May 2002 Federal Election Commission Volume 28, Number 5

Table of Contents

Commissioners

1 Toner Joins Commission

Legislation

1 Bipartisan Campaign Reform Act

Regulations

2 Final Rules on Independent

Expenditure Reporting

2 Federal Register

Court Cases

3 FEC v. Arlen Specter ’96

3 New Litigation

3 Bipartisan Campaign Reform Act

Litigation

4 Advisory Opinions

Staff

4 Greg Scott Named Assistant Staff

Director for Information

Administrative Fines

5 Committees Fined for Nonfiled

and Late Reports

Reports

6 North Carolina Primary Election

Postponed

6 Pennsylvania Primary Election

May Be Postponed

6 Virginia Convention Reports

Outreach

6 FEC Conferences

7 Are You a Membership

Organization?

8 Index

Compliance Commissioners Legislation

Toner Joins Commission

Michael E. Toner was nominated

to the Federal Election Commission

by President Bush on March 2,

2002, and appointed on March 29.

Prior to his appointment, Mr.

Toner was Chief Counsel to the

Republican National Committee and

served as General Counsel to the

Bush/Cheney Transition and Bush/

Cheney 2000 Presidential Campaign. From 1997 to 1999, Mr.

Toner served as Deputy Counsel to

the Republican National Committee,

and he was Counsel to the 1996

Dole/Kemp campaign. He was an

Associate with Wiley, Rein and

Fielding in Washington, D.C., from

1992 to 1996. Mr. Toner received

an undergraduate degree from the

University of Virginia, a Master’s

degree from Johns Hopkins University and a J.D. from Cornell Law

School.✦

—Amy Kort

Bipartisan Campaign

Reform Act of 2002

On March 27, 2002, President

Bush signed into law the Bipartisan

Campaign Reform Act of 2002

(BCRA). The BCRA, which amends

the Federal Election Campaign Act

(FECA), becomes effective November 6, 2002, and will not affect the

2002 elections. The legislation

requires the Commission to promulgate new soft money regulations by

June 25, 2002, and regulations to

implement other BCRA provisions

by December 22, 2002.

The BCRA makes a number of

significant changes to the FECA,

from increasing individual contribution limits to banning national party

committees from raising or spending

soft money (funds not subject to the

limitations, prohibitions and disclosure requirements of the federal

campaign finance law). For example, the BCRA:

• Eliminates the FECA’s provisions

concerning national party office

building funds;

• Increases the maximum civil

penalties that may be assessed for

violations of the federal campaign

finance law; and

• Prohibits individuals 17 years old

or younger from contributing to

(continued on page 2)
Federal Election Commission RECORD May 2002

2

Federal Election Commission

999 E Street, NW

Washington, DC 20463

800/424-9530

202/694-1100

202/501-3413 (FEC Faxline)

202/219-3336 (TDD for the

 hearing impaired)

David M. Mason, Chairman

Karl J. Sandstrom, Vice Chairman

Danny L. McDonald,

 Commissioner

Bradley A. Smith, Commissioner

Scott E. Thomas, Commissioner

Michael E. Toner, Commissioner

James A. Pehrkon, Staff Director

Lawrence H. Norton, General

 Counsel

Published by the Information

 Division

Greg J. Scott, Assistant Staff

 Director

Amy Kort, Editor

http://www.fec.gov

federal candidates and party

committees.

Senator Mitch McConnell, the

National Rifle Association and

others have filed lawsuits challenging the constitutionality of certain

provisions of the BCRA. See related

article on page 3.✦

—Amy Kort

Information

(continued from page 1)

Regulations

Final Rules on Independent

Expenditure Reporting

Based on a statutory change, the

Commission has revised its regulations regarding the reporting of

independent expenditures. The final

rules and Explanation and Justification appeared March 20, 2002, in

the Federal Register (67 FR 12834).

The new regulations will take effect

following the 30 legislative day

Congressional review period, and

the Commission will announce the

effective date in the Federal Register.

