EAO 048

An organization that is registered as a lobbyist and has several registered employees is not required to report on its lobby activity report reimbursements to those employees for lobby expenditures. The registered employees must list those reimbursed expenditures on their respective lobby activity reports. If a registered employee assists another employee in lobby activities and acts at the other’s direction, the assisted employee must list the assisting employee on his lobby activity report for purposes of Government Code section 305.005(f)(5). Circumstances of mutual assistance may lead to each registered employee listing the other as an assistant. An individual who communicates to influence, on behalf of an organization of which he is a member, is not required to register as a lobbyist unless he crosses either the compensation threshold or the expenditure threshold under chapter 305 of the Government Code, the lobby statute. Whether communications on behalf of the organization that “coincide” with the interests of the member’s employer are communications for which the member is compensated is a fact question. Members of a nonprofit organization are not “clients” for purposes of section 305.005(j).