FEDERAL ELECTION COMMISSION

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August 1990 999E Street NW Washington DC 20463 Volume 16, Numb

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REVISED ALLOCATICN RULES

SEN!' TO CCHiRESS

On June 18, 1990, the Commission sent

to Congress revised regulations on the

allocation of expenses for activities that

jointly benefit federal and nonfederal

candidates and elections (11 CFR Parts 102,

104 and 106). The allocation rules will

apply to party committees, separate segregated funds and nonconnected committees if

the committee:

o Qualifies as a "political committee," as

defined under the Federal Election Campaign Act, and maintains separate federal

and nonfederal accountSj or

o Does not qualify as a "political committee" as defined under the Act but makes

disbursements for both federal and nonfederal elections.

New reporting forms, designed to

conform with additional disclosure requirements under the revised rules, were sent to

Congress on June 22, 1990. The final text

of the revised regulations ~1d the explanation and justification were published in

the Federal Register on June 26, 1990 (55

Fed. Reg. 26058).

The Commission anticipates that the

revised rules and forms will become effective on January 1, 1991, the beginning of a

new reporting year. Under 2 U.S.C.

§438(d), new rules must remain before Congress for 30 legislative days before being

prescribed. (Forms must be before congress

10 legislative days.) If the current Congress adjourns before the 30 legislative

days have elapsed, the Commission will have

to resubmit the rules at the beginning of

the 102nd Congress in January 1991. This

would delay their effective date.

1IVl'E: A SUDlDary of the revised rules

will appear in a future Record issue.

tmol DEBT SE'I".I'LEMENl' RULES

SENT TO CCN3RESS

On June 22, 1990, the Commission se

to Congress new regulations concerning

debts owed by candidates and political

committees. The agency prepared the ru

to ensure that the creation and settlem

of debts do not result in excessive or

prohibited contributions to the debtor

committees and to promote the timely pu

disclosure of such transactions. The n

rules at 11 CFR Part 116 replace curren

rules at section 114.10, which is being

removed. The Commission also sent to C

gress new reporting forms that implemen

new requirements on the disclosure of d

settlements. The forms were transmitte

June 28, 1990. The final text of the r

and the explanation and justification

(contin

REGUIATIOOS

1 Revised Allocation Rules Sent to

Congress

1 New Debt Settlement Rules Sent to

Congress

2 FEC to Initiate Rulemaking Proceeding 

Foreign National Issue

3 New Rules on computer Formats for

Presidential Audits Sent to Congress

3 FEDERAL REXiISTER N)TICES

4 REPORTING: Hawaii Special Elections

6 ADVISORY OPINIWS

a:xJRT CASES

9 Goland v. U.S. and FEC

11 FEC v. Chipman C. Bull for congress

11 Common Cause v. FEC (89-5231)

12 New Litigation

12 STATISTICS: National Party Committe

14 COMPLIANCE: MURs Released to the Pu

15 INDEX
August 1990 FEDERAL ELECTION COMMISSION

appeared in the Federal Register on June

27, 1990 (55 Fed. Reg. 26378).

Under 2 U.S.C. §438(d), new rules must

remain before Congress for 30 legislative

days before being prescribed. (Forms must

be before Congress 10 legislative days.)

If the current Congress adjourns before the

30 legislative,days have elapsed, the Commission will have to resubmit the rules at

the beginning of the 102nd Congress, which

would delay their effective date.

The principal areas in which new Part

116 differs from current rules (at section

114.10) are:

o qn1y committees preparing to terminate

will be permitted to settle debts;

ongoing committees will not be able to do

so.

o Special provisions have been added

regarding authorized committees

(including committees of publicly funded

Presidential candidates) that wish to

settle debts, terminate or assign debts

to another committee.

o New provisions address debts owed to

unincorporated .commercial vendors,

committee employees or other individuals

who have advanced funds on behalf of a

political committee.

o New provisions provide a detailed

explanation of procedures for submitting

debt settlement statements and the

information that must be included in a

statement.

o New provisions clarify the treatment and

reporting of disputed debts.

o New procedures address situations in

which a creditor has gone out of business

or a political committee has become

essentially defunct.

!Ul'E: A summary of the revised rules

will appear in a future Record issue.

Volume 16, Numb

FEe TO INITIATE RULEMlIKING PROCEEDING

Cf'I FOREIrn' NATICf'IAL ISSUE

On June 28; 1990, the Commission

instructed the General Counsel's Office 

prepare a draft Notice of Proposed Rulemaking concerning election-related activ

ties of domestic corporations partially 

totally owned by foreign national entiti

including corporations and individuals.

Under the Federal Election Campaign Act 

FEC regulations, foreign nationals are

prohibited from making contributions or

expenditures in connection with federal,

state or local elections. 2 U.S.C. §44

11 CFR 110.4(a). In advisory opinions, 

Commission has permitted domestic subsid

aries owned by foreign nationals to par

cipate in election activity provided tha

the funds used are not derived from fore

national sources and all election-relate

decisions are made by U.S. citizens. H

ever, the Co~ssion continues to receiv

advisory opinion requests that reflect

uncertainty about the legal status of

foreign-owned domestic subsidiaries. In

light of these requests, the Commission

voted to initiate a rulemaking proceedin

to open a dialogue on this question and

solicit public comment. The Commission

will be considering, in particular, whe

to limit the ability of domestic subsid

aries to participate in U.S. election

activity to those that are more than 50

percent American-owned.

Federal Election Commission, 999 E Street, Ntl, Washington, DC 20463

800/424-9530 202/376-3120 202/376-3136 (TOD)

Lee Ann Elliott, Chairman

John Warren McGarry, Vice Chairman

Joan D. Aikens

Thomas J. Josefiak

Danny L. McDonald

Scott E. Thomas

Walter J. Stewart, Secretary of the Senate

Ex Officio commissioner

oonnald K. Anderson, Clerk of the House of

Representatives, Ex Officio Commissioner

2
August 1990 FEDERAL ELECTION COMMISSION Volume 16, Numb

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NEW RULES 00 <mPUTER F'ORfIVl..TS PUR

PRESIDENTIAL AUDITS SENT 'IO C<:'lGESS

On June 22, 1990, the Commission sent

to congress final rules on the production

of computerized records maintained by

publicly funded Presidential candidates.

CUrrent regulations require that if a

publicly funded campaign maintains computerized financial records, the campaign

must provide the computer tapes to the FEC

when the agency conducts the mandatory

audit of the CODttee. During the 1988

election cycle, the Commission expended

considerable resources reformatting computer tapes submitted during the audit process. Reformatting the records delayed the

completion of certain audits and entailed

additional agency expense.