Independent Expenditure

Reporting

The Federal Election Campaign

Act (the Act) requires political

committees and other persons

making independent expenditures to

file reports or statements if their

independent expenditures exceed

$250. If an independent expenditure

exceeds $1,000 and is made less

than 20 days but more than 24 hours

before an election, an additional

statement (a 24-hour notice) must be

filed.

Filing Deadlines. In the past, 24-

hour notices were required to be

filed within 24 hours after the

independent expenditure was made.

However, amendments to the Act,

implemented in Public Law 106-

346, require that 24-hour notices

must now be received by the

Commission or the Secretary of the

Senate within 24-hours of the time

the independent expenditure is

made. As a result, sending 24-hour

notices by the filing date via registered or certified mail is no longer a

viable filing option.

Filing Methods. The new regulations allow committees and other

persons to transmit 24-hour notices

by fax or e-mail in order to comply

with the new filing deadline.

Additionally, persons other than

political committees may file their

regular reports of independent

expenditures by fax or e-mail in

accordance with the standard filing

schedule. Note, however, that those

persons required to file electronically must file all reports of independent expenditures using the

Commission’s electronic filing

system.

When an Expenditure is Made

The new rules also clarify when

an independent expenditure is

considered to be “made.” Under the

new rules, an independent expenditure is “made” on the first date that

the communication—for instance a

television ad or printed flyer—is

published, broadcast or otherwise

publicly distributed. Committees

and other persons may report the

expenditure as early as when the

first payment is made, but they must

report the expenditure no later than

24 hours after the time that the

expenditure is first publicly disseminated. Independent expenditures that

are mailed to their intended audience are considered publicly disseminated once they are given to the

Post Office.

Notarization Requirement

Although the statute requires that

expenditures be certified as independent, reports of independent expenditures no longer need to be

notarized. Instead, filers may selfverify the report using the handwritten signature of the treasurer on

paper reports or the typed name of

the treasurer on electronically-filed

reports. As a result, Schedule E and

Form 5 no longer require an accompanying paper copy to ensure

notarization, and electronic filers no

longer need to send a paper followup to 24-hour notices submitted

electronically. Persons other than

political committees must report

independent expenditures using

either a Form 5 or a letter and must

continue to include a prescribed

statement of certification as to the

independence of the expenditure. 11

CFR 109.2.✦

—Phillip Deen

Federal Register

Federal Register notices are

available from the FEC’s Public

Records Office, on the FEC web

site at http://www.fec.gov/

register.htm and from the FEC

faxline, 202/501-3413.

Notice 2002-3

Final Rules and Explanation and

Justification on Independent

Expenditure Reporting (67 FR

12834, March 20, 2002).
May 2002 Federal Election Commission RECORD

3

Court Cases

FEC v. Arlen Specter ’96

On March 12, 2002, the U.S.

District Court for the Eastern

District of Pennsylvania granted the

Commission’s request for declaratory and injunctive relief against

Koro Aviation, Inc. (Koro). Pursuant to a stipulation between the

Commission and Koro, the court

held that Koro violated 2 U.S.C.

§441b(a) by making in-kind corporate contributions to Arlen Specter

’96 in the form of air travel services

charged at less than the usual and

normal rate. The court permanently

enjoined Koro from violating 2

U.S.C. §441b(a) by providing goods

or services to any federal candidate

at less than the usual and normal

charge. The court also ordered Koro

to pay a $25,000 civil penalty.

Background

On June 22, 2000, the Commission asked the court to find that

Arlen Specter ’96, Senator Specter’s

Presidential campaign committee,

and Paul S. Diamond, as treasurer,

accepted unlawful in-kind contributions from Koro. The Commission

argued that since Koro was an FAAlicensed commercial charter service

carrier, Specter ’96 should have paid

the “usual and normal” rate for the

air travel provided by Koro, rather

than the first-class fare actually paid

by Specter ’96. Under Commission

regulations, a campaign committee

must pay the charter fare for travel

on an FAA-licensed commercial

charter carrier. 11 CFR. 114.9(e). 1

The difference between the usual

and normal cost of a service and the

amount paid by a candidate or

committee represents an in-kind

contribution. 11 CFR.

