Posts Tagged ‘filing’

Federal Lobbying Disclosure Due

Friday, January 18th, 2013 by Geoffrey Lyons

LOBBYBLOG REMINDS YOU that two disclosure deadlines are approaching:

January 20 – LD-2
The once semi-annual, now quarterly report of lobbying income/expenditures is due for the fourth quarter of the LD-2 reporting calendar (see below). “Each registrant must file a quarterly report on Form LD-2 no later than 20 days (or on the first business day after such 20th day if the 20th day is not a business day) after the end of the quarterly period beginning on the first day of January, April, July and October of each year in which a registrant is registered.” (House Office of the Clerk). January 20th is in fact a Sunday, and the following Monday is a holiday, so make sure to get your LD-2 forms ready by Tuesday the 22nd.

Reporting Period    Filing Date
Jan 1 – March 31 April 20
April 1 – June 30 July 20
July 1 – Sept 30 Oct 20
Oct 1 – Dec 31 Jan 20

January 30 – LD-203
The semi-annual report is required of all lobbyists to certify ethics compliance and disclosure. “Form LD-203 is required to be filed semiannually by July 30th and January 30th (or next business day should either of those days fall on a weekend or holiday) covering the first and second calendar halves of the year. Registrants and active lobbyists (who are not terminated for all clients) must file separate reports which detail FECA contributions, honorary contributions, presidential library contributions, and payments for event costs.”  January 30th is a Wednesday.

For quick guidance on disclosure, visit  For a more substantive reference guide, consider The Lobbying Compliance Handbook

What to Report on the LD-203

Wednesday, July 6th, 2011 by Brittany

The single most significant change in HLOGA is the semi-annual filing of what is referred to as the “contributions reports.” The LD-203 is required to be filed individually by every registered lobbyist, as well as organizations that employ lobbyists, in addition to each registrant’s LD-1 and LD-2 reports. 

The LD-203 is known as the “Semi-Annual Report of Contributions” and is filed according to the following calendar.

Reporting Period                                                                             Filing Date

Jan. 1 through June 30                                                                   July 30

July 1 through Dec. 31                                                                    Jan. 30

The report is filed electronically and every lobbyist must obtain his/her own separate filing password from the Senate. Do not wait until the week or day before the report is due to obtain the electronic password for any newly registered lobbyist employee. It takes several days to obtain a password for the mandatory electronic filing. Obtain all required passwords – for both the registrant and all lobbyist employees – well before the report is due to be filed.

There are three primary provisions of the LD-203:

  • Certification of compliance with the House and Senate Ethics Rules related to gifts and travel
  • Disclosure of certain political contributions
    • PAC contributions to candidates, leadership PACs and national party committees ($200 or more)
    • Contributions to presidential libraries ($200 or more)
    • Contributions to inaugural committees ($200 or more)
    • Disclosure of certain payments and disbursements
  • Contributions of any amount to events and entities involving covered executive or legislative branch officials Pokies

Guidance from the House and Senate Regarding Costs and Payments Subject to LD-203 Reporting

The official guidance to the LDA reporting was amended on July 16, 2008 and substantially narrowed the payments and contributions subject to reporting on the LD-203.

The key points of the guidance include:

  1. A speaking role by a covered official does NOT trigger disclosure.
  2. A contribution to another organization which honors a covered official does not necessarily trigger reporting on the LD-203 (but could under certain circumstances).
  3. A separate segregated fund PAC established and controlled by a lobbying registrant must be disclosed on the registrant’s LD-203. If a registered lobbyist serves on the board or as treasurer of a PAC that is a separate segregated fund, then he/she must disclose ONLY that role on his/her individual LD-203, and only the connected organization registrant (the firm, the association or the company) must disclose the PAC contributions of $200 or more to federal candidates, leadership PACs and federally registered political party committees.

However, for non-connected PACs (associated with partnerships such as law firms and lobbying firms that are organized as partnerships), not only must the firm report all the contributions from the PAC, but also any lobbyist who serves on the non-connected PAC board or who directs the contributions from the non-connected PAC must report the contributions on his/her individual LD-203 report.

For more information or to purchase the Lobbying Compliance Handbook click here.

Filing Alert: LDA Forms Due TODAY

Wednesday, October 20th, 2010 by Vbhotla

Don't forget to file today!

Finish compiling your paperwork and submitting it to the House Clerk and Secretary of the Senate – entities registered to lobby must file their LD-2 forms with the Clerk of the House and Secretary of the Senate TODAY, October 20.

These reports cover the 3rd Quarter of 2010, from July 1 – September 30, 2010.

Find forms and instructions here at the Clerk of the House’s website.

Filing Alert: LDA Forms Due Oct. 20

Wednesday, October 13th, 2010 by Vbhotla

Filing time!

You have one week to finish compiling your paperwork and submitting it to the House Clerk and Secretary of the Senate.

That’s right, it’s that time of the year again – 3rd Quarter 2010 LDA reports are due to the Clerk and Secretary by October 20, 2010.

