January 1997 Federal Election Commission Volume 23, Number 1

Table of Contents

Commissioners

1 1997 Chairman and Vice

Chairman Elected

1 Message From The Chairman

Court Cases

2 DSCC v. FEC

2 NRCC v. FEC

4 DCCC v. FEC

4 FEC v. Parisi

4 Reilly v. FEC

5 Hooker v. FEC

5 New Litigation

5 On Appeal?

3 Award

 Audits

3 Audit Reports Made Public

Reports

6 Reports Due in 1997/1998

800 Line

8 Debt Settlement and Committee

Termination

10 Advisory Opinions

Information

13 Flashfax Menu

15 Index

Commissioners

1997 Chairman and Vice

Chairman Elected

On December 12, 1996, the

Commission unanimously elected

John Warren McGarry as FEC

Chairman and Joan D. Aikens as

FEC Vice Chairman.

Before his original appointment

to the Commission, Mr. McGarry

served as special counsel on elections to the House Administration

Committee. He previously combined private law practice with

service as chief counsel to the

House Special Committee to

Investigate Campaign Expenditures,

a special committee established by

Congress. Before his work with

Congress, Mr. McGarry served as an

assistant attorney general for the

Commonwealth of Massachusetts.

After graduating cum laude from

Holy Cross College, Mr. McGarry

did graduate work at Boston University and earned a J.D. degree from

Georgetown University Law School.

Newly elected Vice Chairman

Aikens is the only original member

of the Commission still serving.

Before her appointment, Ms. Aikens

was an executive with Lew Hodges

Communications, a public relations

firm in Valley Forge, PA. She also

was a member of the Pennsylvania

Republican State Committee,

A Message from Chairman

John Warren McGarry

Nineteen ninety seven promises

to be another year of challenges for

the Federal Election Commission.

• The level of reportable campaign

finance activity grew at a recordsetting pace during the 1995-96

election cycle totaling more than

$2.6 billion—up more than 25

percent since the last Presidential

and congressional campaigns.

• This year the Commission will

introduce an interim voluntary

electronic filing system for disclosure reports while continuing the

development of a full electronic

filing system.

• Steps are underway to improve

existing FEC operations including

the enforcement priority system

and computer intiatives.

• In the event of the passage of

campaign finance reform legislation, the FEC would administer,

implement and enforce any new

laws enacted.

It is essential that the FEC

continue to focus its limited resources on the agency’s core

mission and programs. We always

welcome comments and suggestions

on how to better serve our various

constituencies.

I end this note with a personal

“thank you” to our valued staff for

their outstanding work and continued contributions. ✦

(continued on page 2)
2

Federal Election Commission RECORD January 1997

Federal Election Commission

999 E Street, NW

Washington, DC 20463

800/424-9530

202/219-3420

202/501-3413 (Flashfax Service)

202/219-3336 (TDD for the

hearing impaired)

800/877-8339 (FIRS)

John Warren McGarry, Chairman

Joan D. Aikens, Vice Chairman

Lee Ann Elliot, Commissioner

Danny L. McDonald,

Commissioner

Scott E. Thomas, 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

Court Cases

DSCC v. FEC (96-2184)

On November 25, 1996, the U.S.

District Court for the District of

Columbia denied a request from the

Democratic Senatorial Campaign

Committee (DSCC) to find that the

FEC violated the Federal Election

Campaign Act when it failed to take

action on an administrative complaint the DSCC had filed with the

Commission.

The DSCC filed the lawsuit

against the FEC after the agency had

failed to act on its administrative

complaint against the National

Republican Senatorial Committee

(NRSC) within 120 days. 2 U.S.C.

§437g(a)(8)(A).

The DSCC filed its administrative complaint in 1993 and followed

it with a supplemental complaint in

1995. See August 1993, April 1995

and July 1996 Records for previous

actions in this case. The complaints

alleged that the NRSC had made at

least $187,000 in illegal “soft

money” expenditures to influence

the Senate election of a Republican

candidate in Georgia. The NRSC

did this, the DSCC alleged, by

funneling the money through four

nonprofit organizations that were

allegedly closely aligned with the

Republican Party.

In April 1996, the DSCC asked

the court to order the FEC to act on

its administrative complaints. The

court found the FEC’s delay was

contrary to law and told the agency

to move forward with the case. It

also told the DSCC to file another

lawsuit if the FEC did not take

action.

The DSCC did just that. In

September it filed this case, asking

the court again to order the FEC to

complete the consideration of its

complaint within 30 days or give the

DSCC the authority to file a civil

action against the NRSC.

In denying the DSCC’s request,

the court said the FEC’s conduct did

not yet constitute a failure to act that

was contrary to law. Further, the

FEC provided the court and the

DSCC with a chronology of its

actions taken over the last 15

months.

The court also based its ruling, in

part, on the FEC’s considerable

work load, lack of resources and

competing priorities. In particular, it

noted the recent U.S. Supreme

Court ruling in the Colorado

Republican Federal Campaign

Committee case, which was handed

down in June 1996 and which

invalidated part of the FEC’s

regulation governing expenditures

by national and state party committees. See the August 1996 Record,

page 1. That ruling, the court said,

added an “additional layer of

complexity” to the DSCC’s allegations against the NRSC.

The court noted that the statute of

limitations period was coming to a

close with regard to the DSCC’s

administrative complaint. Therefore,

the court ordered the FEC to file

status reports on its progress on the

administrative complaint every 30

days (the first report was due

December 10, 1996) and scheduled

a March status conference for the

FEC and the DSCC in the event that

the matter was not resolved by then.

U.S. District Court for the

District of Columbia, 96-2184. ✦

NRCC v. FEC (96-2295)

On November 18, 1996, the U.S.

District Court for the District of

Columbia issued an order instructing the FEC to supply the National

Republican Congressional Committee (NRCC) with regular updates of

its progress on the committee’s

administrative complaint against the

actions of labor organizations during

the 1996 election cycle. The order,

which had been submitted by the

parties involved in the suit, also

(continued on page 4)

president of the Pennsylvania

Council of Republican Women and

on the board of directors of the

National Federation of Republican

Women.

