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FEDERAL ELECTION COMMISSION

September 1985 1325 K Street NW Washington DC 20463 Volume 11, Numbe

committees for and against federal candidate

The Commission will make available addition

categories of information, as they are developed

•

INDIVIDUALS WILL HAVE DIRECT

COMPUTER ACCESS TO FEC DATA

On September 2, 1985, the Commission will

inaugurate a service that provides individuals with

direct computer access to the FEC's campaign

finance data base.* The service will be offered as

an extension of the agency's Freedom of Information Act (FOIA) process, with costs based on

amount of usage. Parties interested in the service

should contact the agency's Freedom of Information Office by calling 202/523-4065, or 800/424-

9530.

FEC campaign finance information pertaining

to the 1983-84 and 1985-86 election cycles will be

available to users of the service in two formats:

computer indexes and raw data.

Computer Indexes

Users will be able to obtain, through their

personal computers, a series of FEC computer

indexes on: political committees registered with

the FEC; records relating to an individual candidate (e.g., total receipts and disbursements); each

political committee, including its total receipts

and disbursem ents; poll tical com mittee support,

including, among other things, total contributions

made by each committee to a candidate and funds

the committee spent independently for or against

the candidate; and individuals who made contributions of $500 or more. Using their printers, individuals will be able to receive paper printouts of

these indexes.

AO 1985-18: Nonfederal PAC's Conversion to

Federal PAC

The Automobile Club of Michigan Political Acti

Committee (ACPAC) has operated as a sta

political fund (supporting only state and loc

candidates) since its establishment in 1981 by t

Automobile Club of Michigan (the Club), a me

bership organization. ACPAC may now convert 

a federal committee (Le., a separate segregat

fund) with a combined federal/state account a

use donations received before its conversion f

federal election activities, provided it compl

with the requirements below.

Registration and Reporting

No later than 10 days after it decides 

become a federal committee, ACPAC's treasur

continued on p

TABLE OF CONTENTS

INFORMATION

Computer Access for Individuals

to FEC Data

1 ADVISORY OPINIONS

COMPLIANCE

4 Summary of MURS

CLEARINGHOUSE

2 Panels Meet in Washington

COURT CASES

3 Sierra Club v. FEC

3 Alwin E. Hopfmann v. FEC

3 New Litigation

PUBLICA TIONS

6 Free Publications; Order Form

Raw Data

Users with a personal computer and modem

can have direct, on-line access to FEC campaign

finance information, which they can store on a

floppy diskette or hard disk for later use. This

data will not include the headings and formats

used for standard FEC indexes. (See above.) Raw

data will be available on: 1) federal candidates

and committees and 2) funds spent by political

"'During 1984, the FEe began a progmm that

currently provides eight state elections offices

with direct computer access to FEC campaign

finance data. Later in 1985, five more state

•

offices are expected to join the network.
The Record is published by the Federal Election Commission, 1325 K Street, N.W., Washington,

D.C. 20463. Commissioners are: John Warren McGarry, Chairman; Joan D. Aikens, Vice Chairman

Lee Ann Elliott; Danny Lee McDonald; Thomas E. Harris; Thomas J. Josefiak; Jo-Anne L. Coe,

Secretary of the Senate, Ex Officio; Benjamin J. Guthrie, Clerk of the House of Representatives,

Ex Officio. For more information, call 202/523-4068 or toll-free 800/424-9530.

FEDERAL ELEC1l0N COMMISSION

\bIume 11, Numo

SUbject

PAC established by corporation who

owned by partnership with governm

contract. (Da.te made public: JUly 

1985; Length: 3 pages)

FEC CLEARINGHOUSE PANELS

MEET IN WASHINGTON

On August 5 and 6, 1985, two panels of 

FEe's National Clearinghouse on Election Adm

istration met in Washington: the Clearinghou

Advisory Panel and its Advisory Committee 

Voting Systems Standards. (Composed of state 

local election officials, the panels have some 

the same rnembers.)

