September 1997 Federal Election Commission Volume 23, Number 9

Table of Contents

Court Cases

1 New Litigation

Compliance

1 MUR 4398

2 MUR 3546

3 Statistics

Semiannual PAC Count Shows

Decreases

3 Federal Register Notices

4 Advisory Opinions

6 Conferences

6 Index

MUR 4398

German National Pays

Record Penalty for

Contributions to U.S.

Elections

Thomas Kramer, a German

national and the owner of at least 17

Florida businesses, has paid a

$323,000 civil penalty to the FEC

for violating the section of the

Federal Election Campaign Act (the

Act) that prohibits contributions by

foreign nationals in connection with

U.S. elections. 2 U.S.C. §441e.

Altogether, he contributed over

$300,000 in connection with U.S.

elections.

Mr. Kramer also was cited by the

FEC for having made contributions

in the name of another when he

reimbursed his secretary, Terri

Bradley, for $21,000 in contributions to candidates and national

political committees during the 1994

election cycle. 2 U.S.C. §441f. Ms.

Bradley paid a $21,000 penalty for

her part in the contributions scheme.

The Republican Party of Florida

paid an $82,000 civil penalty for

accepting $110,000 in impermissible foreign contributions from Mr.

Kramer and one of the corporations

he owns.

Mr. Kramer’s civil penalty is the

largest ever paid by an individual to

Court Cases Compliance

New Litigation

RNC v. FEC (97-1552)

The Republican National Committee (RNC) asks the court to find

that the FEC’s dismissal of an

administrative complaint it filed

against its counterpart, the Democratic National Committee (DNC),

was contrary to law and to order the

FEC to bring itself into compliance

within 30 days.

The RNC filed the administrative

complaint with the FEC in August

1995. In it, the RNC alleged that the

DNC had used impermissible funds

to pay for a nationwide media

campaign in 1993 and 1994 to rally

support for President Bill Clinton

and other Democratic candidates in

connection with Democratic legislative proposals for health care

reform. Specifically, the RNC

charged that the DNC had acted

contrary to the Federal Election

Campaign Act (the Act) and FEC

regulations when it paid for the

media campaign with more than $3

million in nonfederal funds. No

federal dollars were spent on this

media effort.

Commission regulations state that

if a political committee has both

federal and nonfederal accounts,

then it must allocate its administra-

(continued on page 6) (continued on page 2)
Federal Election Commission RECORD September 1997

2

Federal Election Commission

999 E Street, NW

Washington, DC 20463

800/424-9530

202/219-3420

202/501-3413 (FEC Faxline)

202/219-3336 (TDD for the

 hearing impaired)

800/877-8339 (FIRS)

John Warren McGarry,

Chairman

Joan D. Aikens, Vice Chairman

Lee Ann Elliott, Commissioner

Danny L. McDonald,

 Commissioner

Scott E. Thomas, Commissioner

John C. Surina, Staff Director

Lawrence M. Noble, General

 Counsel

Published by the Information

 Division

Louise D. Wides, Director

Angela Rucker, Editor

http://www.fec.gov

Compliance

(continued from page 1)

the Commission, and the total sum

of civil penalties attached to this

case—$426,000—is among the

largest in the FEC’s history.

Law, Regulations and Advisory

Opinions

In addition to the broad ban at 2

U.S.C. §441e that prohibits any

foreign national from contributing to

federal, state or local elections,

Commission regulations at 11 CFR

110.4(a) state further that it is

unlawful for any foreign national to

“direct, dictate, control, or directly

or indirectly participate in the

decision-making process of any

person, such as a corporation...”

with regard to decisions concerning

the making of contributions in

connection with such elections.

One exemption from this rule

allows foreign nationals to contribute to party committees so long as

those funds are used solely for

noncampaign-related, redistricting

issues. AOs 1982-14 and 1981-35.

Additionally, it is unlawful for

any person to make a contribution in

the name of another person or to

knowingly permit his or her name to

be used in such a scenario. 2 U.S.C.

§441f.

Violations

Mr. Kramer made a total of

$322,600 in impermissible contributions to federal, state and local

political committees in his own

name ($13,000), through 17 companies that he owned and controlled

($287,600), by reimbursing his

secretary ($21,000) and through

unknown intermediaries ($1,000).

