July 2000 Federal Election Commission Volume 26, Number 7

Table of Contents

Regulations

1 Administrative Fines Program

5 State Filing Waiver Rules Take

Effect

Court Cases

1 FEC v. Colorado Republican

Federal Campaign Committee

6 FEC Statement on the Colorado

Decision

7 Lenora B. Fulani v. FEC

7 Renato P. Mariani v. USA

8 John Jay Hooker v. FEC

8 Reform Party of USA v. Russell J.

Verney; Reform Party of USA v.

John J. Gargan

8 Committee for a Unified

Independent Party v. FEC

Information

2 FEC Names ADR Director

2 Louisiana Elections

Reports

2 Nonfilers

8 Advisory Opinions

Statistics

10 Congressional and Party Receipts

Increase

Outreach

12 Roundtables

14 Public Appearances

800 Line

12 Membership Organization vs.

Trade Association

Publications

14 Summary of State Finance Laws

Compliance Regulations

Administrative Fines Program

Beginning with the July 15

quarterly reports, the Commission

will implement a new program for

assessing civil money penalties for

violations involving:

• Failure to file reports on time;

• Failure to file reports at all; and

• Failure to file 48-hour notices.

The Administrative Fines program is based on amendments to the

Federal Election Campaign Act (the

Act) that permit the FEC to impose

civil money penalties, based on

schedules of penalties, for violations

of reporting requirements that occur

between January 1, 2000, and

December 31, 2001.

If the Administrative Fines

program had been in place for the

April 2000 quarterly reports,

approximately 90 committees would

have faced civil money penalties

ranging from $275 to $12,000.

How the Program Works

In the past, the FEC handled

reporting violations (late filers,

nonfilers and committees that failed

to file 48-hour notices) under the

same enforcement procedures it

employs for other alleged campaign

finance violations, culminating in

agreement on a civil penalty or court

Court Cases

(continued on page 3) (continued on page 5)

FEC v. Colorado Republican

Federal Campaign

Committee

On May 5, 2000, the U.S. Court

of Appeals for the 10th Circuit

affirmed a district court decision

that the coordinated party expenditure limits at 2 U.S.C. 441a(d)(3)

are unconstitutional.

Background

This case—on remand from the

U.S. Supreme Court—involves

$15,000 worth of expenditures the

Colorado Republican Party made in

1986 for advertisements critical of

Democratic Senate candidate Tim

Wirth. The Commission argued that

those ads contained an “electioneering message” relating to a clearly

identified candidate, and therefore

represented coordinated expenditures by the party. (The Commission

further maintained that these

expenditures, when aggregated with

previous expenditures by the party,

exceeded the statutory limits of

441(a)(d).) The party contended that

the ads did not contain express

advocacy and were not subject to

the 441a(d) limits. The party further

argued that the 441a(d) limits

violated its First Amendment rights.
Federal Election Commission RECORD July 2000

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)

800/877-8339 (FIRS)

Darryl R. Wold, Chairman

Danny L. McDonald,

 Vice Chairman

Lee Ann Elliott, Commissioner

David M. Mason, Commissioner

Karl J. Sandstrom, Commissioner

Scott E. Thomas, Commissioner

James A. Pehrkon, Staff Director

Lawrence M. Noble, General

 Counsel

Published by the Information

 Division

Louise D. Wides, Director

Greg J. Scott, Editor

http://www.fec.gov

FEC Names ADR Director

The Commission has named

Allan Silberman Director of its

newly formed Alternative Dispute

Resolution (ADR) Office. Mr.

Silberman has twenty years of

experience in the field of mediation

and dispute resolution. He is a

former Vice President of the American Arbitration Association and,

most recently, operated a private

consulting business that specialized

in providing dispute resolution

services and training to clients.

Mr. Silberman will oversee the

development and implementation of

the Commission’s ADR program, as

it pertains to campaign finance

related complaints filed with the

FEC. The program will offer respondents the option to resolve their cases

through negotiation and/or mediation,

rather than through the FEC’s regular

enforcement process, if the case meets

the FEC’s ADR criteria.

The Commission’s new program

is part of a government-wide move

toward ADR, but is among the first

designed to promote compliance

with federal regulations outside the

personnel area. The Record will

provide additional information on

the program as it becomes

available.✦

Information

Louisiana Elections

In Louisiana, in the absence of a

runoff election in December, there

will be only one election (the

general election in November) with

only one contribution limit.

As a result of a 1997 U.S.

Supreme Court decision and subsequent Federal court decisions on

remand, all candidates in Louisiana,

regardless of party affiliation,

participate in a general election held

on the same day as the national

general election.1

 (There is no

primary.) If a candidate in that

election receives a majority of the

votes or is unopposed, he/she

becomes the officeholder. If not, an

additional runoff election is held in

December.

Under this system, candidates are

entitled to one contribution limit for

the November general election.

They are entitled to a second

contribution limit for the December

runoff only if they participate in that

election. If the runoff election is not

held, then it is not considered an

election, and any contributions

received for the runoff must be

returned, redesignated or

reattributed within 60 days after the

general election. See 11 CFR

110.1(b)(5), 110.2(b)(5) or

110.1(k)(3).✦

1 Foster v. Love, 522 U.S. 67 (1997),

Love v. Foster, No. 95-788-B-M

(M.D.La. May 21, 1998), and Love v.

Foster, 147 F.3d 383 (5th Cir. 1998).

These decisions rendered inoperative

the conclusions stated in FEC Advisory

Opinion 1984-54.

Nonfilers

The Committee to Elect Farley

2000 and Joel Farley, as its treasurer, failed to file a pre-primary

report in connection with the June 6

primary election in New Jersey. The

report, which was due May 25, was

to have included financial activity

for the period April 1 - May 17.

In addition, the Jenerette for U.S.

Congress committee and its treasurer, Van E. Jenerette, failed to file

a pre-primary report in connection

with the June 13 primary election in

South Carolina. The report was due

June 1, and was to have included

financial activity for the period

April 1 - May 24.

The FEC is required by law to

publicize the names of nonfiling

campaign committees. 2 U.S.C.

§438(a)(7). The agency pursues

enforcement action against nonfilers

on a case-by-case basis. Note that,

beginning with the July 15 quarterly

reports, the Commission will

institute an Administrative Fines

program for late filing committees.

For more information on that

program, see p. 1.✦

Reports

Need FEC Material

in a Hurry?

 Use FEC Faxline to obtain FEC

material fast. It operates 24 hours

a day, 7 days a week. More than

300 FEC documents—reporting

forms, brochures, FEC

regulations—can be faxed almost

immediately.