In joint sessions held during the two-

meeting, the panels' members discussed sev

topics:

o The Clearinghouse's current and projected 

tivities.

o The FECls computer access program, wh

currently provides eight states with direct c

puter access to FEC campaign finance in

mation. (For more information on the progr

see page 6 of the April 1985 Reeord.)

o FEe campaign finance workshops.

o The Voting Systems Standards Project m

dated by Congress. Reports were presented 

an on-going, three-part study to develop m

datory standards for voting equipment.

o The Voter Accessibility for the Elderly 

Handicapped Act (Pub. L. 98-435). Discus

focused on implementing the Act, which sti

lates that registration and polling places 

federal elections must be accessible to ha

capped and elderly individuals.

o Use of postal change-of-address forms for vo

registration.

ADVISORY OPINION REQUESTS

The following chart lists recent requests 

advisory opinions (AORs). The full text of e

AOR is available to the public in the Comm

sion's Office of Public Records.

1985-24 PAC established by unincorpora

sports league. (Date made public: Aug

5, 1985; Length: 4 pages)

AOR

1985-23

8efjemoo- 1985

continued from s- l

must file a Statement of Organization (FEC Form

1) with the FEC. 2 U.S.C. §§432 and 433; 11 CF R

102.1(c) and 102.2. As a newly registered separate

segregated fund, ACPAC must also file periodic

reports of its receipts and disbursements, as required by the Act and FEC Regulations. See 2

U.S.C. §434 and 11 CFR 104.5.

Operating as 8 Federal Committee

As a separate segregated fund with a combined federal/state account, ACPAC must:

o Accept only those contributions permissible under the election law; and

o Solicit funds in compliance with FEC Regulations (including those rules restricting solicitations by a membership organization to its

solicitable class). See 2 U.S.C. §§441a and 441b;

11 CFR 102.5(a) and (a)(2) and Part 114.

Notice to Members

ACPAC must also notify donors (i.e., members of the Club) that their donations will be used

to support federal candidates and offer them the

opportunity to request refunds of their unspent

donations for state election activity. Moreover,

since ACPAC plans to solicit additional contributions to its new, combined federal/state account,

the notice must inform members that all contributions are voluntary and that the amount of a

contribution will not affect the donor's membership or employment status. See 11 CFR 102.5(a)(2)

and 114.5(a). Commissioner Thomas E. Harris

filed a dissenting opinion. Commissioner Frank P.

Reiche filed a concurring opinion. (Date issued:

July 16, 1985; Length: 7 pages, including dissent

and concurrence)

Using Donations Reeeived Before

Beeoming 8 Federal Committee

As a newly registered separate segregated

fund, ACPAC may use its cash on hand (Le., those

funds most recently donated to ACPAC before its

conversion) if the funds comply with the Act's

requirements. The donations were originally made

for political purposes in amounts not exceeding

$260 per year. Solicitations had been made only to

the members of the Automobile Club of Michigan,

the parent organization. ACPAC must report the

cash on hand.

2
FEDERAL ELECTION COrvIMISSIOI\J

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SeptemOOr" 1985

SIERRA CLUB v. FEC

On December 21, 1984, the Sierra Club (the

Club) and its separate segregated fund, the Sierra

Club Committee on Political Education

(SCCOPE), filed a second appeal with the U.S.

Court of Appeals for the District of Columbia

Circuit, which sought review of the district

court's second ruling on plaintiffs' suit, Sierra

Club v. FEC (Civil Action No. 84-2354).

The U.S. District Court for the District of

Columbia had originally ruled on the suit in August 1984. Plaintiffs had appealed this first ruling

with the appeals court, which had remanded the

suit to the district court for further consideration. The court issued its second opinion in the

suit on November 5, 1984.

