Lobbying Disclosure: Observations on Lobbyists' Compliance with New Disclosure Requirements
Released: 2008-09-30T00:00:00

Letter

Background

Lobbying registrations and reports are required under the Lobbying Disclosure Act of 1995 (the Act) as amended by the Honest Leadership and Open Government Act of 2007 (HLOGA) to disclose the identities of people attempting to influence the government, the subject matters of their attempts, and the amounts of money they spend to accomplish their goals. The Act requires that lobbyists register with the Secretary of the Senate and the Clerk of the House and file periodic reports disclosing their activities. The Act was amended by HLOGA to make those reports due quarterly (they had previously been due semiannually). HLOGA requires lobbyists to disclose whether they held an official covered position in the past 20 years (rather than the 2 years the Act had previously required), whether the client is a state or local government, and whether any members of a coalition or association actively participated in the lobbying activities. Under HLOGA, lobbyists are required to file these registrations and reports electronically with Congress through a single entry point (as opposed to separately with the Secretary of the Senate and the Clerk of the House as was done prior to HLOGA). The Act, as amended by HLOGA, also provides that registrations and reports must be available in downloadable, searchable databases from the Secretary of the Senate and the Clerk of the House.

The Act defines “lobbyists” and “lobbying activities” and imposes requirements on the reporting of those activities. Under the Act, a lobbyist can be an individual, a lobbying firm, or an organization that has employees lobbying on its own behalf, depending on the circumstances. Lobbyists are required to file a registration with the Secretary of the Senate and the Clerk of the House for each client on whose behalf a lobbying contact is made if a minimum dollar threshold is passed. The registration must list the name of the organization, lobbying firm, or self- employed individual lobbying on that client’s behalf. In addition, the registration and subsequent reports must list the individuals who acted as lobbyists on behalf of the client during the reporting period. For reporting purposes, a lobbyist is defined as a person who has made two or more lobbying contacts and whose lobbying activities represent at least 20 percent of the time that he or she spends on behalf of the client during any quarter. Registrations and reports must also identify any covered official positions a lobbyist held in the previous 20 years.

The registration and subsequent quarterly reports must also disclose the name of and further information about the client. The lobbyist is required to disclose any foreign entities with interest in the client. The lobbyist must report if the client is a state or local government. When the client is a coalition or association, the lobbyist must identify any constituent organization that contributes more than $5,000 for lobbying in a quarter and actively participates in the planning, supervision, or control of lobbying activities. The registration and subsequent reports may either list each organization or make the list available on the coalition’s or association’s Web site and disclose the Web address in the report.

Lobbying registrations and reports must include lobbying activity details such as the general issue area and the specific lobbying issues. The lobbyist must also disclose which federal agencies and house(s) of Congress the lobbyist contacted on behalf of the client during the reporting period.

Finally, the registrant must report the amount of money that was spent on lobbying for the client during the reporting period. The lobbying income or expenses disclosed on the reports are to be rounded to the nearest $10,000. A lobbying firm, or any other organization that is hired to lobby on behalf of an entity other than itself, must report the amount of income related to lobbying activities received from the client during the quarter. An organization that has employees who lobby on its behalf must report the expenses incurred in relation to lobbying activities during the quarter. Organizations may use one of three accounting methods to determine their expenses: the Act’s definitions of lobbying expenses; the Internal Revenue Code definitions for non-deductible business expenses; or, if they are a 501(c) nonprofit organization, the definitions under that portion of the Internal Revenue Code.

Most Registered Lobbyists Could Provide Support for Their Filings and Newly Registered Lobbyists Largely Met Reporting Requirements

We estimate that lobbyists could provide accurate supporting information—in either written or verbal form—on income or expenses for at least 95 percent of all first quarter reports filed that required this information. Neither the Act nor lobbying guidance specifies any standards or requirements for lobbyists to maintain records or documentation to support information disclosed in their reports. Nonetheless, lobbyists were able to provide written or oral support for all required elements of individual reports we examined. However, the extent to which lobbyists could provide written documentation varied for different aspects of the reports. The extent to which lobbyists could provide written documentation to support elements of their filings was quite high for some elements such as income or expenses, but notably lower for other elements such as the individuals who acted as lobbyists. The Act requires lobbyists to make a good faith estimate of either all income received from the client or total expenses of lobbying activities. Although the Act does not contain any special record-keeping provisions, guidance from both the Secretary of the Senate and Clerk of the House recommends that lobbyists retain copies of their filings and supporting documentation for at least 6 years after reports are filed.

