FEDERAL ELECTION COMMISSION

6 ADVISORY OPINIONS

20463 Volume 15, Number 1

800 LINE

7 Debt Retirement by Candidate Committees

continued on p. 2

REGULATIONS

4 Debts Owed by Candidates and Committees

Notice of Proposed Rulemaking

5 MCFL Rulemaking: Public Hearing

REPORTS

1 1989 Reporting Schedule

COMMISSIONERS

1 New Officers Elected

1989 REPORTING SCHEDULE

The accompanying charts list filing dates for

reports required during the 1989 nonelection year

Since special elections may occur during a non

election year, the reporting schedule below also

explains the filing requirements for committees

active in these elections. Note that a politica

committee may not terminate its registration and

reporting obligations during 1989 until all its

debts have been extinguished.

TABLE OF CONTENTS

PUBLICATIONS

15 Free Record Reprints

15 INDEX

9 COURT CASES

STATISTICS

12 Congressional Campaign Activity

14 National Party Activity

January 1989 999E Street NW Washington DC

FEe ELECTS NEW OFFICERS

On December 15, 1988, the Federal Election

Commission unanimously elected Danny L. MeDonald as Chairman and Lee Ann Elliott as Vice

Chairman. They will serve one-year terms commencing January 1, 1989. Mr. McDonald succeeded Commissioner Thomas J . .Josefiak in the

chairmanship. Mrs. Elliott succeeded Commissioner ~cDonald as Vice Chairman.

Commissioner McDonald, a Democrat, has

been a member of the Commission since December 17, 1981. Prior to his appointment to the

Commission, he served as General Administrator

of the Oklahoma Corporation Com mission, responsible for the management of 10 regulatory

divisions. He was Secretary of the Tulsa County

Election Board from 1974 to 1979, and served as

Chief CIerI< of the Board in 1973. He has also

served on the Advisory Panel to the FECls National Clearinghouse on Election Administration. A

native of Sand Springs, Oklahoma, Mr. McDonald

graduated from Oklahoma State University and

attended the John F. "Kennedy School of Government at Harvard University. His term as FEC

Commissioner is scheduled to expire on April 30,

1993.

Commissioner Elliott, a Republican, has been

a member of the Commission since December 17,

1981. Prior to her appointment to the Commission, she was Vice President of Bishop, Bryant &

Associates, Inc. of Washington, D.C. From 1970

to 1979, she served as Associate Executive Director of the American Medical Political Action

Committee, 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

Chamber of Commerce of the U.S. In 1979, she

received the Award for Excellence in Serving

Corporate Public Affairs from the National Association of Manufacturers. A native of St. Louis,

Missouri, Commissioner Elliott graduated from

the University of Illinois and the Northwestern

Medical Association Management Executives Program. Her term as FEC Commissioner expires on

April 30, 1993.

•
January 1989 FEDERAL ELECTION COMMISSION Volume 15, Numbe

YEAR-END REPORT 1988

SEMIANNUAL REPORTS 1989

7/31/

1/31/

1/31/

2/20/

3/20/

4/20/

5/20/

6/20/

7/20/

8/20/

9/20/

10/20

11/20

12/20

1/31/

Filing

Date*

Filing

Date

Filing

Date

11/29**-12/31

1/1 - 6/30

7/1-12/31

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 - 10/31

11/1 - 11/30

12/1 - 12/31

Period Covered

Period Covered

Period Covered

Year-End

Mid-Year

Year-End

Report

Report

February

March

April

May

June

July

August

September

October

November

December

Year-End

Report

MONTHLY REPORTS 1989

All Committees: Year-End Report

All political committees must file a year-end

report due January 31, 1989.

Congressional Candidate Committees

All committees authorized by Congressional

candidates must report semiannually: July 31,

1989, and January 31, 1990. Semiannual filers

include the authorized committees of candidates

retiring campaign debts or running in future elections.

continued from p. 1

Committees should use the peel-off label

provided on the FEC reporting packet when

completing their forms. The Commissions asks

that committees place this peel-off label on line 1

of the reporting form, the space provided for

identifying the committee's name and address.

Any corrections should be made directly on the

label. Committees should also file an amended

Statement of Organization to reflect any name or

address changes.

Presidential Candidate Committees

All committees authorized by Presidential

candidates must file on either a monthly or a

quarterly basis during 1989. The FEC's Reports

Analysis Division requests that Presidential committees which change their reporting schedule

during 1989 notify the Commission of their intention in writing.

QUARTERLY REPORTS 1989

PACs and Party Committees

PACs and party committees are required to

file on either a semiannual or a monthly schedule

in 1989. Any committee that wishes to change its

reporting schedule (for example, from monthly to

semiannual reports) must notify the Commission

of its intention. For procedures, see "Looking

Ahead" below.

Committees Active in Special Elections

All committees authorized by candidates running for Congress in special elections held in 1989

must file a pre-primary report and pre- and postgeneral election reports, as well as the

semiannual reports described above. PACs and

party committees that support candidates in

special elections (and that do nat file monthly

reports) must also follow this reporting schedule.*

Report

First Q

Second Q

Third Q

Fourth Q

(Year-End)

Period Covered

1/1 - 3/31

4/1 - 6/30

7/1-9/30

10/1 - 12/31

Filing

Date*

4/15/8

7/15/8

10/15

1/31/

"'A PAC or part)' committee does not have to

file a pre-election report if this activity has been

previously disclosed.

• Reports sent by registered or certified m

must be postmarked by the filing date. 11 C

104.5(e). 

,., '" Or from the closing date of the last repor

that date occurred before 11/29/88.

2
FEDERAL ELECTION COMMISSION

•

January 1989

LOOKING AHEAD: CHANGE IN

Fll.ING FREQUENCY

PACs and party committees that plan to

change their reporting schedule in 1989 (e.g.,

from monthly to semiannually) must notify the

Commission by submitting a letter. A committee

may not change its filing frequency more than

once a year. 11 CFR 104.5(c).

WHERE REPORTS ARE Fll.ED

Committees must file all reports and statements simultaneously with the appropriate federal

and state officials. 11 CFR 108.5.

Filing with the Federal Government

I. The principal campaign committees of House

candidates and committees supporting or opposing only House candidates file with the

Clerk of the House, Office of Records and

Registration, 1036 Longworth House Office

Building, Washington, D.C. 20515. 11 CFR 104.-

4(c)(3) and 105.1.

