THE FEDERAL ELECTION 

COMMISSION 

1325 K Street N.W., Washington, D.C. 20463 

Volume 4, Number 7 

COMMISSIONERS 

NEW OFFICERS ELECTED 

On May 18, 1978, the Federal Election Commission 

unanimously elected Vice Chairman Joan D. Aikens as its 

new chairman and Commissioner Robert 0 . Tiernan as its 

new vice chairman. The new officers began one-year terms 

of office on May 20, 1978. 

The Federal Election Campaign Act provides that the Commission elect its officers for a term of one year. No Commissioner may serve as chairman more than once during any 

term of office to which he/ she is appointed. The chairman 

and vice chairman must be affiliated with different political parties. Previous Commission chairmen were Thomas B. 

Curtis (1975-1976). Vernon W. Thomson (1976-1977) 

and Thomas E. Harris (1977-1978). 

At the time of her appointment to the Commission, Chairman Aikens was Vice President of Lew Hodges/Communications, a public relations firm located in Valley Forge, 

Pennsylvania. From 1972 until 1974, she was President of 

the Pennsylvania Council of Republican Women and served 

on the Board of Directors of the National Federation of 

Republican Women. Chairman Aikens was one of the six 

original Commissioners appointed in 1975. She was renamed to the Commission in 1976 when it was reconstituted after the Buckley v. Valeo decision. 

Prior to his appointment in 1975, Vice Chairman Tiernan 

served as a Democratic Member of Congress from Rhode 

Island for eight years. He had previously served as a State 

legislator for seven years. An attorney, Vice Chairman 

Tiernan has been admitted to practice in all Federal courts, 

the State of Rhode Island and the District of Columbia. He 

has also held various national and State party positions. 

President Gerald Ford nominated Mr. Tiernan to the Commission for a five-year term after the Buckley decision. 

July 19

REPORTS 

SECOND QUARTER REPORT 

All candidates for Federal office and political co

mittees supporting such candidates must file a seco

quarter report of receipts and expenditures by July 

1978, if total contributions received or total expenditu

made during the second quarter exceeded $1,000. In ad

tion, those candidates or committees whose "debts 

curred" or "debts extinguished" exceeded $1,000 dur

the quarter are required to file the quarterly report. If t

campaign finance activity of a candidate or comm itt

did not exceed this reporting threshold during the quart

they are eligible for the quarterly report exemption. Th

may file FEC Form 3a (postcard form), or a letter conta

ing the same information, instead of the full report of 

ceipts and expenditures. 

Candidates or committees who filed FEC Form 3a for t

first quarter report (April 1 0) and whose campaign finan

activity during the second quarter did not exceed t

$1,000 threshold, continue to be exempt from the qu

terly report. They need not file a second postcard form. 

Candidates who have requested a personal reporting waiv

need not file any report on July 10. A political committ

filing on a monthly basis must file its report for the mon

of June on July 20. 

The quarterly report, filed on FEC Form 3 or 6 (with s

porting schedules). is due on or before July 10, 1978, a

covers the period from April 1, 1978, through June 3

1978. Candidates or committees who have filed pre- 

post-primary election reports after April 1 should file th

quarterly report covering the period from the last rep

filed through June 30, 1978. The report should be fil

with the Clerk of the House, the Secretary of the Sena

or the Federal Election Commission, as appropriate. 

packet of additional information will be sent to all reg

tered candidates and committees . Questions or reque

for forms should be addressed to the Office of Public Co

munications in Washington, D.C. at 202/523-4068 or to

free 800/424-9530. 
REGULATIONS 

REQUEST FOR PUBLIC COMMENT 

On May 31, 1978, the Commission published a notice 

in the Federal Register requesting public comment on the 

Commission's regulations governing the public financing of 

Presidential elections (11 CFR 120-125, 130-134, 

140-146). The Commission is reviewing these regulations 

"in light of the experience of both the Commission and the 

recipients [of public funds] in the 1976 Presidential election process," with a view toward clarifying and simplifying 

the regulations. The notice requested comments from all 

interested persons on needed changes. The Commission was 

especially interested in the views of 1976 Presidential election participants on the following: 

-- Any administrative burdens imposed by the current 

regulations; 

-- Any problems experienced with the recordkeeping requirements of the regulations; and 

-- Any areas of the Act or regulations in need of further 

clarification. 

