January 1998 Federal Election Commission Volume 24, Number 1

Table of Contents

1 Message From the Chairman

Commissioners

2 New Chairman and Vice

Chairman Elected

Court Cases

2 New Litigation

3 On Appeal?

Regulations

4 Public Hearing Set For

Recordkeeping and Reporting

Requirements Rulemaking

4 Comments Sought on Rulemaking

Notice on Who Qualifies as

“Member”

5 FEC Seeks Comments on Petition

Addressing Expenditures by

Qualified Nonprofit Corporations

6 Federal Register Notices

Reports

6 Reports Due in 1998

8 Pre-Election Reporting Dates

 11 Guide to 1998 Reporting

 12 California Special Election

 13 Pennsylvania Special Election

 11 Election Law Amended

Public Funding

 13 Forecast Shows Shortfall in Public

Funding for 2000 Election Cycle

 14 Fulani Repayment Determination

Stayed

14 Advisory Opinions

 15 Conferences

Publications

16 Updated Corporate/Labor

Campaign Guide Available

16 Index

Message From the Chairman

Nineteen ninety-eight promises to be a year of change and challenge for

the FEC.

We can look forward to an election year with an ever-increasing workload

as we implement new and innovative ways to manage this increase on a

limited budget. Many of these innovations are already in place. For example,

committees may now file their reports electronically. Along with the 800

number (800/424-9530), the Commission also has an internet web site (http://

www.fec.gov). Additionally, publications and other election law materials

are available through FEC Faxline (202/501-3413).

All of this advance in technology is to help answer your questions and

satisfy your requests quickly and easily. We welcome your comments and

suggestions and pledge our continuing efforts to help the regulated community successfully comply with the Federal Election Campaign Act and

participate fully in the political process.

While I was elected Chairman for this year, it is only in a caretaker

capacity. There will be two new Commissioners—and a new Chairman—

possibly in office by late February or early March. However, I am very

pleased to be able to once more serve as Chairman during this important

election cycle.

Finally, a very special expression of gratitude to our hardworking staff,

many of whom I have had the great pleasure to work with since 1975.

Without these committed, loyal and dedicated individuals, the FEC would

not be the responsive, informative agency it is today. I am especially grateful

for their commitment to our mission.
Federal Election Commission RECORD January 1998

2

Federal Election Commission

999 E Street, NW

Washington, DC 20463

800/424-9530

202/219-3420

202/501-3413 (FEC Faxline)

202/219-3336 (TDD for the

 hearing impaired)

800/877-8339 (FIRS)

Joan D. Aikens, Chairman

Scott E. Thomas, Vice Chairman

Lee Ann Elliott, Commissioner

Danny L. McDonald,

 Commissioner

John Warren McGarry,

 Commissioner

John C. Surina, Staff Director

Lawrence M. Noble, General

 Counsel

Published by the Information

 Division

Louise D. Wides, Director

Angela Rucker, Editor

http://www.fec.gov

Commissioners

New Chairman and Vice

Chairman Elected

On December 11, 1997, the

Commission elected Joan D. Aikens

as FEC Chairman and Scott E.

Thomas as Vice Chairman.

One of the original members of

the Commission, Ms. Aikens was

first appointed in 1975. She previously served as chairman of the sixmember board in 1978, 1986 and

1992.

Before joining the FEC, Ms.

Aikens was an executive with Lew

Hodges Communications, a public

relations firm in Valley Forge,

Pennsylvania. She also served as a

member of the Pennsylvania Republican State Committee, and president of the Pennsylvania Council of

Republican Women.

A native of Delaware County,

Pennsylvania, Ms. Aikens has been

active in volunteer activities. She

was a member of the Commonwealth Board of the Medical

College of Pennsylvania and a past

president of Executive Women in

Government. She currently is a

member of the board of directors of

Ursinus College, where she received

a B.A. degree and an honorary

Doctor of Law degree; a member of

the board of directors of the National Legal Center for the Public

Interest; and a member and past

King Lion of the Washington Host

Lions Club.

Mr. Thomas was first appointed

to the Commission in 1986, after

starting his career at the FEC as a

legal intern in 1975. He was an

Assistant General Counsel for

Enforcement and an executive

assistant to former Commissioner

Thomas E. Harris, before taking

over Commissioner duties.

A Wyoming native, Mr. Thomas

graduated from Stanford University

and holds a law degree from

Georgetown University Law Center.

He is a member of the District of

Columbia and U.S. Supreme Court

bars. ✦

Court Cases

New Litigation

National Committee of the

Reform Party v. FEC

The National Committee of the

Reform Party, several other groups

aligned with Ross Perot’s Reform

Party and John Place, an individual

eligible to vote for president, ask the

district court to issue an order

convening a three-judge district

court panel to decide several

constitutional issues pertaining to

the Presidential Election Campaign

Fund Act (the Fund Act). The suit

also asks the court to certify questions regarding the constitutionality

of the Federal Election Campaign

Act (the Act) to an en banc panel of

the U.S. Court of Appeals for the

Ninth Circuit.

Other defendants include the

Democratic National Committee

(DNC), the Republican National

Committee (RNC) and President

Bill Clinton’s and former Senator

Bob Dole’s presidential campaign

committees.

The Reform Party contends that,

under the Fund Act, it was unfairly

held to the same $61.8 million

expenditure limit during the 1996

Presidential election as applied to

the Democratic and Republican

presidential contenders, even though

it only received $29 million in

public funding—slightly less than

half of what the major party candidates received. In order to raise the

remainder and thus compete financially for the presidency, Mr. Perot,

the Reform Party’s presidential

nominee, could raise funds only in

federally permissible contributions—that is, $1,000 for individuals

and $5,000 for political action

committees. The suit maintains that

this provision of the Fund Act is

little more than “welfare for the

major parties at the expense of

viable minor parties.”

The suit also contends that both

the Clinton/Gore ’96 Primary

Committee and the Dole for President Committee circumvented the

expenditure limit during the 1996

election through their respective

national party committees. The

Reform Party alleges that the major

parties conducted “massive” advertising campaigns in connection with

the presidential candidates’ committees, a violation of 2 U.S.C.

