Ask the Experts – Disclosure of “All-Invited” Events - State and Federal Communications

January 20, 2011  •  

Ask the Experts – Disclosure of “All-Invited” Events

Nola WerrenQ.  If my employer hosts a function to which all members of the state legislature are invited, must I disclose the name of each individual legislator attending, or can I merely reference the fact that all members were invited?

A. This is a very common occurrence for most lobbyists: to pay for events where all members of the legislature, or some other identifiable group, are invited. The reporting implications for such events range from simple aggregate disclosure to detailed reporting where the name of every legislator attending must be listed. The key to accurate reporting is to know how the state defines “all invited” and whether it takes into consideration any type of “sub-group.”

Here is a representative summary of the varied reporting requirements you might encounter with this type of event:

Arizona – All expenditures incurred by a principal or lobbyist for a special event for legislators – including parties, dinners, athletic events, entertainment, and other functions – to which all members of the legislature, either house of the legislature, or any committee of the legislature are invited must be reported. These expenditures do not have to be reported based on the cost per legislator. However, a description of the event, date and location of the event, number of persons invited, and total expenditures must be reported.

Arkansas – A “special event” is a planned activity to which a specific governmental body or identifiable group of public servants is invited. One of the unique aspects of Arkansas disclosure in this situation is that if the event has multiple co-hosts, the names of all other lobbyists sharing in the cost of the event must be reported.

Also in Arkansas, hospitality rooms may be reported as a “special event” provided the lobbyist invites specific governmental bodies or identifiable groups of public servants. When reporting hospitality room expenses, the lobbyist must itemize the date the hospitality room was open; the name of the event hosted; the exact amount paid by the lobbyist towards the total expenditure for the hospitality room; and the names of all other lobbyists sharing in the cost of the room.

Georgia – Aggregate expenditures on food, beverages, and registration at group events to which all members of an agency, including the legislature and its committees and subcommittees, are invited must be disclosed. Also, if an expenditure is made on behalf of a public official and is simultaneously incurred for an identifiable group of public officials, the individual identification of whom would be impractical, the name of the individual official need not be disclosed. A general description of the identifiable group will suffice.

Louisiana – For legislative lobbying, the following must be invited before invoking group disclosure: the entire legislature; either house; any standing committee; select committee; statutory committee; committee created by resolution of either house; subcommittee of any committee; recognized caucus; or any delegation thereof. Disclosure includes the name of the group invited; the amount, date, and location of the event.

For executive branch lobbying, group disclosure is when more than 25 executive branch officials are invited to a reception, social gathering, or other function. The name of the event, amount, date, and location must be reported.

Utah – In Utah, food or beverage expenditures must be reported if the aggregate daily expenditures benefitting the public official are greater than $25, unless the food or beverage is provided in connection with an event to which all of the members of the legislature, a standing committee, interim committee, legislative task force, or a party caucus are invited.

Washington – Washington does not provide for group reporting. Even if all members of the legislature, or all members of any sub-group within the legislature, are invited, every individual person must be listed by name if the expenditure exceeds $25 per occasion (which it usually does when group events are involved).

If two or more lobbyist employers share the expenses of a reception or other entertainment event, the lobbyist primarily responsible for organizing the event must disclose on his or her monthly L-2 report the names of the legislators (and members of their immediate families) attending the group event. Rather than duplicating this list of attendees, the L-2 reports filed by the lobbyists of the other employers sponsoring the event may make reference to the lobbyist’s report that contains these details.

We have not listed rules for all the states, only examples of some states. If you have a question on a state not listed here, please contact us directly at 330-761-9960.

We are always available to answer questions from clients that are specific to your needs, and we encourage you to continue to call or e-mail us with questions about your particular company or organization. As always, we will confidentially and directly provide answers or information you need. Our replies to your questions are not legal advice. Instead, these replies represent our analysis of laws, rules, and regulations.

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