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THE FEDERAL ELECTION 

COMMISSION 

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

Volume 3, Number 7 

SECOND QUARTER REPORT 

Any candidate for Federal office (who has not qualified 

for a waiver) and any one of his or her authorized committees must file a quarterly report by July 10, 1977, if the 

candidate alone, or all the authorized committees collectively, or the candidate and the committees together received contributions and/or made expenditures totaling more 

than $5,000 between April 1 and June 30, 1977. If a candi· 

date's principal campaign committee exceeded the reporting threshold during the quarter, all the authorized commit· 

tees of that candidate must file Form 3 (not 3a) with the 

principal campaign committee, regardless of how much 

they raised or spent. (See Campaign Guide for Committees, 

p. 1.16.) Noncampaign-related disbursements do not, in 

themselves, trigger registration requirements nor count 

against the reporting threshold. 

All other political committees must file the quarterly report 

if either contributions or expenditures exceeded $1,000 

during the quarter. Quarterly reports must be filed on FEC 

Form 3 or, sometimes in the case of principal campaign 

committees, on FEC Form 6 (short form). If the candidate 

or committee is exempt from filing a report because campaign financial activity did not exceed the reporting threshold, the candidate or committee must nevertheless file 

FEC Form 3a (postcard form), or a letter with the same 

information, at the end of the first quarter in which the 

exemption applies. 

Candidates who have satisfied the Act's requirements for a 

personal reporting waiver and who have previously requested such a waiver from the Commission, with regard to their 

candidacy in the 1976 election, need not file a July 10 candidate report, nor any other reports in 1977. 

SPECIAL ELECTION 

A special election has been scheduled to fill the First 

Congressional District seat in Louisiana, left vacant by 

Congressman Richard Tonry. The special election dates 

are: 

Primary · June 25, 1977 

Runoff · July 30, 1977 

General · August 27, 1977 

July 1977 

For these and future special elections, the FEC Information 

Office will inform candidates, by mail and telephone, of 

their registration and reporting requirements and provide 

them with necessary forms. 

ADVISORY OPINIONS: SUMMARIES 

With the official promulgation of FEC regulations on 

April 13, the Commission discontinued the practice of 

issuing "Re: AOR's." All responses to requests for advisory 

opinions will be issued in the form of Advisory Opinions. 

Designated as AO's, Advisory Opinions concern the application of the Act to specific factual situations. Any person 

requesting an advisory opinion who is good faith acts in 

accordance with the findings of the opinion will not be 

penalized under the Act. The opinion may also be relied 

upon by any other person involved in a specific transaction 

which is indistinguishable in all material aspects from the 

activity discussed in the advisory opinion. 

Re: AOR 1977·8: Joint Fundraising by 

Federal Candidates 

The Sasser for Senate Committee may accept its agreed pro 

rata share of the net proceeds from a joint fundraising event 

held in conjunction with the Rowland for Congress Com· 

mittee, provided reporting requirements and contribution 

limits are observed. This opinion is based on the fact that 

the committees had entered into an agreement before the 

event and both candidates appeared at the event. The pro. 

rata share of each contribution, based on the gross amount 

of the ticket purchase price, may be accepted only to the 

extent the amount, when aggregated with previous contributions to candidate Sasser by the same donor, does not 

exceed the contribution limitations. 

(Continued) 
The total pro rata proceeds should be reported by the 

Sasser Committee as a transfer from the Rowland Committee provided all receipts are reported by the Rowland Committee. In addition, the Sasser Committee must itemize its 

pro rata share ·of all contributions from political committees and its pro rata share of any individual contribution 

which, when added to previous contributions to the Sasser 

Committee from the same donor, exceeds $100. (Length: 

5 pages) 

AO 1977-17: Definition of Membership 

of a Membership Organization 

Commodity representatives of the Chicago Mercantile 

Exchange (the Exchange), a nonprofit membership organization, are not (for purposes of the Federal Election Campaign Act, as amended) considered "members" of the 

Exchange since they do not have the same status within the 

Exchange as that enjoyed by full members. For example, 

commodity representatives may not trade, vote or serve as 

officers of the Exchange. Consequently, the Commodity 

Futures Political Fund, a political action committee established by the Exchange, may not solicit voluntary contributions from the commodity representatives. (Length: 

2 pages) 

