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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

May 2014: 

2013 Lobbying Disclosure: 

Observations on Lobbyists' Compliance with Disclosure Requirements: 

GAO-14-485: 

GAO Highlights: 

Highlights of GAO-14-485, a report to congressional committees. 

Why GAO Did This Study: 

The LDA requires lobbyists to file quarterly lobbying disclosure 
reports and semiannual reports on certain political contributions. The 
LDA also requires that GAO annually (1) audit the extent to which 
lobbyists can demonstrate compliance with disclosure requirements, (2) 
identify challenges to compliance that lobbyists report, and (3) 
describe the resources and authorities available to the Office in its 
role in enforcing LDA compliance and the efforts the Office has made 
to improve enforcement. This is GAO's seventh report under the mandate. 

GAO reviewed a stratified random sample of 104 quarterly disclosure 
LD-2 reports filed for the third and fourth quarters of 2012 and the 
first and second quarters of calendar year 2013. GAO also reviewed two 
random samples totaling 160 LD-203 reports from year-end 2012 and 
midyear 2013. This methodology allowed GAO to generalize to the 
population of 65,489 disclosure reports with $5,000 or more in 
lobbying activity and 31,482 reports of federal political campaign 
contributions. GAO also met with officials from the Office to obtain 
updated statuses on the Office's efforts to focus resources on 
lobbyists who fail to comply. 

GAO provided a draft of this report to the Attorney General for review 
and comment. On behalf of the Attorney General, the Assistant U.S. 
Attorney for the District of Columbia responded that the Department of 
Justice had no comments. 

What GAO Found: 

Most lobbyists provided documentation for key elements of their 
disclosure reports to demonstrate compliance with the Lobbying 
Disclosure Act of 1995, as amended (LDA). For lobbying disclosure (LD-
2) reports and political contribution (LD-203) reports GAO estimated 
the following: 

* Ninety-six percent of newly registered lobbyists filed LD-2 reports 
as required. Lobbyists are required to file LD-2 reports for the 
quarter in which they first register. 

* Ninety-six percent could provide documentation for income and 
expenses. However, 33 percent of these LD-2 reports were not properly 
rounded to the nearest $10,000. 

* Ninety-two percent filed year-end 2012 or midyear 2013 LD-203 
reports as required. 

* Seventeen percent of all LD-2 reports did not properly disclose one 
or more previously held covered position as required. 

* Four percent of all LD-203 reports omitted one or more reportable 
political contributions that were documented in the Federal Election 
Commission database. 

These findings are generally consistent with GAO's reviews from 2010 
through 2012 and can be generalized to the population of disclosure 
reports. 

Most lobbyists in GAO's sample rated the terms associated with LD-2 
reporting as “very easy” or “somewhat easy” to understand with regard 
to meeting reporting requirements. However, some disclosure reports 
demonstrate compliance difficulties, such as failure to disclose 
covered positions or misreporting of income or expenses. In addition, 
lobbyists amended 18 of 104 original disclosure reports in GAO's 
sample to change previously reported information. 

The U.S. Attorney's Office for the District of Columbia (the Office) 
stated it has sufficient authority and resources to enforce LD-2 and 
LD-203 compliance with the LDA for lobbying firms and certain 
individual lobbyists. It has one contract paralegal working full time 
and six attorneys working part time on LDA enforcement issues. The 
Office continues its efforts to follow up on referrals for 
noncompliance with lobbying disclosure requirements by contacting 
lobbyists by e-mail, telephone, and letter. In March 2014, the Office 
filed a civil complaint against a lobbyist for failure to comply with 
LDA reporting requirements. 

GAO's first report on lobbying disclosure under the LDA concluded that 
the lobbying community could benefit from creating an entity to share 
examples of best practices, provide training, and report annually on 
opportunities to clarify guidance and minimize sources of potential 
confusion for the lobbying community. Given the ongoing difficulties 
with compliance, GAO continues to believe that such an entity could be 
useful to the lobbying community. 

View [hyperlink, http://www.gao.gov/products/GAO-14-485]. For more 
information, contact Seto Bagdoyan at (202) 512-4749 or 
bagdoyans@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Most Newly Registered Lobbyists Filed Disclosure Reports as Required: 

Most Lobbying Firms Found It Easy to Comply with Disclosure 
Requirements and Understood Lobbying Terms: 

U.S. Attorney's Office Actions to Enforce LDA: 

Concluding Observations: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: List of Registrants and Clients for Sampled Lobbying 
Disclosure Reports: 

Appendix III: List of Sampled Lobbying Contribution Reports with and 
without Contributions Listed: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Reasons Lobbyists in Our Sample Amended Their Disclosure 
Reports as of April 2014: 

Table 2: Estimated Percent of LD-203 Reports That Omitted One or More 
Political Contributions from 2010 through 2013: 

Table 3: Names of Registrants and Clients Selected in Random Sample of 
Lobbying Disclosure Reports Filed in the Third and Fourth Quarters of 
2012 and the First and Second Quarters of 2013: 

Table 4: Lobbyists and Lobbying Firms in Sample of Lobbying 
Contribution Reports with Contributions Listed, Filed Year-End 2012 
and Midyear 2013: 

Table 5: Lobbyists and Lobbying Firms in a Sample of Lobbying 
Contribution Reports with No Contributions Listed, Filed Year-End 2012 
and Midyear 2013: 

Figures: 

Figure 1: Comparison of Newly Registered Lobbyists That Filed 
Disclosure Reports as Required from 2010 through 2013: 

Figure 2: Percentage of LD-2 Reports with Documentation for Income and 
Expenses from 2010 through 2013: 

Figure 3: Percentage of LD-2 Reports with Differences in the Amount of 
Income and Expenses Reported by at Least $10,000 and Rounding Errors 
from 2010 through 2013: 

Figure 4: Extent to Which Lobbyists Provided Documentation for Issue 
Codes from 2010 through 2013: 

Figure 5: Extent to Which Lobbyists Provided Documentation for 
Lobbying the House from 2010 through 2013: 

Figure 6: Extent to Which Lobbyists Provided Documentation for 
Lobbying the Senate from 2010 through 2013: 

Figure 7: Extent to Which Lobbyists Provided Documentation for 
Individual Lobbyists Listed from 2010 through 2013: 

Figure 8: Extent to Which Lobbyists on LD-2 Reports Filed Contribution 
Reports for All Listed Lobbyists and Lobbying Firms from 2010 through 
2013: 

Figure 9: Estimated Percent of LD-2 Reports Where Lobbyists Failed to 
Properly Disclose One or More Covered Positions from 2010 through 2013: 

Figure 10: Ease of Complying with Disclosure Requirements from 2010 
through 2013: 

Figure 11: Ease of Understanding Lobbying Definitions from 2010 
through 2013: 

Figure 12: Ease of Understanding the Term "Lobbying Activities" from 
2010 through 2013: 

Figure 13: Ease of Understanding Issue Codes from 2010 through 2013: 

Figure 14: Ease of Understanding the Term "Covered Positions" from 
2010 through 2013: 

Figure 15: Ease of Understanding the Term "Terminating Lobbyists" from 
2010 through 2013: 

Figure 16: Status of LDA Enforcement Actions for LD-2 Reporting from 
2009 through 2013 (as of January 16, 2014): 

Figure 17: Status of LDA Enforcement Actions for LD-203(R) Lobbying 
Firms Only Reporting from 2009 through 2013 (as of January 16, 2014): 

Figure 18: Status of LDA Enforcement Actions for LD-203 Lobbyists Only 
for Reporting from 2009 through 2012 (as of January 16, 2014): 

Abbreviations: 

Clerk of the House: Clerk of the House of Representatives: 

FEC: Federal Election Commission: 

HLOGA: Honest Leadership and Open Government Act of 2007: 

LDA: Lobbying Disclosure Act of 1995: 

Office: U.S. Attorney's Office for the District of Columbia: 

[End of section] 

United States Government Accountability Office: 
GAO:
441 G St. N.W. 
Washington, DC 20548: 

May 28, 2014: 

Congressional Committees: 

Questions regarding the influence of special interests in the 
formation of government policy have led to a move toward more 
transparency and accountability with regard to the lobbying community. 
The Honest Leadership and Open Government Act of 2007 (HLOGA) amended 
the Lobbying Disclosure Act of 1995 to require lobbyists to file 
quarterly lobbying disclosure reports and semiannual reports on 
certain political contributions and increased civil and criminal 
penalties for failure to comply with lobbying disclosure requirements. 
[Footnote 1] The mandate requires us to audit the extent of lobbyists' 
compliance with the Lobbying Disclosure Act of 1995, as amended (LDA) 
by reviewing publicly available lobbying registrations and a random 
sampling of reports filed during each calendar year.[Footnote 2] Our 
report shall include any recommendations related to improving 
lobbyists' compliance with the LDA and information on resources and 
authorities available to the U.S. Attorney's Office for the District 
of Columbia (the Office) for effective enforcement of the LDA. This is 
our seventh mandated review of lobbyists' disclosure reports filed 
under the LDA. 

Consistent with our mandate, our objectives were to: (1) determine the 
extent to which lobbyists can demonstrate compliance with the 
requirements for registrations and reports filed under the LDA; (2) 
identify challenges and potential improvements to compliance by 
lobbyists, lobbying firms, and registrants, if any; and (3) describe 
the resources and authorities available to the Office in its role in 
enforcing LDA compliance and the efforts the Office has made to 
improve enforcement. 

To fulfill our audit requirement in HLOGA, we took the following steps: 

* To determine the extent to which lobbyists can demonstrate 
compliance, we examined a stratified random sample of 102 quarterly 
lobbying disclosure (LD-2) reports with income and expenses of $5,000 
or more filed during the third and fourth quarters of calendar year 
2012 and the first and second quarters of calendar year 2013.[Footnote 
3] We selected the randomly sampled reports from the publicly 
downloadable database maintained by the Clerk of the House of 
Representatives (Clerk of the House).[Footnote 4] Appendix II contains 
a list of lobbyists (registrants and clients) whose LD-2 reports we 
selected. This methodology allows us to generalize to the population 
of LD-2 reports. We then contacted each lobbyist or lobbying firm in 
our sample and asked them to provide written documentation for key 
elements of their LD-2 reports, including the amount of money received 
for lobbying activities, the houses of Congress or executive branch 
agencies lobbied, lobbying issue areas, and lobbyists reported as 
having worked on the issues.[Footnote 5] We also reviewed whether 
lobbyists listed on the LD-2 reports properly disclosed prior covered 
official positions and whether the lobbyists filed the semiannual 
report of federal political contributions. Of the lobbyists contacted, 
all in-scope lobbyists in our sample responded to our requests to meet 
with us to review documentation. 

* To determine whether lobbyists reported their federal political 
contributions as required by the LDA, we analyzed stratified random 
samples of year-end 2012 and midyear 2013 semiannual political 
contributions (LD-203) reports. The samples contain 80 LD-203 reports 
that list contributions and 80 LD-203 reports that do not. We selected 
the randomly sampled reports from the publicly downloadable 
contributions database maintained by the Clerk of the House. See 
appendix III for a list of lobbyists and lobbying firms randomly 
selected for our review of LD-203 reports. We then checked the 
contributions reported in the Federal Election Commission's (FEC) 
database against those identified in our sample to determine whether 
all contributions reported in the FEC database also appeared on the LD-
203 reports, as required. We contacted lobbyists and asked them to 
provide documentation to clarify differences we observed. All 
lobbyists complied with our request to provide documentation. This 
methodology allows us to generalize to the population of LD-203 
reports both with and without contributions. 