§441a(d)’s coordinated expenditure

limits. It contends the DNC spent

$34 million illegally, and the RNC

spent $13 million illegally, conducting what they assert to be issue

advocacy advertisements that were,

in reality, express advocacy ads for

or against the presidential contenders. The suit also asserts that the

presidential committees violated the

law in accepting such contributions.
January 1998 Federal Election Commission RECORD

3

Other Constitutional Claims

Against the Act

According to the Reform Party,

the Act violates the plaintiffs’

constitutional rights to due process

and equal protection in both the

exclusive jurisdiction it gives to the

FEC to enforce the Act and Commission regulations and the bipartisan make-up of the Commission,

which it claims excludes members

of minor parties.

The Reform Party asserts that the

barrier imposed by requiring

complainants first to raise all

complaints with the FEC deprives

complainants of their constitutional

rights and, more specifically, results

in “discrimination against the rights

of members and supporters of minor

parties and the campaign organizations of minor parties.” The suit

goes on to state that the structure of

the Commission, with three Democrats and three Republicans as

Commissioners, results in unfair

treatment of those not associated

with the two major parties.

Constitutional Claims Against the

Fund Act

The Fund Act, the suit contends,

violates the constitutional rights to

equal protection and freedom of

association because it discriminates

against minor party candidates in

the unequal distribution of public

funding. This, in turn, negates a fair

opportunity for a minor party

candidate to win the presidency.

The Fund Act provides that the

candidate of each of the major

parties is entitled to equal payments

for the general election campaigns

subject to the maximum spending

cap for that year. Minor parties—

judged as those whose candidates

received between 5 and 25 percent

of the popular vote in the preceding

election—receive proportionally

less funding, based on the vote

received in that election. However,

as a precondition for receiving

public funding, minor party candidates must agree to a spending limit

equal to the funding received by the

major party candidates. This is

discriminatory, the suit contends,

because it forces minor party candidates “to meet requirements to which

the Democratic and Republican

Parties are not subject, thus preserving the major parties’ preferred

position in the electoral process.”

The suit further alleges that the

unfair distribution of public funding

to minor party candidates deprives

minor party candidates, such as Mr.

Perot, a fair opportunity to be

elected President, and to obtain a

sufficient percentage of the popular

vote to entitle the minor party’s next

presidential candidate to receive

funding equal to the major party

candidates in the next election.

State Law Claims

In the alternative, the Reform

Party suit claims unfair competition

and interference with Perot ’96 and

the Reform Party under California

law. The Reform Party states that

the national party committees’

advertising campaigns gave those

committees an unfair advantage

over the Reform Party and thus

violated California’s Elections and

Business and Professions Codes.

Other Requests of the

District Court

Additionally, the Reform Party

asks the court to permanently enjoin

the FEC from providing funding in

unequal portions to major and minor

parties with presidential nominees.

The Party also asks the court to

issue a declaratory judgment that a

private cause of action exists for the

Reform Party to sue the DNC, the

RNC and other named entities in

this suit. Finally, the Reform Party

asks the court to issue a permanent

injunction against the DNC and

RNC, prohibiting them from any

future violations of the Act’s

expenditure limits, and to impose

penalties on the national committees

for the alleged violations.

U.S. District Court for the

Northern District of California,

C97-4048, November 5, 1997. ✦

FEC v. National Medical Political

Action Committee

The FEC asks the court to find

that the National Medical Political

Action Committee (NMPAC) and

its treasurer, Henry W. Williams Jr.,

violated the Federal Election

Campaign Act (the Act) when they

failed to file 14 disclosure reports in

a timely manner.

NMPAC filed all the reports that

were due during 1992 on May 12,

1994. Some of these reports were

more than two years late. NMPAC

also failed to file on time six other

reports due in 1993 and 1994. These

tardy filings violated 2 U.S.C.

§434(a)(4)(i), (ii), (iii) and (iv). The

Commission found probable cause

to believe that NMPAC had violated

the Act. When efforts to enter into a

conciliation agreement with the

defendants failed, the Commission

authorized this suit.

In addition to finding that

NMPAC violated the Act, the FEC

asks the court to enjoin the PAC and

Mr. Williams from failing to file

reports within the time limits set out

by Commission regulations, and to

assess an appropriate civil penalty.

U.S. District Court for the

District of Columbia Circuit, 97-

2961, December 9, 1997. ✦

On Appeal?

FEC v. Williams

On December 8, 1997, the U.S.

Supreme Court declined to hear this

case. The U.S. Court of Appeals for

the Ninth Circuit had reversed a

district court decision and had ruled

in favor of defendant Larry Williams. In that decision, two of the

three appellate judges concluded

that the FEC had waited too long

after an alleged violation of the

Federal Election Campaign Act to

file suit against Mr. Williams. The

court said that, by then, the statute

of limitations had expired. See the

February 1997 issue of the Record. ✦
Federal Election Commission RECORD January 1998

4

Regulations

Public Hearing Set For

Recordkeeping and

Reporting Requirements

Rulemaking

The FEC will hold a public

hearing on its proposed revisions to

rules governing recordkeeping and

reporting requirements on February

11 at 10 a.m. in its hearing room in

Washington, DC.

The Commission has proposed

several revisions to update, clarify

and simplify the current requirements for filing FEC disclosure

reports. The affected regulations are

at 11 CFR 102.9, 104.3 and part

108. See page 4 of the October 1997

Record for more information about

the rulemaking. For the complete

Notice of Proposed Rulemaking on

this issue, call the Public Records

Office at 800/424-9530 (press 3);

request the document from the FEC

Faxline at 202/501-3413 (document

231); see the September 26, 1997,

Federal Register (62 FR 50708); or

see the FEC’s web site (http://

www.fec.gov). The complete public

hearing announcement also is

available at the FEC’s web site and

in the December 24, 1997, Federal

Register (62 FR 67300).

Those wishing to testify during

the hearing must submit a written

request to appear by January 23 to

Susan E. Propper, Assistant General

Counsel. Witnesses also must have

written comments on file with the

Commission by that date. Written

comments and requests to testify

should be mailed to the Federal

Election Commission, 999 E St.,

NW, Washington, DC 20463. Faxed

comments should be transmitted at

202/219-3923, with a copy mailed

to the preceding address to ensure

legibility. Comments also may be

sent by e-mail to reprec@fec.gov.

Electronic submissions must include

the commenter’s full name, e-mail

address and postal mail address. ✦

Comments Sought on

Rulemaking Notice on Who

Qualifies as “Member”

On December 15, 1997, the

Commission approved for public

comment a Notice of Proposed

Rulemaking (NPRM) on who

qualifies as a “member” of a membership association.1 The NPRM

includes three alternatives. Language at 11 CFR 100.8(b)(4)(iv) and

114.1(e) would be modified, and 11

CFR 114.7(k) and 114.8(g) would

be repealed.

