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It can be difficult to determine if someone is engaging in lobbying activity and required to register as a lobbyist under state regulations. Under certain circumstances, a nonprofit employee can influence policy but not be required to register because they did not receive compensation for their work. The following are two recent examples from Iowa and Missouri.

In Iowa, Representative Clel Baudler (R) filed an ethics complaint against Aaron Dorr, executive director of Iowa Gun Owners, alleging that Dorr engaged in lobbying on "stand your ground" legislation without registering as a lobbyist. After reviewing the matter, the Iowa House Ethics Committee determined that because Dorr was an unpaid leader of a nonprofit and not designated as a lobbyist for the organization, he was not required to register. As a result of the ruling, Committee Chair Rob Taylor (R) said that he hoped the legislature would examine the current definition of a lobbyist and change it to include those who discuss policy issues with legislators, regardless of compensation.

Down the road in Missouri, Governor Eric Greitens's (R) former campaign staff formed a nonprofit organization, A New Missouri, to promote the governor’s agenda. As a part of its outreach, the organization paid for buses to transport Missourians from around the state to visit the Capitol and advocate to lawmakers on a piece of legislation under consideration during a special session. The legislation focused on allowing a local utility company to negotiate lower rates for certain users. Afterward, A New Missouri paid for food and drinks at a rally attended by the citizens who were bussed to the Capitol.

A number of Missouri legislators have called on A New Missouri to register, arguing that the organization’s work fits the definition of lobbying. However, the organization has maintained that because it does not employ lobbyists and instead uses volunteers, registration is not required. Under the Missouri Ethics Commission's definition of lobbying, an organization that employs lobbyists is required to register within five days of beginning lobbying. Failure to do so will result in penalties.

The executive director of the Missouri Ethics Commission told the St. Louis Post-Dispatch: “The type of lobbying that you are referring to is sometimes characterized as ‘grassroots lobbying’ — this type of activity may or may not fall within the definition of lobbying.” This debate is Missouri has not been resolved.

When determining whether to register as a lobbyist, it is important to remember the registration requirements for your state. Just because an individual is not employed as a “lobbyist” does not mean that they are not engaging in lobbying activities that could trigger a registration. As a result, it is important to remember that if a person is interacting with public officials, they may be required to register.