100.7(a)(1)(iii)(A). The Commission argued that Specter ’96’s

payment of the first-class fare rather

than the charter rate resulted in an

unlawful in-kind corporate contribution from Koro in the amount of

$233,768. See the August 2000

Record, page 14.

Decision

The order entered by the court

stated that the first-class fares that

Specter ’96 paid for air travel were

less than the charter fares charged to

other Koro customers based on

Koro’s published hourly rate, and,

as a result, Koro made an in-kind

contribution to Specter ’96 in

violation of 2 U.S.C. §441b(a). Both

the Commission and Koro stipulated

to the entry of the court’s judgment,

and Koro waived all rights of

appeal. Koro was ordered to pay the

civil penalty within 10 days of the

entry of the court’s order and

judgment.

U.S. District Court for the

Eastern District of Pennsylvania,

00-CV-3167.✦

—Amy Kort

1

 In the case of air travel contracted

from a corporation that is not licensed

to provide commercial charter air

service (e.g., a private corporate jet), a

committee may pay the first-class fare if

traveling between cities linked by

regular commercial service.

New Litigation

Alliance for Democracy v. FEC

On March 19, 2002, Alliance for

Democracy, a non-profit, nonpartisan advocacy group, Hedy

Epstein and Ben Kjelshus (collectively the Plaintiffs) filed a complaint in the U.S. District Court for

the District of Columbia alleging

that the Commission acted contrary

to law by failing to act on an

administrative complaint filed by

the Plaintiffs. The administrative

complaint, filed March 8, 2001,

alleged that the Spirit of America

PAC contributed a fundraising list

of 100,000 donors to Ashcroft 2000,

the principal campaign committee

for John Ashcroft’s 2000 Missouri

Senate campaign. The administrative complaint alleged that the list

was a contribution by the Spirit of

America PAC to Ashcroft 2000 and

that neither committee reported the

contribution to the Commission. See

2 U.S.C. §431(8) and 11 CFR 100.7.

The Plaintiffs claim that, because

the alleged contribution was unreported, they were denied, and

continued to be denied, access to

information that would assist them

in evaluating candidates for the

2000 Missouri Senate election, as

well as candidates for future elections. They contend that because the

administrative complaint “was

brought against the Attorney

General of the United States, the

nation’s highest law enforcement

officer, it is a matter whose resolution is particularly in the public

interest and the FEC should rule on

the complaint without continued

delay.” The Plaintiffs ask that the

court:

• Find the Commission’s failure to

act on the administrative complaint

contrary to law; and

• Compel the Commission to rule on

the merits of the administrative

complaint within 30 days. 2 U.S.C.

§437g(a)(8)(C) and (3).

U.S. District Court for the

District of Columbia,

1:02CV00527.✦

—Amy Kort

(continued on page 4)

Bipartisan Campaign

Reform Act Litigation

In recent weeks several individuals and parties have filed lawsuits

challenging the constitutionality of

various provisions of the Bipartisan

Campaign Reform Act of 2002 (the

BCRA). The BCRA, which President Bush signed into law on March

27, 2002, amends the Federal

Election Campaign Act (FECA) and

several other provisions of federal

law. Certain provisions of the

BCRA:
Federal Election Commission RECORD May 2002

4

Court Cases

(continued from page 3)

1

 The Federal Communications Commission (FCC) is a defendant because

the McConnell complaint also challenges parts of the BCRA that amend

sections of the Federal Communications Act.

2

 On April 12, an amended complaint

was filed in McConnell v. FEC and

FCC, which added numerous persons,

organizations and political parties as

plaintiffs.

Advisory

Opinions

Advisory Opinion Request

AOR 2002-5

Payment for travel including

campaign and officeholder activities

of federal candidate who is state

officeholder (Mayor Ann

Hutchinson, March 20, 2002)✦

• Ban national party committees

from soliciting or using “softmoney;”

• Raise individual contribution

limits; and

• Increase the contribution limits to

candidates whose opponents spend

large amounts of their personal

funds on the campaign.