 Use a touch tone phone to dial

202/501-3413 and follow the

instructions. To order a complete

menu of Faxline documents, enter

document number 411 at the

prompt.
July 2000 Federal Election Commission RECORD

3

action. Under the new rules, if the

Commission finds “reason to

believe” that a committee violated

the law, the Commission will

provide written notification to the

committee containing the factual

and legal basis of its finding and the

amount of the proposed civil money

penalty. The committee will have 40

days from the date of the reason-tobelieve finding to either pay the

civil money penalty or submit to the

Commission a written response,

with supporting documentation

outlining the reasons why it believes

the Commission’s finding and/or

penalty is in error. (The Commission strongly encourages respondents to submit their documents in

the form of affidavits or declarations. Documents submitted in these

forms are generally given more

weight and credibility.) If the

committee submits such a response,

it will be forwarded to an impartial

reviewing officer—someone

employed by the FEC who was not

involved in the original reason-tobelieve finding.

After reviewing the

Commission’s reason-to-believe

finding and the committee’s written

response, the reviewing officer will

forward a recommendation to the

Commission, along with the original

reason-to-believe finding, the

committee’s written response and

any supporting documentation.

Respondents will have an opportunity to submit a written response to

the reviewing officer’s recommendation. The Commission will then

make a final determination as to

whether the committee violated 2

U.S.C. §434a and, if so, assess a

civil money penalty based on the

schedules of penalties.

Committee treasurers may be

liable for civil money penalties if

reports are not filed on time.

1

 The committee may also seek judicial

review if it disagrees with a final

determination made by the Commission

after the committee submits a challenge.

Regulations

(continued from page 1)

Challenging Commission

Determinations

As noted above, the new rules

allow committees to challenge the

reason-to-believe finding of the

Commission and to seek review by

submitting documentation to a

reviewing officer, who will make a

recommendation to the Commission

as to the final determination.

Should a committee fail to pay

the civil money penalties or submit

a challenge within the original 40

days, the Commission will issue a

final determination with an appropriate civil money penalty. The

committee will then have 30 days to

pay the civil penalty or seek judicial

review through a U.S. district court

in the area where the committee

resided or conducted business.1

Reports Covered

All reports that committees are

required to file are covered under

the Administrative Fines program.

This includes semi-annual, quarterly, monthly, pre-election, 30-day

post-general and special election

reports, as well as 48-hour notices

that candidate committees are

required to file for elections in

which the candidate participates.

Calculating Penalties

The interaction of several factors

will determine the size of the

penalty:

1. Election sensitivity of the report;

2. Committee as late filer, including

the number of days late, or

nonfiler;

3. The amount of financial activity

in the report; and

4. Prior civil money penalties for

reporting violations.

One factor used to determine the

amount of the civil money penalty is

the election sensitivity of the report.

Under the new rules, the following

reports are considered election

sensitive: the October quarterly, the

October monthly and the preelection reports for primary, general

and special elections. All other

reports are considered nonsensitive.

The Commission will also

consider whether the committee is a

late filer or a nonfiler. In the case of

nonsensitive reports, a committee

will be considered a late filer if it

files its report within 30 days after

the due date, and a nonfiler if it files

its report later than that.

In the case of election-sensitive

reports, a committee will be considered a late filer if it files a report

after its due date, but more than four

days before the applicable election;

a committee that files later than that

will be considered a nonfiler.

The third factor is the amount of

financial activity—that is, the total

amount of receipts and disbursements in the report.

The final factor is the existence

of prior civil money penalties for

reporting violations under the

Administrative Fines program.

Schedules of Penalties

The schedules of penalties,

included in the new regulations, are

based on the factors described above.

For Reports Other Than 48-Hour

Notices

The calculation of the civil

money penalties for late filers and

nonfilers of reports, other than 48-

hour notices, has four components,

as described below.

1. Base Amount for Late Filers.

In calculating the penalty, the

Commission begins with the base

amount, a prescribed figure that

depends on the total amount of

financial activity in the report and

the election sensitivity of the report.

For example, on an electionsensitive report, if the total amount

(continued on page 4)
Federal Election Commission RECORD July 2000

4

Regulations

(continued from page 3)

EXAMPLE 1: Late Filer of Election-Sensitive Report. A committee files

its October quarterly report (an election-sensitive report) 10 days late. The

level of financial activity on the report is $105,000, and the committee has

one prior violation in the current two-year election cycle.

Applicable formula:

Penalty = [base amount + (set amount x number of days late)] x [1 + (.25 x

number of previous violations)]

Penalty = [$900 + ($125 x 10)] x [1 + (.25 x 1)]

Penalty = $2687.50

EXAMPLE 2: Late Filer with Relatively Little Activity, No Prior Violations. A committee files its July quarterly report on August 4. The report

contains $500 in receipts and disbursements, and the committee has no prior

violations.

Applicable formula:

Penalty = The lesser of: the level of activity in the report; or

[base amount + (set amount x number of days late)]

Penalty = The lesser of: $500 or [$100 + ($25 x 20)]

Penalty = The lesser of: $500 or $600

Penalty = $500

EXAMPLE 3: Nonfiler of Nonelection-Sensitive Report. A committee

fails to file its July quarterly report within 30 days of its due date. Based on

its previous filings, the committee’s estimated level of activity is $50,000.

The committee has one prior violation in the current two-year election cycle.

Applicable formula:

Penalty = base amount x [1+ (.25 x number of previous violations)]

Penalty = $2,700 x [1 + (.25 x 1)]

Penalty = $3,375

EXAMPLE 4: Nonfiler of 48-Hour Notice. A House campaign committee

fails to submit a 48-hour notice to disclose its receipt of a last-minute $5,000

PAC contribution. The campaign has two prior violations in the current twoyear election cycle.

Applicable formula:

Penalty = [$100 + (.10 x amount of contribution(s) not timely reported)] x [1

+ (.25 x number of previous violations)]

Penalty = [$100 + (.10 x $5,000)] x [1 + (.25 x 2)]

Penalty = $900

of receipts and disbursements is

$80,000, the base amount will be

$600. Or, if the total amount of

receipts and disbursements is

$500,000, the base amount will be

$3,750. The base amount ranges

from $100 to $5,000 for nonsensitive reports and from $150 to $7,500

for election-sensitive reports.

2. Additional Set Amount for Late

Filers.

