April 1993

Table of Conten

ompliance

Violations of the Annual Limit

MUR Released to the Public

Regulations

I Ban on NonfederalTransfer.

(1 RulcmakingPetition on Usc of

andidatc Names

Propo ed Rule on Multicandidate

ornrnittee tauu

800 Line

2 25.000 Annual Limit

Legi lat ion

3 FE Requests : 2.6 Million Budget

Increase

learlnghou e

4 Advisory Panel Discusses "Motor

Voter" Lawat Annual Meeting

'tnti tics

4 1992 House and 'enate ampuign

pending Jumps 25 Percent

p cial ' Iections

7 Puny pending Limits

R'porting

7 Last-Minure ontribution

8 Letter on Reponing Problems

8 Advisor)' Opinion

ourt as '

10 FE v, merion's PA

10 National Rifle A sociation v, F'

10 ommon au. v, F '

Public .undin J

II 1988 Dukakis and imon

arnpai n

1_ Federal Register Notice

1_ Index

Federal Election Commission

Compliance

4E Impose hit Penalti

for iolations of the 25,000

Annual Limit

On March 17, the FE announced

that ten individual agreed to pay

$64.000 in civil penalties for violating

the 25.000 annual limit on contributions and for other violation of the

contributi n limit . Most of the

violation' t k pIa e in 1988. ( ee

table. page .)

The civil penalties were included

in conciliation agreement signed by

the individual . The agreements

included admission of the violation,

but noted wh n refunds had been

obtained by th ntributor .

FE hairrnan cott E. Thoma

commented: "Th m 'age from this

ca 'C i that the FE d . enfore

c ntribu tion limit . Tho e making

political contribution ' hould be

knowledgeable of the limit enacted

by ongress."

nder federa l law. an individual'

total ontri bution to infl uence federal

ele tion may not xceed $25.000 in

one calendar year. ( ee 800 Lin'

article, page 2.)

t the direction of the ommis-

. loners, the General oun el launched

an inve tigation two day after an

pril 1990 Los ATl8 les Times article

reported that several individual had

(continued Oil page J)

Volume 19, Numb er 4

Regulations

Ban on lonfederal ampaign

Tran fe ffective Jul 1

The ornmi ion decided to delay

untilJuly I. 19 3. the effectivedate

of a new rule that will prohibit

transfer of fund from a candidate'

nonfederal campaign to hi or her

federal campaign (I I FR IIO.3(d» .

Thi mean that the prohibition will

likely n t apply to the campaign of

candidate running in the pecial

election cheduled thus far. Those

campaign are ubject to the urrent

nile, II FR 11 0.3(c)(6).

If a federa l campaign committee

ha received transfer of funds from

the candidate' nonfederal committee.

it will have to identify any nonfederal

fu nd' remaining in its account a f

July I. The e fund \ ill have to be

rem ved bef re July I or the

c mmittee will be in violation of the

nev rule, T identif nonf deral

fund . the ornrnittee hould u e the

method described in I I FR

I I0.3(c)(5)(ii) (i.e., con ider the ca h

on hand a ' of July I to be compo ed

of fund mo t recently received by the

federal c mmiuee).

Th mmis ion riginally

intended to et pril I a the effe rive

date for the new rule. However, the

required legi lative I' viev period 30

Ie i lative day ) took longer than

(continued Oil page 6)
FN"aI £1nl;IHI C/""miJJ;'H/ RECORD

800 Line

$25lNlO Annual Limit

Lnoer federal law. an individual

may contribute a maximum of:

• SI,CXXl per election-primary.

general or runoff-c-eo a candidateor

the candidate's authorized committee.

• 5.(0) per calendar year to <I PAC

(political action comrrunee) or to a

state or local pany commi ttee.'

, lkeaju~ localpmry cOfflmittUJ 'illlj/l u

J41ft' are pTr Jllmt:J to ujJilit,'t'd wilh

lIlt' /l(JTIy'J J Udf' com mittee, a C/H11Tihu.

l itHl If ' a Incll/ J)flrty C/'mm itlf.'f' counts

agwTUl lk 15.000l ilRltInrl l ir JUdi: parry comnrillU. JJ CFR I JO,JrbJ(J).

Ff'dl'1"31Ht'1.1lon ('onmllo...inn

IJ99 t: xrrcct, NW

Wa oJlill2lUll,IIC 2lWl.\

X1Xll.l!4-lI5JO

20212 19·3.120

2lJ2I219-.ll"\hn DDI

S(:olt E. ·l1lUma..... Chainnan

'rrcvorI'oncr, vice Chairman

Juan l ), Alkens, Cmllm ~ sinllt

I.('{' Ann Ellllltt, (l ll Jl i~si llnc

Oann." I., Mdkmald ,

Commi..vioner

John warren :'o lrl;urry.

( ·ummi 30'itlfll,...

Walter J. Stl''' art. &'Ch.'ldl)·

uf the Sena te. b Otncio

III11mi"i(ln~

OUllnald K. Andt'NIIl,Clerk

uf Ihc uu of Rep n-wnt..lives,

El OUk io louuni..sioner

Juho C. Surina. Staff Duector

I..." renee 'I. Sohk. u:naal

Coun,d

P'uhli.Jled hy the lnfonua tion

Il

l.oulw O. \\ ido. DIra:1of

Sll.'phank· filzJ:mtld, Edit....

lUalo,(' 1.atlJ:(·. Grotphil...ArJvisor

1

• S20.OCMJ per calendar yearto a

national party committee. I I CFR

1/O.llbXI). (e)( I) and (dXI).

However. an individual is also

subject to an overall annuallinut on

total coruriburions-Tte individual's

aggregate contributions 10 influence

federal elections may noc: exceed

S25.lXXJ in a calendar year. I I CFR

IID.S(b).

This article answers common

questions concerning the S25.OOO

armual limir.

Ir, in 199.\. 1 contribute S250 10a

ca nd idate's 199-1 primary campai gn. " i ll that contribut ion count

aga inst mJ $25.000 3nnuallimit for

199.' or 199

If you make a contribution to a

candidate in a nonelection year (such

as 1993) for the candidate's future

elecuoo (In this case.the 1994

primary). the coernbetioo i" considered to be made in the year in which

that election will be held. II CFR

llO.5(c)(2). Therefore. even if you

contribute the money in 199J. 111e

conrribnion counts against your

S25.(Q) annual limit for 1994.