To smooth the process for the 1990

election cycle, the revised rules require

that computerized materials be submitted in

a format compatible with the FEC's computer

processing capability. The rules also list

the types of computerized information that

an audited committee must produce. Finally, the rules clarify that the committee,

not the Commission, must pay for the cost

of producing the materials in the required

format. Production costs, however, may be

treated as exempt compliance costs.

In connection with the ru1emaking, the

Commission prepared a document that sets

forth the technical standards for computerized records submitted to the agency on

magnetic tapes or diskettes. This document, lIComputerized Magnetic Media Requirements for Title 26 Candidates/Committees

Receiving Federal Funding," is available

from the FEC's Public Records Office or the

Audit Division.

The final rules and the explanation and

justification were published in the Federal

Register on June 27, 1990 (55 Fed. Reg.

26392). The Commission will announce the

effective date of the final rules after

they have been before Congress for the

required 30 legislative days. 2 U.S.C.

§438(d); 26 U.S.C. §§9009(c) and9039(c).

When the commission revises the rules

governing Presidential nominating conventions at 11 CFR Part 9008, it will include

parallel provisions requiring the production of computerized magnetic media by

publicly funded convention commdttees.

3

FEDERAL RroISTER OOl'ICES

Copies of Federal Register

notices are available from the Public

Records Office.

1990-5

Filing Dates for the New Jersey Special Elections (55 Fed. Reg. 18388,

May 2, 1990)

1990-6

11 CFR Parts 102, 104 and 106:

Methods of Allocation Between Federal

and Non-Federal Accounts; Payments;

Reporting; Transmittal of Final Rule

to Congress (55 Fed. Reg. 26058, June

26, 1990)

1990-7

Filing Dates for the Hawaii congressional Special Elections (55 Fed.

Reg. 25880, June 25, 1990)

1990-8

Filing Dates for the Hawaii Special

Senate Elections (55 Fed. Reg.

25881, June 25, 1990)

1990-9

11 CFR Parts 106, 9003, 9007, 9033,

9035 and 9038: Presidential primary

and General Election Candidates;

Technical Requirements for Computerized Magnetic Media; Transmittal of

Final Rule to Congress (55 Fed. Reg.

26392, June 27, 1990)

1990-10

11 CFR Parts 100, 104, 114 and 116:

Debts Owed by Candidates and Political Committees; Transmittal of Final

Rule to Congress (55 Fed. Reg. 26378,

June 27, 1990)
August 1990 FEDERAL ELECTION COMMISSION Volume 16, Numb

HAWAII SPECIAL ELECTIOOS

Hawaii will hold special Senate

elections and a special Congressional

election during september and November

1990.

The special Senate elections, held to

fill the seat of the late Spark M.

Matsunaga, are scheduled for September 22

(primary) and November 6 (general). Former

Representative Daniel K. Akaka was appointed to fill the seat of Senator Matsunaga

until a successor is elected in November.

A special Congressional election will

be held September 22 to fill the 2nd

Congressional District seat formerly held

by Mr. Akaka.

Reporting information is given below.

Authorized CoIIIni.ttees . Authorized committees of candidates

running in the special elections must file

reports according to the schedule given in

the tables below. All candidates known to

be on the ballot are automatically sent FEC

reporting forms.

Note that an authorized committee must

file notices on contributions of $1,000 or

more received after the close of books for

a pre-election report but more than 48

hours before the election. The notice must

reach the appropriate federal and state

filing offices within 48 hours after the

committee's receipt of the contribution.

For information on the content of the

notice, see 11 CFR 104.5(f).

PACs and party COllIDittees

Quarterly Filers. PACs and party

committees that report on a quarterly basis

during 1990 may have to file pre- and postelection reports if:

o The committee makes contributions or

expenditures in connection with a special

election during the coverage dates shown

in the tables; and

o The committee has not preViously

disclosed the special election activity

in an earlier report. 11 CFR 104.5(c}

(1)(ii) and (h).

4

Monthly Filers. PACs and party com

tees that file monthly during 1990 do no

have to file pre- and post-election repo

for the 2nd District special election in

September but are required to file those

reports for the November 6 election. In

addition, PACs may have to file 24-hour

reports on independent expenditures.

PAC Reports on Independent Expenditures. Any PAC (including a monthly fil

that makes independent expenditures in

connection with a specia~ election may h

to file a 24-hour report. This reportin

requirement is triggered when a committe

makes independent expenditures aggregati

$1,000 or more between 2 and 20 days bef

an election. The report must be filed w

the appropriate federal and state filing

offices within 24 hours after the expen

ture is made. For more information on t

reporting requirement, see 11 CFR 104.4(

and 104.5(g).

state Filing

In addition to filing with the appro

priate federal office--the Clerk of the

House, the Secretary of the Senate or th

FEC--commdttees filing Hawaii special el

tion reports must simultaneously file

copies of reports with the Hawaii state

office: campaign Spending commission, P

Box 501, Honolulu, Hawaii 96809.

Authorized committees of candidates

must file the entire report; other comm

tees must file only the portion of the

report that is applicable to the candid

(for example, the Form 3X Summary page a

any schedules that disclose contribution

or expenditures on behalf of the candidate). 2 U.S.C. §439(a); 11 CFR 108.3.

Reporting Waivers Apply only to

Certain Special Election Filers

The reporting waivers noted on the a

companying charts apply only to committ

filing certain Hawaii special election

reports.
FEDERAL ELECTION COMMISSION

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August 1990

IIl\WIII 2ND COOGRESSICIlAL DIS'llUCT

SPECIAL ELECTICIlS

I. Coomittees That SUpport candidates in

the Special General Election (Sept. 22) and

the Regular General Election (Nov. 6)

Reg/certl

Period l'Iail Due

Report Covered Date Date

pre-special2 7/1-9/2 9;7 3 9/10

Oct. Quarter!y ------------waived --------- Post-special 9/3-10/17 10/225 10/25

Pre-general ~------------waived--------- Post-general 10/18-11;26 12/6 12/6

II. Coomittees That SUpport candidates

only in the Special General Election

(Sept. 22)

Reg/cert1

Period l'Iail Due

Report Covered Date Date

pre-special2 7/1-9;2 9;7 3 9/10

Oct. Quarterly ----------waived ------- Post-special 9/3-10/12 10;22 10;22

lReports sent by registered or certified

mail must be postmarked by the mailing

date. Otherwise, they must be received by

the due date.

