• 

THE FEDERAL ELECTION 

COMMISSION 

1325 K Street NW., Washington, D.C. 20463 

Volume 6, Number 8 

FEC PRESCRIBES REGULATIONS 

GOVERNING SUSPENSION OF 

MATCHING FUNDS 

• 

On July 3, 1980, the Commission prescribed revised 

regulations governing the suspension of primary matching 

fund payments to Presidential primary candidates. Under 

the revised regulations, the Commission may suspend 

matching fund payments to a candidate only if he or she 

knowingly, willfully and substantially exceeds the spending 

limits for matching fund recipients. Moreover, a Presidential 

candidate who exceeds the spending limits will not be 

permitted to reestablish matching fund eligibility after 

matching payments have been suspended. 

These Regulations, which affect provisions of 11 CF R 

9033.9, were published in the Federal Register on April 15, 

1980 (45 FR 25378). 

GENERAL ELECTION REGULATIONS 

SENT TO CONGRESS 

On June 13, 1980, the Commission transmitted to 

Congress revised regulations governing the public financing 

of Presidential general election campaigns. The revised 

regulations contain refinements based on the Commission's 

experience in administering the public funding of the 1976 

general election. They also reflect the 1979 Amendments to 

the Act. These general election regulations have been 

renumbered to conform with the section of the U.S. Code 

on which they are based (26 U.S.C. §9001, etseq.). Technical conforming amendments have also been made to Commission Regulations at 11 CFR Parts 100, 106 and 110. 

The following paragraphs highlight the major modifications. 

Readers should not, therefore, rely solely on this summary. 

Instead, they should consult the full text of 11 CFR Parts 

August 

1980 EDITION OF COMMISSION 

REGULATIONS RELEASED 

A copy of the 1980 edition of the Commissio

Regulations has been sent, as an attachment to t

month's Record, to all political committees curren

registered with the Commission. The volume includ

revisions prescribed by the Commission on April 

1980, implementing the 1979 Amendments to t

Federal Election Campaign Act (Parts 100-115); a

revisions to the Convention Financing Regulatio

(Part 9008) and the Primary Election Financi

Regulations (Parts 9031-9038). Additional copies 

the 1980 edition of Commission Regulations 

available to the public free of charge by contactin

Office of Public Communications, Federal Electi

Commission, 1325 K Street, N.W., Washington, D

20463; or call 202/523-4068 or toll free 800/42

9530. 

Starting this month, the Record will regularly publ

a chart indicating the status of regulations propos

by the Commission after the publication of the 19

Regulations. See Page 3. 

the Commission within 14 days after receiving their p

Presidential nomination. 

Minor and new party candidates must submit a let

agreement and written certifications within 14 days 

qualifying for the ballot in 10 states. Minor and new 

candidates may, however, request an extension o

deadline, 

Candidate's withdrawal from the campaign. When an 

cont

100, 106,110, 140-146 and 9001-9007. 

• Candidate Eligibility 

Deadlines for candidate agreements and certifications. 

11 CFR 9003. 1(b). Major party candidates must sign and 

submit a letter of agreement and written certifications" to 

"In the letter of agreement, the candidate must agree to furn

cords of campaign expenses, permit the conduct of an audit

tify the person authorized to receive payments on his/her 

and designate a campaign depository. 11 CFR 9003.1 . In th

ten certifications, the candidate must Certify that he or sh

cornplv with the spending limits, limits on use of contributio

personal spending limits. 11 CFR 9003.2. 
vidual ceases to be a Presidential candidate,* he/she must repayments of public funds to the U.S. Treasury, if resubmit a written statement to the Commission within 60 quired; pay up to 10 percent of oil overhead costs allocable 

days indicating: campaign debts, cash-on-hand, estimated 

winding-down costs, the value of any capital assets, and 

debts owed to the campaign. 11 CF R 9004.8. 

Personal Funds 

The candidate may spend personal funds of up to 

to the campaign's other legal and accounting compliance 

costs; and solicit contributions to the compliance fund. The 

compliance fund may not be used to pay debts remaining 

from the candidate's primary campaign, unless excess funds 

remain 

liquidated. 

after 

11 

all 

CFR 

debts 

9003.3(a)(2). 

of the general election campaign are­ 

$50,000 for any qualified campaign expenditures. In addition to the candidate's personal assets and salary, "personal 

funds" may include funds of the immediate family over 

which the candidate had legal title or to which, under state 

law, the candidate had the right of beneficial enjoyment at 

the time he/she became a candidate. 11 CFR 9003.4(c)(3). 

When a family member contributes funds which the candidate does not control, the funds are considered contributions subject to the $1 ,000 limit. They do not count against 

the $50,000 limit on personal funds. 

Legal and Accounting Fund 

Contributions to a Legal and Accounting Compliance 

Fund. 11 CFR 9003.3(a)(I). Federally funded candidates 

may accept private contributions for a legal and accounting 

compliance fund. Contributions to the fund, which are 

subject to the Act's $1,000 per election limit and to the 

prohibitions on contributions, must be kept in an account 

separate from federal funds. Federal funds may not be used 

to solicit contributions to this account. 11 CFR 9004.4(bl. 

Further, solicitations to the compliance fund must clearly 

indicate that contributions will be used for compliance 

purposes. 

Funds may be transferred from the candidate's primary 

campaign to the compliance fund, provided the candidate 

has sufficient funds to make any required repayments of 

primary matching funds. See 11 CFR 9003.3(a)(1)(ii). 

Contributions designated for the primary campaign, but 

which are made after the beginning of the general election 

expenditure report period, may also be deposited in the 

compliance fund provided the candidate committee complies with certain requirements specified in the regulations. 

See 11 CFR 9003.3(a)(1)(iii). 

Disbursements from the Compliance Fund. Disbursements 

from the compliance fund (other than funds loaned to the 

candidate's campaign for start-up expenses) are not chargeable to the candidate's spending limit, but they are reportable. These funds may be used to comply with the Act; pay 

civil penalties resulting from violations of the Act;** make 

..Any individual who is not actively conducting a campaign in more 

than one state for the Presidency and Vice Presidency ceases to be 

a candidate. 11 CFR 9002.2. 

"Civil or criminal penalties resulting from violations of the Act 

may not be paid from federal funds. 11 CFR 9002.11 (c){3l. 

Start-Up Expenses 

Candidates are permitted to make disbursements to set 

up a basic campaign organization before the expenditure 

report period begins or before they receive public funds. 