In addition to requesting written comments, the notice 

announced a hearing wou ld be held by the Commission 

on June 20, 1978. 

OPINIONS 

PENDING ADVISORY OPINION REQUESTS 

The fol lowing chart l ists pending Advisory Opinion Requests (AOR's). with a brief description of the subject 

matter, the date the requests were made public and the 

number of pages of each request. The full text of each AOR 

is available to the public in the Commission's Office of 

Publ ic Records. 

Date Made Number 

A OR Subject Publ ic of Pages 

1978-28 Get-out-to-vote drive by 5/17/78 2 

party committee. 

1978-29 Registration and reporting 5/18/78 

requirements for 

authorized committee. 

1978-30 Contribution limitations 5/24/78 

for candidate selected by 

convention. 

AOR Subject 

1978-31 See article "Alternate Disposition of Advisory 

Opinion Requests" 

1978-32 Treatment of payment for 

officeholder's appearance/ 

speech as contribution. 

1978-33 Required notices on 

candidate advertising. 

Date Made 

Publ ic 

5/25/78 

6/ 2/78 

ADVISORY OPINIONS: SUMMARIES 

Numbe

of Page

2 

4 

Designated as AO's, Advisory Opinions discuss t

application of the Act or Commission regulations to s

cific factual situations. Any qualified person requesting 

Advisory Opinion who in good faith acts in accordan

with the opinion will not be subject to any sanctions und

the Act. The opinion may also be relied on by any oth

person involved in a specific transaction which is ind

tinguishable in all material aspects from the activity d

cussed in the Advisory Opinion. Those seeking guidan

for their own activity should consult the full text of 

Advisory Opinion and not rely only on the summary giv

here. 

AO 1977-42: Candidate Participation in 

Radio Program 

Ken Hechler, a candidate for the U.S. House of Rep

sentatives, may participate as host and interviewer on tw

radio programs without the funding of the programs be

considered a contribution or expenditure on his beha

This conclusion was based on the following conditions: 

-- The broadcasts did not contain any communication e

pressly advocating the election of Mr. Hechler or ad

cating the defeat of any other candidate; 

- The broadcasts did not contain any solicitation of ca

paign funds for Mr. Hechler; and 

-- The broadcasts were not conducted to influence t

election of Mr. Hechler to Federal office. 

The opinion expressed no opi nion as to the application 

the Communications Act or Federal Communication Co

mission rul ings to the activity described. 

Commissioner Neil Staebler filed a dissenting opinio

(Length, including dissenting opinion, 6 pages) 

AO 1978-20 : Use of Corporate Aircraft 

Robert Davis, candidate for the U.S. House of Represe

tatives, may use a aircraft owned by a nonprofit corpora

flying club for campaign-related travel provided he re

burse the flying club in advance in accordance with § 114

(e) of the Commission's regulations. An individual memb

The RECORD is published by the Federal Election Commission, 1325 K Street, N.W., Washington, D.C. 20463. 

Commissioners are: Thomas E. Harris, Chairman; Joan D. Aikens, Vice-Chairman; William L. Springer; Neil Staebler; 

Vernon W. Thomson; Robert 0 . Tiernan; J.S. Kimmitt, Secretary of the Senate, Ex Officio; Edmund L. Henshaw, Jr., 

Clerk of the House of Representatives, Ex Officio. 

For more information, call 523-4068 or toll free 800-424-9530. 

2 
of the club may use the club's aircraft in connection with 

campaign-related travel as a volunteer "providing personal 

services to the campaign." However, the member or the 

campaign committee would have to reimburse the flying 

club in accordance with § 114.9(e). If made by the club 

member, the total reimbursement could not exceed the 

combined total limits contai ned in 2 U.S.C. §431 (e)(5)(1) 

(travel expenses of individual vol unteering services to 

campaign exempted from definition of contribution) and 

2 U.S.C. §441a (individual contribution limitations). 

The opinion noted the possible application of other laws or 

regulations outside the Commission's jurisdiction, particularly regulations of the Federal Aviation Administration. 

Commissioner Thomas Harris filed a dissenting opinion. 

