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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

April 2013: 

2012 Lobbying Disclosure: 

Observations on Lobbyists' Compliance with Disclosure Requirements: 

GAO-13-437: 

GAO Highlights: 

Highlights of GAO-13-437, 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) audit the extent to which lobbyists can 
demonstrate compliance with disclosure requirements, (2) identify 
challenges to compliance that lobbyists report, and (3) describe the 
resources and authorities available to the U.S. Attorney’s Office for 
the District of Columbia and the efforts the Office has made to 
improve its enforcement of the LDA, as amended. This is GAO’s sixth 
report under the mandate. 

GAO reviewed a stratified random sample of 100 quarterly disclosure LD-
2 reports filed for the third and fourth quarters of calendar year 
2011 and the first and second quarters of calendar year 2012. GAO also 
reviewed two random samples totaling 160 LD-203 reports from year-end 
2011 and midyear 2012. This methodology allowed GAO to generalize to 
the population of 49,286 disclosure reports with $5,000 or more in 
lobbying activity and 31,894 reports of federal political campaign 
contributions. GAO also met with officials from the Office to obtain 
updated statuses on the Office’s efforts to focus resources on 
lobbyists who fail to comply. 

GAO provided a draft of this report to the Attorney General for review 
and comment. 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 the disclosure requirements of the Lobbying Disclosure 
Act of 1995 (LDA), as amended by the Honest Leadership and Open 
Government Act of 2007 (HLOGA). For lobbying disclosure reports (LD-
2), GAO estimates that: 

* 97 percent could provide documentation to support reported income 
and expenses; 

* 74 percent of the reported income and expenses were properly rounded 
to the nearest $10,000; 

* 85 percent filed year-end 2011 or midyear 2012 federal political 
campaign (LD-203) reports as required; and: 

* a minimum of 15 percent of all LD-2 reports did not properly 
disclose formerly held covered positions as required. The LDA defines 
several types of covered positions, including members of Congress and 
their staff and certain executive branch officials. 

These findings are consistent with reviews from prior years. 

For LD-203 reports, GAO estimates that a minimum of 6 percent of all 
LD-203 reports omitted one or more reportable political contributions 
that were documented in the Federal Election Commission (FEC) 
database. Twenty-eight lobbyists in GAO’s sample, compared to17 last 
year, stated that they planned to amend their lobbying registration 
(LD-1) or LD-2 report following GAO’s review to correct one or more 
data elements. Of these, 19 lobbyists had filed an amended report as 
of March 2013. 

The majority of newly registered lobbyists filed LD-2 reports as 
required. Lobbyists are required to file LD-2 reports for the quarter 
in which they first register. GAO could identify corresponding reports 
on file for lobbying activity for 90 percent of registrants, which is 
similar to last year’s findings. 

Most lobbyists in our sample rated the terms associated with LD-2 
reporting as “very easy” or “somewhat easy” to understand with regard 
to meeting their reporting requirements. However, a few cited 
challenges to complying with the LDA, as amended, such as 
differentiating between lobbying and non-lobbying activities. 

The U.S. Attorney’s Office for the District of Columbia (the Office) 
stated that it has sufficient authority and resources to enforce 
compliance with LDA requirements, including imposing civil or criminal 
penalties for noncompliance. Officials reported that during the 2012 
reporting period, the Office took steps to pursue legal action, made 
phone contacts, or sent emails to eight registrants that had been 
repeatedly referred for failure to file required disclosure reports. 
Four of the registrants filed the outstanding reports or terminated 
their registration after being contacted by an Assistant U.S. 
Attorney. Additionally, in September 2012, the Office reached 
settlement agreements with two of the registrants for $50,000 and 
$30,000 in civil penalties. As of March 2013, both firms have paid 
their fines in full and complied with their ongoing reporting 
requirements. In February 2013, the Office sent demand letters to the 
two other registrants who, as of March 2013, have not responded. 

View [hyperlink, http://www.gao.gov/products/GAO-13-437]. 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 Very 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: Differences in the Amount Reported by at Least $10,000 and 
Rounding Errors in Documentation for Income and Expenses Provided for 
LD-2 Reports from 2010 through 2012: 

Table 2: Reasons Lobbyists in our Sample Cited for Not Having 
Documentation for Some Elements of their LD-2 Reports: 

Table 3: Reasons Lobbyists in Our Sample Cited for Planning to Amend 
Their LD-1 or LD-2 Report and the Number of Amendments filed: 

Table 4: Comparison of LD-203 Reports that Omitted Political 
Contributions, 2010 through 2012: 

Table 5: Number of LD-2 Referrals the U.S. Attorney's Office Received 
and Noncompliance Letters the Office Sent: 

Table 6: Number of LD-203 Referrals the U.S. Attorney's Office 
Received and Noncompliance Letters the Office Sent: 

Table 7: Names of Registrants and Clients Selected in Random Sample of 
Lobbying Disclosure Reports Filed in the Third and Fourth Quarters of 
2011 and the First and Second Quarters of 2012: 

Table 8: Lobbyists and Lobbying Firms in Random Sample of Lobbying 
Contribution Reports with Contributions Listed, Filed Year-end 2011 
and Midyear 2012: 

Table 9: Lobbyists and Lobbying Firms in Random Sample of Lobbying 
Contribution Reports with No Contributions Listed, Filed Year-end 2011 
and Midyear 2012: 

Figures: 

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

Figure 2: Feedback from Some Lobbyists in Our Sample of Reports Who 
Reported Challenges to Complying with the Act: 

Figure 3: Ease of Understanding Terms Associated with LD-2 Reporting 
for Lobbyists in Interviews: 

Figure 4: Status of LDA Enforcement Actions for LD-2 Reporting: 

Figure 5: Status of LDA Enforcement Actions for LD-203 Reporting: 

Abbreviations: 

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

FEC: Federal Election Commission: 

HLOGA: Honest Leadership and Open Government Act of 2007: 

LDA: Lobbying Disclosure Act of 1995: 

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

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

April 1, 2013: 

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 us 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 sixth 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 are able to demonstrate compliance with the 
requirements of the LDA, as amended, for registrations and reports; 
(2) identify challenges and potential improvements to compliance by 
lobbyists, lobbying firms, and registrants, if any; and (3) describe 
the resources and authorities available to the Office for the District 
of Columbia 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 2011 and 
the first and second quarters of calendar year 2012. 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 4] 
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, as amended, we analyzed 
stratified random samples of year-end 2011 and midyear 2012 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 2011 and the first and second quarters of 2012 
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 
its efforts to improve its enforcement of the LDA, we interviewed 
officials from the Office and obtained updated information on the 
capabilities of the system they established to track and report 
compliance trends and referrals, and other practices established to 
focus resources on enforcement of the Act. The Office provided us with 
updated reports from the tracking system on the number and status of 
referrals and chronically noncompliant offenders. 