A native of Delaware County,

PA, Ms. Aikens has been active in a

variety of volunteer organizations.

She currently is a member of the

board of directors of Ursinus

College, where she received her

B.A. degree and an honorary Doctor

of Law degree. ✦

Commissioners

(continued from page 1)
3

January 1997 Federal Election Commission RECORD

Audits

FEC Staffer Honored with

COGEL Award

Kent C. Cooper, the FEC’s

Assistant Staff Director for

Disclosure, is the recipient of the

1996 Council on Governmental

Ethics Laws (COGEL) Award for

Distinguished Achievement. The

award honors his work in creating

and directing the FEC’s Public

Records Office, which is considered a model for other agencies

implementing public disclosure

mandates.

The award was presented at

COGEL’s 18th annual conference

held in Philadelphia last month.

Mr. Cooper’s division is

responsible for receiving and

processing campaign finance

reports filed by Presidential and

Congressional candidates,

political party committees and

political action committees. For

researchers seeking campaign

finance information, the Public

Audit Reports Made Public

In the second half of 1996, the

FEC issued 10 final audit reports

pursuant to 2 U.S.C. §438(b). (For

a listing of previously released

1996 audit reports see the July

Record, page 4.) This provision of

the Federal Election Campaign Act

authorizes the FEC to audit any

political committee that files

reports that fail to meet the threshold level of compliance set by the

FEC. The FEC has the authority to

initiate an enforcement matter to

pursue issues revealed by an audit.

The audited committees are

listed below, along with the date

that the audit was approved by the

Commission:

• Idaho Republican Party Federal

Campaign Account (August 2)

• Abraham for Senate (August 2)

• Republican Campaign Committee

of New Mexico (August 7)

• Republican Party of Dade County

(August 12)

• Democratic State Central Committee of California-Federal

(September 11)

• North Carolina Democratic

Victory Fund (1993) (December 3)

• North Carolina Democratic

Victory Fund (1995) (December 3)

• Massachusetts Republican State

Committee (December 4)

• Dan Hamburg for Congress

(December 9)

• Friends for Franks (December 10)

Final audit reports are available

from the FEC’s Public Records

Office. Dial 800/424-9530 (select

option 3 from the menu) or 202/

219-4140. ✦

Records Office is the first contact

they have with the FEC.

Mr. Cooper has been instrumental in computerizing disclosure operations within the FEC.

His “storefront office” is

equipped with high-speed

microfilm, optical imaging and

computer systems that assist the

public in finding and copying

disclosure information easily.

With the agency since it was

established in 1975, Mr. Cooper

has been an invaluable resource

to researchers and representatives

from states and foreign countries,

teaching them how to access

campaign finance information at

the FEC and how to establish

their own disclosure operations.

On December 18, Mr. Cooper

announced that he was resigning

from the Commission in order to

accept a new position as Executive Director of The Center for

Responsive Politics. ✦

Kent C. Cooper, right, accepts the 1996 COGEL Award for Distinguished Achievement from COGEL President Nicole Gordan, Executive Director of the New York City Campaign Finance Board.
4

Federal Election Commission RECORD January 1997

dismissed this case without prejudice.

The NRCC had asked the court to

force the FEC to take action, before

the election, on three administrative

complaints that it had filed with the

FEC concerning the AFL-CIO and

allied labor organizations. The

NRCC had alleged that the labor

groups were making massive

expenditures coordinated with

Democratic candidates, in violation

of 2 U.S.C. §441b(a).

The NRCC had filed its administrative complaints with the FEC in

February, March and April 1996 and

had alleged that the FEC had not

acted on those complaints by

October 3, when the Republican

committee filed its lawsuit. The

NRCC said the FEC’s delay could

cause it irreparable injury and asked

the court to order the FEC to take

action before the election.

The settlement agreement

requires the FEC to provide NRCC

lawyers with confidential updates on

the complaint. The first update is

due six months after the court order

and the second update is due six

months later. Further updates should

follow at 90-day intervals until the

administrative complaint is resolved

or there is further action by the

court.

U.S. District Court for the

District of Columbia, 96-2295. ✦

DCCC v. FEC (96-0764)

On November 18, 1996, the U.S.

District Court for the District of

Columbia dismissed this case. The

Democratic Congressional Campaign Committee (DCCC) had

voluntarily requested such action.

Originally, the DCCC had asked

the court to require the FEC to take

action on an administrative complaint it filed with the agency on

November 4, 1994, alleging violations of the Federal Election Campaign Act (the Act) by Grant Lally,

a Congressional candidate from

New York.

The Act allows a complainant to

file a lawsuit against the FEC if the

agency fails to take action on his or

her administrative complaint within

120 days after it is filed. 2 U.S.C.

§437g(a)(8)(A). The DCCC filed

suit on April 23, 1996, after more

than 120 days had elapsed.

In its original complaint, the

DCCC alleged that Mr. Lally, who

was vying to represent the fifth

district, received substantial,

undisclosed contributions in violation of the limits of the Act. 2

U.S.C. §441a. The DCCC alleged

that the money was in excess of

$300,000. Mr. Lally said the money

was “personal funds” lent to the

campaign. The DCCC filed a

supplemental complaint in 1995

alleging that Mr. Lally had continued to violate the Act.

U.S. District Court for the

District of Columbia, 96-0764. ✦

FEC v. Parisi

On October 31, 1996, the U.S.

District Court for the Southern

District of New York assessed a

$30,000 civil penalty against

Angelo Parisi for exceeding the

contribution limits of the Federal

Election Campaign Act.

The lawsuit against Mr. Parisi

grew out of an administrative

complaint filed with the FEC in

1994 by the Center for Responsive

Politics.

Among the violations, the FEC

uncovered the following transactions:

• Contributions in excess of the

individual $25,000 annual limit. 2

U.S.C. §441a(a)(3). Mr. Parisi

made $33,942 in contributions in

1991, $66,262 in contributions in

1992 and $40,405 in contributions

in 1993.

• Contributions in excess of the

$20,000 per individual limit on

contributions to a national political

party committee. 2 U.S.C.

