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1992 Wis Eth Bd 16 - LOBBYING AND LOBBYISTS; REGISTRATION, LICENSING AND REPORTING

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The time and expenses related to the lobbying activities of individuals
employed by companies that are members of a trade association that is a
principal should be recorded as follows:

(1) If the individuals are lobbying on the trade association's behalf, and under
      its supervision or control, the trade association should account for their time
      and the lobbying expenses that the association incurs;

(2) If the individuals are lobbying on their employer's behalf, then if the
      employer otherwise meets the definition of "principal," the employer should
      account for the employees' time and the lobbying expenses that the employer
      incurs; and

(3) If the individuals are lobbying on behalf of both the trade association and
      the employer, then both the trade association and the employer should
      undertake the accounting described in (1) and (2).
      The exemption for participating in the deliberations of an agency's advisory
      committee on rulemaking established under §227.13 or of a legislative
      committee of which the individual is a member extends to preparation and
      communication with committee members and staff, outside a meeting, that is
      directly related to committee deliberations. OEB 92-16

March 27, 1992