Such disbursements count as qualified campaign expenditures and thus must ultimately be defrayed with public 

funds. In the interim before public funds are available, 

however, the candidate may fund such disbursements from 

other sources. Subject to the restrictions detailed in the 

regulations, the candidate may borrow from the compliance 

fund, from banks in the ordinary course of business, from 

the primary campaign and from personal funds. i 1 CFR 

9003.4(a) and (b). 

Winding Down Costs 

Payments made to terminate campaign activity after the 

close of the expenditure report period are considered 

qualified campaign expenditures. For example, rental of 

office space required for "winding down" activities of the 

campaign is a qualified campaign expenditure. Thus, candidates must use federal funds to defray this expense. 11 

CFR 9004.4(0)(3). 

Documentation of Expenses 

The candidate has the burden of proving that all disbursements made by the candidate, or any authorized 

committee or agent of the candidate, are qualified earnpaign expenses. Minimum documentation required for 

qualified campaign expenses includes: 

For disbursements of $200 or less, a canceled check to the 

payee (unless the disbursement is from a petty cash fund) 

11 CFR 9003.5(0)(2); and 

For any single disbursement exceeding $200, a receipted 

bill from the payee or a canceled check plus a bill, invoice, 

voucher or memorandum from either the candidate or the 

committee. 11 CFR 9003.5(a)(1}. 

Audits 

It is the candidate's responsibility to facilitate an FEC 

audit by gathering records in a central location and providing the necessary space and personnel to perform the 

audit. All bank records and supporting documentation for 

expenditures of public funds must be provided by the 

candidate. 11 CFR 9003.7. 

The RECORD is published by the Federal Election Commission, 1325 K Street, N.W., Washington, D.C. 20463. Cornmissioners are: Max L. Friedersdorf, Chairman; John Warren McGarry, Vice Chairman; Joan D. Aikens; Thomas E. 

Harris; Frank P. Reiche; Robert O. Tiernan; J.S. Kimmitt, Secretary of the Senate, Ex Officio; Edmund L. Henshaw, 

Jr., Clerk of the House of Representatives, Ex Officio. For more information, call 202/523-4068 or toll-free 800/424· 

9530. 

2 
STATUS OF FEe REGULATIONS 

Date Sent Federal Register Date Prescribed** 

• 

Regulations· to Congress Publication by the Commission 

11 CFR 9033.9 4/10/80 4/15/80 7/3/80
 

Suspension of Primary (45 FR 25378)
 

Matching Fund Payments
 

11 CFR Part 4 Not appl icable 5/13/80 6/12/80 

Public Records and the (45 FR 31291) 

Freedom of Information Act 

11 CFR Part 5 Not applicable 5/13/80 6/12/80 

Access to Public Disclosure (45 FR 31292) 

Division Documents 

11 CFR, Parts 100 and 110 5/14/80 5/23/80 Congressional 

Contributions to and (45 FR 34865) approval pending 

Expenditu res by Delegates 

to National Nominating 

Conventions 

11 CFR, Parts 100, 106, 6/13/80 6/27/80 Congressional 

110,140-146 and 9001-9007 (45 FR 43371) approval pending 

Public Financing of Presidential General Election 

Campaign 

• 

"The chart is cumulative, listing all amendments to the FEe Regulations proposed after the 1980 edition of 1f CFR was published, inc

any technical amendments. 

**The Commission may prescribe its regulations 30 legislative days after it has transmitted them to Congress, provided neither the Hou

the Senate disapproves them during this period. 

Reporting Requirements 

General Election vs. Other Elections. The candidate's 

authorized campaign committee(s) must file separate 

reports for the general election campaign and for other 

elections. 11 CFR 9006.1 (a). 

Campaign Funds vs. Compliance Funds. With regard to the 

general election, the campaign must file two separate 

reports: one disclosing receipts and disbursements for 

Qualified campaign expenditures, the other disclosing 

activity of the legal and accounting compliance fund. 11 

CFR 9006.1 (b). 

Disputes Procedure for 

Certification and Repayment 

For those instances when a candidate challenges a 

Commission determination concerning certifications and 

evidence submitted and provide a statement of re

underlying its final determination, including a summa

any investigation conducted. 11 CFR 9005.2 

9007.2(b). 

The regulations governing the public financing of Pres

tial general election campaigns were published in the 

eral Register on June 27,1980 (45 FR 43371). They 

be promulgated 30 legislative days after their transmit

Congress, provided neither the House nor the Senat

approves them. 

• 

repayments of public funds, a procedure has been standardized to conform with due process requirements. The 

candidate has an opportunity to respond to a Commission 

decision within a specified time, engage counsel if he/she so 

desires and submit written evidence in support of his/her 

position. The Commission is required to consider the 

3 
ADVISORY OPINION REQUESTS 

Advisory Opinion Requests (AOR's) pose questions on 

the application of the Act or Commission Regulations to 

specific factual situations described in the AOR. The following chart lists recent ADR's with a brief description of 

the subject matter, the date the requests were made public 

and the number of pages of each request. The full text of 

each AOR is available to the public in the Commission's 

Office of Public Records. 

Date Made No. of 

AOR Subject Public Pages 

'980-76	 Exclusion of candidate's 8/'9/80 4 

fees for television appearances from honorarium limit. 

1980-77	 Allocation of party expendi- 6/20/80 2 

tures for television ads on 

behalf of several candidates. 

'980-78	 Use of campaign finance infer- 6/23/80 

matlcn obtained from disclosure reports in candidate's
 

fund raising letter.
 

1980-79	 Title of unauthorized corn- 6/27/80 2 

mtttee advocating candidate's 

defeat. 

1980·80	 Separate principal campaign 7/1/80 

committees for Congressional 

primary and special ejections 

held on the same day. 

1980-81	 Application of 1980 annual 7/3/80 2 

limit to individual's 1979 contnbutlons to draft committee. 

1980-82	 Individual's involvement in 7/8/60 3 

independent expenditure cornmittee operating on behalf of 

Presidential nominee. 

1980-83	 Reporting requirements for 7/8/80 4 

inactive Presidential primary 

candidate. 

1980-84	 Committee's use of leftover 7/11/80 

stationery and checking 

account bearing its name prior 

to 1979 Amendments to the Act. 

1980·85	 Gift from descendant's estate 7/15/80 2 

as contribution to multlcandldate committee. 

