January 6, 2015 •
Ask the Experts – Goodwill Lobbying and Registration
Q. I will be having meetings with state legislators to introduce myself and my employer. I do not have any legislation of interest yet, though I anticipate that I will. Will this require lobbyist registration?
A. Goodwill lobbying is covered in many jurisdictions. The following 19 states may 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 jurisdictions have specifically addressed goodwill lobbying. Connecticut covers “door opening,” including such things as telephone calls that you make to set up informational meetings with officials. The Maryland State Ethics Commission has indicated generating goodwill or engaging in educational discussions with officials or employees is considered lobbying.
Some states consider additional activities in determining whether an activity is goodwill lobbying. In Pennsylvania, lobbying includes providing hospitality to a state official or employee for the purpose of advancing the interest of the lobbyist or principal. Kansas also includes entertaining or providing a gift to a state officer or employee in its definition of lobbying in certain circumstances.
Any time you interact with a state official or employee, you must consider whether your activities constitute lobbying, even if you are not engaging in lobbying in a traditional manner. Your activities may count toward the threshold requiring lobbyist registration.
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