The U.S. Government Accountability Office (GAO) released its audit of federal lobbying compliance for 2025. For the audit, the GAO reviewed a stratified sample of 101 quarterly disclosure reports filed for the third and fourth quarters of calendar year 2024 and the first and second quarters of calendar year 2025. They also reviewed random samples of 160 LD-203 reports for the year-end 2024 and midyear 2025 reports. Among its findings, the GAO concluded 94% of filers of lobbying disclosure reports were able to provide documentation to support reported income and expenses, 7% of LD-203 reports were missing reportable contributions, and for an estimated 80 percent of LD-2s, lobbyists provided documentation for all individuals who engaged in lobbying activities. For 2025, the GAO estimated that about 22 percent of LD-2s may not have properly disclosed covered positions for individual lobbyists listed. This estimate is generalizable to the population of LD-2s and does not represent a statistically significant change from prior years. The 45-page report, which was released on June 30, is titled “2025 Lobbying Disclosure: Observations on Compliance with Requirements.”

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Hawaii Redefines Corporate Powers to Exclude Election Spending

Hawaii has enacted one of the most significant state-level laws concerning corporate election activity since the U.S. Supreme Court’s landmark decision in Citizens United v. Federal Election Commission. Senate Bill 2471, signed into law by Governor Josh Green, redefines the scope of corporate powers for entities organized or transacting business in Hawaii by explicitly excluding election-related spending. The law is set to take effect on July 1, 2027, though legal challenges are anticipated before that date.

Understanding what the law allows, which entities it covers, and what penalties apply is essential for any organization with a presence in the state.

What Hawaii’s SB 2471 Changes for Corporate Election Activity

At its core, SB 2471 removes election and ballot-issue activity from the scope of powers available to corporations and other artificial legal entities in Hawaii. This means that covered entities will be effectively prevented from paying, contributing, or expending money or anything of value, whether directly or indirectly, to support or oppose a candidate, political committee, or political party.

The law applies beyond candidate elections. Covered entities are also prevented from spending to support or oppose constitutional amendments, county charter amendments, or other ballot questions once those measures have been formally certified or submitted to voters. Additionally, the law removes the authority for covered entities to make donations of any kind, except  charitable donations.

There is an exception for bona fide news stories, commentaries, and editorials. However, even that exception does not apply if the broadcasting, print, online, or digital distribution facility is owned or controlled by a candidate, political committee, or political party.

Which Entities Are Covered Under the New Hawaii Election Spending Law

SB 2471 applies broadly across entity types. The law covers domestic and foreign corporations, professional corporations, credit unions, agricultural cooperative associations, consumer cooperative associations, limited-equity housing cooperatives, limited liability partnerships, limited partnerships, limited liability companies, nonprofit associations, and nonprofit corporations other than committees.

A critical provision of the bill conditions its applicability on ongoing enforcement against foreign entities transacting business in Hawaii. 

Candidate committees, noncandidate committees, and similar committees created under federal law are explicitly granted the power to engage in election and ballot-issue activity.  These carve-outs preserve the ability of political committees to operate within established campaign finance frameworks 

Penalties for Violations of  Hawaii’s Corporate Powers Limits

Any election or ballot-issue activity by a covered entity will be deemed void. Beyond that, the consequences for violations can include suspension of the entity’s authority to operate or transact business in Hawaii, ineligibility for state contracts, designation as a non-compliant entity, revocation of the entity’s operating instrument, involuntary dissolution, and revocation of tax-exempt status where applicable.

Enforcement authority is limited to two state officials: the attorney general and the director of commerce and consumer affairs. This centralized enforcement structure means that private parties and local officials cannot independently pursue violations, Hawaii’s Law in the Context of the Post-Citizens United Landscape

Hawaii is not acting in isolation. The state is one of several jurisdictions that have introduced measures this year addressing the role of corporate powers in elections. These efforts represent an ongoing legislative response to the 2010 Citizens United decision, which held that the federal government’s restriction on independent political expenditures by corporations, associations, and labor unions violated the First Amendment.