:'01)" husband a nd 1 would like to

ma ke a $2.000 joint contri b ution to

a Senator who "'ill nol he lip for

ret'lecl ioll ullti I1 996. lIow ",o uld

this affect our $25,(HH) unnuatltmlt ?

First of all, you and your husband

each have separate contribution

limits: a separate annual limitand a

separate SI.(o) per-electionlimit for

the candidate. II CFR 110.1 OXI) and

1/O.S(b).

Assuming thai the $2.000 joint

contribution is split equally between

you and your husband.' your SI.OCWJ

1Ifdll! nHl1ribll lor! do 1Wt di atl! (I

joim COl11rihullon shotJd be fillrihuln!

lhr f"f!dpit'nJrommiltl!f' !rum ,WTlI>I"1! un

eqoatO/f/OWIl IO eoch p(lnicipClling

conmbiuor. Note. I/fJl\Y'I'('T. {hilta jni,,'

('(In/r ibwi(lfl mlU! be Jig"t:d b)' !>fIlII

cCHllrih.llon . t:i/~ on lilt: cbect: 0" i n t.VI

aJI~clw ",·ril ing. II CFR 1I0./(J,J( J)unJ

m

_ __April / 993

cor uribution-c-and your husband's-ceach count against your respective

annual limits for 1996. the year in

which the Senator's next election (the

primary) will be held. (Each I,OCXl

contribution also counts against your

respective limits for the Senator's

1996 primary; you and your husband

have now contributed the maximum

amount for that eection.)

I plan to buy a $5fH}ticket to a

Iund raeer that 's going 10 be held to

retire a candidate's lefto ver debt

Irom his 1992 genera l election. How

woeld the 25.000 annual limi t

applJ in lhis situa tion?

A contnbuticn for a candidate's

past election counts against the limit

for the yearin which the election was

held. in this case. 1992. Therefore,

your S500 contribution (!he full

purchase price ofthe ticket) to help

reure the debt l coenu against your

1992overall annual limit. even if you

wme the check in 1993.

Remember that contributions 10

retire debts are still subject 10 the

$l,(xx) per-election contribution limit.

so any previous contributions you

made 10 the candidate's 1992 general

election campaign. plus the S500

contribution. may nor exceed $1.000.

1know I can contribute up to

$5,000 per l ea r to a stall' party

committee. La'll yea r, in 1992.1

contributed $2S00 to Ill)' sta te

pari)' committee•.\Ia)' 1 no"

contribute another $2S00 and

apply it agai nst my 1992 limi t for

the part)' committee a nd 111)' 1992

overall annua l Iimit'!

:'010. Unlike contributions to

candidate committees(which are

made on a per-election basis),

JA c(>ft/Tfbll tlf'fl '"retire U cQ" didiUr'J

past campaign debt nuo' be dt:sign(j/ffl m

" 'Ti/i,,!! J(ITIhal r/n:li(lli. Wilh(Jltllllm

desiguaiion: Ihl! t'OIlir ibll/iOlI will

ll f(l",alH. uU COlml OgU lII.lI Ihl! /iml/ JUT

lilt> cundidalr'J /I t'xt f'/I!c lion and agolfl Jl

Ihl! O>'f!ra/l antmallimil10" 1M )~o of

l hol I!ft>clUwt. II CFR 1I0./(bX2J(ii).
FtJa ul EI«" ..., C...........iuu", RECORD

Excessive Contributions and Resulting Civil Penalties

~I URs Released to the Public

Listed below are FEC enforcement

cases (Maners Under Reviewor

MURs) recently released for public

review.The list is based on the FEe

press relecse of March 17. 1993. Fib

onclosed MURs are available for

review in the Public Records Office.

Unless otherwise noted. civil

penalties resulted from conciliation

agreements reached between the

responderasand the Commission.

~t UR .1161/.111»

Respondems: (a) Dwayne and

Dorothy Andreas (lL); (b)Caroline

Ro-e Hunt (TX); (e) Henry Kravis

(OK); (d) Raymond Kravis (OK);

(e) Ronald Perelman (NY); (f) Ira

Rlklis (N Y ); (g) ~1 h u Riklis

(:'I Y); (h) Harold Simmons crx):

( i) Donald Trump (t'Y)

Compla ina nt: Initiated by directive

from Comrnissicoers(After lhe

FEC"!!. investigation began. Common

Cause flied a similar complainr.)

tconunued on PlJgt 10,

Compliance

rCo/l!ll lutd/rom pagt IJ

o-n

Penalty

S 8.lXXl '

s 800

S 8JXXl

$ 1.000

s 7.IOn

s 1.800

S 2500

$19.800

$15.000

S2.000

$1.000

$3.000

S6.ooo

$2.00>

Amou nt O ver

$1.tK)(JLimit

lin Ca ndidate

Contrtbutlons1

513.680

s 4.680

S 3.150

$36.961

s 6.250

$26.2324

s 7.500

s s.soo

s-ui.176·

S47.050

" mounl O ver

$25.000

Indi\ Annu al Llmit ' 'idual

Dwayne O. And reas

Dorothy Inez Andrea'"

Ca roline ROS(' lI unl

Henry Kra vls

Raymond Kra \i",

William Lerach

Ronald Perelma n

Ira Kiklis

Harold Slmmonc !

Donald Trump

exceeded the S25.(O) contribution

ceiling. during the 1988election cycle.

Tbe case against 00( individual was

initiated in 1991. the result of a

complain!based 00 another Los

Angdes Times story.

While the FEC maintains the

contribution records relied upon by

the newspaper for its articles. the

Federal ElectionCampaign Act does

not give the Commission authority 10

open invesngances prior to finding

··rea'..on to believe' the law was

violated. Because ofthe complexities

involved in determining if someone

has exceeded the annual limit. a

simple review of computerized

records may not show conclusively

that a violation occurred. A more

thorough. preliminary investigation .

such as that conducted by the newspaper. is required. The agency is.

however. reviewing its capabilities (in

terms of resources and priorities) to

use computer records 10 monitor

annual limits. •

Legislation ,

FEe Requests $2.6 liUion

Budget Increase

In (~imon before Congressional

subcommiuees. vice Chairman

Tre\'OT Po tter said that the Commission is "now virtuallyoverwbelrred

by the rapidly growing enforcement

case load and by the wave of data

flowing from the 1992 election" and

is in "dire need"of a 1994 fiscal year

budget of $216 million. Tbe Vice

Chairman emphasized thatthis

amount-representing an increase of

$2.6 million and 4-l full-lime employees over current levels-is the "bare

minimum needed for acceptable

functioning of the FEC given its

current responsibilities."

