Guidelines for Grant and Contract Management
219. Federal Lobbying Disclosure Act
THE UNIVERSITY OF CHICAGO
Office of Legal Counsel
MEMORANDUM
TO: Officers, Deans and Directors
FROM: Arthur M. Sussman,
General Counsel and Vice-President for Administration
IN RE: Federal Lobbying Disclosure Act
DATE: July 23, 1996
The purpose of this memorandum is to advise you about the provisions of the Lobbying Disclosure Act of 1995 and how the University is responding to its requirements. Under the Lobbying Disclosure Act, the University must register and semiannually disclose "lobbying contacts made on behalf of" the University. The definitions of "lobbying contacts" and "...on behalf of...." are, as you might expect, complex.
For purposes of this memorandum, I will focus on one part of the law -- the required disclosure of contacts made on behalf of the University. It is important to try to understand what this means. It is generally agreed that this covers only those contacts which are authorized by the University to be made on its behalf. In order to make sure we are able to comply with the record-keeping and reporting requirements of this law, it is necessary to require that no contact with a member of Congress, a congressional staff member or a senior administration official be "on behalf of" the University unless that contact is authorized, in advance and in writing, by this office. When such authority is granted, it will be necessary to adhere to the record-keeping and reporting requirements of the law, which will be explained as part of the authorization.
This requirement is not intended to limit personal contacts by faculty members made to members of Congress, staff members or senior administration officials to discuss matters of personal or professional interest, but only to make clear that these are not official contacts "on behalf of" the University. Therefore, in making such contacts you should be careful not to indicate that you are representing the University. You may, of course, identify your affiliation so long as it is clear that the contact is on your behalf or on behalf of a group other than the University, e.g., a professional association.
I am sorry to add this complication to your lives, but this is an important matter. If you have any questions, please contact Deborah Hyatt, Director of Government Relations (2-7236) or Sam Golden, Associate General Counsel (2-7239).
AMS:np
