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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

April 2011: 

2010 Lobbying Disclosure: 

Observations on Lobbyists' Compliance with Disclosure Requirements: 

GAO-11-452: 

GAO Highlights: 

Highlights of GAO-11-452, a report to congressional committees. 

Why GAO Did This Study: 

The Honest Leadership and Open Government Act of 2007 requires that 
GAO annually (1) determine the extent to which lobbyists can 
demonstrate compliance with disclosure requirements, (2) identify any 
challenges that lobbyists report to compliance, and (3) 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 its enforcement of the Lobbying Disclosure Act of 1995 
as amended (LDA). This is GAO’s fourth report under the mandate. GAO 
reviewed a stratified random sample of 100 lobbying disclosure reports 
filed from the fourth quarter of calendar year 2009 through the third 
quarter of calendar year 2010. GAO also selected two random samples 
totaling 160 reports of federal political campaign contributions from 
year-end 2009 and midyear 2010. This methodology allowed GAO to 
generalize to the population of 55,282 disclosure reports with $5,000 
or more in lobbying activity. GAO also met with officials from the 
Office regarding efforts to focus resources on lobbyists who fail to 
comply. GAO provided a draft of this report to the Attorney General 
for review and comment. The Assistant U.S. Attorney for the District 
of Columbia responded on behalf of the Attorney General that the 
Department of Justice had no comments on the draft of this report. 

What GAO Found: 

Lobbyists were generally able to provide documentation to support the 
amount of income and expenses reported; however, less documentation 
was provided to support other items in their disclosure reports. This 
finding is similar to GAO’s results from prior reviews. There are no 
specific requirements for lobbyists to create or maintain 
documentation related to disclosure reports they file under the LDA. 

For income and expenses, two key elements of the reports, GAO 
estimates that lobbyists could provide documentation for approximately 
97 percent of the disclosure reports for the fourth quarter 2009 and 
the first three quarters of 2010. According to the documentation 
lobbyists provided for income and expenses, we estimate the amount 
disclosed was supported for 68 percent of disclosure reports. After 
GAO’s review, 21 lobbyists stated that they planned to amend their 
disclosure reports to make corrections on one or more data elements. 
As of March 2011, 12 of the 21 amended their disclosure reports.
For political contributions reports, GAO estimates that a minimum of 2 
percent of reports failed to disclose political contributions that 
were documented in the Federal Election Commission database. 

The majority of lobbyists who newly registered with the Secretary of 
the Senate and Clerk of the House of Representatives in the last 
quarter of 2009 and first three quarters of 2010 filed required 
disclosure reports for that period. GAO could identify corresponding 
reports on file for lobbying activity for 90 percent of registrants.
The majority of lobbyists felt that the terms associated with 
disclosure reporting were clear and understandable. For the few 
lobbyists who stated that disclosure reporting terminology remained a 
challenge, areas of potential inconsistency and confusion in applying 
the terms associated with disclosure reporting requirements have been 
highlighted. Some lobbyists reported a lack of clarity in determining 
lobbying activities versus non-lobbying activities. A few lobbyists 
stated that they misreported on their disclosure reports because they 
carried information from old reports to new reports without properly 
updating information. 

The Office is responsible for enforcement of the LDA and has the 
authority to pursue a civil or criminal case for noncompliance. 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. For calendar years 2008 and 2009, the 
Office sent 1,597 noncompliance letters for disclosure reports and 
political contributions reports. About half of the lobbyists who 
received noncompliance letters are now compliant. In response to an 
earlier GAO recommendation, the Office has developed a system to 
better focus enforcement efforts by tracking and recording the status 
of enforcement activities. The system allows the Office to monitor 
lobbyists who continually fail to file the required disclosure 
reports. The Office stated that they plan to institute procedures to 
formalize data review, refine summary data, and ensure data are 
accurate and reliable in the next few months. 

View [hyperlink, http://www.gao.gov/products/GAO-11-452] or key 
components. For more information, contact J.Christopher Mihm at (202) 
512-6806 or mihmj@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Documentation Supporting Disclosure Reports Varied and Newly 
Registered Lobbyists Largely Met Reporting Requirements: 

A Few Lobbyists Continue to Report Challenges in Complying with the 
Act: 

The U.S. Attorney's Office Has Taken Steps to Improve Its Enforcement 
of the LDA: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: List of Registrants and Clients for Sampled Lobbying 
Disclosure Reports: 

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

Appendix IV: GAO Contact and Staff Acknowledgments: 

Tables: 

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

Table 2: Feedback from Lobbyists in Our Sample of Reports Who Cited 
Challenges to Complying with the Act: 

Table 3: Names of Registrants and Clients Selected in Random Sample of 
Lobbying Disclosure Reports Filed in the Last Quarter of 2009 and 
First Three Quarters of 2010: 

Table 4: Lobbyists and Lobbying Firms Selected in Random Sample of 
Lobbying Contribution Reports with Contributions Listed, Filed Year-
end 2009 and Midyear 2010: 

Table 5: Lobbyists and Lobbying Firms Selected in Random Sample of 
Lobbying Contribution Reports with No Contributions Listed, Filed Year-
end 2009 and Midyear 2010: 

Figures: 

Figure 1: Extent of Documentation Lobbyists Provided to Support 
Selected Elements of Lobbying Reports: 

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

Figure 3: Status of LDA Enforcement Actions (as of January 24, 2011): 

Abbreviations: 

Clerk: Clerk of the House of Representatives: 

DOJ: Department of Justice: 

FEC: Federal Elections 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: 

Secretary: Secretary of the Senate: 

[End of section] 

United States Government Accountability Office: 
GAO: 

April 1, 2011: 

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. GAO is mandated 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] GAO's report 
shall include any recommendations related to improving lobbyists' 
compliance with the LDA and report on resources and authorities 
available to the Department of Justice (DOJ) for effective enforcement 
of the LDA. This is GAO's fourth mandated review of lobbyists' 
disclosure reports filed under the LDA. 

Consistent with our mandate, our objectives were to (1) determine the 
extent to which lobbyists can demonstrate compliance with the LDA, as 
amended, by providing documentation to support information contained 
in reports filed under the LDA; (2) identify any challenges that 
lobbyists report to compliance and potential improvements; and (3) 
describe the resources and authorities available to the U.S. 
Attorney's Office for the District of Columbia (the Office) in its 
role in enforcing compliance with the LDA, and the efforts the Office 
has made to improve its enforcement of the LDA. 

[End of section] 

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

* Selected a stratified random sample of 100 quarterly lobbying 
activity disclosure reports (commonly referred to as LD-2 reports) 
with income and expenses of $5,000 or more filed during the fourth 
quarter of calendar year 2009 and the first, second, and third 
quarters of calendar year 2010, with 25 LD-2 reports in each quarter. 
The randomly sampled reports were selected from the publicly 
downloadable database maintained by the Clerk of the House of 
Representatives. This methodology allows us to generalize to the 
population of these activity reports. 

* Contacted each lobbyist[Footnote 4] in our sample by asking each 
lobbyist to provide supporting documentation for key elements of the 
disclosure report, including the amount of money received for lobbying 
activities, the houses of Congress or federal agencies lobbied, 
lobbying issue areas, lobbyists reported as having worked on the 
issues, prior covered official positions held by lobbyists, and 
whether the lobbyists filed a report of federal political 
contributions. All lobbyists in our sample responded to our requests 
for supporting documentation. 

