NEW YORK
TEMPORARY STATE COMMISSION
ON REGULATION OF LOBBYING

OPINION NO. 32 (80-1)

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FACTS

Certain public interest organizations receive grants from the New York State Consumer Protection Board for services relative to public interest intervention in Public Service Commission rate-making proceedings. The Commission has been requested to clarify the obligation of such organizations to register and report under the Regulation of Lobbying Act.

ISSUE

1. Are such organizations and their lobbyists subject to the Regulation of Lobbying Act?

2. Must the source and amount of such grants or contributions be disclosed?

DISCUSSION

Sections 5, 8, and 10 of the Act require registration and reporting by any lobbyist who meets the statutory requirements set forth therein. Section 10 also requires the client to file an annual report if the statutory requirements are met. No section of the Act requires disclosure of the amount of contributions received by a client or the source thereof. The organizations involved are not and do not contend that they are entitled to exemption under Section 12(a)2 as agents of the State.

OPINION

A Statement of Registration and quarterly reports must be filed by a lobbyist who meets the statutory and reporting requirements. Both the lobbyist and client must file the required annual reports. The client is not required to disclose the amount or source of lobbying contributions.


APPROVED BY COMMISSION: MAY 13, 1980

CONCURRING: TEMPORARY CHAIRMAN HARVEY M. LIFSET, FRANCES F. FOX, GAIL HELLENBRAND, and S. STANLEY KREUTZER.

/S/
________________________________________

HARVEY M. LIFSET
Acting Chairman


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