Additionally, Mr. Kramer

contributed a total of $205,000 to

the Republican Party of Florida. The

party, in turn, deposited $95,000 of

the donations in a segregated

redistricting account—a permissible

donation—and deposited the

remainder in its federal and

nonfederal accounts—prohibited in

U.S. elections. The party said it was

unaware that Mr. Kramer was a

foreign national or that the corporation, through which more than half

of the contributions were received,

was controlled by a foreign national.

Mr. Kramer’s secretary was

directed to make a $1,000 contribution to the Mitchell for Senate

committee and a $20,000 contribution to the Democratic Senatorial

Campaign Committee. She was then

reimbursed for the full amounts by

Mr. Kramer.

This MUR, or Matter Under

Review, was initiated by Mr.

Kramer after news accounts

revealed that his contributions were

most likely illegal. Following a

review of the information, but prior

to finding probable cause to believe

that Mr. Kramer, Ms. Bradley or

the Florida Republicans had

violated the law, the Commission

entered into conciliation agreements with them. ✦

MUR 3546

Coordinated Party

Expenditures Result in

Excessive Contribution

President Bill Clinton’s 1992

Presidential primary committee, the

Clinton for President Committee,

and the Democratic National

Committee (DNC) each paid

$10,000 civil penalties to the FEC

for having violated the election law

in connection with a televised town

hall meeting that included a toll-free

number for viewers.

During the 30-minute town hall

meeting that was televised nationwide in June 1992, then Gov.

Clinton answered questions from the

television audience, while a tollfree, 800 number periodically

appeared on the screen. People who

called the number were offered

three options:

• Receive the President’s “Plan for

America’s Future,”

• Leave a message for Mr. Clinton,

or

• Make a contribution to the Clinton

for President Committee, his

primary election campaign committee.

The DNC paid for both the

broadcast and the 800 number,

treating them as coordinated party

expenditures under 2 U.S.C.

§441a(d). Because the 800 number

included a solicitation for contributions to Mr. Clinton’s primary

election committee, a portion of the

DNC’s expenditure had to be

considered a contribution to Mr.

Clinton’s primary campaign rather

than a coordinated party expenditure

made in connection with the general

election. Multicandidate political

committees have a $5,000 limit per

election for contributions to any

candidate or candidate’s authorized

committee. 2 U.S.C.

§441a(a)(2)(A). Because the portion

of the broadcast and 800 number

expenditures attributable to the

primary amounted to $120,000,

which exceeds the $5,000 limit, the
September 1997 Federal Election Commission RECORD

3

Semiannual PAC Count

Shows Decrease

As of July 1997, there were 3,875

political action committees, or

PACs, registered with the FEC. That

figure represents a drop of 204

PACs since the last survey was

taken in December 1996.

The table below shows midyear

and year-end PAC figures compiled

by the FEC since 1990. For a

complete listing of PAC statistics

dating back to 1974, go to the FEC’s

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

request a copy of the FEC’s July 25

Press Release from the Public

Records Office at 1/800-424-9530

(press 3). ✦

Statistics Federal Register

 Federal Register notices are

available from the FEC’s Public

Records Office.

Notice 1997-12

Definition of “Member” of a

Membership Association:

Advance Notice of Proposed

Rulemaking (62 FR 40982, July

31, 1997)

Notice 1997-13

Filing Dates for New York

Special Election (62 FR 43733,

August 15, 1997)

DNC made an excessive contribution to Mr. Clinton’s primary

campaign. The Clinton committee

violated the Act at 2 U.S.C.

§441a(f) when it accepted the

excessive contribution from the

DNC.

Furthermore, because the televised town hall meeting included

express advocacy1

 and a solicitation

for contributions, it had to include a

disclaimer stating who paid for and

who authorized the communication.

2 U.S.C. 441d(a). The DNC

included only a partial disclaimer in

the broadcast. It stated that it paid

for the town hall meeting, but failed

to say whether or not the payment

was authorized by a candidate.

This MUR, or Matter Under

Review, was initiated after the FEC

received a complaint from the

Republican National Committee.

The Commission found probable

cause to believe that a violation of

the Act had occurred and entered

into a conciliation agreement with

the candidate and the party committee. ✦

1

 As evidence of express advocacy, the

conciliation agreement stated that the

television program started with people

stating that they were undecided voters.

