Pending rulings/statements

1. May an Organization’s board members, whose employers are expected to purchase their board seats, like the Michigan Economic Development Foundation (MEDF), for a minimum dues payment of $25,000 per year, use those dues to fund grants made by the Organization to assist in the payment of expenses incurred by these trade missions conducted by the State of Michigan?
2. Upon the invitation of the MEDC or the Governor, may the Organization underwrite the expenses of selected board members for their travel, lodging, gifts, food, and beverages incurred while participating as a guest at State of Michigan sponsored trade missions accompanying and in the proximity of various state public officials?
3. Would those board members, who are registered as lobbyist agents for their employer, be considered a representative of the lobbyist?
4. Would those payments or reimbursement of a board member’s participation in a state trade mission be considered a lobbying expenditure that is used in the calculation to determine whether the Organization reaches the $3,200 threshold that is required for the Organization to register as a “lobbyist”?
5. Are the following lobbying expenditures made by the Organization part of the calculation in determining whether the $3,200 threshold has been reached that requires the Organization to register as a lobbyist within 15 calendar days of crossing that expenditure threshold:
   1. Expenditures made on behalf of or for the benefit of state public officials, to include the Governor and other lobby able state public officials, such as food, beverage, travel, lodging, financial transactions, and gifts, and
   2. Compensation paid for lobbying.
6. May the Organization, if it is determined to not be a lobbyist, use its own treasury funds to pay for gifts to state public officials that are over $79 in fair market value? These gifts may be distributed to state public officials by the Organization’s executive director, who will not be a lobbyist agent. Those gifts consist of, but not limited to, tickets to attend professional and college football, basketball, baseball, hockey games, theater performances, music concerts, and golf greens fees and carts.
7. If determined to not be a lobbyist, may the Organization’s board members in recognition of their Board service receive an honorarium in the form of tickets paid for by the Organization to those same ticketed events provided to state public officials?

There are currently no pending rulings/statements.