June1992

FEDERAL ELECTION COMMISSION

999 E Street NW Washington DC 20463 Volume 18, Num

PUBLICATIONS

REVISED CORPORATE/LMOR CAlIPAI~ GUIDE

1'U'1 AVAILABLE

The Commission recently published a

completely revised edition of the Campaign

Guide for Corpot"ations and Labet" Organizations. The 1992 Guide t"eflects advisory

opinions and regulations issued since the

previous Guide was published in 1986. More

comprehensive than the old Guide, the new

edition includes an expanded reporting

section illustrated with examples of how to

report specific transactions. It also

offers a subject index.

The Guide explains how corporations ana

labor ot"ganization may set up and operate a

a separate segregated fund (SSF) in compliance with the federal campaign finance law.

The Guide also provides information on

other election-related activities that a

corporation or labor organization may

finance with its treasury funds.

Copies of the Guide will automatically

be sent to treasurers of SSFs during June

(delivery may take up to three weeks). The

FEe encourages treasurers to order extra

copies for other SSF staff-such as

bookkeeping, reporting and fundraising

persormel. The Guide is also useful for

anyone with an interest in the campaign

finance law's provisions on corporations

and labor organizations.

To order free copies, use the order

form on the back page of this issue.

1992 mITIOO' OF FEe REGJIATIOOS (11 eFR)

The 1992 edition of FEe regulations,

the 11 CFR, was recently published by the

Office of the Federal Register. The updated edition includes all changes and

amendments to FEC regulations that became

effective during 1991 as well as the new

bank loan regulations, which became

effective April 2, 1992.1/

I The new bank loan regulations appear at

11 CFR 100.7(b)(11)(i)-(ii), 100.8(b)(12)

(i)-(ii) and 104.3(d)(1)-(3).

The FEe will automatically send th

1992 11 CFR to treasurers of registere

political committees during June (del

may take up to three weeks). Anyone 

order free copies by mailing the form 

the back page of this issue.

Not reflected in the 1992 edition 

the repeal of the honoraria regulatio

effective January 15, 1992. (11 eFR

lOO.7(b)(19), 110.12 and 114.1(a)(2)(

were repealed.) Also not reflected a

changes to the allocation regulations

which, though final, will not become

effective until the legislative review

period has expired.

TABLE OF aNl'ENl'S

PUBLlCATIQIIS

1 Revised eorporate/Labor Guide

1 New Edition of FEC Regulations

2 REPORTS: Reports due in July

REXiUlATICIIJS

4 Comments Sought: proposed Procedu

for Rulemaking Petitions

4 ADVISORY OPINICRi

CXUfl' CASES

6 Spannaus v. FEC

6 FEC v. Friends of Schaefer

7 Freedom Republicans, Inc. v. FEe

PUBLIC FUNDING

9 May Matching Fund Payments; Agran

Qualifies for Matching Funds

9 1WDITS: 1988 Jackson campaign

800 LINE

10 contributions: Receipt and Deposi

CCI'IPLIANCE

10 Nonfilers

10 MURs Released to Public

14 INDEX
June 1992 FEDERAL ELECTION COMMISSION Volume 18, Number 6

1992. tuARTERLy BEPORTS

.- ,.,:.'

Report Close of Books Filing Date!

PRE-- AND POST-ELECTICN REPORTS FOR

mvE2'IBER 3 ELEC'l'IOO

1992 n:mm.y REOOR'1'S

Close of Books Filing Date!

JULy REPOR'I'IN3

C~ttees filing on a quarterly basis

must file their second quarter report by

July 15; those filing on a monthly basis

must report their June activity by July 20.

The tables on this page show 1992

reporting dates starting with July. (Not

included are pre-primary and pre-runoff

dates, which are avai1able in a handout an

1992 reporting; call aOO/424-9530 or

202/219-3420). The table on page 3 explains which reports a committee must file.

candidate CCmaittees: 48-Hour Notices on

Last-Minute contributions

Authorized commdttees of candidates

must file 48-hour notices on contributions

of $1,000 or more received after the 20th

day, but more than 48 hours, before the day

of any election in which the candidate

participates. See 11 CFR 104.5(f) and the

the January 1992 Record, page 18.

This requirement applies to all lastminute contributions of $1,000 or more:

o Contributions by check;

o In-kind contributions;

o Loans fram personal funds;

o Guarantees and endorsements of bank

loans; and

o Any of the above contributions made by

the candidate.

2nd Quarter

3rd Quarter

Year-End

Report

June

July

August

September

pre--Genera12

Past-General

Year-End

Report

pre-Genera12

Post-General

June 30

september 30

December 31

Period Covered

June 1-30

July 1-31

August 1-31

September 1-30

oct. i-eee. 14

Oct. 1S-Nov. 23

Nov. 24-Dec. 31

October 14

November 23

July 15

October 15

Jan. 31, '93

Filing Datel

July 20

August 20

September 20

October 20

OCtober 22

December 3

Jan. 31, '93

October 22

December 3

PACS: 24-Hour Reports on Independent

Expenditures

pACs--including monthly filers--are

remdnded of the special reporting requirement for independent expendi tures made

shortly before an election. A 24-hour

report is required for independent expenditures aggregating $1,000 or more that are

made after the 20th day, but more than 24

hours, before the day of the election. The

report must be filed wi thin 24 hours afte r

the expenditure is made. See 11 crn 104.4

(b) and 104.5(9) for further information.

1Reports sent by regist~red or certified

mail must be postmarked by the filing date

(except for pre-election reports; see footnote 2). Reports sent by other means must

be received by the filing date. 11 CFR

104.5(e) .

21f sent registered or certified, the pregeneral must be postmarked by October 19.

