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Regulators are raising questions about a trade between Bob Dole and conservative nonprofit groups that gave his presidential campaign, for free, valuable lists of as many as 200,000 potential contributors, the Miami Herald reported Saturday.

Dole's campaign denied that the senator's fund-raising for the Heritage Foundation and other groups in return for the names of donors violated any federal rules.But under Federal Election Commission law, campaigners cannot accept contributions from tax-exempt organizations - and mailing lists are explicitly banned, the Herald reported in a story from its Washington Bureau.

Internal Revenue Service law, reiterated in a public warning last month, also forbids nonprofit groups from engaging in "any activities that may be beneficial or detrimental to any candidate."

Dole officials sought to play down the report's significance on Saturday.

"The list the campaign made is very typical, very ordinary and I really think there's a lot less to the story than meets the eye," campaign spokesman Nelson Warfield said in Orlando, where Dole was attending a basketball game.

The Herald quoted Dole press secretary Christina Martin as saying: "We are clearly within our rights to have engaged in this practice. We don't think there are any problems, but if there are, they lie with the nonprofits and the IRS, not the Dole campaign."

Although IRS officer Marcus Owens declined to refer specifically to Dole's deal, he said trades involving mailing lists "could very well be viewed as political intervention, because a mailing list is a very valuable item for a political campaign."

Shortly after Dole announced last year that he was running for president, he wrote letters urging millions of Americans to contribute to the Heritage Foundation, Citizens Against Government Waste and other conservative advocacy groups.

"President Clinton and the liberal, big-government advocates," Dole wrote in one letter, are undermining his attempts to balance the budget, "laying the groundwork for future tax increases."

He then called Citizens Against Government Waste his important ally and urged the reader to send money to the group.

The nonprofits paid to mail the estimated 10 million letters, costing in postage about $80,000 per million letters, the Herald reported.

In return, Dole was given the name of every contributor he inspired - and those prospects got letters from Dole asking them to contribute to his campaign.

The mailing lists are worth at least $40,000, the Herald quoted direct-mail specialists as saying.

Dole did not report the mailing lists as contributions; nor have the nonprofits.

Thomas Schatz, president of Citizens Against Government Waste, said the advocacy was a highly successful trade, and that giving an advocate the donor list he or she inspired is "standard practice" in the direct-mail industry.

The Heritage Foundation gained as much or more from Dole's signature as Dole gained from the mailing lists, agreed foundation treasurer John Von Kannon.

Other presidential candidates, including Ronald Reagan, have brokered such swaps, but the IRS may be changing how it treats them.

The IRS last month cracked down on nonprofits that advocated electing particular candidates, a staple of some fund-raisers, and Owens said tax-exempt groups that engage in politics in any way are "going to get into trouble."

The FEC has not yet ruled on an unrelated case involving such an exchange, and so declined comment on Dole's swap.

President Clinton's campaign, which last week promised to monitor Dole's campaign for FEC violations, accused Dole of hypocrisy. GOP leaders last year held high-profile hearings accusing nonprofits that support Clinton causes of partisan activity and "now Dole's working with these other nonprofits," said press secretary Joseph Lockhart.

Clinton's campaign has never used mailing lists from tax-exempt groups, he said.