Mr. Clinton indicated, near the

beginning, that he wanted to help

listeners make the right decision in the

Presidential race. Later, Mr. Clinton

explained his position on a variety of

issues important in the 1992 Presidential campaign. In response to a question

about affordable health care, Mr.

Clinton said, “I will do that if elected

President.”

Trade/ Corp. w/o

Member/ Coop- Capital NonCorporate Labor Health erative Stock connected 1 Total

Jul. ’90 1,782 346 753 58 139 1,115 4,193

Dec. ’90 1,795 346 774 59 136 1,062 4,172

Jul. ’91 1,745 339 749 57 137 1,096 4,123

Dec. ’91 1,738 338 742 57 136 1,083 4,094

Jul. ’92 1,731 344 759 56 144 1,091 4,125

Dec. ’92 1,735 347 770 56 142 1,145 4,195

Jul. ’93 1,715 338 767 55 139 1,011 4,025

Dec. ’93 1,789 337 761 56 146 1,121 4,210

Jul. ’94 1,666 336 777 53 138 963 3,933

Dec. ’94 1,660 333 792 53 136 980 3,954

Jul. ’95 1,670 334 804 43 129 1,002 3,982

Dec. ’95 1,674 334 815 44 129 1,020 4,016

Jul. ’96 1,645 332 829 43 126 1,058 4,033

Dec. ’96 1,642 332 838 41 123 1,103 4,079

Jul. ’97 1,602 332 826 41 118 953 3,8752

1 Nonconnected PACs must use their own funds to pay fundraising and administrative expenses, while the other categories of PACs have corporate or labor “connected organizations” that are permitted to pay those expenses for their PACs. On

the other hand, nonconnected PACs may solicit contributions from the general

public, while solicitations by corporate and labor PACs are restricted.

2

 During the first six months of 1997, 227 PACs were administratively terminated

because of inactivity.

Midyear and Year-End PAC Counts,

July 1990-July 1997
Federal Election Commission RECORD September 1997

4

Advisory

Opinions

AO 1997-9

Electronic Collection of

Member Traders’ PAC

Contributions

The Chicago Board of Trade’s

(CBOT’s) PAC may collect voluntary contributions from its member

traders through a monthly electronic

deduction and transfer of funds from

the traders’ personal trading accounts maintained by trading firms.

It is permissible for a trading firm to

perform these functions so long as

the firm and the CBOT follow

guidelines set out in this advisory

opinion.

The CBOT is a licensed commodity exchange, and the Auction

Markets Political Action Committee

(AMPAC) is its separate segregated

fund (SSF). The CBOT identifies as

its members those who own a seat

on the exchange, lease a self-owned

or firm-owned seat or are named a

member on a firm-owned seat.

Typically, traders conduct their

business through a trading firm—a

partnership, corporation or limited

liability company—which clears the

trades executed by its members.

These trading firms are also identified as members by the CBOT.

Role of the CBOT

While the Act prohibits corporate

contributions or expenditures in

connection with a federal election, it

does allow such businesses to

establish and pay the administrative

costs of an SSF. 2 U.S.C.

§441b(b)(2)(C). An SSF established

by a corporation without capital

stock, such as a membership association, may solicit contributions

from its members. The Commission

assumed that the CBOT was a

membership organization and that

the member traders who would be

using their individual trading

accounts qualified as members

under the Act. AO 1997-5. (See the

July 1997 Record.)

Currently, the CBOT sends each

member firm a monthly statement

letting it know how much the CBOT

is owed by all the individual members who maintain trading accounts

with the firm. The firm collects the

fees from its traders by electronically deducting the amounts from

their personal accounts. Those

amounts are then electronically

transferred from the firm’s bank

account to the CBOT’s account.

The proposal for deducting and

transferring SSF contributions

would work similarly. However, the

contributions would be separated

from the other monthly fees and

automatically transferred from the

CBOT’s bank account to AMPAC’s

bank account. The CBOT would

receive authorization from member

traders for the check-off before it

proceeded with the deductions and

transfers. Under the proposal, at the

time of a transfer, a trader would

have to satisfy the margin and risk

exposure requirements of the CBOT

and the firm, and all other currently

owed obligations. The trader would

have to have enough left over in his

or her account to cover the contribution amount. In the event that an

individual trader did not have

sufficient funds in his or her account

to cover the contribution, no deduction or transfer would occur. This

would prevent AMPAC from

receiving a prohibited corporate

contribution or possibly an excessive contribution, if the member

firm was a partnership or limited

liability corporation. 2 U.S.C.

