April 1987

FEDERAL ELECTION COMMISSION

999 E Street NW Washington DC 20463 Volume 13, Number4

C'f, ,i

"' -, r

COMMISSION DESIGNATES ACTING GENERAL

COUNSEL

On March 10, 1987, the Commission designated Lawrence M. Noble, FEC Deputy General

Counsel, as the agency's Acting General Counsel.

The former General Counsel, Charles N. Steele,

resigned in March to accept a position as General

Counsel for a nonprofit organization. (For more

information on the resignation, see page 1 of the

March 1987 Record.)

PUBLIC HEARING ON BANK LOAN

RULES CANCELED

On March 12, 1987, the Commission announced in the Federal Register that the agency had

canceled a hearing on proposed revisions to its

rules governing bank loans made to candidates and

political committees. 11 CFR Part 100. In a

notice published in the Federal Register on

January 22, 1987, the Commission had scheduled

the hearing for March 11, 1987. 52 Fed. Reg.

2416. Since, however, the Commission received

no requests to appear at the hearing by the

February 23 deadline, the agency canceled the

hearing.

A sum mary of the bank loan issues appeared

on page 2 of the February 1987 Record.

DELEGATE SELECTION RULES:

NOTICE OF PROPOSED RULEMAKING

On March 4, 1987, the Commission pualished

a notice in the Federal Register which sought

comments on proposed revisions to its regulations

governing contributions and expenditures made in

connection with the Presidential delegate selection process. 11 CFR 110.14. In the notice, the

agency also announced that it planned to hold a

public hearing on April 22, 1987, to consider the

proposed revisions and related issues. See 52 Fed.

Reg. 6580. --

Comments on the notice of proposed rulemaking should be submitted in writing to Ms.

Susan E. Propper, Assistant General Counsel, by

April 3, 1987. Those interested in testifying at

the public hearing should so indicate on their

written comments. Ms. Propper may be contacted

at: Federal Election Commission, 999 E Street,

N.W., Washington, D.C. 20463; or by calling 376-

5690 or toll free 800/424-9530.

The Commission's regulation of the delegate

selection process stems from its long-standing

view that funds received to further the selection

of a delegate are contributions and expenditures

made to influence a federal election (i.e., a

Presidential nominating convention or a primary

election held to select delegates). The revisions

proposed in the notice distinguish between individual delegates and delegate committees. The

continued on p. 2

TABLE OF CONTENTS

STAFF

1 Acting General Counsel Designated

REGULATIONS

1 Public Heartng on Bank Loan

Rules Canceled

I Delegate Selection Rules: Proposed

Revisions

4 ADVISORY OPINIONS

LEGISLATION

6 FEC Recommends Changes

in Election Laws

COURT CASES

7 FEC v. Ernest Halter and AIDS

7 FEC v. Mark Barry

7 INDEX

8 FEDERAL REGISTER NOTICES
April 1987 FEDERAL ELECTION COMMISSION Volume 13, Number 4

continued from p. 1

proposed revisions to the regulations are summarized below.

The Commission is also seeking comments on

several issues concerning affiliation between delegate and Presidential committees and activities

conducted by multicandidate and draft committees. (See below.) However, the Commission has

not yet published proposed rules to address these

issues.

Affiliation Between Delegate Committee

and Presidential Principal Campaign

Committee (Issue One)

Under the Act and FEC Regulations, affiliated committees are SUbject to a single contribution limit on both contributions they make and

contributions they receive. Committees are considered affiliated if they have been established,

financed, maintained or controlled by the same

person or group of persons.* . In the delegate selection process, some contact between individuals seeking selection as delegates and a Presidential candidate's authorized

committee(s) is necessary. (For example, the

Presidential candidate's committee may advise

delegates on how to comply with the federal

election Iaw.) Several FEC compliance matters**

have, however, raised issues concerning contacts

that could be viewed as going beyond this necessary interchange to indicate affiliation between

delegate committees and a Presidential campaign.

