April 1994

Ta Ie of Contents

Regulati onsJ "Best Efforts" Rules Effective2 Comments Sought on Rules

Governing National VoterRegistration Form

Confe rences2 Washington. DC, Candidate Con-

ference Rescheduled for April 153 FEe to Hold Pittsburgh Regional

Conference. April 28-29

Public Funding3 LaRouche Campaign Receives

Court-Ordered Public Funding

Audit s3 FEC Releases Reports on '92

Kerrey Campaign and HoustonHost Committee

Statistics5 Off-Veal'Election Activity

Continues to Grow5 1993 Year-End PAC Count

Compliance5 FEC Publishes Nonfi lers

Reports6 Election Dates Changed in South

Carolina and Florida6 FEC Announces New Form for

48-Hour Notices

6 Advisory Opinions

Cour t Cases7 FEC v. NRSC (93-16 12)7 I ew Litigation

8 Index

Federa l Election Comm ission

Regulations

Revised "Best Efforts" RulesNow Effective

March 3 was the effective date ofrevis ed "best efforts" regulat ions onthe identification of contributors. Acommi ttee ' s report s will be con id­ered to be in compliance with theFederal Election Campaign Act (theAct) when the treasurer can showthat "bes t efforts" were used toobtain. maint ain and submit re­quired informat ion. 2 U.S.c.§432(i ).

The revised regu lat ions specifywhat steps must be taken to satisfythe "best efforts" standard forobt aining, mai ntain ing and repor tingthe identifica tion of indiv idualswhose contribut ion to the commit­tee agg regate over $200 in a calen­dar year. (Identification meansname, mailing address, occupationand ernplo yer.) The final rules( I I CF R J04.7(b)) and the ir expla ­nation and just ificat ion were pub­lished in the Federal Regi ster onOctober 27. 1993 (58 FR 57725).

nder the rev ised rules, a com ­mittee can demonst rate "be stefforts" by followi ng the repsbelow.

Request contributor identificationin the initial solicitation. Therequest for contributor informationmust appear clea rly and conspicu-

Volume 20. Number 4

ously on the response card enclosedin the so licitation and must inc ludethe followi ng stateme nt: "Federa llaw requires political committees toreport the name, mai ling address,occupation and name of employerfor each individual who se contribu­tions aggregate in excess of $200 ina calenda r year."

Mak e a follow -up request. ifnecessary. Within 30 days ofreceiving a solicited or unsolicitedcontr ibution aggregating over $200but lack ing required contributorinfor mation, the committee mustmake a wri tten or oral request forthe missing information. Therequest may not include an addi ­tiona l solicitation or material onanother subjec t but may thank thecon tributor for the contribution. Awritten reques t must include a pre­addre ssed card or enve lope for theresponse.

Report/he information. ore thattreasurers are requ ired to reportinformation that is not prov ided bythe contributor but that is availablein the committee ' s records for thetwo-year cycle, including its con ­tribu tor and fundrai sing records aswell as its previous reports.

File amendments 10 disclosepreviously missing information. Ifcon tributor information doe s notbeco me ava ilable until after thecontributions have been reported.the treasurer must e ither:

(continued on page 2)

1

Federal Effellon Commission RECORD

Regulations(cominued f rom page I)

• Sub mit with the next report amemo Schedu le A amendm entshowing the additiona! informationrece ived du ring that repo rtingperiod; or

• File amendments to prev iousrepo rts thai itemized the or igi nalconlributions. The amend mentsmust be filed on or before the nextreporting da le .

