·Subsequently filed report.

PUBLICATIONS

7 1987 Annual Report

7 INDEX

PUBLIC FUNDING

2 Matching Fund Certifications

2 ADVISOR Y OPINIONS

COURT CASES

6 USDC v. FEC

6 FEC v. Working Names. Inc.

7 New Litigation

Nonfilers

Candidate Office State Report

Sought Not Filed

Fernandez, B. President Monthly

Martin-Trigona A. President Monthly

Hopkins, L. J.* House KY Pre-Prim.

Payne, D. M.* House NJ Pre-Prim.

Rossello, P. J. House PR Pre-Prim.

Snelgrove, R. H.* House UT Pre-Conv.

TABLE OF CONTENTS

1 COMPLIANCE

Washington DC 20463 Volume 14, Number?

FEC PUBLISHES NONFILERS

During May and June, the Com mission published the names of House and Presidential

campaigns that had failed to file disclosure reports required by the election law. See chart

below. .

The el~ction law requires the agency to publish the names of nonfiling candidates. Compliance actions against nonfilers are decided on a

case-by-case basis. The law gives the Commission broad authority to initiate enforcement actions resulting from infractions of the law, including civil court enforcement and imposition of civi

penalties.

July 1988 999 E StreetNW

FEDERAL ELECTION COMMISSION

COMMISSION ADOPTS NEW

PROCEDURES TO SPEED UP ENFORCEMENT

On May 12, 1988, the Commission approved a

recommendation by the General Counsel's Office

to expedite FEC enforcement matters involving

violations of the election law's reporting requirements. During a six-month trial period, respondents who have filed their reports late or who

have failed to file their reports will be offered an

opportunity to enter into a conciliation agreement

with the FEC at the time the agency finds "reason

to believe" they have violated the law's reporting

requirements. At the end of the trial period, the

Office of General Counsel will report to the

Commission on these expedited procedures and

make further recommendations.

Under the trial program, late filer and nonfiler respondents will be sent a standardized conciliation agreement at the time they are notified

of the FEC's "reason to believe" finding. The

proposed agreement will contain an admission of

their reporting violations and a civil penalty consistent with the severity of their reporting failures. If a respondent chooses not to sign the

agreement:

o He or she may present arguments to demonstrate why no further action should be taken or

why his/her civil penalty for a reporting violation should be mitigated; or

o Alternatively, the matter will proceed to the

next stage of the enforcement process.

Under existing enforcement procedures, the

respondent first receives notification of the FEC's

"reason to believe" finding. He or she may

SUbsequently request that the Commission approve a conciliation agreement before the agency

finds "probable cause to believe" a violation of

the election law has occurred. The Com mission

noted that this procedure has caused needless

delay and expense. Since late/nonfiler respondents generally request and are granted a conciliation opportunity prior to the Commission's finding of probable cause, the new procedures will

permit a more efficient and timely treatment of

routine filing violations.
2

The Record is published by the Federal Election Commission, 999 E Street, N.W., Washington,

D.C. 20463. Commissioners are: Thomas J. Josefiak, Chairman; Danny L. McDonald, Vice

Chairman; Joan Aikens; Lee Ann Elliott; John Warren McGarry; Scott E. Thomas; Walter J.

Stewart, Secretary of the Senate, Ex Officio; Donna1d K. Anderson, Clerk of the House of

Representatives, Ex Officio. For more information, call 202/376-3120 or toll-free 800/424-9530.

(TDD For Hearing Impaired 202/376-3136)

Volume 14, Numbe

Individual's sale of air travel cou

to campaign. (Date made public: 

16, 1988; Length: I page)

Subject

Communications and events spons

by nonprofit corporation with poli

organization status under the fed

tax code. (Date made public: Ma

1988; Length: 5 pages, plus 82-p

supplement)

-: - ". -~-.:~ ,.,.. ~--'.~' ~-R~~~~ •

. .," '-_-,~;,-~_; ,.~.( j~::~~\L\-n'ri~\_~-~, " ~~- ~~- ~- _..:...._....--,-'"~,,::.... ..~~..:.,._:" ... -' - 

1988-24

AOR

1988-22

ADVISORY OPINION REQUESTS

The following chart lists recent requests 

advisory opinions (AORs). The full text of e

AOR is available to the public in 

Commission's Office of Public Records.