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

We conducted this performance audit from June 2012 to April 2013 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 of the 
Senate and the Clerk of the House review the guidance semiannually. 
The guidance was last reviewed and revised in February 2013. 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. The 
Secretary of the Senate and Clerk of the House previously told us 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 5] represent at least 20 percent of the 
time that he or she spends on behalf of the client during the quarter. 
[Footnote 6] Lobbying firms are persons or entities that have one or 
more employees who lobby on behalf of a client other than that person 
or entity.[Footnote 7] 

Lobbying firms are required to 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 $12,500 in 
incurred expenses from that client for lobbying activities.[Footnote 
8] Lobbyists are also required to submit a quarterly report, also 
known as an LD-2 report, for each registration filed. The 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 covered officials in the previous 20 years; 
[Footnote 9] 

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

Lobbyists Provided Documentation for Most 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 10] Lobbyists for an estimated 97 percent of LD-2 reports 
(97 out of 100) were able to provide documentation to support the 
income and expenses reported for the third and fourth quarters of 2011 
and the first and second quarters of 2012.[Footnote 11] Lobbyists most 
commonly provided documentation in the form of invoices and contracts. 
Last year, lobbyists were able to provide documentation for income and 
expenses for an estimated 93 percent of LD-2 reports for the quarters 
under review.[Footnote 12] Table 1 compares the number of LD-2 reports 
with differences in the amount of income and expenses reported by at 
least $10,000 and those with rounding errors in documentation for 
income and expenses provided for LD-2 reports from 2010 through 
2012.[Footnote 13] 

Table 1: Differences in the Amount Reported by at Least $10,000 and 
Rounding Errors in Documentation for Income and Expenses Provided for 
LD-2 Reports from 2010 through 2012: 

Properly rounded to the nearest $10,000; 
2010: 68% (65 of 96); 
2011: 63% (59 of 93); 
2012: 74% (72 of 97). 

Differed from the amount by at least $10,000; 
2010: 13% (13 of 96); 
2011: 16% (15 of 93); 
2012: 5% (5 of 97). 

Had rounding errors; 
2010: 19% (18 of 96); 
2011: 21% (19 of 93); 
2012: 21% (20 of 97). 

Source: GAO. 

Note: Data for 2011 are from last year's review GAO-12-492 and 2010 
data are from the prior year's review GAO-11-452. Percentage estimates 
in the figure have a maximum margin of error of plus or minus 10.1 
percentage points of the estimate and are weighted to account for the 
probability of selection. While the results of our review were 
generally consistent from 2010 through 2012, our sample was not 
designed to detect differences over time. 

[End of table] 

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

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

[Refer to PDF for image: stacked vertical bar graph] 

Estimated percent of reports[A]: 

Lobbied the House: 
Documentation to support: 71%; 
No documentation to support: 29%. 

Lobbied the Senate: 
Documentation to support: 72%; 
No documentation to support: 28%. 

Issue codes: 
Documentation to support: 76%; 
Some documentation to support[B]: 4%; 
No documentation to support: 20%. 

Individuals acting as lobbyists: 
Documentation to support: 69%; 
Some documentation to support[B]: 13%; 
No documentation to support: 18%. 

Source: GAO. 

[A] Percentage estimates in the figure have a 95 percent confidence 
interval of plus or minus 10.5 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 issue codes, 
or lobbyists reported. 

[End of figure] 

Of the 100 LD-2 reports in our sample, 51 disclosed lobbying 
activities at executive branch agencies with lobbyists for 30 of these 
reports providing documentation to support lobbying activities at all 
agencies listed. 

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

Table 2: 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: 
Did not keep documentation; 
Number of instances reported: 28; 
Did not lobby the Houses of Congress for that quarter; 
Number of instances reported: 21; 
Had documentation, but did not provide documentation by follow-up 
date[A]; 
Number of instances reported: 5. 

LD-2 report element: Individuals acting as lobbyists; 

Reasons for not having documentation: 
Did not keep documentation; 
Number of instances reported: 38; 
Did not lobby on behalf of the client; 
Number of instances reported: 3; 
Had documentation, but did not provide documentation by follow-up 
date[A]; 
Number of instances reported: 13. 

LD-2 report element: Reported lobbying income or expenses; 

Reasons for not having documentation: 
Did not keep documentation; 
Number of instances reported: 1; 
Had documentation, but did not provide the documentation by the follow-
up date[A]; 
Number of instances reported: 5. 

Source: GAO. 

Note: Lobbyists may have reported more than one reason for not having 
documentation to explain more than one element that was not documented 
on their LD-2 report. 

[A] After our review, firms that did not have documentation available 
at the meeting agreed to provide documentation by a mutually agreed 
upon due date. 

[End of table] 

Lobbyists Properly Disclosed Most Covered Positions and Filed LD-203 
Reports 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 15 
percent of all LD-2 reports did not properly disclose one or more 
previously held covered positions compared to 11 percent for 2011 and 
9 percent for 2010.[Footnote 14] These results are generally 
consistent from 2010 through 2012. Of those that failed to disclose 
properly, 11 LD-2 amendments and 2 LD-1 amendments were filed to 
properly disclose covered positions and two lobbying firms addressed 
the omitted covered positions on subsequent LD-2 filings. 

Two lobbyists said they were confused as to whether intern positions 
are covered positions. One of those lobbyists amended the LD-2 report 
to disclose an unpaid internship. However, officials from the Office 
of the Secretary of the Senate and the Clerk of the House clarified 
that unpaid internships are not considered covered official positions, 
and are not required to be disclosed. Two other lobbyists in our 
sample said they were unaware of the HLOGA requirement to disclose 
covered positions held within the last 20 years of first acting as a 
lobbyist for a client. 

Lobbyists for an estimated 85 percent (85 of 100) of LD-2 reports 
filed year-end 2011 or midyear 2012 LD-203 contribution reports for 
all lobbyists and lobbying firms listed on the report as required. 
[Footnote 15] This finding is consistent with previous reports. 
[Footnote 16] 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. 

More Lobbying Firms Indicated That They Planned to Amend Their LD-2 
Reports as a Result of GAO's Review: 

Compared to our last review, more lobbying firms indicated that they 
planned to amend their LD-2 reports as a result of our review. This 
year, for 28 of the LD-2 reports in our sample, lobbyists indicated 
they planned to amend their LD-1 or LD-2 reports as a result of our 
review. As of March 2013, 16 of those 28 lobbying firms had filed an 
amended LD-2 report and 3 lobbying firms amended their LD-1 report to 
make changes to information that was previously reported.[Footnote 17] 
Last year, for 17 of the LD-2 reports in our sample, lobbyists 
indicated they planned to amend their LD-2 reports, and as of March 
2012, 9 had done so.[Footnote 18] 

Table 3 lists reasons lobbying firms in our sample cited for planning 
to amend their LD-1 or LD-2 reports and the number of amendments filed. 

