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Posts Tagged ‘LD-203’
Tuesday, July 16th, 2013 by Geoffrey Lyons
ON JULY 30TH, every federally registered lobbyist must file the semi-annual LD-203 report, which is ample reason to sign up for next week’s LD-203 Filing Boot Camp. The webinar will be led by Foley & Lardner’s Cleta Mitchell, who in addition to training lobbyists is known for her crusades against the IRS. Attendees earn a Certificate of Training upon completing the course, along with a deep knowledge of disclosure law and gift rules ready to be unleashed at the next cocktail party.
July 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.” July 30th is a Tuesday.
Tags: cleta mitchell, FECA, IRS, LD-203
Posted in Lobbying News | Comments Off on LD-203 Reminder
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 lobbyingdisclosure.house.gov. For a more substantive reference guide, consider The Lobbying Compliance Handbook.
Tags: compliance, Disclosure, filing, HLOGA, LD-2, LD-203, LDA, lobby, Lobbying, lobbyist, the lobbying compliance handbook
Posted in Lobbying News | Comments Off on Federal Lobbying Disclosure Due
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:
- A speaking role by a covered official does NOT trigger disclosure.
- A contribution to another organization which honors a covered official does not necessarily trigger reporting on the LD-203 (but could under certain circumstances).
- 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.
Tags: contributions reports, filing, LD-203
Posted in Lobbying News | Comments Off on What to Report on the LD-203
Friday, January 28th, 2011 by Vbhotla
There were not a tremendous amount of headlines about lobbying or lobbyists this week, but the stories that hit the press were big ones.
First, Howard Marlowe, the new president of the American League of Lobbyists, released his take on Tuesday night’s State of the Union address. And suffice it to say he was not impressed with the president’s remarks. In fact, Marlowe reported that the league “deplore[s] the inflammatory rhetoric about lobbyists,” and called the president out on several instances in which he himself has consorted with lobbyists. He also reiterated the stance that earmarks are a Constitutional right and an important part of the democratic legislative process.
Also this week, the trial of Fraser Verrusio, a former House aide who is the final conspirator charged in connection with the long-running Jack Abramoff probe, began. Opening statements took place Wednesday, and neither side mentioned the disgraced former lobbyist. Verrusio is being charged with public corruption for accepting what prosecutors are calling the “illegal gratuity” that was his ticket to the 2003 World Series. His defense lawyer, Joshua Berman, called this “a case about nothing,” because the New York trip was “a legitimate, run-of-the-mill, third party trip.”
Over the weekend, the 2010 lobbying numbers were released: last year, with the combination of stalled Congressional action in anticipation of mid-term elections and the still-slow economy, lobby shops saw a decline in the bottom line. Large firms saw booming revenue, thanks to acquisition of flailing boutique operations, but as a whole, most lobbying offices saw stagnant or declining numbers in 2010. The current Congressional climate — including uncertainty about the budget and appropriations process, and a heavy concentration of power within the regulatory agencies — have some concerned that this year may not be much better. Patton Boggs, which acquired Breaux Lott Leadership Group in July, and Akin Gump, which reported a $3 increase over 2009, remain the top earners, according to recently filed LD-203 reports.
Tags: akin gump, American League of Lobbyists, Breaux Lott, fraser verrusio, howard marlowe, Jack Abramoff, LD-203, lobbying revenue, Patton Boggs, SOTU, state of the union
Posted in Weekly Lobbying News Round-Up | Comments Off on State of Lobbying: Weekly News Round-up
Thursday, January 13th, 2011 by Vbhotla
Tuesday, lobbyists.info hosted the semi-annual ethics boot camp to prepare you to sign the LD-203 “under penalty of perjury.” Here are the basic things you will need to know ahead of the January 30 deadline:
- Every lobbyist must file the LD-203, whether you have contributions or expenditures to report or not.
- Sole practitioners must file on behalf of the business and as an individual lobbyist.
- Registrants include both entities that employ lobbyists and every individual listed on an LD-1 or LD-2 form.
- The report covers July 1-December 31 2010 and must be filed electronically.