Members of a membership

association can be solicited by the

association’s separate segregated

fund and can also receive express

advocacy communications from the

organization. The proposed rules

would expand the class of persons

considered to be “members,” and

include three alternative ways the

current definition could be revised.

An Advanced Notice of Proposed

Rulemaking (ANPRM) on this

subject was published on July 31,

1997. See page 8 of the August

1997 Record.

Background

In FEC v. National Right to Work

Committee, the U.S. Supreme Court

determined that members of

nonstock corporations must have a

significant financial or organizational attachment to the organization. In 1993 the Commission

codified this ruling at 11 CFR

100.8(b)(4)(iv) and 114.1(e).

The U.S. Chamber of Commerce

and the American Medical Association challenged these rules in

Chamber of Commerce of the

United States v. FEC. The U.S.

Court of Appeals for the District of

Columbia Circuit held that, based on

the NRWC opinion, the FEC’s rules

were unduly restrictive as applied to

these two organizations.

Current Rules Not Being Revised

Current rules define a “membership association” as an organization

that: (1) provides for members in its

articles and by-laws; (2) solicits

members; and (3) acknowledges the

acceptance of members, with such

things as a membership card or a

subscription to a membership

newsletter. The Commission is not

proposing that these requirements be

changed. In addition, the current

regulations recognize as members

those who have a strong financial

interest in an association other than

paying dues, such as ownership of a

stock exchange seat. This provision

also has not been modified in the

NPRM.

New Alternative Definitions of

Member

The current rules provide three

different ways that a person can

qualify for membership. In addition

to the financial attachment noted

above, the right to vote directly for

the membership organization’s

highest governing body is sufficient

to confer membership rights.

However, in most instances, membership requires a combination of

regularly-assessed dues and the right

to vote directly or indirectly for at

least one member of the

association’s highest governing

body.

The Commission is seeking

comments on three alternatives of

the definition of member. Each

would provide more guidance

consistent with the decision in

Chamber, expanding the class of

persons that could be considered as

members.

Alternative A. This alternative

sets out three sets of criteria for

membership: (1) annual dues of at

least $50; (2) a major organizational

attachment to the membership

association (possible attachments

are suggested); or (3) a combination

1

 The term “membership association”

includes membership organizations,

trade associations, cooperatives,

corporations without capital stock, and

local, national and international labor

organizations that meet the requirements set forth in the regulations.
January 1998 Federal Election Commission RECORD

5

of annual dues of less than $50 and

some lesser organizational attachment to the association. Under this

alternative a person who satisfied

any one of these criteria would

qualify as a member.

Alternative B. This alternative

would set the amount of annual dues

required for membership at $200—

the same amount that triggers

itemized disclosures for political

committees—for membership

organizations formed to further an

ideological, social welfare or

political bent. Persons affiliated

with these types of groups, but who

pay less than $200 per year in dues,

still would be considered members

for Commission purposes if they

had some right to participate in the

governance of the organization.

Suggested examples are described in

the NPRM.

 However, the members of

organizations formed to further

business or economic interests

would be treated as members by

paying any set amount of regular

dues. Those individuals and entities

generally join membership organizations to foster their business or

economic interests, thus creating an

attachment that is independent of

any political attachment, unlike the

previous category where political

support may be the only motivation.

The business category would

include business leagues, trade

associations, labor organizations and

self-regulating professional associations.

Alternative C. This alternative

would consider any amount of

annual dues set by a membership

association to be sufficient to confer

membership status. This alternative

would treat ideological organizations the same as economic or

business associations for purposes

of the rules.

In addition to the alternatives

described above, the proposed rules

would provide that direct membership in any level of a multitiered

association be construed as membership in all tiers of the association for

purposes of the regulations. 11 CFR

114.7(k) and 114.8(g).

The NPRM is available from the

Public Records Office at 800/424-

9530 (press 3); through the FEC’s

Faxline at 202/501-3413 (request

document 229); and at the FEC’s

web site—http://www.fec.gov. The

NPRM also is published in the

December 22, 1997, Federal Register (62 FR 66832).

Public comments must be submitted in either written or electronic

form to Susan E. Propper, Assistant

General Counsel. Written comments

should be mailed to the Federal

Election Commission, 999 E St.,

NW, Washington, DC 20463. Faxed

comments should be transmitted at

202/219-3923, with a copy mailed

to the preceding address to ensure

legibility. Comments also may be

sent by e-mail to members@fec.gov.

Electronic submissions must include

the commenter’s full name, e-mail

address and postal mail address. The

deadline for comments is January

21. ✦

FEC Seeks Comments on

Petition Addressing

Expenditures by Qualified

Nonprofit Corporations

On December 5, 1997, the

Commission approved for publication a Notice of Availability relating

to its regulations governing expenditures by qualified nonprofit corporations. 11 CFR 114.10. The notice

invites comments on a petition

submitted to the FEC by the James

Madison Center for Free Speech.

The petition urges the Commission to conform portions of its

regulations to the decision by the

U.S. Court of Appeals for the Eighth

Circuit in Minnesota Citizens

Concerned for Life v. FEC. The

regulations in question, found at 11

CFR 114.10, describe a narrow

category of nonprofit ideological

corporations that are exempt from

the Federal Election Campaign

Act’s prohibition on independent

expenditures by corporate entities. 2

U.S.C. §441b. These regulations

were declared invalid by the Eighth

Circuit because they deny the

exemption to “a voluntary political

association that conducts minor

business activities or accepts

insignificant corporate donations.”1

The appeals court denied the FEC’s

petition for a rehearing of this case

and its suggestion for a rehearing en

banc.

The Notice of Availability seeks

comments on whether the FEC

should initiate a rulemaking in

response to the petition. The Commission routinely provides an

opportunity for comments on

rulemaking petitions before the

agency considers the merits of the

petition.

The petition and notice are

available from the Public Records

Office at 800/424-9530 (press 3) or

202/219-4140; through the FEC’s

Faxline at 202/501-3413 (document

233); and at the FEC’s web site—

http://www.fec.gov. The notice is

published in the December 10,

1997, Federal Register (62 FR

65040).