While the Commission wishes to continue allowing

some cooperation between a Presidential candidate's authorized committees and the delegate

committees supporting the candidate, the agency

asks:

o What circumstances indicate per affiliation,

or result in a presumption of affiliation, between a delegate committee and a Presidential

candidate's authorized committee(s)?

o What types of interaction between a delegate

committee and a Presidential candidate's au-

·The Commission's affiliation rules are set

forth at 11 CFR 11 0.3.

**MURs 1667 and 1704 (1984).

thorized cornmttteets) indicate affiliation as a

result of common establishment, financing,

maintenance or control?

o Under what circumstances should the Commission view a Presidential candidate's authorized

committee(s) and a delegate committee as unaffiliated?

o Should the application of the FEC's affiliation

rules to delegate committees and Presidential

committees be clarified by revising the Commission's regulations?

o What standards should be used to determine

affiliation between several delegate committees supporting the same Presidential candidate?

Role of Multicandidate Committee Founded by

Potential candidate (Issue Two)

Political committees and unregistered organizations have already begun engaging in activities

which anticipate the selection of delegates for

Presidential nominating conventions in 1988. In

this regard, this notice of proposed rulemaking

seeks comments on issues raised by the activities

of multicandidate committees founded by individuals who may become Presidential candidates,

Le., those who may seek their respective parties'

Presidential nominations.

In AO 1986-6, the Commission examined the

extent to which a multieandidate committee established by an individual could encourage individuals to seek selection as precinct delegates. (At

the time, the committee's founder, a federal office holder, was not considering a Presidential

candidaey.) The Commission concluded that the

multicandidate committee's proposed activities,

by themselves, would not constitute "contributions" or "expenditures" for the purpose of influencing the nomination or election of either the

committee's founder or any other candidate.

Therefore, payments for the activities would not

have to be allocated to, nor would they trigger,

any candidacy.

Current FEC rules do not address all the

issues raised by this advisory opinion or by the

delegate selection process generally. The Commission therefore seeks public comments on a ron

range of issues related to the role of the multicandidate committee in the delegate selection

process.

o Should the regulations define more precisely

when specific activities are part of the delegate selection process governed by the rules?

The RecoSd is published by the Federal Election Co~mission, 999 E Street! N.W:, Washi~gton,

D.C. 20463. Commissioners are: Scott E. Thomas, Chairman, Thomas J. Josefiak, VIce Chairrnaru

Joan Aikens; Lee Ann Elliott; Danny Lee McDonald; John Warren McGarry; Walter J. Stewart,

Secretary of the Senate, Ex Officio; Donnald K. Anderson, Clerk of the House of Representatives, .Ex Officio. For more information, call 202/376-3120 or toll-free 800/424-9530.

2
April 1987 FEDERAL ELECTION COMMISSION Volume 13, Numter4

o Should expenditures made by a multieandldate

com mittee (established by an individual who

may later become a Presidential candidate) be

chargeable, at a later time, to the Presidential

candidate's expenditure limits, if that individual

does in fact become a candidate?

o Should activities engaged in by the multicandidate committee during the delegate selection

process be viewed as testing-the-waters activities on behalf of the committee's founder or as

campaign activities, SUbject to limits? (In AO

1985-40, for example, the Commission permitted a multicandidate committee to undertake

certain activities to assist the testing-the-wetel's efforts of an individual closely identified

with the eomrnittee.)

Role of Draft Committee (Issue Three)

A draft committee is organized to gain

enough grass roots support for an individual to

influence his/her decision to become a federal

candidate. Some courts have said that draft

committees are not considered political committees, but that they are SUbject to the Act's

reporting requirements.* If, however, a draft

committee becomes involved in the selection of

delegates who support its proposed candidate,

such activities may go beyond the narrow range of

permissible activities, as defined by the courts.