Federal Election CODIIIi.ssion, 999 E Streett 1M, washington, OC 20463

800/424-9530 202/219-3420 202/219-3336 (TDD)

Joan D. Aikens, Chairman

Scott E. 'l'homas, Vice Chairman

Lee Ann Elliott

DaImy L .. MCDonald

John warren McGarry

Trevor Potter

walter J. stewart, Secretary of the Senate,

Ex Officio Commissioner

Donnald K.. Anderson, Clerk of the House of

Representatives, Ex Officio Commissioner

2
June 1992 FEDERALELECTION COMMISSION Volume 18, Num

•

•

GUIDE ro 1992 REPOkrm:;

Required Reports

semi- Quar- Pre- rl Pre- P

Type of Filer annual terly _thly Prima. General G

House and Senate Campaigns ,f ,f ,f 

of 1992 Candidates required only if2

candi

runs in election

Other House and Senate ,f

campaigns

1992 Presidential campaigns ,f ,f 

Anticipating Activity of filed in lie

$100,000 or Above Nov. and De

monthly repo

candidate ru

general elec

1992 Presidential Campaigns , ,f ,f 

Wi th Activity Less Than required only if cand

$100,000 runs in election

other Presidential Campaigns3 .f-or--f

PACs and party Committees ,f ,f 

Filing Monthly filed in lie

Nov. and Dec

monthly repo

PACs and party 4committees ,f ,f ,f 

Filing Quarterly required only if re

committee makes re

contributions or le

expenditures in ac

connection with

election during

reporting period

corporations and Labor Organi- , ,f

zations (Reportsson Partisan

communications) .

lIncludes pre-convention (if convention qualifies as election) and pre-runoff reports.

2Reports and 48-hour notices are required even if the candidate is unopposed or if the

primary or general is not held because candidate is unopposed or received a majority o

votes in the previous election. (However, a primary election not held because the can

was norodnated by caucus or convention is not considered a separate election for report

purposes or for purposes of the contribution lirodts.) See 11 eFR 110.1(j).

3presidential committees in this category that wish to change their filiog frequency d

1992 should notify the Commission in writing.

4To avoid the need to file pre-primary and pre-runoff reports, these committees may ch

to monthly filing if they first notify the Commission in writing. 11 CFR 104.5(c).

5Required if the organization's aggregate costs exceed $2,000 for internal communicat

expressly advocating the election or defeat of a clearly identified candidate. See 11 

104.6 and page 24 of the Campaign Guide for Corporations and Labor orceatsaetons,

3
June 1992 FEDERAL ELECTION COMMISSION Volume 18, Number 6

REGULATIONS·

CD9IDll'S 5CO:iBT CI'l PROPOSED RULES CN

RlJLE2'IAKING PETITIOOS

on May 13, 1992, the Commission

published a Notice of proposed Rulemaking

seeking comments on new rules that would

explain the procedures for submitting a

petition for rolemaking for the agency' 5

consideration (57 FR 20430). Comments are

due on June 12 and should be addressed to

Ms. Susan E. sropper, Assistant General

counsel, !f99 E Street, NW', Washington, DC

20463.

The proposed rules at 11 CFR Part 200:

o Descdbe the information needed in a

rulemaking petition;

o Explain the steps the agency would take

in responding to a petition (this

proposed rule is based on current

procedures) ;

o List the factors the commission might

consider in deciding whether to initiate

a rulemakingi

o Provide for the reconsideration of

petitions that were denied; and

o Define the administrative record (i.e.,

the documents upon which the agency would

base its decision on the petition).

The proposed rules would not limit the

Commission's current authority to open a

rulemaking on its own ioitiative, based on

suggestions contained in advisory opinion

requests, complaints and other documents

that do not qualify as rulemaking petitions. However, in handling these rulemakings, the Commission would not be bound by

the petition procedures. Also, the

agency's decision not to open a rulemaking

in such situations would not constitute the

denial of a rulemaking petition.

PUBLIC APPE:A1UU'KES

6/5-1 American Bar Association

Standing Committee on

Election Law

Santa Fe, New Mexico

Chairman Joan D. Aikens

Commissioner John Warren

McGarry

Commissioner Trevor Potter

4

ADVISORYOPINION$ .

ADVISORY OPINICN REJJUESTS

Recent requests for advisory 0p1n10ns

(AORS) are listed below. The full text of

each ADR is available for review and comment in the FEe's Public Records Office.

AOR 1992-15

Extension of 60-rlay deadline for contribution redesignations. '(Requested by Russo

for Congress Committee; Date Made Public:

May S, 1992; Length: 1 page)

AOR 1992-16

Nonfederal contributions by corporation

owned by foreign national parent.

(Requested on behalf of Nansay Hawaii,

Inc.; Date Made Public: May 12, 1992;

Length: 10 pages)

NlR 1992-17

Relationship between nonconnected PAC of

partnership and SSFs of two corporations

that jointly own partnership. (Requested

on behalf of Du Pont Merck Program for

Active Citi~enship, Inc.; Date Made Public:

May 14, 1992; Length: 11 pages plus

attachments)

ADYISORY OPINICN SUMMARIES

NJ 1992-7: Corporate PAC's SOlicitation of

Franchise Personnel

Major and satellite franchises of H & R

Block, Inc., are considered Block affiliates by virtue of the company's control

over their operations. Because the franchises are considered affiliated organizations, H & R Block political Action Committee (BLOCKPAC) may solicit contributions

fram their executive and admdnistrative

personnel (and families). 11 CFR 114.5(g)

(1). BLOCRPAC may additionally solicit the

franchisees (i.e., the franchise owners),

if they are unincorporated, as well as the

designated principals of incorporated

franchisees.

In determining whether an organization

is affiliated with a corporation, the

Commission may consider several factors,

including:

o Whether the corporation has authority to

direct or participate in the governance

of the organization;

o Whether the corporation has the authority

to hire, demote or otherwise control the

directors or other decisionmakers of the

organization; and
FEDERALELECTION COMMISSION

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•

June 1992

o Whether the corporation had a significant

role in fo~in9 the organization. 11 eFR

lOO.5(g)(4)(ii)(B), Ie) and (I).

Past advisory opinions have determined

that corporations were affiliated with

licensees or franchisees based on factors

similar to two of those listed above. Bee

ADs 1988-46, 1979-38, 1978-61 and 1977-70.

By contrast, see AQ 1985-7.

Like the corporations in the first four

opinions, Block has a substantial degree of

control over the policies, practices and

daily operations of both satellite and major franchises. For example, in addition

to other restrictions. Block imposes

requirements on franchises with respect to

the accurate preparation of tax returns,

the hours of operation, the condition of

offices and the employment of trained

personnel. Block also provides extensive

training, guidance and oversight of franchisees. FurtheDrnore, Block has some

control over the selection of a franchise's

decisionmakers through its authority to

grant a franchise and its approval rights

over any transfer of interest in a franchise. For these reasons, the franchises

are considered to be affiliated with Block;

BLQCKPAC may therefore solicit their

executive and administrative personnel.

The PAC may also solicit the franchisees themselves if they are individuals,

partnerships or other unincorporated entities. with regard to incorporated

franchisees, BLQCKPAC may solicit their

designated "principals," i.e., the individuals who assume the obligations of the

franchise agreement.