Volume 15, Number 1

3. PACs and party commmittees making contributions or expenditures in connection with House

and Senate races file in the state in which the

candidate seeks election. The law requires a

copy only of that portion of the report applicable to the candidate(s) being supported. Com

mittees supporting Presidential candidates must

file in the state(s) in which the Presidentia

committee and donor committee have their

respective headquarters.

HOW TO OBTAIN MORE INFORMATION

The Commission regularly mails reporting

forms and additional information to registered

committees. Instructions and forms for the year

end report were mailed out in December 1988.

Questions and requests for additional forms

should be addressed to Information Services, Fed

eral Election Commission, 999 E Street, N.W.

Washington, D.C. 20463; or call 202/376-3120 or

toll free 800/424-9530.

Nonfilers

FEC PUBLISHES NONFll.ERS

During November and December 1988, the

Commission published the names of two federa

campaigns that had failed to file a disclosure re

port required by the election law. See the char

below•

The election law requires the agency to pub

lish the names of nonfiling candidates. Compli

ance actions against nonfilers are decided on a

case-by-case basis. The law gives the Commis

sion broad authority to initiate enforcement ac

tions resulting from infractions of the law, includ

ing civil court enforcement and imposition of civi

penalties.

•

2. The principal campaign committees of Senate

candidates and committees supporting or opposing only Senate candidates file with the

Secretary of the Senate, Senate Public Records,

Senate Hart Office Building, Room 232,

Washington, D.C. 20510. 11 CFR 104.4(c)(2)

and 105.2.

3. All other committees, including the principal

campaign committees of Presidential candidates, file with the Federal Election Commission, 999 E Street, N.W., Washington, D.C.

20463. 11 CFR 105.3 and 105.4.

Filing with State Governments

I. The principal campaign committees of Congressional candidates must file a copy of every

report and statement with the Secretary of

State or the appropriate elections official of

the state in which the candidate seeks federal

office. 11 CFR 108.3.

2. 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 which apply to that state during

the reporting period covered. II CFR 108.2.

Candidate

Fernandez, B.

Tuffle, F.

Office State Report

Sought Not

Filed

President Monthly

House Amer- Preican runoff

Samoa

•

The Record is published by the Federal Election Commission, 999 E Street, N.W., Washington,

D.C. 20463. Commissioners are: Danny L. McDonald, Chairman; Lee Ann Elliott, Vice Chairman;

Joan Aikens; Thomas J. Josefiak; John Warren McGarry; Scott E. Thomas; Walter J. Stewart,

Secretary of the Senate, Ex Officio; Donnald K. Anderson, Clerk of the House of Representatives,

Ex Officio. For more information, call 202/376-3120 or toll-free 800/424-9530. (TDD for Hearing

Impaired 202/376-3136)

3
Janua.ry 1989 FEDERAL ELECTION COMMISSION Volume 15, Numbe

DEBTS OWED BY CANDIDATES AND

POLITICAL COMMITTEES: NOTICE OF

PROPOSED RULEMAKING

On December 6, 1988, the Commission published a notice of proposed rulemaking in the

Federal Register which seeks comments on proposed rules governing debts owed by federal candidates and political committees. 53 Fed. Reg.

49193. The notice also announces that, on February 15, the Commission plans to hold a public

hearing on the proposed rules.

The FEC's notice of proposed rulemaking

seeks comments on:

a A proposed new Part 116 of FEe rules which

would govern: (1) extensions of credit to federal

candidates and political com mittees and (2)

procedures for settling their debts. The new

Part 116 would replace debt settlement procedures contained in section 114.10 of the FEC's

current rules;

o Possible revisions to the definition of "excess

campaign funds" contained in section l13.l(e)

of the current rules; and

o Related issues for which no regulatory language

has been proposed, such as settlement of debts

owed by publicly funded Presidential campaigns

and disclosure thresholds for debts that must be

continuously reported by political committees.

Written comments on the FEC's notice of

proposed rulemaking should be submitted to Ms.

Susan E. Propper, Assistant General Counsel, by

January 27, 1989. Those interested in testifying

at the public hearing should so indicate on their

written comments. Ms. Propper may be contacted at: FEC, 999 E Street, N. W., Washington,

D.C. 20463 or by calling 202/376-5690 or, toll

free, 800/424-9530.

Debt Settlement Procedures

11 CFR Part 116

The proposed new Part lIB would address a

broad range of topics concerning debts owed by

federal candidates and political committees. The

proposed new rules, together with revisions to

debt settlement procedures contained in FEC Directive No.3, I would establish a new system

whereby:

o An indebted political committee could settle its

debts only when the committee was preparing

to terminate. However, the creditors of a com':

mittee that was not terminating could forgive

1These procedures became effective on July

22, 1982. See FEC agenda document #82-110

available fQr review and copying in the FEC'~ Public .Records Office.

4

the committee's debts if the committee wa

essentially defunct and was clearly unable to

pay its creditors; 

o An indebted political committee would be 

quired to submit a comprehensive debt sett

ment plan for Commission review prior to t

mination. The committee's plan would have 

include all debts owed by the committee a

provide for the disposition of the committe

remaining funds and assets.

The proposed debt settlement procedures 

new Part 116 would also cover debts owed by 

candidate with multiple committees, that is 

candidate with campaign committees establish

for different elections or offices. The propo

rules would address situations in which some 

the candidate's committees might be in debt wh

others might have surplus funds.

Finally, the new Part 116 would cover seve

specific types of debts not mentioned in the FE

current rules, such as debts owed to unincor

rated commercial vendors, campaign employ

and other individuals. However, the propo

rules would not apply to bank loans obtained 

federal candidates and committees because t

form of debt is governed by other FEe rules at 

CPR 100.7(b)(ll) and IOO.8(b)(l2).2

Definition of Excess Campaign Funds

II CPR: Il3.1(e)

Under a proposed revision to the definition 

C

neoXmcmesl.St tCeaemcpoauigldn fUntds'd" a

l

candidate's campa

no ec are excess campa

funds until after the campaign had ended and 

committee had determined that it had no rema

ing debts. By contrast, under the current pro

sion, a candidate's committee may declare exc

campaign funds at any time and use those fun

for a variety of purposes other than mak

payments to creditors for bona fide campa

debts.

2These rules are currently under review in 

a separate rulemaking. See the Advance Noti

of Proposed Rulemaking published in the Augu

5, 1988, issue of the Federal Register. 51 Fe

Reg. 28154 -
FEDERALELECTION COMMISSION

•

•

•

January 1989

FEC HOLDS PUBLIC HEARING

ON MCFL RULEMAKING

On November 16, 1988, the Commission held

a publlc hearing on what regulatory changes might

be appropriate in light of the Supreme Court's

opinion in FEC v. Massachusetts Citizens for Life

(MCFL),1 479 U.S. 238, 107 S.Ct. 616(1986). The

issues had been outlined in an Advanee Notice of

Proposed Rulemaking concerning Parts 109 and

114 of the Commission's regulations. See 53 Fed.

