May /993

able of Conten

Advisory Opinions

Regulati ons

Conflicting Testimony on Proposed

"Best Efforts" Rule

4 Commission Holds Public Hearing

on Ex Pane Communication Rules

COUl1 Ca es

2 FEC v. International Funding

Institute

Publi c Funding

2 Update on 1992 Matching Fund

Program

Publi c Appea ra nces

5 FECStaff to Hold Meetings in

Hanford, Indianapolis, Helena and

Lincoln

800 Line

5 Credit Card Contributions

Statistics

6 Democrats Narrow Fundraising Gap

Compliance

7 MURs Released to the Public

8 Index

Publi cati ons

8 Free Copies of 1993 Disclosure

Directory Available

Federal Election Commission

Advisory

Opinions

AO 1993-3

Retroactive Reallocation

of 1991-92Activity

Democrats 2000, a nonconnected

committee, may retroactively reallocate its fundra ising and administrative

expen es for the period January 199.1

through May 1992, when the cornrmttee had difficu lty understanding and

implementing the allocation rules.

TIle committee said that during that

time-before it had an effective

allocation system in place-the

federal account had overpaid its share

of joint administrative and dr~isi ng

expenses by $20.375. The committee

may adjust for the overpayment by

transferring that amount from the

nonfederal account to the federal

account but must do 0 within 30 days

from the date of the opinion.

The Commission has permitted

retroactive reallocations in three

previous opinions, recognizing that

the allocation regulations (which

became effective at the start of 1991)

were a significant departure from.past

practice and required a "brief penod

of adjustment," i.e., the 1991-92

election cycle. AO 1992-2. See also

AOs 1992-27 and 199 1- 15. The

opinion noted that Democrats 2000

(continued on page 2)

Regulations

Commission Hears Conflic

Testimony on Proposed "B

Efforts" Regulations

The Commission heard diverg

views on proposed rule that wou

requirecommittee to make a sec

request for missing contributor 

information. At the larch 31 he

witnesses representing political

committees believed that the pro

requirement would strain budget 

do little to enhance disclosure. Pu

interest groups, by contrast, supp

the change but advocated a furth

measure under which committee

when makinga request for missi

information. would have to retur

contribution or, alternatively, wit

hold deposit until the contributor

responded.

Propo. ed Rulernakin g

The Federal ElectionCampaig

Act requires committees to use "

efforts" to obtain and report the n

addre'S, occupation and employe

individuals whose contribution

exceed $200 or aggregate over $

in a calendar year. 2 U.S.c. §432

Under the current regu lation (I I 

104.7(b)), a committeesatisfies t

requirement if the originalsolicit

includes a request for the inform

and states that the committee is

(continued on p
Cumula 

Candidate Total

Republicans

Patrick Buchanan $ 5.199.

George Bush 10.6585

Democ r a ts

Larry Agran 2ffi.

Jerry Brown 4.239.

Bill Clinton 12.536.

Tom Harkin 2.103.

Bob Kcrrcy 2.1 955 

r aul Tsongas 2.995.4

Douglas Wilder 289.0

New Alliance " art }"

Lenora Fulani 2.013.

Natural Law Party

John Hagelin 353.

Total ~2.853.

F~du(J/ fire /ion Commission RECORD

Advisory Opinions

{continued from page 1)

submined its advisory opinion request

on December 31. 1992. the lastday of

the "brief period of adjustment"

mentioned in AO 1992-2.

The opinion also noted that the

current allocation rules (effective JUIlC

1992) provide a 7Q..day window

within which a comminee's nonfedcral account must transfer funds to its

federaJ account 10 pay for the nonfederal share of a joint expense. The

window begins 10 days before and

ends 60 days after the federal account

makes the payment. 11 CFR

106.6(e)(2)(ii)(B). The rules also

require comminees to adjust the

allocation ratio for direct fundraising

costs within 60 days after the fundraising program or event. II CFR

106.6(d)(2). Date Issued: April 2.