The Commission therefore solicits comments on

draft committee activities.

o If a draft committee recruits and assists delett-.i;gates committed to an individual who later

~~~,ecomes a publicly funded Presidential candi- ~.,l~date, would the draft committee's contributions

and expenditures for this activity be chargeable

to the candidate's expenditure limits?

o How would a disavowal by the potential candidate affect the above situation?

Delegate Selection Rules:

Proposed Revisions

Delegates are not considered "candidates"

under the federal election law. Therefore, donations to them do not count against the donor's

limits for a candidate, and they are not reportable

by the delegate. (They do, however, count against

an individual donor's annual $25,000 contribution

limit, and they are SUbject to the contribution

prohibitions.) By contrast, delegate committees

that qualify as political committees are subject to

the same registration and reporting requirements

and contribution limits as other political committees.

The suggested delegate revisions reorganize

current language in order to clearly distinguish

between the rules governing individual delegates

<see FEC v. Machinists Non-Partisan Political

League (210 U.S. App. D.C. 267, 655 F.2d 380

(D.C. Cir.)) and FEe v. Florida for Kennedy

Committee (681 F.2d 1281 (11 Cir. 1982»)

3

and those affecting delegate committees. Additionally, the Commission seeks comments on a

new provision and on issues raised by "dual purpose" communications.

Contributions and Expenditures in the Delegate Selection Process. A new provision (110.14

(c) makes clear that funds received, or disbursements made, for the purpose of furthering the

selection of delegates to a national nominating

convention constitute election influencing "contributions" or "expenditures." The new provision

follows current llO.14(g) in making two exceptions to this rule: a delegate's fees for ballot

access as a delegate and administrative expenses

incurred by state parties in connection with delegate selection activity would be exempt from the

definitions of "contribution" and "expenditure,"

"Dual Purpose" Communications. Under the

current rules, delegates and delegate committees

may make payments for campaign materials that

advocate the delegate's selection and also refer to

a Presidential candidate. (These provisions are

based on the so-called "coattail" provisions of 2

U.S.C. §43l(8)(B)(xi).). Disbursements for these

materials are not considered contributions tOJ or

expenditures by, the Presidential candidate, provided: 1) the materials are used in connection

with volunteer activities and 2) the disbursements

are not made to pay for general public communications or political advertising. Only delegate

committees-not individual delegates-are required to report such expenditures.

IfJ however, these expenditures are made tor

public political advertising, the current regulations may require the delegate or the delegate

committee to consider the portion of the ad which

benefits the Presidential candidate as an independent expenditure or an in-kind contribution, depending on the circumstances of the expenditure.

The proposed rules would clarify the distinction between "dual purpose" payments made by

delegates and those made by delegate committees. The proposed rules would apply to dual

purpose communications that refer to, or provide

information on, Presidential candidates or candidates for any other public office (federal, state or

local).

The Commission seeks comments on several

questions related to dual purpose communications.

o Should a dual purpose communication by a delegate committee automatically be considered

either a contribution in-kind to, or an independent expenditure on behalf of, the candidate

referred to in the communication, even if the

communication is not made through general

public political advertising?

o Should lack of coordination with a candidate be

considered a valid basis tor exempting from the

election law's contribution limits payments for

continued
April 1987 FEDERAL ELECTION COMMISSION Volume 13, NumOOr" 4

dual purpose communications using public political advertising?

o If the current rules are retained, should more

criteria be used to determine when a delegate's

or a delegate committee's expenditures are inkind contributions?

o Should the FEC retain the provisions permitting

delegates and delegate committees to allocate

expenditures for dual purpose communications