* Analyzed two random samples of year-end 2009 and midyear 2010 
semiannual reports of federal political contributions (commonly 
referred to as LD-203 reports) disclosing certain contributions, 
comparing the contributions reported to information contained in the 
Federal Elections Commission's (FEC) database. The first sample 
contains 80 LD-203 reports selected that have contributions listed, 
and the second sample contains 80 LD-203 reports selected that list no 
contributions. The randomly sampled reports were selected from the 
publicly downloadable contributions database maintained by the Clerk 
of the House. In instances where an entry in the FEC database could 
not be confirmed by information reported in the LD-203, because the 
contribution was not disclosed on the LD-203, as required, we 
contacted lobbyists and asked them to provide documentation, 
information, or both to clarify differences we observed. All lobbyists 
complied with our request to provide documentation, information, or 
both. This methodology allows us to generalize to the population of LD-
203 reports both with and without contributions. 

* Compared new registrations (commonly referred to as LD-1s) filed in 
the fourth quarter of 2009 and the first three quarters of 2010 to the 
corresponding LD-2 reports on file with the Clerk of the House to 
determine whether registrants were meeting the requirement to file an 
LD-2 report in the first quarter in which they first registered. 

To identify challenges and potential improvements to compliance, we 
used structured interviews to obtain views from lobbyists included in 
our sample of reports on any challenges to compliance. 

To describe the efforts the Office has made to improve its enforcement 
of the LDA, we interviewed officials from the Office and obtained 
information on the capabilities of the system they established to 
track and report compliance trends and referrals and other practices 
they have established to focus resources on enforcement of the LDA; 
the extent to which they have implemented data reliability checks into 
their tracking system; and the level of staffing and resources 
dedicated to lobbying disclosure enforcement. The Office provided us 
with reports from the tracking system on the number and status of 
referrals. 

The mandate does not include identifying lobbyist organizations that 
failed to register and report in accordance with LDA requirements, or 
whether for those lobbyists who did register and report the lobbying 
activity or contributions disclosed represented the full extent of 
lobbying activities that took place. 

We conducted this performance audit from April 2010 to March 2011 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. No specific requirements 
exist for lobbyists to create or maintain documentation in support of 
the reports they file. However, LDA guidance issued by the Secretary 
of the Senate and the Clerk of the House recommends lobbyists retain 
copies of their filings and supporting documentation for at least 6 
years after their reports are filed. 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. 

The LDA requires that the Secretary of the Senate and the Clerk of the 
House of Representatives provide guidance and assistance on the 
registration and reporting requirements of the LDA and develop common 
standards, rules, and procedures for compliance with the LDA. The 
Secretary and the Clerk are to review the guidance semiannually, with 
the latest revision having occurred in June 2010 and the latest review 
having occurred in December 2010. The guidance provides definitions of 
terms in the Act, Secretary and Clerk interpretations of the LDA as 
amended by HLOGA, specific examples of different scenarios, and an 
explanation of why the scenarios prompt or do not prompt disclosure 
under LDA. In meetings with the Secretary and Clerk, they stated that 
they consider information we report on lobbying disclosure compliance 
when they periodically update the guidance. 

The LDA defines a "lobbyist" as an individual who is employed or 
retained by a client for compensation; who has made more than one 
lobbying contact (written or oral communication to a covered executive 
or legislative branch official made on behalf of a client); and whose 
lobbying activities[Footnote 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 are lobbyists 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 
lobbying firm receives or is expected to receive over $3,000 in income 
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 must disclose: 

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

* a list of individuals who acted as lobbyists on behalf of the client 
during the reporting period; 

* whether any lobbyists served as covered executive branch or 
legislative branch officials in the previous 20 years, known as a 
"covered official" position;[Footnote 9] 

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

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

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

* whether the client is a state or local government; 

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

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

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

The LDA, as amended, also requires lobbyists to report certain 
contributions semiannually in the contributions report, also known as 
the LD-203 report. These reports must be filed 30 days after the end 
of a semiannual period by each organization registered to lobby and by 
each individual listed as a lobbyist on an organization's lobbying 
reports. The lobbyists or organizations 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 of 
Representatives, along with the U.S. Attorney's Office for the 
District of Columbia (the Office) are responsible for the enforcement 
of the LDA. The Secretary and the Clerk notify lobbyists or lobbying 
firms in writing that they may be in noncompliance with 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 no 
response is received after 60 days, the Office decides whether to 
pursue a civil case against referred lobbyists which could result in 
penalties up to $200,000 or a criminal case against lobbyists who 
knowingly and corruptly fail to comply with the act that could lead to 
a maximum of 5 years in prison. 

Documentation Supporting Disclosure Reports Varied and Newly 
Registered Lobbyists Largely Met Reporting Requirements: 

Lobbyists for Most LD-2 Reports Provided Documentation to Support the 
Amount of Income and Expenses Reported, but Provided Less 
Documentation to Support Other Elements of the LD-2: 

While no specific requirements exist for lobbyists to create or 
maintain documentation in support of the reports they file, LDA 
guidance issued by the Secretary of the Senate and Clerk of the House 
recommends lobbyists retain copies of their filings and supporting 
documentation for at least 6 years after their reports are filed. 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 were able to 
provide documentation for income and expenses for the fourth quarter 
of 2009 and the first three quarters of 2010.[Footnote 11] The most 
common forms of documentation provided included invoices for income 
and payroll records for expenses. According to the documentation 
lobbyists provided for income and expenses, we estimate that the 
amount disclosed was supported for 68 percent (65 of 96) of the LD-2 
reports; differed by at least $10,000 from the reported amount in 13 
percent (13 of 96) of LD-2 reports;[Footnote 12] and had rounding 
errors in 19 percent (18 of 96) of LD-2 reports.[Footnote 13] 
Lobbyists for an estimated 90 percent of the LD-2 reports filed year-
end 2009 or midyear 2010 LD-203 contribution reports for all of the 
lobbyists and the lobbying firm listed on the report as required. 
[Footnote 14] All individual lobbyists and lobbying firms reporting 
specific lobbying activity are required to file LD-203 reports each 
period even if they have no contributions to report, because they must 
certify compliance with the gift and travel rules. 

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 of Documentation Lobbyists Provided to Support 
Selected Elements of Lobbying Reports: 

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

Estimated percent of reports[B]: 

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

Lobbied the Senate: 
Documentation to support:	79%; 
Some documentation to support[A]:	0%; 
No documentation to support: 21%. 

Issue codes: 
Documentation to support:	85%; 
Some documentation to support[A]:	9%; 
No documentation to support: 6%. 

Individuals acting as lobbyists: 
Documentation to support:	72%; 
Some documentation to support[A]:	21%; 
No documentation to support: 7%. 

Source: GAO 

Note: Not all elements of the report were applicable to all lobbyists. 

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

[B] Percent estimates in the table have a 95 percent confidence 
interval of plus or minus 10 percentage points or less of the estimate. 

