So you’re a lobbyist, you just moved to your brand-new Capitol Hill rowhouse, and you want to invite friends – including Members and staffers – over for a house-warming party. Who can you invite? Do you have to get it approved by the ethics committee? What should you serve?
We can’t help you with the menu in this case (although take a look at our Meal Definition Edition ethics tip for tips on what constitutes a “meal”). But here’s does and don’ts for entertaining people at your home.
A lobbyist may entertain a Member or staffer in his/her home if that person is a personal friend of the lobbyist and the situation meets the test for the personal friendship exceptions. This means that the personal hospitality being offered under the personal frienship exception is reciprocal in that the Member or staffer similarly provides meals and personal hospitality to the lobbyist.
A lobbyist is not permitted to offer his / her home as an entertainment venue to a Member or staffer, nor to issue an invitation to visit or use a lobbyist’s beach house or mountain condo, even if those are owned by the lobbyist personally. The exception for personal hospitality does not extend to individuals who are lobbyists. Inviting Members or staffers to your home must fall under the personal friendship exception, meaning that all the factors of personal friendship must be in place for the exception to be appropriate.
Again – the key word is “reciprocal.” There must be a history of gift-giving or reciprocal dinner invitations, at the same level of giving.
The information in this post is from the Lobbying Compliance Handbook, a comprehensive guide to ethics, LDA filing, and life as a federal lobbyist. New edition coming soon! Details on the Lobbying Compliance Handbook are available here.
Tags: entertaining, Ethics, lobbyists, lobbyists entertaining Members of Congress