(Length, including dissenting opinion, 5 pages) 

AO 1978-22: Hospital ity Suite Maintained 

by Candidate 

The cost of maintaining a "hospitality room" at the 

State Convention of the Democratic Party of Hawaii by 

Congressman Cecil Heftel, a candidate for the U.S. House 

of Representatives, would constitute an expenditure 

subject to the disclosure provisions of the Federal Election 

Campaign Act. Funds donated to the Congressman to 

defray the costs of maintaining such a room would be 

contributions under the Act. This conclusion is based on 

several factors: 

.. Mr. Heftel's appearances at the convention would be 

before "a substantial number of people who comprise 

a part of the candidate's electorate ... "; 

.. The State party convention is inherently a partisan 

event at which decisions will be made affecting both the 

primary and general elections; and 

.. Mr. Heftel 's attendance at the convention and main· 

tenance of a hospitality suite is likely to "have the effect 

of furthering [his) candidacy." 

Commissioner Robert 0. Tiernan fi led a dissenting opinion. 

(Length, including the dissenting opinion, 4 pages) 

AO 1978-23: Payroll Deduction Plan 

The Square 0 Company may facilitate a method of col· 

lecting political contributions by the International Association of Machinists (lAM) whereby members of lAM 

authorize payroll deductions of contributions to lAM's 

separate segregated fund (Machinists Non-Partisan Politi· 

cal League). Square 0 Company may facilitate this plan 

even though the company itself does not utilize a payroll 

deduction system to facilitate political contributions from 

executive employees to its own separate segregated fund. 

(Length: 2 pages) 

AO 1978-24: Preemption of State Law 

The Sonneland for Congress Committee does not have to 

comply with a Washington State statute which requires 

campaign advertising to disclose the party affiliation of 

3 

the candidate involved. This portion of the Wash ington 

is preempted by the Federal Election Campaign 

because: 

Sponsorship statements and notices of the availa

of campaign finance reports on campaign advert 

" ... are an integral part of the scheme prescribe

the Act for effective full disclosure"; and 

.. The Act preempts any State law with respect to 

quired disclosures in conducting political campaigns 

Federal office." (Length: 3 pages) 

AO 1978-25 (Part A): Contributions for a Primary 

Runoff Election 

Congressman Thad Cochran and Senator Jesse He

candidates for the U.S. Senate in Mississippi and N

Carolina, respectively, may not benefit from a sep

contri bution limitation for a primary runoff electio

which they are not on the ballot. Even though a runo

required for Senate candidates seeking the nominatio

another political party, a candidate who has already 

nominated through a primary election victory is "no lo

seeking nomination and therefore is not regarded 

candidate with respect to any runoff election ... to s

another nominee for the same Federal office." Cont

tions with respect to a potential runoff may not be mad

accepted and then held in escrow with a view toward sp

ing them in the event a runoff becomes necessary. 

An Advisory Opinion responding to additional ques

posed in AOR 1978-25 will be issued by the Commis

at a future date. (Length: 4 pages) 

ALTERNATE DISPOSITION OF 

ADVISORY OPINION REQUESTS 

Since May 1, 1978, the F EC has responded to the 

lowing Advisory Opinion Requests in a manner other 

the issuance of an Advisory Opinion: 

.. AOR 1976-115 (affil iation of political committ

AO R 1977-69 (magazine published by PAC's conne

organization) and AOR 1978-31 (acceptance of co

butions from local candidates or committee) 

withdrawn from consideration by their requestors. 

.. AO R 1978-11 and AO R 1978-14 (application of 

oraria provisions to Supreme Court Justice or Fe

judge) were answered by a letter from the Commiss

General Counsel stating that neither Supreme C

Justices nor other Federal judges have standing t

ceive Advisory Opinions under the Act. The 

further explained that the Commission and its sta

specifically prohibited from issuing other opinion

"an advisory nature." 
INFORMATION 

Under this heading, the Record periodically summarizes 

new developments of general interest to candidates for 

Federal office and committees which support such 

candidates. 

DEBT SETTLEMENT 

On May 4, 1978, the Commission approved a d irective 

to staff containing procedures for processing requests for 

settling debts owed to cred itors (both corporate and 

noncorporate). 

Corporate Creditors 

The Commission's regulations provide that a corporation 

may extend credit to a candidate or pol itical committee in 

connection with Federal elections provided: 

·· The extension of credit is in the ordinary course of business; and 

.. The terms of the credit are si111ila r to extension of 

credit to nonpolitical debtors. 

Under the definition of "contribution," however, the 

regulations state that a creditor who extends credit to a 

candidate or committee "for a length of time beyond 

normal business or trade practice" makes a contribution, 

un less the creditor makes a "commercially reasonable 

attempt to collect the debt." (Emphasis added) 100.4(a)(6). 

