The director of State/local government relations for a corporation has the responsibility "to remain aware of proposed legislative and regulatory activity which could impact the corporation's business". He is also required to monitor relevant New York State activity.
The question presented to the Commission is whether, under the Regulation of Lobbying Act of 1977 (hereinafter referred to as the Act), officers, agents, or employees of a corporation are required to file Statements of Registration if they "monitor New York legislative and regulatory activity".
A Statement of Registration is required to be filed by officers and other employees of the corporation if they individually incur, receive, or expend $1000 of reportable expenses during a calendar year. If there is no specific fee or remuneration, a reasonable estimate of their proportionate share of salary would have to be computed to determine whether they reach the $1000 threshold. Such filing would be required within fifteen days after there is an anticipation or within ten days after the making of such reportable expenditures (Sec. 5(a)(1)(2) of the Act). The corporation may designate one person to file a Statement of Registration for all of its employees who engage in lobbying activity. However, said Statement would have to contain the names of all employees of the corporation who lobby on its behalf (see Section VI(A), subparagraph three of the Commission's Guidelines).
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/