THE FEDERAL ELECTION

COMMISSION

1325 KStreet N.W., Washington, D.C. 20463

Volume 8, Number 10

REPORTS DUE IN OCTOBER

The following paragraphs explain the reporting schedule for the various categories of

filers that have reports due in October.

Quarterly Filers .Authorized candidate committees active in

1982 elections, as well as authorized Presidential

committees and noncandidate committees* that

have chosen to file on a quarterly (rather than a

monthly) basis, are required to file a quarterly

report, due by October 15. The report should

cover all financial activity from the closing date

of the last report filed or fro m the date of

registration, whichever is later, through September 30, 1982.

Pre-General Election Pilers

Authorized committees of candidates who

will participate in the 1982 general elections, as

well as noncandidate committees making contributions, coordinated party (§441a(d» expenditures

and independent expenditures in the general elections, must file a pre-general election report, due

by October 21. The report should cover all activity from the closing date of the last report filed

or from the date of registration, whichever is

later, through October 13, 1982.

In additio~ any eontribution of $1,000 or more

received by an authorized candidate committee

between two and twenty days before the general

election must be reported in writing by the recipient committee within 48 hours of its receipt.

Noncandidate committees (filing on a quarterly

basis) do not have to file a pre-general election

report if all disbursements made in connection

with the general elections have been previously

disclosed.

• Political committees that have not been

authorized by any federal candidate, e.g., separate segregated funds and party committees.

October 1

Monthly Pilers

Noncandidate committees that have cho

to file on a monthly basis must file a mont

report and a pre-general election report dur

October. The monthly report, due by October 

should cover all activity from the closing date 

the last report filed or from the date of reglst

tton, .whichever is later, through September 

The pre-general election report, due by Octo

21, should cover all activity from October 1, 

from the closing date of the last report fil

through October 13•

Note: In lieu of the monthly reports due in N

vember and December 1982 and January 19

noncandidate committees filing on a mont

basis must instead file pre- and post-general el

tion reports and a year-end report.

Forms and Information

Reporting forms and additional informat

have been sent to all registered com mitte

alerting them to their reporting obligations. Qu

tions and requests for additional forms should 

addressed to the Office of Public Communi

tions, Federal Election Commission, 1325 

Street, N.W., Washington, D.C. 20463; or c

202/523-4068 or toll free 800/424-9530.

DEADIJNE EXTENDED FOR COMMENTS ON

PRIMARY MATCHING PUND REGULA110NS

The Commission has extended the deadl

for submitting comments on proposed revisions 

its regulations governing the FEe's administrat

of the Presidential Primary Matching Fund p

gram. (See Commission Regulations at 11 C

Parts 9031 et seq.) Comments or questions on 

proposed revisions should be submitted to M

Susan E. Propper, Assistant General Counsel, 

November 15, 1982. Ms. Propper may be conta

e? at 202/523-4143 or by writing to the Comm

sion at 1325 K Street, N.W., Washington, D

continu
20463. A public hearing on the proposed revisions

has been rescheduled for November 17. Those

interested in testifying should notify the Commission in writing on or before October 29 and should

submit their written comments by November IS.

ADVISORY OPINION REQUESTS

The following chart lists recent requests f

advisory opinions (AORs). The full text of ea

AOR is available to the public in the Commi

.sion's Office of Public Records.

The Record is published by the Federal Election Commission, 1325 K Street, N.W., Washington,

D.C. 20463. Commissioners are: Frank P. Reiche, Chairman; Danny Lee McDonald, Vice

Chairman; Joan D. Aikens; Lee Ann Elliott; Thomas E. Harris; John Warren McGarry; William F.

Hildenbrand, Secretary of the Senate, Ex Officio; Edmund L. Henshaw, Jr., Clerk of the House of 

Representatives, Ex officio. POl' more information, call 202/523-4068 or toll-free 800/424-9530.

2

Breakfast and lunch club organized 

individual to raise funds for Congre

sional candidates. (Date made publi

August 18, 1982; Length: 1 page)

Quarterly reporting obligation for cam

paign of withdrawn Senate candidat

(Date made public: August 26, 198

Length: I page)

Subject

ADVISORY OPINIONS: SUMMARIES

An Advisory Opinion (AO) issued by the Co

mission provides guidance with regard to t

specific situation described in the AOR. A

qualified person who has requested an AO a

acts in accordance with the opinion will not 

subject to any sanctions under the Act. Oth

persons may rely on the opinion if they a

involved in a specific activity which is indisti

guishable in all material aspects from the activi

discussed in the AO. Those seeking guidance f

their own activity, however, should consult t

full text of an AO and not rely only on t

sum mary given here. .

