June 1997 Federal Election Commission Volume 23, Number 6

Table of Contents

Compliance

1 MUR 3672

Regulations

1 FEC to Hold Public Hearing on

Regulations for Expenditures by

Party Committees

6 Revised Best Efforts Regulations

Sent to Congress

Conferences

2 Conferences Scheduled

2 Workshop Canceled

Publications

2 FEC Issues 1996 Annual Report

2 Resubscribe to the Record

Court Cases

6 FEC v. Orton

7 Jones v. FEC

7 On Appeal?

7 New Litigation

8 Federal Register Notices

 Statistics

9 Congressional, PAC Fundraising

and Expenditures Continue Strong

Showings in 1996 Election Cycle

 11 Advisory Opinions

Information

 13 FEC Faxline Menu

 14 Index

Compliance Regulations

MUR 3672

Penalties Paid By

Corporations, Partnership for

Impermissible Contributions

Two U.S. corporations and a

limited liability partnership have

paid a combined $168,000 in civil

penalties to the FEC for improperly

collecting contributions from their

employees and customers, and then

forwarding the funds in the contributors’ names to various Republican party operations during the 1992

election cycle.

Cherry Communications, Inc.

(CCI), agreed to pay $150,000,

Chrysler Corporation agreed to pay

$11,000 and Deloitte & Touche

agreed to pay $7,000. The violations

by the three businesses occurred

independently of one another, but all

three involved collecting and

forwarding contributions.

The Law

In the cases of CCI and Chrysler,

the corporations violated the provision in the Federal Election Campaign Act (the Act) that prohibits

corporations from making contributions or expenditures in connection

with a federal election. 2 U.S.C.

§441b(a). Chrysler and Deloitte &

Touche also violated the ban at 2

FEC to Hold Public Hearing

on Regulations for

Expenditures by Party

Committees

The FEC will hold a public

hearing on proposed rules governing

independent expenditures and

coordinated party expenditures by

party committees on June 18 at 10

a.m. in its hearing room in Washington, DC.

The Commission has proposed

rules with several alternative

provisions (see 62 FR 24367 in the

May 5 Federal Register). Many of

the changes are in response to the

U.S. Supreme Court’s ruling in

Colorado Republican Federal

Campaign Committee v. FEC.1 In

this case, the court concluded that

political parties are capable of

making independent expenditures

on behalf of their candidates in

congressional races. Prior to this

ruling, it was presumed that party

committees—which, by their very

nature, have close contact with their

affiliated candidates—could not

make expenditures independently of

candidates.

(continued on page 4)

(continued on page 3)

1

 Colorado Republican Federal

Campaign Committee v. FEC, 116 S.Ct.

2309 (1996).

Changes to Flashfax

The FEC’s Flashfax system

has a new name and all new

document numbers. See page

13 for information about the

new Faxline and how to use it.
Federal Election Commission RECORD June 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

FEC Issues 1996 Annual

Report

In June, the FEC issued its

Annual Report 1996, chronicling the

agency’s activities during that year.

The annual report includes a

section that examines some of the

most pressing legal issues the

Commission confronted in 1996—

and continues to face today. Among

the topics covered in this chapter

are:

• Corporate and labor communications

 - Express advocacy

 - Coordination with candidates

• Independent expenditures by party

committees

 - Independent expenditures by

qualified nonprofit corporations

• State and national committee

status

• “Major purpose” test

• Best efforts

• Personal use of campaign funds

Conferences Scheduled

The FEC has set dates for three

of its conferences scheduled for

1997-1998.

• Seattle Regional Conference

September 24-26, 1997

This conference will include

workshops for representatives of

candidate, party and corporate and

labor committees.

• Atlanta Regional Conference

October 15-17, 1997

This conference will include

workshops for representatives of

candidate, party and corporate and

labor committees.

• Washington, DC, Regional

Conference

November 6-7, 1997

This conference will include

workshops for representatives of

corporations and labor organizations. • News story exemption

• Application of contribution limits

• Sale or use ban

• Enforcement process

The annual report also includes

an accounting of the Commission’s

achievements during last year and

legislative recommendations

submitted to Congress. Charts and

statistical tables also tell the story of

the FEC’s activities during 1996.

Free copies of Annual Report

1996 are available through the

FEC’s Information Division. Call

800/424-9530 (press 1) or 202/219-

3420. ✦

Conferences

Workshop Canceled

The FEC’s workshop scheduled

this month in Bismarck, ND, has

been canceled. For more information, call the Information Division at

1/800-424-9530 (press 1) or 202/

219-3420. ✦

Resubscribe to the Record

Subscribers other than registered

political committees must return the

renewal notice they received in the

mail recently in order to continue

receiving the Record. If subscribers

do not mail in the form, they will be

dropped from the mailing list in the

next few months. For more information, call the FEC’s Information

Division at 1/800-424-9530 or 202/

219-3420. ✦

Read the Record to find out about

additional conferences scheduled for

late 1997 and 1998. A tentative

schedule includes conferences in

December 1997 for trade and

membership associations (Washington, DC); in February 1998 for

candidate committees (Washington,

DC); in March for candidate, party

and corporate and labor committees

(Denver); and in April for

nonconnected committees (Washington, DC). ✦

Back Issues of the

Record Now Available

on the Internet

This issue of the Record and all

other issues of the Record from

1996 and 1997 are now available

through the Internet as PDF files.

Visit the FEC’s World Wide Web

site at http://www.fec.gov and

click on “What’s New” for this

issue. Click “Help for Candidates,

Parties and PACs” to see back issues. Future Record issues will be

posted here as well. You will

need Adobe® Acrobat Reader

software to view the publication.

The FEC’s web site has a link

that will take you to Adobe’s web

site, where you can download the

latest version of the software for

free.

Publications
June 1997 Federal Election Commission RECORD

3

Compliance

(continued from page 1)

U.S.C. §441c on contributions by

federal contractors.

The Act defines a contribution to

include services or anything of

value made to a candidate, campaign committee or political party or

organization in connection with a

federal election. 2 U.S.C.

§441b(b)(2). When a corporation

facilitates the collection of contributions to a candidate or political party

organization, the corporation has, in

fact, provided something of value—

that is, the corporation has made a

prohibited contribution. Additionally, at §441b(a), the Act prohibits

any officer or any director of a

corporation from consenting to any

contribution or expenditure by the

corporation. The Act does, however,

provide for certain exemptions from

these prohibitions.