Tbe amount of political money

tracked by the Commission has

increased by $1 billion since 1980.

During the 1992election cycle. fbe

agency monitored almost $2 billion in

federal campaign activit)' and more

than 7.100 corruruuees. The enforcement workload has also grown: the

number of respoooenrs more than

tripled in four years. Each of the

enforcerrera auomeys currently

handles upwardsof 20 ongoing

matters involving an average of more

than 100 respondents. vice Chairman

Potier said that the agency i, "deeply

concerned that there are entire areas

oftbe election la\\"!i.thal we currently

(ronJinMd (1ft ptrgr .J)

contnbctions to party committees and

PACs count against the limit for the

year in which they are made. I I CFR

110.5(c)(3). Therefore. once 1992

ended. your 1992contribution limit

for the panycommittee expired. even

though )'00 didn't contribute t~

maximum amount. Any contribuuons

you make to the comrmnee in 1993

will count against your 1993 limit for

the comrninee and your 1993S25.lXXl

annuallimit. •

J
ml [Itn/IN! Cn"'mmuJI/ HEX OHO _ A.pril /99J

Legislation

(cOfltjnutdfrom pog~ J'

lack the resourcesto monitor or

enforce appropriately:'

Reminding panel members that

President Clinton has placed earnpaign finance reform near the top of

his agenda. the Vice Chairman stated:

'There is no point in maintaining

campaign finance laws on the' books.

orin adding to them. if tbey cannot be

administeredand enforced in a timely

manner."

He pointedout mal the' passage of

the Nati0031v oter Registration Act

(the - lllOI:or voter-law; Stt next

article) and an)' new campaign reform

legislation would place additional

administrative burdens on the agency.

Even without them. however. the

Commission projects an extremely

heavy workload for the 1melection

cycle.

Vice Chairman Potter, who beads

the FEe s finance commi ttee.

appeared with Chairman Scott E.

Thomas and Commissioner Danny L.

McDonald.They testified on February 24 before the House Appropriation' s Subccmminee on Treasury.

Postal Service and General Government, and on March 16 before the

House Administration's Subcommittee onElections. +

Clearinghouse

Ad,'i\fln' Panel Discusses

":\ICltor \tOler" Law a t Annual

~" eting

The FEe s National Clearinghouse

on Election Administration and its

Advisory Panel recently met with

nearly 200election officials from

around the COUntry to discuss issues in

election administration. including d1C

pending "fTIO{Of voter" law. The

Advisory Panel is madeup of 20 stare

and local election officials from

different states. Also anendmg the

March 24-26 meeting in Savannah,

Georgia, were FEC Chairman Scott E.

Thomas. Vice Chairman Trevor

Potter and Commissioner John

WarrenMcGarry.

The "motor vorervlaw. officially

called the National v oter Registration

Act of 1993, is expected to be enacted

in the nearfuture. The law would

significantly alter the registration

systems of most stares. It would also

assign new responsibilities 10 the

FEC. thereby affecting the agency s

budget.(See previous article. page 3.)

The Clearinghouse would be largely

responsible for the "EC"s duties

under this Act. In anticipation of the

law's passage, the office has already

begun planning cooperative activities

with the stales.

The Clearinghouse wa\ created

under the Federal Election Campaign

Act to serve as a central exchange for

research and information on tbe

administration of elections. During

1992. the office responded to over

8.000 phone calls. a four-fold increase

over 1991. Tbe office also introduced

3 series of research guides describing

recent technological and ndministrari ve innovations in slate and local

election offices. In preparation for a

long-term projcct- a training program for local election ofticials-the

Clearinghouse began to assess their

educational needs.

A number of Clearinghouse

publications are available for order,

'Such a'S a summary of state election

laws (Campaign Finane' inK' '91J

and an essayon the Electoral College

thai generated over 14.(xx)orders in

1992. The office also publishes the

Journal on Hection ,\ dmin;jlratiOtL

The next issue of the Journal will

offer advice to election officials on

how to serve voters in special poputanons.such asthe homeless. the

disabled and minority group'S who do

not speak English. For information on

Clearinghouse publications. call 800/

42+.9530 (ask for the Clearinghouse)

or 2<PJ219-3670. •

Statistics

1992 House a nd Sena te

Campaign Spending Jumps

521)ercent

A March 4 press release reports

that House and Senate campaigns in

the 1991-92 election cycle spent 52

percent more and raised -topercent

more than campaigns in the previous

election cycle (1989·90).

The jump in House and Senate

campaign activity was influenced by

Congressional redistricting. an

unusual number of House incumbent

departures. and three special Senate

elections (Californi a had both a

regular and a special Senate election).

These circumstances. in tum. led to a

68 percent increase in the number of

candidates ('SeC: Table I ), more open

seat races and more nonincumbent

campaigns with competitive funding.

Comparing 1991-92 House

campaign activity with the previous

cycle. sperding went up 53 percent to

s.t07 million. while receipts rose 39

percent to $396 million. Incumbent

House candidate'S accounted for 93

percent of the $48 million tota l

closing cash on hand for all 1992

House candidates. Nevertheless,

incumbents' closingcash represented

a 42 percent drop from the 1990

figure and left the smallest incumbent

"war chests" since the end of 1984.

The press release. available from

the FEC's Public Records Office.

contains numerous tables on House

and Senate financial activity, including summary data for the 1992 cycle.

comparison figuresfor previous

election cycles, statistics on individual

1992candidates and median financial

activity of House campaigns. One

table IiSlS. for each state. Sena te

spending per voter(i.e.. spending

divided by the voting age population

of the stare).

The tables opposite are based on

the press release. +
il

Table I: Money Raised and Spent by House and Senate Campaigns I

Election Cycles 1980-1992 2

(millions of dollars)

Federat Election Commission RECORD

1979-80 1981-82 1983-8-1 1985-86 1987-88 1989-90 1991-92

---

Receipts $248.8 $354.7 $397.2 $-1 72.0 $-177.6 $471.7 $658.6

Disbursements $239.0 $342.4 $374. 1 $450.9 $459.0 $466.3 $678.3

Number of Cand idates 2.288 2,240 2.036 1,873 1.792 1.759 2,956

I Tabte inctudesIpecial election activity.

2An eteaion <,ylce i,1 (/two-vear period. the year befare the election and the election year ilw '!

Table 2: Median Disbu rsements I of New House Members a nd Their OPPOIH'llts

J989·90 Cycle 1991·92 Cyc te

Democranc New Members

and O pponents

Democrats Who Defeated...

