FEDERAL ELECTION COMMISSION

September 1992 999E Street NW Washington DC 20463 Volume 18, Number 

TRANSFERS F1U'l ~ERAL CAMPAIGNS

PIOIIBI'l'ED AFl'ER 1992 ELECTICfiS

On August 6, 1992, the Conunission

approved a final rule that prohibits

transfers of funds and assets from a

candidate's nonfederal campaign to his or

her federal campaign. This rule will not

become effective, however, until after the

1992 election cycle.

The new regulation at 11 CFR 1l0.3(d)

replaces the current regulation at 11 CFR

110.3(c){6), which perrrcits nanfederal to

federal campaign transfers as long as the

transfers do not contain any contributions

that are impermissible under the Federal

Election Campaign Act (the Act) •

The regulation and its Explanation and

Justification were published in the Federal

Register on August 12 (57 FR 36344). The

rule was sent to Congress on August 7.

After the rule has been before Congress for

30 legislative days, the Commission will

announce the effective date. 2 U.S.C.

§438(d) •

Background

The final rule grants a petition for

rulemaking filed by Congressman William

Thomas (RICA), who alleged that the current;

regulation fails to prevent nonfederal campaigns from using impermissible funds to

raise permissible contributions that are

then transferred to federal campaigns.

In response, the COmnUssion published a

Notice of Proposed Rulemaking seeking

comments on draft rules that would have

required a nonfederal campaign to exclude a

contribution from the amount transferred if

it resulted from a fundraising actiVity

financed with impermissible funds. Under

the proposed rule, nonfederal campaigns

would have had to be able to demonstrate

that the funds to be transferred were

raised with funds permissible under federal

law.

The Commission saw that it would be

difficult for nonfederal campaigns to link

funds to be transferred with particular

fundraising disbursements, given that:

most nonfederal campaigns are subject to

less stringent recordkeeping and reporting

requirements than those imposed under

federal law~ their accounts may contain a

constantly varying mixture of permissible

and ill'lpEirmissible funds; and their fundraising expenses are often paid for with

multiple disbursements over the course of

several days. Consequently, the draft

(continued

-

TABLE OF <Dll'llNl'S

BmULM'IWS

1 Transfers from Nonfederal Campaigns

2 Transfers Between Federal Campaigns

3 Candidate Names Used in Special Project

4 Final Regulation on Rulemaking Petition

PUBLIC PUNDIm

4 Clinton, Bush Each Receive $55 Million

in Public Funds

5 August Matching Fund payments

5 Final Repayments: 1988 Kemp and BushQuayle Campaigns

REJ?ORl'S

6 Reports Due in Coming Months

8 Florida Runoff Date Changed

8 STATISTICS: Midyear PAC Count

8 AINISlJRY OPINICES

10 800 LINE: Staff Advances

COORT CASES

11 FEe v. Eldredge for Congress Committee

11 FEC v. International Funding Institute

13 fEDERAL RmISTER OOI'ICES

CCIIPLIANCE

13 Nonfilers

13 MURs Released to PUblic

15 INDEx:

16 PUBLIC APPFARANCES

16 II'fFORlIIM'Im: New IRS Phone Numbers

;
September 1992 FEDERAL ELECTION COMMISSION Volume 18, Number 

Federal Election Cc:mInission, 999 E street, Nf, washin¢on, DC 20463

800/424-9530 202;119-3420 202/219-3336 (TOO)

rules would have been difficult for the Commis~ion to monitor and enforce.

In light of these anticipated practical

difficulties, the Notice also sought comments on an alternative approach: To ban

all transfers from nonfederal campaigns.

All of the commenters who supported a rulemaking in this area preferred a total ban,

and this is the approach the Commission

adopted in its final rule.

Although the revised rule reverses a

long-standing policy of permitUng nonfederal transfers, the total ban will more

effectively prevent the indirect use of

imper.missible funds in federal elections,

an area in which the Commdssion has

recently engaged in closer regulation.

Final ltUle

The final rule, as explained earlier,

prohibits transfers of cash and other

assets from a candidate's nonfederal

campaign committee (or account) to his or

her federal campaign commdttee. The rule

does not, however, prohibit the sale of

assets by the nonfederal campaign to the

federal campaign as long as the assets are

sold at fair market value. (Committees may

consult 11 CFR 9034.5(c)(1) for guidance in

determining fair market value.) A federal

campaign may, for example, purchase the

nonfederal campaign's mailing list at fair

market value.

The final rule also provides that a

nonfederal campaign may, if it wishes, make

refunds to its donors and make arrangements

wi th the candidate's federal campai9I\ for

the solicitation of the same donors by the

federal campaign. All solicitation costs,

however, Imlst be paid by the federal

campaign.

Joan D. Aikens, Chairman

Scott E.. 'lbomas, Vice Chairman

Lee Atm Elliott

Danny L.. McDonald

John Warren MeGany

Trevor Potter

PBOPOSED ROLES TRANSFERS BE'lWEI!N

FEDERAL CMPAIGNS

The FEe seeks comments on proposed

rules that would amend the current regulations on transfers of funds between a

federal candidate's committees authorized

for different election years or for

different offices (11 eFR 110.3(c)(4) and

(c}(S»). The proposed rules would add new

requirements to such transfers. First, the

transferring commdttee would have to inform

donors of its intent to transfer their

contributions. Additionally, the committe

would be permitted to transfer only those

contributions whose donors provided written

authorization for the transfer; other

contributions would have to be excluded.

The authorizations would operate as

redesignations of contributions for anothe

election under 11 CFR 110.1(b)(5)(iii).

Comments are also sought on an alterna

tive to the "affirmative authorizationll

draft rule. under the altemative , the

comrndttee would still have to notify donors

but would be permitted to transfer the

contribution of any donor who did not

object to the transfer. The Commission

asks cammenters to consider questions raised by the I1no objectionll approach:

Should the transferring committee be

required to give contributors a minimum

amount of time to object? If so, how long?

Written comments on the proposed rules

are due on September 11, 1992. The Notice

of Proposed Rulemaking was published in the

Federal Register on August 12, 1992 (57 FR

36023).

walter J. Stewart, Secretary of the Senate,

Ex Officio Commissioner

Donn8ld It. Anderson, Clerk of the House of

Representatives, Ex Officio Commissioner

2
September 1992 FEDERAL ELECTION COMMISSION Volume 18, Number9

MN 00 USE OF CANDIMTE 1W'IES IN

SPECIAL PROJECT TITLES

The commission recently approved a

revised regulation that prohibits

unauthorized political co~tteesll from

using candidate names in the titles of

special projects and other communications.

Note that this rule will not become effective until after the i992 election cycle.

The Federal Election Campaign Act and

FEC regulations prohibit an unauthorized

commi.ttee from including the name of a

candidate in its own "name." 2 U.S.C.