Table 3: Reasons Lobbyists in Our Sample Cited for Planning to Amend 
Their LD-1 or LD-2 Report and the Number of Amendments filed: 

Update covered position; 
Indicated plans to file an amendment: 19; 
Filed an amendment as of March 2013: 13. 

Change reported Income or expenses; 
Indicated plans to file an amendment: 9; 
Filed an amendment as of March 2013: 4. 

Change House, Senate or executive agency lobbying activity; 
Indicated plans to file an amendment: 4; 
Filed an amendment as of March 2013: 2. 

Total; 
Indicated plans to file an amendment: 32[A]; 
Filed an amendment as of March 2013: 19. 

Source: GAO. 

[A] Four of the 28 lobbying firms that indicated they planned to file 
an amendment, said they planned to change more than one element of 
their LD-1 or LD-2 report. 

[End of table] 

In addition, 2 lobbying firms did not indicate plans to file an 
amendment at the time of our review, but later filed amended reports 
after meeting with us to add an issue area code and remove a lobbyist. 
Similar to our 2012 report, lobbying firms filed amendments for 3 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.[Footnote 19] 

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

As part of our review, we compared contributions listed on lobbyists 
and lobbying firms' LD-203 reports against political contributions 
reported in the FEC database to identify whether political 
contributions were omitted on LD-203 reports in our sample. The sample 
of LD-203 reports we reviewed contained 80 reports with contributions 
and 80 reports without contributions. We estimate that overall, a 
minimum of 6 percent of reports failed to disclose one or more 
contributions.[Footnote 20] Table 4 compares the number of LD-203 
reports that omitted political contributions for 2010 through 2012. 

Table 4: Comparison of LD-203 Reports that Omitted Political 
Contributions, 2010 through 2012: 

Number of reports with contributions that had one or more omissions: 
2010: 7; 
2011: 12; 
2012: 14. 

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

Estimated minimum percentage of all reports with one or more omissions: 
2010: 2%; 
2011: 4%; 
2012: 6%. 

Source: GAO. 

Note: Data for 2011 are from last year's review GAO-12-492 and 2010 
data are from the prior year's review GAO-11-452. Percentage estimates 
in the figure have a maximum margin of error of plus or minus 4.7 
percentage points of the estimate and are weighted to account for the 
probability of selection. While the results of our review were 
generally consistent from 2010 through 2012, our sample was not 
designed to detect differences over time. 

[End of table] 

Most Newly Registered Lobbyists Filed Disclosure Reports as Required: 

Of the 3,074 new registrants we identified from fiscal year 2012, we 
were able to match 2,753 reports filed in the first quarter in which 
they were registered. This is a match rate of 90 percent of 
registrations, which is consistent with our prior reviews.[Footnote 
21] To determine whether new registrants were meeting the requirement 
to file, we matched newly filed registrations in the third and fourth 
quarters of 2011 and the first and second quarters of 2012 from the 
House Lobbyists 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 Very Easy or Somewhat Easy to Meet, A Few Lobbyists Reported 
Challenges in Complying with the Act: 

As part of our review, 90 different lobbying firms were included in 
our sample.[Footnote 22] Of the 90 different lobbying firms in our 
sample, 32 reported that the disclosure requirements were "very easy" 
to comply with, 39 reported they were "somewhat easy" and 19 reported 
that the disclosure requirements were "somewhat difficult" or "very 
difficult".[Footnote 23] Last year, we also asked the lobbying firms 
in our sample if they found the disclosure requirements easy to 
meet.[Footnote 24] Of those 90 firms, 61 agreed that the requirements 
were "easy" to meet, 25 reported that requirements were "somewhat 
easy" to meet, and 4 reported that the disclosure requirements were 
"not easy" to meet. 

In addition, some lobbyists provided feedback identifying specific 
challenges to compliance, as shown in figure 2. The most frequently 
cited challenges were differentiating between lobbying and non-
lobbying activities and determining the most appropriate issue code to 
use. 

Figure 2: Feedback from Some Lobbyists in Our Sample of Reports Who 
Reported Challenges to Complying with the Act: 

[Refer to PDF for image: horizontal bar graph] 

Meeting quarterly reporting time frame: 
Number of lobbying firms: 5. 

Understanding which activities met the definition of a lobbying: 
Number of lobbying firms: 4. 

Differentiating between lobbying activities and non-lobbying 
activities: 
Number of lobbying firms: 15. 

Determining the most appropriate issue code to use: 
Number of lobbying firms: 14. 

Knowing which federal officials they met with that held a covered 
position: 
Number of lobbying firms: 9. 

Source: GAO. 

[End of figure] 

Figure 3: Ease of Understanding Terms Associated with LD-2 Reporting 
for Lobbyists in Interviews: 

[Refer to PDF for image: vertical bar graph] 

Number of lobbying firms: 

Lobbying definitions: 
Very easy: 29; 
Somewhat easy: 42; 
Somewhat difficult or very difficult: 19. 

Lobbying activities: 
Very easy: 25; 
Somewhat easy: 42; 
Somewhat difficult or very difficult: 23. 

Issue codes: 
Very easy: 47; 
Somewhat easy: 28; 
Somewhat difficult or very difficult: 14. 

Covered positions: 
Very easy: 51; 
Somewhat easy: 15; 
Somewhat difficult or very difficult: 22. 

Terminating lobbyist: 
Very easy: 52: 
Somewhat easy: 21: 
Somewhat difficult or very difficult: 14. 

Source: GAO. 

Note: Although, all lobbyists were asked about challenges to complying 
with the Act, they did not all provide feedback on specific challenges 
to compliance and some lobbyists may have provided feedback on more 
than 1 challenge to complying with the Act. 

[End of figure] 

Most lobbyists we interviewed rated the terms associated with LD-2 
reporting requirements as "very easy" or "somewhat easy" to understand 
with regard to meeting their reporting requirements. Figure 3 shows 
how lobbyists rated the ease of understanding the terms associated 
with LD-2 reporting. 

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 authority and resources to 
enforce compliance with LDA requirements, including imposing civil or 
criminal penalties for noncompliance. Noncompliance of LDA reporting 
requirements refers to the lobbying firm's failure to file its 
quarterly LD-2 disclosure reports and semiannual LD-203 reports on 
certain political contributions by the filing deadline. In our 2012 
report, we described the Office's process for addressing referrals 
received from the Secretary of the Senate and Clerk of the 
House.[Footnote 25] Additionally, we described the Office's staff and 
use of its LDA database to pursue enforcement actions and centralize 
the process of checking and resolving referrals. The LDA database 
allows the Office to track when LD-2 and LD-203 referrals are 
received, record reasons for referrals, record actions taken to 
resolve them, and assess the results of actions taken. 

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 lobbyists 
to comply with the law by promptly filing the appropriate disclosure 
reports, and inform lobbyists of potential civil and criminal 
penalties for not complying. In addition to sending letters, a 
contractor sends e-mails and calls lobbyists to inform them of their 
need to comply with LDA reporting requirements. Not all referred 
lobbyists receive noncompliance letters, e-mails, or phone calls 
because some of the lobbyists have terminated their registrations or 
filed the required financial disclosure reports before the Office 
received the referral. 

