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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

March 2012: 

2011 Lobbying Disclosure: 

Observations on Lobbyists' Compliance with Disclosure Requirements: 

GAO-12-492: 

GAO Highlights: 

Highlights of GAO-12-492, a report to congressional committees. 

Why GAO Did This Study: 

HLOGA requires lobbyists to file quarterly lobbying disclosure reports 
and semiannual reports on certain political contributions. HLOGA also 
requires that GAO annually (1) determine the extent to which lobbyists 
can demonstrate compliance with disclosure requirements, (2) identify 
any challenges to compliance that lobbyists report, and (3) describe 
the resources and authorities available to the Office and the efforts 
the Office has made to improve its enforcement of the LDA. This is GAO’
s fifth report under the mandate. GAO reviewed a stratified random 
sample of 100 quarterly LD-2 reports filed for the third and fourth 
quarters of calendar year 2010 and the first and second quarters of 
calendar year 2011. GAO also reviewed two random samples totaling 160 
LD-203 reports from year-end 2010 and midyear 2011. This methodology 
allowed GAO to generalize to the population of 51,792 disclosure 
reports with $5,000 or more in lobbying activity and 32,301 reports of 
federal political campaign contributions. GAO also met with officials 
from the Office regarding 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. 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 on the draft of this report. 

What GAO Found: 

Most lobbyists were able to provide documentation to demonstrate 
compliance with disclosure requirements. This finding is similar to GAO’
s results from prior reviews. There are no specific requirements for 
lobbyists to create or maintain documentation related to disclosure 
reports they file under the Lobbying Disclosure Act of 1995 as amended 
(LDA). Nonetheless, and similar to last year’s results, for two key 
elements of the reports (income and expenses), GAO estimates that 
lobbyists could provide documentation to support approximately 93 
percent of the disclosure reports for the third and fourth quarters of 
2010 and the first and second quarters of 2011. According to 
documentation lobbyists provided for income and expenses, GAO 
estimates that the amounts disclosed were properly reported and 
supported for 63 percent of the quarterly lobbying disclosure (LD-2) 
reports. For lobbyists and lobbying firms listed on the LD-2 report, 
an estimated 86 percent filed year-end 2010 or midyear 2011 reports of 
federal political campaign contributions (LD-203) reports as required. 
For LD-203 political contributions reports, GAO estimates that a 
minimum of 4 percent of all LD-203 reports omitted one or more 
reportable political contributions that were documented in the Federal 
Election Commission database. Fewer lobbyists—-17 this year versus 21 
in the prior year-—stated that they planned to amend their LD-2 report 
following GAO’s reviews to make correction on one or more data 
elements. As of March 2012, 9 of 17 amended their disclosure reports. 

 

Lobbyists are required to file LD-2 reports for the quarter in which 
they first register. The majority of lobbyists who newly registered 
with the Secretary of the Senate and Clerk of the House of 
Representatives in the third and fourth quarters of 2010 and first and 
second quarters of 2011 filed required disclosure reports for that 
period. GAO could identify corresponding reports on file for lobbying 
activity for 88 percent of registrants. 

The majority of lobbyists felt that the terms associated with 
disclosure reporting were clear and understandable and the 
requirements were easy to meet. However, a few lobbyists reported 
challenges in complying with the LDA. 

The U.S. Attorney’s Office for the District of Columbia (the Office) 
stated that it has resources and authorities to pursue civil or 
criminal cases for noncompliance with LDA requirements. To enhance 
enforcement efforts and support the 17 staff who have been working on 
compliance issues on a part-time basis, the Office hired one contract 
staff member in September 2010 who works full-time on lobbying 
compliance issues. The Office has primarily focused on contacting 
lobbyists who have potentially violated the LDA by not filing 
disclosure reports. In November 2011, the Office settled its first 
enforcement case since the enactment of the Honest Leadership and Open 
Government Act of 2007 (HLOGA), and reached a $45,000 settlement with 
a lobbying firm that had been referred to the Office repeatedly for 
failure to file disclosure reports. More than half of the 561 
lobbyists who were contacted for noncompliance with LD-2 requirements 
for calendar years 2009 and 2010 are now compliant. Approximately 
1,081 lobbyists were referred by the Secretary of the Senate for 
noncompliance with LD-203 requirements for calendar year 2009. 

View [hyperlink, http://www.gao.gov/products/GAO-12-492]. For more 
information, contact J. Christopher Mihm at (202) 512-6806 or 
mihmj@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Documentation to Support Some LD-2 Report Elements Varied, but Most 
Newly Registered Lobbyists Met Disclosure Reporting Requirements: 

While Most Lobbying Firms Reported That the Disclosure Requirements 
Were Easy or Somewhat Easy to Meet, a Few Lobbyists Reported 
Challenges in Complying with the Act: 

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

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 
Contributions and No Contributions Listed: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Reasons Lobbyists in Our Sample Cited for Not Having 
Documentation for Some Elements of Their LD-2 Reports: 

Table 2: Feedback from Lobbyists in Our Sample of Reports Who Rated 
the Lobbying Terms as Either "Not Clear and Understandable" or 
"Somewhat Clear and Understandable": 

Table 3: Number of LD-2 Referrals the U.S. Attorney's Office Received 
from the Secretary of the Senate and the Clerk of the House: 

Table 4: Status of LDA Enforcement Actions for LD-203 Referrals for 
the 2009 Filing Period (as of February 22, 2012): 

Table 5: Names of Registrants and Clients Selected in Random Sample of 
Lobbying Disclosure Reports Filed in the Third and Fourth Quarters of 
2010 and the First and Second Quarters of 2011: 

Table 6: Lobbyists and Lobbying Firms in Random Sample of Lobbying 
Contribution Reports with Contributions Listed, Filed Year-end 2010 
and Midyear 2011: 

Table 7: Lobbyists and Lobbying Firms in Random Sample of Lobbying 
Contribution Reports with No Contributions Listed, Filed Year-end 2010 
and Midyear 2011: 

Figures: 

Figure 1: Documentation Lobbyists Provided to Support Selected 
Elements of LD-2 Reports: 

Figure 2: Rating of Terms Associated with LD-2 Reporting for Lobbyists 
in Interviews: 

Figure 3: U.S. Attorney's Office Process for Addressing Referrals 
Received from the Secretary of the Senate and Clerk of the House: 

Figure 4: Status of LDA Enforcement Actions for LD-2 Reporting (as of 
February 22, 2012): 

Abbreviations: 

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

DOJ: Department of Justice: 

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: 

United States Government Accountability Office: 
Washington, DC 20548: 

March 30, 2012: 

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)[Footnote 
1] amended the Lobbying Disclosure Act of 1995 (LDA)[Footnote 2] to 
require lobbyists to file quarterly lobbying disclosure reports and 
semiannual reports on certain political contributions. HLOGA also 
increased civil penalties and added criminal penalties for failure to 
comply with LDA requirements. The mandate requires GAO to audit the 
extent of lobbyists’ compliance with the requirements of the LDA by 
reviewing publicly available lobbying registrations and a random 
sampling of reports filed during each calendar year.[Footnote 3] 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 fifth 
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 LDA, as 
amended, by providing documentation to support information contained 
in reports filed under the LDA, (2) identify any challenges that 
lobbyists report to compliance and potential improvements, and (3) 
describe the resources and authorities available to the Office in its 
role in enforcing compliance with the LDA and the efforts the Office 
has made to improve its enforcement of the LDA. 

