RE RIN 3209AA04 [Proposed Amendments Limiting Gifts from英文资料.pdfVIP

October 5, 2011 Don Fox Acting Director and General Counsel Office of Government Ethics 1201 New York Avenue, NW Suite 500 Washington, DC 20005-3917 RE: RIN 3209-AA04 [Proposed Amendments Limiting Gifts from Registered Lobbyists and Lobbying Organizations] Dear Mr. Fox: ASAE is appreciative of the opportunity to comment on proposed rule RIN 3209-AA04, which restricts all executive branch employees of the Federal Government from using certain exceptions to accept gifts from registered federal lobbyists and lobbying organizations, including invitations to widely attended gatherings (“WAGs”). The American Society of Association Executives (“ASAE”) is a section 501(c)(6) individual membership organization of more than 22,000 association executives and industry partners representing nearly 12,000 tax-exempt organizations. Its members manage leading trade associations, professional societies, and voluntary organizations across the United States and in 50 countries around the globe. We advocate for associations so that they may continue to fulfill their important missions and improve the quality of life in the United States and abroad. ASAE fully supports OGE’s mission to promote high ethical standards for executive branch employees, and is generally accepting of OGE’s intention to limit some of the exceptions that may have been used on occasion to permit certain gifts, such as invites to holiday parties or other social events, where the nexus to the government’s interest is attenuated. ASAE is encouraged, further, by OGE’s acknowledgement that certain widely attended gatherings can serve important government purposes. OGE justly asserts in its proposed rule that federal employees, including political appointees, should be able to accept offers of free attendance to “substantive events that would provide a legitimate educational or professional development benefit that furthers the interests of an agency.” In crafting that exception, OGE pr