§§441b(a), 441a(a)(1)(C) and

441a(f), and 11 CFR 110.1(e).

It also would avoid a firm’s

making a contribution in the name

of one of its individual traders. 2

U.S.C. § 441f. Contributions must

be transferred to the CBOT based

upon the status of the trader’s

account at the time of the transfer,

not any period prior to that.

In transferring SSF contributions

from its account to AMPAC’s

account, the CBOT would be

performing the functions of a

collecting agent. 11 CFR 102.6(b).

By virtue of this status, the CBOT

could pay the solicitation and

transfer costs it incurred for soliciting and transmitting the contributions it received. So long as the

CBOT did not engage in any other

activities that influenced federal

elections, it could serve as a collecting agent without registering as a

political committee and reporting to

the FEC. Contributions of $50 or

less would have to be transmitted

from the CBOT to AMPAC within

30 days; contributions that are more

than $50 would have to be transmitted within 10 days. 11 CFR

102.8(b)(1) and (2).

Under FEC regulations, one

check from a contributing member

to the collecting agent, representing

both a contribution and other fees, is

permissible so long as the funds are

drawn on a personal account or

nonrepayable corporate drawing

account of the member. 11 CFR

102.6(c)(3). Although, in this case,

the deduction and transfer are not

carried out with an actual check, the

CBOT’s electronic transaction

contains the same protections as

those described in AO 1990-4,

which addressed combining a

contribution and a membership fee

in one written check.

Role of Member Clearing Firms

The member firm would be

involved in transmitting contributions to CBOT, but it would qualify

as neither a connected organization

of AMPAC nor a collecting agent.

That means that the cost to the

trading firm for transmitting contributions and monitoring the accounts

would be considered an in-kind

contribution unless one of two

possible exemptions applied.

Under Commission regulations,

legal and accounting services

provided to political committees are

not considered contributions so long

as the person paying for such

services is the regular employer of
September 1997 Federal Election Commission RECORD

5

AO 1997-11

Use of Campaign Funds for

Language Program

Congresswoman Lucille RoybalAllard may use campaign funds for

tuition, travel and other related

expenses to participate in a Spanish

language immersion program. Such

expenses do not constitute personal

use.

Ms. Roybal-Allard, who represents a California congressional

district with a large constituency of

Spanish speakers and people who

speak limited English, plans to

enroll in a language immersion

program to help her be more effective and responsive to those constituents’ needs and concerns. She

Correction

Acceptable depositories for

political committees registered with

the FEC include federally chartered

institutions or banks where accounts

are insured by the Federal Deposit

Insurance Corporation or the National Credit Union Administration.

A footnote to the article summarizing

Advisory Opinion 1997-6, which

appeared in the August Record,

incorrectly stated that bank accounts

insured by the Federal Savings and

Loan Insurance Corporation (FSLIC)

also were acceptable depositories.

The FSLIC was abolished in 1989. ✦

the individual rendering the services

and the services are rendered solely

to ensure compliance with the Act

and the provisions in title 26. 11

CFR 100.7(b)(14). In this case,

reviewing traders’ accounts and

setting up the process for deducting

contributions and sending them to

the CBOT (which includes, as an

integral part, a method for ensuring

that sufficient funds are available)

would be for the purpose of ensuring AMPAC’s compliance with the

Act. Consequently, regular employees of the member firms could carry

out such functions without making

an in-kind contribution. AMPAC

would have to report the value of

the service as a memo entry on

Schedule A.

The second exemption would

allow the CBOT to treat the member

firms’ expenses as exempt administrative costs so long as it paid the

member firms for these costs. The

CBOT would pay the firms on a

periodic basis or, if the actual cost

were difficult to determine, it could

contract with member firms for an

amount based on a reasonable

estimate of the costs of such services,

and thereafter pay that amount.

Date Issued: July 31, 1997;

Length: 10 pages. ✦

Advisory Opinion Requests

Advisory opinion requests are

available for review and comment in

the Public Records Office.