Typically, lobbyists resolve their noncompliance issues by filing the 
reports or terminating their registration. As we previously reported, 
resolving referrals can take anywhere from a few days to years 
depending on the circumstances.[Footnote 26] During this time, the 
Office continues to monitor and review all outstanding referrals and 
uses summary reports from the database to track the overall number of 
referrals that become compliant as a result of receiving an e-mail, 
phone call, or noncompliance letter. According to officials from the 
Office, more referred lobbyists are being contacted by e-mail and 
phone calls, which has decreased the number of noncompliance letters 
the Office sends to lobbyists. Officials from the Office stated that 
the majority of these e-mails and calls result in the registrant 
becoming compliant without sending a letter. Currently, the system 
collects information on contacts made by e-mail and phone calls in the 
notes section of the referral entry in the database, but does not 
automatically tabulate the number of e-mails and phone calls to 
lobbyists, as it does for letters sent. Officials stated they would 
consider developing a mechanism for tracking e-mails and phone calls. 

Status of LD-2 Enforcement Efforts for the 2009, 2010, 2011 and 2012 
Reporting Periods: 

As of March 5, 2013, the Office had received approximately 2,062 
referrals from both the Secretary of the Senate and the Clerk of the 
House for noncompliance with LD-2 requirements for the 2009, 2010, 
2011, and 2012 reporting periods. Table 5 shows the number of 
referrals the Office received and the number of noncompliance letters 
the Office sent during these reporting periods. The number of 
referrals received will not match the number of letters sent because 
some referred lobbyists receive a phone call or e-mail instead of a 
noncompliance letter. Additionally, letters sent includes those sent 
to referred registrants who may have been referred for noncompliance 
with more than one client. According to officials from the Office, the 
Office has not sent any noncompliance letters for the 2012 reporting 
period because it is still processing the referrals it received for 
prior reporting periods. 

Table 5: Number of LD-2 Referrals the U.S. Attorney's Office Received 
and Noncompliance Letters the Office Sent: 

Reporting period: 2009; 
Number of referrals received: 678; 
Number of noncompliance letters sent: 320. 

Reporting period: 2010; 
Number of referrals received: 672; 
Number of noncompliance letters sent: 193. 

Reporting period: 2011; 
Number of referrals received: 577; 
Number of noncompliance letters sent: 179. 

Reporting period: 2012; 
Number of referrals received: 135; 
Number of noncompliance letters sent: 0. 

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

Note: Data for 2009, 2010, and 2012 are as of February 25, 2013. Data 
for 2011 are as of March 5, 2013. 

[End of table] 

As shown in figure 4, about 63 percent (1,311 of 2,062) of all the 
lobbyists who were referred by the Secretary of the Senate and Clerk 
of the House for noncompliance for the 2009, 2010, 2011, and 2012 
reporting periods are now considered compliant because lobbyists 
either filed their reports or terminated their registrations. In 
addition, some of the referrals were found to be compliant when the 
Office received the referral, and therefore no action was taken. This 
may occur when 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. About 36 percent (734 of 2,062) of 
referrals are pending action because the Office was unable to locate 
the lobbyist, did not receive a response from the lobbyist, or plans 
to conduct additional research to determine if it can locate the 
lobbyist. The remaining 1 percent (17 of 2,062) of referrals did not 
require action or were suspended because the lobbyist or client was no 
longer in business or the lobbyist was deceased. The Office suspends 
enforcement actions against registrants that are repeatedly referred 
for not filing disclosure reports, but do not have any lobbying 
activity. The suspended registrants are periodically monitored to 
determine whether the registrants actively lobby in the future. As a 
part of this monitoring, the Office checks the lobbying disclosure 
databases maintained by the Secretary of the Senate and the Clerk of 
the House. Also, the Office's Civil Division staff discusses the 
status of pending and suspended referrals with the Secretary of the 
Senate and Clerk of the House contacts to determine whether to 
continue enforcement actions, which includes considering legal actions 
or dismissing certain referrals. 

Figure 4: Status of LDA Enforcement Actions for LD-2 Reporting: 

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

2009: 
Number of referrals received: 678;      
Referrals now compliant: 565; 
Referrals pending action: 111; 
Referrals with no action taken or suspended: 2. 

2010: 
Number of referrals received: 672; 
Referrals now compliant: 529; 
Referrals pending action: 128; 
Referrals with no action taken or suspended: 15. 

2011: 
Number of referrals received: 577; 
Referrals now compliant: 216; 
Referrals pending action: 361; 
Referrals with no action taken or suspended: 0. 

2012: 
Number of referrals received: 135; 
Referrals now compliant: 1; 
Referrals pending action: 134; 
Referrals with no action taken or suspended: 0, 

Totals: 
Number of referrals received: 2,062; 
Referrals now compliant: 1,311; 
Referrals pending action: 734; 
Referrals with no action taken or suspended: 17. 

Referrals now compliant: 63%; 
Referrals pending action: 36%; 
Referrals with no action taken or suspended: 1%. 

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

Note: Data for 2009, 2010, and 2012 are as of February 25, 2013. Data 
for 2011 are as of March 5, 2013. 

[End of figure] 

Status of LD-203 Enforcement Actions for the 2009, 2010, and 2011 
Reporting Periods: 

As of March 5, 2013, the Office has also received approximately 2,472 
referrals from the Secretary of the Senate and the Clerk of the House 
for noncompliance with LD-203 requirements for the 2009, 2010, and 
2011 reporting periods. For LD-203 referrals, 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. As of February 25, 2013, the Office 
has mailed LD-203 noncompliance letters to approximately 62 percent 
(482 of 773) of the referrals for the 2009 reporting period and 21 
percent (270 of 1,296) of the referrals for the 2010 reporting period. 
According to officials from the Office, the Office is still processing 
the LD-203 referrals it received for the 2011 reporting period and has 
not yet sent noncompliance letters. Officials said they have not 
addressed the 2011 referrals because they have been focusing on the 
referrals for prior years. Table 6 shows the number of referrals the 
Office received for noncompliance with the LD-203 reports filed for 
the 2009, 2010, and 2011 reporting periods and the number of letters 
sent by the Office. 

Table 6: Number of LD-203 Referrals the U.S. Attorney's Office 
Received and Noncompliance Letters the Office Sent: 

Reporting period: 2009; 
Number of referrals received: 773; 
Number of noncompliance letters sent: 482. 

Reporting period: 2010; 
Number of referrals received: 1296; 
Number of noncompliance letters sent: 270. 

Reporting period: 2011; 
Number of referrals received: 403; 
Number of noncompliance letters sent: 0. 

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

Note: Data for 2009, and 2010 are as of February 25, 2013 and 2011 
data are as of March 5, 2013. 

