State of Minnesota

Campaign Finance & Public Disclosure Board
Suite 190, Centennial Building. 658 Cedar Street. St. Paul, MN55155-1603
THE FOLLOWING PUBLICATION DOES NOT IDENTIFY
THE REQUESTER OF THE ADVISORY OPINION, WHICH IS NON PUBLIC DATA
under Minn. Stat. § 10A.02, subd. 12(b)RE:
Expenses that must be reported on lobbyist disbursement reports and annual
reports of lobbyist principals
ADVISORY OPINION 429
SUMMARY
Compensation paid to a lobbyist is the consideration paid to the lobbyist or the lobbyist's employer
for the time that the lobbyist spends (1) communicating with officials to urge official action, (2)urging others to communicate with officials to urge official action, and (3) engaging in any otheractivity that directly support these activities.
When a principal hires a law firm under an annual retainer agreement to provide the principal witha wide range of government affairs services, the principal incurs the entire fee for those services
when the agreement is entered into by the parties. The law firm must track the number of hours
spent on each type of service covered by the retainer agreement and the parties must use thoserecords, along with an assumed rate for each type of service, to determine what costs to report on
the lobbyist disbursement reports and annual principal reports.
An expense is a lobbyist disbursement if it is incurred (1) to communicate with officials for the
purpose of influencing official action, (2) to urge others to communicate with officials for the
purpose of influencing official action, or (3) for any activity that directly supports either of thesetypes of communication.
An annual principal report must include the total amount that the principal spent to influence
governmental action even if no communication with government officials was involved. The total
amount reported must also include the supporting activities listed in Minnesota Statutes section
10A.04, subdivision 6, paragraph (c) (2).

FACTS
As the attorney for a lobbyist principal, you ask the Board for an advisory opinion that the principal
intends to use to guide its Minnesota lobbyist and principal report preparation. Your request isbased on hypothetical facts that you have provided which are, in relevant part, as follows:-1-1. The principal that you represent is a business entity (ABC Company) that has legislative
and administrative interests in Minnesota.
2. ABC Company has retained XYZ law firm to provide it government-affairs-related advice
and services. The services are provided under an annual retainer agreement. A
member of XYZ law firm is ABC Company’s designated Minnesota lobbyist.
3. ABC Company also has an in-house employee who is a registered Minnesota lobbyist.
4. Non-lobbyist employees of both ABC Company and XYZ law firm engage in various
support activities, some of which are directly related to the activity of the lobbyists andsome of which are generally related to the fact that ABC Company has legislative andadministrative interests in Minnesota.
5. ABC Company compensates XYZ law firm by way of an annual retainer agreement
calling for monthly payments of $5,000. The parties understand that ABC Company will
pay XYZ law firm the monthly retainer amount without regard to the amount ofgovernment-affairs-related work the firm does during any particular month, the type ofgovernment-affairs-related work the firm does during the month, and the position of thelaw firm employees who actually performed the work.
6. The work that XYZ law firm performs for ABC Company includes such things as strategic
government affairs consulting, coalition building with industry allies and others withsimilar legislative and administrative interests, direct communications with public officials
to influence legislative and administrative actions, and activities that directly support
those communications such as research, drafting, and preparing materials to be used inthose communications. The work also includes general public relations, communicatingwith the principal’s representatives regarding the status of matters of interest, and similar
activities.
7. ABC Company and both its in-house and outside lobbyist make expenditures. Some ofthese expenditures are made solely because ABC Company has a lobbying presence inthe state and, but for that presence, such expenditures would not be made. Examples ofsuch expenditures would include:
a. Expenses associated with attending meetings or conferences with those whohave similar legislative and administrative interests, but which have noconnection to any specific legislation or administrative action (e.g., travel
expenses for the in-house lobbyist and non-lobbyist employees to attend a social
event to build relationships with representatives of entities with similar
government affairs interests and priorities; travel expenses associated withcorporate executives meeting a newly retained outside lobbyist; etc.).
b. Expenses associated with complying with the laws regulating lobbying (e.g.,
expenses related to managing lobbying registration and reporting requirements,
such as the value of employee time involved in recording, collecting, andcompiling information required to be included on a lobbying report; expenses
associated with obtaining legal counsel with respect to matters such as lobbyist
registration, reporting and compliance with the gift ban; etc.).

