November 11, 2022 •
Michigan Lobby Registration Act 2023 Reporting Thresholds Published
The Michigan Bureau of Elections posted the Lobby Registration Act 2023 Reporting Thresholds, which change every year in January to reflect the change in the consumer price index for Detroit. The registration thresholds for individual lobbyist compensation and for employer […]
The Michigan Bureau of Elections posted the Lobby Registration Act 2023 Reporting Thresholds, which change every year in January to reflect the change in the consumer price index for Detroit.
The registration thresholds for individual lobbyist compensation and for employer expenditures on a single official increased from $675 to $725.
Exempt expenditures increased from $14 to $15. The registration threshold for an employer making lobbying expenditures increased from $2,675 to $2,900 for any 12-month period.
The financial transaction threshold between a registered employer or lobbyist and a public official increased from $1,350 to $1,450.
The reporting threshold for travel and lodging reimbursements increased from $875 to $950.
Monthly food and beverage expenditures allowance for a public official increased from $66 to $72, and the threshold for food and beverages purchased between January 1 and end the reporting period increased from $400 to $450.
Employee reimbursements increased from $27 to $29, and the general gift threshold also increased from $66 to $72.
Late filing fees increased from $27 a day up to a maximum of $810, to $29 a day up to $870 maximum.
April 14, 2021 •
Idaho Amends Reporting Requirements for Independent Expenditures
Gov. Brad Little signed a bill amending reporting requirements for independent expenditures. House Bill 104 requires reporting of the identity of the candidate or measure and whether the expenditure was made in support of or in opposition to the candidate […]
Gov. Brad Little signed a bill amending reporting requirements for independent expenditures.
House Bill 104 requires reporting of the identity of the candidate or measure and whether the expenditure was made in support of or in opposition to the candidate or measure.
The bill becomes effective July 1.
February 2, 2021 •
FEC Updates Lobbyist Bundling Disclosure Threshold

Today, the Federal Election Commission (FEC) published its price index adjustments for expenditure limitations and the federal lobbyist bundling disclosure threshold. The lobbyist bundling disclosure threshold has increased for 2021 from $19,000 to $19,300. This threshold amount is adjusted annually. […]
Today, the Federal Election Commission (FEC) published its price index adjustments for expenditure limitations and the federal lobbyist bundling disclosure threshold.
The lobbyist bundling disclosure threshold has increased for 2021 from $19,000 to $19,300. This threshold amount is adjusted annually. Federal law requires authorized committees of federal candidates, leadership political action committees (PACs), and political party committees to disclose contributions bundled by lobbyists and lobbyists’ PACs.
Additionally, the FEC published its adjusted Coordinated Party Expenditure Limits for political parties for 2021.
August 24, 2020 •
Federal Appellate Court Upholds District Court’s Invalidation of FEC Disclosure Regulation
On August 21, the federal D.C. Circuit Court of Appeals upheld a 2018 federal District Court ruling invalidating a federal campaign finance regulation limiting the disclosure requirements of organizations making independent expenditures. On August 3, 2018, a federal district court […]
On August 21, the federal D.C. Circuit Court of Appeals upheld a 2018 federal District Court ruling invalidating a federal campaign finance regulation limiting the disclosure requirements of organizations making independent expenditures.
On August 3, 2018, a federal district court had ruled a campaign finance disclosure regulation followed for decades by the Federal Election Commission (FEC) failed to uphold disclosure requirements required by a federal statute.
Chief Judge Beryl A. Howell of the United States District Court for The District of Columbia issued an order, in CREW v. FEC, vacating 11 C.F.R. §109.10(e)(1)(vi), but stayed the vacatur to give time for the FEC to issue interim regulations comporting with the statutory disclosure requirements of 52 U.S.C. §30104(c). The court also has allowed the FEC 30 days to change an earlier FEC dismissal to conform with the court’s ruling. The FEC has not yet replaced the rule.
The case originated because of independent expenditures made in a 2012 Ohio senate race by the non-political social-welfare nonprofit Crossroads Grassroots Policy Strategies (Crossroads GPS), an affiliate of the American Crossroads Super PAC. Crossroads GPS did not report donors when reporting its independent expenditures, while it acknowledged receiving contributions over $200, arguing the donors did not donate funds directly tied to any specific reported expenditure, as the FEC interpreted 11 C.F.R. §109.10(e)(1)(vi) to require.