§432(e)(4)i 11 CrR l02.14(a). The revised

rule at 11 CPR 102.14(al defines "name" to

include "any name under which a committee

conducts activities, such as solicitations

or other communications, including a

special project name or other designation."

The revised regulation and its EXplanation and Justification were published in

the Federal Register on July 16, 1992 (52

FR 31424). After the rule has been before

Congress fa' 30 legislative days, the

Commdssion will announce the effective

date. 2 U.S.C. §438(d). The agency plans

to set an effective date of November 4,

1992 (the day afte~ the general election).

Background

The Comadssion had previously interpreted section 432(e)(4) as applying only

to a committee's registered name on its

Statement of organization and had thus

permitted an unauthorized comrrdttee to

solicit contributions for itself under a

special project name that included the name

of a candidate (e.g. "Americans for Doe").

In Common Cause v. FEC, 842 F.2d 436

(D.C. Cir. 1988), the court of appeals

upheld the commission's authority to interpret section 432(e)(4) in this fashion,

recognizing, however, that a more extensive

ban on the use of a candidate's name would

also be a reasonable interpretation.

The Conuuon cause decision grew out of

the 1980 Presidential election. In recent

years, however, unauthorized commdttees

have increasingly adopted the practice of

using a candidate's name in the title of a

special project. Such projects have the

potential for: confusing the public and

diverting funds away from the named candidates. candidates have objected to the use

of their names in special projects when

they shared none of the fundraising proceeds or disagreed with the views expressed

in the cOlllll1U!lication.

lunauthorized political comndttees are

commdttees not authorized by a candidate,

such as party committees or PACs.

3

Notice of Proposed Rulemakiog

In response to these concerns, the

agency sought "comments on proposed regula~

tions that would have: (1) required an

unauthorized committee to use a more info~­

mative disclaimer for a special fundraising

project using a candidate's name in the

title; and (2) required that checks given

in response to the solicitation be made

payable to the unauthorized comni ttee's

registered name. (See 57 Fa 13056, April

15, 1992.) Neither of these proposals were

included in the final rule.

Commission Decision

Rather, the final rule bans the use of

candidate names in the titles of all

communications by unauthorized committees.

The agency views thts approach as more

responsive to the problems at issue and

easier to monitor and enforce than the

restrictions in the proposed rules.

While comments from unauthorized committees opposed tightening the rules on the

use of candidate names, the record supports

the Commission's decision. For exarople, a

comment feom a Presidential campaign stated

that an unauthorized project raised over

$10 million despite the candidate'S disavowal of the activities. A recent television documentary (now placed on the rulemaking record) reported that a political

action comndttee raised $9 million in

numerous projects whose titles included

candidates' names; none of the funds went

to the named candidates. Proqram investigators found that elderly people wer-e

particularly vulnerable to being misled

into believing they were contributing to

the candidates named in the titles.

Proposed Revision to Disclaimer Rule

Postponed

The Commission decided to reserve

action on another change that had been

included in this rulemaking. The change

would have amended the disclaimer requirement for solicitations by unauthorized

committees at 11 CFR 110.11(a)(1)(iv)(A) to

confonm with 2 u.s.C. §441d(a)(3). The

proposed rule would have required an

unauthorized commdttee, when soliciting

funds for itself through public advertising, to state in the disclaimer not only

who paid for the communication (as required

in the current rule) but also whether the

communication had been authorized by any

candidate. The agency now plans to consider this change in a future ru1emaking

specifically on disclaimer requirements.

(Regulations continued)
September 1992 FEDERALELECTION COMMISSION Volume 18, Numb

FINN. RmlLM'ICNS QlIl.tlLD'WUNG PETITICfi

PROCI!nJRES

The Commission recently approved final

rules that explain procedures for filing

petitions for rulemaking for the agency's

consideration. Closely based on the

aqency's previous procedures, the new

regulations provide the public with easy

access to the information.

Found in newly created 11 CFR Part 200,

the new rules:

o Describe what information is required in

a rulemaking petition;

o Explain the steps the agency takes in

respondinq to a petition;

o List the factors the Comission may

consider in decidinq whether to initiate

a rulemaking;

o Provide for the reconsideration of

petitions that are denied; and

o Define the adrninistrative record (L, e •,

the documents upon which the agency will

base its decision on the petition) for

purposes of judicial review.

In a change from the proposed rule, the

final rule provides that the Commission

will publish a Notice of Disposition in the

Federal Register only if it denies a

rulemaking petition. since that will be the

only opportunity to explain its decision.

When the agency decides to initiate a

rulemaking, its reasoning will be stated in

othe r rolemaking documents.

The final rules were published in the

Federal Register on August 5, 1992 (57 FR

34508}. A "statement of Basis and Purpose"

accompanies the rules, as required by the

Administrative Procedures Act, which

governs these regulations. The new rules

became effective on September- 4, 1992.

4

CLIN'ltN AND BUSH FAaI RECEIVE $55 MILLIC

IN PUBLIC Ft.N>S

The FEC recently approved public

funding grants for the Democratic and

Republican Presidential tickets. on Jul

17, the agency certified a $55.24 millio

payment to the campaign of the Democrati

Presidential nominee. GOvernor Bill

Clinton, and his Vice Presidential runni

mate, Senator Al Gore. The same amount 

certified on August 21 to the Republican

ticket, president George Bush and Vice

President Dan Quayle. The U.S. Treasury

paid the funds shortly after the certifi

tions.

To establish their eligibility for t

general election grants, the candidates

submdtted letters of agreements and

certifications in which they agreed to

comply with the law and submit to certai

conditions, including a post-campaign

audit.

Under the Presidential Election

Campaign Fund Act. the Democratic and

Republican nominees are each entitled to 

$20 million public funding grant as

increased by the cost-of-living adjustme

(COLA). The 1991 COLA was 2.762, thus

increasing the base grant to $55.24

million. Each major party nominee has

received general election funds since th

first pubJicly funded Presidential elect

in 1976.

Major party nominees must agree to

limit campaign spending to the amount of

the public funding grant, although they 

spend up to $50,000 from their personal

funds. These limits are shared by their

Vice Presidential running mates.

Althou<jh major party nominees may no

accept private contributions for their

campaigns, contributions may be made to

their legal and accounting funds, which 

to be used solely to comply with the law

Contributions to these compliance funds 

subject to the linuts and prohibitions o

the Federal Election Campaign Act.

