Volume 13, Numbe

7 INDEX

TABLE OF CONTENTS

CLEARINGROUSE

7 Accessibility of Polling Places

\ 

COURT CASES

6 FEe v. Sailors' Union of the

Pacific Fund

PUBLIC FUNDING

5 Hart Not Eligible for Public Funds

5 ADVISORY OPINIONS

SPECIAL ELECTIONS

4 Tennessee

REGULATIONS

I Delegates and Delegate Committees

4 Freedom of Information Act

STAFF

New General Counsel

contin

REVISED REGULATIONS ON

DELEGATES AND DELEGATE COMMITTEES

On September 17, 1987, the Commission 

to Congress its revised regulations, at 1I C

110.14, setting forth the Act's prohibitions, l

tations and reporting requirements as they a

to the process of selecting delegates to the Pr

dential nominating conventions. The revisions 

designed to clarify which provisions apply to 

dividual delegates and which apply to dele

committees. The revised rules also provide 

teria for determining affiliation between dele

committees and Presidential campaign com

tees. These regulations, along with an expl

tion and justification, were published in 

September 22, 1987 issue of the Federal Regi

See 52 Fed. Reg. 35530. .

After these amended rules have been be

Congress for 30 legislative days, the Commis

will announce their effective date.

999 E Street NW Washington DC 20463

FEDERAL ELECTION COMMISSION

November 1987

----_._-------- *Mr. Steele's resignation as General Counsel

was reported in the March 1987 issue of the

Record, p.t,

FEe NAMES NEW GENERAL COUNSEL

On October 6, 1987, the Federal Election

Commission appointed Lawrence M. Noble as the

agency's General Counsel. Mr. Noble had been

Acting General Counsel since the resignation of

Charles N. Steele earlier this year.*

Mr. Noble, who has been with the agency

since 1977, served as FEC Deputy General

Counsel from November 1983 until his appointment as Acting General Counsel. Prior to that,

he was Assistant General Counsel for Litigation

and, earlier, a litigation attorney. Before joining

the FEC, he was an attorney with the Aviation

Consumers Action Project.

A native of New York, Mr. Noble holds a

Bachelor of Arts in Political Science from

Syracuse University and a Juris Doctor from the

National Law Center at George Washington

University. He is a member of ·the u.s. Supreme

Court Bar, the U.S. Court of Appeals Bar for the

D.C. Circuit, the U.S. District Court Bar for the

District of Columbia and the District of Columbia

Bar. Mr. Noble is also a member of the American

and District of Columbia Bar Associations.
2

The Record is published by the Federal Election Commission, 999 E Street, N.W., Washington,

D.C. 20463. Commissioners are: Scott E. Thomas, Chairman; Thomas J. Josefiak, Vice Chairman;

Joan Aikens; Lee Ann Elliott; Danny Lee McDonald; John Warren McGarry; Walter J. SteVfart,

Secretary of the Senate, Ex Officio; Donnald K. Anderson, Clerk of the House of Representatlv.es, 

Ex Officio. For more information, call 202/376-3120 or toll-free 800/424-9530. (TDD For Hearmg

Impaired 202/376-3136)

\blume 13. Numrnr 

DUal-Purpose Expenditures by Delegates

political committees do not apply to contributio

to delegates. However~ontributions which 

individual makes to a delegate are SUbject to th

individual's $25,000 annual limit on contributio

Similarly, section 110.14(e) of the revis

rules retains the current provision (IIO.14(

under which expenditures by a delegate to p

mote his or her selection only are neither limi

nor reportable. Moreover, such disbursements a

not considered expenditures by Presidential can

dates and do not count against the spending lim

of publicly funded candidates, regardless 

whether the delegate is com mitted or pledged 

a partieular candidate.

No Public Political Advertising. Under a 

organization of the delegate regulations, secti

110.14(f) now governs "dual purpose" expenditu

by a delegate--expenditures which advocate t

delegate's selection and which also refer to 

candidate for public office (such as a President

candidate).

