A registrant may split an expenditure with another registrant and not lose the exceptions found in the Penal Code for bribery and gifts.

Note that splitting means that you "join together" and all pay at the same time…all credit cards in the middle of the table. If one person pays and then bills the others, technically that is not a split expenditure, that’s a reimbursement. What’s the difference? If it is a split expenditure, the payers report based on what each spent. If it is a reimbursement, then the person who paid initially owns the full expenditure and reports the full expenditure.

There are some caveats to splitting that could potentially cause you significant legal exposure if you are not careful, including:

• The law provides that a lobby expenditure may be split, and a registrant only has to report the portion that you (the registrant) paid. But, and this is where it gets more complicated, you also have to report as your own, any portion that was paid by a non-registrant. Legislation passed in 2013 clarified the law so that a registrant, who reports the portion of a joint expenditure made by a non-registrant, continues to have the exceptions to the bribery law as provided in the Penal Code for properly reporting so long as the registrant reported the portion made by the non-registrant as required by the statute.

• This exception, however, doesn't cover the non-registrant. So if you split the cost of a meal with your non-registered client, you report the cost of your portion and the client’s portion, but the client is still potentially exposed to a complaint and criminal prosecution for bribery.

• You cannot split an expenditure with a non-registrant totaling more than $500 for entertainment, gifts or awards and mementos, period. And, while the total expenditure in these categories can exceed $500 if you split them only with other registrants, remember that no single registrant's portion can exceed $500. For example, for large events where many people join together to make expenditures (i.e., committee parties, staff-only receptions, end-of-session parties, etc.) - call the organizer and make sure that everyone involved in splitting the event's costs is registered. One non-registrant splitting a party, including an entertainment cost of $5,000, makes the expenditure illegal since the participation of the non-registrant means the total cost of the entertainment expense cannot exceed $500.