The Commission then adds to the

base amount a number that is

calculated by multiplying a set

amount, based on the financial

activity in the report, by the number

of days the report is filed late (up to

30 days). The set amount ranges

from $25 to $200 per day, depending on the total amount of receipts

and disbursements.

3. Base Amount for Nonfilers.

In the case of nonfilers, the

Commission begins with a base

amount that depends on both the

election sensitivity of the nonfiled

report and the estimated level of

activity based on the average

activity in the current or prior twoyear election cycle. The base

amount will range from $900 to

$12,000 for nonsensitive reports and

from $1,000 to $16,000 for electionsensitive reports.

4. Additional Premium for Previous

Violation(s).

With regard to both late filers and

nonfilers, the Commission adds a

premium for prior civil money

penalties assessed for failure to file

timely reports. The premium is

equal to 25 percent of the civil

money penalty times the number of

final civil money penalties assessed

during the previous and current twoyear election cycles under the

Administrative Fines program.

For 48-Hour Notices

The calculation of the civil

money penalties for committees that

fail to file timely 48-hour notices is

$100 for each nonfiled notice plus

10 percent of the dollar amount of

the contributions not timely reported. The civil money penalty

increases by 25 percent for each

time a prior civil money penalty was

assessed during the previous and

current two-year election cycles

under the Administrative Fines

program.

The table below provides examples of how civil money penalties

are calculated.
July 2000 Federal Election Commission RECORD

5

State Filing Waiver Rules

Take Effect

The FEC’s revised rules on filing

copies of reports and statements

with state officers—the State Filing

Waiver program—took effect June

7, 2000. (65 FR 36053, June 7,

2000).

The rules implement a 1995

amendment to the Federal Election

Campaign Act that gives the FEC

authority to exempt states meeting

certain criteria from the requirement

to receive and maintain copies of

FEC reports. 2 U.S.C. §439(c). To

date, 45 states/territories have

qualified for the exemption, referred

to as a state filing waiver.2

The final rules appeared in the

Federal Register on March 22, 2000

(65 FR 15221). For a summary of

the rules, see the April Record, p.

3.

-

1

 The waiver program, itself, has been

in place since October 1999.

2

 The Commission has certified that the

following states and territories qualify

for filing waivers: Alabama, American

Samoa, Arkansas, California, Colorado, Connecticut, Delaware, Florida,

Hawaii, Idaho, Illinois, Indiana,

Kansas, Kentucky, Louisiana, Maine,

Maryland, Michigan, Minnesota,

Mississippi, Missouri, Nebraska, New

Hampshire, New Jersey, New Mexico,

New York, North Carolina, North

Dakota, Ohio, Oklahoma, Oregon ,

Pennsylvania, Rhode Island, South

Carolina, South Dakota, Tennessee,

Texas, Utah, Vermont, Virginia, Virgin

Islands, Washington, West Virginia,

Wisconsin and Wyoming. Committees

that file their reports at the FEC need

not file copies in these states.

2

 In compliance with the Debt Collection Improvement Act of 1996 (31

U.S.C. §3711(g)).

Collecting Unpaid Penalties

When a respondent fails to pay

the civil penalty, the Commission

will transfer the case to the U.S.

Department of the Treasury for

collection.2

 Alternatively, the

Commission may decide to file suit

in the appropriate U.S. district court

to collect owed civil money penalties, under 2 U.S.C. §437g(a)(6).

More Information

Copies of this article will soon be

mailed to all political committees.

Additional information is available

on the Commission’s home page

(www.fec.gov). Click on the

Administrative Fines graphic.

Committees seeking additional

information on the program may

contact the FEC’s Information

Division, 202/694-1100 or toll free

at 800/424-9530 (press 1, then 3).

Free copies of the final rules as

they appeared in the Federal

Register (65 FR 31787, May 19,

2000) are available through the FEC

Faxline (202/501-3413, document

247) and on the FEC’s Web site at

http://www.fec.gov/pdf/

00%20Administrative%20Fines%20

E&J.pdf.✦

Court Cases

(continued from page 1)

FECFile Help on Web

 The manual for the Commission’s FECFile 3 electronic filing

software is now available on the

FEC’s web site. You can download a PDF version of the manual

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

fecfile3.pdf.

(continued on page 6)

Colorado I

In the first ruling on this case, the

U.S. District Court for the District

of Colorado concluded that the ads

were not subject to the 441a(d)

limits because they did not contain

express advocacy. Having already

ruled in the party’s favor, the court

did not address the party’s constitutional challenge.

On appeal, the U.S. Court of

Appeals for the 10th Circuit,

agreeing with the FEC that a

441(a)(d) expenditure need only

depict a clearly identified candidate

and convey an electioneering

message, reversed the district

court’s decision. The appeals court

also held that the 441a(d) limits did

not violate the party’s First Amendment rights.

The U.S. Supreme Court agreed

to hear the case principally to

resolve the constitutional question.

In its June 26, 1996, plurality

decision, the Court concluded that

the Party’s expenditures had not

been coordinated with a candidate,

and were instead independent

expenditures. The Court then also

concluded that the 441a(d) limits

were unconstitutional as applied to

political parties’ independent

expenditures. The Court did not

rule on the constitutionality of the

limits as applied to coordinated

party expenditures, but instead,

remanded the case to the district

court for further proceedings on that

issue.

Colorado II

On remand, both sides compiled

an extensive record focusing on the

constitutional issue raised in Colorado I. On February 23, 1999, the

district court ruled that the coordinated expenditure limits were

unconstitutional. The court concluded the FEC had failed to offer
Federal Election Commission RECORD July 2000

6

1

 See footnote 1 of the court’s opinion.

FEC Statement on the

Colorado Decision1:

 “In a split decision, the United

States Court of Appeals for the

Tenth Circuit recently held that 2

U.S.C. §441a(d)(3), which limits

the amount of a political party’s

coordinated expenditures in

congressional elections, violates

the First Amendment. FEC v.

Colorado Republican Federal

Campaign Committee. The

Solicitor General has decided to

seek review of that decision by

the United States Supreme Court.

Until the Supreme Court resolves

the case, the Federal Election

Commission will not file any

action in the courts in the Tenth

Circuit to enforce section

441a(d)(3). The Commission will,

however, generally continue the

administrative processing of

matters concerning section

441a(d)(3).

 Only the Tenth Circuit has

found section 441a(d)(3)

unconstitutional, and its decision

is not controlling outside that

court’s geographic jurisdiction.

Furthermore, if the United States

Supreme Court overrules the

Tenth Circuit, the Court’s

decision upholding section

441a(d)(3) will apply

retroactively to any activities in

the interim that violate section

441a(d)(3), even in the Tenth

Circuit. See James B. Beam

Distilling Co. v. Georgia, 501

U.S. 529 (1991); Harper v.

