Posts Tagged ‘LD-2’

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

Compliance Q&A: Registration Termination

Thursday, December 30th, 2010 by Vbhotla

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.

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.

Ghosts of Lobbyists Past

Wednesday, October 13th, 2010 by Brittany

LD-1 lobbying registrations for new clients of lobbying firms must disclose the prior government service of each individual lobbyist for 20 years preceding the filing of the registration. (This is known as the “20-year look-back” provision). New individual lobbyists employed by an existing registrant will also need to disclose this look-back information on the entity’s next quarterly LD-2 report. Employees of the organization registered as lobbyists prior to January 1, 2008 are governed by a two-year look-back provision only.

New employee lobbyists must report their prior government service for the twenty years preceding the reporting period in which they are newly registered as lobbyists.

Prior government service is defined serving as a “covered executive or legislative branch official.” For purposes of disclosing prior government employment, all registrants and filers must use the LDA definition of “covered executive or legislative branch official.”

Covered executive branch officials under the LDA are:

  1. The President
  2. The Vice President
  3. Officers and employees of the Executive Office of the President
  4. Any official serving in an Executive Level I-V position
  5. Any member of the uniformed services serving at grade 0-7 or above
  6. “Schedule C” Employees

Covered legislative branch officials are:

  1. A Member of Congress
  2. An elected officer of either the House or the Senate
  3. An employee, or any other individual functioning in the capacity of an employee who works for a Member, committee, leadership staff of either the Senate or House, a joint committee of Congress, a working group or caucus organized to provide services to Members, and
  4. Any other legislative branch employee who, for at least 60 days, occupies a position for which the rate of basic pay is equal to or greater than 120 percent of the minimum rate of basic pay payable for GS-15 of the General Schedule

For more compliance information visit the Lobbying Compliance Center on

Tuesday Ethics Tip: Deregistering as a Lobbyist

Tuesday, September 21st, 2010 by Vbhotla

Since there are always some lobbyists that seem to be confused over whether, or when, to take themselves off the roster of lobbyists on LD-2 forms, here’s a refresher on de-registering as a lobbyists.

Lobbyists must be removed from the form LD-2 (the quarterly form stating income or expenditures on lobbying), on Line 23 of a current LD-2 form in order to be considered inactive. This “inactive” status frees them from the obligation of filing an LD-203 (the semi-annual filing of lobbyist campaign contributions).

As for de-registration triggers, lobbyists must de-register when have a reasonable expectation or knowledge that they will no longer be working on behalf of a particular client or issue.

Until a lobbyist is formally de-registered (using Line 23), he or she is obligated to file Form LD-203.

By The Way: Minting And Mining Are Not The Same Thing

Wednesday, July 21st, 2010 by Vbhotla

We’re in the process of reviewing Second Quarter LDA filings (due yesterday!), and while preparing for an analysis of the issues that had the most filings, I discovered a typo in the drop-down “issue code” selection – the issue code “Minting/Money/Gold Standard” is misspelled “Mining/Money/Gold Standard” in the drop-down menu.

Be aware of this in the future – minting and mining are two very different issues. I would assume the “/Money/Gold Standard” portion of the issue code would tip off a filer, and most LDA filers are probably well aware of the codes. But it doesn’t hurt to do a quick review of all the codes before you make your filings, to ensure a good-faith effort at accuracy.

Source: Senate Office of Public Records

I did tip off the SOPR to this issue, as well, so this may be changed before you even need to worry about another filing. Happy preparing for the LD-203! (Isn’t July great?)

Filing Reminder: LDA Forms Due Today

Tuesday, July 20th, 2010 by Vbhotla

2nd Quarter 2010 LDA forms are due to the House Clerk and Secretary of the Senate TODAY.

The Lobbying Disclosure Act of 1995, as amended by the Honest Leadership and Open Government Act of 2007, requires those who have registered as lobbyists to file quarterly activity reports with the Clerk of the U.S. House of Representatives and the Secretary of the U.S. Senate. The second quarter report is due Tuesday, July 20, 2010, covering April 1, 2010 through June 30, 2010.

If you are a lobbying firm or sole practitioner, you should already have a login and password for use at the site. Contact the Clerk or Secretary if you are unsure how to proceed.

Find forms and instructions at:

Filing Reminder: LDA Forms Due July 20

Tuesday, July 13th, 2010 by Vbhotla

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 – 2nd Quarter 2010 LDA reports are due to the Clerk and Secretary by July 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. Interested in a refresher course on the LD-203 form (which is due at the end of July)? If you read this before 2:oopm, consider attending our LD-203 Ethics Boot Camp, with Cleta Mitchell. Register here!

