The LD-2s contain  information that includes:  the name of the lobbyist reporting on quarterly lobbying activities and  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 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. Figure 1 shows lobbyists filed  disclosure reports as required for most new lobbying registrations from  2010 through 2014. 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  have been consistent from year to year. For this year’s review, lobbyists for an estimated  93 percent of LD-2 reports provided written documentation for the income  and expenses reported for the third and fourth quarters of 2013 and the  first and second quarters of 2014. In  2014, 6 percent of lobbyists reported the exact amount of income or  expenses. For Most Lobbying Disclosure Reports (LD-2), Lobbyists Filed Political Contribution Reports (LD-203) for All Listed Lobbyists

Lobbyists for an estimated 94 percent of LD-2 reports filed year-end 2013  reports for all lobbyists listed on the report as required. This year, we estimate that 14 percent of all LD-2 reports did not  properly disclose one or more previously held covered positions as  required. Most LD-203 Contribution Reports Disclosed Political Contributions Listed in the FEC Database

As part of our review, we compared contributions listed on lobbyists’ and  lobbying firms’ LD-203 reports against those political contributions  reported in the FEC database to identify whether political contributions  were omitted on LD-203 reports in our sample. We estimate that overall for 2014, lobbyists  failed to disclose one or more reportable contributions on 4 percent of  reports. 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. According to officials USAO is close to finalizing a settlement with another  firm for repeated failure to file. Agency Comments

We provided a draft of this report to the Attorney General for review and  comment. The Department of Justice provided a technical comment,  which we incorporated into the draft 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 enforcement of the  LDA. 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 third and fourth quarters of 2013 and  the first and second quarters of 2014. To describe the resources and authorities available to the U.S. Attorney’s  Office for the District of Columbia (USAO) and its efforts to improve its  enforcement of the LDA, we interviewed officials from USAO. 2008 Lobbying Disclosure: Observations on Lobbyists’ Compliance with  Disclosure Requirements. 2012 Lobbying Disclosure: Observations on Lobbyists’ Compliance with  Disclosure Requirements. 2013 Lobbying Disclosure: Observations on Lobbyists’ Compliance with  Disclosure Requirements.
Why GAO Did This Study

LDA 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) 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 USAO in its role in enforcing LDA compliance, and the efforts USAO has made to improve enforcement. This is GAO's eighth report under the mandate.
GAO reviewed a stratified random sample of 100 quarterly disclosure LD-2 reports filed for the third and fourth quarters of calendar year 2013 and the first and second quarters of calendar year 2014. GAO also reviewed two random samples totaling 160 LD-203 reports from year-end 2013 and midyear 2014. This methodology allowed GAO to generalize to the population of 46,599 disclosure reports with $5,000 or more in lobbying activity, and 30,524 reports of federal political campaign contributions. GAO also 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 a technical comment, which GAO incorporated as appropriate.

What GAO Found

For the 2014 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 and political contributions (LD-203) reports filed during the third and fourth quarter of 2013 and the first and second quarter of 2014, GAO estimates that
90 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).
93 percent could provide documentation for income and expenses. However, 21 percent of these LD-2 reports were not properly rounded to the nearest $10,000 and 6 percent of those reports listed the exact amount.
94 percent filed year-end 2013 reports as required.
14 percent of all LD-2 reports did not properly disclose one or more previously held covered positions (certain positions in the executive and legislative branches) as required.
4 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 prior reports GAO issued for the 2010 through 2013 reporting periods and can be generalized to the population of disclosure reports.
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. However, some disclosure reports demonstrate compliance difficulties, such as failure to disclose covered positions or misreporting of income or expenses. In addition, lobbyists amended 19 of 100 original disclosure reports in GAO's sample, changing information previously reported.
The U.S. Attorney's Office for the District of Columbia (USAO) stated it has sufficient resources and authority to enforce LD-2 and LD-203 compliance with LDA. It has one contract paralegal working full time and six attorneys working part time on LDA enforcement issues.
USAO continued its efforts to follow up on referrals for noncompliance with lobbying disclosure requirements by contacting lobbyists by e-mail, telephone, and letter. Also, USAO has finalized a settlement with a lobbyist to resolve multiple instances of noncompliance and is in the process of finalizing another settlement.