Posts Tagged ‘lobbying compliance’

Are you prepared for a GAO audit?

Wednesday, November 10th, 2010 by Brittany

Preparing for a GAO Audit of Lobbying Disclosure Reports
What you need to know
December 9, 2010 | 2:00-3:30 pm EST

Have you aligned your activities with HLOGA? Don’t let the new year find you unprepared. The GAO has now gone through several audit cycles. With leeway for unintentional failure to disclose expired, flawed disclosure and information monitoring will now trigger enforcement actions – and severe civil and criminal penalties.

Keeping your political activities, yourself, and your firm in compliance with the law takes vigilance. Find out what you can do now to protect yourself and prepare.

Register for Preparing for a GAO Audit of your Lobbying Disclosure Filings. This information-packed audioconference arms you with specific “do it now” guidance for making sure your records, contributions, gifts, practices and reporting will stand up under the harshest regulatory scrutiny. From checklists to real-world advice, you’ll come away with a solid action plan you can implement by December 31st, allowing you to breathe easy as you make all of the required filings.

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Tuesday Ethics Tip: Compliance System Edition

Tuesday, October 12th, 2010 by Vbhotla

Today’s post is an excerpt from the Lobbying Compliance Handbook:

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)?

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Compliance Q and A: Document Retention

Wednesday, September 8th, 2010 by Vbhotla

Q: How long would you recommend that all filers maintain their records in order to comply with the Lobbying Disclosure Act’s record retention requirement?

A: The House and Senate LDA Guidance requires document retention for six years. The documentation supporting each LDA report should be maintained with a copy of the as-filed report and maintained for six years.

When the Government Accountability Office audits lobbying firms, they ask for documentation on several things:

  • Lobbying income or expenses
  • Specific issues lobbied
  • Identity of lobbyists engaged in lobbying activities on each issue during the reporting period
  • Disclosure of “active participants” in lobbying activities of a coalition or association
  • Disclosure  of the interest(s) of a foreign  entity in each issue lobbied
  • Termination of individuals no longer engaged in lobbying for the filer
  • The agency or house of Congress lobbied on each issue
  • Proper disclosure of “prior government service” for individual lobbyists listed on the reports

Make sure your lobbying firm (even if you’re a sole practitioner) has an internal compliance system in place for documenting and retaining these records for each client.

This information is condensed from the Lobbying Compliance Handbook, by Cleta Mitchell.

Have a question for Compliance Q&A? Send your questions to ehill@columbiabooks.com.

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Did you know?

Tuesday, September 7th, 2010 by Vbhotla

The Office of the Clerk has referred an aggregate of 887 potential non-compliant [Lobbying Disclosure Act] registrants to the United States Attorney for the District of Columbia.

(From lobbyingdisclosure.house.gov, updated periodically)



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