Advisory Opinion No. 1996-8
Valuation Of
Reportable Lobbyist Expenditures
For Legislative Receptions
Under the general reporting requirements of the Code of
Ethics for Lobbyists, Conn. Gen. Stat. Chapter 10, Part II, a lobbyists
disclosure reports must include ...an itemized statement of each expenditure
of ten dollars or more per person for each occasion made by the reporting
registrant for the benefit of a public official in the legislative or executive
branch, a member of his staff or immediate family, itemized by date,
beneficiary, amount and circumstances of the transaction. Conn. Gen. Stat. §1-96(e). When, however, the event is a publicly
noticed legislative reception, costing less than fifty dollars per person, to
which all members of the General Assembly have been invited, the itemization
threshold is twenty dollars. Under the Codes closely related, but distinct, gift
restrictions, a Gift is anything of value ...which is directly and
personally received ... Conn. Gen.
Stat. §1-91(g). For purposes of
implementing this statutory language, the Commission has adopted regulations
which specifically exempt from the value of food and beverage provided at a
reception or party
overhead costs such as in-house planning costs,
invitations, rental fees, and decorations
Regulations of While these regulations reference only gift valuation, not
lobbyist financial disclosure, it would be anomalous indeed to require lobbyist
itemization of benefits that had not been directly and personally
received. Such an interpretation would
produce public disclosure records which inaccurately state the actual benefits
received by the reportable official, staff or family member. As a consequence, in certain instances anyone
reviewing the reports would be incorrectly led to conclude that the Codes
applicable gift limits had been illegally exceeded when, in fact, no such
violation has occurred. Therefore, the State Ethics Commission rules that, in reporting itemizable legislative receptions, lobbyists should
disclose only the dollar value of the benefits which have been directly and
personally received. It should be
remember, however, that client lobbyists must include all ancillary costs (e.g.,
overhead) when disclosing aggregate entertainment on their periodic financial
reports. Conn. Gen. Stat. §1-96(e); Regulations
of Conn. State Agencies §1-92-49(a)(4). By order of the Commission, David T. Nassef
Chairperson