Subject: 527s and BCRA
From: AHayward@fec.gov
Date: 1/13/2004, 7:06 AM
To: election-law@majordomo.lls.edu, npersily@law.upenn.edu, rick.hasen@mail.lls.edu





Since people are discussing the political committee issue, I thought it
might be helpful to point out a couple of things.  As indicated by the
advisory opinion request submitted by ABC, available here:
http://www.fec.gov/aos/aor2003-37.pdf.
that requestor maintains both a federal committee and a separate 527
account.  People interested in doublechecking can find the ABC political
committee on our Web page, and it has an ID number of C00390047.

So, the questions raised on the list regarding what a "pure" 527 entity may
do, may not be squarely raised by the request under consideration, where a
group maintins a federal committee as well as a separate "non-committee"
account.  Just thought I'd raise this, since this point seemed not to be
considered in some of the postings.

Happy new year, in any event,

Allison