Advisory Opinions


Reporting when a lobbyist hires a lobbyist
Indiana Lobby Registration Commission

(Determination made at public meeting on November 13, 1997)
(Ratification at public meeting of March 24, 1998)


Chairman Bepko - yes
Vice-Chairman Krahulik - yes
Commissioner Hicks - yes
Commissioner Abbs - yes

Questions and written comments may be directed to Indiana Lobby Registration Commission, 115 W. Washington, Suite 1375 S., Indianapolis, IN 46204 (317) 232-9860


There does not appear to be statutory authority which would support the Commission in requiring that a compensated lobbyist disclose for which clients of an employer lobbyist he lobbies. In the general spirit of disclosure, the Commission invites, bu t does not require, compensated lobbyists to voluntarily disclose those clients on whose behalf they are lobbying.


Lobbyist "A" is paid by Lobby Firm "B" to lobby for client "C". A's compensation for the lobbying A does for client C is paid solely by B. A currently reports that he is a compensated lobbyist for B, and does not report that he lobbies for B's client , C.


The statute does not require that A disclose for which clients of B that A lobbies. However, a general sense of this type of disclosure can be obtained by looking at B's compensated lobbyist form, which will list those employer lobbyists who compensat e B.

It should be noted that if the facts were changed, and if C pays A directly, or if B served as a mere conduit between A and C, then A would need to report as C's compensated lobbyist.