1980·86	 Abbreviated name used by 7/15/80 

corporate separate segregated 

fund. 

4 

ADVISORY OPINION 

REQUEST WITHDRAWN 

AOR 1980-61 (application of contribution and expendi· 

ture limits to independent expenditure committee for the 

Presidential general election) was withdrawn by its re- 

quester on July 1, 1980. 

ADVISORY OPINIONS: SUMMARIES 

An Advisory Opinion (AO) issued by the Commission 

provides guidance with regard to the specific situation 

described in the AO R's. Any qualified person who has 

requested an AD and acts in accordance with the opinion 

will not be subject to any sanctions under the Act. Other 

persons may rely on the opinion if they are involved in a 

specific activity which is indistinguishable in all material 

aspects from the activity discussed in the AD. Those 

seeking guidance for their own activity, however, should 

consult the full text of an AO and not rely only on the 

summary given here. 

AO 1980-42: FUndraisin9 Concerts Conducted for 

Senatorial Campaign Committee 

Volunteer services provided by entertainers for fundraisinq 

concerts to be held on behalf of the Hart for Senate Campaign Committee, Inc. (the Committee) would not count as 

in-kind contributions to the Committee, provided the 

Committee reimbursed the entertainers for their expenses. 

2 U.S.C. §431(8)(B). Further, the Committee could 

contract with a promoter who, as an agent of the Committee, would handle concert arrangements. 

Under the contractual arrangements, ticket sales could be 

made at outlets normally used for commercial concerts, and 

tickets issued could be identical to those issued for nonpolitical concerts. Advance publicity and notices at sales 

locations, however, would have to inform ticket purchasers 

that the concert would benefit the Committee. 

Since ticket sales would be treated as contributions from 

the purchasers, the proceeds would have to be handled as 

contributions. The Committee' would have to establish 

controls to ensure that purchasers did not violate the Act's 

dollar limits or prohibitions on contributions. The identity 

of contributors would have to be obtained when any 

person's ticket purchases exceeded $50 at the same selling 

loeation. 2 U.S.C. §432(b); 11 CFR 102.9, 

Checks for ticket purchases would not have to be made 

payable to the Committee, but they would have to be 

deposited in the special account established for the fundraiser. Proceeds deposited in the special account would then 

be forwarded to the campaign's treasurer within 10 days of 

their receipt. 2 U.S.C. §432(b)(1); 11 CFR 102.8(0). The 

treasurer, in turn, would have to deposit the proceeds in a 

designated campaign depository within 10 days of their 

receipt. 11 CFR 103.3(a). Alternatively, the promoter, as 

the Committee's agent, could transfer the proceeds from 

the special account directly to a deslqnated Committee 

account within 10 days of their receipt. The promoter 

would also have to keep records for all ticket proceeds. 2 

U.S.C. §432; 11 CFR 102.9. 
The promoter could pay for concert expenses from ticket NEA's membership dues. Therefore, NEA would n

sale proceeds deposited in a special account established in making a prohibited in-kind contribution to NEA-PA

an official campaign depository. Similarly, funds in this be fully permissible, however, the second and f

• 

account could be used to pay the promoter the usual and 

normal fee for his services. The promoter would then 

forward the balance of the proceeds to the Committee. All 

expenses (including fees to the promoter) would be subject 

to the Act's recordkeeping and reporting requirements. 

Commissioner Frank P. Reiche issued a dissenting opinion. 

(Date Issued: June 25, 1980; Length, including dissenting 

opinion: 14 pages) 

AO 1980-44:	 Collection Systems Proposed 

by Labor Organization for its 

Soparate Segregated Fund 

Two collection systems proposed by the National Education Association (NEA) to collect contributions for its 

political aetlon committee, NEA-PAC, would be. permissible; however, two other proposed systems would not. 

Under the current system, NEA members authorize deduction of a fixed sum from their pay checks for contributions 

to NEA-PAC and for their unified membership dues to 

NEA. To ease the administrative burden imposed by a 

provision of the Act requiring timely transmittal of political 

contributions to the treasurer of a political committee (2 

U.S.C. §432(b)(2)), NEA proposed four alternative payroll 

deduction systems. all of which would be less costly and 

time-consuming than NEA's current collection system. 

• 

Under the first proposed collection system, the entire NEAPAC contribution would be deducted from the first payroll 

deduction check of NEA's membership year. Membership 

dues would then be deducted from subsequent checks. No 

change would be made in the members' current payroll 

deduction authorization form. The third proposed system 

is identical to the first, except that the authorization form 

would indicate that NEA-PAC's contribution was being 

drawn entirely from the first payroll deduction check. 

These two collection systems would not be permissible. By 

deferring its receipt of membership dues in order to facilitate member contributions to NEA-PAC, NEA would be 

giving "something of value, if not an advance . . . to NEAPAC." Therefore, NEA's service would constitute a prohibited contribution from NEA to NEA-PAC. 2 U.S.C. §441b 

(b). Even if NEA members signed authorization cards 

agreeing to defer their membership dues, a prohibited 

in-kind contribution would still result since NEA - not its 

individual members - would be providing the deferred 

receipt of dues. 

Under the second proposed collection system, the NEAPAC contribution would be deducted in one lump sum 

from the last payroll deduction check after all membersh ip 

dues had already been deducted from previous checks. 

There would	 be no change in the authorization form. The 

• 

fourth proposed system is the same as the second except 

that the authorization form would indicate the change in 

the payroll deduction system. 

These collection systems would be permissible because 

NEA-PAC's contributions would be deferred. rather than 

collection systems would also have to meet all legal re

ments pertaining to the solicitation, collection and 

mittal of contributions to NEA-PAC. (Date Issued: J

1980; Length: 5 pages) 

AO 1980·46:	 Fundraising Plan of Independent 

Expenditure Committee 

Expenditures made by the National Conservative Po

Action Committee (NCPAC) for a mass mailing that 

cates a candidate's election and solicits contributions 

campaign through NCPAC (as a conduit) would be c

ered an in-kind contribution to the candidate's pri

campaign committee, rather than an independent exp

ture. 