Because some franchises are located in

foreign countries, BL(X;KPAC must be careful

not to solicit or accept any contributions

from foreign nationals, since such contributions are prohibited under 11 CFR 110.4

(a) (1) and (2). (Date Issued: April 10,

1992; Length: 7 pages)

NJ 1992-9: Cooperative's Twice-Yearly

Solicitation ibrough Raffle at

Annual .Meeting

KAMO power, an tncorporeted cooperative,

proposes to raise money for its separate

segregated fund by conducting a twiceyearly solicitation that would involve the

sale of raffle tickets at KAMO's annual

meeting. However, the proposed activity

would not meet the requirements for twiceyearly solicitations under 11 CFR 114.6

and, furthemore, would result in the

illegal solicitation of outsiders attending

the event.

5

Volume 18, Num

'lWice-Yearly solicitations

Section 114.6 allows a corporation 

solicit employees outside the restricte

class twice each year, but the solicita

tions must be written and mailed to the

employees' residences in order to prote

their anonymity. As part of its twiceyearly solicitation, the company propo

to send a letter stating that "all KAMO

employees (and their immediate fandlies

will be eligible to purchase raffle

tickets." The letter itself is a perm

ble solicitation.

However, KAMe plans to set up a boo

for raffle ticket sales and promote the

raffle at the meeting. Both these acti

ties would constitute a solicitation (s

AO 1979-13), with the result that KAMO

would be directing the solicitation to 

restricted employees at the meeting sit

rather than at their r~sidences

Solicitation of Non--&aployees

RAMO anticipates that individuals w

are not KAMa employees will also attend 

annual, meeting. The proposed raffle ac

ities would therefore result in the imp

er solicitation of those individuals, w

may not be solicited by KAMa at any tim

See AD 1981-41.

Solicitation of Board of Trustees

Members of KAMO's board of trustees 

alternate, nonvoting board members are 

formal part of KAMO's governing structu

and thus would qualify as solicitable

executive or admdnistrative personnel u

11 CFR 114.1(c) if they receive stipend

from KAOO.

Chairman Joan D. Aikens filed a

concurring opinion. (Date Issued: Ap

10, 1992; Length: 12 pages, including concurrence)

N) 1992-10: ComDittee's Disbursement 

Nonprofit Voter Organizat

The Committee for a Democratic consens

multicandidate cornmdttee registered wi

the FEC, proposes to disburse funds to 

Center for Participation in Democracy

(CPO), a nonprofit voter registration

organization. CPO will use the funds 

defray its own legal expenses and thos

Senator Alan Cranston's son, a board m

ber, in connection with an investigatio

involving the Senator, Charles Keating 

CPO's activities in general. The Comm

may make the proposed disbursements to 

however, this conclusion is based on

certain assumptions.

(contin
June 1992 FEDERAL ELECTION COMMISSION Voiume 18, Number6

Although the Senator, who is the honorary chairman of the Committee, does not

serve on its board or otherwise control the

Committee, individuals associated with the

senator, including his chief of staff, have

served on the Committee'S board. According

to its statement of organization, however,

the Conuuittee is neither -authot"ized by Senator Ct'"anston nor affiliated with his c~

paign. ASsuming that is the case, the Com- ~ttee would not be subject to the restrictions on the use of funds that apply to an

authorized committee (e.g., the personal

use restrictions at 11 eFR 113.21 and may

expend its funds for any lawful purpose.

AOs 1991-21, 1986-32, 1985-34 and 1983-4.

The Commi.ttee may therefore make the proposed disbursements to COP.

This conclusion is,based'on COP's

continuing qualification as a tax-exempt

organization under 26 U.S.C. §501(c)(3) and

on the assumption th~t neither its ~st nor

its future activities would qualify it as a

political committee under the Federal

Election Campaign Act.

The opinion did not address any tax

ramifications of the proposed activity

since those issues are outside the FEC's

jurisdiction. (Date Issued: April 24,

1992j Length: 3 pages)

NJ 1992-11: C<.JDPUter-Generated SUlmary

Page and Detailed SUDIllary page

In preparing FEC reports for political

conunittees. Coopers & Lybrand may use a

computer-generated Form 3X Surranary Page and

Detailed Summary Page as long as the pages

are an accurate and exact reproduction of

the original FEe forms. Commission regulations permit cornmittees to reproduce FEe

forms provi.ded they are not reduced in

size. 11 CFR 104.2(c). The term "reproduce" means that the "resulting product••• is identical in every respect to an original FEe Form sx." AO 1982-7. Accordingly,

Coopers & Lybrand must modify its coroputerproduced forms to correct cextain deviations from the original form. The changes

will ensure that reports filed on the

reproduced forms will be easy to read and

review.

Anyone else seeking approval of computet-produced forms should submit them to

the FEC's Reports Analysis Division, 999 E

Street, NW, washington. DC 20463. (Computer-produced forms may be used only aftec

they receive FEC approval.) (Date Issued:

April 24, 1992; Length: 2 pages)

6

s.. .:

SPMmP.US v. FlOC: (91-0681(BHG»

On March 25, 1992, the U.S. District

Court for the District of Columbia dismissed this suit because it was filed late.

Edward w. spannaus sought judicial

review of the FEe's decision to dismiss his

administrative complaint. under the statute, he had to file his petition within "60

days after the date of the dismissal."

2 U.S.C. §437g(a)(8). The complaint was

dismissed on January 9, 1991, when the

Commission voted on the decision, but Mr.

spannaus did not file his court petition

until April 2, 1991-83 days after the

dismissal date.

Hr. Spannaus argued that the 60-day

period should begin on the date he received

notice of the FEe's decision (notice was

received at his post office box on January

28 and was claimed on 'February 2). The

court, however, said that this interpretation ttwould be in direct contravention of

the plain words of the statute," which "may

not be superseded by policy goals that cannot be found in the statute..•. " The court

also rejected plaintiff's contention that,

because the 60-day period had already begun

by the time he received notice, he was

denied fair notice and, consequently, due

process. The court pointed out that when

he received notice on February 2, he still

had several weeks to file his petition

within the deadline.

FEe v. FRIWDS Of' SO:IAEFER (91-0650)

SCHAEFER v. FEe (91-90240)

These suits arose from an FEC enforcement proceeding against Friends of Schaefer

and J. Michael Schaefer, as treasurer. Mr.