Reg. 416. -

During the hearing2 presided over by FEC

Chairman Thomas ,J, Josefiak, the Commissioners

heard testimony from two witnesses: Mr. Rex

Weil, an attorney appearing on behalf of Citizen

Action, People for the Ameriean Way Action

Fund, SANE/Freeze, Inc. and the Sierra Club, and

Mr. Philip S. Neal, an attorney with the law firm

of Miller and Chevalier.

Before drafting final proposed revisions to

Parts 109 and 114 of the regulations, the Commission will review the testimony from the public

hearing, as well as written comments received in

response to the advance notice.3

Issues

The FEC's Advanee Notice of Proposed Rulemaking had asked witnesses to focus their testimony on the following issues:

o How should the Commission determine when a

nonprofit organization is an MCFL-type entity?

o What are the appropriate reporting and disclosure requirements for an MCFL-type organization?

o When does an MCFL-type organization become

a political eommittee?

o Should the Commission adopt an "express advocaey" standard for determining when a prohibited corporate or union expenditure is made

under section 441b of the election law?

lIn its decision, the Court said that,

under a narrow exception to the ban on corporate

expenditures, an incorporated nonprofit membership organization could make independent expenditures if, among other things, the organization:

(1) was formed for the purpose of promoting

political ideas and did not engage in business

activities, (2) had no shareholders and (3) was not

established by a corporation or labor organization

and had a policy of not accepting corporate or

union donations.

2A transcript of the hearing is available for

review and copying in the FEC's Public Records

Office.

3The Commission received over 17,000 comments in response to its advance notice of proposed rule making. Almost all exclusively addressed the express advocacy issue.

5

Volume 15, Number 1

Testimony

In testimony presented at the publle hearing,

Mr. Weil, representing several organizations, said

that associational rights form "the underlying

gist" of the MCFL decision. The Court recognized that MCFL's incorporated status was merely

a convenience for purposes of the tax code; the

primary purpose of the organization was politica

-not business -activity.

Mr. Weil testified that the FEC should not

preclude a nonprofit organization from status as

an MCFL-type entity if it received "marginal or

minimal corporate or labor support." The organization could establish a separate account to receive corporate or labor union money. Alterna

tively, the Commission could establish a "safe

harbor" standard, that is, an exception that would

allow the organization to receive a small portion

of its funds from corporate or labor sources

without jeopardizing its ability to make independent expenditures.

To ensure that an MCFL-type organization

did not use impermissible funds for making inde

pendent expenditures, Mr. Weil suggested that the

Commission adopt a disclosure rule that would

apply once the organization's independent expen

ditures exceeded a certain amount. The organiza

tion would disclose only those contributions ear

marked for independent expenditures.

To determine whether an MCFL-type organi

zation was a political committee, Mr. Wei

suggested that the Commission use a "primary

purpose" test similar to that provided in the tax

code; that is, the agency would determine whether the organization was primarily engaged in

political activities. Alternatively, if the Commis

sion applied the election law's monetary thresh

old, the organization's expenditures for communi

cations that were not express advocacy should not

count toward the threshold.

Mr. Neal, speaking on his own as a practicing

lawyer, said that the Supreme Court's MCFL deci

sion used an II 'express advocacy'" standard for

deter mining when an MCFL-ty'pe organization

made a prohibited expenditure.~ The Commis

sion's rulemaking notice explained that, since the

Court found that MCFL's communications con

tained express advocacy, the Court's discussion

of express advocacy in the decision can be viewed

as "dicta -that is, it [was] unnecessary to the

holding of the Court and thus [did] not represent a

final resolution of that issue." Mr. Neal disagreed

with this view, asserting that the Court's holding

was not dicta but "resolved the issue" of when a

prohibited expenditure was made.

continue

4The FEC's current regulations interpret the

election law's prohibition on corporate expendi

tures "in connection with federal elections" as a

ban encompassing more than expenditures fo

communications containing express advocacy.
January 1989 FEDERAL ELECTION COMMISSIOI\J Volume 15, Numbe

In response to the Commissioners' questions,

Mr. Neal said that, if a corporation or labor

organisetion provided certain goods or services to

a candidate (e.g., the use of the organization's

airplane for campaign travel), the Com mission

could view such services as prohibited "contributions for advocacy purposes." He added that, if

the organization's goods or services were provided

by an individual acting on behalf of the organization, they would still constitute a prohibited contribution by the corporation or labor organization.

Mr. Neal recognized that his approach would

necessitate focusing on what activities constituted "express advocacy." In response to the

Commissioners' questions, he suggested that a

good starting point would be the express advocacy

standard applied by the U.S. appeals court in its

FEC v. Furgatch decision.5

AO 1988-37: Affiliated Status of Two Corporate

PACs After Leveraged Buy-out

WARDPAC, the separate segregated fund of the

Montgomery Ward Corporation, and GEPAC, the

separate segregated fund of the General Electric

Corporation (GE), are affiliated political committees by virtue of the affiliated relationship between the two sponsoring organizations. Accordingly:

o WARDPAC and GEPAC are subject to a single

contribution limit on both contributions they

make and receive; and

o WARDPAC and GEPAC must identify each

other as affiliated committees on their respective statements of organization.

Under the Act and FEC regulations, political

committees are considered affiliated if they are

established, financed, maintained or controlled by

the same corporation. In applying this principle,

the Commission may conclude that political committees established by two organizations are affiliated if one organization has the power: (1) to

direct the other organization through provisions

of by-laws, a constitution or other documents or

(2) to otherwise influence the decisions of the

organization's officers. 11 CFR IOO.5(g)(2)(ii) and

llO.3(a)(l)(iii); ADs 1978-39, 1979-56, 1983-19t

1986-42 and 1987-21.

5The express advocacy standard applied by

the appeals court in its Furgatch decision (Civil

Action No. 85-5524) is summarized on page 6 of

the March 1987 Record.

6

'fhe separate segregated funds of affilia

organizations are subject to a single contribut

limit on both contributions they make and con

butions they receive. 2 U.S.C. §441a(a)(5); 

CFR IOO.5(a){2) and IlO.3(a)(l)(i}.