BackgroWld

On July 31, 1984, the Club and SCCOPE had

filed suit with the district court. Plaintiffs had

challenged the FEC's construction and application

of 2 U.S.C. §441b in an advisory opinion the

agency had issued to the Sierra Club on July 13,

1984. In the opinion, AO 1984-24, the Commission

rejected the two financing methods proposed by

the Club for selling its goods and services to

SCCOPE as part of SCCOPE's in-kind contribution

program for federal candidates. (See the September 1984 issue of the Record, page 7.)

The Sierra Club had asked the court to declare that:

o The election law permits the Club to provide

goods and services to SCCOPE for use in

SCCOPE's in-kind contribution program, provided: a) SCCOPE makes payments in advance

to an escrow account or reimburses the Club

within a commercially reasonable time, and b)

the goods and services are purchased at fair

market value.

o Section 441b, both on its face and as applied to

plaintifrs activities, violates the First Amendment by abridging plaintiff's freedom of association and by being unconstitutionally vague,

o Advisory Opinion 1984-24 is contrary to law and

to the First and Fifth Amendments.

Plaintiff had also asked the court to enjoin

the FEC from commencing or continuing any

enforcement proceedings designed to prevent

SCCOPE from using Sierra Club goods and services for its in-kind contribution program.

District Court's Initial Ruling

On August 11, 1984, the district court issued

an order dismissing the suit. The court ruled that

the case was not ripe for consideration and that

the Club had not exhausted the administrative

remedies available to it before filing suit.

3

\bIurne 11 , NumOOr

Appeals Court Remand to District Court

The Sierra Club appealed the ruling. T

appeals court treated the Club's motion to e

pedite the appeal as a motion for summary 

versal. In its order of September 7, 1984, t

appeals court granted this motion, reversing t

district court's dismissal, and remanded the ca

to the district court for further consideration.

District Court's Seeond Ruling

On October 31, 1984, the district co

granted the FEC's motion to dismiss the suit. 

the opinion that followed on November 5, 19

the court upheld AO 1984-24 as a reasonab

interpretation of the law's prohibition on corp

rate contributions, noting that "the Federal El

tion Com mission is the type of agency to wh

considerable weight and deference should p

sumptively be accorded••••" The court also 

jected the Club's claim that the opinion viola

its First Amendment rights, Which, the co

stated, were "overborne by the interests Congr

has sought to protect in enacting Section 441b."

Since the court upheld the Commission's 

terpretation of Section 441b in the advisory op

ion and since the Commission has the statuto

authority to investigate possible violations of t

election law, the district court denied the Sie

Club's request for an injunction barring any pen

ing or future investigation of the Club's activitie

The Sierra Club then filed its second app

with the appeals court.

ALWIN E. HOPFMANN v. FEe

On July 19, 1985, the U.S. Court of Appe

for the District of Columbia Circuit denied app

lant Alwin E. Hopfmann's petition for a reheari

of his suit, Hopfmann v. FEC (Civil Action N

84-5207). On May 13, 1985, the court had 

firmed a district court ruling dismissing the ca

For a summary of the appeals court's decision, s

page 7 of the July 1985 Record.

NEW LITIGATION

Antosh v. FEC (Fourth Suit)·

Mr. James Edward Antosh, President 

Shawnee Garment Manufacturing, Inc., seeks 

court's expedited review of an FEC determinati

dism issing an administrative complaint he filed 

April 16, 1984. In the complaint, Mr. Antosh h

alleged that:

continu

*The three other suits Mr. Antosh has pe

ing against the FEC in the D.C. District Co

are: Civil Action Nos. 84-3048, 85-1410 and 

2737.
FEDERAL ELECTION COMMISSION

General Counsel's Report

The Federal Election Campaign Act (the 

prohibits a corporation from making contribut

or expenditures "in connection with" federal e

tions and defines an expenditure to include 

ments made "for the purpose of influen

MUR 1723: Payments for Media Campaign

by Nonpartisan Membership

Corporation

On August 15, 1984, the Commission found 

reason to believe that a nonprofit, nonpart

membership corporation violated the election 

(2 U.S.C. §441b) by conducting a media camp

to influence the 19B4 Presidential and Cong

sional campaigns.