We estimate that lobbyists have written documentation to support income or expenses for approximately 91 percent of first quarter reports that required this information. We also estimate that lobbyists could provide written support for issues lobbied for approximately 58 percent of reports and for 47 percent of report information on which house of Congress or agencies were lobbied. Lobbyists had written documentation to support information about the individuals who acted as a lobbyist for 35 percent of reports. Sample sizes for affiliated organizations, foreign entity interests, and the names of individuals no longer acting as lobbyists were too small to provide reliable estimates of levels of written documentation and verbal explanations in support of first quarter reports that required this information.

Our estimates of the levels of lobbyists’ documentation are based on our review of 100 reports, which included 93 reports of lobbying activity and 7 “no activity” reports. Table 1 provides the actual numbers from our sample that formed the basis for our estimates.

In our meetings with lobbyists, the types of documentation we were provided and processes to track lobbying activity to support filings varied widely among lobbyists, with some of the lobbyists in our sample providing comprehensive written documentation supporting information in the reports they filed and others providing less or no documentation, often adding verbal explanations.

Most lobbyists supported their reported information on lobbying income with billing statements, invoices, or contracts.

Some lobbyists supported their reported information on lobbying contacts and issues using e-mails or summaries of meetings with Congress or federal agencies.

Lobbyists who had little or no written documentation provided verbal explanations to support the reported information.

Our sample also showed that just one of the disclosure reports did not match the information provided for one of the specific elements we examined during our review. In this case, the lobbyists we visited realized that the lobbying expenses dollar amount had been reported incorrectly. That lobbyist subsequently filed an amended report to correct the amount of expenses disclosed.

Although the legislation and guidance do not require lobbyists to maintain records or documentation to support information disclosed in their reports, several of the lobbyists we spoke to during our review expressed interest in obtaining advice or information on documentation that would best support their filings. Some lobbyists, for example, told us they would like information from other firms on how to set up tracking and compliance systems before filing deadlines. Some felt that a checklist of useful information and documentation to consider when filing would be helpful.

Lobbyists had systems to track lobbying contacts and the amount of time spent on lobbying activities for an estimated 49 percent of first quarter reports. Some lobbyists had detailed tracking and accounting systems. One large lobbying firm, for example, provided us with a demonstration of a database system that they developed to track their lobbying activity in detail. The system captured data provided by the firm’s many lobbyists about their contacts, time charges, issues lobbied, and clients and generated monthly e-mail reports for lobbyist so that they could verify the information and report any discrepancies. Other firms used lobbying activity tracking systems that were integrated with their billing systems. Of these, some told us that they had recently augmented their billing codes to better track lobbying activity to report under HLOGA.

In contrast, the other lobbyists we spoke to did not have detailed tracking or accounting systems for lobbying activity. These lobbyists estimated elements of their lobbying activity as necessary in preparing their reports. Lobbyists who lobbied and performed non-lobbying consulting services for clients for the same monthly retainer estimated the amount of time spent lobbying versus providing consulting services in preparing their reports. In addition, a number of firms reported they were uncertain of whether to track the time and involvement of volunteers or members of their boards of directors.

Six of the lobbyists within our sample reported some aspects of lobbying activity that did not take place. Some lobbyists told us that they reported individuals as lobbyists even though the individuals were not involved in any lobbying activities for the client in question during the reporting period; reported that they had lobbied certain federal agencies even though they indicated during our visits that such activity did not take place during the reporting period; and filed reports but stated that they actually had not engaged in any lobbying activity for the client in question during the reporting period.

In addition, three lobbyists rounded the amount of their lobbying income up to the next $10,000, rather than to the nearest $10,000 as instructed.

A few of the lobbyists cited unclear and vague law and guidance as a reason for reporting more information than their lobbying activity required. But other lobbyists told us that they added information as part of a cautious approach to the filing process, to lessen the chances that they would fail to fully report. Another reason for reporting additional data was that lobbyists did not want to edit their reports each quarter to reflect what they perceived to be minor changes—such as changes in the names of individuals acting as lobbyists on specific issues or in lists of federal agencies lobbied—and chose to leave this kind of information in their report in case it should become applicable again for a future reporting period.

