Federal Election Commission Advisory Opinion Number 1994-4

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Judith K. Richmond
Associate General Counsel
U.S. Chamber of Commerce
1615 H Street, N.W.
Washington, D.C. 20062

RE: Advisory Opinion Request 1994-4

Dear Ms. Richmond:

This refers to your letters dated March 11 and May 19,
1994, on behalf of the U.S. Chamber of Commerce ("the
Chamber") concerning the application of the Federal Election
Campaign Act of 1971, as amended, and Commission regulations
to the Chamber's payments for partisan communications and
contribution solicitations to various classes of Chamber
members.

Enclosed are Agenda Documents #94-63 and #94-63-A which
the Commission considered on June 23 and July 14, 1994. On
July 14, the Commission failed to approve these documents and
was unable to agree to issue any opinion. Two separate
motions were offered. One to approve the cited documents and
the other to refer the documents back to the Office of
General Counsel with directions to prepare another draft.
Both motions failed by votes of 3-3. See 2 U.S.C. 437c(c),
437d(a)(7) [approval of an advisory opinion requires the
affirmative vote of four members of the Commission].

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 1994-4.

Sincerely,

Lawrence M. Noble
General Counsel

BY: ______sig________________
N. Bradley Litchfield
Associate General Counsel

Enclosures