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Nine months after the Oklahoma Ethics Commission dissolved its contract with RFD & Associates for an upgrade to the state agency’s financial disclosure system for political candidates and committees, the software development company has filed counterclaims against the state. In its original lawsuit filed in January, the Ethics Commission contends RFD & Associates failed to […] The post Jilted developer of Guardian System 2.0 files countersuit against Ethics Commission appeared first on NonDoc .
NonDoc · Andrea Hancock · September 9, 2026

Nine months after the Oklahoma Ethics Commission dissolved its contract with RFD & Associates for an upgrade to the state agency’s financial disclosure system for political candidates and committees, the software development company has filed counterclaims against the state.
In its original lawsuit filed in January, the Ethics Commission contends RFD & Associates failed to develop a new system in a timely manner and fell short of contractual obligations and expectations. But in an Aug. 24 filing, the Texas-based company now claims the delays were caused by inaccurate and incomplete Ethics Commission data, slow approvals on key deliverables and moving goalposts from the state’s side.
“RFD invested more than 25,000 hours into this project in less than a year and worked tirelessly to deliver a successful system,” Scott Glover, the company’s chief operating officer, said in a press release. “We believe the full record will show that RFD worked in good faith and delivered a functional system, despite significant challenges outside our control.”
The Oklahoma Legislature has appropriated more than $2 million since 2024 for an upgrade to the Guardian System, and the Ethics Commission initially targeted a July 1, 2025, rollout for the new and improved version. However, that date arrived without a new system, as did a revised Sept. 2 target date, with Guardian eventually relaunching in a limited beta phase Oct. 27. By December , with the 2026 election cycle barreling down the tracks without a website able to receive and display candidate and PAC reports, the Ethics Commission pulled the plug on RFD’s project and reengaged its prior developer, Civix, to restore the original Guardian System.
Glover claims that, despite the Ethics Commission’s frustrations, RFD operated within the agreed-upon timeline.
“You cannot separate the project timeline from incomplete data, delayed approvals and changing requirements,” Glover said in RFD’s release. “Despite those challenges, we worked through the issues, completed testing and delivered a system that was accurate and available for active filers by Dec. 12, 2025.”
Filed Jan. 22, the Ethics Commission’s lawsuit claims RFD failed to deliver promised services by six of seven contractual deadlines and that the only deliverable met on time was the project’s start date. In Ethics Commission meetings throughout 2025, frustrations were apparent among the commissioners, as the dates they expected to have major updates online came and went.
“Throughout the project, RFD repeatedly provided system-ready assurances despite known deficiencies, forcing the Ethics Commission to issue public delay notices, extend deadlines for filers, and field daily inquiries from legislators, candidates, PACs, lobbyists, political subdivisions, the media and the public,” the commission’s lawsuit states .
The Ethics Commission, which is scheduled to meet at 10 a.m. Thursday, sued on seven causes of action, each essentially accusing RFD of overpromising and under-delivering on its capabilities:
The commission seeks $800,000 in relief, along with attorney fees. It has since dismissed its seventh count, violation of the Oklahoma Deceptive Trade Practices Act. In June, Oklahoma County District Judge Natalie Mai denied RFD’s partial motion to dismiss the lawsuit.
RFD & Associates, on the other hand, seeks more than $6 million in its counterclaim ( embedded below ). According to the developer’s press release, it seeks $1 million for unpaid contractual compensation and $5.1 million for lost profits and business opportunities “ as a result of the Ethics Commission’s actions.”
RFD’s counterclaim says the Ethics Commission caused significant delays from the beginning, first by waiting a full year after Civix announced it would end support for Guardian 1.0 before soliciting bids for a replacement.
When the commission awarded RFD the contract, the company claims the agency did not provide specific system requirements, instead offering “general functionality descriptions, such as comprehensive reporting tools, without specifying the reports or data fields required.” The counterclaim also alleges the Ethics Commission did not review and approve key deliverables within contractually mandated timeframes, and the company says the commission continuously supplied RFD with erroneous and incomplete data from the Civix system.
The developer claims the due dates cited by the commission’s lawsuit were not “unconditional milestones,” and the commission and the Office of Management and Enterprise Services accepted four of the seven deliverables. Further, the counterclaim says the commission was contractually obliged to review deliverables within five days of receipt and circumvented this by having RFD submit many deliverables informally, with the commission then taking “weeks or months” to review them.
When Guardian 2.0’s beta phase opened in 2025, it allowed users to register and enter data, but not to file their financial disclosure reports.
“This functionality existed but was intentionally disabled at the request of [the Oklahoma Ethics Commission],” RFD’s counterclaim states.
RFD continued developing the system, even as frustrations mounted throughout 2025. In a teleconference with RFD on Dec. 11, a representative of the commission allegedly referred to the status of Guardian 2.0 as “excellent,” according to the counterclaim, but the commission terminated its contract with RFD just eight days later.
