golf tournament. Those tickets were generally priced at $200 per golfer, though ticket-purchasers could donate above that amount or purchase tickets in bulk. The foundation did not detail the exact number and amounts of those donations.  

The MJW Foundation said that it will disclose all donors, including individual participants in its golf tournament, going forward; and that it would make donors to its 2016 tournament available to WGBH News in coming months.