Republican Incumbents

Democrats Who Defeated...

Republican Opponents in Open Seat Races

Democrats Who Defeated...

Democratic Incumbents (Primary) and

Republican Opponents (General)

New Mem bers Medi an New Mem bers Median

Elected Z Dlsbu rsernents Elected ,\ Disbursements

8 $-169,107 6 $260,223

$707,95 1 $7 16.536

19 5638,36 1 -17 $420,227

$297,348 $166,756

8 $394.424

$346.407

$ 35.848 ---

Republican New Members

ancl Opponents

-- Republicans Who Defeated...

Democratic Incumbents

Republicans Who Defeated...

Democratic Opponents in Open Seat Races

Republicans Who Defeated...

Democrutic Challengers Who Had Defeated

Incumbents in Primary

---

6 $259.503 13

$608.496

II $581.625 28

$378.537

2

$-139,718

$924.384

$-152,420

$3-1 1,107

$325,034

$-176,981

Republicans Who Defeated...

Republican Incumbents (Primary) and

Democratic Opponents (General)

$732.765

s 52.562

$114.852

3 $3 6-l ,~ 15

$767,425

$336.-1 18

I Median 1II 1' ( /f/ 1 Ilw l all equalnumber ofcandidiucs hml (/('/il'iryabove und "dow Ih(' 1IIII00ml-l' .l" /(}'~ II

1/" 19YO. 45 11('11' HOlli e Ml'lIIb('n were elected.

! 11/ I QQ2, 110 m'w HOI/I'e Members were elected. NOIf'. howe ver, Ih /ll uus whle "01." ,\ notreflect the three 1ll'lI' Members who were

elected aji",. Ih /! illClIlI1llt'lIIl'rilllllry winners either died or withdrew .f1'01II the /IK e (NI:\\' Jen eylJ. New }"w k!8 WI/I 01lio/ I).

5
Fedeml Elecli,,,, 'ommi sian RECORD------ April 1993 ----"-

egula 0

(col/til/lied rom page I )

e peered and would ha e resulted in

the e recti e date falling ometime in

mid-April.I The ommi ion anted

to a oid tting an effe tiv date in

the middle 0 the pe ial ele tion

tivity and therefo de ided on a

July l e e ti e date.

The a en • ann un ed it plan to

change the e fecti e dale in a Federal

Regi tel'n ti publi hed on I ar h

17 ( FR 14_ 10). •

RuJ rnakin P titi n

on f andidat am

The ommi ion recently sought

commen on a rulemaking petition

filed b itizen gain t Da id Duke.

\ ho requ ted that th agency amend

its regulation on the u of candidate

nam in pe ial fundrai ing proje Is

( I I FR 102.14(a» . Thi rule. hich

became effc ti e on Iovernber 4.

199_. prohibit the u e of a candidate' name in the title of a fundrai -

ing project or other communication

pon ored by an unauthorized

committee (i.e.. a partycommittee.

PA or other rnrnittee not authorized by any andidate).

The ommis ion adopted the

regulation to minimize the potential

for fraud and abu e. In the pa t. the

u e of a candidate' name in a project

title ha. rni led the public into

belie ing that they w re onrributing

to the named candidate or that their

contribution would be u ed on the

candidat . behalf. when that wa n

the a e.

itizen gain t David Duke.

whi h identified i elf a a "propo ed

project of a political committee."

I I gislativ day are those do 's wh 1/ tM

House or S nate is ill Sf! sion. V.S.c.

3 d)(3). Th 30·da)'legislativ review

period pi, d on larch 18. 1993. 01/

April I. the Commission is expected 10

approve all announcem nt 0 th July I

effectiv date fo r publication in the

Federal Register.

6

challenged the con titutional alidiry

of the entire regulation. Contending

that its chosen name wa con rituuonally protected political pee h. th

petitioner in parti ular que tioned the

rule's application to project that

oppose a cand idate. in t:: "[tlh re i

no danger of confu ion I' abu .• in

tho e situations.

Commen on the rulemaking

petition were due April 2. The petition

and comments are a ailabl for

re iev in th Commi ion' Public

Records Offi e. ee FR 121 9.

'larch :', 199:'. •

Propo ed RuJ 'tutti andidate mmitt u t

The Commi ion ha proposed

ne regulation that \ ould m 'e it

ea ier for candidate ornminee and

the Commi ion to id ntify political

committe that ha e qualified a

multicandidate committee I and are

therefore entitled to give up I 5.000.

per election. to a candidate. onqualified committee are ubject to a

1.000 per-candidate. per-ele tion

limit.

Two of the propo ed regulation

would apply to newly qualified

multicandidate committee . while a

third regulation would apply to all

multicandidate comrniuee .

The otice of Propo ed Rulernaking was published in the ederal

Register on March 3. I 93 (5 FR

121 89). Comment were due April 2,

lew 'lulticandidat ommittee

nder current practice. a committee notifie the Commi ion that it h

qualified a a rnulticandidate orrunittee by checking a bo on it regularly

filed report (Form 3 ') once it ha

I A committee qualifies as a multicandidar committee ",II II it has be II r. gi -

tered at least 6 l1WIUhJ. has receiv d

contributions rom more than 0 perSOliS

and has made contribution to at last -

ederol candidat s. (7 last r qui, / /II

does not apply to state parry committees. )

II CFR JOO.5fe (3).

ati fied the qualif ing criteria.

Howe er. there can be a delay of

e eral month between the dale the

committee qualifies and the date the

ornmi ion n:: eive notice in the

rep 11. Thi i especiall true in an

off-ele lion. ear, when committees

file n a emiannual basis. For

.ample. if a comminee qualified

h rtl after filing a mid-year report.

th ommi ion \ ould nOI recei e

n ti e of the committee's multicandidate tatu until six months later,

\ hen the comm ittee filed its year-end

report. During that Lime. the ornrnittee \ ould not be listed in the Commi ion' I Iulticand idate Commi ttee

lnde . making it difficult for a

candidate committee to erify the

legalit of a contribution from the

ornmittee in e s of 1.000.

The proposed regulation \ ould

01 e thi problem b requiring a

nev I qualified committee to report

ilS multicandidate tatus in an

amended tatement of Organization

filed \ ithin 10 day follov ing the

qualif ing date (propo ed I I CFR

I02.2(a)(1)( ii» .

nd r the proposed rules, at the

time the amended taternent wa

filed. the ornrnission would not have

ufficient information to verify that

the committee had, in fact, qualified.

