fh

FEDERAL ELECTION COMMISSION

January1990 999 E Street NW Washington DC 20463 Volume 16, Numb

•

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, '_ {~,,~v~-r-;"ir~-:·-.- r • \: • •

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COMMISSIONERS ELECT NEW

OFFICERS FOR 1990

On December 19, 1989, the

Federal Election Commission

unanimously elected Lee Ann Elliott

as Chairman and John Warren McGarry

as Vice Chairman. Their one-year

terms began January 1, 1990. Mrs.

Elliott succeeds Danny L. McDonald

in the chairmanship, and Mr. MCGarry

succeeds Mrs. Elliott as Vice

Chairman.

Commissioner Elliott, a

Republican, has been a member of the

Commission since 1981. Prior to her

appointment, she was Vice President

of Bishop, Bryant & Associates,

Inc., a washington, D.C., political

consulting firm. From 1970 to 1979,

she served as Associate Executive

Director of the American Medical

political Action Committee (AMPAC),

having served as Assistant Director

from 1961 to 1970. Commissioner

Elliott also served on the board of

directors of the American

Association of political Consultants

and on the Board of the Chicago Area

Public Affairs Group, of which she

is a past president. She has been

a member of the public Affairs

Committee of the United States

Chamber of Commerce. In 1979, she

received an Award for Excellence in

Serving Corporate Public Affairs

from the National Association of

Manufacturers.

A native of St. Louis, Mrs.

Elliott graduated from the

University of Illinois and

Northwestern University's Medical

Association Management Executive

program. Her term as Commissioner

expires in 1993.

Commissioner MCGarry, a

Democrat, was first appointed to the

FEC in 1978, after serving as

Special Counsel on Elections to the

House Administration Committee.

Prior to that, he combined private

law practice with service as Chie

Counsel for the Special Committee 

Investigate Campaign Expenditures

special House committee establishe

by Congress after every election

until 1972. Before his work with

Congress, Mr. McGarry served as

Assistant Attorney General for th

Commonwealth of Massachusetts.

Mr. McGarry graduated cum lau

from Holy Cross College, did

graduate work at Boston Universit

and earned a J.D. from Georgetown

university Law School. Recently

reappointed to the Commission by

President Bush, Mr. McGarry's term

on the FEC expires in 1995.

TABLE OF CONTENTS

1 COMMISSIONERS: Officers Elected

PUBLIC FUNDING

2 Presidential Fund still Shrink

REGULATIONS

3 Forei9n National Rules Revised

3 Revised Affiliation & Earmarkin

Rules Take Effect

3 REPORTS: 1990 Schedule

9 ADVISO~Y OPINIONS

12 AUDITS: Fulani Committee

13 COURT CASES: FEC v. Franklin

COMPLIANCE

13 Publicly Released MURs

STATISTICS

15 PAC Activity, 1987-88

16 Final Report Issued

800 LINE

17 Combined DueS/Solicitations

19 Designating a principal Campai

Committee

20 PUBLICATIONS: New Party Guide
January 1990 FEDERAL ELECTION COMMISSION Volume 16, Num

FEC REPEATS WARNING ABOUT SHRINKING

PRESIDENTIAL ELECTION CAMPAIGN FUND

updating a warning sent to

Congress and the President in

April, former Chairman Danny L.

McDonald in November projected that,

if the current taxpayer checkoff

rate continues, the Presidential

Election Campaign Fund will be

exhausted by the end of the 1996

elections.

As Commissioner McDonald

(Chairman of the Commission during

1989) pointed out in his November 1

letter to Congress and the

president, the amount of money

taxpayers checked off for

Presidential elections on their

income tax forms declined slightly

in 1988. Moreover, Commissioner

McDonald said, based on the returns

Presidential Election Campaign Fund

Post-Election Balance

Millions of Dollars

filed during the first eight mon

of 1989, the Commission estimate

that even fewer dollars will be

checked off on 1989 tax returns. 

this trend continues,1I Commissio

McDonald said, "by the end of th

1996 Presidential campaign, the

balance [of the Presidential

campaign Fund] will be in a nega

position."

Commissioner McDonald repeate

his April suggestion that Congre

modify the current public funding

process, which was set up in the

early 1970's and which has gover

each presidential election since

1976. The current law provides 

private contributions may be use

make up for any shortfall in

available public funds. Should th

situation arise, however, the fo

Chairman warned that "serious

distortions to the Presidential

election process will occur." (F

more information, see page 2 of 

May Record.)

_ Actual

..... Projected

100 .-------------------~-----------

50 I--~-----

o

-50 I---~----

-100 ~------

FEDERAL ELECTION COKMISSION

999 E street, N.W.

Washington, DC 20463

800/424-9530 202/376-3120 202/376-3136(TDD)

Lee Ann Elliott, Chairman

John Warren MCGarry, Vice Chairman

Joan Aikens

Thomas J. Josefiak

Danny L. McDonald

Scott E. Thomas

2

Walter J. Stewart, Secretary of th

Senate, Ex Officio 

Donnald K. Anderson, Clerk of the 

House of Representatives, Ex Off
FEDERAL ELECTION COMMISSIOI\J Volume 16, Numb

ELECTION YEAR REPORTING

Nineteen ninety is a

Congressional election year. All

candidates for federal

office--includiog Presidential

candidates--must file reports.

Filing dates are listed on page 5

Reporting requirements are as

follows:

(continu

Congressional Candidates

Active in 1990 Elections

During 1990, principal campai

committees of candidates active i

1990 elections are required to fi

pre-primary, pre-runoff (if held)

and pre- and post-general electio

reports, as appropriate. They mu

also file quarterly reports.

In addition, any committee th

receives a contribution of $1,000 

more between 20 and 2 days before 

election must notify the appropri

filing offices (see below). This

notice must reach the filing offi

within 48 hours after the

committee's receipt of the

contribution. 11 crR 104.5(f).

If a Congressional candidate 

more than one authorized committe

the principal campaign committee

must also file a consolidated rep

on FEC Form 3Z. 11 CFR 104.3(£).

For details, see page 14 of the

FEC's campairn Guide for

Congressiona Candidates and

Committees.

CANDIDATE COMMITTEES

The final revisions to the ru

on affiliation, transfers,

prohibited contributions, the ann

contribution limit for individual

and earmarked contributions were

published August 17, 1989, in the

Federal Register along with the

Explanation and Justification of 

new rules. See 54 Fed. Reg. 3409

For a summary of the new rules, s

the October and November 1989 issu

of the Record.

3

January 1990

NEW REGULATIONS TAKE EFFECT

The Commission's recent

amendments to sections 110.3 through

110.6 of the regulations became

effective November 24, 1989, with an

announcement in the Federal

Register. See 54 Fed. Reg. 48580.

