February 1994

Ta Ie of Co ten 5

onfere nces

Washington, New Orleans and

Pittsburgh Conferences

Advisory Opinions

our t Cases

2 New Litigation

Audits

2 Audit Report on '92 New York

Host Committee

pecial Elections

3 Oklahoma's 6th ongressional

District

Compliance

5 MUR 36 19: Post-Election

Contributicns Exceed arnpaign

Debl

5 MURs Released to the Public

Regulati ons

6 Status of Regulations Projects

7 Task Force 10 Study Impact of

Allocation Rules

7 Index

Correction

The heading of one reporting

table in the January Record was

incorrect. The heading on page 5

should have read: " 1994 Monthly

Reports" (not " 1993 Monthy

Reports"), The reporting dales

within the tnble were correct,

Federal Election Comm ission

Conferences

Upcoming Conferences in

Washington, New Orlean s

and Pitt. burgh

T he FEC wi ll hold a conference

for candidate comm ittees on February 1I in Washington. DC. T he

agency will also hold two regional

conferences, a M arch conference in

New Orleans and an A pri l conference in Pittsburgh.

The conference offer basic and

advanced work shops on the federal

campaign finance law and provid e

an opportunity to di cuss problem

and questions wi th FEC Commissioners and staff.

For more information. or to order

registration material for any of the

conferences, call the FEC : 800/424-

95 0 or 202/2 19- 420.

Wa hington . 0 , onfere nce for

.a nd ida te ommi ttee

On Fri day, February I I, the FE

wi l l hold a day -long conferenc

designed to help candidates and

campaign staf f comply with the

federal election laws. In addition.

repre entati ves from the Internal

Revenue Serv ice and the ongressional ethics committees wi ll brief

auendees on the applicable lax laws

and House and enate rul es, re peeti vely. T he Hatch Act w i ll be

(continlied fill page 2)

Volume 20. Number 2

AO 1993-18

or po rate Plan to Foste r

Political Participati on

Southwestern Bell Corporation

(S8 ) and it s subsidi arie may

institute a program to encourage

employees and stockholders to

volunteer on behalf of candi dates'

campaigns, but may not offe r the

program to retirees Or to the general

publ ic.

sac and its subsidiarie plan to

ask every candidate running for a

part icular office how vo lunteers

could best help wi th his/her campaign, whom the vo lunteer should

contact and when they wou ld be

needed. T he companies would then

dissemi nate this informati on via

written communicatio ns or through

candi date inform ation booths er up

in company locations. Other a

companies might invite candidates

on a nonparti an basis to make

appearances at ornpany 10 arion .

at whic h time the company would

provide the relevant volunteer

in formal ion.

T he federal electio n law prohibits

cor porate contributions and expenditu res in connection with federal

electio ns. 2 U.S. . §44 1bta):

«("0111;1/1/1'(/ 0 11 page 3 )
~Jtr Election CllmmlSS;on RECORD

Conferences

tcominued from page J,

cove red by a represenrau ve from the

Office of Special Counsel.

If space a llows. the FEe will

accept on-sire registratio ns from

8:00 10 8:30 the morn ing of the

conference. A S10 late fee will be

added to the SI05 conference fee.

(The $10 fee will be added 10 all

reg istrati ons received after January

28.) The confere nce fee covers

materials. breakfast (conti nental)

and lunch.

The conference will be held at rbe

Wash ington Hillon and Towers.

19 19 Connecticut Avenue , NW.

w ashington. DC 2()())9(202n97·

5820). To receive the gro up rate of

S125 per night for a sing le roo m.

notify the borel rhar you will be

anending the FEC conference.

New Orleans a nd Pittsburgh

Regional Con fere nces

Th e New Orleans and Pittsburgh

conferences will include wo rkshops

for ca nd idates. PACs and party

Federa l Electio n Commh lo ion

999 E Stree t. N\ \'

sh ~t on DC 20-163

R(jOj424-9530

20212 19-.1420

20212 19-3336 <TOO)

Trevor Potier, Chairman

Dann y I.. '-'eDonald,

Vice Chairman

J oan D. Ai kens. Commissioner

l ee Ann Eulot t, Commisxicner

J ohn Warren '-teGarr)",

Commissioner

Scott E. Th omas, Commissioner

John C. Surina, SlatTDirector

Lawrence 'I. l"oble, GC~n11

Counsel

Published by the Informalion

Division

Loui-.e D. Direcrce

Greg SCUll, Associate Edilor

2

committees. Each IY! da y con ference will featu re FEC Commissioners and staff, and lax experts from

the IRS.