Therefore, the committee would also

be required 10 submit the following

data along with the amended latement of rganization (proposed

I I FR 102.2(a)(3» :

• Th date it first registered with the

Commi ion;

• A ertification that it had received

ontribution from more than -0

dono : and

Ii t of the federal candidates it had

upported, if unavailable from its

pre i u reports.

II lulti candidate onuni tte

II multi andidate ornmittees

\ ould be required to pro ide written

n ti e of their multicandidate tatu to

andidate committees hen making

ontribution to them (propo ed

I I CFR 110.2(a)(_ ). The lotice of
April /993

Propo ed Rulernakin ought comment on how thi might be done.

ugge. ting, f r example. that committe could ati f thi requirement b

printing the notice on their che . or

tationery. +

Partv p ndin Limi

Thi article provid updated

information n the coordinr ted party

expenditure limit ( 'Mla(d limits)

for the pedal electi n in Mi isippi, alif rnia r nd Texa .

f-or reporung dar and other

information on th 19 pecial

electi n cheduled to date. ee the

I larch 199 Record. In thi i ue, ee

the reporting articl thm follow and

the front page article on the Jul I

effective date of the ne regulation

prohibiting tran fer from nonfederal

campaign cornmiuee .

p cial Runoff Ele tion

Mis: i sippi. alifornia and Te as

will hold pecial runoff election if no

candidate win a majority of the vote

in the fir t pecial election. As a result

of a ommission decision in a recent

advi ory opinion. there is no eparate

coordinated parry expenditure limit

for these runoff election ; one limit

applie to b th the fir t election and

the runoff. There i . however. a

eparate contribution limit for each

election. ee the ummary of AO

1993-2. page 9.

e.'3 pial nat I ct ion

The coordinated part e penditure

limit for the Ma I pecial enate

election in Te a i 716._ I. based

on the 0 110\ ing formula: 2

12,5 4.000 ( 1992Texa voung age

populati n). multiplied b _. 6

(I 2 co t of Ii ing adju trnent). ee

II CFR llO.7(b)(i) and 110.9(c). +

Reporting

L t-Minut ntributi n :

48-Hou r Rep rtin

Authorized committee of eel ral

candidates mu t file pecial netic if

the recei e contribution of I.

or more hort l before the election.

_ C. .c. 434(a (6 ; I I FR I . .5( .

These notices are called "4 -hour

notices" becau e the are du \ ithin

4 hours of the committee' re eipt of

the contribution.

What Trigg 4 -H ur Reportin

A candidate committee mu t lie a

4 -hour notice if it receive a contribution of 1.000 or m re after th

close of books for the pre-el tion

report but more than h u before

the election.

This requirement applie to an

t pe of election in hich th candidate participate (primary. run ff.

general or special). including an

election in which the candidate i

unoppo ed.

The 4 -hour notice requirement

al 0 applie to all type of c ntribution of $ 1.000 or more, including:

• In-kind contribution ;

• Loan (other than bank loan );

• Guarantees and endor cmcnt of

bank loans;

• ontributions and personal loan

from the candidate; and

• The candidate' guarantee and

endorsements of bank loan .

2 C.S.c. 43 1(8)(A); I I rn

lOO.7(a).

What to Report

The notice mu t di clo e the

follov ing:

• The name of the andidate and the

office ought;

• The complete identification of the

contributor(name. add and. if

the contributor i an indi idual.

occupation and emplo er : and

• The date and amount of the contribution.

Federal Election Commission RECORD ---

Reporting on Time

A 4 -hour notice must be received

b the appropriate federal and late

filing office within 4 hours of the

campaign' receipt of the contribution.

Becau 4 -hour notice do not

ha e to be igned by the trea urer,

the rna besent b mailgram.

telegram or telefac imile (fax)

rna hine in order to meet the 4 -h ur

requirement. 0 19 -32. The a.

number for the Clerk of the Hou i

_0212_5-77 I; the fax number for the

ecretary of the enate i 2021224-

I 51. 01 : Other reports and

tarernents ma not be faxed becau

of the original ignature requirement.

ertified. regi tered and first-cla

mail are al 0 acceptable method of

sending a notice. provided the notice

i recei ed at the appropriate filing

office b the 4 -hour deadline. in the

c, e of a 4 -hour notice. a po tmark

dale i nOI ignificant for purpo of

filing on time. 0 19 -3_.

Wher to File

Authorized committee of House

and enatc candidates file with the

lerk of the Hou e or the Secretary of

the enate, a appropriate. 2 U. . .

§432(g ( I and (2); 11CFR 105.1 and

105.2.

House and Senate committees

, must simultaneously fi le copies of 48-

hour notices with the Secretary of

tate (or equivalent filing officer) in

the tate in which the candidate is

eeking election. 2 .S.c.

'4 9(a)(2) B).

Reporting on tributions a cond

Tim

The committee must itemize

contribution di clo ed in a 4 -hour

notice a econd time on the next

regularly cheduled report. 2 C. . .

434(a)(6)(B); I I CrR 104.5(f). +

(Reporting continued Oil page

7
Frdrrat Etecuon eVlI/min;m! RECORD '-""--

Reporting

[continued frolll /"tt~ t! 7)

Le tter 10 New Ca ndidates

on Reporting Problems

In 1992. the Commission began

sending a lener from theChairman to

newly registered candidates to alert

them to reponing problemscommon

to candidate commiuees. The Commission recently revised the letter to

include another area of concern: the

"best efforts" requirement for contributor information. The revised

leiter con tinues 10 provide guidance in

other problem area!'> as well.

Best ElTorts

Tbe letter underlines the need for

committees 10 obtain the required

contributor information-name.

address. occupation and employerfrom individuals whose aggregate

contributions exceed S200 in a

calendar year. Under the "best

efforts" standard. treasurers must

make atleast one effort per solicitation-and one effort for each unsolicited contribution-e-tc obtain the

required information from the

contributor. The request for the

information. either written or oral

(though an oral request must be

doc umented), must inform the

contributor that the reporting of such

information is required by law. The

letter gives examples of acceptable

and unacceptable requests:

• Acceptable: Federal law requires

that our commiuee report the full

name. address. occupation and name

of employer for each individual

whose contributions aggregate in

excess of $200 in a calendar year.

• Unaccc p ta blcr Federallaw requires

that we ask you for the following

information.

If the committee used an unacceptable "best efforts" request in us

solicitation materials. the committee

mUSI make an additional request to

obtain any missing information.