[End of table] 

As shown in figure 5, about 45 percent (1,122 of 2,472) of the 
lobbyists who were referred by the Secretary of the Senate and Clerk 
of the House for noncompliance for the 2009, 2010, and 2011 reporting 
periods are now considered in compliance because lobbyists either have 
filed their reports or have terminated their registrations. About 55 
percent (1,349 of 2,472) of the referrals are pending action because 
the Office was unable to locate the lobbyist, did not receive a 
response from the lobbyist, or plans to conduct additional research to 
determine if it can locate the lobbyist. 

Figure 5: Status of LDA Enforcement Actions for LD-203 Reporting: 

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

2009: 
Number of referrals received: 773;      
Referrals now compliant: 480; 
Referrals pending action: 293. 

2010: 
Number of referrals received: 1,296; 
Referrals now compliant: 597; 
Referrals pending action: 699. 

2011: 
Number of referrals received: 403; 
Referrals now compliant: 45; 
Referrals pending action: 357. 

Totals: 
Number of referrals received: 2,427; 
Referrals now compliant: 1,122; 
Referrals pending action: 1,349. 

Referrals now compliant: 45%; 
Referrals pending action: 55%. 

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

Note: Data for 2009, and 2010 are as of February 25, 2013 and 2011 
data are as of March 5, 2013. 

[End of figure] 

Many of the pending LD-203 referrals represent lobbyists who no longer 
lobby for the organizations affiliated with the referrals, even though 
these organizations may be listed on the original lobbyist 
registration. Office officials stated that they continue to experience 
challenges with increasing LD-203 compliance because the Office has 
little leverage to bring individual lobbyists into compliance. Office 
officials said that there have been complaints within the lobbying 
community regarding responsibility for responding to letters of 
noncompliance with LD-203 requirements. Although firms are not 
responsible for an individual lobbyist's failure to comply with the LD-
203 disclosure requirement, nor are firms required to provide contact 
information for the noncompliant lobbyist, Office officials stated 
that many firms have assisted them by providing contact information 
for lobbyists, and only a few firms have not been willing to provide 
contact information for noncompliant lobbyists. Officials said they 
have often suggested to registrants to terminate or inactivate 
lobbyists from the client and firm registration when the lobbyists 
leave the firm. Many of the LD-203 referrals remain open in an attempt 
to locate individual lobbyists, and may take years to resolve. 

Enforcement Settlement Actions: 

We previously reported that the Office developed a system to track 
lobbyists and lobbying firms that have a history of chronic 
noncompliance and have repeatedly been referred by the Senate and 
House for failing to file disclosure reports.[Footnote 27] Officials 
reported that as a result of the tracking system and the actions of 
staff assigned to these cases, the Office has been able to identify 
more noncompliant lobbyists for civil enforcement action. In 2011, the 
Office settled its first enforcement case since the enactment of HLOGA 
in 2007, reaching a $45,000 settlement with a lobbying firm.[Footnote 
28] The firm has fully complied with its outstanding and ongoing 
reporting requirements. 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. 

Officials reported that for the 2012 reporting period, the Office sent 
demand letters, made phone contacts or sent emails to eight 
registrants on the chronic offenders list. Demand letters list the 
number of times the registrant was referred by the Secretary of the 
Senate and Clerk of the House; describe the number of occasions that 
lobbying disclosure reports were not filed by the deadline; and 
request registrants to immediately file the outstanding reports and 
contact the Office within 10 days to resolve the matter. Four of the 
registrants filed the outstanding reports or terminated their 
registration after being contacted by an Assistant U.S. Attorney. 
Additionally, in September 2012, the Office reached settlement 
agreements with two of the registrants from the chronic offenders 
list. One firm agreed to pay $50,000 and the other $30,000 in civil 
penalties for repeatedly failing to file disclosure reports. As of 
March 2013, both firms have paid the fines in full and complied fully 
with their outstanding and ongoing reporting requirements. The Office 
sent demand letters to the remaining two registrants from the chronic 
offenders list on February 4, 2013. As of March 5, 2013, the two 
registrants have not responded to the demand letters. The Assistant 
U.S. Attorney is preparing a memorandum to request legal authority to 
pursue civil or criminal penalties against both registrants. Civil 
Division management will review this request and determine the 
appropriate action. 

The Office continues to monitor and review the chronic offenders list 
to determine whether to continue enforcement actions, which includes 
considering legal actions or dismissing certain cases. 

Agency Comments: 

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

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

If you or your staff have any questions about this report, please 
contact me at (202) 512-6806 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. 

Singed by: 

J. Christopher Mihm: 
Managing Director, Strategic Issues: 

List of Committees: 

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

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

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

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

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

The Honorable Darrell E. Issa: 
Chairman: 
The Honorable Elijah E. Cummings: 
Ranking Member: 
Committee on Oversight and 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 challenges and potential improvements to compliance, if 
any; and: 

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

To respond to our mandate, we used information in the lobbying 
disclosure database maintained by the Clerk of the House of 
Representatives (Clerk of the House). To assess whether these 
disclosure data were sufficiently reliable for the purposes of this 
report, we reviewed relevant documentation and spoke to officials 
responsible for maintaining the data. Although registrations and 
reports are filed through a single web portal, each chamber 
subsequently receives copies of the data and follows different data 
cleaning, processing, and editing procedures before storing the data 
in either individual files (in the House) or databases (in the 
Senate). Currently, there is no means of reconciling discrepancies 
between the two databases caused by the differences in data 
processing. For example, Senate staff told us during previous reviews 
that they set aside a greater proportion of registration and report 
submissions than the House for manual review before entering the 
information into the database, 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 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 2011and 
the first and second quarters of calendar year 2012, as well as for 
sampling year-end 2011 and midyear 2012 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 2011 and the first and second quarters of 2012. We excluded reports 
with no lobbying activity or with income less than $5,000 from our 
sampling frame.[Footnote 29] We drew our sample from 49,286 activity 
reports filed for the third and fourth quarters of 2011 and the first 
and second quarters of 2012 available in the public House database, as 
of our final download date for each quarter. One LD-2 report in the 
sample was amended after the lobbyist was notified of being selected 
for the sample but prior to the review. As a result, we excluded this 
report from our sample and replaced it with another LD-2 report for 
the same quarter. Our sample was not designed to detect differences 
over time and we did not conduct tests of significance for changes 
from 2010 to 2012. 

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 10.5 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 disclose properly 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 2011 or midyear 2012 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 2011 and the first and second quarters of 2012, 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 2,753, or 90 percent, of the 
3,074 newly filed registrations. We began by standardizing client and 
registrant names in both the report and registration files (including 
removing punctuation and standardizing words and abbreviations, such 
as "company" and "CO"). We then matched reports and registrations 
using the House identification number (which is linked to a unique 
registrant-client pair), as well as the names of the registrant and 
client. For reports we could not match by identification number and 
standardized name, we also attempted to match reports and 
registrations by client and registrant name, allowing for variations 
in the names to accommodate minor misspellings or typos. For these 
cases, we used professional judgment to determine whether cases with 
typos were sufficiently similar to consider as matches. We could not 
readily identify matches in the report database for the remaining 
registrations using electronic means. 

