October 1999 Federal Election Commission Volume 25, Number 10

Table of Contents

Regulations

1 Public Financing of Presidential

Candidates and Conventions

1 Public Appearances

Court Cases

4 FEC v. Friends of Jane Harman

5 New Litigation

5 On Appeal?

5 Advisory Opinions

Outreach

6 FEC Monthly Roundtable

6 FEC Conferences

Information

6 Preliminary Primary Dates

7 Index

Regulations

Public Financing of

Presidential Primary and

General Election Candidates

and Conventions; Final

Rules

On September 3, 1999, the

Commission approved several

revisions to its rules concerning the

public financing of Presidential

primary and general election

candidates and Presidential nominating conventions. 11 CFR parts

9001 through 9039. These regulations reflect the Commission’s

experience in administering the

public funding programs in past

elections and seek to resolve some

issues that may arise in the 2000

election.1

The revised rules were published

in the Federal Register on September 13, 1999, and transmitted to

Congress for a 30-legislative day

review period. The date the regulations take effect will be published in

the Federal Register following the

review period.

1

 The Commission has already published final rules modifying the candidate agreement provisions so that

federally-financed Presidential committees must electronically file their

reports. Those regulations became

effective on November 13, 1998.

Additionally, the Commission has

issued final rules governing the

matchability of contributions made by

credit and debit cards, including those

transmitted over the Internet, which

became effective on September 23,

1999. Rules governing coordinated

party committee expenditures in the

pre-nomination period and reimbursement by the news media for travel

expenses are pending before Congress;

the effective date will be published

following the legislative review period.

Federal Funding of General

Election

1. General Election Legal and

Accounting Compliance Fund

The Commission amended 11

CFR 9003.3(a)(1)(i):

• To state that, before June 1 of the

Presidential election year, the

General Election Legal and

Compliance (GELAC) Fund may

only be used for the deposit of

primary election contributions that

exceeded the contributors’ contribution limits and are properly

redesignated under 11 CFR 110.1;

(continued on page 2)

Public Appearances

October 2, 1999

California Political Attorneys

Association

Sparks, Nevada

Darryl Wold, Vice Chairman

October 22, 1999

Glasser Legal Works

Washington, D.C.

Scott Thomas, Chairman

October 22, 1999

Lewis & Clark College

Washington, D.C.

Darryl Wold, Vice Chairman
Federal Election Commission RECORD October 1999

2

Federal Election Commission

999 E Street, NW

Washington, DC 20463

800/424-9530

202/694-1100

202/501-3413 (FEC Faxline)

202/219-3336 (TDD for the

 hearing impaired)

800/877-8339 (FIRS)

Scott E. Thomas, Chairman

Darryl R. Wold, Vice Chairman

Lee Ann Elliott, Commissioner

David M. Mason, Commissioner

Danny L. McDonald,

 Commissioner

Karl J. Sandstrom, Commissioner

James A. Pehrkon, Staff Director

Lawrence M. Noble, General

 Counsel

Published by the Information

 Division

Louise D. Wides, Director

Cheryl A. Fowle, Editor

http://www.fec.gov

• To specify that the GELAC Fund

may not solicit contributions

before June 1 of the Presidential

election year2;

• To more clearly state that a

GELAC Fund may be established

by an individual who is seeking the

nomination of a major party,3

 but

who is not yet a general election

candidate, under 11 CFR 9002.2;

and

• To indicate that, if the candidate

does not become the nominee, all

contributions accepted for the

GELAC Fund, including redesignated contributions, must be

refunded within 60 days of the

candidate’s date of ineligibility.

2. Documentation of

Disbursements

Section 9003.5 sets out the

documentation that publicly financed general election committees

must provide for disbursements in

excess of $200, including a canceled

check negotiated by the payee. The

phrase “negotiated by payee” has

been added to paragraph

(b)(1)(iv)—which refers back to the

canceled check—so that it now

specifically restates that the check

must be negotiated by the payee.

3. Entitlement of Eligible

Candidates to Payments; Use of

Payments

Winding Down Costs. The

Commission amended 11 CFR

9004.4(a)(4)(i) by changing the “or”

at the end of that paragraph to

“and,” clarifying that the expenses

listed in both paragraphs (a)(4)(i)

and (ii) are considered winding

down costs.

