CONGRESSIONAL RECORD PROCEEDING AND DEBATES OF THE 94TH CONGRESS, FIRST SESSION

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP77M00144R000800150028-1
• Release Decision: RIFPUB
• Original Classification: K
• Document Page Count: 6
• Document Creation Date: December 9, 2016
• Document Release Date: August 24, 2001
• Sequence Number: 28
• Publication Date: October 6, 1975
• Content Type: OPEN

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01
oRecord
United States
of America
PROCEEDINGS AND DEBATES OF THE 94th CONGRESS, FIRST SESSION
WASHINGTON, MONDAY, OCTOBER 6, 1975
Senate
By Mr. RIBICOFF (for himself,
Mr. BROCK, Mr. JAVITS, Mr. KEN-
NEDY, Mr. MUSKIE, Mr. PERCY,
Mr. RoTI-H, Mr. STAFFORD, and
Mr. CHILES) :
S. 2477. A bill to provide more effec-
tive public disclosure of certain lobbying
activities to influence issues before the
Congress and the executive branch,. and
for, other purposes. Referred to the Com-
mittee on Government Operations.
Mr. RIBICOFF. Mr. President, today
I am introducing the Lobbying Act of
1975 on behalf of myself and Senators
BROCK, JAVITS, KETTNEDY, MUSKIE, PERCY,
ROTH, STAFFORD, and CHILES. I ask unan-
imous consent that a summary of the
bill be inserted in the CONGRESSIONAL
RECORD at the end of my remarks.
The PRESIDING OFFICER. Without
objection, it is so ordered.
Mr. RIBICOFF. The legislation I am
Introducing today is an effective, fair,
and workable lobbying reform bill. Such
'legislation is long overdue.
Senators BROCK, JAVITS, KENNEDY,
MUSKIE, PERCY, and STAFFORD have all
introduced lobbying bills of their own
this year. I am grateful that each one of
them has chosen to be a cosponsor of
this bill. They have all significantly con-
tributed to the legislation.
Earlier this year the committee held
a total of 3 days of hearings on legisla-
tion to reform the present lobbying laws.
The witnesses at the hearings all agreed
that reform of the present lobbying law
was essential. The 1946 act is too limited
in scope, too vague in its wording, and
too weak in its enforcement authority.
A 1970 House report described the pres-
ent act as a thoroughly deficient law. A
report the General Accounting Ofllce
prepared this year for me similarly
emphasized the inadequacies of the pres-
ent law. The report stated that in one
recent reporting period 48 percent of the
lobbying reports filed were incomplete,
and 61 percent were received too late.
Yet, the Justice Department has investi-
gated only five complaints of violations
of the law since March 1972. In the 29
years since the lobbying law was passed
there has been only one successful prose-
cution for violation of the law. The re-
port of _the General Accounting Office
concludes that-
The The Department of Justice does not moni-
tor the registration or disclosure require
ments of the Act or evaluate the effective-
n or compliance with Act.
Lobbying serves a very useful role in
the decisionmaking process. Without it
Congress would be deprived the informa-
tion and the variety of viewpoints it
should have. But the ineffectiveness of
the current law has cloaked the lobbying
process in unnecessary secrecy. Neither
the Congress nor the public have any
accurate picture of the lobbyist's activi-
ties. For Congress to operate effectively
and for the public to understand, the
legislative process, and to participate in
it a.5 effectively as possible, basic infor-
mation about lobbying must be public.
The Supreme Court recognized the
need for disclosure of lobbying activi-
ties in its opinion reviewing the 1946 act.
In that case, entitled United States
against Harriss, Chief Justice Warren
said of lobbying that--
Full realization of the American ideal of
government by elected representatives de-
pends to na small extent on their abiitty to
properly evaluate such pressures. Otherwise
the voice of the people may all too easily
be drowned out by the voice of special inter-
est groups seeking favored treatment while
masquerading as proponents of the public
weal.
The Lobbying Act of 1975 will tell the
Congress and the public what interests
are making significant efforts to in-
fluence the legislative process, what Is-
sues they are attempting to influence,
and how much money they have spent
in the effort to do so. The bill would give
a comprehensive picture, for the first
time, of the lobbyist's efforts to influence
an issue before Congress, including his
efforts to generate grass roots support
for a particular position. At the same
time, the bill is carefully drafted to in-
sure that no one will be deterred from
fully participating in the public debate
on any matter by unnecessarily broad or
detailed lobbying laws.