AO 1977-19: Taxes on Interest Earned 

Texaco may not use treasury funds to pay taxes on the 

interest income earned on unused contributions which were 

placed by Texaco's separate segregated fund (Texaco Employees Political Involvement Committee) in an interestbearing account. The tax obligation is not considered an 

"administrative" cost because it was not incurred in the 

establishment of, the administration of, or the solicitation 

of contributions to the separate segregated fund. Rather, 

the tax was the result of the production of income to the 

separate segregated fund. (Length: 2 pages) 

AO 1977-20: Joint Fundraising by Federal 

and Non-Federal Committees 

The National Association of Realtors Political Action Committee (RPAC), established by the National Association of 

Realtors (a trade association) to support Federal candidates, may follow procedures it proposed to the FEC for 

receiving and allocating funds donated for both Federal 

and non-Federal elections. Under the proposed procedures, 

funds would be collected jointly by RPAC and State political action committees which are established by State 

associations of realtors which, in turn, are affiliated with 

the National Association of Realtors. These funds would 

be deposited in a special account established in a bank 

which would have escrow instructions directing the bank to 

allocate the contributions between the State political action 

committees and RPAC on a 60-40 percent basis. Contributors would be fully advised of the allocation ratio and, 

according to the proposed plan, RPAC would report to the 

FEC the names of contributors and the amount of contributions (40 percent of the total contributions). Commission approval of this proposal was conditioned on RPAC's 

complying with the following additional requirements of 

the Act: 

-- The solicitation materials must also inform the contributor that the Federal portion of the contribution is 

charged against applicable contribution limitations of 

the Act. 

-- The special -bank accounts must be designated on 

RPAC's Statement Of Organization as campaign depositories. 

-- All joint contributions deposited into the special 

accounts including the portion intended for the State 

committees must be otherwise lawful under the Act. 

Contributions from national banks, corporations, labor 

organizations, Government contractors and foreign 

nationals are prohibited altogether. Joint contributions 

would be subject to contribution limitations only to the 

extent of RPAC's 40 percent share of the contribution. 

-- Contributions are deemed "received" by RPAC at the 

time they are delivered to the treasurer of RPAC or the 

RPAC representative functioning in each State (i.e., the 

bank), rather than when RPAC receives a bank transfer 

from a State escrow account. The State RPAC representative must supply RPAC with all information necessary 

to comply with its recordkeeping and reporting obligations under the Act. (Length: 5 pages) 

AO 1977-21: Transfers Between Affiliated Committees 

Realtors Political Action Committee and the California 

Realtors Political Action Committee/Federal are two affiliated. political action committees {connected to two trade 

associations, the National Association of Realtors and the 

California Association of Realtors, respectively)_ Therefore, 

both committees are regarded as a "single political committee" for purposes of applying the Act's contribution limits 

to their contributions to Federal candidates and other political committees. Transfers of funds between them, however, are considered intracommittee transactions and not, 

therefore, subject to contribution limits. Nevertheless, the 

two affiliated committees must each file separate reports 

which reflect, among other transactions, transfers made and 

transfers received. (Length: 2 pages) 

AO 1977-22: Fundraising Concert 

In connection with a fundraising concert, the Democratic 

Congressional Campaign Committee (the Committee) may 

rent amphitheater facilities from Universal City Studios, 

Inc. (a corporation) for a fee of $5,000 if this fee is the normal and usual rental charge for the use of equivalent facili-

The RECORD is published by the Federal Election Commission, 1325 K Street, N.W., Washington, D.C. 20463. 

Commissioners are: Vernon W. Thomson, Chairman; Thomas E. Harris, Vice Chairman; Joan D. Aikens; William L. 

Springer; Neil Staebler; Robert 0. Tiernan; Francis R. Valeo, Secretary of the Senate, Ex Officio; Edmund L. Henshaw, 

Jr., Clerk of the House of Representatives, Ex Officio. 

For more information, call 382-4733 or toll free 800-424-9530. 

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ties at the time the event is held. With regard to record keeping and reporting, the full amount of a ticket purchase is 

regarded as a contribution. Recordkeeping requirements 

are triggered if the total amount paid for any number of 

tickets purchased by the same individual exceeds $50. 

