November 1985

FEDERAL ELECTION COMMISSION

1325 K Street NW Washington DC 20463 Volume 11, Number 11

SUNSHINE ACT RULES PRESCRmED

On October 1, 1985, the Commission published in the Federal Register the final, revised

version of its Sunshine Act Regulations. See It

CPR Part 2. Approved by the Commission on

September 26, 1985, the rules of 11 CFR Parts 2

and 3 have been modified and consolidated into a

single part, called Part 2. See 50 Federal Register

39968. The revised rules:

o Provide a more complete statement about matters which may be discussed in closed meetings

(i.e., matters exempted from discussion in open

meetings);

o Clarify the procedures for closing meetings;

o Provide new procedures for processing requests

for transcripts and recordings of closed meeting

discussions; and

o Explain open meeting procedures more fully,

The Commission announced that the revised

Sunshine Act Regulations will become effective

on October 31, 30 days after their pub llcation in

the Federal Register. This 30-<1ay period will

allow FEC staff sufficient time to begin operating

under the revised rules.

The major revisions to the Sunshine Act rules

are highlighted below.

Exemptions from the Open

Meeting Requirement

The revised rules clarify the distinction between matters that may be exempted from open

meeting discussions under one of the discretionary

exemptions in the Sunshine Act and matters that

must be exempted under the confidentiality provision in the Federal Election Campaign Act

(FECA) or other relevant statutes. This distinction is important because, under the Sunshine

Act, the Commission has the power to waive a

discretionary exemption and discuss a matter in

public session. The confidentiality requirements

oC the FECA and other relevant statutes, however, may not be waived. This distinction also

affects the procedures for public disclosure of

information that no longer qualifies for the exemptions. See Transcripts and Recordings below.

In keeping with recent court decisions, the

revised rules exempt from public meetings any

discussions or materials that would reveal FEC

enforcement guidelines because such disclosure

would risk circu mvention of FEC rules.* The rules

exempt, for example, discussions of investigatory

techniques and audits, and documents (such as

staff compliance manuals) that reveal compliance

thresholds.

Procedures for Closing Meetings

The Commission has revised its procedures

for closing meetings. The agency has also added a

provision which allows parties to request that a

Com mission meeting be closed if their interests

are directly affected by a discussion. A requester

must: 1) submit a written request to the FEe's

chairman and 2) specify those exemptions (listed

under Il CFR 2.4) that would permit closing the

discussion. The Commission will then vote on the

request. A statement accompanying the revised

rules notes that this new procedure does not grant

a requester the right to compel the closing of a

meeting. Nor does the procedure entitle the requester to a hearing on the request or to otherwise participate in an FEC meeting.

Transcripts and Recordings

The revised rules explain more fully the

Commission's procedures for releasing transcripts

and recordings of closed meeting discussions, once

relevant disclosure exemptions no longer apply.

continued

, ·See especially the district court's ruling in

Funrl or a Conserwtive Ma'orit v. FEC, summarized on p, 3 0 the June 1985 Record.

TABLE OF CONTENTS

REGULATIONS

I Sunshine Act Rules Prescribed

2 FEDERAL REGJSTER NOTICES

2 ADVISORY OPINIONS

COURT CASES

4 FEC v. Kirk Walsh

for Congress Committee

4 New Litigation

INFORMATION

5 Campaign Finance Report

Filing Offices
Novemb3r 1985 FEDERAL ELECTION COMfVlISSION \tJlume 11, Numoo- 11

With regard to matters exempted under one of the

discretionary exemptions provided by the Sunshine

Act (11 CFR 2.4(b», the Commission will determine at the end of each closed session whether

the relevant exemption still applies. If the exemption can no longer be claimed, the Commission will review the transcript or tape to be sure

no other exemption applies. Once reviewed, the

materials will be made available to the public,

With regard to discussions of enforcement

matters and other materials that cannot be made

immediately available, the Commission will continue its past practice of reviewing material, on

request, and releasing those portions that are no

longer entitled to any exemption.

