If the association retains an outside firm to lobby, the lobbying firm must register if otherwise required to do so, i. Each registrant must file a quarterly activity report LD-2 no later than 20 days or on the first business day after such 20th day if the 20th day is not a business day after the end of the quarterly period beginning on the first day of January, April, July, and October of each year in which a registrant is registered.
Lobbying firms file separate reports for each client for each quarterly reporting period, while organizations employing in-house lobbyists file one report covering their in-house lobbying activities for each quarterly reporting period. All reports must be filed electronically.
The obligation to report under the LDA arises from active status as a registrant with a registration on file for which a termination report has not been filed. A timely quarterly activity report LD-2 is required even though the registration was in effect for only part of the reporting period. So long as a registration is on file and has not been terminated, a registrant must report its lobbying activities even if those activities during a particular quarterly period would not trigger a registration requirement in the first instance e.
A client that is a state or local government or instrumentality must be disclosed as such on the quarterly activity report LD Mandatory electronic filing of all documents is required by the LDA 2 U. The only exception to mandatory electronic filing is for the purpose of compliance with the Americans with Disabilities Act. The online electronic filing system provides usability for people with vision impairments who have the appropriate software and hardware. The LDA does not contain any special record keeping provisions, but requires, in the case of an outside lobbying firm including self-employed individuals , a good faith estimate of all income received from the client, other than payments for matters unrelated to lobbying activities.
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In the case of an organization employing in-house lobbyists, the LDA requires a good faith estimate of the total expenses of its lobbying activities. As long as the registrant has a reasonable system in place and complies in good faith with that system, the requirement of reporting expenses or income would be met. Since the LDA 2 U. Lobbying firms report income earned or accrued from lobbying activities during a quarterly period, even though the client may not be billed or make payment until a later time.
For a lobbying firm, gross income from the client for lobbying activities is reportable, including reimbursable expenses, costs, or disbursements that are in addition to fees and separately invoiced. Organizations that employ in-house lobbyists may incur lobbying-related expenses in the form of employee compensation, office overhead, or payments to vendors, which may include lobbying firms.
Organizations must report expenses as they are incurred, though payment may be made later. To ensure complete reporting, the Secretary and Clerk have consistently interpreted 2 U. Logically, if an organization employing in-house lobbyists also retains a lobbying firm, the expense reported by the organization should be greater than the fees reported by the lobbying firm of which the organization is a client. An organization must contact any other organization to which it pays membership dues in order to learn what portion of the dues is used by the latter organization for lobbying activities.
It is necessary for the former organization to include the portion of the dues that is designated for lobbying activities in the total of lobbying expenses reported by the former organization. A registrant cannot apportion the lobbying expense part of the dues to avoid disclosure. Dues payments for lobbying activities should be included in the estimate for the quarter in which they are paid.
Similarly, all expenses of lobbying activities incurred during a quarterly period are reportable. The LDA definition of lobbying activities 2 U. Examples of lobbying expenses to be included are reflected below. The entire staff prepares a strategic lobbying plan to support the building of the bypass.
This includes both federal and state lobbying.
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The examples below are intended to be illustrative of the possibilities of LDA expense reporting, and are not intended to require detailed accounting rules. These percentages could be averaged to compute the percentage of the organization's total effort and budget that is devoted to lobbying activities. Under this example the organization would include salary costs including a percentage of support staff salaries , overhead, and expenses, including any third-party costs attributable to lobbying.
Example 2: Another organization, which lobbies out of its Washington office, might avoid the need for detailed breakdowns by including the entire budget or expenses whichever the organization believes in good faith is closer to the actual amount of its Washington office. Care should be taken in this instance to also add any additional lobbying expenses to this amount, such as the cost of fly-ins, events, etc.
Charitable organizations, as described in 26 U. The eligible entities include for-profit organizations other than lobbying firms and tax-exempt organizations such as trade associations that calculate their lobbying expenses for IRC purposes with reference to 26 U.
The Secretary and the Clerk believe that this reporting option is available to include also a small number of trade association registrants not required by the IRC to report non-deductible lobbying expenses to their members i. If an eligible organization elects to report under 2 U.