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

To determine the extent to which lobbyists can demonstrate compliance, 
we selected a stratified random sample of 100 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 2010 and 
the first and second quarters of calendar year 2011.[Footnote 4] We 
selected the randomly sampled reports from the publicly downloadable 
database maintained by the Clerk of the House of Representatives 
(Clerk of the House). Appendix II contains a list of lobbyists 
(registrants and clients) who we randomly selected for our review of 
LD-2 reports. This methodology allows us to generalize to the 
population of these LD-2 reports. We then contacted each lobbyist or 
lobbying firm[Footnote 5] in our sample and asked them to provide 
supporting 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. 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. All 
lobbyists in our sample responded to our requests for supporting 
documentation. 

To determine whether lobbyists’ reported their federal political 
contributions as required by the LDA, we analyzed stratified random 
samples of year-end 2010 and midyear 2011 semiannual federal political 
contributions (LD-203) reports. The samples contain 80 LD-203 reports 
that have contributions listed and 80 LD-203 reports that list no 
contributions. 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 the contributions identified in our sample to 
determine whether all contributions reported in the FEC database were 
also reported on the LD-203s, 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 (commonly referred to as LD-1s) filed in the third 
and fourth quarters of 2010 and the first and second quarters of 2011 
to the corresponding LD-2 reports on file with the Clerk of the House.
To identify challenges and potential improvements to compliance, we 
used structured interviews to obtain views from lobbyists included in 
our sample of reports. 

To describe the resources and authorities available to the Office and 
efforts the Office has made to improve its enforcement of the LDA, we 
interviewed officials from the Office and obtained information on the 
level of staffing and resources dedicated to the enforcement of the 
LDA, and the practices they have established to enforce the LDA. The 
Office provided us with information on the processes used to enforce 
compliance with the LDA and reports from the tracking system on the 
number and status of referrals. 

The mandate does not require GAO 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 contributions represented the 
full extent of lobbying activities that took place. 

We conducted this performance audit from June 2011 to March 2012 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 
(as opposed to separately with the Secretary of the Senate and the 
Clerk of the House as was done prior to HLOGA). 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 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 the registration and 
reporting requirements of the LDA and develop common standards, rules, 
and procedures for compliance with the LDA. The Secretary and the 
Clerk review the guidance semiannually. The guidance was last revised 
and published in December 2011. The guidance provides definitions of 
terms in the LDA, elaborates on the registration and reporting 
requirements, includes specific examples of different scenarios, and 
provides explanations of why certain scenarios prompt or do not prompt 
disclosure under the LDA. In meetings with the Secretary of the Senate 
and Clerk of the House, they stated that they consider information we 
report on lobbying disclosure compliance when they periodically update 
the guidance. 

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[Footnote 6] represent at least 20 percent of the 
time that he or she spends on behalf of the client during the quarter. 
[Footnote 7] 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 8] 

Lobbying firms are required to file a registration with the Secretary 
of the Senate and the Clerk of the House for each client if the firms 
receive or expect to receive over $3,000 in income or $11,500 in 
incurred expenses from that client for lobbying activities.[Footnote 
9] Lobbyists are also required to submit a quarterly report, also 
known as an LD-2 report, for each registration filed. The registration 
and subsequent LD-2 reports contain the following elements, if 
applicable: 

* the name of the organization, lobbying firm, or self-employed 
individual that is lobbying on that client's behalf; 

* a 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 "covered officials" in the previous 20 
years;[Footnote 10] 

* the name of and further information about the client, including a 
general description of its business or activities; 

* information on the specific lobbying issue areas and corresponding 
general issue codes used to describe lobbying activities; 

* any foreign entities that have an interest in the client; 

* whether the client is a state or local government; 

* information on which federal agencies and House(s) of Congress the 
lobbyist contacted on behalf of the client during the reporting period; 

* the amount of income related to lobbying activities received from 
the client (or expenses for organizations with in-house lobbyists) 
during the quarter rounded to the nearest $10,000; and: 

* a list of constituent organizations that contribute more than $5,000 
for lobbying in a quarter and actively participate in planning, 
supervising, or controlling lobbying activities, if the client is a 
coalition or association. 

The LDA, as amended, also requires lobbyists to report certain 
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 reports. 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 the Senate and House 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 and the Clerk of the House, along with 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, requesting that the lobbyists file reports or 
correct reported information. 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. 

Documentation to Support Some LD-2 Report Elements Varied, but Most 
Newly Registered Lobbyists Met Disclosure Reporting Requirements: 

Most Lobbyists Provided Documentation for LD-2 Reports, but 
Documentation For Some Report Elements Did Not Match Their Disclosure 
Reports: 

As in our prior reviews, most lobbyists reporting $5,000 or more in 
income or expenses were able to provide documentation to varying 
degrees for the reporting elements in their disclosure reports. 
[Footnote 11] Lobbyists for an estimated 93 percent of LD-2 reports 
were able to provide documentation to support the income and expenses 
reported for the third and fourth quarters of 2010 and the first and 
second quarters of 2011.[Footnote 12] Last year, we reported that 
lobbyists for an estimated 97 percent of LD-2 reports were able to 
provide documentation for income and expenses for the quarters under 
review.[Footnote 13] The most common forms of documentation provided 
included invoices for income and payroll records for expenses. 
According to the documentation lobbyists provided for income and 
expenses, we estimate that the amount disclosed was properly rounded 
to the nearest $10,000 and supported for 63 percent (59 of 93) of the 
LD-2 reports; differed by at least $10,000 from the reported amount in 
16 percent (15 of 93) of LD-2 reports; and had rounding errors in 21 
percent (19 of 93) of LD-2 reports.[Footnote 14] 

Figure 1 illustrates the extent to which lobbyists were able to 
provide documentation to support selected elements on the LD-2 reports. 

Figure 1: Documentation Lobbyists Provided to Support Selected 
Elements of LD-2 Reports: 

[Refer to PDF for image: vertical bar graph] 

Estimated percentage of reports[A]: 

Lobbied the House: 
Documentation to support: 81%; 
Some documentation to support[B]: 0%; 
No documentation to support: 19%. 

Lobbied the Senate: 
Documentation to support: 78%; 
Some documentation to support[B]: 0%; 
No documentation to support: 22%. 

Issue codes: 
Documentation to support: 79%; 
Some documentation to support[B]: 7%; 
No documentation to support: 14%. 

Individuals acting as lobbyists: 
Documentation to support: 68%; 
Some documentation to support[B]: 77%; 
No documentation to support: 15%. 

Source: GAO. 

[A] Percentage estimates in the figure have a 95 percent confidence 
interval of plus or minus 10 percentage points or less of the 
estimates. 

[B] Lobbyists having some documentation to support issue codes and the 
names of individuals acting as lobbyists refers to the lobbyists being 
able to provide documentation for only some of the total number of 
issue codes or lobbyists reported. 

[End of figure] 

Of the 100 LD-2 reports in our sample, 47 disclosed lobbying 
activities at executive branch agencies, with lobbyists for 19 of 
these reports providing documentation to support lobbying activities 
at all agencies listed. 

Table 1 lists the common reasons why lobbyists we interviewed said 
they did not have documentation for some of the elements of their LD-2 
reports. 

Table 1: Reasons Lobbyists in Our Sample Cited for Not Having 
Documentation for Some Elements of Their LD-2 Reports: 

LD-2 report element: Lobbied the Houses of Congress; 
Reasons for not having documentation: Several lobbyists told us they 
did not keep documentation of their lobbying contacts with the House 
and the Senate. Additionally several lobbyists told us they 
overreported contact with the House and Senate staff and that the 
contact did not occur during the quarter under review. 