The rules have been slightly revised to indicate that closed session records will be retained

for a minimum of two years, or one year after the

conclusion of an enforcement matter, whichever

is later. This provision conforms with the Sunshine

Act's minimum requirement. In practice, however,

the Commission retains such documentation indefinitely for historical purposes.

Definitions and Miscellaneous

Provisions

The revised rules refine the definition of

"meeting" by explaining those circumstances that

would not constitute a "meeting" as, for example,

notation voting by the Comm issioners, (Notation

voting, used to expedite consideration of routine

matters, is a process whereby Commissioners note

their approval or disapproval of a given matter on

a memo circulated to all Commissioners.) Additionally, the rules make clear that the statements

made by Commissioners and staff at meetings

should not be construed as final FEC determinations or beliefs.

The revised rules explain that members of

the press who plan to use cameras or large

electronic recording equipment at FEC open sessions should notify the FEC's Press Officer in

advance. The purpose of this requirement is to

give the Press Officer an opportunity to coordinate news coverage under limited space eonditions,

FEDERAL REGISTER NOTICES

Copies of this notice are available in the

Public Records Office.

Notice Title

1985-11 11 CFR Parts 2 and 3: Sunshine Act

Regulatlonss Final Rules; Announcement

of Effective Date (50 Reg. 39968,

October 1, 1985)

ADVISORY OPINION REQUES'l'S

The following chart lists recent requests for

advisory opinions (AORs). The- full text of each

AOR is available to the public in the Commission's Office of Public Records.

AOR Subject

1985-30 Activities of authorized candidate committee converted to multicandidate

committee. (Date made public: September 17, 1985; Length: 1 page)

1985-31 Affiliation of insurance corporation and

agencies for purposes of PAC solicitations. (Date made pUblic: September 26,

1985; Length: 3 pages, plus 41-page supplement)

1985-32 Disclosure of costs for Congressional reception sponsored by two trade associations. (Date made public: October 9,

1985; Length: 1 page)

1985-33 Personal loans to candidate loaned to

candidate's committee. (Date made public: October 10, 1985; Length: 1 page)

1985-34 Nonconnected PAC's purchase and use of

life insurance policy on its chairman.

(Date made public: October 15, 1985;

Length: 2 pages)

The Record is published by the Pederal-Electlon Commission, 1325 K Street, N.W., Washington,

D.C. 20463. Commissioners are: John Warren McGarry, Chairman; Joan D. 'Aikens, Vice Chairman;

Lee Ann Elliott; Danny Lee McDonald; Thomas E. Harris; Thomas J. Josefiak; Jo-Anne L. Coe,

Secretary of the Senate, Ex Officio; Benjamin J. Guthrie, Clerk of the House of Representatives,

Ex Officio. For more information, call 202/523-406801' toll-free 800/424-9530.

2
Noverrta" 1985 FEDERAL ELECTION COMMISSION \bIume 11 ,NumOOr" 11

ADVISORY OPINIONS: SUMMARIES

An Advisory Opinion (AO) issued by the Commission provides guidance with regard to the

specific situation described in the AOR. Any

qualified person who has requested an AO and

acts in accordance with the opinion will not be

subject to any sanctions under the Act. Other

persons may rely on the opinion if they are

involved in a specific activity which is indistinguishable in all material aspects from the activity

discussed in the AO. Those seeking guidance for

their own activity, however, should consult the

full text of an AO and not rely only on the

sum mary given here.

AO 1985-24: Unincorporated Membership Organization Prohibited from Establishing

Separate Segregated Fund

The National Football League (NFL), an unincorporated, nonprofit membership organization consisting of 28 professional football teams, may not

use its treasury funds to establish, administer or

solicit contributions to a separate segregated fund

under 2 U.S.C. §44Ib(b)(2)(C). Since NFL may not

establish a separa te segrega ted fund (i.a., a political action committee or PAC), the Commission

did not address the issue of which personnel would

be solicitable by the proposed PAC. See 11 CFR

ll2.l(b).