Schaefer was a 19&6 Senatorial candidate in

Maryland. Mr. Schaefer and his committee

were respondents in an admdnistrative complaint ~ich the Commission had been unable

to resolve through info~l conciliation

efforts. 'l'he agency filed suit against the

respondents on May 15, 1991.

Penalty Claims Against Schaefer

On April 19, 1991 (after the FEe had

notified him of its intention to file

suit). Mr. Schaefer filed an adversary proceeding against the FEC in the U.S. Bankruptcy Court for the Southern District of

California, "mere he had filed for bankruptcy. In Schaefer v. FEC, he argued that

the FEe had failed to file a proof of claim

with the court and therefore could not make
FEDERALELECTION COMMISSION

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June 1992

a claim against him wi th respect to the

payment of any civil penalty that; might

result from the agency's enforcement

efforts.

The FEe asked the court to dismiss Mr.

SChaefer's adversary proceeding or, alternatively, to refer the matter to the federal district court, which was the proper

forum to litigate campaign finance issues.,

On July 2, 1991, the bankruptcy court

denied the FEe'S motion to dismiss and also

denied the alternative motion, stating that

it should be brought before the district

court. The FEe then asked the U.S.

District Court for the southern District of

California to take jurisdiction over this

issue. (FEe v. Friends of Schaefer was

then pending in that court.)

The district court accepted jurisdiction over Mr. Schaefer's adversary proceeding and consolidated the two cases. In

a November 25, 1991, ruling, the court held

that, because a civil penalty is a nondischargeable debt, the FEe could enforce a

civil penalty against M'. Schaefer, regardless of the agency's f?4lure to file a

claim in bankruptcy court;, (Judgment was

entered April 3, 1992.)

contempt Motion

On May 16, 1991, claiRcing that the

Bankruptcy Code barred the FEC from filing

suit against him, Mr. Schaefer moved that

the bankruptcy court hold then FEe Chairman

Jolm warren l'lcGatry in contempt of court

and incarcerate him until the FEC's district court case was dismissed. The FEC

opposed the motion, arguing that the

provision cited Mr. Schaefer did not

apply to a government agency enforcing its

regulatory power. The bankruptcy court

agreed with the FEe and, on OCtober 28,

1991, ordered Mr. Schaefer- to pay the FEe

$750 in sanctions for filing a frivolous

motion.

FECA Violations

on April 7, 1992, the district court

entered a final judgment in FEC v. Friends

of schaefer and ordered defendant Schaefer

to pay a $3,000 civil penalty. The court

found that Me. schaefer and his conunittee

had violated the Federal Election Campaign

Act ~:

o Failing to file a Statement of C~dacy

and statement of Organization on time;

o Accepting an excessive contribution (Mr.

Schaefer received a $30,000 loan from an

individual, deposited the money in his

personal account and then loaned the

money to his cornmittee);

o Failing to continuously report the loan

until it was extinguished;

7

Volume 18, Num

o Knowingly accepting a $28,000 loan f

corporation (Mr. Schaefer obtained a

$28,000 margin loan drawn on his acc

with Charles Schwab & Co. and then l

the funds to his committee); and

o Failing to file three reports on tim

(they were filed between 2 months an

over one year late).

Based upon Mr. Schaefer's continui

refusal to remedy several of the viola

tions, the court enjoined him from com

ting similar violations for one year,

unless the FEe demonstrates that an ex

sion is necessary.

'!HE FREI!:IJCIil 1IEPUBLICANS, INC. v, FEe

On April 7, 1992, the u.s. Distric

Court for the District of Columbia rem

this case to the FEC, ordering the age

"with all deliberate speed•.. [to] begi

ruleroaking proceedings designed to con

the means through which the FEC will e

compliance with Title VI of the Civil

Rights Act•..• " Title VI bars racial

discrimination in aTrf program receiving

federal funds.

In response to the FEe'S motion to

amend judgment, and over the objection 

plaintiffs, the court revised its orde

May 4. 1992, to make clear ~t the or

referred to a rulernaking governing the

delegate selection process of federally

funded national party conventions. Th

amended order also made clear that the

court did not impose a deadline for the

promulgation of the rules.

Background

The plaintiffs in this case--The F

dom Republicans, Inc., and its preside

Lugenia Gordon--alleged that the Repub

party's delegate selection process disc

inated against African Americans in vi

tion of Title VI. (Plaintiffs had mad

similar allegations in an administrativ

complaint, ~ich FEe staff dismissed fo

lack of jurisdiction.) Claiming that 

FEe was responsible for ensuring that 

convention funding program complied wi

Title VI, plaintiffs asked the court to

order the agency to conduct investi

tion of the Republican Party's delegat

selection procedures and to adopt Titl

regulations on delegate selection.

Plaintiffs additionally claimed th

Title VI prohibited the FEe from provi

any public funds to the Republican par

for its 1992 national convention becau

the party's alleged discriminatory dele

process. In moving for partial summar

judgment, however, plaintiffs asked th

(contin
June 1992 FEDERALELECTION COMMISSION

court to consider only their request for a

rulemaking.

The FEe asked the court to dismdss the

case, arguing, among other things, that

plaintiffs lacked 'standing to bring suit;

that they had not exhausted administrative

remedies; that Title VI did not apply to

the public funding programs the FEe administers; and that the FEe did not have

authority to issue delegate selection

regulations under Title VI.

Plaintiffs' standing to Bring SUit

The agency first argued that plaintiffs

lacked standing to bring suit. {The FEe

contended that the jurisdiction of the

courts can be invoked only when an individual plaintiff has suffered <lctual injury

and that plaintiff Gordon made no such

allegation. The FEe similarly argued that

Freedom Republicans failed to allege injury

to its members sufficient to invoke the

court's jurisdiction.)

The court, however, held that Freedom

Republicans had standing to sue on behalf

of its members because the organization

satisfied the three criteria set forth in

Hunt v. washington State Apple Advertising

Commission 1/.

First, the individual members of the

group could themselves have brout;ht action

under Title VI, which "entitIes the Plaintiffs to a private right of action against

the agency for dereliction of its enforcement duties."

Second, the interests Freedom Republicans sought to protect were germane to its

purpose, namely, "advancing the interests

of African Americans through, and within,

the Republican Party."

And third, "the presence of individuals

who have actually been denied delegate status on the basis of racial discrimination

is not necessary" when an organization

challenges an agency's interpretation of

law, "such as the FEC's Interpretet.Ion of

the applicability of Title VI."

