Volume 7, Number 12

THE FEDERAL ELECTION

COMMISSION

1325 KStreet N.W., Washington, D.C. 20463

December 

•

REPORTING INTERNAL

COMMUNICATIONS BY CORPORATIONS,

LABOR ORGANIZATIONS AND OTHER

MEMBERSHIP ORGANIZATIONS

The Federal Election Campaign Act of 1971, as

amended, allows communications by a corporation "to

its stockholders and executive or administrative personnel and their families, and communications by a memo

ship organization (including a labor organization) to its

members and their families on any subject. 2 U.S.C.

§441 btb) (2)(Al. The Act, however, requires the reporting of certain communication costs paid with

corporate or membership organization funds if those

costs exceed $2,000 per election. 2 U.S.C.

§431 (9)(B)Oii). The reporting obligation applies to

those communications which expressly advocate the

election or defeat of a clearly identified candidate

(partisan communications). Communications primarily

devoted to subjects other than express advocacy of the

election or defeat of a clearly identified candidate are

not covered by this particular reporting requirement.

The $2,000 threshold for reporting applies separately

to each election process within a calendar year (i.e.,

all primary elections, the general election and any

special or run-off elections). 2 U.S.C. §431 (1HA).

Each corporation, each incorporated subsidiary and

each State and local labor organization has a separate

$2,000 threshold. Therefore, each entity does not

report until the threshold is reached.

Note: This particular reporting requ irement is not

applicable to "political committees" as defined by 2

U.S.C. §431 (4l.

What Form To Use

Corporations, labor organizations and other membership organizations required to file a report under

these provisions should use either FEC Form 7 or a

letter containing the same information.

What Must Be Reported

Each report filed under these provisions must include

the following for each communication:

1. The type of communication (e.g., direct mail, tel

phone or telegram).

2. The class or category communicated with (e.

members, stockholders or executive/administrati

personnel).

3. The date(s) of the communication.

4. Whether the communication is in support of, or 

opposition to, a particular candidate.

5. The name of the candidate, the office sought, th

district and State of the office and whether th

communication was for the primary or the gener

election.

6. The cost of the communication.

Note: In the case of a communication which adv

cates the election or defeat of more than one cand

date, the cost should be allocated among the cand

dates according to the benefit they are expected 

derive and should be reported accordingly.

When to Report

Organizations required to report under these pr

visions must file quarterly reports during a calendar ye

in which a regularly scheduled general election is held. 

addition, a 12-day pre-general election report must 

filed for activity in connection with any general electio

Reports are required beginning with the first reporti

period during which the aggregate cost for com

munications exceeds $2,000 per election and for ea

period thereafter in which the organization makes a

additional disbursements in connection with the sam

election. 2 U.S.C. §431 (9) (B)(iii); 11 CFR 100.8(bIl4

104.6 and 114.3.

(FEC Agenda Document No. 81-151)

For more information on reporting procedures, consu

the instructions on FEC Form 7 or contact: Office 

Public Communications, Federal Election Commissio

1325 K Street, N.W., Washington, D.C. 20463, or ca

202-523·4068 or toll free 80Q.424-9530.

For statistics on communication costs, see p, 7.
4 The Federal Election Campaign Act, as amended in 1979

ADVISORY OPINION REQUESTS

Advisory Opinion Requests (AORs) pose questions on

the application of the Act or Commission Regulations to

specific factual situations described in the AOR. The

following chart lists recent AORs with a brief description of

the subject matter, the date the requests were made public

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

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

Office of Public Records.

HONORARIA LIMIT REPEALED

On October 1, 1981, Congress approved legislation

repealing 2 U.S.C. §441 Ha)(2), a provision of the election

law4that had placed an overall $25,000 annual limit on

honoraria that a federal officeholder or employee could

accept for speeches, appearances and articles (Pub. L.

97·51). The $2,000 limit on individual honorarium payments continues to apply. The Senate Appropriations

Committee had approved the repeal as an amendment

to House Joint Resolution 325, an interim funding measure

that provided continuing appropriations into Fiscal Year

1982 for federal programs without permanent funding.