For example, a corporation may

make partisan communications to its

restricted class—stockholders and

executive and administrative

personnel and their families. 2

U.S.C. §441b(b)(2)(A). A corporation may not, however, step beyond

the line of partisan communications

and collect contribution checks or

facilitate the making of contributions to a political party or organization.

As another example of an exception to the normal ban on corporate

contributions and expenditures,

corporate employees may make

occasional, isolated or incidental use

of the facilities of a corporation for

individual volunteer activity in

connection with a federal election.

Those employees must reimburse

the corporation for the increased

overhead or operating costs. 11 CFR

114.9(a)(1). The exemption for

volunteer efforts does not, however,

extend to “collective enterprises”

where the top executives of a

corporation direct their employees

to raise funds—using corporate

resources, such as lists of vendors

and customers—or to solicit a whole

class of corporate executives and

employees to contribute to a candidate or political committee.

Cherry Communications, Inc.

James R. Elliott, chairman and

chief executive officer of CCI, was

appointed a co-chairman of an event

known as the President’s Dinner, a

fundraiser to benefit the National

Republican Senatorial Committee

and the National Republican Congressional Committee. Mr. Elliott

set about soliciting his employees to

make contributions and attend the

dinner, and recruited other CCI

officials to help raise money. In

addition to soliciting CCI employees, CCI and Mr. Elliott solicited

CCI’s business clients. As a result

of the fundraising effort, CCI

collected and forwarded to the

President’s Dinner $113,125. The

cover letters that accompanied the

checks were on CCI’s corporate

letterhead.

The actions carried out by CCI

constituted organized fundraising

and, therefore, were not exempted

from the ban on corporate contributions. In addition to CCI’s being

penalized for corporate contributions, Mr. Elliott was cited by the

FEC for consenting to making

corporate contributions, in violation

of 2 U.S.C. §441b(a).

Chrysler

During the same election cycle,

Chrysler Chairman Lee Iacocca was

asked to serve as a co-chair of a

Bush-Quayle ‘92 fundraiser. The

request also asked that co-chairs sell

a minimum of one table—or raise

$10,000—for the event, which was

held at the Ritz-Carlton Hotel in

Dearborn, MI. Mr. Iacocca forwarded the request to subordinates

in the corporation who carried out

the fundraising legwork. In all,

Chrysler officials collected $11,750

in this effort and forwarded it to

Bush-Quayle ‘92. Additionally,

Chrysler sent thank-you notes to its

employee contributors on corporate

stationery. This organized

fundraising activity constituted a

corporate contribution and thus

Chrysler violated 2 U.S.C. §441b(a).

In light of the corporation’s status as

a federal contractor, Chrysler also

violated 2 U.S.C. §441c.

Deloitte & Touche

The prohibited activity at Deloitte

& Touche occurred in its Michigan

offices where the head of the firm’s

state office, Daniel Kelly, was also a

finance committee member of

Michigan Bush-Quayle ‘92. As a

member of the finance committee,

Mr. Kelly had committed to raising

$10,000 for Bush-Quayle ‘92. In

that effort, Mr. Kelly contacted the

Deloitte & Touche partner who

regularly conducted the firm’s

fundraising for state and local

political efforts in order to have him

help with the fundraising effort. In

the end, 35 partners contributed

$10,075 for Bush-Quayle ‘92. The

contributions were forwarded to the

representatives of the Michigan

Bush-Quayle ‘92 Finance Committee and were labeled as contributions collected at Deloitte &

Touche. The final installment of the

contributions included a letter from

Mr. Kelly on the accounting firm’s

letterhead. As a federal contractor,

Deloitte & Touche’s organized

fundraising activity constituted a

contribution and thus violated 2

U.S.C. §441c. ✦

Need FEC Material

in a Hurry?

Use FEC Faxline to obtain FEC

material fast. It operates 24 hours

a day, 7 days a week. More than

300 FEC documents—reporting

forms, brochures, FEC regulations—can be faxed almost immediately.

Use a touch tone phone to dial

202/501-3413 and follow the instructions. To order a complete

menu of Faxline documents, enter

document number 411 at the

prompt.
Federal Election Commission RECORD June 1997

4

Consequently, the Democratic

Senatorial Campaign Committee

and Democratic Congressional

Campaign Committee requested a

rulemaking in light of the decision

in this case.

The Notice of Proposed

Rulemaking (NPRM) examines a

number of different issues, as

discussed below.

Contributions (11 CFR 100.7)

The Commission proposes to add

new language to the definition of

“contribution,” regarding coordinated payments for communications

and other things of value. Under two

alternative proposals, the definition

of contribution would include a

payment for a communication or

anything of value that is coordinated

with a candidate or a political

committee. One alternative would

specify that the payment for the

communication or the thing of value

is for the purpose of influencing a

federal election.

Coordination (11 CFR 100.23)

The Commission proposes tying

its current definition of independent

expenditure found at 11 CFR

109.1(a) more clearly to the concept

of what negates the independence of

expenditures and what constitutes

coordination. Revised rules would

more fully explain what is meant by

coordination, and they would apply

to separate segregated funds (SSFs),

other political committees and

individuals, as well as to party

committees. Again, there are several

alternatives to this proposal. In each

of them, however, the new rule

would replace the current language

in the regulations indicating when

expenditures are “presumed” to be

coordinated. Some of the alternatives would also add new language

to the definition of coordination

based on the decision in Colorado.

Currently, the Act defines

independent expenditure at 2 U.S.C.

431(17) as “an expenditure by a

person expressly advocating the

election or defeat of a clearly

identified candidate which is made

without cooperation or consultation

with any candidate, or any authorized committee or agent of such

candidate, and which is not made in

concert with, or at the request or

suggestion of, any candidate, or any

authorized committee or agent of

such candidate.” The new language

from the Colorado ruling refers to

independent expenditures as those

“developed...independently and not

pursuant to any general or particular

understanding with [candidates and

their agents].” Comments are being

sought on whether the new language

should be added to the definition of

coordination or whether the high

court intended its phrasing to be

limited solely to independent

expenditures.