1982-53 Corporate solicitation of licensee

(Date made publics September 14, 198

Length: 5 pages, plus supplement)

1982-51

AOR

1982-50

1982-52 Funds transferred from state campai

to federal campaign for debt retir

ment. (Date made publics August 3

1982; Length: 1 page)

ALTERNATE DISPOSITION OF

ADVBORYOMmONREQ~

AOR 1982-51 was withdrawn by its request

on September 30, 1982.

The intent of the proposed revisions is to clarify

and simplify administration of the matching fund

program and compliance with its provisions. The

changes have three major purposes: to provide

workable rules to govern many of the areas which

have caused uncertainty in the past; to provide a

fuller explanation of the certification and audit

processes; and to add new provisions to cover

aspects of the Presidential primary process not

previously addressed in the FEC's Regulations.

For more detailed information, see the August 17,

1982, edition of the Federal Rel;fister, page 35892.

Copies of the proposed reviSions may also be

obtained from the FEC's Public Communications

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

20463; or call 202/523-4068 or toll free 800/424-

9530.

ADVISORY OPINIONS

AVAILABLE ON MICROFll.M

During August, the FEC's Office of Public

Records made available two microfilm reels containing all advisory opinions (ADs) issued by the

Commission, as well as all advisory opinion requests (AORs) made public, between 1975 and

1981. One reel includes all AOs and AORs for the

period between 1975 and 1979; a second reel

covers the period between 1980 and 1981. An

index at the beginning of each reel indicates the

exact location of each AO and AOR. Paper copies

of this microfilmed information are available at

10 cents per page. The microfilm reels are also

available at $10 each. Checks should be made

payable to the FEC. For more information, contact the PUblic Records Office, 1325 K Street,

N.W., Washington, D.C. 20463 or call 2021523-

4181 or toll free 800/424-9530.
AO 1982-44: Donation of Free Air Time

to National Party Committees

by Cable T.V. Network

The Turner Broadcasting System, Inc. (Turner), an

incorporated cable television network, may donate two hours of free cablecast time to both the

Democratic National Committee (DNC) and the

Republican National Committee (Rl:-fC). Since the

programs aired during the free cablecast time

would constitute news commentaries specifically

exempted from the Act's definitions of "contribution" and "expenditure,l! Turner's donation of the

air time would not result in a prohibited corporate

contribution to either the DNe or the RNC. (The

programs will be aired on WTBS, a "super satellite" station owned by Turner.)

Turner is providing both major political parties

with an opportunity to discuss issues, to demonstrate their differences and to encourage support

of their respective parties. For example, the

cableeast program already aired by the DNC

consisted of a two-hour presentation by various

leading Democrats in which they discussed public

issues and programs from the Democratic Party's

perspective and solicited contributions to support

the DNC. Various Democratic Party officials and

officeholders also urged support of Democratic

candidates generally, but did not advocate the

election or defeat of any specific candidates.

The Act and Commission Regulations permit

broadcast (and other media) corporations to air

news commentaries (as well as news stories and

editorials) that are exempted from the Act's definitions of "contribution" and "expenditure,II provided: a) the broadcast corporation is not owned

or controlled by a political party committee,

political committee or candidate and b) the

broadcast corporation is acting within its legitirnate broadcast function in airing the com mentary. 2 U.S.C. §43l(9)(B)(i); II CFR sections

lOO.7(b)(2) and 100.8(b)(2). Turner's offer of free

air time satisfied these criteria. Furthermore,

news commentaries covered by the media exemption Were intended to give third parties, such as

the DNC and the RNC, access to the media to

discuss issues. The Act and FEC Regulations do

not define the issues that third parties may discuss or the format for their presentation; nor do

they set limits on the length of the commentaries.

The Commission cautioned that any deviation

from the facts presented by the requesters in

their advisory opinion would compel the Commission to reconsider whether, based on the new

facts, the media exemption would apply. Chairman Frank P. Reiche filed a dissenting opinion.

