SEAC 84-13

If an association that employs a registered lobbyist funds a banquet with the consent of the lobbyist and invites a public official to be its banquet speaker, and if that banquet is an entertainment event that brings about direct communication to influence legislation or administrative action, then the lobbyist must report the expenses that were made for such communication with a member of the legislative or executive branch. These expenses include the speaker’s travel, accommodations, and honorarium. Whether the banquet expenses are to be reported in total or on a pro rata basis, or not at all, is a question of fact.