More on the Revised LD-203 Guidance
7.23.2008
Now that the Secretary of the Senate and the Clerk have issued their revised guidance for the LD-203 (reports of payments made for the benefit of or in recognition of Members), the next question is: how much of the new guidance is in the form of liberalizations, and how much poses new challenges for reporting entities and lobbyists? On the face it, the rules have been simplified, and the lines made clearer.
But the Guidance states that the facts matter, and an event could become reportable if there were indications that it more like an honoring event, and the financial support more like a sponsorship, than might be first believed.
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Revised Guidance on LD-203 Reporting
7.17.2008
LDA registrants and individual lobbyists are required to file the new LD-203 on July 30. Just in the nick of time, the House and Senate released revised guidance on July 16 that clarifies the new LD-203 disclosure obligations for certain political and honorary contributions. The full text of the revised guidance is available here.
Listed below are several significant issues raised in the new guidance. We will provide additional analysis of the LD-203, including issues addressed in the new guidance, here in the coming days.
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LD203 Issues: Registrant Liability, Member Events
7.7.2008
- Who is responsible for certification of the information contained in LD203?
- What payments are disclosable by registrants as payments made to benefit a member?
Immediately upon enactment of the new reform law, a leading question of concern to registrants was the liability attaching to the certification of compliance to be filed on LD203. Some would have to file—that is, to "sign"—the certification and presumably to be exposed in the event that a question of the certification's accuracy is raised.
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