Also relevant to the concept of

coordination is the definition of

agent. The NPRM offers two

alternatives. One would identify an

agent as a person who holds a

significant position with, participates in policy-making decisions of

or provides campaign-related

services to a candidate’s authorized

committee. The other alternative

expands upon that definition, adding

a provision that would require

agents to have expressed or implied

authority from the principal—the

candidate or authorized committee—to act as an agent.

Independent Expenditure

Definition (11 CFR 109.1)

The proposed rules would state

that party committees may make

independent expenditures. There are

two alternative wordings for this

regulation.

Party Committee Coordinated

Expenditures and Independent

Expenditures (11 CFR 110.7)

Currently, this section of the

regulations implements an exception

to the contribution limits found at 2

U.S.C. §441a. Essentially, it allows

national, state and local committees

to make limited expenditures on

behalf of the general election

campaigns of federal candidates

without counting the expenditures

against the committees’ contribution

limits for those candidates. 2 U.S.C.

§441a(d). Such expenditures may be

made in consultation with the

candidates; hence, they are called

coordinated expenditures. The

NPRM explains that the Supreme

Court’s Colorado decision did not

modify or eliminate the existing

statutory limits on coordinated

expenditures. The NPRM raises a

number of questions about the

relationship, if any, between these

coordinated expenditures and

independent expenditures made by

the same party committee.

• Independent Expenditures for

Congressional Candidates. The

proposed rules would subject

party committee independent

expenditures to the same standards

and conditions as independent

expenditures made by other

entities—including the requirement that they not be coordinated

with candidates, reporting requirements, rules on disclaimers and

contribution limits and prohibitions. However, the Commission is

considering whether, in some

respects, these rules should be

modified for party committees,

given their traditionally close ties

to candidates. The NPRM observes

that “the Court found it was

possible for the Colorado Republican Party to make independent

expenditures in the specific

circumstances presented in the

Colorado case. These circumstances included the fact that the

expenditures were made months

before the primary election, three

individuals were vying for the

nomination, and no general

election candidate had yet been

selected.” The Commission is

considering what methods party

committees could employ to

Regulations

(continued from page 1)
June 1997 Federal Election Commission RECORD

5

ensure that their independent

expenditures were genuinely

independent of an affiliated

candidate. For example, the NPRM

asks:

 Whether it would be feasible for a

party committee to create a

separate subdivision for the

exclusive purpose of making

independent expenditures and

insulating them from the daily

campaign activities of the party?

 Whether a party committee’s

ability to make independent

expenditures for a certain candidate would end after it nominates

the candidate?

 Whether independent expenditures on behalf of a particular

candidate would be possible once

a party committee had coordinated

with the candidate?

 Whether, assuming that party

committees are affiliated, coordination between the candidate and

one party committee would automatically cancel the ability of

other affiliated party committees to

make independent expenditures for

that candidate?

 Whether coordination exists

between an unopposed primary

candidate and the party committee

that nominated him or her at a

convention so as to preclude

subsequent independent expenditures by the party committee for

the candidate?

• Independent Expenditures for

Presidential Campaigns. The

proposed rules would continue the

current ban on independent

expenditures by national party

committees on behalf of the

general election campaigns of their

presidential candidates. This rule

recognizes that it may be nearly

impossible for a national party

committee to be independent of its

presidential candidate if the chair

of the party has been selected by

the presidential candidate, if the

national committee serves as the

candidate’s principal campaign

committee or if the staff of the two

committees work closely together.

The NPRM asks a number of

related questions:

 Should the ban on independent

expenditures on behalf of presidential candidates in general election

campaigns be extended to cover

presidential primaries as well?

 Should other party committees be

barred from making independent

expenditures on behalf of presidential candidates?

 Should the ban only apply to

candidates who receive public

funding?

• Other Proposals. The proposed

revised rule would require that

when a party committee authorized

another party committee to use

part or all of its coordinated

expenditure limit, the authorization

would have to be in writing,

specify a dollar amount and be

made before the committee

actually made the coordinated

expenditure. The Commission is

seeking comments on whether

copies of such authorizations

should be attached to a

committee’s disclosure reports.

 The proposed rules would clarify

that the Commission’s standard for

determining whether a party

committee communication qualified as a coordinated expenditure

would continue to depend on

whether it contained an electioneering message and mentioned a

clearly identified candidate.

Reporting Independent

Expenditures (11 CFR 104.4(a))

The revised rules would add a

specific reference to make clear that

national, state and subordinate

committees of political parties

would be subject to the same

reporting requirements as other

political committees.

Contributions to Committees

Making Independent

Expenditures (11 CFR 110.1(n)

and 110.2(k))

These sections of the regulations

would be updated to state that party

committees may make independent

expenditures. The changes would

also make clear that the contribution

limits by individuals of 2 U.S.C.

§441a would still apply when a

party committee used contributions

it received to make independent

expenditures.

Party Committee Disclaimers (11

CFR 110.11(a))

The regulations at paragraph

(a)(2)(i) would be updated to state

that the required disclaimer for

communications that constituted

coordinated expenditures had to

indicate who authorized the communication. When parties made

independent expenditures, a new

paragraph in the regulations would

require that a disclaimer state that

the party committee paid for the

communication, but that it was not

authorized by any candidate or

authorized committee.

The deadline for submitting

comments and requests to testify on

this proposed rulemaking was May

30. The location for the public

hearing is the Commission’s ninth

floor meeting room, 999 E Street,

N.W.

Copies of the Federal Register

notice are available from the FEC

Press Office and at the U.S. Government Printing Office web site

address, http://www.access.gpo.gov/

su_docs/aces/aces140.html. The

notice also is available from the

FEC’s Faxline at 202/512-3414

(document 228). An article discussing the FEC’s efforts to conform

with the decision in Colorado is on

page 1 of the September 1996

Record.

For more information, call Susan

E. Propper, Assistant General

Counsel, Rosemary C. Smith,

Senior Attorney or Teresa A.

Hennessy, Attorney, at 202/219-

3690. The toll-free number at the

FEC is 800/424-9530. ✦

(Regulations continued on page 6)
Federal Election Commission RECORD June 1997

6

Revised Best Efforts

Regulations Sent to Congress

On April 25, the Commission

submitted to the U.S. Congress

revisions to its “best efforts”

regulations. These revised rules and

an Explanation and Justification

were published in the Federal

Register on April 30 (62 FR 23335),

and an Announcement of Effective

Date will be published after the

rules have been before Congress for

30 legislative days.