Lost, Misplaced or Stolen Items.

The Commission amended paragraph (b)(8) of section 9004.4,

which addresses situations where

general election campaign equipment is lost or damaged, to include

stolen items and to add, as a factor

to determine the degree of responsibility, whether a police report was

filed.

Capital and Noncapital Assets.

Further, section 9004.9(d)(1)(iii)

was amended to indicate that an

inventory must be prepared when

noncapital assets owned by the

primary committee are sold to the

general election committee.

Additionally, under revised

regulations at 11 CFR 9004.9(d),

once the general election campaign

is over, the value of assets obtained

from the primary campaign committee must be listed on the NOQCE

(Net Outstanding Qualified Campaign Expenses) statement as 20

percent of the original cost to the

primary committee.

Finally, a new sentence added to

9004.9(d) clarifies “capital asset,”

stating that, when the components of

a system, such as a computer or

telecommunications system, are

used together and the total cost of

the components exceeds $2,000, the

entire system is considered a capital

asset.

Federal Funding of Nominating

Conventions and Host

Committees

1. Use of Funds

Section 9008.7 was amended by

adding new paragraph (c) to address

situations where convention committee equipment is lost, misplaced

or stolen. This paragraph is consistent with the change made in

paragraphs (b)(8) of 11 CFR 9004.4,

discussed above and 9034.4, discussed below.

2. Petitions for Rehearing; Stays

of Repayment Determinations

In 11 CFR 9008.14, the phrase

“final repayment determinations”

was replaced by “repayment determinations.”

3. Receipts and Disbursements by

Host Committees: Local Banks

and Local Individuals

Section 9008.52(c)(1) was

amended to allow local banks to

donate funds and make in-kind

donations for the limited purposes

described in section 9008.52. This

new language supersedes, in part,

Advisory Opinion (AO) 1995-31.

Additionally, section

9008.52(c)(1) was amended to

specify that the individuals who

may donate funds to host committees, governments agencies and

municipal corporations must either

maintain a local residence or work

for the local office of a business, of

a labor organization or of another

organization.

2

 The Commission also indicated that it

does not intend to make this GELAC

provision effective until June 1, 2000.

3

 At a later date, a Notice of Proposed

Rulemaking may be issued regarding

the possible formation of GELACs by

minor or new party candidates who

accept public funding.

Regulations

(continued from page 1)
October 1999 Federal Election Commission RECORD

3

4. Receipts and Disbursements by

Government Agencies and

Municipal Corporations

The amendments to 11 CFR

9008.53(b)(1) generally follow the

revisions to section 9008.52(c)(1)

concerning receipts by host committees, discussed above.

Federal Funding of Primary

Elections

1. Definition of “State”

Section 9032.11, containing the

definition of “State,” was amended

to delete Canal Zone and add

American Samoa.

2. Documentation of

Disbursements

Revisions to 11 CFR 9033.11

follow the “negotiated by payee”

language discussed above, concerning documentation of general

election disbursements, under 11

CFR 9003.5.

3. Entitlements

Use of Contributions and Matching Payments: Winding Down

Costs. The revised rules at 11 CFR

9034.4(a)(3) provide that a publicly

funded primary candidate who does

not run in the general election may

begin to treat 100 percent of salary

and overhead expenses as compliance costs after the date of ineligibility. However, federally financed

primary candidates who continue on

to the general election, as well as

non-federally funded primary

candidates who accept general

election funding, must wait until

after the end of the expenditure

report period for the general election

before they begin treating all salary

and overhead expenses as compliance expenses.

Lost, Misplaced or Stolen Items.

Revisions pertaining to lost, misplaced or stolen items of the primary

election campaign similar to the

amendments to section 9004.4(b)(8)

(pertaining to general election

funding) were made to 11 CFR

9034.4(b)(8).

Attributing Expenditures Between

Primary and General Election

Spending Limits. While the Commission expects to address a variety

of issues concerning the distinction

between primary and general

election expenses at a later date, it

did amend paragraph (e) of section

9034.4 to indicate that the provision

applies to Presidential campaigns

that accept federal funds for either

election.