Most Newly Registered Lobbyists Met Reporting Requirements

Lobbyists who registered in the first quarter of 2008 largely filed disclosure reports for the reporting period as required. To determine whether new registrants were meeting the requirement to file, we matched newly filed registrations from the House Lobbyists Disclosure Database to their corresponding first quarter disclosure reports using an electronic matching algorithm that allowed for misspelling and other minor inconsistencies between the registrations and reports. Our analysis of the 1,460 new registrations showed that the majority (1,358) had a clearly corresponding disclosure report on file, indicating that the requirement for these lobbyists to file reports for specific clients was generally met. However, we could not identify corresponding first quarter reports of lobbying activity for 102 (approximately 7 percent) of the 1460 new registrations.

We brought this matter to the attention of the Secretary of the Senate and Clerk of the House so that they could follow up with the lobbyists to resolve any potential compliance issues. Staff of the Secretary of the Senate and Clerk of the House told us that while the newly registered lobbyists for whom we could not identify corresponding reports may not have filed a report, it is possible that they filed reports with information that did not fully match their registrations. For example, if a client’s name did not precisely match the name listed on the lobbyist’s registration, it would be difficult to match the registrants to their corresponding reports. Figure 1 below illustrates the number of registrations for which we were unable to find a corresponding report.

Some Lobbyists Reported Challenges to Complying with the Act

Some lobbyists identified certain challenges to their compliance with the Act, including uncertainty about how to report various pieces of information about their organizations and lobbying activity. Our random sample of 100 quarterly reports included 86 separate lobbyists (some lobbyists had reports for more than one client in our sample). About half (41 out of 86) of these lobbyists said that they needed further information specific to their own situations, in addition to the law and the guidance provided by the Secretary of the Senate and the Clerk of the House. Many lobbyists told us that when they had questions or needed clarification regarding the law and associated guidance, the staffs of the Secretary of the Senate and the Clerk of the House were helpful at providing needed assistance. For example, some lobbyists told us: They were confused about whether and under what circumstances members of a trade association had to be listed under the requirement to report certain affiliated organizations.

They did not know how to report foreign entity interest in the client if the client is a U.S. corporation with an international parent company.

The issue area codes used to indicate types of lobbying activity are not well defined and may overlap, requiring them to use their judgment to choose between codes that were not entirely applicable to their individual situations.

They were not sure which of their activities constituted “lobbying activity” as defined in the Act.

They did not know how much detail they needed to provide on the specific lobbying issues for each client.

Some lobbyists also cited certain administrative constraints as challenges to their compliance with the Act. Under HLOGA, the deadline for filing disclosure reports is 20 days after each reporting period, or the first business day after the 20th day if the 20th day is not a business day. Prior to HLOGA, the deadline for filing disclosure reports was 45 days after the end of each reporting period. Some lobbyists told us: The new 20-day deadline was difficult to meet because of limitations of their own internal billing or record-keeping systems.

The increased frequency of reporting presented an administrative burden. They found the increased frequency of reporting to be beneficial for their own record-keeping.

Some lobbyists told us they took added steps to help ensure their compliance with the new requirements of HLOGA. These actions included conducting internal training sessions for their staff, hiring outside counsel to give presentations and provide training, and attending training seminars and workshops offered by other lobbying organizations, law firms, and membership organizations in the lobbying community.

In this regard, a vehicle for lobbying organizations to share information may assist some lobbyists in better ensuring the accuracy and completeness of information in their lobbying disclosure reports. HLOGA includes the sense of Congress that the lobbying community should develop proposals for multiple organizations that could provide a number of programs to assist compliance with lobbying disclosure, such as creating standards for the organizations appropriate to the type of lobbying and individuals to be served and providing training and educational materials on reporting and disclosure requirements. The creation of such organizations may assist the lobbying community with minimizing confusion and clarifying the information needed to comply with the Act.

The United States Attorney’s Office for the District of Columbia Assigns Resources Based on Competing Demands and Has Sufficient Authorities to Enforce Lobbying Compliance

Officials from the United States Attorney’s Office for the District of Columbia (the Office) informed us that resources are assigned to lobbying compliance issues based on competing priorities within the Office. In addition to responding to referred cases of lobbyist noncompliance, the Office is responsible for prosecuting all criminal cases in the District of Columbia including cases that would be otherwise prosecuted by state authorities in other jurisdictions. The Office also prosecutes and defends all civil cases in the District of Columbia in which the United States is a party, and initiates legal process to collect debts owed to the federal government. It is the largest U.S. Attorney’s Office with more than 350 Assistant U.S. Attorneys and more than 350 support personnel for carrying out the multitude of the Office’s responsibilities.