AOR 1997-15

Establishment of nonconnected PAC

by incorporated membership

organization’s CEO (Kenneth

Nickalo; July 21, 1997; 2 pages plus

23-page attachment)

AOR 1997-16

Methods of providing PAC endorsements of federal candidates to

restricted class (Oregon Natural

Resources Council Action Federal

PAC; July 31, 1997; 2 pages plus

24-page attachment) ✦

Alternative Disposition of

Advisory Opinion Request

AOR 1997-08

This advisory opinion request,

submitted by Congressman Lamar

Smith and his authorized committee,

was withdrawn from consideration

on July 14. Mr. Smith had requested

an opinion on the use of campaign

funds to rent space in a dwelling

that he owns. ✦

wants to enroll in a program that

could cost as much as $5,000.

Candidate committees may not

convert campaign funds to the

personal use of the candidate or any

other person. 11 CFR 113.1(g) and

113.2(d). FEC guidelines define

personal use as “any use of funds in

a campaign account...that would

exist irrespective of the candidate’s

campaign or duties as a federal

officerholder.” Among the personal

use examples listed at 11 CFR

113.1(g)(1)(i) is tuition payments,

unless those payments are for

training campaign staff. In addition, the regulations state that

excess campaign funds may be

used to pay for travel for the

candidate to participate in functions

so long as they are directly connected to bona fide official responsibilities. 11 CFR 113.2(a).

Because effective communication

with constituents is part of a

member’s representative function,

tuition for the immersion program is

directly related to Ms. RoybalAllard’s duties as a congresswoman.

The travel expenses related to the

immersion program would not exist if

Ms. Roybal-Allard were not a federal

officeholder. Consequently, campaign

funds may be used to pay for them. In

making this determination, the

Commission emphasized the importance of the limited duration of classes

(two weeks) and the program’s

immediate link to Ms. RoybalAllard’s duties as she interacts with

constituents in her district.

The optional add-ons in each of

the programs Ms. Roybal-Allard is

considering—golfing in the case of

one program and after-class excursions and a trip to Acapulco in the

case of another—do not have a

substantive link to the immersion

program. Payments for these

expenses would therefore be

deemed a personal expense and

could not be paid for with campaign

funds. Any campaign committee

disbursements that are permissible

in this advisory opinion, but are not

campaign related, should be reported as “other disbursements.”

Date Issued: July 25, 1997;

Length: 4 pages. ✦
Federal Election Commission RECORD September 1997

6

 The FEC has set dates for three

regional conferences, and tentative

dates for four others for 1997 and

1998.To register for any of the

three scheduled conferences, call

Sylvester Management at 1/800-

246-7277 or send an e-mail

message to

TSYLVESTER@WORLDNET.ATT.NET.

Seattle

Date: September 24-26, 1997

Location: Cavanaugh’s Inn

Registration: $175

Hotel rate: $134

Candidates, political parties,

corporate and labor organizations

Atlanta

Date: October 15-17, 1997

Location: Sheraton Colony Square

Registration: $180

Hotel rate: $149

Candidates, political parties,

corporate and labor organizations

Washington, DC

Date: November 6-7, 1997

Location: Madison Hotel

Registration: $180.50

Hotel rate: $124

Corporate and labor organizations

 Read future issues of the Record

to get more scheduling information

for these conferences:

Washington, DC

December 1997

Trade and membership associations

Washington, DC

February 1998

Candidate committees

Denver

March 1998

Candidates, political parties,

corporate and labor organizations

Washington, DC

April 1998

Nonconnected committees

 For more information, call the

FEC at 1/800-424-9530 (press 1).

FEC Sets Conference

Schedule

Index

The first number in each citation

refers to the “number” (month) of

the 1997 Record issue in which the

article appeared. The second

number, following the colon,

indicates the page number in that

issue. For example, “1:4” means

that the article is in the January

issue on page 4.

Advisory Opinions

1996-35: Status of Green Party as

national committee, 1:10

1996-42: SSF disaffiliation following corporate spin off, 1:11

1996-45: Use of campaign funds,

1:12

1996-46: Continuation of exemption

from select FECA reporting

provisions, 4:7

1996-48: Application of “news

story” exemption, 2:5

1996-49: Affiliation between PAC

of joint venture partnership and

SSF of corporate partner, 3:7

1996-50: Disaffiliation of SSFs, 3:9

1996-51: Qualification as state

committee of political party, 3: 9

1996-52: Resolicitation of excess

campaign funds for nonfederal

campaign, 3:10

1997-1: Use of excess campaign

funds to establish foundation, 5:8

1997-2: Use of campaign funds for

congressional retreat fees, travel,

5:8

1997-3: Qualification as state

committee of political party, 6:11

1997-4: Application of contribution

limit to limited liability company,

6:12

1997-5: Qualification of lessee of

trading “seat” on Exchange as

member, 7:6

1997-6: Reinvestment by political

committee of investment income,

8:8

1997-7: Status as state committee of

political party, 8:9

1997-9: Collection of PAC contributions from individual members

through electronic debiting of

Court Cases

(continued from page 1)

tive and generic expenses between

those two accounts. 11 CFR 102.5.