\blume 11, Numo

SUMMARY OF MURs

The Act gives the FEC exclusive jurisdic

for its civil enforcement. Potential violations 

assigned case numbers by the Office of Gen

Counsel and become "Matters Under Rev

(MURs). All MUR investigations are kept co

dential by the Commission, as required by 

Act. (For a summary of compliance procedu

see 2 U.S.C. SS43'1g and 43'1(d)(a) and 11 

Part 111.)

This article does not summarize every s

in the compliance process. Rather, the sum ma

provide only enough background to make clear 

Com mission's final determ ination. Note that 

Com mission's actions are not necessarily b

on, or in agreement with, the General Coun

analysis. The full text of these MURs is avail

for review and purchase in the Commiss

Public Records Office.

Complaint

On June 16, 1984, a nonconnected polit

action committee (PAC) filed a complaint aga

a nonpartisan membership corporation claim

that its financing of a media campaign, a

during the Presidential primary season, con

tuted prohibited corporate expenditures. The 

poration had planned to spend $600,000 on m

advertisements that focused on the need for c

paign finance reform and criticized the influe

of PAC contributions on incumbent Member

Congress. The complainant PAC contended 

the media campaign's purpose was to influe

the financing of federal elections "with the p

able result being a reduction in the financing 

elections of incumbent members of Congre

The respondent's payments for the commerc

would therefore be made "in connection w

federal elections, the complainant argued, 

would result in prohibited corporate expenditu

Septemoor 1985

o The Engineers Political Education Committee/

International Union of Operating Engineers

(EPEC/IUOE) violated 2 U.S.C. §441a(a)(2)(A)

by making excessive contributions (amounting

to $7,250) to Senator Dennis DeConcini's 1984

reelection campaign;

o The reelection campaign violated section 441a

(f) by accepting the contributions; and

o Senator DeConcini and his reelection campaign

violated the law by failing to accurately report

some of the contributions. See 11 CFR 104.14

(d).

Mr. Antosh asks the court to:

o Declare that the FEC's dismissal of his complaint was contrary to law (see 2 U.S.C. §437g

(a)( 10)); and

o Issue an order requiring the FEC to take action

on the administrative complaint within 30 days.

See 2 U.S.C. §437g.

U.S. District Court for the District of Columbia, Docket No. 85-2035, June 21, 1985.

ltMulticandidate committees may contribute up

to $5,000 per election to a candidate's authorized

committee(s) or any other political committee. To

achieve multicandidate committee status, a committee must have more than 50 contributors, have

been registered for at least six months and, with

the exception of state party committees, have

made contributions to five or more candidates for

federal office. 2 U.S.C. 441a(a)(4); 11 CFR 100.5

(e)(3).

FEC v; Be-Elect Hollenbeck to Congress

Committee

The FEC asks the district court to declare

that Congressman Harold C. Hollenbeck's 1982

reelection campaign, Re-elect Hollenbeck to Congress Committee (the Committee), and its treasurer, David I. Kersh, violated the election law by

accepting an excessive contribution from the New

Jersey Republican State Committee and by failing

to refund the excessive portion of the contribution (I.e., $4,000) to the state party committee.

See 2 U.S.C. §441a(f); 11 CFR 103.3(b)(l) and (2).

At the time the state party committee made the

$5,000 contribution, it had not achieved multicandidate comm ittee status and was, therefore,

only eligible to make a $1,000 contribution to the

Com mittee.* The FEC further asks the court to:

o Assess a $5,000 civil penalty against the Committee or an amount equal to 100 percent of

the amounts involved in the violation; and

o Order the Committee and its treasurer to refund the excessive portion of the contribution

to the state party committee.

4
Septemoor 1985 FEDERAL ELECTION COMMISSION \blume11, Numoor 

Commission Determination

The Commission accepted the General Counsel's recommendation. On August 15, 1984, the

Com mission found no reason to believe that the

respondent had violated 2 U.S.C. §441b.