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The electing organization also must report all expenses that fall within the applicable Internal Revenue Code definition. The total that is ultimately reportable to the Internal Revenue Service is the figure that would be used for the quarterly activity report. Registrants are advised that if they elect to report under IRS methods per 2 U. Doing so alters the IRS reportable total, and is not permitted. Example 3: Same circumstances as example 2, but one of the lobbyists retires during the reporting period. Such disclosures are not adequate, for several reasons.
First, 2 U. Many bills are lengthy and complex, or may contain various provisions that are not always directly related to the main subject or title. Even if a bill concerns only one specific subject, a lobbying report disclosing only a bill number is still inadequate, because a member of the public would need access to information outside of the filing to ascertain that subject.
The disclosures on the quarterly activity report must include bill numbers, where applicable, but must always contain information that is adequate, standing alone, to inform the public of the specific lobbying issues.
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An appropriate disclosure of the specific lobbying issue would read as follows: H. The Tariff TAR issue code is used for tariff bills, including miscellaneous tariff bills. Filers must use this general issue area code to report lobbying activity related to tariff issues, including miscellaneous tariff issues. For any other trade-related issues, filers should use the Trade TRD code.
In the Q3 reporting period, the two chemical tariff provisions are each rolled into an omnibus bill e. The Houses of Congress and Federal agencies contacted by lobbyists during the reporting period must be disclosed on the quarterly activity report LD-2 , picking from the list of government entities provided in the online filing system.
Registrants should select the most specific Federal Agency possible. If the list does not display the government entity contacted, then select the department in which the entity is housed. Previously identified lobbyists and new lobbyists for this reporting period must be listed on the quarterly activity report LD-2 if they had any lobbying activities during the reporting period, whether or not they made lobbying contacts.
The General Issue Area on the quarterly activity report is only intended to reflect lobbying activity by lobbyists , and not activity of those who are not lobbyists. The registrant does not report the names of individuals who may perform some lobbying activities, but who do not and are not expected to meet the definition of a lobbyist.
The outside lobbying firm would file its own report pursuant to the LDA, listing the names of its lobbyists, as appropriate. New lobbyists must be disclosed in the appropriate General Issue Area for the reporting period in which the individual first meets the definition of lobbyist. We are aware that there will be situations in which a registrant expects an individual to become a lobbyist and wishes to disclose the name of that individual as a matter of public record. However, the LDA 2 U. Therefore, there may be a period of time in which an individual is legitimately making lobbying contacts but is not identified on the public record until the next quarterly activity report LD-2 is filed.
In such cases, the registrant reports updated information as the LDA requires. A foreign entity is reported on the quarterly activity report LD-2 if both of two circumstances apply: 1 the foreign entity must be an entity that is required to be identified on the registration LD-1 or on the Information Update page on the quarterly activity report LD That, in turn, depends on whether the entity meets one of the three conditions of the LDA 2 U. If a foreign entity has an interest in the specific issues, the quarterly activity report LD-2 requires a description of that interest.
Registrants and lobbyists must file a semiannual contribution report LD by July 30 and January 30 or on the next business day should either day occur on a weekend or holiday for each semiannual period in which a registrant or lobbyist remains active and regardless of whether they do or do not make reportable contributions. If a lobbyist is listed as active on a quarterly activity report LD-2 for all or any part of a semi-annual period, he or she must file a contribution report LD for that period see Guidance Section 8.
Sole proprietors and small lobbying firms are reminded that two contribution reports are required: one filed by the registrant and one filed by the listed lobbyist even if the lobbyist is the registrant and vice versa.
Example: A sole proprietor is registered identifying the sole proprietorship business name as the registrant name. When the registrant contribution report LD is due from the registrant sole proprietorship business organization, the lobbyist contribution report LD is also due from the individual lobbyist. Records of interstate shipments 21 U.
The owner, operator, or agent in charge of a facility must establish and maintain the following records: 1 The written food safety plan, including the written hazard analysis, preventive controls, monitoring procedures, corrective action procedures, verification procedures, and recall plan. Records be kept and be accessible 21 U. Accordingly, management should recognize its responsibility in providing adequate training for new employees orientation sessions and regular review sessions to reinforce necessary practices and implement new practices as appropriate.
Food must meet the regulations of the jurisdiction where it is located. For example, food produced in the United States and then exported to another nation for consumption must first meet U.
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