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c. Expenses associated with monitoring political developments in Minnesota andascertaining their impact on the company’s legislative and administrativeinterests (e.g., expenses associated with consultants, surveys and polling used
to assist in the development of long-term government affairs strategic planning;etc.).
8. Other expenditures are made in connection with a specific lobbying activity, such as:a. The principal’s payment to a lobbyist for his or her time preparing for andcommunicating with a public official to influence that official.
b. The preparation of materials used in efforts to influence a public official.
c. Expenses associated with meetings wherein strategy is discussed relative to aparticular legislative or administrative matter that the principal and lobbyist intend
to influence.
d. Travel expenses relating to a non-lobbyist executive of the company appearing toprovide testimony before a legislative committee on a bill that the company
supports.
9. Between these two categories of expenditures are other expenditures that are ostensibly
lobbying-related but which cannot be said to directly support a lobbying communication,such as those related to:a. Strategic consultations with respect to general legislative and administrativeinterests in Minnesota (e.g., expenses associated with meetings wherein general
lobbying-related planning and strategy are discussed; discussions with
consultants regarding the effectiveness and implementation of various strategies
for advancing legislative and administrative interests, etc.);
b. Updates on the status of government affairs projects or lobbying activity (e.g.,
preparation of internal reports for company executives relating to the status ofvarious government affairs initiatives in Minnesota; etc.); andc. Public relations-related activities designed to influence the general public’s
opinion about a particular legislative or administrative matter in Minnesota, butwhich do not urge any specific action on the part of the general public.
Based on these hypothetical facts, you ask for the Board's opinion regarding the application of
Minnesota's lobbyist/principal reporting requirements.
Question One
Under Minnesota Rules 4501.0100, subpart 4, “compensation paid to the lobbyist” is notreported on a lobbyist disbursement report but is included on the annual report of lobbyist
principal. How can ABC Company determine what constitutes “compensation paid to thelobbyist” when XYZ Law Firm provides the services of a lobbyist as well as lobbying support andother services?

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Opinion
The concept of "compensation paid to the lobbyist" is important because it defines a category of
payments that are excluded from the periodic reports of disbursements filed by lobbyists but areincluded in the lump-sum amount reported by a principal annually.
This principle is codified in Minnesota Rules 4511.0700 as follows:
Subpart 1. Reporting by lobbyist. Compensation paid to a lobbyist for lobbying is notreportable by the lobbyist as a lobbyist disbursement.
Subp. 2. Reporting by principal. Compensation for lobbying paid by a lobbyist
principal to a lobbyist or to the employer of a lobbyist must be included when
determining the spending level categories for reporting by the lobbyist principal.
Subpart 1 above clarifies that the compensation in question is "compensation paid to a lobbyist
for lobbying." The rule contemplates, and the present request demonstrates, that a person who
is a lobbyist for an association may receive compensation for services other than lobbying.
When applying Chapter 10A, the Board will interpret the phrase "compensation paid to alobbyist" to be limited to that compensation paid to the lobbyist for lobbying.
In the present context, the word "compensation" is used in its ordinary sense, which means
consideration for services. Reimbursements for expenses are separate from compensation
and, if in support of lobbying, must be included in lobbyist disbursement reports.
Subpart 2 of the rule quoted above also makes it clear that compensation paid to a lobbyist
includes compensation paid to the lobbyist's employer for the lobbying services provided by thelobbyist.
The definition of “lobbying” is provided in Minnesota Rules 4511.0100, subpart 3. Lobbying
includes (1) communicating with officials for the purpose of influencing official action, (2) urging
others to communicate with officials for the purpose of influencing official action, and (3) any
activity that directly supports either of these types of communication.
From the above definition, it follows that compensation paid to a lobbyist is the consideration
paid to the lobbyist or the lobbyist's employer for the time that the lobbyist spends (1)communicating with officials to urge official action, (2) urging others to communicate with
officials to urge official action, and (3) engaging in any other activity that directly support these
activities. Compensation for these activities is included in the annual principal's report but is
excluded from lobbyist disbursement reports.
Non-lobbyists may also provide services in support of lobbying and a law firm may have otherexpenditures that constitute lobbying. These payments are not part of the compensation paid tothe lobbyist. As a result, they must be included in the lobbyist disbursement reports.
Question Two
How would “compensation paid to the lobbyist” be reported if ABC Company paid XYZ law firm
$25,000 for general government affairs representation during the five-month reporting period
from January through May ($5,000 per month) but the law firm only performs $10,000 of work-4-