MUR 1808: Candidate Committee's Failure to

Report In-k:ind Contributions from

a Nonconnected PAC

On April 2, 1985, the Commission decided to take

no further action against a 1984 Congressional

campaign that had failed to report several in-kind

contributions made on the campaign's behalf by a

nonconnected political action committee.*

federal elections," 2 U.S.C. §§44lb(a) and 431(9)

•

(A)(i). Neither the Act nor Commission Regulations define "in connection with" or "for the

purpose of influencing" an election. However, in

numerous enforcement cases and advisory opinions that have required application of this language, the Commission has considered certain

factors based on judicial interpretations of the

statute: 1) whether the communication solicits

contributions for a candidate; 2) whether it expressly advoca tes the election of a candidate; and

3) whether its overall purpose is to advocate a

candida te's election rather than an issue or policy.

The respondent corporation's proposed communication did not solicit contributions to candidates and, in fact, contained no references to

specific candidates. Its content was limited to the

discussion of an issue - the present role of

political action com mittees in the political process. Although the communication was timed to

coincide with the Presidential primaries, the respondent explained that this timing provided a

national forum in which to focus attention on the

financing of federal elections and that the drive

for election reform would continue afterward.

Counsel concluded that, because the media

campaign did not meet the criteria listed above,

the respondent's financing of the ads would not

constitute prohibited corporate expenditures. The

•

General Counsel therefore recommended that the

Commission dismiss the matter.

•

Complaint

On October 4, 1984, a state party committee

filed a complaint with the FEC alleging that a

House candidate's principal campaign committee

(the Committee) and the Committee's treasurer

had violated the reporting provisions of the election law by failing to report in-kind contrlbu-

• A political committee which supports or

opposes candidates for federal office but which is

not established or administered by any candidate,

poUtical party, corporation or labor organization.

5

tions* (amounting to $1,089.84). A nonconnecte

PAC (the PAC) had made the in-kind contrib

tions on behalf of the Committee between Augu

1983 and August 1984. Disclosed by the nonco

nected PAC on its FEC reports, the in-kind co

tributions included, for example, the value 

postage and delivery services and of time given 

the Committee by the PAC's director.

Based on information in the complaint and 

campaign reports placed on the public record, th

General Counsel recommended that the Commi

sion find reason to believe that the Committ

and its treasurer had violated 2 U.S.C. §434 an

11 CFR 104.l3(a)(1) and (2). On October 31, 198

the Commission adopted the General Counse

recommendation and opened an investigation in

the complaint.

General Counsel's Report

In letters responding to the party com mi

tee's allegations, the Committee's treasurer ge

erally admitted that the Committee had failed 

report the in-kind contributions and requeste

that it be allowed to enter into a pre-probab

cause conciliation agreement with the FEC. Th

Com mittee attributed its failure to report the i

kind contributions to: 1) the PAC's failure to i

form the Committee of any in-kind contribution

made on the Committee's behalf during the cam

paign (despite the Committee's request that it b

informed); and 2) the failure of communicatio

among Committee staff.

On February 21, 1985, however, the cand

date sent the Commission a letter in which h

stated that his treasurer's account of the r

porting problem had been inaccurate. The ca

didate claimed that the Committae's failure 

report the in-kind contributions had been "pr

marily the fault" of the PAC rather than th

Committee. The candidate asserted that th

Committee had made reasonable efforts to obta

information from the PAC on the amount an

purpose of the in-kind contributions. Neverth

less, the PAC had failed to provide the inform

tion to the Committee on numerous occasion

despite the PAC's policy of notifying candidat

of all contributions made on their behalf. Th

candidate noted that the PAC and the Committ

had worked. together on some matters, but th

the PAC had also made in-kind contributions o

its own, without working with the Committe

(The candidate suggested that, in som e instance

his Committee may not have been aware of th

PAC's in-kind con tributions on his behalf.) Th

candidate .also noted that of the $1,089.84 in i

kind contributions alleged to be undisclose

$232.23 had, in fact, been disclosed on the Com

mittee's 1983 year-end report. Finally, the eand

continu

·Contributions in the form of services, goo

or property offered free or at less than the usu

charge to a political committee.
SePtembar 1985 FEDERAL ELECTION COIVIIVIISSIOI\J \bIume 11, Num