Administrative Remedies Pursued

by Plaintiffs

The FEC contended that the plaintiffs'

suit was barred because they failed to pursue an adnUnistrative remedy still open to

them: to petition the agency to issue a

rulemaking on Title VI.

The court, however, pointed out tl1at

the a~nistrative complaint plaintiffs had

filed with the agency "put the FEC on

sufficient notice of Plaintiffs' desire for

a rulemaking."

1432 U.S. 333, 97 S.Ct. 2434 (1977).

8

Volume 18, Number6

Application of Title VI to Convention

Funding

The FEC contended that Title VIZ/ was

not applicable to the public funding of

nominating conventions because of First

Amendment concerns (i.e., government control over the selection of delegates to the

party conventions). The court, however,

said that there were numerous cases in

which First Amendment rights were overridden "by the need to prevent statesponsored discrimination."

The court also rejected the FEe's

argument that the convention funding does

not qualify as "federal financial assistance" because Title VI applies only to

programs where funding is provided to a

nonfedetal entity, which then provides the

assistance to the ultimate beneficiaries.

In the court's view, convention funding

meets this test because the funds "enebke

the party to provide a platform for other,

ultimate beneficiaries, such as Republican

candidates and party members."

Responding to the FEe'S argument that

Congress never intended for the agency to

have any control over the internal .....orkings

of the parties, the court said that there

was nothing in the legislative history

suggestive of Congress's desire to prevent

the FEC from enforcing Title VI.

SUDlaary Judgment

~inding that Title VI applies "to the

FEC as well as to both major political

parties and other recipients of federal

funds," the court granted plaintiffs'

motion for partial summary judgment and

denied the FEe's motion to dismiss. The

court held that the FEC was obligated to

adopt rules that would ensure enforcement

of Title VI in the delegate selection

process.

2Ti tle VI states: "Each Federal agency ••• which is empowered to extend Federal financial assistance to any program or activity,

by way of grant, loan, or contract•.•is

authorized arrl directed to effectuate the

provisions of section 2000d of this

title••• by issuing rules, regulations or

orders of general applicability which shall

be consistent with achievement of the

objectives of the statute authorizing the

financial assistance." 42 U.S.C. S2.000d-1.
FEDERAL ELECTION COMMISSION

•

June 1992

PUBUCFUNDING ,••

Volume 18, Num

.. 

AUDITS

Republicans

Patrick Buchanan s 706,465 $ 2,877,501

George Bush 1,884,092 6,785,189

Democrats

Jerry Brown 1,159,539 2,017,045

Bill Clinton $1,070,846 4,240,649

*Torn Harkin 76,088 1,810,495

"'"Bob Kerrey 159,299 1.783.680

*Paul Tsongas 349,557 1,442,946

*Douglas Wilder 0 289,027

New Alliance Party

tenore Fulani 141,235 1,174,329

'rotal.s $5.627,121 $22,420,860

MAY Pf.H) PAYMBNTS;

AGImN ~IFIES FOR M1\TCBING FWDS

On April 28, the Commission certified

$5.6 million in matching fund payments to

eight 1992 Presidential candidates. The

u.a. Treasury made the payments early in

May. As of the May payment, primary candidates have received $22.4 million in matching funds, as shown in the table. Candidates have requested $5.8 million for the

June payment.

Included in this figure is a $100,000

payment requested by Larry Agran, a Democratic candidate whose eligibility for

matching funds was approved by the Commission on May 14. Mr. Agran is the tenth

presidential candidate to qualify for 1992

matching fWlds.

Matching Fund payments

•

I<ay

Payment

CUrIulative

Total

FDI\.L AlDIT REPORl' rn 1988

JAQ{SOO C\MPAIGN

On April 9, 1992, the CoItUll.ission

approved the final audi t report on the

Jesse Jackson for President '88 Commit

{the Jackson Committee} and two other c

mittees authori~ed by the candidate for 

1988 primary campaign (the California a

New York Committees). Based on the in

repayment determinations listed below, 

Committees must repay a total of $310,9

in public funds to the U.S. Treasury. 

candidate had received over $8 millien 

matching funds for his 1988 campaign.

Based on audit findings, the Comm

made initial determdnations that the

Jackson campaign had to repay the follo

amounts:

Nonqualified campaign Expenses1/

a $18,953, the pro rata portion of $61,

in tax penalties paid by the Jackson

Committee.

o $159,161, the pro rata portion of

$513,329 in disbursements insufficien

documented by the Jackson Commit.tee.

0$57,509, the pro rata portion of $185

apparently overpaid to a vendor by th

Jackson Committee.

o $36,930, the pro rata portion of $119

in disbursements insufficiently

documented by the california Committ

o $23,042, the pro rata portion of $74,

in disbursements insufficiently

documented by the New York Committee

Matching Ftmds Received for: Excessive o

Refunded contributions

o $9,524, representing excessive

contributions submitted for catching

funds by the Jackson CammiUse.

o $672, representin9 contributions

subrnitted for matching funds and then

later refunded by the California

Committee.

Stale-Dated Checks

o $5,115 in checks written by the New Y

Committee that were never negotiated.

• *These candidates have withdrawn from the

presidential race. Governor Wilder withdrew on January 8, Senator xerrey on March

6, senator Harkin on March 9 and former

Senator Tsongas on March 19. '

9

lA ratio formula is used to calculate w

portion of a nonqualifed campaign expen

represented the payment of public funds 

opposed to private contributions. Tha

amount (the pro rata portion) is subje

repayment.
FEDERAL ELECTION COMMISSION Volume 18, Number 6

-" ....:.

oeposit of Contribution

Once the committee treasurer t~ceives a

contribution (either a contribution

forwarded by an agent or one received

directly}, he at she has 10 days to deposit

it. 11 eFR 1Q3.3(a).

o For contributions of $50 or less, the

same records as those requited for contributions that exceed $50 or, in the

case of small contributions collected at

a fundraising event (such as cash contributions collected at a bake sale or gate

receipts for a picnic), the name and date

of the event, and the total amount of

contributions received on each day of the

event. An 1980-99; see also 1981-48.

FEe PUBLISHES tUWILER

The Commission recently cited the committee of Thomas M. Foglietta (pennsylvania

House candidate, 1st Congressional District) for failing to file its pre-primary

report. The names of authorized committees

that fail to file reports are published

pursuant to 2 U.S.C. §438(a)(7). Enforcement actions against nonfilers are pursued

on a case-by-case basis.

