A.1. Grassroots Lobbying

(1) Grassroots lobbying or indirect lobbying is communication that attempts to

influence the opinion of the general public, or any segment of the general public about legislation. Forms of communications include propaganda and other materials affecting public opinion.

(2) A communication is a grassroots lobbying communication if it:

a. Refers to specific legislation;

b. Reflects a view on the legislation; and

c. Encourages the recipient of the communication to take action with respect to

the legislation. See Treas. Regs. 53.4945-2(a)(1) and 56.4911-2(b)(2)(ii).

(3) The specific rule for communications with members under Section 4911 generally

does not apply to private foundations. See Treas. Reg. 53.4945-2(a)(2).