date stated that, once the FEC had notified the

Committee of its reporting omissions, the Committee immediately filed amended reports disclosing the in-kind contributions.

In a letter of March 8, 1985, the PAC confirmed the information provided by the candidate.

The General Counsel recommended that the

Commission take no further action against the

Com mittee, based on:

o The mitigating circumstances revealed by the

Committee (and confirmed by the PAC); and

o The FEC's reason to believe finding, which had

put the Committee on notice with regard to the

violation.

Commission Determination

On April 2, 1985, the Commission voted to

adopt the General Counsel's recommendation.

The FEC offers the following free publications. To order, return the completed form below.

Federal Election Campaign Laws

Complete compilation of Federal election

campaign laws prepared by FEC.

FEC Regulations (II CF R)

FEC regulations; subject indexes prepared by

FEC.

FEC Record

Monthly newsletter covering reporting, advisory opinions, litigation, legislation, statistics,

regulations, compliance, Federal Register notices,

FEC procedures and staff, and publications.

Campaign Guides

Clear explanation and illustration of election

law requirements. Separate Guide for:

Congressional Candidates and Committees

Party Committees

Corporations and Labor Organizations

Nonconnected Political Committees

House and Senate Bookkeeping Manual

Recommended method of bookkeeping and

reporting for Federal candidates and their committees.

FEC and Federal Election Law

Brief overview of major provrsions of the

Federal Election Campaign Act and the Commission's role in administering it.

Brochures

Advisory Opinions

Candidate Registration

6

Contributions

Corporate/Labor Com munieations

Corporate/Labor Facilities

Independent Expenditures

Local Party Activity

Political Ads and Solicitations

Public Funding of President Elections

State Computer Access to FEC Data

State Elections & Federal Campaign Law

Trade Associations

Using FEe Campaign Finance Information

Volunteer Activity

Order Form NAME

STREET

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CONNECTED ORGANIZATION IPHONE (Optional)

Please indicate quantity in box to left of each item.

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Federal EI~tion Bookkeeping Manual

Campaign Laws for Candidates

FEC Regulations Annual

Report

FEC Record 10-Year

(subscrtpnen f Report

Campaign Guides

congressional Corporations and

Candidates Labor Organizations

Partv Committees Nonconnected

Committees

Brochures

Advisory Opinions Political Ads

and SOlicitations

Candidate Public Funding of

Registration Presidential EI~tions

Contributions State Computer

Access to FEC Data

Corporate) Labor State Elections 8<

Communications Federal Ca'npaign Law

Corporate} Labor Trade Associations Facilities

FEC and Federal Using FEe Campaign

Election Law Finance Info rmation

Independent Volunteer Activity Expenditures

Local Party

Activity

Mail to: Federal Election Commission

Information Services

WaShington, D.C. 20463

Phone: Toll Free 800/424-9530
7

--.~,,~~"-'--""P'~_'_'~~-"' __ ~_~ __ r~ - -~.-~ -:}'~- ~_ ~~j& __ ~. __•• .-yo ... ~~ __ .~ •••• _ • • __ 

1 M \ \0 " , •

?:_L,:,:' ,~, ,_ _~ !, '< _ : _ __:, ,,_

Political Committees

Registered political committees are automatically sent the Record. Any change of address by

a registered committee must, by law, be made in writing as an amendment to FEC Form I

(Statement of Organization) 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 is sent.

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 numbers. Without this number, there is no

guarantee that your subscription can be located on the computer.