(Date issued: August 27, 1982; Length: 7 pages,

including dissent)

3

AO 1982-4'1: Single Contribution Limit for

Candidate Seeking Nomination

by Three Parties

Although Ms. Florence M. Sullivan sought nomin

tion by three different parties (i.e., the Repub

can, Conservative and Right-to-Life Parties) 

the New York Senate primary,« contributions 

her campaign were SUbject to a single, per ele

tion limit. Under the Act and Commission Reg

lations, the primary was considered one electio

and Mrs. Sullivan was considered to be seeki

one federal office, that is, U.S. senator from N

York. (See 2 U.S.C. §43l(3)j 11 CFR lOO.2(c

and 104.4.) (Date issued: August 20, 1982; Leng

4 pages)

AO 1982-48: Coordinated Party Expenditures

in Behs.lf ot Independent

Candidate

Since Mr. Henry A. Huish is affiliated with t

Utah State Democratic Committee (the Co

mittee), the Committee may make coordina

(§44Ia(d)) expenditures in behalf of his gene

election campaign for the House seat in Uta

Third Congressional District, even though M

Huish is listed on the ballot as an independ

candidate. (Mr. Huish is running as an independ

candidate because he failed to meet state 

quirements for ballot access as the Democra

nornlnee.)

While the Act requires that a candidate for fed

al office be affiliated with the political party th

plans to make coordinated expenditures in his 

her behalf, the Act does not require that t

candidate be listed on the general election bal

as the party's nominee. For purposes of coor

nated expenditures, Mr. Huish's affiliation w

the Democratic Party is evidenced by the f

lowing facts:

1. Delegates to the Utah State Democra

Convention formally nominated Mr. Huish 

the party's candidate for the House seat.

2. The Committee continues to endorse M

Huish as its candidate. No other candida

will appear on the general election ballot 

the Democratic candidate. (Date issue

August 26, 1982; Length: 3 pages)

"'The New York primary was held on Septe

ber 23, 1982.
SEPARATE SEGREGATED FUNDS

ANDINDEPENDENTPACS

The. press and pUblic refer to all nonparty,

noncandidate committees as PACs or political

action committees. However, the Act and Commission Regulations distinguish between two types

of PACs: separate segregated funds and independent political com mittees (or independent PACs).

The article below discusses some of the major differences between these two types of political

committees.

What is the principal difference between separate

segregated funds and other PACs'?

The Act prohibits corporations (profit or nonprofit), labor organizations and incorporated

membership organizations from making direct

contributions or expenditures in connection with

federal elections. 2 U.S.C. §44lb. These organizations may, however, sponsor a separate segregated fund (SSF), popularly called. a PAC, which

collects contributions from a limited class of

individuals and uses this money to make contributions and expenditures to influence federal elections. 11 CFR 100.6. As the sponsor of the SSF

(Le., its "connected organization"), the corporation, labor organization or incorporated membership organization may absorb all the costs of

establishing and operating the SSF and soliciting

contributions to it. These administrative expenses

are fully exempted from the Act's definitions of

"contribution" and "expenditure." II CFR 114.1(a)

(2)(iii).

By contrast, an independent political committee,

an~ther type of PAC, is financially independent.

ThIS means that the independent political committee must pay for its own administrative expenses, u~ing. the contributions it raises. Although an

orgamzation may spend funds to establish or support an independent PAC, these expenditures are

considered contributions to the PAC and are subject to the dollar limits and other requirements of

the Act.

Do the reporting requirements vary for SSFs and

independent PACs!

Yes. An SSF is not required to report any

fundraising' or administrative expenses that are

paid for by its sponsoring organization. (The SSF

must, however, report these expenses if it pays

for thern.) On the other hand, an independent PAC

must report all its operating and solicitation expenses.

4

Are different restrictions placed on the groups 

individuals who may be soJieited by SSFs and i

dependent political committees!

Yes. SSFs may solicit only certain groups 

individuals specifically identified in the Act an

Commission Regulations, while independent PAC

may solicit contributions from the general publi

For example, a corporation with capital stock an

its SSF may solicit only the corpora tion's stoc

holders, executive and administrative personn

and the families of both groups. II CF

114.5(g)(l). A labor union and its SSF may solic

only union members and their families. II CF

114.5(g)(2). Twice a year, SSFs and their spo

soring organizations may expand their solicit

tions to include certain individuals outside t

nor mal restrictions; the expanded groups are al

specifically limited by the law. 11 CFR 114.6.