The New Orleans conference will

be he ld March 14-1 5. at the Omn i

Royal Or leans. ThePinsburgh

conference is set for April 28-29, at

the Pittsburgh Vista Hotel.

The S115 reglstrarlon fee for each

co nfe rence covers three meals (two

cor uinema l breakfasts and a lunch)

and a reception. +

Court Cases

New Litig ation

Francis Froelich v. FEe

Plaintiffs see k a declaratory

judgment that the Federal Electi on

Ca mpaign ACI (FECA ) is unconstiunional 10 the extent thai it allows

House and Se nate candidate s to

solicit and accept co ntribu tions from

ou t-of-state donors. The plaintiffs

also ask the court 10 declare the

contributions from out-of-stare

donors unconstitution al. and to

prohibit further acceptance of such

contributions by the anno unced U.S.

Se nate candida tes from Virginia.

who are named in the suit.

The suit allege s that our-of-state

cam paign comri bunons deny

citize ns the rep resentation gua ranreed under the Constitution. Specifica lly. the plai ntiffs co ntend thai

out-of-slate contri butio ns impermissibly influence the e lection of

Senators. and ma y subsequently

di vide the loyalties of those Senators. This. they argue , v io leres:

• The 17th Amend ment 's guarantee

tha i IwOsenators from each stale

are "elected by the people thereof;"

• Article 5' s provision that each

sta le's citizens shall have "equa l

suffrage in the Senate:" and

ru ry 1994

• Th e Constlunion's separation of

powers doctrine. which ensures a

ba lanced represent ation of

inte rests.

If the cou rt determines marthe

I7l h Amendment's "elected by the

peo ple thereof ' does nOI ap ply to

campaign contributions. the

plaintiffs contend that Article I,

Section 4-which permits Congress

to regu late "The Time, Places and

Mencer of holding etecuons.i.v-;

should like wise 001 apply to contributions. If tha t were the case. the

plaintiffs argue. the FECA wou ld be

unconsu nn ional to the extent that it

reg ulates such co ntributions.

U.S. District Court for the

Eastern District of Virginia Alexandria Division, Civil Action No. 93-

1610-A. December 20. 1993. •

,

Audits

FEe Releases Audit Report

on '92 Host Committee

On November 10, 1993. the

Co mmission approved the final

audit re port on the New York ·9 2

Host Co mmittee , Inc.-the host

committee for the 1992 Democratic

co nvention. (Host commi uees are

established by cities hosting President ial nominating co nven tions to

encou rage commerce an d 10 project

a favora ble image o f the cit)" to

convention attendees. Unlike pan y

convention committees. host

committees do not rece ive public

funds.)

TIle audit report's find ings

inc luded:

• Appa ren t proh ibited contri butions

from two businesses outside the

New York metropolitan area,

which the ccmrrnnee subsequently

refunde d;

• Possible commingling of funds for

"con vention expenses" and "host
February /9

expen e ." \ hich ultimately

proved to be permi sible; and

• Failure 10 di clo e the actual alue

for certain in-kind contribution

received and the ource of interest

income; the Commis ion required

the committee 10 amend its report

accordingly.

The final audit report include an

executive summary of the

ommis ion' findings. Thi is the

fir t lime that the agenc ha

included uch a ummary in a mal

audit report. The agency believe

that the summar will make the

audit rep rt more acces ible to the

public.

he e\ York '92 rep rt i the

second final audit report from the

1992 election that the FE ha

relea ed. The first \ as the audit

report on the Agran for Pre ident

'92 committee. approved by th

ommission on June 8. 1993. +

Oklahoma pedal lection

klahorna ha cheduled the

follov ing pecial elections 10 fill the

6th Congre sional Di trierseat

formerl held b Glenn Engli h.

who resigned:

• larch 8 Primary

• pril Runoff

• Ma 10 eneral.

andidates and committee \ ho

plan 10 participate in the pecial

election hould call the FEC for

information on reporting requirement ( 0/ _4-9- 30 0r_0_1_ 19-

3420). +

- -------

5

(cantil/lied from pa~e /)

I I -R 114.2 b). orporations

may. however. make parti an and

nonpartisan communication ,

ubject to certain restriction .