Officials from the Office stated that most tasks on referred lobbying compliance cases are administrative, such as researching and responding to referrals and sending notices to the lobbyists requesting that they file reports or correct reported information. The Office has five staff members who work on lobbying noncompliance issues in addition to other duties: a deputy chief, three assistant U.S. Attorneys, and an investigator. Officials stated that the Office’s other resources in its civil work are dedicated to higher priority activities with a higher return to the taxpayer, such as health care fraud.

If the Office decides to pursue a case against a referred lobbyist, penalties may be imposed on lobbyists who intentionally fail to (1) remedy a defective filing within 60 days after notice of such a defect by the Senate Secretary or House Clerk’s Office and the U.S. Attorney’s Office or (2) comply with any other provision of the Act. Penalties, recently increased by HLOGA for offenses committed after January 1, 2008, involve a civil fine of not more than $200,000 and criminal penalties of not more than 5 years in prison. Criminal penalties may be imposed against lobbyists who knowingly and corruptly fail to comply with the Act. Officials from the Office stated that they have sufficient civil and criminal statutory authorities to enforce the Act.

The Office receives referrals of noncompliance from the Secretary of the Senate and Clerk of the House. The Secretary of the Senate and Clerk of the House send referrals after they have twice contacted the lobbyists by letter to inform them of the need to remedy an error or file a missing report. Extended periods of time may lapse between when the Secretary of the Senate and the Clerk of the House send the first contact letter and when they make referrals to the U.S. Attorney’s Office. For example, the most recent referrals were received in April 2008 for the filing period that ended in 2006. According to the Office, lobbyists often respond to a contact letter from the Secretary of the Senate and Clerk of the House after referrals have been received by the Office.

Before the Office sends out its own letters requesting compliance to lobbyists once referrals are received, its staff first reviews the Secretary of the Senate and Clerk of the House databases to determine if that lobbyist has already resolved the compliance issue. Once this has been done, the Office will send a letter to each lobbyist informing the lobbyist of the need to correct the problem or file reports. The Office attempts to verify the lobbyist’s address where letters were returned or no response was received after 60 days. Thereafter, the Office makes a determination whether to pursue a case of noncompliance with HLOGA. Office officials told us that the work involved in this entire process takes a considerable amount of time and resources. For an overview of the referral process, see figure 2.

Referrals have increased in recent years, and as a result, the Office’s workload relative to lobbying disclosure has increased. The Secretary and Clerk automated their referral process in 2004, and began transmitting referrals to the Office electronically in 2006. According to Office officials, the automation of the referral process likely contributed to a significant increase in the number of referrals. Since 2004, the Office has received more than 4,000 referrals from the Secretary of the Senate and Clerk of the House. Because of a lack of consistent records in past years, the Office was unable to provide complete and accurate data for each reporting period prior to 2006 to indicate the number of letters it sent to lobbyists asking them to comply with the Act, and the number of lobbyists who complied after the referral was received. Office officials indicated that such information would be useful to help them better track their workload and make resource decisions.

The Office has not received referrals for the 2007 reporting period. The Office received more than 1,000 for the 2003, 2004, and 2005 reporting periods. In September 2007, the Office received 449 referrals for the mid- year 2006 reporting period. The most recent set of referrals was sent by the Secretary of the Senate in April 2008 and totaled approximately 330 referrals, all of which were for the 2006 year-end reporting period. Office officials provided additional information on these referrals, and explained that they consolidated the 2006 year-end referrals for lobbyists that have more than one report that is noncompliant, leaving 268 lobbyists with one or more filings. Officials researched the Senate database and determined that 16 of the 268 lobbyists filed a report after the Office received the referrals from the Senate. As a result, the Office has recently sent 252 letters to lobbyists asking them to comply with the Act by promptly filing a report or an amendment to correct an issue that has been identified.

The Office does not have a formal, structured approach that enables them to readily prioritize matters that should be the focus of its resources. For example, it does not identify those lobbyists who continually fail to file or otherwise do not comply with requirements of the Act. In commenting on a draft of this report, Office officials stated they have recently begun to redesign their computer database to more accurately track referrals and identify trends in past compliance matters in order to create a more structured approach for assigning its resources. Office officials believe that once this is accomplished it should provide a foundation that will allow the Office to better focus its lobbying compliance efforts. Such a structured approach becomes increasingly important in light of the Office’s growing workload.