2I f the pre-special report is the first

report filed by the committee, the report

must disclose all activity that occurred

before the committee registered and before

the individual became a candidate.

3The quarterly reporting waiver applies

only to committees filing both the pre- and

post-special election reports.

4The coverage dates of the post-special

election report have been extended to cover

activity normally disclosed in the pregeneral election report, which has been

waived.

5The pre-general reporting waiver applies

only to committees filing the post-special

election report.

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Volume 16, Numb

IIl\WIII SENATORIAL SPECIAL ELECTlOO'

I. coomittees That SUpport candidates 

the Special Primary (Sept. 22) and the

Special General (Nov. 6)

RegjCertl

Period Mail Du

Report Covered Date Da

pre-primary2 7/1-9/2 9;7 3 9/

oct. Quarterly -----------waived -------

Pre-general 9/3-10/17 10/22 10

Post-general 10/18-11/26 12/6 12

II. Commi.ttees That SUpport candidates

only in the Special Primary (Sept. 22)

RegjCertl

Period Mail Du

Report Covered Date D

pre-primary2 7/1-9/2 9;7 9/

Oct. Quarterly 9/3-9/30 la/IS la

lReports sent by registered or certified

mail must be postmarked by the mailing

date. Otherwise , they must be recei ved 

the due date .

2I f the pre-primary report is the first

report filed by the committee, the repo

must disclose all activity that occurred

before the committee registered and befo

the individual became a candidate.

3The quarterly reporting waiver applies

only to committees filing both the

pre-primary and pre-general election

reports.
August 1990 FEDERAL ELECTION COMMISSION Volume 16, Numb

ADVISORY OPINIW Im;2UESTS

The following chart lists recent

requests for advisory opinions (AORs). The

full text of each AOR is available for

public review and comment in the FEC's

Public Records Office.

AOR 1990-12

use of poll results purchased by Congressional campaign volunteer. (Date Made

Public: June 28, 1990; Length: 4 pages)

AIJR 1990-13

Restoration of committee's exemption from

disclosure provisions previously granted by

court. (Date Made Public: July 6, 1990;

Length: 25 pages plus attachments (294

pages) and a correction/supplement (27

pages) )

AOR 1990-14

Use of 900-line telephone service for

campaign activities. (Date Made Public:

July 10, 1990; Length: 43 pages)

AOR 1990-15

Termination of defunct conunittee with

disputed debt. (Date Made Public: July

17, 1990; Length: 20 pages)

ADVISORY OPINIW SUMMARIES

AD 1989-32: Foreign National Contribution

to state Ballot Measure

CODnittee "Controlled" by

candidate

Californians for Safe streets (CSS), a

committee formed to pass a state ballot

measure, may not accept a contribution from

a foreign national because CSS activities

are viewed as related to the 1990 reelection campaign of Lieutenant Governor Leo

Mccarthy.

under the Federal Election Campaign Act

and FEC rules, contributions made by foreign nationals in connection with a United

states election are prohibited. 2 U.S.C.

§441e(a); 11 CFR 110.4(a). The Commission

has previously stated that contributions

relating exclusively to ballot referendum

issues, and not to any election for political office, are not within the Act's purview. See, for example, AD 19BO-95. In

this case, however, additional factors

indicate that ess activities are election

related and therefore subject to the foreign national prohibition.

6

Mr. McCarthy organi~ed css to promo

the passage of the Safe Streets Initiati

a ballot measure he helped draft. Unde

California law, CSS is a "controlled" co~ttee because Mr. McCarthy has sign

cant influence on its actions. Californ

law requires that CSS include the name o

the controlling candidate (Mr. McCarthy) 

its registration form, in reports filed

with the state and in committee mailing

200 or more pieces.

Although CSS has not expressly advo

cated his election or solicited support 

his behalf, Mr. McCarthy has organized e

and inextricably linked his name with CS

through CSS communications to the electo

ate at the same time he is seeking reelection as lieutenant governor. Going

beyond the state requirement, CSS has

issued press releases quoting Mr. McCar

and sent out personalized solicitation

letters signed by him. Finally, CSS and

Mr. MCCarthy's campaign committee have c

ordinated their efforts to such an exten

(e •g., ove rlapping key pe rsonnel) that t

two appear to be functioning as one

committee.

The Commission concluded that, based 

these facts, the activities of ess are

related to Mr. McCarthy's campaign. Co

sequently, CSS may not accept a contribu

tion from a foreign national, even if it

were deposited in a separate account th

was not used to pay expenses associated

with materials that include the candida

name. (Date issued: July 2, 1990; Len

8 pages}

NJ 1990-7: Transfer from candidate's

Former Presidential Explora

cOlllllittee to 1990 House

COlllllit tee

The Schroeder Fund for the Future, Inc.

(the Fund), originally established in 19

as a testing-the-waters committee for R

resentative Patricia Schroeder's possib

Presidential candidacy, may not make un

°ited transfers of funds to Ms. Schroede

1990 House campaign committee, based on

information provided by the requester co

cerning the purpose and activities of th

Fund and its relationship with MS.

Schroeder's House committee.

As represented in the advisory opini

request, the Fund was formed in 1987 to

conduct testing-the-waters activities an

was then called ItSchroeder 19887". When

Ms. Schroeder announced in September 19

that she would not be a 1988 Presidenti

candidate, the Fund changed its name, be

to "wind down" its exploratory activitie

and announced that the Fund would suppo
FEDERAL ELECTION COMMISSION

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August 1990

Ms. Schroeder's efforts to speak on issues

of national interest. A fundraising mailing for the Fund was conducted in February

1989. (Ms. Schroeder was House candidate

in 1988 and is a 1990 candidate for the

same office.)

Commission regulations at 11 CFR

110.3(c)(4) permit transfers without limit

between a candidate's previous and current

federal campaign committees (provided that

the individual is not a candidate for more

than one federal office at the same time).

The Fund, however, does not qualify as a

previous federal campaign committeee, which

is defined as a principal campaign committee or other authorized committee organized

to further the candidate's campaign in an

election already held. 11 CFR Il0.3(c)(4)

(i). In this case, the Fund was not an

authorized committee in any election. Ms.

Schroeder did not become a 1988 Presidential candidate, assuming that amounts

received and spent by the Fund qualified

for the testing-the-waters exemption under

11 CrR 100.7(b)(1) and lOO.8(b)(1). Moreover, she did not authorize the Fund to

receive contributions or make expenditures

for her 1988 House candidacy. Because the

Fund does not meet the definition of a

previous federal campaign committee under

11 CFR ll0.3(c)(4), the Fund may not rely

on that regulation for the purpose of

transferring unlimited amounts to the

Schroeder for Congress Committee.