Missing contributor information

that becomes available after a repon

8

has been filed must be disclosed in an

amended report.

Ca ndidate Cont ributions and

Loa ns

Explaining that candidates are not

bound by the SI .QOC) limit when they

give or loan personal funds or other

assets to their own campaigns, the

letter points out three problem areas:

FlCSI. the funds or assets must

belong 10 the candidate personally.

Funds or assets from spouses. family

members. friends and other individuals are subject to the $ 1.000 per

election limit. In the case of property

joi ntly owned with a spouse. such as

stock that is liquidated or a home used

to secure a home equity loan. the

candidate may U'iC his or her personal

share of the asset; useof the spouse' s

share is a contribution subject to the

SI,OO:> limit.

Second. the funds must be reponed

as a direct COntribution or a loan from

the candidate. But note thai a candidate cannot make a direct contribution

and then later callthe gift a loan.

expecting repayment If the funds are

loaned. the report must make this

clear from the very beginning. This is

necessary to distinguish future loan

repayments to the candidate from

what would otherwise look like

personal enrichment. which is

prohibited.

Third. if the candidate obtains a

bank loan for campaign-related

purposes. the comrniuee must report

the bank-not the candidate-as the

source of the loan. although the

candidate must be reponed as the

endorser or guarantor.

Contributions that Appear

Excessive

"The letter warns candidates that

any check from an ird ividual rhat

exceeds $ 1.000 is suspect If the

check is drawn on ajoim account. the

full amount counts against the

contribution limit of the person

signing the check. If the contnbution

is to be divided between the joint

account holders. both signatures must

_ ___ ApnllCJ93

appear on the check or in an accompanying letter.

If a contribution exceeds the

SI.OXI limit. the excessive portion

must be: refunded £0 the contributor;

reanribured to a joint contributor; or

redesignated for a different election.

Until the problem is resolved, the

committee may 110 1 use the money.

(Many candidates ha....e found it

helpful to place the excessive funds in

a separate accounr.) TIle full amount

of the contribution must be reported.

but the committee should note that the

donor is being contacted 10 resolve

the problem. Unless the comnuuee

receives a reauribution or redesignalion signed by the contriburortsj.me

committee must refund the excessive

amount within 60 days after receipt of

the original check. (The Commission

sends treasurers of candidate committees both a copy of the leiter and a

Record supplement explaining the

redesignation and reauribution

process in more det ail.)

JS·llour Reporting

The letter reminds candidate

committees that they must comply

with this reporting requirement;see

previous article. page 7. +

,

Advisory

Opinions

'\0 1993-(

Campaign's Rental of Storage

Unit from Ca ndida te

Congressman Dan Burton proposed using personal funds to build a

storage shed on his property and then

to rent the unit to his campaign

committee for storage of campaign

materials. charging rent equivalent to

that charged by commercial Storage

finns in the area. The Commission

has previously concluded that this

type of arrangement is permissible.

See AO 1988-13 (campaign's
~p,.i 1993

payment of rent to the candidate for

torage pa e in a building owned by

the andidat ): . e al 0 A 1985-42.

19 3-1 and 197 - O. The rental

payment \ ould be reportable a

operating expenditure . ee I I CFR

104. (b _). Qu ting A 19 -l Lthe

Commi ion n ted that "[i] . uch

rent I pa rn nt b a andidate'

campaign mrniuee repr ent m re

than the u. ual nd normal harge for

the u e o the a ilitie in qu tion, the

amount in ex . 0 th u ual and

normal char e would be ubject to the

personal u e ban 0 2 .S. ' . 4 9a:' I

The ommi ion e pr ed no

opinion on the appli arion 0 House

rules r tao law to the propo ed

rivit , ince th e i u are out. ide

it juri diction.

i e hairman Tre r Potter \ rote

a con urring opinion. Date I ued:

February , 199 ; Length: 2 page .

plu I-page con urren e. +

119 -2

Applica tion of Part ' p nding

Limiu to pial Runoff

The Dem rari enatorial

ampaign rnrnittee ( 0 . ). acting

a. the agent for the 0 rno ratic

National ommiueeand the tate

Democratic ommitree of Texas.

plans to make coordinated party

(*44 Ia(d» expenditure ' for the

party' candidate in the May I pecial

enate election in Te as. (The

national ommiu e and the state

ommittee are ea h entitled to a

separate §441 a(d) limit on behalf of

the part . general election candidate.) If no candidate in a majority

vote in that election. the top two ore

getter will cornpet in a pecial

runoff election. The runoff election

\ ill not be on idered a eparate

general ele tion or purpo e 0 the

441< d) limit. There ore, the 0

a lember ofthe JOld Congre ,

COli reSJnUlJI Burton i prohibited from

C01ll rting campaign fund. to personal

W e', 2 U.S.c. . 39".

ha a ingle set of 441a(d) limits (the

national committee' limit and the

'tate committee' limit) 0 ering both

election . However. the runoff

election, if held. \ ill be on idered a

eparate ejection for purpo 0 the

contribution limi ,

The Cornrni ion av no pra ti al

difference betv een th Te a situation and the ituation in A 19 -16.

\ here a pecial runoff ele tion or a

California Hou e at would have

been held if no candidate had re eived

a majority of the vote in the first

pe ial election. In th t opinion, the

Commi ion oncluded that th fir t

election \ as a "general ele rion'

under JI CFR IOO.2(b _ be au. it

\ a. intended to re ult in the 111 I

election of a ingle indi iduaJ. The

runoff election \ a not on idered a

eparate general election \ ith a

eparate . Ia(d) limit. ne .

limit applied to both election .

A noted in A 19 - 16. a run f

election icon idered a eparate

election for purpos of the ontribution limit . whi h appl \ ith re peer

to "an election" or "each ele tion."

By contra t, coordinated party

expenditure limit apply to a "general

election campaign." ompare

2 U.S.c. §44 1a(a)(I), (2) and (6) to

*44I a(d).

The onference Report for th

1976 amendment to the t support

the separate treatment of expenditure

limits (§44 1a(d» and ontribution

limits(§44 Ia(a». The Rep rt e 'plain

that the "limited permi ion [in

§44 1a(d)] allow the political partie

to make contribution in kind by

pending money for cenain un tion

to aid the individual candidate who

represent the party during the ele uon

proce ." I The Rep rt ' languag

indicates that 441a(d . unlike

§441a a), addr the "el tion

proce "rather than pecific tage:

within the proc

I H.R. Rep. o. 1057, 94th COli .• 2d

Sess. 59 ( 1976).

