International Foundation for Electoral Systems and enforcing decisions. In the U.S., the Office of Special Counsel (OSC) is the independent government agency charged with receiving complaints, investigating alleged violations, and prosecuting violations of the Hatch Act pertaining to the abuse of state personnel and physical resources.153 The Merit Systems Protection Board (MSPB) is the administrative adjudicatory body that hears the cases brought by the OSC, and orders penalties if it finds a violation has occurred.154 The OSC may also endeavor to resolve the case informally before prosecuting the violation before the MSPB.155 Federal prosecutors have the jurisdiction to prosecute violations of the numerous criminal statutes related to coercing political activity, misuse of physical and financial resources, and the misuse of the franking privilege.156 For the legislative branch in the U.S., the ethics committees of the House and Senate are responsible for investigating violations of their respective rules and ethics manuals, as well as administering penalties if a violation is found.157 Specifically, within the House of Representatives, the Office of Congressional Ethics (OCE) is tasked with receiving complaints and making initial investigations into allegations of violations.158 If the OCE finds that there is a substantial reason to believe a violation has occurred, it will then forward the case on to the House of Representatives Committee on Ethics for further investigation and administration of penalties.159 However, if rules regarding the franking privilege in the House are violated, the House Commission on Congressional Mailing Standards (“Franking Commission”), rather than the OCE, is the body responsible for investigating complaints of potential violations.160 Like the OCE, it does not have power to grant legal relief;161 but it will conduct an initial investigation and refer cases to the House Committee on Ethics.162 Unlike the House, the Senate does not have a separate commission for initial investigation, thus the Senate Select Committee on Ethics is responsible for all enforcement process steps of all alleged violations of Senate Rules.163 153 5 C.F.R. § 734.102(a)-(b); see also Eleanor Smith & Leslie B. Kiernan, supra note 118, at § 19:13. 5 C.F.R. § 734.102(b); see also Eleanor Smith & Leslie B. Kiernan, supra note 118, at § 19:13. There is no cause of action for citizens to sue individuals in courts for violating the Hatch Act. See Webb v. Scott, 2015 WL 1257513, at *15 (D. Utah 2015) (citing Hall v. Clinton, 285 F.3d 74, 83 (D.C. Cir. 2002) as authority that there is no private cause of action for Hatch Act violations), rev’d on other grounds, 2016 WL 1105254 (10th Cir. 2016); see also Brooks v. Nacrelli, 331 F. Supp. 1350, 1354 (E.D.Pa.1971) (government exclusively enforces the Hatch Act), aff’d, 473 F.2d 955 (3d Cir.1973). However, a private citizen may file a complaint with the OSC regarding possible violations of the Hatch Act, and the OSC may then investigate and possibly prosecute the violation. See Eleanor Smith & Leslie B. Kiernan, supra note 118, at § 19:13. 155 See Off. of Special Counsel, Annual Report to Congress for Fiscal Year 2014, 39 (2014). 156 See Craig C. Donsanto et al., supra note 59, at 109-15; see also H. Andrew Wasmund, Use and Abuse of the Congressional Franking Privilege, 5 Loy. L.A. L. Rev. 52, 80 n.172 (1972). 157 See General Prohibition Against using Official Resources, supra note 113; see also Staff of H. Comm. on Ethics, 113th Cong., Summary of Activities 13 (2d Sess. 2015). 158 See id. 159 See id. 160 2 U.S.C.A. § 501(e) (1981). 161 See Barbara J. Van Arsdale et al., Postal Service, 28 Fed. Proc., L. Ed. § 63:72 (citing Common Cause v. Bolger, 512 F. Supp. 26 (D.D.C. 1980)). 162 2 U.S.C.A. § 501(e); see also Public Citizen Files Complaint for Violations of Franking Privilege, Public Citizen: WatchDog Blog (Oct. 23, 2008 3:26 PM) http://www.commondreams.org/newswire/2008/10/23/public-citizen-filescomplaint-violations-franking-privilege-rep-peter-roskam. The Franking Commission is also responsible for issuing advisory opinions that House of Representative Members are required to obtain before sending out the mass communication to certify that it is in compliance with the rules. See 39 U.S.C. § 3210(d)(1)(6)(A); see also 2 U.S.C.A. § 501(d) (1981). 163 See Jacob R. Straus, Enforcement of Congressional Rules of Conduct: A Historical Overview, Cong. Research serv. 15 (2015). 154 20