While the Citizens United ruling remains the law of the land at the federal level and as applied throughout the states,  Hawaii is approaching the issue in a novel way. SB 2471 received overwhelming bipartisan support in both chambers of the Hawaii legislature, signaling broad political backing for the measure. However, the law is expected to face legal challenges before its effective date of July 1, 2027.

Organizations operating in Hawaii or monitoring state-level campaign finance developments should track the progress of any litigation closely, as court rulings could shape the future  of similar measures in other states.

Steps for Businesses and Organizations to Prepare

Even though the law does not take effect until July 2027, companies and organizations with operations in Hawaii should begin evaluating their existing election and ballot-issue spending activity. Assess whether your entity type is covered under the law. Identify any planned contributions, expenditures, or ballot-measure spending that would need to be curtailed before the effective date.

For organizations operating across multiple states, Hawaii’s new law adds another layer to an already complex patchwork of state-level campaign finance and corporate governance requirements. State and Federal Communications provides compliance consulting services to help government affairs professionals and corporate counsel navigate these evolving obligations.

Q: My company is a registered lobbyist employer in California. We are sponsoring an invitation-only reception and want to invite state officials. Are there any gift laws or other requirements we need to worry about?

A: The California gift laws allow lobbyist employers to provide gifts to an official with an aggregate total value of $630 or less each year. The gift would be reportable as an activity expense on your quarterly lobbyist employer report. Lobbyist employers must also comply with notification rules when an official receives a gift aggregating $50 or more in a calendar year.

Where notifications are required, lobbying entities must include a notice in all written or printed invitations to events at which an official will receive a reportable gift. The notice must state attendance at the event by a public official will constitute acceptance of a reportable gift. The lobbying entity must also send the official a written notice of the gift’s value after the event. The notice must be sent to an official who received a gift within 30 days following the end of the calendar quarter in which the gift was provided.

For valuation purposes, the amount of the gift to each official is the official’s pro rata share of the total cost of the food, catering services, and entertainment, plus any item provided at the event. Only those officials who attended the event should be disclosed. To determine which officials to include on the lobbyist employer report, it is a good idea to have a sign-in sheet or guest book to track attendance. Immediate family members of officials must also be disclosed if the family member attended the event.

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For more information, please visit the California lobbying entry in our guidebooks. Feel free to give us a call if you have any questions. Not a guidebook subscriber yet? Request your free demo today and keep up with all lobbying, procurement lobbying, and campaign finance compliance.

The Campaign Finance and Public Disclosure Board will be conducting a compliance training for party units and political committees and funds on Thursday, June 5, at 1:00 p.m. The training will be conducted remotely using Webex. The training will provide an overview of campaign finance laws and rules applicable to party units and political committees and funds in Minnesota. The training will last approximately two hours. You may register for the training on the Board’s website at https://cfb.mn.gov/filer-resources/self-help/education-and-tools/live-training/. The training will be recorded, and video of the training will be added to the Board’s website within a week after the training. Additional training resources, including information on how to use Campaign Finance Reporter Online (CFRO), is available on the Board’s website at https://cfb.mn.gov/filer-resources/self-help/education-and-tools/online-videos/?utm_medium=email&utm_source=govdelivery.

I am pleased to share the news State and Federal Communications has acquired the lobbying compliance reporting business of MER Consulting Services, LLC, from its owner and founder, Mary Roche.

MER has been a fixture in Massachusetts lobbying compliance reporting and consulting, having served local organizations and leading companies in the state since 2001. She has had a very successful career in this field.

This move allows Mary to wind down her career, while ensuring a solid transition for her clients to continue receiving professional and thorough political reporting and lobbying consulting services, plus additional support from our larger research and compliance staffs.

Mary will stay on with State and Federal Communications as a consultant in the year ahead as the transition takes place to ensure clients’ reporting needs are adequately served.

I personally am enthused about this development! It will allow State and Federal Communications to continue to grow our business by doing what we do best…providing top-tier and trusted political compliance services. It is a positive endorsement Mary has put her faith in our capabilities to take care of the lobbying compliance reporting needs of her Massachusetts clients.

For the full story, please read the media press release announcement.

Have you assessed the health and overall risks in your company’s government affairs compliance program?

Reputation is your company’s most valued asset.

