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    "seq": 1,
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    "ocrText": "Ronald Reagan Presidential Library\nDigital Library Collections\nThis is a PDF of a folder from our textual collections.\nCollection: Roberts, John G.: Files\nFolder Title: JGR/Campaign Debts (1 of 2)\nBox: 6\nTo see more digitized collections visit:\nhttps://reaganlibrary.gov/archives/digital-library\nTo see all Ronald Reagan Presidential Library inventories visit:\nhttps://reaganlibrary.gov/document-collection\nContact a reference archivist at: [email protected]\nCitation Guidelines: https://reaganlibrary.gov/citing\nNational Archives Catalogue: https://catalog.archives.gov/\nTHE WHITE HOUSE\nWASHINGTON\nFebruary 28, 1983\nMEMORANDUM FOR FRED F. FIELDING\nFROM:\nJOHN G. ROBERTS\ngod\nSUBJECT:\nFundraiser to Retire Debt of Jim Coyne's\n1982 Congressional Campaign Committee\nJim Coyne, Special Assistant to the President for Private\nSector Initiatives, has asked for guidance concerning a\nfundraiser to retire the debt owed to him by his 1982\ncongressional campaign committee. This office has recently\nprovided guidance on the subject of retiring campaign debts\nto David Emery and Margaret Heckler, who presented similar\nquestions. Coyne's situation is somewhat different than\nthat of either Emery or Heckler since Coyne is already on\nboard as a Special Assistant to the President. At the same\ntime, however, his situation would seem to raise fewer\nproblems, because his office performs no regulatory role nor\ndoes it typically have business dealings of any sort with\nthe private sector. And, in any event, the memoranda to\nEmery and Heckler advised them that they should consider\nthemselves subject to federal employee and White House\nstandards as if they had already been appointed, to avoid\nappearance problems.\nOne provision that was not considered in the Emery or\nHeckler memoranda, but should be in Coyne's case, is whether\ncommittee payments to Coyne would violate 18 U.S.C. § 209 as\nsupplementations of his federal salary. This section\nprohibits supplementation of salary \"as compensation for\nservices as an officer or employee of the executive\nbranch.' The critical question is whether the payor or\nrecipient intended the payment to be for government services\nor for something else. In this case the committee rather\nclearly would be paying Coyne not for his government\nservices but because it is liable on a pre-existing debt.\nContributions to the committee must, however, be considered\nindirect payments to Coyne, and some contributors may be\nmotivated by a desire to supplement Coyne's federal salary.\nFollowing the established OGE test for $ 209 matters, Coyne\nand the Committee should be advised not to accept any gift\nthat they have reason to believe would not have been made\nbut for Coyne's Federal employment.\n-2-\nI have revised the Emery and Heckler memoranda for use in\nCoyne's case. In particular, I have deleted the requirement\nthat Coyne provide us with a list for pre-clearance of those\nindividuals or entities his committee intends to solicit.\nSince Coyne's office does not regulate or have dealings with\nany particular industry, such a list would be meaningless.\nWith your approval, I will review this informally with the\nOffice of Government Ethics. Assuming they agree with its\nsubstance -- as they did in the cases of Emery and Heckley\n-- we can then send it on to Coyne.\n,\nTHE WHITE HOUSE\nWASHINGTON\nDate\n3.14.83\nSuspense Date\nMEMORANDUM FOR: John\nFROM:\nDIANNA G. HOLLAND\nACTION\nApproved\nPlease handle/review\nFor your information\nFor your recommendation\nFor the files\nPlease see me\nPlease prepare response for\nsignature\nX\nAs we discussed\nReturn to me for filing\nCOMMENT\nOK\n-\nmit JGR\nwaiting to hear\nfrom OGR. status?\nTHE WHITE HOUSE\nWASHINGTON\nFebruary 28, 1983\nMEMORANDUM FOR FRED F. FIELDING\nFROM:\nJOHN G. ROBERTS\nor\nSUBJECT:\nFundraiser to Retire Debt of Jim Coyne's\n1982 Congressional Campaign Committee\nJim Coyne, Special Assistant to the President for Private\nSector Initiatives, has asked for guidance concerning a\nfundraiser to retire the debt owed to him by his 1982\ncongressional campaign committee. This office has recently\nprovided guidance on the subject of retiring campaign debts\nto David Emery and Margaret Heckler, who presented similar\nquestions. Coyne's situation is somewhat different than\nthat of either Emery or Heckler since Coyne is already on\nboard as a Special Assistant to the President. At the same\ntime, however, his situation would seem to raise fewer\nproblems, because his office performs no regulatory role nor\ndoes it typically have business dealings of any sort with\nthe private sector. And, in any event, the memoranda to\nEmery and Heckler advised them that they should consider\nthemselves subject to federal employee and White House\nstandards as if they had already been appointed, to avoid\nappearance problems.\nOne provision that was not considered in the Emery or\nHeckler memoranda, but should be in Coyne's case, is whether\ncommittee payments to Coyne would violate 18 U.S.C. $ 209 as\nsupplementations of his federal salary. This section\nprohibits supplementation of salary \"as compensation for\nservices as an officer or employee of the executive\nbranch.' The critical question is whether the payor or\nrecipient intended the payment to be for government services\nor for something else. In this case the committee rather\nclearly would be paying Coyne not for his government\nservices but because it is liable on a pre-existing debt.\nContributions to the committee must, however, be considered\nindirect payments to Coyne, and some contributors may be\nmotivated by a desire to supplement Coyne's federal salary.\nFollowing the established OGE test for $ 209 matters, Coyne\nand the Committee should be advised not to accept any gift\nthat they have reason to believe would not have been made\nbut for Coyne's Federal employment.\n-2-\nI have revised the Emery and Heckler memoranda for use in\nCoyne's case. In particular, I have deleted the requirement\nthat Coyne provide us with a list for pre-clearance of those\nindividuals or entities his committee intends to solicit.\nSince Coyne's office does not regulate or have dealings with\nany particular industry, such a list would be meaningless.\nWith your approval, I will review this informally with the\nOffice of Government Ethics. Assuming they agree with its\nsubstance -- as they did in the cases of Emery and Heckley\nM\n-- we can then send it on to Coyne.