The LD-2s contain information that includes:  the name of the lobbyist reporting on quarterly lobbying activities;  the name of the client for whom the lobbyist lobbied; a list of individuals who acted as lobbyists on behalf of the client  during the reporting period; whether any lobbyists served in covered positions in the executive or  legislative branch such as high-ranking agency officials or  congressional staff positions, in the previous 20 years;  codes describing general issue areas, such as agriculture and  education; a description of the specific lobbying issues; houses of Congress and federal agencies lobbied during the reporting  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. For Most LD-2 Reports, Lobbyists Provided Documentation for Key Elements but Fewer Lobbyists Provided Documentation for Their Income and Expenses

For selected elements of lobbyists’ LD-2 reports that can be generalized  to the population of lobbying reports, our findings have been consistent  from year to year. For this year’s review,  lobbyists for an estimated 83 percent of LD-2 reports provided written  documentation for the income and expenses reported for the third and  fourth quarters of 2015 and the first and second quarters of 2016. Although the estimated decline from 92 percent in 2015 to 83 percent in  2016 is notable, our analysis does not provide sufficient evidence of a  statistically significant decrease in the percentage of lobbyists who have  documentation for income and expenses. This year, we estimate that 15  percent of all LD-2 reports may not have properly disclosed 1 or more  previously held covered positions as required. As in our other reports,  some lobbyists were still unclear about the need to disclose certain  covered positions, such as paid congressional internships or certain  executive agency positions. Consistent with prior reviews,  most lobbying firms reported that they found it “very easy” or “somewhat  easy” to comply with reporting requirements. This is consistent with  prior reviews. Figures 12 through 16 show what lobbyists reported as  their ease of understanding the terms associated with LD-2 reporting  requirements from 2012 through 2016. However, it is not  always successful. Agency Comments

We provided a draft of this report to the Attorney General for review and  comment. The Department of Justice provided technical comments,  which we incorporated as appropriate. Appendix I: Objectives, Scope, and Methodology

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; to identify  challenges and potential improvements to compliance, if any; and to  describe the resources and authorities available to the U.S. Attorney’s  Office for the District of Columbia (USAO), its role in enforcing LDA  compliance, and the efforts it has made to improve LDA enforcement. We used the House database for sampling LD- 2 reports from the third and fourth quarters of 2015 and the first and  second quarters of 2016, as well as for sampling year-end 2015 and  midyear 2016 political contributions (LD-203) reports. 2008 Lobbying Disclosure: Observations on Lobbyists’ Compliance with  Disclosure Requirements. 2010 Lobbying Disclosure: Observations on Lobbyists’ Compliance with  Disclosure Requirements. 2015 Lobbying Disclosure: Observations on Lobbyists’ Compliance with  Disclosure Requirements.
Why GAO Did This Study

The LDA, as amended, requires lobbyists to file quarterly lobbying disclosure reports and semiannual reports on certain political contributions. The law also requires that GAO annually audit lobbyists' compliance with the LDA. GAO's objectives were to (1) determine 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 USAO in its role in enforcing LDA compliance, and the efforts USAO has made to improve enforcement. This is GAO's 10th report under the mandate.
GAO reviewed a stratified random sample of 78 quarterly disclosure LD-2 reports filed for the third and fourth quarters of calendar year 2015 and the first and second quarters of calendar year 2016. GAO also reviewed 2 random samples totaling 160 LD-203 reports from year-end 2015 and midyear 2016. This methodology allowed GAO to generalize to the population of 46,450 disclosure reports with $5,000 or more in lobbying activity, and 22,820 reports of federal political campaign contributions. GAO met with officials from USAO to obtain status updates on its 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 Department of Justice provided technical comments, which GAO incorporated as appropriate. GAO is not making any recommendations in this report.

What GAO Found

For the 2016 reporting period, 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 filed during the third and fourth quarters of 2015 and the first and second quarters of 2016, GAO estimates that
90 percent of lobbyists filed required reports for the quarter in which they first registered; the figure below describes the filing process and enforcement;
83 percent (down from 92 percent in 2015) could provide documentation for income and expenses; and
94 percent filed year-end 2015 LD-203 reports as required.
These findings, with the exception of fewer lobbyists who could produce documentation for income and expenses, are generally consistent with prior reports GAO issued for the 2010 through 2015 reporting periods. Although the estimated decline in lobbyists who could document expenses is notable, the decrease is not statistically significant.
As in GAO's other reports, some lobbyists were still unclear about the need to disclose certain previously held covered positions, such as paid congressional internships or certain executive agency positions. GAO estimates that 15 percent of all LD-2 reports may not have properly disclosed 1 or more previously held covered positions. However, over the past several years of reporting on lobbying disclosure, GAO has found that most lobbyists in the sample rated the terms associated with LD-2 reporting as “very easy” or “somewhat easy” to understand.
The U.S. Attorney's Office for the District of Columbia (USAO) stated it has sufficient resources and authority to enforce compliance with the LDA. USAO continued its efforts to bring lobbyists into compliance by prompting them to file reports or applying civil penalties.