[End of figure] 

Of the 100 LD-2 reports in our sample, 52 disclosed lobbying 
activities at executive branch agencies with lobbyists for 28 of these 
reports providing documentation to support lobbying activities at all 
agencies listed. These results are consistent with our findings from 
last year's Lobbying Disclosure report.[Footnote 15] Based on this we 
estimate that approximately 54 percent of all reports disclosing 
executive branch activities could be supported by documentation. 
[Footnote 16] 

The LDA requires lobbyists to disclose previously held covered 
positions when first registering as a lobbyist for a new client, 
either on the lobbying registration (LD-1) or on the first LD-2 
quarterly filing when added as new.[Footnote 17] Of the 100 reports in 
our sample, 15 reports listed lobbyists who did not disclose covered 
positions when they first lobbied on behalf of the client as required 
or on subsequent disclosure reports. [Footnote 18] We therefore 
estimate that a minimum of 9 percent of all LD-2 reports, list 
lobbyists who never properly disclosed one or more previously held 
covered positions. 

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

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

LD-2 report element: Lobbied the houses of Congress; 
Reasons for not having documentation: Several lobbyists said they did 
not keep documentation of certain types of contacts with the houses of 
Congress, such as telephone calls. 

LD-2 report element: Lobbied executive branch agencies; 
Reasons for not having documentation: Several lobbyists said they did 
not keep documentation of certain types of contacts with the executive 
branch agency officials, such as telephone calls. In addition to 
lobbyists not having supporting documentation to demonstrate they 
lobbied executive branch agencies, some lobbyists told us they 
overreported contacts with executive branch agencies. For example, 
lobbyists reported lobbying contacts with executive branch agencies on 
their LD-2 reports when federal officials were in attendance at 
meetings and conferences they attended, even when they did not 
communicate with the federal officials in attendance. Lobbyists said 
they overreported to err on the side of caution and to prevent 
potential underreporting. 

LD-2 report element: Name of individuals acting as lobbyists; 
Reasons for not having documentation: Several lobbyists stated they 
listed all of the lobbyists in their firm on all of the LD-2 reports 
even if they did not actively lobby on behalf of the client. 

LD-2 report element: Covered positions; 
Reasons for not having documentation: Some lobbyists thought the 
position was either outside of the required reporting time frame[A] or 
they were unaware that the position was a covered official position. 
For example, some lobbyists did not know whether congressional 
internships were considered covered official positions and therefore 
needed to be disclosed. According to officials from the Secretary of 
the Senate and Clerk of the House, internships are considered covered 
official positions and therefore should be disclosed. 

Source: GAO. 

[A] 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. 

[End of table] 

Some Lobbyists Indicated They Planned to Amend Their LD-2 Reports: 

For 21 of the LD-2 reports in our sample, lobbyists indicated they 
planned to file an amendment as a direct result of our review. As of 
March 2011, 12 of those 21 lobbyists had filed amended LD-2 reports. 
Reasons for filing amendments varied, but included reporting lobbyists 
covered positions, changing the income or expense amounts previously 
reported, and removing lobbyists who did not lobby on behalf of the 
client during the quarter under review. In addition to the 21 reports 
that lobbyists stated they were going to file an amendment following 
our review, lobbyists filed amendments for 8 of the reports in our 
sample after being notified their report was selected as part of our 
random sample but prior to our review. Specific reasons lobbyists 
filed amendments to change the original filing were to: 

* Report no lobbying activity, reduce the amount of lobbying income 
from $21,000 to less than $5,000, and remove the previously reported 
lobbying contact with the Senate and the House, which the lobbyists 
stated did not occur during the quarter. 

* Add a lobbying contact with the Senate and lower the income reported 
from $10,000 to less than $5,000. 

* Add the client's interest in a foreign entity. 

* Change the client's name, remove and add the name of the federal 
agencies lobbied, remove the earlier reported lobbying contact with 
the Senate, and remove a lobbyist. 

* Add a lobbying contact with the House and add a lobbyist. 

* Add lobbyists. 

* Add a federal agency and remove a bill number. 

* Change the point of contact. 

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

We estimate that a minimum of 5 percent of all LD-203 reports with 
contributions omit one or more FEC-reportable contributions. The 
sample of LD-203 reports we reviewed contained 80 reports with 
political contributions and 80 reports without political 
contributions. We compared those reports against the contribution 
reports in the FEC database to identify any instance when the FEC 
database listed political contributions made by the lobbyists that 
were not disclosed on the lobbyist's LD-203 report. 

Of the 80 LD-203 reports sampled with contributions reported, 7 
sampled reports failed to disclose one or more political contributions 
that were documented in the FEC database. Of the 80 LD-203 reports 
sampled with no contributions reported, 1 of the sampled reports 
failed to disclose political contributions that were documented in the 
FEC database. We estimate that among all reports a minimum of 2 
percent failed to disclose one or more political contributions. 
[Footnote 19] 

Most Newly Registered Lobbyists Filed Disclosure Reports as Required: 

Of the 4,553 new registrations we identified from fiscal year 2010 we 
were able to match 4,132 reports filed in the first quarter in which 
they were registered, which is a match rate of more than 90 percent of 
registrations, similar to our prior reviews.[Footnote 20] To determine 
whether new registrants were meeting the requirement to file, we 
matched newly filed registrations in the last quarter of 2009 and the 
first three quarters of 2010 from the Senate and House Lobbyists 
Disclosure Databases to their corresponding quarterly disclosure 
reports using an electronic matching algorithm that allowed for 
misspelling and other minor inconsistencies between the registrations 
and reports. 

A Few Lobbyists Continue to Report Challenges in Complying with the 
Act: 

LD-2 Reporting Requirement Terminology Remains a Challenge for a Few: 

While most lobbyists we interviewed told us they thought that the 
reporting requirements were clear, a few lobbyists highlighted areas 
of potential inconsistency and confusion in applying some aspects of 
LDA reporting requirements. Several of the lobbyists said that the 
Secretary of the Senate and Clerk of the House staff were helpful in 
providing clarifications when needed. 

As part of our review, lobbyists present during reviews were asked to 
rate various terms associated with LD-2 reporting as being clear and 
understandable, not clear and understandable, or somewhat clear and 
understandable.[Footnote 21] Figure 2 shows the terms associated with 
LD-2 reporting that the lobbyists we interviewed in our sample of 
reports were asked to rate and how they responded to each term. 

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

[Refer to PDF for image: vertical bar graph] 

Number of interviews: 

Lobbying definitions; 
Clear and understandable: 61; 
Somewhat clear and understandable: 26; 
Not clear and understandable: 5. 

Lobbying activities; 
Clear and understandable: 60; 
Somewhat clear and understandable: 28; 
Not clear and understandable: 4. 

Issue codes; 
Clear and understandable: 61; 
Somewhat clear and understandable: 27; 
Not clear and understandable: 4. 

Covered positions; 
Clear and understandable: 69; 
Somewhat clear and understandable: 18; 
Not clear and understandable: 5. 

Terminating lobbyist; 
Clear and understandable: 67; 
Somewhat clear and understandable: 18; 
Not clear and understandable: 7. 

Source: GAO. 

Note: The total number of interviews totals 92 and is less than our 
sample of 100 reports because some lobbyists had more than one report 
in our sample that we reviewed on the same day. In these cases, we 
interviewed the lobbyist once to ask about clarity of lobbying terms. 

[End of figure] 

Table 2 summarizes the feedback we obtained from the lobbyists in our 
sample of reports that rated the lobbying terms as either not clear 
and understandable or somewhat clear and understandable.[Footnote 22] 

Table 2: Feedback from Lobbyists in Our Sample of Reports Who Cited 
Challenges to Complying with the Act: 

Associated terms: Lobbying definitions; 
Feedback about LD-2 terminology and challenges to reporting: Several 
lobbyists told us that differentiating between lobbyists and non-
lobbyists (i.e., consultants or government relations workers) was 
difficult to understand. Of lobbyists who had difficulty with this 
differentiation, several stated that more clarity is needed in the 
differences between lobbying, consulting, and performing government 
relations activities. 