1993;Length: 6 pages. +

Federa l Elretion Commix...ion

lJ9C) . : Slrt't't. NW

Wa, hinb'10n, uc UM6J

KOOJ424-9530

20"-'219·3420

2021219-3336 (T OO)

Scott E. Thomas.Chainnan

Trevor Putter, Vice Chairman

Joan D. Aiken.., Conuntsxlcncr

L('(' Ann t<:lIiolt. Commissioner

Danny L. McDonald.

Ccmmlssloner

J ohn w arren McGarr)',

Commissioner

Walter J. Stewart. Secretary

of the Senate. ExOfficio

Commissioner

Donnald K. Anderson. Clerk

of the House of Representatives,

ExOfficio Commissioner

John C. Surina, StaffDirector

Le wrence M, Noble. General

Counsel

Publisb:d by the Infonnation

Division

Lo uise n.wldes, Dnector

Stephanie fitll:mlld. Editor

Blake lange,Graphics Acvlsor

,

Court Cases

FEe v, International Funding

Institute

On March I, 1993. the U.S.

District Court for the District of

Columbia ordered defendants to pay

an S18.0CX> civil penally for knowing

and willful violations of the sale or

use restriction. Linder 2 U.s.c.

§438(a)(4), it is unlawful to sell or

use, for solicitation or commercial

purposes, infonnation on individual

contributors taken from reports filed

with the FEe.

Defendants had challenged the

constitutionality of the provision,

claiming that it violated the First

Amendment. In a July 1992 ruling,

however. a U.S. court of appeals

upheld the constitutionality of

§438(aX4). Later that year. in Kovember. the U.S. Supreme Court

refused to review the court of appeal's

ruling. leaving that decision intact I

"The case was then remanded to the

district court.

According to the facts of the case.

defendant Robert E. Dolan, as an

officer of International Funding

Institute ([FT). subscribed to an online data base containing contributor

names and addresses compiled from

I--'EC reports. IFI developed the data

into a mailing list, w hich it marketed

through a broker. IFI received some

59.500 in rental income. Mr. Dolan.

as committee treasurer of American

Citizens for Political Action, Inc.

(also a defendant). rented the list.

using it to solicit about 5.<XXJ individuals for contributions [0 the

committee.

Defendants agreed to the district

court's order. which imposed the

S18.0CX> penalty and also permanently

enjoined defendants from future

violations of the sale or usc

restriction. +

I For a 5ummaryoft"~cour1ofappeal 's

decision. see the SeplemMr / 991 Record.

page 11.

May / 

Public Funding

Upda te on the 1992l\lalchin 

Fund Program

By the end of March 1993.the

Commission had certified almost

$42.9 million in matching funds to 

11 Presidential primary candidates

who qualified for the 1992 matchin

fund program. March I was the las

day candidates could request matc

ing funds in an original submission

(Only three candidates made subm

sions on thai dare.)The Commissio

certified payments for the last subm

sions in late March, and the payme

were made by the U.S. Treasury in

early April.(Sec table bclow.)

Candidates may continue to ma

rcsubmissions through September

1993, although payments based on

resubmlssions will probably be sm

(Resubrrussionscontain contributio

that were previously rejected becau

of deficiencies in the original submission.) +

Matching Fund Payments

Through April 1993
•

•

•

Regulations

(continued from page JJ

required by law 10 report the information. (Comnunees generally include

the request and statement on a

contributor return card.)

Concerned that some comnunees'

reports showed a significant percentage of incomplete contributor infermarion, the Commission proposed to

strengthen and clarify the current rule

by requiring thar cornminees:

• Request the contributor information

in every solicitation.

• Make a separate. follow-up request

for missing information with respect

to both solicited and unsolicited

contributions.

• Report information not supplied by

the contributor bUI known by the

treasurer or the treasurer's agents.

• File amended reports when mis-sing

information is later obtained. (This

simply clarifies a current requirement.}

The Commission sought public

comment on the above changes in a

Notice of Proposed Rulemaking (57

FR 44137, Septemher 24,1 992) and

later announced the public hearing.