The “best efforts” regulations set

up procedures to ensure that political committees meet the statutory

requirement to use their best efforts

to obtain and report the required

contributor information—name,

address, occupation and employer—

of individuals who contribute $200

or more during a calendar year. The

changes came about in response to

the court decision in Republican

National Committee v. FEC,1

 where

the U.S. Court of Appeals for the

District of Columbia Circuit ruled

that the solicitation notice, required

by former FEC regulations, was

inaccurate and misleading. For a

summary of that case, see the April

1996 Record, page 10.

There are two significant changes

to the rules, found at 11 CFR

104.7(b)(1) and (b)(3).

Solicitations (104.7(b)(1))

All solicitations must include an

accurate and clear statement of the

law’s requirements for the collection

and reporting of contributor information. The following examples are

acceptable wording that may be

included in solicitations, but these

are not the only allowable statements:

• “Federal law requires us to use our

best efforts to collect and report

the name, mailing address, occupation and name of employer of

individuals whose contributions

exceed $200 in a calendar year.”

• “To comply with Federal law, we

must use best efforts to obtain,

maintain, and submit the name,

mailing address, occupation and

name of employer of individuals

whose contributions exceed $200

per calendar year.”

This request, or one of similar

meaning, must be displayed in a

clear and conspicuous manner on

any response materials included in a

solicitation.

Connected Organization’s

Information (104.7(b)(3))

Under current regulations,

committee treasurers must report all

contributor information not provided by the contributor but in the

political committee’s possession. In

this regard, the regulation was

modified to clarify that separate

segregated funds must report

contributor information in the

possession of their connected

organizations. ✦

Regulations

(continued from page 5)

Court Cases

1

 Republican National Committee v.

FEC, 76 F.3d 400 (D.C. Cir. 1996),

cert. denied, 117 S. Ct. 682 (1997).

FEC v. Orton

On April 27 and 28, the U.S.

District Court for the District of

Utah, Central Division, approved

the parties’ settlement that required

Utahns for Ethical Government

(UEG) to pay a $9,000 civil penalty

to the FEC for violations of the

Federal Election Campaign Act (the

Act) and to amend their termination

report so that all of their expenditures would be reported as in-kind

contributions to Orton for Congress.

UEG also had to either refund

$1,800 in impermissible corporate

contributions or remit that same

amount to the U.S. Treasury.

The violations resulted from

UEG’s involvement in the 1990

general election campaign for the

3rd Congressional District seat in

Utah. UEG, a single-candidate

political committee registered with

the FEC, supported William Orton

over his opponent, Karl Snow.

The settlement states that UEG

accepted corporate contributions

and contributions in the name of

another, in violation of the Act. 2

U.S.C. §§441b(a) and 441f. The

committee reported receipts of inkind contributions of $1,000 from

Sherman Fugal and of $800 from

Jayson Fugal. In fact, these contributions were actually from Fugal &

Fugal, Inc., a corporation, d/b/a

Peggy Fugal Advertising.

The settlement also states that,

although UEG included disclaimers

on its advertisements that opposed

Mr. Orton’s opponent, the disclaimers failed to include a statement

indicating whether the ads had been

authorized by a candidate or candidate committee. Additionally, UEG

failed to file a statement of organization with the Commission within

10 days of becoming a political

committee, as required by 2 U.S.C.

§433(a).

The settlement includes no

judicial determination as to whether

expenditures of $11,452, made by

UEG to pay for ads opposing Mr.

Orton’s opponent, were in fact

excessive contributions to Mr.

Orton. The Commission, in its

administrative proceedings, had

found probable cause that UEG’s

expenditure had been coordinated

with the Orton campaign, based on

the fact that a former Orton campaign volunteer had participated in

some UEG activities. Under the law,

any expenditure made in cooperation with or at the suggestion of a

candidate or his campaign is considered a contribution. 2 U.S.C.

§441a(a)(7)(B)(i). In prior enforcement matters, the Commission had
June 1997 Federal Election Commission RECORD

7

interpreted this provision to cover

situations where the spender’s

activity was based on knowledge of

official campaign strategy, the

source of which was the candidate

or the campaign. The defendants

disagreed with the finding, arguing

that the Commission had no direct

evidence of the alleged violation.

The claims against all the defendants, including Mr. Orton and his

campaign committee, will be

dismissed with prejudice once UEG

pays the fine and amends its reports.

U.S. District Court for the

District of Utah, Central Division,

95-977W, April 27 and 28, 1997. ✦

New Litigation

DNC v. FEC (97-676)

The Democratic National Committee (DNC) asks the court to find

that the FEC’s actions on one part of

its administrative complaint against

Christian Coalition, Inc., are contrary to law. The FEC filed suit

against the Christian Coalition for

violations alleged in one part of the

DNC’s complaint, but closed the

investigation and did not file suit on

the part of the DNC complaint

alleging the Christian Coalition’s

failure to register and file reports as

a political committee. However, a

subsequent appeals court opinion

undercut the stated justification for

that decision. The DNC also asks

the court to order the FEC to take

action on this matter expeditiously.

After complaints against the

Christian Coalition by the DNC and

others and an FEC investigation, the

Commission filed a lawsuit in July

1996 alleging that the Christian

Coalition made prohibited corporate

contributions—in the form of

coordinated expenditures—on

behalf of Republican candidates

during the 1990, 1992 and 1994

election cycles, in violation of 2

U.S.C. §441b (see the September

1996 Record). In its original administrative complaint, the DNC had

charged that not only had the

Christian Coalition made prohibited

corporate contributions, but that it

had also made excessive contributions and that it had failed to register

and file with the FEC as a political

committee. 2 U.S.C. §§441b(a),

441a(a) and (f), 433 and 444.

The September 26, 1995, decision to file a lawsuit alleging only

the violation of prohibited contributions came after FEC Commissioners failed to provide the necessary

four-vote authorization for the

agency to also charge the Christian

Coalition with failure to register and

file as a political committee. The

two commissioners who voted

against including the registration

Jones v. FEC

On April 30, the U.S. District

Court for the Eastern District of

Michigan granted the FEC’s motion

to dismiss this case. The suit,

seeking $249 trillion in damages,

was filed in February by Alfonzo

Jones, a Detroit resident who said,

among other things, that the FEC

acted contrary to law in not certifying him for public financing for the

1996 presidential campaign.