Public comments must be submitted in either written or electronic

form to Susan E. Propper, Assistant

General Counsel. Written comments

should be mailed to the Federal

Election Commission, 999 E St.,

NW, Washington, DC 20463. Faxed

comments should be transmitted at

202/219-3923, with a copy mailed

to the preceding address to ensure

legibility. Comments also may be

sent by e-mail to qncpetition@fec.gov.

Electronic submissions must include

the commenter’s full name, e-mail

address and postal mail address. The

deadline for comments is January

23. ✦

1 Minnesota Citizens Concerned for

Life v. FEC, 113 F. 3d at 130-131.
Federal Election Commission RECORD January 1998

6

Reports

Reports Due in 1998

This article on filing requirements for 1998 is supplemented by

the reporting tables that follow.

It is the responsibility of the

committee treasurer to file required

reports on time. To assist treasurers,

the Commission sends committees

FEC reporting forms and notices of

upcoming reporting deadlines.

For further information on

reporting or to order extra forms,

call the FEC: 800/424-9530 (press

1) or 202/219-3420. Additionally,

most forms are available at the

FEC’s web site (http://www.fec.gov)

and from the agency’s Faxline

system (dial 202/501-3413).

Year-End Reports Covering

1997 Activity

All committees must file a 1997

year-end report due January 31,

1998. The coverage and reporting

dates are found on page 7.

Reports Covering 1998 Activity

To find out which reports your

committee must file in 1998, check

the Guide to Reporting chart on page

11. Please note that committees

active in special elections in 1998

may have to file additional special

election reports, as explained below.

Committees Active in

Special Elections

Committees authorized by candidates running in any 1998 special

election must file election reports in

addition to regularly scheduled

reports. 11 CFR 104.5(h). They are

also required to comply with the 48-

hour notice requirement for contributions of $1,000 or more (including

loans) received shortly before an

election. See 11 CFR 104.5(f).

PACs and party committees

supporting candidates running in

special elections also may have to

file pre- and post-election reports

unless they file on a monthly basis.

11 CFR 104.5(c)(3) and 104.5(h).

However, all PACs are subject to

24-hour reporting of independent

expenditures made shortly before an

election. See 11 CFR 104.4(b) and

(c) and 104.5(g).

When timing permits, the Record

will alert committees to special

election reporting dates in 1998. In

this issue, see pages 12 and 13 for

filing dates for the special elections

in California and Pennsylvania.

Late Filing

The Federal Election Campaign

Act does not permit the Commission

to grant extensions of filing deadlines

under any circumstances. Filing late

reports could result in enforcement

action by the Commission.

Where to File

Committee treasurers must file

FEC reports with the appropriate

federal and state filing offices.

Please note that:

• The addresses for the federal

offices (FEC and Secretary of the

Senate) appear in the instructions

to the Summary Page of FEC

Forms 3 and 3X.

• A list of state filing offices is

available from the Commission.

House Candidate Committees.

Principal campaign committees of

House candidates file with the FEC.

11 CFR 105.1. The principal

campaign committee must simultaneously file a copy of each report

and statement with the Secretary of

State (or equivalent officer) of the

state in which the candidate seeks

(or sought) election. 2 U.S.C.

§439(a)(2)(B).

Senate Candidate Committees.

Principal campaign committees of

Senate candidates file with the

Secretary of the Senate, as appropriate. 11 CFR 105.2. The principal

campaign committee must simultaneously file a copy of each report

and statement with the Secretary of

State (or equivalent officer) of the

state in which the candidate seeks

Federal Register

 Federal Register notices are

available from the FEC’s Public

Records Office.

Notice 1997-16

Filing Dates for the California

Special Election (62 FR 63715,

December 2, 1997)

Notice 1997-17

Rulemaking Petition: Qualified

Nonprofit Corporations; Notice

of Availability (62 FR 65040,

December 10, 1997)

Notice 1997-18

Filing Dates for the Pennsylvania

Special Election (62 FR 65704,

December 15, 1997)

Notice 1997-19

Privacy Act; Republication and

Notice of New Routine Uses for

Disclosure (62 FR 65694,

December 15, 1997)

Notice 1997-20

Definition of “Member” of a

Membership Association; Notice

of Proposed Rulemaking (62 FR

66832, December 22, 1997)

Notice 1997-21

Recordkeeping and Reporting;

Notice of Public Hearing (62 FR

67300, December 24, 1997)
January 1998 Federal Election Commission RECORD

7

(or sought) election. 2 U.S.C.

§439(a)(2)(B).

Presidential Committees. Principal campaign committees of Presidential candidates file with the FEC.

11 CFR 105.3. The principal

campaign committee must simultaneously file a copy of each report

and statement with the Secretary of

State (or equivalent officer) of each

state in which the committee makes

expenditures. 11 CFR 108.2.

Candidate Committees with More

Than One Authorized Committee. If

a campaign includes more than one

authorized committee, the principal

campaign committee files, with its

own report, the reports prepared by

the other authorized committees as

well as a consolidated report (FEC

Form 3Z or page 5 of FEC Form 3P,

as appropriate). 11 CFR 104.3(f).

PACs and Party Committees.

Generally, PACs and party committees file with the FEC. 11 CFR

105.4. However, committees

supporting only Senate candidates,

and the national Democratic and

Republican senatorial committees

file with the Secretary of the Senate.

11 CFR 105.2.

PACs and party committees must

simultaneously file copies of reports

and statements with the Secretary of

State (or equivalent officer), as

follows:

• Committees making contributions

or expenditures in connection with

House and Senate campaigns also

file in the state in which the

candidate seeks (or sought)

election. The committee is required

to file only that portion of the report

applicable to the candidate in that

state (e.g., the Summary Page and

the schedule showing the contribution or expenditure). 2 U.S.C.

§439(a)(2)(B).

• Committees making contributions

or expenditures in connection with

Presidential candidates also file in

the states in which the Presidential

committee and the donor committee have their headquarters. 11

CFR 108.4. ✦

1997 Year-End Report

Note: All committees file this report.