Assuming that the Fund and the

Schroeder for Congress Committee are not

affiliated, as asserted by the requester,

any transfers from the Fund to the

Schroeder for Congress Committee will be

treated as contributions, subject to a

$1,000 per election limit. 2 U.S.C.

§44la(a)(1)(A); 11 crn 1l0.1(b)(1). If the

Fund contributes more than $1,000, it will

trigger political committee status.

2 U.S.C. §43l(4); 11 CFR 100.5(a).

Concerning the limit on the Fund's

transfers, the Commission based its conclusion on the requester's assertion that

the Fund and the Schroeder for Congress

Committee are not affiliated. The Commission's acceptance of this assertion for

purposes of the opinion "does not imply

[the agency'sI agreement with that assertion, nor with [the requester's] related

assertions that the Fund is not a 'political committee' and that it has not accepted

any 'contribution' or made any 'expenditure.' "

Although one of the indicia of affiliation under FEC rules is whether a committee

provides funds in a significant amount to

another committee, the Fund's contributions

7

Volume 16, Numb

in permissible amounts to the Schroeder 

Congress ~6mmittee would not, in and of

themselyes, jeopardize the assumed unaf

iated,status of the two organizations,

given the substantial cash-on-hand amou

of both the Fund and the Schroeder for

Congress Committee. 11 CFR 100.5(g)(4)

(ii)(G) and 1l0.3(a)(3) (ii)(G).

The Commission expressed no opinion 

the application of House rules or any ta

ramifications, since those issues are n

within its purview.

Commissioner Lee Ann Elliott filed 

dissenting opinion. (Date issued: June

18, 1990; Length: 9 pages, inCluding th

dissent)

AD 1990-8: Establishment of PAC by

Corporation Jolajority-Qwned 

Foreign Bank

The CIT Group Holdings, Inc. (CIT), a

Delaware corporation, may establish and

operate a separate segregated fund even

though 60 percent of CIT's stock is own

by Dai-Ichi Kangyo Bank Ltd., a Japanes

bank, and CIT's lO-member board include

five foreign national. members.

The Federal Election Campaign Act a

Commission regulations prohibit foreign

nationals from making contributions

(directly or indirectly) or expenditure

connection with any United States elect

2 U.S.C. §44le(a); 11 CFR 110.4(a). CI

however, because it is organized under

state law and has its principal place o

business in the United States, is not a

foreign national under 2 U.S.C. §441e a

22 U.S.C. §6ll(b). Therefore, CIT may

establish and operate a separate segreg

fund (CITPAC) provided that foreign nat

als are not solicited for contributions 

do not participate directly or indirect

in the decision-making process of CITPA

11 CFR 110.4(a) (3). See also ADs 1989

1983-31, -1983-19, 1982-34, 1981-36, 198

111, 1980-100 and 1978-21. To ensure th

exclusion of foreign nationals from par

cipation in PAC activity, foreign natio

board members must abstain from voting, 

just on matters concerning the PAC, but

also on the selection of individuals to

operate the PAC.

Commissioner Scott E. Thomas plans 

file a dissenting opinion. (Date issue

June 18, 1990; Length: 4 pages)
August 1990 FEDERAL ELECTION COMMISSION

N) 1990-9: Newsletter Published by

candidate as Sole Proprietor

Margaret R. Mueller, a 1990 House

candidate, may publish a newsletter as an

unincorporated sole proprietor, but funds

received and payments made to publish the

newsletter will result in contributions and

expenditures if the publication contains

campaign-related material.

In AO 1990-5, the Commission concluded

that publication of a newsletter published

by a .corporation owned by Ms. Mueller would

result in expenditures to influence her

election if:

o The newsletter directly or indirectly

referred to the candidacy, campaign or

qualifications for public office of Ms.

Mueller or her opponent;

o The newsletter contained articles or

editorials that referred to her views, or

those of her her opponent, on public

policy issues, or referred to issues

raised in the campaign; or

o The distribution of the newsletter were

expanded beyond its present audience or

in any manner that would indicate its use

as a campaign communication.

(See the June 1990 Record ~or a summary of

MJ 1990-5.)

Based on these criteria, the May 1990

issue published by Ms. Mueller would be

campaign related because it contained an

article expressing her views on public

issues and two articles on campaign issues.

Costs for producing and distributing the

entire issue would therefore constitute

expenditures.

As the candidate and unincorporated

sole proprietor, Ms. Mueller may make

unlimited expenditures from personal funds

for campaign-related issues of the newsletter. 11 CFR 110.10(a). The expenditures would be in-kind contributions,

reportable as both contributions from the

candidate and expenditures by the committee. 11 CFR 100.7(a)(1)(iii) and

104.13(a). Other funds received to pay for

the expenses of campaign-related issues,

including payments for advertising space,

would be considered contributions subject

to federal limits and prohibitions. (Date

issued: June 25., 1990; Length: 4 pages)

N) 1990-11: Publicly Funded Campaign's

Donation of Fundraising Items

to Staff and Charity

The Friends of Gary Hart--l988, Inc., the

publicly funded committee of Presidential

primary candidate Gary Hart, may donate

unused fundraising items--silver belt

buckles--and other excess campaign funds to

8

Volume 16, Numb

former campaign personnel and to charita

organizations. Before making the donations, however, the committee must first

repay public funds in amounts determined 

the Commission and also pay any possible

civil penalty assessments.

The silver belt buckles, as campaign

assets, may be treated as excess campaig

funds, which are defined as amounts

received by a candidate which he or she

determines are in excess of amounts need

to defray campaign expenses. 11 CFR

113.1(e). The donation of 40 belt buckl

and other excess funds to charities woul

be a permissible use of excess campaign

funds because the Federal Election Camp

Act and FEC regulations expressly provid

that excess campaign funds may be donate

to qualified charitable organizations.

2 U.S.C. §439a; 11 CFR 113.2. The same

provisions of the Act and regulations al

permit excess campaign funds to be used 

any lawful purpose except personal use.

The donation of the remaining nine belt

buckles to former campaign staff members

would not be considered personal use of

excess campaign funds and would qualify 

a lawful use of such funds.

However, the committee cannot make a

donations of excess campaign funds until 

has satisfied its public funding repayme

obligations and paid pOssible civil

penalties. The excess campaign fund pre

visions at 2 U.S.C. §439a and 11 CFR 113

do not supplant or supersede these requi

ments under the Title 26 public funding

law. AO 1988-5.