The Notice and written comments are

available in thePublic Records

Office. (A transcript of the public

hearing will also be placed on the

public record.)

The Commission received written

comments front 14 groups and

individuals and heard testimony from

six witnesses: Keith A. Davis, vice

president of Huckaby and Associates;

Michael A. Hess, acting chief counsel

of the Republican National Commitfee; Robert F. Bauer of Perkins Coie:

SIUar1 Reges, national director of the

Libertarian P3J1y; Elizabeth Hedlund,

project director for the Center of

Responsive Politics: and Donna F.

Edwards, staff attorney for Public

Citizen.

Testimony by Committees

Witnesses resnfying from the

standpoint of political comminees

agreed that comributoes most often

left out occupation and employer

from their return cards. However, the

witnesses contended thai requesting

this information a second lime would

be lime consuming. costly and, in the

end, not worth the effort. since

comminees who voluntarily made

follow-up requests said that response

rates were low. This view was held by

the Republican National Committee

(Rl'C). the Libertarian Party and J\1I.

Davis of Huckaby and Associates.

Mr. Reges said that the proposed

follow-up request would be particularly burdensome for the Libertarian

National Commitree. with its small

staff and limited resources. Some

witnesses discussed whether it would

be more effective to make follow-up

requests by phone rather than by mail.

but there was no consensus. There

was also discussion on whether

comrninees would be more likely to

obtain and disclose occupation and

employer information if the FEC were

to release statistics on committees'

success rates in reporting that infermarion.

In his testimony, Mr. Hess (R.l'\C)

argued that the Commission lacked

statutory authority to impose the

follow-up requirement. Mr. Hess said

that, in RNCs reading of the legislative history, a single request for

contributor information satisfied "best

efforts."

Witnesses generally did not believe

that contributors failed to provide the

information because of the small type

size or poor placement of the printed

request for the information Rather.

they said, contributors choose not to

comply with the request for a number

of reasons, such as to protect their

privacy or OUI of simple indifference.

Nevertheless. mo...t witnesses said that

they would agree to a regulation

specifying a standard wording and

display for the information request.

Mr. Bauer (Perkins Coie) encouraged the Commission 10 adopt such a

regulation and to postpone further

revisions until the agency had evaluated the effectiveness of the rule. He

also suggested that the Commission

Federo!Election Commission RE

conduct a survey to find out why

contributors withhold informatio

whether missing contributor info

lion is more characteristic of one 

of committee than of another (e.g

candidate. p3J1y or PAC).

Both in testi mony and written

comments. IDose representing

commiuees urged the Commissio

delete the proposed requirement

concerning the disclosure of mis

information based on the treasure

knowledge. Several arguments w

put forward. E rst. a contributor c

have purposely withheld the info

lion and would object to its discl

sure. Second. treasurers typically

cannot review all contrib utions. A

third, treasurers mig ht be held lia

for disclosure ofinaccurate infor

tion. Some witnesses discussed t

possibility of USlOg a comnunee'

fundraising or contribu tor data b

conj unctio n with the committee'

computerized reponing system.s

the data base might hold informa

not disclosed by the contributor i

return card.

Finally, committees and pract

tioners a...ked the Comm i...sion ab

the requirement to file amendme

disclose pre viou sly missing cont

tor information. For example, so

witnesses asked if they could file 

such amendments with their next

regularly scheduled report instea

filing separate amendments as

contributor responses trickled in.

Testimony by Pub lic Interest

Gro ups

The Center for Responsive Po

and Public Citizen supported the

proposed changes 10 the "best eff

rules but recommended stronger

measures to ensure disclosure of

complete contributor information

Hedlund and Ms. Edwards both

testified that Congress recognize

importance of the public's right t

know the occupation and employ

a contributor.