Associated terms: Lobbying activities; 
Feedback about LD-2 terminology and challenges to reporting: Some 
lobbyists stated additional clarity is needed in the differences 
between lobbying activities and non-lobbying activities. 

Associated terms: Issue codes; 
Feedback about LD-2 terminology and challenges to reporting: Some 
lobbyists said issue codes were unclear and that the issue codes 
overlapped, making it difficult to choose the most appropriate issue 
code for their specific lobbying issues. 

Associated terms: Covered positions; 
Feedback about LD-2 terminology and challenges to reporting: Lobbyists 
expressed concern with not only knowing when to disclose covered 
official positions on the LD-2 report, but also knowing when a federal 
official they met with held a covered official position, which would 
require them to disclose the contact. Additionally, several lobbyists 
told us they referred to the Plum Book[A] for guidance on covered 
officials; however, some lobbyists said it did not provide up-to-date 
information on individuals' covered official positions within federal 
agencies. 

Associated terms: Terminating lobbyists; 
Feedback about LD-2 terminology and challenges to reporting: Several 
lobbyists said they were uncertain if it is necessary to terminate a 
lobbyist if that individual did not actively lobby during the most 
recent reporting period, but may work on behalf of that client in the 
future. 

Source: GAO. 

[A] The "United States Government Policy and Supporting Positions," 
commonly referred to as the Plum Book, is published every 4 years 
after a presidential election. It contains a listing of legislative 
and executive branch covered positions. Many of the positions have 
duties that support administration policies and programs. The Plum 
Book was most recently published in November 2008. 

[End of table] 

A Few Lobbyists Cited Other Filing Challenges: 

Sixty-nine lobbyists in our sample of LD-2 reports said that they 
found the reporting requirements easy to meet. However, 10 lobbyists 
we interviewed told us that they found meeting the deadline for filing 
disclosure reports difficult because of the short time frame between 
the end of the reporting period and the deadline for filing reports. 
For example, one lobbyist mentioned that they have to estimate the 
income for the final month of the reporting period because bills are 
prepared after the filing deadline. The deadline for filing disclosure 
reports is 20 days after each reporting period, or the first business 
day after the 20th day if the 20th day is not a business day. Prior to 
enactment of HLOGA, the deadline for filing disclosure reports was 45 
days after the end of each reporting period. 

While the electronic filing system used for lobbying reports may 
reduce the amount of time filers must spend on data entry, a few 
lobbyists stated that they misreported on their LD-2 reports because 
they carried information from old reports to new reports without 
properly updating information. As a result, some lobbyists now have to 
amend their LD-2 reports to accurately reflect the lobbying activity 
for the quarter under review. 

The U.S. Attorney's Office Has Taken Steps to Improve Its Enforcement 
of the LDA: 

Status Update on Enforcement for the 2008 and 2009 Reporting Periods: 

Since the enactment of HLOGA, quarterly referrals for noncompliance 
with the LD-2 requirements have been received from both the Secretary 
of the Senate and the Clerk of the House. From June 2009 to July 2010, 
the Office received referrals from both the Secretary and the Clerk 
for noncompliance with reports filed for the 2008 and 2009 reporting 
periods.[Footnote 23] The Office received a total of 418 referrals of 
lobbying firms for the 2008 filing period and 457 referrals of 
lobbying firms from the 2009 filing period for noncompliance with the 
quarterly LD-2 reporting requirements. The Office has not yet received 
all referrals from the Secretary of the Senate and the Clerk of the 
House for the 2010 reporting period. 

In addition, the Office has received referrals from the Secretary and 
the Clerk for noncompliance with LD-203 contribution reports. For 
noncompliance in the 2008 calendar year, the Office has to date 
received LD-203 referrals from the Secretary of the Senate for 1,324 
lobbying firms, and 126 LD-203 referrals from the Clerk of the House. 
The Office mailed 962 noncompliance letters to the registered lobbying 
firms and included the names of the individual lobbyists who were not 
in compliance with the requirement to report federal campaign and 
political contributions and certify that they understand the gift 
rules. However, the Office stated that there is confusion among the 
lobbying community as to whether the individual or organization is 
responsible for responding to letters of noncompliance with LD-203 
requirements. To date, the Office has received 765 lobbying firm LD-
203 referrals from the Secretary of the Senate, and 195 referrals from 
the Clerk of the House for the 2009 calendar year. The Office has not 
yet sent letters of noncompliance with the LD-203 referrals for the 
2009 calendar year. 

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. Not all referred lobbyists are 
sent noncompliance letters because some of the lobbyists have 
terminated their registrations, or lobbyists may have complied by 
filing the report before the Office sends noncompliance letters. The 
letters request that the lobbyists comply with the law and promptly 
file the appropriate disclosure documents. Resolution typically 
involves the lobbyists coming into compliance by filing the reports or 
terminating their lobbying status. 

As of January 25, 2011, about 47 percent (758 of 1,597) of the 
lobbyists sent letters for noncompliance with 2008 and 2009 referrals 
are now considered compliant because the lobbyists in question have 
either filed reports or they have terminated their registrations as 
lobbyists. Additionally, about 49 percent (776 of 1,597) are pending 
action because the Office did not receive a response from the lobbyist 
and plans to conduct additional research to determine if they can 
locate the lobbyist or close the referral because the lobbyist cannot 
be located. The remaining 4 percent (63 of 1,597) of the referrals did 
not require action because the lobbyists were found to be compliant 
when the Office received them. This may occur when lobbyists have 
responded to the contact letters from the Secretary of the Senate and 
Clerk of the House after the referrals have been received by the 
Office. Other referrals did not require action because the lobbyist or 
client was no longer in business or the lobbyist was deceased. Figure 
3 shows the status of enforcement actions as a result of noncompliance 
letters sent to registrant organizations for 2008 and 2009 referrals. 

Figure 3: Status of LDA Enforcement Actions (as of January 24, 2011): 

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

Total number of noncompliance letters sent by the U.S. Attorney’s 
Office: 
Reporting period (calendar year): 
2008 LD-2: 316; 
2008 LD-203: 962; 
2009 LD-2: 319
2009[A] LD-203: NA; 
Totals: 1,597. 

Number of referrals now compliant: 
Reporting period (calendar year): 
2008 LD-2: 217; 
2008 LD-203: 367; 
2009 LD-2: 174; 
2009[A] LD-203: NA; 
Totals: 758. 

Number of referrals pending: 
Reporting period (calendar year): 
2008 LD-2: 99; 
2008 LD-203: 536; 
2009 LD-2: 141; 
2009[A] LD-203: NA; 
Totals: 776. 

Number of referrals with no action taken: 
Reporting period (calendar year): 
2008 LD-2: 0; 
2008 LD-203: 59; 
2009 LD-2: 4; 
2009[A] LD-203: NA; 
Totals: 63. 

Percent of total enforcement actions (2008 and 2009): 
Pending: 49%; 
Compliant: 47%; 
No action taken: 4%. 

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

[A] Information reported for the 2009 calendar year only includes LD-2 
referrals the Office has not yet sent letters of noncompliance with 
the LD-203 referrals for the 2009 calendar year. 