Under the bill's provisions only an or-
ganization, or an individual retained by
someone else to lobby for him,.could be
a lobbist. The bill defines organization to
include both. businesses, labor unions,
and public interest -groups. The bill thus
avoids sweeping into its coverage the
Individual citizen who wishes to com-
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 municate hiispviie?ws on any issue0to/ / 0 : CIA- ac i7n0Mt4% iV80&olrts are cov-
gress. Such a person would not be a ered if the solicitation reaches 500 or
lobbyist under the law no matter how more members of the general public and
often he exercises his constitutional right the solicitation costs more than $200 to
to petition his government for a redress prepare and distribute. Additional pro-
of grievances. visions require an organization to register
With respect to direct efforts to in- as a lobbyist if it organizes a nationwide
fluence Congress, an organization is a grass-roots lobbying campaign by re-
lobbyist under the bill's provisions only questing a number of its affiliates at the
if it attempts to influence an issue before State and local level, or its own em-
Congress by talking to, a Congressman or ployees, to communicate with Congress
his staff on 12 or more occasions in a or the executive branch.
3-month period. Organizations are The bill does not make members of
thus excluded if their lobbying efforts the public who themselves communicate
are too infrequent to have any significant directly with Congress about purely
effect on Congress. An additional pro- executive agency matters lobbyists. Cov-
vision provides that if the officials of an erage of such activities raises special
organization converse only with the Sen- problems because of the extent and va-
ators or Congressmen who represent
them, the organization will not, just be- intends to look at this matter carefully
cause of these contacts, become a during its forthcoming hearings on lob-
lobbyist. bying legislation. In addition, Senator
At the same time, the bill does guar-
antee that any organization that lobbies
Congress in a sustained fashion will be a
lobbyist. By basing the definition of a
lobbyist on the` number of contacts the
organization makes with Congress, the'
bill provides a clear standard which will
allow any organization to easily tell
whether or not it is a lobbyist. The bill
relies on the number of contacts to define
a lobbyist, rather than the amount of
money spent by the lobbyist on lobbying,
because such. a contacts test most ac-
curately reflects the extent and impact
of the organization's lobbying activities.
Furthermore, the bill's definition of a
lobbyist as one who makes 12 contacts
provides a test any organization may ap-
ply without the extensive bookkeeping
required by a test based on the amount
of money it spends of lobbying.
An individual who is employed by an
organization to lobby for it would not
himself be a lobbyist, although his ac-
tivities would be likely to make the or-
ganization he works for a lobbyist. An
individual would be a lobbyist in his
own right only if he receives money from
someone else for the specific purpose of
attempting to influence an issue before
Congress, and communicates with the
Congress on one or more occasions in an
effort to influence an issue before Con-
gress.
The bill recognizes that a lobbyist may
also try to indirectly affect an issue be-
fore Congress by persuading a large
number of other people to express their
views to Congress. In order to judge how
representative such views are of the
general public, Congress must know
whether the letters it receives reflect the
spontaneous expression of the public's
feelings, or whether they have been gen-
erated by the lobbying efforts of a spe-
cial interest. Since the executive branch
as well as Congress may receive such
letters, the bill also covers efforts by lob-
byists to mobilize public support or op-
position for any action a Federal agency
may take.
riety of the contacts. The committee
KENNEDY'S Subcommittee on Administra-
tive Practice and Procedure presently has
under consideration S. 1289, which re-
quires Federal agencies to keep a public
record of the most important contacts
between Federal officials and outside par-
ties. This bill, which I cosponsored, may
prove to be a very sensible, alternative
way to assure full disclosure of which in-
terests seek to influence important execu-
tive agency decisions.
Organizations or individuals who do
engage in substantial lobbying efforts
will have to file reports that will give
Congress and the public an accurate pic-
ture of their lobbying activities. The re-
ports a lobbyist will file will disclose each
issue the lobbyist worked on, and the
method it used to try to influence
Congress.
At the same time, the bill's reporting
requirements will not weigh the lobbyist
down with unnecessarily extensive re-
porting requirements.. To avoid cumula-
tive or unnecessary filing, the bill does
not require each individual who works as
a full-time employee of an organization
which is a lobbyist to also file as a lobby-
ist. A local organization that does noth-
ing but solicit its members at the re-
quest of a national organization would
not also have to file as a lobbyist, but the
report filed by the national organiza-
tion would have to include information
about the solicitations made by its
affiliates.