These disbursements are not subject to co

tribution limits (110.1) or spending limits 

Presidential candidates (110.8) provided that:

o The materials are used in connection with v

unteer activity; and

o The expenditures are not made for gene

public communications or political advertising

This provision is based on the "coattail" exern

tion from the definition of contribution in 

U.S.C. §43l(8)(B)(xi).

Public Political Advertising. Section 110.

(f)(2) concerns "dual purpose" expenditures 

delegates for general public political advertis

(e.g., broadcasting, newspapers, magazines, b

boards and direct mail), Only slightly revised (

former regulation at 1l0.14(d)(2)(ii»t the regu

tion applies the standards under 2 U.S.C. S43l

and (17) to determine whether such expenditu

by individual delegates are in-kind contributio

or independent expenditures on behalf of t

candidates mentioned in the communications. 

in-kind contributions, the expenditures would 

subject to the contribution limits of 110.1 and t

Presidential candidate's spending limits und

1I0.B. Such in-kind contributions would be 

ported by the recipient candidate's committ

On the other hand, those expenditures wh

qualified as independent expenditures would n

be SUbject to limitations but would be reported 

Novemoor 1987 FEDERAL ELECTION COMMISSION

continued from p. 1

Funds Received and Expended

All funds received or spent for delegate

selection activities are contributions or expenditures made for the purpose of influencing a

federal election (see 11 CPR 100.2(c)(3) and (el)

with these two exceptions:

o Ballot access fees paid by a delegate to a state

or subordinate party committee are not contributions or expenditures; and

o Any administrative expenses incurred by a state

or subordinate party committee in connection

with its sponsorship of a convention or caucus

to select delegates to a nominating convention

are also exempt from the definitions of contribution and expenditure.

Note, however, that all funds received or

spent for any type of delegate selection activity,

inclUding ballot access fees and administrative

expenses, must be from sources which are permissible under the Act.

Contributions to and Expenditures by Delegates

Delegates are not considered "candidates"

under the election law because they are not

seeking nomination or election to federal office.

(See 2 U.S.C. §43l(2) and 11 CFR 100.3(a)(1).)

ThUS, section 110.14(d) of the revised rules retains

the current provision (IIO.14(c» under which the

contribution limits which apply to candidates and

Definitions

Under 1l0.14(b)(l), "delegate" means an individual who becomes or seeks to become a delegate to a national nominating convention or to a

state, district or local convention, caucus or primary held to select delegates to a national nominating convention. This definition is unchanged in

the revised regulations. The definition of "delegate committee'! in 1l0.14(b)(2), however, has

been revised to clarify that a delegate committee

may not necessarily be a political committee

under the Act (see 11 CPR 100.5). Only delegate

committees which qualify as political committees

under 11 CF R 100.5 are required to register with

the Commission and file reports of receipts and

disbursements.
Novemoor 1987 FEDERAL ELECTION COMMISSION Volume 13, Numrn

the delegate under 11 CFR Part 109. Note that, in

either case, only the portion of the expenditure

allocable to the candidate would be treated as an

in-kind contribution or an independent expenditure.

Candidate Materials. Section 110.14(f)(3),

concerning delegate expenditures for disseminating, distributing and republishing a eandidate's

campaign materials, clarifies that such expenditures are in-kind contributions subject to the

contribution limits and reportable by the Federal

candidate whose material is used. The expenditures would count against a Presidential candidate's spending limits only if the expenditures

were made with the cooperation or prior consent

of, or in consultation with or at the request or

suggestion of, the candidate or the candidate's

campaign committee.

Contributions to Delegate Committee

Under 110.14 (g), contributions received by a

delegate committee from a Presidential candidate's campaign committee would -count against

the candidate's spending limits under 11 CFR

110.8. The contribution limits apply to all contributions made to and received by delegate committees. Registered delegate committees must

report such transactions.

Expenditures by Delegate Committee

Under the revised section 110.14(h), delegate

committee expenditures which advocate only the

selection of one or more delegates are not contributions to any candidate, and are not SUbject to

the 110.1 contribution limits. Similarly, they are

not chargeable to the expenditure limitations of

any Presidential candidate under 110.8(a). Delegate committees which have qualified as political

committees must, however, report these expenditures in accordance with 11 CFR Part 104.