To assess the accuracy of the LD-203 reports, we analyzed stratified 
random samples of LD-203 reports from the 31,894 total LD-203 reports. 
The first sample contains 80 reports of the 10,948 reports with 
political contributions and the second contains 80 reports of the 
20,946 reports listing no contributions. Each sample contains 40 
reports from the year-end 2011 filing period and 40 reports from the 
midyear 2012 filing period. The samples from 2012 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 8.6 
percentage points or less, and to within 4.7 percentage points of 
estimate when analyzing both samples together. Our sample was not 
designed to detect differences over time and we did not conduct tests 
of significance for changes from 2010 to 2012. We analyzed the 
contents of the LD-203 reports and compared them to contribution data 
found in the publicly available Federal Elections Commission's (FEC) 
political contribution database. We interviewed 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 explain 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. Our estimates of the percentage of reports that omit 
contributions is a lower-bound estimate. We did not estimate the 
percentage of other non-FEC political contributions that were omitted 
because they tend to constitute a small minority of all listed 
contributions and cannot be verified against an external source. 

To identify challenges to compliance, we used structured interviews 
and obtained the views from 90 different lobbying firms included in 
our sample of 100 LD-2 reports rather than on the total number of 
interviews conducted, on any challenges to compliance. To obtain their 
views, we asked them to rate their ease with complying with the LD-2 
disclosure requirements using a scale, of "very easy", "somewhat 
easy", "somewhat difficult" or "very difficult." In addition, using 
the same scale we asked them to rate the ease of understanding the 
terms associated with LD-2 reporting requirements. 

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

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 2012 through April 2013 
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 7). 

Table 7: Names of Registrants and Clients Selected in Random Sample of 
Lobbying Disclosure Reports Filed in the Third and Fourth Quarters of 
2011 and the First and Second Quarters of 2012: 

Registrant Name: Aduston Consulting, LLC; 
Client: Escape Media Group, Inc. 

Registrant Name: Aegon USA, LLC; 
Client: Aegon USA, LLC. 

Registrant Name: Aerospace Industries Association of America, Inc.; 
Client: Aerospace Industries Association of America, Inc. 

Registrant Name: Akerman Senterfitt; 
Client: Corinthian Colleges, Inc. 

Registrant Name: Albertine Enterprises, Inc.; 
Client: Trinity Industries Inc. (Purchased/Formerly Quixote ). 

Registrant Name: Alliance One; 
Client: Empire District Electric Company. 

Registrant Name: Arent Fox LLP; 
Client: Lake Erie College of Osteopathic Medicine. 

Registrant Name: Arnold & Porter LLP; 
Client: Dutch Association of Insurers. 

Registrant Name: Baker Donelson Bearman Caldwell & Berkowitz; 
Client: Metro Gold Line Foothill Extension Construction Authority. 

Registrant Name: Ball Janik LLP; 
Client: Port of Hood River, Oregon. 

Registrant Name: Barbara Zylinski; 
Client: Qinetiq North America. 

Registrant Name: Barbara Zylinski; 
Client: Qinetiq North America. 

Registrant Name: Bracy Tucker Brown & Valanzano, Inc.; 
Client: Future of Music Coalition. 

Registrant Name: California Hospital Association; 
Client: California Hospital Association. 

Registrant Name: Capitol City Group, Ltd.; 
Client: Ameresco. 

Registrant Name: Capitol Tax Partners LLP; 
Client: Invesco Ltd. 

Registrant Name: Cassidy & Associates, Inc. (formerly known as Cassidy 
& Associates); 
Client: Afton Chemical, Inc. 

Registrant Name: Cassidy & Associates, Inc. (formerly known as Cassidy 
& Associates); 
Client: Elmira College. 

Registrant Name: Cavarocchi Ruscio Dennis Associates, L.L.C.; 
Client: Marshall University Research Corporation. 

Registrant Name: Chad Bradley & Associates, L.L.C.; 
Client: Portland Cement Association. 

Registrant Name: Chambers, Conlon & Hartwell, LLC; 
Client: Alaska Railroad. 

Registrant Name: Chambers, Conlon & Hartwell, LLC; 
Client: Southern California Regional Rail Authority. 

Registrant Name: CIT Group Inc.; 
Client: CIT Group Inc. 

Registrant Name: Clark Hill PLC; 
Client: Van Andel Institute. 

Registrant Name: Consumer Specialty Products Association; 
Client: Consumer Specialty Products Association. 

Registrant Name: Cornerstone Government Affairs, LLC; 
Client: Cotton Growers Warehouse Association. 

Registrant Name: Covington & Burling LLP; 
Client: Credit Suisse. 

Registrant Name: Covington & Burling LLP; 
Client: Union Pacific Corporation. 

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

Registrant Name: Edington, Peel & Associates, Inc.; 
Client: Gavi Alliance (formerly known as the Gavi Fund). 

Registrant Name: Environmental Working Group; 
Client: Environmental Working Group. 

Registrant Name: Ferguson Group; 
Client: Buchanan County-MO. 

Registrant Name: Fierce, Isakowitz & Blalock; 
Client: Apria Healthcare. 

Registrant Name: General Mills; 
Client: General Mills. 

Registrant Name: Hart Health Strategies; 
Client: American College of Mohs Surgeons. 

Registrant Name: Healthpartners, Inc.; 
Client: Healthpartners, Inc. 

Registrant Name: Heather Podesta + Partners, LLC; 
Client: Aramark. 

Registrant Name: Hecht Spencer and Associates, Inc; 
Client: 3M Company. 

Registrant Name: Hengen Group, LLC; 
Client: Hyperion Technology Group, Inc. 

Registrant Name: Holland & Knight LLP; 
Client: Hubbard Broadcasting. 

Registrant Name: Holly Stevens; 
Client: American Pacific Corp. 

Registrant Name: Hughes Hubbard & Reed; 
Client: HBO Latin America Production Services. 

Registrant Name: International Dairy Foods Association; 
Client: International Dairy Foods Association. 

Registrant Name: J.G. Ferguson & Associates, LLC; 
Client: Innovative Solutions Group (ISG). 

Registrant Name: Jones, Walker, Waechter, Poitevent, Carrere & Denegre; 
Client: Sasol North America, Inc. 

Registrant Name: K&L Gates LLP; 
Client: Pitney Bowes. 

Registrant Name: Kelley Drye & Warren LLP; 
Client: Allegheny Technologies Inc. 

Registrant Name: Khalil G. Saliba; 
Client: Northwestern Mutual Life Insurance. 

Registrant Name: Locke Lord Strategies, LP; 
Client: Financial Planning Coalition. 

Registrant Name: McAllister & Quinn LLC; 
Client: Intelligent Optical Solutions, Inc. 

Registrant Name: McBee Strategic Consulting, LLC; 
Client: VantagePoint Management, Inc. 