Specifically in July 1988t with the help of 

General Electric Capital Coporation (GECC)t 

BFB Acquisition Corporation acquired the Mo

gomery Ward Corporporation. After this lev

aged buy-out, the BFB Acquisition Corporat

became the Montgomery Ward Holding Corpo

tion (MWHC). MWHC owns Montgomery W

and Montgomery Ward's Directors are drawn fr

MWHC's Board of Directors.

Two GE subsidiaries, GECC and Kidder-P

bdy, Ine., own 50 percent of the common sto

and all the preferred stock, in MWHC. GECC 

the power to appoint six of MWHC's 13 bo

directors. Although the GECC-appointed bo

directors do not constitute a voting major

their concurrence is needed for the two-thi

majority votes required when MWHC's board vo

on certain important MW management decisio

GE, therefore, through its subsidiary GECC, 

power and authority to direct Montgomery W

Consequently, their PACs are ffiliated, (D

issued: November 7, 1988; Length: 5 pages)

AO 1988-47: Publisher's Donation of 

Free Magazines to

Candidate Prohibited

People and Politics, Inc., the publisher of Peo

and Politics, could not donate 2tOOO free copies 

the September issue of the magazine 

Congresman Bruce F. Vento's 1988 reelect

campaign. A corporation may not ma

contributions in connection with a fede

election; nor maya federal candidate accept su

contributions. 2 U.S.C. §§441b(a).

The publisher's donation of 2,000 free cop

of the magazine would have constituted 

prohibited corporate contribution to the Ve

campaign because:

o It represented "something of value" ($2.10 

$3.00 each issue); and

o It was made "in connection with" a fede

election in as much as the magazine discus

and evaluated Vento's candidacy and would ha

been distributed during his campaign. (D

issued: November 8, 1988; Length: 3 pages)
January 1989 FEDERALELECTION COMMISSION Volume 15, Number 1

•

DEBT RETIREMENT BY CANDIDATE

COMMITTEES

After the election is over, an authorized candidate committee may want to terminate. To do

so, a committee must no longer intend to receive

contributions or make expenditures, and it must be

free of outstanding debts and obligations. 2 U.S.C.

§433(d)(l); 11 CFR 102.3. This article examines how

a committee can retire its debts. Note that several

methods are permissible, including:

o Accepting post-election contributions;

o Selling assets;

o Receiving party support;

o Receiving candidate help; and

.0 Using funds from a past campaign.

Should you have any questions after reading this

article, please call the FEC's Information Services

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

Accepting Post-Election Contributions

May our authorized committee aeeept contributions to retire debts for a particular election

after that election has been held? Yes. Candidat es

may receive contributions after the election to

retire debts provided the contributions satisfy four

general rules:

o The contributions must be specifically designated in writing for that election by the contributor;l

o The contributions may not exceed the campaign's

net debts outstandingi2

o The contributions must come from permissible

sources; and

o Each contribution, when added to other contributions from the same donor, may not exceed the

donor's contribution limit for that election. 11

CF R 1l0.l(b)(3), (b)(4) and 110.9(a).

May our committee join with other committees

in an effort to retire debts? Yes. Committees that

want to retire their debts may form a joint funeralsing committee. 11 CFR 102.17(a) and 9034.8(a).

Such committees should refer to the joint fundraising regulations at 11 CFR 102.17. Publicly funded

Presidential campaign committees should follow

joint fundraising regulations at 11 CFR 9034.8.

1A contributor's written designation may include a card printed by the committee which (1)

notes the election and (2) is signed and returned by

the contributor.

2A campaign's net debts outstanding consist of

unpaid debts incurred with respect to the election

minus cash on hand. 11 CFR 110. UO)(3)(ii).

7

May a corporation pay for a f1Dldraising eve

designed to retire a debt from a past campaig

No. Payments to sponsor a fundraising event for 

candidate are considered contributions to the cand

date. Contributions and expenditures by corpor

tions are prohibited regardless of when they a

made. See, for example, AO 1982-16.

Selling Assets

When a campaign sells a committee asset, do

the purchaser make a contribution? Generally, ye

In advisory opinions, the Commission has conclud

that the sale of fundraising items or uniquely deve

oped campaign materials (such as art work, opinio

polls and candidate-advocacy advertisements) r

sults in contributions, subject to the limits an

prohibitions of the Act. 11 CFR 100.7(a)(2); AO

1980-70, 1980-34 and 1980-19. Presidential prima

candidates receiving matching funds should see 

CFR 9034.9.

The Commission also views the sale or use 

committee assets in a business or commercial ve

t ure as simply another form of fundraising, th

proceeds of which are also SUbject to the prohib

tions and limits. AO 1983-2.

The Commission has, however, recognized na

row exceptions to the general rule that the sale 

committee assets results in contributions.

What are these exceptions? Under the ci

cumstances described below, the sale of an ass

does not result in a contribution, and the procee

are not subject to limits or prohibitions, as long 

the item is sold at the "usual and normal charge

11 CFR 100.7(a)(l)(iii).

o A campaign committee that wishes to termina

may liquidate equipment and leftover supplies 

order to retire debts or, in the case of a campaig

in a surplus situation, in anticipation of prompt

terminating after liquidation. AOs 1985-1 an

1979-24.

o A committee may sell a mailing list or contrib

tor list of unique value, developed by the comm

tee primarily for its own use. AOs 1982-41 an

1981-53.

o A committee may liquidate obsolete or deprecia

ed equipment if it is sold outright in a singl

isolated transaction without any expectation 

committee repurchase or lease-back. AO 198

14.

Remember that under each of these exceptio

a contribution is avoided only if the purchaser pa

no more than the "usual and normal" charge.

continued
January 1989 FEDERAL ELECTION COMMISSION Volume 15, Numbe

Receiving Parly Support

May a party committee help pay a candidate's

campaign debts? Yes, a party committee may help

in t he followlng ways:

o It may make contributions designated to retire

debts, subject to the contribution limits. 11 CFR

110.I(b)(3) and 110.2(b)(3).

o It may make payments to the candidate's creditor

as in-kind contributions, subject to the contribution limits.

o In the case of general election candidates, the

party committee may make payments directly to

the candidate's creditors as coordinated party

expenditures on behalf of the candidate, subject

to the special limits of 2 U.S.C. §44Ia(d). II CF R

110.7; AOs 1979-30 and 1979-9.3

102.6(a)(I)(i). However, the transfers may tr

registration and reporting obligations for the 

federal campaign committee.4 See AOs 1984-4

1982-52.