The exact type of information a lobby-
ist must file is carefully tailored to fit
each particular kind of lobbying activity
involved. For example, an organization
will have to estimate the total amount
of money spent on all its efforts to di-
rectly lobby Congress during the period.
It will not have to itemize the amount
of money spent in directly trying to in-
fluence any particular issue before Con-
gress. On the other hand, an individual
or an organization which lobbies on be-
half of someone -else is required to file
more detailed financial statements about
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the amount o money his cl en pays m the definition. n ual w o en a es in
for his services. Any lobbyist who en- lobbying activities as a paid employee of the
gages in an indirect lobbying campaign organization on whose behalf he lobbies
on any issue will have to file a full re- would not have to file a report as a lobbyist,
port On the amount of money spent on although his activities would be likely to
make the organization a lobbyist. In that
that campaign. case, his name would appear on the report as
The bill requires the lobbyist to list one who did lobbying for the organization.
any officer, director, or paid employee To be a lobbyist the individual must also
who directly spoke to a Federal officer on directly communicate one or more times with
one or more occasions in an effort to Congress during any three month period
about
influence a particular issue before Con- an issue before Congresse. The bill
terms such a contact with Congress "a
gress and to identify the issue involved. lobbying communication". An individual
On the other hand, it does not require would also be a lobbyist if he Is 'paid to urge
the lobbyist to file an individual record 5 o re o her persons ur ng the same
of each conversation the lobbyist had :)eri5tt'ttr co sate w congress or an
with any Member of Congress or his a ranch agency on any issue before
it. This is termed "a lobbying solicitation".
staff. In addition to an individual, an organiza-
The bill gives the enforcement author- tion may also be a lobbyist. The bill defines
ity to the General Accounting Office. The "organization" broadly to include businesses,
agency successfully administered the labor unions, and voluntary membership or-
Federal Elections Campaign Act for sev- ganizations.
eral An organization becomes a lobbyist if it
years and has the necessary per- engages in lobbying communications or so-
sonnel and experience to enforce this licitations on its own behalf or on behalf of
new law. The General Accounting Office its members in any of the following three
will have the full investigative and ad- ways:
ministrative powers, and the range of (1) Engages orally, and on its own behalf,
sanctions, it needs to do an effective job. In a total of 12 or more lobbying communi.
Informal procedures will be used as much cations with Congress during any 3-month
as possible and court sanctions will be period. However, communications between a
largely civil and injunctive in nature, local businessman on behalf of his company
and the Senators and Congressmen who rep-
In short, the Lobbying Act of 1975 Is resent the State where the businessman lives
both a strong and balanced bill. On the do not count for purposes of determining
one hand, it guarantees the right of whether an organization is a lobbyist. If a
Congress and the public to know how lob- local businessman just communicates with
byists are attempting to influence the his Senators or Congressman about problems
decisions of government. On the other affecting his company, neither the company
nor the businessman would be. a lobbyist re-
hand, it protects the constitutional rights gardless of the number of times he talks to
of every citizen to petition his govern- his Senators or Congressman.
ment for a redress of grievances. (2) Expends $200 or more in any 3-month
I plan to hold additional hearings period to make solicitations urging 500 or
shortly on this bill, as well as the other more other persons to communicate with any
lobbying bills that have already been member of Congress about a particular issue,
or urging 500 or more persons to communi-
intraduced. sate with any executive branch official about
Committee action on this much-needed any issue under consideration in the execu-
legislation will follow as quickly as pos- tive branch.
sible after these hearings are completed. (3) Solicits 50 or more of its own em-
The summary follows: ployees or. 12 or more other organizations
SUMMARY OF THE LOBBYING ACT OF 1975 with which it is affiliated to communicate
An individual may be a lobbyist under the with any member of Congress about a par-
bill's definition only if someone else retains titular issue, or solicits the same number
him to lobby in some capacity other than as of people to communicate with any Execu-
a full-time employee. An organization may tive branch official about any issue under
be a lobbyist if it is paid to lobby on behalf consideration in any agency.
An organization can also ,become a lobby-
of someone else, or if it engages in a sib- 1st if it is retained-by some other person to
stantial amount of lobbying on its own be- engage in the same lobbying activities that
half.
The bill does not make any other indi- would make an individual who is retained vidual or organization a lobbyist. Thus, it in for pay a lobbyist.
no way affects the individual citizen who DEFINITION OF LOBBYING COMMUNICATIONS
expresses his personal views to Congress on OR SOLICITATIONS
any matter, regardless of the extent of his Since the definition of a lobbyist is large-
activities. ly based on the number of lobbying commu-
Any organization or individual who is a nications or solicitations certain individuals
lobbyist must register with the Comptroller or organizations make, the definitions of
General and file quarterly reports with the lobbying communications and solicitations
Comptroller General. The bill authorizes the are an essential part of the bill.