1988-23

Joint campaign committee establi

by federal/nonfederal candidates 

ning in California primary. (D

made public: May 25, 1988; Lengt

page, plus l-page supplement)

1988-25 Automobiles provided by car manu

turer to major parties' national Pr

dential nominating conventions. (D

made public: May 31, 1988; Lengt

pages, plus l-page supplement)

1988-26 Solicitability of hourly wage ear

with teaching responsibilities. (D

made publics June 7, 1988; Lengt

page, plus lO-page supplement)

198~-27 Corporate honorarium paid to fed

officeholder/candidate for PAC f

raising appearance. (Date made pu

June 7, 1988; Length: 2 pages, plu

page supplement)

1,008,550

8,313,988

7,358,287

8,360,150

2,550,954

539,857

2,710,319

3,286,990

525,414

1,122,282

4,842,611

5,292,093

662,668

8,774,727

2,998,593

Total Amount

Certified

Through June 15

FEDERAL ELECTION COMMISSION

625,115

$ 4,211

606,909

51,208

Amount

Certified

June 15

July 1988

Primary Matching Fund

Certification Activity

Candidate

FEC APPROVES MATCHING FUNDS

FOR PRESIDENTIAL CANDIDATES

On June 15, the Commission certified

$1,287,442.96 in federal matching funds to four

eligible Presidential candidates campaigning in

the 1988 primaries. These certifications raised to

$1,287,442.96 the total amount of payments the

agency had certified to the Treasury for 15

eligible candidates by June 15, 1988.

The summary chart below provides cumulative information on certifications of primary

matching funds made to fifteen eligible Presidential candidates between January 1 and June

15, 1988. The chart also indicates the most

recent certifications made to eligible candidates.

During 1988, an eligible Presidential candidate may submit requests for primary matching

funds on the second and fourth Mondays of each

month. The federal government will match up to

$250 of an individual's total contributions to an

eligible candidate. Contributions from political

committees are not matchable. (See 26 U.S.C.

§§9034 and 9036 and 11 CFR 9034 and 9036.l(b)

and 2(a).)

Babbitt (D)

Bush (R)

Dole (R)

Dukakis (D)

DuPont (R)

Fulanl (NA)

Gephardt (D)

Gore (D)

Haig (R)

Hart (D)

Jackson (D)

Kemp (R)

LaRouche (D)

Robertson (R)

Simon (D)
July 1988 FEDERALELECTION COMMISSION Volume 14, Number7

ADVISORY OPINIONS; SUMMARIES

AO 1988-3: Solicitations by Trade Association

with Corporate/Noncorporate

Members

The American Pilots' Association (APA), a trade

association representing licensed marine pilots

who are members of 59 separate state and local

pilot associations, may solicit contributions to its

separate segregated fund, APA PAC, from:

o Individual pilots who own stock or equity interests in two incorporated membership associations that belong to APA, the Crescent River

Port Pilot's Association (The Crescent Pilots

Association) and the San Francisco Bar Pilots

Benevolent and Protective Association (the San

Francisco Pilots Association); and

o An unincorporated membership association -that

belongs to APA, the Pilots' Association of the

Bar River Delaware (Delaware River Pilots

Association). However, APA may not solicit

the individual members of the Delaware River

Pilots Association; nor does it have to attribute

any portion of the Delaware River Pilots Association's contrtbutlonts) to its members.

Solicitation of Incorporated Members'

Stockholders

Under the Act and FEC regulations, a trade

association, or its PAC, may solicit the stockholders of the association's incorporated members

provided: 1) the association obtains a written

approval from each corporate member before

conducting the solicitation, 2) the corporate

member has not authorized solicitations by any

other trade association for the same calendar

year and 3} the association complies with the

election law's other relevant solicitation requirements and limits on contributions. 2 U.S.C.