2

4

2

No. of

Pages

Date Made

AOR Subject Public

1981-49 Contribu ti0 ns and ex- 10/14/81

penditures mede on

behaIf of state and local

candidatesby holdingcompanyof federally

charteredsavi ngs and

loan.

1981-50 Partnership's services to 10/22/81

facilitatemembers' con- tributions to candidates.

1981-51 Volunteerservices oHered 10/27/81

by foreignartist to candidate committee.

FEC HOLDS HEARINGS

ON CORPORATE/LABOR COMMUNICATIONS

On October 26, 1981, the Commission held a public

hearing on possible revisions to Sections 114.3 and 114.4 of

F EC Regulations, which govern partisan and nonpartisan

communications that may be made by labor organizations

and corporations (including incorporated trade associations,

incorporated membership organizations, cooperatives and

corporations without capital stock). During a full day of

hearings presided over by Chairman John Warren McGarry,

the Commissioners heard testimony from nine witnesses

representing the following organizations (listed in order of

their testimony): the National Soft Drink Association, the

National Association of Broadcasters, the Washington Legal

Foundation, American Bankcorp, lnc., the National Right

to Work Committee and the AFL-CIO. Comments on

nonpartisan communications ranged from suggestions to

clarify the definition of "nonpartisan" communications

covered by Section 114.4 to suggestions for modifying the

conditions under which nonpartisan communications may

be made. Comments on partisan communications included

a suggestion that an organization be allowed to follow the

rules for partisan appearances, even if a few nonsolicitable

employees helped administer a meeting at which candidates

or party representatives addressed the organization's

solicitable class (i.e., its executive and administrative

employees and members).

Copies of the written comments may be obtained by

contacting the FEC's Public Records Office at 202-

523-4181 or toll free 800-424-9530.

Prior to holding the public hearing, the Commission had

received 42 written comments on possible revisions to

Sections 114.3 and 114.4. The Commission will review

these comments and testimony before drafting final proposed revisions to Sections 114.3 and 114.4.

The RECORD is pUblished by the Federal Election Commission, 1325 K Street, N.W., Washington, D.G. 20463. Commissioners are: John Warren McGarry, Chairman; Frank P. Reiche, Vice Chairman; Joan D. Aikens, Thomas E. Harris;

Vernon W. Thomson; Robert 0. Tiernan; William F. Hildenbrand, Secretary of the Senate, Ex Officio; Edmund L.

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

800/424-9530.

2
•

•

•

ALTERNATE DISPOSITION OF

ADVISORY OPINION REOUESTS

AOR 1981-31 (Property made available to candidate for

use in fundraising raffle) was withdrawn by its requester

on September 14. 1981.

ADVISORY OPINIONS: SUMMARIES

An Advisory Opinion (AO) issued by the Commission

provides guidance with regard to the specific situation

described in the AOR. Under the 1979 amendments to the

Act, any person may request an AD on a specific activity

which the person intends to undertake. The requester

will not be subject to any sanctions under the Act if he/she

acts in accordance with the opinion. Other persons may

rely on the opinion if they are involved in a specific activity

which is indistinguishable in all material aspects from the

activity discussed in the AD. Those seeking guidance for

their own activity, however, should consult the full text of

an AD and not rely only on the summary given here.

AO 1981-37: Corporate and Union Purchases

in Connection With Public

AffairsPrograms Featuring

Congressional Candidate

Corporations and unions may purchase tickets and advertising in connection with a public affairs series that will be

moderated by Congressman Richard A. Gephardt and

sponsored by Delano Productions, Inc. (Delano). Since the

major purpose of the programs is not to influence Congressman Gephardt's nomination or election, expenditures made

by unions and corporations with regard to television and

radio broadcasts (and rebroadcasts) of the series will

not result in prohibited contributions to his campaign

committee. The Commission expressly conditioned its

approval of these expenditures on:

1. The absence of any communication expressly advocating

the nomination or election of Congressman Gephardt or

the defeat of any other candidate;

2. The avoidance of any soliciting, receiving or making of

campaign contributions in connection with the series;

3. Delano's compliance with its stated intention not to sell

political advertising for any broadcast or rebroadcast of

the programs; and

4. Delano's adherence to guidelines mentioned in AO 198(}

90 concerning the sale of transcripts and their use by

corporations and labor organizations.