Report Period Covered Filing Date 1

Year-End Closing date January 31, 1998

of last report

through

December 31, 1997

1998 Monthly Reports

Report Period Covered Filing Date 1

February January 1-31 February 20

March February 1-28 March 20

April March 1-31 April 20

May April 1-30 May 20

June May 1-31 June 20

July June 1-30 July 20

August July 1-31 August 20

September August 1-31 September 20

October September 1-30 October 20

Pre-General2 October 1-14 October 22

Post-General Oct. 15-Nov. 23 December 3

Year-End Nov. 24-Dec. 31 January 31, 1999

1998 Quarterly Reports

Report Close of Books Filing Date 1

1st Quarter March 31 April 15

2nd Quarter June 30 July 15

3rd Quarter September 30 October 15

Year-End December 31 January 31, 1999

Pre- and Post-Election Reports

for November 3 General Election

Report Close of Books Filing Date 1

Pre-General 2 October 14 October 22

Post-General November 23 December 3

1 Reports sent by registered or certified mail must be postmarked by the filing date

(except in the case of the pre-general election report; see footnote 2). Reports sent

by other means must be received by the filing date. 11 CFR 104.5(e).

2

 If sent by registered or certified mail, the pre-general must be postmarked by

October 19.

(continued on page 8)
Federal Election Commission RECORD January 1998

8

* States holding 1998 Senate elections.

1

 The mailing date is the same as the filing date because the computed mail date falls one day before the primary date.

2

 Federal holiday. For registered/certified mailing date, the report should be postmarked before that date. For filing date, the

report should be received by the FEC the day before (or, in the case of Labor Day and Memorial Day, the Friday before).

3

 Saturday or Sunday. Because filing dates are not extended when they fall on nonworking days, the report should be received by

the appropriate filing offices the Friday before.

4

 The July Quarterly report is waived for committees filing the Georgia pre-primary report. See 11 CFR 104.5(a)(1)(iii)(C) and

(c)(1)(i)(C).

Pre-Election Reporting Dates: 1998 Primary and Runoff Elections

S y tate or Territory E s lection Da Close of Book Registered/Certified

M e ailing Date

Filing Date

* 2 Alabama J 3 une M 8 ay 1 M 1 ay 1 May 2

* 5 Alaska A 5 ugust 2 A 0 ugust A 3 ugust 1 August 1

American Samoa

November 3

Runoff: November 17

October 14

October 28

October 19

November 51

October 22

November 5

* 8 Arizona S 9 eptember A 4 ugust 1 A 7 ugust 2 August 2

*Arkansas

May 19

Runoff: June 9

April 29

May 20

May 4

May 252

May 7

May 28

* 2 California J 3 une M 8 ay 1 M 1 ay 1 May 2

* 1 Colorado A 2 ugust 1 J 7 uly 2 J 0 uly 2 July 3

* 5 Connecticut S 6 eptember 1 A 1 ugust 2 A 3 ugust 3 September

D 2 elaware S 3 eptember 1 A 8 ugust 2 A 1 ugust 2 August 3

D 5 istrict of Columbia S 6 eptember 1 A 1 ugust 2 A 3 ugust 3 September

*Florida

September 1

Runoff: October 1

August 12

September 11

August 17

September 16

August 20

September 193

*Georgia

July 21

Runoff: August 11

July 1

July 22

July 6

July 27

July 94

July 30

G 5 uam S 6 eptember A 1 ugust 1 A 4 ugust 2 August 2

* 9 Hawaii S 0 eptember 1 A 4 ugust 3 S 7 eptember September 2

* 6 Idaho M 6 ay 2 M 1 ay M 4 ay 1 May 1

* 7 Illinois M 5 arch 1 F 2 ebruary 2 M 5 arch March

* 5 Indiana M 5 ay A 0 pril 1 A 3 pril 2 April 2

* 2 Iowa J 3 une M 8 ay 1 M 1 ay 1 May 2

* 4 Kansas A 5 ugust J 0 uly 1 J 3 uly 2 July 2

* 6 Kentucky M 6 ay 2 M 1 ay M 4 ay 1 May 1

Reports

(continued from page 7)
January 1998 Federal Election Commission RECORD

9

* States holding 1998 Senate elections.

1

 The mailing date is the same as the filing date because the computed mail date falls one day before the primary date.

2

 Federal holiday. For registered/certified mailing date, the report should be postmarked before that date. For filing date, the

report should be received by the FEC the day before (or, in the case of Labor Day and Memorial Day, the Friday before).

*Louisiana

October 3

Runoff: November 3

September 13

October 14

September 18

October 19

September 21

October 22

M 9 aine J 0 une M 5 ay 2 May 2 2 May 28

* 5 Maryland S 6 eptember 1 A 1 ugust 2 A 3 ugust 3 September

M 5 assachusetts S 6 eptember 1 A 1 ugust 2 A 3 ugust 3 September

M 4 ichigan A 5 ugust J 0 uly 1 J 3 uly 2 July 2

M 5 innesota S 6 eptember 1 A 1 ugust 2 A 3 ugust 3 September

Mississippi June 2

Runoff: June 23

May 13

June 3

May 18

June 8

May 21

June 11

* 4 Missouri A 5 ugust J 0 uly 1 J 3 uly 2 July 2

M 2 ontana J 3 une M 8 ay 1 M 1 ay 1 May 2

N 2 ebraska M 2 ay 1 A 7 pril 2 A 0 pril 2 April 3

* 1 Nevada S 2 eptember A 7 ugust 1 A 0 ugust 1 August 2

* 8 New Hampshire S 9 eptember A 4 ugust 1 A 7 ugust 2 August 2

N 2 ew Jersey J 3 une M 8 ay 1 M 1 ay 1 May 2

N 2 ew Mexico J 3 une M 8 ay 1 M 1 ay 1 May 2

* 5 New York S 6 eptember 1 A 1 ugust 2 A 3 ugust 3 September

*North Carolina

May 5

Runoff: June 2

April 15

May 13

April 20

May 18

April 23

May 21

* 9 North Dakota J 0 une M 5 ay 2 May 2 2 May 28

* 5 Ohio M 5 ay A 0 pril 1 A 3 pril 2 April 2

*Oklahoma

August 25

Runoff: September 15

August 5

August 26

August 10

August 31

August 13

September 3

* 9 Oregon M 9 ay 1 A 4 pril 2 M 7 ay May

* 9 Pennsylvania M 9 ay 1 A 4 pril 2 M 7 ay May

R 5 hode Island S 6 eptember 1 A 1 ugust 2 A 3 ugust 3 September

*South Carolina

June 9

Runoff: June 23

May 20

June 3

May 252

June 111

May 28

June 11

S y tate or Territory E s lection Da Close of Book Registered/Certified

M e ailing Date

Filing Date

(continued on page 10)
Federal Election Commission RECORD January 1998

10

* States holding 1998 Senate elections.