PROHIBITION ON FOREIGN

NATIONALS REVISED

The Commission has transmitted

to Congress revised rules concerning

expenditures by foreign nationals

(11 CFR 110.4). The amendments add

language to clarify that foreign

nationals may not:

o Make expenditures (including

independent expenditures) in

connection with any local, state

or federal election; or

o Participate directly or indirectly

in the decision-making process of

any person, such as a corporation,

labor organization or political

committee, with regard to that

person's federal or nonfederal

election-related activities.

Based on section 441e of the

Federal Election Campaign Act, the

current rules specify that

contributions by foreign nationals

are prohibited. Although the Act

does not explicitly refer to

expenditures by foreign nationals,

the statute generally prohibits

expenditures by persons prohibited

from making contributions (such as

corporations and labor

organizations). The Commission has

consistently understood expenditures

by foreign nationals to be

prohibited. The explicit

prohibition against participation by

foreign nationals in

election-related activities is

consistent with FEC advisory

opinions. See AOs 1989-20, 1982-10

and 1980-100.

The final rules were published i~

the Federal Register on November 24,

1989, along with an Explanation and

Justification. See 54 Fed. Reg.

48580. An effective date will be

announced after the rules have been

before congress for thirty

legislative days.
January 1990 FEDERAL ELECTION COMMISSION

Congressional Candidates

Not Active in 1990 Elections·

The principal campaign

committees of Congressional

candidates not active in 1990

elections (e.g., committees

authorized by candidates seeking

election in future years or

committees active in previous years

that have outstapding debts) must

continue to report semiannually.

Note that campaigns with more

than one authorized committee must

also file a consolidated report.

See above.

Presidential Committees

All committees authorized by

Presidential candidates must file on

either a monthly or a quarterly

basis during 1990.

PARTIES AND PACS

All unauthorized political

committees (i.e., party committees,

separate segregated funds and

nonconnected committees) are

required to file on either a

quarterly or a monthly schedule in

1990.

Quarterly Filers

Those committees that filed

semiannually in 1989 must file

quarterly in 1990 (unless they

switch to a monthly schedule--see

below). Quarterly filers also must

file a post-general election report.

In addition, quarterly filers that

make contributions or expenditures

to -support or oppose specific

candidates in 1990 must also file

appropriate pre-election reports

(primary, runoff and general, as

applicable) if their financial

activity has not been previously

disclosed.

Monthly Filers

Committees filing on a monthly

schedule must file pre- and

post-general election reports in

lieu of their November and December

monthly reports, and a year-end

report, due January 31, 1991.

INDEPENDENT SPENDERS

Note that any independent

expenditures aggregating $1,000 or

more and made between 20 and 2 days

before an election must be reported

4

Volume 16, Numb

within 24 hours after the

expenditures are made.

LATE FILING

The Federal Election Campaign

Act does not permit the FEC to wa

reporting requirements or grant

extensions on filing deadlines un

any circumstances. Failure to fi

by the dates listed in the chart

could result in enforcement actio

by the FEC.

CHANGING FILING SCHEDULE

PACs and party committees may

wish to file monthly during 1990 

avoid filing pre-primary election

reports, which may be required fro

committees filing quarterly durin

an election year. (See above.) 

committee that wants to change it

filing schedule must notify the

Commission in writing when filing 

report under its current schedule

A committee may not change its

filing frequency more than once a

year. 11 CFR 104.5(c). The FEC

requests that Presidential

committees also inform the

Commission in writing if they dec

to change their reporting schedu

WHERE REPORTS ARE FILED

Committees must file all repo

simultaneously with the appropria

federal and state officials. 11 

108.5.

Filing with the Federal Governmen

o House Candidates: principal

campaign committees and commit

supporting or opposing House

candidates file with the Clerk 

the House, Office of Records an

Registration, 1036 Longworth Ho

Office Building, Washington, DC

20515.

o Senate Candidates: principal

campaign committees and commit

supporting or opposing Senate

candidates file with the secret

of the Senate, Senate Public

Records, Hart Senate Office

Building, Room 232, Washington, 

20510.

o All Others: PACs, party commit

and principal campaign committe

of Presidential candidates file

with the Federal Election

Commission, 999 E Street, NW,

Washington, DC 20463.
January 1990 FEDERAL ELECTION COMMISSION Volume 16,Numb

FILING DEADLINES*

*Reports sent by registered or

certified mail must be postmarked

by the filing date (except in the

case of the pre-general report).

Reports mailed first class or hand

delivered must be received by the

filing date.

**If the pre-general report is

sent by registered or certified

mail, it must be postmarked three

days before the filing date. If

sent by first class mail or hand

delivered, the report must be

received by the filing date.

***Committees may also have to fi

pre-primary and pre- and postgeneral reports.

GENERAL ELECTION

Filing

Date*

April 

July 15

Oct. 15

Jan. 31

Filing

Date·

Feb. 20

Mar. 20

Apr. 20

May 20

June 20

July 20

Aug. 20

sep. 20

Oct. 20

Oct. 2

Dec. 6

Jan. 31

(continu

October 2

October 2

December 

December 

November 

November 

october 1

Close of

Books

Mar. 31

June 30

Sept. 30

Dec. 31

FILERS···

Quarter

QUARTERLY

First

Second

Third

Fourth

MONTHLY REPORTS

Report Period

Covered

1/1-1/31

2/1-2/28

3/1-3/31

4/1-4/30

5/1-5/31

6/1-6/30

7,.<1-7/31

8/1-8/31

9/1-9/30

10/1-10/17

10/18-11/26

11/27-12/31

February

March

April

May

June

JUly

August

September

October

Pre-General

Post-General

Year-End

Post-General Report

Close of Books

Registered/Certified

Mail Date

Filing Date*

Date of Election

Pre-General Report*.

Close of Books

Registered/Certified

Mail Date

Filing Date*

5

CONFERENCE FOR PACS IN JANUARY On January 17, the FEC will

host a day-long conference on

political activity by

corporations, labor organizations

and trade associations.

The conference will provide

opportunities to learn how to set

up a separate segregated fund

(PAC) and how to comply with the

rules on registration, reporting

and fundraising. Special programs

will also be offered for more

advanced committee personnel.

The conference will be held on

January 17 at the Sheraton

Washington Hotel in washington,

D.C. The fee is $112. For more

information, call the FEC at

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

Filing with State Governments

o House and Senate Candidates: The

principal campaign committees of

Congressional candidates must file

a copy of every report and

statement with the Secretary of

State (or other election official,

as appropriate> of the state in

which the candidate is seeking

office. 11 CFR 108.3.

o Presidential Candidates: The

principal campaign committees of

Presidential candidates must file

copies of reports and statements

with the Secretary of State or the

appropriate elections official of

the state in which the committee

makes campaign expenditures.