May a candidate committee retire deb

using excess fWlds from another federal comm

authorized by the same candidate in a diff

eleetion cycle? Yes. Excess funds may be t

ferred without limit between committees autho

by the same candidate for different election cy

II CFR 110.3(a)(2)(iv); AOs 1987-4 and 19

Presidential campaigns with excess funds wh

cepted federal funding are subject to other re

tions. See AO 1988-5.

Transferring Debts

Receiving Candidate Help

May House and Senate candidates make unlimited loans to their authorized committees? Yes.

Because Congressional candidates are not limited in

the amount of personal funds they may spend on

their campaigns, they may make unlimited contributions and loans using their personal funds. 11 CFR

110.10.

May House and Senate eandidates forgive pe.....

sonal loans made to their campaigns? Yes, for the

reason given above. 11 CFR 110.10.

May House and Senate candidates use personal

foods to payoff the debts of their committees?

Yes. However, when Congressional candidates donate their personal funds to their committees, as

distinct from lending them, the contributions cannot

be refunded to the candidates later. Such payments

would represent the conversion of excess campaign

funds to the candidate's personal use, which is

prohibited unless the candidate was a member of

Congress on January 8, 1980. 2 U.S.C. §439a; 11

CFR 113.2.

Using Foods from Another Campaign

May a candidate transfer excess foods from his

or her nonfederal campaign committee to his or her

federal campaign committee to retire debts? Yes.

Because the two committees are considered to be

affiliated, such transfers are not limited, provided

none of the funds transferred include contributions

which would be in violation of the Act. 11 CFR

May a 1990 campaign committee assum

debts of a 1988 campaign committee, so tha

older committee may terminate? Yes, a Hou

Senate candidate's campaign committee from a 

vious election may transfer its debts and Obliga

to that same candidate's current Congressional 

paign committee. See ADs 1980-143, 1980-43 

1977-52. Once the debts and cash on hand (if 

are transferred to the current 1990 committee

1988 committee may terminate. Different 

apply to Presidential candidates receiving p

funds. See AO 1988-5.

Failure to Pay Debts

What happens if our efforts to raise food

not sufficient to fully repay all of our cam

debts? If a political committee fails to pay a 

in a timely fashion consistent with normal bus

practice, the debt becomes a contribution by 

creditor unless the creditor has made a comme

ly reasonable attempt to collect the debt. 11 

100.7(a)(4) and 114.10. Contributions made 

such circumstances may violate the prohibition

limits of the Act (e.g., if the creditor is a cor

tion). Note debt settlement procedures at 11 

114.10.

May the candidate, treasurer or comm

members be held personally liable for debts ow

the committee? The Act and regulations do 

govern personal liability for payment of comm

debts. Debt claims and liabilit ies are gene

governed by state law. AOs 1979-1 and 1975-10

3A party committee that does not have its own

coordinated party expenditure limit may make such

expenditures only with the prior, written authorization of the national or state committee. 11 CFR

110.7.

8

4Several rules apply to such transfers. Se

chapter on transfers in the Campaign Guid

Congressional Committees.
January 1989 FEDERAL ELECTIOI\J COIV1IVlISSIOI\J Volume 15, Number 1

•

FEC v. TED BALEY

CONGRESSIONAL COMMITfHH

On November 22t 1988t the U.S. District

Court for the Western District of Washington at

Tacoma issued an amended judgment in FEC v.

Ted Haley Congressional Committee. (Civil

Action No. 85-1185) The district court's amended

judgment responded to a July 1988 remand order

issued in the suit by the U.S. Court of Appeals

for the Ninth Circuit. In its amended [udgrnent,

the district court:

o Reversed its February 1987 decision in the suit

in favor of plaintiff Federal Election Commission;

o Ordered that no civil penalties be assessed

against defendants; and

o Vacated its order awarding attorneys' fees to

defendants.

The district court's first decision in the suit

is summarized on page 6 of the May 1987 Record

and the appeals court's decision, on page 7 of the

September 1988 Record.

FEC v. CALIFORNIANS

FOR A STRONG AMERICA

On November 14, 1988, the U.S. District

Court for the Central District of California

granted the FEC's motion for a default judgment

against Californians for a Strong America (CSA),

a nonecnneeted political committee, and eSA's

treasurer Albert J. Cook. (Civil Action No. 88-

1554-AWT)

In the judgment, the court declared that the

defendants had violated 2 U.S.C. §§434(a)(4)(a)(i)

and (iv) by failing to file reports covering 1986

activity, that is, two quarterly reports and a yearend report.

Accordingly, the court:

o Ordered defendants to pay a $15,000 civil penalty, together with $28.20, to cover the FEC's

court costs in the case; and

o Enjoined defendants from similar violations of

the election law in the future.

9

USDCv. FEe

In a decision of November 7, 1988, the U.S.

Court of Appeals for the Second Circuit held that

the United States Defense Committee's (USPC's)

complaint against the FEC was not ripe for the

court's review. (See USDC v. FEC, Civil Action

No. 88-6127.) The appeals court therefore remanded the case to the U.S. District Court for

the Northern District of New York with instructions for the district court to dismiss the case.

Background

In a complaint1 filed with the U.S. District

Court for the Northern District of New York,

USDC challenged the Commission's conclusion in

Advisory Opinion (AO) 1987-7 that USDC's distribution of two letters to the general public could

not be financed with USDC's treasury funds. The

complaint asked for declaratory and injunctive

relief.

In upholding the FEels conclusion in the advisory opinion, the district court found that USDC's

proposed expenditures were prohibited by the

election law's ban on corporate contributions in

connection with federal elections. (See 2 U.S.C.

S44Ib.) The court further concluded that the

Supreme Court's decision in FEC v.

Massachusetts Citizens for Life (MCFL)Z did not

"apply to USDC's case because USDC, unlike

MCFL, accepts contributions from business corporations."

Appeals Court Ruling

In deciding that USDC's case was not ripe for

judicial review, the appeals court said that nothing in the legislative history indicated that Congress thought advisory opinions were reviewable.

Further, the appeals court explained that an FEC

advisory opinion was not "final or binding••••" In

this regard, the court noted that "if a person

proceeded to act contrary to an FEC advisory

opinion, [that person} would be entitled to all of

the enforcement protections, including conciliation, conference, persuasion and the like, provided

under 2 U.S.C. §437g." continued

1The complaint was submitted as an

amendment to a complaint originally filed in

March 1984 and amended the same year. In the

original complaint and in the 1984 amendment,

USDC had challenged the validity of advisory

opinions 1983-43 and 1984-14 on statutory arid

constitutional groWlds. For a summary of the

district couet's decision, see p.6 of the July 1988

Record.