SS441a(a) and 441b(b)(4t)(D); 11 CFR 114.5 and

114.8(c). Further, in AO 1982-12, the Commission

concluded that a trade association could also

solicit individuals who have an equity interest in

the association's corporate member. Thus, assuming APA PAC complies with the appropriate solicitation requirements, it may solicit both pilots

who are stockholder/members of the Crescent

Pilots Association and pilots who are members of,

and have equity interest in, the San Francisco

Pilots Association.

Solicitation of Unincorporated Member

Association

APA may not solicit individual members of

its unincorporated member, the Delaware River

Pilots Association, because these individuals are

not APA members. Under the Act and FEC

regulations, APA may, however, solicit the Delaware River Pilots Association itself at any time

and without obtaining the association's prior approval. 2 U.S.C. S441b(b){4){C); 11 CPR 114.7{c).

Since the Delaware River Pilots Association acts

3

primarily as an administrative entity for its individual members, contributions solicited by APA

are attributable only to the Association-not to

its members.

The Commission noted that, since many of

APA's 59 member associations differed in organization and structure, it would have been impractical for the FEC to determine the solicitability of

each association's individual members. Thus, the

FEC chose a sample consisting of APA's three

largest member associations, representing, respectively, the Gulf, Pacific and North Atlantic

states. The Commisson said that APA could rely

on this opinion in determining the solicitability of

the individual members of APA's other member

associations-provided the factual situations

represented by these other associations were indistinguishable from the situations addressed in

the FEC's opinion. See 2 U.S.C. S437f(c)( lXB).

Chairman Thomas J. Josefiak filed a concurring

opinion. (Date issued: April 29, 1988; Length: 6

pages, including concurrence)

AO 1988-12: Joint Promotion of Credit Card

Program by Local Party Committee

and Bank

The Empire of America Federal Savings Bank

(Empire), a federally chartered savings bank, and

the Erie County (New York) Democratic Committee (the Committee), a local party committee,

may not enter into a proposed agreement Whereby

the Committee would provide mail lists and

marketing support to Empire for its credit card

program in return for a portion of the credit card

membership fees. Even though Empire's payments

would be deposited in a special account, the

payments would still be considered prohibited

contributions from Empire to the Committee because:

o The payments would constitute something of

value to the Committee, rather than the "usual

and normal" fee charged by the Committee for

such services; and

o The payments would not qualify for the building

fund exemption available toa national or state

party committee.

Proposed Agreement for Promoting

Credit Card Program

Under the proposed agreement between Empire and the Committee, the Committee would

provide Empire with membership lists consisting

of the names and addresses of registered Democrats who had voted in the last four general

elections. The Committee would also help Empire

market its credit card program to persons on the

Commitee's membership lists by:

o Allowing Empire to use the Committee's name

and goodwill in making such solicitations; and

continued
JUly 1988 FEDERAL ELECTION COMMISSION

o Providing other forms of market support, such

as placing containers of credit card applications

at Committee headquarters.

Empire would compensate the Committee for

these services by depositing into a special

Committee account an unspecified portion of the

annual membership fee paid by each credit card

holder. Payments deposited in the special

account would only be used to maintain the

Committee's current office space (e.g., to pay for

rent, maintenance, equipment and utilities).

Empire's Reimbursements Prohibited

The election law prohibits corporations

chartered under federal statutes, such as Empire,

from making contributions or expenditures in

connection with any election for federal, state or

local office. For purposes of this prohibition, an

illegal contribution would include the making of a

direct or indirect payment, or anything of value,

to a political party for use in connection with

federal elections. 2 U.S.C. §§441b(a) and (b)(2)j

11 CFR 114.I(a)(1) and 114.2(a).

Further, in past advisory opinions, the Commission has generally viewed the sale of a political committee's assets to a corporation as a

prohibited contribution to the committee from

the corporation. See, for example, AOs 1983-2,

1981-7, 1980-70, 1980-34 and 1980-19. However.

in several advisory opinions, as a narrow exception to this general prohibition, the Commission

has allowed political committees to sell (or exchange) contributor or mailing lists for the usual

or normal fee, without considering the funds received (or the value of the item) as a contribution. The lists sold by these committees were

unique in that they were developed primarily for

the commitees' own use, rather than as fundraising items. See AOs 1982-41, 1981-53, 1981-46

and 1979-18 and 11 CFR 100.7(a)(iii).