[End of figure] 

Since the LDA was passed in 1995, the Office has settled with three 
lobbyists and collected civil penalties totaling about $47,000. All of 
the settled cases involved a failure to file. The settlements occurred 
before the enactment of HLOGA, which increased the penalties for 
offenses committed after January 1, 2008, to involve a civil fine of 
not more than $200,000 and criminal penalties of not more than 5 years 
in prison. Criminal penalties may be imposed against lobbyists who 
knowingly and corruptly fail to comply with the act. Officials from 
the Office stated that they have sufficient civil and criminal 
statutory authorities to enforce the LDA. 

As we reported previously, the Office identified six lobbyists whose 
names appeared frequently in the referrals and sent them letters more 
targeted toward repeat nonfilers. However, the Office has decided not 
to pursue action against any of them because they determined the 
lobbyists were unaware of the need to file, and therefore did not 
intentionally avoid compliance with the requirements of the LDA. In 
all of those cases, the lobbyists terminated or filed once they were 
made aware of the requirements. In addition, in the summer of 2010, 
six additional lobbyists were identified as repeat nonfilers and to 
date, no action has been taken against any of them. Three of these 
cases have been resolved because the Office decided not pursue further 
action due to lobbyists' illness, inability to pay, or lobbyists' 
stating the failure to file was the result of an inadvertent 
oversight. In an additional case, the Office determined the level of 
noncompliance was not sufficiently significant for further action. The 
Office continues to consider further enforcement actions for the 
remaining two, and has forwarded these matters to the Assistant United 
States Attorney for Civil Enforcement for further review. In addition, 
the Office plans to identify additional cases for civil enforcement 
review in the coming months. 

The U.S. Attorney's Office Has Established a System to Track Lobbying 
Enforcement Activities: 

In a prior report, we raised issues regarding the tracking, analysis, 
and reporting of enforcement activities for lobbyists whom the 
Secretary of the Senate and the Clerk of the House identify as failing 
to comply with LDA requirements.[Footnote 24] Our report recommended 
that the Office complete efforts to develop a structured approach for 
tracking referrals when they are made, recording reasons for 
referrals, recording the actions taken to resolve them, and assessing 
the results of actions taken. The Office has developed a system to 
address that recommendation. The current system provides a foundation 
that allows the Office to better focus its lobbying compliance efforts 
by tracking and recording the status and disposition of enforcement 
activities. In addition, the system allows the Office to monitor 
lobbyists who continually fail to file the required disclosure reports. 

Under HLOGA, the Attorney General is required to file an enforcement 
report with Congress after each semiannual period beginning on January 
1 and July 1, detailing the aggregate number of enforcement actions 
DOJ took under the act during the semiannual period and, by case, any 
sentences imposed. On September 6, 2009, the Attorney General filed 
his report for the semiannual period ending June 30, 2009. We found 
information provided in the enforcement report generally matched 
information the system provided to GAO. In cases where we identified 
inconsistencies, they were very minor. For example, the differences in 
the number of noncompliance letters sent were less than 10 out of 
several hundred letters sent. In addition, there were small 
inconsistencies regarding the dates referrals were received from the 
Secretary of the Senate and Clerk of the House. There were also 
inconsistencies in the number of referrals received regarding 
individual lobbyists and registrant organizations. These 
inconsistencies totaled less than 10 out of more than a thousand 
referrals received. We brought these minor errors to the attention of 
the Office and asked them about their processes for ensuring data 
accuracy. Officials from the Office stated that they do not have 
formal procedures for ensuring that data are entered into the system 
in a timely fashion. In addition, they stated that there are no formal 
processes in place to review, validate, or edit the system data after 
they are entered to help ensure that accurate data are entered into 
the system and to help ensure that erroneous data are identified, 
reported, and corrected. The Office stated that they plan to formalize 
data review, refine summary data, and institute procedures to ensure 
data are accurate and reliable in the next few months. As part of this 
effort, they plan to establish periodic quality checks and 
verification of data as we suggested when we met with them in January 
2011. 

The U.S. Attorney's Office's Resources and Authorities to Enforce the 
LDA: 

Officials from the Office stated that they have sufficient civil and 
criminal statutory authorities to enforce LDA. The Office has 
increased the number of staff assigned to assist with lobbying 
compliance issues from 6 to 17.[Footnote 25] All of the staff continue 
to work on lobbying disclosure enforcement part-time and primarily in 
an administrative capacity. Some of their administrative activities 
include researching the Senate and House databases to determine if 
referrals have been resolved, or mailing noncompliance letters. In 
addition to those 17 part-time staff members, one contractor was hired 
in September 2010 to work on lobbying compliance issues on a full-time 
basis. 

Agency Comments: 

We provided a draft of this report to the Attorney General for review 
and comment. We met with the Assistant U.S. Attorney for the District 
of Columbia, who on behalf of the Attorney General responded that DOJ 
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. This report also is 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

Please contact J. Christopher Mihm at (202) 512-6806 or mihmj@gao.gov 
if you or your staffs have any questions about this report. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix IV. 

Signed by: 

J. Christopher Mihm: 
Managing Director, Strategic Issues: 

List of Congressional Committees: 

The Honorable Joseph I. Lieberman: 
Chairman: 
The Honorable Susan M. Collins: 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

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

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

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

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

The Honorable Darrell E. Issa: 
Chairman: 
The Honorable Elijah E. Cummings: 
Ranking Member: 
Committee on Oversight and Government Reform: 
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Consistent with the audit requirements in the Honest Leadership and 
Open Government Act of 2007, our objectives were to: 

* determine the extent to which lobbyists are able to demonstrate 
compliance with the Lobbying Disclosure Act of 1995 (LDA), as amended 
by providing documentation to support information contained on reports 
filed under the LDA; 

* identify any challenges that lobbyists report to compliance and 
potential improvements; and: 

* describe the resources and authorities available to the U.S. 
Attorney's Office for the District of Columbia (the Office), and the 
efforts the Office has made to improve enforcement of the LDA, 
including identifying trends in past lobbying disclosure compliance. 

To respond to our mandate, we used information in the lobbying 
disclosure database maintained by the Clerk of the House of 
Representatives. 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 
thorough 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 that 
result from chamber differences in data processing. For example, 
Senate staff has told us during previous reviews[Footnote 26] 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; and 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 
information on 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 reason to 
believe that the content of the Senate and House systems would vary 
substantially. While we determined that both the Senate and House 
disclosure data were sufficiently reliable for identifying a sample of 
quarterly disclosure reports (LD-2 reports) and for assessing whether 
newly filed registrants also filed required reports, we chose to use 
data from the Clerk of the House for sampling LD-2 reports from the 
last quarter of 2009, first three quarters of 2010, as well as for 
sampling year-end 2009 and midyear 2009 contributions reports (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 fourth quarter of calendar 
year 2009 and the first, second, and third quarters of calendar year 
2010, with 25 reports selected from each quarter. We excluded reports 
with no lobbying activity or with income less than $5,000 from our 
sampling frame[Footnote 27] and drew our sample from 55,282 activity 
reports filed for the last quarter of 2009 and the first three 
quarters of 2010 available in the public House database, as of our 
final download date for each quarter. There is 1 LD-2 report in the 
sample that amended their LD-2 after notification of being selected 
for the sample but prior to our review. The amended LD-2 report 
decreased lobbying activity income for that quarter from $21,000 to 
less than $5,000. Further, that report was amended to show no lobbying 
contact, whereas the original LD-2 activity report showed lobbying 
contact with the Senate and House. We conducted a review of this 
report because they amended to no activity with lobbying income of 
less than $5,000 following notification of inclusion in the sample. 
Since "no lobbying activity" was indicated on the amended LD-2 
activity report, lobbyists were not required to provide information 
for all reporting elements on the LD-2. Therefore, in certain 
calculations this 1 report is excluded from the sample. 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 is the interval that would contain the 
actual population value for 95 percent of the samples that we could 
have drawn. All percentage estimates in this report have 95 percent 
confidence intervals of within plus or minus 10.0 percentage points or 
less of the estimate itself, unless otherwise noted. When estimating 
compliance with certain of the elements we examined, we base our 
estimate on a one-sided 95 percent confidence interval to generate a 
conservative estimate of either the minimum or 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 that they had lobbied. 

