Three elements define lobbying:

1. The individual is paid by an employer or a client.
2. The individual communicates directly (i.e. either in writing or orally) or indirectly (i.e. grass-roots communication), with a federal public office holder.
3. The individual communicates about one of the following subjects:
   • Development of any legislative proposal
   • Introduction, defeat or amendment of any Bill or resolution
   • Making or amendment of any regulation
   • Development or amendment of any policy or program
   • Awarding of any grant, contribution or other financial benefit