Federal Election Commission Main Page
FEDERAL ELECTION COMMISSION
Washington, DC 20463
June 22, 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Carol A. Laham, Esquire
D. Mark Renaud, Esquire
Wiley Rein & Fielding, LLP
1776 K Street, NW
Washington, DC 20006
RE: AOR 2006-14
Dear Ms. Laham and Mr. Renaud,
This refers to your letters received on March 24 and April
6, 2006, requesting an advisory opinion on behalf of the National
Restaurant Association's political action committee ("NRA PAC"),
concerning the application of the Federal Election Campaign Act
of 1971, as amended, and Commission regulations to a proposal by
NRA PAC to communicate with the general public to expressly
advocate the election or defeat of, and solicit contributions to,
certain clearly identified candidates for Federal office. NRA
PAC also proposed to solicit contributions from the general
public earmarked for Federal candidates, which NRA PAC would then
collect and forward to the designated candidates.
Earlier today, the Commission considered Agenda Document No.
06-44, a copy of which is enclosed. Agenda Document No. 06-44
contained three alternative draft advisory opinions (Drafts A, B,
and C) responding to your request. The Commission voted on Draft
C, which failed by a vote of 3-2. See 2 U.S.C. 437c(c) and
437d(a)(7) (approval of an advisory opinion requires the
affirmative vote of four members of the Commission). The
Commission did not vote on Draft A or Draft B. No other motions
were voted upon.
Accordingly, pursuant to Commission regulations at 11 CFR
112.4(a), you are hereby advised that with this letter the
Commission has concluded its consideration of Advisory Opinion
Request 2006-14.
Sincerely,
(signed)
Lawrence H. Norton
General Counsel
Enclosures