EAO 093

A registrant may provide transportation expenses for a member of the executive or legislative branch to attend “a conference or similar event in which the member renders services.” However, the nature of those services must be “more than merely perfunctory.” Whether a particular event or a service falls within these definitions is a fact question. A registered organization that provides a luncheon for a member of the legislative or executive branch and the organization’s members for the purpose of communicating directly to influence legislation or administrative action must report the entire cost of the luncheon on its lobbyist activity report. When a registrant pays for an event that other registrants attend, none of the expenses of the event are attributable to the other registrants who are in attendance but who make no expenditures themselves.