Advisory Opinion No. 1996-7

Lobbyist Reporting Of Expenditures For “JF” Parties

On behalf of a registered lobbyist, State Ethics Commission Supervising Attorney Rachel Rubin has asked how the reporting requirements of The Code Of Ethics For Lobbyists, Conn. Gen. Stat. Chapter 10, Part II, apply to “JF” parties (i.e., events traditionally held at the General Assembly to mark the end of various legislative committees’ work on proposed bills).  Specifically, the Commission has been asked to delineate how the reporting requirements of the Code apply to lobbyist contributions to such events; particularly in light of the fact that the number and identities of the attendees at these parties are not precisely known in advance.

In general, the Lobbyist Code requires “…an itemized statement of each expenditure of ten dollars or more per person for each occasion made by the reporting registrant or a group of registrants which includes the reporting registrant for the benefit of a public official in the legislative or executive branch, a member of his staff or immediate family, itemized by date, beneficiary, amount and circumstances of the transaction.”  Conn. Gen. Stat. §1-96(e).  “JF” parties and similar events (e.g., legislative receptions), where the specific attendance list is not known in advance, are in no way exempt from this general requirement.  Rather, in cognizance of the difficulties inherent in such reporting, the Commission, by regulation, has allowed that, under these circumstances, disclosure may be premised “…on an anticipated number of attendees…”  Regulations of Conn. State Agencies §1-92-48(c)(6)(B).  See, also, Conn. Gen. Stat. §1-91(g)(10) which directs that the reporting of legislative receptions shall be based on “…the number of persons whom the donor reasonably expects to attend the reception.”

Therefore, when a lobbyist or lobbyists are asked to contribute goods or money for a “JF” party, they must obtain in writing from the Clerk of the Committee, or other Committee representative responsible for the event, an estimate of the expected number of attendees.  If the total amount contributed by lobbyists divided by the anticipated number of attendees is ten dollars or more per person, arrangements (e.g., a sign-in sheet) must be made to allow for itemized lobbyist disclosure of the event.  If, however, the preceding calculation yields a figure less than ten dollars per person, itemization is not required.  In either case, however, it should be remembered that client lobbyists must include such entertainment expenditures, in the aggregate, on their periodic financial disclosure reports.  Conn. Gen. Stat. §1-96(e); Regulations of Conn. State Agencies §1-92(a)(4).

By order of the Commission,

David T. Nassef
Chairperson