Citing statistics compiled by t

Center, Ms. Hedlund noted the

{continued on pa
Federat Election CommiSJion RECORD _______ ____---C:' Mu)' 

Regulations

[continued from page 3)

considerable disparity in the disclo--

sure of contributor information by

candidates' campaigns. While some

campaigns managed to obtain and

report the occupation and employer

for a large percentage of their contributions. many other campaigns were

much less successful. Both public

interest groups believed that the

campaigns who had a high percentage

of fully identified contributions

simply took the law more seriously.

and made greater efforts to obtain the

information. than the campaigns with

low percentages. Ms. Hedlund

recommended that the Commission

promote "best efforts" in three ways:

• Commiuees should be required to

return a contribution received

without full contributor information

or. alternatively, to delay deposit of

the check until the contributor

responds to the comminee's wri tten

request for the information. Under

the alternative. the committee could

also deposit the check if the contributor fails to respond within a

certain time period. to be set by the

Commission.

• The Commission should amend its

Presidential primary matching fund

rules to require that committees

provide full contributor identification for every contribution submitted

for matching funds; if information is

missing. the contribution should not

be matched with federal funds.

• The Commission should adopt an

enforcement policy of auditing

comnutrees whose incomplete

contributor identification exceeds a

certain threshold percentage.

Both the Center and Public Citizen

believed that the Commission had

statutory authority to implement

stronger "best efforts" rules. In their

view. the legislative history supported

such measures. +

4

Commission Holds Pu blic

Hea ring on Ex Parte

Communica tions Rules

At an Aprill public hearing, the

Commission heard testimony from

two witnesses who, while generally

supporting the interimrules on ex

parte communications.' suggested

some changes. A third witness.

however, said that the rules went too

far in restricting communications

between private parties and the

Commissioners.

The three witnesses testifying at

the hearing were Robert F. Bauer of

Perkins Coie: Elizabeth Hedlund.

project director for the Center for

Responsive Politics; and Ernest

Gcllhom of Jones. Day, Reavis &

Pogue.They also submitted written

comments. which are available for

review in the Public Records Office.

(A transcript of the hearing will also

be made available to the public.)

The Commission will publish final

rules after considering comments and

testimony on the interim rules.

Interim Rules

The Commission sought comments

on the interim ex pane communications regulations. which became

effective when published in the

Federal Register on December 9,

1992 (57 FR 58133). The rules

govern written and oral communications between outside parties and

certain covered personnel: the six

voting Commissioners and the two ex

officio Commissioners (the Clerk of

the House and the Secretary of the

Senate). the Special Deputies of ex

officio Commissioners and individuals serving under the im mediate

supervision of the Commissioners and

Deputies.

The Commission adopted the rules

to protect the integrity of the agency' s

decision-making process and to make

sure that ex pane communications.

I For a delailed summa ry of h~ interim

rules(II CFR Pan 201J. w e Ih January

Record. fXJSe3.

when authorized. receive full publ

disclosure.

The interim rules prohibit ex pa

communications made in connect

with ongoing Commission audits 

litigation. They supplement an

existing ban on ex parte communi

tions pertaining to enforcement

matters (MURs). Ex pane commu

cations on rulemaking proceeding

and advisory opinions are permissible. but a writtenrecord of the

communication must be made pub

Comments and Testimony

Mr. Bauer (Perkins Coie) said t

the Commission needed more-no

fewer-c-communications from out

parties since. in his view. these par

were denied the unlimited access t

the Commissionersthat was availa

10 the FEC's General Counsel. wh

he characterized in his written

comments as "an interested party,

acting effectively as an adversary 

the other party" in audit mailers an

other proceedings. Mr. Bauer said

that. in fairnessto outside parties. 

Commission should permi t ex part

communications in audit matters, w

a record of the communication pla

in the public file. He also said that 

prohibition on ex parte communic

tions concerning litigation should 

lifted since, in his view, the Comm

sion had not made a convincing ca

for the prohibition.

