reported income (or expenses for organizations with in-house  lobbyists) related to lobbying activities during the quarter (rounded to  the nearest $10,000). The LDA also requires lobbyists to report certain political contributions  semiannually in the LD-203 report. Figure 1 shows  that most newly registered lobbyists filed their disclosure reports as  required from 2010 through 2013. For Most LD-2 Reports Lobbyists Provided Documentation for Key Elements, but for Some LD-2 Reports Lobbyists Rounded Their Income or Expenses Incorrectly

For selected elements of lobbyists’ LD-2 reports that can be generalized  to the population of lobbying reports, unless otherwise noted, our findings  were consistent from year to year. For Most LD-2 Reports, Lobbyists Filed LD-203 Reports for All Listed Lobbyists

Lobbyists for an estimated 92 percent of LD-2 reports filed year-end 2012  or midyear 2013 LD-203 reports for all lobbyists and lobbying firms listed  on the report as required. This year, we estimate that 17 percent of all LD-2 reports did not  properly disclose one or more previously held covered positions as  required. We estimate that overall, for 2013,  lobbyists failed to disclose one or more reportable contributions on 4  percent of reports. Most lobbyists we interviewed rated the terms associated with LD-2  reporting requirements as “very easy” or “somewhat easy” to understand  with regard to meeting their reporting requirements. This is consistent  with prior reviews. U.S. Attorney’s Office Actions to Enforce LDA

		The Office’s Authorities, Processes, and Resources to Enforce LDA Compliance

The Office stated it continues to have sufficient personnel resources and  authority under the LDA to enforce LD-2 reporting requirements, including  imposing civil or criminal penalties for noncompliance of LD-2 reporting. Noncompliance refers to a lobbyist’s or lobbying firm’s failure to comply  with LDA requirements. According to the Office, it has sufficient authority to enforce LD-203  compliance with the LDA for lobbying firms and certain individual  lobbyists. In March 2014, the Office filed a  civil complaint in the U.S. District Court for the District of Columbia for a  registrant’s failure to comply with LDA reporting requirements. In our first lobbying  disclosure report in September 2008, we concluded that the lobbying  community could benefit from creating an organization to  share examples of best practices of the types of records maintained to  support filings; use this information gathered over an initial period to formulate  minimum standards for recordkeeping; provide training for the lobbying community on reporting and  disclosure requirements intended to help the community comply with  the LDA; and  report annually to the Secretary of the Senate and the Clerk of the  House on opportunities to clarify existing guidance and ways to  minimize sources of potential confusion for the lobbying community. Agency Comments

We 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. Appendix I: Objectives, Scope, and Methodology

Consistent with the mandate in the Honest Leadership and Open  Government Act (HLOGA), our objectives were to determine the extent to which lobbyists are able to demonstrate  compliance with the Lobbying Disclosure Act of 1995, as amended  (LDA) by providing documentation to support information contained on  registrations and reports filed under the LDA;  identify challenges and potential improvements to compliance, if any;  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. We  used the House database for sampling LD-2 reports from the third and  fourth quarters of 2012 and the first and second quarters of 2013, as well  as for sampling year-end 2012 and midyear 2013 political contributions  (LD-203) reports and finally for matching quarterly registrations with filed  reports.
Why GAO Did This Study

The LDA requires lobbyists to file quarterly lobbying disclosure reports and semiannual reports on certain political contributions. The LDA also requires that GAO annually (1) audit the extent to which lobbyists can demonstrate compliance with disclosure requirements, (2) identify challenges to compliance that lobbyists report, and (3) describe the resources and authorities available to the Office in its role in enforcing LDA compliance and the efforts the Office has made to improve enforcement. This is GAO's seventh report under the mandate.
GAO reviewed a stratified random sample of 104 quarterly disclosure LD-2 reports filed for the third and fourth quarters of 2012 and the first and second quarters of calendar year 2013. GAO also reviewed two random samples totaling 160 LD-203 reports from year-end 2012 and midyear 2013. This methodology allowed GAO to generalize to the population of 65,489 disclosure reports with $5,000 or more in lobbying activity and 31,482 reports of federal political campaign contributions. GAO also met with officials from the Office to obtain updated statuses on the Office's 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. On behalf of the Attorney General, the Assistant U.S. Attorney for the District of Columbia responded that the Department of Justice had no comments.

What GAO Found

Most lobbyists provided documentation for key elements of their disclosure reports to demonstrate compliance with the Lobbying Disclosure Act of 1995, as amended (LDA). For lobbying disclosure (LD-2) reports and political contribution (LD-203) reports GAO estimated the following:
Ninety-six percent of newly registered lobbyists filed LD-2 reports as required. Lobbyists are required to file LD-2 reports for the quarter in which they first register.
Ninety-six percent could provide documentation for income and expenses. However, 33 percent of these LD-2 reports were not properly rounded to the nearest $10,000.
Ninety-two percent filed year-end 2012 or midyear 2013 LD-203 reports as required.
Seventeen percent of all LD-2 reports did not properly disclose one or more previously held covered position as required.
Four percent of all LD-203 reports omitted one or more reportable political contributions that were documented in the Federal Election Commission database.
These findings are generally consistent with GAO's reviews from 2010 through 2012 and can be generalized to the population of disclosure reports.
Most lobbyists in GAO's sample rated the terms associated with LD-2 reporting as “very easy” or “somewhat easy” to understand with regard to meeting reporting requirements. However, some disclosure reports demonstrate compliance difficulties, such as failure to disclose covered positions or misreporting of income or expenses. In addition, lobbyists amended 18 of 104 original disclosure reports in GAO's sample to change previously reported information.
The U.S. Attorney's Office for the District of Columbia (the Office) stated it has sufficient authority and resources to enforce LD-2 and LD-203 compliance with the LDA for lobbying firms and certain individual lobbyists. It has one contract paralegal working full time and six attorneys working part time on LDA enforcement issues. The Office continues its efforts to follow up on referrals for noncompliance with lobbying disclosure requirements by contacting lobbyists by e-mail, telephone, and letter. In March 2014, the Office filed a civil complaint against a lobbyist for failure to comply with LDA reporting requirements.
GAO's first report on lobbying disclosure under the LDA concluded that the lobbying community could benefit from creating an entity to share examples of best practices, provide training, and report annually on opportunities to clarify guidance and minimize sources of potential confusion for the lobbying community. Given the ongoing difficulties with compliance, GAO continues to believe that such an entity could be useful to the lobbying community.