THE FEDERAL ELECTION 

COMMISSION 

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

Volume 5, Number 11 

PUBLIC 

FINANCING 

DISCLOSURE OF MATCHING 

FUND SUBMISSIONS 

On September 6, 1979, the Commission approved 

procedures for the public disclosure of information from 

the submissions of Presidential candidates seeking 

public matching funds for the 1980 election. 

For each contribution submitted to the FEC for matching fund payments, candidates must provide a check or 

other written instrument as well as other information required by the Commission. Additionally, each submission must contain an alphabetical listing of the contributors and the amounts of their contributions. 

Under the recently adopted procedures, the 

alphabetical listing will be forwarded to the Commission's Public Records Office for microfilming on the last 

day of the week the submission is received. The 

alphabetical listing will then be available to the press 

and the public, although copies of the checks and other 

written documentation will not be. In certain instances, 

the listing will be released before the Commission has 

certified that the candidate is eligible for matching 

funds. The alphabetical listing, therefore, will merely 

identify the contributions for which a ca ndidate has requested matching payments. The list will not, in itself, 

represent a Commission determination that the candidate is entitled to receive matching funds in the 

amount of the listed contributions. 

November 197

REPORTS 

SPECIAL ELECTIONS IN ILLINOIS 

Illinois has scheduled special elections for Decembe

11 (primary) and January 22 (general) to fill the sea

vacated by Federal Judge Abner Mikva, forme

Representative from the 10th Congressional District 

Candidates in these special elections must file ten-da

pre-election and 30-day post-election reports. Th

Federal Election Commission will send notices to a

candidates on the ballot with more information o

reporting dates. Political committees that plan to con

tribute to, or make expenditures on behalf of, one o

these candidates are also required to file pre- and post

election reports. For more information on require

reports or other matters, they should contact the Publi

Communications Office at the Commission by callin

toll free (800)424-9530 or 523-4068 in Washington, D.C

Multicandidate committees that file on a monthly basi

need not file pre- and post-election reports. Instead

their monthly reports are due on the 20th of eac

month. 

FORMS FOR ETHICS ACT REPORTS 

Presidential and Vice Presidential candidates may ob

tain forms for reports required under the Ethics Act (se

Record, August 1979, p.2) from the FEC. Contact th

Information Office at the Federal Election Commission

1325 K Street, N.W., Washington, D.C., 20463; or ca

202/523-4068, toll-free 800/ 424-9530. 

Senate and House candidates, however, must obtai

forms and information from the Clerk of the House o

the Secretary of the Senate, as appropriate. Ethics Ac

forms for House and Senate candidates are no

available from the FEC or the Office of Governmen

Ethics. 

Questions about completing and filing the reports re

quired under the Ethics Act should be addressed to th

Office of Government Ethics, 1900 E Street, N.W

Roon 5315, Washington, D.C., 20415; telephone

202/ 632-7642. 
, 

REGULATIONS 

FEC HEARING ON 

PROPOSED REGULATIONS 

Following the Senate's disapproval, on September 

17, 1979, of the FEC's proposed regulations on candidate debates (See Record, August 1979, p. 1), the 

FEC held hearings on October 23 and 24, 1979, on the 

funding of candidate debates. The Commission requested public comments on several specific issues, including the types of organizations that could sponsor 

candidate debates, the role of the news media in the 

sponsorship and coverage of debates, and payments by 

corporations and labor unions in connection with the 

staging and covering of debates. (See Federal Register 

Notice 1979-17, 44FR 59162.) 

OPINIONS 

ADVISORY OPINION REQUESTS 

The following chart lists recent Advisory Opinion Requests (AOR's), with a brief description of the subject 

matter, the date the requests were made public and the 

number of pages of each request. The full text of each 

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

AOR Subject Date M ade No. of 

Public Pages 

1979-54 Appearance of Senatorial 9/ 21/79 

candidate in commercial 

television advertisement. 

1979-55 Status of committee promot- 9/ 27/79 

ing uncommitted slate of 

delegates to national 

nominating convention . 

1979-56 PAC of company that is 9/ 28/79 2 

joint venture of two other 

corporations. 

1979-57 Use of money orders to 10/ 2/79 

transfer mass collections to 

PAC. 

