Advisory Opinions, (cont'd trom P. 4)

interest earned from transferred funds be timely
reflected in reporting.

Surplus funds remaining from an election cam-
paign for local or State office are contributions subject
to reporting requirements and limitations if transferred
to a Federal election campaign committee by a pre-
existing committee with consent of the original donors
to “earmark” their monies to a particular Federal candi-
date. As both the committee and the individual donor
assert control over earmarking, the transfer will be con-
sidered a contribution applicable to the limitations of
both parties. Such contributions must be reported by
the political committee to the Commission and to the
intended recipient. Future regulations will provide
specific guidelines for reporting of these transfers.
Such funds may not include contributions from
national banks, corporations, labor unions, Govern-
ment contractors, or agents of foreign principals.

AO 1975-13 — CHAMBER OF COMMERCE MONIES

The Commission was asked to determine whether
acceptance of travel expenses for a speaking engage-
ment at.a Chamber of Commerce is prohibited if the
chamber’s treasury contains corporate contributions.

Once an individual has become a Presidential
candidate, all speeches before substantial numbers of
people are made presumably to enhance his candidacy.
Accordingly, use of corporate money for payment of
expenses would constitute an illegal campaign contri-
bution. The Commission noted, however, that
organizations such as a Chamber of Commerce could
legitimately pay such expenses from separate,
segregated accounts containing no corporate con-
tributions.

AO 1975-14 — CONTRIBUTIONS TO DEFRAY CON-
STITUENT SERVICE EXPENSES

The Commission ruled that contributions to and
expenditures from an office account of a Member of
Congress are to be treated as political contributions
and expenditures, subject to applicable limitations and
prohibitions. Upon the theory that Congressional
appropriations for legislative activities reflect a Con-
gressional determination of the amount necessary for
continued performance of public duties, additional
monies contributed to an office account are political in
nature, and expenditures from such an account are
intended for purposes of influencing a Federal
election.

Therefore, money from the “educational fund” of a
labor union, derived from dues and not from voluntary
donations of members, may not legally be contributed
to an office account of an incumbent Senator or Repre-
sentative. Similarly, contributions by incorporated

State banks or bank-holding corporations to an
agricultural conference organized by a Member of Con-
gress would be prohibited, as the conference would
otherwise be financed from an office account if not
directly by Congressional appropriations. In direct
analogy, free use of a corporate computer to analyze
the results of a Congressman’s survey is an illegal con-
tribution, since the exemption for material prepared to
be mailed under the frank does not extend to analysis
of returns.

AO 1975-16 — INCORPORATED ASSOCIATIONS

An incorporated association is prohibited by Fed-
eral law from making Federal campaign contributions.
Prohibitions in the Federal campaign law apply
“... with limited exemption, to contributions or ex-
penditures by non-profit corporations, just as they
apply to contributions or expenditures made by profit-
making corporations.”

Excepted from the FEC ruling would be “a non-
profit organization created expressly and exclusively to
engage in political activities, (which) has incorporated
for liability purposes only. That type of corporation is
essentially a political committee and may contribute
its assets to Federal candidates the same as unin-
corporated political committees.”

Included in the Opinion was a reminder that a cor-
poration subject to such prohibitions may establish a
segregated fund of voluntary individual contributions
and may make contributions and/or expenditures in
connection with Federal elections from that fund. In
turn, a candidate or political committee may accept a
contribution from such a fund.

AO 1975-17 — PARTNERSHIP CONTRIBUTIONS

Federal election campaign law restricts the amount
which a partnership can contribute to a candidate for
Federal office to $1,000 in each election. Such a con-
tribution counts against each individual partner's
limitation in direct proportion to his share in the
profits. The Commission cited the following example:
“In the case of a four-member partnership (each
partner having an equal share) which makes $1,000
contribution to a Federal candidate, one-fourth of the
$1,000, or $250, is counted toward each individual
partner's limit. Therefore, each partner may contribute
no more than an additional $750 to the same Federal
candidate with respect to the same election.”

When a contribution is made in the partnership
name without accompanying information as to each
partner’s proportionate share thereof, the committee
recipient must obtain a written statement providing
this information within 30 days after receiving the con-
tribution. If the information is not received in time, the
contribution must be returned or the candidate or com-
mittee will be held to have illegally accepted a contri-
bution in the name of another (i.e., the partnership).



against expenditure limits if distributed only to dues- *

paying members of the party and if the party is not
organized primarily to influence the nomination or
election of any person to Federal office.

