Advisory Opinion No. 1994-4
Disclosure Of Advertising
Expenditures
Pursuant to the Code of Ethics for Lobbyists, Chapter 10, Part II, Connecticut General Statutes, certain purchases of advertising space in a program booklet for a political fundraising event are excluded from the definition of a gift, as long as these expenditures are properly reported. Conn. Gen. Stat. §1-91(g)(1). See also Conn. Gen. Stat. §9-333b(11). Attorney Paul L. McCormick from the law firm of Updike, Kelly and Spellacy, P.C. has asked whether such purchases, nonetheless, are expenditures for the benefit of a public official and/or expenditures in furtherance of lobbying which must be reported on the lobbyist financial disclosure forms.
The State Ethics Commission has broadly defined the term
expenditures in furtherance of lobbying to include any expenditure which
fosters goodwill between lobbyists and public officials. State Ethics Commission Advisory Opinion No. 93-14,
55
Since its establishment in 1978, the State Ethics Commission has
considered campaign contributions to be expenditures in furtherance of
lobbying. Consequently, in January 1981,
the State Ethics Commission submitted a regulation which would have required
disclosure of campaign contributions made by lobbyists. The Legislative Regulations Review Committee
refused to approve the regulation until the Commission had specific statutory
authority to require the disclosure. In
1982, the Legislature rejected the recommendation of the Codes of Ethics Study
Committee to amend the Lobbyists Code to require lobbyists to report campaign
contributions to the State Ethics Commission. See
Report to the General Assembly by the Codes of Ethics Study Committee,
p. 33,
Christopher T. Donohue
Chairperson