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. Most lobbyists reporting $5,000 or more in  income or expenses provided written documentation to varying degrees  for the reporting elements in their disclosure reports. However, in  recent years our findings showed some variation in the estimated  percentage of lobbyists who have reports with documentation for income  and expense supporting lobbying activities. Specifically, our estimate for  2017 (99 percent) represents a statistically significant increase from  2016. For Most Lobbying Disclosure Reports (LD-2), Lobbyists Filed Political Contribution Reports (LD- 203) for All Listed Lobbyists

Lobbyists for an estimated 93 percent of LD-2 reports filed year-end 2016  for all lobbyists listed political contributions on the report as required. This year, we estimate that 15  percent of all LD-2 reports may not have properly disclosed 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 2017. It also shows the status of the referrals received and the  number of enforcement actions taken by USAO to bring lobbyists into  compliance. Agency Comments

We provided a draft of this report to the Department of Justice 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 2016 and the first and second quarters of  2017, as well as for sampling year-end 2016 and midyear 2017 political  contributions reports (LD-203). To assess the extent to which lobbyists could provide evidence of their  compliance with reporting requirements, we examined a stratified random  sample of 98 LD-2 reports from the third and fourth quarters of 2016 and  the first and second quarters of 2017. 2010 Lobbying Disclosure: Observations on Lobbyists’ Compliance with  Disclosure Requirements.
Why GAO Did This Study

The LDA, as amended, requires lobbyists to file quarterly disclosure reports and semiannual reports on certain political contributions. The law also includes a provision for GAO to 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 11th report under the provision.
GAO reviewed a stratified random sample of 98 quarterly disclosure LD-2 reports filed for the third and fourth quarters of calendar year 2016 and the first and second quarters of calendar year 2017. GAO also reviewed two random samples totaling 160 LD-203 reports from year-end 2016 and midyear 2017. This methodology allowed GAO to generalize to the population of 45,818 disclosure reports with $5,000 or more in lobbying activity, and 30,594 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 is not making any recommendations in this report. GAO provided a draft of this report to the Department of Justice for review and comment. The Department of Justice provided technical comments, which GAO incorporated as appropriate.

What GAO Found

For the 2017 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 2016 and the first and second quarter of 2017, GAO estimates that
87 percent of lobbyists filed reports as required for the quarter in which they first registered; the figure below describes the filing process and enforcement;
99 percent of all lobbyists who filed (up from 83 percent in 2016) could provide documentation for income and expenses; and
93 percent filed year-end 2016 LD-203 reports as required.
These findings are generally consistent with prior reports GAO issued for the 2010 through 2016 reporting periods. However, in recent years GAO's findings showed some variation in the estimated percentage of reports with supporting documentation. For example, an estimated increase in lobbyists who could document expenses is notable in 2017 and represents a statistically significant increase from 2016.
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 previously held covered positions. On the other hand, over the past several years of reporting on lobbying disclosure, GAO 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 reminding them to file reports or by applying civil penalties.