Joint Primary/GELAC Fund

Solicitations. Under revisions to 11

CFR 9034.4(e)(6)(i), the GELAC

Fund and the primary committees

must apportion their joint

fundraising costs according to the

percentage of contributions each

committee receives from the joint

fundraising effort. This new provision follows the guidelines given in

section 9034.8, pertaining to joint

fundraising by unaffiliated committees.

Net Outstanding Qualified

Campaign Expenses (NOQCE) and

Net Outstanding Campaign Obligations (NOCO); Capital Assets.

Section 9034.5(c)(1) permits a

Presidential primary committee to

deduct 40 percent of the original

cost of capital assets for depreciation in determining its NOCO.

Section 9004.9(d)(1) provides for

straight 40 percent depreciation for

capital assets purchased by general

election committees for purposes of

its statement of NOQCE. Both

sections 9034.5(c)(1) and

9004.9(d)(1) were amended to allow

candidates to demonstrate a higher

depreciation figure through documentation of the fair market value.

The Commission also amended

11 CFR 9034.5 to say that, where a

candidate’s primary committee

transfers or sells capital assets to his

or her publicly financed general

election committee, the minimum

fair market value is 60 percent of

the original purchase price.

Finally, a new sentence added to

section 9034.5(c)(1) is similar to the

new language concerning multiple

components of a telecommunication

system found at section 9004.9(d).

See description above.

4. Expenditure Limits;

Compliance and Fundraising

Exceptions

The rules at 11 CFR 9035.1(c)(1)

were amended to allow an amount

equal to 15 percent of the

candidate’s overall expenditure limit

to be excluded as exempt legal and

accounting compliance costs under

11 CFR 100.8(b)(15). In addition, as

explained above, overhead and

salary expenses may be treated as

exempt compliance costs after the

end of the expenditure report period

or after the date of ineligibility.

5. Review of Matching Fund

Submissions and Certification of

Payments by Commission

Threshold Submission. New

language in paragraph (b)(3) of

section 9036.1 permits the use of

digital imaging for primary committees’ threshold submissions (i.e.,

committees may make those submissions using digital images on CD

ROMs instead of submitting paper

photocopies of checks and deposit

slips).

Additional Submissions for

Matching Fund Payments. Additionally, paragraph (b)(1)(vi) of section

9036.1 was revised to enable

primary committees to submit

digital images of contributor

redesignations, reattributions and

supporting statements and materials

needed to establish the matchability

of contributions.

(continued on page 6)
Federal Election Commission RECORD October 1999

4

Court Cases

FEC v. Friends of Jane

Harman

On August 18, 1999, the U.S.

District Court for the Central

District of California found that

Friends of Jane Harman, the principal campaign committee of former

Congresswoman Jane Harman, and

its treasurer violated the Federal

Election Campaign Act (the Act)

when they accepted corporate

contributions in the form of earmarked contributions collected by a

corporate representative and an

“advance” from the same corporation.

Background

Hughes Aircraft Company

(Hughes), a Los Angeles corporation, sponsored a fundraiser for Ms.

Harman at her request during the

1993-1994 election cycle.

Hughes’s chairman and CEO

approved the fundraiser and directed

Hughes’s employees to carry out the

logistics of the fundraiser. Hughes’s

executives and employees secured a

room at Hughes’s corporate headquarters, hired a caterer, issued

invitations and collected and

transmitted Hughes employees’

contribution checks to the Harman

campaign.

A solicitation letter, sent to

Hughes’s employees in tandem with

an invitation, requested contributions to Ms. Harman’s campaign.

The solicitation letter also requested

that personal checks be made out to

the campaign and that they be

forwarded, via interoffice mail, to a

Hughes employee in advance of the

event.

On October 29, 1993, Representative Harman appeared at the

fundraiser held at Hughes’s corporate headquarters. Hughes’s Director

of Public Affairs collected some

contributions for the event through

interoffice mail prior to the event

and collected others from executives

at the door. A few days after the

fundraiser, a representative of the

Harman campaign picked up the

checks. Altogether, Hughes collected and forwarded $20,600 to the

Harman campaign.