\nTHE WHITE HOUSE\nWASHINGTON\nMarch 1, 1983\nMEMORANDUM FOR THE HONORABLE JAMES COYNE\nSPECIAL ASSISTANT TO THE PRESIDENT\nPRIVATE SECTOR INITIATIVES\nFROM:\nFRED F. FIELDING\nCOUNSEL TO THE PRESIDENT\nSUBJECT:\nRetirement of the Debts of the\nJames Coyne for Congress Committee\nAs a Special Assistant to the President for Private Sector\nInitiatives, you are in a unique position with regard to\nyour efforts to retire the campaign debts of your 1982\nCongressional Campaign Committee (the \"Committee\"). As a\nSpecial Assistant to the President, and an SES employee of\nthe Department of Commerce detailed to the White House, you\nare subject to the Standards of Ethical Conduct for\nGovernment Officers and Employees as set forth in Executive\nOrder No. 11222, and, as a matter of policy, the Standards\nof Conduct for White House Employees, 3 C.F.R. § 100.735.\nFurther, several provisions of the Federal Criminal Code, 18\nU.S.C. §§ 201, 203, 209, 210, 211, 602, 603 and 607 are\napplicable to you as a Federal employee and should be\nreviewed carefully in the course of retiring the Committee's\ndebts. Since the Committee owes a substantial debt to you\nas an individual, contributions to the Committee must be\nconsidered indirect payments to you.\nOutlined below is our analysis of the restrictions of each\nof the statutory provisions / and the Executive Order noted\nabove which are or should be considered applicable to your\nactivities in connection with any efforts to retire the\ndebts of the Committee. Additionally, we have attached a\nsummary of the general guidelines which you and your\ncampaign committee should follow in planning the Committee's\nfundraising activities to retire the Committee's debts.\n* / All references to statutory requirements contained\nherein, unless otherwise specifically noted, are paraphrases\nof the referenced statutes. Accordingly, when in doubt as\nto the applicability of these statutory provisions to\nspecific facts or circumstances, reference should be made\ndirectly to the statute in question.\n-2-\n18 U.S.C. § 201: provides in part that any public official\nmay not solicit, accept, receive or agree to receive\nanything of value for himself or for any other person or\nentity, in return for being influenced in his performance of\nany official act; for being induced to do or omit any act in\nviolation of his official duty; or being influenced in his\ntestimony under oath in any proceeding before any court or\nCongressional hearing. Violations of this provision are\npunishable by fine, imprisonment or both, and possible\ndisqualification from holding any office of honor or trust\nunder the United States.\nAdditionally, 18 U.S.C. $ 201 prohibits any public official\nfrom soliciting, accepting, receiving or agreeing to receive\nanything of value for himself or for another person or\nentity for or because of any official act, including testi-\nmony before any court or Congressional committee, to be\nperformed by him. Violations of this provision are punish-\nable by fine, imprisonment or both.\nUnder certain circumstances these restrictions may preclude you\nor the Committee from accepting any contributions from\nindividuals or political committees, including political action\ncommittees (PAC's), whose specific purpose in making such\ncontribution is to influence your official acts. To avoid\nany appearance of a violation of this provision, you and the\nCommittee should not solicit or accept contributions from any\nindividual, political committee or organization which has\ninterests or represents individuals or organizations having\ninterests that are now or will be affected by the actions or\nnon-actions of the Office of Private Sector Initiatives.\n18 U.S.C. $ 203: prohibits Members of Congress, or officers or\nemployees of the Federal government from receiving, soliciting,\nor seeking any compensation for services rendered by them or\nany other person on behalf of another person in relation to any\nproceeding, request for a ruling or other determination,\ncontroversy or particular matter in which the United States is a\nparty or has a direct and substantial interest. Violation of\nthis provision is punishable by fine, imprisonment or both.\nAccordingly, you and the Committee should not accept contribu-\ntions from any individual, political committee or organization\nif the acceptance of such contribution could reasonably be\nperceived as compensation for anticipated services to be\nrendered by you as a Federal employee on behalf of such\nindividuals or groups represented by such political committees.\nHence you should not solicit or accept contributions from\n-3-\nentities which have or will have interests pending before\nthe Office of Private Sector Initiatives or before other\nFederal government agencies which could reasonably be\nconstrued to be subject to significant influence by you.\n18 U.S.C. § 209: prohibits supplementation of the salary of\na Federal official as compensation for his services as a\nFederal official. No payments to the Committee may be\nsolicited or accepted as additional compensation for your\nservices as a Special Assistant to the President.\nContributions may only be solicited and accepted to retire\nthe Committee's preexisting debt. As a general matter, you\nand the Committee should not accept any contributions which\nyou have reason to believe would not have been made but for\nyour current Federal employment.\n18 U.S.C. § 210: prohibits the payment of money or anything of\nvalue to any person, firm or corporation in consideration of the\nuse or promise to use any influence to procure any appointive\noffice in the United States.\n18 U.S.C. $ 211: prohibits the solicitation or receipt, either\nas a political contribution or personal emolument, of any money\nor thing of value in consideration for the promise of support or\nuse of influence in obtaining for any person any appointive\noffice in the United States.\nOut of an abundance of caution, these prohibitions should be\nviewed by you and the Committee as prohibiting the acceptance of\nany contributions from individuals whom you may wish to appoint\nto positions within your office, or who are seeking\nappointments to positions within your office or any other\nposition within the Federal government.\n18 U.S.C. § 602: prohibits any candidate for the Congress, any\nSenator or Congressman, or any officer or employee of the United\nStates or any department or agency thereof, from knowingly\nsoliciting political contributions from any other such officer or\nemployee.\nThus, you and the Committee should take the steps necessary to\nensure that no Senators or Congressmen, or officers or employees\nof the Federal government, are knowingly solicited for contri-\nbutions to the Committee.