2The Supreme Court's decision in FEC v.

MCFL drew a narrow exception which permits

certain types of nonprofit incorporated organizations to make independent expenditures on behalf

of or in opposition to federal candidates. For a

summary of the court's decision, see p. 4 of the

February 1987 Record..
January 1989 FEDERAL ELECTION COMMISSION

The appeals court further noted that AO

1987-7 was "particularly inappropriate for judicial

resolution at this time. As a consequence of the

Superme Court's decision in FEC v. Massachusetts Citizens for Life the Commission is

engaged in a rulemaking proceeding which could

atter.the very regulations applied in the opinion."3

On November 22, 1988, USDC filed a petition

with the appeals court which requested a rehearing and a rehearing bane of its case.

FEC v, HARRY BRAUN

FOR CONGRESS COMMlTTIlE

On October 3, 1988, the U.S. District Court

for the District of Arizona, Phoenix Division,

issued a consent order in a suit the FEC filed

against the Harry Braun for Congress Committee

(the Committee), the principal campaign

committee for Mr. Braun's 1986 House campaign,

and Mary Irene Moore, the Committee's treasurer.

FEC v. Harr Braun for Con ress Committee

Civil Action No. CIY 88-1174 PHY) CLH)

In the consent order, the court decreed that

defendants had violated the election law by

failing to meet the filing deadlines for two 1986

quarterly reports and two 1986 pre-election

reports. (See 2 U.S.C. SS434(a)(2)(A)(i) and (iii).)

The court ordered defendants to pay a $300

civil penalty within 20 days of the court's entry of

the consent order.

Finally, the court enjoined defendants from

future, similar violations of the election law.

FEC v, DIETL FOR CONGRESS

On JUly 18, 1988, the U.S. District Court for

the Eastern District of New York issued a consent

order in a case that the FEC brought against Dietl

for Congress, Richard B. Dietl's principal campaign committee for his 1986 House campaign,

and Alan J. Dietl, the campaign's treasurer. (FEC

v. Dietl for Congress; Civil Action No. CY-88-

1143)

In the consent order, the court decreed that

defendants had violated the election law's reporting requirements for the 1986 election year by

failing to meet the filing deadlines for an October

quarterly report and a pre-election report. (See 2

U.S.C. SS434(a)(2)(A)(iii) and (i) respectively.)

The district court ordered defendants to

comply with certain actions within 20 days after

3The FEC held a public hearing on the proposed MCFL rnlemaking on November 16, 1988.

For a summary of the proposed ruIemaking and

related issues, see the January and November

1988 issues of the FEC Record and this issue,

page 5.

10

Volume 15, Numbe

the court entered its consent [udgrnent, Spe

cally, defendants had to:

o File the 1986 pre-election report; and

o Pay a $3,000 civil penalty.

Finally, the court permanently enjoined 

fendants from future, similar violations of 

election law.

FEC v, TA YLOR CONGRESSIONAL COMMITT

On June 22, 1988, the U.S. District Court 

the District of Columbia issued a default [u

ment in a suit that the FEC brought against 

Taylor Congressional Committee, the princ

campaign committee for Clarence Taylor's 

House campaign, and the Committee's treas

Richard L. Smith. (FEC v. Taylor Congressi

Committee; Civil Action No. 88-0453 (SSH»

In the default judgment, the district c

decreed that:

o Defendants had violated the terms of 

conciliation agreement that they had ente

into with the FEC in February 1988. (In 

agreement, the defendants had agreed to pa

$1,500 civil penalty in two equal installrnent

o Defendants had to pay the $1,500 penalty

additional $500 penalty for violating the te

of the conciliation agreement and a small 

to cover the FEC's court costs in the c

These penalties had to be paid within 15 d

from the date the court entered the def

judgment against defendants.

Finally the court enjoined defendants f

future, similar violations of the election law.

FEC v. CESAR RODRIGUEZ

On October 28, 1988 , the U.S. District Co

for the Middle District of Florida granted 

FEC's motion for a default judgment in a c

that the FEC had reo~ened against Mr. Ce

Rodriguez in June 1988. (FEC v. Rodriguez; C

Action No. 86-687-CIV-T-IO). The case c

cerned certain contributions that Mr. Rodrig

had solicited on behalf of Alan Wolfson for 

1984 Carter/Mondale Presidential Committee.

In the default [udgrnent, the court decr

that:

o Mr. Rodriguez violated 2 U.S.C. S44lf by kn

ingly assisting in the making of contribution

the name of another.

o Mr. Rodriguez must pay, within 15 days of 

court's entry of the judgment, a $5,000 c

penalty, together with $22.95, to cover co

incurred by the FEC in the suit.

Finally, the court enjoined Mr. Rodriguez fr

future, similar violations of the election law.

1For a summary of the court's prior acti

in the case, see p.6 of the August 1988 Record.
FEDERAL ELECTION COMMISSION

•

•

•

January 1989

NEW LITIGATION

FEC v. AFSCME-PQ

The FEC asks the district court to declare

that the American Federation of State, County

and Municipal Employees-P.E.O.P.L.E., Qualified

(AFSCME-PQ), the separate segregated fund of

AFSCME, and AFSCME-PQ's treasurer William

Lucy violated section 434(b) of the election law

by failing to report in-kind contributions

AFSCME-PQ had made to the 1982 and 1984

Indiana House campaigns of Francis McCloskey.

Specifically, during the 1982 general election

period, AFSCME-PQ established telephone banks

which advocated Mr. McCloskey's election. Instead of reporting this in-kind contribution to the

McCloskey campaign on its 1982 pre-general election report, AFSCME-PQ did not report the

contribution (amounting to $4,814.92) until May

1983. Again, during the 1984 general election

period, AFSCME-PQ provided the same service to

the McCloskey campaign and did not report the

value of this in-kind contribution (amounting to

$1,362.81) until February 1985.

The FEC further asks the court to:

o Assess an appropriate civil penalty against

AFSCME-PQ and treasurer William Lucy; and

o Permanently enjoin defendants from future violations of the election law.

U.S. District Court for the District of Columbia, Civil Action No. 88-3208, November 7,

1988.