In addition, we determined whether each individual lobbyist listed on 
the LD-2 report had filed a semiannual LD-203 report. 

Prior to interviewing lobbyists about each LD-2 report in our sample, 
we conducted an open-source search to determine whether each lobbyist 
listed on the report appeared to have held a covered official position 
required to be disclosed. For lobbyists registered prior to January 1, 
2008, covered official positions held within 2 years of the date of 
the report must be disclosed; this period was extended to 20 years for 
lobbyists who registered on or after January 1, 2008. Lobbyists are 
required to disclose covered official positions on either the client 
registration (LD-1) or on the first LD-2 report for a specific client, 
and consequently those who had held covered official positions may 
have disclosed the information on a LD-2 report filed prior to the 
report we examined as part of our random sample. To identify likely 
covered official positions, we examined lobbying firms' Web sites and 
conducted extensive open-source search of Leadership Directories, 
Who's Who in American Politics, and U.S. newspapers through Nexis for 
lobbyists' names and variations on their names. We then examined the 
current LD-2 report under review, prior LD-2 reports, and the client 
registration to determine if the identified covered positions were 
disclosed properly. Finally, we asked lobbying firms and organizations 
about each lobbyist listed on the LD-2 report that we had identified 
as having a previous covered official position that we had not found 
disclosure of to determine whether covered official positions had been 
appropriately disclosed or whether there was some other acceptable 
reason for the omission (such as having been disclosed on an earlier 
registration or LD-2 report). Despite our rigorous search protocol, it 
is possible that our search failed to identify omitted reports of 
covered official positions. Thus, our estimate of the proportion of 
reports with lobbyists who failed to appropriately disclose covered 
official positions is a lower-bound estimate of the minimum proportion 
of reports that failed to report such positions. 

In addition to examining the content of LD-2 reports, we confirmed 
whether year-end 2009 and midyear 2010 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 fourth quarter of 2009 
and the first, second, and third quarters of 2010, 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 4,132 of the 4,553, or 90.8 percent, of 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. 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 two 
stratified random samples of LD-203 reports from the 32,893 total LD- 
203 reports. The first sample contains 80 reports of the 10,956 
reports with political contributions and the second contains 80 
reports of the 21,937 reports listing no contributions. Each sample 
contains 40 reports from the year-end 2009 filing period and 40 
reports from the midyear 2010 filing period. The samples allow us to 
generalize estimates in this report to either the population of LD-203 
reports with contributions or the reports without contributions to 
within a 95 percent confidence interval of plus or minus 7.1 
percentage points or less, and to within 3.5 percentage points of the 
estimate when analyzing both samples together. We analyzed the 
contents of the LD-203 reports and compared them to contribution data 
found in the publicly available Federal Elections Commission's (FEC) 
political contribution database. For our fiscal year 2009 report, we 
interviewed staff at the FEC responsible for administering the 
database and determined that the data reliability is suitable for the 
purpose of confirming whether a FEC-reportable disclosure listed in 
the FEC database had been reported on an LD-203. 

We compared the FEC-reportable contributions reported 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, we asked the lobbyists or 
organizations to provide an explanation of why the contribution was 
not listed on the LD-203 report or to provide documentation of those 
contributions. As with covered positions on LD-2 disclosure reports, 
we cannot be certain that our review identified all cases of FEC-
reportable contributions that were inappropriately omitted from a 
lobbyist's LD-203 report. We did not estimate the percent of other non-
FEC political contributions that were omitted (such as honoraria, or 
gifts to presidential libraries). 

We obtained views from lobbyists included in our sample of reports on 
any challenges to compliance. 

To describe the processes used by the Office in following up on 
referrals from the Secretary of the Senate and the Clerk of the House, 
data reliability in the Office's tracking system for referrals, and to 
provide information on the resources and authorities used by the 
Office in its role in enforcing compliance with the LDA, we 
interviewed officials from the Office and obtained information on the 
capabilities of the system they established to track and report 
compliance trends and referrals and other practices they have 
established to focus resources on enforcement of the LDA; the extent 
to which they have implemented data reliability checks into their 
tracking system; and the level of staffing and resources dedicated to 
lobbying disclosure enforcement. The Office provided us with reports 
from the tracking system on the number and status of cases referred, 
pending, and resolved. 

The mandate does not include identifying lobbyists who failed to 
register and report in accordance with LDA requirements, or whether 
for those lobbyists that did register and report all lobbying activity 
or contributions were disclosed. We conducted this performance audit 
from April 2010 through March 2011 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 3). 

Table 3: Names of Registrants and Clients Selected in Random Sample of 
Lobbying Disclosure Reports Filed in the Last Quarter of 2009 and 
First Three Quarters of 2010: 

Registrant name: American Coalition for Ethanol; 
Client: American Coalition for Ethanol. 

Registrant name: American Continental Group; 
Client: Siemens Corporations. 

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

Registrant name: American National Red Cross; 
Client: American National Red Cross. 

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

Registrant name: American Public Transportation Association; 
Client: American Public Transportation Association. 

Registrant name: Assurant, Inc.; 
Client: Assurant, Inc. 

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

Registrant name: Beacon Consulting Group; 
Client: Boston Architectural College. 

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

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

Registrant name: Bryan Cave LLP; 
Client: Polimaster, Inc. 

Registrant name: Building & Construction Trades Dept, AFL-CIO; 
Client: Building & Construction Trades Dept, AFL-CIO. 

Registrant name: C2 Group, LLC; 
Client: General Electric. 

Registrant name: Capital Partnerships (VA) Inc.; 
Client: Taxicab, Limousine & Paratransit Association. 

Registrant name: Capitol Resources LLC; 
Client: Greater Jackson Chamber Partnership. 

Registrant name: Cardinal Point Partners; 
Client: Middlesex Community College. 

Registrant name: Cauthen Forbes & Williams; 
Client: United Health Group, Inc. 

Registrant name: CBS Corporation; 
Client: CBS Corporation. 

Registrant name: CLMM & Associates; 
Client: Cerberus Capital Management. 

Registrant name: Communicating for America; 
Client: Communicating for America. 

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

Registrant name: Crowell & Moring LLP; 
Client: The Dow Chemical Company. 

Registrant name: DeBrunner & Associates, Inc.; 
Client: Monongahela Valley Hospital. 

Registrant name: Dutko Worldwide LLC; 
Client: Coalition to Advance Healthcare Reform. 

Registrant name: Edward D. Heffernan, Esq.; 
Client: DePaul University. 

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

Registrant name: Eris Group (formerly known as Bartlett, Bendall & 
Kadesh, LLC); 
Client: NBC-Universal. 