A strong compliance program will help your company remain qualified for future contract opportunities and will save your brand reputation.

State and Federal Communications is here to help you. Our newest white paper “Corporate Compliance and Knowing the Score: Assessing the Health and Overall Risks in Your Company’s Government Affairs Compliance Program” will inform you on important elements and characteristics of an effective compliance program and tips to audit the effectiveness of your government affairs program.

This new white paper will provide you with the key information to keep in mind as you continue your government affairs program.

Click here to get this FREE white paper today – and ensure you and your team can say “I Comply!”

It is not too early to start planning…Not for Thanksgiving, Christmas, or New Year’s Eve. I am talking about 2018 legislative sessions, primary elections, and the November 6th general election.

The Research Department at State and Federal Communications has been busy, busy, busy updating our website with the important dates you need for 2018.

• When will the states go into session? √
• When are lobbying reports due? √
• Will there be blackout periods in 2018? √
• When will the primaries be held in the states? √
• When are pre- and post-election reports due? √
• Does every state have a general election in 2018? √

You just cannot go wrong when connected with the State and Federal Communications Community to know when your reports are due; elections are held; and when legislatures convene, adjourn, recess, and go into special session.

Access is easy for our subscribers. Sign onto StateandFed.com and input your login and password. The world is then at your fingers. If you need assistance with your access information, please call Megan Huber-Kovachik or Tony Didion at 330-761-9960 and they will provide the information.

You might not be able to tell by my desk, but my calendar is organized. Staying on top of these important compliance dates will help you manage your time in 2018.

This year is almost ending, which is hard to believe. Rest assured, State and Federal Communications is at your side for 2018.

Attorney General TJ Donovan and Sec. of State Jim Condos announced the creation of a joint Committee on Campaign Finance Education, Compliance, and Reform.

The committee’s goal is to encourage a greater level of knowledge to facilitate compliance and to seek out areas where Vermont’s current law could be improved. A series of public forums will be held to seek input from citizens of the state, including elected officials, PACs, and parties.

This input will assist the committee toward creating more robust campaign finance rules.

We are sending out the 2017 Compliance Laws Guidebook for Government Relations Professionals ™ today! Our clients rave about this handy resource. Keep an eye out for this value-added benefit.

If you would like to know more about the guidebook and our online compliance publications, contact us at marketing@stateandfed.com.

 

National:

Gun Control Advocates Find a Deep-Pocketed Ally in Big Law
New York Times – Jessica Silver-Greenberg and Ben Protess | Published: 12/7/2016

On the defensive, gun control advocates are now quietly developing a plan to chip away at the gun lobby’s growing clout: team up with corporate law firms. Together, the firms are committing tens of millions of dollars in free legal services from top corporate lawyers who typically bill clients $1,000 an hour or more. Although law firms often donate time to individual causes, and some firms have worked on gun control on a piecemeal basis, the number and the prominence of the firms involved in the new coalition are unheard-of for modern-day big law. Rather than fighting the political headwinds, the coalition is focusing on courts and state regulatory agencies, among the few places where they might still gain some traction.

Ontario Overhauls Campaign Finance Rules with Sweeping Reforms
Toronto Globe and Mail – Adrian Morrow | Published: 12/1/2016

Legislation that alters the political fundraising landscape in Ontario was approved recently. The new law takes effect on January 1, 2017. It will prohibit all provincial politicians, candidates, and senior political staff from attending fundraising events, ban corporations and unions from giving, and cap donations from individuals at $3,600 per political party annually, among other provisions. The reforms were introduced following revelations that corporate leaders and lobbyists seeking government contracts or favorable policy decisions had spent up to $10,000 to buy exclusive face-time with Premier Kathleen Wynne and members of her cabinet over cocktails and dinner.

Federal:

Business Since Birth: Trump’s children and the tangle that awaits
New York Times – Matt Flegenheimer, Rachel Abrams, Barry Meier, and Hiroko Tabuchi | Published: 12/4/2016

Since his election, Donald Trump has chafed at the suggestion that keeping his business in the family could create problems, despite several episodes during his transition that seemed to mix business and diplomacy. While he has insisted he faces no legal requirement to turn over the company, the Trump Organization said it is preparing an “immediate transfer of management” to Trump’s three eldest children, along with a team of executives. An examination of the professional histories of the three children shows how deeply the family, business, and politics are interwoven, raising doubts about how a meaningful wall can ever be erected between the president-elect and his heirs.