Read more about filing, and find forms and instructions here at the Clerk of the House’s website.

Now’s a good time to review what you need to file.

Compliance Q&A: Who Has to File the LD-203?

Thursday, August 5th, 2010 by Vbhotla

Q: Who is considered a registered lobbyist for purposes of filing the LD-203 semi-annual certification?  That is, if you did lobbying a year ago but have done none during the reporting period, do you still have to certify?

A: The first question to ask yourself is: Are you still registered? That is, are you still shown on the LDA report for that particular client?If you are listed on a LDA report for a client as the lobbyist, then you must file and certify the LD-203. If you have truly done no lobbying for a client in a year, then you need to be terminated off the lobbying report.

For example, in this old screenshot from a 2008 US Chamber lobbying report, the following lobbyists are on Line 18 as having lobbied on behalf of the issues listed:

If you haven’t been marked as terminated from a lobbying report, you’re still under obligation to file the LD-203.

Have a question for Compliance Q&A? Submit your questions to

Lobbying Disclosure: Kilroy Plays the Blame Game

Wednesday, August 4th, 2010 by Vbhotla

In a recent press release, Mary Jo Kilroy (D-Ohio) explained the purpose of her Lobbying Disclosure Enhancement Act, saying,

“When Americans on Main Street try to cheat or break the law; there are repercussions… [this bill] will go after the lobbyists who engage in shoddy practices and hide behind ignorance of the law.”

(View the release here).

However, what Kilroy is trying to fix is not as much a lobbying problem as it is a federal government problem.  Lobby disclosure may not be the most popular rule on K Street but it is still the law of the land and the vast majority of lobbyists willingly adhere to it.  The only reason that lobbyists continue to hide behind “ignorance” of the law is because the Department of Justice has neglected its side of the bargain.

The idea behind Kilroy’s bill is nothing new; in fact some lobbyists have spoken out in favor of greater disclosure, saying that having a system of lobbying laws but no enforcement makes a mockery of the entire system.  Following the law is the responsibility of each individual lobbyist. Enforcing the law is solely the responsibility of the Department of Justice. In short, Kilroy should be requiring the Department of Justice to change its “shoddy practices,” not lobbyists. But lobbyists are low-hanging fruit, since many citizens don’t understand the First Amendment political speech right of having a government relations representative.

Kilroy’s bill as originally introduced intended to place more impetus on the lobbyists themselves to ensure complete lobby filings, with fee structures and fines for underdisclosure.

Americans don’t speed down Main Street when a cop is sitting in the McDonald’s parking lot and lobbyists won’t be ignorant of the law if the federal government enforces its own regulations.

Filing Reminder: LD-203 Forms Due Today

Friday, July 30th, 2010 by Vbhotla

All lobbyists listed on LDA registration and reporting forms (LD-1 & LD-2) must file and certify their LD-203 Form TODAY, Friday, July 30.

Get that last minute paperwork in to the Secretary of the Senate and the Clerk of the House.

Need to catch up on what’s required in your filing? Check out the Lobbying Compliance Handbook for easy-to-use, practical compliance advice and legal analysis.

Filing Reminder: LD-203 Forms Due Next Week

Thursday, July 22nd, 2010 by Vbhotla

LD-203 Filing Time!

All federally-registered (more on that here) lobbyists must file and certify their LD-203 form next week.

The form is due July 30, and there is no extension available.

First time filer? Take a tutorial here at the Senate’s site.

Interested in researching previous filings? Downloadable and searchable databases are here.

Take time to read the House and Senate gift and ethics rules, since you must certify that you have read, understood, and abided by those rules.

LD-2 Filing: Be Specific

Friday, July 9th, 2010 by Vbhotla

Do you remember how we kept telling you to be specific in filing your LD-2 forms?

Someone didn’t take our advice, and for their pains, they got a nice little write-up by Politico and the Center for Public Integrity.

The screenshot below is not acceptable filing, because on Line 16, they entered “health issues” as their “specific” lobbying issue. “Health issues” is not specific. Stating specific bill numbers and titles is specific. (E.g. “HR 1234, a bill to modify the appropriations process for Medicare/Medicaid, provisions regarding funding for federal employees”…). You don’t even have to state which side of the issue you fall on.

Unfortunately, their LDA filing is full of these under-disclosures.

While we tend to find these incorrect filings mildly humorous over here at Lobby Blog, the fact remains that this is not funny. The law requires that you file completely and correctly. Even a cursory glance at the requirements can solve these problems.

Don’t open yourself up for embarrassing and costly investigations. Follow the law. Everyone will be happier.

Don’t forget to file: LD-203 reporting requirements stressed

Monday, June 21st, 2010 by Vbhotla

All lobbyists must file a report on their political contributions, the Clerk of the House and Secretary of the Senate stressed in their semi-annual guidance for lobbyists.  Two changes were made in this cycle to the guidance (first released after HLOGA was implemented) – a modification of language to stress the importance of filing the LD-203, and a clarification of the requirement for disclosing former positions in the government.

