July 1994

Table of Con ents

Commission

FEC Automates 800 Line

Publications

1 Six New Publications Available

7 Order Form for New Publications

Special Elections

2 Senate Election in Oklahoma

to Fill Boren Seat

Court Cases

2 NRSC v. FEC

3 New Litigation

Advisory Opinions

4 Sum maries of Advisory Opinions

6 Corrections to Advisory Opi nion

Summarie s

6 Advisory Opin ion Requests

Statistics

7 Congress ional Activity 15 Month s

into Cycle

8 Index

Federal Election Commission

Commission

FEe Automates 800 Line

Peop le call ing the FEe's 800

number (800/424-9530) can now

reach the office they need by

I pressing a button . A recorded

announcement offers callers fi ve

choices. Callers with rotary phones

should stay on the line; a rece ptionist will direct the ir ca lls. The new

serv ice began June 10. It operates

from 8:30 A.M . to 5:30 P.M . (ET),

Mond ay through Friday .

If you' re using a phone with a

tone pad, you can interrupt the

message at any time to press the

number of the office you need.

o Press 1 (Infor mation Division) to

order form s or publi cations.

o Pre ss 2 (Repo rts Analysis Division) if you are calling to respond

to a Comm ission letter co ncern ing

your committee's repo rt or if you

wish to speak to the person who

reviews your repo rts.

o Press 3 (Public Disclosure Divisio n) to obtain cam paign finance

information on candidates and

committees.

o Press 4 (Na tional Clear inghouse on

Election Adm inistratio n) for

informa tion on the elec tion process, includi ng voter registration

and voting statistics.

o Press 5, or stay on the line, for all

othe r inquiries. •

Volume 20, Numb er 7

Publications

Six New Publications

Available

You can order any of the new

publications listed below using the

orde r form on page 7. All the

documents are free .

Committee treasurers will

automatica lly receive one or more

of these publications, depend ing on

the type of committee they are wit h.

Treasurers are welcom e to order

extra copies for staff membe rs.

o Updated Campaign Guide for

Corporations and Labor Organizations. The new edition (March

1994) covers new regulations

ado pted since the last editi on

(multica ndidate committee status,

definit ion of member, best efforts).

In addition, several areas have

been reorga nized to bette r co nvey

the material (foreig n-ow ned

domestic co rpora tions, alloca tion,

debt settlement). Th e new Gu ide

will soo n be sent to treasurers of

separate seg regated funds.

• Record Supplement for Political

Party Committees. Published as a

com panion to the Campaign Guide

fo r Party Committees, the Party

Supp lement summarizes regulatory

changes made since the current

edition of the Guide was pub lished

(continued on page 2)
Federal ElectionCommission RECORD

I

Special .

Elections

Senate Election in Oklahoma

to Fill Boren Seat

Oklahoma will hold special

elections to fill the seat of Senator

David L. Boren, whose retirement

will become effective November 15,

1994. The special election dates are

the same as the dates for the

regularly scheduled elections in

Oklahoma: August 23 primary,

September 20 runoff and November

8 general.

Campaigns and committees

which expect to be active in the

Oklahoma special elections should

order the FEe handout on 1994

reporting. (Call 800/424-9530 or

202/219-3420.) The handout

explains reporting obligations and

lists the Oklahoma primary and

runoff reporting dates and the

general election reporting dates.•

Federal Election Commission

999 E Street, NW

Washington, DC 20463

800/424-9530

202/219-3420

202/219-3336 (TOO)

Trevor Potter, Chairman

Danny L. McDonald,

ViceChairman

Joan D. Aikens, Commissioner

Lee Ann Elliott, Commissioner

John Warren McGarry,

Commissioner

Scott E. Thomas, Commissioner

John C. Surina, Staff Director

Lawrence M. Noble,General

Counsel

Published by the Information

Division

Louise D. Wides, Director

Stephanie Fitzgerald, Editor

2

Publications

(continued from page 1)

in September 1989. The Supplement was sent to all party committee treasurers.

- Record Supplement for Nonconneeted Committees. Also a

companion piece, this Supplement

updates the Campaign Guide for

Nonconnected Committees by

explaining the regulatory changes

made since the June 1985 publication of the Guide . It was sent to

treasurers of nonconnected committees.