The Office has been primarily focused on sending letters to lobbyists who have potentially violated the Act, requesting that they comply with the law and promptly file the appropriate disclosure documents. Resolution typically involves the lobbyists coming into compliance. Office officials told us that since the Act was passed in 1995, they have settled with three lobbyists and collected civil penalties totaling about $47,000. All of the settled cases involved a failure to file.

Under HLOGA, DOJ is required to file an enforcement report with Congress after each semiannual period beginning on January 1 and July 1, detailing the aggregate number of enforcement actions taken by DOJ under the Act during the semiannual period and, by case, any sentences imposed. On September 18, 2008, DOJ filed its first report for the semiannual period ending June 30, 2008.

Conclusions and Observations

Most registered lobbyists could provide support for their filings and newly registered lobbyists largely met the reporting requirements. However, several lobbyists in our sample reported some lobbying activity that did not occur, a circumstance that diminishes the value of information reported to Congress. In addition to a lack of clarity in the available guidance, the absence of documentation requirements and the fact that some lobbyists estimate amounts to be included in their reports may have resulted in some inaccurate information reported to Congress.

Based on these observations, we believe that the lobbying community could benefit from creating an organization to share examples of best practices of the types of records maintained to support filings and use this information gathered over an initial period to formulate minimum standards for recordkeeping; provide training for the lobbying community on reporting and disclosure requirements, intended to help the community comply with the Act; and report annually to the Secretary of the Senate and the Clerk of the House on opportunities to clarify existing guidance and ways to minimize sources of potential confusion for the lobbying community.

The recent increase in public and congressional attention on lobbyists and their interactions with government officials and the increase in disclosure requirements indicate the importance of enforcing the Act. To better address potential issues of noncompliance, the Department of Justice and the U.S. Attorney’s Office’s limited resources need to be targeted toward the most significant and repeated cases of noncompliance. Without a structured approach, the Office does not have the assurance that it is investing its limited resources in the most useful manner. Office officials believe that the recently initiated effort under way to redesign its computer database to more accurately track referrals should provide a structured approach to address problem filers.

Recommendation

We recommend the U.S. Attorney for the District of Columbia Complete efforts to develop plans for a structured approach to focus limited resources on those lobbyists that continually fail to file as required or are otherwise not in compliance. Such an approach should require the Office to track the referrals when they are made, record reasons for the referrals, record the actions taken to resolve them, and assess the results of actions taken.

Agency Comments and Our Evaluation

We provided a draft of this report to the Attorney General for the Department of Justice (DOJ) for review and comment. On behalf of the DOJ, the U.S. Attorney for the District of Columbia provided us with written comments (see app. III). The U.S. Attorney for the District of Columbia concurred with our recommendation and stated that the office has devoted appropriate attention to enforcing the Act and plans to continue to develop an approach to focus limited resources on lobbyists that continually fail to file as required or otherwise fail to comply with the Act. The U.S. Attorney noted that his office is taking or planning to take actions that should allow the office to develop a more structured approach as we recommended. Specifically, the U.S. Attorney indicated that the office plans to enhance its database to improve tracking and has assigned an additional staff member to assist with lobbying compliance matters. The Office of the U.S. Attorney also provided technical comments, which we have incorporated as appropriate.

We are sending copies of this report to the Attorney General, Secretary of the U.S. Senate, Clerk of the U.S. House of Representatives, and other interested congressional committees and members. Copies of this report will be made available to others upon request. In addition, this report is available at no charge on the GAO Web site at http://www.gao.gov.

Please contact George Stalcup at (202) 512-9490 or stalcupg@gao.gov if you or your staffs have any questions about this report. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made major contributions to this report are listed in appendix IV.

Appendix I: Objectives, Scope, and Methodology

Consistent with the requirements of the Honest Leadership and Open Government Act (HLOGA), our objectives were to determine the extent to which lobbyists can demonstrate compliance by providing support for information on registrations and reports filed in response to requirements of the amended Lobbying Disclosure Act (the Act); identify the challenges lobbyists cite in complying with the Act and suggestions for improving compliance; and describe the process of referring noncompliance cases to the Department of Justice (DOJ) and the resources and authorities available to DOJ in its role in enforcing compliance with the Act.

