Ohio Joint Legislative Ethics Commission (JLEC) issues memo on lobbyist expenditures and reporting requirements

The JLEC is Ohio’s bipartisan ethics committee for the legislative branch responsible for overseeing lobbying compliance. JLEC recently issued a memorandum reminding regulated entities about restrictions and reporting requirements related to meals and beverages, travel, and gifts, and attendance at meetings and conferences of national organizations to which the State pays dues.

Meals and Beverages

The JLEC emphasizes that “meals and beverages provided by a legislative agent to a legislator while attending a meeting/conference of a national organization do not count towards the annual $75 limit,” noting, however, that this exception “does not apply to legislative employees.” On the reporting side, “payment of expenses for meals and beverages provided to public officials while in the host city at the time of the conference are reported as an aggregate dollar amount (recipient not disclosed) in the national conference reporting category of the Activity and Expenditure Report,” or, “in the all-invited reporting category if all House and Senate members are invited to a reception.”

Travel

If legislators or legislative staff are attending a national organization’s meeting/conference, which is considered an “official duty,” then they may accept from a legislative agent “actual travel/lodging expenses directly related to their attendance,” according to the JLEC’s travel expense guidance.

Gifts

The JLEC specifically states that “. . . neither the Ohio Revised Code § 102.031 nor the Legislative Code of Ethics provides a national conference exception to the annual $75 limit for gifts to legislators and legislative staff from legislative agents;” however, “this limit does not apply to gifts from the employer of a legislative agent.” Gift expenditures exceeding $25 “must be reported in the Activity and Expenditure Report’s itemized gift category of the Activity & Expenditure Report (recipient name, date, amount and nature of gift disclosed).”

Financial Support of Conference Events

If financial support is provided by registered lobbyists or the employers of registered lobbyists to a national organization’s conference event to offset associated costs, and, when the national organization is responsible for: “(1) determining who is invited; (2) extending any invitation to those invited; and (3) the activity is part of the conference agenda,” then the financial support is “not a reportable Ohio lobbying expenditure,” according to the JLEC’s memo.