Comptroller General to enforce the bill's pro- A lobbying communication includes, except
visions and establishes sanctions for any vio- for certain specified exemptions, any direct
lations. communication with members of Congress
DEFINITION OF A LOBBYIST or their staff, in order to influence any issue
For an "individual" to be a lobbyist he before Congress. The term "issue before Con-
must be retained for money by someone else. gress" covers the entire range of matters
Only independent contractors and similar considered by Congress including bills, reso-
types of individuals retained to perform a lutiQns, nominations, hearings, or investi-
specific lobbying task are included within gations.
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A lobbying communication also include
any direct col nunication between a lol3by-
ist and a l !ederal agency official where the
lobbyist tries .to get the Federal official to
express a particular position before Congress.
Similarly, it includes any. dlrrect effort to get
a member of Congress to influence the deci-
sion of any matter under consideration by
theexecutive branch.
A lobbying solicitation arises whenever a
person requests other persons to write or
otherwise communicate with Congress about
an Issue before Congress. Similarly, the term
Includes any effort by a person to get.others
to write or otherwise communicate with the
executive branch about any issue before the
executive branch. - -
Certain efforts to influence an issue be-
fore Congress or the executive branch are
specifically excluded from the definition - of
lobbying communications or solicitations.
The exclusions cover:
A communication or solicitation by an in-
dividual acting solely on his own behalf for
redress of personal grievances or to express
his own personal opinion.
Requests for Information about the status,
existence, or effect of a bill or other issue
before Congress.
Communications or solicitations by a Fed-
eral officer or employee of the executive
branch, or communications or solicitations
by a Member, officer, or employee of Congress.
Testimony or subpoenaed information sub-
mitted to a congressional committee.
Communications or solicitations by State
or local officials, by candidates for Federal,
state, or local offices, or by National, State, or
local political parties.
Communications or solicitations (other
than advertisements) appearing on televi-
sion or in newspapers or other publications
distributed to the general public.
REGISTRATION AND REPORTING REQUIREMENTS
_ An individual or organization which meets
the definition of a lobbyist must register
annually with the Comptroller General.
The registration must contain basic in-
formation about the identity of the lobbyist,
list any individuals whom the lobbyist ex-
pects to pay to do lobbying, and generally
describe the subject matter - of the types of
issues before Cou
ress or the executive
branch which the bbyist expects to seek
to influence, and the means the lobbyist ex-
pects to influence such types of Issues. The
lobbyist must also disclose the identity of
any other "organization" which financially
supported his lobbying activities during the
past year,: and each "individual"- who pro-
vided more than 5 percent of the lobbyist's
funds for lobbying during the past year.
In the case of a lobbyist who is retained
for money, the registration will include the
Identity of the person who retained him, and
a description of the financial terms under
which the lobbyist was retained. If the
lobbyist is a voluntary membership organiza-
tion, such as a trade association or a public
Interest group supported by Its members,
the registration would disclose the approxi-
mate number of persons who are members,
as well as a description of procedures the
organization follows In establishing its posi-
tion on particular issues.
In addition to registering with the Comp-
troller General, a lobbyist will have to file
reports every three months describing his
lobbying activities. The precise informa-
tion which the lobbyist must provide in the
quarterly report will vary depending on the
exact nature - of the lobbyist's activities. For
example, the bill requires less detailed fi-
nancial data from -an organization which
lobbies on its own behalf than from an,
individual who is retained by a client to
lobby on a particular issue.
REPORTS OF LCBBYISTS RETAINED FOR PAY
TO LOBBY DIRECTLY
A lobbyist retained by any other: person
to lobby for him by engaging in one or more
lobbying communications must--
(1) disclose the Identity of the person on
whose behalf he is acting and laow much
money he was paid by such person for his
services in connection with each issue;
(2) identify the issues he worked on for
each client and the lobbyist's position on the
issue;
(3) list any individuals who In turn were
paid by the lobbyist to make one or more
lobbying communications during the period;
and
(4) provide a general description of any
lobbying "solicitations" concerning an issue
before Congress which were made by the
lobbyist for the person who retained him
and which are not otherwise reported.