By contrast, Ms. Hedlund (Cent

for Responsive Politics) supported 

prohibitions on ex pane communic

tions concerning audits and litigati

but urged the Commission to addre

violations of the prohibitions. She

suggested. for example, that all

prohibited communications be mad

pan of the public record and that th

Commission permanently or rempo

rarily deny violators the opportuni

to appear before the agency in othe

matters. She also suggested some

changes to the provision governing

rulemakings and advisory opinions

such as adding language to discour

communications made after the pu

comment period.
•

•

•

Mr. Gellhorn (Jones. Day Reavis

& Pogue) staled in his wnuen

comments that the rules "reach[ed] a

balancedjudgment and seemled]

likely to be workable and practical: '

He did. however. suggesr Hmirmg the

provision on advisory opinionsand

rulemakings so that it would apply

only to ex partecommunications

received-not received and made

{interim rule}-by Commissioners

and covered staff. He said that

Commissioners were expected to

have opinions on policy matters and.

therefore. "what they say to others

raises no fairness issues: ' He also

suggested some refinements (0 the

rules. such as clarifying lime periods

during which the prohibitions on ex

parte communications are in effect. +

FEe Staff to Hold

Meetings in Hartford,

Indianapolis, Helena

and Lincoln

This summer, FEe public affairs

specialists will be holding informal

meetings in the above cities [0 offer

help in understanding the requirements of the campaign finance law.

Candidates, campaign staff, and

staff members of party committees

and PACs are welcome10 schedule

meetings, which willhetailored to

theparticular needs of the participants.

If you would like to schedule a

meetingor want more information.

call800/424-9530 or 20212 19-.3420

and ask forthe specialistassigned

10 your location. Although visiting

dates are I10t yetset. the specialists

are interestedin learning whal

areas ofthe law you wouldlike to

cover.

• Hartford , Conneetk ut

Ian Stinon

• Indi anapol i... Indian a

Greg Scoe

• Helena. :\lonl.lllla

Janet Hess and Kevin Salley

• Lincoln, Nebraska

Kathlene Martin

800 Line

Credit Card Contributions

The Commission has permitted

committees to accept contributions

made by credit card in several

advisory opinions, which are the basis

of this anic le.

To order the opinions cited here

(AOs 1991 -1. 1990-4. 1984-45. 1983-

22 and 1978-68), send your name,

addre ss and a $1 check or money

order made out to the U.S.lXpartment of Treasury to: Federal Election

Commission, Public Records Office

(Credit Card Contributions). 999 E

Street, N\\!. Washington, IX 20463.

If you have any questions on ordering

the ADs. call Public Records (8OCV

424.-9530 or 202121 9-4140).

Credit Ca rd Service Charges

Generally, credit card companieslike all other corporations providing

services to political commiueesmust charge their "usual and normal"

charge, since charging less would

result in a prohibited corporate

contribution to the committee.

II CFR lOO.7(a)(I)(iii)(A); AOs

1991 -1and 1978-68. (Any discount

offered by the company should reflect

the company's usual and normal

practice. AD 1991 -1.)

However, in the case of a separate

segregated fund (SSFl,' this issue

does not arise if the connected

organization or a qualified collecting

agent! pays the credit card service

charges as an exempt fundraising

expense under I I CFR 114.I(a)(2)(iii)

and 114.I (b). The SSF may initially

pay the charges and later be

I A separate seg'egated/und(commonl.v

catted a corporate or labor PAC) is a

political committee established b)'a

"connected organizanon." ....hich rnav lw

eithera corponuion (profi l or lOl fil

ora labor organization. See II CFR

100.6 and II CFR 114.5.

1 See II CFR I02.6(b)(/J.

Federal EIEc/;on Commission RE

reimbursed by the connected org

zation or collecting agent, but th

reimbursement must take place n

later than 30 days after the SSF's

payment. II eFR 102.6(cX2)(ii) 

114.5(bX3). AOs 1990-4 and 198

Contributor Authorizations

Contributors generally sign fo

to authorize the charge of a cont

tion to their credit card accounts

However, in AO 1978--68,the

Commission said that credit card

contributions could be made by

telephone as long as the pertinen

contributor and credit card inform

tion was recorded on a form.

Contributors must sign an aut

zation form when authorizing co

butions to be charged periodicall

such as on a monthly or yearly b

Moreover, in this situation. contr

tors must be informed of their

continuing right to revoke the au

zation at any time. AO 1991-1.