A DVISORY OPINIONS: SUMMARIES 

Designated as AO's, Advisory Opinions discuss 

application of the Act or Commission Regulation

specific factual situations. Any qualified person 

questing an Advisory Opinion who in good faith ac

accordance with the opinion will not be subject to 

sanctions under the Act. The opinion may also be re

upon by any other person involved in a specific tran

tion which is indistinguishable in all material asp

from the activity discussed in the Advisory Opin

Those seeking guidance for their own activity sh

consult the full text of an Advisory Opinion and not 

only on the summary given here. 

AO 1979-31 : Solicitations by 

Independent Committee 

If Western Enterprise Political Action Comm

(WEPAC) is, as it claims, an independent, unaffili

committee with no connected organization, it 

solicit and receive contributions from individ

employed by Hilton Hotels Corporation as well as o

individuals and political committees. The contribut

it receives must be within the limits of 2 U.S.C. §4

and otherwise lawful under the Act. 

The Commission noted that the Act prohibits WEP

from receiving any contribution of goods, service

anything of value from Hilton Hotels Corporation or 

other corporation (2 U.S. C. 8 441 b), and emphas

that WEPAC's receipt of a mailing list of Hilton Ho

Corporation employees would constitute a prohib

contribution, unless WEPAC paid the "usual and 

mal charge" for such a list. 11 CFR 114.9(d) 

100.4(a)(1)(iii)(B). (Date Issued: September 13, 1

Length: 3 pages) 

AO 1979-41 : Registration and Reporting 

Requirements of Political 

Committee 

The National Committee for a Democratic Alterna

(the Committee) is a political committee within 

meaning of the Act and is subject to the Act's regis

tion and reporting requirements. 

The Committee's purpose is to stimulate debate on 

tain pol icies of the present administration and to see

alternative Democratic candidate for President in 1

To accomplish this end, the Committee intends to sp

sor advertisements to express its views and so

funds. A prototype of the Committee's intended 

specifically identifies President Carter as the Demo

to whom an alternative is needed, and include

solicitation for contributions. 

The RECORD is published by the Federal Election Commission, 1325 K Street, N. W., Washington, D. C. 2046

Commissioners are: Robert 0 . Tiernan, Chairman; Max L. Friedersdorf, Vice Chairman; Joan D. Aiken

Thomas E. Harris; John W. M cGarry; Frank P. Reiche; J . S. Kimmitt, Secretary of the Senate, Ex Offici

Edmund L. Henshaw, Jr., Clerk of the House of Representatives, Ex Officio. For more information, c

2021523-4068 or toll-free 800/ 424-9530. 

2 
The Committee's proposed activity, as represented by 

the ad, is to influence the 1980 election. And, since the 

Committee has stated that it anticipates receiving contributions or making expenditures totaling more than 

$1,000 during 1979, it is a political committee within the 

meaning of the Act. 2 U.S.C. §431 (d) and 11 CFR 

100.14. The Committee is therefore subject to all provisions of the Act. (Date Issued: September 13, 1979; 

Length: 4 pages) 

AO 1979-42: Administration of Separate 

Segregated Fund 

The South Carolina National Bank may pay premiums 

on liability insurance to protect the officers and 

members of its separate segregated fund, the South 

Carolina National Bank Political Action Committee 

(BANK-PAC), against liability arising from the direction 

of BANK-PAC. 

Although national banks are prohibited from making 

contributions or expenditures in connection with any 

election, the Act specifically allows banks (and other 

corporations and labor organizations) to establish, administer and solicit funds to a separate segregated fund, 

from which political contributions and expenditures 

may be made. Since the Bank's payment of the insurance premiums is a cost of establishing and administering a separate segregated fund rather than a 

contribution, it is permissible under the Act. (Date 

Issued: September 14, 1979; Length: 2 pages) 

AO 1979-44: Solicitation of Executive 

and Administrative Personnel 

The Public Affairs Fund, the separate segregated fund 

of United Carolina Bank, Whiteville (Whiteville), a wholly owned subsidiary of United Carolina Bankshares Corporation (UCB), may solicit the executive and administrative personnel of UCB and each of UCB's three 

wholly owned subsidiaries after an internal corporate 

reorganization is completed. Commission Regulations 

permit a corporation and/ or its separate segregated 

fund to solicit the executive and administrative personnel (and their families) of the corporation's subsidiaries, 

branches, divisions and affiliates. 11 CFR 114.5(g)( 1). 