These reports must contain all

financial transactions pertaining

to that state during the reporting

period covered. 11 CFR 108.2

o All Others: PACs and party

committees makin9 contributions or

expenditures in connection with

House and Senate races file

reports and statements in the

state in which the candidate seeks

election. The law requires a copy

of only that portion of the report

applicable to the candidates who

seek election from that state.

Committees supporting Presidential

candidates must file in the states

in which the Presidential

committee and donor committee have

their respective headquarters.
January 1990 FEDERAL ELECTION COMMISSION Volume 16, Numb

CONGRESSIONAL PRIMARY ELECTION REPORTS DUE IN 1990

12-Day Pre-Election Report

State or

Territory

Date of

Election

Close of

Books**

Reg./Cert.

Mailing Date

Filing

Date

Alabama*

Runoff

June 5

June 26

May 16

June 6

May 21

June 11

May 24

June 14

6

March 20 February 28 March 5

June 12 May 23 May 28****

September 10

May 10

March 8

April 26

August 30

August 30

August 27

August 23

September 20

August 2

May 17

May 31

May 24

August 16

October 25

November a

May 24

July 26

May 17

July 5

July 26

August 30

September 24

October 25

May 31

August 30

August 24

August 27

May 14

May 31***

August 27

August 20

September 17

July 2

July 23

August 17   August 20

September 3** * September 3

August 13

october 22

November 8***

May 21

July 30

August 27

August 12

August 26

May 9

May 23

May 16

July 25

August 22

August 22

August 15

September 12

August 8

October 17

October 31

August 19

June 27

July 18

August 22

July 17

August 7

August 28

September 22 September 2 September 7

May 22 May 2 May 7

August 14

September 11

November 6

November 20

September 8

September 1

September 15

September 11

September 4

October 2

June 5

September 11

May 29

June 12

May 8 April 18 April 23

June 5 Hay 16 May 21

August 7 July 18 July 23

May 29 May 9 May 14

September 11 August 22 August 27

October 6 September 16 September 21

November 6 october 17 October 22

Delaware*

Indiana*

Iowa*

Idaho*

Oistrict of

Columbia

Arkansas*

Runoff

Connecticut

California

Georgia*

Runoff

Maryland

Florida

Runoff

Illinois*

Hawaii

Arizona

Kansas*

Colorado*

Alaska*

Maine*

Arne ri can Samoa

Runoff

Guam

Runoff

Kentucky'"

Louisiana*

General
January 1990 FEDERAL ELECTION COMMISSION Volume 16, Numbe

CONGRESSIONAL PRIMARY ELECTION REPORTS DUE IN 1990

12-Day Pre-Election Report

state or

Territory

Date of

Election

Close of

Books··

Re9·/Cert.

Mailing Date

Filing

Date

Massachusetts* September 18 August 29 September 3**** September 6

Michigan* August 7 July 18 JUly 23 July 26

Minnesota* September 11 August 22 August 27 August 30

Mississippi* June 5 May 16 May 21 May 24

Runoff June 26 June 6 June 11 June 14

Mi ssouri August 7 July 18 JUly 23 July 26

Montana* June 5 May 16 May 21 May 24

Nebraska'" May 15 April 2S April 30 May 3

Nevada September 4 August 15 August 20 August 23

New Hampshire'" September 11 August 22 August 27 August 30

New Jersey* June 5 May 16 May 21 May 24

e New Mexico* June 5 May 16 May 21 May 24

New York September 11 August 22 August 27 August 30

North Carolina* May 8 April 18 April 23 April 26

Runoff June 5 May 16 May 21 May 24

North Dakota June 12 May 23 May 28"'*** May 31

Ohio May 8 April 18 April 23 April 26

Oklahoma'" August 28 August 8 August 13 August 16

Runoff September 18 August 29 September 3**** September 6

Oregon* May 15 April 25 April 30 May 3

Pennsylvania May 15 April 25 April 30 May 3

Puerto Rico Resident Commissioner to be elected in 1992.

Rhode Island* September 11 August 22 August 27 August 30

South Carolina* June 12 May 23 May 28**** May 31 Runoff June 26 June 6 June 14*** June 14

South Dakota* June 5 May 16 May 21 May 24

Runoff June 19 May 30 June 7*** June 7

e Tennessee* August 2 July 13 July 18 July 21

Texas* March 13 February 21 February 26 March 1

Runoff April 10 March 21 March 26 March 29

7
January 1990 FEDERAL ELECTION COMMISSION Volume 16, Num

CONGRESSIONAL PRIMARY ELECTION REPORTS DUE IN 1990

12-Day Pre-Election Report

8

LOOKING AHEAD: WORKSHOP FOR CANDIDATES PLANNED FOR MARCH

The Commission is planning to host a day-long workshop for

Congressional candidates and their campaign staff members in

Washington, D.C., in early March. See next month's Record for

information on registration, or call Bobby Werfel at the FEe at

800/424-9530 or 202/376-3120 for details.

"'These states are also holding u.s. Senate elections in 1990.

"''''This date indicates end of reporting period; the period begins with

the close of books of the-rist report filed by the committee. If the

committee has filed no previous reports, the period begins with the date

of the committee's first activity in 1990.

"'''''''Committees involved in the runoff elections held in American Samoa,

Arkansas, Guam, South Carolina and South Dakota may use the filing date a

the mailing date for their 12-day pre-runoff report.

"''''''''''The mailing date listed is a federal holiday; nevertheless, the

report must be received by the filing date.

Filing

Date

Reg./cert.

Mailing Date

Close of

Books**

Date of

Election

utah September 11 August 22 August 27 August 30

Vermont September 11 August 22 August 27 August 30

Virginia* June 12 May 23 May 28***'" May 31

virgin Islands September 11 August 22 August 27 August 30

washington September 18 August 29 September 3**** september 6

West virginia'" May 8 April 18 April 23 April 26

Wisconsin September 11 August 22 August 27 August 30

wyoming* August 21 August 1 August· 6 August 9

State or

Territory
January 1990 FEDERAL ELECTIOI\J COMMISSION Volume 16,Numb

ADVISORY OPINION REQUESTS

The following chart lists recent

requests for advisory opinions

(AORs). The full text of any AOR is

available for public inspection and

comment from the FEC's Public

Records Office.