The BCRA also bans the use of

corporate and labor union funds to

pay for “electioneering communications,” which include broadcast

advertisements that refer to a clearly

identified federal candidate and are

made within 30 days of a primary

election or 60 days of a general

election.

Although the BCRA does not

become effective until November 6,

2002, it provides for immediate

judicial review by a three-judge

panel, as well as expedited appellate

review by the Supreme Court, in

order to settle questions of the law’s

constitutionality.

McConnell v. FEC and FCC 1

 and

NRA v. FEC

On March 27, 2002, Senator

Mitch McConnell and the National

Rifle Association (NRA) each filed

a complaint with the U.S. District

Court for the District of Columbia,

challenging the constitutionality of

several provisions of the BCRA.2

Both plaintiffs requested that the

cases be heard together by a threejudge panel. On April 3, 2002,

Senators John McCain, Russell

Feingold, Olympia Snowe and

James Jeffords and Representatives

Christopher Shays and Martin

Meehan (collectively the Reform

Act Sponsors) filed motions to

intervene as defendants.

Constitutional Challenges.

Senator McConnell alleges in his

complaint that aspects of the BCRA

violate the First, Fifth and Tenth

Amendments and the principles of

federalism. For example, the

complaint alleges that the BCRA:

• Unconstitutionally favors some

speakers over others;

• Unconstitutionally constrains the

rights of officeholders and candidates to raise money for taxexempt organizations, political

parties and other candidates;

• Burdens First Amendment associational rights by requiring organizations to disclose the identity of

their supporters to a greater extent

than does the FECA; and

• Places unprecedented limits on

political parties’ ability to make

expenditures for political speech.

The NRA’s complaint alleges

similar constitutional violations,

focusing specifically on the BCRA’s

limits and prohibitions on electioneering communications.

Reform Act Sponsors. The

Reform Act Sponsors counter that

the BCRA “affirmatively promotes

and enhances core First Amendment

values,” and “ensures that candidates, parties, and citizens have

robust opportunities to exercise their

fundamental rights of expression

and association.” They have asked

the court to allow them to intervene

in support of the BCRA in both

lawsuits.

Echols v. FEC

On April 4, 2002, Emily Echols,

Isaac McDow, Jessica Mitchell,

Daniel Solid and Zacahry White,

who are minors, and Reverend

Patrick Mahoney filed a complaint

with the U.S. District Court for the

District of Columbia. The complaint

challenges, among other things, the

constitutionality of BCRA provisions that prohibit contributions by

individuals 17 years old and

younger and that prohibit certain

groups from engaging in electioneering communications.

McConnell v. FEC et al., U.S.

District Court for the District of

Columbia, 1:02cv00582; NRA et al.

v. FEC, U.S. District Court for the

District of Columbia, 1:02cv00581;

Echols. v. FEC, U.S. District Court

for the District of Columbia,

1:02cv00633.✦

—Amy Kort

Staff

Greg Scott Named Assistant

Staff Director for Information

The Commission has appointed

Greg J. Scott to be the Assistant

Staff Director for the Information

Division. Mr. Scott had served as

the Acting Assistant Staff Director

for the Information Division since

July 2001.

Mr. Scott joined the agency in

1990 as a Public Affairs Specialist.

He has since served as the Information Division’s Senior Public Affairs

Specialist, Senior Communications

Specialist and Deputy Assistant

Staff Director. Mr. Scott graduated

from Indiana University in 1988

with a B.A. in Political Science and

Journalism.✦

—Amy Kort
May 2002 Federal Election Commission RECORD

5

Committees Fined for

Nonfiled and Late Reports

The Commission recently

publicized its final action on 34 new

Administrative Fine cases, bringing

the total number of cases released to

the public to 345.

