Splitting the Cost of a Gift Among Various Sources

Lobbyists and employers may make an expenditure in conjunction with other persons. While each lobbyist/employer is only required to report their proportionate share of a gift, they may NOT split an expenditure that is really a single gift in order to avoid reporting.  If the total value of the gift is greater than $25.00, the amount must be reported even if the lobbyist’s/employer’s share may be $25.00 or less. [See Ohio Lobbying Handbook p. 46 and OAC 101-9-01(D)(2)].

Example:

John and Jane Lobbyist split the cost of greens fees and a cart for a round of golf with Legislator Doe.  The total cost is $40.  Both John and Jane must disclose Legislator Doe as the recipient of a $20 gift on their corresponding activity & expenditure reports.  As the value of the single gift (greens fees and cart) was greater than $25, John and Jane cannot split the expenditure in order avoid disclosure.  

If you have questions regarding the giving or reporting of expenditures, please contact JLEC at 614-728-5100.