Adding Federal Lobbyists: A Two-Step Method
In the old days—the years preceding HLOGA, it was pretty straightforward when a registrant under the Lobbying Disclosure Act (LDA), such as a corporation or trade association, needed to add a new federal lobbyist. With the advent of mandatory electronic filing and of Form LD-203, however, the complete process has become a bit more complicated—in the technical sense. Below is some technical assistance to ensure 100% compliance.
Form LD-2 -- Pretty Much the Same as Always
To add a new lobbyist, a registrant simply must list on the quarterly LDA report, Form LD-2, the employee on Line 18 of all of the issue pages on which the employee engaged in lobbying activities during the previous calendar quarter. On that line, the registrant must check the box for "new" and list the covered positions held by the employee during the previous 20 years. (This process is the same as it always has been except that the covered positions must be reported for 20 years instead of for two.)
Form LD-203— New System, New Technical Issues
Unfortunately, the system for quarterly LDA reports and the system for the semiannual LDA contribution and gift reports, Form LD-203, do not necessarily share all information. As a result and in order to ensure that both systems have complete information about new lobbyists, a registrant should take the following steps in the Form LD-203 system, which can be accessed here and selecting LD-203 Contributions in the blue menu bar.
To identify a new lobbyist the registrant is responsible for activating an account for the lobbyist. The following steps are necessary for a new account activation:
(1) Access the Lobby Disclosure web page for the Office of the Clerk of the House.
(2) Sign in to the Lobby Contributions System with the Senate ID and password established previously.
(3) After logging in, select "Manage Lobbyists" and complete the following four steps to properly activate a lobbyist:
Click on the "Add New Lobbyist" button.
The "Add New Lobbyist" screen will be displayed -- enter the new lobbyist name in the appropriate fields. A phone number and email address for the lobbyist will be required.
Click in the box next to "Effective Date" to display the calendar. Select the date the lobbyist began actively lobbying, and that date will appear in the "Effective Date" field.
Click the "Add Lobbyist" button.
(4) You will now be returned to the "Manage Lobbyist" page. If you need to activate additional new lobbyists, follow the steps outlined above. Once you have completed updating your lobbyist account, click "Sign Out" at the upper right corner on the "Manage Lobbyist" page, and all modifications will be uploaded into the Lobby Contribution System.
Lobbyist accounts are unique to each registered lobbyist. Once the registrant has added a lobbyist to the registrant's account and this has been processed by the system, an email will be sent directly to the lobbyist with instructions on how to activate the account and create a personal password.
For step-by-step instructions on terminating lobbyists, please see the November 2008 issue of Election Law News.
*Mr. Shriver is the Manager of the Legislative Services division of the Wiley Rein LLP legal library and is responsible for executing the LDA filings made by Wiley Rein.