The court found that Mr. Jones

failed to allege any facts in his suit

that indicated that the Commission

had illegally failed to provide him

with public funds.

U.S. District Court for the

Eastern District of Michigan, 97-

70006-PH, April 30, 1997. ✦

On Appeal?

Hagelin v. FEC and the

Commission on Presidential

Debates

On May 12, the U.S. Supreme

Court denied a request from Dr. John

Hagelin and the Natural Law Party to

hear this case. The U.S. Court of

Appeals for the District of Columbia

Circuit had upheld a lower court

ruling that dismissed this case for

lack of jurisdiction. See the November 1996 Record, page 1. ✦

and reporting allegation—Commissioners Lee Ann Elliott and Joan D.

Aikens—based their decisions on a

ruling from the U.S. Court of

Appeals for the District of Columbia

Circuit in Akins v. FEC (Akins I)

(see the February 1997 Record).

That opinion held that an organization does not constitute a political

committee under the Act unless, in

addition to receiving contributions

or making expenditures aggregating

in excess of $1,000 on behalf of

federal candidates in a calendar

year, its major purpose is the

election of candidates.

However, in December 1996, an

en banc panel of the appeals court

issued a new opinion (Akins II),

reversing its earlier decision. It said

that the major purpose test applies

only to groups making independent

expenditures. An organization that

makes contributions or coordinated

expenditures (also contributions)

need only satisfy the $1,000 threshold to qualify as a political committee under the federal election law.

On February 28, 1997, the FEC

notified the DNC that it had closed

the investigation of the Christian

Coalition in regard to all of the

DNC allegations except the prohibited corporate contributions and

independent expenditures.

The DNC asks the court to find

that, in light of the en banc opinion

from the appeals court, the FEC’s

failure to take any action on the

Christian Coalition’s failure to

register as a political committee was

contrary to law. In the alternative,

the DNC asks the court to find that,

if it is the FEC’s position that the

agency has not yet dismissed the

registration and filing complaint

against the Christian Coalition, then

the FEC has failed to take action on

this particular complaint in a timely

manner. The Act allows complainants to file suit against the FEC for

dismissing their complaint or for

failing to act within 120 days after

the complaint is filed. 2 U.S.C.

(continued on page 8)
Federal Election Commission RECORD June 1997

8

Right to Life of Dutchess

County, Inc. v. FEC

Right to Life of Dutchess County,

Inc., (RLDC) asks the court to find

that the FEC is acting contrary to

law in enforcing the regulation

found at 11 CFR 100.22(b), which

defines “express advocacy.” RLDC

cites the October 1996 ruling by the

U.S. Court of Appeals for the First

Circuit in Maine Right to Life

Committee v. FEC1

, which struck

down that provision on grounds that

it was beyond the scope of the

FEC’s authority.

RLDC is a nonprofit, membership corporation based in New

York. Its primary purpose is to

provide the general public with

information concerning political

candidates’ stands on pro-life issues.

It says it does not intervene in

political campaigns on behalf of or

in opposition to any candidate for

public office; nor does it support or

oppose federal candidates.

The group intends to make

communications to its members and

the general public—using newsletters, voter guides, columns, press

conferences, fliers and other methods—about the stances of federal

candidates on abortion. RLDC

would pay for such communications

from its general treasury, and would

accept donations offered it—even

those from corporations—in order to

fund such endeavors. RLDC maintains that these communications are

issue advocacy communications and

§437g(a)(8)(A). In addition, the

DNC asks the court to order the

FEC to pay attorney’s and other

relevant fees associated with this

lawsuit.

U.S. District Court for the

District of Columbia, 97-676, April

4, 1997. ✦

that they do not constitute express

advocacy under the Buckley v. Valeo

opinion. Under the current regulations defining express advocacy,

RLDC acknowledges that its

communications would be considered express advocacy and, since

RLDC is a corporation, that they

would be contrary to law.

The regulations defining express

advocacy were born out of the U.S.

Supreme Court decisions in Buckley

and Massachusetts Citizens for Life

v. FEC. The court held in MCFL

that the Federal Election Campaign

Act’s (the Act) ban on corporate

independent expenditures only

applies when the money is used to

“expressly advocate” the election or

defeat of a clearly identified candidate for federal office. The Buckley

decision lists examples of phrases

that constitute express advocacy:

“vote for,” “elect,” “support,” “vote

against,” “defeat,” “reject.” These

examples are codified in subsection

a of 11 CFR 100.22(a). However, in

subsection (b), the Commission

further defines express advocacy as

a communication that, when taken

as a whole and with limited references to external events (such as

proximity to an election), can only

be interpreted by a reasonable

person as unambiguously advocating the election or defeat of a clearly

identified candidate.

The RLDC contends that the FEC

continues to follow this section of

its regulations despite the appeals

court ruling that struck it down. The

group states that enforcement

proceedings against it by the FEC

would infringe upon its rights under

the law and would have a chilling

effect upon its future plans for

communications. Additionally, the

RLDC’s funding plans would be

contrary to the Act’s prohibition on

the use of corporate treasury funds

in connection with a federal election

if its actions were deemed express

advocacy and not issue advocacy. 2

U.S.C. §441b.

The RLDC asks the court to find

that subsection (b) of the regulation

is void and unenforceable and

enjoin the FEC from enforcing it.

The RLDC states that 11 CFR

100.22(b):

• Is in excess of the statutory

authority granted the FEC because

it regulates speech, which does not

constitute express advocacy;

• Contains vague language—such as

“when taken as a whole,” “limited

reference,” “external events” and

“proximity”—and provides

inadequate notice of what conduct

is actually prohibited; and

• Violates the Fifth Amendment’s

due process clause by vesting the

FEC with excessive discretion in

enforcing the Act.

U.S. District Court for the

Southern District of New York, 97-

2614, April 11, 1997. ✦

Court Cases

(continued from page 7)

1

 Maine Right to Life v. FEC (96-1532).