"AO 1975-3 — REPUBLICAN CONGRESSIONAL
COMMITTEE

The National Republican Congressional Commit-
| tee provides various services for Republican members
of the House of Representatives. These include: print-
ing newsletters, excerpts from the Federal Register,
‘and surveys to be mailed under the member’s frank;
paying for tabulation of responses to questionnaires
/ Sent to constituents under the frank; reimbursing for
| cost of newsletter stationery. The Committee inquired
as to whether these services constitute campaign
contributions.
| The Commission stated that the cost of preparing
materials to be mailed under the frank will not be
| charged against contribution or ‘expenditure limita-
tions. But the practice of paying cost of tabulating
‘ responses to surveys is attributable to these limits.

AO 1975-4 — DEMOCRATIC PARTY TELETHON

The Democratic National Committee, in reference
to its National Telethon, inquired: Is the endorsement
or guarantee by an individual of a bank loan considered
a contribution, although the loan will be repaid from

| proceeds of the telethon?
| The Commission determined that loan guarantees
: constitute contributions on the part of guarantors,
i since the purpose of any transfer of money or thing of
value to a political party, even if not earmarked for a
: particular candidate, is the election of the party’s
designated candidate. To the extent that such a loan is
not repaid, the endorsements will be considered
| statutory contributions in an amount equal to the
| remaining balance.

| AO 1975-5 — PRE-1973 DEBTS

Current contributions made solely for repayment of
debts stemming from Federal election campaigns,
which were incurred prior to January 1, 1973, are not
subject to contribution and expenditure limitations.
: The Commission requires, to assure compliance, that:
; (1) a candidate or former candidate who wishes to
retire a debt inform the Commission of the amount by
filing before August 25, 1975, (2) solicitations for con-
| tributions to retire debts include clear notice of that

purpose, (3) contributions exceeding $100 to be

earmarked for that purpose, (4) contributions be re-

ceived before December 31, 1975, (5) such contribu-

tions be reported separately from funds raised for
| future elections until the debt is erased.

AO 1975-6 — 1973-1974 CAMPAIGN DEBTS

The Commission was asked to decide three ques-
tions relating to campaign debts incurred from Jan-
uary 1, 1973, through December 31, 1974: (1) Is a former
candidate limited in expenditures from personal and

family funds to erase a past debt? (2) Are contributions
raised solely to liquidate past debts subject to limits?
(3) Can a candidate cancel debts. owed to ‘him by his
committee?

The Commission determined that candidates are
subject to personal limitations in repaying the .1973-
1974 debts. Political committees and individuals are
not bound by the present contribution limitations if
their contributions are to be used solely for eradication
of 1973-1974 debts. The guidelines established in
AO 1975-5 are to be followed by both candidates and
contributors. Finally, a former candidate can cancel
any debt owed to him by his campaign committees.

AO 1975-8 — HONORARIUMS

A Federal officeholder or employee is considered
to have accepted an honorarium subject to limitations
if (1) he receives it for personal use, (2) he directs that
the honorarium be given to a charity which he names,
(3) he suggests that the honorarium be donated to a
charity of the sponsor’s own choosing, or (4) a charita-
ble donation is made in his name, assuming that the
officeholder made an appearance or speech or had
written an article for the sponsor.

Members of Congress who have already received
the total limit of $15,000 per year in honorariums “may
continue to accept speaking engagements for which
they receive only their own personal actual transporta-
tion, accommodation, and meal expenses.” Once an
individual becomes a candidate, he cannot receive
expense money for speeches before substantive

- numbers of people comprising a part of his electorate

from organizations prohibited by law to make cam-
paign contributions, since such appearances presum-
ably enhance his candidacy.

AO 1975-9 — UNOPPOSED PRIMARY CANDIDATE

A candidate unopposed in a primary election is
entitled to receive contributions and make expendi-
tures in equal amounts to any candidate in a primary
fight. Expenditures made solely to defray costs
incurred in the primary election will not be chargeable
to the unopposed candidate’s expenditure limits in the
general election. The Commission stated: “The Fed-
eral Election Campaign Act makes no distinction be-
tween opposed and unopposed candidates for pur-
poses of either contributions or expenditure limits.”

