Reporting Gifts from Multiple Sources

If you make a reportable expenditure in conjunction with other persons or entities, you are only required to report your proportionate share. However, you may not separate expenditures that are really a single gift to reach the conclusion that the gift is not reportable.  Although you must disclose the gift; you are required to report only your proportionate share.

EXAMPLES

• A legislative agent and the agent’s employer pay the green fee for a round of golf, valued at $40, for a public official or a staff person who files a Financial Disclosure Statement. Each pays $20.

The legislative agent and the employer will each report $20 in Section A – Gifts, on their activity and expenditure report for the reporting period in which the round of golf was played. Although each will only report their proportionate share of the expenditure, the value of the gift is $40, which exceeds $25 and must therefore be disclosed. A reference that the amount disclosed is the filer’s proportionate share should be included in the gift description field.

• Two legislative agents who share similar interests wish to take the newly hired caucus counsel to a baseball game to establish rapport with the caucus counsel. The cost of the ticket is $45, which the legislative agents split.

Each legislative agent will disclose $22.50 in Section A-Gifts on their activity and expenditure report for the reporting period in which the game was played. Although each will only report their proportionate share of the expenditure, the value of the gift is over $25 and therefore must be disclosed.