between the delegate and the Presidential candidate it supports or should the entire amount

be considered support of the Presidential candidate? (Concerns have been expressed that,

since public political advertising primarily advocates the Presidential candidate, expenditures for such ads should not be allocated.)

ALTERNATE DISPOSITION

OF ADVISORY OPINION REQUEST

AO 1986-43: Services Provided to Campaign

by Corporation Owned by

Candidate and His Wife

On February 27, 1987, the General Counsel notified the requester by letter that the Commission

had considered two proposed responses to his

advisory opinion request but failed to approve an

opinion by the requisite four-vote majority.

ADVISORY OPINION REQUESTS

The following chart lists a recent request for

an advisory opinion. The full text of the AOR is

available to the public in the Commission's Office

of Public Records.

AO 1986-45: Interest Payments by Principal

Campaign Committee to

Candidate (Lender)

The Jeff Bingaman for U.S. Senate Committee

(the 1982 Committee), Senator Bingaman's principal campaign committee for his 1982 New Mexico

Senate campaign, may pay interest to Senator

Bingaman on loans which he made to the Committee from personal funds beginning in 1981. The

1982 Committee may pay an annual interest rate

of nine percent on the outstanding loan balance

ADVISOR Y 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

summary given here.

Conforming Amendments. If the Commission

adopts the proposed revisions to the delegate

selection regulations, other sections of the regulations could be amended to conform with these

provisions. Possible conforming amendments include: 1) revision of the definition of "delegate

committee" at 11 CPR lOO.5(e)(5}, 2) a crossreference in the rules to the definition of delegate and 3) Clarification of the contribution limits

in 11 CFR 110.1 and 110.2 as they apply to

delegates and delegate committees.

PUBUC APPEARANCES

4/9 Business Industry Political

Action Committee

Washington, D.C.

Vice Chairman Thomas J.

Josefiak

4/20 Fresno Rotary ClUb

Fresno, California

Chairman Scott E. Thomas

4/21 The College of Democracy

Washington, D.C.

Commissioner Lee Ann

Elliott

4/29 Citizens' Research Foundation

Washington, D.C.

Chairman Scott E. Thomas

Vice Chairman Thomas J.

Josefiak

5/1 Conference on Federal

Campaign Finance Law

Federal Election Commission

and the Missouri Secretary

of State

St Louis, Missouri

4

AOR

1987-8

Subject

International corporation as advertising sponsor for news corporation's

multimedia presentation of 1988

Presidential candidate interviews.

(Date made public: March 11, 1987;

Length: 13 pages, plus 26-page supplement)
~---------------~--- ---

April 1987 FEDERAL ELECTION COMrvllSSION Volume 13, Numb3r4

reported by the 1982 Committee as of August

1986 (i.e., $272,623.41). The 1982 Committee

must report and itemize the interest payments as

operating expenses. See 2 U.S.C. §434(b)(5)(A); 11

CFR 104.3(b)(4}.

Senator Bingaman began making Loans of personal funds to the 1982 Committee in 1981.

Although Senator Bingaman and the 1982 Committee had no written agreement concerning the

loan transactions, the Committee's treasurer disclosed a 13 percent interest rate on the loans,

beginning with the Committee's 1982 October

quarterly report. By August 1986, however, the

1982 Committee had not made any interest payments to Senator Bingaman. At that time, the

1982 Committee set up a loan liquidation schedule

and agreed to pay an annual interest rate of nine

percent on the outstanding loan balance. (The

nine percent rate was slightly lower than the

prime lending rate of a local New Mexico bank.)

Neither the Act nor FEC Regulations specifically address a campaign's payment of interest on

loans made by the candidate from personal funds.

However, the RegUlations permit a candidate to

use unlimited personal funds for making campaign

expenditures (Including campaign loans), and the

regulations allow campaigns to pay interest on

loans at a commercially reasonable rate. 11 CFR

100.7(a) (l)(i)(E); IOO.S(a)(l)(i).

At the same time, although the Act and FEe

Regulations prohibit a candidate from converting

excess campaign funds to personal use, the Regulations specifically permit a candidate's campaign

to use excess campaign funds to repay loans from

the candidate. 2 U.S.C. §439a; 11 CFR 113.2(d).

Finally. the nine percent interest does not exceed

a commercially reasonable rate.