Dolte of Receipt

With the exception explained

below, a credit card contribution 

received on the date the com mitt

receives the contributor's author

tion to charge his or her credit ca

account. This date is considered 

date of receipt for recordkeeping 

reporting purposes because, once 

possession of the authorization, t

committee may transmit it to the 

for credit 10 the committee's acc

AD 1990-4 (which supersedes A

1978-68 Oil this point).

However, the Commission m

an exception to this rule in AO 1

I, where contributors authorized

periodic contributions to be char

once a year. Because several mo

might intervene between the auth

zation and the actual charge to th

contributor, the Commission said 

the date of receipt was the date (h

committee sent the credit card

company (or bank ) the authoriza

to credit the committee's accoun

to debit the contributor's accoun

Untilthat point. the contributor h

the right to revoke the authorizat

(continued on p
National Pa rty I Federal Activity

Through End of Election Year

(Millions of Dollars)

1983·84 1985·86 1987·88 1989·'10 1991·92

Receipts

Democrats $ 65.9 s 43.0 $ 81.1 $ 4 1.1 $104.1

Republicans $245.9 $208.0 $ 191.5 $167.0 $ 192.1

Disbursements

Democrats $ 65.5 $ 43.5 $ 75.8 $ 45.2 $ 103.2

Republicans $249.9 $208 .2 $ 187.0 $ 172.4 $187.2

Cash on Hand

Democrats s 0.8 s OJ s 5.5 $ 1.4 $ 3.0

Republicans s 3.0 $ 1.7 s 6.2 $ 0.9 $ 36

Debts

Democrats $ 2.3 $ 4.2 $ 3J $ 4J s 4.4

Republicans s 0.4 s 8.5 s 0.8 s 6.1 s 14.3

and

I Each

the

major

House

pol

and

ilical

Senate

parry

ca

has

mpaign

three

co

na

mmi

tionai

ttees.

-le vei commiueet: the national commit

Frderai Elrcuon Commission RECORD

800 Line

(continued/rom page 5'

and had not relinquished control over

the contribution. See I I CFR

110.1(bX6).

R('C()r dkceping

The recordkeeping requirements

for credit card contributions are the

same as those that apply 10 any other

type of contribution:

• For contributions in excess of $50.

(he contribute..' S name and address

and me date and amount of the

contribution. (The Commission

recommends recording this same

information for contributions of $50

or less.)

• For contributions aggregating over

$200 in a calendar year, the above

information plus the contributor's

occupation and employer. I I CFR

102.9(a)( I) and (2).

Repo ..tin g

Again, credit card contributions are

reported in the same way as other

types of contributions from individuals. Itemization is required when

aggregate contributions from one

individual exceed $200 in a calendar

year. II CFR 104J (aX4)(i).

Credit card service charges arc

reportable operating expenditures and

must be itemized once charges exceed

$200 in a calendar year. 11CFR

100.J( b)(J )(i) and (4)(i). (In the case

of a separate segregated fund. no

reporting is required if the connected

organization or a collecting agent

pays the chargcs.)! If the credit card

company debits the committee's

account for the charges. then the date

of the expenditure is the date the

committee receives notice of the

debit. AO 1978-68. +

J It however. the SSF initially pays the

charges and is later reimbursed by f il l'

connected organization or a collecting

agent, SSF should report lhe reim.

bursement as lUI "other receipt. " I I CFR

104 .3(aX4KI·i); ADs /98-1-45 and 1983 ·

22.

6

Statistics

Democrats Narrow Fundraising Gap

Although, at the end of the 1991·

92 election cycle. the Republican

national committees had raised almost

twice as much as the Democrats. the

fundraising gap was much less than in

me previous cycle, when Republicans

raised four times more than the

Democrats. See accompanying table.

The Republican committees raised

more contributions from individuals.

collecting almost SI70 million <88

percent of total federal receipts). The

Democrats. by contrast, raised $76

million in individual contributions 03

percent of federal receipts). On the

other hand, the Democratic committees took in more PAC contributions:

$13 million (12 percent of federal

receipts), compared with the $4

million (2 percent of federal receipts)

raised by the Republicans.

