Compliance Q&A: Registration Termination

Q: Is it true that once a nonprofit has registered under the LDA, it will have to continue to register indefinitely regardless of whether it meets the monetary quarterly threshold for lobbying?

A:  No. When there is an agreement that no future lobbying activity is expected for the next quarter or thereafter, or otherwise reasonable expectation that your company will no longer be lobbying on the issue, you would file your LD-2 as a termination.  The absence of activity during a quarter does not relieve the obligation to file.  If there is reasonable expectation that you will commence lobbying in another quarter, you will file an LD-2 form indicating that there was no activity in that period.  If, however, you continued to lobby during that period at a level beneath the amount needed to trigger registration once you are already registered, you will need to indicate the amount spent in that period, because registration has already been triggered and there is a reasonable expectation that your organization will continue to lobby on the issue.

You want to ensure that you DO actually file a termination, as opposed to simply ceasing filings, because failure to file will result in follow-up action by the House Clerk and Secretary of the Senate, who may choose to refer your organization to the Department of Justice.

Tags: , ,

Comments are closed.