The Proposed Amendments Limiting Gifts from Registered Lobbyists and Lobbying Organizations proposed by the U.S. Office of Government Ethics would eliminate an exception that now allows federal employees of the Executive Office branch to accept invitations to “widely attended gatherings” as guests of organizations that lobby. “When such gifts are offered by persons who are paid to influence government action, the concerns obviously are magnified,” stated the proposal in the Federal Register.
In one of the best rebuttal letters ever written, Steven Hacker, CAE, FSAE, president, International Association of Exhibitions and Events, wrote to the acting director and general counsel of the OGE. IAEE is a 501(c)(6) nonprofit trade association that represents the exhibitions and events industry.
“We are writing to express our profound concerns,” wrote Hacker. “We are fearful that ... if adopted, [the guidelines] will materially impair the abilities and opportunities for those in government service to interact appropriately with the industries they are charged to regulate.”
The most objectionable change, says Hacker is the improper differentiation between organizations of the same class. He highlights the government’s misunderstanding of the differences between “professional” and “trade” associations, differences many in the meetings industry don’t understand.
“Distinctions are made in the proposed amendments between nonprofit professional associations, scientific organizations, learned societies, and trade associations. We think this is unfair and inconsistent with existing law and regulations. We believe that all 501(c)(6) organizations, whether professional societies or trade associations, should be treated uniformly and should all be exempt. It is untrue that ‘... the primary concern of [trade] associations generally is not the education and development of members of a profession or discipline, which is the focus of the proposed exclusion.’ This statement is not correct. The fact is that the focus of most trade associations is to provide their members with education, information, best practices, and guidance. While many are engaged in government affairs and lobbying, those activities are almost always supplemental and subordinate to their main missions.”
He continued, “Limiting the opportunities for those in government service to participate in these events will only serve to isolate regulators from important industry changes and trends of which they must be aware.”
Support IAEE, U.S. Travel Association, and ASAE by submitting comments by November 14 to the OGE at firstname.lastname@example.org.