\n18 U.S.C. $ 603: prohibits an officer or employee of the Federal\ngovernment from making political contributions to their\nsupervising officers in the Federal government. For purposes of\nthis provision, a contribution to a political committee\nauthorized by an officer of the Federal government is considered\na contribution to such officer.\n-4-\nThe Committee, therefore, should not accept any contributions\nfrom individuals presently employed by your office.\n18 U.S.C. § 607: prohibits the solicitation or acceptance\nof a political contribution in a Federal building. There is\nan exception to this prohibition for the receipt of\ncontributions in Federal buildings by persons on the staff\nof a Senator or Congressman under specific circumstances,\nbut such exception would no longer be applicable to you or\nthe Committee.\nThis provision would preclude all solicitation of contributions\nat the Office of Private Sector Initiatives. Further, in\nthe event that any political contributions to the Committee\nare received at your office, such contributions should be\nreturned directly to the donor with instructions as to the\nappropriate mailing address for the Committee.\nSection 201 (c) of Executive Order No. 11222 provides in part:\nIt is the intent of this section that employ-\nees avoid any action\nwhich might result\nin, or create the appearance of:\n(1) using public office for private gain;\n(2) giving preferential treatment to any\norganization or person;\n(3) impeding government efficiency or\neconomy;\n(4) losing complete independence or impar-\ntiality of action;\n(5) making a government decision outside\nofficial channels; or\n(6) affecting adversely the confidence of\nthe public in the integrity of the\nGovernment.\nYou and the Committee should, therefore, avoid soliciting or\naccepting unsolicited contributions whose receipt will create the\nappearance of precluding your exercise of independent judgment or\nimpartial action with regard to the issues coming before\nyou. Accordingly, you and the Committee should not accept\ncontributions from individuals or political committees who\nhave not previously contributed to your political committees\nand whose contributions, in light of your current position,\ncould be viewed as efforts to affect your independence and\nimpartiality in issues coming before you. Additionally, you\nand the Committee should not solicit contributions in any\nmanner that suggests that you are using your appointment to\nFederal office for personal gain. Solicitations by the\nCommittee referring to your current position could create\nsuch an appearance, and should, therefore, be avoided.\n- -5-\nFinally, the issues raised by settlement of the debts of the\nCommittee for less than their full amount are governed by the\nprovisions of the Federal Election Campaign Act of 1971, as\namended, and its regulations. Although a full discussion of\nthose provisions is beyond the scope of this memorandum, you\nshould be aware that all of the above considerations which apply\nto contributions would also apply to the forgiveness of all or\npart of an existing debt.\nAttachment\nSUMMARY OF GENERAL GUIDELINES FOR\nACCEPTANCE OF POLITICAL CONTRIBUTIONS\nI. GENERAL RULE:\nThe Committee should not solicit or accept contributions\nfrom any individual, political committee, or organiza-\ntion (a) if the individual or entities represented by\nthe Committee or organization has interests in matters\nwhich are or may be pending before your office or is\naffected or regulated by any policies, decisions or\nregulations of your office, or (b) if such solicitation\nor acceptance would create the appearance of precluding\nyour exercise of independent judgment or impartial\naction with regard to the issues coming before you, or\notherwise affect adversely the confidence of the public\nin the integrity of the government.\nII. SPECIFIC PROHIBITIONS:\nDo not accept any contributions from individuals whom\nyou may wish to appoint to positions within the Office\nof Private Sector Initiatives.\nDo not accept any contributions from individuals who\nare seeking appointments within the Office of Private\nSector Initiatives or any other position within the\nFederal government.\nDo not solicit any Senators, Congressmen or officers or\nemployees of the Federal government for contributions\nto the Committee.\nDo not accept any contributions from individuals\npresently employed by the Office of Private Sector\nInitiatives.\nDo not solicit or accept any contributions in your\nFederal offices. If any contributions are received at\nthese offices, such contributions should be returned\ndirectly to donors with instructions as to the\nappropriate mailing address of the Committee.\nDo not solicit contributions in any manner which\nsuggests that you or the Committee are using your\nappointment to Federal office for your personal gain.\nSolicitations should not include reference to the fact\nof your current Federal employment.\nTHE WHITE HOUSE\nWASHINGTON\nMarch 1, 1983\nMEMORANDUM FOR THE HONORABLE JAMES COYNE\nSPECIAL ASSISTANT TO THE PRESIDENT\nPRIVATE SECTOR INITIATIVES\nFROM:\nFRED F. FIELDING\nCOUNSEL TO THE PRESIDENT\nSUBJECT:\nRetirement of the Debts of the\nJames Coyne for Congress Committee\nAs a Special Assistant to the President for Private Sector\nInitiatives, you are in a unique position with regard to\nyour efforts to retire the campaign debts of your 1982\nCongressional Campaign Committee (the \"Committee\"). As a\nSpecial Assistant to the President, and an SES employee of\nthe Department of Commerce detailed to the White House, you\nare subject to the Standards of Ethical Conduct for\nGovernment Officers and Employees as set forth in Executive\nOrder No. 11222, and, as a matter of policy, the Standards\nof Conduct for White House Employees, 3 C.F.R. § 100.735.\nFurther, several provisions of the Federal Criminal Code, 18\nU.S.C. §§ 201, 203, 209, 210, 211, 602, 603 and 607 are\napplicable to you as a Federal employee and should be\nreviewed carefully in the course of retiring the Committee's\ndebts. Since the Committee owes a substantial debt to you\nas an individual, contributions to the Committee must be\nconsidered indirect payments to you.\nOutlined below is our analysis of the restrictions of each\nof the statutory provisions / and the Executive Order noted\nabove which are or should be considered applicable to your\nactivities in connection with any efforts to retire the\ndebts of the Committee. Additionally, we have attached a\nsummary of the general guidelines which you and your\ncampaign committee should follow in planning the Committee's\nfundraising activities to retire the Committee's debts.\n* / All references to statutory requirements contained\nherein, unless otherwise specifically noted, are paraphrases\nof the referenced statutes. Accordingly, when in doubt as\nto the applicability of these statutory provisions to\nspecific facts or circumstances, reference should be made\ndirectly to the statute in question.