The LDA, as amended by HLOGA, requires lobbyists to register with the Secretary of the Senate and the Clerk of the House and file quarterly reports disclosing their lobbying activity. Lobbyists are required to file their registrations and reports electronically with the Secretary of the Senate and the Clerk of the House through a single entry point. Registrations and reports must be publicly available in downloadable, searchable databases from the Secretary of the Senate and the Clerk of the House. No specific statutory requirements exist for lobbyists to generate or maintain documentation in support of the information disclosed in the reports they file. However, guidance issued by the Secretary of the Senate and the Clerk of the House recommends that lobbyists retain copies of their filings and supporting documentation for at least 6 years after they file their reports. The LDA requires that the Secretary of the Senate and the Clerk of the House provide guidance and assistance on registration and reporting requirements and develop common standards, rules, and procedures for LDA compliance. The Secretary and the Clerk of the House review the guidance semiannually. It was last reviewed December 12, 2013, and revised February 15, 2013. The guidance provides definitions of LDA terms, elaborates on the registration and reporting requirements, includes specific examples of different scenarios, and explains why certain scenarios prompt or do not prompt disclosure under the LDA. The Secretary of the Senate and Clerk of the House told us they continue to consider information we report on lobbying disclosure compliance when they periodically update the guidance. In addition, they told us they send quarterly e-mails to registered lobbyists that address common compliance issues as well as reminders to file reports by the due dates. The LDA defines a lobbyist as an individual who is employed or retained by a client for compensation, who has made more than one lobbying contact (written or oral communication to a covered executive or legislative branch official made on behalf of a client), and whose lobbying activities represent at least 20 percent of the time that he or she spends on behalf of the client during the quarter. Lobbying firms are persons or entities that have one or more employees who lobby on behalf of a client other than that person or entity. Organizations employing in-house lobbyists file only one registration. An organization is exempt from filing if total expenses in connection with lobbying activities are not expected to exceed $12,500. Amounts are adjusted for inflation and published in LDA guidance. 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. These reports must be filed 30 days after the end of a semiannual period by each lobbying firm registered to lobby and by each individual listed as a lobbyist on a firm’s lobbying report. The lobbyists or lobbying firms must: list the name of each federal candidate or officeholder, leadership political action committee, or political party committee to which they made contributions equal to or exceeding $200 in the aggregate during the semiannual period; report contributions made to presidential library foundations and presidential inaugural committees; report funds contributed to pay the cost of an event to honor or recognize a covered official, funds paid to an entity named for or controlled by a covered official, and contributions to a person or entity in recognition of an official or to pay the costs of a meeting or other event held by or in the name of a covered official; and certify that they have read and are familiar with the gift and travel rules of Congress and that they have not provided, requested, or directed a gift or travel to a member, officer, or employee of Congress that would violate those rules. The Secretary of the Senate, the Clerk of the House, and the Office are responsible for ensuring compliance with the LDA. The Secretary of the Senate and the Clerk of the House notify lobbyists or lobbying firms in writing that they are not complying with reporting requirements in the LDA and subsequently refer those lobbyists who fail to provide an appropriate response to the Office. The Office researches these referrals and sends additional noncompliance notices to the lobbyists or lobbying firms, requesting that they file reports or terminate their registration. If the Office does not receive a response after 60 days, it decides whether to pursue a civil or criminal case against each noncompliant lobbyist. A civil case could lead to penalties up to $200,000, while a criminal case—usually pursued if a lobbyist’s noncompliance is found to be knowing and corrupt—could lead to a maximum of 5 years in prison. Of the 3,034 new registrants we identified for the time periods corresponding to our review, we matched 2,925 reports (96 percent) of registrations filed in the first quarter in which they were first registered. These results are consistent with prior reviews. To determine whether new registrants