Do SSFs have any special requirements in solic

ing contributions that independent PACs do n

have?

Yes. For example, under Commission Reg

lations, SSFs must inform their solicitees of th

polltical purpose of the SSF and of the individua

right to refuse to contribute without reprisa

SSFs are specifically prohibited from usi

threats of physical force, job discrimination 

financial reprisal when soliciting contribution

Moreover, if the SSF uses a guideline in soliciti

contributions, the solicitees must be inform

that they are free to contribute more or less th

the amount stated. In addition, SSFs may n

accept as contributions any dues or fees obtain

as a condition of membership or employment. 

CPR 114.5(a).

Independent political committees are not subje

to these solicitation restrictions. On the oth

hand, solicitations by independent PACs that a

~ade through public political advertising mu

m~lude an authorization notice indicating w

paid for and authorized the solicitation. This ty

of notice is not required on SSF solicitations. 

CFR llO.ll(a)(l)(iv).

Do the registration requirements for an SSP diff

from those for independent PACs?

. Yes•.An SSF must register within 10 days 

Its establishment by its sponsoring organizatio

II CFR 102.1(c). An independent PAC howeve

must . " register as a political committee within 

days after it has received contributions or ma

expenditures aggregating in excess of $1,000. 

CFR 102.I(d).

Are the titles chosen for SSFs and independe

PACs subject to different requirements?

.Yes. The Ac.t and Commission Regulatio

require an SSF to Include the name of its sponso
ing organization in its official title. 2 U.S.C.

§432(e)(5); 11 CFR I02.14(c). The Act places no

such restriction on the title that an independent

PAC uses. Neither committee, however, may include the name of a candidate in its title.

May both an SSF and an independent PAC contribute up to $5,000 to each of a candidate's election

campaigns?

Yes, provided the SSF or the independent

PAC has qualified as a multicandidate committee

by: 1) having been registered with the Commission

at least six months, 2) having received contributions from over 50 persons and 3) having made

contributions to at least five candidates for federal office. 2 U.S.C. §44la(a)(5).

What other requirements of the Act and FEe

Regulations apply to both SSFs and independent

PACs?

Most of the basic requirements of the Act

and Regulations are the same for SSFs and independent political committees. For example, the

prohibitions and limits on contributions apply

equally to both SSFs and independent PACS. In

addition, both types of committees must fulfill

the same basic reeordkeeping and reporting requirements, although an SSF does not have to

report :operating expenses paid for by its sponsoring organization (see above). Finally, SSFs and

independent PACs may support candidates in the

same ways, that is, by making monetary and

in-kind contributions to candidates, by contributing to their political parties and by making

independent expenditures to support or oppose

candidates.

The item below identifies an FEC document

that appeared in the Federal Register on September 22, 1982. Copies of this notice are available in

the Public Records Office.

Notiee Title

1982-7 Filing Dates for Special General Election, Ist Congressional District, Indiana

(Citation: 47 Fed. Reg. 41861)

5

SUMMARY OF MOOs

The Act gives the FEC exclusive jurisdict

for its civil enforcement. Potential violations 

assigned case numbers by the Office of Gene

Counsel and become "Matters Under Revie

(MURs). All MUR investigations are kept con

dential by the Commission, as required by 

Act. (For a summary of compliance procedur

see 2 U.S.C. §§437g and 437(d)(a) and II C

Part 111.)

This article does not summarize every stage 

the compliance process. Rather, the summ

provides only enough background to make cl

the Commission's final determination. Note t

the Commission's actions are not necessar

based on, or in agreement with, the Gene

Counsel's analysis. The full text of this MUR 

available for review and purchase in the Comm

sion's Public Records Office.

MUR 1398: Independent Expenditures, Multi

Candidate Committee Status,

Prohibited Contributions

On May 5, 1982, the Commission found reason 

believe that a political action committee (PA

had improperly reported an in-kind contribution 

an independent expenditure and had contribu

over $1,000 to a candidate committee bef

achieving multicandldate committee status. T

Commission also found reason to believe 

PAC's sponsor, an incorporated special inter

group, had made prohibited contributions.