Registrant Name: Mercury/Clark & Weinstock (formerly known as Mercury); 
Client: HP Enterprise Services. 

Registrant Name: Mercury/Clark & Weinstock; 
Client: Martin County Board of County Commissioners. 

Registrant Name: Mitch Rose Strategic Consulting LLC; 
Client: National Business Aviation Association, Inc. 

Registrant Name: ML Strategies, LLC; 
Client: Suniva, Inc. 

Registrant Name: Molly Dye; 
Client: Mueller Water Products, Inc. 

Registrant Name: Morrison Public Affairs Group; 
Client: American Hospital Association. 

Registrant Name: Museum of Science and Industry; 
Client: Museum of Science and Industry. 

Registrant Name: National Association of Chemical Distributors; 
Client: National Association of Chemical Distributors. 

Registrant Name: National Environmental Strategies; 
Client: Cenovus Energy. 

Registrant Name: National Environmental Strategies; 
Client: Coalbed Methane Association of Alabama. 

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

Registrant Name: National Group LLP; 
Client: Rochester Institute of Technology. 

Registrant Name: Nelson, Mullins, Riley & Scarborough; 
Client: Pharmaceutical Industry Labor Management Association (PILMA). 

Registrant Name: Nixon Peabody LLP; 
Client: Council for Affordable Housing and Rural Development. 

Registrant Name: Nossaman LLP (formerly Nossaman LLP/O'Connor & 
Hannan); 
Client: M&T Bank. 

Registrant Name: Ogilvy Government Relations; 
Client: ACCUS. 

Registrant Name: Ogilvy Government Relations; 
Client: American Petroleum Institute. 

Registrant Name: O'Neill and Associates; 
Client: Avantair Inc. 

Registrant Name: Peck, Madigan, Jones & Stewart, Inc.; 
Client: The Ickes & Enright Group, Inc. (on behalf of North Shore-LIJ 
Health System). 

Registrant Name: Petrizzo Bond, Inc; 
Client: Seattle Cancer Care Alliance. 

Registrant Name: Polk Consulting LLC; 
Client: SunCoke Energy, Inc. 

Registrant Name: Polsinelli Shughart PC; 
Client: Hearth, Patio & Barbecue Association. 

Registrant Name: Portland Cement Association; 
Client: Portland Cement Association. 

Registrant Name: Prime Policy Group; 
Client: Cummins Inc. 

Registrant Name: Science Applications International Corporation; 
Client: Science Applications International Corporation. 

Registrant Name: SNR Denton LLP; 
Client: SMS Holdings Corporation. 

Registrant Name: Solar Energy Industries Association; 
Client: Solar Energy Industries Association. 

Registrant Name: Strategic Health Care; 
Client: HealthEast. 

Registrant Name: Stuntz Davis & Staffier, P.C.; 
Client: County of Los Angeles. 

Registrant Name: Susan Carr & Associates; 
Client: Innovative Federal Strategies, LLC. 

Registrant Name: The Dow Chemical Company; 
Client: The Dow Chemical Company. 

Registrant Name: The Franklin Partnership; 
Client: Cobham. 

Registrant Name: The Glover Park Group LLC; 
Client: Coca-Cola. 

Registrant Name: The McManus Group; 
Client: Pharmaceutical Research and Manufacturers of America. 

Registrant Name: The Moffett Group, LLC; 
Client: Caithness Energy. 

Registrant Name: The Normandy Group, LLC; 
Client: Becker College. 

Registrant Name: The Walter Group; 
Client: American Assoc. of People with Disabilities. 

Registrant Name: The Washington Tax Group LLC; 
Client: R&D Alternative Simplified Credit Coalition. 

Registrant Name: Theodore (Ted) Jones; 
Client: Advanced Computer and Communications, LLC. 

Registrant Name: University of Pittsburgh Medical Center; 
Client: University of Pittsburgh Medical Center. 

Registrant Name: Van Scoyoc Associates; 
Client: International Technological University. 

Registrant Name: Van Scoyoc Associates; 
Client: Mobile County Commission. 

Registrant Name: Volvo Group North America, LLC; 
Client: Volvo Group North America, LLC. 

Registrant Name: Volvo Group North America, LLC; 
Client: Volvo Group North America, LLC. 

Registrant Name: Walker, Martin & Hatch, LLC; 
Client: Pharmaceutical Research & Manufacturers of America. 

Registrant Name: Washington Strategic Consulting; 
Client: JFK Health System. 

Registrant Name: Wexler & Walker Public Policy Associates; 
Client: The Huntsville Hospital Foundation. 

Registrant Name: Williams & Jensen, PLLC.; 
Client: Abbott Laboratories. 

Registrant Name: Williams & Jensen, PLLC.; 
Client: Research Society on Alcoholism. 

Source: Lobbying disclosure database of the Clerk of the House of 
Representatives for the third and fourth quarters of calendar year 
2011 and the first and second quarters of calendar year 2012. 

[End of table] 

[End of section] 

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

See table 8 for a list of lobbyists and lobbying firms from our random 
sample of lobbying contribution reports with contributions. See table 
9 for a list of lobbyists and lobbying firms from our random sample of 
lobbying contribution reports without contributions. 

Table 8: Lobbyists and Lobbying Firms in Random Sample of Lobbying 
Contribution Reports with Contributions Listed, Filed Year-end 2011 
and Midyear 2012: 

Lobbyist or lobbying firm: Aaron Whitesel; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Alexander Silbey; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Alison Weiss; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: American Foreign Service Association; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: American Horse Council; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: American Hospital Assn.; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Amy Roberti; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Arshi Siddiqui; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Barbara Benham; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Barnes & Thornburg LLP; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Bertram Carp; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Brian Heindl; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Brian Moran; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Camille Fleenor; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Charles Merin; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Chevron U.S.A. Inc.; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Christina Hamilton; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Christopher Chwastyk; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: CML Consulting Services Inc.; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Constantinople & Vallone Consulting LLC; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: David Colangelo; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: David Kozak; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Florence Prioleau; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Footwear Distributors & Retailers of 
America; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Fred McDuff; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Frederic Mills; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Fredrick Palmer; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Graham Shalgian; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Grant Consulting Group; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Health Management Systems; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: International Federation of Professional 
and Technical Engineers (IFPTE); 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Jack Ferguson; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: James Backlin; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: James Gigrich; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: James Meltsner; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Jane Calderwood; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Jay Rosenblum; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Jeffrey Speaks; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Jerry Straus; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Joel Lisker; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Johnson Controls, Inc; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Jon Sender; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Joseph Webster; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Kurt Wimmer; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Lauch Faircloth; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Lawrence Duncan; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Lindsey Ledwin; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Louis Finkel; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Marc Dibella; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Matt Trant; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Michael Brzica; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: National Grain and Feed Association; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Newmont Mining Corporation; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Nick Manetto; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Paul Mica; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Peter Loughlin; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Peter Madigan; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Pillsbury Winthrop Shaw Pittman LLP; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Printing Industries of America, Inc.; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Prudential Financial Inc.; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: R.D. Folsom; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Randall West; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Randolph Cloud; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Rebecca Hyder; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Richard Collins; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Robert Wrigley; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Ron Carlton; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Sandy Marks; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Sean Bersell; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Sean Kennedy; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Sierra Club; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Stacey Hughes; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Stanley Rapp; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Stephen Francis; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Ted Monoson; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Trans Union LLC; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: William Frymoyer; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: William McCann; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: William Signer; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Wine and Spirits Wholesalers of America, 
Inc; 
Reporting period: Midyear 2012. 

