A law firm writes to the Commission advising that its partners and associates serve on committees of various organized bar associations. Part of the committees' work involves drafting position papers on behalf of the committees with respect to proposed or pending legislation as well as bills pending before the Governor's office. The position papers may or may not be transmitted to legislators or to the Governor's office by the bar association's registered lobbyist. No fee is received by the firm, its partners or associates for these activities and such activities are not undertaken on behalf of any client. However, such activities may be performed during the firm's regular business day for which the partner or associate receives compensation from the firm.

The question presented to the Commission is whether, under the Regulation of Lobbying Act of 1977 (hereinafter referred to as the Act), the law firm, its partners or associates are required to register as lobbyists.

Such volunteer services are for the benefit of the general public. The expertise of the lawyer is of direct benefit to the legislature or the Governor's office.

The net effect of such volunteer activity actually reduces the net income of the law firm, thus reducing the ultimate income to the firm's partners and associates. Therefore, although the volunteer work is performed during office hours, negative compensation is received and cannot be deemed reportable "income". Accordingly, on the facts stated, the law firm's partners and associates are not required to file a Statement of Registration, Periodic Reports, or Annual Report with the Commission.

APPROVED BY COMMISSION: October 6, 1978

CONCURRING: CHAIRMAN S. STANLEY KREUTZER, VICE CHAIRMAN OWEN McGIVERN, MARGARET C. ANDRONACO, D. CLINTON DOMINICK, DANIEL GUTMAN, and DAVID C. TAIT.