FEC v, Californians

for a Strong America

The FEC asks the district court to declare

that Californians for a Strong America (CSA), a

nonconnected political committee, and CSA's

treasurer Albert J. Cook violated the election law

by:

o Failing to file a 1987 mid-year report on time

(2 U.S.C. S434(a)(4)(A)(iv»;

o Failing to properly report independent expenditures (i.e., fundraising letters and tv and radio

ads) which advocated the defeat of Senator

Alan Cranston in his 1986 reelection bid (2

U.S.C. S434(b)(6)(B)(iii»; and

o Failing to include a disclaimer notice on the

fundraising letters in which CSA requested financial help to "retire" or "defeat" Senator

Cranston.

The FEC further asks the court to order

defendants to:

o File CSA's overdue reports and to file amended

reports which properly disclose CSA's independent expenditures against Senator Cranston;

o Assess an appropriate civil penalty against defendants; and

o Permanently enjoin defendants from future,

similar violations of the election law.

II

Volume 15, Number 1

U.S. District Court for the Central District

of California, Civil Action No. 88-o6449-J GD

(KX), October 28, 1988.

FEC v, Life Amendment

Political Action Committee

The FEC asks the district court to declare

that:

o The Life Amendment Political Action Committee (LIFE PAC), a nonconnected political committee, and Rick Woodrow, LIFE PAC's treasurer, violated the election law by failing to

meet filing deadlines for the 1985 and 1987

mid-year reports, a 1986 pre-general election

report and a 1986 year-end report (2 U.S.C.

SS434(a)(4)(A)(i)(ii) and (iv».

o Citizens Organized to Replace Kennedy

(C.O.R.K.), a political committee, and Rick

Woodrow, C.O.R.K.'s treasurer, violated the

election law by failing to itemize debts and

obligations disclosed on C.O.R.K.'s 1986 quarterly, post-general election and year-end reports (2 U.S.C. S434(b)(8».

The FEC further asks the court to:

o Assess appropriate civil penalties against each

defendant;

o Order C.O.R.K. and its treasurer to file reporting schedules which provide itemized information on the debts and obligations the committee

disclosed on its 1986 reports (see above); and

o Permanently enjoin the defendants from similar, future violations of the election law.

U.S. District Court for the Western District

of Washington, Civil Action No. C88-860Z, July 6,

1988.

FEC v. Chipman C. Bull for Congress

The FEC asks the district court to find that

Chipman C. Bull for Congress (the campaign), the

principal campaign committee for Mr. Bull's 1984

House campaign, and the campaign's treasurer

Denise M. Deshane violated the election law by:

o Knowingly accepting excessive contributions

from three individuals in the form of loan

guarantees and interest payments they made

with regard to a bank loan obtained by the

campaign (2 U.S.C. S441a(f)},

o Knowingly accepting direct contributions from

two of the loan guarantors (2 U.S.C. §441a(f)},

o Failing to disclose these contributions in its

1984 post-general election and year-end reports

(2 U.S.C. S434(b)(3)(E»; and

o Failing to meet the filing deadlines for two

reports due in the 1985 nonelection year (2

U.S.C. §§434(a)(2)(B)(i) and (ii».

The FEC further asks the court to:

o Assess an appropriate civil penatly against defendants; and continued
January 1989 FEDERAL ELECTION COMMISSION Volume 15, Numbe

o Enjoin defendants from future violations of the

election law.

U.S. District Court for the District of Maine,

Civil Action No. 88-37B (Cyr., J.), February 16~

1988.

FEe v. Populist Party, et aL

In this suit, the FEC asks the court to declare

that:

o The Populist Party, a nonconnected political

committee, and Blayne E. Hutzel, acting as the

Party's treasurer, failed to meet the filing

deadlines for two 1985 reports and four 1986

reports (in violation of 2 U.S.C.

§§434(a)(4)(A)(i), (iii) and (iv».

o The Populist Party and Mr. Hutzel failed to file

an amended Statement of Organization disclosing changes in: (a) the name of the Party's

treasurer and (b) the Party's campaign depositories (in violation of 2 U.S.C. S433(c».

o The Populist Party and Mr. Hutzel failed to

disclose the purpose of certain operating expenditures (in violation of 2 U.S.C. S434(b)(5)(A».

o The Populist Party and Mr. Hutzel failed to

disclose certain outstanding debts and obligations owed two corporations, Liberty Lobby,

Inc. and Cordite Fidelity, Inc. (in violation of 2

U.S.C. S434(b)(S».

o The Populist Party and Mr. Hutzel failed to

itemize a contribution in excess of $200 (in

violation of 2 U.S.C. S434(b)(3)(A»; and

o The Populist Party and Mr. Hutzel failed to

disclose certain 108.ns~ debts and obligations

which exceeded $500 by reporting them: (a) at

the time they were transacted and (b) until they

were extinguished (in violation of 11 CFR

104.11).

The FEC further asks the court to declare

that the following defendants violated 2 U.S.C.

S44lb(a) by making or knowingly receiving prohibited corporate contributions to the Populist Party:

o Liberty Lobby, Inc., by making a $7,500 contribution;

o Cordite Fidelity, Inc., by making a $10,478.55

contribution through its newspaper, The

Spotlight;

o Mr. Hutzel and Willis Carto, who in their respective roles as officers and directors of Liberty Lobby, Inc. and Cordite Fidelity, lnc.,

consented to the contributions made by their

corporations; and

o The Populist Party and Mr. Hutzel by knowingly

accepting aggregate corporate contributions of

$17,978.55.

Finally the FEC asks the court to:

o Assess appropriate civil penalties against each

defendant; and

o Permanently enjoin each defendant from future, similar violations of the election law.

U.S. District Court for the District of Columbia, Civil Action No. 88-0127 (RCL), January

20, 1988.

12

FEe v. Citizens Party

The FEC asks the district court to dec

that the Citizens Party, a national p

committee, and the Citizens Party's treas

Kirby Edmonds willfully violated sect

434(a)(4)(A)(i) and (iv) of the election law 

failing to meet the filing deadlines for the 

year-end report and two 1986 quarterly report

The FEC further asks the court to:

o Assess an appropriate civil penalty aga

defendants; and

o Enjoin defendants from any future, sim

violations of the election law.

U.S. District Court for the Northern Dis

of New York, Civil Action No. 87-CV-1

December 16, 1987.

CONGRESSIONAL CAMPAIGN

ACTIVITY: 1987-88

Pre-general election data released by 

FEC on November 4, 1988, showed that to

spending by Congressional campaigns (House 

Senate) from January 1987 through mid-Octo

1988 increased only three per cent over Cong

sional spending during the same period in 

1985-86 election cycle.