The solicitation system proposed by NCPAC for the 

mailing would consist of a letter suggesting that a c

bution for the candidate be mailed to NCPAC, which w

gather and transmit the contributions to the candi

principal campaign committee. Even if no communic

occurred between NCPAC and the candidate or any a

of his -campalqn, expenditures for the mass mailing w

be an in-kind contribution to the candidate's pri

campaign committee because, in accepting the earm

contributions forwarded through NCPAC, the candi

campaign would also be accepting the solicitation se

provided by NCPAC. 

conti

The list below identifies all FEC documents 

appeared in the Federal Register between June 27, 

and July 17, 1980. Copies of these notices are not 

able from the FEC. 

Notice Title 

Federal Register 

Publication Date Cita

1980·22 Public Financing of 

Presidential General 

Election Campaigns 

(Transmittal of Regulations to Congress) 

6/27/80 45 FR 

1980-23 Federal Election Commission Opinion and 

Regulation Index 

(Notice of Availability) 

6/24/80 45 FR 

1980-24 Suspension of Primary 

Fund Payments 

(Announcement of effective date for Regulations) 

7/3/80 45 FR 

1980-25 Filing Dates for Michigan 

Special Primary and 

General Elections 

7/17/80 45 FR 

5 
NCPAC would be considered a conduit transmitting the CFR 114.4(c)(2). 

contributions to the candidate's principal campaign committee. Since, however,. NCPAC would exercise no control 

over the contributions made to the candidate, the contributions would not count as contributions by NCPAC and 

would not count against NCPAC's $5,000 contribution 

limit. 11 CFR 110.6(d)(1). Instead. the contributions 

would count against the individual contributor's limits. 2 

U.S.C§441a(a) and 11 CFR 110.1. 

Voter Registration Drives. Since the voter registration 

drives which the state's registrars of voters plan to undertake would be completely nonpartisan, corporations may 

make their facilities available for the drives. The corporations' employees may also assist in the drives as officially 

appointed 

(Date Issued: 

assistant 

June 25,1980; 

registrars. 11 CFR 

Length: 4 pages) 

114.4(d)(2) and (3). 

As a conduit, NCPAC would be required to report the 

contributions to both the candidate's principal campaign 

committee and to the Federal Election Commission according to reporting procedures detailed in Commission Regulations. See 11 CFR 110.6(c)(4)(i), (ii) and (iii). Chairman 

Max L. Friedersdorf filed a dissenting opinion. (Date 

Issued: June 25,1980; Length: 6 pages) 

AO 1980-53:	 Donation of Promotion Item to 

Host Committees of National Conventions 

Kelly Services, Inc. may donate canvas tote bags to the host 

committees of the Democratic and Republican National 

Conventions for free distribution to delegates and convention attendees. Costs of providing the tote bags would not 

count against either national party's expenditure limits for 

the convention. 

Kelly Services, Inc. may provide the tote bags, which will 

be inscribed with the convention's name on one side and 

the company's name on the other, because the bags are of 

nominal value, are provided solely for bona fide advertising 

purposes, and are provided in the ordinary course of 

business. 11 CFR 9008.7(c)(2). (Date Issued: June 17, 

1980; Length: 2 pages) 

AD 1980-54:	 Contributions by 

National Bank 

The First National Bank of West Monroe may not make 

contributions to the Louisiana Political Action Council 

(LAPAC), a committee supporting candidates for state 

office. The Act prohibits national banks from making 

contributions and expenditures in oonnection with "any 

election to any political office" (2 U.S.C. §441b(a)), 

including donations to political committees which support 

candidates for state or local office as well as federal office. 

(Date Issued: June 17, 1980; Length: 2 pages) 

AO 1980-55:	 Corporate Assistance for Secretary of 

State's Voter Registration Drive 

The Office of the Secretary of State for Connecticut, which 

administers the state's elections, may accept corporate 

assistance in undertaking the following nonpartisan voter 

registration activities, provided these activities are permitted by state law: 

Reprinting and Distributing Voter Registration Information. A corporation may use its facilities to reprint and 

distribute to the general public materials prepared by the 

Secretary of State on topics such as voter' registration and 

party enrollment. These reprints may contain the corporation's logo, identification or a statement identifying the 

corporation's participation, such as: "Printed and distributed as a public service by the XYZ Corporation in conjunction with the Secretary of State of Connecticut." 11 

AD 1980-56:	 Method of Counting Votes to
 

Determine Minor Party Candidate's
 

Eligibility for Public Funding
 

The total number of votes cast in the 1980 Presidential
 

general election for Mr. Barry Commoner will be counted
 

to determine his eligibility for retroactive public funds and
 

the appropriate amount due - regardless of whether his
 

name appears on a state ballot as an independent candidate
 

or as the Presidential candidate of the Citizens' Party.
 

Under the J;\C1, a minor or new party candidate is eligible
 

for retroactive public funding if the candidate of a political
 

party receives five percent or more of the total number of
 

popular votes cast for President. 11 CFR 9004(a)(3). (Date
 

Issued: June 17, 1980; Length: 2 pages)
 

AD 1980-57:	 Fundraising to Defray Candidate's 

Litigation Fees
 

The Bexar County Democratic Party (the Committee) may
 

solicit funds for Congressman Henry B. Gonzalez, which
 

. Mr. Gonzalez will then use to defray litigation fees he
 

incurred while challenqin, the nominating petitions of a
 

potential Republican opponer-: r ce Mr. Gonzalez's
 

litigation activity could influence l"e outcome of a federal
 

election by preventing his opponent's name from appearing
 

on the state ballot, funds raised by the Committee would
 

campaign 

be considered 

committee 

"contributions" 

and would be subject to 

to Mr. Gonzalez's 

the reporting
 

principal
 

requirements, limitations and prohibitions of the Act.
 

The Committee could raise funds for Mr. Gonzalez's
 

litigation fees by using either one of the following methods:
 

1. If	 the Committee solicited funds and contributed them
 

to Mr. Gonzalez's principal campaign committee, the
 

Committee would be required to register and report as a
 

"political committee" under the Act once it had re­


ceived contributions in excess of $5,000. 2 U.S.C.
 

§ §433 and 434. Contributions to the Committee by an
 

individual and contributions by the Committee to Mr.
 

Gonzalez would each be subject to a $5,000 per year
 

limit, provided the Committee qualified as a multicandi­


date committee (i.e., the committee had been registered
 

for at least six months, had received contributions from
 

more than 50 donors and had contributed to at least five
 

federal candidates).
 