REPORTS OF ORGANIZATIONS LOBBYING FOR
THEMSELVES
Any organization which is a lobbyist be-
cause it engages on its own behalf in 12 or
more oral lobbying communications must-
(1) identify each issue which it sought to
influence by making one or more lobbying
communications;
(2)1disclose the identity of each officer, di-
rector, or employee of the organization who
orally engaged in one or more lobbying com-
munications, along with a description of the
Issues on which he worked;
(3) disclose the identity of any affiliated
organizations the lobbyist solicited concern-
ing an issue before Congress, along with a
description of the particular Issue involved;
(4) provide a general description of any
lobbying "solicitations" concerning an issue
before Congress made by the lobbyist not
otherwise reported; and
(5) estimate the total expenses incurred
by the organization In connection with all
its lobbying activities during the 3-month
period. -
The lobbyist would not have to Itemize the
amount spent on particular issues or esti-
mate the particular amounts spent on sal-
aries, overhead, or the like.
REPORTS OF LOBBYISTS THAT SOLICrt -
Any lobbyist that solicits 500 or more other
persons, 50 or more of its employees, or 12
or more of its affiliates on a particular Issue
before Congress or the Executive Branch, and
meets, where applicable the $200 expenditure
test must--
(1) provide a sample of any form letter,
written advertisement, or other similar writ-
ten material used to solicit 500 or more peo-
ple; a transcript, if available, of any adver-
tisement used to solicit orally 500 or - more
people; and a description of the content of
other solicitations used by the lobbyist;
(2) Identify each issue the lobbyist sought
to influence by soliciting the requisite num-
ber of persons and the lobbyist's position oil
the Issue;
(3) estimate the total number of persox?
solicited in connection with each issue, in-
cluding the number solicited by written
means In each state, and identify any affili-
ate which helped make the lobbyist solicita-
tions, along with an estimate of the number
of persons solicited by such affiliate.
(4) estimate the total expenses Incurred
by the lobbyist in connection with each issue
it worked on during the period by soliciting
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(5) if the lobbyist was retained by some
other person to engage in the solicitations,
the amount of money received by the lobbyist
from such person in connection with each
issue.
REPORTING REQUIREMENTS APPLICABLE TO ALL
LOBBYISTS
Each quarterly report filed by each lobby-
ist would also have to include an identiflea-
tion of the lobbyist, and a record of any gift
or loan to a Congressman or his staff exceed-
ing $50 in value which was paid for by the
lobbying organization, or by an individual
lobbyist on behalf of the person who retained
him.
ENFORCEMENT
The bill authorizes a civil penalty of not
more than $10,000 for each violation of the
law. Criminal violations are only authorized
where any person knowingly and willfully
violates the law or files fraudulent informa-
tion.
The General Accounting Office will have
primary responsibility for civil enforcement
of the new law. The Comptroller General Is
authorized to investigate possible violations
and to correct any violations It discovers by
informal methods, by cease and desist orders
issued after an administrative hearing or
through civil litigation in court. The Comp-
troller General may also refer any apparent
civil violation of law to the Department of
Justice for action. If the apparent violation is
criminal in nature, tl, a Comptroller must in
every circumstance refer the proceeding to
the Department of Justice for prosecution.
Each lobbyist and each person who retains
a lobbyist is required by the bill to maintain
financial and other records on which the in-
formation filed with the Comptroller Gen-
eral must be based. The Comptroller General
will have the authority to inspect such rec-
ords when necessary.
The Comptroller General is also given
authority to prepare necessary regulations,
develop forms, render advisory opinions when
requested, and to issue subpoenas. The
Comptroller General is given responsibility
for making the registrations and reports pub-
lic, and preparing special preliminary reports
on' a lobbyist's activities upon the request of
a Senator or Congressman. After each
3-month period the Comptroller General will
be required to publish in the Federal Register
a report based on the registrations and re-
ports filed with it summarizing all the lobby-
ing activities that occurred pertaining to a
specific issue and all the lobbying activities
of persons who share an economic, business,
or other interest In common.
EXAMPLES OF WHO WOULD BE A LOBBYIST
The following are examples of which in-
dividuals and organizations would be a lobby-
ist under the bill's provisions:
(1) An individual citizen, concerned about
the safety of children's toys, journeys to
Washington and talks on her own behalf
to staff assistants in the offices of 80 dif-
ferent Congressmen or Senators. Including
20 from her own state. The cit zen "is not"
a lobbyist because she Is simply expressing
on her ' own bohaif her personal concern
about a matter.
