* Disclosure forms do not require clients to state clearly the average cost per person.
Calculating the average cost per person may not be as simple as dividing the total cost by the number of people attending.
Because the forms and instructions are unclear, the amount listed can represent either the total cost of the event,
the amount spent on only the officials who attended or the average cost per person.
VPAP has adjusted these expenses
In an attempt to simplify the data and keep it consistent, VPAP has recalculated the cost of a limited number of lobbyist entertainment reports where the amount spent on public officials was only a fraction of the total cost of the event.
A Virginia Ethics Council opinion states that if a lobbyist invites an executive or legislative official to an event, it is presumed that (a) lobbying has taken place and (b) the entire cost of the event must be listed as a lobbying expense. This opinion has resulted in disclosures that defy common sense. (In one example, a trade association felt compelled to report more than $100,000 in lobbying expenses for an event attended by more than 800 people, only one of whom was a reportable official.)
VPAP has adopted a policy to recalculate the costs of an event that fit the following criteria:
The cost of the event is more than $5,000
There are 50 or more people attending
The disclosure form lists the number of executive or legislative officials in attendance
The officials listed represent 10% or less of the number of people in attendance
In each case, VPAP has preserved the original (higher) amount reported. But VPAP uses the adjusted (lower) amount when compiling lists that compare how much clients spend on entertainment.
# "Portion of Cost to Entertain Officials" was calculated based on this formula: (average cost per person x the number of executive or legislative officials present)
Why did VPAP recalculate the cost of this event?
METHODOLOGY: CGI reported the items shown on required personal financial disclosures, known as Statement of Economic Interests.