III. Private Entities With Shared Goals

The House organizations described above often share goals with outside entities. Sometimes Members who have formed a CMO are affiliated with a private foundation or institute with similar objectives. Members may cooperate with these private entities, subject to all the generally applicable restrictions on involvement with outside entities, as described in this chapter.

No outside entity may imply official House sponsorship. The letterheads of a CMO and any outside organization with related goals should be sufficiently distinct as to avoid any confusion of identities. No outside organization may use any official funds or resources, including House office space, the frank, and staff time. Public and private funds must be kept absolutely separate. While outside entities may raise private funds, these funds may not be used to support any official functions. Official and unofficial organizations may not co-sponsor events or jointly undertake any activities. As to any event or activity that is sponsored by a CMO or outside organization, the identity of the sponsoring entity should be made clear. No House resources, including staff time, may be used to support any event or activity of the outside organization, and the Members of the CMO may not accept any resources of the outside organization (or any other private individual or entity) in furtherance of the CMO’s events or activities.

Example 1. Several Members organize an informal caucus to assist them in foreign trade matters. An academic who has written extensively on foreign trade issues offers his assistance. While he may address the group and provide them with a copy of a report he had previously prepared, he may not be a regular member of the informal caucus.

Example 2. A group of private individuals has formed a coalition to promote environmental legislation. Member A may join the coalition, but she may not permit the coalition to suggest that it has any official standing within the House, nor may she permit the coalition to use any congressional resources, including staff time, in connection with the coalition’s work.

Example 3.  A trade association is interested in issues being considered by a CMO. The association offers to “sponsor” the CMO by providing staff support and hosting weekly breakfast meetings on the CMO’s behalf. The Members may not accept the offer. However, the association may host its own reception for the CMO, provided that the event is not characterized as a CMO function and the invitations for the event are issued by the association, not the CMO.

Example 4. An informal staff group is planning an open house to encourage new employees to join. The reception may be held in House facilities. A supermarket chain that does not retain or employ a federal registered lobbyist offers to provide sodas for the event. The offer may be accepted, provided that the acceptance would not give rise to an appearance of improper influence.