1

 The mailing date is the same as the filing date because the computed mail date falls one day before the primary date.

2

 Federal holiday. For registered/certified mailing date, the report should be postmarked before that date. For filing date, the

report should be received by the FEC the day before (or, in the case of Labor Day and Memorial Day, the Friday before).

3

 Saturday or Sunday. Because filing dates are not extended when they fall on nonworking days, the report should be received by

the appropriate filing offices the Friday before.

Reports

(continued from page 9)

S y tate or Territory E s lection Da Close of Book Registered/Certified

M e ailing Date

Filing Date

*South Dakota

June 2

Runoff: June 16

May 13

May 27

May 18

June 41

May 21

June 4

T 6 ennessee A 7 ugust J 2 uly 1 J 5 uly 2 July 2 3

Texas

March 10

Runoff: April 14

February 18

March 25

February 23

March 30

February 26

April 2

* 3 Utah J 3 une 2 J 8 une J 1 une June 1

* 8 Vermont S 9 eptember A 4 ugust 1 A 7 ugust 2 August 2

V 9 irginia J 0 une M 5 ay 2 May 2 2 May 28

V 8 irgin Islands S 9 eptember A 4 ugust 1 A 7 ugust 2 August 2

* 5 Washington S 6 eptember 1 A 1 ugust 2 A 3 ugust 3 September

W 2 est Virginia M 2 ay 1 A 7 pril 2 A 0 pril 2 April 3

* 8 Wisconsin S 9 eptember A 4 ugust 1 A 7 ugust 2 August 2

W 8 yoming A 9 ugust 1 J 3 uly 2 A 6 ugust August
January 1998 Federal Election Commission RECORD

11

Guide to 1998 Reporting: Required Reports

(All committees must also file a 1997 year-end report, which is due on January 31.)

T l ype of Filer S y emiannua Q y uarterl M y onthl Pre-Primar 1 P l re-General Post-Genera

House and Senate

Campaigns of 1998

Candidates

✓ ✓✓✓

Other House and

Senate Campaigns2

✓

Presidential

Campaigns3

✓ ✓

PACs and Party

Committees Filing

Monthly

✓ ✓✓

PACs and Party

Committees Filing

Quarterly4

✓ ✓✓✓

 Required only if candidate runs in election.

or

 Filed in lieu of November and

 December monthy reports.

 Required only if committee

 makes contributions or

 expenditures in connection

 with election during the

 reporting period.

 Required

 regardless of

 activity.

1

 Category also includes pre-convention and pre-runoff reports.

2

 Special election candidates must file additional reports pertaining to their special elections. See periodic Record announcements.

3

 Presidential committees that wish to change their filing frequency during 1998 should notify the Commission in writing.

4

 PACs and party committees that filed on a semiannual basis in 1997 file on a quarterly basis in 1998. To avoid the need to file

pre-primary and pre-runoff reports, these committees may change to monthly filing if they first notify the Commission in writing.

(continued on page 12)

Election Law Amended

Commissioner Terms

 The Federal Election Campaign Act (the Act) has been

amended to allow FEC Commissioners to serve only one

six-year term. The amendment at 2 U.S.C.

§437c(a)(2)(A) strikes the phrase “for terms of 6 years”

and adds in its place “for a single term of six years.” The

amendment is applicable to individuals nominated by the

President after December 31, 1997, unless the President

announced his intent to nominate an individual prior to

November 30, 1997.

Point of Entry for Senatorial Campaign Committees

 The second change to the Act concerns filing

requirements. The Democratic Senatorial Campaign

Committee and the National Republican Senatorial

Committee may now file campaign financial disclosure

forms with the Secretary of the Senate, rather than with

the FEC. The amendment at 2 U.S.C. §432(g)(1) strikes

the “and” after “Senator,” and inserts “and by the

Republican and Democratic Senatorial Campaign

Committees” after “candidate.”

 An updated compilation of the Act will be available

later this year.
Federal Election Commission RECORD January 1998

12

1

 These committees include authorized committees of candidates running in the election and other political committees that

support these candidates and do not file monthly.

2

 This date has been adjusted because the computed date falls on a federal holiday.

3

 Committees should file a consolidated Post-Runoff and April Quarterly Report by the filing date of the Post-Runoff Report.

California Special General Election Reporting

Committees1 involved in the January 13 Special Election and/or the March 10 Special Runnoff Election to fill the

22nd Congressional District seat vacated by Congressman Walter Capps, who died in October 1997, must follow the

reporting schedules below. Note that 48-hour notices are required of authorized committees that receive contributions

(including loans) of $1,000 or more between December 25, 1997, and January 10, 1998, for the Special General

Election, and between February 19 and March 7 if a Runoff Election is required.

If Only the Special General Election Is Held:

C d lose of Books Certified/Registere

M e ail Date

Filing Date

Pre-General D 7 ec. 24, 1997 D 2 ec. 29, 199 Jan. 2

Year- End D 1 ec. 31, 1997 J 1 an. 3 Jan. 3

Post-General F 2 eb. 2 F 2 eb. 1 Feb. 1

Committees Involved in the Special General and Special Runoff Elections:

C d lose of Books Certified/Registere

M e ail Date

Filing Date

Pre-General D 7 ec. 24, 1997 D 2 ec. 29, 199 Jan. 2

Year-End D 1 ec. 31, 1997 J 1 an. 3 Jan. 3

Pre-Runoff F 3 eb. 18 F 6 eb. 2 Feb. 2

Post-Runoff and April

Q y uarterly3 M 9 arch 31 A 9 pril April

Committees Involved in Only the Special General Election When Both It and the Runoff Election Are Held:

C d lose of Books Certified/Registere

M e ail Date

Filing Date

Pre-General D 7 ec. 24, 1997 D 2 ec. 29, 199 Jan. 2

Year-End D 1 ec. 31, 1997 J 1 an. 3 Jan. 3

Reports

(continued from page 11)
January 1998 Federal Election Commission RECORD

13

Pennsylvania Special General Election Reporting

Committees1 involved in the May 19 Special Election to fill the 1st Congressional District seat vacated by Congressman Tom Foglietta, who was named U.S. Ambassador to Italy, must follow the reporting schedule below. Note

that 48-hour notices are required of authorized committees that receive contributions (including loans) of $1,000 or

more between April 30 and May 16.