2. Alternatively, Mr. Gonzalez could mail out a fundraising
 

letter on the Committee's letterhead. In this case, the
 

fundraising would be an activity of Mr. Gonzalez's
 

campalqn.,Therefore, expenditures made for the solicita­


tion, and any funds received, would be expenditures by
 

and contributions to Mr. Gonzalez's principal campaign
 

committee. As such, they would be reportable by Mr.
 

Gonzalez's campaign. The Gonzalez campaign commit­


tee would also be required to include a statement on the
 

solicitation 

§441d. (Date Issued: 

authorizing 

June 

the 

25,1980; 

fundraising 

Length: 4 pages) 

activity. 2 U.S.C.
 

6 
~--------------------

AO 1980·58: National Bank's Contributions to 

State Senators' Officeholder 

• 

Expense Funds 

Union Bank and Trust Company (the Bank), a national 

bank in Grand Rapids, Michigan, may make donations 

payable by corporate check to the Officeholder Expense 

Funds of state senators. Michigan. law prohibits public 

officials from using their officeholder expense funds to 

make contributions or expenditures to further their nomination or election to public office. The Act's ban on 

political contributions by national banks would not, 

therefore, apply to donations made to a state officeholder's 

expense fund if that fund is not utilized in connection with 

any election to any federal, state or local office. (Date 

Issued: June 25, 19BO; Length: 3 pages) 

AO 1980·62: Labor Union's Solicitation of 

.Temporary Employees 

The Pipefiners Local 524 Political Action Fund (the 

Committee), the separate segregated fund of the Pipefiners 

Local 524 (the Local), may solicit contributions from one 

category of temporary employees (travel card holders) but 

not from another category (permit card holders). 

The Committee proposed soliciting both types of temporary employees through a voluntary payroll deduction plan. 

One group, the travel card holders, are not members of the 

Local. They are, however. members of other local unions 

• 

affiliated with the Local's national organization, the United 

Association of Journeymen and Apprentices of the Plumbing and Pipe Fining Industry of the United States and 

Canada (United Association). Under Commission Regulations, the travel card holders areconsidered members of the 

United Association by virtue of being members of one of its 

affiliated local unions. The Committee may therefore solicit 

these employees because a subsidiary organization or its 

separate segregated fund may solicit members of its "parent 

organization," l.e, the United Association. (See also AO 

197B-75.) 

The other group of employees, the permit card holders, are 

not members of the Local or of the United Association. 

The Committee may not, therefore, solicit this group of 

employees. 2 U.S.C. §441b(b)(4)(A). Commissioners 

Thomas E. Harris and Frank P. Reiche filed concurring 

opinions. (Date Issued: July 3, 1980; Length: 6 pages, 

including coneurrinq opinions) 

AO 1980-64: Labor Organization's Payment 

of Members' Delegate Expenses 

The National Education Association (NEA), a national 

labor organization, may not use its general treasury funds 

to pay the travel and living expenses of NEA memberswho 

will be attending the Democratic and Republican national 

nominating conventions asdelegates. 

The Act explicitly prohibits labor organizations from 

• 

making contributions or expenditures in connection with 

federal elections. 2 U.S.C. §441b. The Commission's 

proposed delegate selection regulations" reinforce this 

prohibition by explicitly stating that "all contributions to 

and expenditures by any delegate ... are subject to the 

prohibitions of 11 CFR 110.4(a), Part 114; 2 U.S.C. 

§§441b and 441e." Moreover, the delegates' exp

would not be considered the type of exempted expend

which a labor organization may make for nonpa

get-out-the-vote drives directed to members. 11 

114.3Ic)(3). (Date Issued: July 9, 1980; Length: 3 pag

PRESIDENTIAL ELECTIONS 

The Office of Public Communications receives ~ume

inquiries from the public on its toll-free line: 800

9530. The following questions and answers respon

questions the office hasreceived about the public fina

program for the 1980 Presidential general election. 

Question: How are public funds made available to Pre

tial candidates for their general election campaigns? 

Answer: Public funds for the Presidential general ele

are made available through the Presidential Election 

paign Fund, which consists of dollars voluntarily ch

off by taxpayers on their Federal income tax retu rns. 

Question: Who is eligible to receive public financing

how much money maya candidate receive? 

Answer: Each major party* Presidential nominee is e

for a public grant of $20 million plus the cost-of-

adjustment (or $29.4 million in 19BO) for campaign

the general election. 

Qualified minor party* candidates are eligible to rec

proportionate amount of the grant available to major 

candidates. This proportionate grant is based on the 

ber of votes the minor party candidate or his/her resp

party received in the last Presidential general ele

Eligible new party* candidates may receive a partial 

after the general election based on the number of 

they receive in the 1980 election. 

Question: How do Presidential candidates obtain p

funding? 

Answer: Requests for public funds are reviewed for e

ity by the FEC and then certified by the FEC t

Department of Treasury, which in turn disburses the f

To be eligible, candidates must agree in writing to: 

Limit campaign spending to the amount of the 

available to major party candidates ($20 million pl

cost-of-Iiving adjustment). Note: This spending 

appliesto major, minor and new party candidates; 

Spend public funds only on qualified campaign exp

tures (i.e., expenditures which influence the cam

for the Presidency); 

..A major party is a political party whose nominee receives 2

cent or more of the total popular votes in the preceding Pr

tial election; a minor party is a political party whose nomin

ceived between 5 and 25 percent of the total popular votes 

preceding Presidential election; and a new party isa political 

whose nominee received less than 5 percent of the total v

the preceding election. 

7 
Repay public funds to the U.S. Treasury, if required; 

and 

Facilitate an FEC audit of the campaign by gathering all 

records in a centralized location and providing the 

necessary space and persbnnel to assist in the audit. 

Question: May Presidential candidates who receive public 

funding also accept private contributions? 

Answer: Major party candidates who accept public funding 

may not accept any private contributions for their general 

election campaigns, except for a special account maintained 

exclusively to pay expenses related to their complying with 

the ejection law. Minor and new party candidates who 

accept partial public financing may, in addition to accepting contributions for their compliance fund, accept private 

contribution for the campaign itself, as long as the sum of 

public funds and private contributions does not exceed a 

major'party candidate's total grant. 

Question: May a candidate spend any of his or her own 

funds, or funds of his or her family, to promote his or 

her candidacy? 

Answer: Yes. A Presidential candidate who accepts public 

funding may spend up to $50,000 in personal funds (including family funds over which the candidate had direct 

legal control at the time helshe became a candidate) to 

promote his or her campaign for the Presidency. These 

expenditures are not chargeable to the spending limit. 