Although the Commission has already

determined that the committee must repay $35,789 in public funds, the committee m

have to repay additional public funds

because it failed to include the value o

the silver belt buckles in its Statement 

Net outstanding Campaign Obligations (NO

statement). A NOCO statement lists, amo

other items, a committee's total assets.

including the fair market value of fundraising items, and is used by the Commi

sion in determining a candidate's contin

eligibility to receive federal matching

funds to retire outstanding campaign

obligations. See 11 CFR 9034.5(g)(3). 

Hart committee representative informally

estimated that the belt buckles were wor

between $10,000 and $40,000. Because th

1988 committee has cash and other assets

that exceed its unpaid obligations, the

inclusion of the buckles' value in the N

statement could result in the committee

having to repay additional surplus publi

funds.
August 1990 FEDERAL ELECTION COMMISSION Volume 16, Numbe

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The Commission noted that it has

recently approved new debt settlement

regulations which, once prescribed, would

affect the proposed activities of the Hart

committee. Under these new regulations, if

the 1988 committee has assets that could be

used to defray the debts of Gary Hart's

1984 Presidential committee, the 1984

committee could not settle its debts and

the 1988 committee could not terminate.

These new rules will become effective when

the commission formally prescribes them.

(See the article on the new rules in this

issue. )

The commission also noted that this

advisory opinion would not affect remedies

available to creditors of the 1984 committee with regard to the assets of the 1988

committee. Debt claims and liabilities are

subject to relevant state law, and a committee's responsibility for satisfying

those obligations would have to be determined with reference to those laws. See AD

1989-2.

Commissioner Thomas E. Josefiak plans

to file a concurring opinion. (Date

issued: June 29, 1990; Length: 5 pages)

GOIAND v , U.S. AND FEC

on May 21, 1990, the U.S. Court of

Appeals for the Ninth Circuit affirmed the

district court's decision to dismiss the

suit and to deny appellant's motion to

certify constitutional challenges to the

Federal Election Campaign Act. (Civil

Action No. 89-55422.) Appellant Michael R.

Galand had claimed that the First Amendment

guaranteed his right to make unlimited

anonymous contributions to candidates.

Background (U.S. v. Galand)

On December 14, 1988, a federal grand

jury in Los Angeles indicted Mr. Galand for

violations of the Federal Election Campaign

Act and criminal statutes stemming from his

activities during the 1986 Senatorial election in California. According to the indictments, he advanced $120,000 to a media

company to produce advertisements for Ed

vallen, a third-party candidate for the

Senate seat. Mr. Galand actually wanted

Democratic Senator Alan Cranston to win the

election and financed the last-minute

Vallen effort in order to divert votes from

the Republican candidate, Ed Zschau. Mr.

Goland tried to conceal his identity as the

9

donor of the $120,000 contribution by fu

neling the money through 56 persons, who

were later reimbursed by Mr. Galand. Th

Vallen campaign, uninformed of the true

source of the contribution, reported the

money as contributions from the 56

individuals.

The federal grand jury indicted Mr.

Galand on criminal violations, charging

that he had knowingly and willfully caus

the treasurer of the Vallen campaign to

make false statements to the FEC for the

purpose of concealing his $120,000 contr

bution. 18 U.S.C. §§37l and 1001. Addi

tionally, Mr. Galand was charged with

Violating the Federal Election Campaign A

(the Act) by exceeding the $1,000 contribution limit and by making a contribution in the1name of another. 2 U.S

§§441a and 441£.

District Dourt Decision

On March 13, 1989, after the Decembe

1988 criminal indictment, Mr. Galand file

civil suit in the U.S. District Court fo

the Central D~strict of California. (Ci

Action No. 89-1480.) Pursuant to 2 U.S.C

§437h, he sought immediate certification 

the district judge of three constitution

challenges to the Act, as applied. He

claimed that the Act's contribution limi

and disclosure provisions violated his

constitutional rights. He further claim

that the First Amendment proctected his

right to make unUmited anonymous contri

tions to a third-party candidate. Mr.

Galand also sought a stay of the pending

criminal proceeding. On May'l, 1989, th

court dismissed the suit with prejudice,

finding that the Supreme Court had alread

adressed appellant's constitutional ques

(continu

1The first criminal trial, which conclad

on July 10, 1989, resulted in a mistrial

because of a hung jury. on September 19

1989, a federal grand jury returned a

superseding indictment charging addition

violations of the Act's contribution lim

and of criminal statutes. The second tr

ended on May 3, 1990. Mr. Galand was co

victed on one misdemeanor count of makin

an excessive contribution. He was acqui

ted on four other counts of conspiracy a

making false statements. The jury deadlocked on one felony count of making fal

statements. On July 16, 1990, Mr. Galan

received a federal prison sentence of 90

days on the one conviction (excessive

contribution) •
August 1990 FEDERAL ELECTION COMMISSION

tions in Buckley v. Valeo. Concluding that

the constitutional claims were frivolous

under Buckley, the court denied plaintiff's

motion for certification and stay. Mr.

Goland immediately filed an appeal.

Appeals Court Decision

On May 11, 1989, the appeals court

denied his motion for a stay of the

criminal trial but agreed to review the

district court's dismissal of the constitutional questions. In its opinion of May

21, 1990, the court affirmed the district

court's judgment, denying appellant's

constitutional challenges and dimissing the

suit.

Standing to Bring Challenge. The

appeals court first considered whether Mr.

Goland had standing to bring a constitutional challenge. The court found that

"Goland statisfies the traditional standing

criteria: he has alleged an actual or

threatened injury; that injury was caused

by the challenged act; and that injury is

apt to be redressed by a favorable decision." The court observed that "[aJ

successful constitutional challenge to FECA

provisions would give at least partial

redress to Goland."

constitutional Challenges. The appeals

court ruled that the district court was

acting within its discretion by dismissing

the suit once it found the constitutional

issues were frivolous. A complaint is

frivolous when none of the legal points are

arguable on their merits. In this case,

the issues raised by Mr. Goland had already

been resolved by the Supreme Court in

Buckley v. Valeo, 424 U.S. 1 (1976).

Appellant argued that Buckley did not

resolve the issues he raised. He claimed

that the reasoning the Supreme Court

applied in upholding the contribution

limits--to prevent quid pro quo corruption

or the appearance of corruption -did not

apply to his claim. There was no opportunity for exacting a quid pro quo deal since

he sought to keep his identity secret.

FUrther, because the candidate (Vallen) had

no chance of winning the election, he would

not be in a position to exchange official

favors for money.