A new § 110.140) has been added to the

regulations concerning "dual purpose" expenditures made by delegate committees. The provision parallels llO.14(f), concerning "dual purpose"

expenditures by individual delegates (see above).

Under these revised rules, "dual purpose" expenditures by delegate committees -are not

treated as contributions to federal candidates

when certain types of campaign materials are

used in connection with volunteer activity and

public political advertising is not used. 11 CFR

110.14(i)(1). Note, however, that registered delegate committees must report such expenditures

(although individual delegates need not do so).

By contrast, under 11O.14(i)(2), "dual purpose"

expenditures by delegate committees for general

public communications and political advertising

are considered either independent expenditures;

or contributions in kind, which may count against

Presidential spending limits. The provision

follows 110.14(f}(2), summarized above. In alloca3

ting "dual purpose" expenditures under this 

tion, delegate committees should follow the g

eral principles in 11 CFR Part 106, attributin

each delegate or candidate an amount reflec

the benefit reasonably expected to be der

from the expenditure. 11 CFR 106.1(a).

Under 110.14(i)(3), a delegate committ

expenditure to disseminate, distribute or repub

a candidate's campaign materials constitutes 

in-kind contribution to the candidate.

Affiliation of Delegate Committee with

Presidential Candidate's Authorized Committe

The Commission added a new section, 11

(j), to provide guidance concerning when a d

gate committee is considered affiliated with 

authorized com mittee of a Presidential can

date. Under 110.14(j)(1), the two commit

would be affiliated if they were establis

maintained, financed or controlled by the s

person (e.g., the Presidential candidate) or 

same group of persons.

Section 110.14{j)(2) states that the Com

sion may consider a number of factors in de

mining whether a delegate committee is affili

with an authorized Presidential committee u

§1l0.14{j)(I). The Commission will consi

among other factors, whether or not:

o The Presidential candidate or another pe

associated with the authorized Preside

com mittee played a significant role in the d

gate committee's formation;

o Any delegate associated with a delegate c

mittee has been or is a staff member of 

authorized Presidential committee;

o The committees have common or overlap

officers or employees;

o The authorized Presidential committee prov

goods or funds in a significant amount or o

ongoing basis to the delegate committee, o

than through the transfer to a committee o

allocated share of joint fundraising proc

(pursuant to 11 CFR 102.17 or 9034.8);

o The Presidential candidate or any person a

ciated with the authorized Presidential c

mittee suggests, recommends or arranges 

contributions to be made to the delegate c

mittee;

o The committees receive contributions from 

same sources;

o One committee provides a mailing list to 

other committee;

o The authorized Presidential committee o

person associated with it provides ongoing 

ministrative support to the delegate com

tee;

o The authorized Presidential committee o

person associated with it directs or organ

the campaign activities of the delegate c

mittee; and

contin
NovemOOr' 1987 FEDERAL ELECTION COMMISSION \blume 13, NumOO

o The authorized Presidential committee or a

person associated with it files statements or

reports on behalf of the delegate committee.

Affiliation Between Delegate Committees

Under a. new provision, 1l0.14(k), delegate

committees will be considered affiliated with

each other if they meet the criteria for affiliation

set forth in section 100.5(g) of the regulations.

FINAL REVISIONS TO FOIA RULES

On October 1, 1987, the Commission approved final revisions to its regulations implementing

the Freedom of Information Act (ForA). The

final rules, with the one exception noted below,

are identical to the interim rules, which became

effective on June 24, 1987.*

The Com mission revised its rules to conform

with the Freedom of Information Reform Act of

1986, which expanded the law enforcement exemptions of the ForA, modified the fees charged

for material requested under the FOIA and

amended the standards for waiving fees. Revised

regulations at 11 CFR 4.5(a)(7) and 4.9(c) reflect

these changes. The Commission also updated

certain fees charged for public disclosure documents obtained through the FEC Public Records

Office (II CFR 5.6). For a more detailed summary of the revised regulations, see the August

1987 Record, pp. 5-6.

The final rules add language concerning the

billing of special mail services. If a person wishes

information to be sent through a special service,

such as express mail, the requester must make all

arrangements for pickup and billing directly with

the company providing the delivery service.