Federal Register

 Federal Register notices are

available from the FEC’s Public

Records Office.

Notice 1997-6

Electronic Filing of Reports by

Political Committees: Final

Rules; Announcement of

Effective Date (62 FR 22880,

April 28, 1997)

Notice 1997-7

Recordkeeping and Reporting by

Political Committees; Best

Efforts: Final Rule; Transmittal

of Regulations to Congress (62

FR 23335, April 30, 1997)

Notice 1997-8

Independent Expenditures and

Party Committee Expenditure

Limitations: Notice of Proposed

Rulemaking (62 FR 24367, May

5, 1997)
June 1997 Federal Election Commission RECORD

9

Congressional, PAC

Fundraising and

Expenditures Continue

Strong Showings in 1996

Election Cycle

Congressional candidates in 1996

raised nearly $800 million and spent

almost that much in a two-year

fundraising cycle that showed

marked increases from the previous

presidential election cycle in 1992.

The 2,605 candidates vying for

seats in the U.S. House and Senate

raised $790.5 million, a 20 percent

increase over 1992, and spent

$765.3 million, which was a 12

percent increase. The fundraising

also was ahead of 1994 election

cycle financial activity, with increases of 7 percent in money raised

and 5 percent in expenditures.

The jump in fundraising and

spending is due to House candidates, who raised $505.4 million of

the total and spent $477.8 million.

Among these candidates, Republicans outdid their Democratic

counterparts with a 32 percent

increase in financial activity over

the previous election cycle. The

Democrats mustered only an 8

percent increase in receipts and a 4

percent increase in expenditures

compared with the 1994 election

cycle. The large disparity is due, in

part, to the large number of Republican incumbents seeking reelection.

PACs continued their prominence

in federal elections, posting a 12

percent increase in money raised

and an 11 percent increase in

expenditures compared with the

1994 election cycle. PACs raised

$437.4 million and spent $429.4

million.

 Direct contributions to federal

candidates totaled $217.8 million,

up 15 percent from 1994. While

incumbents were able to attract far

more PAC money than their chalStatistics

(continued on page 10)

Contributions to 1996 Candidates from

Individuals, by Size of Contribution

Senate House

39.5% 36.5%

14.2% 9.8%

Democrats

$79.1 million

Republicans

$87.8 million

43.3%

14.5%

9.7%

32.5%

Other Parties

$0.6 million

73.4%

12.3%

7.8%

6.5%

Democrats

$117.5 million

31.7%

17.3% 14.6%

36.4%

Republicans

$155.4 million

32.9% 36.1%

17.1% 13.9%

Other Parties

$3.6 million

24.8%

44.6%

14.9%

15.5%

$200 or less

$200-$499

$500-$749

Greater than $749
Federal Election Commission RECORD June 1997

10

Statistics

(continued from page 9)

lengers—$146.4 million to $31.6

million—their take of PAC money

represented a lower proportion of

contributions to incumbents than in

previous years. In federal elections

where there was an open seat, PACs

contributed $39.8 million to candidates.

In addition to those contributions,

PACs made $10.6 million in independent expenditures, almost double

what they spent in the last election

cycle. PAC independent spending

on behalf of the 1996 presidential

campaign dropped from $4 million

in 1992 to $1.4 million in 1996.

None of these figures, however,

includes PAC spending on issue

advocacy campaigns. Such spending

is not reported to the FEC.

The charts that accompany this

article provide additional information about Congressional and PAC

fundraising during the 1996 election

cycle. More information about

financial activities during the most

recent campaigns is available in

news releases dated April 22, April

14 and March 19. The releases are

available:

• At the FEC’s web site at http://

www.fec.gov (click on “News

Releases and Media Advisories” at

the main menu); and

• From the Public Records office by

calling 1/800-424-9530 (press 3).✦

Median Activity of House General Election Candidates

This chart shows how much it cost the typical candidate to vie for a seat in the U.S. House of Representatives

during the 1995-96 election cycle, and compares those numbers with median disbursements of the two previous

election cycles.

1996

1994

1992

Incumbents Challengers Open Seats

600

500

400

300

200

100

 0

Thousands of Dollars
June 1997 Federal Election Commission RECORD

11

AO 1997-3

Status of State Affiliate as

State Committee of a

Political Party

The Constitutional Party of

Pennsylvania (CST/PA) satisfies the

definition and requirements of a

state committee set out in the

Federal Election Campaign Act (the

Act) and several advisory opinions.

This status results, in part, from its

affiliation with the U.S. Taxpayers

Party (USTP), which is a Commission-recognized national committee

of a political party.

The Act defines a state committee

as “the organization which, by

virtue of the bylaws of a political

party, is responsible for the day-today operation of such political party

at the State level.” 2 U.S.C.

§431(15). The definition of a state

committee also requires the existence of a political party. A political

party is “an association, committee,

or organization which nominates a

candidate for election to any Federal

office whose name appears on the

election ballot as the candidate of

such association, committee, or

organization.” 2 U.S.C. §431(16).

In AO 1992-30, the Commission

identified two requirements necessary for state political committee

status. The first is that the organization must have a state affiliate

agreement that “delineates activities

commensurate with the day-to-day

operation” of a party at a state level.

Second, the state affiliate must gain

ballot access for its presidential and

other federal candidates. The

application of these requirements

also can be seen in AOs 1996-51,

1996-43, 1996-27 and 1995-49.

The CST/PA satisfies the first

requirement. As in the other advisory opinions, the CST/PA’s by-

(continued on page 12)

Advisory

Opinions

Median Disbursements by Candidates for the U.S.

House of Representatives in 1996 Election

Type of Candidate Dollars

Republican Challengers Who Won 1,181,546

Democratic Incumbents Who Lost 708,778

Democratic Challengers Who Won 933,425

Republican Incumbents Who Lost 1,144,540

Republican Open Seat Winners 743,577

Democratic Open Seat Losers 526,735

Democratic Open Seat Winners 791,590

Republican Open Seat Losers 453,510

Independent Expenditures, 1996 Election Cycle

 For Against Total

 $314,689 $5,498,204 $5,812,893

$7,697,442 $2,254,670 $9,952,112

 $808,327 $181,599 $989,926

$2,540,241 $1,655,766 $2,196,007

Senate

Democrats

Senate

Republicans

House

Democrats

House

Republicans
Federal Election Commission RECORD June 1997

12

AO 1997-4

Contribution Limits for

Limited Liability Company

Eckert Seamans Cherin &

Mellott, L.L.C., a Pennsylvania law

firm organized as a limited liability

company (LLC), may make contributions to federal candidates from

its general treasury funds subject to

the limits set out in the Federal

Election Campaign Act (the Act).