for ABC Company during the period? That is, how is compensation paid by the principal to thelobbying firm, but which is not specifically attributable to any work performed, to be reported?
OpinionThis question asks how much of a principal’s payments are for “compensation paid to thelobbyist” when a fixed-fee retainer agreement includes compensation for a broad range ofservices and the payments for those services do not correspond to the time when the services
are actually provided.
To simplify the discussion, the Board assumes that out-of-pocket disbursements made by XYZ
law firm on behalf of ABC Company are reimbursed in addition to payments made under theretainer agreement. If the disbursements constitute lobbyist disbursements, they will be
included on the lobbyist’s report.
The Board also assumes that the retainer agreement is intended to fairly compensate the law
firm for all of the services it provides. To reach this goal, the law firm and the client must have ashared expectation about the amount of services that they expect to be performed over thecourse of a year and about the assumed rates of compensation for various types of services.
The request suggests that the payment of $5,000 each month is compensation for the services
provided in that particular month. This is not the approach suggested by Chapter 10A. In the
campaign finance program, an expenditure is deemed to be incurred when the obligation to
make the expenditure is incurred. Under this approach, which the Board now adopts forlobbying as well, the compensation for XYZ law firm’s services for the year is $60,000. Thisobligation was incurred at the beginning of the year when ABC Company and XYZ law firm
entered into the year-long retainer agreement. The $60,000 happens to be paid over the courseof the year at the rate of $5,000 per month.
Under section 10A.025, subdivision 3, a person is required to keep detailed records sufficient tosupport what is included in a report filed with the Board. Under that statute, XYZ law firm must
develop and maintain records that reflect with a reasonable degree of accuracy the amount oftime spent on the various types of services it provides to ABC Company. These records must
separately track the services of the XYZ law firm lobbyist for lobbying or in support of lobbying,services of others for activities in support of lobbying, and non-lobbying services.
Minnesota Rules 4511.0600 requires that, to the extent that actual costs of lobbying activities
can be calculated by reasonable means, the actual costs must be used for reporting. The rulealso provides that when actual costs cannot be calculated by reasonable means, a reasonableapproximation may be used. The procedure set forth in the remainder of this section willproduce a reasonable approximation of lobbying costs for reporting purposes.
Lobbyists file two reports annually. The first report covers from January 1 through May 31 of theyear and is due June 15. The second report covers the remainder of the year and is due by
January 15th of the following year. Under the stated facts, a member of the XYZ law firm is
ABC Company’s designated lobbyist. Therefore, that individual will be responsible for reporting
all of ABC Company’s lobbyist disbursements.
After the May 31 cutoff date for disbursements included on the first report, XYZ law firm must
review its records to determine the number of hours of work provided for each type of service.
Minimally, the classes of service must include class (a): services of the lobbyist for lobbying and-5-