(Charges for ordinary packaging and mailing are

absorbed by the Cornrnission.)

The Commission received three sets of public

comments on the interim rules. These comments

are discussed in the Statement of Basis and

Purpose, which was published along with the final

rules in the Federal Register on October 21, 1987.

The final rules will become effective 30 days

after the publication date.

*The interim rules became effective upon

their publication in the Federal Register (52 Fed.

Reg. 23636).

4

TENNESSEE SPECIAL ELECTIONS: REPORTS

BY PACS, PARTIES AND CANDIDATES

During December and January, Tenne

will hold special elections in its 5th Congressi

District to fill the seat vacated 1:>Y Representa

William H. Boner. A special primary election 

be held on December 3, 1987, and a spe

general election, on January 19, 1988.

All political committees which support ca

dates in the special election(s) (and which do 

report on a monthly basis) must file the appro

ate pre- and post-election reports•. This requ

ment applies to PACs, party committees 

authorized candidate committees. The repor

schedule will depend on whether the suppo

candidate participates only in the special prim

election or in both the special primary and 

special general election. (See below.)

Committees supporting candidates in 

special primary election must file a pre-prim

and 1987 year-end report. (See chart I below.)

Committees supporting candidates in 

special general election must file reports disc

ing special general election and year-end activ

Since the year-end report would cover only 

day, the Commission recommends that com

tees file a consolidated pre-general election 

year-end report, due by January 7, 1988.* 

post-general election report is also required. 

chart II below.)

The FEC has sent notices on reporting 

quirements and filing dates to individuals kn

to be actively pursuing election to the Tenne

House seat. All other committees suppor

candidates in the special elections should con

the Commission for forms and more informa

on required reports. Call 202/376-3120 Of, 

free, 800/424-9530.

-------

*Alternatively, committees Which sup

candidates in the special general eletion may 

separate pre-general election and year-end 

ports. Due by January 31, 1988, the year

report would cover activity for a single 

December 31, 1987.
Novemoor 1987 FEDERAL ELECTION COMMISSION Volume 13, Numbe

---'---~---~-'-- -----

AOR Subject

Candidate Status of Mr. Hart

In order to establish eligibility for match

funds, an individual must certify, among ot

things, that he or she is presently seeking nomi

tion by a political party for election as Preside

Counsel for the Hart campaign noted that 

Hart had signed his application for matching fu

on May 4, 1987, when he was still an act

candidate. The letter, however, was not s

mitted to the Commission until May 18--after 

had announced his withdrawal as a candidate i

press conference held on May 8. In conclud

that the letter did not qualify as a certification 

active candidacy, the Commission stated: 

reality, Gary Hart certified...that he used to b

candidate...The statute, however, requires 

certification to be a reflection on the individu

present status."

*The Commission received a letter signed 

six senators, urging the Commission to reverse 

initial determination and find Mr. Hart's comm

tee eligible to receive matching fundS. 

Commission considered the letter as a comm

on the initial determination.

HART NOT ELIGIBLE FOR MATCHING FUNDS

FINAL DETERMINATION

On September 24, 1987, the Commiss

made a final determination that Gary Hart 

failed to establish eligibility to receive prim

matching funds for his 1988 Presidential prim

campaign. This decision affirmed an initial det

mination of June 4 (summarized in the July 1

Record, p.B),* The paragraphs below sum mar

the Commission's legal statement explaining 

final decision. Mr. Hart can ask the Court 

Appeals for the District of Columbia to rev

the decision.