-r:

.' . - .

. :,,'t .. .800::~INE' ,":" :"< ..,'

__"'· "';";''--'''''IIIIIIiio'''''''';'';';':;''';_''''''_........_

CON'I'ftlBU'I'IOOS RECEIPT AND DEPOSIT

This article explains what date should

be reported as the "date of receipt." It

also covers the fOIw&tding and deposit of

contributions.

Note that this article does not cover

ea.l'llIarked contributions.

Date of Receipt vs, Date of Deposit

When reporting an itemized contributton's date of receipt, the cOrnmUttee

should not use the date the contribution

was dHpOSlted. Instead, the committee

must use the date the treasurer or

committee agent obtained possession of the

contribution for the committee. 11 eFR

102.8 and l04.3(a)(4)(i) and (i1). An

agent of the committee may 00, far example, th~ candidate, a comncittee employee or

volunteer, a commercial firm hired to raise

funds, a joint fundraising representative,

or, in the case of a separate segregated

fund, a collecting agent.

Date of Receipt: In-Kind COntributions

With respect to in-kind contributions,

the date of receipt is the date that the

goods or services are provided to the

conmdttee. See 11 CFR 110.1(b)(6).

Forwarding Contributions and Records

When an agent not located at corrmrittee

headquarters receives a contribution on

behalf of the committee, the agent must

forward it to th~ committee treasurer

within 10 days from the date of receipt

[i.e., the date the agent obtained

possession) ..!I Exception: Contributions

of $50 or less received for a party

committee, PAC Or other unauthorized

committee must be forwarded within 30 days

from Che date of receipt.

The following records must be forwarded

at the same time as the contribution:

o For contributions exceedmq $200, the

amount, the date of receipt and the complete identification of the contributor

(name, address, occupation and employer).

o For contributions exceeding $50, the

amount, the date" of receipt and the contributor's name and address. 11 CFR

102.8.

MURS RELEASED TO mE PUBLIC

Listed below are MURs (FEC enforcement

cases) recently released for public review.

The list is based on the FEe press releases

of February 5 and 28, March 6, and April

16, 17 ond 24, 1992. Files on closed MURs

are available for review in the Public

Records office.

Unless othe~ise noted, civil penalties

resulted from conciliatio~ agreements

reached between the respondents and the

Commission.

Pre-fIDR 227

Respondents: Re-Elect Stangeland to

Congress Coromittee, Wayne E. Puppe, treasurer (MN)

Canplainant: SUa sponte

SUbject: Disclaimer

Disp::lsition: Declined to open a MUR

lJoint fundraising proceeds do not have to

be transferred to participants within any

specified time period. See 11 eFR

102.17.

Pre-MUR 235

Respondents: National Republican Senatorial Committee, J~s L. Hagen, tceasurer

(DC)

complainant: Referral by Deputy Secretary

of State, Maine

10
FEDERAL ELECTION COMMISSION

•

•

•

June 1992

SUbject: contribution solicitations

Disposition: Declined to open a MUR

1'DJR 1600

Respondents: (a) Rhoads for Congress

committee, William E. Naegel, treasurer

(IL); (b) Mid-America Conservative PAC,

Leroy Corey, treasurer (!Al; (c) Mary

Rhoads (IL)

CODlplainant: FEe initiated

SUbject: Excessive contributions

Disposition: (a) and (c) U.S. District

Court consent order: $2,000 civil penalty;

(b) $250 civil penalty (case was closed

following litigation in 1986)

MlJR 2293

Respondents: (a) working Names, Inc.,

Meyer T. Cohen (Me); et al. (b)-(q)

Carplainant: Sue Elsenbrook (TX)

SUbject: Commercial use of contribution

information

Disposition: (a) U.S. District Court

stipulation and order: $15,000 civil

penalty; (b)-(e) reason to believe but took

no further action; (f)-(q) no reason to

believe

l'lUR 2344

Respondents: (a) Friends of Isaiah

Fletcher, Isaiah Fletcher, Sr., treasurer

(MO); (b) Fannie E.C. Alston as treasurer

of Friends of Isaiah Fletcher

COPlplaillMl.t; FEe initiated

Subject: Failure to file reports

Disposition: (a) U.S. District Court judgment: $5,000 civil penalty; (b) probable

cause to believe but took no further action

MlJR 2590

Respondents: (a) Fields for congress

COmRUttee, Barbara Shaw, treasurer (MO);

(b) Officer campaign Comnittee (NO) ~ainant; Mike Mansfield (MO)

Subject: Failure to register and report;

inadequate disclosure

Disposition: (a)-(b) Reason to believe but

took no further action

MlJR 2696;2615

Respondents (all in 00): (a) James

Kassouf; (b) Michael DeGrandis; (c) James

Dietz

CODlplainants; The Honorable Edward F.

Feighan (OB) (267S); James M. Ruvolo,

Chairman, Ohio Democratic party (2696)

Subject: Disclaimer; failure to register

and report

Disposition: (a)-(c) Raason to believe but

took no further action

11

Volume 18, Num

MUR 2743

Respondents (all Ln NY): (a) swarts f

Congress, Inc., Lawrence H. Levin, tre

urer; (b) Friends of Dave SWarts, Mary

Suto, treasurer; (c) Dave swarts

CoIIplainant: Joseph R. Gaylord, Execu

Director, National Republican Congress

Commi t tee (oc:1

SUbject: Failure to register and repo

corporate contributions

Disposition: (a) and (b) $500 joint c

penalty; (c) no reason to believe

MlJR 2161

Respondents: (a) Sevier Heights Bapt

Church ('IN): (b) Hollie Miller (TN).