LD-2 report element: Lobbied executive branch agencies; 
Reasons for not having documentation: Several lobbyists told us they 
did not keep documentation of their contacts with executive branch 
agencies. Several lobbyists told us they overreported their contact 
with the agencies and that lobbying activity with the agencies listed 
did not occur during the quarter under review. 

LD-2 report element: Individuals acting as lobbyists; 
Reasons for not having documentation: As in last year's report, 
several lobbyists told us they listed all lobbyists on the LD-2 
reports even if they did not lobby on behalf of the client during the 
quarter under review. Several lobbyists stated that they might have 
lobbied on behalf of the client in a previous quarter but not the 
quarter under review. 

LD-2 report element: Covered positions; 
Reasons for not having documentation: Several lobbyists told us it was 
oversight that they did not disclose the covered positions and that 
they planned to amend their LD-2 reports. Confusion still exists among 
some lobbyists as to whether congressional interns were considered 
covered positions and therefore need to be disclosed.[A] 

Source: GAO. 

[A] In our last report, officials from the Offices of the Secretary of 
the Senate and Clerk of the House confirmed that internships are 
considered covered official positions and therefore should be 
disclosed. 

[End of table] 

Most Lobbyists Properly Disclosed Covered Positions as Required: 

The LDA requires a lobbyist to disclose previously held covered 
positions when first registering as a lobbyist for a new client, 
either on the LD-1 or on the LD-2 quarterly filing when added as a new 
lobbyist. Based on our analysis, we estimate that a minimum of 11 
percent of all LD-2 reports did not properly disclose one or more 
previously held covered positions.[Footnote 15] This finding is 
consistent with last year's report.[Footnote 16] Lobbyists for an 
estimated 86 percent of LD-2 reports filed year-end 2010 or midyear 
2011 LD-203 contribution reports for all of the lobbyists and lobbying 
firms listed on the report as required.[Footnote 17] All individual 
lobbyists and lobbying firms reporting specific 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. 

Fewer Lobbying Firms Indicated That They Planned To Amend Their LD-2 
Reports as a Result of GAO'S Review: 

Compared to our last review, fewer lobbying firms indicated that they 
plan to amend their LD-2 reports as a result of our review. This year, 
lobbying firms for 17 of the LD-2 reports in our sample indicated that 
they planned to amend their LD-2 reports as a result of our review. 
Last year, 21 lobbying firms indicated they planned to amend their LD-
2 reports. As of March 2012, 9 lobbying firms have amended their LD-2 
reports (compared to 12 lobbying firms last year). 

Specific reasons for filing amendments included the following: 

* Decreasing reported income from $60,000 to $30,000: 

* Increasing the reported income from $20,000 to $30,000: 

* Changing the client's name on the LD-2 report: 

* Adding additional information about the specific issues lobbied: 

* Adding contact with the House: 

* Removing reported contact with the Senate: 

* Adding a federal agency: 

* Adding covered positions: 

* Adding a lobbyist: 

In addition, lobbying firms filed amendments for 3 (compared to 8 
reports last year)[Footnote 18] of the LD-2 reports in our sample 
after being notified that their LD-2 reports were selected as part of 
our random sample but prior to our review. 

Some LD-203 Contribution Reports Omitted Political Contributions 
Listed in the FEC Database: 

We estimate that overall, a minimum of 4 percent of reports failed to 
disclose one or more contributions.[Footnote 19] 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-2 reports in our sample. The sample of LD-203 reports we 
reviewed contained 80 reports with political contributions and 80 
reports without political contributions. Of the 80 LD-203 reports 
sampled with contributions reported, 12 reports omitted one or more 
contributions. Of the 80 LD-203 reports sampled with no contributions 
reported, 2 reports failed to disclose contributions listed in the FEC 
database. 

Most Newly Registered Lobbyists Filed Disclosure Reports as Required: 

Of the 3,802 new registrations we identified from fiscal year 2011, we 
were able to match 3,357 reports filed in the first quarter in which 
they were registered. This is a match rate of 88 percent of 
registrations, which is consistent with our prior reviews.[Footnote 
20] To determine whether new registrants were meeting the requirement 
to file, we matched newly filed registrations in the third and fourth 
quarters of 2010 and the first and second quarters of 2011 from the 
House Lobbyist Disclosure Database to their corresponding quarterly 
disclosure reports using an electronic matching algorithm that allows 
for misspelling and other minor inconsistencies between the 
registrations and reports. 

While Most Lobbying Firms Reported That the Disclosure Requirements 
Were Easy or Somewhat Easy to Meet, a Few Lobbyists Reported 
Challenges in Complying with the Act: 

Disclosure Requirements Were Easy or Somewhat Easy to Meet for Most 
Lobbying Firms: 

As part of our review, 90 different lobbying firms were included in 
our sample.[Footnote 21] Of the 90 lobbying firms, 86 reported that 
the disclosure requirements were "easy" or "somewhat easy" to meet. 
[Footnote 22] Of the 86 lobbying firms in our sample of LD-2 reports 
that said the requirements were "easy" or "somewhat easy" to meet, 61 
lobbyists indicated that the requirements were "easy" and 25 indicated 
that the requirements were "somewhat easy" to meet. Compared to last 
year, fewer lobbyists told us that they found the quarterly reporting 
requirement difficult to meet. This year, 5 lobbyists we interviewed 
(compared to 10 lobbyists last year)[Footnote 23] said that it was 
difficult to file reports quarterly or difficult to meet the 20 day 
filing deadline. The deadline for filing disclosure reports is 20 days 
after each reporting period, or the first business day after the 20th 
day if the 20th day is not a business day.[Footnote 24] 

A Few Lobbyists Cited Challenges in Complying With The Act: 

While most lobbyists we interviewed told us they thought that the 
terms associated with LD-2 reporting requirements were clear, a few 
lobbyists highlighted areas of confusion in applying some aspects of 
LDA reporting requirements. This is consistent with our prior report. 
We asked the lobbyists we interviewed to rate various terms associated 
with LD-2 reporting as being "clear and understandable," "somewhat 
clear and understandable," or, "not clear and understandable." Figure 
2 shows the terms associated with LD-2 reporting that the lobbyists 
were asked to rate and how they responded to each term. Table 2 
summarizes the feedback we obtained from the lobbying firms in our 
sample of reports that rated the lobbying terms as either "not clear 
and understandable" or "somewhat clear and understandable." 

Figure 2: Rating of Terms Associated with LD-2 Reporting for Lobbyists 
in Interviews: 

[Refer to PDF for image: vertical bar graph] 

Number of lobbying firms: 

Lobbying definitions: 
Clear and understandable: 64; 
Somewhat clear and understandable: 22; 
Not clear and understandable: 4. 

Lobbying activities: 
Clear and understandable: 59; 
Somewhat clear and understandable: 27; 
Not clear and understandable: 4. 

Issue codes: 
Clear and understandable: 67; 
Somewhat clear and understandable: 20; 
Not clear and understandable: 3. 

Covered positions: 
Clear and understandable: 67; 
Somewhat clear and understandable: 19; 
Not clear and understandable: 4. 

Terminating lobbyist: 
Clear and understandable: 74; 
Somewhat clear and understandable: 12; 
Not clear and understandable: 4. 

Source: GAO. 

[End of figure] 

Table 2: Feedback from Lobbyists in Our Sample of Reports Who Rated 
the Lobbying Terms as Either "Not Clear and Understandable" or 
"Somewhat Clear and Understandable": 

Associated terms: Lobbying definitions; 
Feedback about LD-2 terminology and challenges to reporting: Some 
lobbyists stated that lobbying definitions were unclear and that it 
was difficult to determine which activities met the definition of 
lobbying activity. A few lobbyists said that it was difficult to 
understand the definition of lobbying activities or determine whether 
20 percent of their time over the three-month period was spent on 
lobbying activities. 