Virginia Dep’t of Taxation, 509

U.S. 86 (1993). Therefore,

anyone who chooses to act in

contravention of section

441a(d)(3)—within or without the

Tenth Circuit—before the

Supreme Court rules in Colorado

could be subject to liability for

violating the statute if the

Colorado decision is reversed.”

1

 Approved June 21, 2000.

evidence that there was a compelling need for limits on coordinated

party expenditures. In its opinion,

the court equated coordinated party

expenditures with a candidate’s own

campaign expenditures which, based

on the Supreme Court’s ruling in

Buckley v.Valeo, cannot be limited.

(See the April 1999 Record, p. 1.)

Current Decision

To support the constitutionality

of the 441a(d) limits, the Commission offered three principal arguments that the limits prevent

corruption or the appearance of

corruption:

1. Section 441a(d)(3) limits the

extent to which generous contributors to the party can influence the party “to either support

or neglect those candidates who

endorse or eschew the interests of

the large contributor”;

2. The cap on coordinated party

expenditures reduces the ability

of a small group of incumbent

officeholders (the party elite) to

exert improper pressure on the

party’s candidates by granting or

withholding the use of party

funds; and

3. The 441a(d) limits reinforce the

Act’s cap on individual contributions. Without them, individuals

could try to circumvent the

$1,000 per candidate, per election

contribution limit by giving the

maximum $20,000 per year

contribution to the party with the

expectation that the funds would

be spent to support a particular

candidate.

The court, in a 2-1 decision,

rejected the first of these arguments

by noting, in part, that—based on

the Supreme Court’s earlier ruling

in this case—party committees can

already make unlimited independent

expenditures. The court refused to

consider the potential corrupting

influence of unregulated “soft

money” contributions, since those

funds cannot legally be spent to

influence federal elections.

With respect to the FEC’s second

argument, the court concluded that

“there is nothing pernicious” about a

party “shaping the views of its

candidates.” The court added that,

“Parties are simply too large and too

diverse to be corrupted by any one

faction.”

The court dismissed the

Commission’s final argument by

noting that 2 U.S.C. 441a(a)(8)

requires that contributions earmarked for a particular candidate

(i.e., that pass through an intermediary) be treated as contributions from

the original source to the candidate.

Having found no persuasive

evidence that coordinated party

expenditures corrupt, or appear to

corrupt, the electoral process, the

appeals court upheld the district

court’s decision. The court concluded that “441a(d)(3)’s limit on

party spending . . . constitutes an

‘unnecessary abridgment’ of First

Amendment freedoms.” The court

stated explicitly that its analysis and

holding apply only to party spending in connection with Congressional races.1

In dissent, Chief Judge Seymour

found the “majority opinion fundamentally flawed in several respects.” In her view, the panel

majority “substitute[d] its judgment

for that of Congress on

quintessentially political matters the

Supreme Court has cautioned courts

to leave to the legislative process.

In so doing, the majority creates a

special category for political parties

based on its view of their place in

American politics, a view at odds

with history and with legislation

drafted by politicians.”

U.S. Court of Appeals for the

10th Circuit (99-1211).✦

Court Cases

(continued from page 5)
July 2000 Federal Election Commission RECORD

7

Renato P. Mariani v. USA

On May 18, 2000, the U.S. Court

of Appeals for the Third Circuit

rejected constitutional challenges to

the Federal Election Campaign

Act’s (the Act’s) prohibitions on

corporate contributions and contributions in the name of another. 2

U.S.C. §§441b and 441f.

Renato P. Mariani brought the

challenges under 2 U.S.C. §437h,

which permits individual voters to

challenge the constitutionality of

any provision of the Act in district

court. The district court certifies the

constitutional questions to the

circuit court of appeals, which hears

the cases sitting en banc.

Mr. Mariani is currently the

subject of criminal prosecution

concerning the very provisions he

challenged in this case.

Corporate Contributions

Mr. Mariani argued that the

development of issue advocacy and

the increasing role of unregulated

“soft money” in the electoral

process “has so eroded the theoretical distinction between hard and soft

money” that §441b’s prohibition

against corporate contributions has

become “fatally underinclusive.” As

such, he asserted, it should be struck

down. He also challenged the ban as

a violation of corporations’ First

Amendment rights.

In response, the court acknowledged that “[t]he practical distinctions between hard and soft money

may have diminished in the past

decade with the rise of issue advocacy, but not to such an extent that

there is no practical distinction

between the two.” The court went

on to note, “If hard and soft money

were equivalent, it would be hard to

imagine why Mariani would have

gone to the lengths he allegedly

went to in order to give hard money

instead of soft.” Noting that Congress can act incrementally—and

referencing legal precedents—the

court concluded that the corporate

ban “is not fatally underinclusive.”

The court also rejected the First

Amendment challenge, citing the

U.S. Supreme Court’s decisions in

FEC v. National Right to Work

Committee, FEC v. National Conservative PAC and Austin v.

Michigan Chamber of Commerce.

Though the court stated that none of

these cases directly addressed the

constitutionality of the corporate

ban, their “strong implications” led

the court “to reject Mr. Mariani’s

facial challenge to §441b(a).”

Contributions in the Name of

Another

Mr. Mariani argued that §441f’s

ban on contributions in the names of

others violates the First Amendment

by failing to advance a compelling

government interest and is

underinclusive because it does not

apply to soft money donations.

The appeals court found the 441f

challenges “patently without merit.”

The court noted that the Supreme

Court, in Buckley v. Valeo, specifically held that the Act’s disclosure

requirements were constitutional

absent a “reasonable probability”

that disclosure would result in

“threats, harassment, or reprisals”

for contributors. Since contributions

in the names of others undermine

disclosure, the court rejected Mr.

Mariani’s First Amendment challenge.

The court also rejected Mr.

Mariani’s underinclusiveness

argument. The court concluded that

“Congress was free to determine

that disclosure of hard money

donations was the most important

form of disclosure, and to limit the

regulation to that area.”

U.S. Court of Appeals for the

Third Circuit, No. 99-3875.✦

(continued on page 8)

PACronyms, Other

PAC Publications

Available

 The Commission annually

publishes PACronyms, an

alphabetical listing of acronyms,

abbreviations and common names

of political action committees

(PACs).

 For each PAC listed, the index

provides the full name of the

PAC, its city, state, FEC

identification number and, if not

identifiable from the full name,

its connected, sponsoring or

affiliated organization.