The Commission distinguished this opinion

from AD 1977-58, in which the Commission had

concluded that the pr-inlelpal campaign committee

could not retroactively report a candidate gift to

the committee as a candidate loan, and thereby

justify committee repayments of the loan to the

candidate. (Date issued: February 6, 1987;

Length: 5 pages)

AO 1987-1; Campaign's Compensation of Lost

Wages to Candidate Prohibited

Friends of Jim Dawson (the Committee), Mr.

Dawson's principal campaign committee for his

1986 House campaign, may not use its excess

campaign funds to compensate Mr. Dawson for

wages he lost as a result of his candidacy. The

Committee's payment of Mr. Dawson's claim for

the wages would constitute a prohibited conversion of excess campaign funds to the candidate's

personal use. (The lost wages amounted to

$7,000.)

Under the Act and FEC Regulations, a campaign may use its excess campaign funds for a

5

variety of lawful purposes, but it may not convert

the funds to the candidate's personal use. 2

U.S.C. §439a; 11 CFR 113.2.

The Committee's compensation of lost wages

cannot be viewed as the payment of a campaign

obligation. The Committee had no preexisting

'written contract with Mr. Dawson to compensate

him for the lost wages or to compensate him for

any valuable services performed for the campaign. Nor had Mr. Dawson incurred a debt or an

obligation for his living expenses during the campaign (e.g., an outstanding bank loan), which the

Committee could lawfully assume. (The Commission distinguished this view from its conclusion in

AD 1982-64. In that opinion, the Commission

allowed a candidate's committee to assume, and

solicit contributions to repay, a bank loan the

candidate had obtained to cover living expenses

during his campaign.) (Date issued: February 20,

1987; Length: 2 pages)

AO 1987-2: Campaign's Purchase of Car for

Candidate's Reelection and .

Official Duties

The Florio '88 Commitee (the Florio Committee),

Representative James J. Florio's principal campaign committee for his 1988 reelection campaign, may purchase a car that will be used by Mr.

Florio and others for travel related to both the

campaign and his official duties of office, provided the Florio Committee pays the usual and

normal charge for the car. 11 CFR IOO.7(a)(l)(iii)

and AOs 1985-42, 1984-59~ 1977-1 and 1976-64.

The Act and FEG Regulations permit candidates and their campaigns to decide which types

of expenditures will most effectively influence

their nominations and elections. Further, the Act

provides that candidates may use excess campaign

funds for "ordinary and necessary expenses incurred in connection with" their official duties. 2

U.S.C. §439a; 11 CF R 113.2.

Although the law prohibits candidates from

converting excess campaign funds to personal use,

this prohibition does not apply to individuals, such

as Representative Florio, who were Members of

Congress on January 8, 1980. Thus, the Florio

Committee may pay for Representative Florio's

use of the car even if his travel expenses to use

the car are incurred for personal purposes.

Reporting Requirements

The Florio Committee should report payments for the purchase of the car as disbursements. If the caris to be used primarily for

campaign purposes, the Committee should disclose these disbursements as campaign operating

expenditures. 2 U.S.C. §434(b)(5)(a) and (6)(A).

The expense of using the car for campaignrelated activity should also be reported as "operating expenditures." Z U.S.C. S434(b)(4)(A); 11

continued
April 1987 FEDERAL ELECTION COMMISSION Volume 13, Numt€r4

CPR 104.3(b)(4)(i) and 106.3(a). However, the

Committee should report use of the car for official duties or personal purposes as "other disbursements." 2 U.S.C. §434(b)(6)(A); 11 CFR

l04.3(b)(4)(i). (Date issued: February 20, 1987;

Length: 3 pages)

AO 1987-3: Refund for Terminated Presidential

Campaign Remitted by Media

Pirm to U.S. Treasurer

Mr. Harry O'Connor, the president of a firm which

made media buys for the Reagan for President

Committee (RPC), must remit a check to the U.S.

Treasurer (for deposit in the Presidential Election

Campaign Fund) for the full amount of a refund

which, in 1980, he received from CBS Radio

Network (CBS) on behalf of RPC.

RPC was the principal campaign committee

for Mr. Reagan's publicly funded Presidential primary campaign in 1980. In late 1979, Mr.

O'Connor and his firm, O'Connor Creative Services, represented RPC in buying broadcast time

