EAO 004

An association’s transfer of a free pass for use of recreational facilities would be a direct communication for purposes of chapter 305 of the Government Code. Such a transfer for the purpose of generating goodwill among members of the legislative and executive branches and for the purpose of giving legislators insight into industry problems would be to influence legislation or administrative action. The transfer of such a pass would be reportable as “entertainment.” Thus, an association may provide such a pass only if the registrant is present each time the pass is used.