Justices Wrestle with Role of Race in Redistricting
New York Times – Adam Liptak | Published: 12/5/2016

Race and politics divided the U.S. Supreme Court along ideological lines in two cases that could affect the way state Legislatures draw election districts in the future. The court’s more liberal justices criticized maps drawn after the 2010 Census by Republican Legislatures in North Carolina and Virginia for focusing predominantly on the percentage of African Americans in various districts. The more conservative justices mostly defended the maps, either because race did not dictate the contours of the districts or because the motivator was political advantage, something the high court has not ruled against. Several justices expressed frustration that unless they define clearly what is allowed and what is not, they could be left with what Justice Stephen Breyer called “a set of standards that district courts can’t apply, which will try to separate sheep from goats.”

Trump Adviser Has Pushed Clinton Conspiracy Theories
Politico – Bryan Bender and Andrew Hanna | Published: 12/5/2016

Before the election, Lt. Gen. Michael Flynn, who is Donald Trump’s choice for national security adviser, tweeted a fake news story that claimed police and prosecutors had found evidence linking Hillary Clinton and much of her senior campaign staff to money laundering, perjury, and other felonies. Flynn’s tweet is attracting renewed attention after a man fired a rifle inside a Washington, D.C. restaurant that was the subject of false stories tying it and the Clinton campaign to a child sex trafficking ring. Some say Flynn’s fondness for spreading fake news casts doubt on his fitness to serve as national security adviser, suggesting he either cannot spot a blatant falsehood or is just ideologically bent to believe the worst of his perceived enemies.

Trump Sold All Shares in Companies in June, Spokesman Says
Washington Post – Drew Harwell and Rodsalind Helderman | Published: 12/6/2016

Donald Trump sold all his stock back in June, a transition team spokesperson said, showing the president-elect has begun to address concerns about complicated entanglements between his business and new government life. Questions about Trump’s stock holdings came back into view after he criticized the costs of Boeing to build a new Air Force One. Trump’s portfolio included shares in a number of banks, oil giants, and other companies with business pending before the U.S. government and whose value could rise due to Trump’s decisions in office. Those stock holdings, ethics advisers said, offered a potentially troublesome facet of Trump’s private finances that could entangle his public decision-making.

From the States and Municipalities:

Alabama
Ethics Commission Pulls Opinion Over Nonprofit Concerns
Montgomery Advertiser – Brian Lyman | Published: 12/7/2016

The Alabama Ethics Commission withdrew an opinion that said the state ethics law’s definition of a principal – an individual or organization that hires a lobbyist – included not only a firm that hired the lobbyist but anyone in the organization with authority, including executives, officers, and members of boards of directors. Lobbyists and principals cannot provide legislators with things of value. The jury that convicted former House Speaker Mike Hubbard on corruption charges accepted a broad definition of principal favored by prosecutors. That stirred unease in the business community and among nonprofits. Representatives of nonprofits who spoke at a recent commission hearing said many of their chief donors had cut off funds over concerns about the principal definition.

California
EBay Faces Fines from State Ethics Watchdog after Failing to Disclose Sacramento Lobbying on Time
Los Angeles Times – Patrick McGreevy | Published: 12/6/2016

The California Fair Political Practices Commission proposed a $6,500 fine for eBay after the company missed deadlines for filing lobbying spending reports and failed to properly disclose campaign contributions. The commission will vote on December 15 whether to approve the deal. EBay representatives told investigators the failure to file the reports on time was “inadvertent” and caused by a transfer of responsibility for filing during a “corporate transition.” The firm also was late in filing statements required of major donors that disclose their contributions.

