Ask the Experts - Goodwill Lobbying and Keeping Compliant - State and Federal Communications

October 24, 2022  •  

Ask the Experts – Goodwill Lobbying and Keeping Compliant

Q: I am a registered lobbyist in Illinois and want to take an Illinois official out to dinner in order to garner goodwill.  What do I need to know to ensure we are compliant?

A: In Illinois, lobbyists reports must itemize for each individual expenditure or transaction, including any expenditures made by a consultant in performing services for the lobbying entity. The report must include the name of the official for whose benefit each expenditure was made, the name of the client the expenditure was made on behalf of, the total amount of the expenditure, a description of the expenditure, the vendor to whom the expenditure was made, the date of the expenditure, and the subject matter of the lobbying activity, if any.

Lobby or lobbying is to communicate, including the soliciting of others to communicate with an official of the executive or legislative branch of state or local government for the ultimate purpose of influencing executive, legislative, or administrative action at the state, municipal, county, or township government level. In Illinois, influencing includes promoting goodwill. Additionally with the passage of Senate Bill 539 in 2021, lobbying on a local level, except in Chicago, requires registration and reporting with the state.

In order to comply with Illinois lobbying law, the dinner would need to be reported on the appropriate entity report. There are two notification requirements a lobbyist must make to an official. First, the official must be informed, in writing, at the time the expenditure is received by the official, that the expenditure is reportable, and the official will appear in the expenditure report. Second, within 30 days after a reporting deadline, a lobbyist must notify each official on whose behalf an expenditure was reported. The 30-day notification must include the name of the registered lobbyist, a description, the total amount, the date, and subject matter of the expenditure. Please note there is a $75 per person limit on meals. Additionally, because Illinois does not have a time or expenditure registration threshold, any other individuals attempting to influence the official will need to register as a lobbyist.

For more information, check out the “Reports Required” section of the Lobbying Compliance Laws online publication for Illinois.  Please do not hesitate to contact us if you have questions.

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