This opinion supersedes AOs 1975-8. 1975-13. 1975-20 and

1975-10B. which held that speeches made by a candidate

before a substantial number of the candidate's constituency would be considered an activity advancing his/her

candidacy! This opinion also qualifies AO 1977-31, which

held that a corporation's employment of a candidate as an

announcer constituted a contribution to his campaign.

The Commission expressed no opinion on the application

of House Rules or the Communications Act (or related

rules and regulations of the Federal Communications

• The programs will be held in St. Louis, a city that is partially

situated within Congressman Gephardt's Congressional district.

3

Commission) to this activity since they are bey

FEC's jurisdiction. Commissioner Joan D. Aikens 

concurring opinion. (Date issued: October 13

Length: 6 pages, including concurring opinion)

AO 1981-38: Publication's Use of Information

in FEC Reports

CAMPAC Publications (CAMPAC) may use info

obtained from reports filed with the FEC in con

with the publicatlon of a national newsletter cove

political campaigns of federal candidates. CAMPA

to use the names and addresses of candidates, c

workers and consultants - but not contributors - t

information on campaigns and to build a subscriptio

To protect the privacy of individuals who make C

tions, the Act and Commission Regulations p

strictions on the use of information disclosed in 

filed under the Act. The election law prohibits th

information about individual contributors for purp

soliciting contributions or for commercial purp

U.S.C. §438(a); 11 CFR 104.15(a). Although CA

intends to use the information for commercial p

CAMPAC's use of information disclosed on FEC re

permissible because its newsletter will not includ

mation about individual contributors. In fact. C

plans to use information derived from FEC Sche

which itemizes expenditures. (This schedule do

contain information on individual contributors, 

when a contribution has been refunded.) (Date 

October 13, 1981; Length: 3 pages)

AO 1981·42: Consultant's Payment of Rental Fee

for Equipment Used by Campaign

If Consulting Associates (Consulting). a campaign m

ment and consulting corporation hired by the Fitzge

Congress Committee (the Committee). pays the re

for office machines used by the campaign, Cons

payment might be considered a prohibited contribu

the Committee. Consulting entered into an agreeme

the Committtee to provide certain campaign service

agreed price, plus expenses. Consulting and the Com

are CUrrently in conflict as to which organization 

for the debt incurred for the rental of the office m

Under the following circumstances. payment of the 

Consultlnq would result in a prohibited corporate co

tion:

1. If Consulting was not obligated to pay the ren

under the terms of its contract with the Com

Consulting would be making a contribution in-

the Committee by paying the debt and allOW

Committee to use the equipment free of charge 

reduced rate. 11 CFR 100.7Ia)(l)(iii). Note. h

that if Consulting pays the debt as a result of 

judgment holding it liable for the rental fee. th

ment would not be considered a contribution.

2. Apart from the issue of who is liable for the re

under the terms of the contract. Consulting 

be making a prohibited contribution to the Com

if it treated the Committee differently from other 

in similar circumstances, l.e., if Consulting ex

credit to the Committee for a period of time 

con
"normal business practice" without making a "commercially reasonable attempt to collect the debt." 11

CFR 100.7(a)(4).

The Commission noted that it has no jurisdiction to determine each organization's obligations and rights under the

contract. Such determinations are subject to relevant state

law. (Date issued: October 13,1982; Length: 3 pages)

AO 1981·43: Nonpartisan Get-Out-The-Vote

Posters Sponsored by Trade

Association PAC

The American Hotel & Motel Association Political Action

Committee (AHMPAC1, the separate segregated fund of a

trade association, the American Hotel and Motel Association (AH & MA), may finance posters urging the general

public to "Support The Candidate Of Your Choice."

AHMPAC plans to distribute the posters to individual and

corporate members of AH & MA, who will display them at

their respective hotel properties.

Under Commission Regulations, the separate segregated

fund of a trade association may finance communications

directed to the general public, as long as the communications do not solicit contributions from individuals outside

the trade association's solicitable class. 11 CFR 114.5lil.

