First quarter lobbying disclosure reports are due on Monday, April 20. This report, the LD-2, is where organizations report their expenses for federal lobbying efforts. The first quarter of a year is often a good time to evaluate your organization’s recordkeeping and processes for filling out the report and to determine what changes may need to be made. Keep in mind these key aspects of preparing the report:
- Calculating expenses. Take time to make sure your organization is capturing all expenses that the Lobbying Disclosure Act requires be included. The first quarter of a year is often the best time to make sure you’re using updated salary information for employees involved in federal lobbying and accounting for year-end raises, bonuses, and/or benefits changes. Your organization may also pay more trade association dues at the beginning of a new year.
- What reporting method to use. The first quarter also offers an opportunity to consider which method your organization uses to report lobbying expenses – Method A, B, or C. The choice of reporting method can significantly affect the amount reported for total lobbying expenses.
- Who to list as a lobbyist and who to terminate. The start of a new year may have brought with it some shifts in job duties for employees in your organization. Those changes may impact who should and should not be listed as a lobbyist on the LD-2 report.
- Training on gift and travel rules. An organization that employs or retains federal lobbyists is subject to more stringent limits on gifts to Members of Congress and staff, as well as on gifts to the Administration’s political appointees. Indeed, someone must certify twice a year that the organization is familiar with Congressional ethics rules on gifts and travel. A new reporting year is a good time to review policies and procedures for approving gifts, and scheduling training for public affairs personnel and others who interact with government officials.
- Make sure that reporting by in-house and outside lobbyists is in sync. While each outside lobbyist you retain is responsible for filing his or her own report, it can draw the attention of competitors, watchdog groups, and the media when there is a disparity between how the company describes lobbying issues and activities, and the descriptions of outside lobbying firms. The income and expenses reported by each lobbying firm should also coincide with the amount the company is attributing to that work in its own lobbying report.
- Lots of eyes on these reports. Remember that LD-2 reports are public documents. As such, they often draw scrutiny from regulators, competitors, watchdog groups, and the media. Take the time to characterize issues in a favorable manner that is consistent with the way the organization refers to the same issues in other contexts. If you are lobbying on new issues, consider giving a heads-up to your Public Relations office so they are not blind-sided by media inquiries.