AO 1975-10 — INTERNAL TRANSFER OF CAMPAIGN
FUNDS

The Commission ruled that campaign funds may
be transferred from a designated campaign depository.
to a savings account in the same bank or in another
financial institution if full disclosure is made and the
campaign committee retains complete control .of, the
transferred funds at all times. To assure compliance,
the Commission requires: (1) that all funds transferred
be reflected clearly on reporting forms, (2) that all
funds be eventually transferred back into the campaign
depository checking account, and this be clearly
reflected in reporting, (3) that no expenditures be made
from any account other than the checking account at
the designated campaign depository, (4) that any



NEW HAMPSHIRE & TENNESSEE
HOLD SPECIAL ELECTIONS

Two Federal elections this fall, in New Hampshire
and Tennessee, are the first held under the provisions
of the 1974 Amendments to the Federal Election Cam-
paign Act of 1971.

‘The New Hampshire race was a Sept. 16 rerun of
last November’s general election. Republican Louis
Wyman, Democrat John Durkin, and American Party
Candidate Carmen C. Chimento opposed one another.
Each candidate had been notified by the Commission
of the interim guidelines issued Aug. 20, under which
their race was conducted, and each candidate, as well
as his supporting committees, was informed that any
campaign-related activities are subject. to the provi-
sions of the new Amendments. The Commission, as an
added effort to aid the candidates in this highly
unusual election under the new provisions, dispatched
a Staff team of accountants and lawyers to New Hamp-
shire to advise and discuss the guideline provisions
and answer questions the candidates may have had.

Eleven candidates have filed for Tennessee’s Sth
Congressional seat vacated by Richard Fulton, Mayor-
elect of the City of Nashville. They will compete in
party primaries on October 9, with winners meeting in
the November 25th general election. As in the New
Hampshire case, all candidates will be notified that
new laws are in effect and that the Commission will
soon be establishing guidelines concerning the
financial aspects of the election.

FEC INITIATES AUDIT OF
PRESIDENTIAL CAMPAIGNS

Members of the Federal Election Commission A
Audit and Investigation Division are currently “in the
field” to audit the records of the principal campaign
committees. of Presidential candidates who “have
either announced that they have met threshold require-
ments which would make them eligible to receive
public funds, or, on the basis of reports and state-
ments filed with the Commission, appear to. have
raised substantial amounts of funds.”

In teams of three, the auditors will visit in alpha-
betical order by name of the support committee—
Bentsen in '76, and the Committee for Jimmy Carter,
and so on down the line.

Peter Roman, Chief of the Audit and Investigation
Division, states that this will be the first of several
visits in an on-going review of the committees’ finan-
cial records between now and the 1976 election.

REPORTING REQUIREMENTS

A candidate or political committee as defined by
the Federal Election Campaign Act which has received
contributions in excess of $1,000, or made expendi-
tures in excess of $1,000, during the calendar quarter
duly 1, 1975, through Sept. 30, 1975, is required to file
areport of receipts and expenditures on or by Oct. 10,
1975.

Published by THE FEDERAL ELECTION COMMISSION, 1325 K Street, N.W., Washington, D.C. 20463. Commissioners are:
THOMAS B, CURTIS, Chairman; NEIL STAEBLER, Vice-Chairman; JOAN D. AIKENS; THOMAS E. HARRIS; VERNON W.
THOMSON; ROBERT O. TIERNAN; FRANCIS R. VALEO, Secretary of the Senate, Ex-Officio; W. PAT JENNINGS, Clerk of the

House of Representatives, Ex-Officio.

Staff Director - Orlando B. Potter; General Counsel -.John G. Murphy, Jr.; Asst. Staff Director for Administration - Robert
Baker; Asst. Staff Director for Disclosure and Compliance - Drew McKay; Asst. Staff Director for Information Services, and

Editor - Herb Koster.

FEDERAL ELECTION COMMISSION
1325 K STREET, NW
WASHINGTON, DC 20463

OFFICIAL BUSINESS

GPO 900-327

POSTAGE AND FEES PAID



THE FEDERAL ELECTION

COMMISSION

=zCORD

1325 K Street N.W. Washington, D.C. , 20463

Volume 1, No. 1

September 1975

FIRST ADVISORY OPINIONS ISSUED -- REQUESTS POUR IN

The Federal Election Commission is moving at a
rapid pace now to eliminate a backlog of nearly 100
questions put to the Commission in the form of
Advisory Opinion Requests. In the period from early
July through August, 1975, the Commission has
handed down 14 Advisory Opinions from a wide variety
of applicants, dealing with questions from contribu-
tions by unions and corporations to Congressional
office accounts to the maximum expenditure limitation
allowed:a primary candidate.