The poster AHMPAC plans to distribute is not considered a

solicitation to AHMPAC because it will contain no reference to AHMPAC or AH & MA Nor is the poster considered an expenditure because, although it will contain a

picture of AH & MA's president, he is not a candidate for

any federal office. Payments for the posters must nevertheless be reported by AHMPAC as general"disbursements." 2

U.S.C. §434(b)(4)(H)(v); 11 CFR 104.3(bll3) [ix]. Commissioner Frank P. Reiche filed a concurring opinion.

Commissioner Thomas E. Harris filed a dissenting opinion.

(Date issued: November 4, 1981; Length: 5 pages, including

concurring and dissenting opinions)

AO 1981-44: Multicandidate Committee's Expenditufes

Advocating Candidate's Defeat

Expenditures made by the National Conservative Political

Action Committee (NCPAC) for radio commercials that

criticized Congressman Les Aspin's vote against President

Reagan's tax program and advocated his defeat in 1982 do

not constitute a "contribution" to Mr. Aspin or his earnpaign committee, the Friends of Les Aspin, even though

NCPAC communicated with Mr. Aspin about the expenditures before making them. Accordingly, neither Mr. Aspin

nor his campaign committee is required to report NCPAC's

expenditures as "contributions" to Mr. Aspin's campaign.

Nor are the expenditures subject to the dollar limits the

Act imposes on contributions by multicandidate political

committees.

NCPAC had sent out a press release notifying Mr. Aspin and

13 other Congressmen that it planned to "alert voters" in

their respective Congressional districts to the fact that

"their Congressman is working against the Reagan tax cut."

If the Congressmen chose not to support the Reagan tax

cut, NCPAC informed them that it was "prepared to expose

their records" through radio and direct mail campaigns.

NCPAC would also run "additional, harder hitting com4

mercials." In a follow-up letter to Mr. Aspin, NCPAC

offered to run a media campaign "applauding" him if he

announced his support of the tax cut bill. Mr. Aspin

subsequently announced that he would vote against the tax

cut bill.

As defined by the Act, the funds NCPAC spent advocating

Mr. Aspin's defeat do not constitute "contributions" to his

campaign because:

The campaign did not accept a gift or "anything of

value" from NCPAC (2 U.S.C. §431(8)(A); 11 CFR

100.7(a)(l )); and

Although NCPAC communicated with him, the expanditures did not aid the " ... candidate in a manner indistinguishable in substance from the direct payment of

cash ...." 11 CFR 109.1 (c). (See also, Conference

Report on the FECA Amendments of 1976, H.R. Rep.

No. 94-1057, 94th Cong., 2d Sess. 59(1976).)

Because Mr. Aspin racked standing to ask the question, the

Commission expressed no opinion on whether NCPAC's

expenditures constituted contributions to other candidates

who may oppose Mr. Aspin in a future campaign. 11 CFR

112.1 (bl. Moreover, the Commission expressed no opinion

on the application of statutes outside its jurisdiction.

(Date issued: November 9.1981; Length: 3 paqes]

SELECTED BIBLIOGRAPHY

OF CAMPAIGN FINANCE

LAWS AVAI LABLE

During October 1981, the FEC's Library issued an

updated edition of its Campaign Finance and Federal

Elections Bibliography. The Bibliography, which is updated periodically, provides a selected, annotated cornpilation of publications issued from January 1977 through

September 1981. Indices and data bases searched for

bibliography entries included the Reader's Guide to

Periodical Literature, the Index to Legal Periodicals, the

Current Law Index, the Social SciencePeriodical Index, the

Social Sciences Citation Index and the Library of Congress'

computerized.file of current periodical holdings. Entries

are listed according to four information caterqories:

Part I: Legislative history of the Federal Election Campaign Act from 1971 through the passage of the

1979 amendments (Pub. L. 96-1871.

Part II: Books. monographs, treatises and studies.

Part III: Manuals, guidebooks, reference services and search

tools.

Part IV: Law review articles and articles from business, political science and general periodical indexes.

