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Organization Lobbyists

This Frequently Asked Questions page contains answers to many of the questions that the Ethics Commission has received regarding Organization Lobbyists. For more information concerning the Lobbying Ordinance, please visit the Lobbyist portion of our website or refer to our lobbying-related Fact Sheets.

Are 501(c)(3) organizations exempt from the Lobbying Ordinance?

No. Any organization, including a non-profit organization, that pays its officers or employees to have 10 or more lobbying contacts with City Officials within a 60 day period must register as an Organization Lobbyist.

If two employees of my organization meet with one City Official for lobbying purposes, is that 1 contact or 2?

It is 1 contact. Each meeting to lobby one City Official with regard to one municipal decision counts as one contact regardless of the number of individuals from your organization who are present at the meeting.

If my company is an Organization Lobbyist and also hires a firm to lobby the City, do I report that firm on my disclosure statements?

No. In such a situation, your company is both an Organization Lobbyist and the "client" of a Lobbying Firm. Your company does not need to report anything in its capacity as a "client." Instead, the firm your company hires will be required to register as a Lobbying Firm and will report on its disclosure statements the lobbying that it does on behalf of your company.

Do I report the lobbying done by uncompensated officers or other volunteers in my organization?

No. The Lobbying Ordinance does not regulate any actions of an organization's volunteers. Their communications with City Officials are not considered lobbying contacts and need not be disclosed.

If a City Official is present at an organization’s committee meeting or membership meeting and a municipal decision is discussed at that meeting, does that count as a lobbying contact?

Yes. If a City Official is present at a meeting, and if one or more of the organization’s compensated individuals makes a comment during the meeting for the purpose of attempting to influence a particular municipal decision, then that comment is considered a lobbying contact. Moreover, if the organization is an Organization Lobbyist, it must register as lobbyists all of the individuals who made lobbying contacts.

I will be involved in a roundtable discussion with a City Official on a number of topics. Does each topic discussed count as a separate contact?

If each separate topic pertains to a separate "municipal decision," and you are communicating with the City Official regarding each topic for the purpose of influencing the decision, then each discussion on a particular topic will count as a separate contact. Keep in mind that not every City decision is a "municipal decision" under the Lobbying Ordinance; for example, asking the City Official to fill the potholes in front of your organization’s building is not a "municipal decision."

I sent an email to one City Official, who forwarded it to another City Official. How many contacts did I make?

You made only 1 contact. The fact that a City Official forwarded it to other City Officials does not alter the fact that you were engaging in a direct communication with only one City Official. The first City Official could have forwarded the email to 20 other City Officials and it still would be only 1 contact.

I provided a City Official with a policy analysis that does not take a specific stance (support or opposition) to a municipal decision. Did I make a lobbying contact?

Educating an official regarding a particular matter often constitutes lobbying. Providing information to a City Official is a lobbying contact if done for the purpose of influencing a municipal decision. One needn’t advocate for one side or another to influence a decision. Providing information, statistics, analysis, or studies to a City Official is considered a contact if it could affect the decision.

If I contact a City Official on a general municipal issue (e.g., revenue shortfall in the budget), does that count as a lobbying contact?

It depends. If your communication may reasonably be considered an effort to get a municipal decision underway (e.g., getting the City Council to adopt an ordinance to reverse the budget shortfall, to prevent future shortfalls, etc.), then it is a contact even though there is no decision docketed when the communication is made. On the other hand, if the communication is not reasonably likely to lead to a municipal decision, then it is not a contact.

If I contact a City Official to inquire about the status of a project, am I making a lobbying contact?

Merely seeking information is not a contact (unless the request for information is a disguised attempt to influence a decision). For example, asking a City Official this question is not a lobbying contact: "Has the City Council voted yet on the Sunstreet project?" On the other hand, this question is a lobbying contact: "Has the City Council voted yet on the Sunstreet project that will leave 100 low income residents with no place to live?"