Civil money penalties for late

reports are determined by the

number of days the report was late,

the amount of financial activity

involved and any prior penalties for

violations under the administrative

fine regulations. Penalties for

nonfiled reports—and for reports

filed so late as to be considered

nonfiled—are also determined by

the financial activity for the reporting period and any prior violations.

Election sensitive reports, which

include reports and notices filed

prior to an election (i.e., 12 Day preelection, October quarterly and

October monthly reports), receive

higher penalties. The committees

and the treasurers are assessed civil

money penalties when the Commission makes its final determination.

Unpaid civil money penalties are

referred to the Department of the

Treasury for collection.

The committees listed in the chart

at right, along with their treasurers,

were assessed civil money penalties

under the administrative fine

regulations.

Closed Administrative Fine case

files are available through the FEC

Press Office, at 800/424-9530 (press

2) and the Public Records Office, at

800/424-9530 (press 3).✦

—Amy Kort

Administrative

Fines

Committees Fined and Penalties Assessed

3Penalty reduced due to a decrease in the level of activity on the report.

1The Commission took no further action in this case.

2

 This civil money penalty has not been collected.

 1. Alaska Democratic Party Federal Account —— 1

 2. American Neurological Surgery PAC, Inc.

(12-Day Pre-General 2000) $5,000

 3. American Neurological Surgery PAC, Inc.

(30-Day Post-General 2000) $1,800

 4. American Resort Development Association Resort

Owners Coalition PAC $2,350 2

 5. AMERIPAC: The Fund for a Greater America $400

 6. Brian Baird for Congress —— 1

 7. Citizens for the Republic $695

 8. Commerce Bancorp Inc.—PAC Fed, $1,000

 9. Committee for Responsible Government

of Temple—Inland Inc. $800

10. Conservative Victory Committee $1,000

11. Dave Treen for Congress $250

12. District No. 1—PCD MEBA Political

Action Fund (MEBA-PAF) $1,000

13. Eckerd Corporation PAC (ECKPAC) $1,000

14. Ed Janosik for Congress $900 3

15. Elect, The Political Education and Action Committee

of Alabama Farmers Federation $3,000

16. Friends of David Bishop $900

17. Harry Browne for President, Inc. $1,850

18. Lincoln Club of Riverside County $1,000

19. New Hampshire Republican State Committee $12,000

20. New York State Conservative Party —— 1

21. Ocean County Democratic Committee $9,000

22. Ohio Bankers Association PAC (Federal) —— 1

23. Ohio D.R.I.V.E. (Democratic Republican Independent

Voter Education) (TEAMSTERS) $2,000

24. ORBPAC (The PAC of Orbital Sciences) $1,000

25. Peter Abair for Congress Committee $650 2

26. Randy Heine for Congress —— 1

27. Reform Party of Minnesota

(Independence Party of Minnesota) $900 3

28. Riverside County Republican Central Committee $1,800

29. Sallie Mae Inc. PAC (Sallie Mae PAC) $600

30. San Bernardino County Republican Central Committee —— 4

31. Sills Cummis Radin Tischman Epstein & Gross

Federal PAC, Inc. —— 1

32. Transport Workers Union - Local 100

Political Contributions Committee $3,100

33. Women’s Campaign Fund $4,500

34. Yuba County Republican Central Committee $2,700

4 The Commission waived the $3,375 civil money penalty because the respondents demonstrated the existence of extraordinary circumstances that were

beyond their control and a duration of at least 48 hours.
Federal Election Commission RECORD May 2002

6

Republican Party

Election Day Close of Books Mailing Date Filing Date 48-Hour Notice

Period

House Districts 3, 8 May 11 April 21 April 26 April 29 April 22—May 8

House District 9 June 1 May 12 May 17 May 20 May 13—May 29

* Virginia will hold a primary election on June 11 for U.S. Senate candidates and House candidates in other districts. See the

January Record for reporting dates.