- Contributions of $200 or more from individual registrants or PACs controlled by an individual registrant to federal candidates, leadership PACs, federal party committees AND contributions of $200 or more to presidential inaugural committee or library must be reported as FECA contributions.
- Payments AND expenditures are subject to reporting
- Your signature certifies that, beyond just HLOGA rules, you have read both the House and Senate Gift and Ethics rules and exceptions, and have in no way violated them.
- If an event honors, recognizes covered official, costs are subject to disclosure on LD-203 of sponsor – but not donor unless donor participates in honoring Member
Review filings and supporting documents closely before you sign. Remember the “perjury trap.”
Tags: ethics rules, Ethics Tip, LD-203, under penalty of perjury
Posted in Ethics Tip | Comments Off on The LD-203: Compliance for Campaign Finance Disclosure
Tuesday, January 11th, 2011 by Vbhotla
You have probably heard by now that Paul Magliocchetti, the founder of the now-defunct PMA Group, was sentenced to 27 months behind bars for his role in organizing a campaign finance scheme. In addition to the prison sentence, which will be served at a North Carolina federal prison hospital, the former House Appropriations Committee staffer was fined $75,000.
The sitting judge, the Honorable T.S. Ellis, issued the sentence as a warning to other lobbyists, and simultaneously expressed his displeasure with prosecutors who seek only fines in similar cases. He did not grant the 57 month prison term and $629,000 fine the prosecutors sought initially, and told Magliocchetti that his good works were not obliterated, he was not responsible for a PMA Group-favorite donor’s suicide in light of the investigations, and said he should make amends with his son, who plead guilty to charges related to the case.
So what can be drawn from the Magliocchetti case? First, people are seeking to make examples of lobbyists, so tread lightly. Make sure you are in compliance with HLOGA and all of its developments, and be sure to carefully review your LD-203 filings for errors, remembering that your signature is “under penalty of perjury.”
Make sure that you disclose any campaign donations, be they to PACs, independent expenditure groups, political parties, or candidates and their election committees, on the form.
Bundle with care. You will need to be aware of the limits and follow them closely. Citizens United opened the door for unlimited giving, but did not take away the reporting requirements.
A good rule of thumb: if you can’t report it, don’t give it. Recent cases have shown that prosecutors are looking and will find any missteps. Repercussions may not be immediate, but they are coming. US News & World Report found that only 20% of companies properly disclose their political donations, and only 14% actually have indirect disclosure policies.
If you find yourself overwhelmed by the LD-203’s reporting requirements, it is not too late to join today’s LD-203 bootcamp, which will be held at 2p.
Tags: Campaign Finance, Disclosure, Ethics Tip, LD-203, lobbyist fined, lobbyist jail, Paul Magliocchetti, pma group
Posted in Ethics Tip | Comments Off on How not to land yourself in jail
Tuesday, November 2nd, 2010 by Vbhotla
There has been lots of talk recently about lobbyists’ campaign contributions to state-level candidates. For example, the backlash one Tennessee lobbyist received after donating to a gubernatorial candidate’s campaign and the interest in the amount of money donated by PACs to Alabama governor-hopefuls. Rules on contributions by lobbyists to these campaigns vary from state to state.
The good news is, thanks to guidelines on LD-203 disclosure released June 2009 by the House Office of the Clerk and Secretary of the Senate, these state and local-level campaign contributions do not trigger disclosure on a lobbyist’s LD-203 form. Because these candidates do not register campaign donations with the FEC, any amount a lobbyist contributes to said campaigns is exempt from LD-203 disclosure.
Other exceptions to LD-203 reporting requirements include:
- Donations to an entity on which a covered legislative or executive branch official serves as an honorary board member with no vote in board affairs,
- Contributions to a charity established by a covered official prior to his/her term in the covered office,
- Contributions to a charity to which a covered official makes only “de minimus” donations, and
- Costs related to sponsorship of a multi-candidate debate.
Though campaign contributions by lobbyists can be virtually unregulated in some states like Texas, it is still advised that lobbyists tread lightly when working on behalf of candidates at the state and local levels. Candidates are increasingly under fire for accepting special interest money, making them reluctant to be associated with government relations personnel.