The court rejected this argument,

pointing out that there is no assurance

that a donor's identity will remain secret

forever and, even if there were, the Act's

disclosure provisions prohibit anonymous

contributions exceeding $50. (See 2 U.S.C.

§432(c)(2).) Moreover, Buckley upheld the

application of contribution limits to minor

10

Volume 16, Num

party candidates as well as to candida

likely to win. Id. at 30-31.

Appellant Goland also argued that t

Act's discloure requirements as they re

to anonymous contributions to a third-p

candidate were unconstitutional on the

face and as applied to him. He based h

claim on the historic constitutional pr

tection given to anonymous political

speech, citing several Supreme Court ca

The court found that Mr. Galand cou

not avail himself of this protection. 

Supreme Court in Buckley carefully con

ered the danger posed by compelled disc

sure but held that state interests jus

fied the indirect burden imposed by the

Act's disclosure requirements on First

Amendment interests. The appeals cour

concluded: "the [Supreme J Court carved 

a narrow exception to the line of cases

Goland relies on, and that exception

encompasses Goland's activities."

In response to appellant's emphasi

the minor party status of the recipien

candidate, the court stated that the

Buckley Court provided an exception to 

disclosure provisions for those parties

that could show a "reasonable probabili

that disclosure would subject their co

butors to "threats, harassment, or rep

sals." Id. at 74. The appeals court no

that appellant Galand "[did] not even

attempt to make such a showing." The c

also observed that Mr. Goland "was not

promoting a reviled cause or candidate.

Finally, Mr. Galand argued that the

substantial state interests that the

Buckley Court found to justify the disclosure requirements did not apply to

anonymous contributions made to a cand

with whom the donor disagrees.

The appeals court found no merit in

this argument, observing that one purpo

behind the diclosure provisions is "to 

the electorate fully informed of the

sources of campaign funding .•..There is

valuable information to be gained by

knowing that Vallen took $120,000 from 

Cranston supporter." Another purpose

behind the Act's disclosure provisions 

"to gather the data necessary to detec

violations of the contribution limits."

The court said that if Galand's positio

were adopted, one could avoid the cont

tion limits simply by making an anonymo

contribution.
FEDERAL ELECTION COMMISSION

•

•

•

August 1990

FEC v. OIIPMIIN C. BULL FOR CONGRESS

on June 8, 1990, the U.S. District

Court for the District of Maine imposed

civil penalties on defendants Chipman C.

Bull for Congress, the principal campaign

committee for Mr. Bull's 1984 House

campaign, and Denise M. Deshane, the

committee treasurer, for violating several

provisions of the Federal Election Campaign

Act. (Civil Action No. 88-0037-B.) In

earlier rulings of September 13, 1989, and

January 9, 1990, the court found that

defendants had violated the law by:

o Knowingly accepting $8,937.50 in

excessive contributions from three

individuals whose contributions took

several forms--direct contributions,

guarantees of a $10,000 bank loan and

interest payments made on the loan

(2 U.S.C. §441a(f»;

o Failing to disclose the identification of

the three guarantors of the bank loan

(§434(b)(3)(E»; and

o Failing to meet the filing deadlines for

the two reports covering 1985 activity

(§434(a)(2)(B».

In its June 8 order, the court adopted

the civil penalties recommended by a United

States Magistrate and assessed a penalty of

$18,437.50 against the committee and a $500

penalty against the treasurer.

CAUSE v. FEC (89-5231)

on June 19, 1990, the U.S. court of

Appeals for the District of Columbia

Circuit reversed a district court decision

by ruling that the FEC did not adequately

analyze an affiliation issue in its

dismissal of an administrative complaint

filed by Common Cause. (Civil Action No.

89-5231.) The court remanded the case to

the district court with instructions to

return the matter to the FEC for reconsideration consistent with the appeals court

ruling.

Background

Common Cause filed an administrative

complaint with the FEC alleging that the

Republican National Independent Expenditure

Committee (RNIEC) and the National Republican Senatorial Committee (NRSC) were

affiliated committees and that RNIEC's

expenditures on behalf of then-Senator Dan

Evans' 1984 reelection campaign were

coordinated with NRSC. As a result, Common

Cause contended, contributions made by the

two committees on behalf of Mr. Evans exceeded the contribution limits of 2 U.S.C.

§441a. The Commission found no probable

cause to believe that a violation. of the

Federal Election Campaign Act had occurred.

11

Volume 16, Numbe

After the Commission dismissed the

administrative complaint, Common Cause

filed suit in 1985 with the U.S. Distric

Court for the District of Columbia. (Ci

Action No. 85-1130). Common Cause asked

the court to find that RNIEC and NRSC we

affiliated committees, or that they had

coordinated their expenditures on behalf 

Senator Evans. (Either finding would hav

resulted in excessive contributions by

NRSC. )

District Court Decision

In its decision of May 30, 1989, the

court found that the Commission's dismis

of Common Cause's principal allegations-

affiliation and coordination between RNIE

and NRSC--was reasonable. The court did

remand one issue from the original comp1aint--that of affiliation between RNIEC

and the Republican National Committee--b

to the FEC for further consideration, fin

ing that the Commission had not addressed

that allegation in dismissing the admini

trative complaint.

Appeals Court Decision

In its per curium opinion, the appea

court noted the deference accorded by the

courts to FEe decisions. However, in

considering the General Counsel's brief

recommending the "no probable cause to

believe" finding adopted by the Commissi

the court found that "the brief lacks any

discussion of the affiliation issue that 

independent of the analysis of the separ

coordination issue. 1I

Common Cause's affiliation claim was

based on three facts: (1) Mr. Rodney Sm

served as the financial director and tre

urer of NRSC until two months before he 

founded and became treasurer of RNIEC; (

Senator John Heinz continued to be a mem

of NRSC a short time after he co-founded

and joined the advisory panel of RNIEC; 

(3) there was a substantial overlap in c

tributors to the two committees, the res

of RNIEC'S use of NRSC's mailing list.

Section 441a(a)(5) of the Act define

affiliated committees as those that are

"established or financed or maintained o

controlled" by the same person or group.

Commission regulations then in effect

listed several indicia of affiliation at

11 CFR 100.5(g)(2)(ii)(A)-(E). (Current

FEC rules provide revised indicia at 11 

100.5(g)(4)(ii)(A)-(J).) The court state

that the General Counsel's brief made no

attempt to tie the relevant indicia of

affiliation to the facts of the case. A

result, there was no indication that the

agency had considered one pertinent indi

(continue
August 1990 FEDERAL ELECTION COMrvIISSIOI\J

cium of affiliation~ whether Mr. smith or

Senator Heinz had the ability to influence

the decisions of both committees. 11 crn

100.5(g)(2)(ii)(C) (since revised at 100.5

(g) (4) (ii) (B)).