Three months later, the Harman

campaign paid $857 to the corporation to cover Hughes’s labor costs

and the cost of using Hughes’s

facilities. The campaign paid the

food caterer for the event directly.

Earmarked Contributions

The Act prohibits corporations

from making contributions or

expenditures in connection with any

federal election. 2 U.S.C. §441b(a).

Because Hughes, as a corporation,

was prohibited from making a

contribution to a federal campaign,

it was also prohibited under FEC

regulations from acting as a conduit

for contributions that are earmarked

to candidates or their authorized

committees. 11 CFR 110.6(b)(2).

Additionally, 2 U.S.C. §441b(a)

prohibits candidates or their committees from knowingly accepting

“anything of value” from a corporation.

The court found that the collection of contributions by a Hughes

employee in her official capacity as

Director of Public Relations conferred a benefit on the campaign

from the corporation. Therefore,

when the Harman campaign received the checks collected, it

violated the §441b(a) prohibition

against accepting anything of value

from a corporation.

Reimbursement of Staff Labor

Costs

Section 441a(b)(2) of the Act

provides that a “contribution”

includes an advance. On the other

hand, 11 CFR 114.9(2) (an FEC

regulation) permits campaigns to

reimburse corporations for the use

of corporate facilities within a

commercially reasonable time. The

FEC maintained that this regulation

covers reimbursement for the use of

facilities but not reimbursement for

the labor costs of corporate employees.

Deferring to the FEC’s interpretation of the Act and its regulations,

the court concluded that, “because

the Harman Campaign did not pay

for the use of employee services

until after the event occurred,” the

$731 value of the employees’ labor

constituted an advance of corporate

funds and was, therefore, an impermissible corporate contribution

violating 2 U.S.C §441b(a).

Remedy

While the court found that the

committee knowingly violated the

Act, the court denied the FEC’s

request to require the committee to

disgorge to the U.S. Treasury an

amount equal to the prohibited

contributions, to assess a civil

penalty against the committee or to

enjoin the committee from accepting

corporate contributions in violation

of 2 U.S.C. Section 441b(a).

The court stated that there was no

evidence that the defendants believed, at the time of the fundraiser,

that they were not complying with

the law. The court also stated that

the FEC subsequently clarified its

regulations surrounding the use of

corporate staff; the regulations now

specifically state that the use of

corporate staff to “plan, organize or

carry out [a] fundraising project”

requires payment of the fair market

value of the services in advance. 11

CFR 114.2(f)(2)(i)(A). The court

did not issue an injunction because

the likelihood of future violations of

the Act by the campaign or its

treasurer was remote since the

Harman campaign is no longer in

existence and Representative

Harman is no longer in office.

U.S. District Court for the

Central District of California, 98-

7691-CAS(JGx), August 18, 1999.✦
October 1999 Federal Election Commission RECORD

5

New Litigation

John Jay Hooker v. FEC

John Jay Hooker, a registered

voter and “qualified candidate for

the United States Senate,” asks the

court to declare the Federal Election

Campaign Act (the Act) unconstitutional. Mr. Hooker alleges that the

Act preempts state laws that would

prohibit interstate contributions to

federal candidates. He asserts that

interstate contributions interfere

with the rights of the people of

Tennessee to elect their two U.S.

Senators.

Mr. Hooker also asks the court to

declare that the Act and the “matching funds” provisions (“26 U.S.C.

§9001 et seq.”) are “outside the

power of Congress and are in

violation of the state’s constitutional

prerogatives in the Presidential

election process.”

U.S. District Court for the Middle

District of Tennessee, 99-0794,

August 18, 1999.✦

Virginia Society for Human Life,

Inc. v. FEC

Virginia Society for Human Life,

Inc. (VSHL) asks the court to:

• Declare that the FEC regulation

found at 11 CFR 100.22(b) is

unconstitutionally overbroad,

vague and contrary to law;

• Overturn the FEC’s decision not

to act on VSHL’s petition for

rulemaking, in which VSHL had

asked the FEC to repeal the

regulation;

• Set aside the regulation; and

• Permanently enjoin the FEC from

enforcing the regulation.