 The index is helpful in identifying PACs that are not readily

identified in their reports and

statements on file with the FEC.

 To order a free copy of

PACronyms, call the FEC’s

Disclosure Division at 800/424-

9530 (press 3) or 202/694-1120.

PACronyms also is available on

diskette for $1 and can be

accessed free under the “Using

FEC Services” icon at the FEC’s

web site—http://www.fec.gov.

Other PAC indexes, described

below, may be ordered from the

Disclosure Division. Prepayment

is required.

• An alphabetical list of all

 registered PACs showing each

 PAC’s identification number,

 address, treasurer and

 connected organization ($13.25).

• A list of registered PACs

 arranged by state providing the

 same information as above

 ($13.25).

• An alphabetical list of

 organizations sponsoring PACs

 showing the PAC’s name and

 identification number ($7.50).

 The Disclosure Division can

also conduct database research to

locate federal political committees

when only part of the committee

name is known. Call the telephone

numbers above for assistance or

visit the Public Records Office in

Washington at 999 E St., N.W.
Federal Election Commission RECORD July 2000

8

Court Cases

(continued from page 7)

New Litigation

Committee for a Unified

Independent Party v. FEC

The Committee for a Unified

Independent Party and other plaintiffs (collectively “the Committee”)

ask the U.S. District Court for the

Southern District of New York to

find that the FEC’s debate regulations are not authorized by the

Federal Election Campaign Act (the

Act) and violate the First and Fifth

Amendments to the U.S. Constitution.

The regulations in question, 11

CFR 110.13 and 114.4(f), permit

nonprofit corporations to stage

candidate debates and to accept

donations from corporations and

labor unions to defray the costs of

those debates. This exemption from

the general prohibition against

corporate and union contributions

and expenditures is based on a

statutory provision that permits

“nonpartisan activity (by corporations or unions) designed to encourage individuals to vote or to register

to vote.” 2 U.S.C. §431(9)(B)(ii).

The Committee argues that

debates are not “nonpartisan activity

designed to encourage individuals to

vote or to register to vote” and are

therefore not authorized by the Act.

Further, even if debates were

considered exempt nonpartisan

activity, the FEC’s regulations

unlawfully expand the statutory

exemption to permit debates that are

neither nonpartisan nor designed to

encourage voting. Rather, the debate

regulations permit corporations and

unions to make prohibited contributions to influence federal elections.

The Committee further contends

that the debate regulations “tilt the

electoral playing field so as to put

minor parties . . . and persons and

organizations seeking to promote a

democratic multiparty electoral

process, at a competitive disadvantage” in violation of the First and Fifth

Amendments to the U.S. Constitution.

U.S. District Court for the

Southern District of New York, 00-

CIV-3476, May 8, 2000.✦

On Appeal

John Jay Hooker v. FEC

(3-99-0794)

On May 11, 2000, John Jay

Hooker appealed this case to the

U.S. Court of Appeals for the Sixth

Circuit. He seeks review of a district

court order dismissing his constitutional challenges concerning

interstate campaign contributions

and the Presidential Primary Matching Payment Act. See the June 2000

Record, p. 9.✦

Reform Party of USA v. Russell J.

Verney

Reform Party of USA v. John J.

Gargan

Former Reform Party leaders

John J. Gargan and Ronn Young

have appealed this case to the U.S.

Court of Appeals for the Fourth

Circuit. They seek review of a

district court decision that upheld

their removal as chairman and

treasurer of the Reform Party. See

May 2000 Record, p. 9.✦

Advisory

Opinions

AO 2000-05

Contributions by Indian Tribe

The Oneida Nation of New York

(the Nation) may make contributions in support of federal candidates totaling in excess of $25,000

in a calendar year.

The Nation, an Indian tribe

located in central New York state, is

a non-corporate entity.

Under the Federal Election

Campaign Act (the Act), no “person” may contribute in excess of

$1,000 per candidate, per election.

The Act defines the term “person”

as including an “individual, partnership, committee, association,

corporation, labor organization, or

any other organization or group of

persons....” 2 U.S.C. 431(11). As

indicated in AO 1999-32, the Nation

falls under the category of “any

other organization or group of

persons.” Thus, the Nation is a

person and its contributions are

subject to the $1,000 per election,

per candidate limit.

By contrast, the Nation is not

subject to the $25,000 annual

contribution limit prescribed under 2

U.S.C. §441a(a)(3). That limit

applies only to “individuals,”

prohibiting them from contributing

more than $25,000, in aggregate,

per calendar year. Although the

Nation is a person, it is not an

individual. Therefore, it is not

subject to the $25,000 limit.

The Nation said that the source of

its funds for its political contributions was its general treasury funds.

These funds included revenue

generated by several incorporated

businesses that it owns, but the

Nation explained that it had sufficient permissible funds in its general

treasury (i.e., funds that comply

with the Act’s limitations and

prohibitions) to make its contributions.

The FEC Takes Visa

and Mastercard

 FEC customers can pay for FEC

materials with Visa or

Mastercard. Most FEC materials

are available free of charge, but

some are sold, including financial

statistical reports ($10 each),

candidate indexes ($10) and PAC

directories ($13.25). The FEC

also has a 5¢ per page copying

charge for paper documents and a

15¢ per page copying charge for

microfilmed documents.
July 2000 Federal Election Commission RECORD

9

Since the Nation did not request

an advisory opinion on the source of

funds that may be lawfully used, the

Commission did not issue an

opinion on that issue.

Date Issued: May 16, 2000;

Length: 3 pages.✦

AO 2000-06

Use of Federal Convention

Funds

The Reform Party may use

federal convention funds to pay for

the development of a voter data base

and balloting system to choose the

party’s presidential candidate.

As part of the Reform Party’s

nominating process, a national vote

is held through which the presidential candidate is chosen. According

to the Reform Party’s nomination

rules, those who can participate in

the national vote include all members of the Reform Party, others

who want to participate in the

Reform Party organization in their

state and those who sign a nominating petition for a Reform Party

candidate. The party will compile

the names of these people and put

them into a voter data base. The

national vote will take place when

these voters cast their ballots by

telephone, mail or e-mail during

July 2000. The party will then

tabulate the ballots and announce

the results at the Reform Party

National Convention in August

2000.

The Reform Party has qualified

as a minor party by meeting the

criteria at 11 CFR 9002.7. Under 26

U.S.C. §9008(b)(2), the national

committee of a minor party is

entitled to federal funding for its

presidential nominating convention

to pay for convention expenses.