In deciding that Empire's reimbursements to

the Committee for its mailing lists and marketing

services would constitute prohibited contributions, the Commission distinguished this opinion

from previous opinions that had permitted the

sale of a committee's mailing lists. First, Empire'S payments to the Committee would be unlimited and not reflective of the current value of

the lists since the payments would be based on a

portion of each card holder's annual membership

fee. By contrast, past opinions permitting the

sale of lists involved specific, predetermined payments from mail list brokers. Further, since the

Committee's membership lists are available from

other public sources, they are not sufficiently

unique to qualify for the mailing list exception.

Finally, the additional marketing services given

by the committee to Empire materially distinguished the circumstances of this opinion from

opinions that only permitted the ordinary sale or

lease of lists.

4

Volume 14, Numb

Building Fund Exemption Does Not Apply

Although corporations like Empire may 

make contributions in connection with feder

nonfederal elections, under limited and 

defined circumstances, they may donate fund

political party comrnittees, provided the f

are: 1) maintained in a separate account an

are used only for exempted purposes. 

example, a national or state party committee 

use corporate donations to defray the cos

building or purchasing an office facility, prov

the committee has not acquired the facilit

influence the election of a federal candidate

U.S.C. §43l(8)(B)(viii); 11 CFR 100.7(b)

100.8(b)(l3) and 114.1(a)(2)(ix). However, s

the Erie Committee is a local party comm

(rather than a state or national party commit

it is not eligible for this building fund exemp

Moreover, the exemption does not cover paym

for operating and administrative costs, 

proposed here. (Date issued: May 27, 

Length: 6 pages)

AO 1988-13: Campaign Funds Used to Pay

Candidate's Apartment Rent

Congressman Richard Ray plans to use an ap

ment he owns in Columbus, Georgia, in part

his personal use and, in part, as a "perma

satellite campaign officell for his 1988 reelec

effort. Congressman Ray's principal camp

com mittee may pay him for ·its share of le

space in the apartment, provided these payme

o Represent the usual and normal (prora

charge for such rental space; and

o Are properly reported by the committee

U.S.C. §434(b)j 11 CFR 104.3(b). See also 

1978-80, 1983-1 and 1985-42.

Under the Act and FEC regulations, a ca

date and the candidate's campaign comm

have wide discretion in making expenditure

influence the candidate's election, provided 

candidate does not convert any excess camp

funds to personal use. 2 U.S.C. §§43l(a) 

439a. Thus the Commission cautioned that, i

Ray reelection committee's payments for 

campaign space exceeded the usual and no

charge, the excessive amount would be consid

a prohibited conversion of excess campaign f

to the candidate's personal use. Conversel

the payments were less than the usual and no

charge, the difference would be considered an 

kind contribution by the candidate to his c

paign. Although not limited by the Act, this 

of contribution would be reportable. Chair

Thomas J. Josefiak and Commissioners Joan 

Aikens and Lee Ann Elliott filed a 

concurring opinion. (Date issued: April 21, 1

Length: 4 pages, including concurrence) 
July 1988 FEDERAL ELECTION COMMISSION Volume 14, Number 7

AO 1988-18: Liability of Union for Federal

Election Contributions Made from

Its Donations to Nonfederal Entities

Under Missouri law, Local 36, a local union of

Sheet Metal Workers International Association.

AFL-CIO, may make contributions from its treasury funds to state and local candidates and to

local party organizations. If a recipient of such

contributions (e.g., a local party organization)

were to donate these funds to a federal candidate

or committee, without Local 36Ts prior knowledge,

Local 36 could avoid its own prohibited

contribution by continuing its policy of clearly

designating, in writing, that its donations to

nonfederal candidates and committees (consisting

of its treasury funds) are to be used exclusively

for state and local elections. For example, Local

36 could: 1) write the name of a specific state or

local candidate or election on its check (or other

written instrument) or 2) attach a signed

statement to its check with this information.