Reports

North Carolina Primary

Election Postponed

The North Carolina State Board

of Elections has delayed North

Carolina’s May 7, 2002, primary

elections pending the North Carolina Supreme Court’s decision in a

legislative redistricting case,

Stephenson v. Bartlett. The Commission will provide a revised

reporting schedule for North Carolina pre-primary filings once the

new primary date is announced.✦

—Amy Kort

FEC Conferences

Conference for Trade Associations

The FEC will hold a conference

for trade associations and their

PACs May 22-24, 2002, in Washington, D.C. The conference will

consist of a series of interactive

workshops presented by Commissioners and experienced FEC staff,

who will explain how the requirements of the federal election law

apply to trade associations. In

addition, an IRS representative will

be available to answer electionrelated tax questions.

Outreach

1 Notice that this deadline falls on a federal holiday. Filing dates are not extended for weekends or holidays. Reports filed on

paper or diskette must be received by the appropriate filing office(s) the Friday before the filing date.

Virginia Convention Reports*

Democratic Party

Election Day Close of Books Mailing Date Filing Date 48-Hour Notice

Period

House Districts 1, 9 June 8 May 19 May 24 May 27 May 20—June 5

House Districts May 18 April 28 May 3 May 6 April 29—May 15

2, 5, 7, 8

House District 11 May 11 April 21 April 26 April 29 April 22—May 8

House District 6 Convention Date Pending

1

Pennsylvania Primary

Election May Be Postponed

Pennsylvania’s primary election,

planned for May 21, may be postponed because of disputes over the

state’s redistricting plan. If the

primary is postponed, the Commission will publish new reporting

dates for committees involved in

Pennsylvania primaries. Any new

reporting dates will be made available on the Commission’s web site

at www.fec.gov/reporting.html.✦

—Amy Kort
May 2002 Federal Election Commission RECORD

7

Are You a Membership

Organization?

The FEC’s Labor and Membership Organization Conference is

intended only for labor unions and

membership organizations other

than trade associations.

Conferences in 2002

For complete conference

information, visit the FEC’s web

site at www.fec.gov/pages/

infosvc.htm#Conferences.

Conference for Trade

Associations

Date: May 22-24, 2002

Location: Washington, D.C.

(Loews L’Enfant Plaza)

Registration Fee: $375

Conference for Membership

and Labor Organizations

Date: June 26-28, 2002

Location: Washington, D.C.

(Loews L’Enfant Plaza)

Registration Fee: $375

The registration fee for this

conference is $375, which covers

the cost of the conference, materials

and meals. The deadline for registration (and for fully-refunded registration cancellations) is April 28. A

late registration fee of $10 will be

added effective April 29.

The conference will be held at the

Loews L’Enfant Plaza Hotel, 480

L’Enfant Plaza, SW, Washington,

D.C. A room rate of $220 single or

$250 double is available for reservations made by April 28. Call 800/

635-5065 or 202/484-1000 ext.

5000 to make reservations. In order

to receive this room rate, you must

notify the hotel that you will be

attending the FEC conference. After

April 28, room rates are based on

availability. The hotel is located

near the L’Enfant Plaza Metro and

Virginia Railway Express stations.

Conference for Membership and

Labor Organizations

On June 26-28, 2002, the

Commission will hold a conference

in Washington, D.C., for membership and labor organizations.

Commissioners and experienced

FEC staff will conduct a series of

interactive workshops explaining

how the requirements of the federal

election law apply to these organizations. A representative from the IRS

will be available to answer electionrelated tax questions.

The registration fee for this

conference is $375, which covers

the cost of the conference, materials

and meals. The registration deadline

(and the deadline for fully-refunded

registration cancellations) is June 4.

A late registration fee of $10 will be

added effective June 5.

The conference will be held at the

Loews L’Enfant Plaza Hotel, 480

L’Enfant Plaza, SW, Washington,

D.C. A room rate of $199 single or

$229 double is available for reservations made by June 4. Call 800/635-

5065 or 202/484-1000 ext. 5000 to

make reservations. In order to

receive this room rate, you must

notify the hotel that you will be

attending the FEC conference. After

June 4, room rates are based on

availability. The hotel can be easily

reached via the L’Enfant Plaza

Metro and Virginia Railway Express

stations.