Thus far in the 1992 Presidential

season, the Comrndssion has certified alm

$166.7 million in public funds. In add

tion to the $55.24 million grants certif

to the general election nominees, the

agency has certified $34.1 md11ion in

matching funds to 10 primary candidates 

$11.048 million apiece to the Democratic

and Republican Parties for their nomina

conventions.
September 1992 FEDERAL ELECTION COMMISSION

AOOUST MA'l'CHIm FUND PAYMml'S

On July 30, the Commission certified a

total of $2.8 million in matching fund

payments to 1992 presidential primary

candidates. The u.s. Treasury made the

payments early in August. As of the August

payment, primary candidates had received

over $34 million in matching funds, as

shown in the table. Candidates have

requested $2.7 million for the September

payment.

After a candidate's date of ineligibility, the candidate may still receive

matching funds to wind down the prirPary

campaign and to retire debts incurred

before that date. Several Democratic

candidates became ineligible when they

publicly withdrew from the race.1/ The

remaining Democratic candidates 1Agran,

Brown and Clinton) became ineligible on

July 15, when the Democratic Party nominated Governor Clinton. The Republican

candidates likewise became ineligible when

the Party nominated President Bush on

August 19. Lenora Fulani became ineligible

on August 20.

August Cumulative

candidate payment Total

Republicans

Patrick Buchanan $ 304,744 $ 3,612,696

George Bush 546,097 9,502,153

Democrats

Larry Agran 19,934 269,692

Jerry Brown 171,136 4,239,405

Bill Clinton 1,431,599 7,924,627

Tom Harkin 28,498 1,913,413

Bob I<errey 41,640 1,927,552

Paul Tsongas 129,748 2.802,341

Douglas Wilder 0 289,027

New Alliance party

Lenora Fulani 141,B34 1,589,775

Total $2,815,229 $34,070,680

1covernor Wilder withdrew on January 8,

senator Kerrey on March 6. Senator Harkin

on March 9 and former Senator Tsongas on

March 19.

5

Volume 18, Number 9

F1Nl\L REPAmlWl'S: 1988 AND

BUSlI-OlA'YLE CAMPAIGiS

During June, the Commission issued

final repayment determinations with respect

to two 1988 Presid~ntial campaigns: the

Jack Kemp for President Committee, Inc.,

and Bush-Quayle '88. Under mc rules, campaigns have 30 days from their receipt of

the final repayment determination to repay

the funds to the u.s. Treasury. In

accordance with FEe regulations, the Commission, on August 6, 1992, granted the

Kemp Committee's request for a 90-<1ay

extension of the repayment deadline to give

the Committee time to raise the necessary

funds ..3:/

Jack Kemp for President CoIIInittee, Inc.

In its final determination, the Commission ordered the Kemp Committee to repay

$103,555 in public funds. The Committee

had received $5.985 million in matching

funds for the 1988 primary election.

The final repayment consisted of:

o $54,253.13, the pro rata portion of

$169,805 in expenditures that exceeded

the New Hampshire and Iowa spending

lindts: 2/ and

o $49,302-in stale-dated committee checks

never cashed by the recipients.

Bush-Quayle ' 88

Under the terms of the final repayment

determination, the Bush-Quayle Committee

was ordered to repay $115,142 to the

Treasu~. The repayment represented $18,733 spent by the Committee in oonqualified campaign expenses; $95,909 in

excessive travel reimbursements received

from media fioms; and a $500 stale-<1ated

committee check. The Co~ttee had

received $46.1 million in public funds for

the 1988 general election.

The Committee was also orde~ed to

refund the following amounts paid by media

organizations for travel: $133,819 fo~

payments received in excess of the maximun

amount the Conmittee could charge, and

$61,558 for unused prepayments.

lFor the same reason, the Commission also

granted a 90-day repayment extension to the

Gephardt for President Committee, Inc., on

August 6.

2A ratio formula is used to calculate what

portion of the excessive expenditures

represented the payment of public funds as

opposed to private contributions. That

amount--the pro rata portion--is subject to

repayment.
6

luse the chart, opposite page, to find out which reports your committee must file.

2Reports sent by registered or certified mail must be postmarked by the mailing date.

Reports sent by other means must be received by the filing date. Note that the registe

certified mail date for the pre-general report is three days before the filing date.

Filing Date

OCtober 15

OCtober 20

October 22

November 20

December 3

December 20

January 31, 

Volume 18, Num

Reg./Cert. Mail Date~/

October 15

October 20

October 19

November 20

December 3

December 20

January 31, 1993

Late Filing

The Federal Election Campaign Act d

not peonit the Connnission to grant exte

sions of filing deadlines under any cir

stances. Failure to file on time could

result in enforcement action by the Fee

~ere to File Reports

Committees must file original repo

with the appropriate federal office and

simultaneously file copies of reports w

the appropriate state filing offices. 

CFR Parts 105 and 108. See the instruc

tions to FEe Forms. A list of state fi

offices is available from the FEe.

PACs and Individuals: 24-Hour Reports 

Last-Minute Independent Expenditures

PACs (including monthly filers) and

other persons planning to make independ

expenditures in connection with the

November 3 general election are reminde

the 24-hour reporting requirement: Any

person making independent expenditures

aggregating $1,000 or more in connectio

with the general election must report t

expenditures within 24 hours if they ar

made between October 15 and November 1.

The report must be filed with the appro

priate federal and state offices. For

further infor.mation, see 11 CFR 104.4 (

and (c), 104.5(g) and 109.2(bl.

machine. The fax numbers for the Clerk 

the House and secretary of the Senate a

o Clerk of the House: 202;225-7761

a Secretary of the Senate: 202/224-185

. Other statements and reports may no

however, be faxed due to the original

signature requirement.

Close of Books

September 30

September 30

October 14

OCtober 31

November 23

November 30

December 31

September 1992 FEDERALELECTION COMMISSION

REPORTS OOB IN <D£I'ItG fIDll'8S

To find out what reports your conmittee

must file from October through January,

refer to the chart on the opposite page.

'Ibe reporting dates appear in the tables

below. The FEe sends reporting notices and

forms to registered committees. {Note,

however, that the agency does not send

these materials to corporations and labor

organizations for partisan communication

reports.) For additional forms or information on reporting requirements, call the

FEe at 800/424-9530 or 202/376-3120.

Candidate camrl. ttees: 48-Hour Notices on

Last-Minute contributions

Authorized committees of candidates

rurming in the November 3 general election

must file special notices on contributions

of $1,000 or more received between October

15 and october 31. The notice is due

within 48 hours of the committee's receipt

of such a contribution. See 11 eFR

l04.5(f).

This requirement applies to all lastminute contributions of $1,000 or more:

o Contributions by check;

o In-kind contributions;

o Loans fram personal funds;

o Guarantees and endorsements of bank

loans; and

a Any of the above contributions made by

the candidate.

Forty-eight houe notices must be filed

with the appropriate federal and state

offices. Because 48-hour notices do not

have to be signed by the t~easurer, they

may be sent by mailgram, telegram or fax

Report!/

october Quarterly

October Monthly

Pre-General

November Monthly

Post-Gener:al

December Monthly

Year-End

REP()R"I'JN; Ili\TES, OC'IOOER 1992 - JANlIARY 1993
7

(Reports continued)

lReports and 48-hour notices are required even if the candidate is unopposed or if the

general is not held because the candidate received a majority of votes in the previous

election.