Weekly Lobbying News Round-Up

Friday, July 9th, 2010 by Vbhotla

Weekly newsUFO Lobbyist seeks to bring extra-terrestrial issues to the forefront of Congress’s legislative schedule.

How sweet it is: honey lobbyists ask the FDA for national purity standards as a method of trade protection.  (Washington Post)

Publicly-financed elections come to the fore-front. The Washington Post reports on Common Cause  and Public Campaign’s effect to pass the Fair Elections Now Act.

People seem to be endlessly fascinated by the fact that Facebook has a DC lobbying presence. Maybe it’s because they’re spending all day on Farmville? (The Hill, subscription required).

DISCLOSE Soldiers On. The Democrats are hopeful that they’ll get their pet campaign finance issue through the Senate within a reasonable time-frame. (Roll Call, subscription required).

Lobbyists take advantage of World Cup fever by lobbying for the world’s biggest sporting event to be held in the US in 2022. (The Hill, subscription required).

LD-2 filings are due in less than two weeks. Are you prepared? And it’s July, meaning a double-whammy of filing: LD-203 Forms are due on July 30.

Quote of the week:

“Lobby disclosure enforcement is notoriously lax.” – Meredith McGehee, Campaign Legal Center, Politico, July 4.

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.

Tuesday Ethics Tip: Filing Deadlines Edition

Tuesday, June 22nd, 2010 by Vbhotla

Quick refresher for your Tuesday afternoon: LDA filing deadlines.

Lobbying Disclosure (LD) Form 1
Definition / issues disclosed: The form filed by any entity or individual lobbyist at the outset of commencing activities that trigger lobbying registration. (See here for registration triggers).
Recurrence: filed once

Lobbying Disclosure (LD) Form 2
Definition / information disclosed:

  • Particular issues and agencies lobbied
  • Income/expenditures related to the issues lobbied
  • Identity of individual lobbyist employees engaged on the particular issues

Recurrence: Quarterly
Filing deadlines:
Quarter 1 (Jan. 1 – Mar. 31): April 20
Quarter 2 (Apr. 1 – June 30): July 20
Quarter 3 (July 1 – Sept. 30): Oct. 20
Quarter 4 (Oct. 1 – Dec. 31): Jan. 20

Lobbying Disclosure (LD) Form 203
Definition / issues disclosed: Report of specific political contributions by each individual lobbyist and lobbying firm. (See here for list of required disclosures).
Recurrence: Semi-annual
Filing deadlines:
Jan. 1 – June 30: July 30
July 1 – Dec. 31: Jan. 30

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

Weekly Lobbying News Round-Up

Friday, June 18th, 2010 by Vbhotla

DISCLOSE Drama. Will they or won’t they? I’m not sure anyone knows what’s going on with the DISCLOSE Act these days. A Politico story with full background is here. (Eric Brown does an excellent round-up of news reports, here).

C St. Scandal: OCE drops it like it’s hot. According to Roll Call, OCE will drop an investigation into a potential violation of the gift rules. News reports around several member scandals indicated that a house on C Street in Washington DC was owned by a private organization called “The Fellowship” and was providing housing for members of Congress on both sides of the aisle, under-cost – a potential violation of the gift rules.

Hey lobbyists! LD-203 NOT optional. Yes, we already posted on the LDA guidance update, but we don’t want you to forget. Scan the changes, study the PDF, just just read our post!

Norm Eisen: scary individual. Did we get your attention? We’re just kidding, Norm Eisen seems like a nice guy, and he is an excellent “ethics czar.” But some watchdog groups fear for the future of his office if he is confirmed for an ambassadorship to the Czech Republic.

Patton Boggs’ Nick Allard does a Bulletproof Blog video interview on lobbying, and says the American public does not understand lobbying.

Take a number. The FCC wants lobbyists and others with an interest in shaping FCC processes to sign up for meeting time slots online. The Hill has the story.

Quote(s) of the Week:

“We investigative specific allegations. We do not conduct fishing expeditions.” OCE spokesman Jon Steinman, Roll Call June 14

“The “wink-wink-nod-nod” game we have all known to exist with regard to earmarks and campaign contributions is well-documented, and the ethics committee’s definition of “financial interest” needs to be updated to reflect these findings.” – Jeff Flake, Roll Call, June 17

“Is the NRA exception ideal, or pretty? No. Is it likely to complicate the defense of the DISCLOSE Act when it is challenged? Yes. But, is it worth dropping support of the legislation altogether? No.” – Scott Thomas, Of Counsel, Dickstein Shapiro, National Journal’s Under the Influence Experts Blog, June 16

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.