Another indicium set out in the rules

is whether two committees show a similar

pattern of contributions. 11 crn 100.5(g)

(2)(ii)(D) (since revised at 100.5 (g)(4)

(ii)(J)). The General Counsel's brief did

not specifically refer to this indicium.

The appeals court found this issue "less

troubling" since the brief considered

possible affiliation resulting from RNIEC's

use of RNSC's contributor list but went on

to explain that this implication was

rebutted by the committees' dispute over

the ownership of the list.

In conclusion the court stated: "Based

upon the General Counsel's brief to the

Commission, it is impossible to discern

whether the FEC applied the applicable

statute and regulation to the claim that

the NRSC and the RNIEC were affiliated. II

The court therefore reversed the judgment

of the district court on the affiliation

issue and remanded the case with instructions for the FEC to reconsider the issue

based on the court's decision.

NDl LITlGA.TICN

Democratic Senatorial campaign committee

v. FEe (90-1504)

The Democratic Senatorial Campaign

Committee (DSCC) asks the district court to

declare that the Commission acted contrary

to law in dismissing certain allegations

DSCC had made in an administrative

complaint filed with the FEC.

In its administrative complaint, DSCC

alleged that $325,000 in media expenditures

made by the Auto Dealers and Drivers for

Free Trade Political Action Committee (Auto

Dealers PAC) in support of 1988 Senate

candidate Connie Mack were not independent

and thus violated the PAC's $5,000 contribution limit for the candidate under

2 U.S.C. §441a(a)(2). DSCC contended that,

because the Auto Dealers PAC and the Mack

campaign (Friends of Connie Mack) both used

the services of two key campaign consultants, the independence of the PAC's

expenditure was compromised, resulting in

an excessive contribution by. the PAC. DSCC

also alleged that the Mack campaign violated 2 U.S.C. §441a(f) by knowingly accepting the contributions. In an allegation

unrelated to the Auto Dealers PAC's expenditures, DSCC alleged that the Mack campaign

violated §434(a)(6)(A) by failing to file

the 48-hour notices required W,hen a cam12

Volume· 16, Numb

paign receives contributions of $1,000 o

more shortly before an election.

The Commission found reason to belie

that the Mack campaign had failed to com

with the 48-hour notice requirement and

later entered into a conciliation agreem

with the campaign with respect to that v

lation. The Commission could not, howe

reach agreement on the alleged violation

stemming from the Auto Dealers PAC's me

expenditures and ~ccordingly dismissed

those allegations.

DSeC requests that the court find th

the FEC's dismissal was contrary to law 

order the Commission to initiate expedi

enforcement proceedings concerning the

alleged violations.

U.S. District Court for the Distric

Columbia, Civil Action No. 90-1504, June

26, 1990.

FI~ ACTIVITY OF NATI<H\L

PARTY CCJOO:TI'EES

During the first 15 months of the 19

90 election cycle, the three national

committees of the Republican party raise

almost $113 million, spent almost $100

million and had cash reserves of over $1

million. By contrast, the three Democr

national committees raised and spent ju

over $24 million, reporting less than $6

million in cash on hand.

Although these figures reveal that t

Republican national committees raised an

spent more than four times the amount of

the Democratic committees, the two parti

provided approximately the same amount-

miliion--in direct support of candidates

(contributions and coordinated party exp

ditures). Republicans spent $1,177,219 

the Democrats, $940,103. Most of this

activity was in support of candidates

running in the ten special elections hel

thus far during the 1989-90 election cy

Comparing transfers from the nationa

committees to state and local party com

tees, the figures show that, during the

first 15 months of the current cycle, th

Republican committees transferred $1.1

million--more than twice the amount tran

ferred by the Democratic committees.

The accompanying charts are based on 

May 25, 1990, press release that provide

summary data on the 1S-month activity of

the national party committees for the 19

1988 and 1990 election cycles.
August 1990 FEDERAL ELECTION COMMISSION Volume 16, Numb

e

National Party Committee Activity:

First 15 Months of Election Cycle 1

Receipts

Millions of Dollars Millions of Dollars

125 125

1

~OO 100

75 75

50 50

25 25

0 0

1986 1988 1990 1986 1988 1990

Republican Democratic

Contributions to Candidates

Millions of Dollars Millions of Dollars

1.0 .1.0 I

0.75 0.75

0.50 0.50

-

0.25 0.25

0 0

1986 1988 1990 1986 1988 1990

Republican Democratic

Transfers to State and Local Party

Committees 2

Millions of Dollars Millions of Dollars

3

1 3

2 2

1 1

0 0

1986 1988 1990 1986 1988 1990

Republican Democratic

• 1Graphs show the aggregate activity of the three national committees of each major party: the national party comm

the Senatorial campaign committee and the Congressional campaign committee.

2Limited to transfers made for federal election activity.

13
August 1990 FEDERAL ELECTION COMMISSION

MURS RELEASED 'IO THE PUBLIC

Listed below are MURs (FEC enforcement

cases) recently released for public review.

The list is based on the FEC press releases

of June 12 and June 25, 1990. Files on

closed MURs are available for review in the

Public Records Office.

Unless otherwise noted, civil penalties

resulted from conciliation agreements

reached between the respondents and the

Commission.

MUR 2522

Respondents: (a) John vandenberge for

congress, Stephen P. Poulos, treasurer

(MO); (bl Vandenberge Enterprises, Inc.

(aka John vandenberge, D.D.S., P.A.) (MO);

(c) Linda Vandenberge (MO)

Complainant: FEe initiated

subject: Corporate contributions;

excessive contributions

Disposition: (a) $1,000 civil penalty; (b)

$500 civil penaltYi (c) $500 civil penalty

MUR 2655

Respondents: (a) David Edwat"d Landau (PA);

(b) Friends of David Landau, Inc., Lawrence

M. Goodman, treasurer (PA); (c) stephanie

Klein (PA); (d) Cyrus Landau (PA);

(e) Philadelphia National Bank

Complainant: Earl M. Baker, chairman,

Republican state Committee of Pennsylvania

Subject: Bank loans; excessive contributions

Disposition: (a), (b) and (d) no probable

cause to believe; (c) and (e) no (eason to

believe

MUR 2733

Respondents: (a) Stenholm for Congress

Committee, Charles E. Brownfield, Jr.,

treasurer (TX); (b) Media Management

Consultants, Inc. (TX)