-1994 Edition of FEC Regulations

(11 CFR). The new edition

contains all regulations effective as

of January 1994 as well as the

revised "best efforts" rules (11 CFR

104.7(b», which became effective

on March 3, 1994. (The outdated

best efforts rules are also included,

since the new ones were not yet

effective when the document went

to press.) The Commission has

sent the 1994 11 CFR to all

committee treasurers.

- Annual Report 1993.The report

documents the rapidly increasing

demands on Commission resources. It also explains major

legal developments during 1993,

including passage of the Motor

Voter law and the court ruling on

the constitutionality of the FEC's

composition. The report includes

the 1994 legislative recommendations and features graphs and

tables on campaign finance and

FEC operations.

- Using FEC Campaign Finance

Information. This revised,

expanded brochure explains how

to use the FEe's services to obtain

information on money raised and

spent by federal campaigns, PACs

and political party committees. •

lilly 1994

,

Court Cases

NRSC v, FEC

A federal district court recently

dismissed this suit in which the

National Republican Senatorial

Committee (NRSC) had asked the

court to stop the FEC from proceeding in an internal enforcement

matter opened in 1991, MUR 3204.

The NRSC claimed that the FEe's

vote to find "reason to believe" that

the committee had violated the law

and the ensuing investigation were

invalid because they took place

when the composition of the FEC

was unconstitutional. On May 11,

the U.S. District Court for the

District of Columbia ruled that the

case was not ripe for adjudication

since the FEC had not yet taken

'''concrete' action" in MUR 3204.

But the court was doubtful whether

NRSC would have succeeded on the

merits even if its case had been ripe

for review. No. 94-332 (TPJ).

NRSC had relied on the October

1993 appellate court ruling in FEC

v. NRA Political Victory Fund

(NRA). In that case, the District of

Columbia Circuit ruled that the FEC

lacked authority to bring action

against the NRA because the

composition of the agency was

unconstitutional.'

The court said that NRSC's

reliance on NRA was "misplaced"

because, in that case, the court of

appeals was confronted with an

otherwise final district court judgment obtained by an unlawfully

/6 F.3d 821 (D.C. Cir. 1993). The court

found that the presence ofthe Clerk of

the House and the Secr etary ofthe

Senate as nonvoting, ex officio Commission members violat ed the Constitution 's separation ofpowers doctrine.

After the October 1993 NRA ruling was

handed down, the FEC immediately

I reconstituted itself by excluding the ex

officio members. The Supreme Court

has agreed to review the ruling.
July 1994

constituted Commission against a

respondent. By contrast, the court

pointed out, in this case, NRSC had

filed suit before the FEC had taken

final action. The agency had not

even voted on whether to find

"probable cause to believe" that

NRSC had violated the law, the next

step in the enforcement process. The

court said that the impending vote

"will either confirm and ratify what

was thought sufficient to warrant an

investigation" in 1991, or the FEC

will terminate the matter.

Concluding that the NRSC had

filed its case prematurely, the court

observed that, even had the case

been ripe for judicial review, NRSC

would have failed to satisfy the

standards for a preliminary injunction to stop the FEC from proceeding in the MUR.

NRSC has filed an appeal. •

New Litigation

RNC v. FEC (94-1017)

The Republican National Committee (RNC), the National Republican Senatorial Committee and the

National Republican Congressional

Committee challenge the revised

"best efforts" regulations, claiming

they are contrary to law. In filing

suit, the committees asked the court

for a temporary restraining order

and preliminary injunction to

prevent enforcement of the regulations but later withdrew the request.I

I The Republican committees first asked

the FEC to stay the effective date ofthe

revised rules, pending court review. On

May 5, 1994, the FEC declinedfor two

reasons. First, a stay would mean there

would be no valid best efforts rules in

effect, contrary to the Congressional

goal offull disclosure. Second, in the

agency's view, the request did not

satisfy the requirements for a stay. See

FEC Agenda Documents 94-45 and 94-

45-A, available in the Public Records

Office.

The best efforts rules, which

became effective March 3, 1994,

explain what steps a committee

must take in order to demonstrate

that it has made "best efforts" to

obtain and report information on

individual contributors. Under the

revised rules, a committee can

demonstrate best efforts by:

(1) requesting the information in a

specifically worded statement 2

displayed on the contributor response card; (2) making a follow-up

request for missing information; and

(3) reporting previously missing

information in amendments to

reports. 11 CFR 104.7(b).

