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B-211149 1 (1983-06-22)

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D!TLj. n0 CICULATM          (For u (A
COMPTROLLER GENERAL OF THE UNITED STATES
          WASHiNGTON b.=. XM


QONGiV- &4n


a-211149.


June 22, 1983


Te Hortorable James A. McClure
chairfmni Subcnittee on the Departrent
  of the Interibr and Related Agencies
rrnnInttse on Amroriations


C     _ _ _ _ _ _


United States Senate
            •0--Po not-mako.avntlable to pubilo readtn                     .c t3 Od )
Pear hr. Chairmn;


          In your letter dated March 9, 1983, you requested our opinion on
     whether the United States Holocaust Memorial Council may use Federal em-
     ployees and consultants paid with Federal funds to raise oney for the
 ,    holocaust memorials You also asked whether appropriated funds could be
     used to hire an investsmnt counselor to manage the donations;. You origi-
     nally requested that we provide you with a preliminarV response by   .
     April 15. lowever, when we sppka with Linda Richardson of your staff on
     AprIl 14, and explained that we were-awaiting formal caflnts on these
     matters Cr&i the Holocaust Memorial Council, she indicated that a pre-.
     1J.niary. response would be unnecessary and that she would prefer that we
     not respond until the Council had furnished us with carrents. We recent-
     ly received the Concl's crnmnts.
         We see no reason to object to the use of appropriated funds to pay
     consultants awl Federal enployees who engage in fund raising activities.
  ,  The lolocaust Menorial Council was established to encourage an annual
     cormerration of the Holocaust and to plan, construct, and oversee the
 Soperation of, a per      pt living memorial ruseum to the victims of the
     Holocaust.* Section 3 'f the Act to establish the United Stat s
     H olocaust Menorial Council, Puib. L. No..96-388, 94 Stat. 1547  1980),'
     provides for payment of ,Council meirbers, other than full-time officers or
     enployees of the United States or Mnters of'je Congress, at. the daily
     equivalent of a GS-18 salary, while section 5uthorizes, the Executive  7
     Director of the Council to appoint any pay such additional personnel as
5 Che considers appropriate. Section 4 Iprovides that the Council may hire
*4   experts and consultants. Section 7Authorizes the Council to solicit,
*    accept, hold,. administer, anduse gifts, bequests, and devises of prvp-
     erty, both real and personal, to aid and facilitate the construction,
 *   maintenance, and operation of the menorial. Since the solicitation of
     donations for costruction of the nmorial is an authorized agency func-
     LiOn, we would not object to the use of Federal funds to pay employees of
     the Council and consultants hired by the Coucil who engage in fund
   rais-e9. /...                9                       --


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U We notethat in its ccments th  Merorial Council stated that it did
    not intend.to pay fund raisers out of appropriated funds.


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