Federal Elec/ion Commissio n RECOR D

Vice Chairman Trevor Potter filed

a di enting opinion: Commi sioner

Joan D. Aiken and Lee Ann Elliott

filed a joint concurring opinion. Date

I ued: larch 5. 1993: Length: 4

pages. plu 3-page di sent and 7-page

on urrencc. •

dvi 1")' Opinion Requ

Re ent reque t for advi ory

opinion (AOR) are listed belov .

The full te: t of each OR i available

for reviev and comment in the l-l:C'

Publi Record Office.

OR 199 •

Tran er from nonfederal a count to

correct overpayment by federal

a count 0 1991 and 1992expen es.

(Dernocra 2000: March 3. 199

page )

R 1993-4

Electroni pa ment of campaign

expenditure . (Chri topher Cox

ongre ional Committee; March 9.

199 : _ pages plu attachment)

OR 1 93-5

ontributions made in 1992 mi -

placed at po t office and discovered in

January 1993, Field for Congres ;

'larch 12, 1993; 6 pages plu attachments)

AOR 1993-6

Use of campaign funds by former

Member of I03d Congre s. Citizens

for ongre srnan Panetta. tarch 18,

1993:3 page ) +

9
Federal ELectionCommission RECORD _ ------- April L993.

Compliance

(continued from page 3)

ubjecl: Contribution limits

Disposition: (a) $8,000joint civil

penalty: (b) $800 civil penalty;

(c) $8.000 civil penalty; (d) $1,000

civil penalty:(e) $1,000 civil penalty;

(f) $2,500 civil penalty;(g) reason to

believe but took no further action;

(h) $19,800 civil penalty; (i) $ 15,000

civil penalty

M R 3456

Respondents: (a) William Lerach

( A); et at. (b)-{e)

ompluinant: Walter Palmer( A)

ubject: Contribution limits

Di position: (a) $7,100 civil penalty;

(b)-(e) reason to believe but took no

further action +

Court Cases

FE merica' P

In a defaultjudgment entered on

January 14, 199 . the U.. District

ourt of the cntral District of

aliforniaordered America' PA (a

state committee) and eil Barry

Rincovcr, as executivedirector and

acting treasurer, to pay a $25.000 civil

penalty for violating the Federal

Election ampaign Act. ( ivil Action

o. V- 2-2747-L n(Tx).)

The FE had alleged that

America'. P had altered an

earmarked contribution received from

the Phv ician Intcrindemnity/Pa

(PI/PA ) by changing the notation n

the che k from "Bill Pre s for .S.

enat .. to "political contribution."

The FE claimed that, becau e

America' PA converted and

dep ired the 2,000 contribution, it

became a p litical .ornmiuee with

attendant regi tration and reporting

bli arion that were never fulfilled.

The F further claimed that dcfendant knowingly accept d a

prohibited contribution from PIIPA ,

10

whose check contained corporate

funds.

The court granted the FEe'

motion for defaultjudgment, ordering

defendants to pay a $5,000 civil

penalty for each of five violations:

• Failing to forward an earmarked

contribution (2 U.S.c. §432(b» ;

• Failing to forward the requisite

information on the earmarked

contribution (§432(b» ;

• Failing to file a Statement of

Organization (§433);

• Failing to file periodic FE reports

(§434); and

• Knowingly accepting a contribution

that contained prohibited fund

(§441b(a» .

The court al 0 ordered defendant

to refund the $2,000 contribution to

PTIPA and to file a tatcrnent of

Organization and the required reports

within 15day .

Furthermore, given defendants'

default in the litigation, the ourt

found there wa a likclih d that

defendant would repeat the violations and therefore enjoined them

from further violation f the provision cited above. +

ational Rifle A ociation

ofAmerica v, FE

(92·5078)

On February25. It 3, the U.S.

01ll10f ppeal for the Di trierof

olurnbia ircuit, in a per curiam

judgment. affirmed the di trier court'

ruling in NRA v, FE . The lower

court had rejected the RA' challenge to the P 's di rni al of an

admini trativc complaint.

The di trier court ruled that it

lackedjuri diction to review the

FEC' dcci ion to di mi the complaint ince the agcn y had con idered the arne i ue in a previou

complaint. which it had al 0 di .

rni cd, and the 1 R had failed to

challcns that deci ion within the 60

day allowed by law. ( ivil Action

No. 89-. 0 I I.) The RA' administrative complaints had contended that,

because the members of Handgun

Control, Inc. (HCI) lacked the

necessary organizational rights to

qualify as "solicitablc members,"

HCr s solicitationsviolated the law.

(The district court decision was

summarized in the April 1992

Record.)

The court of appeal found that the

di.trict court had "correctly concluded

that appellant's fourth adrnini trative

complaint raised issues 'substantially

similar' to those re olved in a previous complaint, and that appellant's

petition forjudicial review was

therefore untimely." +

ommon au e v. F

(92-0249 (JHG

On March 3, 19 3, the

District curt for the Di trier of

olumbia di mi ed this uit by

agreement of both partie . Common

au e had asked the court to order the

FE to take action on an adrnini tralive complaint but agreed to drop it

claim because the agency had completed the inve tigation and entered

into conciliation agreement with the

re pendent . In it administrative

complaint, ommon au e had

alleged that even individual had

each exceeded the $25,000 annual

limit on aggregate federal contributions. (See ornpliance article , page

1and .) +

Public Funding

Final Repa ment D terminatim for Dukaki. and imon

1988 Primar I ampaign

The omrni ion has approved

final repayment determination

requiring the 19 Pre idential

primary ampaign of lichacl

Dukaki to return 4 1,2 2 in public

fund t the .S. Trca ury and

cnator Paul irnon' I 8
Presidential campaign to return

$412,163. [ The Dukakis for President

Committee had received over $9

million in primary matching funds,

while the Paul Simon for President

Committee had received almost $3.8

million.

The repayments were due within

30 days of the committees' receipt of

the final determinations. (The Commission accepted a $485,000 check

from the Dukakis committee in April

1991, which left only $6,282 outstanding on the rcpayment.)

The Commission issued Statements of Reasons to support these

final repayment determinations. The

Statements responded to the committees' challenges to the agency's earlier initial repayment determinations.

Both committees took the position

that the agency had failed to notify

them of their repayment obligations

within the statutory three-year deadline, which expired July 20, 1991.2

ommittees' Position on ThreeYear otification

The committees believed that they

received valid notification only when

they were notifi ed of the initial

repayment determinations contained

in the final audit reports, which were

approved after the July 199 1deadline.