Question: Are a candidate's legal and accounting expenses 

chargeable to his/her spending limit for the general election? 

Answer: Payments for legal and accounting fees related to 

compliance with the Act, which are paid from the candidate's compliance fund, are not chargeable to the candidate's spending limit; but they are reportable. (The compliance fund may also be used for other purposes, as 

specified in the regulations. see Disbursements from the 

Compliance Fund on page 2 of this issue of the Record.) 

Question: Under what circumstances must a candidate repay public funds? 

Answer: Repayment of public funds is required in several 

situations, including cases where the amount of public 

funds received exceeds the amount to which the candidate 

is entitled; where spending limits are exceeded; where 

public funds are used for purposes other than "qualified 

campaign expenditures"; or where public funds remain 

after debts and obligations have been paid. 

Question: Maya candidate dispute an FEe determination 

concerning certifications and repayments of public funds? 

Answer: Yes. Commission Regulations provide a dispute 

procedure, consistent with due process requirements, 

whereby candidates may challenge FEC decisions concerning certifications and repayments. The FEC must respond 

by investigating any additional evidence provided and by 

submitting its findings in writing. 11 CFR 9005.2 and 

9007.2(bl. 

8 

LOUISIANA PRIMARY 

RESCHEDULED 

The filing date for the Louisiana pre-primary repor

has been changed because the Louisiana primary election 

for Congressional candidates has been rescheduled fo

September 13 (instead of september 20). This chang

affects the authorized committees of all federal candidate

in the primary election and any other political committee

that support a federal candidate in the Louisiana primary 

(except those filing on a monthly basis). The new schedul

for filing a 12·day pre-election report for the Louisian

primary is as follows: 

Mailing Date of Report 

Closing Date (if sent by registered Filing 

of Books by certified mail) D.te 

August 24,1980 August 29, 1980 September 1. 1980 

DISTRICT COURT GRANTS SUMMARY 

MOTIONS IN COMMON CAUSE ET AL. 

V. FEC ET AL. 

trict of 

On April 30, 1980, 

Columbia granted 

the 

summary 

U.S. District Court for the Dis

judgment in two cros

motions filed by parties to the suit, Common Cause et st. v

FEC et al. (Civil Action No. 78-2135). 

Common Cause had filed its motion for summary judgmen

in November 1978, requesting that the Court rule the FEC 

had acted contrary to law in failing to take final action on 

Common Cause's administrative complaint within 90 day

of its being filed. 2 U.S.C. §437g(a)(9)(B)(JJ). In its com

plaint, Common Cause had asserted that the American 

Medical Political Action Committee (AMPAC), the separate 

segregated fund of the American Medical Association 

lAMA), and the state political action committees of AMA'

state affiliates constituted a single political committee by 

virtue of their affiliation. 2 U.S.C. §441a(a)(5). Therefore

alleged Common Cause, AMPAC and its affiliated state 

PACs shared a single contribution limit of $5,000 pe

candidate, per election. Common Cause's complaint listed 

numerous instances in the 1976 Congressional election

where the combined contribution of AMPAC and an 

affiliated state PAC to a candidate had exceeded the $5,000 

limit. 

At the time Common Cause filed its motion for summary 

judgment, the Commission had entered into conciliation 

agreements only with AMPAC and a few of the state PAC

named in the June 1978 complaint. By fall of 1979, how
ever, the Commission had entered into separate agreements 

with an additional five state PACs; between Fall 1979 

• 

and Spring 1980 the Commission entered into agreements 

with eleven other state PACs and was preparing to enter 

into 10 additional agreements. The Court also noted that in 

February 1977 the Commission had broadened the scope of 

its initial investigation to include all of the AMA's state 

affiliates and their PACs. Moreover, the Commission had 

begun investigating four additional complaints which also 

alleged violations of the Act's contribution limits by 

AMPACand its affiliated state PACs. 

Common Cause nevertheless maintained that the FEe had 

acted contrary to law in not taking final action on its 

complaint within 90 day's. The FEC, on the 6ther hand, 

viewed the SO-day provision as jurisdictional, giving the 

Court power to decide after the 90'day period whether or 

not the Commission had acted contrary to law. 

In addition to supportinq the FEC's interpretation of the 

90·day provision, the Court noted that the determination 

of whether AMPAC and its state PACs were affiliated (l.e., 

whether they had been established, financed, maintained or 

controlled by the same entity) was a factual question 

requiring proof provided by extensive investigation. Therefore, the Court did not find the FEC's efforts to collect 

further evidence to be an abuse of discretion. Moreover, 

the Court found that the FEC's decision not to investiqate 

• 

combined contributions by state PACs affiliated with 

AMPAC (in addition to the combined AMPAC-State PAC 

contributions it had investigated) was not contrary to law 

since Common Cause had mentioned only one such Occurrence among the 69 violations it had cited. The Court did, 

however, order the Commission to either enter into conciliation agreements with the te~ remaining respondents 

named in Common Cause's complaint Within 30 days of the 

Court's rulin9 or brin9 suit against them. The Commission 

did enter into conciliation agreements with the remaining 

respondents, and the Court issued an order on June 13, 

1980, disrnlssinq the case. 

LITIGATION STATUS INFORMATION 

The following is a list of new litigation involving the 

Commission, together with the date the suit was filed, the 

court involved, the docket number and a brief description 

of the major issuets) involved in the case. Persons seeking 

additional information on a particular case should contact 

the court where the suit isfiled or the Commission. 

Felice M. Gelman and Citizens for LaRouche, Inc. Y. FEC, 

U.S. Court of Appeals for the District of Columbia Circuit, 

Docket No. 80-1646, June 11, 1980. 

Pursuant to 26 U.S.C. §9041, plaintiffs seek 

review of an FEC decision issued May 29, 1980, 

• 

that Lyndon H. LaRouche had not reestablished eligibility for primary matching funds in 

the Michigan Democratic Presidential Primary 

of May 20, 1980, and that the Commission 

would therefore proceed with a post-primary 

FEC CHANGES LATE AND 

NONFILER PROCEDURES 

In March and July 1980, the Commission approved 

procedures for notifying authorized and unauthor

committees of their reporting Obligations under the 

These procedures reflect the 1979 Amendments to 

federal election law (2 U.S.C. § §437g(bl and 438(a)(

The Commission will continue to notify late filers 

nonfilers of their reporting requirements under the 

However, no compliance action will be initiated until a

the Commission has notified nonfiling committees of t

failure to comply with reporting obligations and, in the 

of authorized candidate committees, after the Commis

has published the names 01 nonfilers. The nonfiler pro

uresare summarized below: 

Election Year Procedures 

Before each reporting deadline, a "prior notice" exp

ing reporting requirements for the particular tvpels] 

reports due will be sent to all registered committees. 

the 12-day pre-primary report, this notice will be sent to 

individualswho appearon the state ballot. 

