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1091 <br />BEST BEST & KRaEGER <br />ATTORNEYS AT LAW <br />• Gifts To Agencies Exception: Meals that are paid by a third party donor as a <br />result of a gift to an agency must be evaluated under Regulations 18944- <br />18944.3. <br />E. Picking Up the Meals For Officials From Other Agencies <br />• Prohibition On Reimbursements: An agency is not permitted to pay or <br />reimburse the cost of meals for officials from other agencies as the Attorney <br />General has opined that these expenses are not considered "actual and <br />necessary." However, an agency expense policy with appropriate findings can <br />address this concern. (See www.ca-lig.org/dime.) <br />• Meals Provided For Working Meetings: An agency may pay for a meal for <br />officials and/or members of the public in advance so long as it is in <br />furtherance of a public purpose and not greater than a nominal value. <br />F. Conferences/Trainings <br />• Conference Expenses: Food and "nominal items" provided as part of a <br />conference registration are neither gifts nor income. The courts have <br />concluded that the conference expenses are reimbursable as a "proper <br />municipal purpose."" <br />G. Invitation -Only Events and Fundraisers <br />• Invitation -Only Events: The reporting value of an invitation -only event is <br />determined by considering the admission value of the benefit received by <br />both the official and any guest that may accompany the official, which <br />includes their pro rata share of the cost of the food, catering, entertainment, <br />and any item provided to the official and guest that is available to all guests in <br />attendance. Any other specific benefit (such as golf greens fees) that may be <br />provided to the official and guest, is valued at fair market value. (Reg. <br />18946.2.) <br />Y Drop -Ins At Invitation -Only Events: If an official attends an invitation -only <br />event, and does not have a full meal, but only consumes minimal appetizers <br />and drinks, the reportable value of the gift is the value of any specific item <br />(other than food) presented to the official and any guest that accompanied the <br />official to the event. <br />11 See Roseville v. Tulley, (1943) 55 Cal.App.2d 601 (court deferred to city's conclusion that such <br />attendance would improve city administration and networking purposes). <br />-9- <br />09879.00000A8634133.4 <br />