Compliance
Do Volunteers Have to Register as Lobbyists? It Depends
November 5, 2024 | Nicole Galloway, Denisse Girón, Karen Kulivan
July 30, 2024 | Lauren Calhoun, Bradley Coffey, Stephanie Meyer
Key Takeaways:
While the heat outside is still sweltering, things are cooling off for compliance. In August, 13 states and five localities will have disclosure reports due. Even with many legislative sessions having adjourned for the year, keep in mind that many jurisdictions still require reporting even after sine die.
In states such as Georgia, Louisiana, and Ohio, lobbying is regulated by the branches lobbied (for example, executive, legislative, judicial, and local). Branches aren’t universal across states, however. For example, 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. Be sure you know which branches you are registered in so you do not miss a report.
The following localities also have disclosure reports due in August.
State | Localities |
California | City and County of San Francisco |
City of San Jose | |
New York | Nassau County |
Washington | City of Seattle |
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 Commision on Ethics and Lobbying in Government (COELIG) as well to avoid hefty fines.
Starting August 7th through the election, those that qualify for California Major Donor Reports will be required to file disclosure reports within 24 hours of making an expenditure. While the California Major Donor Report only applies to a few, it is a tricky and frequently misunderstood report to watch out for.
To determine if you or a business entity needs to worry about the upcoming 24 hour reports, you must first have given an aggregate of $10,000 or more in a calendar year to California political committees (candidate committee, political party, political action committee, ballot measure committee, independent expenditure committee, etc.). If you or an entity have met the threshold of giving an aggregate of $10,000 this calendar year, this will trigger registration with the state of California as a Major Donor.
If you or your company qualify as a major donor committee, you are required to file a 24-hour report if an expenditure or contribution totaling $1,000 or more to a single state, county, or local candidate, primarily formed ballot measure committee, or political party participating in the November 5th election. Note that contributions to federal committees and federal accounts of state and local political parties are excluded from the late contribution reporting obligation.
In August, 29 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 August. 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.
Don’t miss a critical deadline as we enter the final stretch of the election season — learn more about our industry-leading lobbying compliance services. We can also help if you’re running a political committee and unsure of your compliance requirements. Don’t hesitate to reach out to our team with questions.
November 5, 2024 | Nicole Galloway, Denisse Girón, Karen Kulivan
November 5, 2024 | Hilary Smith
October 29, 2024 | Chase Klingensmith, Bradley Coffey