Section 441b of the Act' prohibits corporations " (including incorporated membership organizations) from making contributions or expenditures in connection with federal elections. As an

exception to this broad prohibition, an incorporated organization may pay the costs of establishing and administering a separate segregated fund

which may, in turn, solicit voluntary contributions

from the corporation's solicitable class. See

2 U.S.C. §§44Ib(b)(2)(C) and 431(8)(B)(vl); 11 CFR

114.l(a)(2)(iil), 100.7(b)(10) and 100.8(b)(ll). However, as an unincorporated membership organization, the NFL is not eligible for this exception.

The different treatment that the election law

accords unincorporated and incorporated organizations was upheld by both the U.S. Appeals Court

for the Ninth Circuit and the Supreme Court in

California Medical Association v. FEC. 641 F.2d

619, 630 (9th Cir. 1980), aff'd, 453 U.S. 182

(I981). (Date issued: September 23, 1985; Length:

5 pages)

'Organizations covered by the prohibition

include: corporations with capital stoejc, national

banks, incorporated membership organizations,

corporations without capital stock, incorporated

trade associations, incorporated cooperatives and

labor organizations.

3

AO 1985-25: Reattribution of Excessive

Contributions to Spouse

In May 1985, the Steve Bartlett Congressional

Campaign Committee (the Committee), the principal campaign committee for Mr. Bartlett's

House campaign, held a picnic fundralser, Subsequently, some of the picnic ticket purchasers

made additional contributions to the Committee

Which, when added to their ticket purchases,

caused them to exceed their respective $1,000 per

election limits. As an alternative to refunding the

excessive portion of a donor's contributions, the

Committee may reattribute the excessive amount

to a donor's spouse, provided the requirements

outlined below are met.

Proposed Beattrjbutlon Procedure

Under the Committee's proposal, the Committee will send a letter and contribution reattributton form to any married individual who made

excessive contributions to Mr. Bartlett's campaign

and who did not attribute any portion of his/her

contributions to a spouse. The letter will itemize

the contributions and inform the donor of: I) the

election law's contribution limits and 2) the

donor's option to attribute the excessive portion

of the contributions to his/her spouse's contribution limit. The contribution reattribution form,

which must be returned to the committee, will

include: each spouse's signature and information

on the contribution (date, amount and election).

Reattribution Requirements

Under FEC Regulatlons, a husband and wife

may each contribute up to $1,000 to the same

candidate for the same election, even if they are

a single-income family. If, however, they make a

joint contribution by a single check, each spouse

must sign the check or an accompanying statement specifying the amount to be attributed to

each one. II CFR II 0.1(1)(1) and 100.7(a).

The Committee's proposed letter and reattrlbution form meet these requirements. However,

to ensure that the reattribution procedure does

not circumvent the Act's contribution limits, the

Committee must also fulfill the following conditions:

o Before mailing the letter and form, the Committee should have a reasonable basis for coneluding that the contributions were made by a

married individual.

o The Committee may seek a reattribution only if

the aggregate contributions made by husband

and wife do not exceed $2,000 per election.

o The Committee must revise the letter to inform the contributor that he or she may request

a refund of the excessive amount rather than

reattribute it to a spouse.

o If a contributor and his/her spouse do not send

back a signed form authorizing the reattribucontinued
Novemb9r 1985 FEDERAL ELECTIOI\J COMMISSION \blume 11, Numter11

tion, the Committee must refund the excessive

portion of a contribution within 30 days of its

receipt.

o If the contributor requests a refund, the Committee must make it promptly, i.e., within 10

days.

o The Committee must keep written, up-to-date

records on relevant details of Committee requests for reattributtons and the disposition of

each.

o The Committee must report all deposits and

refunds of the excessive contributions. 2 U.S.C.

§434(b); 11 CFR 103.3(b)(2).