(Date issued: May 20, 1988; Length: 3 pages)

AO 1988-19: Solicitability of Employees in

Company Shareholder Plan

Employees of Ashland Oil, Inc. who have participated in the company's Leveraged Employee Stock

Ownership Plan (LESOP) for at least one year may

qualify as solicitable stockholders under FEC

regulations. (Under the employee shareholder

plan, a LESOP member must be employed by

Ashland for a least one year and may not be an

hourly wage earner or a union member.)

Accordingly, even though some of the LESOP

.members may not be executive or administrative

personnel, as Ashland shareholders, they may be

solicited by the company's separate segregated

fund, provided the fund's! solicitations meet the

requirements of FEC rules. See 11 CFR 114.5(a).

For purposes of PAC solicitations, Commission regulations define a stockholder as a person

who has:

1. A vested beneficial interest in the' company's

stock;

2. The power to direct how stock will be voted;

and

3. The right to receive dividends. 11 CFR

114.4(h).

Ashland employees who have participated in

LESOP for at least one year satisfy these requirements for stockholder status. First, they receive

a 10 percent vested interest in the Ashland common stock that is allocated to them after each

year of employment. Second, before each stockholder meeting, the employees direct the Trustee

on how to vote their shares. Finally, the employees directly receive dividends earned on their

vested shares. (Date issued: May 26, 1988;

Length: 3 pages)

5

AO 1988-21: Act's Preemption of California

Ordinance Governing Campaign

Contributions

Harriet Wieder, a candidate for Congress and 

member of the Orange County (California) Boa

of Supervisors, may accept a contribution of up 

$1,000 from a "County Influence Broker" (i.e

lobbyist) for her Congressional campaign, eve

though a county ordinance would prohibit th

contribution. See 2.U.S.C. §441a(a)(l)(A).

Under the Orange County ordinance, a Cou

ty Influence Broker may not contribute more tha

a total of $868 per year to all members of an

candidates for the Orange County Board of Supe

visors. The Federal Election Campaign A

(FECA), however, preempts the local ordinanc

The FECA "supersedes and preempts" state an

local provisions with respect to the sources an

amounts of federal election contributions.Cons

quently, the broker's contribution to Mr

Wieder's campaign is not subject to the coun

ordinance limitation. 2 U.S.C. S453; 11 CF

108.7(c). (Date issued: May 16, 1988; Length: 

pages)

CHANGE OF ADDRESS

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.

Record subscribers (who are not political committees), when calling or mailing in

a change of address, are asked to provide

the following information:

I, 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.
July1988 FEDERAL ELECTION COMMISSION Volume 14, Numbe

USDC v; FEC

On April 12, 1988, the U.S. District Court for

the Northern District of New York entered an

order granting summary judgment to the FEC in

United States Defense Committee v. FEC (Civil

Action No. 84-CV-450).

Background

In filing suit on March 28, 1984, the United

States Defense Committee (USDC) asked the U.S.

District Court to take action with respect to the

Commission's Advisory Opinion (AO) 1983-43.

In that opinion, issued to USDC on January

26, 1984, the Commission expressed the view that

corporate treasury expenditures for certain voter

guides which USDC proposed to compile and distribute to the general public were not exempted

under Part 114 of FEC regulations. Consequently,

the voter guides were prohibited by 2 U.S.C.

S441b because, as drafted, the language of the

guides suggested an election-influencing purpose.

(Taken together, these legal provisions prohibit

corporations, labor organizations and incorporated

membership organizations from distributing to the

general public voter guides that favor one candidate or political party over another.)

In response to AO 1983-43, USDC asked the

court to declare that USDC's proposed expenditures were not proscribed by FEC regulations.

Alternatively, USOC asked the district court to

certify to an en bane court of appeals three

constitutional questions concerning its distribution of the voter guides. For example, USDC

asked the court to consider whether section 441b

abridged its First and Fifth Amendment rights by

discriminating between incorporated organizations like USDC and the institutional press;"

(Costs incurred by news media corporations for

bona fide coverage of political events are exempt

from the election law's broad prohibition on corporate expenditures, provided the news corporation is not owned or controlled by any political

party, political committee or candidate.)