Associated terms: Lobbying activities; 
Feedback about LD-2 terminology and challenges to reporting: Some 
lobbyists still expressed concern about differentiating between 
lobbying activities versus nonlobbying activities. For example, some 
lobbyists said they were not sure when research and support activities 
become lobbying activities and therefore needed to be disclosed.[A] 

Associated terms: Issue codes; 
Feedback about LD-2 terminology and challenges to reporting: Some 
lobbyists said additional clarity would be helpful to determine the 
most appropriate issue codes to use. For example, lobbyists mentioned 
confusion with using an appropriation code versus the specific issue 
area code. 

Associated terms: Covered positions; 
Feedback about LD-2 terminology and challenges to reporting: Some 
lobbyists continued to express concern about knowing when a federal 
official they met with held a covered position. Some lobbyists said 
they might overreport their meetings because they are unclear whether 
the person they met with held a covered position. 

Associated terms: Terminating lobbyists; 
Feedback about LD-2 terminology and challenges to reporting: Few 
lobbyists expressed concerns about when to terminate a lobbyist who 
was no longer lobbying on behalf of the client. 

Source: GAO. 

[A] The LDA guidance provides examples of lobbying activities, which 
includes preparation or planning activities and research and 
background work that is expected to be used in contacting and 
coordinating the lobbying activities of others. 

[End of table] 

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

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

The Office stated that it has sufficient resources and authority to 
enforce compliance with LDA requirements, including imposing civil or 
criminal penalties for noncompliance. In a prior report, we 
recommended that the Office develop a structured approach for the 
tracking and recording of enforcement activities for lobbyists whom 
the Secretary of the Senate and the Clerk of the House identify as 
failing to comply with LDA requirements.[Footnote 25] As a result, the 
Office developed a system that allowed it to track when referrals are 
received, record reasons for referrals, record actions taken to 
resolve them, and assess the results of actions taken. The system has 
allowed the Office to take actions to achieve compliance with the LDA. 
The Office uses the summary reports to track progress and quickly 
identify lobbyists that continuously fail to comply. In addition, the 
Office hired one contract staff member in September 2010 to work on 
lobbying compliance issues on a full-time basis. This has enhanced the 
Office's ability to pursue enforcement actions by centralizing the 
process of checking and resolving referrals. The Office has 17 staff 
to assist with lobbying compliance issues on a part-time basis. 

To enforce LDA 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 that 
lobbyists comply with the law by promptly filing the appropriate 
disclosure documents. Not all referred lobbyists receive noncompliance 
letters because some of the lobbyists have terminated their 
registrations, or lobbyists may have complied by filing the report 
before the Office sent noncompliance letters. In addition to sending 
letters, the contractor sends e-mails and calls lobbyists to inform 
them of their need to comply with the LDA requirements. Figure 3 
describes the process and time frames of the Office's enforcement 
efforts. 

Figure 3: U.S. Attorney's Office Process for Addressing Referrals 
Received from the Secretary of the Senate and Clerk of the House: 

[Refer to PDF for image: illustration] 

Processing referrals into LDA database: 
Time: Within 1 week. 

U.S. Attorney's Office Civil Division staff receive referrals from the 
Clerk of the House and Secretary of Senate. The referrals are reviewed 
to ensure the registrant's name and address information is complete. 

The contractor enters referrals into the LDA database. 

Research: 
Time: Within 1 week. 

U.S. Attorney's Office Civil Division staff access House and Senate 
database to verify continued noncompliance. 
Registrant complies: The referral is closed; 
Registrant does not comply: continue. 
     
Actions taken to address noncompliance: 
Time: Within several years. 

The contractor sends a letter to the registrant within 3 months. 
                 
U.S. Attorney's Office Civil Division staff review responses from the 
registrant. 

The contractor updates the status of the referral in the LDA database 
using codes to identify whether the registrant is compliant: 
Compliant: Registrant filed disclosure report or terminated the 
registration after receiving the letter; 
Noncompliant: Registrant responded to the letter, but did not file the 
disclosure report; 
Pending: Registrant continues to actively lobby without filing a 
disclosure report; 
Suspense: Registrant is repeatedly referred for not filing disclosure 
reports, but does not show lobbying activity. 

The contractor and U.S. Attorney's Office Civil Division staff access 
House and Senate database again, 30-60 days after sending letters, to 
determine compliance. 
Registrant complies: The referral is closed; 
Registrant does not comply: continue. 
                
The contractor updates the codes and determines further action: 
Noncompliant: The contractor makes three additional attempts to 
contact noncompliant registrants; 
Pending: Registrants remain in this status until further action is 
taken by U.S. Attorney's Office or the registrant files the disclosure 
report or terminates; 
Suspense: U.S. Attorney's Office attorney will continue to monitor and 
determine whether the registrant actively lobbies in the future; 
U.S. Attorney's Office Civil Division staff discuss the status of 
referrals with House and Senate contacts to determine whether to 
continue enforcement actions, which includes considering legal 
actions, or dismissing certain referrals. 

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

[End of figure] 

Typically, 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. 
Office officials said that they could not set strict time frames or 
deadlines for closing out pending cases because of these varying 
circumstances. In addition, they stated that setting strict deadlines 
might encourage noncompliance if a lobbyist believes that a referral 
will close out on a certain date if he or she never responds. Although 
the Office is concerned with all noncompliance, it places a greater 
emphasis on pursuing lobbyists and registrants who continue to lobby 
and avoid filing required disclosure reports. A similar approach to 
the LD-2 enforcement process is being developed for tracking and 
reporting noncompliance with LD-203 reporting. 

Update on Enforcement For The 2009 and 2010 Reporting Periods: 

Since the enactment of HLOGA, both the Secretary of the Senate and the 
Clerk of the House have made quarterly referrals for noncompliance 
with the LD-2 requirements. Table 3 shows the number of referrals the 
Office received from both the Secretary and the Clerk for 
noncompliance with reports filed for the 2009 and 2010 reporting 
periods and the actions taken by the Office. 

Table 3: Number of LD-2 Referrals the U.S. Attorney's Office Received 
from the Secretary of the Senate and the Clerk of the House: 

Reporting period (calendar year): 2009; 
Number of referrals received[A]: 457; 
Number of noncompliance letters sent by the Office[B]: 320; 
Number of noncompliance phone calls made or e-mails sent by the 
Office: 0. 

Reporting period (calendar year): 2010; 
Number of referrals received[A]: 446; 
Number of noncompliance letters sent by the Office[B]: 193; 
Number of noncompliance phone calls made or e-mails sent by the 
Office: 48. 

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

[A] As of January 25, 2012. 

[B] As of February 22, 2012. 

[End of table] 

As of January 25, 2012, the Office has received 118 referrals from the 
Clerk of the House for the first and second quarter for the 2011 LD-2 
reporting period, but has not yet received any referrals from the 
Secretary of the Senate for the 2011 reporting period. 

As shown in figure 4, about 56 percent (312 of 561) of the lobbyists 
who received letters, phone calls, or e-mails from the Office for 
noncompliance for 2009 and 2010 LD-2 referrals have either filed 
reports or have terminated their registrations and are now considered 
compliant. Additionally, about 43 percent (243 of 561) are pending 
action because the Office did not receive a response from the lobbyist 
and plans to conduct additional research to determine if it can locate 
the lobbyist. The remaining 1 percent of (6 of 561) referrals did not 
require action because the lobbyist or client was no longer in 
business or the lobbyist was deceased. In addition, lobbyists were 
found to be compliant when the Office received the referral. This may 
occur when lobbyists have responded to the contact letters from the 
Secretary of the Senate and Clerk of the House after the Office has 
received the referrals. 