\n-2-\n18 U.S.C. § 201: provides in part that any public official\nmay not solicit, accept, receive or agree to receive\nanything of value for himself or for any other person or\nentity, in return for being influenced in his performance of\nany official act; for being induced to do or omit any act in\nviolation of his official duty; or being influenced in his\ntestimony under oath in any proceeding before any court or\nCongressional hearing. Violations of this provision are\npunishable by fine, imprisonment or both, and possible\ndisqualification from holding any office of honor or trust\nunder the United States.\nAdditionally, 18 U.S.C. § 201 prohibits any public official\nfrom soliciting, accepting, receiving or agreeing to receive\nanything of value for himself or for another person or\nentity for or because of any official act, including testi-\nmony before any court or Congressional committee, to be\nperformed by him. Violations of this provision are punish-\nable by fine, imprisonment or both.\nUnder certain circumstances these restrictions may preclude you\nor the Committee from accepting any contributions from\nindividuals or political committees, including political action\ncommittees (PAC's), whose specific purpose in making such\ncontribution is to influence your official acts. To avoid\nany appearance of a violation of this provision, you and the\nCommittee should not solicit or accept contributions from any\nindividual, political committee or organization which has\ninterests or represents individuals or organizations having\ninterests that are now or will be affected by the actions or\nnon-actions of the Office of Private Sector Initiatives.\n18 U.S.C. § 203: prohibits Members of Congress, or officers or\nemployees of the Federal government from receiving, soliciting,\nor seeking any compensation for services rendered by them or\nany other person on behalf of another person in relation to any\nproceeding, request for a ruling or other determination,\ncontroversy or particular matter in which the United States is a\nparty or has a direct and substantial interest. Violation of\nthis provision is punishable by fine, imprisonment or both.\nAccordingly, you and the Committee should not accept contribu-\ntions from any individual, political committee or organization\nif the acceptance of such contribution could reasonably be\nperceived as compensation for anticipated services to be\nrendered by you as a Federal employee on behalf of such\nindividuals or groups represented by such political committees.\nHence you should not solicit or accept contributions from\n-3-\nentities which have or will have interests pending before\nthe Office of Private Sector Initiatives or before other\nFederal government agencies which could reasonably be\nconstrued to be subject to significant influence by you.\n18 U.S.C. § 209: prohibits supplementation of the salary of\na Federal official as compensation for his services as a\nFederal official. No payments to the Committee may be\nsolicited or accepted as additional compensation for your\nservices as a Special Assistant to the President.\nContributions may only be solicited and accepted to retire\nthe Committee's preexisting debt. As a general matter, you\nand the Committee should not accept any contributions which\nyou have reason to believe would not have been made but for\nyour current Federal employment.\n18 U.S.C. $ 210: prohibits the payment of money or anything of\nvalue to any person, firm or corporation in consideration of the\nuse or promise to use any influence to procure any appointive\noffice in the United States.\n18 U.S.C. § 211: prohibits the solicitation or receipt, either\nas a political contribution or personal emolument, of any money\nor thing of value in consideration for the promise of support or\nuse of influence in obtaining for any person any appointive\noffice in the United States.\nOut of an abundance of caution, these prohibitions should be\nviewed by you and the Committee as prohibiting the acceptance of\nany contributions from individuals whom you may wish to appoint\nto positions within your office, or who are seeking\nappointments to positions within your office or any other\nposition within the Federal government.\n18 U.S.C. § 602: prohibits any candidate for the Congress, any\nSenator or Congressman, or any officer or employee of the United\nStates or any department or agency thereof, from knowingly\nsoliciting political contributions from any other such officer or\nemployee.\nThus, you and the Committee should take the steps necessary to\nensure that no Senators or Congressmen, or officers or employees\nof the Federal government, are knowingly solicited for contri-\nbutions to the Committee.\n18 U.S.C. § 603: prohibits an officer or employee of the Federal\ngovernment from making political contributions to their\nsupervising officers in the Federal government. For purposes of\nthis provision, a contribution to a political committee\nauthorized by an officer of the Federal government is considered\na contribution to such officer.\n-4-\nThe Committee, therefore, should not accept any contributions\nfrom individuals presently employed by your office.\n18 U.S.C. $ 607: prohibits the solicitation or acceptance\nof a political contribution in a Federal building. There is\nan exception to this prohibition for the receipt of\ncontributions in Federal buildings by persons on the staff\nof a Senator or Congressman under specific circumstances,\nbut such exception would no longer be applicable to you or\nthe Committee.\nThis provision would preclude all solicitation of contributions\nat the Office of Private Sector Initiatives. Further, in\nthe event that any political contributions to the Committee\nare received at your office, such contributions should be\nreturned directly to the donor with instructions as to the\nappropriate mailing address for the Committee.\nSection 201 (c) of Executive Order No. 11222 provides in part:\nIt is the intent of this section that employ-\nees avoid any action\nwhich might result\nin, or create the appearance of:\n(1) using public office for private gain;\n(2) giving preferential treatment to any\norganization or person;\n(3) impeding government efficiency or\neconomy;\n(4) losing complete independence or impar-\ntiality of action;\n(5) making a government decision outside\nofficial channels; or\n(6) affecting adversely the confidence of\nthe public in the integrity of the\nGovernment.