ADR 1989-29

Contributions by foreign-owned

corporation to state, local and

federal candidates. (Date made

public: November 16, 1989; Length:

29 pages, including supplement)

ADR 1989-30

Payment to Senator for teaching of

law school course. (Date made

public: November 16, 1989; Length:

2 pages)

ALTERNATE DISPOSITION OF

ADVISORY OPINION REQUESTS

ADR 1989-23

On December 7, 1989, the Associate

General Counsel sent the requesters

a letter informing them that the

Commission was unable to approve a

draft advisory opinion by the

required four votes.

AOR 1989-24

On November 22, 1989, the Associate

General Counsel sent the requesters

a letter informing them that the

Commission was unable to approve a

draft advisory opinion by the

required four votes. Commissioner

McDonald issued a statement

explaining his votes.

ADVISORY OPINION SUMMARIES

AO 1989-21: Fundraising by

Sole Proprietor in

Cooperation with

Candidates

Elaine Sandra Abramson, an artist

and sole proprietor doing business

as Create-a-Craft, may design and

sell campaign-related merchandise as

a fundraising effort on behalf of

federal candidates and party

committees. Implementation of her

plan, however, will trigger several

requirements of the election law,

including contribution limits,

disclaimer notices, recordkeeping

9

obligations, the establishment of

special bank accounts and, on the

part of the participating campaig

reporting and recordkeeping

requirements.

proposal

MS. Abramson is planning to

enter into agreements with severa

candidates and committees to help

them raise money by selling, at th

usual and normal charge, t-shirts

posters, mugs and similar items

featuring cartoon characters she h

created. Each piece of merchandi

will feature a design, or likenes

of the candidate, with one

chartacter portrayed as advocating

the candidate's election for a

particular offfice.

Ms. Abramson plans to

custom-design merchandise, hire th

manufacturers, process all orders

and design sales fliers for each

campaign. She will give each

participating campaign 10 percent 

the retail price of every item sh

sells. Out of the remaining 90

percent, Ms. Abramson will cover 

costs and make a small profit.

Additionally, Ms. Abramson will s

some items at a discount directly 

the campaigns involved; in those

instances, no portion of the sale

receipts would be turned over to 

campaigns.

Sale of Merchandise to Contributo

Contributions. Any goods and

services or funds that Ms. Abramso

provides before selling the campa

items (e.g., deposits to the

manufacturer and materials and tim

used in creating designs) will be

considered, in effect, loans to th

committee benefiting from the

fundraising. Such loans will be

considered contributions to the

committee to the extent that Ms.

Abramson remains unpaid. 11 CFR

100.7(a)(1)(i)(B). She will,

accordingly, have to: (1) ensure

that such outlays do not exceed th

$1,000 per candidate, per election

contribution limit, (2) keep reco

on the amount spent for each

committee and (3) inform the

committee of the outlays in time 

them to file timely reports. 2

U.S.C. §441a.

(continu
January 1990 FEDERAL ELECTION COMMISSION Volume 16, Numb

Individual purchasers will also

be making contributions to the

committees by buying her

merchandise. The full retail price

of each item will count toward each

purchaser's own contribution limit

and be subject to the prohibitions

of the Act.

Fundraiser Rules. Based on the

proposal, Ms. Abramson will be

considered an agent authorized by

the participating campaigns to

receive contributions and make

expenditures on their behalf. As an

agent, Ms. Abramson will have

certain obligations under FEC rules:

o Each solicitation for the sale of

the items must contain a

disclaimer stating the name of the

committee authorizing the activity

and the person paying for the

solicitation. 11 eFR 110.11(a)

( 1 ) .

o Ms. Abramson must obtain and

forward to the committees the

information they need to comply

with the recordkeeping and

reporting requirements of the Act.

11 CFR 102.9(a)(I) and (2) and

104.3(a)(4)(i).

o MS. Abramson must inform each

committee of how much she spends

from proceeds to defray her costs;

these monies are considered

repayments by the committee for

her advances, and are reportable

by the committee as operating

expenditures. 11 CFR 102.9(b) and

104.3(b)(3) and (4). Such

information must be forwarded in

time for the committee to report

the transactions in a timely

manner.

Absent Ms. Abramson's adherence

to these rules, the 10 percent of

sales that she plans to forward to

the committees will be considered

contributions from her to those

committees, subject to limits.

Bank Accounts

Because the election law does

not allow the commingling of

political committee funds with

personal funds, Ms. Abramson will

have to set up a separate bank

account for each committee

authorizing her to raise funds. The

appropriate bank accounts,

established at depositories

des.ignated by the committees, should

be used for the deposit of

10

contributions received (deposits

must be made within 10 days) and 

disbursements to cover merchandis

costs and reimbursements to Ms.

Abramson for her previous advance

Such reimbursements will be

considered expenditures by the

committees. If funds from MS.

Abramson'S personal or business

accounts are used for these

disbursements, however, they will

count as contributions to the

appropriate committees.

Sale of Merchandise

to Campaigns

Ms. Abramson has not indicate

that the reduced price on

merchandise she plans to sell to 

committees is the usual and norm

charge offered to nonpolitical

clients in the ordinary course of

business. Thus, the amount of th

discount will be an in-kind

contribution from her to each

committee, subject to the same

$1,000 limit (per candidate, per

election) as the other possible

contributions mentioned above.

Trademark

Finally, the Commission noted

that, should Ms. Abramson decide 

trademark her artwork, her

obligations under the election la

and FEC regulations would remain 

same. (Date issued: November 17

1989; Length: 7 pages)

AO 1989-25: preemption of State

Law Limiting

party Spending on

Behalf of Candidates

The Federal Election Campaign Act

preempts a recently enacted New

Hampshire state law to the extent

that the state statute sets limit

on party spending on behalf of

federal candidates. (Since the

requester of this AO was the New

Hampshire Republican State

Committee, and not an authorized

candidate committee or an authori

agent of a candidate, the Commis

in this instance addressed only t

issue of party expenditure limits

under the federal and state law;

the broader issue of whether the 

preempts New Hampshire's limits o

candidates' own spending was not

addressed.)
January 1990 FEDERAL ELECTION COMM1SSIOl\i Volume 16, Numbe

The New Hampshire law sets

"voluntary" spending limits for

candidates for local, state and

federal office, and for party

committees spending on their behalf.

The limits apply only to candidates

who obtain a waiver of required

ballot filing fees and primary

petition signatures. The New

Hampshire law also counts

coordinated party expenditures

(441a(d) expenditures) against the

state limit of any federal candidate

who obtained a fee waiver.

The Act states that the federal

law "supersedes and preempts" all

state laws with respect to federal

elections. 2 U.S.c. S453.

Commission regulations further

specify that the Act supersedes

state laws concerning limits on

expenditures regarding federal

candidates. 11 CFR 108.7(b)(3).

