It is about to become a little more challenging for companies to pay travel costs for House Members and staff.  Starting for trips on or after April 1, 2013, Members and employees of the House must submit pre-approval request forms to the House Ethics Committee at least 30 days prior to the trip.  Previously, they could wait until two weeks out to submit this paperwork.  This means that trip sponsors will need to start preparing these events sooner than they currently do.  In addition, a trip sponsor’s duties will no longer be over even when the event itself is.  Sponsors must submit to the House Member or staffer a “Sponsor Post-Travel Disclosure Form” itemizing actual expenses paid on behalf of the traveler within 10 days of the Member or staffer’s return.

These changes are just two of many reflected in new House Ethics Committee travel regulations issued late last year.  Among the other new topics covered in these 26 pages of rules (now formatted to look like federal regulations):

  • an exception that allows lobbyist board members of sponsoring organizations to plan, organize, request, or arrange trips for House Members and employees if the board member does not lobby for the sponsor or a related entity on issues related to the officially-connected purpose of the trip;
  • more detail concerning what counts – and what does not count – as de minimis lobbyist involvement in a trip;
  • an affirmation that trip sponsors can be subject to criminal penalties if false information about the trip is submitted to the House Ethics Committee;
  • special rules regarding travel offered by private foundations;
  • a discussion regarding multi-destination and mixed purpose trips; and
  • a list of situations in which first-class airfare can be paid by the trip sponsor.

Simply put, these new rules illustrate two important points for those thinking about paying the travel costs for House Members and staffers: (1) plan ahead and (2) carefully vet each trip, even if the company has previously provided travel for similar events.

Tags: Committee on Ethics, House of Representatives, traps for the unwary, travel rules
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Photo of Zachary G. Parks Zachary G. Parks

Zachary Parks advises corporations, trade associations, campaigns, and high-net worth individuals on their most important and challenging political law problems.

Chambers USA describes Zachary as “highly regarded by his clients in the political law arena,” noting that clients praised him as their “go-to outside…

Zachary Parks advises corporations, trade associations, campaigns, and high-net worth individuals on their most important and challenging political law problems.

Chambers USA describes Zachary as “highly regarded by his clients in the political law arena,” noting that clients praised him as their “go-to outside attorney for election law, campaign finance, pay-to-play and PAC issues.” Zachary is also a leading lawyer in the emerging corporate political disclosure field, regularly advising corporations on these issues.

Zachary’s expertise includes the Federal Election Campaign Act, the Lobbying Disclosure Act, the Ethics in Government Act, the Foreign Agents Registration Act, and the Securities and Exchange Commission’s pay-to-play rules. He has also helped clients comply with the election and political laws of all 50 states. Zachary also frequently leads political law due diligence for investment firms and corporations during mergers and acquisitions.

He routinely advises corporations and corporate executives on instituting political law compliance programs and conducts compliance training for senior corporate executives and lobbyists. He also has extensive experience conducting corporate internal investigations concerning campaign finance and lobbying law compliance and has defended his political law clients in investigations by the Federal Election Commission, the U.S. Department of Justice, Congressional committees, and in litigation.

Zachary is also the founder and chair of the J. Reuben Clark Law Society’s Political and Election Law Section.

Zachary also has extensive complex litigation experience, having litigated major environmental claims, class actions, and multi-district proceedings for financial institutions, corporations, and public entities.

From 2005 to 2006, Zachary was a law clerk for Judge Thomas B. Griffith on the United States Court of Appeals for the District of Columbia.

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