Various members of a not-for-profit corporation, on their own and without compensation, seek to influence legislation and speak to various State officials and legislators on behalf of themselves and their membership.
The question presented to the Commission is whether, under the Lobbying Act of 1977 (hereinafter referred to as the Act), civil servants who are non-salaried members of a not-for-profit corporation and lobby for themselves and the corporation are required to file a Statement of Registration.
Under our Constitution, the people of our land have the right to petition their government for the "redress of grievances and the express freely to appropriate officials their opinions on legislation and governmental operations" (Sec. 1 of the Act). Consequently, no Statement of Registration is required to be filed by the members of the organization whose lobbying activities are on behalf of themselves or their group and receive no compensation.
This does not exempt all the members of the organization and those who act in its behalf. If, for example, its legislative chairman receives, incurs, or expends $1000 or more of reportable expenditures, he would be required to file. We are informed that there is no anticipation at present that members would be reaching the threshold of the $1000 of reportable expenditures for the calendar year and, therefore, no filing is required. A filing would be required, however, within the 15-day period after there is an anticipation or within 10 days after the making of such reportable expenditure. (Sec. 5(a)(1)(2) 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/