Date:    11/18/97  1:12 PM

Subject: s7-26-97 

Mr. Gatz, Secretary
        I am concerned about the vagueness of the language contained in H.R. 944
&
945.  Allowing the SEC to interpret the language of the bills does not give 
nonprofits much comfort.  It seems to be one more area where donors lose 
the freedom to choose the recipients of their charitable contributions.  It 
also removes one more opportunity for not-for-profits to advance the 
charitable work they perform.  
        H.R. 944 & 945 allow the SEC to determine who will be exempted from the
requirements of the bill.  They do not say how they will determine who will 
be exempted.  Many good organizations may be affected by this legislation.
        The bills would be close to impossible to implement and their
implementation would be costly.  These bills will only reduce, if not 
eliminate, corporate charitable contributions to nonprofits other than 
schools and certain local entities providing the SEC exempts them from the 
requirements of the legislation.
        Please work with the charitable community in developing legislation
which
will improve their options instead of reducing them.  Before this 
legislation is implemented lets see if we can close some of the vague 
loopholes and protect charitable options instead of reducing them.