Ask the Experts – Nuances with the New Illinois Lobbying Disclosure Requirements - State and Federal Communications

March 2, 2011  •  

Ask the Experts – Nuances with the New Illinois Lobbying Disclosure Requirements

James Warner, Esq.

Q: Now that Illinois has semi-monthly reporting, are there any changes to the contents of the report?

A: As of January 1, 2011, Illinois requires disclosure reports to be submitted on the fifth and 20th of each month.  This new schedule began on January 20, 2011.  The Secretary of State’s Office issued a 2011 Expenditure Report Filing Guide concerning how to disclose reportable activity on the Activity Detail Report.  This guide contains some changes for client or lobbying entity reporting.

Individual expenditures made on behalf of covered officials must be itemized with expanded information.  Lobbying entity reports must itemize for each individual expenditure or transaction:

  • The name of the official for whose benefit each expenditure was made;
  • The name of the client on whose behalf the expenditure was made;
  • Whether the expenditure was made on behalf of a client;
  • The total amount of the expenditure;
  • A description of the expenditure;
  • The vendor or purveyor to whom the expenditure was made;
  • The address and location of the expenditure if the expenditure was for an intangible item such as lodging;
  • The date on which the expenditure occurred; and
  • The subject matter of the lobbying activity, if any.

As in previous years, the expenditure reports must also include reporting of lobbying activity that is unrelated to an itemized expenditure.  This requirement is satisfied by identifying:

  • Names of any lobbyists who conducted lobbying activities;
  • The name of the state agencies lobbied;
  • Whether the lobbying action was executive, legislative, or administrative;
  • and the subject matter or description of the lobbying activity.

Please note a lobbying entity or client does not report activity undertaken on its behalf by a contractual lobbying firm.  The contractual lobbying firm has the responsibility of disclosing activities for each of its clients.

When completing the description of lobbying action, the subject matter must identify a substantive issue or a legislative proposal.  Descriptions which are too general, such as “lobbied on behalf of client’s interests,” are not acceptable.  If lobbying is not associated with an expenditure, the subject matter cannot be described as “goodwill.”  The space available for describing lobbying activity is limited to 1,500 characters.  Therefore, brief descriptions may be necessary and logical abbreviations are permissible when needed.

The following is an example of how lobbying unrelated to an expenditure should be reported.  ABC Company has two exclusive lobbyists, Jane Smith and John Doe.  During the covered period, Ms. Smith lobbied Senator Jones concerning Senate Bill 100.  The authorized agent for ABC Company will go through the following steps on the Illinois Lobbyist Registration and Reporting System:

1.       Select Jane Smith as the lobbyist who acted on ABC Company’s behalf.
John Doe should not be selected.;

2.       General Assembly Members should be checked as the state agency lobbied;

3.       Select Legislative Action as the type of lobbying conducted; and

4.       Enter SB100 as the subject matter or description.

While there are not numerous changes to the content of the report, understanding the nuances is important in order to comply with the state’s new reporting guidelines.  Finally, do not forget individual lobbyists are required to complete the mandated Lobbyist Ethics Training within 30 days of their registration date.  Authorized agents and lobbyists will be notified about this requirement via email.


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