II CFR 114. and 114. .

ince the ommunication

contemplated by SB cornpa nie

\ ould not fa or one candidate 0 er

another, the rules go emin nonparti an communication would apply.

Under those rules, a corporation

may communicate with its employee and stockholder. and \ ith the

general public. pro ided the corporation follov pecific guideline .

II -RI1 4.4.

lonparti an communications 10

the general public. a defined in

FE regulations, are limited 10:

oter regi tration and get-out-theVOle information; di tribution of

official registration or voting

materials: voting record not

prepared for the purpose of influencing an election: voter guide: and

nonpartisan andidate debates.

J I FR 114.4(b), (c) and (e). The

volunteer information S8 companies plan to obtain and distribute

doe not fall within these categorie .' In particular. the information

doe not qualify a a voter guide

becau e it include strategic campaign information regarding candidat . need for olunteer er ice

and the preferred liming of tho e

services. I I FR 114.4(b)(5). sa

re un, the BC companies may not

offer the volunteer information to

the general public.

The rezulation at I I FR 11 4.4

do not identify company retirees a

a separate group. di tinct from the

general public, so retiree rna not

recei e the information either.

I Prior consultation with and receipt of

information fro m candidate .' campaign wil! compromise the ability of

an F ofth SBC companies to mak e

indep ndent expenditures on behal of

these campaigns. I I CFR 109./(0 ) and

(b)(4)(i)(A ).

Federal Election Commission RECORD

The rule on nonpartisan communication ' to corporate emplo ees

and to kholders permit an additional class of ccmmunication-inonparti 'an candidate (or party)

appearances. nder I I CFR 114.4(a)

(2) . a corporation may inv ite ,

candidate 10 address it employee

and stockholder • pro ided other

candidates for the ame office who

reque t to appear are i en the arne

opportunit and the orzanization

(including employees. toe 'holder

and the SSF) does not endor e or

oppo e any candidate or solicit

contributions f r the candidate in

conjunction \ ith his/her appearance.

The element of the BC plan are

irnilar to the afeguard for nonpartisan communication . While the

information on how and \ hen to

olunteer may assist candid re '

campaigns, uch information. along

with the other elementary inform -

tion to be conveyed. may be proided a part of a nonparti an

appearance. Con equentl . the 8

ompanie rna offer the olunteer

information program to their

employees and stockholders.

Commissioners Joan D. Aiken

and Lee Ann Elliott filed concurrins

opinion . Date Is ued: December 9.

1993; Length: page plu t\ 0

2-pagc concurrences. +

I 3-2

Purcha e and Di tribution

of andidate Biography

The Campbell Victory Fund

( enator Ben ' ighthorse ampbell'

principal campaign commiuee) may

purcha e copies of 'enator ampbell' . biograph at a di count. and

distribute them as aifts to former

campaign taff and volunteers,

I i ounted Purcha

The incorporated publi her of the

biography plan to ell 100 copie of

the book to the campaign committee

at half price.

(continued 0 11 pag 4)

J
------

Advisory Opinions

cc"'l/ /l rfl p(Jg~ 3)

The federal elec tion law prohibits

corporate contributions and expenditures in connection with federal

elections. 2 U.S.c. §44lb(a). Under

FEC regulations. the terms "contriburien" and "expenditure" include

"the provision of any goods or

services without charge or at a

charge which is less than the usual

and normal charge for such goods or

services."}! CFR 100.7(a)(l)(iii).

In Adviso ry Op inions (AOs)

1992-24 and 1987-24. howe ver. the

Commission concluded that complimentary items or discounts thai

were ava ilable to others on eq ual

terms or were offered as part of a

pre-existi ng busi ness relationship

did not result in co ntributions. Since

the half-price discount offered to the

Campbell campaig n is available to

o ther similarly-situated customers.

the discount is nOI a prohibited

corporate contribution from the

publisher.

Distribution

The Campbell campaig n plans (0

distribute co pies of the biog raphy as

a " thank you" to supporters and

volunteers who helped with the

Senator 's campaign.

The Commission has. in a

number of AOs. app roved distribution plans simi lar to the one proposed by the Campbe ll campaign

becau se they were camp aign related .

(See. for example. AOs 1983-53 and

1980-12.>

As a rule, the Commission

afford s each campaig n wide d iscretion in determining how best to

expend its resources. barring only

those expenditures thai represent a

prohibited conversion of excess

campaign funds to personal usc.'