* To determine whether registrants were meeting the requirement to 
file an LD-2 report for the quarter in which they registered, we 
compared new registrations (LD-1) filed in the third and fourth 
quarters of 2012 and the first and second quarters of 2013 to the 
corresponding LD-2 reports on file with the Clerk of the House. 

* To identify challenges and potential improvements to compliance, we 
used a structured online survey to obtain views from lobbyists 
included in our sample of reports. In addition, we considered 
reporting difficulties that became apparent during our reviews of 
lobbyists' documentation. 

* To describe the resources and authorities available to the Office 
and its efforts to improve LDA enforcement, we interviewed Office 
officials and obtained updated information about the capabilities of 
the Office's systems to track enforcement and compliance trends and 
referral data that it receives from the Secretary of the Senate and 
Clerk of the House. 

The mandate does not require us to identify lobbyist organizations 
that failed to register and report in accordance with LDA 
requirements. The mandate also does not require us to determine 
whether reported lobbying activity or political contributions 
represented the full extent of lobbying activities that took place. 

We conducted this performance audit from June 2013 to May 2014 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. For more 
details on our methodology, see appendix I. 

Background: 

The LDA, as amended by HLOGA, requires lobbyists to register with the 
Secretary of the Senate and the Clerk of the House and file quarterly 
reports disclosing their lobbying activity. Lobbyists are required to 
file their registrations and reports electronically with the Secretary 
of the Senate and the Clerk of the House through a single entry point. 
Registrations and reports must be publicly available in downloadable, 
searchable databases from the Secretary of the Senate and the Clerk of 
the House. No specific statutory requirements exist for lobbyists to 
generate or maintain documentation in support of the information 
disclosed in the reports they file. However, guidance issued by the 
Secretary of the Senate and the Clerk of the House recommends that 
lobbyists retain copies of their filings and supporting documentation 
for at least 6 years after they file their reports. 

The LDA requires that the Secretary of the Senate and the Clerk of the 
House provide guidance and assistance on registration and reporting 
requirements and develop common standards, rules, and procedures for 
LDA compliance. The Secretary and the Clerk of the House review the 
guidance semiannually. It was last reviewed December 12, 2013, and 
revised February 15, 2013. The guidance provides definitions of LDA 
terms, elaborates on the registration and reporting requirements, 
includes specific examples of different scenarios, and explains why 
certain scenarios prompt or do not prompt disclosure under the LDA. 
The Secretary of the Senate and Clerk of the House told us they 
continue to consider information we report on lobbying disclosure 
compliance when they periodically update the guidance. In addition, 
they told us they send quarterly e-mails to registered lobbyists that 
address common compliance issues as well as reminders to file reports 
by the due dates. 

The LDA defines a lobbyist as an individual who is employed or 
retained by a client for compensation, who has made more than one 
lobbying contact (written or oral communication to a covered executive 
or legislative branch official made on behalf of a client), and whose 
lobbying activities represent at least 20 percent of the time that he 
or she spends on behalf of the client during the quarter.[Footnote 6] 
Lobbying firms are persons or entities that have one or more employees 
who lobby on behalf of a client other than that person or entity. 
[Footnote 7] 

Lobbying firms are required to register with the Secretary of the 
Senate and the Clerk of the House for each client if the firms receive 
or expect to receive more than $3,000 in income or $12,500 in incurred 
expenses from that client for lobbying activities.[Footnote 8] 
Lobbyists are also required to submit a quarterly report, also known 
as an LD-2 report, for each registration filed. The LD-2s contain 
information that includes: 

* the name of the registrant reporting on his or her quarterly 
lobbying activities and the name of the client on whose behalf the 
registrant lobbied; 

* the list of individuals who acted as lobbyists on behalf of the 
client during the reporting period; 

* whether any lobbyists served as covered executive branch or 
legislative branch officials in the previous 20 years; 

* codes describing general issue areas and specific lobbying issues; 

* houses of Congress and federal agencies lobbied during the reporting 
period; and: 

* reported income (or expenses for organizations with in-house 
lobbyists) related to lobbying activities during the quarter (rounded 
to the nearest $10,000). 

The LDA also requires lobbyists to report certain political 
contributions semiannually in the LD-203 report. These reports must be 
filed 30 days after the end of a semiannual period by each lobbying 
firm registered to lobby and by each individual listed as a lobbyist 
on a firm's lobbying report. The lobbyists or lobbying firms must: 

* list the name of each federal candidate or officeholder, leadership 
political action committee, or political party committee to which they 
made contributions equal to or exceeding $200 in the aggregate during 
the semiannual period; 

* report contributions made to presidential library foundations and 
presidential inaugural committees; 

* report funds contributed to pay the cost of an event to honor or 
recognize a covered official, funds paid to an entity named for or 
controlled by a covered official, and contributions to a person or 
entity in recognition of an official or to pay the costs of a meeting 
or other event held by or in the name of a covered official; and: 

* certify that they have read and are familiar with the gift and 
travel rules of Congress and that they have not provided, requested, 
or directed a gift or travel to a member, officer, or employee of 
Congress that would violate those rules. 

The Secretary of the Senate, the Clerk of the House, and the Office 
are responsible for ensuring compliance with the LDA. The Secretary of 
the Senate and the Clerk of the House notify lobbyists or lobbying 
firms in writing that they are not complying with reporting 
requirements in the LDA and subsequently refer those lobbyists who 
fail to provide an appropriate response to the Office. The Office 
researches these referrals and sends additional noncompliance notices 
to the lobbyists or lobbying firms, requesting that they file reports 
or terminate their registration. If the Office does not receive a 
response after 60 days, it decides whether to pursue a civil or 
criminal case against each noncompliant lobbyist. A civil case could 
lead to penalties up to $200,000, while a criminal case--usually 
pursued if a lobbyist's noncompliance is found to be knowing and 
corrupt--could lead to a maximum of 5 years in prison. 

Most Newly Registered Lobbyists Filed Disclosure Reports as Required: 

Of the 3,034 new registrants we identified for the time periods 
corresponding to our review, we matched 2,925 reports (96 percent) of 
registrations filed in the first quarter in which they were first 
registered. These results are consistent with prior reviews. To 
determine whether new registrants were meeting the requirement to 
file, we matched newly filed registrations in the third and fourth 
quarters of 2012 and the first and second quarters of 2013 from the 
House Lobbyists Disclosure Database to their corresponding quarterly 
disclosure reports. We did this using an electronic matching algorithm 
that allows for misspellings and other minor inconsistencies between 
the registrations and reports. Figure 1 shows that most newly 
registered lobbyists filed their disclosure reports as required from 
2010 through 2013. 

Figure 1: Comparison of Newly Registered Lobbyists That Filed 
Disclosure Reports as Required from 2010 through 2013: 

[Refer to PDF for image: vertical bar graph] 

Year of review: 2010; 
Filed: 91%; 
Did not file: 9%. 

Year of review: 2011; 
Filed: 88%; 
Did not file: 12%. 

Year of review: 2012; 
Filed: 90%; 
Did not file: 10%. 

Year of review: 2013; 
Filed: 96%; 
Did not file: 4%. 

Source: GAO analysis. 

Note: Results are based on an analysis of all newly registered 
lobbyists for the periods corresponding to our reviews. 

[End of figure] 

For Most LD-2 Reports Lobbyists Provided Documentation for Key 
Elements, but for Some LD-2 Reports Lobbyists Rounded Their Income or 
Expenses Incorrectly: 

For selected elements of lobbyists' LD-2 reports that can be 
generalized to the population of lobbying reports, unless otherwise 
noted, our findings were consistent from year to year. We used tests 
that adjusted for multiple comparisons to assess the statistical 
significance of changes over time. 

Most lobbyists reporting $5,000 or more in income or expenses provided 
written documentation to varying degrees for the reporting elements in 
their disclosure reports. For this year's review, lobbyists for an 
estimated 96 percent of LD-2 reports (98 out of 102) provided written 
documentation for the income and expenses reported for the third and 
fourth quarters of 2012 and the first and second quarters of 2013. The 
most common forms of documentation provided included invoices for 
income and internal expense reports for expenses. Figure 2 shows that 
for most LD-2 reports, lobbyists provided documentation for income and 
expenses for sampled reports from 2010 through 2013. 

Figure 2: Percentage of LD-2 Reports with Documentation for Income and 
Expenses from 2010 through 2013: 

[Refer to PDF for image: vertical bar graph] 

Year of review: 2010; 
Documentation for income and expenses: 97%; 
No documentation for income and expenses: 3%. 

Year of review: 2011; 
Documentation for income and expenses: 93%; 
No documentation for income and expenses: 7%. 

Year of review: 2012; 
Documentation for income and expenses: 97%; 
No documentation for income and expenses: 3%. 

Year of review: 2013; 
Documentation for income and expenses: 96%; 
No documentation for income and expenses: 4%. 

Source: GAO analysis. 

Note: Estimates of proportions based on sampled reports, generalizable 
to the universe of LD-2 reports with lobbying activity. Results have a 
maximum margin of error of 11 percent. Year-to-year differences are 
not statistically significant. 

[End of figure] 

Figure 3 shows that for some LD-2 reports, lobbyists rounded their 
income or expenses incorrectly. We identified 33 percent of reports as 
having rounding errors. On 13 percent of those reports, lobbyists 
reported the exact amount of lobbying income or expenses instead of 
rounding to the nearest $10,000 as required. Rounding difficulties has 
been a recurring issue from 2010 through 2013.[Footnote 9] 

Figure 3: Percentage of LD-2 Reports with Differences in the Amount of 
Income and Expenses Reported by at Least $10,000 and Rounding Errors 
from 2010 through 2013: 

[Refer to PDF for image: vertical bar graph] 

Year of review: 2010; 
Properly rounded to the nearest $10,000: 68%; 
Differed from amount by at least $10,000: 13%; 
Had rounding errors (differed from amount by less than $10,000): 19%. 

Year of review: 2011; 
Properly rounded to the nearest $10,000: 63%; 
Differed from amount by at least $10,000: 16%; 
Had rounding errors (differed from amount by less than $10,000): 21%. 

Year of review: 2012; 
Properly rounded to the nearest $10,000: 74%; 
Differed from amount by at least $10,000: 5%; 
Had rounding errors (differed from amount by less than $10,000): 21%. 

Year of review: 2013; 
Properly rounded to the nearest $10,000: 67%; 
Differed from amount by at least $10,000: 9%; 
Had rounding errors (differed from amount by less than $10,000): 24%. 

Source: GAO analysis. 

Note: Estimates of proportions based on sampled reports, generalizable 
to the universe of LD-2 reports with lobbying activity. Results have a 
maximum margin of error of 11 percent. With the exception of the 
decrease in the proportion of reports with a $10,000 or greater 
discrepancy from 2011 to 2012, results were not statistically 
significant. 

[End of figure] 

The LDA requires lobbyists to disclose lobbying contacts made to 
executive branch agencies on behalf of the client for the reporting 
period. This year, of the 102 LD-2 reports in our sample, 42 LD-2 
reports disclosed lobbying activities at executive branch agencies. Of 
those, lobbyists provided documentation for all lobbying activities at 
executive branch agencies for 30 LD-2 reports.[Footnote 10] 

Figures 4 through 7 show that lobbyists for most LD-2 reports were 
able to provide documentation for selected elements of their LD-2 
reports from 2010 through 2013. 