(Date issued: September 30, 1985; Length: 4

pages)

FECv. KIRK WALSH FOR CONGRESS

COMMITrEE

On September 20, 1985, the U.S. District

Court for the Eastern District of Michigan, Southern Division, issued an opinion which held the Kirk

Walsh for Congress Committee (the Committee)

and its treasurer, Kirk Walsh, in contempt for

failing to comply with a default judgment entered

against the Committee in April 1985. «nvu Action No. 84-9802)

In the April 1985 default judgment, the court

had ordered the Committee, Mr. Walsh's principal

campaign committee for his 1980 House campaign, to take the following actions within 30

days:

o File a 30 day post-general election report for

1980 and mid-year and year-end reports for

1981, 1982 and 1983;

o Pay a $5,000 civil penalty to the U.S. Treasury;

and

o Pay court costs incurred by the FEe in pursuing

the action.

In its contempt order, the court ordered the

Committee and Mr. Walsh to comply with the

default judgment by October 11, 1985. In the

event the Committee failed to meet the deadline,

the court would assess a fine of $2,000 and $100

per day until the Committee fully complied with

the court's orders. (As of October 11, 1985, the

respondents had not complied with the court's order.)

The court also ordered the Committee and

Mr. Walsh to pay costs and attorney fees incurred

by the Commission in bringing this action.

4

NEW LITIGATION

FEC v. NCPAC (Seeond Suit)

The FEC filed suit against the National Conservative Political Action Committee (NCPAC), a

noneonnected political committee, and its treasurer, Leif E. Noren, with regard to independent

expenditures NCPAC made to advocate President

Reagan's reelection in 1984. As part of its independent expenditure activities conducted between

April and July 1984, NCPAC mailed solicitation

materials to approximately 955,750 persons.

The FEC asks the district court to:

o Declare that defendants violated 2 U.S.C.

§441d(a)(3) by failing to include on the solicitation materials a statement clearly identifying

NCPAC as the sponsor of the solicitation mailings;

o Assess a civil penalty against defendants

amounting to the greater of $5,000 or an

amount equal to 100 percent of the amount

involved in the violation (approximately

$373,000); and

o Permanently enjoin defendants from further

violations of the election law.

U.S. District Court for the District of Columbia, Civil Action No. 85-2898, September 12,

1985.

FEC v. John A. Dramesi for Congress

The FEC asks the district court to declare

that Mr. Dramesi's 1982 House campaign, John A.

Dramesi for Congress Committee (the Committee), and its treasurer, Russel E. Paul, violated

the election law by accepting an excessive contribution from the New Jersey Republican State

Comm ittee and by failing to refund the excessive

portion of the contribution (l.e., $4,000) to the

state party cornm ittee. See 2 U.S.C. §441a(f); 11

CFR 103.3(b)(l) and (2). At the time the state

party committee made the $5,000 contribution, it

had not achieved multicandidate committee status and was, therefore, only eligible to make a

$1,000 contribution to the Committee.*

The FEC further asks the court to:

o Assess a $5,000 civil penalty against the Committee or an amount equal to 100 percent of

the amounts involved in the violation; and

o Order the Committee and its treasurer to refund the excessive portion of the contribution

to the state party com mittee.

U.S. District Court for the District of New

Jersey, Civil Action No. 85-4039, August 19,

1985.

"Multicandidate committees may contribute

up to $5,000 per election to a candidate's authorized committee(s). To achieve multicandidate

committee status, a state party committee must

have more than 50 contributors and have been

registered for at least six months. 2 U.S.C.

441a(a)(4); 11 CFR 100.5(e)(3).
Novemrer 1985 FEDERAL ELECTION COMMISSION Volume 11, Numrer11

Copies of federal campaign finance reports may be reviewed and copied by the public at the

locations listed below. Note that the federal election law places restrictions on the use of information

copied from campaign finance reports and statements. They "may not be sold, or used by any person for

the purpose of soliciting contributions or for commercial purposes, other than using the name and address

of any political committee to solicit contributions from such committees," 2 U.S.C. §438(a)(4).