from CBS for a nationwide airing of a five-minute

radio address by Mr. Reagan. CBS subsequently

refunded $5,350.92 to the O'Connor firm because

several CBS radio affiliates did not air the

Reagan address. Although the O'Connor firm

received the refund check in 1981, for various

reasons it failed to transmit the refund to RPC

before RPC terminated several years ago.

Had the refund been made to RPC in 1980 or

1981, before it terminated, the Commission would

have required RPC to make a repayment, in part,

to the U.S. Treasury, not to others.

The Commission noted that there was no

basis for permitting Mr. O'Connor to submit the

refund to RPC or any of its former officers.

Since RPC terminated without ever receiving the

refund, the refund may not now be treated as the

committee's excess campaign funds. 2 U.S.C.

§439a; 11 CFR 113.3(e). Moreover, the threeyear period during which the Commission could

have demanded RPe's repayment of the refund

expired in 1984.* See 26 U.S.C. §9038(b)(2) and

(b)(3). (Date issued: March 3, 1987; Length: 3

pages)

• Under the public funding sta tures, a publicly

funded Presidential primary campaign must return

unspent primary matching funds to the U.S. Treasurer, within the period designated by the statute.

See 26 U.S.C. Section 9038(c).

6

FEe RECOMMENDS CHANGES

IN ELECTION LAWS

On March 4, 1987, the Commission transmitted to Congress and the President 24 recommendations for legislative changes in federal

election laws. The recommendations would enhance the agency's ability to administer election

laws. The Commission is statutorily mandated to

submit recommendations each year "for any legislative or other action the Commission considers

appropriate••••" 2 U.S.C. §438(a)(9).

Among the 24 proposals submitted this year,

four would affect Presidential elections. These

proposals contain recommendations that Congress;

o Eliminate state-by-state spending limits for

publicly funded Presidential primary candidates. The Commission believes that the overall national limit would serve as a constraint on

state spending.

o Combine the overall spending limit for Presidential primary candidates with the spending

limit for fundraising, This proposal would simplify reporting requirements, reduce accounting

burdens for committees and simplify the Commission's auditing procedures.

o Require the U.S. Treasurer to deposit in the

Presidential Election Campaign Fund all repayments required by publicly funded Presidential

nominating conventions and Presidential nominees. Currently, the Fund receives only those

repayments made by publicly funded Presidential primary candidates.

o Reaffirm Congressional intent that draft committees are subject to the provisions of the

Federal Election Campaign Act.

Other proposals aimed at enehancing public

disclosure would:

o ReqUire House and Senate campaigns to report

their financial activity for an entire election

cycle. They currently report on a calendar year

basis.

o Give Congressional campaigns the option to file

monthly reports.

o Require monthly filers to file their reports

closer to the closing date of a reporting period

in order to make information more timely.

o Eliminate the requirement that potential committees file copies of their reports with the

Secretaries of State, Instead, the Commission

proposes a system whereby the Secretaries of

State would have direct access to this information through the FEC's computerized disclosure

data base.

Included among the Commission's remaining

16 recommendations were suggestions that Congress:
April 1987 FEDERAL ELECTION COMMISSION Vo\ume 13, Number 4

o Make the FEC the sole point of entry for all

disclosure documents filed by federal candidates and political committees; and

o Establish a reimbursement account for the FEC

that would enable the agency to offset expenses

incurred from reproducing documents and tapes

purchased by requesters.

The full text of the recommendations will be

published in the Commission's 1986 Annual Report. Copies of the recommendations are also

available from the FEC's Public Records Office,

999 E Street, N.W., Washington, D.C. 20463.

FEC v. ERNEST HALTER AND AMERICAN

INTERNATIONAL DEMOGRAPHIC SERVICES,

INC.

On February 2, 1987, the U.S. Court of Appeals for the Fourth Circuit dismissed FEC v.

Ernest Halter and American International Demographic Services, Inc. (Appeal No. 86-1560). The

court's action responded to Mr. Halter's request