2campaiqns of House and Senate candidates who sought election in a previous year or who are

seeking election in a future year file on a semiannual basis in 1992. The next semdannual

report is the 1992 year-end report, due January 31, 1993; it will cover activity from July

through December 1992.

3These campaigns may file on either a monthly or quarterly basis. If they decide to change

their filing frequency during 1992, they should notify the Commission in writing.

4These reports, filed on FEe Forn. 7, are required if the organization's aggregate costs

exceed $2,000 for internal communications expressly advocating the election or defeat of a

clearly identified candidate. See 11 CFR 104.6 and page 44 of the 1992 Campaign Guide for

Corporations and Labor organizations.

()JarType of Filer terly Monthly Pre-General Post-General Year-End

Bouse and senate campaigns -I -/ r ./

of 1992 Candidates requi red if candidate runs in

election, even if unopposed~1

other House and senate I

campai<JIlS~/

1992 presidential campaigns .f I" I I

Witil Activity of $100,000 filed in lieu of November and

or Above December monthly reports if

candidate runs in election

1992 Presidential campaigns -/ I .f I

With Activity Less Than required only if candidate runs

$100,000 in election

:Previous Presidential .f or ~/ campaigns

PACs and party Coaai.ttees .f .f .f .f

Filing Monthly filed in lieu of November and

December monthly reports

PACs and Pa1"ty coomittees .f '" '" .f

1'il1ng ()1arterly required only if required

committee makes regardless

contributions or of activity

expenditures in

connection with

election during

pre-general

reporting period

corporataons and Labor I' -/ I

Organizations (Reports on

Partisan Coamunications).!1

FEDERAL ElECTION COMMISSION Volume 18, Number 9

Required RepOrts

September 1992

QJIDE TO REPOR'I'IN3, 0C'lmER 1992 - Jl\NUl\RY 1993
FEDERAL ELECTION COMMISSION

Florida Runoff, OCtober 1

Volume 18, Numb

NJR 1992-26: Free or Reduced-Rate camp

Ad Time Offered by Corpor

Broadcaster to candidates

Requested on behalf of EZ Communication

Inc. On August 13, 1992, the COlmli.ssio

failed to approve an advisory opinion b

the required four votes. See Agenda

Documents #92-107 and i92-107-A.

AD'lIseJ« OPINI~ RIQJESl'S

Recent requests for advisory opinio

(MRS) are listed below. The full text 

each AOR is available for review and com

ment in the FEC's Public Records Office

ALTERNl\TE DISPOSITlm OF MRs

.NJR 1992-34

Use by federal candidate/state governor 

state-provided car. (Requested by Cast

for Congress Fund; Date Made Public:

August 14, 1992; Length: 3 pages)

.Nm. 1992-13: Loans to Law Firm of Atto

Considering candidacy

Requested by James M. Blackbum. By le

dated July If 1992; this AOR was closed

without issuance of an opinion because 

incomplete facts.

POR 1992-30

Status of political organization as

national party committee. (Requested b

Natural Law Party of the uni ted states 

America; Date Made Public: August 5; 1

Length: 7 pages plus attachments)

1\DR 1992-31

Campaign donation to public housing res

dents council. (Requested by Michael A

Andrews for Congress Committee; Date Ma

Public: August 10, 1992; Length: 2 pa

.NJR 1992-32

Filing requirements of Vice Presidentia

candidate on independent ticket. (Requ

ed by LaRouche for President - Independ

for Economic Recovery; Date Made Public

August 10, 1992; Length: 3 pages)

1lOR 1992-33

Treatment of goods and services donated 

prohibited sources in connection with

shared federal and nonfederal activitie

(Requested by the Democratic and Republ

National Committees; Date Made Public:

August 14, 1992; Length: 3 pages)

a

+8

-1

-7

+8

+17

+6

+31

Gail'V'LOss

Since

12/31/91

759

344

144

56

Nt.mlber

of PACs

7/1/92

4,125

1,731

1,091

Reg./Cert. Filinq

Mailing Date.!/ Date!/

Close of

Books

FLORIM mmn' MTE CHAl«Z>

The date of the Florida ~unoff has

been changed from September 29 to

October 1. '1l1e pre-election reporting

dates that appeared in the January

issue have therefore been changed.

The revised dates are shown below.

sept. 11 sept. 16 Sept. 19

1Reports sent by registered or

certified mail must be postmarked by

the mailing date; otherwise, they must

be received by the filing date.

Total

September 1992

PAC category

MIDYFAR PAC WJNT

By July 1, 1992, the number of PACs

registered with the FEe had grown to 4,125,

an increase of 31 PACs since the count was

taken six months ago.

Please note, however, that the number

of PACS does not necessarily correlate with

financial activity. Many PACs have little

or no activity. For example, according to

their reports, 45 percent of all PACs did

not make any contributions to candidates

from January 1, 1991; through March 31,

1992 •.

For statistics on semiannual PAC counts

taken sinee 1975, order the press release

of July 23, 1992; call 800/424-9530 (ask

for Public Records) or 202;219-4140.

Corporate

Nonconnected

Trade/Membership/

Health

Labor

Corporations

Without stock

Cooperatives
September 1992 FEDERAL ELECTION COrvlMISSION Volume 18,Number9

,

ADVISORY OPINlOO SUMMMUES

NJ 1992-19: state campaign's Lease of

Canputers to candidate's

Federal Campai90

Mike Kreidler's state campaign committee

may lease two computers to his federal campaign committee (Mike Kreidler for Congress

Committee) without making a contribution to

the federal committee assuming the rental:

(1) reflects the usual and normal charge

and (2) conforms to standard business

practices.

These two factors have been the focus

of past advisory opinions on transactions

between a state committee and a federal

committee. If a state commdttee provides

goods or services at less than the usual

charge (i.e., at less than the current

market rate), it makes a contribution to

the federal committee--a possibly unlawful

contribution if state law permits the state

comIllittee to accept funds that would be

prohibited under federal law. 11 CFR

lOO.7(a)(1)(iii); hOs 1989-4, 1980-38 and

1978-67.

Mr. Kreidler's state committee account

contained primarily prohibited funds when

it purchased the computers, since it had

already transferred its permissible funds

to the federal co~ttee. The state

committee now rents the equipment to the

federal committee at $200 a month, although

the COmnUttee has determined that a fee of

$100 a month is reasonable given the prevailing rates in Olympia, Washington.