FEDERAL RECORDS OFFICES

ALL REPORTS

Public Records Office

Federal Election Commission

toll free BOO/424-9530 $.05-.15/pg.

ALABAMA(FEC Computer Access)

Elections Division

Office of the Secretary of State

Room 103, Capitol BUilding

Montgomery, AL 36130

205/261-3124 $1.50/pg.

ALASKA

Office of the Lt. Governor

State Capitol, Room 313

Juneau, AK 99B II

907/465-3520 $.25/pg.

Mailing address:

State of Alaska, Pouch AA

Juneau, AK 99811

ARIZONA

Office of the Secretary of State

State Capitol, West Wing, 7th Floor

1700 West Washington

Phoenix, AZ 85007

602/255-8683· $.50/pg.

ARKANSAS

Elections Division

Office of the Secretary of State

State Capitol BUilding, Room 026

Little Rock, AR 72201

501/371-5070 $.50/pg.

CALIFORNIA (FEC Computer Access)

Political Reform Division

Office of the Secretary of State

1230 J Street, Room 219

Sacramento, CA 95814

916/322-4880 $.30/pg.

Mailing address:

P.O. Box 1467

Sacramento, CA 95807

FEC Computer Access Only

Corporations Office

Office of the Secretary of State

Room 4001

107 Broadway

Los Angeles, CA 90012

213/620-3104

n.s, SENATE REPORTS

Office of Public Records

Oftice of the Secretary of the Senate

Hart Senate Office Bldg., Room 232

Washington, D.C. 20510

202/224-0322 $.IO/pg.

STATE RECORDS OFFICES

COLORADO (FEC Computer Access)

Elections Division

Office of the Secretary of State

1560 Broadway, Suite 200

Denver, CO 80202

303/B66-2041 $.50/pg.

CONNECTICUT

Elections Division

Office of the Secretary of State

30 Trinity Street, Room 114

Hartford, CT 06106

203/566-3059 $.10/pg.

DELAWARE

Office of the Secretary of State

Townsend Building

Dover, DE 1990I

302/736-4111 $.125/pg.

Mailing address:

~.O. Box 1401

Dover, DE 19901

DISTRICT OF COLUMBIA

Office of Campaign Finance

Landsburg Building, Room 340

420 7th si., N. W.

Washington, D.C. 20004

202/727 -2410 $. 10-. 15/pg.

FLORIDA

Division of Elections

Office of the Secretary of State

The Capitol, ROom 180I

Tallahassee, FL 3230 I

904/488-7690 $.IO/pg.

GEORGIA (FEC Computer Access)

Elections Division

Office of the Secretary of State

State Capitol, Room 110

Atlanta, GA 30334

404/656-2871 1st copy free

2nd+$.25/pg.

5

U.S. HOUSE OF REPRESENTA11VHS

REPORTS

Office of Records and Registration

Office of the Clerk of the House

Longworth House Office Bldg., Rm. 1036

Washington, D.C. 20515

202/225-1300 $.lO/pg.

HAWAU

Campaign Spending Commission

State CapitOl, Rm. 008

Honolulu, HI 96809

808/548-5411 $.25/pg.

Mailing address:

P.O. Box 501

Honolulu, HI 96809

IDAHO

Elections Division

Office of the Secretary of State

205 State House

Boise, lD 83720

208/334-2852 $.25/pg.

ILLINOIS (FEC Computer Access)

Sta te Board of Elec tions

1020 South Spring Street

Springfield, IL 62704

217/782-4141 $.50/pg.

Mailing address:

P.O. Box 4187

Springfield, IL 62708

State Board of Elections

Suite 14-100

100 West Randolph Street

Chicago, IL 60601

312/917~440

INDIANA

Office of the Secretary of State

State House, Room 20I

Indianapolis, IN 46204

317/232~531 $.15/pg.