441a(a)(1)(B). Mr. Parisi gave

$27,262 to the National Republican Senatorial Committee (NRSC)

and $22,750 to the National

Republican Congressional Committee in 1992. He also gave

$24,655 to the NRSC in 1993.

• Contributions in excess of the

$5,000 annual limit on contributions to a PAC. 2 U.S.C.

§441a(a)(1)(C). In 1991, Mr. Parisi

gave $6,200 to American Citizens

for Political Action.

Because of unusual mitigating

circumstances, all but $5,000 of the

penalty was suspended. However,

Mr. Parisi will be required to pay

the remaining $25,000 if he violates

the contribution limits again.

U.S. District Court for the

Southern District of New York,

White Plains Division, 96-0348. ✦

Reilly v. FEC

On October 18, 1996, the U.S.

District Court for the Northern

District of California, Oakland

Division, dismissed this case.

Clinton Reilly, doing business as

California Democratic Voter

Checklist, asked the court to stop

the FEC’s investigation of him

because he believed the Commission had no jurisdiction over his forprofit operation.

Mr. Reilly’s slate mail business

distributes lists of federal, state and

local candidates and advocates their

election or defeat. Mr. Reilly sold

and donated space to candidates and

initiative committees who wished to

appear on a slate card that he

distributed to voters. He said

Checklist was not a political committee under the Federal Election

Campaign Act (the Act).

As an alternative, Mr. Reilly

asked the court to find that his

business had no reporting obligations under the Act other than

reporting free or reduced-cost space

Court Cases

(continued from page 2)
5

January 1997 Federal Election Commission RECORD

on the voting slate as independent

expenditures.

In a related case, FEC v. California Democratic Voter Checklist, the

court resolved many of the same

issues raised in Reilly in the

Commission’s favor. Accordingly,

both Mr. Reilly and the FEC agreed

to the dismissal of this case.

U.S. District Court for the

Northern District of California,

Oakland Division (96-2335). ✦

Hooker v. FEC, et al.

On October 23, 1996, the U.S.

District Court for the Middle

District of Tennessee dismissed this

case for lack of prosecution.

John Jay Hooker, who billed

himself as a potential candidate for

the presidency in 1996, had asked

the court to declare it unconstitutional for candidates who seek

federal office to accept out-of-state

contributions for their campaigns.

He also had asked the court to

issue a permanent injunction against

candidates who solicit, accept or use

contributions from outside their

home states; force the sitting

Congress to address the situation;

and notify states that they have a

right to prohibit out-of-state contributions in federal elections.

U.S. District Court for the Middle

District of Tennessee, 95-0654. ✦

On Appeal?

Appealed?

FEC v. Christian Action Network No

The Solicitor General declined to ask the U.S. Supreme Court to hear this

case after a request from the Commission to do so. The U.S. Court of

Appeals for the Fourth Circuit upheld the dismissal of this case. The U.S.

District Court for the Western District of Virginia, Lynchburg Division, ruled

against the FEC after it charged the Christian Action Network with making

independent expenditures with corporate funds, failing to include a proper

disclaimer on its political communications and failing to file the required

disclosure reports with the FEC. See the December 1994, September 1995

and October 1996 editions of the Record.

New Litigation

FEC v. Fund for a Conservative

Majority

The FEC asks the court to find

that the Fund for a Conservative

Majority (FCM) and its treasurer,

Robert Heckman, violated the

Federal Election Campaign Act (the

Act) by failing to file the 1994

Year-End report on time.

The Act requires all political

committees to file a year-end report

by January 31. 2 U.S.C. §434(a).

DNC v. FEC (96-2506)

The Democratic National Committee (DNC) asks the court to order

the FEC to take action within 30

days on administrative complaints it

filed against Bob Dole’s 1996

Republican presidential campaign,

Dole for President Inc.

The DNC, which filed its initial

administrative complaint on June

12, 1996, and a supplemental

complaint on July 22, 1996, contends that the FEC’s failure to act on

the complaint within 120 days after

the complaint was filed was contrary to law. 2 U.S.C.

§437g(a)(8)(A).

The DNC contends that Dole for

President “blatantly, knowingly and

willfully” disregarded the limit on

expenditures by a presidential

campaign during the 1996 preprimary election season. Under the

Presidential Primary Matching

Payment Account Act, presidential

candidates may get matching

payments for their primary campaigns if they agree to limit expenditures to the legal limit. 2 U.S.C.

§441a(b)(1)(A). In 1996, that limit

was a little more than $37 million.

U.S. District Court for the

District of Columbia, 96-2506,

October 31, 1996. ✦

The Commission alleged that Mr.

Heckman filed the FCM’s 1994

Year-End Report on June 27,

1996—nearly a year and a half after

it was due.

The FEC also asks the court to

assess an appropriate civil penalty

against FCM and enjoin the political

committee from not filing financial

disclosure reports on time.

U.S. District Court for the

Eastern District of Virginia, Alexandria Division, 96-1567-A, October

29, 1996 ✦
6

Reports

Reports Due in 1997

This article on filing requirements for 1997 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 or 202/

219-3420.

Year-End Reports Covering

1996 Activity

All committees must file a 1996

year-end report due January 31,

1997. The coverage and reporting

dates are found in Table 1 on page

7.

Reports Covering 1997 Activity

To find out what reports your

committee must file in 1997, check

the Guide to Reporting table, below.

Then check the accompanying

tables on reporting dates, page 7.

Please note that if any special

elections are held in 1997, committees active in those elections may

have to file special election reports,

as explained below.

Committees Active

in Special Elections

Committees authorized by

candidates running in any 1997

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, rather

than semiannual, 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 1997.

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. In

1996, the FEC promulgated new

regulations that changed the point of

entry for disclosure forms for principal campaign committees of House

candidates. They now 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

Guide to 1997 Reporting

Type of Filer Reports

‘96 Year- SemiEnd annual Quarterly Monthly

House and Senate ✓ ✓

Candidate Committees 1

Presidential Candidate ✓ ✓ or 2 ✓

Committees

PACs and Party ✓ ✓ or 3 ✓

Committees

1 This category includes committees of candidates retiring debts from a previous

election or running for a future election.