C d lose of Books Certified/Registere

M e ail Date

Filing Date

Year-End D 1 ec. 31, 1997 J 1 an. 3 Jan. 3

April Quarterly M 5 arch 31 A 5 pril 1 April 1

Pre-General A 4 pril 29 M 7 ay May

Post-General J 8 une 8 J 8 une 1 June 1

1

 These committees include authorized committees of candidates running in the election and other political committees that

support these candidates and do not file monthly.

Public Funding

Forecast Shows Shortfall in

Public Funding for 2000

Election Cycle

An FEC staff analysis of funding

available for the presidential election of 2000 projects a shortfall in

the Presidential Election Campaign

Fund.

The projections suggest that there

will be insufficient funding to

provide timely matching payments

to primary candidates in the 2000

election. These projections are

based on several assumptions: (1) a

2.5 percent rate of inflation, (2) fund

receipts of $67 million a year, based

on the $3 checkoff on tax forms and

(3) participation of the Reform

Party, in addition to the two major

parties, in all phases of the public

funding program. The Reform Party

is likely to request, and qualify for,

status as a minor national party,

based on the popular vote it received

in the 1996 elections. See 2 U.S.C.

§9002(7).

A number of circumstances factor

into this forecast.

• At the end of 1996, just $3.5

million remained in the Presidential Election Campaign Fund, and

calculations for the fund balance in

2000 will include receipts only for

1997, 1998 and 1999—not 2000—

at a rate of $67 million a year.

• If, as anticipated, conventions are

held in 2000 by two major parties

and one minor party, the organizers of those events would be

entitled to approximately $30

million, the bulk of which would

be paid out in 1999.

• If the two previous projections

hold up, the December 31, 1999,

balance in the fund would be

approximately $174.5 million.

Receipts from the 2000 taxpayer

checkoff are not counted in this

total, but will come into play

during the year 2000 and can be

paid out to candidates as the funds

accumulate.

• With a set aside of $149 million

for the candidates of two major

parties and one minor party in the

general election, the Presidential

fund would be left with only $25.5

million for payments to primary

candidates on January 1, 2000.

U.S. Treasury Department regulations require that the Treasury set

aside funding for the general

election and nominating conventions prior to making any matching

payments to Presidential primary

candidates.

• Because there will be no incumbent in the 2000 race, Commission

staff anticipate vigorous primary

contests with far more qualifying

candidates than the 11 who were

funded in the 1996 primaries.

Based on the above analysis,

those candidates who qualify for

matching payments would receive

small, pro-rated payments, which

might have to be stretched out for

the entire year. Bridge loans might

not be as easily obtained as they

were in 1996 when the shortfall in

the fund was short term. Moreover,

servicing of such loans over a longer

period of time would require more

campaign spending for interest on

the loans. ✦

(continued on page 14)
Federal Election Commission RECORD January 1998

14

Public Funding

(continued from page 13)

Fulani Repayment

Determination Stayed

On December 5, 1997, the

Commission granted a request for a

stay of its final repayment determination to Lenora B. Fulani and her

1992 campaign committee, Lenora

B. Fulani for President, pending the

outcome of their appeal of the

determination to the U.S. Court of

Appeals for the District of Columbia

Circuit.

The Commission had determined

that the Fulani committee had to

repay $117,269.54 to the United

States Treasury. The committee

repaid $1,394, but disputed the

remaining $115,875.54. That

dispute is now the subject of the

appeal (see page 2 of the October

1997 Record). ✦

Advisory

Opinions

AO 1997-18

Status as Local Party

Committee of National Party

The California Reform Party

Congressional Committee (Congressional Committee) at this time does

not qualify as a local party committee.

The Federal Election Campaign

Act (the Act) defines a state committee as “the organization which,

by virtue of the bylaws of a political

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

at the State level, as determined by

the Commission.” 2 U.S.C.

§431(15).

While the Act and Commission

regulations do not explicitly define a

local committee of a political party,

it can be viewed as the same as a

“subordinate committee.” A subordinate committee is “any organization which is responsible for the

day-to-day operation of the political

party at the level of city, county,

neighborhood, ward, district,

precinct, or any other subdivision of

a State or any organization under the

control or direction of the State

committee.” 11 CFR 100.14(b).

In its request, the Congressional

Committee states that it is independent of any state committee and has

no relationship with the National

Reform Party. Further, it intends to

continue in this mode. The Congressional Committee, at this time, also

contends that it does not wish to

seek state committee status as there

already is a statewide political

party—the Reform Party of California—which may itself wish to seek

state committee status at a later date.

A prerequisite for committee

status is the existence of a political

party. See AOs 1997-7, 1997-3,

1996-51, 1996-43 and 1996-35. The

Reform Party movement in California qualifies as a “political party”

for purposes of the Act and Commission regulations, and the Congressional Committee is an

“instrumentality” of that organization, based on the following information. Two of the seven Reform

Party candidates supported by the

Congressional Committee in 1996

had sufficient financial activity to

qualify as candidates under the Act.

Nonetheless, the Congressional

Committee does not meet either of

the two requirements of “subordinate committee” found in the

regulation: (1) responsibility for the

day-to-day operations of the party

on the local level or (2) being under

the control or direction of a state

committee.

In its request, the Congressional

Committee states that its purposes

include electing state Reform Party

candidates to the U.S. House of

Representatives, raising funds and

providing support for those candidates and developing coordinated

campaigns in all 52 of California’s

congressional districts. Thus, the

Congressional Committee’s activities are not local, or confined to one

specific geographic region or

subdivision. The activities it describes are more consistent with

statewide activity.

Under section 100.14(b), some

subordinate committees may operate

beyond a local geographic or

jurisdictional area, but these committees must be under the direction

or control of a state committee. As

stated before, the Congressional

Committee currently is not affiliated

with the Reform Party of California.

Moreover, the Commission has not

yet recognized any committee as the

California state committee of the

Reform Party. Thus, the Congressional Committee’s activities are not

being directed by any state committee of the Reform Party.

Because the Congressional

Committee does not qualify as a

local party committee, it may not

participate in making the coordinated party expenditures described

at 2 U.S.C. §441a(d). It also may

not take advantage of the exemptions from the definition of contribution and expenditure for certain

kinds of activities. 2 U.S.C.

§431(8)(B) and (9)(B).