Non-political committees making independent expenditures over $250 in a calendar year must comply with disclosure obligations closely analogous to those imposed on political committees.
The vacated regulation required the identification of each person who made a contribution in excess of $200 to the person filing a disclosure report, including for non-political 501(c)(4) non-profit entities making independent expenditures, if the contribution was made for the purpose of furthering the reported independent expenditure. The district court found the regulation, as construed and applied by the FEC, did not require the disclosure of donors, absent the donor’s express agreement that the funds be used for the specific expenditures reported to the FEC, even though the donor may otherwise support and in fact contribute for the purpose of funding those expenditures.
The district court had found the regulation impermissibly narrows the mandated disclosure in 52 U.S.C. §30104(c)(2)(C), which requires the identification of such donors contributing for the purpose of furthering the non-political committee’s own express advocacy for or against the election of a federal candidate, even when the donor has not expressly directed that the funds be used in the precise manner reported.
June 22, 2020 •
Hawaii Ethics Commission Approves Administrative Rules on Lobbying, Gifts

The Hawaii Ethics Commission approved a package of proposals on June 18. These proposals amend and adopt portions of the Hawaii Administrative Rules related to lobbying and gifts. The amendments in chapters one through six address the Commission’s operations and […]
The Hawaii Ethics Commission approved a package of proposals on June 18. These proposals amend and adopt portions of the Hawaii Administrative Rules related to lobbying and gifts.
The amendments in chapters one through six address the Commission’s operations and procedures. Additionally, chapters seven through 10 now include sections on “Lobbying” and “Gifts and Fair Treatment”.
The proposed rules do not purport to amend any statutes. Rather, they are designed to interpret and execute the statutes enacted by the Legislature.
Section 21-10-5
Section 21-10-5, statement of contributions and expenditures, addresses the statutory requirement that statements of contributions and expenditures must be filed by up to three different entities. This could be the client, the employing organization, and the lobbyist. Or, in the case of lobbyists employed in-house by the client, the client or employing organization and the lobbyist.
This rule creates a single, client-based report rather than requiring separate reports from the client, the employing organization, and the lobbyist. This single, client-based reporting method avoids double or sometimes triple reporting. Additionally, it eliminates the practice, when clients or employing organizations cover expenditures, of having lobbyists submit reports listing “zero” expenditures.
Section 21-10-1
Section 21-10-1 contains definitions of “direct lobbying” and “grassroots lobbying” to demonstrate that lobbying can be both direct and indirect, consistent with the definition of lobbying in Section 97-1 of the Hawaii Revised Statutes. Under Rule 21-10-1, direct lobbying is defined as any oral or written communication with a legislator, an employee, intern, or volunteer of the legislature or an agency that would appear to a reasonable person to be an attempt to influence legislation or rule-making.
Additionally, grassroots lobbying is defined as any oral or written communication directed at any member of the public that expresses an opinion about existing or potential legislation, administrative rule, or ballot issue and includes an explicit or implied call to action.
Section 21-7-6
Section 21-7-6, valuation of gifts, defines the value of a gift as the cost that a member of the public would reasonably expect to incur to purchase it. For example, If the face value of a ticket to an event is $100, but the event is sold out and tickets on the secondary market are $500 at the time the ticket is offered as a gift, the value of the ticket is $500.
The rules must now be approved by the Department of the Attorney General, and then by the governor. Once approved by both offices, they will be posted with the Office of the Lieutenant Governor for 10 days before becoming effective.
June 19, 2020 •
Illinois Board of Elections Announces Amnesty Period for Late Contribution Reports
Due to the COVID-19 pandemic, the Illinois Board of Elections announced an amnesty period for late filers of the March 2020 quarterly report of campaign contributions and expenditures, due on April 15. No penalties will be assessed for reports filed […]
Due to the COVID-19 pandemic, the Illinois Board of Elections announced an amnesty period for late filers of the March 2020 quarterly report of campaign contributions and expenditures, due on April 15.
No penalties will be assessed for reports filed on or before June 30.
Similarly, no penalties will be assessed for late Schedule A-1 reports of contributions of $1,000 or more, due between March 18 and June 30, as long as they are filed on or before June 30.