Figure 4: Extent to Which Lobbyists Provided Documentation for Issue 
Codes from 2010 through 2013: 

Refer to PDF for image: vertical bar graph] 

Year of review: 2010; 
Documentation for all issue codes: 85%; 
Documentation for some issue codes: 9%; 
No documentation for issue codes: 6%. 

Year of review: 2011; 
Documentation for all issue codes: 79%; 
Documentation for some issue codes: 7%; 
No documentation for issue codes: 14%. 

Year of review: 2012; 
Documentation for all issue codes: 76%; 
Documentation for some issue codes: 4%; 
No documentation for issue codes: 20%. 

Year of review: 2013; 
Documentation for all issue codes: 77%; 
Documentation for some issue codes: 5%; 
No documentation for issue codes: 18%. 

Source: GAO analysis. 

Note: Estimates of proportions based on sampled reports, generalizable 
to the universe of LD-2 reports with lobbying activity. Results have a 
maximum margin of error of 11 percent. Year-to-year differences are 
not statistically significant. 

[End of figure] 

Figure 5: Extent to Which Lobbyists Provided Documentation for 
Lobbying the House from 2010 through 2013: 

Refer to PDF for image: vertical bar graph] 

Year of review: 2010; 
Documentation for lobbying the House: 78%; 
No documentation for lobbying the House: 22%. 

Year of review: 2011; 
Documentation for lobbying the House: 81%; 
No documentation for lobbying the House: 19%. 

Year of review: 2012; 
Documentation for lobbying the House: 71%; 
No documentation for lobbying the House: 29%. 

Year of review: 2013; 
Documentation for lobbying the House: 74%; 
No documentation for lobbying the House: 26%. 

Source: GAO analysis. 

Note: Estimates of proportions based on sampled reports, generalizable 
to the universe of LD-2 reports with lobbying activity. Results have a 
maximum margin of error of 11 percent. Year-to-year differences are 
not statistically significant. 

[End of figure] 

Figure 6: Extent to Which Lobbyists Provided Documentation for 
Lobbying the Senate from 2010 through 2013: 

Refer to PDF for image: vertical bar graph] 

Year of review: 2010; 
Documentation for lobbying the Senate: 79%; 
No documentation for lobbying the Senate: 21%. 

Year of review: 2011; 
Documentation for lobbying the Senate: 78%; 
No documentation for lobbying the Senate: 22%. 

Year of review: 2012; 
Documentation for lobbying the Senate: 712%; 
No documentation for lobbying the Senate: 28%. 

Year of review: 2013; 
Documentation for lobbying the Senate: 75%; 
No documentation for lobbying the Senate: 25%. 

Source: GAO analysis. 

Note: Estimates of proportions based on sampled reports, generalizable 
to the universe of LD-2 reports with lobbying activity. Results have a 
maximum margin of error of 11 percent. Year-to-year differences are 
not statistically significant. 

[End of figure] 

Figure 7: Extent to Which Lobbyists Provided Documentation for 
Individual Lobbyists Listed from 2010 through 2013: 

Refer to PDF for image: vertical bar graph] 

Year of review: 2010; 
Documentation for all lobbyists listed: 72%; 
Documentation for some lobbyists listed: 21%; 
No documentation for lobbyists listed: 7%. 

Year of review: 2011; 
Documentation for all lobbyists listed: 68%; 
Documentation for some lobbyists listed: 17%; 
No documentation for lobbyists listed: 15%. 

Year of review: 2012; 
Documentation for all lobbyists listed: 69%; 
Documentation for some lobbyists listed: 13%; 
No documentation for lobbyists listed: 18%. 

Year of review: 2013; 
Documentation for all lobbyists listed: 64%; 
Documentation for some lobbyists listed: 23%; 
No documentation for lobbyists listed: 13%. 

Source: GAO analysis. 

Note: Estimates of proportions based on sampled reports, generalizable 
to the universe of LD-2 reports with lobbying activity. Results have a 
maximum margin of error of 11 percent. Year-to-year differences are 
not statistically significant. 

[End of figure] 

For Most LD-2 Reports, Lobbyists Filed LD-203 Reports for All Listed 
Lobbyists: 

Lobbyists for an estimated 92 percent of LD-2 reports filed year-end 
2012 or midyear 2013 LD-203 reports for all lobbyists and lobbying 
firms listed on the report as required. Figure 8 shows that lobbyists 
for most lobbying firms filed contribution reports for lobbyists and 
lobbying firms as required for LD-2 reports from 2010 through 2013. 
All individual lobbyists and lobbying firms reporting lobbying 
activity are required to file LD-203 reports semiannually, even if 
they have no contributions to report, because they must certify 
compliance with the gift and travel rules. 

Figure 8: Extent to Which Lobbyists on LD-2 Reports Filed Contribution 
Reports for All Listed Lobbyists and Lobbying Firms from 2010 through 
2013: 

Refer to PDF for image: vertical bar graph] 

Year of review: 2010; 
Filed reports for all lobbyists: 90%; 
Did not file for one or more lobbyists: 10%. 

Year of review: 2011; 
Filed reports for all lobbyists: 86%; 
Did not file for one or more lobbyists: 14%. 

Year of review: 2012; 
Filed reports for all lobbyists: 85%; 
Did not file for one or more lobbyists: 15%. 

Year of review: 2013; 
Filed reports for all lobbyists: 92%; 
Did not file for one or more lobbyists: 8%. 

Source: GAO analysis. 

Note: Estimates of proportions based on sampled reports, generalizable 
to the universe of LD-2 reports with lobbying activity. Results have a 
maximum margin of error of 11 percent. Year-to-year differences are 
not statistically significant. 

[End of figure] 

For Some LD-2 Reports, Lobbyists Failed to Disclose Covered Positions: 

The LDA requires a lobbyist to disclose previously held covered 
positions when first registering as a lobbyist for a new client. This 
can be done either on the LD-1 or on the LD-2 quarterly filing when 
added as a new lobbyist. This year, we estimate that 17 percent of all 
LD-2 reports did not properly disclose one or more previously held 
covered positions as required. Figure 9 shows the extent to which 
lobbyists failed to properly disclose one or more covered positions as 
required from 2010 through 2013. 

Figure 9: Estimated Percent of LD-2 Reports Where Lobbyists Failed to 
Properly Disclose One or More Covered Positions from 2010 through 2013: 

Refer to PDF for image: vertical bar graph] 

Year of review: 2010; 
Disclosed: 85%; 
Failed to disclose: 15%. 

Year of review: 2011; 
Disclosed: 83%; 
Failed to disclose: 17%. 

Year of review: 2012; 
Disclosed: 78%; 
Failed to disclose: 22%. 

Year of review: 2013; 
Disclosed: 83%; 
Failed to disclose: 17%. 

Source: GAO analysis. 

Note: Estimates of proportions based on sampled reports, generalizable 
to the universe of LD-2 reports with lobbying activity. Results have a 
maximum margin of error of 11 percent. Year-to-year differences are 
not statistically significant. For this element in prior reports, we 
reported an estimated minimum percentage of reports based on a one-
sided, 95 percent confidence interval rather than the estimated 
proportion as shown here. 

[End of figure] 

Some Lobbyists Amended Their Disclosure Reports After We Contacted 
Them: 

As of April 10, 2014, lobbyists amended 18 of the 104 disclosure 
reports in our original sample to make changes to previously reported 
information. One of the 18 reports was amended twice--once after we 
notified the lobbyists of our review and again after we met with them. 
An additional 7 of the 18 reports were amended after we notified the 
lobbyists of our review, but before we met with them. Finally, an 
additional 10 of the 18 reports were amended after we met with the 
lobbyists to review their documentation. We cannot be certain how 
lobbyists not in our sample would have behaved had they not been 
contacted by us. However, the notable number of amended LD-2 reports 
in our sample each year following notification of our review suggests 
that sometimes our contact spurs lobbyists to more closely scrutinize 
their reports than they would have without our review. 

Table 1 lists reasons lobbying firms in our sample amended their LD-1 
or LD-2 reports. 

Table 1: Reasons Lobbyists in Our Sample Amended Their Disclosure 
Reports as of April 2014: 

Reasons for amending: Update covered position; 
Number of times reason selected: 6. 

Reasons for amending: Change reported Income or expenses; 
Number of times reason selected: 5. 

Reasons for amending: Change House, Senate, or executive agency 
lobbying activity; 
Number of times reason selected: 5. 

Reasons for amending: Change individuals who acted as a lobbyist; 
Number of times reason selected: 2. 

Reasons for amending: Change specific issue areas lobbied; 
Number of times reason selected: 1. 

Reasons for amending: Change to no lobbying activity; 
Number of times reason selected: 1. 

Reasons for amending: Total; 
Number of times reason selected: 19. 

Source: GAO analysis. 

Note: Some firms cited more than one reason for amending. 
Additionally, one firm amended its disclosure report twice; once after 
we contacted the firm about the interview and again after the 
interview. Lobbyists may have amended either their LD-1 or LD-2 
reports to change information previously reported on the LD-2 under 
review. 

[End of table] 

Most LD-203 Contribution Reports Disclosed Political Contributions 
Listed in the FEC Database: 

As part of our review, we compared contributions listed on lobbyists' 
and lobbying firms' LD-203 reports against those political 
contributions reported in the FEC database to identify whether 
political contributions were omitted on LD-203 reports in our sample. 
The sample of LD-203 reports we reviewed originally contained 80 
reports with contributions and 80 reports without 
contributions.[Footnote 11] We estimate that overall, for 2013, 
lobbyists failed to disclose one or more reportable contributions on 4 
percent of reports.[Footnote 12] Table 2 illustrates that most 
lobbyists disclosed FEC reportable contributions on their LD-203 
reports as required from 2010 through 2013. 

Table 2: Estimated Percent of LD-203 Reports That Omitted One or More 
Political Contributions from 2010 through 2013: 

Year of review: Number of reports with contributions that had one or 
more omissions; 
2010: 7; 
2011: 12; 
2012: 14; 
2013: 10[A]. 

Year of review: Number of reports without contributions that had one 
or more omissions; 
2010: 1; 
2011: 2; 
2012: 4; 
2013: 0. 

Year of review: Estimated percentage of all reports with one or more 
omissions; 
2010: 4%; 
2011: 9%; 
2012: 9%; 
2013: 4%. 

Source: GAO analysis. 

Note: These results contain contributions that are reportable to the 
FEC. For this element in prior reports, we reported an estimated 
minimum percentage of reports based on a one-sided, 95 percent 
confidence interval rather than the estimated proportion as shown here. 

[A] n=80, except where noted with n=79. 

[End of table] 

Most Lobbying Firms Found It Easy to Comply with Disclosure 
Requirements and Understood Lobbying Terms: 

As part of our review, 92 different lobbying firms were included in 
our 2013 sample.[Footnote 13] Consistent with prior reviews, most 
lobbying firms reported that they found it very easy or somewhat easy 
to comply with reporting requirements. Of the 92 different lobbying 
firms in our sample, 20 reported that the disclosure requirements were 
"very easy," 59 reported them "somewhat easy," and 9 reported them 
"somewhat difficult" or "very difficult" (see figure 10).[Footnote 14] 

Figure 10: Ease of Complying with Disclosure Requirements from 2010 
through 2013: 

[Refer to PDF for image: vertical bar graph] 

Number of reports: 

Year of review: 2010; 
Very easy: 69; 
Somewhat easy: 0; 
Somewhat difficult or very difficult: 31. 