2 U.S.C §439a; I I CFR 113.2. In

AO 1981-2. the Commission slated

"Senator Call1pMl/ receives flO'0)'01-

ties (lr profits from ,h, jQ/~ of,h, t;.(I(It .

,

that costs for activities tha i had "an

election influencing purpose, either

retrospective or prospect ive"

constituted expenditures. In accordance with these precedents. the

Campbell Victory Fund may offer

copies of the Senator 's biography as

gifts to forme r staff and volu nteers.

Date Issued: December 9, 1993;

Length: 3 page s. +

"0 1993-21

Preemption of Ohio Law

The federal election law preempts

an Ohio stat ute that effecti vely

prohibits the transfer of tax-checkoff

funds from a "separate segregated

accou nt" to an allocation account. as

prescribed in the FEC s alloca tion

regulations.

Back grou nd

Under Ohio law. each political

party receives a share of the pro -

ceeds from the state 's income tax

checkoff. The parties must deposit

these checkoff funds into a "separate segregated accou nt." and may

not commingle them with any o ther

party funds. Checkoff funds may

o nly be used to support party

activities. including the party's

adm inistrative and ge t-out-t he-vote

expe nses. The funds may not be

used to further the election or defeat

of any part icular ca ndida te or to pay

a party debt incurred as the result of

an election.

Expenditures for acministrauve

and get-out-the-vote activ ities and

other. simila r expenditures perrms- sible under state law are subjec t to

the FEC' s allocation rules. Those

rules require committees thai

maintain separa te fede ral and

nonfcdcral accounts to allocate

ce rtain sha red federal/nonfede ral

expenses according to specific

formulas. I I CFR 106.5and 106.6.

With regard 10 shared expenses.

com mittees have IWO payment

options under the alloc ation rules:

Frbruar." /994

• They may use the ir federal account

to pay a shared expense and

transfer in the approp riate amount

of nonfede ral funds: or

• The y may transfer the appropriate

amounts of federal and nonfedera l

funds into an allocation account

establis hed solely to pay shared

expenses.

The Ohio Republican Party's use

of the allocation account resulted in

com m ingling fede ral and nonfederal

funds. Since Ohio state law prohibits the commingling of tax-checkoff

funds. but limits the use of those

funds to expenses that are subject to

the FECs allocation rules. there is a

conflict between state and federal

law .

P.-eemption

The Federal Election Campaign

Act (FECA) and FEC regulations

"supersede and preempt any provision of State law with respect to

e lection to Federal office:' 2 U.S.c.

§453 : I I CF R 108.7(.). Specifically. federal preemption extends 10

"the organization and registration of

political com mittees suppo rting

Federal ca nd idates, disclosure of

receipt s and expe nditures by Federal

candida tes and political committees.

and the limitation on contributions

and expendi tures regarding Federa l

candidates and political committees:' II CFR 108.7(b). Therefore.

fede ral law preempts the Ohio

provision that purport s to bar the

transfer of tax-checkoff funds from

the party 's "separate segregated

accou nt" 10 its allocation account.

Consequently. the Ohio Republican

Party may transfer tax-checkoff

funds into its allocation account in

accordance with FEC rules. However. nothing in the FECA or FEC

rules preve nts the state from auditing the use of state revenues to

ensure compliance with stare laws.

T a\. -Check off Funds

Furthermore. in keeping with

Commission precedent. the party

may treat tax-checkoff fund s as

•
I

federal dollars, applicable to the

federal share of the allocable

e xpenses.' The Commission noted

that the tax-checkoff funds. though

not con tributions, did not exceed the

FECA's limits and were derived

from permissible federal sources,

i.e. revenues gene rated by designations made by indiv idual taxpayers.

Date Issued: December 10, 1993:

Length: 8 pages. Comm issioner

Trevor Potter submitted a disse nting

opinion (4 pages). +

Advisory Op inion Requests

The advisory opinion requests

(AORs) listed below are available

for review and comment in the

FEe 's Public Records Office .

AO R 1993·2 4

Effect of revi sed membership rules

on SSF solicitations. (National Rifle

Association: December 16, 1993 :

I page plus anachrnents)

AOR 1993·25

Preemption of state law limiting

contributio ns by lobbyists 10 fede ral

candidates who hold state office.

(Robert T. Welch; December 22.

1993: 2 pages) +

I Su./o,. example , AO 1991·14 .

