Pursuant to a congressional request, GAO provided comments on S. 1405, the Federal Neutrality Act of 1983, which would provide criminal penalties for organizations which use Federal funds to finance lobbying activities. GAO stated that the penalties provided by S. 1405 are unduly harsh and raise serious constitutional questions. GAO prefers that lobbying costs be accounted for in the same manner as other unallowable costs such as advertising and fund raising. Consequently, GAO did not recommend enactment of the bill.