Your letters state that AISA is an incorporated, non-profit nonstock trade association. Its membership includes shippers' cooperatives that are, for the most part, non-profit, nonstock incorporated associations of business corporation that join together in order to take advantage of collective volume rate savings in the movement of freight. The cooperatives are funded by their members who pay them for the performance of services. The daily operation of each cooperative is handled by employees hired either by the cooperative's board of directors or by a management corporation chosen by the cooperative's board of directors.
Cooperative associations run by management corporations have a distinctive organizational structure.
You explain that generally the management corporation is formed for the specific purpose of serving a particular cooperative. It does not engage in any activity other than management of the cooperative, and it supplies all personnel needed to run the latter, which, strictly speaking, has no employees of its own. At the annual meeting of AISA members, the vote of a shipper's cooperative run by a management corporation is cast by the cooperative's general manager, who is employed by the management corporation. The personnel who handle the business of only AISA member cooperatives thus present a unique and exclusive class of personnel and may be regarded as the member cooperative's own executive and administrative personnel since they, and they alone, run the cooperative's business. All statutory provisions and Commission regulations pertinent to a trade association's solicitation of its member corporation's executive or administrative personnel and their families are, of course, applicable.