January 26, 1995
TO: BOARD OF GOVERNORS No. 15-95
RE: FEDERAL ELECTION COMMISSION DECISION
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As you may be aware, the Federal Election Commission ("FEC") recently announced the
settlement of a case involving a corporation’s activities with respect to certain fundraising
events for political candidates. Its decision in this case is significant in that, from an FEC
enforcement perspective, it narrows the permissible options for a corporation’s participation in
federal elections. In particular, the decision addresses itself to the general impermissibility of
the use of corporate resources to influence federal elections.
Enclosed for your information is a memorandum from the Institute’s FEC counsel that
analyzes the decision and provides guidance that is intended to assist in the development by
corporations of appropriate internal compliance guidelines.
At Matt Fink’s direction, we are in the process of reviewing existing guidelines for the
Institute in light of this recent decision. We will keep you advised of further developments in
this area.
Paul Schott Stevens
General Counsel