The regulations further provide that, in the case of corporate creditors, a debt owed by a candidate or political 

committee may be forgiven or settled for less than the total 

amount if it is settled in a commercially reasonable manner 

and a Statement of Settlement is submitted to the Commission by the corporation and/or the debtor. This Statement 

is subject to Commission review. (For the specific details 

on settling corporate debts, see 114.10 of the regulations.) 

Noncorporate Creditors 

In the recent staff directive , the Commission outlined 

the following procedures whereby a noncorporate creditor 

may demonst rate to the Commission that it has made a 

"commercially reasonable attempt to collect the debt," 

and t hereby settle a debt owed by a candidate or committee without the settlement being considered making a 

contribution: 

1. A noncorporate credi tor may forgive or settle a debt 

only if credit was ext ended in connection with rendering 

goods and/or services to a candidate or political committee 

in the normal course of a business or professional enterprise. (A debt involving only the lending of money could 

not, therefore, be forgive n without a contribution being 

made.) 

2. The settlement of any debt owed by a candidate or political committee to a noncorporate creditor is subject to 

Commission review if either: 

4 

-- The amount of the debt forgiven causes the credi

exceed contribution limitations (when added to 

other contributions made by the creditor to the 

candidate); or 

-- The creditor wishes the entire amount of the forgiv

to be regarded as a debt settlement (and so notifie

Commission), rather than as a contribution in-kind. 

In either case , a Statement of Settlement simi lar to 

required when corporate debts are settled would ha

be submitted to the Commission by the creditor a

debtor. 

3 . In reviewing an agreement to settle a noncorp

debt, the Commission evaluates information foun

campaign finance reports fi led with it (e.g., amou

original debt, percentage of debt forgiven, total am

of debtor's debt activity, debtor's year-to-dat e exp

tures, etc.) and information submitted by the creditor 

or debtor in the Statement of Settlement(s) (see above

REPORTING DEBTS AND LOANS 

In two notices sent to candidates and politica l 

mittees in recent months, the Commission clarified ce

reporting obligations. 

Disclosure of Loan Information 

The January 1978 revision of FEC Form 3, Schedu

provides space for the full disclosure of the original s

of loans. If, for example, a candidate obtains a loan fr

bank and, in turn, loans the proceeds to his/her prin

campaign committee, both the candidate and the 

must be identified on the committee's report as so

of the loan: the bank, as the original source; the cand

as the intermediary. 

In addition, the revised Schedule C provides for th

closu re of the rate of interest on the loan, information 

whether or not the loan was secured and the full ident

tion of each endorser or guarantor. 

For specific details, see the revised instructions for co

tion of Schedule C (provided to all registered candi

and committees). 

Debt Activity May Trigger 

Quarterly Reporting 

In a notice sent to all registered candidates and 

mittees (March 1978), the Commission · clarified 

quarterl y reports are required. The Federal Election 

paign Act states that quarterly reports are required 

contributions or expenditures exceed $1 ,000 duri

calendar quarter. "Contribution" and "expendi

are defined in the Act to include "not only cash-in, 

out transactions, but also the receipt of 'anyth ing of v

or a 'contract, promise, or agreement' to make an exp

ture." 2 U.S.C. § 431 (e)(1) and §431 (f)(1 )-(2). 

Quarterly reporting is thus required when "debts incu

by a candidate or political committee exceed $1 ,000 d

a calendar quarter. The notice states that the term "

incurred" includes: 
-- Any loans to the candidate or committee which were 

received during the calendar quarter; 

-- Any commercial obligations for which the candidate or 

committee has received a bill or invoice during the 

calendar quarter. (Note, however, accounts payable of 

less than $500 which have been outstanding less than 

sixty days need not be included when calculating tota l 

"debts incurred.") 

A quarterly report is also required when "debts extinguished" (i.e., expenditures made) by the candidate or committee exceed $1,000 during the calendar quarter. "Debts 

extinguished" include debts which are paid, settled, or 

forgiven. 

Note: The mere existence of previously reported debts does 

not independently trigger the quarterly reporting requirement. 

