Ask the Experts – Lobbyist Disclosure Requirements - State and Federal Communications

December 11, 2012  •  

Ask the Experts – Lobbyist Disclosure Requirements

James Warner, Esq.

Q. I am a registered lobbyist who will be having a colleague accompany me to meetings with legislators. Should I be concerned with registration and/or reporting for my colleague?

A. Many individuals believe the presence of a registered lobbyist relieves a person of any disclosure requirements. Most jurisdictions have no exemption for this scenario. Lobbyist registration and reporting is required upon meeting the registration threshold.

Some jurisdictions do have limited exemptions from lobbyist registration requirements. In California, these particular actions would not be counted towards the lobbyist registration threshold. You do not engage in direct communication when you meet with a covered official in the company of a registered lobbyist retained by you or your employer. In Idaho, corporate employees need not register if the corporation is registered as a lobbyist and designates one or more of its employees as the corporation’s official lobbyist and the designated lobbyist is also registered.

Even if registration is not required, you must consider the applicable reporting requirements. A number of jurisdictions require your employer to report all lobbying expenses, which include those for employees who lobby but do not meet the registration requirements. Wisconsin specifically requires the disclosure of pro-rata compensation and expenses for these non-lobbyist employees. In Idaho, even if you are not required to register as discussed above, expenditures made by unregistered corporate employees in a lobbying effort must appear on the applicable reports.

Whenever you lobby state officials, consider all disclosure and compliance requirements, especially those related to the reporting for a non-lobbyist employee.


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