In this case, by attributing

coordinated party expenditures to

the state limit of a federal

candidate, the New Hampshire statute

imposes restrictions and penalties

on those party expenditures that

are expressly allowed by the Act.

Accordingly, to the extent that the

state law limits coordinated party expenditures, it is preempted by the

Act.

In addition, payments by the

party that are exempt from the

definition of "expenditure" under

the Act (2 U.S.C. S431(9)(B)(iv) and

(viii» cannot be subject to

any limitations in the New Hampshire

statute. (Date issued: November

30, 1989; Length: 6 pages)

AO 1989-26: Automatic Bank

Transfers from

Contributor's Account

to Candidate

Committee's Account

The Dick Bond for Congress

Committee, a principal campaign

committee in Colorado, may use a

system of automatic bank account

transfers to collect contributions

from individuals, as long as certain

safeguards are met.

Proposal

The Committee plans to set up a

system through an agreement with its

bank whereby, after obtaining

authorization from an individual

11

contributor, a certain amount wou

be transferred from the

contributor's bank account to the

Committee'S bank account on a

predesignated date each month. Th

Committee would keep cumulative

records of contributions and would

not accept any transfers fcom

corporate accounts or from accoun

of other persons prohibited by law

from contributing. With respect t

bank accounts held jointly by two 

more individuals, the Committee

would comply with the rules at 11

CFR 110.1(k) and (1) concerning

joint contributions a~d

reattributions.

Authorization Form

A form, to be signed by the

contributor, would authorize the

Committee and the contributor's

bank to make the transfers. On th

form, the contributor would speci

the amount to be transferred each

month. The authorization would

remain in effect through November

1990, or until both the Committee

and its depository received writte

notification from the contributor 

terminate the transfers "in

sufficient time and manner to affo

a reasonable opportunity to act on

it."

Agreement with Bank

The Committee has entered into

an agreement with its campaign

depository, Union Colony Bank,

setting forth the terms under whi

transfers to the Bond account wou

be made from contributors' accoun

maintained in member banks of the

Rocky Mountain Automated Clearing

House Association. (The agreemen

is described in the text of the

advisory opinion.) These terms

include the proposed authorization

form and other stipulations on the

conduct of the program, as well a

fees charged by Union Colony for

establishing and handling the

program. The fees charged by the

bank must be the bank's usual and

normal charges for similar servic

if the Bond Committee fails to pa

the usual and normal charges, a

prohibited contribution from the

bank will result.
January 1990 FEDERAL ELECTION COMMISSION Volume 16, Numb

Recordkeeping and Reporting

The form used to obtain

authorization for automatic

transfers should also provide

information enabling the Committee

to comply with the election law's

recordkeeping requirements. 2

U.S.C. §§431(13) and 432(c)(3); 11

CFR 100.12 and 102.9(a)(2). The

Committee must report contributions,

itemizing those that aggregate more

than $200 from one individual during

a calendar year. 11 CFR 104.8(b).

The date of receipt of a

contribution will be the date on

which the Committee's account is

credited with the funds debited from

the contributor's account.

Designation of Contributions

The proposed authorization form

does not ask contributors to

indicate whether contributions are

intended for the general or the

primary election. If no such

designation is made by the

contributor in writing, the

transfers will be considered

contributions for the next election.

11 CFR 110.1(b)(2)(ii).

Designations, however, may be made

on the authorization form or on an

amendment to the form.

Although the proposed form

authorizes transfers through

November 1990, the Committee may

have to terminate the program prior

to that date, under certain

conditions. If Mr. Bond is not a

candidate in the general election,

all contributions made for the

general election will have to be

returned or refunded to the

contributors. Alternatively, the

contributions may be reattributed or

redesignated, as appropriate, to the

extent that reattributions and

redesignations do not exceed the

Committee's net primary debts or the

contributors' contribution limits.

Revocation

As for contributors, the ability

of each contributor to deduct or

revoke his or her authorization must

be made clear. In addition to what

the proposed form and bank agreement

already provide with respect to this

information, the Committee should

state on the authorization form what

it considers to be a reasonable

amount of time to cut off automatic

12

debits in response to a

contributor's revocation of the

authorization. The Committee sho

provide refunds to those

contributors whose requests for

termination are not received in

enough time to stop the next

automatic transfer. (Date issued

December 1, 1989; Length: 6 page

FINAL AUDIT REPORT ON

FULANI CAMPAIGN RELEASED

On November 4, 1989, the

Commission released the final aud

report on Lenora B. Fulani's

Committee for Fair Elections, Dr.

Fulani's publicly funded 1968

Presidential campaign. The resu

of the audit are described below.

Copies of the final report m

be obtained from the FEC's Public

Records Office.

Failure to Disclose

Matching Fund Payment Received 

The Commission's review found

that the Committee had failed to

properly disclose the receipt of 

matching payment of $79,482,

received in July 1988. The paym

instead, was reported as part of 

Committee's "unitemized

contributions from individuals."

The Committee filed an amende

report correcting the discrepancy 

March 13, 1989.

Stale-Dated Committee Checks

As a result of the audit, the

Fulani Committee repaid to the U

Treasury $193, representing five

stale-dated checks--i.e., checks

written by the Committee but neve

cashed by their payees. 11 CFR

9038.6.

Matching Funds Received

in Excess of Entitlement

The audit revealed that the

Fulani Committee had received

matching funds in excess of its

entitlement after Dr. Fulani's "d

of ineligibility." After that d

a candidate may receive matching

payments only to cover its net
January 1990 FEDERAL ELECTION COMMISSIOI\I Volume 16, Numb

(continu

FEC v. FRANKLIN

on September 27, 1989, the U.S

Court of Appeals for the Fourth

Circuit granted the FEC's motion f

summary affirmance in FEC v. Willi

Franklin (No. 89-1512). The appe

court remanded the case to the

district court (C.A. No. 89-324-N

which on September 29 ordered Mr.

Franklin to provide the Commission

with "full and complete answers to

the extent of his knOWledge to eac

and every question propounded to

him" by the agency in 1988 in

response to a complaint from Robb

for the Senate, Senator Charles

Robb's principal campaign committ

In accordance with the higher

court's mandate, the district cou

ordered Mr. Franklin to provide th

answers within five days.

On the direction of the appea

court, the district court also

vacated a protective order that i

had imposed in July. See the Sep

1989 Record for a summary of the

case.

MUR 2543

Respondents: (a) John Bryant

Campaign Committee and treasurer

(TX); (b) R. Hayes (TX); (c) J.

Hayes (TX)

MURS RELEASED TO PUBLIC

Starting with this issue, the

Record will list all publicly

released summary files on MURs

(Matters Under Review--FEC

enforcement actions).