\nYou and the Committee should, therefore, avoid soliciting or\naccepting unsolicited contributions whose receipt will create the\nappearance of precluding your exercise of independent judgment or\nimpartial action with regard to the issues coming before\nyou. Accordingly, you and the Committee should not accept\ncontributions from individuals or political committees who\nhave not previously contributed to your political committees\nand whose contributions, in light of your current position,\ncould be viewed as efforts to affect your independence and\nimpartiality in issues coming before you. Additionally, you\nand the Committee should not solicit contributions in any\nmanner that suggests that you are using your appointment to\nFederal office for personal gain. Solicitations by the\nCommittee referring to your current position could create\nsuch an appearance, and should, therefore, be avoided.\n-5-\nFinally, the issues raised by settlement of the debts of the\nCommittee for less than their full amount are governed by the\nprovisions of the Federal Election Campaign Act of 1971, as\namended, and its regulations. Although a full discussion of\nthose provisions is beyond the scope of this memorandum, you\nshould be aware that all of the above considerations which apply\nto contributions would also apply to the forgiveness of all or\npart of an existing debt.\nAttachment\nFFF: JGR: aw 3/1/83\nCC: FFFielding\nJGRoberts\nSubj.\nChron\nSUMMARY OF GENERAL GUIDELINES FOR\nACCEPTANCE OF POLITICAL CONTRIBUTIONS\nI. GENERAL RULE:\nThe Committee should not solicit or accept contributions\nfrom any individual, political committee, or organiza-\ntion (a) if the individual or entities represented by\nthe Committee or organization has interests in matters\nwhich are or may be pending before your office or is\naffected or regulated by any policies, decisions or\nregulations of your office, or (b) if such solicitation\nor acceptance would create the appearance of precluding\nyour exercise of independent judgment or impartial\naction with regard to the issues coming before you, or\notherwise affect adversely the confidence of the public\nin the integrity of the government.\nII. SPECIFIC PROHIBITIONS:\nDo not accept any contributions from individuals whom\nyou may wish to appoint to positions within the Office\nof Private Sector Initiatives.\nDo not accept any contributions from individuals who\nare seeking appointments within the Office of Private\nSector Initiatives or any other position within the\nFederal government.\nDo not solicit any Senators, Congressmen or officers or\nemployees of the Federal government for contributions\nto the Committee.\nDo not accept any contributions from individuals\npresently employed by the Office of Private Sector\nInitiatives.\nDo not solicit or accept any contributions in your\nFederal offices. If any contributions are received at\nthese offices, such contributions should be returned\ndirectly to donors with instructions as to the\nappropriate mailing address of the Committee.\nDo not solicit contributions in any manner which\nsuggests that you or the Committee are using your\nappointment to Federal office for your personal gain.\nSolicitations should not include reference to the fact\nof your current Federal employment.\nTHE WHITE HOUSE\nWASHINGTON\nDate\n2.28.83\nSuspense Date\nalice\nMEMORANDUM FOR:\nFROM:\nDIANNA G. HOLLAND\nACTION\nApproved\nPlease handle/review\nFor your information\nFor your recommendation\nFor the files\nPlease see me\nPlease prepare response for\nsignature\nAs we discussed\n3/1/83\nReturn to me for filing\nCOMMENT\nDow for\nPlease Dec Clip\n-\nTHE WHITE HOUSE\nWASHINGTON\nFebruary 28, 1983\nMEMORANDUM FOR THE HONORABLE JAMES COYNE\nSPECIAL ASSISTANT TO THE PRESIDENT\nPRIVATE SECTOR INITIATIVES\nFROM:\nFRED F. FIELDING\nCOUNSEL TO THE PRESIDENT\nSUBJECT:\nRetirement of the Debts of the\nJames Coyne for Congress Committee\nAs a Special Assistant to the President for Private Sector\nInitiatives, you are in a unique position with regard to\nyour efforts to retire the campaign debts of your 1982\nCongressional Campaign Committee (the \"Committee\"). As a\nSpecial Assistant to the President, and an SES employee of\nthe Department of Commerce detailed to the White House, you\nare subject to the Standards of Ethical Conduct for\nGovernment Officers and Employees as set forth in Executive\nOrder No. 11222, and, as a matter of policy, the Standards\nof Conduct for White House Employees, 3 C.F.R. § 100.735.\nFurther, several provisions of the Federal Criminal Code, 18\nU.S.C. §§ 201, 203, 209, 210, 211, 602, 603 and 607 are\napplicable to you as a Federal employee and should be\nreviewed carefully in the course of retiring the Committee's\ndebts. Since the Committee owes a substantial debt to you\nas an individual, contributions to the Committee must be\nconsidered indirect payments to you.\nOutlined below is our analysis of the restrictions of each\nof the statutory provisions / and the Executive Order noted\nabove which are or should be considered applicable to your\nactivities in connection with any efforts to retire the\ndebts of the Committee. Additionally, we have attached a\nsummary of the general guidelines which you and your\ncampaign committee should follow in planning the Committee's\nfundraising activities to retire the Committee's debts.\n* / All references to statutory requirements contained\nherein, unless otherwise specifically noted, are paraphrases\nof the referenced statutes. Accordingly, when in doubt as\nto the applicability of these statutory provisions to\nspecific facts or circumstances, reference should be made\ndirectly to the statute in question.\n-2-\nDRAFT\n18 U.S.C. § 201: provides in part that any public official\nmay not solicit, accept, receive or agree to receive\nanything of value for himself or for any other person or\nentity, in return for being influenced in his performance of\nany official act; for being induced to do or omit any act in\nviolation of his official duty; or being influenced in his\ntestimony under oath in any proceeding before any court or\nCongressional hearing. Violations of this provision are\npunishable by fine, imprisonment or both, and possible\ndisqualification from holding any office of honor or trust\nunder the United States.\nAdditionally, 18 U.S.C. § 201 prohibits any public official\nfrom soliciting, accepting, receiving or agreeing to receive\nanything of value for himself or for another person or\nentity for or because of any official act, including testi\nmony before any court or Con- gressional committee, to be\nperformed by him. Violations of this provision are punish-\nable by fine, imprisonment or both.