Under ei the r optio n. the newinforma tion should be cros s refer­en ced to the previou s repo rt wherethe contriburion was orig inallyitemized. Amended information isrequi red onl y for contributionsreceived during the current two-yearelectio n cyc le. •

Federal Election Commiro.<;ion999 E Strt't't. S WWashington, DC 20463

800/424.95302021219-34202lPJ219·3336 (TOO)

Trev or Potter, ChairmanDann y L. McDonald,

Vice ChairmanJ oan D. Aikens, CommissionerLee Ann EJliou , Commissione­J ohn w arren McGarry,

CommissionerSt oll E. T homas, Commissioner

J ohn C. Surina, Staff DirectorI.awrencl' :\1. Noble, General

Counsel

Published by the InformationDivision

Louise D. wid es, DirectorStephanil' f itzgerald, Editor

Comments Sought on RulesGoverning National VoterRegist ratlon Form

The Co mm ission seeks commentso n proposed rule s describing thecontent and format of a nationalmail -in vote r regi stration form. Thecreation of the form is One of theCommission ' s responsib ilitie s underthe Natio nal Voter Regi stration Act(NVRA) .' whic h was enacted toincrease the numbe r of regis teredvoters. The law will become effec­tive January 2,1 995 , in most stales .

As an additional duty under theNVRA. the agency mu st submit 10Congress . every two years , a reportasse ssing the impact of the NVRAand suggest ing improvement s invoter reg istra tion form s and proce ­d ures . T he proposed rulernakingseeks co mments on the specificvoter registration data thai Slateswould have (0 subm it to the FEe inorder for the agency to eval uateregi srranon activity for the Congres­sional report.

T he Notice of Prop osed Rule­making on the NVRA was publishedin the Fed eral Register on March 10(59 FR 112 11). T he deadl ine forcomments (which mu st be inwriti ng) is April I I. Th ey should besent to Susan E. Propper, AssistantGeneral Co unse l. 999 E St ree t NW,Washi ngton. DC 20463.

In drafting the propo sed ru les. theCom mission co nsidered responsesto an advance rulema king notice ! aswell as information on stare lawsand proced ures compi led by [heFEC's Nat iona l Clearinghou se onElection Administration . •

I For a summary Oflh~ NVRA. su lheJune 1993 Record.

1See the NOllemher 1993 issue.

Ap,-i1 /994

Conferences

\Vashington, DC, CandidateConference Rescheduled forApril 15

The February I I candidateco nference. cancelled because of asnow storm, has been rescheduledfor Apri l 15. It is open to newregi strants as well as those who hadreg istered for the ca nce lled confer­ence .

The one-day conference isdes igned to help candidates andthe ir campa ign staff comply withthe fede ral electio n law . In addition.participa nts will be briefed onapplica ble ta x. laws and Hou se andSe nate rules by staff from the IRSand the Con gre ssio nal ethicscommittees. The Hatch ACI will beco vered by a representative fro m theOffice of Special Co unsel.

If space allows. the FEC willaccept on-site registra tion s from8:00-8 :30 the mornin g of theconferenc e. A $ 10 late fee will beadded to the $105 registra tion fee .(The late fee will be added to allregistra tion s rece ived after April I. )T he conference fee covers mater ials.a continental breakfa st and lunch.

Th e confe rence will be held at theWashin gton Hilton and Towers.19 19 Connecticut Avenue, NW.Washington. DC. 20009 (2021797.5820). To receive the $ 125 per nigh tgroup ra te fo r a single roo m. not ifythe hotel that yo u will be attendingthe FEC conference.

For more information call theFEC: 8001424·9530 ", 2021219.3420. +

April 1994

FEC to Hold Pitts burgbRegiona l Conference,April 28-29

The FEC will hold a regiona lcon ference at the Pittsburgh VistaHotel on Apri l 28-29. This is the lastregiona l confe rence for the 1994e lectio n cycle.

The 11/2 day con ference willfea ture workshops for candidates,party committees and corporate andlabor PAC s. The workshops will bepresented by FEC Commissionersand staff and tax experts from theIRS.