Since UCB and its three subsidiaries will become affiliated entities, the Public Affairs Fund may lawfully 

solicit the executive and administrative personnel of the 

parent corporation and its wholly owned subsidiaries. 

The Commission noted that all separate segregated 

funds established by a corporation, its affiliates, subsidiaries, branches and divisions are treated as a single 

political committee and are subject to a single contribution limitation. 2 U.S.C. §441a(a)(5). Commissioner 

Thomas Harris filed a dissenting opinion. (Date Issued: 

September 21, 1979; Length, including dissenting opinion: 3 pages) 

3 

AO 1979-46: Permissible Contributions After 

Conversion To Multicandidate 

Committee 

Americans Organized for Responsibility (Americans) e

pects to qualify for status as a multicandidate comm

tee after the primary election. Once it qualifies fo

multicandidate status, Americans may contribute up t

$4,000 to retire the primary election debt of a candida

to whom it contributed $1,000 during the primary cam

paign provided that the candidate has a primary debt o

at least $4,000 when he/ she receives the post-prima

contribution. The contribution must be designated 

writing as a contribution to the primary. 

Monies donated by Americans for noncampaign o

ficeholder activity are not "contributions" under the A

and, therefore, do not count against the Act's contribu

tion limitations. Such monies are, however, "fund

donated" (11 CFR 113.1), which must be reported b

Americans on Schedule B, with an explanation that th

amount is to support officeholder expenses rather tha

campaign activities. 11 CFR 104.2(b). Furthermore, th

recipient must report those funds as a receipt on his/ h

biannual report on office accounts. 11 CFR 113.4. 

The Commission expressed no opinion on the possib

application of the Standing Rules of the Senate o

possible tax ramifications. Those issues are not with

the Commission's jurisdiction. (Date Issued: Septemb

21, 1979; Length: 3 pages) 

ADVISORY OPINION 

REQUESTS WITHDRAWN 

Since October 1979, the following Advisory Opinio

Request was withdrawn by its requester: 

- AOR 1979-47 

COMPLIANCE 

SUMMARY OF MUR's 

Selected compliance cases, which have been close

and put on the public record, are summarized in th

Record. Compliance matters stem from possible viola

tions of the Act, which come to the Commission's a

tention either through formal complaints originatin

outside the Commission or by the FEC's own monito

ing procedures. The Federal Election Campaign Act o

1971 , as amended (the Act) gives the FEC the exclusiv

primary jurisdiction for the civil enforcement of the Ac

Potential violations are assigned case numbers by th

Office of General Counsel and become "Matters Und

Review" (MUR's). All MUR investigations are kept con

fidential by the Commission, as required by the Act. 

MUR's may be closed at any one of several poin

during the enforcement process, including when th

Commission: 

continue
- Determines that no violation of the Act has occurred; 

- Determines that there is no reason to believe, no 

reasonable cause to believe or no probable cause to 

believe a violation of the Act has occurred; 

- Enters into a conciliation agreement with the respondent; 

- Finds probable cause to believe a violation has occurred and decides to sue; or 

- Decides at any point during the enforcement process 

to take no further action. 

After the MUR is closed and released by the Office of 

General Counsel, the Commission makes the MUR file 

available to the public. This file contains the complaint, 

the findings of the General Counsel's Office and the 

Commission's actions with regard to the case, including 

the full text of any conciliation agreement. The Commission's actions are not necessarily based on, or in 

agreement with, the General Counsel's analysis. 

Selection of MUR's for summary is made only from 

MUR's closed after January 1, 1979. The Record article 

does not summarize every stage in the compliance process. Rather, the summary provides only enough 

background to make clear the Commission's final determination. The full text of these MUR's and those which 

were closed between 1976 and 1978 are available for 

review and purchase in the Commission's Public 

Records Office. 

