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.