\nUnder certain circumstances these restrictions may preclude you\nor the Committee from accepting any contributions from\nindividuals or political committees, including political action\ncommittees (PAC's), whose specific purpose in making such\ncontribution is to influence your official acts. To avoid\nany appearance of a violation of this provision, you and the\nCommittee should not solicit or accept contributions from any\nindividual, political committee or organization which has\ninterests or represents individuals or organizations having\ninterests that are now or will be affected by the actions or\nnon-actions of the Office of Private Sector Initiatives.\n18 U.S.C. $ 203: prohibits Members of Congress, or officers or\nemployees of the Federal government from receiving, soliciting,\nor seeking any compensation for services rendered by them or\nany other person on behalf of another person in relation to any\nproceeding, request for a ruling or other determination,\ncontroversy or particular matter in which the United States is a\nparty or has a direct and substantial interest. Violation of\nthis provision is punishable by fine, imprisonment or both.\nAccordingly, you and the Committee should not accept contribu-\ntions from any individual, political committee or organization\nif the acceptance of such contribution could reasonably be\nperceived as compensation for anticipated services to be\nrendered by you as a Federal employee on behalf of such\nindividuals or groups represented by such political committees.\nHence you should not solicit or accept contributions from\nChapter I-Office\n§ 732.401\nTitle 5-Administrative Personnel\npreceding election\nPART 732-PERSONNEL SECURITY\nPART 733-POLITICAL ACTIVITY OF\ntial electors were S\nAND RELATED PROGRAMS\nFEDERAL EMPLOYEES\n(2) An election\nor issue which is\nSubparts A-C-[Reserved]\nSubport A-The Competitive Service\ntified with a polit\nconstitutional ar\nGENERAL PROVISIONS\ndum, approval o\nSubport D-Security and Related\nSec.\nnance, or any qui\nDeterminations\n733.101 Definitions.\nsimilar character;\n(f) \"Partisan\" w\nPERMISSIBLE ACTIVITIES\n§ 732.401 Reemployment eligibility of cer-\njective refers to a :\ntain former Federal employees.\n733.111 Permissible activities.\nPERMISSIBI\n(a) Request. A former employee who\nPROHIBITED ACTIVITIES\nwas terminated, or who resigned while\n733.121 Use of official authority: prohibi-\n§ 733.111 Permissib\nsuspended or while charges were pend-\ntion.\n(a) All employee\ning. from a department or agency of\n733.122 Political management and political\nin political activ\nthe Government under a statute or ex-\ncampaigning: prohibitions.\nextent consistent 1\necutive order authorizing termination.\n733.123 Prohibited activity: exception of\nimposed by law an\nin the interest of national security. in\ncertain employees.\n733.124 Political management and political\nemployee retains t\nthe interest of the United States, or\ncampaigning: exception of certain elec-\n(1) Register and\non grounds relating to loyalty, and\ntions.\n(2) Express his o\nauthorizing OPM to determine his eli-\nual privately and\ngibility for employment in another de-\nSubport B-The Excepte Service\nsubjects and candie\npartment or agency of the Govern-\n(3) Display a pol\n733.201 Jurisdiction.\nment, may request OPM in writing to\ner, badge, or butto\ndetermine whether he is eligible for\nSubpart C-The U.S. Postal Service\n(4) Participate in\nemployment in another department or\ntivities of a civic,\nagency of the Government.\n733.301 Jurisdiction\nlabor, or professio\n(b) Action by OPM. (1) OPM shall\nAUTHORITY: 5 U.S.C. 1308. 3301. 3302,\nof a similar organiz\ndetermine, and will notify the former\n7301, 7324, 7325. 7327: 42 U.S.C. 2729: E.O.\n(5) Be a member\nemployee, after appropriate considera-\n10577. 3 CFR. 1954-1958 Comp., p. 218,\nor other political\nunless otherwise noted.\nparticipate in its\ntion of his case, including such investi-\ngation as it considers necessary,\nSOURCE: 35 FR 16785. Oct. 30. 1970, unless\nextent consistent w\notherwise noted.\n(6) Attend a P\nwhether he may be employed in an-\nrally, fund-raising\nother department or agency of the\nGovernment.\nSubpart A-The Competitive Service\npolitical gathering;\n(7) Sign a politic\n(2) If a former Federal employee\nfound unsuitable under this section\nGENERAL PROVISIONS\ndividual;\n(8) Make a finan\nhas had an opportunity to comment\n§ 733.101 Definitions.\na political party or\non the reasons for the action, or has\n(9) Take an active\nfurnished them to OPM or to his\nIn this subpart:\npendent candidate,\nformer employing agency, OPM may\n(a) \"Employee\" means an individual\nindependent candi\nalso cancel his reinstatement eligibil-\nwho occupies a position in the compet-\nelection covered by\nity if the eligibility resulted from his\nitive service;\n(10) Take an acti\n(b) \"Agency\" means an executive\nlast Federal employment and was ob-\ndate or in support\nagency and the government of the Dis-\ntained through fraud, or OPM may\nnonpartisan electio\ntrict of Columbia;\nprescribe a period of debarment from\n(11) Be politicall\n(c) \"Political party\" means a Nation-\nthe competitive service. not to exceed\ntion with a questio\nal political party, a State political\n3 years. or both.\ncifically identified\nparty, and an affiliated organization;\nparty, such as a co\n(5 U.S.C. 3301. 3302. 7312: 50 U.S.C. 403:\n(d) \"Election\" includes a primary,\nment, referendum,\nE.O. 10450. 3 CFR. 1949-1953 Comp., p. 936;\nspecial, and general election;\nnicipal ordinance (\nE.O. 10577. 3 CFR, 1954-1958 Comp., p. 218)\n(e) \"Nonpartisan election\" means-\ntion or issue of a sir\n[33 FR 12484, Sept. 4, 1968]\n(1) An election at which none of the\n(12) Serve as an\ncandidates is to be nominated or elect-\nclerk, or in a simil\ned as representing a political party\nform nonpartisan di\nany of whose candidates for presiden-\nby State or local lav\ntial elector received votes in the last\n428\nistrative Personnel\nChapter I-Office of Personnel Management\n§ 733.122\npreceding election at which presiden-\n(13) Otherwise participate fully in\nACTIVITY OF\ntial electors were selected: and\npublic affairs, except as prohibited by\nMPLOYEES\n(2) An election involving a question\nlaw, in a manner which does not mate-\nor issue which is not specifically iden-\nrially compromise his efficiency or in-\nompetitive Service\ntified with a political party, such as a\ntegrity as an employee or the neutral-\nconstitutional amendment, referen-\nity, efficiency, or integrity of his\nROVISIONS\ndum, approval of a municipal ordi-\nagency.\nnance, or any question or issue of a\n(b) Paragraph (a) of this section\nsimilar character: and\ndoes not authorize an employee to\n(f) \"Partisan\" when used as an ad-\nengage in political activity in violation\nACTIVITIES\njective refers to a political party.\nof law, while on duty. or while in a\nctivities.