IOWA

Campaign Finance Disclosure

Commission

507 10th Street, 5til Floor

Des Moines, IA 50309

515/281-4411 $.IO/pg.
Navemre- 1985 FEDERAL ELECTION COMMISSION \bIume 11, Numre- 11

KANSAS

Office of the Secretary of State

State House, Room 234 North

Topeka, KS 66612

913/296-2236 $.25/pg.

KENTUCKY

Registry of Election Finance

1604 Louisville Road

Frankfort, KY 4060I

502/564-2226 $.IO/pg.

LOUISIANA

Elections Division

Office of the Secretary of State

7051 Florida Boulevard

Baton Rouge, LA 70816

504/922-0415 $.IO/pg.

Mailing address:

P.O. Box 94125

Baton Rouge, LA 70804-9125

"MAIllE

Bureau of Elections

Office of the Secretary of State

State Office Building, Room 221

Augusta, ME 04333

207/289-350 I $.10-.20/pg.

Mailing address:

Bureau of Elections

Station 101

Augusta, Maine 04333

MARYLAND

State Administrative Board

of Election Laws

11 Bladen Street

Annapolis, MD 21404-0231

301/269-3711 $.10/pg.

Mailing address:

P.O. Box 231

Annapolis, MD 21404-0231

MASSACHUSET1'S (FEC Computer Aeeess)

Division of Public Records

Office of the Secretary of State

1701 McCormack Building

One Ashburton Place

Boston, MA 02108

617/727-2832 $.20/pg.

MICRIGAN (FEC Computer Access)

Elections Division

Office of the Secretary of State

4th Floor, Mutual Bldg.

208 N. Capitol Avenue

Lansing, MI48918

517/373-2540 $.16/pg.

Mailing address:

P.O. Box 20126

Lansing, MI48901

MINNESOTA

Elections Division

Office of the Secretary of State

180 State Office Building

St. Paul, MN 55155

612/296-2805 $.25/pg.

MISSISSIPPI

Office of the Secretary of State

401 Mississippi Street, Room 223

Jackson, MS 39201

601/359-1350 $.30-.60/pg.

Mailing address:

P.O. Box 136

Jackson, MS 39205

MISSOURI

Division of Campaign Reporting

Office of the Secretary of State

Truman Office Building, 8th Floor

Jefferson City, MO 65102

314/751-3077 $.15-.50/pgs.

Mailing address:

P.O. Box 1370

Jefferson City, MO 65102

MONTANA

Office of Political Practices

1205 8th Avenue

Helena, MT 59620

406/444-2942 $.10/pg.

NEBRASKA

Office of the Secretary of State

State Capitol, Suite 2300

Lincoln, NE 68509

402/471-2554 $1.00/pg.

NEVADA

Office of the Secretary of State

Capitol Complex

Carson City, NV 89710

702/885-5203 $.50/pg.

NEW HAMPSHIRE

Office of the Secretary of State

State House, Room 204

Concord, NH 03301

603/271-3242 $.15/pg.

NEW,JERSEY

Elections Division

Department of State

107 West State Street

Trenton, NJ 08625-0304

609/292-3760 $.10-.50/pg.

FEC Computer Aeeess Only

New Jersey Election Law

Enforcement Commission

28 State Street, Suite 1215

Trenton, NJ 08625-0185

609/292-8700

NEW MEXICO

Office of the Secretary of State

Room 400

Executive-Legislative Building

Sante Fe, NM 87503

505/827-3620 $.10/pg.

NEW YORK

State Board of Elections

One Commeree Plaza, 18th Floor

Albany, NY 12260

518/474-8200 $.10/pg.

Mailing address:

P.O. Box 4

Albany, NY 12260

6

NORTH CAROlJNA

Campaign Reporting Office

State Board of Elections

Raleigh Building, Rm, 809

5 West Hargett Street

Raleigh, NC 27601

919/733-2186 $.25/pg.

Mailing address:

P.O. Box 1934

Raleigh, NC 27602

NORTH DAKOTA

Office of the Secretary of State

State Capitol, First Floor .