During a non-presidential election

year, national party committees

must allocate at least 60 percent of

such expenses to the federal account. 11 CFR 106.5(b)(2)(ii).

The Commission reviewed the

RNC’s complaint—designated

MUR 4246—and voted unanimously to close the case. This vote

came after the Commission had

failed to accept a recommendation

from the Commission’s general

counsel that it accept a DNC

proposal that would have had the

Democrats admit violating the Act

and pay an undisclosed penalty.1

In addition to the alleged violations of the Act and Commission

regulations, the RNC’s court

complaint points to a 1995 advisory

opinion from the Commission that,

the RNC believes, describes a

situation that is legally indistinguishable from the DNC’s health

care reform campaign. In AO 1995-

25, the Commission told the RNC

that it had to allocate, between its

federal and nonfederal accounts, its

expenditures for a media campaign

that highlighted several Republican

legislative initiatives. The RNC

states that the Commissioner who

cast the dissenting vote to adopt the

general counsel’s recommendation

for MUR 4246 had voted to approve

AO 1995-25.

U.S. District Court for the

District of Columbia, 97-1552, July

7, 1997. ✦

1

 Three commissioners voted to accept

the general counsel’s recommendation,

one commissioner voted against the

recommendation and one commissioner

recused himself from voting on this

issue. There is one vacancy on the sixmember Commission.
September 1997 Federal Election Commission RECORD

7

their trading accounts held with

member firms, 9:4

1997-11: Use of campaign funds, 9:5

Court Cases

FEC v. _____

– California Democratic Party, 7:5

– Charles Woods for U.S. Senate, 4:6

– Christian Action Network, 1:5;

5:5; 8:4

– Christian Coalition, 7:2

– DSCC (95-2881), 3:2; 8:3

– Fund For a Conservative Majority,

1:5

– Kalogianis, 5:3

– Legi-Tech, 7:4

– McCallum, 2:4

– Orton, 6:6

– Parisi, 1:4

– Public Citizen, 4:6

– Williams, 2:3; 7:5

_____ v. FEC

– Akins, 2:1; 7:5

– Bush-Quayle ‘92 Primary Committee, 3:5

– Clark, 5:1

– Clifton, 8:1

– Common Cause (96-5160), 5:4

– DCCC (96-0764), 1:4

– DNC (96-2506), 1:5; 5:5

– DNC (97-676), 6:7

– DSCC (96-2184), 1:2; 8:3

– Gottlieb, 7:5

– Hagelin, 6:7

– Hooker, 1:5

– Jones, 6:7

– Minnesota Citizens Concerned for

Life, 7:2; 8:4

– NRCC (96-2295), 1:2

– Reilly, 1:4

– Right to Life of Dutchess Co.,

Inc., 6:8

– RNC (94-5248), 2:5

– RNC (97-1552), 9:1

Reports

Electronic Filing, 2:1; 5:9; 7:10

July Reporting Reminder, 7:1

Schedule for 1997, 1:6

Special Election, New Mexico, 4:3

Special Election, Texas, 3:6; 4:3

800 Line

Amended reports, 4:2

Debt settlement and committee

termination, 1:8

Change of Address

Political Committees

 Treasurers of registered political committees automatically receive the

Record. A change of address by a political committee (or any change to

information disclosed on the Statement of Organization) must, by law, be

made in writing on FEC Form 1 or by letter. The treasurer must sign the

amendment and file it with the Secretary of the Senate or the FEC (as

appropriate) and with the appropriate state office.

Other Subscribers

 Record subscribers who are not registered political committees should

include the following information when requesting a change of address:

• Subscription number (located on the upper left corner of the mailing label);

• Subscriber’s name;

• Old address; and

• New address.

 Subscribers (other than political committees) may correct their addresses by

phone as well as by mail.
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Federal Election Commission RECORD September 1997