\nuniform that identifies him as an em-\nPERMISSIBLE ACTIVITIES\nployee. The head of an agency may\nACTIVITIES\nprohibit or limit the participation of\n§ 733.111 Permissible activities.\nauthority: prohibi-\nan employee or class of employees of\n(a) All employees are free to engage\nhis agency in an activity permitted by\nagement and political\nin political activity to the widest\nparagraph (a) of this section, if par-\nlibitions.\nextent consistent with the restrictions\nticipation in the activity would inter-\nactivity: exception of\nimposed by law and this subpart. Each\nfere with the efficient performance of\nemployee retains the right to-\nagement and political\nofficial duties, or create a conflict or\neption of certain elec-\n(1) Register and vote in any election:\napparent conflict of interests.\n(2) Express his opinion as an individ-\nual privately and publicly on political\nPROHIBITED ACTIVITIES\nExcepte Service\nsubjects and candidates:\n(3) Display a political picture. stick-\n§ 733.121 Use of official authority: prohi-\ner, badge, or button:\nbition.\n(4) Participate in the nonpartisan ac-\nAn employee may not use his official\nU.S. Postal Service\ntivities of a civic, community. social,\nauthority or influence for the purpose\nlabor, or professional organization, or\nof interfering with or affecting the\n1308. 3301. 3302.\nof a similar organization;\nresult of an election.\n42 U.S.C. 2729: E.O.\n(5) Be a member of a political party\nComp., p. 218.\nor other political organization and\n§ 733.122 Political management and politi-\nparticipate in its activities to the\ncal campaigning: prohibitions.\nOct. 30. 1970. unless\nextent consistent with law;\n(a) An employee may not take an\n(6) Attend a political convention,\nactive part in political management or\nrally. fund-raising function; or other\nin a political campaign, except as per-\npolitical gathering:\nmitted by this subpart.\nCompetitive Service\n(7) Sign a political petition as an in-\n(b) Activities prohibited by para-\ndividual;\ngraph (a) of this section include but\nPROVISIONS\n(8) Make a financial contribution to\nare not limited to-\na political party or organization:\n(1) Serving as an officer of a political\n(9) Take an active part, as an inde-\nparty, a member of a National, State,\npendent candidate, or in support of an\nor local committee of a political party.\nmeans an individual\nindependent candidate, in a partisan\nan officer or member of a committee\nin the compet-\nelection covered by § 733.124:\nof a partisan political club, or being a\n(10) Take an active part, as a candi-\ncandidate for any of these positions;\nleans an executive\ndate or in support of a candidate, in a\n(2) Organizing or reorganizing a po-\nvernment of the Dis-\nnonpartisan election;\nlitical party organization or political\n(11) Be politically active in connec-\nclub;\nty\" means a Nation-\ntion with a question which is not spe-\n(3) Directly or indirectly soliciting,\na State political\ncifically identified with a political\nreceiving, collecting, handling, disburs-\nated organization:\nparty, such as a constitutional amend-\ning. or accounting for assessments,\nncludes a primary,\nment, referendum, approval of a mu-\ncontributions, or other funds for a\n1 election;\nnicipal ordinance or any other ques-\npartisan political purpose:\nelection\" means-\ntion or issue of a similar character;\n(4) Organizing. selling tickets to,\nwhich none of the\n(12) Serve as an election judge or\npromoting. or actively participating in\nnominated or elect-\nclerk, or in a similar position to per-\na fund-raising activity of a candidate\n: a political party\nform nonpartisan duties as prescribed\nin a partisan election or of a political\nidates for presiden-\nby State or local law; and\nparty, or political club;\nd votes in the last\n429\n§ 733.123\nTitle 5-Administrative Personnel\nChapter I-Of\n(5) Taking an active part in manag-\n(3) Subject to the conditions of\nCottage City (Ja\nDistrict Heights\ning the political campaign of a candi-\n§ 733.124, an employee who resides in a\nEdmonston (Oct.\ndate for public office in a partisan\nmunicipality or other political subdivi-\nFairmont Height\nelection or a candidate for political\nsion designated by OPM under that\nForest Heights C\nparty office;\nsection: or\nGarrett Park (O\n(6) Becoming a candidate for, or\n(4) An employee who works on an ir-\nGlenarden (May\ncampaigning for, an elective public\nregular or occasional basis. on the\nGlen Echo (Oct.\noffice in a partisan election:\nGreenbelt (Oct. 4\ndays that he performs no services.\n(7) Soliciting votes in support of or\nHoward County (\nHyattsville (Sept\nin opposition to a candidate for public\n§ 733.124 Political management and politi-\nKensington (Nov\noffice in a partisan election or a candi-\ncal campaigning: exception of certain\nLandover Hills (B\ndate for political party office:\nelections.\nMontgomery Col\n(8) Acting as recorder, watcher, chal-\n(a) Section 733.122 does not prohibit\nMorningside (Ma\nlenger, or similar officer at the polls\nMount Rainier (1\nactivity in political management or in\non behalf of a political party or a can-\nNorth Beach (Se\na political campaign by an employee in\ndidate in a partisan election:\nNorth Brentwood\nconnection with-\n(9) Driving voters to the polls on\nNorth Chevy Ch:\nbehalf of a political party or a candi-\n(1) A nonpartisar election, or\nNorthwest Park (\n(2) Subject to the conditions and\nPrince Georges o\ndate in a partisan election;\n(10) Endorsing or opposing a cand.-\nlimitations established by OPM, an\nRiverdale (Sept.\ndate for public office in a partisan\nelection held in a municipality or po-\nRockville (Apr. 1\nSeat Pleasant (A\nelection or a candidate for political\nlitical subdivision designated by OPM\nSomerset (Nov. 2\nparty office in a political advertise-\nunder paragraph (b) of this section.\nTakoma Park (O\nment, a broadcast, campaign. litera-\n(b) For the purpose of paragraph\nUniversity Park (\nture, or similar material;\n(a)(2) of this section. the Office may\nWashington Gro\n(11) Serving as a delegate, alternate.\ndesignate a municipality or political\nbirth\nor proxy to a political party conven-\nsubdivision in Maryland or Virginia in\ntion:\nthe immediate vicinity of the District\nAlexandria (Apr.\n(12) Addressing a convention,\nof Columbia or a municipality in\nArlington County\nwhich the majority of voters are em-\nClifton (July 14.\ncaucus, rally, or similar gathering of a\nFairfax County (\npolitical party in support of or in op-\nployed by the Government of the\nTown of Fairfax\nposition to a partisan candidate for\nUnited States, when the Office deter-\nFalls Church (Ju\npublic office or political party office;\nmines that, because of special or un-\nHerndon (Apr. 7,\nand\nusual circumstances. it is in the domes-\nLoudoun County\n(13) Initiating or circulating a parti-\ntic interest of employees to participate\nManassas (Jan. 8\nsan nominating petition.