The Commission administers, interprets, and en-
forces Federal election campaign financing laws, and
is responsible for upholding the reporting and financial
disclosure requirements of all persons seeking Federal
office, as well as individuals and groups supporting
them.

FEC’S CONSTITUTIONALITY UPHELD,
CASE HEADS FOR SUPREME COURT

The United States Court of Appeals has upheld the
basic provisions of the new Federal Election Law and
has ruled that Congress has the power to limit: cam-
paign contributions and expenditures and to provide
for public financing of Presidential campaigns.

Created to administer and enforce the 1974 Amend-
ments to the Federal Election Campaign Act of 1971,
the Commission is a legislative agency and, as such,
has the power—reinforced by the Court decision—to
render opinions to certain persons as to whether
planned activities or transactions will violate certain
Federal statutes governing the electoral process.

The suit—filed by Sen. James L. Buckley, former
Senator Eugene McCarthy and others—challenged the
law as being unconstitutional because it limited the
amount individuals could contribute to campaigns and
the amount candidates could spend in their effort to be
elected. -

Upholding the Commission’s constitutionality, the
judicial panel in its summary stated, “The Court finds
that the power of Congress to regulate Federal
elections embraces the power to adopt per candidate
an overall limitation on the amount that an individual or
political committee may contribute in the context of
Federal elections and primaries.

(Continued, P. 3)

The law provides that upon request of (1) any
individual holding Federal office, (2) any candidate for
Federal office, or (3) any political committee, the Com-
mission shall render an Advisory Opinion as to whether
any specific transaction or activity by that individual or
committee would constitute a violation of the Federal
Election Campaign Act, as amended, and certain provi-
sions of Title 18, United States Code. (See Insert.)

The Commission is guided ‘in its duties by six
Commissioners and two ex-officio, non-voting mem-
bers. The Commissioners are Chairman Thomas B.
Curtis, Vice-Chairman Neil Staebler, Joan D. Aikens,
Thomas E. Harris, Vernon W. Thomson and Robert O.
Tiernan. The ex-officio members are Francis R. Valeo,
Secretary of the Senate, and W. Pat Jennings, Clerk of
the House of Representatives.

The Commission generally meets twice a week, but
may be called into session at other times at the request
of any member. The Commission .meets in open
session except when discussing ‘personnel or
investigatory matters.

The Commissioners have set for the Commission a
primary goal of full voluntary compliance with the Fed-
eral election campaign financing laws. In pursuit of
this goal, the Commission hopes to encourage greater
understanding and participation in the electoral
process.

Any person may direct an inquiry to the Commis-
sion. Those having general questions concerning the
Federal Election Commission, or the Federal election
campaign financing laws should contact the Office of
Public Communication either at (202) 382-4733 or at
The Federal Election Commission, 1325 K Street,
N.W., Washington, D.C. 20463.

Highlights of the Advisory Opinions issued to date
follow. These brief synopses of “AOs” will be a regular
feature of The FEC Record.

AO 1975-1 — NATIONAL PARTY CONVENTIONS
The Democratic and Republican National Commit-
tees both asked the Commission: Would goods and
in-kind services which are offered to national parties by
cities and private corporations constitute illegal contri-
butions; if not, would such services be credited against
expenditure limits allowed to a party with respect to a
Presidential nominating convention?
(Continued, P. 2)



FEC PROCEDURES DESCRIBED
FEC Procedures Regarding Rulemaking:

* All notices of FEC intent to make rules will be
published in the Federal Register and Congres-
sional Record, and the period for public come:
ment will be stated. Comments concerning the
interpretation and implementation of specific
provisions should be made in writing to the
FEC, Office of General Counsel, Rulemaking
Section...

‘After considering comments received from: the
public, the Commission will formally propose
rules concerning the interpretation and imple-
mentation of specific provisions of the law. The
proposed rules will be forwarded to Congress
for review and, if not disapproved by Congress
within 30 legislative days, will be formally pro-
mulgated by the Commission.