PUblicly released MUR files, 

announced in FEC press releases

since November 21, 1989, are liste

below. Except where noted, civil

penalties resulted from conciliati

agreements reached between

respondents and the Commission.

The summary file for each MUR 

available from the FEC's Public

Records Office.

13

Apparent Nonqualified

Campaign Expenses

Public funds may only be used to

defray "qualified campaign

expenses. It A "qualified campaign

expense" is defined (in part) in FEC

regulations as a purchase, payment,

distribution, loan, advance, deposit

or gift of money or anything of

value incurred in connection with

a Presidential election. If public

funds are used to pay nonqualified

expenses, a portion of the expenses

(representing the portion defrayed

with public funds) must be repaid to

the u.s. Treasury.

The audit revealed that the

Committee had made 41 nonqualified

disbursements for, inter alia,

penalties on state witholding tax

payments and bank charges for

insufficient funds. other

nonqualified expenses included a

$1,000 contribution to the Jesse

Jackson Presidential campaign and a

$1,816 reimbursement for a trip to

London by Dr. Fulani. Nonqualified

expenses, thus, totaled $3,444. The

Commission eventually reduced this

amount by $77, representing the

portion of nonqualified expenses

paid with matching funds after Dr.

Fulani's date of ineligibility but

not recognized for NOCO purposes.

Applying the formula described

at 11 CFR 9038.2(b)(2)(iii), the

Commission initially determined that

the Fulani Committee had to repay

$1,434, the portion of nonqualified

expenses that appeared to have been

defrayed with public funds. The

Committee made the repayment prior

to the Commission's formal

determination.

outstanding campaign obligations

(NOCO). 11 CFR 9033.5. Because the

committee received $15,064 above and

beyond its net debts, the audit

found that the Committee had

received matching funds (of

$15,064) in excess of its

enti tlement.

Matching funds received in

excess of a candidate'S entitlement

must be repaid to the U.S. Treasury.

The Commission made an initial

determination that the $15,064 had

to be repaid to the U.S. Treasury.

The Committee repaid that amount

prior to the Commission's

determination.
January 1990 FEDERAL ELECTION ;

COMMISSION Volume 16, Numb

Complainant: T. Carter/Tom Carter

for Congress Committee (TX)

Subject: Excessive contributions;

improper use of contributor

information

Disposition: (a) U.S. District

Court Final Consent Order and

Judgment: $500 civil penalty; (b)

and (c) Reason to believe but took

no further action

MUR 2572

Respondents: (a) Royce Campaign

Committee and treasurer (CA); (b)

Wally Herger for Congress Committee

and treasurer (CA)# (c) phil Wyman

Committee and treasurer (CA)

Complainant: R. Bauer, Counsel,

Democratic congressional Campaign

Committee (DC)

Subject: Excessive contribution;

prohibited funds

Disposition: (a) $750 civil penalty;

(b) Re excessive contribution,

reason to believe, but took no

further action; re prohibited funds,

no reason to believe; (e) No reason

to believe

PlUR 2591

Respondents: (a) Funderburk for

Senate Committee and treasurer (NC)#

(b) G. Jacobson (CA); (c) L. Kiser

(NC); (d) H. Leigeber (AL); (e) C.

Sicard (MI)

Complainant: FEC initiated

Subject: Excessive contributions 1

failure to timely refund excessive

contributions

Disposition: (a) $7,000 civil

penalty; (b), (c) and (d) Reason to

believe but took no further action:

(e) $300 civil penalty

MUR 2777

Respondents: (a) U.S. Rep.

E. Patterson (SC); (b) Liz Patterson

for Congress 1988 and treasurer

(SC); (c}-(p), at al.

Complainant: South-carolina

Republican Party and chairman

Subject: Excessive contributions;

failure to disclose, accurately file

and timely amend information

Disposition: (a), (c)-(f), (h) and

(j)-(n) No reason to believe; (b)

$800 civil penalty; (g) $400 civil

penalty; (i), (0) and (p) Reason to

believe but took no further action

14

MUR 2855/2865

Respondents: Laborers' District

Council Political Action Fund and

treasurer (PA)

Complainant: FEC initiated

SUbject: Failure to report on ti

Disposition: $3,375 civil penalt

MUR 2870

Respondents: washington Teamste

Legislative League-Fund A (WA)

Complainant: FEe initiated

SUbject: Failure to report on ti

Disposition: $250 civil penalty

MUR 2894

Respondent: Democratic state

Committee of Delaware and treasur

Complainant: FEC initiated

Subject: Failure to report on ti

Disposition: $1,500 civil penalt

MUR 2904

Respondents: (a) J. McCarthy (IL

(b) McCarthy Election committee a

treasurer (IL); (c) E. Menker (IL

Complainant: FEC initiated

SUbject: Excessive contribution

Disposition: (a), (b) and lc) $7

civil penalties

HUR 2945

Respondents: Americans for the

Republic, Inc. (FKA Committee for

Freedom) and treasurer (VA)

Complainant: FEC initiated

Subject: Failure to report on ti

Disposition: $1,000 civil penalt

MUR 2948

Respondents: Corporation for the

Advancement of psychiatry PAC

(CAPPAC) and treasurer (DC)

Complainant: FEe initiated

Subject: Failure to report on ti

Disposition: $1,100 civil penalt

MUR 2949

Respondents: Delaware Valley

Leadership Fund and treasurer (PA

Complainant: FEC initiated

Subject: Failure to report on ti

Disposition: $800 civil penalty

MUR 2951

Respondents: Electrical

Construction PAC-National Electr

Contractors Association, Inc.,

(ECPAC) and treasurer (MD) 

Complainant: FEC initiated

Subject: Failure to report on ti

Disposition: $1,000 civil penal
January 1990 FEDERAL ELECTION COrvllVllSSION Volume 16, Numbe

01.--------------

1980 1982 1984 1986 198

100 ---------------

200f----~=-F--~-------~

3001--~-----~------.oil1Ji!!Il'~---

Millions of Dollars

400,---------~-~-~

PAC ACTIVITY, 1987-88:

FINAL FEC REPORT ISSUED

The Final Report on financial

activity by nonparty political

committees showed a slowdown in th

growth of PAC receipts and

disbursements during the 1987-88

election cycle. Analysis of repor

filed during the past cycle showed

increases of 8.8 percent in PAC

receipts and 7.1 percent in PAC

disbursements, compared with the

1985-86 election cycle. By

contrast, PAC receipts in the 1986

cycle increased 22 percent from th

previous election, while

disbursements increased 27 percent

The Final Report also showed

that:

o Incumbents received 74.2 percent

of all PAC contribution$ in "the

1988 cycle, up from 68.8 percent

in the previous cycle.

o Contributions to challengers

represented 11.8 percent, down"

from 14.2 percent in 1985-86;

o Democrats received $98.4 million

from PACs, or 62% of all PAC

contributions during 1987-88.

