Filing the LD-203 Women in Government Relations December 2008

 When are they due?  30 days after the close of each semi-annual period (Jan. – June, July – Dec.)  Next ones due January 30, 2009  Who must file?  Each active LDA registrant  Each active lobbyist employee of the registrant Introduction: The LD-203

 Who must file?  An "active" lobbyist is any individual who was listed on registrant's LD-1 registration form OR on subsequent LD-2 activity reports, and has not been terminated on Line 23 of the LD-2

Required Disclosure  Three broad categories of disclosure for each filer (registrant or individual lobbyist)  1. FEC-reportable political contributions made by filer or filer-controlled PAC  2. Non-FEC-reportable contributions or expenditures made by filer to entities or events "honoring," "recognizing," designated by covered public officials  3. Certification as to compliance with gift ban

FEC-Reportable Contributions  Filer must disclose any federal political contributions aggregating to $200 or more made by the filer, or a PAC the filer controls, during the reporting period  Reportable recipients: federal candidates; leadership PACs; joint fundraising committees; political party committees

FEC-Reportable Contributions  Reporting issues:  $200 threshold  Reporting dates will not always match

FEC-Reportable Contributions  Registrant must disclose contributions by registrant-controlled PACs  Individual lobbyist filer must disclose contributions by individual-controlled PACs

FEC-Reportable Contributions  No mechanism yet to import contribution data from FEC database or software  Registrants should be prepared to input contribution data

Contributions "Honoring" Members  Filer must disclose several categories of spending  1. Costs incurred to pay for event honoring a covered legislative or executive branch official  2. Contribution to entity designated by a covered official  3. Contribution to entity established, financed, maintained, or controlled by covered official

Contributions "Honoring" Members  4. Costs incurred to pay for meeting, retreat, conference, or similar event held by, or in the name of, 1 or more covered officials  5. Contributions to person or entity made in recognition of a covered legislative branch official  6. Contributions of $200 or more to Presidential library foundation or Presidential inaugural committee

Compliance Tips  Establish information collection system that reaches all necessary staff  Conduct appropriate trainings on gift rules  Adopt and enforce internal policies and procedures to prevent violations of gift rules  Establish deadlines as needed

The Mechanics of Filing  All filing must be done electronically  Step One: Registrant must update and verify of "active" lobbyists   Step Two: Each individual lobbyist must obtain a password

The Mechanics of Filing  Step Three: Prepare and submit reports Documents/introduction.htm