EAO 377

A group that makes contributions for the use of university academic departments is not making expenditures that count toward lobby registration under Government Code section 305.003(a)(1) as long as the group does not earmark the contributions to be used for an expenditure or expenditures described in Government Code section 305.006(b). An entity that holds and disburses funds used for an expenditure or expenditures described in Government Code section 305.006(b) is not “making expenditures” for purposes of Government Code section 305.003(a)(1) as long as the group’s only discretion in regard to disbursement of the funds is to ensure that the funds are used to support a university.