Note: Unauthorized committees will not be sent a p

notice for the pre-primary report. (Unauthorized com

tees include party committees. nonparty committees 

unauthorized single candidate committees.) Instead 

prior notice for quarterly reports will remind unauthori

committees of their obligation to file pre-primary rep

for those primary elections in which they made ei

contributions or expenditures (if these contributions 

expenditures were not reported on a prior report). 

After each reporting deadline, the Commissionwill sen

mailgram to all registered political committees that fai

file a report, informing them that their reports have 

been received. 

After the mailgram has been sent, the Commission 

publish the names of all authorized candidate committ

which still have not filed their report by the particular d

state? in the mailgram. The Commission will not, howe

publish the names of any other types of committees wh

fail to file required reports, since their publication is 

authorized in the 1979 Amendments to the Act, Inste

the Commission will handle such nonfllers and late fi

through normal compliance procedures. 

Nonelection Year Procedures 

During nonelection years, the Commission will s

prior notices to filers semiannually. Procedures for not

ing late or nonfilers and publishingthe names of authoriz

candidate committees that fail to file a report are the Sa

asthosefor an election year. 

audit of Mr. LaRouche's campaign. 

9 
SUMMARY OF MUR's 

Selected. compliance cases, which have been closed and 

put on the public record, are summarized in the Record. 

Compliance matters stem from possible violations of the 

Federal Election Campaign Act of 1971, as amended, which 

come to the Commission's attention either through formal 

complaints originating outside the Commission or by the 

FEC's own monitoring procedures. The Act gives the FEC 

the exclusive jurisdiction for the civil enforcement of the 

Act. Potential violations are assigned case numbers by the 

Office of General Counsel and become "Matters Under 

Review" (MUR's). All MUR investigations are kept confidential by the Commission, as required by the Act. 

MUR's may be closed at anyone of several points during 

the enforcement process, including when the Commission: 

Oetermines that no violation of the Act has occurred; 

Determines that there is no reason to believe or no 

probable cause to believe a violation of the Act has 

occurred; 

Enters into a conciliation agreement with the respondent; 

Finds probable cause to believe a violation has occurred 

and decides to sue; or 

Decides at any point during the enforcement processto 

take no further action. 

After the MUR is closed and released by the Office of 

General Counsel, the Commission makes the MUR file 

available to the public. This file contains the complaint, 

the findings of the General Counsel's Office and the Com' 

mission's actions with regard to the case, including the full 

text of any conciliation agreement. The Commission's 

actions are not necessarily based on, or in agreement with, 

the General Counsel'sanalysis. 

Selection of MUR's for summary is made only from MUR's 

closed after January 1, 1979. The Record article does not 

summarize every stage in the compliance process. Rather, 

the summary provides only enough background to make 

clear the Commission's final determination. The full text of 

these MUR's and others which were closed between 1976 

and the present are available for review and purchase in the 

Commission's Public RecordsOffice. 

MUR 885: Express Advocacy, Required 

Authorization Notice, 

FederallState Accounts
 

On November 21, 1979, the Commission entered into
 

a conciliation agreement with a political committee that 

had violated provisions of the Act by its failure to register
 

and file timely reports as a political committee, to include
 

authorization/nonauthorization notices on advocacy litera­


ture and to either keep separate federal and state accounts
 

for contributions or notify potential contributors of the 

Act's contribution limits. 

Complaint: On November 29, 1978, a membership organization filed a complaint alleging that the political committee: 

10 

1.	 Had violated 2 U.S.C. §441a(a)(1) by contributing 

over $1,000 to a candidate, since the committee was 

ineligible for the multicandidate contribution limits

($5,000 per candidate per election).
 

2. Had failed to report its affiliation with a nonprofit 

corporation in its Statement of Organization, despite 

alleged financial 

resulting status as a 

support 

separate 

from 

segregated 

that corporation 

fund of the 

and 

corporation. 11 CFR 100.14(c) and 100.15. 

3. Had	 neglected to register with the Commission as a 

political committee when it allegedly exceeded the 

$1,000 contribution or expenditure threshold that, at 

that time, triggered required registration. 2 U.S.C. 

§433(a). 

4. Had failed	 to report alleged expenditures. for its preprimary and pre-general election brochures. 2 U.S.C. 

§434(b). 

The Commission voted to take no action on the first 

allegation and, on the second allegation, found no reasonable cause to believe the Act had been violated. The Cornmission did, however, take action on the third and fourth 

allegations. The investigation also disclosed other violations, 

detailed below. 

GeneralCounsel Reports: 

Registration and reporting violations. Although the 

report, submitted by the committee to state officials 

after the primary, disclosed donations and costs for a 

pre-primary brochure which exceeded the $1,000 threshold, the committee had not registered with the FEC since it 

did not believe its pre-primary brochure was an endorsement of a federal candidate. The brochure urged readers to 

vote for candidates whose stand .on a certain Issue agreed 

with 

state 

the 

candidates' 

committee's. 

positions on the issue in question. The 

The brochure identified federal and 

General Counsel reported that "anv reasonable person" 

would have known the committee was endorsing a cendidate whose views agreed with the committee's and that the 

brochure clearly attempted to influence primary election 

results. Therefore, the General Counsel recommended the 

Commission find reasonable cause to believe the committee 

had violated 2 U.S.C. §433(a) by the late filing of its 

Statement of Organization. (The Statement had not been 

filed until some months after the primary.) Moreover, 

because the brochure endorsed a federal candidate, the 

expenditures and contributions connected with the brochure should have been reported to the Commission. The 

General Counsel recommended a reason to believe finding 

that the committee had violated 2 U.S.C. §434 by filing 

late pre- and post-election reports. 