FEC Procedures Regarding Advisory Opinions:

* A request for an Advisory Opinion must be sub-
mitted in writing to the Gommission.

All valid requests for Advisory Opinions will be
made public and published in the Federal Regis-
ter and Congressional Record In edited original,
paraphrased, or, in the case of multiple similar
requests, consolidated form.

Interested parties will have a period of 10 days
from the date of publication to submit written
comments. (Reasonable requests for an extéen-
sion of the comment period will normally be
granted.) Comments should refer to the specific
Advisory Opinion number and should be dix
rected to the FEC Office of General Gounsel,
Advisory Opinion Section.

After consideration of the request and the public
comments received, the FEC will Issue a formal
Advisory Opinion.

* An individual or committee requesting an opin-
ion ona matter which the Commission-deems to
have already been answered by an earlier Advi-
sory Opinion will be referred in a formal and
published fashion to the previous Advisory
Opinion. The Gommission publishés Advisory
Opinions for general guidance. A recipient of
such an opinion who in good faith relies on its
contents will be presumed to be in compliance
with the Act. Others who feel that their question
bears. similar circumstances and should fall
under the provisions of the opinion, should stil!
request an opinion of the Commission.

“Opinion of Counsel” and General Information Letters:

in the case of géneral réquests for guidance and
Specific inquiries that do not meéet the statutory re-
quirements for a formal Advisory Opinion, the FEC
Office of Géneral Counsel or Office of Information. will
éndéavor to provide information, answers or guidance.
While these “Opinion of Counsel” or general informa-
tion letters will not extend the same statutory presump-
tion of compliance as the forma! Advisory Opinion, the
Commission recognizes the need and desirability to
assist individuals, candidates and committees in their
efforts to understand and comply with the law.

Final rules approved by the Commission and Con-
gress, formal Advisory Opinions, and Interim Guide-
lines will be published in the Federal Register and
other. outlets of wide public distribution.

The Federal Election Commission Record will be
published on aregular basis. With Volume I, Number 1,
we have explored and experimented with contents and
their presentation. We hope the looseleaf binder sys-
tem will be a ptactical means by which you can be kept
up to date on Commission activity. We welcome any
Suggestions you may have on the format for future
issues.

FEC CARRIES MESSAGE
The Federal Election Commission has ac-

cepted invitations to be represented at these
Sept. events:

Sept.12 National Federation of Republi-
can Women Biennial Convention,
Dallas, Texas

Commissioner Joan D. Aikens

Conference on State and Federal
Campaign Laws, Pace University,
Westchester Campus, Pleasant-
_ville, New York (afternoon panel)
Susan King, Drew McKay

Sept. 18-21 Democratic National Committee
Campaign Training Institutes,
Louisville, Kentucky

Attending
Sept.18

Attending

Attending Vice-Chairman Staebler

Sept. 24 National Press Club V.I.P.
Luncheon

Attending Chairman Curtis
Vice-Chairman Staebler

Sept. 24 93rd Congressional Democrats,
Washington, D.C.

“Attending Chairman Thomas B. Curtis

Vice-Chairman Neil Staebler

Advisory Opinions, AO 1975-1
(cont'd trom P.-1)

The Commission determined that local or State
government agencies would not be prohibited from
providing facilities or services, provided that facilities
are not leased from corporations, national banks and
labor organizations for less than fair market value, and
that the municipal corporations are not mere conduits
for corporate contributions unable to be made directly.
As to private corporations, rate reductions and “free”
facilities like those offered in the ordinary course of
business to non-political conventions are not to be
considered political contributions. Local retail busi-
nesses may contribute funds to a non-profit civic asso-
ciation, business league or Chamber of Commerce, if
in the course of giving to encourage the arrival of
equally large non-political conventions. The Commis-
sion classified these transactions as “gratuities” which
are not attributable to the parties’ $2 million expendi-
ture limitation.

AO 1975-2 — MICHIGAN COMMITTEES
This opinion defines (until promulgation of regula-
tions) the relationship between the Michigan Demo-

cratic Party’s State Central Committee and local com-
mittees for purposes of filing reports and application of

(Continued, P. 3)



CHAIRMAN URGES VOLUNTARY COMPLIANCE

The elections process, to be
truly meaningful, requires the active
participation of as many people as
possible. This involvement is an
honorable and praiseworthy en-
deavor and is indeed one of the
most important responsibilities of
every citizen.