Compliance

M UR 3619

Post- Election Contr ibutions

Exceed Ca mpaign Debt

The Hoosiers for Tim Roemer

committee agreed to pay a $3,900

civil pena lty for failing to re fund or

seek redesignation of post-election

cont ributions that exceeded the

campaign 's net debts outstanding. in

violation of 2 USc. §44 la (f).

Unde r FEC regulations. a candidate may accept contributions for a

panicular elect ion after it has been

held , but onl y to the extent that the

contributions do not exceed the

campaign's net debts outstanding

and only if the contributions have

been designated by the contributors

for that election,' I I CFR I IO.l(b)

and 11O.2(b). A campaign's net

de bts outstanding consis t of unpaid

deb ts incurred with respect to the

election minus cash on hand. Should

a campaign receive designated postelection contributions exceeding its

outstanding debt. it must refund

them or ask the contributors to

redesignate their contributions for

another election within 60 days.

The Roemer committee accepted

$ 15.768 in post-general election

contributions that exceeded its net

debts, and failed to refu nd or seek

redesign ation of them. The committee contended that the Violation.

which date s back to the 1990

election. resulted from its misundcrstanding of the debt retirement rules.

Subseq uently. the committee

refunded the cont ributions. paid its

civil penalty and too k steps to

ensure that the violation did not

occ ur again. +

I A ll undesignated contribution made

afle,. an election COUfll S against lhe

donor:s limit[or the cundidate's next

electi on, I I CFR IIO.I (bH2}(ji).

Federal till Commission RECORD

~IU Rs Released to the Public

Listed below are FEC enforcement cas es (Maners Under Review

or MURs) recently re leased for

public revie w. The list is based on

the FEC press release of January 4,

1994. Files on closed MURs are

available for review in the Public

Records Office.

IUR 3619

Respondents: Hoo siers for Tim

Roemer Committee. John R. Gildea.

treasurer (IN)

Compla ina nt: FEC initiated (a udit

for cause)

Subj ect : Excessive contrib utions

Disposition : $3.900 ci vil penalty

MUR .1740

Responde nts: (a) Congressman Dan

Rostenkowskl (Il.); (b) Rostenkowski for Congress. Leo V. Magrini.

treasurer (Il.): (c) America's Leaders'

Fund. Stanley Harrison. treasurer

(DC); (d)-(x) (20 other respondent s)

Complainant: Dick Simpson (lL)

Subj ect: Authorized candidate

committee 's affiliation with leade rship PAC: corporate contributions:

failure to register and report

Disp osition : (aj-Ix) No reason to

believe

IU .1823

Respondents: Repub lican Party of

Dade County. Jorge RodriguezChomat. treasurer (FL)

Complainant: FEC initiated (audit

for cause)

Subj ect: Excessive co ntributions:

allocation of expenses; failure to

identify con tributors adequately

(best effo rts)

Disposition: Reason to believe but

took no further action +
federal EtecuonCommission Rt:CORD

Regulations

Status of FEC Regulations

Projects

The Commission is in the midst

of a particularly active regulatory

period with more than a dozen

ongoing projec ts on its decker. The

chart below provides information

regarding some of those projects.

In addition to those listed in the

chart, future projects include:

• Disclaimer Not ices ( II CFR

110.1 1) - draft Notice of Proposed

Rulemaking (NPRM) sched uled

for Commission consideration on

January 27;

• Recordkeeping a nd Reporting

(I I CFR Part s 102 and 104)-

drafting NPRM;

• Coordi na ted Party Ex pend itures

( 11 CFR 110.7) - finalizing draft

NPRM,

• Alloca tion or Trav el Ex pe nses

(I I CFR 106.3) - drafting NPRM;

and

February 1994

• Loans on Br okera ge Accounts -

researching whether to draft

NPRM.