Copies of the Campaign Finance and Federal Elections

Bibliography are available for review and copying in the

FEC's Office of Public Records. Requests for the Bibliography should be accompanied by a money order or check for

$2.00 payable to the U.S. Treasurer, and sent to the FEC's

Office of Public Records.
l,

CANDIDATES RUNNING FOR MORE

THAN ONE OFFICE

If a candidate is running for more than one federal office,

must he or she maintain separate campaign organizations?

Yes. A candidate must establish completely separate

campaign organizations. For each office sought, the candidate must file a Statement of Candidacy (FEC Form 2),

designating a separate principal campaign committee.

Within 10 days after the candidate designates a principal

campaign committee, its treasurer must file a Statement of

Organization (FEC Form 1) for that committee. 11 CFR

110.8(d)(1 ).

Do these procedures apply to an individual who is a candidate for both a federal and a state office?

Yes. Separate campaign organizations must be established, but only the candidate's federal campaign committee is required to register and report under the Federal

Election Campaign Act.

Mayan individual contribute to each campaign of a candidate running for more than one federal office?

Yes. An individual may contribute up to $1,000, per

election, to each of the candidate's campaigns, provided he

or she clearly designates in writing the campaign for which

the contribution is intended (e.g., Senate primary campa19nl. 11 C FR 110. 1(fl.

May the committees of a candidate who is actively campaigning for more than one federal office share personnel

and facilities?

Yes, provided none of the campaigns receives Pres;-

dential public funds and provided that the campaigns

allocate the expenditures between them. 11 CFR

110.8(d)(31.

Maya candidate who is actively campaigning for more than

one federal office transfer funds, goods Drservices between

campaign organizations?

No. 11 CFR 110.8(d)(2).

Once a candidate has decided to campaign actively for only

one office, may funds then be transferred from the inactive

campaign to the active one?

Yes, provided three conditions are met:

1. One of the campaigns must officially become inactive by

either filing a termination report with the FEC (or other

appropriate office)" or by notifying the appropriate

office that the candidate and his/her authorized committees will no longer make expenditures, except to

retire debts. 11 CFR 110.3(a){2)(v)(AI.

2. The candidate has not received any Presidential public

funds. 11 CFR 110.3(al(21(vl(CI.

• The notice of termination should be filed with the Clerk of the

House, the Secretary of the Senate or the FEC, as appropriate.

11 CFR Part 105.

5

3. The treasurer of the active campaign committ

ensure that the transfer will not cause a contri

exceed his/her limits for the candidate's active ca

11 CF R 110.3(a)(2}(v)(BI.

How can the treasurer ensure that transfers fr

inactive committee will not result in excessive contr

to the active committee?

The treasurer may do this by examining funds 

red from the inactive committee on a "last in, fi

basis. For example, if $6,000 in contributions is tra

from the inactive committee, the treasurer should 

each contribution making up the last $6,000 in c

tions received by the inactive committee. A cont

should be excluded from the transfer if it causes 

co

PUBLIC RECORDS ACCESSIBLE TO

HISPANIC AND HANDICAPPED PERS

In order to encourage public disclosure of 

paign finance records, the Federal Election C

mission has made a concerted effort to make 

Publ ic Records Office accessible to as many per

as possible, includinq Hispanics and the physi

handicapped.

For Hispanic visitors, a staff member fluen

Spanish is available for asssistance.

Staff are also available to assist handicapped per

in locating, reviewing, copying and understan

campaign finance reports. computer indexes 

other FEC documents. For visitors with he

impairments, staff will provide literature that exp

what information is available and write out respo

to questions.

For visitors who are visually impaired, the P

Records Office makes available visual aids. suc

stationary page magnifiers and hand-held magni

glasses. Zoom lenses on the microfilm machines 

to review and copy documents also magnify i

mation. On request, staff will also prepare cassett

campaign finance information for visually imp

persons living outside the Washington, D.C. area.

The Commission's offices at 1325 K Street, N

Washington, D.C. 20463, are located within one 

half blocks of Metro bus lines and the McPh

Square Metro subway stop (blue llne]. The P

Records Office is on the ground floor of the buil

All entrances are barrier-free, and restrooms 

equipped for the handicapped.
butor to exceed his/her $1,000 limit when added to a

contribution made by the same donor to the active committee. See the procedures spelled out in Section

110.3(a)(2)(v)(B) of Commission Regulations.