Bismarck, ND 58505

701/224-2900 $.25/pg.

ORIO

Office of the Secretary of State

30 East Broad Street, 14th Floor

Columbus, OH 43266-0418

614/466-2585 $.10-1.00/pg.

OKLAHOMA

Office of the Secretary of State

101 State Capitol

Oklahoma City, OK 73105

405/521-3911 $l.OO/pg.

OREGON

Elections Division

Office of the Secretary of State

141 State Capitol

Salem, OR 97310

503/378-4144 $.15/pg.

PENNSYLVANIA

Bureau of Commissions,

Elections &: Legislation

305 North Office Building

Harrisburg, PA 17120

717/787-5280 $.10/pg.

RHODE ISLAND (FEC Computer Access)

Elections Division

Office of the Secretary of State

State House, Room 218

Providence, RI02903

401/277-2340 $.15/pg.

SOUTH CAROLINA

State Election Commission

2221 Devine Street, Room 105

Columbia, SC 29205

803/758-2571 $.25/pg.

Mailing address:

P.O. Box 5987

Columbia, SC 29250

SOUTH DAKOTA

Office of the Secretary of State

State Capitol Building, 2nd Floor

500 East Capitol

Pierre, SD 57501-5077

605/773-3537 $.50/pg.

TENNESSEE

State Library &: Archives

403 7th Avenue North, Room 200

Nashville, TN 37219

615/741-1075 $.15/pg.
Novernter 1985 FEDERAL ELECTION COMMISSION \bIume 11 ,Numter11

TEXAS

Disclosure Filing Division

Office of the Secretary of State

State Capitol, Room 127

Austin, TX 78711

512/475-5619 $.15-.55/pg.

Mailing address:

P.O. Box 12697

Austin, TX 78711

UTAH

Office of the Lieutenant Governor

State Capitol Building, Room 203

Salt Lake City, UT 84114

801/533-5111 $.35/pg.

CHANGE OF ADDRESS

VERMONT

Office of the Secretary of State

Redstone Building

26 Terrace Street

Montpelier, VT 05602

802/828-2363 $.10/pg.

VIRGINIA

State Board of Elections

101 Ninth Street Office Building

Richmond, VA 23219

804/786-6551 $.25/pg.

WASHINGTON (PEC Computer Access)

Public Disclosure Commission

403 Evergreen Plaza

Olympia, WA 98504

206/753-1111 $.10-.25/pg.

WEST VIRGINIA

Office of the Secretary of State

State Capitol, Room 157-K

Charleston, WV 25305

304/345-4000 $.75-1.00/pg.

WISCONSIN

State Elections Board

132 East Wilson Street, 3rd Floor

Madison, WI 53702

608/266-8005 $.15-.20/pg.

WYOMING

Elections Division

Office of the Secretary of State

Capitol Building, Room 106

Cheyenne, WY 82002-0020

307/777-7378 $.15-.50/pg.

Political Committees

Registered political committees are automatically sent the Record. Any change of address by

a registered committee must, by law, be made in writing as an amendment to FEC Form 1

(Statement of Organization) and filed with the Clerk of the House, the Secretary of the Senate, Or

the FEC, as appropriate.

Other Subseribers

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

address, are asked to provide the following information:

1. Name of person to whom the Record is sent.

2. Old address.

3. New address.

4. Subscription number. The subscription number is located in the upper left hand corner of the

mailing label. It consists of three letters and five numbers. Without this number, there is no

guarantee that your subscription can be located on the computer.

7
Novemffir 1985 FEDERAL ELECTION COMMISSION \6lume 11, Numter 11

This cumulative index lists advisory opinions, court cases and 800

Line articles published in the Record

during 1985. The first number in the

citation refers to the "number"

(month) of the Record issue; the second number, following the colon, indicates the page number in that

issue.

OPINIONS

1984-16: One Limit for Convention &.