General election candidates for the Ho

spent $166.2 million-a six percent increase o

spending by House candidates in 1985-86 ra

This increase occurred despite the unusually sm

number of open seat races, which often acco

for the largest spending in Congressional races

The proportion of PAC contributions recei

by 1988 House campaigns increased approxima

five percent over the proportion of PAC contri

tions received by 1986 House campaigns.

The pie charts on the opposite page prov

detailed information on the sources of rece

for all 1988 Congressional candidates (

primary losers and candidates who went on 

campaign in the general election).

More detailed information may be obtai

from the FEe's November 4, 1988, press rele

For copies of the release, contact the FE

Public Records Office locally at 376-3140 or t

free at 800/424-9530.
FEDERAL ELECTION COMMISSION

•

January 1989

CHART I

SOURCES OF RECEIPTS1

All Congressional Candidates

January 1987 - September 1988

Incumbent Challenger

Volume 15, Number 1

Individual Contributions

Candidate Contributions

PAC contrtbunonss

Candidate Loans

Other Receipts3

Open Seat4

SENATE

Democratic $45 million $22.2 million $21.1 million

Republican $38.8 million $21.4 million $11.1 million

$81.1 million $21.8 million $23.1 million

HOUSE

Democratic

•

Republican $57 million $14.4 million $16.6 million

1 Charts do not reflect funds received prior to 1987-88.

2 PAC contributions include contributions from other candidate committees and from any other political committees that are not part o

national or state party organizations.

30ther receipts include, for example, party committee contributions, interest and dividends earned on investments, and offsets t

expenditures.

4 Herbert Kohl's contributions to his Wisconsin Senatorial campaign account for 98 percent of the contributions made by Democrati

Senatorial candidates to their open seat races.

13
January 1989 FEDERAL ELECTION COMMISSION Volume 15, Numbe

NATIONAL PARTY ACTIVITY: 1987-88

From January 1987 through mid-October

1988, Republian party committees at the national

level raised $171 million and spent $ L52 million.

The Republican committees' overall activity

declined 10 percent, as compared with their

activity during the same period in the 1985-86

election cycle. , Democratic party committees at the national

level raised $68 million and spent $58 million -

approximately double their overall activity in the

last election cycle.

National Republican party committees contributed $2.2 million to federal candidates

through mid-october 1988. They made coordinated expenditures! of approximately $12 million

lLimited expenditures made by party

committees on behalf of federal candidates in

general election campaigns. 2 U.S.C. section

441a(d).

CHART II

RECEIPTS OF

NATIONAL PARTY COMMITIEES1

First 21 Months of the Election Cycle

250

200

150

100

50

o

on behalf of the party's general election no

nees. Democratic national party committees 

tributed $1.1 million to federal candidates du

the same period. They spent almost $14 mi

on behalf of the party's general election no

nees.

PACs (l.e., nonparty, noncandidate poli

committees) gave approximately twice as m

money to the national party committees of 

major parties during the current cycle (Le., 

million) as compared with PAC contribution

the committees during the same period in the 

election cycle. The chart below depicts m

party receipts over three election cycles.

More detailed information may be obta

from the FEC's November 3, 1988, press rele

For copies of the release, contact the F

Public Records Office locally at 376-3140 or 

free at 800/424-9530.

II Democra

III Republica

1984 1986

(In Millions of Dollars)

1988

1 Nationalpartycommittees include,for eachof the two majorparties,the national partycommittee, the Senatorial campaigncom

and the Congressional campaigncommittee.

14
FEDERAL ELECTION COMMISSION Volume 15, Number 1

COURT CASES

FEC v,

-AFSCME-PQ, 1:11

-Braun for Congress Committee, 1:10

-Chipman C. Bull for Congress, 1:11

-Californians for a Strong America, 1:9

-Californians for a Strong America, 1:11

-Citizens Party, 1:12

-Dietl for Congress, 1:10

-Ted Haley Congressional Committee, 1:9

-Life Amendment Political Action

Committee, 1:11

-Populist Party, et al., 1:12

-Cesar Rodriguez, 1:10

-Taylor Congressional Committee, 1:10

For Teachers, Students and Researchers

o Dear Educator Letter (Describes FEC resources

and services available to educators)

o Dear Librarian Letter (Describes available

research materials and FEC resources)

o Educational Materials and Services (5:84)

o Legislative History Reference Information

o Presidential Election Campaign Fund Chart

OPINIONS

1988-37: Affiliated status of two corporate PACs

after leveraged buy-out, 1:6

1988-47: Publisher's donation of free magazines to

candidate prohibited, 1:6

This cumulative index lists advisory opinions,

court cases and 800 Line articles published in the

Record during 1989. The first number in the

citation refers to the "number" (month) of the

Record issue; the second number, following the

colon, indicates the page number in that issue.

v, FEC

---USDC, 1:9

January 1989

REPRINTS OF RECORD ARTICLES AVAILABLE

Callers inquiring about different aspects of

the law often ask whether the Commission has

materials on their topic of interest. In response

to these requests, many previously published 800

Line articles have been transformed into handouts

for quick and easy reference. Periodically

appearing in the Record, the 800 Line articles

answer frequently asked questions about

specialized topics relating to election law, such as

fundraisers or transfers of funds.

Other handouts on specific topics, not

previously published, are available as well.

For convenience, handouts have been grouped

in the list below according to their intended

audience. For each handout taken from the

Record, a parenthetical reference indicates "the

month and year when the article was originally

published.

Readers will find the handouts to be a

valuable resource. The Commission provides

them free of charge. To order, call the FEC's

Information Services Division at 800/424-9530 or

202/376-3120.

For All Committees

o Computerized Format for Reporting (11:80)

o Contribution Limits

o Joint Fundraising

o Overall Annual Limit on Contributions for

Individuals (7:83)

o Public Records Fee Schedule

o State Filing Offices

o 1988 Filing Dates

For Authorized Candidate Committees

o Concert Fundraisers (12:82)

o Disposal of Campaign Property (1:83)

o Presidential and Congressional Primary Dates

(1:88)

o Termination Procedures/Winding Down the

Campaign

o Transfer of Candidate Funds to Federal

Committee (1:86)

•

•

For Unauthorized Committees

o Delegates/Delegate Committees (11:87)

o Partnerships (6:83)

o Reporting Internal Communications by

Corporations, Labor Organizations and other

Membership Organizations

o Single Candidate Committees (10:87)

o SSF & Nonconnected Committees 00:82)

800 LINE

Debt retirement by candidate committees, 1:7

15
January 1989 FEDERALELECTION COMMISSION Volume 15, Numbe

FEDERAL ELECTION COMMISSION

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