MUR 700: Independent Expenditures; 

Candidate Authorization 

On March 6, 1979, the Commission entered into a conciliation agreement with an individual who had violated 

2 U.S. C. §434(e) by failing to report independent expenditures, and 2 U.S.C. 8 441d(2) by failing to include the 

required authorization notice on a publication. 

Complaint: On September 6, 1978, a former Federal 

candidate filed a complaint alleging that an individual's 

distribution of a brochure advocating his defeat in a 

Congressional primary election was in violation of the 

Act. Although the brochure did not endorse his opponent, it expressly advocated the former candidate's 

defeat because of his position on the legalization of 

marijuana and the decriminalization of homosexuality. 

Styled as an open letter to concerned citizens, the 

brochure contained no notice of authorization or 

nonauthorization from any candidate. Furthermore, the 

distributor of the brochure had not reported his expenditures to the FEC. 

General Counsel Reports: The subsequent Commission 

investigation revealed that 25,000 copies of the 

brochure had been distributed to 22,000 people immediately before the primary election. The costs for 

printing and distribution amounted to $2,493.58; of that 

amount, $100 had been received in contributions. Since 

the respondent had failed to report independent expenditures in excess of $100, the General Counsel recommended that the Commission find reasonable cause to 

believe he had violated §434(e). The General Counsel 

also recommended that the Commission make the same 

4 

finding with the respect to the violation of §441 d, 

the brochure failed to include a notice stating that i

not authorized by any candidate. 

Commission Determination: On December 12, 1978

Commission found reasonable cause to believe tha

respondent had violated 2 U.S.C. §§434(e) and 44

and entered into a conciliation agreement with 

respondent on March 6, 1979. Civil penalties 

levied. 

MUR 916: Use of Federal Facilities 

by Incumbent 

On February 16, 1979, the Commission found no re

to believe a campaign committee had violated 11 

104.3(a)(1 ) and 11 CFR 104.1 (a) by failing to report 

tributions or expenditures. 

Complaint: On January 31 , 1979, an individual fi

complaint alleging that a Federal officeholder 

violated the Act during his recent campaign for re

tion to the House of Representatives. The nota

complaint, based on a newspaper report that the in

bent used his Congressional district office as sole h

quarters for his 1978 reelection campaign, alleged 

1. The House Administration Committee provided 

funds to maintain the district office. Therefore, 

a political campaign is not an official duty, use o

office for this purpose constitutes a violation o

u.s.c. §628; 

2. The unreimbursed use of the office facility is a 

tribution as defined by 11 CFR 100.4(a) and 11 

100.4(a)(1)(iii)(A), and should be reported as a

kind contribution under 11 CFR 104.3(a)(1 ); or 

3. The campaign committee must reimburse the H

of Representatives for the value of the office fac

such payment would be an expenditure as define

11 CFR 100.7(a)(1) and should be reported acco

to 11 CFR 104.1(a). 

The complaint alleged that a review of the reports o

with the Commission did not disclose any contribu

or expenditures for use of the office space. 

General Counsel Reports: The General Counsel po

out that, although the Commission had no jurisdi

over the first allegation, the second and third allega

were similar to those before the Commission in ano

MUR (MUR 672). In that matter, the Commission 

firmed that " the United States is not a 'person' w

the meaning of the Act's contribution reporting p

sions," and the use of government facilities or ser

could not be deemed a campaign expenditure. Fur

more, the General Counsel pointed out that in 

earlier Advisory Opinions (1976-34 and 1976-44)

Commission had established the general principle 

Congress did not intend legislatively appropriated f

to be considered contributions under §431 (e). Fin

the Commission had found no reason to believ

previous MUR's, that a violation of the Act had 

curred when there was no reporting of services 
goods allegedly provided by the Federal government 

and State government to Federal candidates. 

Therefore, the General Counsel concluded that failure 

to report the use of Federal office space as a contribution or expenditure was not a violation of the Act, and 

recommended that the Commission find no reason to 

believe the committee had violated the Act. 

Commission Determination: On February 16, 1979, the 

Commission found no reason to believe the respondent 

committee had violated 11 CFR 104.3(a)(1) and 11 CFR 

104.1(a), and voted to close the file. 