Many people today are under-
standably turned off by politics. For
example, the Census Bureau estimates that during the
1974 Federal General Election, only 62% of those eligi-
ble to vote bothered to register and of those registered
to vote, only 72% bothered to show up at the polls to
cast a ballot. (These rates compare very badly with
other western democracies where 80 to 90% of those
eligible cast ballots.) A much lower percentage, per-
haps as low as 1%, participate in the “nuts and bolts”
of this process in the United States by being candi-
dates or active political workers.

The reasons for this ever-decreasing level of politi-
cal participation are many and complex. But there is no
question that increasing numbers of people.are making
conscious decisions not to participate in the elections
process. Large numbers of people have decided that
the benefits they derive from the political system are
not worth the costs of casting a ballot or otherwise
participating in the political process. Equally certain is
that public faith in the elections process and public
participation in that process have been affected by
campaign financing procedures.

FEC Chairman
Thomas B. Curtis

The picture, however, is not entirely bleak. The
people of this great country have addressed the
problem. Their representatives in Congress have re-
sponded by passing legislation substantially changing
the way Federal Elections are financed. Many provi-
sions have existed in the past but have often been ig-
nored. However, stricter enforcement can be expected.
Most of the requirements have their genesis in the ini-
tial reform measures which went into effect on April 7,
1972, and were strengthened by the 1974 Amendments
to the Federal Election Campaign Act. These amend-
ments for the first time in our history created a govern-
mental body to enforce and oversee Federal campaign
activity—the Federal Election Commission.

In this Commission the American people now
have, if you will, an “umpire.” All of us. understand
sports and what it means to play by “the rules of the
game.” We all want these rules to apply uniformly to all
“players.” We all expect each participant to comply
voluntarily with the rules that have been issued rather
than have the “whistle” blown on them.

We in the Commission are determined to do what
we can to restore public faith in elections by monitor-
ing the process by which campaigns are financed and
to apply the new rules fairly. We believe the American
people’s response to our efforts will be positive and
that more and more citizens of this country will partici-
pate in the elections process and do their part to keep
this Nation vital and free. We're here to help them in
any way we can!

Constitutionality, (cont'd from P. 1)

“The Court holds that Congress acted within its
power when it determined that providing public
financing for the Presidential selection process would
advance the general welfare of the Nation by reducing
the reliance of Presidential candidates on large
contributors, thus reducing their influence on the
outcome of elections and on the operation of
government.”

The plaintiffs argued that the law favors
incumbents by limiting the amount that can be spent
by a challenger, and restricts the First Amendment
tights of free expression by putting limits on the size of
contributions.

They said the FEC was illegal because it is respon-
sible to Congress which created it, rather than the
Executive branch as is the case with other Federal
Agencies.

The Court said some rulings of the FEC may be
subject to later challenges “since the Commission has

not yet exercised most of the challenged powers.”

In a statement on behalf of the Commission, Chair-
man Thomas B. Curtis remarked, “Il am pleased with
the results of the Court case. The decision implores an
understanding and sense of discipline on the part of
the Commission in having a concern about First
Amendment Rights.

“| welcome the admonition from the Courts.”

Vice-Chairman Neil Staebler also commented:
“The Federal Election Commission has been working
all summer to fully implement the election law and the
Commission’s responsibilities, and thus we are grati-
fied by the U.S. Court of Appeal’s decision upholding
the constitutionality of this important campaign fi-
nance law.

“The FEC will continue to develop regulations, and
provide even-handed and fair enforcement of the cam-
paign finance disclosure and the contribution and
expenditure limitations of the law.”

Advisory Opinions, (cont'd from P. 2)

expenditure and contribution limitations. Any commit-
tee which, under the bylaws of the Democratic Party or
State statutes, is a part of the State party structure is
included within the State party expenditure limitation.
The State central committee wil! be responsible for in-
suring that the expenditures of the entire party are
within legal restrictions, and any expenditure by a local
committee may be reported to the State central com-
mittee or to the Federal Election Commission under an
alternate “allocation” plan. If the local committees are

in fact truly independent of the State central commit-
tee, however, they are considered separate organiza-
tions for purposes of contribution limitations and may
make contributions up to the legal ceilings established
for committees. Each local committee will then file re-
ports of contributions with the Federal Election Com-
mission.

In addition, the Commission determined that a
Michigan Democratic Party newsletter is not creditable