The $1 15 reg istrat ion fee for theconfere nce covers three mea ls (twocontinental breakfasts and a lunch)and a reception. For more informa ­tion ca ll the FEC: 800/424-9530 or202/219-3420 . •

Public Funding

La Rouche Ca mpa ignReceives Court-O rderedPublic Funding

On Feb ruary 17 the Commiss ioncomplied with a court mandate tocertify Lyndon LaRouche as elig ibleto receive federal matching funds.The agency cert ified a $ 100,000threshold payme nt on February 22.The ca mpaign may request addi­tional marchi ng funds on Apri l I,1994.

The FEC had originally den iedMr. LaRouche' s reques t for match ­ing fu nds based on his past abusesof the public funding law and hiscriminal convictions for ma il fraud,includ ing fraudulent fundraising.

Ruling that the FEC did not havesta tutory authori ty to de ny federalfunds on tha t basis, the U.S. Courtof Appeals for the District ofColum bia Circuit, on July 2, 1993,instructed the agency to ce rtify thecandi date as el igible to receivepub lic funds.

Give n the appella te cou rt'sdecision and the Supreme Court 'srefusal to rev iew that decisi on,' theCommission cert ified the $100,000payment. T he agency d id not ce rtifyany interest payment despi te thecampaign 's claim that it was ent itledto interest accru ing since the Julyco urt decis ion. The FEC said thatthe cla im was not sup ported byfedera l law or court precedent. +

Audits

FE C Releases Audit Reportson '92 Kerrey Ca mpaign andHouston I-Iost Committee

The Commission recentlyreleased final aud it reports on twocommittees active in the 1992Presidential elect ions : the Kcrrcy forPresiden t committee and the Hous­ton Host Commi ttee. The reports arcsummarized below. They areavail ab le from the FEC 's PublicRecords Offic e.

Kcr rcy for Pr esidentKcrrcy for President, the 1992

Presidential primary campaign ofSenator Bob Kerrey, rece ived $2.2million in fede ral matc hing funds .The final audit report, which wasreleased to the public on March 3,included the Commission' s initialdete rm inat ions that the ca mpaignrepay to the U.S. Treasury:

- $ 1, 175 in outsta nding committeechecks never cashed by the payees ;aod

- $6,762 in profits ea rned throughovercharg ing the media for trans­portation and related services. (Thecommittee was a lso required to

I LaRouche I' . FEe. 996 F.2d 1263(D,C. Cir. / 993). cen . denied. _ U.s.-----' /14S.o. 550 (1993), See/heSeptember 1993 Recordfor a summaryof [ hi' appetloie court ruling.

Federal Election Commission RECO RD

refund $3,93 9 to the press organi­zations.)

The repaymen t amo unts willbecome final if the cam paign doesnot challenge them within 30 days.

ln other findings, the audit reportcon clud ed tha t the campaign:

- Accepted $5,238 in excessivecontribu tions result ing from itsfai lure to repay a staff member' sadva nces within the required timeframe ;

- Fai led to report requi red informa­tion for numerous transactions butlater disclosed the miss ing infor­mation in amended reports: and

- Failed to adequate ly documentabout $24,500 in disb ursementsbut later submitted the requireddocumentat ion.

Hou ston Host Com mitteeAs the site of the 1992 Repubti­

ca n natio nal conve ntion. Houstonestabl ished the host committee toencourage commerce and to projecta favorable image of the ci ty toconvent ion participants. Unlikeconven tion commi ttees. hostcommit tees do not receive publicfunds but mus t undergo an FEeaud it. The fina l audit report on theHo uston Host Committee wasreleased on January 5.

The report consis ted of thefollowing findings:

- The commi ttee accepted appar­ently prohibited dona tions total ing$42,680 from bus inesses locatedoutside the Houston metropolitanarea.

<T he committee insufficientlydocumented in-kind dona tions butlater demonstrated that the dona ­tions were used for permissiblehost com mittee activities.