Complaint: In a complaint filed on November 

1981, a political com mittee sta ted that indep

dent expenditures allegedly made by a spec

interest PAC in behalf of a candidate and agai

his opponent did not qualify as independent exp

ditures because there was coordination betw

the PAC and the candidate's committee. Acco

ing to the complainant, the PAC had violated 

Act's reporting provisions by identifying the p

ments in question as independent expenditu

rather than as in-kind contributions in the can

date's behalf. The complainant also alleged t

because of this mistake and other reporting 

rors, the PAC had actually contributed o

$5,000 to the candidate committee, a violation 

the Act's limit on contributions by multicandid

com mittees. (See 2 U.S.C. §441a(a)(2)(A).) 

though not specifically alleged, the candid

committee's acceptance of excessive contri

tions might have violated Section 441a(f).

A second part of the MUR arose from a refer

by the Commission's Reports Analysis Divis

continu
questioning the validity of the PAC's multicandidate committee status. If the PAC had not attained that status, its per candidate, per election

contribution limit would have been $1,000 rather

than $5,000.

General Counse's Report:

Independent Expenditures or In-kind Contributions. In an effort to show that coordination

between the committees did exist, the complainant submitted samples of two brochures, similarly

designed and printed, one distributed by the PAC

and the other by the candidate committee. The

complainant contended that this and other evidence of the PAC's "continued involvement" in

the candidate's campaign prevented any expenditure in the candidate's behalf from being independent.

In response, the PAC admitted that its brochure

had been prepared in cooperation with the candidate's committee but showed that it had reported

the expense as an in-kind contribution to the

candidate. The second brochure, the PAC noted,

had been produced "exclusively" by the candidate

committee. The General Counsel's Report concluded that the similarity between the brochures

was relevant only if the PAC had reported its

expenditure as independent and if it had failed to

provide factual evidence that the expenditures in

question were not independent.

With regard to a letter opposing the candidate's

opponent, which was distributed by the PAC and

reported as an independent expenditure, the General Counsel concluded the expenditure was really

a contribution in-kind. The General Counsel's Office found that, in its mailing, the PAC had

enclosed a copy of the brochure produced in

cooperation with the candidate it supported,

which compromised the independence of the communication. The PAC's expenditure of $247.52 for

the mailing was, in effect, payment for the distribution of candidate campaign literature and, as

such, was an in-kind contribution. By improperly

reporting the expenditure as independent, the

PAC had violated Section 434 of the Act. But,

because the expenditure would have been independent had not the PAC enclosed the brochure, and

because the amount of the expenditure was only

$247.52, the General Counsel's Report recommended the Commission take no further action in

this matter other than sending the PAC and the

candidate com mittee letters of admonition. The

letters would request that they amend their reports to show the expenditure as an in-kind contribution.

Finally, the complainant alleged that a portion of

the PAC's administrative expenditures should

have been reported as in-kind contributions to the

6

candidate, since over 30 percent of the PAC

activities benefited the campaign. Agreeing th

part of their expenses for a 1980 issue of the PA

magazine should have properly been allocated 

an in-kind contribution to the candidate, the PA

amended its report, showing $52.23 as an in-ki

contribution•.The Genera.l Counsel's report reco

mended the Commission accept this amendme

noting that there was no factual basis for t

allegation that other portions of the PAC'S adm

istrative expenses should have been reported 

in-kind contributions.

Multicandidate Committee Status. To qualify as 

multieandldate committee, with a $5,000 per ca

didate, per election contribution limit, a PA

must: 1) have been registered with the Comm

sion at least six months, 2) have received cont

butions from over 50 persons and 3) have ma

contributions to at least five candidates for fe

eral office. Z U.S.C. S441a(a)(5). Although t

PAC had fulfilled the first two requirements, 

did not satisfy the third until September 13, 198

However, during the previous JUly and August, t

PAC had contributed over $3,000 to the candida

committee. The PAC claimed that its connect

(sponsoring) organization, an incorporated spec

interest group, had fulfilled the third requireme

by making in-kind contributions to to Congr

sional candidates totaling $150. The PAC, 

though it had not originally reported these cont

butions, regarded the money as a debt that 

owed to its connected organization. The PA

further provid-ed an amended October quarter

report identifying PAC payments to the conne

ed organization (to extinguish the debt) as in-ki

contributions to the 10 candidates. The Gene

Counsel's Report rejected this solution as tech

cally impermissible, as Section 44lb of the A

prohibits a connected organization from advan

ing money for PAC contributions. The Repo

noted, however, that the PAC qualified as 

multieandidate committee shortly after the e

cess contributions were made, The Report ther

fore recommended the Commission take no fu

ther action on the issue beyond finding reason 

believe that the PAC had violated the Act 

contributing over $1,000 to a candidate befo

achieving multicandidate status.