(c) Presidential Biblical Scoreboard (

(d) Tim LaHaye (DC); (e) Family Life

Seminars (DC)

Complainant: Robert Lawson, CumberLan

Baptist Church (TN)

SUbject: corporate contributions; fai

to report independent expendtturesr

disclaimers

Disposition: (a)-(b) Insufficient num

of votes to find reason to believe; (c

reason to believe; (d)-(e) reason to

believe but took no further action

MlJR 2926;2822

Respondents: (a) Donald M. Hiner (VA)

Hiner and Associates, Inc. (VA]; et a1

(c)-(o)

~lainant: National Republican Cong

sional Committee (DC)

SUbject: Use of FEC reports for comm

purposes

Disposition: (a)-(b) $5.000 joint civ

penalty; (c)-Col reason to believe but 

no further action

1'lUR 3013

Respondents (both in DC): (a) Nationa

Conservative Congressional Committee, 

William Bonsib, Jr., tr~asurer; (b) Bo

Iric , , L. William Bonsib, Jr., chairman

Complainant: FEe initiated

SUbject: corporate contributions; fai

to maintain proper checking account; f

ure to file reports on time

Disposition: (a)-(b) Probable cause t

believe but took no further action

MUR 3054

Respondents: 1a) Ileana Ros-Lehtinen 

Congress Committee, Jose M. MartinezArmesto, treasurer (FL); 1b) Republica

National Committee, William J. McManus

treasurer (DC); (c) National Republica

Congressional Committee, Nancy S. MAr

assistant treasurer (OC); (d) Republic

Party of Florida. Shirlee Bowne, treas

(conti
June 1992 FEDERAL ELECTION COMMISSION

(FL); (e) Republican party of Dade County,

Ernesto Martinez, treasurer (FL)

Complainant: FEe initiated

SUbject: Excessive contributions; failure

to file 48-hour notices; inaccurate disclosure of financial activity

Disposition: (a) $4,000 civil penalty;

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

further action; (ef $1,000 civil penalty

MUR 3081

Respondents: Iowans for Powell, M. Craig

McIntyre, treasurer (LA)

COJIPlainant: Judith Reinhart, Bluegrass

Associates, Inc. (lA)

Subject: Inaccurate disclosure of debts

Disposition: Reason to believe but took no

further action

MU1I. 3155/3078

Respondents: Margaret Mueller for Congress

Commdttee, Gerald wolanin, treasurer (oa)

Ca!lplainant: Richard Bates, Executive

Director, Democratic Congressional

COJ1Ul\i t tee (IX:)

Subject: Failure to file reports on time;

improper disclosure; disclaimer

Disposition: $5,000 civil penalty

MUR 3176/3167

Respondents: (a) Christian Coalition,

Ralph Reed. executive director (VA),

(b) American Family ASsociation Foundation,

Don wildmon, executive director (MS);

(c) Montana Family Forum, Ron Oberlander,

state director (MT)

Complainants: Democratic congressional

campaign CoImlittee (DC) (3167); Montana

Democratic party (3176)

Subject:.; Corporate contributions;

disclaimers; express advocacy; failure to

register and report

Disposition: Insufficient number of votes

to find either reason to believe or no

reason tc believe

MUR 3261

Respmdents: Keep George Brown in

Congress, Eugene F. Basinger, treasurer

iCA)

Ccmplainant: FEe initiated

SUbject: Failure to file 48-hour notices

Disposition: $750 civil penalty

MUR 3284

Respondents: corporate Citizenship conmit-.

tee !ITT), Charles M. wurst, treasurer (NY)

COOJplainant: FEe initiated

SUbject: Failure to file report on time

Disposition: $275 civil penalty

12

Volume 18, Number 6

IIlR 3315

Respondents: Josie Heath for U.S. senate,

Inc., Tim Atkeson, treasurer (CO)

Ccaplainant: FEe in1tiated

SUbject: Failure to file 48-hour notices

Disposition: $3,000 civil I;enalty

MIJR 3324

Respondents: National Freedom political

Action Committee, Kendall McBriar,

treasurer (WA)

complainant: FEC initiated

Subject: failure to file reports on time

Disposition: $250 civil penalty

IIlR 3349

Respondents: Pete Peterson Campaign Fund,

Mary K. venccre , treasurer (Ft)

Complainant.: FEe in!Hated

Subject: Excessive contributions; contributions from unregistered organizations

Disposition: $900 civil penalty (excessive

contributions); no probable cause to

believe (unregistered organizations)

IIlR 3353

Respondents: Richard E. Neal for congress

Commdttee, Michael Hall, treasurer (Me)

Complainant: FEe initiated

Subject: Failure to file 48-hour notices

Disposition: $2,000 civil ·penalty

MUR 3358

Respondents (all in FA): (a) Don L.

Ritter; (b) Lehigh Valley Citizens for Don

Ritter, Betty S. Gates, treasurer

complainant: Richard J. Orloski (PA)

Subject: Inaccurate disclosure; conuniteee

depositories; excess funds

Dispositioo: (a) and (b) No reason to

believe

MUR 3361

Respondents: (a) Stevens for Congress,

Stephen w. Woody, treasurer (NC); et al.

ibl-ijl

Carp1"inant: Jack Hawke, chairman, North

Carolina Republican party

SUbject: Disclaimer; failure to register

and report

Disposition: (a) Reason to believe but

took no further action; (b)-( j) no reason

to believe

MUR 3363

Bespoo:lents: Glassco for Congress Committee, Chris Economou, treasurer (OK)

Ctx!lplainant: FEe initiated

Subject: Excessive contributions; contributions fr~ unregistered organization

Disposition: $800 civil penalty
June 1992 FEDERAL ELECTION COMMISSION Volume 18, Num

•

•

•

,.,. 3376

Respondents (both in MAl: (a) congressman

Gerry E. studds; {bl studds for Congress

Committee, Edwin M. 'Martin. treasurer

complainant: Jon L. Bryan (MAo)

SUbject: Disclaimer

Disposition: Insufficient number of votes

to find eithe!" reason to believe or no

reason to,believe

MUR 3387

Respondents: Wine Institute Political

Action Commdttee, John A. DeLuca, treasurer

(CA)

caaplainant: t='EC initiated

SUbject: Failure to file report on time

Disposition: $1,000 civil penalty

,.,. 3415

Respondents: United Egg Association

political Action Cornmdttee, Albert E. Pope,

treasurer (GA)

complainant: FEe initiated

SUbject: Failure to file report on time

Disposition: $500 civil penalty

MUR 3424

Respondents: People for Carlos Lucero,

Inc., carolyn E. Daniels, treasur~r (00)

CaDplainant: FEe initiated

SUbject: Failure to file 4B-hour notice

Disposition: $750 civil penalty

lOJR 3433

Respondents: Friends of Sam Johnson,

Lyndon Bozeman, treasurer (TXl

Complainant: FEe initiated

SUbject: Failure to file 4B-hour notices

Disposition: $3,000 civil penalty

MlJR 3434

Respondents: Anita for Congress, Virginia

R. Patterson, treasurer (CAl

Complainant: FEe initiated

SUbject: Failure to file 4B-hour notices

Disposition: $2/000 civil penalty

,.,. 3438

Bespondents (both in MA): (a) Congressman

Gerry E. Studds; (b) Studds for Congress

Committee, Edwin M. Martin, treasurer

complainant: Jon L. Eryan (MA)

