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The end of the second quarter is a good time to terminate individuals who will no longer serve as lobbyists because they can end their LD-203 obligations with this mid-year report. If the individuals do not have a reasonable expectation of being a lobbyist in the current or next quarter, then the Guidance says that the individual may be terminated. A lobbyist is someone who has made more than one lobbying contact (ever) and spends more than 20 percent of his or her time on lobbying activity in a three-month period. Thus, if an individual is changing roles, or the organization has determined that the person does not (and will not in the next quarter) spend 20 percent of his or her time on lobbying activity, then termination is appropriate. Remember, an organization can always re-list the person if things change.

Lobbying

Terminating is different than just not listing someone on the report. Rather, you have to use the update page (Line 23) to list the person as someone who will not be a lobbyist in the future.

LD-2 pic

If you know a lobbyist will be leaving the organization in the near future, think hard about whether that person’s activities in the next quarter will rise to the level of being a lobbyist. It is far easier to terminate now and avoid being responsible for a year-end LD-203 next January than to keep the person on for another quarter.

Finally, many people forget that a person may be listed as a lobbyist on the current report and simultaneously terminated. This is possible if a person will no longer anticipate making lobbying contacts (e.g., because he is leaving the organization at the end of the quarter) or is moving to a non-lobbying job and will cease making contacts. It is also possible if the person no longer spends 20 percent of his or her time on lobbying activity.