Colorado
Amendment 71 Made It Harder to Get Initiatives on the Ballot – What Happens Now?
Denver Post – Brian Eason | Published: 12/5/2016

Anyone able to raise enough money and signatures can propose an amendment to the Colorado Constitution through a ballot initiative, sidestepping the legislative process. But Amendment 71, approved by voters November 8, made that harder to do, so much harder, critics say, that amending the constitution is no longer an option for all but the most well-funded organizations. Statutory ballot measures that fall short of amending the constitution are still on the table, but there are downsides to that approach too.

Florida
Corcoran Offers Lobbyist ‘Training’ to Adjust to New Legislative Limitations
Sunshine State News – Allison Nielson | Published: 12/1/2016

The Florida House passed a sweeping set of rule changes during its organization session, with several of those changes directly affecting lobbyists. To help lobbyists transition to the new guidelines, the House will be holding training sessions on December 13 and December 14 in Tallahassee. The lobbyist training will cover disclosure requirements for lobbyists, as well as other rules.

Massachusetts
Businesses Seek to Overturn Massachusetts Ban on Political Contributions
MassLive.com – Shira Schoenberg | Published: 12/7/2016

Under Massachusetts campaign finance law, businesses are not allowed to contribute to candidates. Individuals can donate up to $1,000 per year and unions can give up to $15,000. Republican lawmakers have tried, unsuccessfully, to bring the amount unions can donate down to $1,000. The law has typically benefited Democrats, who get the bulk of union campaign contributions. Attorneys for two businesses recently tried to convince a Superior Court judge to allow businesses to make the same political donations as labor unions.

Missouri
Lawsuit Seeks to Stop Campaign Contribution Limits Approved by Missouri Voters Last Month
St. Louis Post-Dispatch – Kurt Erickson | Published: 12/7/2016

A lawsuit filed in federal court challenges the voter-approved referendum that reinstated campaign contribution limits in Missouri. The same group that unsuccessfully sought to block the ballot measure before the November election argues the change in the state constitution unfairly limits some businesses and associations from giving money to campaigns. In particular, the change would stop the Association of Missouri Electrical Cooperatives from donating to campaigns and PACs, violating the free speech rights of its members, the lawsuit notes. The legal action comes one day before the new limits are set to take effect.

New York
Anthony Weiner Fined $65,000 for Campaign Finance Violations
New York Times – J. David Goodman | Published: 12/1/2016

The New York City Campaign Finance Board ordered Anthony Weiner’s campaign to repay more than $195,000 in public matching funds he received as part of his failed 2013 mayoral bid.  The board also ordered the campaign to pay a $64,956 fine for spending irregularities, including personal expenses not allowed under the current law.  The campaign committed multiple infractions, the board found, including accepting 21 contributions that exceeded the legal limit, accepting contributions in excess of the limit for donors who have business with the city, and failing to demonstrate how some expenses were made in furtherance of the campaign. New revelations of sexually explicit text messages and photographs, sent to women after he had left Congress, came to light and derailed Weiner’s bid for mayor.

North Carolina
North Carolina Gov. Pat McCrory (R) Concedes Closely Contested Governor’s Race
Washington Post – Amber Phillips | Published: 12/5/2016

Ending an acrimonious stalemate that dragged on for nearly a month, North Carolina Gov. Pat McCrory conceded in his bid for re-election, clearing the way for the ascension of his challenger, Roy Cooper, and giving the national Democratic Party a rare cause for celebration. Cooper, the current state attorney general, declared victory on election night, but McCrory’s allies lodged election challenges in dozens of counties. Most of the challenges proved to be of little consequence, however. As partial results of a recount of more than 90,000 votes that Republicans had demanded in Durham County showed no significant change in the results, McCrory had little choice but to admit defeat.

Washington
EPA, Tribe: State commission not venue for complaint
The Olympian – Don Jenkins (Capital Press) | Published: 12/7/2016

The Environmental Protection Agency (EPA) and a Puget Sound tribe say the Washington Public Disclosure Commission (PDC) should step away from an investigation into whether the What’s Upstream advocacy campaign violated state law. The EPA said a federal audit will answer whether What’s Upstream organizers misspent public funds. The tribe said the PDC has no jurisdiction over how a tribe spends money. Save Family Farming alleges What’s Upstream lead organizer Larry Wasserman, the tribe’s environmental policy director, failed to register his group as a political committee or grassroots lobbying organization. The complaint also named EPA Northwest Administrator Dennis McLerran and Seattle lobbying firm Strategies 360.