Figure 4: Status of LDA Enforcement Actions for LD-2 Reporting (as of 
February 22, 2012): 

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

2010: 
Total Number of registrants who received phone calls, e-mails or a 
letter from the U.S. Attorney's Office[A]: 
2009: 320; 
2010: 241; 
Total: 561.     

Number of referrals now compliant: 
2009: 191; 
2010: 121; 
Total: 312.  

Number of referrals pending action: 
2009: 125; 
2010: 118; 
Total: 243.    

Number of referrals with no Action taken by the U.S. Attorney's Office: 
2009: 3; 
2010: 3; 
Total: 6.  

Now compliant: 56%; 
Pending: 43%; 
No action taken: 1%. 

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

[A] Letters sent includes those sent to referred registrants who may 
have been referred for noncompliance with more than one client. 

[End of figure] 

The Office has also received referrals from the Secretary of the 
Senate and the Clerk of the House for noncompliance with LD-203 
reports. The Office sends noncompliance letters to the registered 
organizations and includes the names of the lobbyists who did not 
comply with the requirement to report federal campaign and political 
contributions and certify that they understand the gift rules. For 
noncompliance in the 2009 filing period, as of January 25, 2012, the 
Office has received LD-203 referrals from the Secretary of the Senate 
for 1,081 lobbyists. As of March 23, 2012, the Office received LD-203 
referrals from the Secretary of the Senate for noncompliance in the 
2010 filing period and from the Clerk of the House for the 2009 and 
2010 filing periods; however, the Office is still processing the 
referrals. As of February 22, 2012, the Office has mailed 68 
noncompliance letters to the registered organizations.[Footnote 26] 
The registered organizations may receive a noncompliance letter 
listing the name of more than one lobbyist. As a result, the number of 
letters sent will not match the number of referrals now compliant, 
pending, and with no action taken. However, 7 percent of (73 of 1,081) 
referrals did not require action because the lobbyist was no longer in 
business, deceased, or found to be compliant when the Office received 
the referral. This may occur when lobbyists have responded to the 
contact letters from the Secretary of the Senate and Clerk of the 
House after the Office has received the referrals. Table 4 shows the 
status of enforcement actions for LD-203 reporting after noncompliance 
letters were sent to registrant organizations for 2009. 

Table 4: Status of LDA Enforcement Actions for LD-203 Referrals for 
the 2009 Filing Period (as of February 22, 2012): 

Actions taken for LD-203 referrals for the 2009 filing period: 
Number of referrals now compliant; Number of LD-203 referrals: 97. 

Actions taken for LD-203 referrals for the 2009 filing period: 
Number of referrals pending action; Number of LD-203 referrals: 530. 

Actions taken for LD-203 referrals for the 2009 filing period: Number 
of referrals with no action taken by the Office; 
Number of LD-203 referrals: 73. 

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

[End of table] 

Status of Pending Enforcement Actions: 

According to officials from the Office, many of the LD-2 pending cases 
represent lobbyists who are no longer lobbying or have never filed a 
disclosure report. Officials from the Office stated that they have 
been working more closely with the Senate and the House to remove 
these referrals before they are forwarded to the Office. 

The Office has mailed noncompliance letters to the registered 
organizations and included the names of the lobbyists who did not 
comply with the LD-203 requirement. However, Office officials said 
that there have been complaints within the lobbying community 
regarding responsibility for responding to letters of noncompliance 
with LD-203 requirements. They also said that many lobbyists who were 
not in compliance no longer lobby for the organizations affiliated 
with the referrals, even though these organizations may be listed on 
their original lobbyist registration. Organizations are not 
responsible for an individual lobbyist's failure to comply with the LD-
203 disclosure requirement, nor are they required to provide contact 
information for the noncompliant lobbyist. Because of these 
limitations, officials told us that the Office has very little 
leverage to bring individual lobbyists into compliance. Officials 
stated that many of the LD-203 pending cases remain open in an attempt 
to locate the individual lobbyists, and as a result, these referrals 
may take years to resolve. 

Enforcement Settlement Actions: 

Since the enactment of the LDA in 1995, but before the 2008 
implementation of HLOGA, the Office had settled with three lobbyists 
who failed to file and collected civil penalties totaling about 
$47,000. In November 2011, the Office settled its first enforcement 
case since the enactment of HLOGA in 2007 and reached a $45,000 
settlement with a lobbying firm that had been referred to the Office 
repeatedly for failure to file disclosure reports. HLOGA increased the 
penalties for offenses committed after January 1, 2008. As stated 
earlier, a civil case could lead to penalties up to $200,000, while a 
criminal case--usually pursued if lobbyists' noncompliance is found to 
be knowing and corrupt--could lead to a maximum of 5 years in prison. 

We previously reported that the Office planned to identify additional 
cases of repeat LDA noncompliance for civil enforcement review in the 
spring and summer of 2011. The Office conducted research and used the 
system it developed to identify and track lobbyists and firms that 
have a history of chronic noncompliance. As a result, the Office has 
developed a "top 10 list" of noncompliant lobbyists whom it may 
potentially pursue for enforcement actions using five civil 
enforcement attorneys who have been assigned to review the cases. 

Agency Comments: 

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

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) 512-6806 or mihmj@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: 

J. Christopher Mihm: 
Managing Director, Strategic Issues: 

List of Committees: 

The Honorable Joseph I. Lieberman: 
Chairman: 
The Honorable Susan M. Collins: 
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 Lamar Alexander: 
Ranking Member: 
Committee on Rules and Administration: 
United States Senate: 

The Honorable Daniel E. Lungren: 
Chairman: 
The Honorable Robert A. Brady: 
Ranking Member: 
Committee on House Administration: 
House of Representatives: 

The Honorable Lamar S. Smith: 
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 Government Reform: 
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Consistent with the audit mandates 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 any challenges to compliance and potential improvements; 
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, 
including identifying trends in past lobbying disclosure compliance. 

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 have 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, and 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 also told us 
during previous reviews that they rely heavily on automated 
processing, and that while they manually review reports that do not 
perfectly match in formation 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 calendar year 2010 and the first and second quarters of calendar 
year 2011, as well as for sampling year-end 2010 and midyear 2011 
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, although 
we consulted with officials from each office, and they provided us 
with general background information at our request and detailed 
information on data processing procedures. 

To assess the extent to which lobbyists could provide evidence of 
their compliance with reporting requirements, we examined a stratified 
random sample of 100 LD-2 reports from the third and fourth quarters 
of 2010 and the first and second quarters of 2011. The third quarter 
2010 LD-2 reports were from our prior review and were included in the 
current review to redistribute the LD-2 reports evenly across the 
calendar year for future lobbying reviews.[Footnote 27] We excluded 
reports with no lobbying activity or with income less than $5,000 from 
our sampling frame.[Footnote 28] The third quarter 2010 sample was 
drawn from 13,489 activity reports and we drew our remaining sample 
from 38,303 activity reports filed for the fourth quarter of 2010 and 
first and second quarters of 2011 available in the public House 
database, as of our final download date for each quarter. This allowed 
us to generalize to a population of 51,792 activity reports. Our 
sample is based on a stratified random selection, and it 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. All percentage estimates in this report have 95 percent 
confidence intervals of within plus or minus 10.0 percentage points or 
less of the estimate itself, unless otherwise noted. When estimating 
compliance with certain of the elements we examined, we base our 
estimate on a one-sided 95 percent confidence interval to generate a 
conservative estimate of either the minimum or the maximum percentage 
of reports in the population exhibiting the characteristic. 