Year of review: 2011; 
Very easy: 61; 
Somewhat easy: 25; 
Somewhat difficult or very difficult: 4. 

Year of review: 2012; 
Very easy: 32; 
Somewhat easy: 39; 
Somewhat difficult or very difficult: 19. 

Year of review: 2013; 
Very easy: 20; 
Somewhat easy: 59; 
Somewhat difficult or very difficult: 9. 

Source: GAO analysis. 

Note: In 2011, our scale was easy to meet, somewhat easy to meet, or 
difficult to meet. In 2010, we asked if it was easy to comply with 
disclosure requirements. For 2013, 4 of the 92 different lobbying 
firms did not respond to the question about ease of compliance with 
reporting requirements. 

[End of figure] 

Most lobbyists we interviewed rated the terms associated with LD-2 
reporting requirements as "very easy" or "somewhat easy" to understand 
with regard to meeting their reporting requirements. This is 
consistent with prior reviews. Figures 11 through 15 show how 
lobbyists reported ease of understanding the terms associated with LD-
2 reporting requirements from 2010 through 2013.[Footnote 15] 

Figure 11: Ease of Understanding Lobbying Definitions from 2010 
through 2013: 

[Refer to PDF for image: vertical bar graph] 

Number of reports: 

Year of review: 2010; 
Very easy: 61; 
Somewhat easy: 26; 
Somewhat difficult or very difficult: 5. 

Year of review: 2011; 
Very easy: 64; 
Somewhat easy: 22; 
Somewhat difficult or very difficult: 4. 

Year of review: 2012; 
Very easy: 29; 
Somewhat easy: 42; 
Somewhat difficult or very difficult: 19. 

Year of review: 2013; 
Very easy: 34; 
Somewhat easy: 47; 
Somewhat difficult or very difficult: 7. 

Source: GAO analysis. 

Note: In 2011 and 2010, we asked lobbyists to rate the terms 
associated with LD-2 reporting using the scale clear and 
understandable, somewhat clear and understandable, or not clear and 
understandable. 

[End of figure] 

Figure 12: Ease of Understanding the Term "Lobbying Activities" from 
2010 through 2013: 

[Refer to PDF for image: vertical bar graph] 

Number of reports: 

Year of review: 2010; 
Very easy: 60; 
Somewhat easy: 28; 
Somewhat difficult or very difficult: 4. 

Year of review: 2011; 
Very easy: 59; 
Somewhat easy: 27; 
Somewhat difficult or very difficult: 4. 

Year of review: 2012; 
Very easy: 25; 
Somewhat easy: 42; 
Somewhat difficult or very difficult: 23. 

Year of review: 2013; 
Very easy: 30; 
Somewhat easy: 49; 
Somewhat difficult or very difficult: 10. 

Source: GAO analysis. 

Note: In 2011 and 2010, we asked lobbyists to rate the terms 
associated with LD-2 reporting using the scale, clear and 
understandable, somewhat clear and understandable, or not clear and 
understandable. 

[End of figure] 

Figure 13: Ease of Understanding Issue Codes from 2010 through 2013: 

[Refer to PDF for image: vertical bar graph] 

Number of reports: 

Year of review: 2010; 
Very easy: 61; 
Somewhat easy: 27; 
Somewhat difficult or very difficult: 4. 

Year of review: 2011; 
Very easy: 67; 
Somewhat easy: 20; 
Somewhat difficult or very difficult: 4. 

Year of review: 2012; 
Very easy: 47; 
Somewhat easy: 28; 
Somewhat difficult or very difficult: 14. 

Year of review: 2013; 
Very easy: 40; 
Somewhat easy: 37; 
Somewhat difficult or very difficult: 11. 

Source: GAO analysis. 

Note: In 2011 and 2010, we asked lobbyists to rate the terms 
associated with LD-2 reporting using the scale, clear and 
understandable, somewhat clear and understandable, or not clear and 
understandable. 

[End of figure] 

Figure 14: Ease of Understanding the Term "Covered Positions" from 
2010 through 2013: 

[Refer to PDF for image: vertical bar graph] 

Number of reports: 

Year of review: 2010; 
Very easy: 60; 
Somewhat easy: 18; 
Somewhat difficult or very difficult: 5. 

Year of review: 2011; 
Very easy: 67; 
Somewhat easy: 19; 
Somewhat difficult or very difficult: 4. 

Year of review: 2012; 
Very easy: 51; 
Somewhat easy: 15; 
Somewhat difficult or very difficult: 22. 

Year of review: 2013; 
Very easy: 38; 
Somewhat easy: 31; 
Somewhat difficult or very difficult: 13. 

Source: GAO analysis. 

Note: In 2011 and 2010, we asked lobbyists to rate the terms 
associated with LD-2 reporting using the scale, clear and 
understandable, somewhat clear and understandable, or not clear and 
understandable. 

[End of figure] 

Figure 15: Ease of Understanding the Term "Terminating Lobbyists" from 
2010 through 2013: 

[Refer to PDF for image: vertical bar graph] 

Number of reports: 

Year of review: 2010; 
Very easy: 67; 
Somewhat easy: 18; 
Somewhat difficult or very difficult: 7. 

Year of review: 2011; 
Very easy: 74; 
Somewhat easy: 12; 
Somewhat difficult or very difficult: 4. 

Year of review: 2012; 
Very easy: 52; 
Somewhat easy: 21; 
Somewhat difficult or very difficult: 14. 

Year of review: 2013; 
Very easy: 34; 
Somewhat easy: 33; 
Somewhat difficult or very difficult: 8. 

Source: GAO analysis. 

Note: In 2011 and 2010, we asked lobbyists to rate the terms 
associated with LD-2 reporting using the scale, clear and 
understandable, somewhat clear and understandable, or not clear and 
understandable. 

[End of figure] 

U.S. Attorney's Office Actions to Enforce LDA: 

The Office's Authorities, Processes, and Resources to Enforce LDA 
Compliance: 

The Office stated it continues to have sufficient personnel resources 
and authority under the LDA to enforce LD-2 reporting requirements, 
including imposing civil or criminal penalties for noncompliance of LD-
2 reporting. Noncompliance refers to a lobbyist's or lobbying firm's 
failure to comply with LDA requirements. According to the Office, it 
has one contract paralegal specialist assigned full time, as well as 
five civil attorneys and one criminal attorney assigned part time for 
LDA compliance work. In addition, the Office stated that it 
participates in a government-wide program that provides temporary 
access to attorneys to assist with LDA compliance. The temporarily 
assigned attorneys work with the contract paralegal specialist to 
contact referred lobbyists or lobbying firms who do not comply with 
the LDA. 

According to the Office, it has sufficient authority to enforce LD-203 
compliance with the LDA for lobbying firms and certain individual 
lobbyists. However, it has difficulty pursuing hundreds of LD-203 
referrals that arise when a lobbying firm does not maintain or a 
lobbyist does not leave forwarding contact information upon leaving 
the firm. The LD-203 report does not provide contact information. It 
only provides the name of the lobbyist and lobbying firm. As a result, 
the Office does not have contact information to find the referred 
lobbyist to bring him or her into compliance. Office officials 
reported that many firms have assisted them by providing contact 
information for lobbyists, and only a few firms have not been willing 
to provide contact information for noncompliant lobbyists. 
Additionally, the Office stated that because the current structure of 
the LDA requires registered lobbyists to file their LD-203 reports and 
does not require lobbying firms to ensure that their registered 
lobbyists have complied with LD-203 filing requirements, the Office 
has no authority to hold lobbying firms responsible for a registered 
lobbyist who fails to comply with LD-203 requirements. Accordingly, 
when the Office does not have contact information to find a lobbyist 
who left the firm and it cannot hold the lobbying firm responsible for 
the lobbyist's noncompliance with lobbying disclosure requirements, 
the Office has no recourse to pursue enforcement action. 

In a prior report, we recommended that the Office develop a structured 
approach for tracking and recording its enforcement actions.[Footnote 
16] The Office developed the LDA database to track the status of 
referrals and enforcement actions it takes to bring lobbyists and 
lobbying firms into compliance with the LDA. To enforce compliance, 
the Office has primarily focused on sending letters to lobbyists who 
have potentially violated the LDA by not filing disclosure reports as 
required. The letters request lobbyists to comply with the law by 
promptly filing the appropriate disclosure reports and inform 
lobbyists of potential civil and criminal penalties for not complying. 
In addition to sending letters, a contractor sends e-mails and calls 
lobbyists to inform them of their need to comply with LDA reporting 
requirements. Not all referred lobbyists receive noncompliance 
letters, e-mails, or phone calls because some of the lobbyists have 
terminated their registrations or filed the required financial 
disclosure reports before the Office received the referral. 

Office officials stated that lobbyists resolve their noncompliance 
issues by filing the reports or terminating their registration. 
Resolving referrals can take anywhere from a few days to years 
depending on the circumstances. During this time, the Office monitors 
and reviews all outstanding referrals and uses summary reports from 
the database to track the overall number of referrals that become 
compliant as a result of receiving an e-mail, phone call, or 
noncompliance letter. In addition, more referred lobbyists are being 
contacted by e-mail and phone calls, which has decreased the number of 
noncompliance letters the Office sends to lobbyists. Officials from 
the Office stated that the majority of these e-mails and calls result 
in the registrant becoming compliant without sending a letter. In our 
last report, the Office told us that its system collects information 
on contacts made by e-mail and phone calls in the notes section of its 
database, but the database does not automatically tabulate the number 
of e-mails and phone calls to lobbyists, as it does for letters sent. 
[Footnote 17] In March 2013 as a part of closing discussions with the 
Office about the findings of our last lobbying disclosure report, as 
part of its enforcement efforts we urged the Office to develop a 
mechanism to track e-mails and telephone contacts to individual 
lobbyists. Since then, the Office has started tracking the number of e-
mails and telephone contacts that are associated with its enforcement 
efforts to bring lobbyists and lobbying firms into compliance. These 
actions are now included in the number of enforcement actions taken to 
bring lobbyists and lobbying firms into compliance. 

Status of LD-2 Enforcement Efforts from 2009 through 2013 Reporting 
Periods: 

As of January 16, 2014, the Office has received 2,722 referrals from 
both the Secretary of the Senate and the Clerk of the House for 
failure to comply with LD-2 reporting requirements cumulatively for 
calendar years 2009 through 2013. Figure 16 shows the number and 
status of the referrals received and the number of enforcement actions 
taken by the Office in its effort to bring lobbying firms into 
compliance. Enforcement actions include the number of letters, e-
mails, and calls made by the Office. About 66 percent (1,787 of 2,722) 
of the total referrals received are now compliant because lobbying 
firms either filed their reports or terminated their registrations. In 
addition, some of the referrals were found to be compliant when the 
Office received the referral, and therefore no action was taken. This 
may occur when lobbying firms respond to the contact letters from the 
Secretary of the Senate and Clerk of the House after the Office has 
received the referrals. About 34 percent (922 of 2,722) of referrals 
are pending action because the Office was unable to locate the 
lobbying firm, did not receive a response from the firm, or plans to 
conduct additional research to determine if it can locate the lobbying 
firm. According to the Office, resolving referrals can take anywhere 
from a few days to years depending on the circumstances. Referrals may 
remain in pending status and may be monitored by the Office until it 
determines whether to pursue legal action against the registrant or 
dismiss certain referrals or until the registrant files the disclosure 
report or terminates his or her registration. The remaining 13 
referrals did not require action or were suspended because the 
lobbyist or client was no longer in business or the lobbyist was 
deceased. The Office suspends enforcement actions against lobbyists or 
lobbying firms that are repeatedly referred for not filing disclosure 
reports but that do not have any current lobbying activity. The 
suspended lobbying firms are periodically monitored to determine 
whether they actively lobby in the future. As a part of this 
monitoring, the Office checks the lobbying disclosure databases 
maintained by the Secretary of the Senate and the Clerk of the House. 