\bIume 11, Numba

800 LINE

Foreign Nationals, 5:8

State and Local Party Activities, 

Supreme Court Rules on 26 U.S

§9012(f), 4: 1

Using Excess Campaign Funds, 2:4

COURT CASES

Antosh v. FEC, 2:4

Citizens for Percy '84 v, FEC, 1:6

DCCC v, FEC, 2:6

FCM v, FEC, 6:3

FEC v, Anderson, 2:6; 8:8

FEC v, Committee to Return St

to Congress, 8:7

FEC v. Furgatch; FEC v, Domin

1:6

FE C v. Gus Savage for Congress 

6:3

FEC v, Hemenway for Cong

Committee, 2:6

FEC v. Liberal Party Federal C

paign Committee, 3:3

FEC v, NCPAC, 5:6

FEC v. NR WC; NRWC v, FEC, 1:7

FEC v, Kirk Walsh for Cong

Committee, 6:3

Alwin Hopfmann v, FEC, 7:7

LaRouche v. State Board of E

tions, 8:7

National Congressional Club and J

ferson Marketing, Inc. v, FEC, 3

Orloski v, FEC, 2:5

1984-61: Trade Association Solicitation Approvals, 3:2

1984--£2: Campaign Firm's Slate Mail

Program, 5:4

1984-63: Savings and Loan Association's Solicitations, 3:2

1985-1: Liquidation of Campaign

Assets, 4:4

1985-2: State Funds Tran sf erred to

Congressional Campaign, 4:5

1985-3: Contributions to State Campaign by SUbsidiary of Foreign Corporation, 4:5

1985-4: Payments not Honorarium,

4:5

1985-5: Contributions Made Before

but Received After Election, 4:6

1985-6: Affiliated PACs of Local!

International Unions, 4:6

1985-7: Solicitation of Wholesalers'

Personnel, 5:4

1985-8: Fundraising to Refund Illegal

Contributions, 5:5

1985-9: Excess Funds for University

Programs, 5:5

1985-10: Campaign Loan Liquidated

by Candidate's Estate, 5:5

1985-11: Trade Association's Nonsolicitahle Members, 6:4

1985-12: Trade Association's Collecting Agents, 6:5

1985-13: Transfers to Suecessor Candidate's Campaign, 7:5

1985-14: National Party Com mittee's

Media Program, 7:6

1985-16: Prohibited Use of FEC Contributor Information, 7:6

1985-17: Congressional Scholarship

Trust, 8:3

FEDERAL ELECTIOI\J COMfVllSSION

CHANGE OF ADDRESS

Septemter 1985

This cumulative index lists advisory opinions, court cases and 800

Line articles published in the Record

during 1985. The first number i)l the

citation refers to the "number"

(month) of the Record issue; the second number, following the colon, indicates the page number in that

issue.

OPINIONS

1984-16: One Limit for Convention &

Primary, 1:3

1984-33: Fundraiser- by Trade Association's Allied embel's, 1:3

1984-41: Corporate Payments for

!VIedia Ads, 2:1

1984-48: Travel Reimbursements to

State by Senate Campaign, 2:1

1984-52: Refund of Illegal Contributions, 1:4

1984-53: Real Estate Lessors as Federal Contractors, 1:4

1984-54: Reporting/Limits for Candidate Eleeted in Primary, 1:5

1984-55: Solicitation of Law Firm's

Partners by Bank PAC, 1:5

1984-56: Book Payments & Honorarium, 1:5

1984-57: Corporate Communications

on Legislation, 2:2

1984-58: City's Claim for Reimbursement by Presidential Campaign,

2:3

1984-59: Noncampaign Uses of Campaign Assets, 2:3

1984-60: Campaign Debts Liquidated

through Sale of Real Estate Assets,

3:1

•

•

•
Septemter 1985 FEDERAL ELECTION COMMISSION \bIume 11 ,Numte

FEDERAL ELECTION COMMISSION

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