Primary, 1:3

1984-33: Fundraiser by Trade Association's Allied Members, 1:3

1984-41: Corporate Payments for

Media Ads, 2:1

1984-48: Travel Reimbursements to

State by Senate Campaign, 2:1

1984-52: Refund of lllegal Contributions, 1:4

1984-53: Real Estate Lessors as Federal Contractors, 1:4

1984-54: Reporting/Limits for Candidate Elected in Primary, 1:5

1984-55: Solicitation of Law Firm's

Partners by Bank PAC, 1:5

1984-56: Book Payments &. Honorarium, 1:5

1984-57: Corporate Com munieations on Legislation, 2:2

1984-58: City's Claim for Reimbursement by Presidential Campaign,

2:3

1984-59: Noncampaign Uses of Campaign Assets, 2:3

1984-60: Campaign Debts Liquidated

through Sale of Real Estate Assets,

3:1

1984-61: Trade Association Solicitation Approvals, 3:2

1984-62: Campaign Firm's Slate Mail

Program, 5:4

1984-63: Savings and Loan Association's Solicitations, 3:2

1985-1: Liquidation of Campaign

Assets, 4:4

1985-2: State Funds Transferred to

Congressional Campaign, 4:5

1985-3: Contributions to State Campaign by Sllbsidiary of Foreign Corporation, 4:5

1985-4: Payments not Honorarium,

4:5

1985-5: Contributions Made Before

but Received After Election, 4:6

1985-6: Affiliated PACs of Local!

International Unions, 4:6

1985-7: Solicitation of Wholesalers'

Personnel, 5:4

1985-8: Fundraising to Refund Illegal

Contributions, 5:5

1985-9: Excess Funds for University

Programs, 5:5

1985-10: Campaign Loan Liquidated

by Candidate's Estate, 5:5

1985-11: Trade Association's NonsoIlcltable Members, 6:4

1985-12: Trade Association's Collecting Agents, 6:5

1985-13: Transfers to Successor Candidate's Campaign, 7:5

1985-14: National Party Committee's

Media Program, 7:6

1985-16: Prohibited Use of FEC Contributor Information, 7:6

1985-17: Congressional Scholarship

Trust, 8:3

1985-18: Conversion to Federal PAC,

9:1

1985-19: Purchase of Computer System by Committee and Corporation, 10:3

1985-22: Excess Funds Used for

Evening-Attire, 10:3 .

1985-23: PAC Established by Corporation Owned by Partnership with

Federal Contract, 10:4

800 LlHE

Foreign Nationals, 5:8

State and Local Party Activities, 8:4

Supreme Court Rules on 26 U.S.C.

S9012(f), 4: 1

Using Excess Campaign Funds, 2:4

COURT CASES

Antosh v, FEC, 2:4

Citizens for Percy '84 v. FEC, 1:6

DCCC v. FEC, 2:6

FCM v, FEC, 6:3

FEC v. Anderson, 2:6; 8:8

FEC v, Committee to Return Stack

to Congress, 8:7

FEC v. Furgatch; FEC v, Dominelli,

1:6

FEC v, Gus Savage for Congress '8~,

6:3

FEC v, Hemenway for Congress

Committee. 2:6

FEC v, Liberal Party Federal Campaign Committee, 3:3

FEC v, Massachusetts Citizens for

Life, Ine., 10:7

FEC v, NCPAC, 5:6

FEC v, NRWC; NRWC v. FEC, 1:7

FEC v. Kirk Walsh for Congress

Committee, 6:3

Alwin Hopfmann v, FEC, 7:7; 9:3

LaRouche v, State Board of Elections, 8:7

Maine Right to Life Committee v;

FEC, 10:9

National Congressional Club and Jefferson Marketing, Inc. v; FEC, 3:3

NCPAC v, FEC, 10:9

Orloski v, FEC, 2:5

Sierra Club v, FEC. 9:3

FEDERAL ELECTION COMMISSION

1325 K Street, N.W.

Washington, D.C. 20463

Official Business

Bulk Rate Mail

Postage and Fees Paid

Federal Election Commission

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