Figure 16: Status of LDA Enforcement Actions for LD-2 Reporting from 
2009 through 2013 (as of January 16, 2014): 

[Refer to PDF for image: table and pie-chart] 

Year: 2009; 
Number of enforcement actions: 414; 
Number of referrals received: 678; 
Referrals now compliant: 569; 
Referrals pending action: 107; 
Referrals with no action taken or suspended: 2. 

Year: 2010; 
Number of enforcement actions: 262; 
Number of referrals received: 672; 
Referrals now compliant: 575; 
Referrals pending action: 86; 
Referrals with no action taken or suspended: 11. 

Year: 2011; 
Number of enforcement actions: 364; 
Number of referrals received: 577; 
Referrals now compliant: 383; 
Referrals pending action: 194; 
Referrals with no action taken or suspended: 0. 

Year: 2012; 
Number of enforcement actions: 232; 
Number of referrals received: 665; 
Referrals now compliant: 258; 
Referrals pending action: 407; 
Referrals with no action taken or suspended: 0. 

Year: 2013; 
Number of enforcement actions: 0; 
Number of referrals received: 130; 
Referrals now compliant: 2; 
Referrals pending action: 128; 
Referrals with no action taken or suspended: 0. 

Total: 
Number of enforcement actions: 1,272; 
Number of referrals received: 2,722; 
Referrals now compliant: 1,787; 
Referrals pending action: 922; 
Referrals with no action taken or suspended: 13. 

Referrals now compliant: 66%; 
Referrals pending action: 34%; 
Referrals with no action taken or suspended: 0%. 

Source: U.S. Attorney's Office for the District of Columbia. 

[End of figure] 

Status of LD-203 Enforcement Actions from 2009 through 2013 Reporting 
Periods: 

LD-203 referrals consist of two types: LD-203(R) referrals represent 
lobbying firms that have failed to file LD-203 reports for the firm, 
and LD-203 referrals represent the lobbyists at the lobbying firm who 
have failed to file their individual LD-203 reports as required. As of 
January 16, 2014, the Office had received 1,350 LD-203(R) referrals 
and 3,042 LD-203 referrals from the Secretary of the Senate and Clerk 
of the House cumulatively for calendar years 2009 through 2013. For LD-
203 referrals, the Office sends noncompliance letters for the 
lobbyists to the registered lobbying firms listed on the LD-203 report 
because the lobbyist's personal contact information is not listed on 
the LD-203 report. 

Figure 17 shows the status of LD-203(R) referrals received and the 
number of enforcement actions taken by the Office in its effort to 
bring lobbying firms into compliance. About 43 percent (581 of 1,350) 
of the lobbyists who were referred by the Secretary of the Senate and 
Clerk of the House for noncompliance during the 2009 through 2013 
reporting periods are now considered compliant because lobbying firms 
either have filed their reports or have terminated their 
registrations. About 57 percent (768 of 1,350) of the referrals are 
pending action because the Office was unable to locate the lobbyist, 
did not receive a response from the lobbyist, or plans to conduct 
additional research to determine if it can locate the lobbying firm. 

Figure 17: Status of LDA Enforcement Actions for LD-203(R) Lobbying 
Firms Only Reporting from 2009 through 2013 (as of January 16, 2014): 

[Refer to PDF for image: table and pie-chart] 

Year: 2009; 
Number of referrals received: 151; 
Referrals now compliant: 106; 
Referrals pending action: 45; 
Referrals with no action taken or suspended: 0; 
Number of enforcement actions taken: 79. 

Year: 2010; 
Number of referrals received: 328; 
Referrals now compliant: 223; 
Referrals pending action: 105; 
Referrals with no action taken or suspended: 0; 
Number of enforcement actions taken: 167. 

Year: 2011; 
Number of referrals received: 403; 
Referrals now compliant: 219; 
Referrals pending action: 184; 
Referrals with no action taken or suspended: 0; 
Number of enforcement actions taken: 282. 

Year: 2012; 
Number of referrals received: 345; 
Referrals now compliant: 33; 
Referrals pending action: 311; 
Referrals with no action taken or suspended: 1; 
Number of enforcement actions taken: 122. 

Year: 2013; 
Number of referrals received: 123; 
Referrals now compliant: 0; 
Referrals pending action: 123; 
Referrals with no action taken or suspended: 0; 
Number of enforcement actions taken: 0. 

Total: 
Number of referrals received: 1,350; 
Referrals now compliant: 581; 
Referrals pending action: 768; 
Referrals with no action taken or suspended: 1; 
Number of enforcement actions taken: 650. 

Referrals now compliant: 43%; 
Referrals pending action: 57%; 
Referrals with no action taken or suspended: 0%. 

Source: U.S. Attorney's Office for the District of Columbia. 

[End of figure] 

Figure 18 shows that as of January 16, 2014, the Office had received 
3,042 LD-203 referrals from the Secretary and Clerk for lobbyists who 
failed to comply with LD-203 reporting requirements for calendar years 
2009 through 2012. Figure 18 shows the status of the referrals 
received and the number of enforcement actions taken by the Office in 
its effort to bring lobbyists into compliance. Figure 18 shows that 55 
percent (1,676 of 3,042) of the lobbyists either have come into 
compliance by filing their reports or are no longer registered as a 
lobbyist. About 44 percent (1,352 of 3,042) of the referrals are 
pending action because the Office was unable to locate the lobbyists, 
did not receive a response from the lobbyists, or plans to conduct 
additional research to determine if it can locate the lobbyists. 

Figure 18: Status of LDA Enforcement Actions for LD-203 Lobbyists Only 
for Reporting from 2009 through 2012 (as of January 16, 2014): 

[Refer to PDF for image: table and pie-chart] 

Year: 2009; 
Number of referrals received: 980; 
Referrals now compliant: 656; 
Referrals pending action: 319; 
Referrals with no action taken or suspended: 5; 
Number of enforcement actions taken: 495. 

Year: 2010; 
Number of referrals received: 1,810; 
Referrals now compliant: 1,017; 
Referrals pending action: 784; 
Referrals with no action taken or suspended: 9; 
Number of enforcement actions taken: 621. 

Year: 2011; 
Number of referrals received: 103; 
Referrals now compliant: 0; 
Referrals pending action: 103; 
Referrals with no action taken or suspended: 0; 
Number of enforcement actions taken: 0. 

Year: 2012; 
Number of referrals received: 149; 
Referrals now compliant: 3; 
Referrals pending action: 146; 
Referrals with no action taken or suspended: 0; 
Number of enforcement actions taken: 0. 

Total: 
Number of referrals received: 3,042; 
Referrals now compliant: 1,676; 
Referrals pending action: 1,352; 
Referrals with no action taken or suspended: 14; 
Number of enforcement actions taken: 1,116. 

Referrals now compliant: 55%; 
Referrals pending action: 44%; 
Referrals with no action taken or suspended: 1%. 

Source: U.S. Attorney's Office for the District of Columbia. 

[End of figure] 

The Office said that many of the pending LD-203 referrals represent 
lobbyists who no longer lobby for the lobbying firms affiliated with 
the referrals, even though these lobbying firms may be listed on the 
lobbyist's LD-203 report. In addition, Office officials stated that 
they continue to experience challenges with increasing LD-203 
compliance because the Office has little leverage to bring certain 
individual lobbyists into compliance. Many of the LD-203 referrals 
remain open in an attempt to locate lobbyists who are no longer 
employed by the lobbying firm and do not leave a forwarding address. 
As a result, it may take years to resolve the referrals and bring the 
lobbyists into compliance. 

Status of Enforcement Settlement Actions: 

Since the 2012 reporting period, the Office has identified nine 
registrants on its chronic offenders list for failure to comply with 
reporting requirements. Of the nine registrants, five filed the 
outstanding reports or terminated their registration after being 
contacted by an Assistant U.S. Attorney. The Office reached settlement 
agreements with two of the registrants for $50,000 and $30,000, 
respectively, in civil penalties for repeatedly failing to file 
disclosure reports. In December 2013, the Office filed a default 
judgment for $200,000 against a registrant for repeated failure to 
file his LDA reports as required. In March 2014, the Office filed a 
civil complaint in the U.S. District Court for the District of 
Columbia for a registrant's failure to comply with LDA reporting 
requirements. 

The Office continues to monitor and review chronic offenders to 
determine appropriate enforcement actions, which may include 
considering legal actions or dismissing certain cases. 

Concluding Observations: 

Over the past several years of reporting on lobbying disclosure, we 
have found that lobbyists reported understanding terms and 
requirements, but their disclosure filings demonstrated some 
compliance difficulties. For example, a number of lobbyists had 
rounding errors in their reports, failed to disclose covered 
positions, and did not accurately disclose their lobbying activity 
with the House, the Senate, or executive agencies. As a result, after 
being contacted by us, lobbyists amended their reports to address 
these types of compliance difficulties. In our first lobbying 
disclosure report in September 2008, we concluded that the lobbying 
community could benefit from creating an organization to: 

* share examples of best practices of the types of records maintained 
to support filings; 

* use this information gathered over an initial period to formulate 
minimum standards for recordkeeping; 

* provide training for the lobbying community on reporting and 
disclosure requirements intended to help the community comply with the 
LDA; and: 

* report annually to the Secretary of the Senate and the Clerk of the 
House on opportunities to clarify existing guidance and ways to 
minimize sources of potential confusion for the lobbying community. 

The continuing difficulties that some lobbyists have demonstrated in 
their disclosure reports, coupled with the sustained public and 
congressional attention on lobbyists and their interactions with 
government officials, underscores the importance of accurate and 
public disclosure of such activities. In that regard, we continue to 
believe that creating the type of organization we described in our 
first report could still be beneficial to the lobbying community and 
the public interest. The activities of such an organization could help 
enhance the enforcement and compliance with the LDA as amended by 
HLOGA and improve the accuracy and value of the information reported 
to Congress. 

Agency Comments: 

We provided a draft of this report to the Attorney General for review 
and comment. The Assistant U.S. Attorney for the District of Columbia 
responded on behalf of the Attorney General that the Department of 
Justice had no comments. 

We are sending copies of this report to the Attorney General, 
Secretary of the Senate, Clerk of the House of Representatives, and 
interested congressional committees and members. In addition, this 
report is available at no charge on the GAO website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-4749 or bagdoyans@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix IV. 