COMPLIANCE 

FEC PUBLISHES NAMES 

OF NONFILERS 

The Commission is required by the Federal Election 

Cam paign Act to publish the names of candidates and political comm ittees who fail to file required reports of receipts 

and expenditures. In an election year, candidates and committees must file quarterly reports (Apri l 10, July 10, 

October 1 0), pre- and post-election reports (primary and 

general) and a year-end report (January 31 ). (Under certain 

circumstances, if the candidate or committee has minimal 

financial activity, quarterly reports and the year-end 

report may be exempted.) 

Political committees which make contributions or expenditures in more than one State may. upon request to and 

approval by the Commission, file monthly reports by the 

20th of each month. In November, December and January, 

in lieu of monthly reports, such committees must file the 

pre- and post-general election report s and a year-end report. 

Under Commission procedures, prior to publishing the 

name of a candidate or committee, at least two notices are 

sent to those who have fai led to fi le. If the required reports 

are not filed following receipt of these notices, the name of 

that "nonfi ler" is made public. The following is a list of 

recent nonfiler actions taken by the Commission: 

Publication 

Date 

5/ 13/78 

5/20/78 

Report Not 

Filed 

Pennsylvania 

(Pre-primary) 

Kentucky 

(Pre-primary) 

Number of 

Nonfilers 

11 

5 

5 

Publication Report Not Numbe

Date Filed Nonfi

5/20/78 Oregon 2 

(Pre-primary) 

6/ 3/78 California 21 

(Pre-primary) 

6/ 3/78 Iowa 

(Pre-primary) 

6/ 3/78 Montana 

(Pre-primary) 

6/ 3/78 New Jersey 3 

(Pre-primary) 

6/ 3/78 New Mexico 

(Pre-primary) 

6/ 3/78 Ohio 4 

(Pre-primary) 

THE LAW 

IN THE COURTS 

LITIGATION STATUS INFORMATION 

The following is a l ist of new litigation involving 

Commission, together with the date the suit was filed

Court involved, the Docket Number and a brief descri

of the major issue(s) involved in the case. Persons se

additional information on a particular case should co

the Court where the suit is filed, or the Commission. 

Robert J. Luellen v. FEC, U.S. District Court for the D

trict of Columbia, Docket No. 78-0724, April 25, 1978

Plaintiff has brought suit against the Commission pursuant to 2 U.S.C. §437g(a)(9) alleging 

that the Commission's dismissal of his complaint was contrary to law. 

FEDERAL REGISTER 

NOTICES 

The following list identifies all FEC documents ap

ing in the Federal Register between May 16, 1978

June 8, 1978. 

Federal Register 

Notice Title Publication Date Cita

1978-5 Public Hearing on 5/31/78 43 FR 

Proposed Revision 

of Regulations 
AUDITS 

AUDITS RELEASED TO THE PUBLIC 

The Federal Election Campaign Act requires the Com· 

mission " . .. to make from time to time audits and field 

investigations with respect to reports and statements filed 

under the [Act) ." The Commission is also required to 

conduct audits of all campaigns of Presidential candidates 

who received public funds. Once an audit is completed and 

an audit report is approved by the Commission, the report 

is made public and is available in the Office of Public 

Records and the Press Office. The following is a list of all 

audits released as of March, 1978, in chronological order. 

(Notations in parentheses indicate Congressional candi· 

date's State and district.) 

Audit 

1. Caldwell Butler/Butler '76 Committee 

(VA/06) 

2. Warren D. Saunders/Saunders for 

Congress Campaign Committee (V A/06) 

3. Bill Frenzel/Frenzel Volunteer Commit· 

tee (MN/03) 

4. Jerome Coughlin/Coughlin for Congress 

Committee (MN/03) . 5. Lynn Greer/ Lynn Greer for Congress 

Committee (AL/05) 

6. Jules Machen/Machen for Congress 

Committee (AL/05) 

7. Robert C. McEwen/Citizens for McEwen 

Committee (NY/30) 

8. Bobby Richardson/Richardson for 

Congress Committee (SC/05) 

9. Larry Pressler/Pressler for Congress 

Committee (SD/01) 

10. Robert Cornell/Cornell for Congress 

Committee (WS/08) 

1 1. Berkley W. Bedell /The People to 

Re-Elect Bedell Committee (IA/06) 

Date Made 

Public 

2/ 1/78 

2/1/78 

2/3/78 

2/3/78 

2/3/78 

2/3/78 

2/9/78 

2/9/78 

2/9/78 

2/9/78 

2/9/78 

12. Norma Bartle/Norma Bartle for Congress 2/14/78 

Committee (NY/30) 