To respond to the requirements of HLOGA, we used information in disclosure databases maintained by the Secretary of the Senate and the Clerk of the House of Representatives. To assess whether these disclosure data were sufficiently reliable for the purposes of this report, we reviewed relevant documentation and spoke to officials responsible for maintaining the data. Although registrations and reports are filed through a single Web portal, each chamber subsequently receives copies of the data and follows different data cleaning, processing, and editing procedures before storing the data in either individual files (in the House) or databases (in the Senate). Currently, there is no means of reconciling discrepancies between the two databases that result from chamber differences in data processing; however, we do not have reason to believe that the content of the two systems would vary substantially. While we determined that the both the House and Senate disclosure data were sufficiently reliable for identifying a sample of first quarter reports and for assessing whether newly filed registrants also filed required reports, we chose to use data from the Clerk of the House for ease of processing. We did not evaluate the Offices of the Secretary of the Senate or the Clerk of the House—both of which have key roles in the lobbying disclosure process—although we met with officials from each office, and they provided us with general background information at our request.

To assess the extent to which lobbyists’ could provide evidence of their compliance with reporting requirements, we examined a random sample of 100 of the 19,861 first quarter reports filed by the April 21 deadline and available in the House database as of our download date of May 12, 2008. We later determined that a portion of the reports in the database were amendments or test cases, and thus 17,801 first quarter reports were in scope for our sample. Our sample is based on random selection, and it is only one of a large number of samples that we might have drawn. Because each sample could have provided different estimates, we express our confidence in the precision of our particular sample’s results as a 95 percent confidence interval. This is the interval that would contain the actual population value for 95 percent of the samples that we could have drawn. All percentage estimates in this report have 95 percent confidence intervals of within plus or minus 11 percentage points of the estimate itself, unless otherwise noted.

We contacted each lobbyist in our sample and asked them to provide support for eight key elements in their reports, including the amount of money received for lobbying activities; the amount of money spent on lobbying activities; the specific issues on which they lobbied; the houses of Congress and federal agencies which they lobbied; the names of individuals who acted as lobbyists for the client listed on the report; the names of foreign entities with interest in the client; the names of individuals no longer acting as a lobbyist for the client; and the names of any member organizations of a coalition or association that actively participated in lobbying activities on behalf of the client.

Our work to examine lobbyists’ compliance was limited to reviewing support provided by the lobbyists, which included both documentation and oral explanations. Neither the law nor guidance currently specifies any documentation requirements in relation to information reported under the Act.

To determine if the Act’s requirement for registrants to file a report in the quarter of registration was met during the first quarter of 2008, we matched the 1460 records in the House’s first quarter registration file as of May 13, 2008, to those in the first quarter report filings using House ID, Senate ID, and text matching procedures. We examined all first quarter registrations filed and signed on March 31, 2008, or before. We deleted 31 duplications of multiple registrations and selected only the most recent registration each lobbyist filed for each particular client. We electronically matched registrations with reports using House and Senate identification numbers, lobbyist organization name, and client name. We identified 94 perfect matches, then relaxed our criteria to allow for minor typos and missing identification codes, and identified an additional 1233 registrations with corresponding reports in the first quarter filings. We could not readily identify matches in the report database for the remaining 102 registrations.

We obtained views from lobbyists included in our sample of reports on any challenges to compliance and how the challenges might be addressed. To describe the process used in referring cases to the Department of Justice and provide information on the resources and authorities used by the department in its role in enforcing compliance with HLOGA, we interviewed department officials, obtained information from those involved in the referral process, and obtained data on the number of cases referred, pending, and resolved.

Our objectives did not include identifying lobbyists that failed to register and report in accordance with HLOGA requirements, or whether for those lobbyists that did register and report, all lobbying activity was disclosed. We conducted this performance audit from March 2008 through September 2008 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Full List of Sampled Registrants and Clients

The random sample of lobbying disclosure reports we selected was based on client names.

Appendix III: Comments from the Department of Justice

Appendix IV: GAO Contacts and Staff Acknowledgments

Acknowledgments

In addition to the contacts named above, Robert Cramer, Associate General Counsel; Bill Reinsberg, Assistant Director; Michael Volpe, Assistant General Counsel; Katrina Taylor, Analyst-in-Charge; Christopher Backley; Ellen Grady; Anna Maria Ortiz; Melanie Papasian; Sabrina Streagle; and Greg Wilmoth made key contributions to this report.

Assisting with lobbyist’s file reviews and interviews were Stephen Ander, Amy Bowser, Dewi Djunaidy, Daniel Dunn, Karin Fangman, Melanie Helser, Ashleigh Kades, Olivia Leonard, Andrea Levine, Ryan Little, Mary Martin, Jeff McDermott, Jackie Pontious, Wes Sholtes, A.J. Stephens, and Tammy Stenzel.