MUR 592: Use of FEC Reports 

for Commercial Purposes 

On March 16, 1979, the Commission entered into a conciliation agreement with a publication that had used information copied from FEC reports for a commercial 

purpose, a violation of 2 U.S.C. §438(a)(4). 

Complaint: On March 16, 1979, an individual requested 

copies of a specific committee's reports from the Commission's Public Records Office. The individual stated 

that he wished to obtain contributor names to create a 

mailing list for the publication with which he was 

associated. The publication intended to solicit the listed 

contributors for magazine subscriptions. The Public 

Records Office informed the individual that §438(a)(4) 

prohibited the use of FEC reports for commercial purposes, but he stated that the publication was exempt 

from the prohibition. The order was filled and the matter 

was referred to the Office of General Counsel. On June 

7, 1979, the Commission found reason to believe that 

the publication had violated 8 438(a)(4). 

The publication had compiled a list of 25,000 names 

from FEC reports. It had already solicited 2,500 of the 

group when it received notification of the Commission's 

reason to believe finding. The publication agreed it 

would not mail the additional solicitations until the matter had been resolved, and it then submitted a 

memorandum of law disputing the Commission's finding. 

General Counsel Reports: The respondent's memorandum maintained that since 11 CFR 104.13 exempted the 

sale of newspapers, magazines, books and similar communications from the definition of "commercial purpose," the publication had not violated the Act. The 

General Counsel pointed out that the Act prohibits t

use of information taken from FEC reports for comme

cial purposes and that, when 11 CFR 104.13 w

transmitted to Congress, it was explained that t

Regulation "defines commercial use to exclude use to 

news media and books." The exemption was not 

tended and had never been interpreted, despite t

respondent's assertions to the contrary, to inclu

solicitations for subscriptions. Furthermore, legislati

history showed that the prohibition was not aimed e

clusively at listbrokers, as the respondent maintaine

but at any person who would use the information f

any commercial purpose. Therefore, the Gene

Counsel recommended that the Commission fi

reasonable cause to believe that the respondent h

violated the Act. 

Commission Determination: On December 15, 1978, t

Commission found reasonable cause to believe t

respondent publication had violated 2 U.S.C. §438(a)(

and sent a proposed conciliation agreement to t

publication. The respondent then requested that t

conciliation agreement be revised to allow the public

tion to use its remaining solicitation materials to soli

the unused FEC names. The Commission refused. 

the conciliation agreement, which the respondent a

the Commission entered into on March 16, 1979, t

respondent agreed not to solicit the unused names a

not to use information from FEC reports for any com

mercial purpose in the future. 

FEC PUBLISHES NAMES OF NONFILERS 

On September 18, 1979, the Federal Election Co

mission published the names of 376 nonfilers who fail

to file the required July 10 quarterly campaign finan

report. Nonfilers included Federal candidates, their pr

cipal campaign committees and other political comm

tees from 46 States and the District of Columbia. 

Under Commission procedures, three notices are se

to candidates and committees reminding them of th

reporting obligations and urging compliance. If a ca

didate or committee does not file the required report(

following the receipt of these notices, the name of th

"nonfiler" is made public, as required by law. In ad

tion to publishing the names of nonfilers, the Comm

sion has the authority to take further enforcement a

tion under the statute, including civil court enforceme

and imposition of civil penalties. 

Forms for candidate and committees to register and report are available at any time by contacting: Office of Public 

Communications, Federal Election Commission, 1325 K Street, N.W., Washington, D.C. 20463 (Telephone: 202/523-

4068; Toll-Free 800/424-9530). 

Candidates and committees should use the revised form for reporting receipts and expenditures, which is designated in 

the upper left hand corner as: FEC Form 3 REVISED, January 1978. All Presidential candidates must file on FEC 

Form JP, even if they do not receive public funds. Filers must submit legible reports which can be reproduced clearly; 

candidates or committees who file illegible or barely legible reports will be required to refile. 

5 
•. 

AUDITS 

REVIEW OF FEC AUDIT PROCEDURES 

On June 7, 1979, the Commission authorized a review 

of existing FEC audit practices and procedures to identify problem areas and develop recommendations to 

substantially reduce the time required to complete and 

release audits. The review was conducted by Arthur 

Andersen and Co., a private firm with extensive experience in the area of campaign financing. Since Arthur Andersen's clients include members of both major 

political parties, the Commission decided that the 

Andersen review should be conducted in conjunction 

with Accountants in the Public Interest (API). API was 

selected to monitor the findings from a public interest 

viewpoint and to determine whether the results were 

without bias. 