VSHL is a nonprofit, membership

corporation in Virginia, which does

accept donations from other corporations. The group intends to make

communications to the general

public using voter guides that

tabulate federal candidates’ positions on abortion-related issues. The

voter guides would indicate VSHL’s

official position on these issues and,

in some cases, would indicate that

one of the candidates for a particular

office agreed with VSHL’s position

while his or her opponent did not.

VSHL would not coordinate the

guides with any candidate.

Subsection (b) of 11 CFR

100.22—the section opposed by

VSHL—defines express advocacy

as a communication that, when

taken as a whole and with limited

reference to external events (such as

proximity to an election), can only

be interpreted by a reasonable

person as unambiguously advocating the election or defeat of a clearly

identified candidate.

U. S. District Court for the

Eastern District of Virginia,

3:99CV559, August 9, 1999.✦

On Appeal?

FEC v. Christian Coalition

On September 22, 1999, the

Commission decided not to appeal

the recent decision by the U.S.

District Court for the District of

Columbia in FEC v. Christian

Coalition. See the September 1999

Record, page 4.✦

Advisory

Opinions

AO 1999-19

Contribution from Living

Trust

A contribution to a congressional

candidate made from a living trust1

established by Andrea Ellis is

permissible and is considered a

contribution from Andrea Ellis

because her signature appears on the

check.

Ms. Ellis is the beneficiary,

trustee and trustor of a living trust.

The trust consists of Ms. Ellis’s

assets and is not a tax shelter. Ms.

Ellis is the only person authorized to

access the funds in the trust and to

write checks from the trust. The

trust is not a testamentary trust. 2

Commission regulations state

that, “Absent evidence to the

contrary, any contribution made by

check, money order, or other written

instrument shall be reported as a

contribution by the last person

signing the instrument prior to

delivery to the candidate or committee.” 11 CFR 104.8(c).

The contribution is permissible

and considered a contribution from

Ms. Ellis rather than from the trust

because her signature appears on the

check. Ms. Ellis is the beneficial

owner of the funds, and she has

retained complete control over the

use of the funds in the trust.

The Commission distinguished

this situation from previous Advisory Opinions (AOs) that dealt with

1

 A living trust, technically called an

inter vivos trust, is one set up by a

living person.

2

 A testamentary trust is one created

upon one’s death by his/her last will

and testament.

Federal Register

Federal Register notices are

available from the FEC’s Public

Records Office.

Notice 1999-17

Public Financing of Presidential

Primary and General Election

Candidates; Final Rules and

Transmittal of Regulations to

Congress (64 FR 49355,

September 13, 1999)

Notice 1999-18

Matching Credit Card and Debit

Card Contributions in

Presidential Campaigns;

Announcement of Effective Date

(64 FR 51422, September 23,

1999)

(continued on page 7)
Federal Election Commission RECORD October 1999

6

Rules Addressed at a Later Date

The rulemaking also touched

upon five other topics, which the

Commission expects to address at a

later date. Those topics are:

• Coordination between candidates

and party committees on political

ads, polling, media production,

consulting services and sharing of

employees;

• Modifications to the audit process;

• Bases for primary repayment

determinations;

• A “bright line” between primary

expenses and general election

expenses; and

• Forming Vice Presidential committees prior to nomination.✦

Regulations

(continued from page 3)

Regional Conference (includes

candidate, corporate/labor and

party workshops)

Date: November 15-17, 1999

Location: San Francisco

(Grand Hyatt)

Registration: $250

Candidate Conference

Date: February10-11, 2000

Location: Washington, DC

(Hyatt Regency Capitol Hill)

Registration: To be determined

FEC Conference Schedule

 The FEC continues its series of conferences on campaign finance this fall.

See below for details. To register for any conference, call Sylvester

Management at 800/246-7277 or send an e-mail to

tsylvester@worldnet.att.net. For program information, call the FEC’s

Information Division at 800/424-9530 or 202/694-1100. A regularly updated

schedule for the conferences and a downloadable invitation/registration form

appear at the FEC’s Web site. Go to http://www.fec.gov/pages/infosvc.htm for

the latest information.