in support of lobbying, class (b): services of others in support of lobbying, and class (c): services
that are not included in (a) or (b) above.
Having determined the number of hours for each class of service, XYZ law firm must multiply
those hours by the assumed rate for each service to get the total cost of each class of service.
If the total calculated for all services is not reasonable based on the parties’ expectations ofservices to be performed during the remaining seven months of the year, the assumed rate foreach type of service must be adjusted so that the anticipated cost for all services expected to beprovided over the course of the year equals $60,000.
The value of class (b) services, as calculated above, must be disclosed on the lobbyist
disbursement report. Both class (a) and class (b) services will be included in the total
disbursements reported by ABC Company on its annual principal report. Class (c) services are
not subject to disclosure under Chapter 10A.
For the year-end lobbyist disbursement report, the balance of the $60,000 contract notaccounted for in the calculations for the first five months must be allocated to the services
provided in the last seven months of the year. XYZ law firm again must review its records todetermine the number of hours of work provided for each type of service. XYZ law firm should
multiply the number of hours for each class of service by the assumed rates for each class to
obtain the value of each class of service. If the total of these three values does not equal theunaccounted-for balance of the contract, a pro-rata adjustment of the total for each class ofservice should be taken so that the total value of the contract over the year equals $60,000.
Question Three
Minnesota Rules 4511.0600 lists specific categories of lobbying disbursements that must bereported. But the subparts and items in this rule use different phrases to refer to the different
categories of lobbying disbursements. Does the use of these different phrases create different
standards for determining whether an expense is sufficiently connected to lobbying to constitutea reportable disbursement? Is there a general rule that can be applied in all situations todetermine if an expense is a reportable lobbying disbursement?
OpinionMinnesota Statutes section 10A.04, subdivision 4, requires lobbyist disbursements to bereported in specific categories such as the cost of publications used in lobbying, postage, travel,
entertainment, and other expenses. Minnesota Rules 4511.0600 further defines these specificcategories of lobbyist disbursements and provides additional guidance for reporting lobbyist
disbursements. The rule’s subparts and items, however, use slightly different phrases to referto the lobbying disbursements that must be reported. For example, subparts 1 and 2 refer to
disbursements for “lobbying activities” while subpart 5, item A, refers to “materials that directly
support lobbying.” Subpart 5, item D refers to “costs associated with lobbying activities” while
two other categories of disbursements, entertainment and food and beverage, refer to costs“associated with any situation where lobbying activities take place.”
The rule’s use of these slightly different phrases does not create different standards fordetermining whether an expense is sufficiently connected to lobbying to constitute a reportabledisbursement. Minnesota Statutes section 10A.04, subdivision 4, requires a lobbyist to report“total disbursements on lobbying.” “Lobbyist’s disbursements” are “all disbursements forlobbying made by the lobbyist, the lobbyist’s employer or employee, or any person or-6-