On September 13, 1979, both Arthur Andersen and API 

presented their findings to the Commission. The 

Andersen review identified a number of problem areas 

and presented a series of recommendations to assist the 

Commission in conducting audits on a timely basis and 

with minimal disruption to political committees. API 

concluded that the Andersen reivew and recommendations were without bias. 

The Andersen report included recommendations that 

the FEC: 

1 . Change the Objective of the Audit Process: Arthur Andersen recommended that, rather than expecting its auditors to verify each transaction of 

every political committee, the FEC consider a more 

limited audit objective, i.e., to verify committees' 

compliance in areas with the greatest risk of noncompliance. Andersen recommended, accordingly, 

the establishment of valid risk criteria and the concentration of limited audit resources on identified risk 

areas, so that the Commission could maximize its 

verification of compliance with the Act by expanding 

its audit coverage to more committees. This new 

procedure would not, however, apply to committees 

receiving public funds. 

2. Establish Thresholds: Andersen pointed out that 

the required resolution of minor discrepancies had 

proven time consuming for both campaign staffs and 

FEC auditors. Therefore, Andersen recommended 

that thresholds be established so that only significant 

problems would be included in audit reports and/ or 

referred to the General Counsel. 

3. Eliminate Categorization of Audit Reports; Issue 

Audit Findings Letters: Andersen pointed out that, 

although the current practice of assigning one of 

three possible audit opinions (clean, qualified or 

adverse) to each audit report had been designed to 

6 

help the public understand the degree of a spe

committee's compliance with the Act, the public 

not able to make that distinction. To imp

disclosure, Andersen recommended that audit 

dings letters, indicating the scope and findings o

audit, be issued within two weeks of completio

the field work. The audited committee would 

given a reasonable period for response. At the en

that period, the findings letter, together with a s

mary of issues resolved by the FEC and the com

tee, would be released as the final report. 

4. Separate Audit Reports from Compliance M

ters (MUR's): Andersen noted that many a

reports are delayed for weeks and months pen

the resolution of MUR's (potential compliance 

tions against committees) in the General Couns

FEC PUBLIC APPEARANCES 

In keeping with its objective of making informa

tion available to the public, the Federal Electio

Commission regularly accepts invitations to ad

dress public gatherings on the subject of cam

paign finance laws and the Commission itse

This regular column lists scheduled Commissio

appearances, detailing the name of the sponso

ing organization, the location of the event and th

name of the Commission's speaker. For addition

information on any scheduled appearance, pleas

contact the sponsoring organization. 

11 / 27- 28 Federal Bar Association 

Conference on Congressional 

Campaigns and Campaign Law 

House and Senate Code of Ethics 

and Campaigns 

Doug Patton, Special Deputy to 

the Clerk of House of 

Representatives 

12/ 2-4 Clearinghouse Northeast Regional 

Seminar 

Conference on Election 

Administration 

Philadelphia, PA 

FEC Commissioners and Staff 

12/ 3 FEC Campaign Finance Seminar 

Philadelphia, PA 

FEC Commissioners and Staff 

12/ 9- 11 Clearinghouse Southwest Regional 

Seminar 

Conference on Election 

Administration 

Austin, TX 

FEC Commissioners and Staff 

12/ 10 FEC Campaign Finance Seminar 

Austin, TX 

FEC Commissioners and Staff 
office. In those cases where a MUR is opened, 

Andersen suggested that the Audit Division issue an 

audit findings letter that does not address the MUR 

issue, but states that the General Counsel is reviewing a matter uncovered during the audit. 

5. Limit Commission Review of Audits: Andersen 

recommended that the current policy of requiring 

Commission review of all audit reports be modified 

so that Commission approval would be necessary only for audits which contained unusual findings or 

serious violations of the Act. 