6 

Audit 

13. Edward J. Patten/Edward J. Patten for 

Congress Committee (NJ/ 15) 

14. Charles Wiley/Wiley for Congress 

(NJ/ 15) 

15. Allen Ertel/ Ertel for Congress (PA/ 17) 

16. Joseph Hepford/Hepford for Congress 

Committee (PA/ 17) 

17. Dave Evans/Dave Evans for Congress 

Committee (IN/06) 

18. Christopher Dodd/Congress '76 Com· 

mittee (CT/02) 

19. Richard Jackson/Jackson for Congress 

Committee (CT/02) 

20. Bud Shuster/Bud Shuster for Congress 

Committee (PA/09) 

Date 

Pu

2/ 2

2/2

2/2

2/2

2/2

3/6

3/6

3/6

21 . Brady Denton/ Denton for Congress Com- 3/9

mittee/Saginaw County GOP Congressional 

Boosters Club (MI/08) 

22. Democratic Senatorial Campaign Committee 

23. Dennis Adams/Citi zens to Elect Dennis 

Adams People (NJ/ 15) 

24. Jo Anne Soper/Soper for Congress 

Committee (IA/06) 

25. Edward Koch/The Committee to Re· 

Elect Ed Koch/New Yorkers for Koch 

(NY/18) 

26. Sonia Landau/The Sonia Landau for 

Congress Committee (NY/18) 

27. Milton Shapp/The Shapp for President 

Committee 

28. Geral d R. Ford/President Ford Com· 

mittee (General) 

29. Richard L. Ott inger/Better Government 

Committee (NY /24) 

30. David Hicks/Citizens for Hicks (NY /24) 

31. Sam Gibbons/Committee for Sam 

Gibbons (FL/07) 

3/1

3/1

3/ 1

3/ 1

3/ 1

3/2

3/2

3/3

3/3

3/3
e 

Date Made 

Audit Public 

32. Dr. Ralph Y. McGinnis/ McGinnis for 3/30/78 

Congress Committee (I L/22) 

33. Robert Potts/Potts for Congress Com- 3/30/78 

mittee (AL/05) 

34. Gerald R. Ford/President Ford Com- 3/30/78 

mittee (Primary) 

800 LINE 

The Public Communications Office of the Federal Election Commission receives numerous inquiries from the 

public on the toll-free line (800/424-9530). The following 

explanation of certain provisions of the Act and regulations 

is in response to several frequently asked questions. 

EFFECT OF STATE LAWS ON CANDIDATES 

FOR FEDERAL OFFICE 

Although the Act and regulations "supercede and preempt any provision of State law with respect to election to 

Federal office" (2 U.S.C. §453), the Act does not supercede State laws which provide for the following types of 

activities: 

(1) Manner of qualify ing as a candidate or pol itical 

party organization; 

(2) Dates and places of elections; 

(3) Voter registration; 

(4) Prohibition of false registration, voting fraud, theft of 

ballots, and similar offenses; or 

(5) Candidate's personal financial disclosure (i.e., networth, personal assets, etc.) 

Candidates shoul d especially note that registration with the 

Commission does not qualify them for ballot position in 

their State. Qual ification for and position on a State ballot 

are determined by State law -- not the Act. Nor is qual ifications for a State's ballot sufficient registration for the 

purposes of the Federal Election Campaign Act. The candidate must st ill register on FEC Form 2. For information on 

requirements for ballot access, candidates should contact 

the appropriate election official in their State. 

SOLICITATIONS BY CORPORATIONS 

AND LABOR ORGANIZATIONS 

Corporations and labor organ izations are limited by the 

Federal Election Campaign Act (2 U.S.C. §441 b) and the 

Commiss ion's regulations (11 CFR 114) as to whom and 

when they may sol icit for contribut ions to their separate 

segregated funds. The following brief ex planat ion of who 

7 

may be solicited is for GENERAL IN FORMATION ONLY

It should not be used to determine whether specific indiv

duals in a corporation or labor organization may be so

cited. For detailed information _on whom may be sol icite

and when the solicitations may be made, consult the Act o

regulations, or contact the Federal Election Commissio

CORPORATIONS 

A corporation may solicit the following individuals a

unlimited number of times during a calendar year: 

-- Stockholders of the corporation; 

-- Execut ive or administrative personnel of the corpor

t ion; 

-- Executive or administrative personnel of the corpora

tion's subsidiaries, branches, divisions, and affiliates; 

-- Families of the three groups above. 

