The LD-2s contain information that includes: a list of individuals who acted as lobbyists on behalf of the client  the name of the lobbyist reporting on quarterly lobbying activities;  the name of the client for whom the lobbyist lobbied;  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  period; and  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 2 shows  lobbyists filed disclosure reports as required for most new lobbying  registrations from 2010 through 2015. 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 our findings have been consistent  from year to year. In 2015, we identified 31  percent of reports that did not round reported income or expenses  according to the guidance. This year, we estimate that 21  percent of all LD-2 reports may not have properly disclosed one 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. Most lobbying firms we surveyed rated the definitions of terms used in  LD-2 reporting as “very easy” or “somewhat easy” to understand with  regard to meeting their reporting requirements. This is consistent with  prior reviews. It also shows the status of the referrals received and the  number of enforcement actions taken by USAO in its effort to bring  lobbyists into compliance. In August 2015, USAO finalized a settlement in the amount of $125,000  for the Carmen Group to address failure to file for several years. This is  the largest civil penalty assessed under the LDA to date. Agency Comments

We provided a draft of this report to the Attorney General for review and  comment. The Department of Justice provided updated data which we  incorporated into the report. 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 2014 and the first and  second quarters of 2015, as well as for sampling year-end 2014 and  midyear 2015 political contributions (LD-203) reports. To assess the extent to which lobbyists could provide evidence of their  compliance with reporting requirements, we examined a stratified random  sample of 80 LD-2 reports from the third and fourth quarters of 2014 and  the first and second quarters of 2015.
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 ninth report under the mandate.
GAO reviewed a stratified random sample of 80 quarterly disclosure LD-2 reports filed for the third and fourth quarters of 2014 and the first and second quarters of 2015. GAO also reviewed two random samples totaling 160 LD-203 reports from year-end 2014 and midyear 2015. This methodology allowed GAO to generalize to the population of 45,565 disclosure reports with $5,000 or more in lobbying activity, and 29,189 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 updated data which GAO incorporated into the report.
GAO is not making any recommendations in this report.

What GAO Found

For the 2015 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 quarter of 2014 and the first and second quarter of 2015, GAO estimates that
88 percent of lobbyists filed initial LD-2 reports as required for new lobbying registrations (lobbyists are required to file LD-2 reports for the quarter in which they first register); the figure below describes the filing process and enforcement;
93 percent could provide documentation for income and expenses, but on 31 percent of these LD-2 reports lobbyists did not correctly follow the guidance to round to the nearest $10,000; and
85 percent filed year-end LD-203 2014 reports as required.
These findings are generally consistent with prior reports GAO issued for the 2010 through 2014 reporting periods. 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. GAO estimates that 21 percent of all LD-2 reports may not have properly disclosed one 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 with regard to meeting their reporting requirements.
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. In August 2015, USAO finalized a $125,000 settlement with the Carmen Group, the largest civil penalty settlement for noncompliance.