The Republican committees

claim that the revised best efforts

rules are arbitrary, capricious and

contrary to law because:

• The required statement on contributor response cards falsely

implies that contributors must

provide the information to committees;

• During the rulemaking process, the

FEC failed to respond to comments

expressing this and other concerns;

• The required follow-up request for

missing contributor information

contradicts a House committee

report interpreting section 432(i) to

require only one clear request for

the information; and

I • The follow-up request unjustifiably burdens First Amendment

rights because, under the new

rules, it cannot include other

materials or solicitations.

The committees contend that the

rules will be expensive to implement and will impair their relationship with supporters.

U.S. District Court for the

District of Columbia, May 9, 1994,

Civil. Action No. 94-1017 (JHG).

2 The statement reads: Federal law

requires political committees to report

the name, mailing address, occupation

and name of employer for each individual whose contributions aggregate

over$200 in a calendar year.

Federal Election Commission RECORD

FEC v. LaRouche (94-658-A)

The FEC asks the court to find

that Lyndon H. LaRouche, Jr., and

his 1988 Presidential primary

campaign violated the public

funding law by failing to repay

$146,464 in federal matching funds.

The agency asks the court to order

Mr. LaRouche and his campaign to

repay that amount-plus interest

accruing from October 22, 1992-to

the U.S. Treasury.

The Commission claims that, in a

letter of September 22, 1992, it

notified defendants that the repayment was due within 30 days. On

October 22, instead of repaying the

funds, Mr. LaRouche and his

campaign filed suit against the FEC

to challenge the repayment amount.'

They did not ask the FEC to stay the

repayment until the court decided

the case; nor did they deposit the

repayment amount in an interestbearing account. See 11 CFR

9038.5(c).

Mr. LaRouche received $833,577

in 1988 primary matching funds.

The Commission determined that he

had to repay $151,260 in funds

received in excess of his entitlement

and funds spent on nonqualified

campaign expenses. The campaign

repaid part of that amount in February 1992, leaving $146,464 still

outstanding.

U.S. District Court for the

Eastern District of Virginia, Alexandria Division, May 23, 1994, Civil

Action No. 94-658-A.•

I LaRouche v. FEe, No. 92-1555. The

Court ofAppeals for the District of

Columbia Circuit has not yet decided

the case. The LaRouche campaign has

asked the district court to dismiss the

FEC's suit or, alternatively, to abstain,

until the appellate court rules on the

repayment issue.

3
Federal Election Commission RECORD

Advisory

Opinions

AO 1994-6

Charitable Matching Plan

forTwice-Yearly Solicitations

To encourage participation in the

corporate PAC by all employees,

including those who may be solicited only twice a year, Coors

Brewing Company may use corporate funds to match 25 cents of

every dollar contributed to its PAC

with donations to charity. The PAC

will either designate a single charity

to receive all matching donations or

provide a list of four charities from

which a contributor may choose. As

long as the twice-yearly solicitations

comply with the procedures set forth

in 11 CFR 114.6 , the plan is pennissible. I

The Commission has consistently

viewed a corporation's charitable

matching donations as a permissible

solicitation expense rather than as a

prohibited exchange of corporate

funds for PAC contributions.'

2 U.S.c. §441b(b)(2)(C); II CFR

114.5(b). (See, for example, AO

1990-6.) In AO 1994-3, the agency

'In AO 1994-3, the Commission

cautioned that any review ofthe

charities chosen by contributors must

preserve the anonymity ofnonadministraiive and nonexecutive employees

contributing small amounts ($50 or

less, or $200 aggregate per calendar

year). Furthermore, letters sent to

charities should not give the actual

name ofthose employees. Letters of

appreciation from charities could be

conveyed to those employees through

the custodian.

2 The IRS has concluded thai charitable

matching plan donalions do not result

in compensation 10 the employees and

are not tax deductible by the corporation. Judith E. Kindell and John F.

Reilly, Election Year Issues, IRS

publication, 441 (1992); see also Rev.

Rut. 67-137, 1967-1 C.B. 63 .

4

specifically approved a charitable

matching plan for contributions

collected in twice-yearly solicitations of nonadministrative and

nonexecutive employees.

Date Issued: May 12, 1994;

Length: 5 pages, including l-page

dissent filed by Vice Chairman

Danny L. McDonald and Commissioner Scott E. Thomas...