2 Presidential committees may file on either a quarterly or a monthly basis. Those

wishing to change their filing frequency should notify the Commission in writing.

3 PACs and party committees may file on either a semiannual or a monthly basis.

Committees wishing to change their filing frequency must notify the Commission in

writing when filing a report under the committee’s current schedule. A committee

may change its filing frequency only once per calendar year. 11 CFR 104.5(c).

Federal Election Commission RECORD January 1997
7

Table 1: 1996 Year-End Report

(Required of all committees.)

Report Period Covered Filing Date 1

Year-End Closing date January 31, 1997

of last report

through

December 31, 1996

Table 2: 1997 Semiannual Reports

Report Period Covered Filing Date 1

Mid-Year January 1 – June 30 July 31, 1997

Year-End July 1 – December 31 January 31, 1998

Table 3: 1997 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

November October 1 – 31 November 20

December November 1 – 30 December 20

Year-End December 1 – 31 January 31, 1998

Table 4: 1997 Quarterly Reports

(Option available to Presidential committees only.)

Report Period Covered Filing Date 1

1st Quarter January 1 – March 31 April 15

2nd Quarter April 1 – June 30 July 15

3rd Quarter July 1 – September 30 October 15

Year-End October 1 – December 31 January 31, 1998

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

reports sent by other means must be received by the federal and state filing offices

on that date. 11 CFR 104.5(e).

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

(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. There is one exception:

Committees supporting only Senate

candidates 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 file

in the state in which the candidate

seeks 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).

(continued on page 8)

January 1997 Federal Election Commission RECORD
8

Federal Election Commission RECORD January 1997

800 Line

Candidate Committee

Termination and Debt

Settlement

This article, written for authorized candidate committees, explains how to settle debts and

terminate the committee.

It is reprinted from a previous

post-election edition of the Record.

Eligibility for Termination

An authorized committee may

terminate its registration and

reporting obligations by filing a

termination report, provided that:

• It has ceased raising and spending

funds (11 CFR 102.3(a)(1));

• It has extinguished all debts and, if

the committee is a principal

campaign committee, the debts of

any other committees authorized

by the candidate for the election

cycle have also been extinguished

(11 CFR 102.3(a)(1) and (b));

• It does not have any funds or

assets available to pay debts owed

by another committee authorized

by the same candidate, regardless

of the election cycle (11 CFR

116.2(c)(1)(ii)); and

• It is not involved in an ongoing

FEC enforcement matter (MUR),

audit or court case.

Termination Report

If a committee is eligible to

terminate, it may file a termination

report at any time.

When filing a termination report,

the treasurer should check the

“Termination Report” box on the

Form 3 Summary Page (Line 4).

The termination report for an

authorized committee must include:

• The disclosure of all receipts and

disbursements not previously

reported;

• A statement explaining how any

excess campaign funds will be

used and, if applicable, whether

the funds will be used for the

individual’s duties as a federal

officeholder; and

• A statement, signed by the

treasurer, verifying that any

remaining noncash assets will not

be converted to personal use.

11 CFR 102.3(a).

After filing a termination report,

however, the committee must

continue to file regularly scheduled

reports until it receives notice from

the FEC that the termination report

has been accepted.

Committees That Have Debts But

Want to Terminate

A terminating committee—that

is, a committee that raises contributions and makes expenditures only

for the purpose of paying debts and

winding-down costs—can eliminate

its debts in one of two ways: It may

assign its debts to another committee of the same candidate, or it may

settle them for less than the amount

owed. 11 CFR 116.1(a), 116.2(a)

and 116.2(c)(3). These procedures

are explained below.

Assigning Debts to Another

Committee

To expedite termination, an

authorized committee that qualifies

as a terminating committee and has

no cash on hand or assets available

to pay its debts may assign them to

another authorized committee of

the same candidate, provided that: 1

• The assignment is permitted under

applicable state laws (e.g., laws on

debts and creditors);

• The committee assigning the debts

was organized for an election

already held;

• No later than 30 days before the

assignment takes effect, the

assigning committee notifies each

creditor in writing of the name and

address of the committee assuming

the debts; and

• The committee assuming the debts

notifies the FEC in writing that it

has assumed the obligation to pay

and report the debts. (The committee uses separate schedules to

report the debts and the contributions raised to retire them.)

Once the debts are assigned, the

assigning committee may terminate.

11 CFR 116.2(c)(3).

Settling Debts

An authorized committee may

extinguish its debts by settling them

for less than the amount owed if:

• The committee qualifies as a

terminating committee (that is, one

that raises contributions and makes

expenditures only for the purpose

of paying debts and winding-down

costs);

• The candidate does not have

another authorized committee with

enough funds to pay all or part of

the debts; and

• The committee files a debt settlement plan (see below), which is

subject to FEC review, and complies with the other rules governing debt settlement. 11 CFR

116.1(a), 116.2(a), 116.2(c)(1) and

116.7.

Note that a committee may not

terminate until the debt settlement

process is concluded.

Debts Subject to Settlement

The following debts may be

settled for less than the amount

owed in accordance with debt

settlement procedures:

• Committees making contributions

or expenditures in connection with

Presidential candidates file in the

states in which the Presidential

committee and the donor committee have their headquarters. 11

CFR 108.4. ✦

Reports

(continued from page 7)

1 Special rules apply to Presidential

candidate committees receiving public

funds. See 11 CFR 116.2(c)(3).
9

January 1997 Federal Election Commission RECORD

• Debts owed to commercial vendors;

• Salary owed to employees;

• Debts arising from advances by

individuals (e.g., campaign staff)

using personal funds or credit

cards to pay campaign expenses;

and

• Loans owed to political committees or individuals (including the

candidate). 11 CFR 116.7(b).

All such settlements must be

made in the ordinary course of

business. The Commission will

review them to ensure they are not

in violation of the Act or FEC

regulations. 11 CFR 116.2(a).