The Committee must report total proceeds and must 

itemize any ticket purchase which exceeds $100 (in a 

calendar year) when combined with other contributions 

from the same person. (Length: 3 pages) 

PUBLIC COMMENT REQUESTED 

On May 26, 1977, the Federal Election Commission 

published a notice in the Federal Register, inviting public 

comment on a proposed regulation concerning how a corporation meets its obligation to make its political solicita· 

tion methods available to a labor organization. (42 FR 

26990.) The notice opened a period of 30 days during 

which the Commission welcomed written comments "in the 

form of suggested language" for a proposed regulation. 

Under existing FEC regulations, any corporation which 

raises funds for its "political action committee" by soliciting voluntary contributions from its executive and administrative personnel and stockholders must, upon request, 

make the same solicitation method available to a labor 

organization representing the corporation's employees. 

FEC regulations identify. as examples, several methods of 

political solicitation, including payroll deduction or "checkoff" plans, computer mailing services and the use of corporate meeting rooms to explain voluntary giving. 

The May 26 n·otice asked for comment on the following 

issues: 

1. To what extent is a corporation required to make its 

solicitation plan available to a labor organization (representing the corporation's employees) after the corporation stops utilizing the plan, if the union's request was 

initially made while the plan was still in use? 

2. To what extent must a corporation make its solicitation 

plan available to the labor organization if the union's 

request was initially made after the corporation stopped 

utilizing the plan? 

3. Is a parent corporation required to make its solicitation 

plan available to a labor organization representing employees of one of its subsidiaries if the parent corporation solicits the executive and administrative personnel 

of another subsidiary corporation which does not employ any members of this labor organization? 

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NATIONAL RIGHT TO WORK COMMITTEE 

v. VERNON W. THOMSON et al. 

On May 17, 1977, the National Right to Work Commit· 

tee (the Committee) filed in the U.S. District Court for the 

District of Columbia a suit for declaratory and injunctive 

relief against the Federal Election Commission. The Committee argues that the Commission failed to take action on 

two complaints which the Committee had previously filed 

with the FEC against the AFL-CIO and its Committee on 

Political Education (COPE). In these complaints, filed on 

December 20, 1976, and January 28, 1977, the Commit· 

tee alleged that: 

1. The AFL·CIO and COPE made massive in·kind contribu· 

tions to the Carter Presidential campaign which were not 

reported, which exceeded the contribution limits of the 

Act and, in some cases, which violated the Act's prohibi· 

tions against expenditures by labor unions. 

2. The AFL-CIO and COPEengaged in "highly partisan and 

hence illegal registration and get·out·the·vote drives in· 

volving the expenditure ... of union treasury funds .... " 

3. COPE transferred to its Political Contributions Commit· 

tee funds which it had received from the AF L-CIO 

treasury. 

4. Either the AFL-CIO used "compulsory union funds" to 

communicate with and register to vote non-union members or the COPE Political Contributions Committee 

violated the Act's contribution limits. 

Contending that the Commission failed to act on these 

complaints within 90 days after the complaints were filed, 

as required under the Act, the Committee asked the Court 

for a mandatory injunction directing the FEC to take 

action on the two complaints. 

RAMSEY CLARK et al. v. J.S. KIMMITTet al. 

(Part Ill) 

In a brief order issued on June 6, 1977, the Supreme 

Court of the United States affirmed a lower court decision 

which dismissed a suit challenging Congress' power to exercise a single-House veto over proposed FEC regulations. The 

U.S. Court of Appeals had dismissed the case brought by 

Ramsey Clark, former Senate candidate in New York, on 

grounds that: 

-- Clark, no longer a candidate when the decision was 

handed down, had no "ripe injury" nor personal stake in 

the matter; 

·· Clark had failed to identify any specific action or regula· 

tion tainted by the threat of a congressional veto; and 

-- The case was "unripe" for adjudication since Congress 

had not yet disapproved a proposed regulation . 

(See the March Record, pp. 5·6, for a summary of the 

Court of Appeals' decision; and the June Record, p. 4, for a 

summary of subsequent action in the case.) 
TWO SUITS CHARGE FEC WITH FAILURE 

TO ACT ON COMPLAINT (Part II) 

NATIONAL RIGHT TO WORK COMMITTEE 

v. VERNON W. THOMSON et al. (Part II) 

In a motion filed in U.S. District Court for the District 

of Columbia on May 13. 1977, the Federal Election Com· 

mission moved to dismiss a complaint brought by the 

National Right to Work Committee (the Committee) 

against the Com'mission. The Court complaint challenged 

the FEC's failure to act within 90 days on a complaint the 

Committee had filed with the Commission, alleging viola· 

tions of the Act by the National Education Association. 

