I never thought I would say this but the state lobby folks (you know those staffers on the third floor that are treated like the poor cousins from up in the mountains) could learn a lesson from the New York City lobby bureau. This is the same NYC lobby bureau that we use to give a helping hand in the form of our internal controls and audit protocols. They were understaffed and overwhelmed and quite frankly appreciative of the help we provided. But now they are the ones that should be teaching the PIC how to run an integrity agency.
What do I mean? Well it’s simple Jamie Ekle, the city lobby bureau’s lawyer (they don’t use 6 overpaid under talented lawyers like PIC)(memo to new chair fire the lawyers and recruit Jamie you’ll save money and have a competent employee) sent out an email (what PIC would call an eblast) explaining how they interpret due dates. It’s clear and concise and answers the question I asked of Cherkasky Miccio and Ginsburg over 7 months ago. I’ve reproduced it below so PIC can copy it, that way you don’t need another 10 meetings, internal emails to cover your ass that you’ve changed how you calculate due dates and personal and confidential memos regarding THE BIG SECRET (btw wrap those personal and confidential in brown paper and have them delivered to your home address in the future) Its just a due date not the enigma codes.
Anyway kudos to the NYC lobby bureau lets hope PIC can get over themselves and tell us finally when the due dates for registrations are. It’s not fair to impose late fees when you haven’t told the lobby community when they should file.
Here are the NYC rules. All you need to do Ralph is cut and paste, take credit and hope no one notices your previous inconsistencies (I’ve got your memos thank god for plain brown wrappers)
b. Retainer date- Some retainers are in the form of correspondence, and as such are dated at the top of the document. This date is used to determine the timeliness of a statement of registration. This office considers the retainer date, the latest possible date a lobbyist will anticipate representing client and exceeding the reporting threshold, and thus, the 15-day period to file a statement of registration commences to toll on that date.
c. Signature date- Practically all retainers filed with this office have signature dates. On occasion the signature date is the same as the retainer date, but at times the dates are different. If there are no defined dates of representation, the signature date in the retainer may be used to verify the start date in a statement of registration. If there is a variation in these dates, the signature date will be deemed the correct start date.
As stated above, the purpose of this announcement is not to dictate the content or form of your retainers. Nor is there any suggestion that you amend your retainers to include the dates listed above. Rather this announcement is to inform you of the implications of dates in a retainer, and how such dates are used for compliance purposes.