“Nobody wants the Brooks Brothers Brigade out there campaigning for you,” Democratic lobbyist John Michael Gonzalez told a Roll Call staffer.
Today’s ethics tip is condensed from the Lobbying Compliance Handbook. New 2010 edition out this month!
Tags: campaign contributions, Ethics, exceptions, LD-203, lobbying disclosure, state lobbying
Posted in Ethics Tip | Comments Off on Tuesday Ethics Tip: Election Day Edition
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.
Tags: de-registration, LD-2, LD-203, lobbyists
Posted in Ethics Tip | Comments Off on Tuesday Ethics Tip: Deregistering as a Lobbyist
Wednesday, August 25th, 2010 by Vbhotla
Q: Our association has a PAC but our treasurer is not a lobbyist and our assistant treasurer is a lobbyist. Do we still need to file an LD-203 report for the PAC? And if so, who must file and by when must the filing occur?
A: The individual lobbyist will have to file his or her own individual contributions. On the association’s semi-annual report (LD-203), the association would list the name of the PAC. It does not matter whether your treasurer is or is not a lobbyist for the purposes of the filing by the association.
The association would indicate the name of its PAC and indicate contributions of $200 or more from the PAC to any federal candidate, any leadership PAC or any one of the six national party committees that were made during the six-month reporting period.
On the lobbyist’s separate filing, the lobbyist may have to indicate – if he or she has a controlling say in where PAC contributions are spent – that he or she is the assistant treasurer. If the lobbyist has a responsibility for allocating PAC funds, he or she would have to list contributions from the PAC that he or she was responsible for having made in the individual lobbyist report.
So it’s a fact-specific situation depending on how the PAC is set up, and who its officers are, as well as who controls contributions.
Have a question for Compliance Q&A? Send your questions to ehill@columbiabooks.com.
Tags: associations, compliance, LD-203, PACs
Posted in Compliance Q&A | Comments Off on Compliance Q and A: Association PAC Reporting
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 ehill@columbiabooks.com.
Tags: Disclosure, filing, LD-203
Posted in Compliance Q&A | Comments Off on Compliance Q&A: Who Has to File the LD-203?
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.
Tags: Bundling, Contributions, Disclosure, filing, LD-203, Lobbying, lobbyists
Posted in Filing Reminders | Comments Off on Filing Reminder: LD-203 Forms Due Today
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.
Tags: Bundling, Contributions, Disclosure, filing, LD-203, Lobbying, lobbyists
Posted in Filing Reminders, Regulations | Comments Off on Filing Reminder: LD-203 Forms Due Next Week
Friday, July 9th, 2010 by Vbhotla
 UFO 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.
Tags: DISCLOSE Act, Facebook, Fair Elections Now Act, honey, LD-2, LD-203, lobbyists, world cup
Posted in Weekly Lobbying News Round-Up | Comments Off on Weekly Lobbying News Round-Up
Friday, July 2nd, 2010 by Vbhotla
1. As a lobbyist listed on an LD-2, you must file an LD-203. The LD-203 has civil and criminal penalties attached to it. If you fill out a legally binding document incorrectly, you run the risk of opening yourself (and your company) up to damaging PR and DOJ investigations. Learn exactly what you’re signing and why, at the audioconference.
2. Cleta Mitchell. Cleta is one of the nation’s leading political lawyers and an expert on the LD-203 and related issues. Take advantage of the situation to ask your own specific questions, before you have to answer questions from DOJ lawyers.
3. Learn how to record-keep properly. The statute requires a certain number of years’ worth of record-keeping. Learn how to properly retain what you’ll need in the event of an audit or internal investigation.
4. Get proof of your good-faith effort to understand the law. A quick but detailed survey after the conference tests your knowledge of the topics and provides you with proof of training – particularly useful in the event of a GAO audit.
Register today at www.lobbyists.info.
Tags: cleta mitchell, LD-203, lobbyist training
Posted in Training & Events | Comments Off on Four Reasons to Attend LD-203 Ethics Boot Camp
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
Tags: LD-1, LD-2, LD-203, LDA
Posted in Ethics Tip | Comments Off on Tuesday Ethics Tip: Filing Deadlines Edition
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