Addi tional infor mation on the

status of FEC regulations may be

obtained by requesting Agenda

Document #93-10I from the FEC 's

Public Records Office. Call roll-free

800/424-9530 or locally 202/2 19-

4 140. +

Selected Current Regulato ry Projects

Most Recent Com ment Public

Regul ation s FR' Not ice Vue Date Heari ng Status

National Voter Registration Act Advance 11/1/93 Draft NPRM to be

(I I CFR Part 8) NPRM 2 consi dered soon

9/30/93 (see Nov. 93 Record)

58FR 51 132

Personal Use of Campaign Funds NPRM 11/15/93 1/12194 Co mments and testimony

( I I CFR Parts 100 and 113) 8/30193 under review

58 FR 45463 (see Jan. 94 Record)

Unauthorized Use of Ca ndidate 's NPRM 1/31 194 Commen ts under review

Name (I 1 CFR 102. 14) 12/1 5/93 (see Jan. 94 Record)

5SFR 65559

Compliance Procedures NPRM 9/24/93 10/20/93 Comments and testimony

(t 1 CFR Part 1t l) 7/8/93 under revie w

58 FR 36764 (see Dec. 93 Record)

Corporate/Labor Comm unications - NPRM 8/18192 10/ 14- 15192 Recommendations regardMCFL (I I CFR Part 114) 7/29/92 ing final rules expec ted

57 FR 33548 soon (see Dec. 92 Record)

Ex Parte Communications Revised Interim 12/10/93 4/1193 Comments under review

(I I CFR Part 20 1) Rules. 11 /10/93 (see Dec. 93 Record)

58 FR 59642

National Nom inating Convent ions NPRM 9/17/93 10/27/93 Recommendations regard-

(I I CFR Part 9008) 8/12193 ing final rules expected

58 FR 43046 soon (see Dec. 93 Record)

I Federal Register,

1No/ice of Proposed Rulemaking,
F~hruar.r /994

Task Force to Stud}" Imp act

of Allocation Rul es

On Dece mber 9, 199 3, the

Commission voted to crea te a task

force to ev aluate the efficacy of the

age ncy's rules for alloca ting shared

federal/nonfede ral expenses . The

task force will pass its findings on to

the Commissio n. The Commission,

in turn , will conside r whe ther to

amend the alloc ation regu lations.

after the 1994 elec tion cycle.

In the interim. committee s are

rem inded that they must fully

comply with the e xisting allocation

rules. The Commission previously

recogn ized the 1992 e lec tion cycle

as an adj ustme nt period , du ring

which the Comm ission gene rally

accepted goo d faith efforts to

comply with the allccaricn rules.

That adju stm en t period has ex pired.

The Commission now plans to

enforce the regulations strictly.

Committees that need assistance

in complying with the allocation

rules are encou raged to avail

themselves of the many information

resources the FEC offers. Committees may direct the ir reporting

qu estions to the Reports Analysis

Division (202/2 19 ·3580), and othe r

inqu iries to the Information Division

(202/21 9·34 20). Callers may reach

both offi ces toll-free at 800/424-

953 0. Those who wish to remain

ano nymous shou ld co ntact the

Information Division. Copies of the

special Allocation Supplement to

the Record ( revised December

1992) are also available upon

request. +

Index

The first number in each citati on

refers to the " number" (mo nth) o f

the 1994 Record issue in which the

article appeared. The second number,

following the colon, indicates the

page number in that issue . For

example. " I :4" mean s tha t the

artic le is in the January issue on

page 4.

Ad visory Op in ions

1993- 18: Corporate plan to foster

political pa rtici pation, 2:I

1993- 19: Retiring 1984 Presidenti al

debt. 1:13

1993-20: Purchase and distribution

of ca ndidate biograp hy, 2:3

1993-2 1: Preem ptio n of Ohio law ,

2:4

Cou rt Ca ses

FEC v.

- National Repu blican Senatorial

Committee (93 ·16 12).1 :12

- Williams, 1:12

v , FEC

- Cen ter for Responsive Politics,

1:12

- Froe lich, 2:2

- LaRouche (92 · 1100), 1:12

Repo rts

Sc hedule for 1994, 1:4: correction,

2: 1

800 Line Ar ticles

Registration by candidates and their

commi ttees, 1:)4

rd~l"al ElrClion COn/minion RECORD

Change of Address

Political Committees

Treasurers of registered

political commtnees automatically receive the Record. A

change of address by a political

commtnee (or any change to

information disclosed on the

Statement of Organization) must,

by law, bemade in writing on

FEC Fonn I or by letter. The

treasurer must sign the amendment and file it with the Secretary

of the Senate. the Clerk. of the

House or the FEe (as appropriale) and with the appropriate state

office.

Ot her Subscribers

Record subscribers who are not

registered political committees

should include the following

information when requesting a

change of address:

• Subscript ion number (located on

the upper left comer of the

mailing label);

• Subscriber's name:

• Old address: and

• New address.

Subscribers (other than

political committees) may correct

their addresses by phone as well

as by mail.