Commission regulations list examples of permissible convention

expenses at 11 CFR 9008(a)(4), but

the list does not include anything

specific to the Reform Party’s plan.

However, Commission regulations

make clear that the list is not

exhaustive. As stated in the Explanation and Justification to the

original regulations, “the national

committee is . . . not limited to using

its public funds only for the expenses listed but may also use

public funds to defray any other

expense with respect to the convention.” 44 FR 83036 (November 1,

1979).

The costs of the voter data base

and balloting system are acceptable

convention expenses because they

are integral to the convention

process. It is the use of the data

base and balloting procedure which

results directly in the choice of the

presidential candidate, who is later

announced at the convention.

Therefore, the Reform Party may

pay for them with federal convention funds. By contrast, payments

made to help candidates attain ballot

access and thus qualify for the

primary would not be a permissible

use of public convention funding.

Date Issued: May 31, 2000;

Length: 5 pages.✦

AO 2000-07 

Use of Corporate Web Sites

to Provide PAC Information

and Solicit Contributions

Alcatel USA, Inc., may post on

its government relations intranet

Web site (which is accessible to all

employees at Alcatel) certain

messages referring to Alcatel PAC

because the messages do not

constitute a solicitation; they do not

encourage contributions; and they

include a statement that Alcatel will

not accept contributions from those

outside the restricted class.1

 Additionally, Alcatel PAC may use

electronic mail to communicate with

the restricted class and to solicit it

for PAC contributions.

Although neither the Federal

Election Campaign Act nor Commission regulations specifically

address the issue of what makes a

corporate communication a solicitation, previous Commission advisory

opinions offer guidance on this

matter. See AOs 1999-6, 1991-3,

1988-2 and 1983-38.

Government Relations Intranet

Site

Alcatel’s government relations

site, which is accessible by all

employees at Alcatel, does not

contain a solicitation. The intranet

Web site states that Alcatel supports

Alcatel PAC, and it briefly describes

the functions of any PAC and the

rules that govern PACs. Although

the site also states that employees

may contact the PAC for information on their eligibility and the

PAC’s activities, this statement

merely conveys information that

might encourage an inquiry; it does

not encourage contributions.

A second Web page (also viewable by all employees) introduces

the PAC Web site and repeats the

statement about contacting the PAC.

This page, however, discourages

attempts to contribute by stating:

“Federal law prohibits the Alcatel

USA Political Action Committee

from soliciting donations from other

than stockholders, executive and

administrative personnel and the

families of such individuals. Any

contribution received from any other

person will be returned to the

donor.”

Given the content of the government relations web page and the

statement that Alcatel will not

accept contributions from those

outside the restricted class (contained on the page introducing the

PAC site), the messages on the

government relations site and the

Web page introducing the PAC site

do not, either separately or taken

together, constitute a solicitation. 1

 The restricted class includes the

executive and administrative class,

stockholders and the families of both

groups. 11 CFR 114.1(j). (continued on page 10)
Federal Election Commission RECORD July 2000

10

Congressional and Party

Receipts Increase

Congressional candidates raised

nearly $125 million more during the

first 15 months of the 2000 election

cycle than during the same period in

1997-98. In total, House and Senate

candidates raised $462.8 million and

spent $252.4 million between

January 1, 1999, and March 31,

2000. See the chart at the top of

page 11 for an historical view of

median receipts by House candidates.

For the major national party

committees, federal receipts increased by 18 percent over 1997-98,

and soft money receipts rose by 66

percent. The Republicans raised

more in both hard and soft money

than the Democrats. The Republican

national committees raised $129.2

million in hard dollars, compared to

the Democrats’ $77 million. In soft

money, the Republicans collected

$86.4 million to the Democrats’

$80.2 million. See the chart on the

bottom half of page 11.

Additional details are available in

two news releases dated June 5,

2000. The releases, which include

statistical information dating back to

the 1988 election cycle, are available:

• On the FEC Web site at http://

www.fec.gov/news.html;

• From the Public Records Office

(800/424-9530, press 3) and the

Press Office (800/424-9530, press

5); and

• By fax (call the FEC Faxline at

202/501-3413 and request documents 612 and 613).✦

Statistics

PAC Site

The PAC Site is available only to

the restricted class through the use of

a password. Those who qualify for

access to the site (the restricted class

only) will likely receive PAC contribution solicitations once they enter the

site. By providing only the restricted

class with a password to the PAC site,

Alcatel ensures that solicitations for

contributions to the PAC comply with

the restrictions of 2 U.S.C.

§441b(b)(4)(A)(i) and 11 CFR

114.5(g).

E-Mail List

Alcatel also may use an electronic

mailing list containing only the e-mail

addresses of those in the restricted

class to communicate with the

restricted class and to solicit contributions to the PAC. See AO 1995-33.

Date Issued: May 31, 2000;

Length: 6 pages.✦

Advisory Opinions

(continued from page 9)

Advisory Opinion Requests

AOR 2000-12

Use of campaign funds by

withdrawn, and “winding down”

publicly funded Presidential candidates to pay for convention-related

expenses (Bill Bradley for President, Inc. and McCain 2000, Inc.,

May 24, 2000)

AOR 2000-13

Application of “press exemption”

to corporation’s internet video

coverage of Republican and Democratic national conventions (Ampex

Corporation and iNEXTV Corporation, May 31, 2000)

AOR 2000-14

Qualification as state committee

of political party (New York State

Committee of the Working Families

Party, May 31, 2000)

AOR 2000-15

State credit union league’s use of

payroll deduction to collect contributions from executive employees

for SSF of affiliated federation of

trade associations (Credit Union

National Association, Inc., New

York State Credit Union League,

Inc., and Credit Union Legislative

Action Committee, June 1, 2000)

AOR 2000-16

Research study of young voters to

determine effect of Internet campaign ads in 2000 elections on their

voting participation (Third Millennium: Advocates for the Future,

Inc., June 9, 2000)

AOR 2000-17

Proposed formation and administration of SSF by US subsidiary of

foreign corporation (Extendicare

Health Services, Inc., June 9, 2000)

AOR 2000-18

Close of period to claim Federal

matching funds for Presidential

candidate seeking nomination by new

political party (Nader 2000 Primary

Committee, Inc., June 12, 2000) ✦

Back Issues of the

Record Available on

the Internet

This issue of the Record and all

other issues of the Record starting

with January 1996 are available

through the Internet as PDF files.