(For a summary of that complaint, see June Record, p. 3.) 

The Federal Election Commission argues that the Court 

lacks subject matter jurisdiction over the plaintiff's claims 

since "except as provided in Section 437g(a)(9), the power 

of the Commission to initiate _civil actions ... shall be the 

exclusive remedy for the enforcement of the provisions of 

this Act." In the Commission's view, the exception provided for in Section 437g(a)(9) (i.e., when the Commission 

fails to act or when it dismisses a complaint contrary to 

law) does not apply since the Commission has acted upon 

the complaint and has entered upon a conciliation attempt. 

On May 23, 1977, the plaintiff filed its opposition to the 

Commission's motion and asked the Court for a summary 

judgment. 

PAUL E. CHAMBERLAIN et al. 

v. VERNON W. THOMSON et al. (Part II) 

On May 16, 1977, the FEC filed a motion in the U.S. 

District Court for the District of Columbia, asking the 

Court to dismiss the complaint brought by Paul E. Chamberlain against the FEC. The Court complaint challenged 

the Commission's failure to act within 90 days on a complaint filed by Chamberlain with the Commission, alleging 

violations of the Act by several educational associations. 

(For a summary of that complaint, see June Record, p. 3.) 

The Commission again maintains that the Court lacks 

subject matter jurisdiction over the plaintiffs' claims, citing 

the same arguments given in the FEC's motion to dismiss 

the complaint brought by the National Right to Work Com· 

mittee against the Commission. (See above.) In papers filed 

on May 26, 1977, plaintiffs opposed the FEC's motion and 

moved for a summary judgment. 

BREAD POLITICAL ACTION COMMITTEE et al. 

v, FEC et al. (Part II) 

On June 6, 1977, in the U.S. District Court for the 

Northern District of Illinois, the Federal Election Commis· 

sian filed a motion to dismiss a suit brought against the 

Commission by Bread PAC et al. (two trade associations 

and three political action committees}. The suit challenges 

certain provisions of the Act governing solicitations by 

trade associations for voluntary contributions to their political action committees. (See June Record, p. 4, for a summary of Bread PAC's complaint.) Asking the Court to dis· 

miss the case, the FEC argued the Court lacked jurisdiction 

because: 

-- The standing, as plaintiff, to initiate a suit seeking review 

of the constitutionality of the Act is statutorily granted 

only to the Commission, national political parties and 

voters -- but not to trade associations. 

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-- Plaintiffs' action, lacking any factual context, is " ... not 

a case or a controversy." The Commission " .•. has invoked no authority against plaintiffs nor required of 

them any activity." 

-- The Court should exercise restraint since " ... the Act 

provides a comprehensive scheme of review and gives the 

Commission prosecutorial discretion in enforcement." 

COMMITTEE TO ELECT LYNDON LA ROUCHE 

et al. v. FEC (Part II) 

On May 6, 1977, the Committee to Elect Lyndon 

La Rouche (CTEL) filed in the U.S. Court of Appeals for 

the District of Columbia a motion for discovery, asserting 

that the record, as certified by the FEC, is incomplete and 

does not sufficiently explain the reasons for the Commission's action. In papers filed on June 1, 1977, the FEC 

opposed discovery on the grounds that CTE L seeks infor· 

mation which is not a proper subject for discovery in the 

Court of Appeals. In the original petition, plaintiff chal· 

lenged the FEC's methods for certifying matching pay· 

ments. (For a summary of the original petition, see June 

Record, p. 3.) 

FEC RELEASES NON-FILERS 

The FEC published on May 14 the names of two candi· 

dates in Washington's 7th Congressional District who failed 

to file the required 11J.day pre-election report of their cam· 

paign finances for the May 17 special election. The Com· 

mission sent the candidates three notices stating that the 

report was due before making their names public. The Com· 

mission is required by the Act to periodically publish a list 

of candidates whose reports are not filed as required. 

FEC REQUIRES REPAYMENT 

OF MATCHING FUNDS 

In its meeting of May 12, 1977, the Federal Election 

Commission directed Governor Milton Shapp, former 

Presidential primary candidate, to repay to the U.S. 