We contacted all the lobbyists and lobbying firms in our sample and 
asked them to provide support 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. 

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, 
Who's Who in American Politics, Legistorm, and U.S. newspapers through 
Nexis. 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, we conducted an additional review of the publicly available 
Secretary of the Senate or Clerk of the House database to determine 
whether the lobbyist properly disclosed the covered official position. 
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. Despite our 
rigorous search, it is possible that we failed to identify all 
previously held covered official positions for all lobbyists listed. 
Thus, our estimate of the proportion of reports with lobbyists who 
failed to properly disclose covered official positions is a lower-
bound estimate of the minimum proportion of reports that failed to 
report such positions. 

In addition to examining the content of the LD-2 reports, we confirmed 
whether year-end 2010 or midyear 2011 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 2010 and the first and second quarters of 2011, we used 
data filed with the Clerk of the House to match newly filed 
registrations with corresponding disclosure reports. Using direct 
matching and text and pattern matching procedures, we were able to 
identify matching disclosure reports for 3,357, or 88 percent, of the 
3,802 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 32,301 total LD-203 reports. 
The first sample contains 80 reports of the 10,646 reports with 
political contributions and the second contains 80 reports of the 
21,655 reports listing no contributions. Each sample contains 40 
reports from the year-end 2010 filing period and 40 reports from the 
midyear 2011 filing period. 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 8.2 percentage points or 
less, and to within 4.2 percentage points of estimate when analyzing 
both samples together. 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. 
For our fiscal year 2009 report, we interviewed staff at the FEC 
responsible for administering the database and determined that the 
data reliability is suitable for the purpose of 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 provide an explanation of why the contribution was 
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 (such as honoraria 
or gifts to presidential libraries). 

To identify challenges to compliance, we used structured interviews 
and obtained views from lobbyists included in our sample of LD-2 
reports on any challenges to compliance. In addition, we asked 
lobbyists to rate various terms associated with disclosure 
requirements. 

To describe the resources and authorities available to the Office, we 
interviewed officials from the Office and obtained information on the 
level of staffing and resources dedicated to the enforcement of the 
LDA. The Office provided us with information on the processes used to 
enforce compliance with the LDA, and reports from the tracking system 
on their number and status of referrals. 

To describe the efforts the Office has made to improve its enforcement 
of the LDA, we interviewed officials from the Office and obtained 
information on the processes used by the Office in following up on 
referrals from the Secretary of the Senate and the Clerk of the House. 
The Office provided us with reports from the tracking system on the 
number and status of the referred cases. 

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 all lobbying activity 
or contributions were disclosed. 

We conducted this performance audit from June 2011 through March 2012 
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 5). 

Table 5: Names of Registrants and Clients Selected in Random Sample of 
Lobbying Disclosure Reports Filed in the Third and Fourth Quarters of 
2010 and the First and Second Quarters of 2011: 

Registrant name: Aguirre; 
Client: The Geo Group Inc. 

Registrant name: AJW, Inc. 
Client: Noresco. 

Registrant name: Akin Gump Strauss Hauer & Feld; 
Client: Kohlberg Kravis Roberts & Company. 

Registrant name: Alcade & Fay; 
Client: Marin County, California. 

Registrant name: American Continental Group; 
Client: Liberty Lane Partners. 

Registrant name: American Gas Association; 
Client: American Gas Association. 

Registrant name: American Network of Community Options & Resources; 
Client: American Network of Community Options & Resources. 

Registrant name: Baker Donelson Bearman Caldwell & Berkowitz; 
Client: Helen Keller National Center. 

Registrant name: Barbour Griffith & Rogers, LLC d/b/a BGR Government 
Affairs; 
Client: The American Chamber of Commerce in the People's Republic of 
China (AmCham-China). 

Registrant name: Barnes & Thornburg LLP; 
Client: Town of Fishers. 

Registrant name: Behar & Kalman, LLP; 
Client: National Association of Long Term Hospitals. 

Registrant name: Bockorny Group, Inc; 
Client: Elanco Animal Health. 

Registrant name: Brownstein Hyatt Farber Schreck, LLP; 
Client: Z-MEDICA. 

Registrant name: Brownstein Hyatt Farber Schreck, LLP; 
Client: Westwood College. 

Registrant name: Capitol Federal Strategies, LLC; 
Client: GE Inspection Technologies. 

Registrant name: Capstone National Partners; 
Client: Museum of Science and Industry. 

Registrant name: Cassidy & Associates, Inc. (formerly known as Cassidy 
& Associates); 
Client: Vion Corporation. 

Registrant name: Cavarocchi Ruscio Dennis Associates, L.L.C. 


Client: Coalition for Health Services Research. 

Registrant name: CG Technologies, Inc. 


Client: Dynetics, Inc. 

Registrant name: Competition Advocates, LLC; 
Client: Daikin Industries Limited. 

Registrant name: Concerned Women for America Legislative Action 
Committee; 
Client: Concerned Women for America Legislative Action Committee. 

Registrant name: Cystic Fibrosis Foundation; 
Client: Cystic Fibrosis Foundation. 

Registrant name: David Turch & Associates; 
Client: City of Palmdale. 

Registrant name: D.C. Legislative and Regulatory Services, Inc. 


Client: British Petroleum, America. 

Registrant name: DeBrunner & Associates, Inc. 


Client: Monongahela Valley Hospital. 

Registrant name: Defense Strategic Advantage, LLC; 
Client: Sabreliner Corporation. 

Registrant name: Delta Strategy Group; 
Client: Chesapeake Energy Corporation. 

Registrant name: Delta Strategy Group (formerly Parsons Strategies); 
Client: D.E. Shaw & Co., L.P. 

Registrant name: Energy Future Holdings (formerly TXU Electric 
Delivery); 
Client: Energy Future Holdings (formerly TXU Electric Delivery). 

Registrant name: Ernst & Young LLP (Washington Council Ernst & Young); 
Client: Covidien. 

Registrant name: Etherton and Associates, Inc. 


Client: Lockheed Martin Corporation. 

Registrant name: Federal Policy Group (Clark & Wamberg LLC); 
Client: Cigar Association of America. 

Registrant name: Ferguson Group; 
Client: Cary-NC, Town of. 

Registrant name: Firstenergy Corp; 
Client: Firstenergy Corp. 

Registrant name: Fisher Consulting; 
Client: Ball State University. 

Registrant name: Food Marketing Institute; 
Client: Food Marketing Institute. 

Registrant name: Gephardt Group Government Affairs; 
Client: Rational Entertainment Enterprises (on behalf of PokerStars). 

Registrant name: Holland & Knight LLP; 
Client: League of California Cities. 

Registrant name: Innovative Federal Strategies, LLC; 
Client: Advatech Pacific, Inc. 

Registrant name: JEH Government Services, Inc. 


Client: Appleton Paper. 

Registrant name: KAR Associates, LLC; 
Client: Emergency Nurses Assn. 

Registrant name: Law Offices of Kevin G. Curtin; 
Client: Grocery Manufacturers/Food Products Association. 

Registrant name: Legislative Strategies, Inc. 


Client: Kinder Morgan CO2 Company LP. 

Registrant name: LeMunyon Group, LLC; 
Client: Brazos River Authority. 

Registrant name: Liebman & Associates, Inc. 


Client: Lineage Power. 

Registrant name: Marlowe & Company; 
Client: City of Havelock. 

Registrant name: Mattoon & Associates, LLC; 
Client: Rolls-Royce North America, Inc. 