Source: Lobbying contributions database of the Clerk of the House of 
Representatives, Year-end reports for calendar year 2011 and midyear 
reports for calendar year 2012. 

[End of table] 

Table 9: Lobbyists and Lobbying Firms in Random Sample of Lobbying 
Contribution Reports with No Contributions Listed, Filed Year-end 2011 
and Midyear 2012: 

Lobbyist or lobbying firm: Advanced Strategies; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Abigail Stork; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Alan Ross; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Amanda Kadilak; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Andrew Borene; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Ann Waldo; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Anne Duffy; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: APSE: The Network on Employment; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Augustine Tantillo; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Bartlett Naylor; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Brian Eury; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Brian Meighan; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Brian Smith; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: C. Edward Watson; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Caroline Schellhas; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Catriona MacDonald; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Christopher Van Atten; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Christopher Woodside; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Daniel McCarthy; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Debra Cohn; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Dion Spencer; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Douglas Ralph; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Elizabeth Varley; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Food & Water Watch; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Frank McGlynn; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Fred Griesbach; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Gene Lange; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Grigsby Government Relations Associates, 
LLC; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Grizzle Company; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: H. Miller; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: H. Lee Moffitt Cancer Center & Research 
Institute; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Heidi Rudolph; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Iowa Farm Bureau Federation; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: James Roewer; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Jay Eizenstat; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Jim Goldstein; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Joe Panetta; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: John Kalavritinos; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: John Waters; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Julia J. Norrell; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Julie Hyams; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: K. Browder; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Katharine Huffman; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Katharine Kratovil; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Katherine McGuire; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Kathryn Dibitetto; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Kathryn Richardson Cannie; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Kathy Van Kleeck; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Keith Kupferschmid; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Leann Fox; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: M. Arky; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Marc Schurger; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Matthew Sturm; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Megan Montgomery; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Michael Hofkes; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Michael Kans; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Modular Building Institute; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: National Defense Industrial Assn. (NDIA); 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: National Safety Council; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Nicole Carelli; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Peter Lawrence; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Portland State University; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Reuben Smith-Vaughan; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Ricardo Bernal; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Robert Hilton; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Robert Juliano; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Shannon O'Keefe; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Smits Speidell Consulting; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Stephen Scofes; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Strategic Partners, Inc.; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Sutherland Asbill & Brennan LLP; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Tara Hairston; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Tavarski Hughes; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: The Fashion Institute of Design & 
Merchandising; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: The Tim Hugo Group; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Thomas Bliley; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Thomas Jeffers; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: URS Corporation; 
Reporting period: Midyear 2012. 

Lobbyist or lobbying firm: Vito Fossella; 
Reporting period: Year-end 2011. 

Lobbyist or lobbying firm: Whitney Gardiner; 
Reporting period: Midyear 2012. 

Source: Lobbying contributions database of the Clerk of the House of 
Representatives, Year-end reports for calendar year 2011 and midyear 
reports for calendar year 2012. 

[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, Bill Reinsberg, Assistant 
Director; Shirley Jones, Assistant General Counsel; Crystal Bernard, 
Amy Friedlander, Robert Gebhart, Lois Hanshaw, Stuart Kaufman, Natalie 
Maddox, and Anna Maria Ortiz made key contributions to this report. 

Assisting with lobbyist file reviews were Vida Awumey, Peter Beck, 
Benjamin Crawford, Alexandra Edwards, Hayley Landes, Latesha Love, 
Alan Rozzi, Stacy Spence, Megan Taylor, Daniel Webb, Jason Wildhagen, 
and Weifei Zheng. 

[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] 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. 

[5] 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. 

[6] 2 U.S.C. § 1602(10). 

[7] 2 U.S.C. § 1602(9). 

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

[9] 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). 

[10] See GAO, 2011 Lobbying Disclosure: Observations on Lobbyists' 
Compliance with Disclosure Requirements, [hyperlink, 
http://www.gao.gov/products/GAO-12-492] (Washington, D.C.: March 30, 
2012); 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); 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). 

[11] 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 10.5 percentage 
points or less of the estimate. 

[12] [hyperlink, http://www.gao.gov/products/GAO-12-492]. 

[13] 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. 

[14] For information on our methodology, see appendix I. See 
[hyperlink, http://www.gao.gov/products/GAO-12-492] and [hyperlink, 
http://www.gao.gov/products/GAO-11-452]. 

[15] 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. 

[16] Our sample was not designed to detect differences over time. See 
[hyperlink, http://www.gao.gov/products/GAO-12-492] and [hyperlink, 
http://www.gao.gov/products/GAO-11-452]. 

[17] According to the Lobbying Disclosure Electronic Filing Manual, 
lobbying firms must immediately file an amended LD-2 report or the LD-
1 registration to make changes: (1) if notified of a defect in the 
original filing by the Secretary of the Senate or Clerk of the House; 
or (2) if erroneously reported information or an omission is 
discovered by the registrant. Updated LD-1 information (name and 
address changes, new lobbyists, and new issue area codes) must be 
disclosed in the registrant's next scheduled report. U.S. Congress, 
Lobbying Disclosure Electronic Filing, Lobbying Registration and 
Reporting System, Windows User Manual (February 2013). 

[18] [hyperlink, http://www.gao.gov/products/GAO-12-492]. 

[19] [hyperlink, http://www.gao.gov/products/GAO-12-492]. 

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

[21] See [hyperlink, http://www.gao.gov/products/GAO-12-492] and 
[hyperlink, http://www.gao.gov/products/GAO-11-452]. 

[22] 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 lobbyists once to ask about 
lobbying disclosure requirements and the clarity of lobbying terms. If 
the interview was conducted on a different date, but with the same 
registrant, we used the information from the first interview meeting. 

[23] Although the percentage estimates from our sample of LD-2 reports 
are generalizable to all LD-2 reports, results from the analysis of 
lobbying firm opinions are not generalizable 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. 

[24] [hyperlink, http://www.gao.gov/products/GAO-12-492]. 

[25] [hyperlink, http://www.gao.gov/products/GAO-12-492]. 

[26] [hyperlink, http://www.gao.gov/products/GAO-12-492]. 

[27] [hyperlink, http://www.gao.gov/products/GAO-12-492]. 

[28] 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. 

[29] 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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