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

Registrant name: Etherton and Associates, Inc.; 
Client: General Dynamics Corporation. 

Registrant name: Federal Strategy Group; 
Client: Microsoft Corporation. 

Registrant name: Federation of American Hospitals; 
Client: Federation of American Hospitals. 

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

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

Registrant name: Groom Law Group, Chartered; 
Client: Investment Company Institute. 

Registrant name: Groom Law Group, Chartered; 
Client: Microsoft Corporation. 

Registrant name: Hogan Lovells f/k/a Hogan & Hartson LLP; 
Client: Pharmathene. 

Registrant name: Holland & Knight LLP; 
Client: Global Green USA. 

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

Registrant name: Holland & Knight LLP; 
Client: Visual Awareness Technologies and Consulting. 

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

Registrant name: Jones, Walker, Waechter, Poitevent, Carrere & Denegre; 
Client: Association of Catastrophe Adjusters. 

Registrant name: K&L Gates LLP; 
Client: International Housing Coalition. 

Registrant name: Kountoupes Consulting LLC; 
Client: The Weidt Group. 

Registrant name: Land Trust Alliance; 
Client: Land Trust Alliance. 

Registrant name: League of Conservation Voters; 
Client: League of Conservation Voters. 

Registrant name: Liebman & Associates, Inc.; 
Client: Lineage Power. 

Registrant name: Lupus Foundation of America; 
Client: Lupus Foundation of America. 

Registrant name: Markley and Company; 
Client: Kotzebue Electric Association. 

Registrant name: Mayer Brown LLP; 
Client: Asurion Corporation. 

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

Registrant name: McAllister & Quinn LLC; 
Client: Norfolk Southern Corporation. 

Registrant name: Mehlman Vogel Castagnetti, Inc.; 
Client: Electronic Retailing Association. 

Registrant name: Missouri Hospital Association; 
Client: Missouri Hospital Association. 

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

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

Registrant name: National Group LLP; 
Client: San Mateo County Sheriff's Department. 

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

Registrant name: O'Brien & Associates LLC; 
Client: Kidsave International Inc. 

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

Registrant name: Olsson Frank Weeda Terman Bode Matz PC; 
Client: Pixius Communication, LLC. 

Registrant name: Patton Boggs LLP; 
Client: Goodwill Industries of Northern Iowa, Inc. 

Registrant name: Patton Boggs LLP; 
Client: Legg Mason, Inc. 

Registrant name: Patton Boggs LLP; 
Client: St. Thomas Aquinas College. 

Registrant name: Perkins Coie LLP; 
Client: Dragonslayer, Inc. 

Registrant name: Petrizzo Strategic Group, Inc.; 
Client: Allen Institute for Brain Science. 

Registrant name: Podesta Group, Inc.; 
Client: AMGEN. 

Registrant name: Podesta Group, Inc.; 
Client: Coeur d'Alene Mines Corporation. 

Registrant name: Podesta Group, Inc.; 
Client: Sunoco. 

Registrant name: Public Strategies Washington; 
Client: Bristol-Myers Squibb. 

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

Registrant name: Richard Innes; 
Client: The Nature Conservancy. 

Registrant name: RM2 Consultants, Inc.; 
Client: Mercer Engineering Research Center. 

Registrant name: Robert H. Lamb, PLLC; 
Client: Biotechnology Industry Organization. 

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

Registrant name: Schumacher Partners International LLC; 
Client: Roberts Wesleyan College. 

Registrant name: Smiths Detection, Inc.; 
Client: Smiths Detection, Inc. 

Registrant name: Snack Food Association; 
Client: Snack Food Association. 

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

Registrant name: Strategic Health Care; 
Client: MRSSI, Inc. 

Registrant name: Taft, Stettinius & Hollister LLP; 
Client: Vincennes University. 

Registrant name: TCH Group, LLC; 
Client: City of Charleston, SC. 

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

Registrant name: The Glover Park Group LLC; 
Client: Rockefeller Family Fund. 

Registrant name: The Kate Moss Company; 
Client: Medco Health Solutions, Inc. 

Registrant name: The Livingston Group LLC; 
Client: Goodyear Tire and Rubber Company. 

Registrant name: The Mitchell Firm, Inc.; 
Client: Church of Scientology International. 

Registrant name: The Raben Group; 
Client: General Electric. 

Registrant name: The Rhoads Group; 
Client: Actus Lend Lease LLC. 

Registrant name: University of Medicine and Dentistry of New Jersey; 
Client: University of Medicine and Dentistry of New Jersey. 

Registrant name: Van Scoyoc Associates; 
Client: City of Dana Point, California. 

Registrant name: Van Scoyoc Associates; 
Client: DRS Technologies. 

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

Registrant name: Washington Alliance Group, Inc.; 
Client: Southwest Research Institute. 

Registrant name: Wexler & Walker Public Policy Associates; 
Client: American Science & Engineering, Inc. 

Registrant name: Wexler & Walker Public Policy Associates; 
Client: Wight & Company. 

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

Registrant name: Winning Strategies Washington; 
Client: Cablevision. 

Registrant name: Winning Strategies Washington; 
Client: Viaero Wireless. 

Registrant name: World Shipping Council; 
Client: World Shipping Council. 

Source: Lobbying disclosure database of the Clerk of the House of 
Representatives, last quarter of calendar year 2009 and first three 
quarters of calendar year 2010. 

[End of table] 

[End of section] 

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

See table 4 for a list of lobbyists and lobbying firms from our random 
sample of lobbying contribution reports with contributions. See table 
5 for a list of lobbyists and lobbying firms from our random sample of 
lobbying contribution reports without contributions. 

Table 4: Lobbyists and Lobbying Firms Selected in Random Sample of 
Lobbying Contribution Reports with Contributions Listed, Filed Year-
end 2009 and Midyear 2010: 

Lobbyist or lobbying firm: Advanced Medical Technology Association; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Air Products and Chemicals, Inc.; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Akerman Senterfitt; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Alan Mintz; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: American College of Surgeons Professional 
Association; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: American Farm Bureau Federation; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: American Hospital Association; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: American Meat Institute; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Andrea King; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Andrew Howell; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Andrew Solomon; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Barfield Associates; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Bradley Kading; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Caitlin Donovan; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Cary Sherman; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Chad Lord; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Charles Knauss; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Christina West; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Cigar Association of America, Inc.; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Consol Energy, Inc; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Danea Kehoe; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Daryl Buffenstein; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: David Abernethy; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: David Thompson; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Diane Newberg; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Duane Gibson; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Elizabeth Greer; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Geoffrey Peterson; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Gordon Robertson; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Gregg Hartley; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Hach Company/Danaher Corporation; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Hunter Johnston; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: International Association of Amusement 
Parks & Attractions; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Jack Pettus; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: James McConnell; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Jay Truitt; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Jeff Markey; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Jennifer Blum; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Jessica Malow; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Joel Freedman; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: John Killeen; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: John Ladd; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Julie Dammann; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Katharine Leeson; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Kenneth Carpi; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Kutak Rock LLP; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Langston Emerson; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Laura McNeill; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Lisa Sutherland; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Lloyd Lawrence; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Lydia Hofer; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Lynn Cutler; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Matthew Miller; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Matthew Schlapp; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Melissa Hart; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Michael McAdams; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Multiple Strategies LLC; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: NAADAC The Association for Addiction 
Professionals; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: National Association of Postmasters of the 
United States; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: New York Farm Bureau, Inc.; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Nicole Venable; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Peter Jacoby; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Peter Peyser; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Philip Baker-Shenk; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Philip Bechtel; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Portland Cement Association; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Rita Norton; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Robert Juliano; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Sarah Venuto; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Shawn Edwards; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Stephen Richer; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Steven Pines; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Susann Edwards; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: The Outlaw Group; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Theodore Okon; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Tiffany Moore; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Transport Workers Union of America, AFL-CIO; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: TREA Senior Citizens League; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Tribune Company; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: University of Southern California; 
Reporting period: Midyear 2010. 