District Court's Ruling

In a statement read into the public record,

the district court judge presiding in this case held

that the court had. jurisdiction to review USDC's

complaint. While the court acknowledged that

the election law did not specifically provide for

judieial review of FE C advisory opinions, the

ItFor a detailed summary of USDC's constitutional questions, see page 11 of the June 1984

Record.

6

court found that its authority to review the co

plaint had not been "explicitly restricted by s

tute or by Congress•.••"

In ruling on the merits of the case, the co

rejected USDC's claim that the election law d

criminates against USDC by permitting the ins

tutional press to disseminate information on po

tical candidates to the general public while pro

biting USDC from disseminating information 

the form of voter guides. The court held that t

press exemption had a "valid basis" in that 

recognizes the need for informing the public 

federal election-related issues. Further, the pr

is not covered by this exemption when it excee

its legitimate press function.

The court also rejected USOC1s argume

that the guides were not covered by the secti

441b prohibition because they did not include 

explicit request for the recipients to vote one w

or another.

Finally, the court held that the Supre

Court's decision in FEC v. Massachusetts Citize

for Life (Civil Action No. 85-70 I) did not exem

USDC from section 441b's prohibition against c

porate expenditures in connection with fede

elections. To be eligible for the MCFL exceptio

among other things, a nonprofit corporation m

have a policy of not accepting contributions fro

business corporations or labor organizatio

Since USDC had accepted money from its corp

rate members, the court found that the organi

tion was not eligible for the MCFL exception.

USDC subsequently filed an appeal of t

district court's decision with the U.S. Court 

Appeals for the Second Circuit.

FEC v. WORKING NAMES, INC.

On May 19, 1988, the U.S. District Court f

the District of Columbia granted the FEC

motion for a default judgment against Worki

Names, Inc., a corporation that provides maili

list services, and the corporation's presiden

Meyer T. Cohen.

The FEC had .Iiled a motion for the defau

judgment in April 1988, after defendants h

violated the terms of a conciliation agreeme

entered into with the FEC in September 198

Under the terms of the conciliation agreemen

defendants had agreed to pay a $2,000 civil pen

ty for violating S438(a)(4) of the election law a

section 104.15 of FEC Regulations. Specifical

defendants had rented to two organizations a m

list containing a name obtained from a listing 

contributors disclosed on an FEC report. Und

the election laws, names of contributors (oth

than political committees) that are disclosed 

FEe reports may not be copied and used f

eommerleal or solicitation purposes.

The court ordered defendants to comply w

the terms of the conciliation agreement within 

days of tho court's judgment. The court furth
July 1988 FEDERAL ELECTION COMMISSION Volume 14, Number 7

decreed that defendants pay $2,000 for violating

the terms of the conciliation agreement and awarded the Commission its costs for the litigation. The court also permanently enjoined defendants from future violations of the election

law.

NEW LITIGATION

FEe v; The Holmes Committee

The FEC asks the district court to declare

that The Holmes Committee, the principal campaign committee for Lee Holmes' 1986 bid for a

Kentucky House seat, and the Committee's treasurer, Yvonne M. Unseld, violated the election

law by failing to file the following statement and

reports during 1986: a Statement of Organization,

July and October quarterly reports, pre- and postgeneral election reports and a year-end report.

The FEC further asks the court to:

o Order defendants to file these and all other

overdue reports within 15 days;

o Assess an appropriate civil penalty against defendants for these violations; and

o Permanently enjoin defendants from future,

similar violations of the election law.

U.S. District Court for the Western District

of Kentucky, Civil Action No. C88~274L(B),

Apm 19, 1988.

FEC v, Roger Lee

The FEC asks the district court to declare

that Roger Lee, President and Director of the

Bekins Company, violated 2 U.S.C. S44Ib(a) by

using corporate funds to reimburse at least 13

Bekins employees for contributions they made to

federal candidates.

The FEC further asks the court to:

o Assess a $5,000 civil penalty against Mr. Lee

for .this violation of the election law; and

o Permanently enjoin him from further similar

violations of the election law.