“OEC did not claim during this period that Guardian 2.0 had a material defect or that RFD was in material breach,” the counterclaim states. “OEC gave RFD no written notice identifying a material breach and no 30-day opportunity to cure as required by Section 18.1 of the Contract, nor did OEC establish the narrow exception in Section 18.2.”
On the same day the commission terminated the contract, RFD reported, “The Guardian 2.0 system is ready to permit users to file and complete their campaign finance reports immediately and successfully. It is also ready to permit the public to view these filed reports immediately.”
Asked about RFD’s counterclaim, Ethics Commission executive director Lee Anne Bruce Boone deferred comment to the Attorney General’s Office this week. Shauna Peters, the communications director for Attorney General Gentner Drummond, released a statement Tuesday afternoon.
In other ethics news, the commission made two public announcements about pending complaints at its Aug. 13 meeting.
Investigations into possible ethics violations are typically private, known to the public only as case numbers, but the commissioners can vote to issue statements when they determine an investigation is immediately relevant to the public interest.
Amid its own internal inquiry , the Oklahoma House referred concerns about Rep. Danny Williams to the Ethics Commission this summer. The House is investigating “serious allegations” of “improper behavior” by Williams ( R-Seminole ), and concerns about a potential “conflict of interest” were passed to the Ethics Commission. The House Rules Committee met Tuesday to review investigatory reports about Williams, and the body is scheduled to reconvene at 9 a.m. Thursday, an hour before the Ethics Commission’s meeting .
“The Ethics Commission is actively investigating allegations that state Rep. Danny Williams has violated provisions under Ethics Rule 4 , conflict of interest,” Ethics Commission executive director Lee Anne Bruce Boone said in a statement last month. “At its meeting on Aug. 13, 2026, the commission determined there was reasonable cause to believe violations of Rule 4 may have occurred and authorized a formal investigation.”
The commission’s second public notice released in August involved the Republican runoff for state superintendent of public instruction. Both Robert Franklin, who won the Aug. 25 runoff, and his GOP opponent, James Taylor, were noted as violating Ethics Rule 2, which generally prevents using “public funds, property, resources and time” for campaigning. Taylor had filmed a campaign video inside a Little Axe Public Schools classroom, and Franklin filmed campaign content inside a Charles Page High School classroom in Sand Springs.
Neither candidate was punished for their actions, as both pulled their campaign material after learning it violated state rules.
“In light of those corrective actions and the circumstances presented, the commission determined that these matters are appropriately resolved through this public statement and education regarding the requirements of Ethics Rule 2,” Bruce Boone’s public notice read.
All Oklahomans can submit ethics complaints, and while the commission itself must stay mum, sometimes those submitting concerns choose to publicize their own filings. Attorney Bob Burke submitted a complaint July 29 against Oklahoma Insurance Commissioner Glen Mulready, alleging conflict of interest concerns regarding CompSource Mutual’s intent to demutualize .
As outlined in Burke’s complaint , Rep. T.J. Marti ( R-Broken Arrow ) had texted Mulready during the first week of the 2024 regular legislative session to see whether a bill to enable CompSource’s reorganization had originated with Mulready’s department:
Is [ HB 3090 ] a requested bill? Is this an issue or a one off company trying to change from a mutual to stock? Y’all find any issues with it!
Apparently deciding it was a bit rude to ask such a question out of the blue, Marti texted again:
And of course I meant, Hi Glen, hope all is well 🤦♂️
Marti then decided to reference the statewide elected official’s title:
*Mr. Commissioner Sorry got a head cold a little under the weather
Mulready, for his part, seemed unfazed by what Marti may have feared was unprofessional.
“This is not our bull but is a [ Rep. Mark Tedford ] bill. I did some checking and I understand it’s a request from CompSource. This would allow them to raise $$ to expand into other lines of business. (And “Glen” works fine😜),” Mulready wrote back.
Burke’s complaint centers on what the commissioner left out of his reply, alleging it constituted a conflict of interest for Mulready to present the bill to a legislator in favorable terms.
“The commissioner’s voluntary characterization of CompSource’s legislation to a legislator — presenting only the insurer’s benefit and omitting the consumer harm — used the commissioner’s official position and credibility to advance CompSource’s legislative agenda,” the complaint states. “This is not a customary exercise of the commissioner’s regulatory function; the commissioner’s customary role is to protect policyholders, not to advocate for regulated entities’ legislative proposals.”
The Ethics Commission has not made any sort of public announcement on whether Burke’s complaint will be opened into an investigation.
Andrea Hancock became NonDoc’s news editor in September 2024. She graduated in 2023 from Northwestern University. Originally from Stillwater, she completed an internship with NonDoc in 2022.
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