Debts Owed to Commercial

Vendors. A commercial vendor 2

(incorporated or unincorporated)

may settle a debt for less than the

amount owed provided that:

• Credit was initially extended in the

ordinary course of business (see

11 CFR 116.3);

• The committee undertook all

reasonable efforts to pay the debt,

such as raising funds, reducing

overhead and liquidating assets;

and

• The vendor pursued remedies to

collect the debt as vigorously as

those pursued to collect debts from

nonpolitical debtors in similar

circumstances. Remedies might

include, for example, late fee

charges, referral to a collection

agency or litigation. 11 CFR

116.4(d). The creditor is not,

however, required to pursue

activities that are unlikely to result

in the reduction of a debt.

Salary Owed to Staff. Unpaid

salary owed to a committee employee may be settled for less than

the amount owed or entirely forgiven, or alternatively it may be

converted to volunteer work if the

employee signs a statement agreeing

to the arrangement. 11 CFR 116.6.

Other Amounts Owed to Staff and

Other Individuals. When a committee owes money to staff or other

individuals who have used personal

funds to pay expenses on the

committee’s behalf, these debts may

be settled for less than the amount

owed or entirely forgiven. 11 CFR

116.5(d). For more information,

order the Staff Advances handout,

which is available through Flashfax

(document 317). The Flashfax

number is 202/501-3413.

Loans from Individuals and

Political Committees. Loans (except

bank loans—see below) may also be

settled for less than the amount

owed or entirely forgiven. 11 CFR

100.7(a)(1).

Creditor’s Right

A commercial vendor or other

creditor—including a committee

employee—is not required to settle

or forgive debts owed by a committee. 11 CFR 116.4(e), 116.5(d) and

116.6(b).

Debts Not Subject to Settlement

Two categories of debts may not

be settled for less than the amount

owed but must be disclosed in a

debt settlement plan:

• Bank loans (including lines of

credit);3 and

• Repayment obligations of publicly

funded campaigns. 11 CFR

116.7(c).

Debt Settlement Plans

Debt settlement plans are filed on

FEC Form 8. Step-by-step instructions for completing Form 8 are on

the back of the form. See also the

example of a completed Form 8 in

the Campaign Guide for Congressional Candidates and Committees,

pages 57-60.

The Commission recommends

that committees include as many

settlement agreements as possible in

one plan. 11 CFR 116.7(a).

A committee must postpone

making actual payments to creditors

until after the Commission has

reviewed the debt settlement plan.

Moreover, the committee must

continue to report its debts until the

Commission has completed its

review. 11 CFR 116.7(a) and (d).

Once the Commission has

reviewed the debt settlement plans,

the committee may pay the creditors

the agreed-upon amounts and then

file a termination report.

Bankruptcy

If a candidate or committee is

released from debts through a

bankruptcy court decree pursuant to

11 U.S.C. Chapter 7, the committee

must include in a debt settlement

plan the court order and a list of the

obligations from which the committee is released. 11 CFR 116.7(g).

Disputed Debts

A disputed debt is a disagreement

between a creditor and a committee

as to the existence of a debt or the

amount owed. If something of value

was provided, the committee must

continue to report the following

information on Schedule D until the

dispute is resolved:

• The amount the committee admits

is owed;

• The amount the creditor claims is

owed; and

• Any amounts the committee has

paid the creditor.

The committee may note in its

report that disclosure of the disputed

debt is not an admission of liability

or a waiver of its claims against the

creditor.

Note that, in a debt settlement

plan, a terminating committee must

2 A commercial vendor is a business or

an individual who provides goods or

services to a candidate or political

committee and whose usual business is

the provision of those goods or services. 11 CFR 116.1(c). (continued)

3 The Commission recognizes that,

under extraordinary circumstances,

such as the death or bankruptcy of the

candidate, settlement of a bank loan

may be appropriate. The Commission

will consider specific situations on a

case-by-case basis.
10

Federal Election Commission RECORD January 1997

describe any disputed debts and the

committee’s efforts to resolve them.

11 CFR 116.10.

Unpayable Debts

If a committee has an outstanding

debt that is at least two years old

and that cannot be paid because the

creditor has gone out of business or

cannot be located, the committee

may request an FEC determination

that the debt is unpayable. See

11 CFR 116.9 for further details.

Administrative Termination

An authorized committee that is

inactive and wishes to terminate but

cannot reach settlement agreements

with its creditors may ask the FEC

for administrative termination. See

11 CFR 102.4 for further details.

If you have any questions, call

the Information Division at 800/

424-9530 (press 1 if using a touch

tone phone) or 202/219-3420. ✦

Advisory

Opinions

AO 1996-35

Status of Greens/Green

Party USA As National

Committee of Political Party

The Greens/Green Party USA (G/

GPUSA) does not conduct enough

national political campaign activity

to qualify as the national committee

of a political party.

G/GPUSA, which is headquartered in Blodgett Mills, NY, is

recognized throughout much of the

United States as the representative

organization of the Green Party

movement.

In this election cycle, it mounted

a presidential campaign with Ralph

Nader as its candidate. It ran eight

candidates for congressional seats in

five states. Mr. Nader appeared on

the ballot as the Green Party presidential nominee in 16 states. G/

GPUSA also is affiliated with 14

state organizations, publishes a

party journal, holds party conventions and maintains a website on the

internet.

The Federal Election Campaign

Act (the Act) defines a national

committee as the organization that,

by virtue of a party’s bylaws, is

responsible for the day-to-day

operations of that party at the

national level. 2 U.S.C. §431(14). A

political party, according to the Act,

is an association, committee or

organization that nominates a

candidate for election to federal

office and whose name appears on

the ballot as the candidate of that

group. 2 U.S.C. §431(16).

G/GPUSA qualifies as a political

party because its federal candidates

appeared on the ballot in several

states as the party’s nominees.

To obtain national committee

status, however, the Commission

relies on several criteria to determine whether a political party has

demonstrated sufficient activity on

the national level. Those criteria

include:

• Nominating candidates for various

Presidential and Congressional

offices in numerous states;

• Engaging in certain activities—

such as voter registration and getout-the-vote drives—on an

ongoing basis;

• Publicizing the party’s supporters

and primary issues throughout the

nation;

• Holding a national convention;

• Setting up a national office; and

• Establishing state affiliates.

