EAO 528

Title 15 does not prohibit a general-purpose committee from using a political contribution that was legally given and accepted from a corporation, for the purpose of financing the establishment or administration of the committee, to compensate an individual lobbyist for providing lobbying services to a corporation. Assuming that the contributions to the committee were given for the specific purpose of financing the committee’s administrative expenses, and that the funds were not provided to the committee for the purpose of compensating a lobbyist, the committee would not be required to register solely by using the contributions to compensate the lobbyist.