This was a 25 percent increase

over the $78.9 million given to"

Democrats in 1986.

o Republicans received $60.8 milli

in PAC contributions in the 1988

cycle, Virtually unchanged from

the $60.9 million they received 

1985-86.

PAC Receipts, 1980~88

15

MUR 2969

Respondents: Plasterers' and Cement

Masons' Action Committee and

t 1"e a 5 u r e r (DC)

complainant: FEC initiated

Subject: Failure to report on time

Disposition; $300 civil penalty

P1UR 2952

Respondents: First Fidelity, Inc.,

PAC and treasurer (NJ)

complainant: FEe initiated

Subject: Failure to report on time

Disposition: $350 civil penalty

KUR 2954

Respondents: General Atomics

PAC and treasurer (CA)

Complainant: FEC initiated

Subject: Failure to report on time

Disposition: $350 civil penalty

",UR 2959

Respondents: International Sanitary

Supply Association PAC (ISSA Clean

PAC) and treasurer (IL)

complainant: FEC initiated

Subject: Failure to report on time

Disposition: $500 civil penalty

KUR 2960

Respondents: Manufacturers Hanover

Association for Responsible

Government Fund and treasurer (NY)

Complainant: FEC initiated

Subject: Failure to report on time

Disposition: $500 civil penalty

JIIUR 2961

Respondents: Marshall Political

Action Committee and treasurer (PA)

complainant: FEC initiated

Subject: Failure to repqrt on time

Disposition: $550 civil penalty

MUR 2966

Respondents: Northwestern Bell

Telephone Company Federal PAC (NWB

FED PAC) and treasurer (ME)

Complainant: FEe initiated

Subject: Failure to report on time

Disposition: $500 civil penalty

•
January 1990 FEDERAL ELECTION COMMISSION Volume 16, Num

PAC Support of Candidates

By Election Cycle1

• Independent Expenditures

• Contributions to Candidates

Millions of Dollars

"Ohart does not include activityby PACsof cooperatives and corporations withoutcapital stock.

16

78 80 82 84 86 

Trade/Members

Health

18 80 82 84 86 88

Nonconnected

78 80 82 84 86 88

Labor

o

78 80 82 84 86 88

Corporate

20

40t----~--

50

30

FINAL REPORT ON

FINANCIAL ACTIVITY

The FEe recently issued FEC

Reports on Financial ActivitY;-

1987-88, Final Report. The

serIes contains statistical

information on party committees

(Volumes I and II), PACs

(Volumes I, III and IV) and

Conqressional candidates (a

separate volume). Each volume is

available for $10 from the

agency's Public Records Office.

In addition, computer tapes

on party, PAC and Congressional

activity are also available for

$50 each from the FEe'S Data

Systems Development Division.

10

60
January 1990 FEDERALELECTION COMMISSION Volume 16, Numbe

•

COMBINED DUES/SOLICITATION

STATEMENTS

A labor organization,

incorporated trade assoc~on or

other incorporated membership

organization may include a

solicitation for its federal

separate segregated fund (55F, or

PAC) with the bill for dues that it

sends to members who are

individuals. The Commission has

addressed combined dues/solicitation

statements in regulations and

advisory opinions (AOS).

Solicitation Rules

A dues statement that contains

an SSF solicitation is subject to

the same rules that apply to other

SSF solicitations. Thus, a combined

dues/solicitation statement may be

sent only to the restricted £lass of

the sponsoring o~ganization.

2 U.S.C. §441b(b)(4); 11 CFR

114.5(9), 114.7(a} and 114,8(c).

Incorporated trade associations and

membership organizations, in

particular, should note that

corporate members may not be

solicited for SSF contributions by

any means. Under section 441b,

corporations are prohibited from

contributing to political

committees. See AO 1985-12.

Moreover, SSF contributions must

be voluntary and may not be a

condition for membership. This

means that members may not designate

their dues (or a portion of their

dues) for the SSF. Instead, a

contribution designated on the

combined dues/solicitation statement

must be over and above the amount

billed for dues. 2 U.S.C.

1. A chart explaining the

solicitable personnel of labor

organizations, incorporated trade

associations and incorporated

membership organizations can be

found on page 56 of the FEe's

Campaign Guide for Corporations and

Labor Organizations.

17

§441b(b)(3)(A); 11 eFR 114.5(a)(1)

AOs 1980-133 and 1980-44.

Required Information

The combined dues/solicitation

statement must contain a notice

informing members of the political

purpose of the 58F and of their

right to refuse to contribute

without reprisal. 2 U.S.C. S441b(b)(3)~ 11 eFR 114.5(a)(3)-(5

The statement may suggest an amoun

to contribute to the 85F, but if a

amount is suggested, the statement

must include a notice informing th

member that:

o The suggested amount is only a

suggestion;

o More or less than that amount ma

be given;. and

o The amount contributed, or the

refusal to contribute, will not

benefit or disadvantage the

member. 11 erR 114.5(a)(2).

An example of a permissible

combined/dues solicitation stateme

was provided in AQ 1987-17. In th

opinion, the requester (a farmers'

association) proposed a combined

statement that suggested a $1.00

contribution to the SSF. The

statement said, "The amount of a

voluntary contribution to [the fun

is merely a suggestion, and your

contribution may be more or less

than the suggestion. Any amount y

pay on your dues notice in excess 

your membership dues will be sent

directly to (the fund]." The

statement also informed members th

the association would "not favor,

disadvantage, retaliate. or take

reprisal against any person's

decision not to contribute to (the

fund] . "

An example of a combined

statement that the Commission

disapproved is found in AO 1987-6.

In that proposal, the requester

failed to indicate that the stated

contribution amount was only a

suggestion and did not explain how

to contribute an amount different

from the one specified. The

statement also failed to notify

the members as to the political

purpose of the PAC.

(continue
January 1990 FEDERAL ELECTION COMMISSION Volume 16, Num

Layout

In other oplnlons, the

Commission stated that the layout of

the information contained in the

dues/solicitation statement may bear

on whether it is a permissible

solicitation. The layout should

convey the distinction between the

suggested contribution and a

required dues payment. AO 1987-17 pro~ides a good example. The

statement included two lines for

payments by members, as follows:

Membership Dues••••••.••.•••.• $

(Voluntary PAC contribution ••• $===:)

See also AOs 1987-6, 1982-61 and

1960-6.