\nin local elections. Information as to\nManassas Park (1\nthe documentation required to sup-\nPortsmouth (Feb\n[35 FR 16785. Oct. 30, 1970, as amended at\nPrince William C\nport a request for designation is fur-\n41 FR 49473, Nov. 9. 1976)\nStafford County\nnished by the Office on request. The\nVienna (Mar. 18.\n§ 733.123 Prohibited activity: exception of\nfollowing municipalities and political\ncertain employees.\nsubdivisions have been designated. ef-\nOTHER\nfective on the date specified:\n(a) Sections 733.121 and 733.122 do\nAnchorage. Alask\nBenicia. Calif. (F\nnot apply to an employee of an educa-\nIN MARYLAND\nBremerton. Wash\ntional or research institution, estab-\nAnnapolis (May 16, 1941).\nCenterville, Ga. (\nlishment. agency. or system which is\nAnne Arundel County (March 14, 1973).\nCrane. Ind. (Aug.\nsupported in whole or in part by the\nBerwyn Heights (June 15. 1944).\nDistrict of Colum\nDistrict of Columbia or by a recog-\nBethesda (Feb. 17. 1943).\nElmer City, Wasl\nnized religious, philanthropic. or cul-\nBladensburg (Apr. 20. 1942).\nHuachuca City, f\ntural organization.\nBowie (Apr. 11, 1952).\nNew Johnsonville\n(b) Section 733.122 does not apply\nBrentwood (Sept. 26, 1940).\nNorris, Tenn. (M\nto-\nCapitol Heights (Nov. 12. 1940).\nPort Orchard. W\n(1) An individual exempted under\nCheverly (Dec. 18. 1940).\nSierra Vista, Ariz\nChevy Chase, sections 1 and 2 (Mar. 4.\nWarner Robins, (\nsection 7324(d) of title 5, United States\n1941).\nCode:\n(c) An empl\nChevy Chase, section 3 (Oct. 8. 1940).\n(2) An employee of The Alaska Rail-\nmunicipality (\nChevy Chase, section 4 (Oct. 2. 1940).\nroad who resides in a municipality on\nlisted in parag\nMartin's Additions 1. 2. 3, and 4 to Chevy\nthe line of the railroad in respect to\nmay take an\nChase (Feb. 13, 1941).\npolitical activities involving that mu-\nChevy Chase View (Feb. 26, 1941).\nmanagement a\nnicipality:\nCollege Park (June 13, 1945).\nin connection\n430\ninistrative Personnel\nChapter I-Office of Personnel Management\n§ 733.301\nthe conditions of\nCottage City (Jan. 15, 1941).\nfor local offices of the municipality or\nDistrict Heights (Nov. 2. 1940).\nwho resides in a\nEdmonston (Oct. 24. 1940).\npolitical subdivision, subject to the fol-\npolitical subdivi-\nFairmont Heights (Oct. 24. 1940).\nlowing limitations:\nOPM under that\nForest Heights (Apr. 22. 1949).\n(1) Participation in politics shall be\nGarrett Park (Oct. 2. 1940).\nas an independent candidate or on\nwho works on an ir-\nGlenarden (May 21, 1941).\nbehalf of, or in opposition to, an inde-\nbasis, on the\nGlen Echo (Oct. 22. 1940).\npendent candidate.\nGreenbelt (Oct. 4, 1940).\nno services.\n(2) Candidacy for, and service in. an\nHoward County (Apr. 25, 1974).\nelective office shall not result in ne-\nHyattsville (Sept. 20. 1940).\nmanagement and politi-\nKensington (Nov. 8. 1940).\nglect of or interference with the per-\nexception of certain\nLandover Hills (May 5, 1945).\nformance of the duties of the employ-\nMontgomery County (Apr. 30. 1964).\nee or create a conflict, or apparent\ndoes not prohibit\nMorningside (May 19. 1949).\nconflict. of interests.\nMount Rainier (Nov. 22, 1940).\nmanagement or in\nNorth Beach (Sept. 20, 1940).\n(5 U.S.C. 7701. et seq.)\nby an employee in\nNorth Brentwood (May 6, 1941).\n[35 FR 16785. Oct. 30, 1970. as amended at\nNorth Chevy Chase (July 22, 1942).\n36 FR 20649. Oct. 28. 1971]\nelection,\nor\nNorthwest Park (Feb. 17, 1943).\nNOTE: For FR citations affecting § 733.124.\nthe conditions and\nPrince Georges County (June 19, 1962).\nsee the List of CFR Sections Affected in the\nby OPM, an\nRiverdale (Sept. 26, 1940).\nFinding Aids section of this volume.\nmunicipality or po-\nRockville (Apr. 15. 1948).\nSeat Pleasant (Aug. 31, 1942).\ndesignated by OPM\nSomerset (Nov. 22. 1940).\nSubpart B-The Excepted Service\n(b) of this section.\nTakoma Park (Oct. 22, 1940).\nirpose of paragraph\nUniversity Park (Jan. 18. 1941).\n$ 733.201 Jurisdiction.\nthe Office may\nWashington Grove (Apr. 5, 1941).\nlicipality or political\nSections 733.111-733.124 apply to an\nIN VIRGINIA\nryland or Virginia in\nemployee in the excepted service. It is\ncinity of the District\nAlexandria (Apr. 15, 1941).\nthe responsibility of the employing\na municipality in\nArlington County (Sept. 9. 1940).\nagency to investigate and decide alle-\nClifton (July 14, 1941).\nof voters are em-\ngations of prohibited political activity\nFairfax County (Nov. 10, 1949).\nGovernment of the\non the part of such an employee.\nTown of Fairfax (Feb. 9, 1954).\nthe Office deter-\nFalls Church (June 6. 1941).\nof special or un-\nHerndon (Apr. 7. 1945).\nSubpart C-The U.S. Postal Service\nit is in the domes-\nLoudoun County (Oct. 1, 1971).\nployees to participate\nManassas (Jan. 8. 1980).\n§ 733.301 Jurisdiction.\nInformation as to\nManassas Park (Mar. 4. 1980)\nrequired to sup-\nPortsmouth (Feb. 27. 1958).\nSections 733.101 (c), (d), (e), and (f)\nPrince William County (Feb. 14, 1967).\nthrough 733.124 apply to an employee\ndesignation is fur-\nStafford County (Nov. 2. 1979).\nof the U.S. Postal Service.\non request. The\nVienna (Mar. 18, 1946).\npalities and political\n(5 U.S.C. 7701. et seq.)\nbeen designated, ef-\nOTHER MUNICIPALITIES\n[44 FR 48954, Aug. 21, 1979]\nspecified:\nAnchorage, Alaska (Dec. 29. 1947).\nBenicia, Calif. (Feb. 20, 1948).\nPART 734-EXECUTIVE PERSONNEL\nARYLAND\nBremerton, Wash. (Feb. 27. 1946).\nFINANCIAL DISCLOSURE REQUIRE-\n1941).\nCenterville, Ga. (Sept. 16, 1971).\nMENTS\n(March 14, 1973).\nCrane, Ind. (Aug. 3, 1967).\n15.\n1944).\nDistrict of Columbia (July 5, 1977).\n1943).\nElmer City, Wash. (Oct. 28, 1947).\nSubpart A-General Provisions\n1942).\nHuachuca City, Ariz. (Apr. 9, 1959).\nSec.\nNew Johnsonville, Tenn. (Apr. 26. 1956).\n734.101 Authority.\n1940).\nNorris, Tenn. (May 6, 1959).\n734.102 Purpose.\nPort Orchard, Wash. (Feb. 27, 1946).\n12,\n1940).\nSierra Vista, Ariz. (Oct. 5, 1955).\n734.103 Agency regulations.\n1940).\nWarner Robins, Ga. (Mar. 19, 1948).\n734.104 Policies.\n1 and 2 (Mar. 4.\n734.105 Definitions.\n(c) An employee who resides in a\n3 (Oct. 8. 1940).\nmunicipality or political subdivision\nSubport B-Persons Required To File\n4 (Oct. 2. 1940.\nlisted in paragraph (b) of this section\n1. 2. 3, and 4 to Chevy\n734.201 General requirements for filing.\nmay take an active part in political\n734.202 Reporting individual; defined\nFeb.\n26,\n1941).\nmanagement and political campaigns\n734.203 Certain individuals excluded from\n13,\n1945).\nin connection with partisan elections\nreporting requirements.\n431"
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