AO 1994-7

Charitable Matching Plan for

Twice-Yearly Solicitations;

Treasurer as Custodian

In conjunction with a twice-yearly

solicitation of nonadministrative and

nonexecutive employees, the Geon

Company may adopt a charitable

matching plan for contributions to

its PAC. Under the plan , employees

contributing at least $50 by the end

of a year may select a charity to

receive a matching donation by

Geon. Recent advisory opinions

have approved the use of similar

matching plans for solicitations of

employees outside the restricted

class as long as the corporation

complies with the requirements for

twice-yearly solicitations at 11 CFR

114.6. AO 1994-3; see also AO

1990-6.

One of those requirements is the

use of a custodian to preserve the

anonymity of expanded-class

employees who contribute small

amounts ($50 or less, or total annual

contributions of $200 or less) . The

custodian may not be a stockholder

or an officer or employee of the

corporation or PAC. As an exception, the PAC treasurer may serve as

custodian, but only if he or she does

not hold another position with the

corporation, does not hold stock in

the corporation and does not participate in deciding how PAC funds are

spent. II CFR 114.6(d)(l) and (5).

Consequently, the assistant treasurer

of Geon's PAC may not serve as

custodian because he holds another

position (senior corporate counsel);

July 1994

furthermore, he may have acquired

stock in Geon. Similarly, the

assistant secretary of the PAC may

not help process contributions from

expanded-class employees because

she is a Geon Clerical employee.

Date Issued : May 12, 1994;

Length: 5 pages, including l-page

dissent filed by Vice Chairman

Danny L. McDonald and Commissioner Scott E. Thomas...

AO 1994-8

Campaign's Rental of Office

Space from CandidateOwned Corporation

The Friends of Mike Parker for

Congress may sublease office space

and equipment from a corporation

owned by Congressman Parker and

his wife as long as the campaign

pays neither more nor less than the

usual and normal charge. Paying

less than the usual charge would

result in a prohibited in-kind

contribution from the corporation,

while paying more would result in a

prohibited conversion of campaign

funds to the candidate's personal

use, since the excess earnings would

accrue to his corporation. 2 U.s.c.

§§44Ib(b)(2) and 439a; 11 CFR

100.7(a)( I)(iii).

Congressman Parker (4th CDI

Mississippi) and his wife jointly

own a backyard garage with secondfloor office space and plan to lease

the upper level to a corporation they

own . The corporation, in turn,

would lease 75 percent of the space

to the campaign committee; the

remaining 25 percent would be used

by the corporation and Mrs. Parker's

law practice. Utilities would be

allocated on the same percentage

basis. The campaign also proposed

leasing office equipment from the

corporation.

In addition to the usual charge

requirement, the leasing arrangements for the space and equipment

must conform to the normal business practice in the area . The
July 1994

campaign should pay normal

penalties if it breaks the lease. Date

Issued: May 12, 1994; Length:

4 pages."

AO 1994-9

Transfers from Nonfederal

PACs; Effect of Corporate

Reorganization on Affiliation

Because a joint venture partnership, Armco Steel Company, L.P.

(ArmLP) is affiliated with its

corporate parents, Armco, Inc., and

Kawasaki Steel Corporation

(through domestic subsidiaries), the

federal PAC of ArmLP may function as a separate segregated fund

and accept transfers from affiliated

nonfederal PACs acting as collecting agents.

ArmLP will be reorganized into a

holding corporation and a subsidiary

(AK Holding and AK Steel), and,

although neither Armco nor Kawasaki will hold a controlling stock

interest, both former parents will

nevertheless be affiliated with the

new corporations based on the

historical relationships among the

companies and the presence of highranking Armco and Kawasaki

officials on the new boards.

Partnership PAC as SSF;

Transfers from Nonfederal PACs

Acting as Collecting Agents

Committees, including separate

segregated funds (SSFs), are

affiliated-and thus share the same

contribution limits-when they are

established, financed, maintained or

controlled by the same person. FEC

regulations list various factors that

indicate whether one organization is

affiliated with another and, hence,

whether their SSFs are affiliated.

11 CFR 110.3(a)(3)(i) and (ii).

Armco and Kawasaki are both

affiliated with ArmLP because of

their equal ownership of the partnership and the general partner, which

allows them to share equally in the

governance of ArmLP. As a further

indication of affiliation, Armco and

Kawasaki officials each hold three

positions on ArmLP's sevenmember board of directors, with the

seventh member chosen by both

companies. See 11 CFR 11O.3(a)(3)

(ii)(A), (B), (C) and (E).