Source: Lobbying contributions database of the Clerk of the House of 
Representatives, year-end reports for calendar year 2009 and midyear 
reports for calendar year 2010. 

[End of table] 

Table 5: Lobbyists and Lobbying Firms Selected in Random Sample of 
Lobbying Contribution Reports with No Contributions Listed, Filed Year-
end 2009 and Midyear 2010: 

Lobbyist or lobbying firm: Adam Salina; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Alex Oehler; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Alliance of Community Health Plans, Inc.; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: American Association of Port Authorities; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: American Library Association; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Andreas Karellas; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Andrew Futey; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Anthony Lakavage; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Arizona Wheat Growers Association; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Ashli Douglas; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Benjamin Rogers; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Blake Ortner; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Bonnie Hogue Duffy; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Bradley Peganoff; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Business Coalition for U.S. Central America 
Trade; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Candace Bartlett; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Carolyn Osolinik; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Casey Morgan; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Catholic Health East; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Cedric Sheridan; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Ceres, Inc.; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Chad Wolf; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Consumer Federation of America; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Cristina Finch; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Dan Lavey; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: David Bauer; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: David Shoultz; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Debbie Weatherly; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Donna Denison; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Eric Hsieh; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Eugene Miller; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Gene Lange; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Gordon Merritt; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Graham Steele; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Greg Billings; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Hank Monsees; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Jason Scull; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Jennifer Pollakusky; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Jesseca Boyer; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Jessica Mandel; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Jim Ferguson; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Joann Volk; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Joseph Crea; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Julie Nissenbaum; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Kamala Lyon; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Kia Motors Corporation; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Kristen Michal; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Lawrence Cain; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Lisa Colangelo; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Lisa Rickard; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Maureen Hardwick; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Melissa Dupree; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Meyers and Associates; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Michael Barbera; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Michelle Koroghlanian; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Montana Farm Bureau Federation; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Oldaker Group, LLC; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Paul Carothers; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Paul Marcone and Associates, LLC; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Peter Perkins; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Richard Smith; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Robin Phillips; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Ropes & Gray, LLP; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: RPI Group, Inc.; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Russ Reid Company; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Ruth Bahe-Jachna; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Ryan Vaart; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Seth Radus; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Seth Voyles; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Shari Brown; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Solvay North America; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Stapleton & Associates, LLC; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Stephanie Childs; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Stephen DeWitt; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Steven Carter; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Steven Radke; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: Stewart Simonson; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: Susan Frost; 
Reporting period: Midyear 2010. 

Lobbyist or lobbying firm: The Walcott Group; 
Reporting period: Year-end 2009. 

Lobbyist or lobbying firm: W Strategies, LLC; 
Reporting period: Midyear 2010. 

Source: Lobbying contributions database of the Clerk of the House of 
Representatives, year-end reports for calendar year 2009 and midyear 
reports for calendar year 2010. 

[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: 

Acknowledgments: 

In addition to the contacts named above, Robert Cramer, Associate 
General Counsel; Bill Reinsberg, Assistant Director; Shirley Jones, 
Assistant General Counsel; Crystal Bernard; Amy Bowser; Anna Maria 
Ortiz; Melanie Papasian; Katrina Taylor; Megan Taylor; and Greg 
Wilmoth made key contributions to this report. 

Assisting with lobbyist file reviews and interviews were Sarah Arnett, 
Sandra Beattie, Colleen Candrl, Irina Carnevale, Jeffrey DeMarco, 
Nicole Dery, Shannon Finnegan, Robert Gebhart, Meredith Graves, Lauren 
Grossman, Amanda Harris, Lois Hanshaw, Angela Leventis, Blake Luna, 
Patricia MacWilliams, Stacy Ann Spence, Jonathan Stehle, and Daniel 
Webb. 

[End of section] 

Footnotes: 

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

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

[3] 2 U.S.C. § 1614. 

[4] Although we contacted each lobbying firm in our sample, we did not 
always meet with the lobbyists identified as the point of contact or 
the actual lobbyists. For the purposes of our 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 
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 
$11,500. 

[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-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] GAO, 2009 Lobbying Disclosure: Observations on Lobbyists' 
Compliance with Disclosure Requirements, [hyperlink, 
http://www.gao.gov/products/GAO-10-499] (Washington, D.C.: Apr. 1, 
2010); GAO, 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 GAO, 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 is the interval that would 
contain the actual population value for 95 percent of the samples we 
could have drawn. Unless otherwise stated, all percent estimates have 
a maximum 95 percent confidence interval of within 10.0 percentage 
points or less of the estimate. 

[12] Eight lobbyists underreported lobbying income or expenses on the 
LD-2 report by at least $10,000, and five lobbyists overreported 
lobbying income or expenses on the LD-2 report by at least $10,000. 

[13] Lobbyists are expected to provide a good faith estimate on the LD-
2 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] As part of our LD-2 report review, we checked the House database 
to ensure that each lobbyist and organization listed on the LD-2 
report filed an LD-203 report during the reporting period. 

[15] [hyperlink, http://www.gao.gov/products/GAO-10-499]. 

[16] The 95 percent confidence interval for this estimate is plus or 
minus 13.7 percentage points. 

[17] Guidance issued by the Secretary of the Senate and the Clerk of 
the House of Representatives instructs lobbyists that they are only 
required to disclose covered positions on the first filing. 

[18] Prior to each review, we used open source search techniques to 
identify lobbyists on each report who may have held a covered official 
position. Additionally, where a covered official position was found 
during our open source search, we conducted an additional review of 
the publicly available Secretary of the Senate or Clerk of the House 
database to determine whether the covered official position was 
disclosed on the registration or a prior LD-2 report. 

[19] We did not estimate the percent of other non-FEC political 
contributions that were omitted (such as honoraria, or gifts to 
presidential libraries). 

[20] [hyperlink, http://www.gao.gov/products/GAO-10-499], [hyperlink, 
http://www.gao.gov/products/GAO-09-487]. 

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

[22] During several interviews, lobbyists did not identify challenges 
when asked initially; however, they later identified challenges when 
providing overall comments at the end of the interview. 

[23] [3] Although referral and other compliance data provided by the 
Office may not be completely accurate, the magnitude of the errors we 
found were small. Therefore, we have determined that the data were 
sufficiently reliable for purposes of our review to provide a useful 
overview of the Office's compliance efforts. 

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

[25] These 17 staff include a civil chief, two deputy chiefs, three 
civil enforcement attorneys, one civil enforcement investigator, three 
paralegals, one support staff manager, four docket information input 
clerks, and two student interns. 

[26] [hyperlink, http://www.gao.gov/products/GAO-10-499], and 
[hyperlink, http://www.gao.gov/products/GAO-09-487]. 

[27] 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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