Events in Honor of a Member, Officer, or Employee
At times an outside organization wishes to hold a reception or other event in honor of a Member, officer, or employee. As long as the identity of the sponsor (that is, the person that is organizing and paying for the event) is made clear to all participants (e.g., on the invitations), an event nominally “in honor of” a Member or group of Members is not generally considered a gift in itself to the honoree(s). However, the Members being recognized should not identify themselves as hosts or receive any particular benefit from the event. If they do, the entire cost of the event may be viewed as a gift to the honoree(s).
Thus, for example, a Member with a strong record on environmental issues might be honored at a reception hosted by a nonprofit organization interested in those issues without raising concerns under the gift rule. If the same Member were an amateur photographer, however, and the event was set up to provide the Member with a forum for selling his or her photographs of wildlife, the Committee could find that the entire cost of the reception was a gift from the organization to the Member. The Committee could also make such a finding if the honoree assumes any role in organizing the event, such as hosting the event in the honoree’s home. Put another way, the event must genuinely be the event of the outside sponsor, and it is the sponsor who must determine the nature of the event and the guest list.
Of course, whether a Member, officer, or employee may attend such an event will depend on whether attendance would be permitted under the gift rule. As discussed previously, it is permissible for a Member, officer, or employee to accept a gift (e.g., a meal) that has a value of less than $50, and gifts having a cumulative value of less than $100 from a single source in a calendar year. However, if the host of the event is a private entity that retains or employs registered lobbyists, reliance on the less than $50 provision of the gift rule would be impermissible. On the other hand, depending on the circumstances, such an event may qualify as a “widely attended” event, permitting an invitee to accept food and refreshments furnished to all attendees as an integral part of the event.54 In addition, it is permissible for a Member, officer, or employee to accept at a reception “[f]ood or refreshments of a nominal value offered other than as a part of a meal” (House Rule XXV, clause 5(a)(3)(U)).
Furthermore, it would not be permissible for a Member, officer, or employee to solicit another individual or group to hold a reception or event in his or her honor. Similarly, it would not be permissible for a Member, officer, or employee who is being honored at a reception or event to solicit support for the event.