The contributions from the firm will

not count against its members’

individual contribution limits with

respect to federal elections.

On January 2, the law firm filed a

certificate of organization with the

Pennsylvania Department of State as

an LLC. The firm formerly was

organized as a general partnership.

Under the Act, a person includes

“an individual, partnership, committee, association, corporation, labor

organization, or any other organization or group of persons.” 2 U.S.C.

§431(11). The Act includes a broad

prohibition at §441b(a) that prohibits corporations from contributing to

federal elections. Contributions by

“persons” who are otherwise not

precluded from contributing are

subject to the limits set out in §441a.

Partnerships are permitted to

contribute to federal elections, but

their contributions, in addition to

counting against the partnership’s

limit, must be attributed proportionately against each contributing

partner’s limit for that candidate and

election. 11 CFR 110.1(e).

In AOs 1996-13 and 1995-11, the

Commission determined that LLCs

did not fall into the category of

either partnership or corporation in

the states where they were formed,

and thus would be considered “any

other organization or group of

persons” for purposes of the Act.

The characteristics of LLCs set

out in the Pennsylvania statute

correspond, for the most part, with

the characteristics examined in the

previous AOs. Among those characteristics are the state statute’s

specific recognition of LLCs as a

laws delineate activity that is

commensurate with the day-to-day

functions and operations of a state

political party.

However, in one respect, the

CST/PA’s situation differs from

those presented in the advisory

opinions. The CST/PA’s by-laws do

not specify the name of the national

party to which the state party is

affiliated. The by-laws do, however,

state that in the event there is an

affiliation with a national party, then

the CST/PA would elect national

committee members and delegates

to a national convention. Additional

documents submitted to the FEC by

the CST/PA prove that it is indeed

an affiliate of the USTP.

Even if a state party is not

affiliated with a committee that has

achieved national party status, it still

may qualify as a state committee of

a political party if it also qualifies as

a political party. Advisory Opinions

1996-51 and 1996-43. To qualify as

a political party, the party organization must obtain ballot access for its

federal candidates. The USTP’s

presidential and vice presidential

candidates appeared on the ballot as

the candidates of the CST/PA, but

the only CST/PA Congressional

candidate on the ballot did not

qualify as a candidate under the Act.

Nevertheless, in view of the fact that

the CST/PA was an affiliate of the

USTP, a qualified national party

committee, and that the USTP’s

national candidates appeared on the

ballot as CST/PA candidates, the

CST/PA qualified as a political

party. Thus, the CST/PA satisfied

both elements necessary for status as

a state committee of a political party.

Date Issued: April 18, 1997;

Length: 4 pages. ✦

Advisory Opinions

(continued from page 11)

distinct form of business (i.e.,

distinct from corporations and

partnerships), the corporate attribute

of limitation of liability for all

members and the lack of the general

corporate attributes of free transferability of interests and continuity of

life. In addition, the firm’s operating

agreement corresponds to the

provisions of the Pennsylvania law.

In reaching the conclusion that

the firm may make contributions to

federal candidates from its general

treasury, the Commission assumes

that the firm is not a federal contractor. And, as in the previous advisory

opinions, the Commission assumes

that none of the members of the firm

is a corporation, federal contractor

or foreign national, whose contributions would be prohibited under the

Act.

Date Issued: April 25; Length: 4

pages. ✦
June 1997 Federal Election Commission RECORD

13

FEC Faxline Menu

FEC Faxline documents may be

ordered 24 hours a day, 7 days a week,

by calling 202/501-3413 on a touch

tone phone. You will be asked for the

numbers of the documents you want,

your fax number and your telephone

number. The documents will be faxed

shortly thereafter.