- The committee failed to disclosureabout $930,200 in debts andob ligat ions. In Februa ry 1993, thecommittee filed amended reportsdisclosing the debts. •

3

Federal ElecliOIl Commission RECO RD April 1994

House and Senate Campaign Activity in Year Before Election(in millions of dollars)

200 r- - - - - - - - -

175

150 f--- - - - - - t

125

100

25

87 89 91Receipts

93 87 89 91 93Disbursements

87 89 91 93Cash on Hand

87 89 91 93Contributions and Loans

from the Candidate

45 -

151- - - - -

20 -

25 -

10 =-

50,- - - - -

30

35

40

87 89 91 93Contributions from PACs

and Other Committees

~ -

f-

I""""""""" r-

1-- I-LP-1

r--

- ,- ,- I-

- i- i- -

o

20

40

50

30

10

87 89 91 93Contributions from

Individuals

20

40

10

Democratic and Republican House Campaigns: Fundraising in Yea.' Before Election(in millions of dollars)

50

4

April /994 Fedemt Election Commission RECORD

Compliance

I Nonconnected PACs must use their own f unds to pay [undraising and adnunistra­nve exp enses. while the othrr categories oj PAC.~ have co rporate or labo r " COIl'

nec ted or!<(lllizariO/ls" that a re permiued to pay those expenses for thei r PACs . 011the other hand, nonconnected PAC.~ may solicit contributions fro m the gene ralpubtic. while sot icuauons hy corporate and labor PACs (Ire resmctea.

Office Sought

Trade/ Cor p. w/oMember/ Coop- Ca pital Non-

Year Corpora te Labor Health erauve Stock connected I Tota l

1984 1,682 394 698 52 130 1,053 4,0091985 1,710 388 695 54 142 1,003 3,9921986 1,744 384 745 56 151 1,077 4,1571987 1,775 364 865 59 145 957 4,1651988 1.816 354 786 59 138 1,1 15 4,2681989 1,796 349 777 59 137 1,060 4, 1781990 1,795 346 774 59 136 1.062 4. 1721991 1.738 338 742 57 136 1,083 4,0941992 1,735 347 770 56 142 1,145 4, 1951993 1,789 337 76 1 56 146 1,121 4,2 10

Candidate Conumuee

fEC Publishes Non!ilersThe ca ndidate commi ttees listed below failed to file required campaign

finance reports . T he list is based 011 the FEC pre ss releases of March 4 andMarch I I . The Commission is requ ired by law to publicize the nam es ofnonfiling authorized committees. 2 U.S.c. §438(a) (7 ). The age ncy pursue senforcement actions against nonfilers on a case-by -case basis. •

ReportI\ot Filed

1993 Year-End PAC CountAt the end of J993, the number of federa lly reg istered PACs had grown to

4,210, an increase of 185 PAC s since the last count was taken s ix monthsago. However , when comparing year-end 1992 and 1993 PAC counts, 1993sho wed an increase of onl y IS PACs.

T he table below listing year-end PAC cou nts shows that the total num berof PACs has remained relatively s table over the last 10 years, with thegreatest fluctuation in 1986 , when the PAC tota l grew by 165.

T he number of PAC s doe s not necessarily correspond with financialactivity , since many reg istered PACs have little or no activity .

For stat istics on semiannual PAC counts taken sinc e 1975, ord er the FECpress relea se of February II, 1994. Call 800/424-9530 (ask for PublicRecords) or 202/219-4140. +Year- End PAC Counts. J984-199.'

Statistics

Off-Year Election ActivityContinues to Grow

During l 993, an off-electionyear, 1994 House and Senatecampaigns raised 7 percent moreand spent 15 percent more thancandidates did in 1991. While theseincreases in early campaign f inanceactiv ity have recurred in the pastfour cyc les (see first graph), they donot necessarily mean that the growthwill continue over the entire cy cle.

T he boost in 1993 activ ityfo llows a 40 percent growth inCongressional spending duringele ct ion cyc le 1992 , when Con gres­sional redistricting and incumbentdepartures resul ted in con siderablyrnore House challengers and open­seat candidates than in previouscycles.

T he depart ure of several Mem­ber s of Congress in the 1994ele ction cycle has similar ly createda large number of open -seat races,although the total for the cyc le isexpected to fall short of the l 992total.