ASsuming that this rate reflects the

usual and normal charge,ll the rental will

not result in a contribution to Mr. Kreidlet's federal comnittee. This conclusion

is based on the further assumption that the

leasing agreement confooms to standard

business practices and includes standard

auxiliary charges (e.g., a security

deposit, if customary). See AD 1992-12.

The federal conunittee must itemize its

rental payments as operating expenditures.

The tax ramifications and the possible

application of washington State law to the

described activity are outside the Commission's jurisdiction.

(Date Issued; July 10. 1992; Length;

4 pages)

1The Commdssion expressed no opinion on the

validity of the fair market value determined by the committee.

9

1'0 1992-25; utah Convention as

separate Election

The Owens for Senate Committee, the

campaign committee of Congressman Wayne

owens, has a separate contribution limit

for the utah party convention because,

under state law, the convention has authority to select the nominee.

Federal campaign law defines "electionu

to include a general election, a primary

election and Ita convention or caucus of a

political party wich has the authority to

nominate a candidate." 2 U.S.C. §43l(1)(A)

and (B); 11 CFR 100.2(b), (e) and (e).

Past advisory opinions have looked to state

law to determine whether a convention or

caucus has authority to nominate. ADs 1986-

17, 1984-16 and 1978-30.

Under Utah law, the delegates at the

party convention vote for the u.s, Senate

nominee. The two highest vote getters then

face off in a primary. If, however, a

candidate receives 70 percent or more of

the convention votes, he or she becomes the

party's nominee, and the primary is not

held. Therefore, since 'the convention has

the authority to nominate a candidate I it

is considered an election, with a separate

contribution limit. see AOs 1986-21 and

1918-30, both addressing the utah 70-

percent rule.

Mr. Owens was one of the top two vote

getters at the June 13 convention (he ~eceived 69.7 percent of the delegates'

votes) and will be a candidate in the

September 8 primary. His committee therefore has separate contribution limits for

the convention and for the primary. Should

he win the primary, his conunittee will also

have a separate contribution limit for the

general election, thus enabling an individual to make three $1,000 contributions to

the eonunittee. The Commission, however,

reminded the committee that it must comply

wi th the rules on the application of the

contdbution limits, per election, and the

designation of contributions. See 11 eFR

110.1 and 110.2.

(Date Issued: July 10, 19921 Length:

2 pages)
September 1992 FEDERAL ELECTION COMMISSION Volume 18, Numb

BY STAFF: CDfi'RIBUTICN LUITTS

.I\ND REPORTI:N;

Sometimes committee staff, volunteers

and candidates use their personal funds or

credit cards to pay for committee expenses.

These payments are generally considered inkind contributions, subject to the contribution limits, even when the individual

expects to be reimbursed by the committee.l/ Littdted exceptions to this rule are

explained in this article.

NOTE: U.S. House and Senate employees

are reminded of 18 U.S.C. §603, which

prohibits contributions by a Congressional

employee to his or her employing Member.

General Rule

The general rule is that an in-kind

contribution results when an individual.

uses his or her personal funds or credit

card to pay for goods or services on behalf

of a political committee. 11 CFR 116.5(b).

(Limited exceptions to this general rule

apply only when individuals traveling on

behalf of a candidate or pclitical party

pay for their own travel and subsistence

expenses, as explained in the next

section. )

FOI example, an in-kind contribution . results when an individual pays for the

transportation or subsistence expenses of

others or pays for: nontravel expenses such

as meeting rooms, office supplies or c~

paign materials. 11 CPR lOO.7(a}(I}. In

these cases, the in-kind contribution

(combined with previous contributions made

by the same individual) may not exceed the

individual's contribution limit for the

conunittee.2/

Any reImbursements the committee makes

to the individual reduce the amount of the

contribution; when fUlly reimbursed, the

individual's advance no longer counts as a

contribution.

IThis article does not apply to payments

made by individuals acting as commercial

vendors. See 11 CFR 116.3 and 116.4.

2Contributions from the personal funds of

House and Senate candidates to their own

campaigns are not subject to the contribution ~imits. 11 CFR lI0.10(a). Publicly

funded presidential candidates, by contrast, are subject to a $50,000 limit on

campaign spending from personal funds. 11

eFR 9003.2(c) and 9035.2.

10

Exception: UnreiJDbursed Travel and

SUbsistence

The exceptions described below apply

only to an individual's payments for his 

her own travel or subsistence.

Individual's Travel. An individual m

spend up to $1,000 per election for his o

her own travel on behalf of a candidate 

$2,000 per year for his or her own tcave

on behalf of a party commi.ttee without

making a contribution. 11 eFR 100.7(b)(B

Payments that exceed these limits are consid~red in-kind contributions--unless

they ace reimbursed by the committee with

certain time periods (see below).

This travel exemption applies to paid

campaign workers, volunteers and the

candidate.

Volmteer'.s Subsistence. A second

exception applies only to volunteers. Th

may spend unlimited amounts for their ow

meals and lodging when these expenses are

incidental to volunteer activity. The

payments are not considered contribution

11 CFR 100.7(b)(S).

Exception: Reimtursed Travel and

SUbsistence

If an individual pays for his or her

own transportation and subsistence expen

(using personal funds or a credit card)

while traveling on behalf of a candidate 

party committee--and the expenses are no

covered under the above exceptions-the

payments are not considered in-kind

contributions if the committee reimburse

the individual within cectain time period

o In the case of a credit card payment,

within 60 days of the closing date on t

billing statement where the charges fir

appear.

o In all other cases, within 30 days afte

the expenses are incurred. 11 eFR

116.S(b) .

If full reimbursement is not made

within these time limits, the unpaid amo

becomes an in-kind contribution and may

have to be reported as both a contributio

and a debt, as explained below.

Reporting Mvances and Reimbursements3/

The term "advance" is used in this

article to mean an individual's payment f

a commit tee expense when the payment

results in an in-kind contribution which

the committee intends to reimburse.

3The ceportin9 information in this articl

is based on Advisory Opinion 1992-1.
FEDERAL ELECTION COMMISSION

Volume 18, Number 9

(continued)

FEe v, ELtJREOOE FOR aN:iRESS CDIMI'1'TEE

on July 7, 1992, the u.s. District

Court for the District of New Hampshire,

based on a stipulation submitted by the

parties, ruled that the Eldredge for

Congress Committee and Faith D. Eldredge,

as treasurer, violated the Federal Election

Campaign Act by failing to file a timely

1984 quarterly report. As agreed by the

parties, the court ordered defendants to

pay a $500 civil penalty and permanently

enjoined them from future violations of the

reporting laws. (Civil Action No.