Treasury $299,066.21, an amount equivalent to the total 

amount of Federal matching funds he received. The Com· 

mission based its decision on the fact that Governor Shapp 

had incorrectly certified to the Commission that he had 

met the eligibility requirements for obtaining Federal 

matching funds for the primary campaign. 

The Federal Election Campaign Act of 1971, as amended, 

states that no candidate may receive public funds for pri· 

mary elections until he/she has certified that he/she has 

received matchable contributions " ... which in the aggregate exceed $5,000 ... from residents of each of at least 20 
States; and [that] the aggregate of contributions certified 

with respect to any person ... does not exceed $250." 

(26 U.S.C. Section 9033(b)(3) and (4).) Contributions 

which are not matchable include those exceeding $250, 

contributions from political committees, and those from 

out-of-State· residents when counted for the threshold 

amount in a particular State. Nor are matching funds 

available for contributions which are prohibited under 

the Act (i.e., those made in excess of the limitations, 

those made by corporations, labor organizations, or 

Government contractors and contributions made in the 

name of another). 

During the required audit and examination of Governor 

Shapp's campaign finance reports, the Commission found 

evidence that certain persons in at least five States had 

made contributions in the name of another. When these improper contributions were subtracted from the total 

amount submitted, the Commission found that Governor 

Shapp had not satisfied the 20·State threshold requirement 

to qualify for public funding. 

Since Governor Shapp did not meet the statutory qualifica· 

tions for matching funds, the Commission determined that 

the matching payments he received were in excess of the 

amount to which he was entitled and, therefore, had to be 

repaid to the U.S. Treasury. 

FEC RELEASES INDEX ON 

1976 PRESIDENTIAL CAMPAIGN 

On June 5, 1977, the Commission released the Index to 

1976 Presidential Campaign Receipts and Expenditures 

compiled from campaign finance reports filed with the FEC 

from January 1, 1975, through December 31, 1976. The 

Index analyzes the receipts and expenditures of 23 Presidential candidates, including 15 candidates who received 

public fundin_g for the primaries (2 of whom were also the 

major party nominees in the general election) and 8 third 

party or independent candidates who were on general election ballot in at least 10 States. The receipts and expenditures listed in the Index have been adjusted to eliminate 

refunds or rebates, refunded contributions, loan repayments and transfers among affiliated committees. 

Highlights of the Index include: 

.. Over half (approximately 51%) of total private primary 

contributions received respectively by Democratic candidates, Republican candidates and non-major party 

candidates were made in amounts of $100 or less. 

.. Of the $39,612,365 total received by 13 Democratic 

candidates during the primaries, 37% was provided by 

the Presidential Election Campaign Fund. This figure 

has not been adjusted to reflect the routine repayment 

to the fund by Terry Sanford and the repayment, by 

Milton Shapp, of the entire amount he received. See 

"Public Financing" section, p. 4. 

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·· Of the $28,255,259 total received by 2 Republican 

candidates during the primaries, 29% was from the 

Presidential Fund. 

.. Of the $46,118,867 total received by 10 candidates in 

the general election (2 major party candidates and 8 

third party or independent candidates), 95% was from 

public funds. 

·· Total adjusted receipts for the 23 candidates included 

in the Index were $113,986,491, of which 60% came 

from public funds. 

-- Total expenditures for the 23 candidates amounted to 

$112,775,207, of which 59% was spent for primaries 

and 41% for the general election. 

FEC TESTIFIES ON PERSONAL 

FINANCIAL DISCLOSURE 

In testimony presented on June 7, 1977, before the 

House Select Committee on Ethics, Chairman Thomas E. 

Harris and Vice Chairman Joan D. Aikens commented on 

several procedural aspects of the proposed Legislative 

Branch Disclosure Act of 1977. This Act, to be administer· 

ed by the Clerk of the House and the Secretary of the 

Senate, would require Members of Congress, candidates for 

Congress and staff persons earning over $25,000 per year to 

file personal financial disclosure statements for public 

inspection. 

Noting the similarity between procedural questions confronted by the Commission and those raised by the proposed Act, the Commission described FEC methods for 

informing candidates about their disclosure obligations, 

reviewing reports for accuracy and compliance, and dealing 

with State officials who have administrative responsibilities 

under campaign finance laws. 

