Q: How long would you recommend that all filers maintain their records in order to comply with the Lobbying Disclosure Act’s record retention requirement?
A: The House and Senate LDA Guidance requires document retention for six years. The documentation supporting each LDA report should be maintained with a copy of the as-filed report and maintained for six years.
When the Government Accountability Office audits lobbying firms, they ask for documentation on several things:
- Lobbying income or expenses
- Specific issues lobbied
- Identity of lobbyists engaged in lobbying activities on each issue during the reporting period
- Disclosure of “active participants” in lobbying activities of a coalition or association
- Disclosure of the interest(s) of a foreign entity in each issue lobbied
- Termination of individuals no longer engaged in lobbying for the filer
- The agency or house of Congress lobbied on each issue
- Proper disclosure of “prior government service” for individual lobbyists listed on the reports
Make sure your lobbying firm (even if you’re a sole practitioner) has an internal compliance system in place for documenting and retaining these records for each client.
This information is condensed from the Lobbying Compliance Handbook, by Cleta Mitchell.
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