CBS-655-D. )

Background

According to the findings of fact in

this case, International Fundin9 Institute

(IF!), through Robert E. Dolan, its sale

stockholder and director, subscribed to an

on-line data base service provided by

Legi-Tech, Inc. (an ami CDS curiae in this

action) . The data base contained information on individual contributors compiled

from FEC repotts. IF! developed the

contributor data into a mailing list, which

it marketed through a broker. The broker,

in turn, rented the list to about five

customers, including American Citizens for

Political Action, Inc. (ACPA), a political

committee. (Mr. Dolan is also chairman and

treasurer of ACPA.) ACPA used the list for

several mailings, each soliciting about

5,000 individuals.

In an internal enforcement matter, the

FEe found probable cause to believe that

1FI, ACPA and Mr. Dolan, as ACPA treasurer,

knowingly and willfully violated section

438(a)(4). Unable to reach a conciliation

agreement with respondents, the agency

filed suit against them in the u.s. District Court for the District of Columbia.

(Civil Action No. 90-1623.)

FEe v ; INTEBNATICNl\L FUNDDl3 INSTI'l'OTE

On July 10, 1992, the u.s. Court of

Appeals for the District of Columbia

Circuit, sitting en bane, upheld the

constitutionality of 2 U.S.C. §43B(a)(4).

(Civil Action No. 91-5013.) That provision

of the Federal Election Campaign Act (the

Act) prohibits anyone from using, for

solicitation or comroetcial purposes, the

information on individual contributors

listed in political c~ttee reports filed

with the FEC.

11

iilhen Advance Becomes a Reportable Debt.

In addition to any reporting that may be

required under the above paragraphs, the

committee must itemize an advance as a debt

on Schedule D if:

o Full reimbursement was not made wi thin

the same reporting perrod, and 60 days

have elapsed since the advance was made:

oc"

o The advance exceeded $500 and was not

reimbursed within the same reporting

period. See 11 CPR l04.11(b).

Full Reimbursement Not Made Within same

Reporting' Period. When an advance (combined with other contributions made during

the calendar year) exceeds $200 and remains

unreimbursed at the end of the reporting

period, the committee must itemize the

advance as a memo entry on a Schedule A

used for "Contributions from Individuals."

(As a memo entry, the amount is not

included in the total figure.) The entry

should specify the amount as an advance.

Unlike other in-kind contributions,

advances are not simultaneously itemi~ed as

operating expenditures on Schedule B. once

the committee reimburses the individual,

however, it must itemize the reimbursement

as an operating expenditure on Schedule B.

The "purpose of disbursement" box should

specify the amount as a reimbursement and

should indicate the nature of the advance

(e.g., "reimbursement for postage").

Additionally, the entry should be cross

referenced to the corresponding memo entry

on Schedule A, noting the particular report·

where the mewo entry appeared.

If the individual's unreimbursed

advance and other contributions do not

exceed $200, the advance does not have to

be itemized and, in fact, is not reportable

as a contribution. (The unreimbursed

amount, however, may have to be reported as

a debt; see below.) The ceimbursement,

when made, is reportable as an operating

expenditure ,

September 1992

Full JleilltJursement Made Within same

Reporting Period. If the committee

reimburses an advance, in full, within the

same reporting period in which the advance

was made, the advance is not reportabl.e , (Nevertheless, the advance-combined with

other contributions made by the individual-may not exceed the contribution

limdts.) The reimbursement of the advance

is repor-table as an operating expendi ture

and subject to the itemization rules at

11 CFR l04.3(b)(3){i} and (4)(i).
September 1992 FEDERAL ELECTION COMMISSION

Defendants asked the district court to

dismiss the case, arguing that §438(a)(4)

violated the rirst Amendment of the Constitution, both on its face and as applied to

their conduct. The FEC moved to certify

the constitutional question to the court of

appeals. The district court granted the

FEC's motion.

Court of ~s Opinion

Level of SCrutiny. The court first

examined what level of scrutiny it should

apply to determine whether the use restriction of §438(a)(4) was constitutional.

Noting some apparent conflicts in levels of

scrutiny applied by the supreme Court in

similar cases, the court to assumed "-but did

not decide-that §43S(a)(4) was subject to

intermediate scrutiny.

Quoting Seattle Times Co. v. Rhinehart,

467 u.s. 20, 32 (1984), the court explained

the Supreme Court's criteria for inte~diate scrutiny: it "require[ 51 only that the

restriction further 'an important or substantial governmental interest unrelated to

the suppression of expression' and [that

it) be 'no greater than is necessary or

essential to the protection of the particular governmental interest involved.'"

Governmental Interest. The FEe argued,

inter alia, that §438(a)(4) was narrowly

tailored to further an important governmental interest, that of protecting the

value of a political corrmittee's

contributor list. The FEe further argued

that this protection, in turn, preserves

political discourse.

The court agreed: 'IWithout the use

restriction of i438(a)(4), innumerable

entcepreneurs would, like the defendants

here, be able freely to appropriate to

themselves part of the value of the

contributor lists compiled by reporting

political commit tees. As a result, such

commdttees would have less incentive to

compile the lists in the first place. In

other words, if the return on their investment in solicitation would be reduced by

others using the resulting lists, political

commdttees would not find it worthwhile to

solicit as much as they now doi they would

raise less money, spend less money, and

correspondingly underwrite less political

discourse •••• [T]he use restriction protects

political discourse from the adverse effect

that the disclosure requirement of the Act

would otherwise have."

(The FEe also argued, based on legislative history, that §438(a)(4) furthers the

governmental interest in- protecting

contributors from unwanted solicitations,

12

Volume 18, Num

but the court did not find it necessary 

reach that argument.)

Defendants claimed that a politica

committee has no property rights in its

contributor list because a list of nam

and addresses is not sufficiently orig

to warrant copyright protection. The

court, however, observed that "Congres

recognize an intellectual property int

est, narrower than copyright, that is n

subject to the constitutional requirem

of originality."

The court rejected defendants alter

tive argument that S438{a)(4) is incon

tent with the First Amendment because 

creates "a property interest in the po

cal sympathies of another." Instead, 

court said, the use provision "narrowly

protects the value of the list itself 

particular use; it does not prevent on

from soliciting a person who is on a

committee' 5 contributor list, so long a

one does not obtain that person's narne

(directly or indirectly) from a list fi

with the FEe."

Conclusion. The court held that, u

an intermediate level of scrutiny, sec

438(a)(4) is constitutional as applied 

the defendants' conduct because it "ad

vances an important governmental intere

(prese~ing the value of a political

committee' 5 contributor list) and "i.s n

broader than is necessary to that task

The court rejected defendants' seco

claim, that §438(a)(4) was unconstituti

on its face. Quoting Members of the C

oouncil of Los Angeles v. Taxeayers fo

vincent, 466 u.s. 789, 798 (1984), the

court said that a facial challenge can

succeed "only if the statute may 'neve

applied in a valid manner' or is 'writt

so broadly that [itl may inhibit the

constitutionally protected speech of th

parties. r " The defendants, the court 

failed to make such an argument.