1987-29 Communications encouraging mem

contributions to specific candidates; 

sociation PACts transmittal of contri

tions. (Date made public: October 

1987; Length: 9 pages, plus 21-page s

plement)

1987-28 Party expenditures as contributions 

candidates or operating expenditur

(Date made public: September 30, 19

Length: 4 pages, plus 2-page suppleme

5

Filing

Date

Mailing

Date

11/18/87 11/21/87

11/14-12/31 1/31/88 1/31/88

7/1-11/13

Period

Covered

Pre-Primary

Year-End

Report

*Alternatively, committees which support

candidates in the special general election may file

separate Pre-general election and year-end reports. Due by January 31, 1988, the year-end

report would cover activity for a single day,

December 31, 1987.

1987-26 Use of connected organization's "service

mark" as abbreviated name of separate

segregated fund. (Date made publici

September 16, 1987; Length: 2 page, plus

34-page supplement)

1987-27 Agreements among telephone companies

and Presidential campaigns concerning

services and payments. (Date made public: September 22, 1987; Length: ~8

pages)

AOR SUbject

REPORTING SCHEDULES FOR

TENNESSEE SPECIAL ELECTIONS

CHART I:

Committees Active in Primary Election Only

= CHART IT:

Committees Active in Both

Primary and General Elections

Report Period Mailing Filing

Covered Date Date

Pre-Primary 7/1-11/13 11/18/87 11/21/87

Pre-General 11/14-12/31 1/4/88 117/88

and Year-End*

(Consolidated)

Post-General 1/1-2/8 2/18/88 2/18/88

e
Novemoor 1987 FEDERAL ELECTION COMMISSION \t)lume 13, NumOO

The Commission also rejected counsel's contention that Mr. Hart was eligible for public funds

under 26 U.S.C. S9033(c)(2) of the Matching Payment Account Act, which provides for matching

funds to be given to former candidates under

certain circumstances. In the Commission's view,

that provision "assumes that an individual has

established eligibility and merely provides the

formerly eligible candidate with a limited entitlement."

Policy and Equitable Considerations

Counsel for Mr. Hart made a number of

arguments based on policy and equitable considerations. The Commission noted, however, that

such considerations could not refute the plain

language of the statute. This language requires a

person to certify to his or her present status as a

candidate in order to qualify for public funds.

FEe v. SAILORS' UNION OF THE PACIFIC

POLITICAL FUND

On September 15, 1987, the Court of Appeals

for the Ninth Circuit affirmed a district court

ruling that the separate segregated funds of three

maritime unions were not affiliated and therefore

had not exceeded the Act's contribution limits.

(Civil Action No. 86-1775.)

Background

On December 10, 1984, the Commission filed

suit in a federal district court against three

committees: the Sailors' Union of the Pacific

Political Fund, the Marine Firemen's Union Political Action Fund and the Seafarers' Political

Activity Donation. The Commission argued that

because the committees' respective connected organizations were all part of the Seafarers' International Union (Seafarers), contributions made by

the three committees were subject to a single,

shared limit of $5,000 per candidate, per election

pursuant to 2 U.S.C. §441a(a)(5).* The FEe asked

----_..._--'------- --""Secti;;;--441(a)(5) states that "all contributions made by political committees established

or financed or maintained or controlled by any

corporation, labor organization, or any other person, including any parent, sudsidiary, branch, division, department, or local Wlit of such corporation, labor organization, or any other

person...shall be considered to have been made by

a single political committee.... "

----------------_._~_._._._.__. --

6

the court to find that the three committees 

made excessive contributions by together co

buting an aggregate of over $5,000 to the 

Senate primary campaign of California Gove

Jerry Brown.

The District court for the Northern Dis

of California, on January 6, 1986, ruled that 

Seafar-ers' International Union was an associa

of independent unions rather than an internati

union made up of subordinate units. Accordin

the court concluded, the unions' separate se

gated funds were not subject to an aggre

contribution limit; their contributions, theref

were not excessive. (Civil Action No. 84-7

WWS.)* The FEC appealed this decision on M

5, 1986.