T he small graph s compare thesources of funds raised by Demo­cra tic and Republican House andSenate candidates in off-electionyea rs. T he graphs show that , in1993. campaigns relied moreheavil y on contributions fromindividual s and from the candidatethan campaigns had in previouscycles .

Allthe graphs are based on theFebruary 15 FEC press relea se,which lists the 1993 campa ignfinance data of 1994 House andSenate candidates and compares thatactivity with past off-electio n year s.To order the press release, call 80014 24-9530 (ask for Public Records)or 2021219-4140. +

Geraldine A. Sam for U.S. CongressWin Committee for Bonnie AbbottEddie Bernice Johnson for CongressCitizens for Huff in Congress

House, TX/09House, TXIl 5House, T X/30House. ILl08

Pre-primaryPre-primaryPre-primaryPre-primary

5

Federal Election Commission RECORD

Reports

Election Dates Changed inSouth Carolina and Florida

Sou th Carolina and Floridarecently rescheduled their e lectionsas follows:

• South Caro lina primary: August 9(previously June 14);

• SOUlh Caro lina runoff: August 23(previously June 21) ;

• Florida primary: September 8(prev iously September 6, RoshHashanah);

• Florida runoff: October 4 (nocha nge).

The ballot access filing deadli nefor the South Carolina primary hasbeen changed to Jun e 15 (noon);there is no change to the Floridaballo t acces s deadline (May 13,noon).

The pre-elect ion reportingdead lines for these elections arcshow n in the table. For moreinformation on 1994 reportingreq uireme nts, see the January issueor order the 1994 reporti ng handout(ca ll 800/424 ·9530 or 2021219·3420). +

FEe Announces New Formfor 48-Hour Notices

The Commission recently senteach registered cand ida te committeea copy of FEC Form 6, a new formto be used for 48-hour notices.

Candidate committees must filethese special notices to disclosecontributions of $ 1,000 or more(including contributions and loansfrom the cand idate) received lessthan 20 days , but more than 48 ­hours, before election day . I I CF R104.5.

Forty-e ight hour notices must bereceived by the federal and statefiling offices within 48-ho urs of thecommittee's rece ipt of the contribu­tion. Because the treas urer's signa­ture is not required, 48 -hour noticesmay be faxed. (Other reports andstatemen ts, however, may not be.)

Committees are free 10 use Form6 or 10 disclose the information in aleiter. Form 6, like all FEC forms,may be photocopied to makeadditional blank forms . •

April 199.1

AdvisoryOpinions

AO 1993-24Definition of Member

The Nat ional Rifle Association ofAmerica (N RA), an incorporatedmembership group, has severa lclasses of membership, but onlyindividuals belongi ng to two ofthose classes are consi dered "mem­bers" under recently revised regula­tions at II CF R 114.1(e). Onlythose two groups, therefore, areelig ible to rece ive PAC solicitationsand partisan comm unicatio ns fromNRA.

NRA as " Members hipAssocia tio n"

Under the new "member" regula­tions, NRA q ualifies as a "member­ship association" becau se it:( I) provides for members in itsarticles and bylaws; (2) seeksmem bers (it distributes promotionalmembership materials that includean appl ication form ); and (3) ac­knowledges the acceptance ofmembersh ip (it sends new membersa members hip card or certi ficate ).11 CF R 114.1(e)(I).

Revised Repo rting Da tes for Florida a nd South Ca r olinaPre-Primary a nd Pre-Runoff Reports

RegJ Cert.Close of 1\lailing Filing

Election Day Books ' Date 2 Date 2

South Carolina Aug. 9 Primary July 20 July 25 July 28Aug. 23 Runoff Aug. 3 Aug. 8 Aug. I I

Florida Sept. 8 Primary Aug. 19 Aug. 24 Aug. 27 \Oct. 4 Runoff Sept. 14 Sept. 19 Sept. 22

/ The date indicates sheend of the reporting period.