The court remanded the case to the

district court for proceedings consiste

with its holding but, in cesponse to an

unopposed motion by defendants, stayed. 

mandate through October 9, 1992. Defe

ants plan to seek the Supreme Court rev

of the court of appeals decision, and

october 8 is the deadline for filing th

petition.
september 1992 FEDERAL ELECTION COMMISSION

FEDERAL RmISTER mI'ICES

Copies 9f Federal Register notices

are available from the Public Records

Office.

1992-11

11 CFR Parts 109, 110 and 114:

Independent Expenditures, Corporate

and Labor Organization Expenditures;

Notice of Proposed Rulemaking (57 FR

33548, July 29, 1992)

1992-12

11 en Part 200: Administrative Regulations (Rulemaking petitions); Final

Rule (57 FR 34508, August 5, 1992)

1992-13

11 CFR part 110: Transfers of Funds

from State to Federal Campaigns; Final

Rule; Transmittal to Congress (57 FR

36344, August 12, 1992)

1992-14

11 eFR Part 110: Transfers of Funds

Between Federal Campaign Committees;

Notice of Proposed Rulemaking (57 FR

36023, August 12, 1992)

FEe PUBLISHES NalFILKRS

The Commission recently cited the co~

mittees of the candidates listed below for

failing to file reports. The names of

authorized committees that fail to file

reports are published pursuant to 2 U.S.C.

§438(a)(7). Enforcement actions against

nonfilers are pursued on a case-by-case

basis.

Office Report Not

candidate Sought Filed

Martin senate-FL 2nd Quarter

Lally House-NY/27 2nd Quarter

Albert House-GAjlO pre-Runoff

Brown House-GIV06 Pre-Runoff

Lovett House-GAjll Pre-Runoff

pratt House-GlVll Pre-Runoff

Whitaker House-G/V09 Pre-Runoff

13

Volume 18, Number 9

MURS RELEASED ro mE PUBLIC

Listed below are MURs (FSC enforcement

cases) recently released for public review.

The list is based on the FEe press releases

of July 15, 23 and 24, 1992. Files on

closed MURs are available for review in the

Public Records Office.

unless otherwise noted, civil penalties

resulted from conciliation agreements

reached between the respondents and the

Commission.

MUR 2804 1/

Respondent: American Israel Public Affairs

committee (IX:)

complainants: Paul Findley, James E.

Akins, George Ball, Richat=d CUrtiss, Robert

Hanks, Andrew 1. Killgore, Orin Parker

SUbject: (l) Corporate contributions;

(2) failure to register and report

Disposition: (1) probable cause to believe

but took no further action; (2) no probable

cause to believe

MOR.2934

Respondents: (a) Nevada state Republican

Central committee, Bob Beers, treasurer;

(b) Boomtown, Inc., Robert A. Cashell (NV)

Complainant: FEe initiated

SUbject: Excessive contdbutions and

coordinated party expenditures

Disposition: (a) and (b) Reason to believe

but took no further action

MUR 3177

Respondents; (a) National Libet"tarian

Committee, William Redpath, treasurer (DC);

(b) The Invisible Hand Foundation, successor to LPWS Convention Services Group (WA);

et al. (c)-( 1)

complainant: Alan Lindsay (TX)

Subject: Failure to register and report;

corporate contributions

Disposition: (a) and (b) Reason to believe

but took no further action; (c)-(1) no

reason to believe

.MUR 3239

Respondents (all in VA): (a) Smith for

Congress, Alsen H. smith, treasurer;

(b) Moran for Congress cclmlittee, Suzanne

Paciulli Conrad, treasurer; (c) Comfort

Inn-NOrth and Jayanti K. Patel, as owner

camplainant: John White (VA)

SUbject: corporate contributions

Disposition: (a)-(c) Took no action

(continued)

fA portion of this MUR, involVing 31 groups

and individuals, was closed and released to

the public on December 21, 1990.
September 1992 FEDERAL ELECTION COMMISSION

llIJR 3242

Be&pOl1dents (both in NY): (a) Kevin P.

Gaughan for Congress Committee; William F.

Mathews; (b) Frank J. McGuire ~ainant: Charles Leonard, National

Republican Congressional Commdttee (DC)

SUbject: Excessive contribution

Di$position: (a) $1,800 civil penalty;

(b) $1,600 civil penalty

MDR 3271

Respondents: McConnell Senate Committee

'96. Larry Steinberg, treasurer (KY)

Complainant: FEC initiated

Subject: Excessive contributions

Disposition: Reason to believe but took no

further action

JIIlUR 3312

Respondents: Dan Daly for U.s. Senate,

Dorothy Q. Daly, treasurer (MA)

complainant: Philip s. Pepe, Jr. (NY)

SUbject: Failure to disclose disputed

debt

Disposition: Probable cause to believe but

took no further action

MUR 3371

Respondents (both in VA): (a) Americans

United Commdttee, Ruth Stormant, treasurer;

(b) Thomas DeWeese

Complainant: FEe initiated

SUbject: EKcessive contribution

Disposition: (a) and (b) Reason to believe

but took no further action

JiIUR 3384

Bespondents (all in CA): (a) Congressman

Anthony C. Beilenson; (b) Beilenson Campaign Commi ttee, Julius Glazer, treasurer;

( c) Los Angeles Times

complainant: Paul Morgan Fredrix; Salomon

fOl" Congress (CA)

SUbject: Mailing to contributors

DiSpoSition: (a l-Lo) No reason to believe

MUR 3421

Respondents: (a) National Republican

senatorial Committee, James L. Hagen,

treasurer {DC}; (b) U.S. Senator John

Seymour Commdttee, F. Laurence Scott,

treasurer (CA)

Complainant: Congressman William E.

oannemeyer (CA)

SUbject: In1proper coordinated party

expenditures

Disposition: (a) and (b) No reason to

believe

14

Volume 18, Num

fIIJR 3435;3426

Respondents (all in PA): (a) Richard 

Thornburgh; (b) Thornbuf9h for Senate

Committee, Raymond F. Dimuzio, treasu

(c) Kirkpatrick & Lockhart

COOplainant: Michael Waldman, Public

Citizen's congress watch (DC); Bob Ba

De1llOcratic Party of Pennsylvania

Subject: Prohibited contributions

Disposition: (a)-(c) No reason to be

I«JR 3441

Respondents: New Jersey Democratic S

Commdttee, Raymond J. Lesniak, treasu

Callplainant: FEe initiated

SUbject: Reporting errors; impermiss

funds

Disposition: Reason to believe but to

further action

MUR 3447/3229/3180

Respondents: (a) Dan Coats for India

AKA Dan Coats fo~ Senate committee, D

P. Long, treasut'er-; (b) Dan Coats for

Congress Committee, Jeffrey L. Turner

treasurer (IN)

COIlplainant: Baron Hill (IN); FEe

initiated

SUbject: Excessive contributions1 fa

to accurately disclose contributions

Di&position: (a) $9,000 civil penalt

(b) no reason to believe

MUR 3532

Respondents: Bush-Quayle '92 primary 

mittee, J. Stanley Huckaby. treasurer 

Cauplainant: Joseph T. West (CA)

SUbject: Broadcasting subliminal ima

Dispositioo: No reason to believe
FEDERAL ELECTION COMMISSION

, .