Because ArmLP is entirely owned

by corporations and is affiliated

with them, it may function as an

SSF.l AO 1992-17. Armco's

nonfederal PAC and ArmLP's own

nonfederal PAC may, in that case,

act as collecting agents when

transferring funds to Arml.P's

federal PAC (ArmLP Federal). That

way, the nonfederal PACs will

avoid federal registration and

reporting. See 11 CFR 102.6(b) and

(c). The transferred funds, however,

must represent contributions from

lawful donors who have provided

written intent to make a contribution

to ArmLP Federal. That PAC, in

tum, must report the receipt of the

funds as contributions from the

original donors. AO 1984-31.

Furthermore, the nonfederal PACs

must assume that their cash on hand

is composed of funds most recently

received in order to determine

which contributions are included in

the transfer and to eliminate prohibited or excessive contributions.'

II CFR 104.12. See AO 1990-16.

Affiliation After Reorganization

ArmLP will be reorganized into

AK Steel Corporation (AK Steel), a

wholly owned subsidiary of AK

Steel Holding Corporation (AK

Holding). Immediately after the

I If it does function as an SSF, however,

ArmLP Federal will have to amend its

Statement of Organization to identify

Armco and a domestic subsidiary of

Kawasaki as connected organizations,

since the term does not include a

partnership. 11 CFR lOO.6(a); see also

AO 1992-17.

2 Contributions from employees who are

not executive or administrative personnel or who are employed in a company

not affiliated with ArmLP may not be

transferred to ArmLP Federal.

Federal Election Commission RECORD

reorganization, AK Holding will

recapitalize itself through an initial

public offering of common stock.

As a result, Armco will hold 4

percent of the stock, and Kawasaki,

20 percent. Although neither Armco

nor Kawasaki will thus own a

controlling interest, the two former

parent corporations will remain

affiliated with the partnership's

successor companies because of the

following factors:

• The President and CEO of Armco

and a Managing Director of

Kawasaki 3 will sit on the boards of

both AK Holding and AK Steel

and, along with one other person,

will initially choose the remaining

members of both boards;

• Three former Armco employees

will be executive officers of AK

Holding and AK Steel; and

• Armco and Kawasaki were instrumental in forming ArmLP, the

predecessor organization. 11 CFR

11O.3(a)(3)(ii)(B), (C), (E), (F)

and (I).

Given this background, the

disaffiliation of AK Steel and AK

Holding from Armco and Kawasaki

would be premature at this time but

could be possible at a later point in

the operations of AK steel and AK

Holding. See AO 1993-23.

After the reorganization, ArmLP

Federal will become the PAC of AK

Steel and will therefore have to

change its name to include the name

of its connected organization.

11 CFR 102.14(c).DateIssued:June

6, 1994; Length: 9 pages...

(AOs continued on page 6)

3As long as Kawasaki owns 15 percent

of common stock, its position on the

board is, in effect, an obligation ofAK

Holding.

5
Federal Election Commission RECORD

vi ry pinion

(continued from page 5)

AO 1994-11

SSF Activities of Federal

Contractor Partnership

United Defense L.P., a federal

government contractor, is a limited

partnership affiliated with FMC

Corporation, a general partner and

60-percent owner, but not with the

other corporate owner, a subsidiary

of Harsco Corporation. (FMC and

Harsco organized United as a joint

venture to carry out their defense

contracting work.) Although the law

does not extend to partnerships the

exemption for paying the establishment , administrative and solicitation

costs of a separate segregated fund

(SSF), the exemption does apply to

a joint venture partnership like

United-owned entirely by corporations and affiliated with at least one

of them. AO 1992-17 . The SSFrelated costs are also exempt from

the prohibition on contributions and

expenditures by federal government

contractors. II CFR 115.2(a) and

115.3(a) . United may therefore

assist in the solicitation of its

restricted class for contributions to

FMC's SSF, the FMC Corporation

Good Government Program.

Because the term "connected

organization" does not include

partnerships, FMC is the connected

organization of the Program.

II CFR 100.6(a). The Program

includes the fuIl name of its connected organization, as required

under II CFR 102.14(c); the

addition of United's name would be

unnecessary.