Regional Conference (includes

candidate, corporate/labor and

party workshops)

Date: March 8-10, 2000

Location: Miami, FL

(Sheraton Biscayne Bay)

Registration: $240

Corporate and Labor

Conference

Date: May 2000

Location: Washington, DC

Registration: To be determined

Membership and Trade

Association Conference

Date: June 2000

Location: Washington, DC

Registration: To be determined

Information

Preliminary Primary Dates

for 2000 Available

A chart on the tentative dates for

the 2000 Presidential and Congressional primaries is available on the

FEC Web site and also on the FEC’s

automated FAXLINE. Readers

should note that the dates are

tentative, and will be updated as

more information becomes available.

To access the chart on the FEC’s

Web site (http://www.fec.gov), click

first on “What’s New!” and then on

“Preliminary List of 2000 Primary

Dates Published.” To order the chart

from FAXLINE, call 202/501-3413

and request document #650.✦

FEC Conducts Monthly

Roundtable Session

The FEC will conduct a monthly

roundtable for the regulated community on November 3, 1999, from

9:30 to 11:00 a.m. at its offices in

Washington. The session will focus

on new FEC regulations including:

• Definition of member; and

• Contributions from limited liability

companies (LLCs).

The session is limited to 12

participants and the intended

audience includes:

• Trade and member PACs;

• Recipients of contributions from

LLCs (e.g., PACs and campaigns);

• LLCs; and

• Lawyers, accountants and consultants to the above groups.

Registration is $25 and will be

accepted on a first-come, firstserved basis. Please call the FEC

before registering or sending money

to be sure that openings remain.

Prepayment is required. The registration code number is 1190. The

registration form is available at the FEC’s

Web site—http://www.fec.gov—

and from Faxline, the FEC’s automated fax system (202/501-3413,

request document 590). For more

information, call 800/424-9530 or

202/694-1100.✦

Outreach
October 1999 Federal Election Commission RECORD

7

testamentary trusts, in which the

trust was considered the legal

successor of the testator and therefore the source of the contribution.

AOs 1999-14 and 1988-8.

Issued: August 25, 1999; Length:

2 pages✦

Advisory Opinions

(continued from page 5)

Advisory Opinion Requests

AOR 1999-22

Use of merchant ID number by

company that collects and forwards

credit card contributions made

through Internet to multiple candidates (Aristotle Publishing, Inc.,

August 3, 1999; 10 pages)

AOR 1999-23

Replacement of PAC contribution

check originally made in the previous year but lost and never received

by recipient (Arvest Bank Group,

Inc. PAC and Arkansas Bankers

Association PAC, Inc., August 27,

1999; 2 pages)

AOR 1999-24

Use of Web site to provide

questions to, and answers from,

candidates of selected political

races, candidate “chats” and an online debate forum (Election Zone

LLC, August 23, 1999; 6 pages)

AOR 1999-25

Use of Web site to encourage

voting and voter registration, to

provide interactive means for

candidate “online debates”, and for

web site visitors to pose questions

and comments to candidates (Democracy Network, September 1,

1999; 18 pages plus 3-page attachment)

AOR 1999-26

Status of committee as state

committee of a political party

(Virginia Taxpayers Party, September 1, 1999; 6 pages plus14-page

attachment)

AOR 1999-27

Allocation of expenses for

presidential candidate straw poll

conducted on behalf of State party

organization (Alaska Federation of

Republican Women, August 4,

1999; 14 pages plus 32-page

attachment)✦

Index

The first number in each citation

refers to the “number” (month) of

the 1999 Record issue in which the

article appeared. The second

number, following the colon,

indicates the page number in that

issue. For example, “1:4” means

that the article is in the January

issue on page 4.