Authorization/nonauthorization statement violation. The 

Office of General Counsel stated in its report that the 

pre-general election brochure presented a "clear case of 

'express advocacy.' II Similar in format to the pre-primary 

brochure, the pre-general election brochure pictured state 

and federal candidates, noted their opinions on certain 

issues, and encouraged readers to "vote for" and "elect" 

those candidates who supported the committee's stand on 

those issues. Since the committee neglected to include an 
authorization/nonauthorization statement, the General used to make expenditures for federal elections and 

Counsel recommended the Commission find reason to therefore termed "nonvoluntary." A second fund was 

• 

believe the committee had violated 2 U.S.C. §441d(l) and 

11 CFR 110.11 (c). The General Counsel also recommended 

a reason to believe finding that the committee had violated 

11 CFR 110.11(a)(l)(ii) by not including "the nameofthe 

person who made or financed the expenditure for the 

communication." Although the committee responded that 

its name and address appeared on the brochure, the General 

Counsel maintained that the brochure should have stated 

"that it was financed by" the committee. 

State/federal contribution violation. After a Commission 

investigation, the General Counsel recommended a reason 

to believe finding that the committee had violated the 11 

CFR 102.6 requirement that a committee keep either 

separate accounts for state and federal contributions or a 

single account. In the latter case, all contributions must be 

permisslble under the Act and all contributors must be 

informed of the Act's contribution limits. The committee 

indicated no separate accounting of contributions; nor did 

the solicitations notify potential contributors of the Act's 

contribution limits. 

Commission Determination: On April 25, 1979, the Commission found reasonable cause to believe that the committee had violated 2 U.S.C. §§433, 434 and 441d and 11 

CFR 110.ll(a)(I){ii) and 110.11 (c). On September 29, 

1979, the Commission found reasonable cause to believe 

that the committee had also violated 11 CFR 102.6. On 

•
 

November 21, .1979, the Commission entered into a concil­


iation agreement that included payment of a civil penalty.
 

MUR 1025: Solicitation of Members by Labor 

Union's Separate Segregated Fund 

On December 17, 1979, the Commission found no reasonable cause to beHeve that a labor organization had violated 

2 U.S.C. §441b(b)(3)(AI and (C) by requiring contributions to its separate segregated fund as a condition of 

membership and by failing to inform its members of their 

right to refuse to contribute without reprisal. 

Complaint: On September 5, 1979, six members of a labor 

organization filed a complaint with the Commission alleging 

that the union's collective bargaining agreement established, 

as a condition of membership, an automatic payroll deduction for the union's separate segregated fund. The union's 

constitution allowed for a refund of the assessment, but 

only upon request. The complainants specifically referred 

to this assessment mechanism as a "reverse checkoff," a 

violation of 2 U.S.C. §441 b(b)(3JlA) and 11 CFR 114.5(a) 

(1I. The complainants also alleged that. by failing to inform 

its members of their right to refuse to contribute, the union 

had violated 2 U.S.C. §441blb)(3)(C). Finally, by having 

been denied the freedom to refuse to contribute, the complainants believed their First Amendment rights of freedom 

of speech and association had been violated. 

for federal elections but satisfied the Act's solicita

requirements and was therefore termed "voluntary." A

its monies were not commingled with the other, nonvo

tarv fund. Since the complainants based their allegation

the operation of the nonvoluntarv fund .that was not 

for federal elections and was not, therefore, within 

Commission's jurisdiction, the General Counsel rec

mended the Commission find no reasonable cause to be

the union had violated §441b(b)(3). 

Commission Determination: On December 17, 1979, 

Commission found no reasonable cause to believe 

respondent had violated §441 b(bJl3). 

SUBSCRIPTIONS TO ELECTION LAW 

UPDATES AND ELECTION CASE LAW SERI

The following SUbscriptions are available from the F

Clearinghouse: 

Election Law Updates. This quarterly series includ

synopsis of all key federal and state election laws, a 

prehensive index to aid in research and an annual cu

lative summary. Subscription price: $11.00 a year. 

- Election Case Law. This quarterly series is simil

design and concept to the Election Law Updates

federal and state election cases are summarized 

indexed. Subscription price: $10.00 a year. 

Please do not send checks or money orders to the Com

sion. For information on how to subscribe, please w

Clearinghouse - FEC, 1325 K Street, N.W., Washin

D.C. 20463: or call 202/523-4183 locally or toll-free 

424-9530. 

• 

General Counsel Reports: Investigation by the General 

Counsel revealed that the complainants had misunderstood the operation of the union's separate segregated 

fund, which in fact comprised two funds. One fund, subsidized by the allegedly illegal checkoff deduction, was not 

11 
Presidential candidates between January 1, 1980, and July 

3, 1980. The chart includes data on each candidate's total 

submissions (and resubmissions) of private contributions 

for primary matching funds, total funds certified by the 

Commission to each candidate and the total amount of 

matching funds to which the candidate is still entitled

The summary chart below provides cumulative informa­ based (where appropriate) on the candidate's estimate of 

tion on certifications of primary matching funds made to new outstanding campaign obligations. 

FEDERAL ELECTION COMMISSION
 

YEAR·TO-DATE ACTIVITY FOR
 

PRESIDENTIAL CANDIDATES RECEIVING MATCHING FUNDS
 

No. of No. of Amount Certified Maximum
 

Name of Submis- Amount No. of Resubmis· by Commission Entitlement
 

Candidate sians Requested Contributions sians To Date Remaining*
 

ANDERSON, John B. 7 2,895,483 80,744 0 2,680,347 .00
 

BAKER, Howard H. Jr. 11 2.440,576 53,782 0 2,383,263 557,631
 

BROWN, Edmund G. Jr. 14 967,443 15,126 2 857,182 95,033
 

BUSH, George 11 6,245,656 84,474 0 5,608,654 1,751,345
 

CARTER, Jimmy 16 4,821,029 54,462 0 , 4,329,812 3,030,187
 

CRANE, Philip M. 8 2,000,338 89,840 0 1,636,638 378,500
 

DOLE, Robert J. 5 467,117 3,752 1 446,226 108,798
 

KENNEDY, Edward M. 15 3,584,453 65,023 0 3,402,434 3,957,565
 

LAROUCHE, Lyndon H. 14 567,753 10,063 12 526,164 3,972
 

REAGAN, Ronald 8 7,991,331 209,341 0 7,115,168 244,831
 

TOTALS 109 $31,981,183 666,607 15 $28,985,891 

*NOTE: Maximum Entitlement Remaining is based upon candidate's statement of net outstanding campaign obligations. 

FEDERAL ELECTION COMMISSION 

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12