With respect Harsco, the corporation is not affiliated with FMC,

since the two partners are not

shareholders, owners or managers of

each other. Nor is Harsco affiliated

with United, since it holds only a

minority limited-partner interest,

while FMC owns a 60-percent

interest and manages and controls

the partnership. Date Issued: June 6,

1994; Length: 5 pages.•

6

AO 1994-13

Video Slate Card Listing

Multiple Candidates

Voter Education Project (VEP), a

for-profit corporation, plans to

market video slates encouraging

viewers to vote for the listed candidates and ballot measure preferences. YEP anticipates charging

customers (candidate committees

and baIlot measure committees) the

fair market value for their participation in the ad.' In this situation, the

disclaimer message may simply

consist of a visual or oral statement

that the ad was paid for by the

candidates and committees identified in the slate.

Disclaimer

When a message expressly

advocates the election or defeat of a

clearly identified candidate (or

solicits contributions) and is conveyed through public political

advertising, it must include a

disclaimer. 2 U.S.c. §44Id(a)(I). If

the communication is paid for by the

candidate's campaign, the disclaimer must read : "Paid for by

[name of the authorized committee]." II CFR I 1O.II(a)(I). However, to avoid requiring multiple

disclaimers for a communication

advocating and paid for by several

candidates, the Commission concluded, in MUR 2216, that a slate

card mailer simply had to state that

the card was "paid for and authorized by candidates marked with an

asterisk" (those who actuaIly

authorized the ad). YEP's disclaimer may similarly satisfy the

disclaimer requirement without

having to mention each participating

campaign in the notice .

Exhortation to Vote

The video slate ads wiIl conclude

with a message such as "Remember

I Because YEP did not raise the issue,

the opinion did not discuss what would

constitute fair market value for VEP's

services.

July 1994

to vote on Tuesday, June 7." Because the message wiIl be paid for

by all participants, its inclusion will

not cause YEP to make a contribution or expenditure. Date Issued:

June 8, 1994; Length: 5 pages.

Corrections to Advisory

Opinion Summaries

In the summary of AO 1994-3,

published in the June issue, the

word "not" was inadvertently

omitted from the next-to-the-last

sentence. The sentence should have

read:

The treasurer of Enviro PAC,

because he does participate in

selecting recipients of PAC

contributions, may not serve as

custodian.

The summary of AO 1994-5, also

in the June issue, identified the requester as WiIliam A. White instead

of WiIliam D. White.•

Advisory Opinion Requests

Advisory opinion requests

(AORs) are available for review and

comment in the FEC's Public

Records Office.

AOR 1994-16

Funds, previously contributed to

parent corporation's PAC by

subsidiary's employees, now

transferred to PAC of subsidiary's

new corporate owner. (Atlantic

Research Corporation ; May 20,

1994; 3 pages)

AOR 1994-17

Congressional campaign's transfer

of balance remaining in recount

fund. (Barca for Congress Committee; June 6, 1994; 3 pages)

AOR 1994-18

Definition of member applied to

trade association 's membership

structure. (International Council of

Shopping Centers, Inc.; June 7,

1994; 8 pages plus attachments)
Federa l Ele ction Commission RECO RD

Closing

Cash

Disbursements

The IS-month figur es showed

that the 1994 campaigns too k in a

larger share of contributions from

indivi dua ls than the 1992 campaigns

did. In Hou se campaig ns, ca ndida te

contributions and loan s to their own

campaigns increased from $ 10

million in 1992 to $15.7 milli on in

1994.

A May 9 press release compares

15-month summ ary data on Hou se

and Senate campaign activity

throu gh four election cycles. The

release also lists summary figures

for eac h 1994 House and Senate

ca ndida te. Copies are available from

the Public Records Office. ..

Receipts

House and Senate Activity Through March 31 of Election Year

(millions of doll ars )

Election Number of

Cycle Candidates

Congressional Activity

15 Months into Cycle

By March 31, 1994-fifteen

months into the 1993-94 ele ction

cyc le- House and Senate campaigns had raised more money than

their 1992 counterparts had during

the same period in the previous

cyc le. By co ntrast, 1994 campaign s

had spe nt less money at the 15-

month point than had the 1992

cam paigns. (See tabl e.)