Registration Information

Conference registrations will be

accepted on a first-come, firstserved basis. Attendance is limited,

and FEC conferences have sold out

in the past, so please register early.

For registration information:

• Call Sylvester Management

Corporation at 800/246-7277;

• Visit the FEC web site at

www.fec.gov/pages/

infosvc.htm#Conferences (on-line

registration requires complete

credit card information); or

• Send an e-mail to

allison@sylvestermanagement.com.✦

—Amy Kort

If you are not certain whether you

represent a membership organization or a trade association, please

read the following descriptions.

Membership organizations and trade

associations share many of the same

characteristics—indeed, trade

associations are a type of membership organization. Trade associations, however, have certain unique

characteristics and rules that set

them apart from other kinds of

membership organizations.

Membership Organization

Generally, a membership organization is defined by the following

criteria:

• It provides for members in its

articles and bylaws;

• It seeks members;

• It acknowledges the acceptance of

members (e.g., by distributing

membership cards); and

• It is not organized primarily for the

purpose of influencing the election

of an individual to federal office.

Trade Association

In addition to having the characteristics above, a trade association

possesses two unique features:

• Its membership is comprised of

persons and/or companies engaged

in a similar or related line of

commerce or business; and

• It is organized to promote and

improve the business conditions of

its members.

If your organization qualifies as a

trade association, with its own

special characteristics and rules, the

FEC asks that you register for the

Trade Association Conference, May

22-24.✦

—Amy Kort
FEDERAL ELECTION COMMISSION

999 E Street, NW

Washington, DC 20463

Official Business

Penalty for Private Use, $300

Presorted Standard

Postage and Fees Paid

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Printed on recycled paper

Federal Election Commission RECORD May 2002

The first number in each citation

refers to the “number” (month) of

the 2002 Record issue in which the

article appeared. The second

number, following the colon,

indicates the page number in that

issue. For example, “1:4” means

that the article is in the January

issue on page 4.

Advisory Opinions

Alternative Disposition of 2001-15,

3:9; 2001-20, 3:9

2001-13: National committee status

of party committee, 1:11

2001-16: Extension of 70-day

window for transferring funds for

allocable expenses after suspension of party fundraising due to

national emergency, 2:1

2001-17: Reporting contributions

made via single check split

between federal and nonfederal

accounts, 3:5

Index

2001-18: Affiliation between LLC

PAC and PACs of corporate

owners in 60-40 joint venture, 3:7

2001-19: Non-preemption of state

law prohibiting political committees bingo license, 3:8

2002-1: Coalition of minor parties

supporting candidate(s) who

together gain five percent of vote

not eligible for Presidential public

funding, 4:3

2002-2: Preemption of state law

barring lobbyist from fundraising

for Congressional candidate who

is member of Maryland General

Assembly, 4:4

Compliance

Administrative Fine program

extended, 1:13

Committees Fined under Administrative Fine program, 1:13; 2:7;

3:11; 5:5

Court Cases

_____ v. FEC

– AFL-CIO, 2:3; 3:5

– Alliance for Democracy, 5:3

– Baker, 4:3

– Beaumont, 3:4

– Common Cause and Democracy

21, 2:4

– Echols, 5:3

– Judicial Watch, Inc., and Peter F.

Paul, 3:3

– McConnell, 5:3

– Miles for Senate, 3:1

– NRA, 5:3

– Wertheimer, 1:12

FEC v. _____

– Specter ’96, 5:3

Regulations

Allocation of candidate travel

expenses, interpretation, 3:2

Civil penalties, no increase, 3:2

Independent expenditure reporting,

final rules, 5:2

Use of Internet, public hearing, 3:1

Reports

April reporting reminder, 4:1

IRS filing requirements, 1:11

Reports due in 2002, 1:2

Virginia convention reporting, 5:6

48-hour notice periods for 2002

primaries, 3:10