Advisory Opinion No. 1999-27

Reporting Of Expenditures For Unutilized Lobbying Advertising Campaigns

A client lobbyist registrant has paid a consultant to design a television advertising campaign regarding pending legislative action. Subsequently, the registrant decided not to use the advertising. Commission Attorney Catherine Nasto has asked whether the associated cost is an expenditure "in furtherance of lobbying" which needs to be reported, since the ads were never used in actual lobbying efforts.

Pursuant to Conn. Gen. Stat. x 1-96(a), a client lobbyist registrant must disclose on its financial reports expenditures which are in furtherance of lobbying. It is common practice for a registrant to employ many different lobbying methods. The fact that one of its plans is not carried out is irrelevant. The plan at issue was still part of the registrant’s overall strategy. Therefore, under the Lobbyist Code’s reporting requirements, any costs associated with a registrant’s lobbying strategy, including unutilized advertising campaigns, are expenditures in furtherance of lobbying and must be disclosed on its financial reports.

By order of the Commission,

Stanley Burdick,
Chairperson