AOR 1994-20

Don ation of campaign vehicle to

co unty board of health. (Committee

for Co ngress man Charlie Rose; Jun e

10,1 994 ; 3 pages)

AOR 1994-21

PAC so licitation included on

membership dues billing sent to all

members, including thos e who are

not so licitable. (American Pharmaceut ical Associatio n PAC; Jun e 13,

1994 ; 2 pages) ..

AOR 1994-19

Affiliation among PACs established

by professional society at national

and state levels and betw een PACs

of two professional orga nizations.

(America n Soc iety of Anes thesiologists, Inc.; June 7, 1994 ; 5 pages

plu s attac hments)

1993-94

1991-92

1989-90

1,881

2,053

1,269

$253.9

$247.5

$192.5

$163.6

$170.1

$126.6

$140.6

$160.4

$13 8.5

~-------------------------------------

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Campaign Guide for Corporations and Labor Organizations .

- - -

Record Supplement for Political Party Committees .

The Supplement updates the Campaign Guide for Political Party Committees. If you need to order the - - -

Guide, please indicate the number of copies .

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Record Supplement for Nonconnected Committees .

The Supplement updates the Campaign Guide f or Nonconnected Committees. If you need to order the - - -

Guide, please indicate the number of copies .

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1994 Edition of FEC Regulations (11 CFR) .

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Annual Report 1993 . - - -

Using FEC Campaign Finance Information . - - -

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7
Federal Election Commission RECORD ____________ _ _ _ _ _ ....: >'. / 994

Index

The first number in eac h citation

refers to the "n umber" (mo nth) of

the 1994 Record issue in which the

article appeared. The seco nd number,

followi ng the colon, indicates the

page number in that issue. For

exa mple, "I :4" means that the

article is in the January issue on

page 4.

Advisory Opinions

1993-18: Corporate plan to foster

politi cal participation, 2: I

1993- 19: Retiring 1984 Presidenti al

debt , I: 13

1993-20: Purchase and distribution

of candidate biograph y, 2:3

1993-21: Pree mpt ion of Ohio law,

2:4

1993-22: Use of excess funds by

retired House Member, 3:5

1993-23: PAC disaffiliation, 3:6

1993-24: Definition of member, 4:6

1993-25: Preemption of Wisconsin

law restricti ng contribut ions from

lob byists, 3:7

1994-2: Preemption of Minnesota

law restricting contributions from

lobb yists, 5:6

FEDERAL ELECTION COMMISSION

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Washington, DC 20463

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1994-3: Charitable matchin g plan

for twice-yearly solicitations, 6:4;

correction, 7:6

1994-5: Candidate status, 6:5;

correction , 7:6

1994-6: Charitable matching plan

for twice-yearly solicitations, 7:4

1994-7: Charitable matching plan

for twice -yearly solicitations;

treasurer as custodian, 7:4

1994-8: Campaig n's rental of office

space from candidate-owned

corporation, 7:4

1994-9: Transfers from nonfederal

PACs; effe ct of corporate reorganization on affili ation, 7:5

1994-11: SSF activities of federal

contractor partnership , 7:6

1994- 13: Video slate card listing

multi ple candidates, 7:6

Court Cases

FEC v.

- GOPAC, 6:5

- LaRouche (94-658-A), 7:3

- Mic higan Republican State

Committee, 4:7

- National Rep ublican Senatorial

Committee (93-16 12), 1:12; 4:7

- Political Contributions Data, Inc.

(PCD), 5:4

- Rodriguez, 6:5

- Survival Education Fund, Inc., 3:I

- Williams, I:12

__ v. FEC

- Akins (92-1864), 5:4

- Center for Responsive Politics,

I: 12

- Freedom Republicans, Inc. , 3:3

- Froelich, 2:2

- LaRouche (92-1100), I: 12

- National Republican Senatorial

Committee (NRSC), 5:5; 7:2

- Republican National Comm ittee

(RNC) (94- 1017), 7:3

Reports

Reporting reminders, April, 3:I;

July, 6: 1

Schedul e for 1994, 1:4; correc tion,

2:I

- cha nge in Florida and South

Carolina election dates, 4:6

Special elections

- Kentucky (2nd District), 5:9

- Oklahom a (6th District), 3:7

- Oklahoma (Senate), 7:2

800 Line Articles

Hel p - my report is late, 6:I

Registration by candidates and their

committees, I:14

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