In Section 6 of the guidance, the Clerk of the House clarified that “once a filer has met the previously described statutory requirement for listing a new lobbyists’ previous covered position(s), then the filer does not have to list those positions again for subsequent reports concerning the same client.” A different client for the same lobbyist would require another listing of the lobbyist’s previous covered positions. In other words, once filed on an LD-1, the covered positions do not need to be disclosed on subsequent LD-2s for the same firm/client relationship.

Section 7 of the guidance stresses that “sole proprietors and small lobbying firms are reminded that two reports are required: one filed by the registrant and one filed by the listed lobbyist (even if the lobbyist is the registrant and vice versa).”

The Clerk and Secretary work to implement changes to the non-legally binding LDA guidance issued every six months. Lobbyists and others with interest in the LDA may submit comments to the House Clerk.  This June 15 guidance supersedes all previous versions (the guidance is typically released every 6 months).

View the guidance online at

Erring on the Side of Accuracy

Thursday, June 17th, 2010 by Vbhotla

I sat down for a chat with lobbying law expert Cleta Mitchell a few weeks ago. We were discussing, among other things, the upcoming 2010 Edition of the Lobbying Compliance Handbook.

One of the most interesting things Cleta mentioned was that there is too much emphasis recently on the side of disclosure simply for the sake of disclosure. “People talk about erring on the side of caution, but really, instead of erring on the side of disclosure, they should err on the side of accuracy.”

Cleta has a passion for accurate, thorough information. She’s right – it is foolish to overdisclose and illegal to underdisclose. The solution to that problem is to completely and accurately follow what the law requires – which (among other things) is: full disclosure of lobbying clients, the issues upon which you’re lobbying (be thorough!) and amount of money that you’re earning to speak on behalf of your clients.

Why not take a moment to brush up on what the law requires? The payoff is knowing that you’re completely in line with the law. There is plenty of room within this model for good-government groups and ethics watchdogs (and lobbyists themselves, of course) to suggest improvements and changes in the information that is disclosed. That’s a good thing – a citizen-governed nation requires a lot of oversight and maintenance. But don’t assume that disclosure for disclosure’s sake is necessarily a good thing.  As a lobbyist, you should already be maintaining a high regard for the facts – and a commitment to passing them along truthfully.

Updated LDA Guidance Available

Wednesday, June 16th, 2010 by Vbhotla

The House of the Clerk released their latest LDA Guidance yesterday.

There were a couple of changes, which were highlighted in Section 2 of the Guidance.

  • Section 6 – reminder that filers must list a new lobbyist’s previous covered executive or legislative branch positions (held within 20 years of their date of filing). NEW: once the registrant has listed an applicable lobbyist’s covered positions, the registrant does not have to list them again on filings for the same client. However, when listing the lobbyist on a new registration for a different client, the positions must be listed again.
  • Section 7: Stresses that both registrants (the firm or sole proprietor listing lobbying income) AND the individual lobbyist listed on the quarterly LD-2 reports must file the LD-203. Although ONLY the registrant must file the LD-1/LD-2, both must file the LD-203 (Semi-annual reporting of defined political contributions). This is regardless of whether or not the individual lobbyist makes a contribution. He or she must still file an LD-203 report, stating “no contributions” and certifying his or her compliance with the House and Senate gift rules. This is not a change, but a reminder from the Clerk.

Read the PDF of the new guidance here.

Check out our Lobbying Compliance Handbook for practical compliance tips.

Tuesday Ethics Tip: LD-203 Edition

Tuesday, May 25th, 2010 by Vbhotla

In last week’s ethics tip, we discussed registering as a lobbyist. This week we’ll take a look at another form that all lobbyists must contend with: the LD-203.

Background: The LD-203 was first required as part of HLOGA, and unlike the LD-1 and LD-2, the LD-203 is filed by both organizations and individual lobbyists. It is submitted on a semi-annual basis,  on July 30 and Jan. 30.

Information filed: Organizations and lobbyists are required to disclose the following:

  • Any PACs that are “controlled” by the org/lobbyist
  • Contributions of $200 or more made to federal candidate committees, national party committees, and leadership PACs
  • Lobbyists serving on a board of a “non-connected” PAC are also required to disclose the contributions made by the PAC
  • Donations to presidential libraries of $200 or more
  • Donations to inaugural committees of $200 or more

Payments of any amount for the following:

  • Events which “honor or recognize” a covered executive branch or legislative branch official
  • Entity named for a legislative branch official
  • Entity financed, maintained, established or controlled by legislative branch or executive branch official (only applies to entities that are established while serving as covered official)
  • Meeting held in the name of covered legislative branch or executive branch officials

Finally, and very importantly, registrants must state compliance with the House and Senate gift rules:

“Registrant has read the House and Senate rules related to gifts and travel and has not provided, requested, or directed any gift including a gift of travel to a member, officer, employee of the House or Senate with the knowledge that giving that gift or the receipt of that gift by the House or Senate member or employee would violate Senate Rule XXXV or House Rule XXV.”

For more information on the gift and ethics rules, see our Lobbying Compliance Handbook.