The FEC also offered several recommendations to ease 

administrative problems through coordinating campaign 

and personal financial disclosure requirements. These 

recommendations included: 

1. A provision defining "candidate" as one who has registered as a candidate under the Federal Election Campaign Act of 1971, as amended, or who has taken action 

to qualify for the State ballot. Personal disclosure 

requirements would thus be triggered by FEC registra· 

tion, enabling the new program to avoid duplicating 

the Commission's cost of seeking out many minor campaigns that may be unware of disclosure obligations . 

2. A single centralized candidate list to facilitate coordi· 

nation of FEC and congressional information and 

enforcement programs . 

3. A provision establishing a single office in each State for 

receiving both personal and campaign financial disclosure documents. 

4. A provision to give the Clerk of the House and the 

Secretary of the Senate the power to grant reporting 

waivers to candidates whose campaign financial activity 

is minimal. 
FEC documents of general applicability are published 

regularly in the Federal Register. The following list identifies all FEC documents appearing in the Federal Register 

between May 7 and June 20, 1977. 

Notice 

1977-30 

1977·31 

1977-32 

1977-33 

1977-34 

Title 

AOR 1977·22 

Request for 

Comments on 

Proposed Regulation 

AOR 1977·23 

AOR 1977·24 

AORs 1977·25 

and 1977·26 

Federal Register 

Publication Date Citation 

5/23 42 FR 26349 

5/26 42 FR 26990 

6/7 42 FR 29289 

6/17 42 FR 30897 

6/20 42 FR 31303 

FEC PUBLISHES INDEX TO REGULATIONS 

A detailed subject Index to FEC Regulations, Parts 100· 

115, has been compiled by the Commission to facilitate 

rapid and easy use of the FEC Regulations. Copies of the 

Index were recently mailed to all candidates and political 

committees on the FEC mailing list. The Regulations, pub· 

lished as a reprint of the August 25, 1976, Federal Register, 

were sent to Federal candidates and political committees 

at the time they registered. Additional copies of both the 

Regulation and the new Index are available from the Commission's Office of Public Information, 1325 K Street, 

N.W., Washington, D.C. 20463. 

FEC SURVEY AVAILABLE 

Copies of "A Study of the Impact of the Federal Elec· 

tion Campaign Act on the 1976 Elections" are available at 

a. cost of $8.00 per copy from the F EC Public Records 

FEDERAL ELECTION COMMISSION 

1325 KSTREET, NW 

WASHINGTON, DC 20463 

OFFICIAL BUSINESS 

Office. Based on a survey of attitudes of candidates in the 

1976 elections and their campaign managers and treasurers, 

the 240-page document examines the impact of the new 

campaign finance law on the 1976 elections for the House 

of Representatives and the Senate. The study was released 

by the Commission on April 28, 1977, and summarized in 

the June Record, p. 1. Requests for the study should be 

accompanied by a money order or a check made out to the 

"U.S. Treasurer" and mailed to the Public Records Office, 

Federal Election Commission, 1325 K Street, N.W., Wash· 

ington, D.C. 20463. 

NEW APPOINTMENTS 

During the months of May and June, the following new 

senior staff assignments were made at the Commission: 

- Jan Baran, former legal counsel to the National Republi· 

can Congressional Committee, was appointed Executive 

Assistant to Vice Chairman Joan Aikens. 

•· Robert Costa, previously serving as Chief of Compliance 

Review, assumed the position of Acting Assistant Staff 

Director for the Audit Division. 

·· William Loughrey, former Executive Assistant to Com· 

missioner Vernon Thomson, was named Deputy Staff 

Director. He serves as acting Staff Director in the 

absence of the Staff Director and has responsibilities in 

the areas of appointments and recruiting, planning and 

management and information coordination. 

·· Gordon Andrew McKay, former Assistant Staff Director 

for Audit Division, became Associate Staff Director. His 

responsibilities include special projects and assignments 

of a Commission-wide nature. He also maintains supervisory responsibilities for the Presidential audits. 

·• James Pehrkon, who previously served as Deputy Direc· 

tor of Data Services, became Acting Director of Data 

Services. 

-- John Reynolds, a Senior Management Trainee, became 

the new Chief of Public Communications. 

POSTAGE AND FEES PAID 

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