U.S. District Court for the Central District

of California, Civil Action No. 88~2640, May 10,

1988.

7

FEC SENDS 198'1 ANNUAL REPORT

TO PRESIDENT AND CONGRESS

The Federal Election Commission has issued

its thirteenth Annual Report. which details th

agency's role in preparing for the 198

Presidential election year. Copies of th

publication have been presented to the President

the President of the U.S. Senate and the Speake

of the U.S. House of Representatives.

The report, which examines the Commission

administration of federal election laws, also in

cludes information on the FEC's ongoing interna

operations. Enhancement of computer services i

discussed, as well as regulatory changes and Com

mission efforts to assist political committees an

the general public in understanding and complyin

with the law. Also included is a discussion of th

major legal issues that stemmed from advisor

opinions, litigation and compliance actions. Fi

nally, the report contains agency suggestions fo

changes in election laws, which the Commission

presented to Congress earlier this year. A

number of appendices appear in the report

covering a variety of data related to FEC

activities.

For a copy of the 1987 report, contact th

Information Services Division, 800/424-9530 o

202/376-3120.

This cumulative index lists advisory

opinions, court cases and 800 Line articles pub

lished in the Record during 1988. The firs

number in the citation refers to the "number"

(month) of the Record issuer the second number

following the colon, indicates the page number in

that issue.

OPINIONS

1987-29: Partisan communications by incorpo

rated membership organization, 4:6

1987-30: Assets of candidate's wife used to pay

off bank loan to candidate, 2:3

1987-31: Eligibility of security exchange's eigh

membership classes for PAC solicitations, 3:5

1987-32: Campaign contributions in the form of

silver dollars, 3:7

1987-33: Law firm and partner are not govern

ment contractors, 3:7

continued
July 1988 FEDERAL ELECTION COMMISSION Volume 14, Numbe

1987-34: Solicitations by subsidiary of joint

venture partnership, 6:5

1988-1: Activity to influence delegate selection,

5:3

1988-2: FEC reports posted on security exchange's

bulletin boards, 4:7

1988-3: Trade association solicitations, 7:3

1988-4: Affiliation of PACs through corporate

merger, 5:4

1988-5: Presidential matching payments used for

'84 debts, 5:5

1988-6: Allocation of media expenses to fundraising exemption, 4:7

1988-10: Activities for post-primary delegate

selection, 6:5

1988-11: Solicitation of teachers by trade

association of schools, 6:7

1988-12: Promotion of credit card program by

party committee/bank, 7:3

1988-13: Campaign funds used to pay candidate's

. rent, 7:4

1988-14: Joint PAC sponsored by affiliated

corporations, 6:7

1988-18: Liability of union for donations from its

funds by nonfederal entities, 7:9

1988-19:.. Solicitability of employee shareholders,

7:5

1988-21: Act's preemption of California

ordinance governing contributions, 7:5

FEDERAL ELECTION COMMISSION

999 E'Street, NW

Washington, DC 20463

Official Business

COURT CASES

Ralph J. Galliano v, U.S. Postal Service, 1:7; 3:

Harry Kroll v: Americans with Hart, Inc., 5:6

Xerox Corp. v, Americans with Hart, Inc., 5:6

FECv. __,...,..

-Augustine for Congress, 1:8

-Beatty for Congress .Comrnittee, 6:9

-Citizens for the President '84,3:10

-Citizens to Elect Jerald Wilson for

Congress, 1:9

-Dietl for Congress, 6:9

-Dorninelli (second suit), 5:8

-Holmes Committee, 7:7

-Lee, 7:7

-New York State Conservative Party Stat

Committee/1984 Victory Fund, et at, 2

-Working Names, Ine., 7:6

___ ,v. FEC

-Antosh, 1:8; second suit, 3:10; 6:8

-Cornrnon Cause, 5:7

-Stark (second suit), 4:8

-USDC, 7:6

800 LINE

Last-Minute Contributions and Independent 

penditures, 2:4

Bulk Rate Mail

Postage and Fees Paid

Federal Election Commission

Permit Number G-31