A stockholder is defined as a person who "has a veste

beneficial interest in stock, has the power to direct how th

stock shall be voted, if it is voting stock, and has the righ

to receive dividends." Executive or administrative personne

are those corporate employees "who are paid on a salar

rather than hourly basis and who have pol icymaking

managerial, professional, or supervisory responsibilities

This definition does not include: 

-- Professionals who are represented by a labor organiz

tion; and 

-- Salaried foremen and lower level supervisors who hav

direct supervision over hourly employees. 

In addition, a corporation may sol icit all other employee

who are not stockholders or executive or administrativ

personnel on a twice-yearly basis (11 CFR 114.6). Th

category of employees includes, among others, the profes

sionals represented by labor organizations and salarie

foremen and lower level supervisors mentioned above

A. corporation may not, at any time, solicit former o

retired employees who are not stockholders. 

LABOR ORGANIZATIONS 

A labor organization may solicit the following indiv

duals an unlimited number of times during a calend

year: continue

FEC PUBLIC APPEARANCES 

In keeping with its objective of making information available to the public, the Federal Election 

Commission regularly accepts invitations for its 

representatives to address public gatherings on the 

subject of campaign financing laws and the Commission itself. This regular column l ists scheduled Commission appearances, detailing the name of the sponsoring organization, the location of the event and the 

Commission's representative. 

7/19 Presidential Classroom for Young Americans 

" The American Electorate" 

Washington, D.C. 

Commissioner Neil Staebler 
-- Members of the labor organization; 

-- Families of such members. 

Members of a labor organization are defined in the regulations as " ... persons who are currently satisfying the 

requirements for membership in a local, national, or international labor organization." 

Under the twice-yearly provisions, a labor organization may 

solicit the following persons of a corporation in which the 

labor organization represents members: 

-- Employees who are not members of the labor organization; 

-- Executive or administrative personnel; 

-- Stockholders; 

-- Fami lies of the three groups above. 

Determination of who may be solicited by a corporation or 

labor organization depends in large part on the internal 

structure of the particular corporation or labor organizat ion. Additional details on the above definitions may be 

found in Part 114 of the Commission's regulations. Or 

questions may be directed to the Office of Public Communications at 202/523-4068 or toll-free 800/424-9530. 

STATISTICS 

UPDATE OF MULTICANDIDATE 

COMMITTEE INDEX 

The Commission publishes each month an update to 

the Multicandidate Committee Index. For a summary of 

the contents of the Index, see the Record, Febru ary 1978, 

p. 4. The update is available on the last day of each month. 

Copies of the Index, the current update and any past 

updates are available through the Office of Public Records 

- telephone 202/523-4181 or toll-free 800/424-9530. 

The purchase price is 10 cents per page, payable in advance. 

FEDERAL ELECTION COMMISSION 

1325 K STREET, NW 

WASHINGTON, DC 20463 

OFF ICIAL BUSINESS 

CLEARINGHOUSE 

DIRECTORY OF ELECTION 

OFFICIALS AVAILABLE 

The Clearinghouse recently announced that an upd

directory of election officials has been prepared and 

be available soon. The Election Directory '78 (previo

entitled Election Handbook) is designed to facilitate c

munication among election officials nationwide. 

The Directory consists of two parts: Part I is a synops

each State's election offices and functions, and elec

officials and their duties; Part II is a current list o

election personnel, including officials for both the Fed

and State levels of government, chairmen of State leg

tive committees, State legislative reference services 

officers of associations of election officials. The lis

cludes the officials' titles, addresses and phone numbers

Election officials in each State provided basic informa

for the revision, reviewed drafts of the Directory, 

offered suggestions to clarify election law descriptions 

practices in their respective States. 

The Clearinghouse will revise and update the Direc

annually. Any comments, suggestions for improvemen

notation of errors should be addressed to the Clearingho

at the F EC, or telephone 202/523-4183 - toll free 8

424-9530. 

To purchase a copy of the Directory send $7.25 (chec

money order) together with the report number (PB280

to : 

National Technical Information Service 

U.S. Department of Commerce 

5285 Port Royal Road 

Springfield, Va. 22161 

Fl RST-CLASS MAlL 

POSTAGE & FEES PAID 

FEDERAL ELECTION COMMISSION 

WASHINGTON, D. C. 

PERMIT NO. G31