(2) An individual who is personally con-
cerned about an environmental issue buys
with his own funds an advertisement in the
newspaper urging the public to write Con
gress in support of a particular environmen-
tal bill. The individual "is not" a lobbyist
since he is using his own money to express
CsRg7gQ144O~q&0 o5n00&n issue before
Congress.
(3) An individual lawyer is retained by a
company to obtain an amendment to a tax
bill pending in committee. In connection
with the services provided his client, the
lawyer drafts proposed wording, and dis-
cusses the wording with the staff of the
appropriate Committee. The lawyer "Is" a
lobbyist.
(4) Employees of a national company call
Congressional committpes on 20 occasions
during a quarterly filing period in order to
determine whether the committee has sched-
uled hearings on certain bills, and whether
the Committee has reported certain other
bills out of Committee. In addition, the com-
pany president testifies before the Commit-
tee on a particular bill. The company en-
gages in no other communications with Con-
gress. The company "is not" a lobbyist since
the bill excludes from its coverage the spe-
cific types of communications in which the
company engaged.
(5) The president of an organization who
is concerned about the possible effect of a
pending bill on his business travels to Wash-
ington and speaks about the bill on behalf
of the organization to his two Senators and
the Congressman representing the district in
which his business is located. He talks a
total of 15 times to his representatives or
their staff assistants. Since the businessman
only speaks to his own Senators and Con-
gressmen he "is not" a lobbyist.
(6) Three separate individuals employed
by an organization call congressional staff
aides a total of 40 times during a quarterly
filing period in an attempt to secure passage
of amendments to three different bills. On a
fourth issue the company instructs 15 plant
managers to write their own Congressmen
on the issue, but it makes no other effort to
influence Congress. While none of the in-
dividuals would be a lobbyist, the organiza-
tion "is" a lobbyist since together its three
employees orally engaged in over 12 lobbying
communications. The 15 letters sent by the
plant managers do not count in determining
whether the company is a lobbyist, but since
the company is a lobbyist for other reasons,
it would also have to report its interest in
this fourth issue.
(7) A company with a special problem
urges various executive branch officials on 10
different occasions to support legislation to
resolve the problem. The company also talks
on 10 different occasions during the same
three month period with members of the
appropriate congressional committees or
their staff. Since the communications with
the executive branch were on legislation
pending in Congress, they are lobbying com-
munications for purposes of determining
whether the company is a lobbyist. Since the
total of all oral lobbying communications
exceed In this case 12, the company "is" a
lobbyist even if it did not communicate with
Congress on any other matter during the
3-month period.
(8) A national trade association seeking to
gain passage of a bill before Congress sends
a letter to 5,000 of the leading businessmen
An the country urging them to write, or to
talk personally, with their Congressmen in
support of the proposal. The cost of writing,
printing, and mailing the letters was $2,000.
Since this solicitation reached more than
500 persons and cost over $200 to prepare
and send, the organization "is" a lobbyist.
(9) _ A local historic preservation society
worried about the possible destruction of
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an old federal courthouse spends $100 to pre-
pare and distribute a flyer on the street to
about 700 people urging them to write the
Chairman of the appropriate Committee urg-
ing action to save the courthouse. Since the
flyer cost less than $200 to prepare and dis-
tribute, the local historic preservation so-
ciety "is not" a lobbyist.
(10) A national trade association directly
communicates with Congress only when it
wants to know the status of certain bills, but
on four occasions, it writes letters to the 50
companies that are members of the trade as-
sociation and urges them on each occasion
to write their own Congressmen in opposi-
tion to a particular bill pending before
Congress. This solicitation by a trade asso=
elation of more than 12 affiliates means it
"is" a lobbyist.
(11) The Washington office of a company
with 10,000 employees located in five States
writes its 500 top management officials and
requests them to travel to Washington to
talk to their Congressmen and Senators
about a bill directly affecting the company.
Because the company solicited more than 50
of its own employees, it "is" a lobbyist. The
individual employees who travel to Wash-
ington to see their Congressmen "are not"
lobbyists.
(12) A professional association concerned
about the possibility that an executive
branch agency may propose a certain regu-
lation of great importance to its members
spends $300 to distribute a solicitation urg-
ing the 500 individuals who are members of
the organization to write the agency in op-
position to the idea. Since the organization
urged more than 500 persons to communi-
cate with an executive branch agency about
a matter before it, and spent more than $200
to do so, the. organization "is" a lobbyist.
Approved For Release 2001/08/30 : CIA-RDP77M00144R000800150028-1