EAO 113

A donation to a private foundation that supports a state institution of higher education is not a lobby expenditure if the foundation exercises discretion in the use of the donation, even if the donation is ultimately used for the type of expenditures that may require lobby registration and reporting. An individual registrant who attends an event and thereby satisfies the “presence” requirement for an organization that is making the expenditures for the event is not required to report the expenditures for the event.