1 Repor ts sent by registered or certified mail must be postmarked by the mailingdate . Ofherwise they must be received by the fil ing date.

1 August 27 is a Saturday, when fi ling offices are closed. Florida pre-primaryreports must therefore reach the federal and Flor ida Slate filing offices hy Friday,Augllst 26, unless they are sent registered or certified, in which case they must bepostmarked no later than AugU.H 24.

6

Definition of M emberThe new reg ulations list the

req uirements necessary for personsto qua lify as "members" of amembers hip assoc iatio n. UnderII CFR 114.2(e)(2), members mustaff irmatively respond to the invita ­tio n to join (a ll NRA membersappear to mee t this requirement) andmust satisfy one of the followi ngthree requ ire ments:

I. Members must have somesignificant financi al attachmentto the association beyo nd thepayment of dues (voting rightsnot required); or

2. They must pay regular dues andhave the right to vote for at leastone member of the highestgoverning body of the associa tion

April/ 994

or for those who select at leastone member of that body; or

3. They must have the right to votefor all of those on the highestgoverning body. II CFR11 4.1(e)(2)(i)-O ii).

~RA 's Nonvoting Memb ershipAnnual members I pay dues of

$20 and $25 a year, depending onthe membership class, but they lackvoting rights and therefore fail tosatisfy requirements 2 and 3. No r dothey meet requirement I. since anannual membership fee does not. byitself, represent a "significantfinancial attachment." Conse­quently, they are not "members" forpurposes of receiving NRA PACsolicitations and partisan communi­cations.'

:\IRA's Voting Membershi pKRA's voting classes cons ist of

two major groups: Individuals whohave remained annual membersmore than five consecutive years;and various types of lifetimemembers (i.e.• those who make aoneti me dues payment of $500 ormore). T hese members have thepower to vote for t\ RA's highestgoverning body, the board ofdirectors . Beca use of their duesobligation and extensive votingrights, these individuals meet thedefinition of "member" under bothrequirements 2 and 3. Honorary

I The f ollowing mem bershi p classes areannual members (abO/a two-thirds ofNRA 's tota l membership ): adultmembers. a.5.lociwe members (spo usesofa/her members ), junior members(under 21) and senior members (OI'er65).

~ /II a 1984 enforcement case (M UR1765), the Commission had de/erminedthOiNRA ',' solicitation of in nonvotingmembers was permissible. However.severe! odl'isory opinions issue d afterthat decision , but years bef ore the newregulations beca me law , limitedsalicua uons 10 voting members only.See, for example. Advisory Opinions/988-38. /987-/3 and /984-33.

mem bers, who are elected by theboard to receive free lifetimememberships with full voting rights,qualify as members under require­ment 3.

Date Issued: February 3, 1994:Length: 9 pages plus a-page concur­ring opinion filed by CommissionerJoan D. Aikens and 22-page dissent­ing opinion filed by CommissionerLee Ann ElIio11 . •

Advisory Opinion RequestsThe advisory opinion requests

(AORs) listed below are availablefor review and comment in theFEe' s Public Records Office.

AOR 1994·JCompany's plan to match PACcontributions with charitabledonations in twice-yearly solicita­tion of expanded class. (Enviro­Source. Inc.; March J. 1994;2 pages plus 12-page attachment)

AO R [994-4Definition of member applied toorganization's various membershipclasses. (U.S. Chamber of Com­merce; March 14, 1994; 10 pagesplus 43-page attachment) •

Court Cases

FEC v, NRSC (93·1612)On February 8. 1994. the U.S.

District Court for the District ofColumbia ordered this casereopened. The court had dismissedthe suit in November 1993, based ona recent appellate court holding thatthe FEe' s composition wasunconstitutional and that the agencytherefore lacked authority to bringan enforcement action. FEC v. NRAPoliti cal Victory Fund (NRA ),6 F.3d 8211D.C. CiL 1993).