for a dismissal of his appeal.

On March 31, 1986, American International

Demographic Services, Inc. and its Vice President,

Ernest Halter, had appealed an order issued by the

U.S. District Court for the Eastern District of

Virginia. In the February 10, 1986, order, the

district court had permanently enjoined the defendants from using FEC campaign finance informa tion for com rnercial purposes. The district

court had also imposed a $3,500 civil penalty on

the defendants for illegal use of the information.

(For a summary of the suit, see pages 8-9 of the

April 1986 Record.)

FEC v. MARK BARRY

On February 10, 1987, the U.S. District Court

for the District of Massachusetts granted the

FEC's application for entry of default against

Mark Barry. (FEC v. Mark Barry; Civil Action

No. 86-2807-C)

Mr. Barry was the assistant treasurer for

Mickey Edwards' 1982 and 1984 House campaigns.

In filing suit against him in September 1986, the

FEC asked the court to declare that he knowlingly

and willfUlly violated the Act and FEC Regulations by:

*Under the Act, an individual may contribute

up to $1,000 to a candidate per election.

7

o Failing to maintain adequate records for approximately $164,784 in disbursements that he

made on behaU of the Edwards in '82 Committee, the principal campaign committee for Mr.

Edwards' 1982 House campaign (II CFR 102.9

(b)(l»; and

o Making an excessive contribution* of $1,587.60

to the Edwards in '82 Committee {2 U.S.C.

§441a(a)(I)(A»).

This cumulative index lists advisory opinions,

court cases and 800 Line articles published in the

Record during 1987. 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

1986-37: Presidential candidate appearances at

convention of nonprofit corporation, 1:6

1986-38: Individual's financing of media ads to

promote conservative candidates, 1:7

1986-39: Excess campaign funds used to establish trust fund for minor, 2:3

1986-40: Corporate donations to state party

committee's building fund, 2:3

1986-41: Trade association's plan to compensate

employees who make contributions, 2:4

1986-42: Affect of corporate reorganization on

PACs, 3:4

1986-44: Corporation's plan to match contributions to PAC with corporate donations to

chartty, 3:4

COURT CASES

FEC v, Americans for Jesse Jackson, 2:9

FEC v, Beatty for Congress Committee, 3:6

FEC v, Citizens Party, 1:8; 2:8

FEC v, Congressman Charles E. Rose, 2:7

FEC v, Furgatch; FEC v, Dominelli, 3:5

FEe v, John R. Clark, Jr., 2:8

FEC v, Jolyn Robichaux, et al., 2:9

FEC v, MCFL, 2:4

FEC v: 1984 Victory Fund, 3:6

Com.mon Cause v; FEC (fourth suit), 2:6; fifth

SUIt, 2:9

800 LINE

After the election: winding down, 3:9
April 1987 FEDERAL ELECTION COMMISSION Volume 13, Numt€r4

FEDERAL REGISTER NOTICES

Copies of notices are available in the Public

Records Office.

Notice Title

1987-1 11 CFR Parts 100, 102, 103~ 104 and 110:

Contribution and Expenditure Limitations and Prohibitions; Contributions by

Persons and Multicandidate Political

Committees; Final Rules Transmitted to

Congress (52 Fed. Reg. 760~ January 9,

1987)

1987-2 11 CFR Part 100: Bank Loans to Candidates and Political Committees; Announcement of Public Hearing and Extension of Comment Period (52 Fed.

Reg. 2416, January 22, 1987) --

1987-3 Filing Dates for California Special Elections (52 Fed. Reg. 5189, February 19,

1987)

1987-4 11 CFR Part 110: Contributions to and

Expenditures by Delegates to National

Nominating Conventions; Notice of Proposed Rulemaking (52 Fed. Reg. 6580~

March 4, 1987.)

FEDERAL ELECTION COMMISSION

999 E Street,NW

Washington, D.C. 20463

Official Business

FEe WILL CO-HOST CONFERENCE

IN ST. LOUIS

On May 1, 1987, a one-day conference

on federal campaign finance laws will be

held in St. Louis, Missouri. Co-sponsor ed

by the FEC and the Missouri Secretary of

State's Office, the conference will provide

an overview of federal campaign finance

laws and include sessions on: corporate

and labor involvement in federal elections

through PACs and other activities; party

committees' support of federal candidates;

political committees' registration, recordkeeping and reporting requirements; and

case studies that focus on corporate, labor

and party committee participation in federal elections.

For more information on the conference, contact the FEe toll free at

800/424-9530 or the Missouri Division of

Campaign Reporting at 314/751-1831.

Bulk Rate Mail

Postage and Fees Paid

Federal Election Commission

Permit Number G-31