Appeals Court Ruling

The court decided that it would examine 

organizational authority of Seafarers in orde

determine whether its member unions were af

ated under 2 U.S.C. S44Ia(a)(5). The court

making this decision, looked to the legisla

history for guidance: "Varlous comments in 

records of both the House and Senate sug

that...Congress intended to aggregate camp

contributions of locals of international unions 

did not intend to aggregate contributions of m

ber unions of labor federations."

The court then examined the relation

between the Seafarers' International Union and 

member unions to determine whether the de

of control Seafarers exercised over them 

closer to the highly intrusive authority of 

United Steelworkers of America, the internati

union which the court had adopted as a model

the less restrictive authority of a federation 

unions, like the AFL-CIO. Acknowledging 

Seafarers had powers beyond those of the A

CIG (the authority to regulate dues, audit m

bers and appoint financial custodians for m

bers), the court nevertheless judged that 

level of authority exercised over locals by tr

tional international unions like the Steelwor

far exceeds the level of control that Seafa

may exercise under its constitution." Noting 

Seafarers' authority was more like the lim

power of the AFL-CIO, the court concluded 

two of the member unions were independen

Seafarers and that their separate segreg

funds were not, therefore, subject to a com

contribution limit.

The court pointed out that one might q

tion the autonomy of the third union and S

farers because one individual was presiden

both organizations. However, the court did 

have to decide the question because the th

member unions involved would still not be sub

to a single contribution limit.

"See the February 1986 Record, pp. 3-4, f

summary of the district court's decision.
FEDERAL ELECTION COMMISSION Volume 13, Number 

OPINIONS

1986-37: Presidential candidate appearances 

convention of nonprofit corporation, 1:6

1986-38: Individual's financing of media ads 

promote conservative candidates, 1:7

1986-39: Excess campaign funds used to establ

trust fund for minor; 2:3

1986-40: Corporate donations to state pa

committee's building fund, 2:3

1986-41: Trade association's plan to compensa

employees who make contributions, 2:4

1986-42: Effect of corporate reorganization 

PACs, 3:4

1986-44: Contributions to PAC matched with co

porate donations to charity, 3:4

1986-45: Interest payments by his committee 

candidate; 4:4

1987-1: Campaign's compensation of lost wages 

candidate prohibi ted; 4:5

1987-2: Campaign's purchase of car for can

date's reelection and official duties, 4:5

1987-3: Refund for terminated Presidential ca

paign; 4:6

1987-4: Excess campaign funds transferred fro

individual's 1986 to his 1984 campaign; 5:4

1987-5: Solicitability of membership organiz

tion's members, 5:5

1987-6: Trade association PACts combined du

payment/solicitation plan prohibited, 5:5

1987-7: Voter guides distributed to public 

nonprofit corporation, 6:3

1987-8: Multimedia presentation of President

interviews and profiles, 6:4

1987-11: Use of excess campaign funds, 8:2

1987-12: Transfer of funds from state campai

committee to federal campaign committee, 9:3

1987-13: Trade association's solicitation of co

tributions, 8:2

1987-14: National Bank's SSP supporting on

state and local candidates, 8:3 continu

This cumulative index lists advisory opinio

court cases and 800 Line articles published in t

Record during 1987. The first number in t

citation refers to the "number" (month) of t

Record issue; the second number, following t

colon, indicates the page number in that issue.

warn those who are dragging their feet that mo

intrusive legislation might be forthcoming if v

untary compliance appeared insufficient. He a

stressed the need for more systematic and insti

tionalized cooperation between election offici

and handicapped organizations.

7

Novemter 1987

CLEARINGHOUSE TESTIMONY ON

ACCESSmILITY OF POLLING PLACES

On October 6, 1987, William Kimberling,

research specialist with the FEe's Clearinghouse

on Election Administration, testified on the

accessibility of polling places to the elderly and

handicapped. He presented his testimony before

members of the Subcommittee on Elections of the

House Administration Committee. Mr. Kimberling noted that, in April 1987, the

Commission submitted to Congress a report on

the accessibility of polling places throughout the

United States,* as required by the Voting Accessibility for the Elderly and Handicapped Act.