A party cannot qualify for

national committee status if its

activity is focused only on the

Presidential and Vice Presidential

election, if the activity is limited to

one state or if the party has only a

few federal candidates on a limited

number of state ballots. On the other

hand, ballot access for Presidential

candidates is a prerequisite for any

organization trying to attain national

committee status.

In the case of G/GPUSA, it did

obtain ballot access for Mr. Nader,

but, through a unique set of circumstances, the party’s candidate

apparently did not qualify as a

candidate under the Act. Mr. Nader,

in an effort to avoid the FEC’s

registration and reporting requirements, said that he would campaign

for the presidency without meeting

the Act’s definition of a candidate.1

Because Mr. Nader is not a

candidate for purposes of the Act,

he also does not qualify as a candidate in evaluating G/GPUSA’s

status as a national committee. In

addition, G/GPUSA only achieved

ballot access in five states for eight

candidates seeking federal office in

1996—a level of activity deemed

too limited to qualify for national

committee status.

This conclusion means G/

GPUSA may not accept contributions from any donor for its federal

accounts that are greater than $5,000

per year. The Party and its committees also may not make expenditures

pursuant to 2 U.S.C. §441a(d).

G/GPUSA may approach the

Commission through the Advisory

Opinion process to inquire about its

status after it has expanded its

activities.

Date Issued: November 18, 1996;

Length: 4 pages. ✦

1

Under 2 U.S.C. §431(2), an individual

becomes a candidate for federal office

when that person, or his or her committee, receives contributions or makes

expenditures in excess of $5,000. Mr.

Nader stated that he would not spend

more than $5,000 in his campaign and

would not have to file with the FEC.

800 Line

(continued from page 9)
11

January 1997 Federal Election Commission RECORD

AO 1996-42

Disaffiliation of PAC After

Corporate Spin Off

Lucent Technologies Inc.’s

(Lucent’s) separate segregated fund

is no longer affiliated with AT&T

PAC, the SSF of its former corporate parent, AT&T Corp. Before

Lucent PAC can begin payroll

deductions to its own PAC, it must

ask for an affirmative response from

company employees who had

previously contributed to AT&T

PAC through payroll deductions.

Affiliation Status

The separation process began in

early 1996 and extended over

several months. AT&T incorporated

Lucent as a wholly-owned subsidiary and, on February 1, 1996,

began transferring some of its assets

and liabilities to Lucent.

In April 1996, AT&T offered

more than 112 million shares of

Lucent common stock in an initial

public offering. After this, AT&T

owned 82.4 percent of Lucent’s

common stock which it distributed

to its stockholders in September.

That distribution completed the

separation of the two companies and

AT&T and Lucent became two

publicly held companies.

FEC regulations state that SSFs

controlled by the same corporation,

including a parent or subsidiary, are

affiliated for purposes of the Federal

Election Campaign Act (the Act). 11

CFR 100.5(g)(2). That means they

share contribution limits. When an

entity is not an acknowledged

subsidiary of another entity, Commission regulations provide for an

examination of a number of factors

to determine whether one company

is an affiliate of another and, hence,

whether their respective SSFs are

affiliated. See 11 CFR

110.3(a)(3)(ii).

After the distribution of common

stock, Lucent PAC and AT&T PAC

no longer met many of the criteria

listed in 110.3 and, consequently,

were no longer affiliated. Any

factors indicating a continuity of the

relationship between the two

companies were substantially

outweighed by factors indicating

separate control of the companies.

AT&T had no ownership interest in

Lucent, no power to participate in

Lucent operations, no ability to vote

for Lucent’s board of directors and

no authority to control Lucent’s

officers or directors. As of the

distribution, there was no overlap of

directors, officers or employees.

With respect to the commonality

of AT&T and Lucent shareholders,

the requester anticipates that a

distinct difference in ownership will

result from the public trading of

Lucent stock.

Aggregating Contributions

When making contributions after

disaffiliation, both Lucent PAC and

AT&T PAC must take into account

their predistribution contributions.

AO 1993-23. To determine the

amounts that each PAC may contribute to the same candidate after

disaffiliation, the PACs must add

the amounts given by each PAC for

a particular election before disaffiliation and attribute that sum to their

respective contribution limits.

So, if before disaffiliation AT&T

PAC gave $2,000 to a candidate for

the general election and Lucent

PAC subsequently gave $1,000 to

the same candidate for the same

election (Lucent formed its own

PAC after it split from AT&T, but

before the disaffiliation had been

carried out formally), then the two

SSFs may each contribute just

$2,000 more to that candidate for

the general election.1

Similarly, Lucent PAC and

AT&T PAC must aggregate the predisaffiliation contributions of

employees with any post-disaffiliation contributions received from

those same employees. That would

mean that if a Lucent employee

gave $1,000 to AT&T PAC and

$1,000 to Lucent PAC during 1996,

that person could have contributed

only $3,000 more to Lucent PAC

during that year.2

Payroll Deduction

In anticipation of the spin-off,

Lucent informed its employees that

it planned to transfer their authorization for payroll deduction from

AT&T PAC to Lucent PAC. However, it gave employees the option

of canceling the payroll deduction

by returning termination forms that

the PAC distributed. For those

employees who did not return the

termination form, Lucent PAC

assumed consent and, in October,

deducted the PAC contribution from

their paychecks.

This arrangement is not sufficient. Lucent PAC must obtain

express and separate payroll deduction authorizations from Lucent’s

eligible employees in order to

implement payroll deductions for

their contributions to Lucent.3

Lucent PAC may keep the funds

received prior to this advisory

opinion’s release (and for any

monthly payroll deductions not

immediately reversible due to

administrative difficulties)4

 from

those employees who did not give

1

A multicandidate PAC may contribute

up to $5,000 to any candidate per

election. 2 U.S.C. §441a(a)(2)(A).

(continued)

2

An individual may contribute up to

$5,000 to a multicandidate PAC during

a calendar year. 2 U.S.C.

