Q.  As an organization employing in-house lobbyists, what expenditures am I required to capture for inclusion in the aggregate dollar amount reported on my quarterly Federal LD-2 report?

A. There are a variety of expenditures that Federal registrants are required to track and report in an effort to provide a good faith estimate of their activity.  These expenditures include:

• Compensation, expenses and overhead associated with “registered” lobbyist employee activity.  For Federal purposes, a “registered” lobbyist is an individual who meets the statutory definition of a lobbyist and is listed by name on the LD-2 report;
• Compensation, expenses and overhead associated with any non-lobbyist employee who engaged in lobbying activity during the quarter (even though they do not meet the statutory definition of lobbyist).  Their names are not listed on the report, but the value of their activity is included;
• Dues paid to an association or membership organization during the quarter that are attributable to lobbying.  This amount is typically a percentage of the overall payments made to the membership organization and is ascertained by speaking with the outside entity directly.  Importantly, dues payments for lobbying activities should be included in the estimate for the quarter in which they are paid and cannot be apportioned over a longer period of time;
• Retainers/fees incurred during the quarter to outside consultants/firms for lobbying activities.  These fees are required to be included during the quarter in which they are incurred regardless of whether billing or payment has been made.

If we can be of assistance in helping to identify reportable expenditures, please let us know.

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