REPORTING BY AUTHORIZED CANDIDATE

COMMITTEES

How should an authorized candidate committee (other than

the principal campaign committee) file its campaign finance

reports?

The authorized committee must file its reports with the

candidate's principal campaign committee. The principal

campaign committee, in turn, files the reports (together

with its own reports) with the appropriate state and federal

offices. In addition, the principal campaign committee files

an FEC Form 3Z, consolidating its own receipts and

disbursements with those reported by any authorized

commltteets), 11 CFR 104.3(f) and 108.1.

SUPREME COURT DENIES CERT IN FEC v.

MACHINISTS NON-PARTISAN POLITICAL

LEAGUE AND CITIZENS FOR DEMOCRATIC

ALTERNATIVES IN 1980

On October 13, 1981, the Supreme Court denied a

petition for a writ of certiorari, which the Commission had

filed on June 9, 1981, in two subpoena enforcement

actions, FEC v, MachiniS!$ Non-Psrisen Political League and

FEC v, Citizenstor Democratic Alternatives in 7980. The

Commission's petition sought review of decisions issued by

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

Circuit on May 19, 1981. In overturning the district court's

orders enforcing subpoenas the Commission had issued to

the defendants, the appeals court found that the Commission "lacked subject matter jurisdiction over the ...

activities it sought to investigate," (For a detailed summary

of the appeals court's decision in the cases, see the July

1981 Record, p. 5.1

FEC WITHDRAWS APPEAL OF

PHILLiPS PUBLISHING, INC. SUIT

On October 30, 1981, the U,5. Court of Appeals for the

District of Columbia Circuit granted the FEC's motion to

withdraw its appeal of FEe v, PhiINps PUblishing, Inc. (Civil

Action No. 81·2015). In a motion filed on October 21,

1981, the Commission stated that it was withdrawing the

appeal "in the interest of judicial economy," but that it

continued to believe "the district court's decision was

erroneous." On July 16, the district court had denied the

FEC's petition for court enforcement of two subpoenas

against Phillips Publishing, Inc. The FEC had issued the

6

subpoenas as part of an inve~tigation into a complaint filed

by the Kennedy for President Committee in March 1980.

For a detailed summary of the district court's opinion, see

page 2 of the September 1981 Record.

NEW LITIGATION

Kennedy for President Committee v. FEC

Plaintiff asks the district court to declare that the FEC

violated the Government in the Sunshine Act (5 U.S.C.

§552b) by:

1. Considering the final audit report on Senator Edward

Kennedy's Presidential primary campaign in executive

sessions; and

2. Failing to indicate in public notices of the executive

sessions that the FEC would consider plaintiff's audit

report.

Plaintiff asks the court to enjoin the FEC from further

violations of the public notice provisions of the Government in the Sunshine Act, and from continuing to review

audit reports in closed sessions.

Plaintiff further asks the court to order the FEC to make

available to the Kennedy campaign and the public a tape

recording or written transcript (as well as any other documents) pertaining to the FEC's discussion of the audit

report at the executive sessions.

(U.S. District Court for the District of Columbia, Civil

Action No. 81-2552, October 21, 1981)

CHANGE OF ADDRESS

Political Committees

Registered political committees are automatically

sent the Record. Any change of address by a regis·

tered committee must, by law, be made in writing as

an amendment to FEe Form 1 (Statement of Organi·

zation] and filed with the Clerk of the House, the

Secretary of the Senate or the FEC, as appropriate.

Other Subscribers

Record subscribers (who are not political committees), when calling or mailing in a change of address,

are asked to provide the following information:

1. Name of person to whom the Record issent.

2. Old address.

3. New address.

4. Subscription number. The subscription number is

located in the upper left hand corner of the mailing label. It consists of three letters and five nurnbers. Without this number, there is no guarantee

that your subscription can be located on the

computer.
AUDITS RELEASED

TO THE PUBLIC

The Federal Election Campaign Act, as amended (the

Act) gives the Commission authority to audit campaigns of

all Presidential candidates who receive public funds and the

campaigns of other political committees. Final audit reports

are available to the press through the Press Office and to

the general public through the Office of Public Records.