State and Federal Communications produces a weekly summary of national news, offering more than 60 articles per week focused on ethics, lobbying, and campaign finance.

One of the most important facets of any professional in the government relations field is knowing what you can, and cannot do, regarding Political Contributions, Lobbying, and Procurement Lobbying. Making a compliance mistake can be costly, in reputation, negative media exposure, and fines.

The laws and regulations in our field are continually changing. And due to the recent presidential and other elections, we expect many more changes to come in 2017.

We are ready for all of this at State and Federal Communications. We are ready to help you!

That is why we have re-branded our 2017 website guides as the Online Compliance Publications for Government Relations Professionals. These four online publications are:

• Political Contributions Compliance Laws for Government Relations Professionals^TM
• Lobbying Compliance Laws for Government Relations Professionals^TM
• Procurement Lobbying Compliance Laws for Government Relations Professionals^TM
• Canadian Compliance Laws for Government Relations Professionals^TM

Note the emphasis from each title, first on ‘what’ compliance area the online publication is intended to serve, and second on our focused audience, ‘Government Relations Professionals.’

These unique online publications are considered invaluable to government relations professionals. They make it easy to decipher and understand compliance regulations, and to accurately report activities to government entities as needed. They are optimized to easily use and search on any device – computer, laptop, tablet, or smart phone – and updated continually so government relations professionals can comply in a timely and accurate manner.

This is an annual subscription-based service, where you can purchase one, two, three, or four online publications, whatever you need, with special bundled pricing available. They provide accurate, comprehensive, and timely information on thousands of compliance rules, regulations, and statutes across the states, the U.S. federal government, more than 600 municipalities, and Canadian federal, provincial, and territorial governments.

In the weeks ahead, we will send our new 2017 brochure of services, so look for it in the mail. You can also read and download a PDF of the new brochure by visiting a special landing page on our website, at: marketing.stateandfed.com. Note, for 2017 we have updated subscription rates (first time in four years), so for subscribers looking to renew and capture 2016 pricing, consider making the payment by the end of this year.

For the many clients who have used our publications through the years, we thank you for your loyalty, and for the new clients that come onboard in 2017, we look forward to serving you.

There is no other company like State and Federal Communications.

Thank you.

Elizabeth Z. Bartz

President and CEO
@elizabethbartz

Lobby Comply is pleased to announce the celebration of our 5,000^th blog post! We will continue to be your expert source, providing the latest news and analysis on campaign finance, lobbying, procurement, and ethics laws.

Thank you to all of our loyal readers!

Most of us have an idea of what lobbying is, but as states expand the definitions of lobbying, more activities may now trigger registration and reporting requirements. And, as states tighten political contribution rules, more and more contractors may run into problems because of pay-to-play laws. But in order to comply with the rules, you need to know the rules.

State and Federal Communications is taking part in two events over the next few weeks looking specifically at these issues. This fall our Compliance Client Specialist Nola Werren, Esq., will present “Compliance: Pay-to-Play and Procurement Lobbying Process” at events with the Public Affairs Council and WASRG, the Washington Area State Relations Group.

As an expert in the field, Nola will share her knowledge and experiences during a Public Affairs Council webinar and at the annual WASRG Symposium. Topics she will cover include the procurement process; lobbying requirements in the states, including best practices to ensure compliance; and pay-to-play laws. It is this area of pay-to-play, the nexus between making a contribution and the award of a contract, that can have far-reaching consequences for a business.

The Public Affairs Council’s webinar will be held on October 27^th and is entitled “Compliance: State-Level Laws and Recent Trends.” The WASRG Annual Symposium begins at noon on November 2^nd at Carmine’s at 425 7^th Street NW in Washington, DC.

Make sure you keep checking in with State and Federal Communications, Inc. We are your #1 resource on government relations compliance.

We had an amazing experience at the 2016 NCSL Legislative Summit. Our team offered immediate, up-to-date knowledge to clients throughout the week.

You can benefit from the same expertise. We are always available to answer questions. Contact us today at info@stateandfed.com.