The advisory opinion does note

that if the Reform Party of California gained state committee status

and the Congressional Committee

affiliated with it, the Congressional

Committee would become a local

party committee.

Date Issued: December 4, 1997;

Length: 4 pages. ✦

AO 1997-22

Communicating

Endorsements to Members

and Their Restricted Classes

The Business Council of Alabama (BCA) may communicate its

endorsements of federal candidates,

and encourage contributions to those

candidates, by means of communications directed to representatives of

member organizations with whom
January 1998 Federal Election Commission RECORD

15

BCA normally communicates.

Additionally, BCA may request that

these communications be passed

along to the restricted classes of

those membership organizations.

However, it may not provide the

actual materials for redistribution.

BCA is an incorporated membership organization consisting of

individuals, firms, partnerships,

organizations and corporations. The

group, with approximately 5,200

members, plans to evaluate federal

candidates and their positions on

matters that concern its membership. BCA would then prepare a list

of candidates it wishes to support

and oppose and would urge its

membership to follow its advocacy.

In addition, BCA would ask its

noncorporate members and the

separate segregated funds (SSFs) of

its corporate members, by way of

the organization’s usual contact

person, to make contributions to

those supported candidates. And

finally, BCA would ask its corporate

members to forward its endorsements to their restricted classes.

While containing a broad prohibition on corporate contributions and

expenditures in connection with

federal elections, the Federal

Election Campaign Act includes an

exception that allows a corporation

to direct election advocacy communications to its restricted class. 2

U.S.C. 441b(b)(2)(A). For purposes

of these communications, the

restricted class of an incorporated

membership organization, such as

BCA is its membership (as well as

its executive and administrative

personnel and the families of both

groups).

Commission regulations at 11

CFR 114.3 allow a corporation to

solicit or suggest that its individual

members make contributions to

candidates, but does not allow the

corporation to facilitate the making

of contributions or to act as a

conduit. A corporation may provide

the address of a candidate or political committee to its membership. It

may also solicit its restricted class

for contributions to be sent directly

to a candidate. 11 CFR

114.2(f)(4)(ii). See also AOs 1996-1

and 1987-29.

In AO 1996-21, the Commission

approved BCA’s candidate endorsement and contribution solicitation

plan. The advisory opinion concluded that corporate members

could receive BCA’s endorsements

through the individuals who normally represented them with BCA.

In AO 1995-27, the Commission

concluded that noncorporate members of a trade association also could

receive solicitations for candidates

through their organizations’ one or

two usual contact persons.

And, in AO 1991-24, the Commission found that an organization—in this instance, a federation

of trade associations—could have its

membership (trade associations)

communicate candidate endorsements to their own memberships

(corporations) through their usual

contact people. The Commission

cautioned, however, that the trade

association could “not subsidize the

subsequent communications made

[by its members]” to their own

members.

Thus, while BCA’s endorsement

communications plan is permissible,

it may not provide materials—for

example, bulk copies of candidaterelated materials—for redistribution

by its membership to their restricted

classes.1

 This would constitute an

unlawful distribution of election

advocacy communications to the

restricted classes of its corporate

members and the personnel of

noncorporate members. Distribution

of such endorsements must be left to

the membership organizations.

Date issued: November, 13,

1997; Length: 6 pages. ✦

Advisory Opinion Requests

Advisory opinion requests are

available for review and comment in

the Public Records Office.

AOR 1997-25

Affiliation of corporate SSFs after

spin-off and merger (Hughes

Electronics, November 20, 1997; 6

pages plus 65-page attachment)

AOR 1997-26

Nonconnected committee status of

PAC formed by members of a

nonprofit trade association acting in

their individual capacities (Association of Metropolitan Sewerage

Agencies, December 1, 1997; 3

pages plus 7-page attachment) ✦

FEC 1998 Conference

Schedule

 The FEC will hold three

conferences in 1998. To register

for any of the scheduled

conferences, call Sylvester

Management at 1/800-246-7277

or send an e-mail message to:

TSYLVESTER@WORLDNET.ATT.NET.

Washington, DC

For candidate committees

Date: February 23, 1998

Location: Madison Hotel

Registration: $175

Hotel rate: $124

Denver

For candidates, political parties

and corporate and labor

organizations

Date: March 25-27, 1998

Location: Westin Tabor Center

Registration: $180

Hotel rate: $136

 Read future issues of the Record

to get scheduling information for

the third conference slated for

1998:

Washington, DC

For nonconnected committees

April 1998 1

 However, BCA may provide such

materials to its members at a charge.
FEDERAL ELECTION COMMISSION

999 E Street, NW

Washington, DC 20463

Official Business

Penalty for Private Use, $300

Bulk Rate Mail

Postage and Fees Paid

Federal Election Commission

Permit Number G-31

Printed on recycled paper

Federal Election Commission RECORD January 1998

Publications

Index

The first number in each citation

refers to the “number” (month) of

the 1998 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

1997-18: Status of committee as

local party committee, 1:14

1997-22: Communicating membership corporation’s endorsements

of federal candidates to members

and their restricted classes, 1:14

Court Cases

FEC v. _____

– National Medical Political Action

Committee, 1:3

– Williams, 1:3

_____ v. FEC

National Committee of the Reform

Party, 1:2

Reports

Pre-Election Reporting Dates: 1998

Primary and Runoff Elections, 1:8

Reports Due in 1998, 1:6, 1:11

Special Election, California, 1:12

Special Election, Pennsylvania, 1:13

Updated Corporate/Labor

Campaign Guide Available

The Commission has recently

published a new edition of the

Campaign Guide For Corporations

and Labor Organizations. The 80-

page guide explains the rules and

procedures corporations and labor

organizations must follow in

conducting federal campaign-related

activities. This latest edition includes an expanded index and new

sections discussing corporate and

labor communications, the use of

corporate and labor facilities,

revised “best efforts” regulations

and new rules on disclaimer notices.

Every treasurer of a political

committee registered with the FEC

should have already received a copy

of the updated guide in the mail.

However, additional copies are

available for free.

The complete guide is available

for downloading at the FEC’s web

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

Adobe® Acrobat Reader software,

you will be able to view and print

the publication, including its charts

and sample forms and schedules.

The FEC’s web site includes a link

to Adobe’s web site, where you can

download the latest version of its

reader software for free.

Political committee staff and

others interested in the election law

can obtain their own free copies of

the guide by calling the FEC at 800/

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

3420. ✦