Prior to the enactment of HLOGA, most registrants had not reviewed their tracking and filing systems for many years. HLOGA in 2007 provided a reminder that it is a good idea to periodically review the internal compliance and tracking systems toassure they are current.
Periodically ask these questions to help keep your LDA disclosure compliance up to date:
- What are we doing to prepare and file LDA reports?
- How do we determine the information that is included on our reports?
- Who has been compiling the information that is used for preparing the reports?
- What are the standards and definitions being used to account for income ortime/costs and expenditures?
- Who reviews the reports prior to filing?
- Who signs the reports?
- What training is needed for ensuring accuracy of the information in the reports?
- What is the documentation for substantiating the contents of each item of information contained in the reports?
- What is the document retention system and policy?
- Who in management should play a role in the review and approval of the systems and the reports?
- What expertise is needed to ensure the existence of a good faith compliance effort?
- What training is needed for the lobbyists and/or others engaged in lobbying activities or communications?
- What are the backup systems to ensure that more than one individual is responsible for the information that is reflected in the reports?
- What are the legal protections in place for the organization and the individuals preparing and signing the reports?
- What process is in place in the event of the organization’s receipt of a letter of inquiry from the House Clerk, the Secretary of the Senate (or the GAO in the event of an audit letter)?