May /

In comparing nonfederal activit

Republican national comminees

raised $52 million and spent $50

million, $15 million more than the

Democrats. who raised $37 million

and spent $35 million in nonfedera

funds. The 1991-92 cycle was the 

in which the national committees

were required to disclose the activi

of their nonfederal or "soft money"

accounts. which contain money rai

outside the limits and prot.ibitions

federal law. The funds are used to

finance state and local election

activity and to pay the nonfederal

share of activities mat influence bo

federal and nonfederal elections.

National party committee statist

for the 1991·92 election cycle and

previous cycles are available in a

March I I press release, which may 

ordered at no charge from the Publ

Records Office (8O<V424-953Q-as

for Public Records-or 202l219-

4 140). +
•

•

•

Ma) 1993

Compliance

;\IURs Released to the Public

Listed below are FEe enforcement

cases (Matters Cnder Review or

MlJRs) recently released for public

review. The list is based on the FEe

press releases of March 8 and 15.

1993. Files on closed t\1URs are

available for review in the Public

Records Office.

Unlessotherwise noted, civil

penalties resulted fromconciliation

agreements reached between the

respondents and the Commission.

MeR [965

Respondents: ElliotS. Maggio for

Congress. Andi Johnson. treasurer

(NH)

Complainant: FEe initiated

Subject: Failure to file reports on

lime

Disposition: U.S. District Court

reportand recommendation: S5.000

civil penally against committee;

S5.OOO civil penalty agai nst treasurer

MUR 2363

Respondents: The Holmes Committee. Yvonne M. Unseld. treasurer

(K Y)

Complainanl: FEe initiated

Subject: Failure [0 tile reports on

time

Disposition: U.S. District Court

defaultjudgment: $30,000 civil

penalty

:\lliR 256&'2265

Resp ondents: Californians for a

Strong America. AlbertJ.Cook.

treasurer

Complainant: FEC initiated

Subject: Failure 10 file reports on

time

Disposition: $15.(0) civil penally

.\ le R. 279912648126 LV2533125251

2386

Respondents (all in WA): (a) Life

Amendment Political Action Committee, lnc., Rick Woodrow, treasurer: (b) CitizensOrganized to

Replace Kennedy (C O.R.K.). Rick

Woodrow. treasurer

Complainant: FEC initiated

Subject: Failure to cooperate with

FEe re....iew, rnisrepcrting informalion; failure to maintain and preserve

records; failure to reportdebts

continuously;failure to file reports on

time

Disposition: U.S. District Court final

order and default judgment: $125.000

civil penalty

MUR2882

Respondents (all in MN): (a) People

& Politics. lnc.; (b) Ecolab. Inc.. Jon

R. Grunseth. vice president; (c) Ian

Maitland for Congress, Randall 1.

Kroll. treasurer; et at (dH n)

Complainant: Ian Maitland (sua

sponte)

Subject: Corporate contributions

Disposition: (a) U.S. District Court

stipulated dismissal order; (b) rejected

General Counsel's recommendation

and took no action; (cHn) reason to

believe but took no further action

:\-I UR .HM

Respond ents: (all in RI): Congressman SI. Germain Re-election Committee. Fernand SI. Germain.

treasurer; (b) Michael Lolicata:

(c) Steven Salvatore; (d)Joseph

Rodio: (e) Rodio & Ursi1lo. Ltd.