Late reports (Quarterly or A-1) filed after June 30 will be subject to statutorily mandated penalties.
The Board’s one-time amnesty will not apply to the upcoming June 2020 Quarterly Report, which is due no later than July 15.
June 27, 2019 •
New Jersey Dark Money Bill Signed, Challenged
Last week, New jersey Gov. Phil Murphy signed legislation requiring dark money groups spending money to influence elections in New Jersey to disclose their large donors. Senate Bill 1500, carried over from last year’s session, requires certain groups, like 501(c)(4) […]
Last week, New jersey Gov. Phil Murphy signed legislation requiring dark money groups spending money to influence elections in New Jersey to disclose their large donors.
Senate Bill 1500, carried over from last year’s session, requires certain groups, like 501(c)(4) political nonprofits to disclose the identities of donors who give more than $10,000.
Additionally, the groups are required to report expenditures in excess of $3,000.
Gov. Murphy previously conditionally vetoed the bill.
However, the Governor signed an identical version when faced with a veto override because the bill’s sponsors agreed to tweak the legislation before it takes effect.
Since signed, the bill has faced opposition from citizen-based organizations and advocacy groups.
Those groups are arguing the new disclosure requirements will prevent people from donating to them.
On Tuesday, a federal lawsuit challenging the legislation was filed by Americans for Prosperity, a libertarian advocacy nonprofit founded by the Koch brothers.
Americans for Prosperity asked for the new law not to be enforced until the suit challenging the constitutionality of the law is decided.
New Jersey’s Election Law Enforcement Commission and Attorney General Lee Moore declined to comment on the pending legislation.
January 31, 2019 •
New Mexico Passes Bill Requiring Additional Lobbying Disclosures
Senate Bill 191 is on its way to Gov. Michelle Lujan Grisham’s desk. If signed, the bill will require the disclosure of the cumulative total of all individual expenditures of less than $100 made or incurred by the employer or […]
Senate Bill 191 is on its way to Gov. Michelle Lujan Grisham’s desk.
If signed, the bill will require the disclosure of the cumulative total of all individual expenditures of less than $100 made or incurred by the employer or lobbyist during the covered reporting period.
The expenditures must be separated into meals and beverages, other entertainment expenditures, and other expenditures.
Grisham has indicated she intends to sign the bill. Once signed, the bill will be effective July 1, 2019.
November 2, 2018 •
New Hampshire Attorney General Issues Letter on Campaign Finance
Earlier this year, the New Hampshire Attorney General Gordon MacDonald issued a letter to the Office of Secretary of State advising on his interpretation of some aspects of the state’s campaign finance laws. Most notably, a footnote in the letter […]
Earlier this year, the New Hampshire Attorney General Gordon MacDonald issued a letter to the Office of Secretary of State advising on his interpretation of some aspects of the state’s campaign finance laws.
Most notably, a footnote in the letter indicated MacDonald could require corporations making contributions in the state to register and report as political committees.
Under current state law, political committee registration is required for organizations making expenditures of $5,000 or more annually, even if the organization does not have as its major purpose to promote the success or defeat of candidates or measures. This regulation has been in place for several years during which corporate registration has not been the practice.
There is an exception to registration for organizations registered as business entities, but additional guidance on who qualifies as a business entity has not yet been made available.
Though there has been no change in the law to trigger a change in enforcement, MacDonald has indicated he is ramping up enforcement of campaign finance violations.
April 4, 2018 •
Ask The Experts – Covering Expenditures for Site Visits
Q. As a company, we would like to organize site visits for agency officials, so they can better understand our company and industry. Can we cover expenditures for these visits? A. State and local gift restrictions will apply to company expenditures […]
Q. As a company, we would like to organize site visits for agency officials, so they can better understand our company and industry. Can we cover expenditures for these visits?
A. State and local gift restrictions will apply to company expenditures associated with a site visit by a government official or employee, especially if your company is a lobbyist employer or state contractor. Food, beverage, entertainment, travel, lodging, or other promotional/welcome gifts could be restricted or banned. However, many jurisdictions have specific gift exceptions allowing expenditures in conjunction with site visits. Each jurisdiction has its own requirements for gift law compliance…
For more information, be sure to check out the Gift Law and Reports Required sections of the Lobbying Compliance Laws online publication for any jurisdiction. Please feel free to contact us if you have any questions.
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.