SUbject: Disclaimer; 'failure to itemize

contributions

Disposition: (a)-(b) No reason to believe

MUR 3443

Respondents: (a) National Republican

Senatorial Commdttee, James L. Hagen,

treasurer (DC); (b) Bill Grant (FL)

CCmplainant: Anthony R. Martin (FL)

SUbject: Failure to disclose transac

properly

Disposition: Dismissed

Jl1UR 3451

Respondents (both in NV): (a) Marrou 

President, James A. Lewis, treasurer;

(b) Michael L. Enerling

CorIplainant: FEe initiated

Subject: Excessive contributions

Oisposition: (a) $3,000 civil penalty

(b) $1,600 civil penalty

,.,. 3459

Respondents: Quillen for Congress co

tee, Herbert W. Hoover, treasurer (TN

Complainant: FEC initiated

Subject: Failure to file 48-hour not

Disposition: $2,600 civil penalty

MUR 3462

Respondents: Pilzer for Congress, Fr

L. casey, treasurer (TXl

Cooplainant: FE;C initiated

SUbject: Failure to file 48-hour not

Disposition: $1,000 civil penalty

,.,. 3463

,.Respondents: Durkin for u.s. Senate, 

Connelly, treasurer (NH)

complainant: FEC inibated

SUbject: Failure to file 4B-hour not

Disposition: $1,000 civil penalty

MUR 3464

Respondents: Dan Branch for Congress

Committee, R. Byron Carlock, Jr., tre

Complai~t: FEC initiated

SUbject: Failure to file 4B-hour not

Disposition: $1,000 civil penalty

.MUR 3469

Respondents: Bush-Quayle '92 Primary

Committee, Inc., J. Stanley Huckaby,

treasurer (DC)

CO!Ilplainant: Endicott peabody (NHI

SUbject: Misleading committee name

Disposition: No reason to believe

13
June 1992 FEDERAL ELECTION COMMISSION Volume 18, Number6

.INDEX

The first number in each citation

refers to the "number" (month) of the 1992

Record issue in which the article appeared;

the second number, following the colon.

indicates the page number in that issue.

AlNISOR'l OPINI<JiS

1991-29: Contributions received and made by

corporation's employee pledge program,

1:4

1991-32: Charges fOr consultant's fundraising services. 5:6

1991-33: Allocation of expenses when party

committee 'administers primary election,

1:6

1991-34: Comndttee sale of access to voter

data base as ongoing venture, 1:6

1991-35: Application of allocation rules

when S$F's nonfederal account pays it~

own administrative expenses, 2:10

1991-36: corporation's payment of employee's travel expenses to attend party

fundraise!, 3:5

1991-37: Nonconnected PAC's payment to

incorporated firm for shared facilities

and services contributed to committees,

3:5

1991-38: Repayment of embezzled funds to

candidate committee, 3:6

1991-39: Contributions suspected of being

made in names of others, 4:9

1992-1: Campaign salary paid to candidat6;

reimbursements for campaign expenses, 4:9

1992-2: party reallocation of staff

salaries as fundraising expenses, 4:10

1992-3: Corporation's payment of benefits

for employeel candidate on unpaid leave,

5:8

1992-4: Campaign's payment of candidate's

living expenses and spouse's salary, 4:10

1992-5: Candidate's appearance in cable

public affairs programs, 5:8

1992-6: Honorarium paid to candidate for

speech on campaign issues, 4:11

1992-7: Corporate PAC's solicitation of

franchise personnel, 6:4

1992-8: Tax seminars as fundraising

mechanism, 5:0

1992-9: Cooperative's twice-yearly

solicitation throuqh ~affle at annual

meeting, 6:5

1992-10: commdttee's diSbursement to

nonprofit voter organization, 6:5

1992-11: Computer-generated summary page

and detailed summary page, 6:6

14

= CASES

FEe v ,

- AFsCME=Po, 1:7

NlU\ Political Victory Fund, 1:7

- pOpulist party (92-0674), 5:9 - Schaefer, Fciends of, 6:6

v. FEC

- Akins, 1:8, 3:7 - BraiiStoo1, 3:8 - Common Cause (91-2914), 1:9 - Common Cause 192-Q249), 3:8

- Freedom Re~licans, Inc., 3:7; 6:7 - tescuche , 4 :

- National Rifle Association of America

(NRA) (89-3011), 4:8

- Schaefer, 6:6

- s~au$, 6:6 - Trinsey, 3:7

llEl'OR'rml

Pre-prima~ reporting dates - correction, 08, se, 5:9

- House and Senate, 1:14 - presidential, 2:10; 3:10

Schedule for 1992, 1:10; 3:8; 6:2

sm<DIID LIMITS FOR 1992

Coordinated party, 3:1

Presidential. 3:14

800 LINE

COMpliance with laws outside FEC'~ jurisdiction, 3:12

Contributions: receipt and deposit, 6:10

Last-minute contributions: 48-hour notices

required, 1:18

R$9istration by candidates and tneit

comroittees, 2:12
•

•

•

June 1992 FEDERAL ELECTION COMMISSION Volume 18. I~um

"'

15
June 1992

- FEDERALELECTION COMMISSION Volume 1BJ Number 6

_. -----'

ORDER FORM FOR NEW CORPORM'E/IAOOR GUIDE NI)

1992 FEe RmJIATIOOS

{See articles on page 1.)

Name.

f..ddr.ess:

Ddyt1me

Yho:1e:

(Phone n~~r requested in case FEe has questions about your order.)

~ndicate the number of copies you want and mail to: Federal Election Commission,

Information Services Division~ 999 E street, NW, Washin9ton. DC 20463 •

.I

I ---- New Edition of the campaign GUide for corporations and Labor Organizations

l_~~_Uoo of FEe Begulatians (ll CPR)

.--------------~---------,

REl'OR'l'S IX1E IN JULy

See article on page 2.

~iii"'iiiiiiiiiiiiiiiiiiiiiiiiiiiiiiliiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiliiiiiiiiiiiiiiiiiiiiiiiiiiiii__iiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiii__iiiiiiiiliiiiiiiiiiiiiii_"_lIIIIIiiiiiii

FEaEr-1AL ELECTrON COMMISSION

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Washington, DC 20463

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