Congressional officials on July 16 released revised guidance on the Honest Leadership and Open Government Act of 2007 to clarify reporting requirements for lobbyists regarding certain “honorary” contributions. The guidance states that “honorary” contributions reimbursed by a lobbyist’s employer should not be reported on the lobbyist’s individual LD-203 contributions report. Instead, only the lobbyist’s employer should report the contribution on its organizational contributions report.
The clarification specifically applies to reportable contributions made “in honor or recognition of” covered officials, including to entities named for a covered official, “established, financed, maintained, or controlled” by a covered official, or “designated by” a covered official. It also applies to contributions and payments to presidential library foundations and presidential inaugural committees. It does not apply to contributions to any federal candidate or office holder, leadership political action committee or political party committee.
The guidance also states that “designated by” a covered official includes, for example, a covered official’s directing a charitable contribution in lieu of an honoraria, as well as a payment that is directed to an entity by a covered official who also is on the board of that entity. It does not include a contribution following “a mere statement of support or solicitation” without some further role by the covered official. Semi-annual contributions reports are required under the 2007 law.
The deadline for filing the first semi-annual report, covering January 1 – June 30, is July 30. No extensions will be given.
Questions about the new filing requirements and the revised guidance can be directed to American Hospital Association’s assistant general counsel, Lawrence Hughes, at (202) 626-2346. The revised guidance is available online.
[ via AHA News Now ]