September 19, 2013
I could not find your final rule, but I hope it addresses the following:
1) Municipal Employees providing advice to other municipalities. For example, if County A calls City B for advice, can City B give advice? If the Employee of City B "officially" gives advice, then that creates a potential liability (County A could sue City B for bad advice). We are happy to share our experience and expertice, but not if that creates a potential liability.
2) The Public. At the public hearing to approve a bond issue (or in a letter to their elected official), if a member of the public expresses their thoughts, that could be constured as "giving advice", and thus make them subject to registration.