Under that law, the FEC's role is limited to

compiling information submitted by the states.

Mr. Kimberling pointed out that, additionally, in

its capacity as a national clearinghouse on election administration, the Commission worked with

election officials and handicapped organizations,

encouraging communication between the two

groups. The Clearinghouse also offered election

officials support in developing a comprehensive

set of criteria for evaluating polling place accessibility.** With regard to the April report to Congress,

Mr. Kimberling said that information submitted

by the various states differed in some very important aspects. He particularly noted the wide

variation in criteria used to evaluate accessibility

and the significant differences in methods of

collecting and reporting data. Observing that the

Commission received reports on 82 percent of the

polling places, Mr. Kimberling concluded that

"the picture that emerges from the information

reported to us is inconclusive....there appears to

be considerable room for improvement not only in

ensuring accessibility but also in measuring it. It

Chairman Swift commended those jurisdictions that clearly demonstrated a good faith effort to accurately survey all polling sites and

materially improve access. He also chastised

those who apparently took the survey lightly,

saying that Congress deems this as an experiment

in federal legislative restraint. He went on to

"'To obtain a copy of Polling Place Accessibility in the 1986 General Election, call the

Clearinghouse: 800/424-9530 (toll· free) or

202/376-5670. See also a summary of the report

in the June 1987 Record, p.S,

'" "See the article "Providing Accessibility for

the Elderly and Handicapped,I' published in the

Winter 1986 issue of the Journal 0 Election

Administration. For a copy 0 this issue; cal the

Clearinghouse (numbers above).
Novemoor 1987 FEDERAL ELECTION COMMISSION

continued from p. 7

1987-15: Relationship between authorized Presidential committee and delegate committees, 9:4

1987-16: Transfers from state campaign committee to federal campaign committee, 8:3

1987-17: Combined membership dues and contribution on billing statement, 8:3

1987-18: PAC matches employee contributions

with commodity charitable donations, 8:4

1987-21: Effect of corporate reorganization on

PAC and proposed new PAC, 9:4

1987 -22: Polling data provided to federal candidates by corporate polling firm, 10: 1

1987 -23: PAC's acceptance of contributions from

state committee, 9:5

1987-24: Incorporated hotel chain may provide

complimentary items to federal candidates, 10:2

1987-25: Volunteer services conducted by foreign

national, 10:2

COURT CASES

FEC v: -----;--~-

-Arnericans for.Jesse Jackson, 2:9; 8:9

-Bank One, 7:5

-Barry, 4:7

-Batts, Committee to Elect, 10:6

-Beatty for Congress, 3:6

FEDERAL ELECTION COMMISSION

999 EStreet,NW

Washington, D.C. 20463

Official Business

Volume 13, Numtx3

-Citizens for the President '84, 6:6

-Citizens Party, 1:8; 2:8; 9:6

-ClarkJ 2:8

-CRT, 9:8

-Dominelli, 3:5; 6:6

-F urgateh, 3:5; 6:6

-Haley, Ted, Committee, 5:6

-Halter and AIDSJ 4:7

-MCFL, 2:4

-NCPAC,7:5

-NOWJ 10:6

-Pryor for Congress, 6:6

- Robichaux, 2:9

-Rocha, 9:6

-Rose, Congressman, 2:7

-Sailor' Union of th e Paeifi c

Political Fund, 11:6

-1984 Victory Fund, 3:6

__-=:-__ v. FEe

-Cornrnon Cause, fourth suit, 2:6; fifth su

2:9; sixth suit, 9:6; eighth suit, 10:6

-Furgatch, second suit, 6:6

-Glenn Presidential Committee, 9:6

-Spannaus, 10:6

-StarkJ Congressman, 6:6; 10:6; second su

9:8 

800 LINE

After the election: winding down, 3:9

Personal financial reports, 5:7

Honoraria, 8:9

Reporting a new treasurer, 9:9

Single- candidate committees, 10:4

Bulk Rate Mail

Postage and Fees Paid

Federal Election Commission

Permit Number G-31