The Clerk of the House of Representatives and Secretary of the Senate recently issued detailed joint guidance for lobbyist compliance with the Lobbying Disclosure Act, as amended by the Honest Leadership and Open Government Act of 2007 ("HLOGA"). The joint House and Senate guidance replaces and suspends earlier individual guidance provided by each House of Congress. In summary, concerning lobbying disclosure, HLOGA requires the reporting of more information regarding lobbying (and lobbyists), more often. Semiannual Federal "LD-2" lobbying reports must now be filed quarterly, within twenty days (rather than forty-five), of reporting period close. Thresholds for initial registration on an "LD-1" form and periodic "LD-2" reporting have been halved, consistent with the halving of the LD-2 reporting periods from semiannually to quarterly. HLOGA also created a major new semiannual reporting and certification regime for both lobbying entities and individual lobbyists. This information must be reported on not-yet released "LD-203" forms.
The Campaign Finance and Political Law Practice has prepared a client advisory which discusses instances in which this new joint guidance either explains new HLOGA requirements or clarifies issues that arose under the LDA reporting regime pre-dating HLOGA.