(The final audit reports on the

Dukakis and Simon campaigns were

issued December 1991and October

1991, respectively.)

The Dukakis conuniuec, citing

Reagan-Bush ommittee II. FE and

arter/Mondaie Presidential CO IIIniittee. Inc. v, FEC, said that "the

courts have recognized that a repayment determination is made only

I The Commission rI{JfJ f(lI 'ed thefina!

determinations and their .HI{Jpol'lillg

statements of reasons 011 Februury 25

(Dukakis) utu! March" ( imon),

:Repaymeut notificatious tIllISI be 1II(Il/e

within three L'Ol'.I' f o/lOlvillg tli« end o]

the nuuchlng paytuen! period. 26 U. .c. ~90J8( c) The matching payment period

for /988 Democratic candidates ended

Jll ly 20. / 988.

when the final audit report is released

to the public." The conunittee further

cited a 1981 letter quoted in ReaganBush in which then Chairman

McGarry stated that a preliminary

repayment calculation "should not be

interpreted as a Commission determination: ' The committee believed that

it was not required to make any

repayment because the Commission

failed to meet the notification deadline.

The Simon committee, while it did

not specifically conclude that no

repayment was required because of

the alleged late notification, nevertheless contended that the three-year

period was a statute of limitations

similar to the timely notice of tax

assessments under the Internal

Revenue Code. The committee also

said thmtwo letters it had received

from the ornmission (dated January

1991and July 1991) were in apparent

contradiction as to what constituted

notification for purposes of the

statutory time limit.

ommi ion 's Position

The Commission said that it had

satisfied the three-year notification

requirement by providing the committees with preliminary repayment

calculations that were approved

before the three-year period had

expired. The preliminary calculations

were included in lhe Dukakis and

irnon interim audit reports issued in

February 1990 and July 1990,

re .pectively,

The ommission explained that a

preliminary repayment calculation

satisfies the notification requircment

because it is similar to an initial

repayment determination: Both

procedures require preparation by the

Audit Division, legal review by the

Office of General ounscl and

approval by a majority vote of the

Om missioners. "Thus," the .ommission stated, "the preliminary calculation supplics adequate notice of a

conunittec's repayment obiigations,

even though the exact figure may be

modified." The agency pointed out

FederalElection Commission RECORD

that it had recently revised its regulations to make this clear.

The Commission said that the

language from the court cases cited by

the Dukakis committee was inapplicable because the cases were decided

before the agency's 1983 promulgation of regulations that made the

interim audit report a formal part of

the audit process. Furthermore, the

agency explained, the purpose of the

1981 Chairman's letter quoted in

Reagan-Bush was to inform committees that a preliminary repayment

calculation was not considered a final

agency determination that was ripe

[orjudicial review. The notice

requirement in the statute, by contrast,

"requires only a notification of a

repayment, not a final agency determination," the Commission stated,

Addressing the Simon committee's

contention that two Commission

letters were contradictory, the agency

said that, although the earlier letter

(.Ianuary 199 1) referred to the threeyear requirement, it did not specify

what constituted suffic ient repayment

notification. However, the second

letter (July 1991) specifically informed the committee that its receipt

of the interim audit report satisfied the

notification requirement.

mphasizing that both the Dukakis

and Simon ornmittccs were "repeatedly notified, both formally and

informally, that a repayment would be

due," the ommission said that "the

public funding system would be

undermined" if thc committees'

argument. prcvailcd. : ince a campaign could "avoid its repayment

obligation entirely merely by using

stalling tactic. to delay the conclusion

of the ornmission's audit."

The Commission pointed out that

the committees' arguments "essentially amount to a justification for

[their) retaining thousand. of taxpayer

dollars to which [they] were not

entitled or which [they] spent in

violation of the law." +

/I
Federal Election Commission RECORD- -- April /993 ----

Federal Register

Copiesof Federal Register n tie 's

an: available from th Public

Records Office.

1993-7

Filing Dates for the alifornia

Special lection (58 FR 8959.

February 18. (993)

1993·8

II FR Paris 102 and 110: Mu ll icundidute Political ommittccs:

Notice of Proposed Rulcmaking

(58 FR 12189. March 3. (993)

1993·9

II FR PaJ1 102: Rulcmaking

Petition: 'ltizcns Against David

Duke: Notice of Availability ( X

FR 12189. March 3. 1993)

1993· 10

Filing Dale. for the \ i.con.in

pccial Elections (58 FR 12966.

March 8. 1993)

1 9 -II

II FR Part J J0: Trunsf rs of

Fund from tate to Federal ampaigns: Revised Implementation

Plan for ew Rule (58 FR 14 10.

March 17, (993)

FEDERAL ELECTION COMMISSION

999 E Street, NW

Washington, DC 20463

Official Business

*Printed on recycled paper

Index

The first number in each citation

I refers to the "number" (month) of the

1993 Record is. ue in which the article

appeared. The econd number. following the colon, indicate th page number in that issue.

dvisor Opinion

1992- 8: Loom from Pre idential

campaign's legal and complian e

fund to publi funding account, 1:6

1992-40: Commis ions earned by

Slate party ommittces, 2:5

1992-41: Solicitation of member . 3:

1992-42: Bank depo it 10 t in mail,

3:3

1992-4 : Preemption of tate law'

fu ndrai ing re trictions, :4

1993-1: ampaign' s rental of uoruge

unit from candidate. 4:

199 -z: Application of party . pending

limit to Texas pecial runoff. 4:9

ourt

FE

- Ameri a' P .4:10

- International Funding institute. 1:2

- People Politi . In .. 3:3

v . FE

ornmon Cause (92-0249 (JHG».

4:10

ommon Cause (92-_538), 1:8

- Lakouche. Lyndon H. (92-1555).

1:8

ational Rifle Association (92-

5078). 4:10

U. . enator John eyrnour Committee v, Diann Fein rein, 1:8

Reporting

Last-minute contributions: 48-hour

reporting, 4:7

Reporting problems, letter to new

andidaies, 4:8

'chedule for 1993. 1:

pecial Ie tions in alifornia,

Mis is ippi, hio,Texas and

Wi onsin, 3:I: 4:7

00 Lin rticl •

Party committee allocation: carrying

debt from previou electioncycle,

2:7

_5.000annu: I limit. 4:2

Bulk Rate Mail

Postage and Fees Paid

Federal Election Commission

Permit Number G-31