Advisory Opinions

1998-22: Application of expenditure

definition and disclaimer requirements to web site containing

express advocacy, 1:16

1998-23: Status as state committee

of political party, 1:16

1998-26: Candidate committee’s

acceptance of loan repayment

from contested election trust fund

that contains funds loaned to it by

candidate, 3:5

1998-27: Status as state committee

of political party, 3:6

1999-1: Use of campaign funds to

pay salary to candidate, 4:5; 6:6

1999-2: Use of corporate treasury

funds to provide meals to employees attending candidate forums,

4:6

1999-3: Use of digital signatures by

restricted class to authorize

payroll deductions, 5:5

1999-4: Applicability of contribution limits to local party organization conducting federal activity

and affiliated with state party

committee, 6:3

1999-5: Revising state party ballot

composition ratio for new executive office, 6:4

1999-6: Use and publication of

information about annuity allotment program permitting union

member retirees to make contributions to SSF, 6:4

1999-7: Free hyperlinks on government web site to web sites of

candidates, 6:5

1999-8: Investment of excess campaign funds in mutual funds, 6:6

1999-9: Matching credit card

contributions received by Presidential primary candidates via

Internet, 7:5

1999-10: SSF solicitation of member policyholders of mutual

insurance company, 7:7

1999-11: Federal candidate’s use of

funds from state-level account, 7:7

1999-12: Preemption of Pennsylvania disclosure requirements 8:4

1999-13: Use of Corporate Aircraft,

8:4

1999-14: Testamentary bequests

that exceed contribution limits,

9:7

1999-15: Membership status of

unincorporated unit of trade

association, 9:7

1999-16: Solicitation of chapter

members of trade association, 9:9

1999-18: Calculation of allocation

ratio by local party committee,

9:10

1999-19: Contributions from living

trust, 10:5

Compliance

MUR 4546: Failure to provide

contributor information and

demonstrate “best efforts,” 5:8

MUR 4632: Untimely reports;

failure to amend Statement of

Organization; treasurer’s absence,

7:10

MUR 4750: Excessive contributions, 1:13

MUR 4751: Excessive and improper

transfers of nonfederal funds,

excessive contributions, corporate

contributions, 2:2

(continued on page 8)
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Federal Election Commission RECORD October 1999

MUR 4796: Corporate contributions, contributions in the names

of others, 1:13

MUR 4797/4798: Prohibited

transfers from unregistered party

organization to party committees,

failure to allocate, 8:6

MUR 4834: Foreign national

contribution, contribution in the

name of another, 3:7

MUR 4879: Corporate contributions

in the names of others, 8:6

Court Cases

FEC v. _____

– Al Salvi for Senate Committee

(98C-4933), 4:5

– Christian Coalition, 9:4

– Colorado Republican Federal

Campaign Committee, 4:1

– David Gentry for Congress

Committee, 7:10

– Forbes, 4:5

– Friends of Jane Harman, 10:4

_____ v. FEC

– Hooker, 10:5

– Judd, 1:3; 4:5

– Judicial Watch, 7:8

– Mariani, 2:1

– National Committee of the Reform

Party, 4:4

– Perot ’96 (98-1022), 6:1

– RNC (98-5263), 1:2

– Virginia Society for Human Life,

10:5

Other

– Burris v. Russell, 1:3

– Cincinnati v. Kruse, 1:3

– Fireman v. United States, 5:7

– USA v. Hsia, 7:9

Regulations

Debates, 7:5

Definition of “Member” of Membership Association, 1:10; 3:1;

5:6; 9:1

Electronic FOIA, 4:7

Express Advocacy, 3:2; 6:7

Limited Liability Companies, 1:11;

8:1

Matching Credit Card and Debit

Card Contributions in Presidential

Campaigns, 7:4, 9:3

Party Committee Coordinated

Expenditures and Media Travel,

9:12

Public Financing of Presidential

Primary and General Election

Candidates, 1:7; 3:1; 5:6;10:1

Soft money, 1:12

Status of, 3:3

Voter Guide Petition, 9:13

Reports

Electronic filing, 1:6; 2:1

Reports due in 1999, 1:4

Reports due in July, 7:1

Special election, California, 8:9

Special election, Georgia, 2:3

Special election, Louisiana, 4:7

Statistics

Congressional, 2:4; 6:8

PAC, 3:11; 7:2; 9:18

Party, 3:4; 6:8

Index

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