The following is a chronological listing of audits released

between September 28 and November 9, 1981.

--

Audit

1. Kennedy for President Committee (Final

Audit Report of the Primary Campaign)

2. Republican State Central Committee of

Iowa and its Finance Committee

3. National Unity Campaign for John

Anderson (Final Audit Report of the

-General Election Campaign)

4. Carter/Mondale Presidential Committee,

Inc. (Addendum to the Final Audit Report for the Primary Campaign)

Date Made

Public

9/28/81

9/28/81

10/19/81

11/9/81

partisan communications may be directed only t

holders, executive and administrative personnel a

families. Membership groups may direct these co

cations only to individual members, individual rep

tives of member corporations and the organization

tive and administrative personnel and their familie

organizations may make partisan communications 

members and their families. Disbursements for "co

cation costs" may be made in addition to the contr

and independent expenditures made by the separa

gated funds (political action committees or PACs) 

groups. Communication costs must be reported w

exceed $2,000 per election. (See reporting proce

P. 1.)

In the 1979·80 election cycle, a total of 62 groups

ing 57 labor organizations, four membership gro

one corporation reported "communication costs.

percent was spent advocating the election of can

twenty percent was spent advocating their de

contrast, communication costs reported in the 

election cycle totaled approximately $313,000. 

71 groups, mostly labor organizations, reported 

$2.1 million.

A comprehensive statistical study of these expe

the FEC Index of Communication Costs for 19

available for $5 from the Public Records Office, 

Election Commission, 1325 K Street, N.W., Was

D.C. 20463. Or call: 202-523·4181 or toll fre

424-9530.

Chart I below lists the 10 groups that reported spen

most money on communication costs during 

Chart II lists the 15 candidates for or against w

most communication costs were reported.

CHART 1

INTERNAL COMMUNICATION COSTS

REPORTED BY LABOR ORGANIZATIONS

AND CORPORATIONS

Labor organizations, corporations and membership

groups reported spending $3,9 million during 1979-80 for

internal, partisan communications related to federal elections, according to a statistical study released by the FEC

in October 1981. Of the total reported, labor organizations

spent close to $3 million, membership groups spent approximately $1 million and the sole corporation reporting

these expenditures spent less than $4,000.

The election law allows corporations, labor organizations

and membership groups to finance internal communications that expressly advocate the election or defeat of

federal candidates. In the case of corporations, these

7

Organization

National Rifle Association

American Federation of State,

County & Municipal

Employees

AFL·CIO

UAW

United Steelworkers of

America

National Education Association

Chamber of Commerce of the

U.S.

Ohio AFL·CIO

Communication Workers of

America

International Union of Bricklayers

& Allied Craftsmen

Grand Total

Tot

Commun

Cos

$ 803

532

441

402

209

183

158

149

91

85

$3,057
CHART II

Candidate Total Costs Costs

Communication Advocating Advocating

Costs Election Defeat

Jimmy

Presidential

Edward Kennedy (D)

Carter (D) $1,636,394

598,577

$1,510,925

443,077

$125,469

155,500

Ronald Reagan (R) 318,914 64,784 254,130

John Anderson (I) 60,003 60,003

Edmund G. 8rown, Jr. (D) 23,284 23,284

Senatorial

Bireh Bayh (D·IN) $ 44,770 $ 44,292 $ 478

John Glenn (D·OH) 39,093 3B,551 542

Donald Stewart (D·AL) 28,256 28,256

Gaylord Nelson (D·WI) 27,989 15,094 12,895

Charles MeC. Mathias (R·MD) 25,309 25,061 248

House

Les Aspin (D·WI) $ 20,642 $ 20,642 $

Robert Kastenmeier (D·WI) 18,485 16,699 1,786

Edward P. Beard (D·RI) 16,464 15,804 680

Frank Thompson, Jr. (D·NJ) 15,510 15,285 225

Royden P. Dyson (D·MD) 12,323 4,154 8,169

FEDERAL ELECTION COMMISSION

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