Registrant name: Mayer Brown LLP; 
Client: U.S. Chamber of Commerce. 

Registrant name: McAllister & Quinn LLC; 
Client: Childhelp. 

Registrant name: mCapitol Management; 
Client: Emergent Biosolutions. 

Registrant name: McGuireWoods Consulting; 
Client: Dominion Resources, Inc. 

Registrant name: McGuireWoods Consulting; 
Client: Federal Home Loan Bank of Atlanta. 

Registrant name: ML Strategies, LLC; 
Client: APCO Worldwide (Dow Corning). 

Registrant name: Murray, Montgomery & O'Donnell; 
Client: City of Phoenix. 

Registrant name: National Association of Credit Unions; 
Client: National Association of Credit Unions. 

Registrant name: National Association of Letter Carriers; 
Client: National Association of Letter Carriers. 

Registrant name: National Corn Growers Association; 
Client: National Corn Growers Association. 

Registrant name: National Fair Housing Alliance; 
Client: National Fair Housing Alliance. 

Registrant name: National Fisheries Institute; 
Client: National Fisheries Institute. 

Registrant name: National Venture Capital Association; 
Client: National Venture Capital Association. 

Registrant name: Navigators Global LLC (formerly DC Navigators, LLC); 
Client: Pala Band of Mission Indians. 

Registrant name: NCR Corporation; 
Client: NCR Corporation. 

Registrant name: Nelson, Mullins, Riley & Scarborough; 
Client: Maricopa County. 

Registrant name: New York Life Insurance Company; 
Client: New York Life Insurance Company. 

Registrant name: North Shore Consultants; 
Client: JASON Project. 

Registrant name: Ogilvy Government Relations; 
Client: Ogilvy Public Relations on behalf of California High-Speed 
Rail. 

Registrant name: Oglethorpe Power Corporation; 
Client: Oglethorpe Power Corporation. 

Registrant name: Olsson Frank Weeda Terman Bode Matz PC; 
Client: National Meat Association. 

Registrant name: O'Neill and Associates; 
Client: Massachusetts Port Authority. 

Registrant name: Petrizzo Strategic Group, Inc. 


Client: Allen Institute for Brain Science. 

Registrant name: Podesta Group, Inc. 


Client: University of South Carolina. 

Registrant name: Public Strategies Washington; 
Client: Anheuser-Busch Cos. 

Registrant name: Quinn Gillespie & Associates; 
Client: Satcon Technology Corporation. 

Registrant name: Quinn Gillespie & Associates; 
Client: Cayman Finance. 

Registrant name: Ricchetti Incorporated; 
Client: Novartis. 

Registrant name: Rose, Peter J. 


Client: Lockheed Martin Group. 

Registrant name: Russ Reid Company; 
Client: Valparaiso University. 

Registrant name: Save Darfur Coalition; 
Client: Save Darfur Coalition. 

Registrant name: Sears Holdings Corporation; 
Client: Sears Holdings Corporation. 

Registrant name: Smith Dawson & Andrews; 
Client: City of Fontana. 

Registrant name: SRG & Associates; 
Client: Warren Corp. 

Registrant name: Strafegies International, Ltd. 


Client: American Sesame Growers Association. 

Registrant name: Strategic Marketing Innovations; 
Client: University of Maine. 

Registrant name: Strategic Marketing Innovations; 
Client: Ingersoll Machine Tools. 

Registrant name: The Accord Group; 
Client: Southern Company. 

Registrant name: The Glover Park Group LLC; 
Client: Ernst & Young LLP. 

Registrant name: The Glover Park Group LLC; 
Client: Amerilink Telecom Corporation. 

Registrant name: The Livingston Group, L.L.C. 


Client: New Orleans Business Council. 

Registrant name: The McManus Group; 
Client: Genentech. 

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

Registrant name: Troutman Sanders Public Affairs Group, LLC; 
Client: City of Sacramento. 

Registrant name: Urban Swirski & Associates, LLC; 
Client: National Association of Water Companies. 

Registrant name: Van Scoyoc Associates; 
Client: The Rotary Foundation of Rotary International. 

Registrant name: Van Scoyoc Associates; 
Client: City of Pismo Beach. 

Registrant name: Van Scoyoc Associates; 
Client: Martin County, Florida. 

Registrant name: White & Case LLP; 
Client: Employee-Owned S Corporations of America. 

Registrant name: Whitmer & Worrall, LLC; 
Client: Community College of Allegheny County. 

Registrant name: Williams & Jensen, PLLC; 
Client: City of New Haven, Connecticut. 

Registrant name: Williams & Jensen, PLLC; 
Client: U.S. Israel Science and Technology Foundation. 

Registrant name: Williams and Jensen, PLLC; 
Client: County of Maui, Hawaii. 

Source: Lobbying disclosure database of the Clerk of the House of 
Representatives for the third and fourth quarters of calendar year 
2010 and the first and second quarters of calendar year 2011. 

[End of table] 

Appendix III: List of Sampled Lobbying Contribution Reports with 
Contributions and No Contributions Listed: 

See table 6 for a list of lobbyists and lobbying firms from our random 
sample of lobbying contribution reports with contributions. See table 
7 for a list of lobbyists and lobbying firms from our random sample of 
lobbying contribution reports without contributions. 

Table 6: Lobbyists and Lobbying Firms in Random Sample of Lobbying 
Contribution Reports with Contributions Listed, Filed Year-end 2010 
and Midyear 2011: 

Lobbyist or lobbying firm: Air Conditioning Contractors of America; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Alan Slomowitz; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: American Resort Development Assn. 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Association of Home Appliance Manufacturers; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Baker Donelson Bearman Caldwell & Berkowitz; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Business Software Alliance; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Carl Chidlow; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Cecil Swamidoss; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Citigroup Management Corp. 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Clothilde Hewlett; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: David Horne; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: David Polster; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: eBay Inc. 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Edward Baxter; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Elizabeth Sharp; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Eric Stewart; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Erin Martinko; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Frederick Dombo; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: George Mannina; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Grayson Winterling; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Gregory Baise; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Holcim (US) Inc. 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: James Gelfand; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: James Hooley; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: James Rock; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Jeanne Campbell; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: John Blount; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: John Runyan; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: John Troy; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Jose Fuentes; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Josh Bourne; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Kaiser Foundation Health Plan Inc. 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Keith Amason; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Kerry McKenney; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Lawrence Pratt; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Leann Fox; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Leslie Belcher; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Lisa Potetz; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: M. Skiles; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Mark Disler; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Mark Malone; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Melinda Dutton; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Melinda Maxfield; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Michael Johnson; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Michael Mawby; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Michael Werner; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Michelle Vogel; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Mr. Jackson DeWitt; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Mr. Robert Zimmer; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Mrs. Helen Delich Bentley; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: National Air Traffic Controllers 
Association; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: National Association for Uniformed Services; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: National Association of Realtors; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: National Music Publishers' Association; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Newmont Mining Corporation; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Pablo Chavez; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Patrick Carroll; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Peter Loughlin; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Peter Newbould; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Public Service Enterprise Group; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Richard Efford; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Robert Hurt; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Sandra Swirski; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Scott Keefer; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Scott Scanland; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Sodexo Inc. 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Steven Fisher; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Steven McKnight; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Susan Ingargiola; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Ted Monoson; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Terry Allen; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Tesoro Companies; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Thane Young; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: The GoodYear Tire & Rubber Company; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Thomas Keating; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Universal Music Group; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Vicki Iseman; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Vincent Versage; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: William Ris; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Yahoo! Inc. 
Reporting period: Year-end 2010. 