Complainant: FEC initiated

SUbject: Corporate loan repayments

Disposition: (a) $1,500 civil penalty; (b) $100 civil penalty

MUR 2834

Respondents: Jim Cummings for Congress

Committee, Mike McHugh, treasurer (IN)

Complainant: FEC initiated

SUbject: Failure to report on time

Disposition: $250 civil penalty

14

Volume 16, Numb

MUR 2885

Respondents: Jesse Jackson for preside

'88 Committee, Howard R. Renzi, treasure

(IL)

Complainant: FEC initiated

SUbject: Failure to t"eport on time

Disposition: $1,500 civil penalty

MUR 2990

Respondents: Young Executives of Ameri

PAC, Lee Riffe, treasurer (CA)

Complainant: FEC initiated

SUbject: Impermissible transfer of fund

from nonfederal account

Disposition: $1,500 civil penalty

MUR 3003

Respondents: (a) Maria Alonso-Martinez

chairman, Republican Party of Dade Coun

(FL)i (b) Al Cardenas (FL); (c) Mary

Collins (FL)

Complainant: David W. Southwell,

treasurer, Republican party of Dade Cou

(FL)

SUbject: Expenditures made without tt"e

urer's authorization

Disposition: (a)-(c) No reason to belie

IilUR 3032

Respondents: Mississippi Democratic pa

political Action Committee, Ed Lee Cole

treasurer

Complainant: FEC initiated

SUbject: Excessive and prohibited

contributions; inaccurate disclosure

Disposition: $1,800 civil penalty

MUR 3064

Respondents: (a) 1IJllerican Resort &

Residential Development Association

political Action Committee, Thomas C.

Franks, treasurer (DC)i

(b) American Resort & Residential

Development Association (DC)

Complainant: FEe initiated

SUbject: Failure to reimburse

adrrdnistrative expenses on time

Disposition: (a) and (b) Reason to beli

but took no further action
August 1990 FEDERAL ELECTION COMMISSION Volume 16, Numbe

•

The first number in each

citation refers to the "number"

(month) of the 1990 Record

issue in which the article

appeared; the second number,

following the colon, indicates

the page number in that issue.

ADVISORY OPINI(H)

1989-21: Fundraising by sole

proprietor in cooperation

with candidates, 1:9

1989-25: preemption of state

law limiting party spending

on behalf of candidates, 1:10

1989-26: Automatic bank

transfers from contributor's

account to candidate committee's account, 1:11

1989-27: Act's preemption of

state law governing solicitations by state employees, 2:2

1989-28: voter guides distributed by nonprofit corporation, 3:9

1989-29: PAC established by

company owned by foreign

principal, 2:3

1989-30: payment to Senator for

teaching course, 2:4

1989-32: Foreign national contribution to state ballot

measure coannittee "controlled" by candidate, 8:6

1990-1: corporation'S sale of

900-1ine fundraising service

to candidates, 4:3

1990-2: Candidate's use of excess campaign funds to secure

loan for party cOl'lllli.ttee, 4: 5

1990-3: PAC's sale of advertising space in newsletter, 5:3

1990-4: Use of credit cards to

charge combined dues/contribution payments, 7:1

1990-5: Newsletter published by

candidate, 6:4

1990-6: preemption of Oregon

law prohibiting charitable

matching plan for PAC

contributions, 7:2

1990-7: Transfer from candidate's former Presidential

exploratory committee to 1990

House committee, 8:6

1990-8: Establishment of PAC by

corporation majority-owned by

foreign bank, 8:7

1990-9: Newsletter published by

candidate as sole proprietor,

8:8

1990-11: Publicly funded campaign'S donation of fundraising items to staff and charity, 8:8

0XJR'l' CASES

Austin v. Michigan state

Chamber of Commerce, 5:5

FEC v. - ChiFiiailC. Bull for

Congress, 8:11 - Franklin, 1:13 - Friends of Isaiah Fletcher

Committee, 7:4 - Furgatch (83-0S96-GT(M),

2:7 - Life Amendment PAC, Inc.

(89-1429), 4:7 - Mann for Congress

Committee, 7:5 - National Right to Work

Committee, Inc., 5:7 - NY state Conservative

partyj1984 Victory Fund

(87-3309), 6:7

- Working Names, Inc. (87-

2467-GAG), 7:4

- working Names, Inc. (90-

1009-GAG),7:4

PUBLIC APPEARANCES

v. FEC

--=-Common Cause (89-0524),

3:11

- Common Cause (89-5231),

8:11

- Democratic Senatorial

Campaign Committee (90-

1504), 8:12

- Dolan, 5:7 - FaUCher and Maine Right 

Life Committee, Inc.

(90-0112-B), 6: 7 - Goland, 8:9 - NatIOnal Rifle Associati

(89-3011), 2:7

MDR SUMMARIES

MUR 2823: Excessive contribu

tion received by candidate

committee, 2:4

MUR 2599: Reporting errors b

congressional campaign, 4:

MUR 3009: Excessive coordina

expenditures by state part

committee, 6:5

800 LINE

Basic recordkeeping rules, 4

Combined dues/solicitation

statements, 1:17

Coordinated party expenditur

3:6

Designating a principal c~

paign committee, 1:19

Disclaimer notices, 5:8

Exempt party activities, 5:1

Last-minute contributions: 4

hour reporting, 7:8

Last-minute independent expe

itures: 24-hour reporting,

7:9

New treasurer, 2:9

Transfers from candidate's n

federal comrodttee to feder

committee, 6:8

When reimbursements are required in SSF fundraising,

2:8'

•

Septembe r 11

September 12

National Association of Legal Secretaries, Washington, D.C.

Commissioner Scott E. Thomas

Texas Medical political Action Committee, Austin, Texas

Craig M. Engle, Executive Assistant to Chairman Elliott

15
August 1990

aw«;E OF ADDRESS

FEDERAL ELECTION COMMISSION Volume 16, Num

political

Treasurers

Committees

of registered political committees automatically receive the Record.

A change of address by a political committee (or any change to information disclosed

on the statement of Organization) must, by law, be made in writing on FEe Form 1 or 

letter. The treasurer must sign the amendment and file it with the secretary of the

Senate, the Clerk of the House or the FEC (as appropriate) and with the appropriate

state office.

Other SUbscribers

Record subscribers who are not registered political committees should include th

following information when requesting a change of address: . o Subscription number (located on the upper left hand corner of the mailing label);

o Name of the subscriber;

o old address; and

o New address.

Subscribers (other than political committees) may correct their addresses by

phone as well as by mail.

FEDERAL ELECTION COMMISSION

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