Federal Election Commission

411. Complete Menu of All Material

Available

501. The FEC and the Federal

Campaign Finance Law

502. La Ley Federal relativa al

Financiamiento de las Campañas

503. Federal and State Campaign

Finance Laws

504. Compliance with Laws Outside

the FEC’s Jurisdiction

505. Biographies of Commissioners

and Officers

506. Telephone Directory

507. Table of Organization

508. Index for 1996 Record

Newsletter

509. Free Publications

510. Personnel Vacancy

Announcements

Disclosure

521. Guide to Researching Public

Records

522. Accessibility of Public Records

Office

523. Federal/State Records Offices

524. Using FEC Campaign Finance

Information

525. State Computer Access to FEC

Data

526. Direct Access Program (DAP)

527. Sale and Use of Campaign

Information

528. Combined Federal/State

Disclosure Directory 1997 on

Disk

529. Selected Political Party Organizations and Addresses

530. Internet Access to the FEC

531. Downloadable Databases via the

Internet

532. Electronic Filing Took Kit

Limitations

546. Contributions

547. Coordinated Party Expenditure

Limits

548. Advances: Contribution Limits

and Reporting

549. Volunteer Activity

550. Independent Expenditures

551. Local Party Activity

552. Corporate Communications/

Facilities

553. Trade Associations

554. Foreign Nationals

555. The $25,000 Annual Contribution Limit

556. Personal Use of Campaign

Funds

Public Funding

566. Public Funding of Presidential

Elections

567. The $3 Tax Checkoff

568. 1993 Changes to Checkoff

569. Recipients of Public Funding

570. Presidential Fund Income Tax

Checkoff Status

571. Presidential Spending Limits

Compliance

581. Candidate Registration

582. Committee Treasurers

583. Political Ads and Solicitations

584. 10 Questions from Candidates

585. Filing a Complaint

586. 1997 Reporting Dates

587. 1996 Congressional Primary

Dates

588. 1997 Special Election Reporting

Dates

589 1997-1998 FEC Regional

Conference Schedule

Money in Politics Statistics

601. 1991-2 Political Money

602. 1996 Year-End Count

603. 1993-4 Congressional

604. 1993-4 National Party

605. 1993-4 PAC Finances

606. 1995-6 Congressional

607. 1995-6 National Party

608. 1995-6 PAC Finances

1996 Presidential

651. 1996 Presidential Primary Dates

652. Selected 1996 Campaign Names

and Addresses

653. Selected 1996 Campaign

Finance Figures

654. 1996 Public Funding Certifications and Payments

655. 1996 Presidential General

Election Ballots

656. 1996 Presidential General

Election Results

Office of Election Administration

701. List of Reports Available

702. Voting Accessibility for the

Elderly and Handicapped Act

703. National Voter Registration Act

Regulations

704. National Voter Registration Act

of 1993

705. The Electoral College

706. Organizational Structure of the

American Election System

707. Primary Functions of an

Electoral System

Forms

801. Form 1, Statement of Organization

802. Form 2, Statement of Candidacy

803. Form 3 and 3Z, Report for an

Authorized Committee

804. Form 3X, Report for Other Than

an Authorized Committee

805. Form 5, Report of Independent

Expenditures

806. Form 6, 48-Hour Notice of

Contributions/Loans Received

807. Form 7, Report of Communication Costs

808. Form 8, Debt Settlement Plan

809. Form 1M, Notification of

Multicandidate Status

Schedules

825. Schedule A, Itemized Receipts

826. Schedule B, Itemized Disbursements

827. Schedules C and C-1, Loans

828. Schedule D, Debts and Obligations

829. Schedule E, Itemized Independent Expenditures

830. Schedule F, Itemized Coordinated Expenditures

831. Schedules H1 – H4, Allocation

832. Schedule I, Aggregate Page

Nonfederal Accounts

Regulations (11 CFR Parts 100-201)

100. Part 100, Scope and Definitions

1007. Part 100.7, Contribution

1008. Part 100.8, Expenditure

101. Part 101, Candidate Status and

Designations

102. Part 102, Registration, Organization and Recordkeeping by

Political Committees

1021. Part 102.17, Joint Fundraising

by Committees Other Than SSFs

103. Part 103, Campaign Depositories

104. Part 104, Reports by Political

Committees

1047. Part 104.7, Best Efforts

105. Part 105, Document Filing

Information

(continued)
Federal Election Commission RECORD June 1997

14

106. Part 106, Allocations of Candidate and Committee Activities

107. Part 107, Presidential Nominating Convention, Registration and

Reports

108. Part 108, Filing Copies of

Reports and Statements with

State Offices

109. Part 109, Independent Expenditures

110. Part 110, Contribution and

Expenditure Limitations and

Prohibitions

1101. Part 110.1, Contributions by

Persons Other Than Multicandidate Political Committees

1102. Part 110.2, Contributions by

Multicandidate Committees

1103. Part 110.3, Contribution

Limitations for Affiliated

Committees and Political Party

Committees; Transfers

1104. Part 110.4, Prohibited Contributions

1105. Part 110.5, Annual Contribution

Limitation for Individuals

1106. Part 110.6, Earmarked Contributions

1107. Part 110.7, Party Committee

Expenditure Limitations

1108. Part 110.8, Presidential Candidate Expenditure Limitations

1109. Part 110.9, Miscellaneous

Provisions

1110. Part 110.10, Expenditures by

Candidates

1111. Part 110.11, Communications;

Advertising

1112. Part 110.12, Candidate Appearances on Public Educational

Institution Premises

1113. Part 110.13, Nonpartisan

Candidate Debates

1114. Part 110.14, Contributions to

and Expenditures by Delegates

and Delegate Committees

111. Part 111, Compliance Procedure

112. Part 112, Advisory Opinions

113. Part 113, Excess Campaign

Funds and Funds Donated to

Support Federal Officeholder

Activities

114. Part 114, Corporate and Labor

Organization Activity

115. Part 115, Federal Contractors

116. Part 116, Debts Owed by

Candidates and Political

Committees

200. Part 200, Petitions for Rulemaking

201. Part 201, Ex Parte Communications

Recent Actions on Regulations,

Including Explanations

and Justifications

227. Electronic Filing of Reports by

Political Committees

228. Coordinated and Independent

Expenditures by Party Committees

229. National Right to Life Committee, Inc., Rulemaking Petition.

U.S. Code (Title 2)

431. Section 431 442. Section 442

432. Section 432 451. Section 451

433. Section 433 452. Section 452

434. Section 434 453. Section 453

437. Section 437 454. Section 454

4377. Section 437g 455. Section 455

438. Section 438

439. Section 439

441. Section 441

4411. Section 441a

4412. Section 441b

4413. Section 441c

4414. Section 441d

4415. Section 441e

4416. Section 441f

Advisory Opinions

7000. Brochure

9701-4. AOs 1997-1 through 1997-4

9601-52. AOs 1996-1 through 1996-52

9501-49. AOs 1995-1 through 1995-49

9401-40. AOs 1994-1 through 1994-40

9301-25. AOs 1993-1 through 1993-25

9201-44. AOs 1992-1 through 1992-44

9101-40. AOs 1991-1 through 1991-40

9001-40. AOs 1990-1 through 1990-40

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

committe of political party, 6:11

1997-4: Application of contribution

limit to limited liability company,

6:12

Court Cases

FEC v. _____

– Charles Woods for U.S. Senate,

4:6

– Christian Action Network, 1:5; 5:5

– DSCC (95-2881), 3:2

– Fund For a Conservative Majority,

1:5

– Kalogianis, 5:3

– McCallum, 2:4

– Orton, 6:6

– Parisi, 1:4

– Public Citizen, 4:6

– Williams, 2:3

_____ v. FEC

– Akins et al., 2:1

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

– Clark, 5:1

– Common Cause (96-5160), 5:4

– DCCC (96-0764), 1:4

– DNC (96-2506), 1:5; 5:5

Information

(continued from page 13)
June 1997 Federal Election Commission RECORD

15

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.

– DNC (97-676), 6:7

– DSCC (96-2184), 1:2

– Hagelin, 6:7

– Hooker, 1:5

– Jones, 6:7

– NRCC (96-2295), 1:2

– Reilly, 1:4

– Right to Life of Dutchess Co.,

Inc., 6:8

– RNC (94-5248), 2:5

Reports

Electronic Filing, 2:1

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
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Federal Election Commission RECORD June 1997