were meeting the requirement to file, we matched newly filed registrations in the third and fourth quarters of 2012 and the first and second quarters of 2013 from the House Lobbyists Disclosure Database to their corresponding quarterly disclosure reports. We did this using an electronic matching algorithm that allows for misspellings and other minor inconsistencies between the registrations and reports. Figure 1 shows that most newly registered lobbyists filed their disclosure reports as required from 2010 through 2013. For selected elements of lobbyists’ LD-2 reports that can be generalized to the population of lobbying reports, unless otherwise noted, our findings were consistent from year to year. We used tests that adjusted for multiple comparisons to assess the statistical significance of changes over time. 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. For this year’s review, lobbyists for an estimated 96 percent of LD-2 reports (98 out of 102) provided written documentation for the income and expenses reported for the third and fourth quarters of 2012 and the first and second quarters of 2013. The most common forms of documentation provided included invoices for income and internal expense reports for expenses. Figure 2 shows that for most LD-2 reports, lobbyists provided documentation for income and expenses for sampled reports from 2010 through 2013. Figure 3 shows that for some LD-2 reports, lobbyists rounded their income or expenses incorrectly. We identified 33 percent of reports as having rounding errors. On 13 percent of those reports, lobbyists reported the exact amount of lobbying income or expenses instead of rounding to the nearest $10,000 as required. Rounding difficulties has been a recurring issue from 2010 through 2013. The LDA requires lobbyists to disclose lobbying contacts made to executive branch agencies on behalf of the client for the reporting period. This year, of the 102 LD-2 reports in our sample, 42 LD-2 reports disclosed lobbying activities at executive branch agencies. Of those, lobbyists provided documentation for all lobbying activities at executive branch agencies for 30 LD-2 reports. Figures 4 through 7 show that lobbyists for most LD-2 reports were able to provide documentation for selected elements of their LD-2 reports from 2010 through 2013. Lobbyists for an estimated 92 percent of LD-2 reports filed year-end 2012 or midyear 2013 LD-203 reports for all lobbyists and lobbying firms listed on the report as required. Figure 8 shows that lobbyists for most lobbying firms filed contribution reports for lobbyists and lobbying firms as required for LD-2 reports from 2010 through 2013. All individual lobbyists and lobbying firms reporting lobbying activity are required to file LD-203 reports semiannually, even if they have no contributions to report, because they must certify compliance with the gift and travel rules. The LDA requires a lobbyist to disclose previously held covered positions when first registering as a lobbyist for a new client. This can be done either on the LD-1 or on the LD-2 quarterly filing when added as a new lobbyist. This year, we estimate that 17 percent of all LD-2 reports did not properly disclose one or more previously held covered positions as required. Figure 9 shows the extent to which lobbyists failed to properly disclose one or more covered positions as required from 2010 through 2013. As of April 10, 2014, lobbyists amended 18 of the 104 disclosure reports in our original sample to make changes to previously reported information. One of the 18 reports was amended twice—once after we notified the lobbyists of our review and again after we met with them. An additional 7 of the 18 reports were amended after we notified the lobbyists of our review, but before we met with them. Finally, an additional 10 of the 18 reports were amended after we met with the lobbyists to review their documentation. We cannot be certain how lobbyists not in our sample would have behaved had they not been contacted by us. However, the notable number of amended LD-2 reports in our sample each year following notification of our review suggests that sometimes our contact spurs lobbyists to more closely scrutinize their reports than they would have without our review. Table 1 lists reasons lobbying firms in our sample amended their LD-1 or LD-2 reports. 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. The sample of LD-203 reports we reviewed originally contained 80 reports with contributions and 80 reports without contributions. We estimate that overall, for 2013, lobbyists failed to disclose one or more reportable contributions on 4 percent of reports. Table 2 illustrates that most lobbyists disclosed FEC reportable contributions on their LD-203 reports as required from 2010 through 2013. As part of our review, 92 different lobbying firms were included in our 2013 sample. Consistent with prior reviews, most lobbying firms reported that they found it very easy or somewhat easy to comply with reporting requirements.