In April, the Government Accountability Office released its report to Congress on lobbyists’ compliance with federal disclosure requirements. Much to my chagrin, the GAO failed to highlight some of the common filing mistakes that continue to haunt me day in and day out. So, here are a few of the common mistakes I often encounter while reading lobbying reports.
- The “Covered Official Position” box is where you enter any previous federal positions you may have held, NOT your current job title. Federal positions that meet the requirements of a covered official position must be reported for 20 years. Do not enter “Director of Government Affairs at XYZ Lobbying Firm” on line 18. That is clearly not a federal position. While you may be proud of your recent promotion to Lobbying Head Honcho, the Clerk of the House doesn’t care (for purposes of Line 18). But if you were recently the Under-Under-Under-Under Assistant Secretary for Peanut Butter Consumption at the Department of Defense, that may need to be disclosed.*
- Each firm-client relationship should receive its own report form. And don’t post a vague client name. That goes for you too, Firm-That-Will-Not-Be-Named who registered to lobby for the client “Various Japanese Companies, Governmental Entities, Trade Associations & …” That is really not an acceptable disclosure. Unless of course, the actual, legal name of your client is “Various Japanese Companies, Governmental Entities, Trade Associations & …” but somehow I doubt that is the case.
- In the section marked “Specific Lobbying Issues,” lobbying issues must be specific. Entering “Provisions relating to the passage of HR 2454 Climate Change/Clean Air Act” is specific. Entering “Environmental Issues” is not. Entering “HR2847, S1406: Commerce-Justice-Science Appropriations Act for Fiscal 2010 – provisions related to NASA” is specific. (Good job, Filer-Who-Shall-Not-Be-Named!). Entering “HR 2847 Approps Act” is not.
These issues may seem minor when compared to the reporting of financial contributions. But when you’re filing, you need to make every effort to be compliant and accurate. And since filing errors must be corrected through amendments, being aware of common mistakes found on lobbying reports prior to filing could be a real time-saver.
* I really hope there isn’t a Under-Under-Under-Under Assistant Secretary for Peanut Butter Consumption at the Department of Defense. Also, if you have questions about what is and is not a “covered official position,” check out our Compliance Center.
Tags: filing errors, LD-2, lobbyists