§441a(a)(1)(C)

3

In AO 1989-16, the Commission

required a new company that had been

separated from its parent to get

reauthorization for contributions to the

new company’s SSF from those

employees who had contributed to the

parent company’s PAC through payroll

deduction.

4

In Lucent’s situation, the payroll

deductions in question are for October,

November and, possibly, December.
12

Federal Election Commission RECORD January 1997

AO 1996-45

Use of Campaign Funds for

Seminar on Community

Relations

Congresswoman Lucille RoybalAllard may use campaign funds to

pay travel expenses for consultants

who lead a seminar on racial and

ethnic relations that she intends to

sponsor in her district.

Congresswoman Roybal-Allard,

who represents California’s 33rd

District, plans to host a special

seminar that will focus on ways

participants can be more sensitive

and responsive to people from

different ethnic backgrounds and on

how the various groups can work

more effectively to promote racial

and ethnic harmony. The 33rd

District has diverse demographics

and the seminar may be especially

useful to nonprofit organizations

and city agencies that work with the

various populations.

The seminar will be free to

participants. One of the cities in the

congresswoman’s district is expected to donate the use of a conference room for the event. The

consultants who will speak at the

seminar will offer their services free

of charge if transportation and

lodging are made available. The

congresswoman’s staff members

will mail out the invitations, but

they will do so on their own time

and no congressional resources will

be used.

While Congresswoman RoybalAllard will sponsor the event in her

official capacity as a federal officeholder, the seminar will happen after

the November elections and will not

be used as a forum to highlight her

re-election campaign.

FEC regulations prohibit candidate committees from converting

excess campaign funds to personal

use of a candidate or of any other

person. 11 CFR 113.2(d). The rules

make clear, however, that campaign

funds may be spent to defray any

ordinary and necessary expenses in

connection with a person’s duties as

a federal officeholder. 11 CFR

113.2(a)

In this instance, the proposed

seminar is related to the

congresswoman’s duties as a federal

officeholder. The seminar is planned

as a community service, will be held

at least 30 days after the 1996

general election and will have a

direct relationship to public policy

matters that are of concern to

members of Congress. Thus, the

travel and hotel costs of speakers are

ordinary and necessary expenses

related to the seminar, and campaign

funds may be used to cover them.

The congresswoman’s campaign

committee, Lucille Roybal-Allard

Advisory Opinion Requests

Advisory opinion requests are

available for review and comment in

the Public Records Office.

AOR 1996-50

Disaffiliation between membership

organizations’ separate segregated

funds (Farm Credit Council, November 25, 1996; 10 pages plus 50-

page attachment)

AOR 1996-51

Qualification as a state committee of

a political party (Reform Party of

Arkansas, October 24, 1996; 1 page

plus 12-page attachment)

AOR 1996-52

Return of excess Congressional

campaign funds to original donors

and their resolicitation for gubernatorial campaign donations (Robert

E. Andrews for Congress Committee, November 11, 1996; 4 pages

plus 4-page attachment) ✦

Advisory Opinions

(continued from page 11)

affirmative consent to the payroll

deduction only under the following

circumstances:

• The employee must sign a deduction authorization form.

• The employee must approve any

past payroll deductions made by

Lucent PAC.

• Lucent PAC must receive an

employee’s affirmative response

affirmatively within 60 days of

receipt of this advisory opinion in

order to keep any prior deductions.

• Lucent PAC must refund all

deductions to employees who do

not respond within the 60 days and

must stop deducting PAC contributions from employees who do not

give their affirmative consent.

• Until Lucent PAC receives an

affirmative reply, it must place

prior unauthorized deductions in a

separate account from which it will

not make disbursements or maintain sufficient funds in its current

account to make refunds to employees without using those

amounts for other disbursements.

Date Issued: November 18, 1996;

Length: 9 pages. ✦

for Congress, must report the

expenditures related to the event as

other disbursements.

Date Issued: November 8, 1996;

Length: 3 pages. ✦
13

January 1997 Federal Election Commission RECORD

Information

Flashfax Menu

Flashfax documents may be ordered

24 hours a day, 7 days a week, by

calling 202/501-3413 on a touch tone

phone. You will be asked for the

numbers of the documents you want,

your fax number and your telephone

number. The documents will be faxed

shortly thereafter.