Source: Lobbying contributions database of the Clerk of the House of 
Representatives, Year-end reports for calendar year 2010 and midyear 
reports for calendar year 2011. 

[End of table] 

Table 7: Lobbyists and Lobbying Firms in Random Sample of Lobbying 
Contribution Reports with No Contributions Listed, Filed Year-end 2010 
and Midyear 2011: 

Lobbyist or lobbying firm: Abby Bownas; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Alan Ross; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Alexis Latifi; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Alliance for Excellent Education; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: American Business Conference; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: America's Blood Centers; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Amy Edwards; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Amy Rosenthal; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Anne Duffy; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: BAFT-IFSA (formerly known as Bankers' 
Association for Finance & Trade); 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Brendan Flanagan; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Brigen Winters; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Camille Donald; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Capitol Counsel LLC; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Charlene Macdonald; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Christopher Kearney; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Christopher Ross; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Connect; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Corporate Voices for Working Families; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Craig Updyke; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Daniel Smith; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Darah Franklin; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Darren Lasorte; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Deirdre Stach; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Dirk Vande Beek; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Don Miller; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Edward Edens; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Edward Olivares; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Emmer Consulting, P.C. 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Fernando Gomez; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Florida State University; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Frank Ryan; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Fred Searle; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Geos Institute (formerly National Center 
for Conservation Sc); 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Good Will Industries International Inc. 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Harold Johnson; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Heidi Salow; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: International Union of Operating Engineers; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Jake Jacoby; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: James Kuhn; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Jeffry P. Mahoney; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Jerome Nagy; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: John Sabo; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Jonathan Bergner; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Joyce Knott; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Kenneth Nahigian; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Kevin Dempsey; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Kirsten Zewers; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Law Offices of James L. Kane, Jr. 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Madison Government Affairs; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Martin Regalia; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Morgan Brown; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Nancy Kohler; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Natasha Bui; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: National Action Council for Minorities in 
Engineering, Inc. 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: National Alliance on Mental Illness; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Nora Super; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Patricia Chavez; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Porter Delaney; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Priscilla Chatman; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Profit Sharing/401(K) Council of America; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Rachel Hedge; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Rebecca Kelly; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Redfern Resources; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Ryan Quinn; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Safety Net Hospitals for Pharmaceutical 
Access; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Scott North; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Scott Thompson; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Sean Heather; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Stephan Bell; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Steve Gotthiem; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Steven Brownlee; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Terry Francl; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: The Collette Group LLC; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Traditional Values Coalition; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: Washington University in St. Louis; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Wayne LaPierre; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: William Cloherty; 
Reporting period: Midyear 2011. 

Lobbyist or lobbying firm: William Weber; 
Reporting period: Year-end 2010. 

Lobbyist or lobbying firm: Yvonne Roberts; 
Reporting period: Year-end 2010. 

Source: Lobbying contributions database of the Clerk of the House of 
Representatives, Year-end reports for calendar year 2010 and midyear 
reports for calendar year 2011. 

[End of table] 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

J. Christopher Mihm, (202) 512-6806 or mihmj@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Robert Cramer, Associate 
General Counsel; Bill Reinsberg, Assistant Director; Shirley Jones, 
Assistant General Counsel; Crystal Bernard; Amy Bowser; Colleen 
Candrl; Jill Lacey; Natalie Maddox; Donna Miller; Anna Maria Ortiz; 
Melanie Papasian; and Katrina Taylor made key contributions to this 
report. 

Assisting with lobbyist file reviews were Vida Awumey, Alexandra 
Edwards, Emily Gruenwald, Lois Hanshaw, Jeff McDermott, Stacey Ann 
Spence, Megan Taylor and Daniel Webb. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 110-81, 121 Stat. 735 (Sept. 14, 2007). 

[2] Pub. L. No. 104-65, 109 Stat. 691 (Dec. 19, 1995) (2 U.S.C. §§ 
1601-1614). 

[3] 2 U.S.C. § 1614. 

[4] LD-2 reports for third quarter 2010 are from the prior review and 
are included in the current review to redistribute the LD-2 reports 
evenly across the calendar year for this and future lobbying reviews. 
This will allow us enough time to complete reviews and conduct the 
analysis of the data prior to our required reporting date. For the 
prior report, GAO-11-452], we drew a sample from the fourth quarter of 
calendar year 2009 and the first, second, and third quarters of 
calendar year 2010. See GAO, 2010 Lobbying Disclosure: Observations on 
Lobbyists' Compliance with Disclosure Requirements, [hyperlink, 
http://www.gao.gov/products/GAO-11-452] (Washington, D.C.: Apr. 1, 
2011). 

[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] 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. 

[7] 2 U.S.C. § 1602(10) 

[8] 2 U.S.C. § 1602(9). 

[9] 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 
$11,500. Amounts are adjusted for inflation and published in the LDA 
guidance. 

[10] 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, policymaking, 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). 

[11] See [hyperlink, http://www.gao.gov/products/GAO-11-452], and GAO, 
2009 Lobbying Disclosure: Observations on Lobbyists' Compliance with 
Disclosure Requirements, [hyperlink, 
http://www.gao.gov/products/GAO-10-499] (Washington, D.C.: Apr. 1, 
2010); 2008 Lobbying Disclosure: Observations on Lobbyists' Compliance 
with Disclosure Requirements, [hyperlink, 
http://www.gao.gov/products/GAO-09-487] (Washington, D.C.: Apr. 1, 
2009); and 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). 

[12] 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 10.0 percentage 
points or less of the estimate. 

[13] [hyperlink, http://www.gao.gov/products/GAO-11-452]. 

[14] 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. 

[15] For information on our methodology, see appendix I. 

[16] [hyperlink, http://www.gao.gov/products/GAO-11-452]. 

[17] As part of our LD-2 report review, we checked the Clerk of the 
House's database to ensure that each lobbyist and organization listed 
on the LD-2 report filed an LD-203 report during the most recent 
reporting period. 

[18] [hyperlink, http://www.gao.gov/products/GAO-11-452]. 

[19] We did not estimate the percentage of other non-FEC political 
contributions that were omitted (such as honoraria or gifts to 
presidential libraries) because they tend to constitute a small 
minority of all listed contributions and cannot be verified against an 
external data source. 

[20] [hyperlink, http://www.gao.gov/products/GAO-11-452] and 
[hyperlink, http://www.gao.gov/products/GAO-10-499]. 

[21] The number of lobbying firms total 90 and is less than our sample 
of 100 reports because some lobbying firms had more than one LD-2 
report included in our sample for lobbyists that we interviewed on the 
same day. In these cases, we interviewed each lobbyist once to ask 
about lobbying disclosure requirements and the clarity of lobbying 
terms. 

[22] Although the quantitative results from lobbyists in our sample of 
LD-2 reports are generalizable to all LD-2 reports, the qualitative 
results are not generalizable because our sample was designed to 
develop population estimates of the accuracy of information on LD-2 
reports and was not designed to estimate the opinions of lobbyists. 

[23] [hyperlink, http://www.gao.gov/products/GAO-11-452]. 

[24] Prior to the enactment of HLOGA, the deadline for filing 
disclosure reports was 45 days after the end of each reporting period. 

[25] [hyperlink, http://www.gao.gov/products/GAO-08-1099]. 

[26] The Office is in the process of updating the noncompliance letter 
it sends to referred organizations. Officials said that they plan to 
send the new letters to the remaining referred organizations starting 
in the fall of 2012. 

[27] For the prior review, we drew a stratified random sample of LD-2 
reports from the fourth quarter of 2009 and the first, second, and 
third quarters of 2010. 

[28] 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. 

[End of section] 

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