Visit the FEC’s World Wide Web

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

click on “What’s New” for this

issue. Click “Campaign Finance

Law Resources” to see back issues. Future Record issues will be

posted on the web as well. You

will need Adobe® Acrobat®

Reader software to view the publication. The FEC’s web site has

a link that will take you to Adobe’s

web site, where you can download

the latest version of the software

for free.
July 2000 Federal Election Commission RECORD

11

15-Month Party Receipts by Election Cycle

Democratic National Committees Republican National Committees

15-Month Median Receipts of House Candidates

Democrats Republicans

0

50

100

150

200

250

1992 1994 1996 1998 2000

Millions of Dollars

0

50

100

150

200

250

1992 1994 1996 1998 2000

Millions of Dollars

Nonfederal

Federal

0

100

200

300

400

500

1992 1994 1996 1998 2000

Millions of Dollars Millions of Dollars

0

100

200

300

400

500

1992 1994 1996 1998 2000

Open Seats

Challengers

Incumbents
Federal Election Commission RECORD July 2000

12

FEC Roundtables

The Commission will host

roundtable sessions in August and

September.

FEC roundtables, limited to 12

participants per session, focus on a

range of subjects. See the table for

dates and topics. All roundtables are

conducted at the FEC’s headquarters

in Washington, DC.

Registration is $25 and will be

accepted on a first-come, firstserved basis. Please call the FEC

before registering or sending money

to be sure that openings remain in

the session of your choice. Prepayment is required. The registration

form is available at the FEC’s Web

site—http://www.fec.gov—and

from Faxline, the FEC’s automated

fax system (202/501-3413, request

document 590). For more information, call 800/424-9530 (press 1,

then 3) or 202/694-1100.✦

Outreach

Date Subject Intended Audience

Roundtable Schedule

August 2 Update on New and Proposed • PACs

9:30 - 11 a.m. FEC Reporting Regulations • House and Senate

• State Filing Waiver Campaigns

• Mandatory Electronic Filing • Political Party

• Administrative Fines Committees

for Reporting Violations • Lawyers, Accountants

• Election Cycle Reporting and Consultants to

Above

September 13 Pre-Election Reporting • PACs

9:30 - 11 a.m. Tune-Up • House and Senate

• October Deadlines Campaigns

• Last-Minute Notices • Political Party

• Problems to Avoid Committees

• Your Questions Answered • Lawyers, Accountants

and Consultants to

Above

Filled!

Waiting List

Only

Membership Organization

vs. Trade Association: Which

One Are You?

Membership organizations and

trade associations share many of the

same characteristics. Trade associations are, in fact, a type of membership organization. However, specific

criteria set trade associations apart

from other kinds of membership

organizations.

Definition of Membership

Organization

Generally, a membership organization (of any type, including a

cooperative, a labor organization

and a trade association) is defined

by the following traits:

• It provides for members in its

articles and bylaws;

of any type may solicit its corporate

members.1

Trade associations, however, are

permitted to solicit the restricted

class2 of their corporate members,

provided they first obtain the

approval of the corporate members.

11 CFR 114.8(c). Other types of

membership organizations may not

solicit the restricted class of their

corporate members.

For more information regarding

trade association solicitations and

the special rules on seeking prior

corporate approval, see the Campaign Guide for Corporations and

Labor Organizations, Appendix C.

800 Line

• It seeks members;

• It acknowledges the acceptance of

members (e.g., by distributing

membership cards); and

• Is not organized primarily for the

purpose of influencing the election

of an individual for federal office.

Definition of Trade Association

Following are the more

specific criteria that distinguish a

trade association from other membership organizations:

• The membership of a trade association is comprised of persons

and/or companies engaged in a

similar or related line of commerce

or business; and

• A trade association is organized to

promote and improve the business

conditions of its members, but the

organization itself does not make a

profit, and its net earnings do not

benefit any members.

Unique Solicitation Rules for

Trade Associations

When raising funds for their

PACs, no membership organization

1

 Membership organizations are

permitted to solicit their noncorporate

members, their executive and administrative personnel and the families of

both groups.

2

 The restricted class consists of a

corporation’s executive and administrative personnel, stockholders and the

families of both groups.

(continued on page 13)
July 2000 Federal Election Commission RECORD

13

Matching Funds for 2000 Presidential Candidates:

May Certification

Candidate Certification Cumulative

 May 2000 Certifications

Gary L. Bauer (R) 1 $55,746.21 $4,674,357.76

Bill Bradley (D) 2 $71,541.92 $12,462,047.69

Patrick J. Buchanan (Reform) $293,752.00 $3,741,688.19

Al Gore (D) $522,232.35 $14,644,994.73

John Hagelin (Natural Law) $13,684.00 $248,594.00

Alan L. Keyes (R)3 $310,652.07 $2,902,745.82

Lyndon H. LaRouche, Jr. (D) 4 $0.00 $901,338.93

John S. McCain (R) 5 $331,778.88 $14,335,793.88

Dan Quayle(R) 6 $0.00 $2,102,525.00

1 Gary L Bauer publicly withdrew from the race on February 4, 2000.

2 Bill Bradley publicly withdrew from the race on March 9, 2000.

3 Alan L. Keyes became ineligible for matching funds on April 20, 2000.

4

 Lyndon H. LaRouche, Jr. reestablished eligibility for matching funds on May 23,

2000, by receiving more than 20 percent of the vote in the Arkansas primary.

5 John S. McCain publicly withdrew from the race on March 9, 2000.

6 Dan Quayle publicly withdrew from the race on September 27, 1999 .

May Matching Fund Payments

On May 31, 2000, the Commission

approved an additional $1,599,387.43

in matching fund payments to seven

Presidential candidates. With these

latest certifications, the FEC has now

declared nine candidates eligible to

receive a total of $56,014,086.00 in

federal matching funds for the 2000

election.

Due to a shortfall in the Presidential Election Campaign Fund, the

U.S. Treasury Department has been

making partial payments to the

qualified candidates, based on the

Commission’s certifications. The

chart lists the most recent certifications and cumulative payments for

each candidate.✦

Public Funding

Adjusted Payment for

Reform Party Convention

On May 25, the Commission

approved an additional public

funding payment of $53,769 for the

Reform Party’s 2000 presidential

nominating convention. This

additional payment reflects an

adjustment based on the consumer

price index. With this payment, the

Reform Party 2000 Convention

Committee has received its full

public funding entitlement of

$2,522,690. ✦

Definition of Federation of Trade

Associations

A federation of trade associations

is an organization representing trade

associations involved in the same or

an allied line of commerce.

114.8(g)(1). A federation may

solicit contributions from the

restricted class of a member corporation of a trade association that is a

member of the federation.

