Compliance
Municipal Lobbying Compliance: Everything You Need to Know
December 2, 2024 | Nicole Galloway
December 3, 2024 | Lauren Calhoun, Dylan Busler
Key Takeaways:
With 2024 quickly drawing to a close, December is shaping up to be a busy month. Here’s everything you need to know to stay on top of this month’s deadlines.
Lobbyist registrations in 41 states, 39 localities, Puerto Rico, the District of Columbia, and the Canadian provinces of Alberta, British Columbia, and Ontario are set to expire. This year, additional jurisdictions are requiring renewals due to the restart of biennial schedules in 2025. Keep in mind that states regulating lobbying by branch may have different registration periods for each branch. Renewals for 2025 will primarily occur between December and January, so it's crucial to closely monitor your jurisdictions to avoid missing any critical deadlines. The map below highlights the states with expiring registrations.
Localities and Territories with Expiring Registrations
State | Localities |
California | City of Berkeley |
City of Los Angeles | |
City of San Jose | |
Los Angeles County | |
Los Angeles County (Metropolitan Transit Authority) | |
Orange County | |
Colorado | City and County of Denver |
Florida | City of Jacksonville |
City of Miami | |
City of Naples | |
City of Orlando | |
City of Tampa | |
Greater Orlando Aviation Authority | |
Hawaii | City and County of Honolulu |
County of Maui | |
Illinois | City of Chicago |
Indiana | City of Indianapolis |
Kentucky | Louisville Metro |
Maryland | City of Baltimore |
County of Montgomery | |
Massachusetts | City of Boston |
New York | City of New York |
Nassau County | |
Suffolk County | |
Ohio | City of Cincinnati |
City of Columbus | |
Cuyahoga County | |
Oregon | City of Portland |
Pennsylvania | City of Philadelphia |
City of Pittsburgh | |
Rhode Island | Providence |
Texas | City of Austin |
City of Dallas | |
City of Houston | |
Washington | City of Seattle |
King County | |
Wisconsin | Milwaukee County |
District of Columbia | |
Puerto Rico |
As a reminder, lobbying in a locality can trigger registration and reporting requirements as well. In states like New York, lobbying any locality or municipality will require a state registration and state bi-monthly disclosure reports, even if you do not lobby at the state level. Make sure if you lobby in New York you are registered with the New York State Commission on Ethics and Lobbying in Government (COELIG) as well to avoid hefty fines.
While most states and localities require lobbyists to renew their registrations periodically, some jurisdictions do not. Delaware, Michigan, and Minnesota are exceptions where lobbyist registrations remain in effect indefinitely, meaning you will remain a registered lobbyist unless you formally terminate your status. If you are no longer lobbying in any of these states, you must manually terminate your registration to avoid filing disclosure reports in 2025. Be sure to act quickly—disclosure reports are due mid-January! The good news is that you can re-register in these states at any time throughout the year.
Along with registration renewals in full swing for 2025, 10 states and 4 localities still have periodic reports due. Check out the map below to see which states have deadlines this month.
Localities with Disclosure Reports Due
State | Localities |
California | City and County of San Francisco |
City of San Jose | |
Kentucky | Louisville Metro |
New Jersey | Jersey City |
Additionally, Florida, Georgia, and Louisiana, may require you to submit more than one disclosure report this month, depending on the level or branch of government you are registered in (e.g., executive, legislative, judicial, or local). Note that Georgia’s branches, or lobbying types, are slightly different (State, State Agency, State Transportation Board, Vendor, and Local). Some states, like Louisiana, allow for all branches lobbied to be disclosed in one report, but most states require a separate filing for each branch.
In December, 12 states have campaign finance disclosure deadlines, plus the District of Columbia and the Federal Election Commission (FEC). If a political committee is registered in one of these states and is required to file disclosure reports, they must do so in December. Check out the map below for the states with important deadlines this month.
Political committees should be aware of their filing schedules. Some jurisdictions (Texas, for example) give the option to report monthly or quarterly. Also, be aware that some states require a political committee to report large contributions within a set time frame of receipt. Political committees should be reviewing contributions carefully to ensure they do not miss a required contribution- or expenditure-triggered deadline.
Keeping up with rules, deadlines, and often confusing requirements is a daunting prospect for teams of all sizes. Let us manage your federal, state, and local registration and reporting responsibilities, or manage your Campaign Finance program. Read more about our Compliance Services here, or get in touch here.
December 2, 2024 | Nicole Galloway
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