Signed by: 

Seto J. Bagdoyan: 
Acting Director, Strategic Issues: 

List of Committees: 

The Honorable Thomas R. Carper: 
Chairman: 
The Honorable Thomas A. Coburn, M.D. 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Patrick J. Leahy: 
Chairman: 
The Honorable Charles E. Grassley: 
Ranking Member: 
Committee on the Judiciary: 
United States Senate: 

The Honorable Charles E. Schumer: 
Chairman: 
The Honorable Charles P. Roberts: 
Ranking Member: 
Committee on Rules and Administration: 
United States Senate: 

The Honorable Candice S. Miller: 
Chairman: 
The Honorable Robert A. Brady: 
Ranking Member: 
Committee on House Administration: 
House of Representatives: 

The Honorable Robert W. Goodlatte: 
Chairman: 
The Honorable John Conyers, Jr. 
Ranking Member: 
Committee on the Judiciary: 
House of Representatives: 

The Honorable Darrell E. Issa: 
Chairman: 
The Honorable Elijah E. Cummings: 
Ranking Member: 
Committee on Oversight and Governmental Reform: 
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Consistent with the mandate in the Honest Leadership and Open 
Government Act (HLOGA), our objectives were to: 

* determine the extent to which lobbyists are able to demonstrate 
compliance with the Lobbying Disclosure Act of 1995, as amended (LDA) 
by providing documentation to support information contained on 
registrations and reports filed under the LDA; 

* identify challenges and potential improvements to compliance, if 
any; and: 

* describe the resources and authorities available to the U.S. 
Attorney's Office for the District of Columbia (the Office) and the 
efforts the Office has made to improve enforcement of the LDA. 

To respond to our mandate, we used information in the lobbying 
disclosure database maintained by the Clerk of the House of 
Representatives (Clerk of the House). To assess whether these 
disclosure data were sufficiently reliable for the purposes of this 
report, we reviewed relevant documentation and spoke to officials 
responsible for maintaining the data. Although registrations and 
reports are filed through a single web portal, each chamber 
subsequently receives copies of the data and follows different data 
cleaning, processing, and editing procedures before storing the data 
in either individual files (in the House) or databases (in the 
Senate). Currently, there is no means of reconciling discrepancies 
between the two databases caused by the differences in data 
processing. For example, Senate staff told us during previous reviews 
that they set aside a greater proportion of registration and report 
submissions than the House for manual review before entering the 
information into the database. As a result, the Senate database would 
be slightly less current than the House database on any given day 
pending review and clearance. House staff told us during previous 
reviews that they rely heavily on automated processing. They added 
that while they manually review reports that do not perfectly match 
information on file for a given registrant or client, they will 
approve and upload such reports as originally filed by each lobbyist, 
even if the reports contain errors or discrepancies (such as a variant 
on how a name is spelled). Nevertheless, we do not have reasons to 
believe that the content of the Senate and House systems would vary 
substantially. For this review, we determined that House disclosure 
data were sufficiently reliable for identifying a sample of quarterly 
disclosure (LD-2) reports and for assessing whether newly filed 
registrants also filed required reports. We used the House database 
for sampling LD-2 reports from the third and fourth quarters of 2012 
and the first and second quarters of 2013, as well as for sampling 
year-end 2012 and midyear 2013 political contributions (LD-203) 
reports and finally for matching quarterly registrations with filed 
reports. We did not evaluate the Offices of the Secretary of the 
Senate or the Clerk of the House, both of which have key roles in the 
lobbying disclosure process. However, we did consult with officials 
from each office and they provided us with general background 
information at our request. 

To assess the extent to which lobbyists could provide evidence of 
their compliance with reporting requirements, we examined a stratified 
random sample of 104 LD-2 reports from the third and fourth quarters 
of 2012 and the first and second quarters of 2013. We excluded reports 
with no lobbying activity or with income less than $5,000 from our 
sampling frame.[Footnote 18] We drew our sample from 65,489 activity 
reports filed for the third and fourth quarters of 2012 and the first 
and second quarters of 2013 available in the public House database, as 
of our final download date for each quarter. One LD-2 report was 
removed from the sample because we could not contact the firm and it 
appears the firm has gone out of business. We treated this report as a 
nonrespondent for the purposes of analysis and adjusted our sampling 
weights accordingly for analysis. Another LD-2 report was excluded 
because the lobbyist amended the LD-2 to reflect no lobbying activity 
after being notified of the review. This report was treated as out of 
scope. 

Our sample of LD-2 reports was not designed to detect differences over 
time. However, we conducted tests of significance for changes from 
2010 to 2013 for the generalizable elements of our review and found 
that there were generally no statistically significant differences 
over time. With the exception of one yearly decrease in the estimated 
proportion of reports with income or expense discrepancies of $10,000 
or more, we found no statistically significant differences after using 
a Bonferroni adjustment to account for multiple comparisons.[Footnote 
19] While the results provide some confidence that apparent 
fluctuations in our results across years are likely attributable to 
sampling error, the inability to detect significant differences may 
also be related to the nature of our sample, which was relatively 
small and was designed only for cross-sectional analysis. 

Our sample is based on a stratified random selection and is only one 
of a large number of samples that we may have drawn. Because each 
sample could have provided different estimates, we express our 
confidence in the precision of our particular sample's results as a 95 
percent confidence interval. This interval would contain the actual 
population value for 95 percent of the samples that we could have 
drawn. The percentage estimates for 2013 have a 95 percent confidence 
interval of within plus-or-minus 10.1 percentage points or less of the 
estimate itself, unless otherwise noted. For 2010 through 2012, the 
percentage estimates have a 95 percent confidence interval with a 
maximum of 11 percentage points. 

We contacted the lobbyists and lobbying firms in our sample using a 
structured web-based survey and asked them to confirm key elements of 
the LD-2 and provide documentation for key elements in their reports, 
including: 

* the amount of income reported for lobbying activities, 

* the amount of expenses reported on lobbying activities, 

* the names of those lobbyists listed in the report, 

* the houses of Congress and federal agencies that they lobbied, and: 

* the issue codes listed to describe their lobbying activity. 

After reviewing the survey results for completeness, we conducted 
interviews with the lobbyists and lobbying firms to review 
documentation they reported as having on their online survey for 
selected elements of their LD-2 reports. 

Prior to each interview, we conducted an open source search to 
identify lobbyists on each report who may have held a covered official 
position. We reviewed the lobbyists' previous work histories by 
searching lobbying firms' websites, LinkedIn, Leadership Directories, 
Legistorm, and Google. Prior to 2008, lobbyists were only required to 
disclose covered official positions held within 2 years of registering 
as a lobbyist for the client. HLOGA amended that time frame to require 
disclosure of positions held 20 years before the date the lobbyists 
first lobbied on behalf of the client. Lobbyist are required to 
disclose previously held covered official positions either on the 
client registration (LD-1) or on the first LD-2 report when the 
lobbyist is added as "new." Consequently, those who held covered 
official positions may have disclosed the information on the LD-1 or a 
LD-2 report filed prior to the report we examined as part of our 
random sample. Therefore, where we found evidence that a lobbyist 
previously held a covered official position and it was not disclosed 
on the LD-2 report under review, we then conducted an additional 
reviewed the publicly available Secretary of the Senate or Clerk of 
the House database. This was done to determine whether the lobbyist 
properly disclosed the covered official position on a prior report or 
LD-1. Finally, if a lobbyist appeared to hold a covered position that 
was not disclosed, we asked for an explanation at the interview with 
the lobbying firm to ensure that our research was accurate. In 
previous reports, we reported the lower bound of a 90-percent 
confidence interval to provide a minimum estimate of omitted covered 
positions and omitted contributions with a 95 percent confidence 
level. We did so to account for the possibility that our searches may 
have failed to identify all possible omitted covered positions and 
contributions. As we have developed our methodology over time, we are 
more confident in the comprehensiveness of our searches for these 
items. Accordingly, this report presents the estimated percentages for 
omitted contributions and omitted covered positions rather than the 
minimum estimates. As a result, percentage estimates for these items 
will differ slightly from the minimum percentage estimates presented 
in prior reports: 

In addition to examining the content of the LD-2 reports, we confirmed 
whether year-end 2012 or midyear 2013 LD-203 reports had been filed 
for each firm and lobbyist listed on the LD-2 reports in our random 
sample. Although this review represents a random selection of 
lobbyists and firms, it is not a direct probability sample of firms 
filing LD-2 reports or lobbyists listed on LD-2 reports. As such, we 
did not estimate the likelihood that LD-203 reports were appropriately 
filed for the population of firms or lobbyists listed on LD-2 reports. 

To determine if the LDA's requirement for registrants to file a report 
in the quarter of registration was met for the third and fourth 
quarters of 2012 and the first and second quarters of 2013, we used 
data filed with the Clerk of the House to match newly filed 
registrations with corresponding disclosure reports. Using an 
electronic matching algorithm that includes strict and loose text 
matching procedures, we identified matching disclosure reports for 
2,925, or 96 percent, of the 3,034 newly filed registrations. We began 
by standardizing client and registrant names in both the report and 
registration files (including removing punctuation and standardizing 
words and abbreviations, such as "company" and "CO"). We then matched 
reports and registrations using the House identification number (which 
is linked to a unique registrant-client pair), as well as the names of 
the registrant and client. For reports we could not match by 
identification number and standardized name, we also attempted to 
match reports and registrations by client and registrant name, 
allowing for variations in the names to accommodate minor misspellings 
or typos. For these cases, we used professional judgment to determine 
whether cases with typos were sufficiently similar to consider as 
matches. We could not readily identify matches in the report database 
for the remaining registrations using electronic means. 

To assess the accuracy of the LD-203 reports, we analyzed stratified 
random samples of LD-203 reports from the 31,482 total LD-203 reports. 
The first sample contains 80 of the 10,227 reports with political 
contributions. The second contains 80 of the 21,255 reports listing no 
contributions. Each sample contains 40 reports from the year-end 2012 
filing period and 40 reports from the midyear 2013 filing period. 
[Footnote 20] The samples allow us to generalize estimates in this 
report to either the population of LD-203 reports with contributions 
or the reports without contributions to within a 95 percent confidence 
interval of plus or minus 9.5 percentage points or less. Although our 
sample of LD-203 reports was not designed to detect differences over 
time, we conducted tests of significance for changes from 2010 to 2013 
and found no statistically significant differences after adjusting for 
multiple comparisons.[Footnote 21] While the results provide some 
confidence that apparent fluctuations in our results across years are 
likely attributable to sampling error, the inability to detect 
significant differences may also be related to the nature of our 
sample, which was relatively small and designed only for cross-
sectional analysis. We analyzed the contents of the LD-203 reports and 
compared them to contribution data found in the publicly available 
Federal Elections Commission's (FEC) political contribution database. 
We interviewed FEC staff responsible for administering the database 
and determined that the data reliability is suitable for confirming 
whether a FEC-reportable disclosure listed in the FEC database had 
been reported on an LD-203 report. 

We compared the FEC-reportable contributions reporting on the LD-203 
reports with information in the FEC database. The verification process 
required text and pattern matching procedures, and we used 
professional judgment when assessing whether an individual listed is 
the same individual filing an LD-203. For contributions reported in 
the FEC database and not on the LD-203 report, we asked the lobbyists 
or organizations to explain why the contributions were not listed on 
the LD-203 report or to provide documentation of those contributions. 
As with covered positions on LD-2 disclosure reports, we cannot be 
certain that our review identified all cases of FEC-reportable 
contributions that were inappropriately omitted from a lobbyist's LD-
203 report. We did not estimate the percentage of other non-FEC 
political contributions that were omitted because they tend to 
constitute a small minority of all listed contributions and cannot be 
verified against an external source. 