association represented by the lobbyist, but do not include compensation paid to the lobbyist.”
Minn. R. 4511.0100, subpt. 4.
As stated earlier in this opinion, lobbying is defined as (1) communicating with officials for the
purpose of influencing official action, (2) urging others to communicate with officials for the
purpose of influencing official action, and (3) any activity that directly supports either of thesetypes of communication. Minn. R. 4511.0100, subpt. 3. In the Statement of Need andReasonableness for this rule, the Board said that this definition of lobbying was reasonablebecause it
includes in lobbying those activities which directly support the key component, which iscommunication. Without this addition, the definition would be incomplete when applied
to such concepts as disbursements for lobbying, most of which are in support of theactual communication, which is the end result of the process. If disbursements forlobbying did not include support activities, there would be virtually no disbursements forlobbying and no disclosure under the statute.
When Minnesota Rules 4511.0600 is read with the definition of lobbying and its history in mind,
it becomes clear what costs must be reported as lobbying disbursements. Because the key
component of lobbying is communication, a cost is a lobbyist disbursement if it is incurred (1) tocommunicate with officials for the purpose of influencing official action, (2) to urge others tocommunicate with officials for the purpose of influencing official action, or (3) for any activity that
directly supports either of these types of communication.
As a specific example, the costs of travel “associated with lobbying activities” means travel
costs incurred by someone other than the lobbyist (1) to communicate with officials for the
purpose of influencing official action, (2) to urge others to communicate with officials for the
purpose of influencing official action, or (3) for any activity that directly supports either of thesetypes of communication. Similarly, costs “associated with any situation where lobbying activities
take place” means the costs of any setting where communicating with officials for the purpose of
influencing governmental action; urging others to communicate with officials for the purpose of
influencing governmental action; or anything that directly supports either of these types ofcommunication takes place.
Because communication is the end result of the lobbying process, an expense may be incurred
long before the actual communication takes place. But if the expense is used forcommunicating with an official, urging others to communicate with an official, or for any activity
that directly supports either of these types of communications, it is a lobbying disbursement thatmust be reported.
In this opinion, the Board has stated a general rule for determining when an expense is alobbying disbursement. If the requester wants the Board’s advice on the application of that ruleto specific disbursements, the requester may submit another advisory opinion request.
Question FourMinnesota Statutes section 10A.04, subdivision 6, paragraph (b), requires principals to report
the total amount spent to influence official action. This statute does not require the influence on
official action to include any communication with government officials. Does this omission
require principals to use a different standard than lobbyists use to determine what expenses to-7-

include on the annual principal report? If principals are required to use a different standard todetermine what to report, what is this standard?
OpinionMinnesota Statutes section 10A.04, subdivision 6, paragraph (b), provides that a principal “mustreport the total amount, rounded to the nearest $20,000, spent by the principal during thepreceding calendar year to influence legislative action, administrative action, and the official
action of metropolitan governmental units.” This statute does not require the efforts to influence
official action to include any communication with government officials.
This broader reporting requirement is consistent with the definition of “principal.” Minnesota
Statutes section 10A.01, subdivision 33, provides as follows:"Principal" means an individual or association that:(1) spends more than $500 in the aggregate in any calendar year to engage a lobbyist,compensate a lobbyist, or authorize the expenditure of money by a lobbyist; or(2) is not included in clause (1) and spends a total of at least $50,000 in any calendar
year on efforts to influence legislative action, administrative action, or the official actionof metropolitan governmental units, as described in section 10A.04, subdivision 6.
The influence on governmental action described in clause 2 is not limited to communicating withor urging others to communicate with government officials as it is in the definition of lobbyist.
See Minn. Stat. § 10A.01, subd. 21 (defining lobbyist). Consequently, an entity could become aprincipal under Minnesota Statutes section 10A.01, subdivision 33, without ever communicatingwith or encouraging others to communicate with a government official.
Further, an entity that is a principal because it has a lobbyist also may make additional
expenditures to influence governmental action that do not involve communicating with or urging
others to communicate with government officials. Minnesota Statutes section 10A.04,
subdivision 6, paragraph (b), is written more broadly than the lobbyist reporting requirements toensure that the total amount spent by a principal on all attempts to influence governmental
action is disclosed.
Minnesota Statutes section 10A.04, subdivision 6, paragraph (c) (2), specifies that the total
amount reported by the principal must include “all expenditures for advertising, mailing,
research, analysis, compilation and dissemination of information, and public relations
campaigns related to legislative action, administrative action, or the official action of
metropolitan governmental units in this state.” Unlike Minnesota Statutes section 10A.04,
subdivision 6, paragraph (b), this provision does not use the words “to influence” to limit theexpenses that must be reported.
An entity becomes a principal because it has taken steps to influence governmental action
either by hiring a lobbyist or by spending $50,000 or more directly on this goal. The activities
listed in Minnesota Statutes section 10A.04, subdivision 6 (c) (2), all could be used to support
the principal’s efforts to influence governmental action either through its lobbyist or throughdirect spending on issues. For example, a public relations campaign could be used to change
public opinion on an issue that is, or that will be, before the legislature. Because the activities
listed in subdivision 6 (c) (2) provide the underlying support for the principal’s efforts to influence-8-

governmental action, the principal must include the cost of those activities in the total amountspent on lobbying.