Collection of Contributions

Although the amount contributed

to the SSF must be an amount over

and above the membership dues paid,

a contributor may write one check to

cover both the contribution and the

dues. This check must be drawn on

the contributor's personal checking

account or a nonrepayable corporate

drawing account. 11 CFR

1 02,. 6 ( c ) ( 3 ) •

The organization sponsoring the

SSF (i.e., the connected

organization) acts as a collecting

agent and, as such, must forward the

money collected within 10 days

(contributions of $50 or less2must

be forwarded within 30 days). To

do this, the connected organization

may deposit the member's check in a

transmittal account and then write a

check to the SSF representing the

portion of the payment that was

intended for the SSF. Appropriate

recotds of the contribution must be

forwarded along with the check. 11

CFR 102.6{c)(3); AOs 1978-98 and

1978-42.

When transmitting contributions,

the collecting agent may write one

check to the SSF representing all

the individual contributions

collected. 11 CFR l02.6(c)(A)-(5)

and 102.8(b).

2. A connected organization must

directly forward to the SSF all

checks made payable to the SSF. 11

CFR 102.6(c)(4)(i).

18

Payroll Deduction

A labor organization may use 

employer'S payroll deduction sys

to collect both membership dues 

voluntary contributions to its S

provided the individual membets

authorize the deduction beforeha

11 CFR ll4.5(k)(1); See AOs 198

and 1977-37. Under a payroll

deduction plan, the employer may

write a single check to the unio

(or its agent) representing the

combined dues (or other fees) an

SSF contributions. The union, in

turn, splits the combined paymen

transmitting the contribution to 

SSF within the required time.

Contributions collected in this

manner are consideted to be dire

contributions from individuals. 

CFR 102.6(c)(3).

Transmittal Accounts

An organization that function

as the collecting agent may use 

of three types of transmittal

accounts:

o A separate account used solely 

the purpose of transmitting fu

to the SSF;

o The organization's general

treasury account; or

o An account used by the

organization for nonfederal

election actiVity.

If the organization uses a

general treasury account or a

nonfederal political account to

transmit contributions, it must 

separate records for those depos

that represent SSF contributions

11 CFR 102.6(c)(4)(ii).

Anyone with further question

about combined dues/solicitation

may call the Commission's

Information Services Division at

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

PUBLIC APPEARANCES

January 5 Hope College

Washington, DC

Chairman Lee Ann

Elliott
January 1990 FEDERAL ELECTIOI\J COMMISSIOI\J

DESIGNATING A PRINCIPAL

CAMPAIGN COMMITTEE

(Reprinted from the March 1989

Record. )

Under what circumstances must an

individual who plans to run for

federal office in 1990 or 1992

designate a principal campaign

committee? Individuals running for

federal office in 1990 or 1992 must

designate a principal campaign

committee within 15 days of becoming

a candidate. 11 CFR 101.1(a).

Individuals become candidates once

they raise or spend more than $5,000

to influence their future election

or when someone they authorize to

work on their behalf raises or

spends over $5,000 to influence

their election. See 11 CFR

100.3(a).

HoW does a candidate designate a

principal campaign commitee?

Candidates designate a principal

campaign committee by filing a

statement of Candidacy on FEC Form 2

or a letter containing the same

information, i.e., the name and

address of the principal campaign

committee, the candidate's name,

address and party affiliation; the

office sought; and the district and

state in which the office is sought.

11 CFR 101.1(a).

Does a candidate who ran in a

previous election have to file a new

Form 2 for a future campaign? -Yes.

A candidate in a previous election

must file a new FEC Form 2 within 15

days after qualifying as a candidate

in a future election. The candidate

may either redesignate his or her

previous campaign committee (if it

has not terminated) or designate a

new principal campaign committee. A

19

Volume 16, Numb

redesignated committee retains it

original identification number; a

newly designated committee receiv

a new one.

Does the principal campaign

committee of a candidate who ran 

a previous election also have to

file a new Statement of

Organization? If the candidate

designates a new principal campai

committee, the committee must fil

new Statement of Organization (FE

Form 1) within 10 days after bein

designated. 11 CFR 102.1(a).

If the candidate redesignates 

existing committee, the committee

need only amend its Statement of

Organization within 10 days to

reflect any new information (e.g.

change in the committee's name or

address). 11 CFR l02.2(a)(2).

Redesignated committees are remin

that, if outstanding debts remain

from a previous election, the

committee must continue to report

the debts as well as contribution

that have been designated by

contributors to retire them. 11 

104.11; 110.1(b)(3) and (4);

110 . 2 (b) ( 3) and (4).

Where are Forms 1 and 2 filed

U.S. House candidates and their

principal campaign committees fil

all statements and reports with t

Clerk of the House; U.S. Senate

candidates and their prinicpal

campaign committees file with the

Secretary of the Senate;

Presidential candidates and their

principal campaign committees fil

with the FEC. 11 CFR part 105.

Copies of statements and repo

must also be filed with state

officers. House and Senate

campaigns file in the state in wh

the candidate seeks election;

Presidential campaigns file in th

states in which expenditures are

made. 2 U. S. C. § 439 (a) .
FEDERAL ELECTION COMMISSION

Bulk Rate Mail

Postageand Fees Paid

Federal Election Commission

Permit NumberG-31

No. o

Copie

Volume 16, Numb

- - - - - - - - -- - -- - -- - - - - 

CAXPAIGN GUIDE ORDER FORM

Organization

Campaign Guide

Congressional Candidates

City, State, Zip

Address

Name

persons involved'in running a

political committee or filing

reports will find the guides to b

an important resource.

Copies of campaign guides can 

ordered from the FEC by calling

800/424-9530 or 202/376-3120 or b

mailing the form below to:

Federal Election Commission

Information Services Division

999 E Street, NW

Washington, DC 20463

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January 1990

CAMPAIGN GUIDES FOR OTHER COMMITTEES

In addition to the Campaign

Guide for Political Party

Committees, the Commission

publishes gUides for

Congressional candidates,

corporate and labor PACs and

nonconnected committees.

Committee treasurers,

bookkeepers, volunteers and other

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FEDERALELECTION COMMISSION

999 E Street, NW

Washington. DC 20463

CAMPAIGN GUIDE FOR PARTY

COMMITTEES UPDATED

The Commission has just

published a revised Campaign Guide

for Political Party Committees, a

manual designed to help party

commitees understand and comply with

the requirements of the federal

election law. The revised campaign guide will be sent automatically to

all registered party committees;

others may request copies by using

the form below.. Written in plain English, the

guide provides instructions for each

step of the election process--from

registration to fundra~sing to

winding down the campaign. Detailed

information and illustrations are

also included to help committees

follow the recordkeeping and

reporting rules.

Official Business