NEW YORK
TEMPORARY STATE COMMISSION
ON REGULATION OF LOBBYING

OPINION NO. 10 (78-10)

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FACTS

Three employees of an organization have in past years registered as lobbyists and two employees have not done any lobbying, while the third has engaged in limited letter writing. Although the third employee has had a few meetings with legislative staff members, at no time have the expenses incurred reached the $1000 plateau.

The questions presented to the Commission under the Regulation of Lobbying Act of 1977 (hereinafter referred to as the Act) are:

(1) Is a lobbyist required to file a Statement of Registration if there is no likelihood that the lobbyist will incur, expend, or receive at least $1000 in reportable expenses in the calendar year?

(2) Are unpaid volunteer members of an association who receive reimbursement of some of their travel expenses required to register?

OPINION

(1) No Statement of Registration is required to be filed by anyone on the facts stated. There appears presently no likelihood of the employees expending, incurring, or receiving $1000 or more of reportable expenditures. A filing would be required, however, within 15 days after there is a reasonable anticipation, or within 10 days after the actual making of such reportable expenditures. (Sec. 5(a) (1) (2) of the Act).

(2) We hold that unpaid volunteers of public interest and private interest organizations are not required to register. Personal sustenance, lodging, and travel disbursements are not deemed "reportable expenses" within the statute. (Sec. 8(b) (5) (iii) (A) of the Act).


APPROVED BY COMMISSION: October 6, 1978

CONCURRING: CHAIRMAN S. STANLEY KREUTZER, VICE CHAIRMAN OWEN McGIVERN, MARGARET C. ANDRONACO, D. CLINTON DOMINICK, DANIEL GUTMAN, and DAVID C. TAIT.

/S/
________________________________________

S. STANLEY KREUTZER
Chairman


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