Dated: March 5, 2013/s/ Andrew M. Luger
Andrew M. Luger, Chair
Campaign Finance and Public Disclosure Board-9-

Relevant Statutes and Rules
Minnesota Statutes
10A.01DEFINITIONS....

Subd. 33. Principal. "Principal" means an individual or association that:(1) spends more than $500 in the aggregate in any calendar year to engage a lobbyist,compensate a lobbyist, or authorize the expenditure of money by a lobbyist; or(2) is not included in clause (1) and spends a total of at least $50,000 in any calendar year on
efforts to influence legislative action, administrative action, or the official action of metropolitan
governmental units, as described in section 10A.04, subdivision 6.
....
10A.04LOBBYIST REPORTS.

Subdivision 1. Reports required. A lobbyist must file reports of the lobbyist's activities with theboard as long as the lobbyist continues to lobby. The report may be filed electronically. A
lobbyist may file a termination statement at any time after ceasing to lobby.
Subd. 2. Time of reports. Each report must cover the time from the last day of the period
covered by the last report to 15 days before the current filing date. The reports must be filedwith the board by the following dates:(1) January 15; and(2) June 15.
Subd. 3. Information to lobbyist. An employer or employee about whose activities a lobbyist
is required to report must provide the information required by subdivision 4 to the lobbyist no
later than five days before the prescribed filing date.
Subd. 4. Content. (a) A report under this section must include information the board requires
from the registration form and the information required by this subdivision for the reporting
period.
(b) A lobbyist must report the lobbyist's total disbursements on lobbying, separately listing
lobbying to influence legislative action, lobbying to influence administrative action, and lobbying
to influence the official actions of a metropolitan governmental unit, and a breakdown of
disbursements for each of those kinds of lobbying into categories specified by the board,
including but not limited to the cost of publication and distribution of each publication used inlobbying; other printing; media, including the cost of production; postage; travel; fees, including
allowances; entertainment; telephone and telegraph; and other expenses.

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(c) A lobbyist must report the amount and nature of each gift, item, or benefit, excluding
contributions to a candidate, equal in value to $5 or more, given or paid to any official, as
defined in section 10A.071, subdivision 1, by the lobbyist or an employer or employee of thelobbyist. The list must include the name and address of each official to whom the gift, item, or
benefit was given or paid and the date it was given or paid.
(d) A lobbyist must report each original source of money in excess of $500 in any year used forthe purpose of lobbying to influence legislative action, administrative action, or the official actionof a metropolitan governmental unit. The list must include the name, address, and employer, or,if self-employed, the occupation and principal place of business, of each payer of money inexcess of $500.
(e) On the report due June 15, the lobbyist must provide a general description of the subjects
lobbied in the previous 12 months.
. . .
Subd. 6. Principal reports. (a) A principal must report to the board as required in thissubdivision by March 15 for the preceding calendar year.
(b) Except as provided in paragraph (d), the principal must report the total amount, rounded to
the nearest $20,000, spent by the principal during the preceding calendar year to influencelegislative action, administrative action, and the official action of metropolitan governmental
units.
(c) Except as provided in paragraph (d), the principal must report under this subdivision a total
amount that includes:(1) all direct payments by the principal to lobbyists in this state;(2) all expenditures for advertising, mailing, research, analysis, compilation anddissemination of information, and public relations campaigns related to legislative action,
administrative action, or the official action of metropolitan governmental units in thisstate; and(3) all salaries and administrative expenses attributable to activities of the principal
relating to efforts to influence legislative action, administrative action, or the official
action of metropolitan governmental units in this state.
(d) A principal that must report spending to influence administrative action in cases of ratesetting, power plant and powerline siting, and granting of certificates of need under section
216B.243 must report those amounts as provided in this subdivision, except that they must bereported separately and not included in the totals required under paragraphs (b) and (c).