Disclosure

301. Guide to Researching Public

Records

302. Accessibility of Public Records

Office

303. Federal/State Records Offices

304. Using FEC Campaign Finance

Information

305. State Computer Access to FEC

Data

306. Direct Access Program (DAP)

307. Sale and Use of Campaign

Information

308. Combined Federal/State

Disclosure Directory 1996 on

Disk

309. Selected Political Party Organizations and Addresses

310. Internet Access to the FEC

311. Downloadable Databases via the

Internet

Limitations

315. Contributions

316. Coordinated Party Expenditure

Limits

317. Advances: Contribution Limits

and Reporting

318. Volunteer Activity

319. Independent Expenditures320.

Local Party Activity

321. Corporate/Labor Facilities

322. Trade Associations

323. Foreign Nationals

324. The $25,000 Annual Contribution Limit

325. Personal Use of Campaign

Funds

Public Funding

330. Public Funding of Presidential

Elections

331. The $3 Tax Checkoff

332. 1993 Changes to Checkoff

333. Recipients of Public Funding

334. Presidential Fund Tax Checkoff

Status

335. Presidential Spending Limits

Compliance

340. Candidate Registration

341. Committee Treasurers

342. Political Ads and Solicitations

343. 10 Questions from Candidates

344. Filing a Complaint

345. 1996 Reporting Dates

346. 1996 Congressional Primary

Dates

347. 1996 Special Election Reporting

Dates

Federal Election Commission

401. The FEC and the Federal

Campaign Finance Law

402. La Ley Federal relativa al

Financiamiento de las Campañas

403. Federal and State Campaign

Finance Laws

404. Compliance with Laws Outside

the FEC’s Jurisdiction

405. Biographies of Commissioners

and Officers

406. Telephone Directory

407. Table of Organization

408. Index for 1995 Record

Newsletter

409. Free Publications

410. Personnel Vacancy

Announcements

411. Complete Menu of All Material

Available

Clearinghouse on Election

Administration

424. List of Reports Available

425. Voting Accessibility for the

Elderly and Handicapped Act

426. National Voter Registration Act

Regulations

427. National Voter Registration Act

of 1993

428. The Electoral College

429. Organizational Structure of the

American Election System

430. Primary Functions of an

Electoral System

Money in Politics Statistics

525. 1991-2 Political Money

526. 1995 Mid-Year PAC Count

527. 1993-4 Congressional

528. 1993-4 National Party

529. 1993-4 PAC Finances

530. 1995-6 Congressional

531. 1995-6 National Party

532. 1995-6 PAC Finances

1996 Presidential Election

550. 1996 Presidential Primary Dates

551. Selected 1996 Campaign Names

and Addresses

552. Selected 1996 Campaign

Finance Figures

553. 1996 Matching Fund Certifications and Convention Fund

Payments

554. 1996 Presidential General

Election Ballots

Regulations (11 CFR Parts 100-201)

100. Part 100, Scope and Definitions

1007. Part 100.7, Contribution

1008. Part 100.8, Expenditure

101. Part 101, Candidate Status and

Designations

102. Part 102, Registration, Organization and Recordkeeping by

Political Committees

1021. Part 102.17, Joint Fundraising

by Committees Other Than SSFs

103. Part 103, Campaign Depositories

104. Part 104, Reports by Political

Committees

1047. Part 104.7, Best Efforts

105. Part 105, Document Filing

106. Part 106, Allocations of Candidate and Committee Activities

107. Part 107, Presidential Nominating Convention, Registration and

Reports

108. Part 108, Filing Copies of

Reports and Statements with

State Offices

109. Part 109, Independent Expenditures

110. Part 110, Contribution and

Expenditure Limitations and

Prohibitions

1101. Part 110.1, Contributions by

Persons Other Than Multicandidate Political Committees

1102. Part 110.2, Contributions by

Multicandidate Committees

1103. Part 110.3, Contribution

Limitations for Affiliated

Committees and Political Party

Committees; Transfers

1104. Part 110.4, Prohibited Contributions

1105. Part 110.5, Annual Contribution

Limitation for Individuals

1106. Part 110.6, Earmarked Contributions

1107. Part 110.7, Party Committee

Expenditure Limitations

1108. Part 110.8, Presidential Candidate Expenditure Limitations

1109. Part 110.9, Miscellaneous

Provisions

1110. Part 110.10, Expenditures by

Candidates

(continued)
229. Candidate Debates and News

Stories

230. Electronic Filing of Reports by

Political Committees

231. DSCC and DCCC Rulemaking

Petition

Forms

361. Form 1, Statement of Organization

362. Form 2, Statement of Candidacy

363. Form 3 and 3Z, Report for an

Authorized Committee

364. Form 3X, Report for Other Than

an Authorized Committee

365. Form 5, Report of Independent

Expenditures

366. Form 6, 48-Hour Notice of

Contributions/Loans Received

367. Form 7, Report of Communication Costs

368. Form 8, Debt Settlement Plan

369. Form 1M, Notification of

Multicandidate Status

Schedules

370. Schedule A, Itemized Receipts

371. Schedule B, Itemized Disbursements

372. Schedules C and C-1, Loans

373. Schedule D, Debts and Obligations

374. Schedule E, Itemized Independent Expenditures

1111. Part 110.11, Communications;

Advertising

1112. Part 110.12, Candidate Appearances on Public Educational

Institution Premises

1113. Part 110.13, Nonpartisan

Candidate Debates

1114. Part 110.14, Contributions to

and Expenditures by Delegates

and Delegate Committees

111. Part 111, Compliance Procedure

112. Part 112, Advisory Opinions

113. Part 113, Excess Campaign

Funds and Funds Donated to

Support Federal Officeholder

Activities

114. Part 114, Corporate and Labor

Organization Activity

115. Part 115, Federal Contractors

116. Part 116, Debts Owed by

Candidates and Political

Committees

200. Part 200, Petitions for Rulemaking

201. Part 201, Ex Parte Communications

Recent Actions on Regulations,

Including Explanations

and Justifications

227. Presidential Nominating

Conventions

228. Public Financing of Presidential

Primary and General Election

Campaigns

375. Schedule F, Itemized Coordinated Expenditures

376. Schedules H1 –H4, Allocation

377. Schedule I, Aggregate Page

Nonfederal Accounts

U.S. Code (Title 2)

431. Section 431 442. Section 442

432. Section 432 451. Section 451

433. Section 433 452. Section 452

434. Section 434 453. Section 453

437. Section 437 454. Section 454

4377. Section 437g 455. Section 455

438. Section 438

439. Section 439

441. Section 441

4411. Section 441a

4412. Section 441b

4413. Section 441c

4414. Section 441d

4415. Section 441e

4416. Section 441f

Advisory Opinions

601-41. AOs 1996-1 through 1996-41

700. Brochure

701-49. AOs 1995-1 through 1995-49

801-40. AOs 1994-1 through 1994-40

901-25. AOs 1993-1 through 1993-25

Federal Election Commission RECORD January 1997

14
Index

The first number in each citation

refers to the “number” (month) of

the 1997 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

1996-35: Status of Green Party as

national committee, 1:10

1996-42: SSF disaffilation following corporate spin off, 1:11

1996-45: Use of campaign funds,

1:12

Court Cases

FEC v. _____

– Christian Action Network, 1:5

– Fund For a Conservative Majority,

1:5

– Parisi, 1:4

_____ v. FEC

– DCCC (96-0764), 1:4

– DNC (96-2506), 1:5

– DSCC (96-2184), 1:2

– Hooker, 1:5

– NRCC (96-2295), 1:2

– Reilly, 1:4

Reports

Schedule for 1997, 1:6

800 Line

Debt settlement and committee

termination, 1:8

January 1997 Federal Election Commission RECORD

15
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Federal Election Commission RECORD January 1997