Complainant: Linda Jacobs

Subjec t: Excessive contributions:

conmburions in the names of others

Disposition: (aHd) Reason to

believe but took no further action;

(e) no reason 10 believe

:\-1 R 3517

Respondents: Teamsters Local959

Alaska Labor Independent Voter

Education. Mark S.Johnson. treasurer

Complainant: FEC initialed

Subject: Prohibited union contribution

Disposition: $5.(0) civil penalty

J\.IUR 3531

Respondents: Senator Chafee

Committee, John S. Renze. Jr.,

treasurer (DE)

Complaina nt: FEC initiated

Ftdeml EleetiM Commission REC

Subject: Excessive contributions

Dispo..ition: $2500 civil penalty

~IUR .1580

Respondents: Friends of Esther 

Y30. Janet Baker. treasurer(TX)

Complainant: FEC initiated

Subject: Failure to file 48-hour n

Disposition: $3,000 civil penalty

~IU .\603

Respondents (all in NY): (a) W

P. Polito; (b) Bill Polito for Cong

Committee. Preston Vaden, treas

et a1. (c--e)

Complainant: Homer Whitmore

(NY)

Subject: Corporate contribution

Disposition: No reason to believ

:\I(;R 3705

Respondents: Jimmy Hayes for

Congress. Kathryn M . Killeen.

treasurer (GA)

Complainant: Carl Tritschler(L

Subject: Disclaimer

Disposition: No reason to believ

:\IUR 3722

Respondents: Phoenix Firefight

Local 493 Fire PAC Committee.

Michael Gibson, treasurer(Al)

Complainant: FEe initiated

Subject: Failure to file report on 

Disposition: $850 civil penalty

~[ UR 3738

Respondents (all in PAl: (a) Fri

of Mark SingelCommittee, Jose

Varga, treasurer; (b) Jacqueline S

Complainant: FEe initiated

Subject: Loan

DislHlSilion: Reason 10 believe b

took no further action +
------ Federal Election Commission RECORD

Free Copies of 1993

Disclosure Directory

Available

DuringApril. the Commission

released the 1993 edition of the

Combined Federal/State DisclosureDirectory, which lists the state

and federal offices responsible for

public disclosure of reports and for

dispensing information about:

• Campaign finance

• Personal finances of candidates

and offici als

• Public financing

• Spending on state initiatives and

referenda

• Lobbying

• Candidates on the ballot

• Election results

• Accessibility to polling places

• Election-related enforcement aclions

• Corporate registrations

The directory lists office addresses, phone numbers and fax

numbers and also identitiesstaff

members knowledgeable in the

subject areas.

Limited copies are available free

of charge. Call 800/424-9530 (ask

for Public Records) or call the office directly: 20212 19-4140.

FEDERALELECTION COMMISSION

999 E Street, NW

Washington, DC 20463

Official Business

*Printed on recycled paper

Index

The first number in each citation

refersto the "number" (month) of the

1993 Record issue in which the article

appeared. The second number,foUowing the colon, indicates the page number in that issue.

Advisory Opinions

1992-38: Loan from Presidential

campaign's legal and compliance

fund to public funding account. 1:6

1992-40:Commissions earned by

state party committees. 2:5

1992-41 : Solicitation of members, 3:3

1992-42: Bank deposit lost in mail.

3:3

1992-43: Preemption of state law's

fundraising restrictions. 3:4

1993-1: Campaign's rental of storage

unit fromcandidate, 4:8

1993-2: Application of party spending

limits to Texas special runoff, 4:9

1993-3: Retroactive reallocation of

1991 -92 activity, 5:1

Court Cases

FECv .

- America's PAC, 4:10

__May /

- International Funding Institute, 1

5:2

- People & Politics, Inc., 3:3

v.FEC

- Common Cause (92-0249 (JHG»

4:10

- Common Cause (92-2538), 1:8

- LaRouche, Lyndon H. (92-1555)

1:8

- National Rifle Association (92-

5078),4: 10

U.S.SenatorJohn SeymourComm

tee v, Dianne Feinstein, 1:8

Reporting

Last-minute contributions: 48-hour

reporting, 4:7

Reporting problems, letter to new

candidates. 4:8

Schedule for 1993, 1:3

Special elections inCalifornia,

Mississippi, Ohio, Texas and

Wisconsin, 3:I; 4:7

800 Line Articles

Credit card contributions, 5:5

Party committee allocation: carryin

debts from previouselection cyc

2:7

$25,000annual limit, 4:2

Bulk Rate Mail

Postage and Fees Paid

Federal Election Commission

Pe rmit Number G-31