Ask The Expert - Goodwill Lobbying Registration Requirements - State and Federal Communications

March 13, 2024  •  

Ask The Expert – Goodwill Lobbying Registration Requirements

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Q: I am an in-house lobbyist and frequently like to meet with legislators to build relationships. If I am not lobbying on any issues, do I still need to worry about registration requirements? 

A: You should absolutely be thinking about registration requirements anytime you interact with public officials or employees.  Many states require registration for goodwill lobbying.

Goodwill lobbying is covered under the definition of lobbying in several states. The following states require lobbyist registration for goodwill activities: Alaska, Connecticut, Florida, Georgia, Hawaii, Idaho, Illinois, Indiana, Kansas, Maryland, Minnesota, Missouri, New York, North Carolina, Oregon, Pennsylvania, Tennessee, Texas, and Vermont.

Some states go as far as defining the specific conduct constituting goodwill lobbying. Registration in Connecticut is required for “door opening” when an influential individual interacts with a state agency on behalf of a client. The Tennessee Ethics Commission has said that “getting to know” or “building rapport” is considered lobbying in the state of Tennessee and is subject to all registration requirements.

Oregon defines, goodwill, as used in the definition of lobbying, as kindness, friendliness, benevolence, or generosity by a person or entity directed toward a legislative official that could cause the legislative official to have a favorable impression of, or thankfulness to, the person or entity.

It is always a good idea to check the jurisdiction’s specific registration requirements on our website prior to communicating with officials.

You can find this information under the “Registration” section of the U.S. Lobbying Compliance Laws online publication.

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State and Federal Communications, Inc. provides research and consulting services for government relations professionals on lobbying laws, procurement lobbying laws, political contribution laws in the United States and Canada. Learn more by visiting stateandfed.com.

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