6. Establish Proper Campaign Accounting Systems: 

Andersen noted that political committees with adequate record keeping systems produced more accurate disclosure reports. Andersen recommended, 

therefore, that the Commission develop a simple 

bookkeeping system specifically tailored to the needs 

of small part-time campaign committees. Such a 

manual would supplement the existing FEC manuals 

for political committees and Presidential campaigns. 

7. Perform Systems Review on Presidential Candidates: For Presidential campaigns that receive 

public funds, Andersen recommended that the FEC 

Audit Division perform a systems review prior to a 

Presidential Committee's first request for primary 

matching funds. Such a review would confirm that 

the Committee has adequate systems to properly 

safeguard and control public funds and to assure 

compliance with the Act. 

8. Continue the Random Audit Process: Andersen 

recommended that some type of random audit program would be necessary to validate risk criteria (see 

Number 1), and would serve as an incentive to campaign treasurers to maintain good records and proper 

documentation. 

9. Establish an Audit Advisory Committee: Andersen 

recommended the creation of a small, well qualified 

audit advisory committee. The proposed committee 

would confine its advice to policy matters and would 

not become involved in individual audit decisions. 

In addition to the above recommendations, Andersen 

also suggested that strict deadlines be established for 

the audit process, that timeliness of audit reports be improved and that a stronger personnel program (e.g., 

recruiting and formalized training programs) be instituted for the Audit Division. 

The Commission has begun consideration of steps to 

implement recommendations contained in the report. 

7 

AUDITS RELEASED TO THE PUBLIC 

The Federal Election Campaign Act requires the Com

mission to periodically conduct audits and field i

vestigations with respect to reports and statements file

under the Act. The Commission is also required to co

duct audits of all campaigns of Presidential candidat

who receive public funds. Audit reports that have bee

approved by the Commission either through a tally vo

or after discussion in open session, are released as fin

audit reports. If an audit report has been discussed 

open session, but has not been approved by the Com

mission, the report is available as an interim aud

report. Both final and interim reports are availab

through the Office of Public Records and Press Offic

In the list below, interim reports are designated by a

asterisk(*). All others are final audit reports. (Note tha

with the release of the Wallace report, the Commissio

has now completed the audits of all 1976 President

candidates who received public matching funds.) Th

following is a chronological listing of audits release

between September 4, 1979, and October 6, 1979: 

Date Mad

Audit Report Public 

1. George C. Wallace 9/ 4/7

The Wallace Campaign, Inc. 

2. Transportation Political Education 9/ 5/7

League (TPEL) 

3. Republican National Hispanic 9/ 19/7

Assembly 

4. Committee to Preserve the National 9/ 19/7

Republican Center 

5. James Russell Kirby 9/ 19/7

Kirby for Congress Committee, NC/ 2 

6. Democratic Executive Committee of 

Florida 

7. Write-In McCarthy Committee '76 

9/ 27/7

9/27/7
FEDERAL REGISTER 

NOTICES 

The following list identifies all FEC documents which 

appeared in the Federal Register between September 5, 

1979, and October 4, 1979: 

Federal Register 

Notice Title Publication Date 

1979-12 Opinion and Regulation 9/ 17/79 

Index Available 

1979-13 Proposed Regulations: 9/ 17/79 

Access to Public Records 

1979-1 4 Transfer of Regulations 9/ 27/79 

to New Chapter (Reorganizing and Renumbering 

of FEC Regulations) 

1979-15 Proposed Regulations: 9/ 27/79 

Presidential Primary 

Matching Fund (eligibility 

of candidates who exceed expenditure limit) 

FEDERAL ELECTION COMMISSION 

1325 K STREET, NW 

WASHINGTON, DC 20463 

OFFICIAL BUSINESS 

Citation 

44 FR 53800 

44 FR 53923 

44 FR 55781 

44 FR 55594 

STAFF 

FISCAL YEAR 1981 BUDGET 

On September 6, 1979, the Commission approved 

proposed budget for Fiscal Year 1981 . The budget 

quest of $11,530,160 contains 21 program packages 

provides for 312 permanent employees. 

The Commission submitted its proposed budget to 

President, the Congress and the Office of Managem

and Budget on September 17, 1979. 

FIRST CLASS MAIL 

POSTAGE & FEES PAI

FEC 

WASHINGTON, D.C. 

PERMIT NO. G·31