September 1992

The first number in each

cftation refers to the "number"

(month) of the 1992 Record

issue in which the article

appeared; the second number,

following the colon, indicates

the page number in that issue.

ADYISOOY OPnm:ws

1991-29: Contributions received

and made by corporation's

employee pledge program, 1: 4

1991-32: Charges for consultant's fundraising servic@s,

5:6

1991-33: Allocation of expenses

when party co~ttee admdnisters pdmary election; 1:6

1991-34: Coamcittee sale of

access to voter data base as

ongoing venture, 1:6

1991-35: Application of allocation rules when SSF'S nenfederal account pays its own

adndnistrative expenses, 2:10

1991-36; Corporation's payment

of employee's travel expenses

for party fundraise" 3;5

1991-37: Nonconnected PAC's

payment to incorporated finn

for shared facilities and

services contributed to cammittees, 3;5

1991-38: Repayment of embezzled

funds to candidate cemmuttee,

3:6

1991-39: Contributions suspected of being made in rwnes

of others, 4;9

1992-1: campaign salary paid to

candidate; reimbursements for

campaign expenses, 4:9

1992-2: Party reallocation of

staff salaries as fundraising

expenses, 4:10

1992-3: Corporate payment of

benefits for ell'P1oyeej candidate on unpaid leave, 5: 8

1992-4: campaign'S payment of

candidate's living expenses

and spouse's salary, 4:10

1992-5: Candidate's appearance

in cable public affairs

programs, 5:8 1992~6: Honorarium paid to candidate for speech on campaign

issues, 4:11

1992-7: Corporate PAC'S solicitation of franchise personnel, 6:4

1992-8; Tax seminars as fundraising mechanism, 5;8

1992-9: Cooperative's twiceyearly solicitation through

raffle at annual meeting, 6: 5

1992-10: Committee's disbursement to nonprofit voter

organization, 6:5

1992-11: Computer-generated

summary page and detailed

SUlI1Il\ary page I 6 : 6

1992-12; Candidate's future

ownership of campaign van,

7:7

1992-14: candidate's designation of excess campaign funds

in event of his death, 7:7

1992-15: ~tension of time for

redesignations of general

election contributions when

candidate loses primary, 8;6

1992-16: Nonfederal contributions made by U.S. subsidiary

of foreign corporation, 8:7

1992-17: Affiliation of partnership PAC with SSE's of the

corporate partners, 8:8

1992-19: State campaign'S lease

of computers to candidate's

federal campaign, 9;9

1992-21: Excess campaign funds

of 1994 candidate donated to

S170(c) charity, 8:9

1992-25: utah convention as separate election, 9:9

COORT CMES

FlOC v.

---=--AFsCME=Po, 1:7

- America's PAC, 7:10 - Black political Action

CO!llllIit tee, 8: 13

- CaUlder, 8:13 - Eldredge for Congress

cODUlli ttee, 9:11 - International Funding

Institute, 9:11 - lCopko, 8:11

- National Republican Senatorial Committee (91-5176),

B:11 - NP.A Political Victory Fund,

1:7 - ~ist party (92-0e74),

:9 - Schaefer, rriends of, 6:6

- wright, 7;8

v , rEC

--=-Akins, 1:8, 3:7; 8:11 - aranstool, 3: 8 - B~ v. Fee, 8;13 - Common cause (91-2914), 1:9 - Common Cause (92-0249), 3:8 - Freedom Republicans, Inc.,

3:7; 6:7

- LaRoUche, 4: 8

- National Rifle Association

of America (NRA) (89-3011),

4:8 - SchaeferI 6:6

15

Volume 18, Number 9

- Spannaus; 5:6

- Trinsey, 3:7 - White, 7:9

REPOR'l'IN3

Pre-primary, pee-runoff reporting dates - AK date changed, 7:16 - FL date changed, 9:8 - House and Senate, 1:14 - OH, SC dates changed, 5:9 - Presidential, 2:10; 3:10

Schedule for 1992, 1:10; 3:8~

6:2; 9:6

Waivers, July 15 quarterly,

7:16

SPJ!N)~ Lnn:'l'S :FUR 1992

Coordinated party, 3:1

Presidential, 3:14

800-LINE ARTICLES

Advances by staff: contribution limits and reporting,

9;10

Compliance wi th laws outside

FEC's jurisdiction, 3:12

Contributions: receipt and

deposit, 6:10

Debt settlement plans: postponing payment to creditors,

8:10

Last-minute contributions; 48-

hour notices required, 1:18

Names of corporate and labor

PACs, 6:10

Registration by candidates and

their committees, 2;12
FEDERALELECTION COMMISSION

Volume 18, Num

Bulk Ra1e Mail

Postageand Fees Paid

Federal Election Commissio

PermitNumber G-31

REPOR'I'llG SCB:EroLE

OC'.OCBER. '.IBRClm J1IfilIM.y

see page6 ~7

IRS PlUm IUmERS CIWQ:D

The March 1992 article "Compliance 

Laws OUtside FEe's Jurisdictionll listed

telephone numbers for Jack Reilly and D

Jones of the IRS Exempt Organizations T

nical Division. Their telephone number

recently changed. The new numbers are:

Jack Reilly, 202/622-7352; Dave Jones,

202/622-8095.

xr, Reilly and Mr. Jones provide

information on the federal tax obligati

of political organizations.

FEDERAL ELECTION COMMISSION

999 E Street, NW

Washington, DC 20463

September 1992

Official Business

8120-9/4 The Am&rican Council of Young

Political Leaders

Japan

Commdssioner Trevor Potter

9;22 The D.C. Bar/G.W.U. National Law

Center Continuing Legal Education Program

Washington, DC

Commdssioner Trevor Potter

Susan Propper, Office of General

Counsel

9;22-25 Council on Governmental Ethics

Laws, 1992 Annual Conference

Toronto, Ckltacio

Chairman Jocm Aikens

John Surina, Staff Director

Lawrence Noble, General Counsel

Kim Bright-Coleman, Office of

General Counsel

Lois Lerner, Office of General

Counsel

Kent cooper, Public Disclosure

9124 Intelx Educational Foundation

Washington, DC

Michael Dickerson, Public

Disclosure

9/8 American University

washington, DC

Ian stirtoo. Information Services

Michael Dickerson, Public

Disclosure