Minnesota Rules
4511.0100 DEFINITIONS.
. . .
Subp. 1a. Designated lobbyist. "Designated lobbyist" means a lobbyist responsible forreporting the lobbying disbursements of the entity the lobbyist represents. An entity that
employs lobbyists may have only one designated lobbyist at any given time.

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. . .
Subp. 3. Lobbying. "Lobbying" means attempting to influence legislative action, administrative
action, or the official action of a metropolitan governmental unit by communicating with or urging
others to communicate with public officials or local officials in metropolitan governmental units.
Any activity that directly supports this communication is considered a part of lobbying.
Subp. 4. Lobbyist's disbursements. "Lobbyist's disbursements" include all disbursements forlobbying made by the lobbyist, the lobbyist's employer or employee, or any person or
association represented by the lobbyist, but do not include compensation paid to the lobbyist.
4511.0200 REGISTRATION.
. . .
Subp. 3. Registration of designated lobbyist. A designated lobbyist must indicate on thelobbyist registration form that the lobbyist will be reporting disbursements for the entity thelobbyist represents. An entity that employs lobbyists may have only one designated lobbyist. A
designated lobbyist who ceases to be responsible for reporting the lobbying disbursements ofan entity must amend the lobbyist's registration with the board within ten days.
4511.0600 REPORTING DISBURSEMENTS.
Subpart 1. Determination of actual costs required. To the extent that actual costs oflobbying activities can be obtained or calculated by reasonable means, those actual costs must
be determined, recorded, and used for reporting purposes.
Subp. 2. Approximation of costs. If the actual cost of a lobbying activity cannot be obtainedor calculated through reasonable means, those costs must be reasonably approximated.
Subp. 3. Disbursements allocated between multiple entities. A disbursement for lobbying
purposes that benefits more than one entity for which a lobbyist is separately registered must be
allocated between the entities benefited on a reasonable basis and reported based on that
allocation.
Subp. 4. Disbursements which are only partially in support of lobbying. A disbursementthat is partially in support of lobbying and partially for a nonlobbying purpose must be allocatedon a reasonable basis between the two purposes and the portion which is for lobbying activities
must be reported.
Subp. 5. Specific disbursement categories. Lobbying disbursements must be reported
based on the categories in items A to I.
A. "Lobbying materials" includes the cost of production, purchase, or other acquisition ofmaterials that directly support lobbying.
B. "Media costs" includes the cost of media space or time, including Web site design andmaintenance, used for lobbying activities. The cost of preparation of materials for use in
the media is reported in the lobbying materials category.

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C. "Telephone and communications" includes costs for local and long-distance telephoneservices, electronic mail, pagers, cellular telephones, facsimile distribution services,
telegraph, and other communications services.
D. "Postage and distribution" includes costs of postage from the United States Postal
Service as well as other distribution costs associated with lobbying activities.
E. "Fees and allowances" includes fees for consulting, surveys, polls, legal counsel, orother services as well as expenses associated with those services.
F. "Entertainment" includes costs of all entertainment associated with any situation where
lobbying activities take place.
G. "Food and beverages" includes costs of all food and beverages associated with any
situation where lobbying activities take place.
H. "Travel and lodging" includes costs of all travel and lodging associated with any lobbying
activity, excluding the costs of the lobbyist's own travel to accomplish the lobbying
activity.
I. "Other disbursements" includes general administration and overhead and any otherlobbyist disbursements not reported in other categories.
. . .
4511.0700 REPORTING COMPENSATION PAID TO LOBBYIST.
Subpart 1. Reporting by lobbyist. Compensation paid to a lobbyist for lobbying is notreportable by the lobbyist as a lobbyist disbursement.
Subp. 2. Reporting by principal. Compensation for lobbying paid by a lobbyist principal to alobbyist or to the employer of a lobbyist must be included when determining the spending level
categories for reporting by the lobbyist principal.

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