In NRA, the coun of appeals heldthat the presence of the two Con-

Fnl(l"al Ek c/lon Commission Rt:CORD

gressicnally appointed, nonvotingCommissioners W 'CSecretary of theSenate and the Clerk of the House)in an independent agency violatedthe Constitution' s separation ofpowers. However. based on aseverability clause in the FederalElection Campaign Act (2 V.S.c.§454), the court concluded that "theunconstitutional ex offic io member ­ship provision can be severed" fromthe statute. permitting a reconsti­tuted Commission to continue tooperate.

Immediately following the NRAruling. the FEC reconstituted itselfas a six-member body ent irelycomposed of Commissionersappointed by the President. Toensure uninterrupted enforcement ofthe law, the newly constitutedagency ratified its earlier findings inenforcement cases and authorizedongoing litigation .' including FECv. NRSC. (The FEC' s complaint,which alleged that the NationalRepublican Senatorial Committeeexceeded the contribution limits. issummarized in the June 1993Record.)

Due to the FEC's remedia lactions, the district court reversed itsearlier decision that NRA was abasis for dismissa l. The remainingassertions in t\RSC' s motion todismiss are now pending before thecourt. •

New Litigati on

FEe v. Mi chigan RepublicanState Com mittee

The FEe claims that the Michi­gan Republican State Committee,the federal account of the MichiganRepublican Party. and its treasurer:

• Knowingly accepted contributionsthai exceeded the limits by a t01a1

(con tinued on page 8)

I For summary of the NRA decision andthe FEC 's response , see the Decem ber1993 inaI'.

Federal Election Commission RECORD

Court Cases(continued fr om page 7)

of $5.550. a violation of 2 U. .c.§44Ia(f);

• Depo ited $35.655 in nonfederalfunds transferred by the Republi­can National Committee, a viola­tion of II CFR 102.5; and

• Spent $8.298 in excess of the§44I a(d) party expenditure limitfor the party' s nominee in the 1984U.S. Senate race in Michigan. aviolation of 2 U.S.c. §441a(f).

The FEC asks the court to assessa civil penalty against defendantsand order them to tran fer themisdeposited fund to the nonfed­eral account of the MichiganRepublican Party. The agency alsoasks that the court permanentlyenjo in defendants from committingsimilar violations again.

U.S. District Court for theWe tern District of Michigan. CivilAction o. 5:94-CV-27. February17. 1994. +

FEDERAL ELECTION COMMISSION999 E Street, NW

Washington, DC 20463

Official Business* Printed on recycled paper

Index

The fir t number in each citationrefer to the "number" (month) ofthe 1994 Record issue in which thearticle appeared. The second number.following the colon. indicates thepage number in that issue. Forexample. " 1:4" means that thearticle is in the January issue onpage 4.

Advisory Opinions1993-18: Corporate plan to foster

political participation. 2: I1993-19: Retiring 1984 Presidential

debt. I :131993-20: Purchase and distribution

of candidate biography. 2:31993-2 1: Preemption of Ohio law.

2:41993-22: Use of excess funds by

retired House Member. 3:51993-23: PAC disaffiliation. 3:61993-24: Definition of member. 4:61993-25: Preemption of state law

restricting contributions fromlobbyists, 3:6

April /994

Court CasesFECv. __- Michigan Republican Slate

Committee. 4:7- I ational Republican Senatorial

Committee (93-16 12). I : 12; 4:7- Survival Education Fund. Inc.• 3:1- Williams. 1:1 2

v. FEC- Center for Responsive Politics.

1:12- Freedom Republicans, lnc., 3:3- Froelich, 2:2- LaRouche (92-1100), I :12

ReportsApril. 3: IOklahoma special. 3:7ScheduIe for 1994. 1:4; correction.

2:1- change in Florida and South

Carolina election dates, 4:6

800 Line rticlesRegistration by candidates and their

committees. 1:1 4

Bulk Rate MailPostage and Fees Paid

Federal Election Commiss ionPermit Number G-31