To identify challenges to compliance, we used a web-based survey and 
obtained the views from 92 different lobbying firms included in our 
sample on any challenges to compliance. The number of different 
lobbying firms total 92 and is less than our sample of 102 reports 
because some lobbying firms had more than 1 LD-2 report included in 
our sample. We calculated our responses based on the number of 
different lobbying firms that we contacted rather than the number of 
interviews. Prior to our calculations, we removed the duplicate 
lobbying firms based on the most recent date of their responses. For 
those cases with the same response date, we kept the cases with the 
smallest assigned case identification number. To obtain their views, 
we asked them to rate their ease with complying with the LD-2 
disclosure requirements using a scale of "very easy," "somewhat easy," 
"somewhat difficult," or "very difficult." In addition, using the same 
scale we asked them to rate the ease of understanding the terms 
associated with LD-2 reporting requirements. 

To describe the resources and authorities available to the Office and 
its efforts to improve its LDA enforcement, we interviewed officials 
from the Office and obtained updated information on the capabilities 
of the system they established to track and report compliance trends 
and referrals, and other practices established to focus resources on 
enforcement of the LDA. The Office provided us with updated reports 
from the tracking system on the number and status of referrals and 
chronically noncompliant lobbyists and lobbying firms. 

The mandate does not include identifying lobbyists who failed to 
register and report in accordance with LDA requirements, or whether 
for those lobbyists who did register and report, that all lobbying 
activity or contributions were disclosed. 

We conducted this performance audit from June 2013 through May 2014 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: List of Registrants and Clients for Sampled Lobbying 
Disclosure Reports: 

The random sample of lobbying disclosure reports we selected was based 
on unique combinations of registrant lobbyists and client names (see 
table 3). 

Table 3: Names of Registrants and Clients Selected in Random Sample of 
Lobbying Disclosure Reports Filed in the Third and Fourth Quarters of 
2012 and the First and Second Quarters of 2013: 

Registrant name: 38 North Solutions, LLC; 
Client: Gamesa Technology Corporation, Inc. 

Registrant name: A.O. Smith Corporation; 
Client: A.O. Smith Corporation. 

Registrant name: Akin Gump Strauss Hauer & Feld; 
Client: CT Corporation. 

Registrant name: American Continental Group; 
Client: Monsanto Company. 

Registrant name: American Continental Group; 
Client: New York State Association for Affordable Housing. 

Registrant name: Ascension Health; 
Client: Ascension Health. 

Registrant name: Atlantic Strategies Group; 
Client: Scientific Research Corporation. 

Registrant name: Baker Donelson Bearman Caldwell & Berkowitz; 
Client: EO2 Concepts. 

Registrant name: Barnes & Thornburg LLP; 
Client: Board of Commissioners of Vanderburgh County. 

Registrant name: Blank Rome Government Relations; 
Client: Intelsat. 

Registrant name: Bob Lawrence & Associates, Inc. 
Client: Renaissance Associates S.A. 

Registrant name: Breaux Lott Leadership Group; 
Client: St. Tammany Parish. 

Registrant name: Brownstein Hyatt Farber Schreck, LLP; 
Client: Genworth Financial, Inc. 

Registrant name: Capitol Representatives; 
Client: The Greenway Foundation. 

Registrant name: Capitol Strategies, LLC; 
Client: Lower Santa Cruz River Alliance. 

Registrant name: Capitol Tax Partners, LLP; 
Client: International Paper Company. 

Registrant name: Cassidy & Associates, Inc. (formerly known as Cassidy 
& Associates); 
Client: Lovelace Respiratory Research Institute. 

Registrant name: Caterpillar Inc. 
Client: Caterpillar Inc. 

Registrant name: CJ Lake, LLC; 
Client: CALSTART. 

Registrant name: Cornerstone Government Affairs, LLC; 
Client: Custodial Financial. 

Registrant name: Covington & Burling LLP; 
Client: Monster Energy Company. 

Registrant name: DCI Group, LLC; 
Client: Exxon Mobil. 

Registrant name: Denny Miller Associates; 
Client: General Atomics. 

Registrant name: East End Group, LLC; 
Client: The Pharmaceutical Research and Manufacturers of America. 

Registrant name: Edmund Graber; 
Client: Santa Rosa County FL. 

Registrant name: Fleet Street Group; 
Client: Xcel Energy. 

Registrant name: Friends Committee on National Legislation; 
Client: Friends Committee on National Legislation. 

Registrant name: Hannegan Landau Poersch Advocacy, LLC; 
Client: Quad Partners. 

Registrant name: Health Policy Source, Inc. 
Client: American Society for Anesthesiologists. 

Registrant name: Hogan Lovells US LLP; 
Client: National Chicken Council. 

Registrant name: Hogan Lovells US LLP; 
Client: GE Oil & Gas. 

Registrant name: Hyjek & Fix, Inc. 
Client: Assured Information Security, Inc. 

Registrant name: Intellectual Property Owners Association; 
Client: Intellectual Property Owners Association. 

Registrant name: Jackson Lewis LLP; 
Client: Safeway Inc. 

Registrant name: James Desmond; 
Client: Lockheed Martin. 

Registrant name: Jamison and Sullivan, Inc. 
Client: Douglas County, Oregon. 

Registrant name: John T. O'Rourke; 
Client: H&R Block Inc. 

Registrant name: K &L Gates LLP; 
Client: Starbucks Coffee Corp. 

Registrant name: Kadesh & Associates, LLC; 
Client: Chuckwalla Farm Land, LLC. 

Registrant name: Karv Communications, Inc. 
Client: German Insurance Association. 

Registrant name: Kia Motors Corporation; 
Client: Kia Motors Corporation. 

Registrant name: League of Women Voters of the US; 
Client: League of Women Voters of the US. 

Registrant name: Liberty Square Group; 
Client: Massachusetts Biotechnology Council. 

Registrant name: LTD Group, LLC; 
Client: JP Morgan Chase & Co. 

Registrant name: Manatt, Phelps & Phillips, LLP; 
Client: Outdoor Advertising Association of America, Inc. 

Registrant name: Marla Grossman; 
Client: American Continental Group on Behalf of The Authors Guild, Inc. 

Registrant name: McAllister & Quinn LLC; 
Client: Yardney Technical Products. 

Registrant name: McBee Strategic Consulting, LLC; 
Client: Corrections Corporation of America. 

Registrant name: Miller/Wenhold Capitol Strategies, LLC; 
Client: Taxicab, Limosuine and Partransit Association. 

Registrant name: Mintz Levin Cohn Ferris Glovsky and Popeo, P.C. 
Client: National Cable & Telecommunications Association. 

Registrant name: Motorcycle Riders Foundation; 
Client: Motorcycle Riders Foundation. 

Registrant name: Mr. Khalil Saliba; 
Client: OSI Restaurant Partners, Inc. 

Registrant name: MWW Group; 
Client: WebMD Health (formerly known as Medscape, Inc.). 

Registrant name: Nathanson+Hauck; 
Client: Freelancers Union. 

Registrant name: National Beer Wholesalers Association; 
Client: National Beer Wholesalers Association. 

Registrant name: National Council for Community Behavioral Healthcare; 
Client: National Council for Community Behavioral Healthcare. 

Registrant name: National Council of Farmer Cooperatives; 
Client: National Council of Farmer Cooperatives. 

Registrant name: Nelson, Mullins, Riley & Scarborough; 
Client: University of Massachusetts at Dartmouth. 

Registrant name: Nelson, Mullins, Riley & Scarborough, LLP; 
Client: Myrtle Beach Downtown Redevelopment Corp. 

Registrant name: Omer F. Brown, II Law Office; 
Client: Contractors International Group on Nuclear Liability. 

Registrant name: O'Neill, Athy & Casey, P.C. 
Client: Cape Cod Healthcare. 

Registrant name: Palmetto Group; 
Client: Hewlett-Packard Company. 

Registrant name: Palmetto Group; 
Client: Association of Clinical Research Organizations. 

Registrant name: Pennsylvania Farm Bureau; 
Client: Pennsylvania Farm Bureau. 

Registrant name: Podesta Group, Inc. 
Client: Monster Energy Company. 

Registrant name: Podesta Group, Inc. 
Client: URS Corporation. 

Registrant name: PPG Industries, Inc. 
Client: PPG Industries, Inc. 

Registrant name: PRASAM; 
Client: DigitalGlobe, Inc. 

Registrant name: Quinn Gillespie & Associates; 
Client: National Association of Realtors. 

Registrant name: R. B. Murphy & Associates, LLC; 
Client: Google Inc. 

Registrant name: Robert Talley; 
Client: TAPS. 

Registrant name: Russ Reid Company; 
Client: Covenant House Florida. 

Registrant name: Scholastic Inc. 
Client: Scholastic Inc. 

Registrant name: Sustainable Strategies DC; 
Client: The Ferguson Group on behalf of the City of Ranson, WV. 

Registrant name: The Advocacy Group; 
Client: University of Central Florida. 

Registrant name: The Brightup Group LLC; 
Client: Association of Nutrition & Foodservice Professionals (FKA-
Dietary Managers Assn). 

Registrant name: The Ferguson Group, LLC; 
Client: Climate Communities. 

Registrant name: The Majority Group, LLC; 
Client: NumbersUSA. 

Registrant name: The Nickles Group, LLC; 
Client: American Society of Anesthesiologists. 

Registrant name: The Nickles Group, LLC; 
Client: Exxon Mobil Corporation. 

Registrant name: The Normandy Group, LLC; 
Client: American Systems Corporation. 

Registrant name: THE OB-C Group, LLC; 
Client: Eli Lilly. 

Registrant name: The Smith-Free Group; 
Client: Ingram Barge Company. 

Registrant name: The University of Tennessee; 
Client: The University of Tennessee. 

Registrant name: Twenty-First Century Group, Inc. 
Client: Verizon. 

Registrant name: U.S. Apple Association; 
Client: U.S. Apple Association. 

Registrant name: Union Square Strategic LLP; 
Client: American Academy of Otolaryngology-Head and Neck Surgery. 

Registrant name: University of Notre Dame; 
Client: University of Notre Dame. 

Registrant name: Van Ness Feldman, LLP; 
Client: PacifiCorp. 

Registrant name: Van Scoyoc Associates; 
Client: New York University Langone Medical Center. 

Registrant name: Van Scoyoc Associates; 
Client: Morgan State University Foundation. 

Registrant name: Venable LLP; 
Client: Association of Food and Dairy Retailers, Wholesalers and 
Manufacturers. 

Registrant name: Venn Strategies, LLC; 
Client: Campaign to End Obesity Action Fund. 

Registrant name: Water Strategies, LLC; 
Client: Diamond Plastic Corporation. 

Registrant name: Westinghouse Electric Company; 
Client: Westinghouse Electric Company. 

Registrant name: Williams & Jensen, PLLC. 
Client: CME Group. 

Registrant name: Williams & Jensen, PLLC. 
Client: TE Connectivity, Inc. 

Registrant name: Williams & Jensen, PLLC. 
Client: Takeda Pharmaceuticals America, Inc. 

Registrant name: Williams & Jensen, PLLC; 
Client: AK Steel. 

Source: Lobbying disclosure database of the Clerk of the House of 
Representatives for the third and fourth quarters of 2012 and the 
first and second quarters of 2013. 

[End of table] 

[End of section] 

Appendix III: List of Sampled Lobbying Contribution Reports with and 
without Contributions Listed: 

See table 4 for a list of the lobbyists and lobbying firms from our 
random sample of lobbying contribution reports with contributions. See 
table 5 for a list of the lobbyists and lobbying firms from our random 
sample of lobbying contribution reports without contributions. 

