This Frequently Asked Questions page contains answers to some of the questions that the Ethics Commission has received regarding the rules applicable to lobbyists, lobbying firms, and organization lobbyists and the gifts they give to City Officials. For more information concerning the Lobbying Ordinance, please visit the Lobbyist portion of our website or refer to our lobbying-related Fact Sheets.
Does the $10 per month gift limit apply to each lobbyist in a Lobbying Firm or Organization Lobbyist, or does it apply to all the lobbyists collectively?
The $10 gift limit is an aggregate limit. It applies to the total value of all gifts from the lobbying entity and all the lobbyists in that entity. For example, two lobbyists in the same Lobbying Firm may not both purchase $10 meals for the same City Official in the same month.
May a lobbyist invite a City Official to a social event, such as an annual dinner or a gala event?
It depends. Lobbyists, Lobbying Firms, and Organization Lobbyists are subject to the $10 per month limit with regard to any gifts they give to City Officials. There is an exemption, however, for events that are held for non-profit entities. Because of this exemption, a lobbyist, Lobbying Firm, or Organization Lobbyist may provide a City Official with admission to any event held for a non-profit entity without implicating the Lobbying Ordinance’s $10 limit. Note, however, that City Officials are still subject to a separate gift limit and reporting requirements under the Ethics Ordinance.
May a Lobbying Firm or Organization Lobbyist give a City Official tickets to a fundraising event for a non-profit organization?
Under the City's Lobbying Ordinance, Lobbying Firms and Organization Lobbyists may give City Officials tickets to non-profit events without counting the tickets toward the $10 gift limit or triggering any disclosure obligations. Under the Ethics Ordinance, however, City Officials who attend such events may be receiving a "gift." Although the state's gift rules for tickets to fundraising events do not directly impact lobbying entities, these entities should be mindful that such tickets could expose City Officials to gift limit issues and disclosure obligations. Contact the Ethics Commission for additional assistance.
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