Prohibited Contributions. The General Counse

Report stated that the connected organization

payments totaling $150 for in-kind contributio

were prohibited corporate contributions in vio

tion of Section 441b. The Report therefore r

commended that the Commission find reason 

believe the organization had violated that secti

but, because the amount of money involved w

not significant, also recommended the Comm

sion take no further action beyond sending t

respondent a letter of admonition.
Commission Determinations: On May 5, 1982, the

Commission:

1. Found reason to believe the PAC had violated

Section 433 by improperly reporting $247.52

as an independent expenditure rather than as

.. an in-kind contribution;

.. 2. Found no reason to believe the candidate

committee had committed any violations of

the Act as alleged in the complaint;

3. Accepted the PAC's reporting amendment

allocating $52.23 of its administrative expenses as an in-kind contribution;

4. Found reason to believe the PAC had violated

seetion 44la by contributing over $1,000 to

the candidate ' before attaining multicandidate status; and

5. Found reason to believe the PAC's connected

organization had violated Section 44lb by

making contributions to 10 Congressional

candida tes.

The Commission sent letters of admonition to the

respondents and closed the file.

FEe PUBLISHES THE NAMES OF NONFll..ERS

. On July 30, 1982, the Commission published

the names of three political committees supporting candidates in the Kansas House primary election and the Missouri House and Senate primaries

which had failed to file their pre-primary report,

due 12 days before the primary elections in those

states. The primary elections in both states were

held on August 3. Pre-primary reports should have

covered campaign finance activity from July I

through July 14, 1982.

On July 28, 1982, the Commission had notified the

committees of all candidates participating in the

Kansas and Missouri campaigns of their potential

reporting requirements, Subsequently, the Commission notified those com mittees failing to file

timely reports that their names would be published if they did not respond to the FEe's notice

within four business days.

Other political com mittees (not authorized by

candidates) that supported candidates in the Kansas and Missouri primaries were also required to

file pre-primary reports unless they had been

reporting on a monthly basis. The 1979 amendments to the election law do not, however, require the Commission to publish the names of

these unauthorized committees.

Further Commission action against committees

that fail to file reports required during the 1982

election year will be decided on a ease-by-case

basis. The Act gives the Commission broad authority to initiate enforcement actions against

any nonfiler, including civil enforcement and the

imposition of civil penalties.

7

AUDITS RELEASED TO THE PUBLIC

The following is a chronological listing 

audits released by the Commission between Ju

3 and August 12, 1982. Final audit reports 

available to the general public in the Pub

Records Office.

1. Citizens' Advocate Political Action Comm

tee (Final audit report released June 3, 19B

2. Liberal Party Federal Campaign Commit

(Final audit report released June 17, 1982)

3. Libertarian National Committee (Final au

report released June 22, 1982)

4. National Women's Political Caucus of C

fornia (Final audit report released JUly 

1982)

5. Idaho Democratic Partv-Federal Account (

nal audit report releas~d July 15, 1982)

6. Senate Defense and Economic PAC* (Fi

audit report released August 10, 19B2)

7. Democratic State Central Committee 

California) Federal Candidates Fund (Fi

audit report released August 12, 1982)

*Formerly known as the Senator John Tow

'PAC.

CHANGE OF ADDRESS

Political Committees

Registered political committees are

automatically sent the Record. Any change

of address by a registered committee must,

by law, be made in writing as an

amendment to FEC Form 1 (Statement of

Organization) and filed with the Clerk of

the House, the Secretary of the Senate or

the FEC, as appropriate.

Other Subscribers

Record SUbscribers (who are not

political com mittees), when calling or

mailing in a change of address, are asked

to provide the following information:

1. Name of person to whom the Record is

sent.

2. Old address.

3. New address.

4. Subscription number. The SUbscription

number is located in the upper left

hand corner of the mailing label. It

consists of three letters and five

numbers. Without this number, there is

no guarantee that your SUbscription

can be located on the computer.
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