Table 4: Lobbyists and Lobbying Firms in Sample of Lobbying 
Contribution Reports with Contributions Listed, Filed Year-End 2012 
and Midyear 2013: 

Lobbyist or lobbying firm: Aircraft Owners & Pilots Association; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Airports Council International --North 
America; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Alan Elias; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Amy Andryszak; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Arthur Cameron. Sr; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Benjamin Palumbo; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: BP America, Inc; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Brendan Williams; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Brooks Brunson; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Camille Donald; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Capella University; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Charles Nuckolls; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Christopher Heinz; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: CompTIA (Computing Technology Industry 
Association); 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Conor Yunits; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Corley Consulting, LLC; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: David Thompson; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: De'ana Dow; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Discover Financial Services; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Frank Vitello; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Frankie Trull; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Gary Carpentier; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Glen Overton; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Gray & Oscar, LLC (Formerly Bob Gray, LLC); 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Heather Strawn; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Henry Bonilla; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Hobbs Straus Dean & Walker, LLP; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Independent Insurance Agents & Brokers of 
America; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: J. Steven Judge; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: James Massie; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: James Nichols; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Jayne Chambers; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Jennifer Luray; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: John Albertine; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: John Gallagher; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: John Grzebien; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: John Hollay; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: John Sasso; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Jonathan Niedzielski; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Josephine Cooper; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Julie Pawelczyk; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Justin Daly; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Katherine Cullen; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Kathryn Fulton; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Keybank; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Kimberly Dean; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Lawrence Markley; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Mark Holman; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Martin Bayr; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Mary Kenkel; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Mary Savary Taylor; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: McKesson Corporation And Its Affiliate U.S. 
Oncology (Formerly McKesson Corp.); 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Michael Nilsson; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Michele Ballantyne; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Milam Mabry; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Monica Healy; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Mr. James Desmond; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: National Cannabis Industry Association; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: National Funeral Directors Assn; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Peter Begans; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Quadripoint Strategies LLC; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Railway Supply Institute, Inc. 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Robert Neal; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Robyn Lippert; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Ryan Thompson; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Scott Eckart; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Scott Lively; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Sean Richardson; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Society of American Florists; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Susan Bodine; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Susan Neely; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: TECO Energy, Inc. 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Terry Muilenburg; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Thomas Danjczek; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Timothy McGivern; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: VCA -Vision Council of America; 
The Vision Council; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Wayne Smith; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: William Behrens; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Xerox Corporation; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Yahoo! Inc; 
Reporting period: Midyear 2013. 

Source: Lobbying contributions database of the Clerk of the House of 
Representatives, year-end 2012 and midyear 2013 reports. 

[End of table] 

Table 5: Lobbyists and Lobbying Firms in Sample of Lobbying 
Contribution Reports with No Contributions Listed, Filed Year-End 2012 
and Midyear 2013: 

Lobbyist or lobbying firm: 38 North Solutions, LLC; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Allan Adler; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Amelia Consulting Group, LLC; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: American Academy of Actuaries; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: American College of Gastroenterology; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Andrew McNary; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Anna Roberts; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Brian Gantman; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Business Council for Sustainable Energy; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Caroline Cooper; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Carrie Johnson; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Cathy Dewitt; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Charles O'Brien; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Chris Townsend; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Cord Sterling; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Craig Saperstein; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Curators of The University of Missouri; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Daniel Gans; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Daniel Hartnett; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: David Roberts; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Diana Felner; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Edward Wender; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Eileen Sottile; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Elizabeth Fiveash; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Elizabeth Kucinich; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Elizabeth Lawson; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Emily Sass; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: English First, Inc; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Fresh Produce Association of the Americas; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Gerald Hughes; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Haake and Associates; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Hank Webster; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Immigration Equality Action Fund; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: James Backlin; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: James P. Keese; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Jen Kaleta; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Jennifer Bendall; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Jennifer Cervantes; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Jerry Hadenfeldt; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: John Bartimole; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Julie Halbert Wright; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Julie Kirchner; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Kate Petersen; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Kevin Schmidt; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Kristina Butts; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Laurie Bertenthal; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Leslie Griffin; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Lisa Lamkins; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Lorren Walker; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Louis Sheldon; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Lufthansa German Airlines; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Lynn Henselman; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Mary Rosado; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Matthew Coffron; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Meredith Mull; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Meredith Nethercutt; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Michael Roman; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Michael Willis; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Mike Rock; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Morgan Brown; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Mr. Charles Monfort; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Mr. John Troy; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Mr. Richard Hirn; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Mr. Russell Wapensky; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Native American Contractors Association; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: New York State Society Of CPAs; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Rebecca Benn; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Rick Freer; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Ryan Thomas; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Selig Merber; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Shannon Kelly; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Sohini Gupta; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Stiefel & Jones Consulting, LLC; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Susan Johnson; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: The Tomhave Group, Inc. 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: The Winter Group; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: Timothy Dietz; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Todd Davis; 
Reporting period: Midyear 2013. 

Lobbyist or lobbying firm: Trish Jones; 
Reporting period: Year-end 2012. 

Lobbyist or lobbying firm: William Shute; 
Reporting period: Midyear 2013. 

Source: Lobbying contributions database of the Clerk of the House of 
Representatives, year-end 2012 and midyear 2013 reports. 

[End of table] 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Seto J. Bagdoyan, (202) 512-4749 or bagdoyans@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Bill Reinsberg, Assistant 
Director; Shirley Jones, Assistant General Counsel; Crystal Bernard; 
Stuart Kaufman; Lois Hanshaw; Sharon Miller; Anna Maria Ortiz; Anthony 
Patterson; Robert Robinson; Stewart Small; and Katherine Wulff made 
key contributions to this report. 

Assisting with lobbyist file reviews were Vida Awumey and Patricia 
Norris. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 110-81, 121 Stat. 735 (Sept. 14, 2007). Pub. L. No. 
104-65, 109 Stat. 691 (Dec. 19, 1995) codified at 2 U.S.C. §§ 1601-
1614. 

[2] 2 U.S.C. § 1614. 

[3] We originally selected 104 reports for review. After notification 
of our review, one lobbyist amended an LD-2 report to no lobbying 
activity and the case was excluded from the scope of our review. 
Another lobbying firm appeared to have gone out of business and we 
treated this case as a nonrespondent for the purposes of our review. 

[4] Our sample is only one of a large number of samples that we might 
have drawn. Because each sample could have provided different 
estimates, we express our confidence in the precision of our estimate 
as a 95 percent confidence interval. This interval would contain the 
actual population value for 95 percent of the samples we could have 
drawn. Unless otherwise stated, all percentage estimates have a 
maximum 95 percent confidence interval of within 11 percentage points 
or less of the estimate. 

[5] Although we contacted each lobbyist or lobbying firm in our 
sample, we did not always meet with the lobbyists identified as the 
point of contact or the actual lobbyists. We met with individuals 
representing lobbyists or lobbying firms. For the purposes of this 
review, we use the term lobbyists to refer to lobbyists, lobbying 
firms, and individuals representing the lobbyists that were present 
during the review. 

[6] The LDA defines a covered executive branch official as the 
President, Vice President, an officer or employee, or any other 
individual functioning in the capacity of such an officer or employee 
of the Executive Office of the President; an officer or employee 
serving in levels I through V of the Executive Schedule; members of 
the uniformed services whose pay grade is at or above O-7; and any 
officer or employee serving in a position of a confidential, policy-
determining, policy-making or policy-advocating character who is 
excepted from competitive service as determined by the Office of 
Personnel Management (commonly called Schedule C employees). The LDA 
defines a covered legislative branch official as a member of Congress, 
an elected officer of either house of Congress, or any employee or any 
other individual functioning in the capacity of an employee of a 
member, a committee of either house of Congress, the leadership staff 
of either house of Congress, a joint committee of Congress, or a 
working group or caucus organized to provide legislative services or 
other assistance to members. 2 U.S.C. § 1602(3), (4). Lobbying 
activities include not only direct lobbying contacts but also efforts 
in support of such contacts, such as preparation and planning 
activities, research, and other background work that is intended for 
use in contacts. 2 U.S.C. § 1602(10). 

[7] 2 U.S.C. § 1602(9). 

[8] Organizations employing in-house lobbyists file only one 
registration. An organization is exempt from filing if total expenses 
in connection with lobbying activities are not expected to exceed 
$12,500. Amounts are adjusted for inflation and published in LDA 
guidance. 

[9] Lobbyists are expected to provide a good faith estimate on the LD-
2 report of income and expenses reported rounded to the nearest 
$10,000. Our estimate of the number of reports with rounding errors 
includes reports that disclosed the exact amount of income from or 
expenditures on lobbying activities, but failed to round to the 
nearest $10,000 as required. 

[10] The sample size of LD-2 reports that reported contact with 
federal agencies is smaller than the 102 LD-2 reports that were 
included in our sample and used to generate percentage sums for other 
selected reporting elements. The size is also too small to generate 
estimated percentages or to make comparisons across the reviews. 

[11] We treated one respondent as a nonrespondent because the itemized 
contributions in the FEC database were not available at the time of 
our review to determine whether political contributions were omitted 
on the respondent's LD-203 report. 

[12] We did not estimate the percentage of other non-FEC political 
contributions that were omitted because they tend to constitute a 
small minority of all listed contributions and cannot be verified 
against an external data source. 

[13] The number of different lobbying firms total 92 and is less than 
our sample of 102 reports because some lobbying firms had more than 
one LD-2 report included in our sample. We calculated our responses 
based on the number of different lobbying firms that we contacted 
rather than the number of interviews. Prior to our calculations, we 
removed the duplicate lobbying firms based on the most recent date of 
their responses. For those cases with the same response date, we kept 
the cases with the smallest assigned case identification number. 

[14] Four of the 92 different lobbying firms did not respond to the 
question about ease of compliance with reporting requirements. 
Although the percentage estimates from our sample of LD-2 reports are 
generalizable to all LD-2 reports, results from the analysis of 
lobbying firm opinions are not generalizable. Our sample was designed 
to develop population estimates of the accuracy of information on LD-2 
reports and was not designed to estimate lobbyist opinions. 

[15] Some lobbying firms may not have responded to all of the 
questions about their ease of understanding the terms associated with 
LD-2 reporting requirements. Therefore, the number of responses may 
not be consistent with the number of different lobbying firms in 
figures 11 through 15. 

[16] GAO, Lobbying Disclosure: Observations on Lobbyists' Compliance 
with New Disclosure Requirements, [hyperlink, 
http://www.gao.gov/products/GAO-08-1099] (Washington, D.C.: Sept. 30, 
2008). 

[17] GAO, 2012 Lobbying Disclosure: Observations on Lobbyists' 
Compliance with Disclosure Requirements, [hyperlink, 
http://www.gao.gov/products/GAO-13-437] (Washington, D.C.: Apr.1, 
2013). 

[18] LD-2 activity reports with "no lobbying issue activity" and 
reports with less than $5,000 in reported income or expenses are 
filtered out because they do not contain verifiable information on 
income, expenses, or activity. 

[19] We adjusted for three comparisons to account for the three 
pairwise tests for each item examined. 

[20] One midyear 2013 contributions case was not available in the FEC 
data because FEC had not processed individual contributions. The case 
was treated as a nonrespondent for the purposes of data analysis, and 
the weights for mid-year contributions reports was adjusted using an 
effective sample of 39 rather than 40 cases as originally sampled for 
159 reports. 

[21] We used a Bonferroni adjustment to adjust for three comparisons 
to account for the three pairwise tests for each item examined. 

[End of section] 

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