Examples of Trade Associations

and Federations of Trade

Associations

Through various advisory

opinions, the Commission has cited

some examples of a trade association and a federation of trade

associations.

• The Credit Union National Association (CUNA) was a trade

association federation composed of

state credit union leagues. AO

1998-19.

• The Commercial Finance Association (CFA) and its affiliated

regional chapters were all characterized as trade associations. (AO

1999-16)..

• The Michigan State Chamber of

Commerce could not be considered

a federation of trade associations

because its membership consisted

of individuals, corporations and

local chambers of commerce that

were not necessarily involved in

the same or allied line of commerce. AO 1985-37.

• The Association of Trial Lawyers

of America (ATLA) qualified as a

trade association. AO 1977-44 and

AO 1996-1, footnote 1.

800 Line

(continued from page 12)
Federal Election Commission RECORD July 2000

14

Updated Summary of State

Campaign Finance Laws

The FEC recently published

Campaign Finance Law 2000,

which summarizes the campaign

finance laws of each state and

includes state code citations. The

volume was produced for the FEC

by INGroup of Indianapolis with

support from state election officials.

For quick reference, a series of

charts lists each state’s reporting

requirements, contribution restrictions, solicitation restrictions and

expenditure limits. These charts are

available on the FEC’s Web site at

http://www.fec.gov.

Campaign Finance Law 2000 is

available for purchase from the U.S.

Government Printing Office at 202/

512-1800, 202/512-2250 (FAX) or

on-line at https://

orders.access.gpo.gov/su_docs/sale/

prf/prf.html (Stock Number: 052-

006-00062-7; Cost: $67.00). A

limited number of free copies are

available from the Commission’s

Public Records Office at 800/424-

9530 (press 3) or 202/694-1120.✦

Publications

Public Appearances

July 26-28, 2000

Elections Manitoba

Winnipeg, Canada

Lawrence Noble

Do you want to file your FEC reports electronically? The FEC will

mail you a copy of the latest version of its free electronic filing software—FECFile. Mail or fax this form to the address/number below. Or,

download the software from the FEC’s web site at http://www.fec.gov.

FECFile requires a PC with Windows 95, 98 or NT, and approximately

8 MB of free disk space.

FEC Identification Number

Committee Name

Electronic Filing Contact Name

Address: Street 1

Address: Street 2

City

State

Zip Code

Phone Number

Fax Number

E-mail Address

Federal Election Commission

Data Division—Room 431

999 E Street, NW

Washington, DC 20463

Fax: 202/219-0674

✃

FECFile Order Form
July 2000 Federal Election Commission RECORD

15

Index

The first number in each citation

refers to the “number” (month) of

the 2000 Record issue in which the

article appeared. The second

number, following the colon,

indicates the page number in that

issue. For example, “3:4” means

that the article is in the March issue

on page 4.

Advisory Opinions

1999-24: Web site sponsored by

LLC featuring information on

candidates, 1:17

1999-29: Fundraising exemption

from state limits for direct mailing

by Presidential committee, 1:19

1999-30: Application of allocation

ratio in state with single house

legislature, 1:20

1999-31: Application of one-third

rule to prizes and premiums used

in connection with payroll

deduction, 1:21

1999-32: Indian tribe’s utility

authority treated as separate from

the tribe, 3:4

1999-33: Delayed transmittal of

payroll deductions, 3:5

1999-34: Use of campaign funds to

finance charity event, 2:2

1999-35: Soliciting for SSF through

electronic deduction system, 2:4

1999-36: Fundraising via electronic

checks and Internet fund transfers,

3:5

1999-37: PAC distribution of

express advocacy communications through Web site and email, 4:1

1999-39: Disaffiliation of SSFs after

corporate restructuring, 4:5

1999-40: Solicitation of members of

rural electric cooperatives, 5:6

2000-1: Paid leave of absence for

attorney seeking federal office,

4:5

2000-2: Campaign rental of candidate-owned office, 5:7

2000-3: PAC’s payment for corporate communication, 5:8

2000-4: Automatic Deductions for

credit union PAC, 5:8

2000-5: Application of $25,000

limit to contributions by Indian

tribe, 7:8

2000-6: Use of federal convention

funds to develop voter data base

and balloting system, 7:9

2000-7: Use of corporate web sites

to provide PAC information and

solicit contributions, 7:9

Compliance

MUR 3774: Failure to allocate

expenses between federal and

nonfederal accounts for get-outthe-vote drive conducted by third

party, 3:3

MUR 4322 and 4650: Violations by

candidate, campaign committees,

treasurer and relative, 2:1

MUR 4648: Failure to disclose

purpose of expenditures and other

violations, 3:4

Court Cases

_____ v. FEC

– Christine Beaumont, et al., 3:9

– DNC, 4:6

– DSCC, 1:2

– Fulani, Lenora B., 7:7

– Hooker, John Jay, 6:9, 7:8

– Unified Independent Party,

Committee for, 7:8

– Virginia Society for Human Life,

Inc., 3:8

FEC v. _____

– Christian Coalition, 4:7

– Colorado Republican Federal

Campaign Committee, 7:1

– Freedom’s Heritage Forum, 6:8

– Friend for Fasi, 3:9

– Fund for Conservative Majority

(Heckman), 6:8

– National Rifle Association, 6:9

– Salvi for Senate Committee, 6:9

– Toledano, James, 6:9

Other

– Fireman v. USA, 1:13

– Mariani v. USA, 1:3, 7:7

– Reform Party v. Gargan, 5:9, 7:8

– Shrink PAC v. Nixon, 3:7

Regulations

Administrative Fines, 5:1, 7:1

Coordination, 1:14; 4:3

Election Cycle Reporting, 6:1

Electronic Filing, 5:1

Electronic Freedom of Information

Act, 4:1

Express Advocacy, 4:2

Presidential Public Funding, 5:3

Repayments by Federally Financed

Presidential Primary Campaign

Committees, 4:2

State Waivers, 4:3, 7:5

Reports

Reports due in 2000, 1:5

Reports due in July, 6:1

State Filing Waiver, 1:2; 2:5, 4:3,

5:5, 6:3, 7:5

Virginia Convention Reports, 5:5
FEDERAL ELECTION COMMISSION

999 E Street, NW

Washington, DC 20463

Official Business

Penalty for Private Use, $300

Bulk Rate Mail

Postage and Fees Paid

Federal Election Commission

Permit Number G-31

Printed on recycled paper

Federal Election Commission RECORD July 2000