Lobbying Disclosure Act Guidance Reverses Course!
The Secretary of the Senate and Clerk of the House overhauled Section 7 of The Lobbying Disclosure Act Guidance regarding required contribution disclosures (due July 30). Several examples in the most recent Guidance represent a complete reversal from those posted in the May 29, 2008 iteration.
For example, the prior Guidance stated that the mere recognition of a covered official as an "honorary co-host" was sufficient to trigger reporting requirements. Example 7 now provides the opposite.
The prior Guidance also suggested that one must disclose mere payment for a ticket to a luncheon at which a covered official is honored. Example 9 now states that buying a ticket or table to another entity's dinner event is not in itself a reportable circumstance.
In addition, the prior Guidance stated that lobbying registrants must disclose their financial sponsorship of an event when a covered official is merely a speaker or disclosed invitee. Examples 6 and 8 of the Guidance now state that unless the covered official receives a special award, honor, or recognition in connection with such an event, the cost of the event need not be disclosed.
Other minor amendments include a clarification that events must be disclosed where a covered official is bestowed an award, even if the primary purpose of the event is other than to honor the official (e.g., to raise money for the sponsoring organization).
For a copy of the new Guidance, click here:
For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.