Views on Four Bills Dealing with Public Disclosure of Lobbying

Published by the Government Accountability Office on 1977-04-11.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                         DIGEST·                                          ,j;J;r'<· - .Sj\~~~
                                         . COMPTROLLER GENERAL OF THE UNITED STATES                                           278
                                                        .   WASHINGTON,   o.c.   2Q!54B
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                B-129874                                                                                     APR 111977
                                                                                                                                      ...    ~-    .

                The Honorable Peter w. Rodino, Jr.
                Chairman, Committee on the Judiciary·
                House of Representatives
                Dear     Mr~·    Chairman:                                                                                                                     .. ·:·

                     This is in response to your reque~t for our views on
                H.R. 1180 and four related bills, H·.R. 557, H.R. 766, H.R.
                1035, and H.R. 2301. All of the bills deal with the public
                disclosure of lobbying and related activities.

       I             H.R. 1180 and H.R~ 2301, .the most comprehensive of
                the lobby~ng disclosure proposals~ are similar bills entitled
                the "Public bisclosure of Lobbying Act of 1977." A measure
                comparable to H.R. 1180 and H.R. 2301 was passed by the House
                during the 94th Congress but was not. passed by the Senate.                                                                                         . ·:·
                See H.R. 15, 94th Cong., .1st Sess. (1975)~ 122 Cong. R~c.                                                                                                  ~::

                H 11416 (daily ed. September 28, 1976). Unless otherwise
                indicated, comments addressed to H.R. 1180 are equally appli-
                cable to H.R. 2301.

       (             H~R~ 557 and H~R. 1035 are also similar bills but differ
                materially from H.R. 1180 and H.R~ 2301. Unless we indicate                                                            .··.· :.·
                differently, comments addressed to H.R. 557 .also.apply to

      I         H.R. 1035. H.R. 7..66 has no companion bilL Comments on H.R.
                557 and H.R. 766 are integrated with our comments on relevant
                provisions of H.R. 1180.      ·

       l                   1180 would replace the present lobbying disclosure.
                law, the Federal Regulation of Lobbying Act (2 u.s.c. §261Y
                et~.), with a comprehensive new statute defining the
                organizations that must register and report as lobbyists
                                                                                                                                              · ···.


                and specifically describing the. information that those--
                organizations must disclose. H.R. 557 and H.R. 766 have
                a similar ~objective.
                .    We believe H.R. 1180 would ~onstitute a significant
                improvement over the existing lobbying disclosure. law, pre-
                viously cited. In addition to broadening and clarifying
                the definition of those organizations subject to lobbying

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            B-129874                                                        279

     j  '   disclosure requirements, H.R. 1180 would provide additi6nal
            investigative and enforcement p0wers needed to make the
            proposed law effective. Despite these improvements, however,.
            there appear to be certain ambiguities and. omissions in
            H.R. 1180 that should be corrected;.
            I~   H~R.    1180--Scope of Coverage-(Section·3)
                 Section 3 would define who must comply with the bill's
            registration, recordkeeping, and reporting requirements.
                 A.     Coverage· of Organizations that· Retain Lobbyists
                                                                                                          .· ·~ . .

                 Under subsection 3(a)(l), the bill would apply to any

            •organization" (§2(8)) that sp~nds in excess of $1,250 in
            any "quarterly filing period" (§2(9)) to retain another,per-
            son to engage in certain lobbying activities on its behalf.
            The quarterly expenditure threshold in t_his provision differs
            from the $25_0 per calendar quarter . threshold prescribed in
            the comparable provision of H.R. 557~ B.R. 766, unlike both
            H.R. 557 and H.R. 1180, generally require~ a filing before
            lobbying and without regard to the dollar amount expended
            in a lobbying effort.        -

                 Although we have no opinion on the appropriate minimum
            expenditure that should be required before an organization
            must register and report under a new lobbying ·law, a minimum
            quarterly expenditure threshold does seem desirable.
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                 Quarterly expenditures are comparatively easy for lobby-
            ing organizations to determine and for the administering                                                 ·.   :·.

            agency to verify. A quarterly expenditure threshold, in our
            view, is also preferable to an annual expenditure requirement;
            with only an annual expenditure requirement, a lobbyist could
            delay registration for lyear simply by delaying payment
            to the person retained to engage in. lobbying.· Disclosure of                               -    .· ··.
            lobbying activities to Congress and the public must be--timely                        .;   ...

            to be ~ffective. We think the quarterly expenqiture threshold
            provision~ in H.R. 557 and H.R~ 1180 could accomplish this

                 B.     Coverage·of Organi2ations·that Employ·Lobbyists
                                                                                                                 ·   ...        · •.
                 Unlike H.R. 557 and H.R. 7~6, subsection 3(a)(2) of H~R.
            1180 requires registration if an organization employs nat
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                  least one individual ·who spt.nds io· percent of his time or                                :        ·~

                  more in any quarterly filirig period * * *A enga~ed in certain
                  lobbying activities. As we indicated previously, subse·ctiori
                  3(a)(l) would establish a quarterly expenditure threshold for
                  retained lobbyists who are not otherwise employees of the
             II   reg is tr ant.
                        In many instances, we believe it would be difficult for
                  a lobbying organization to determine.and for the admini~tering
                  agency to verify when an organizatior:ial employee had spent                     '\.        ·:.·                ..  ~:      : :         .

                  20 percent or more of his time engaged in lobbying. Further,
                  a lobbying organization could employ 20 individuals to spend
                  19 percent of their time lobbying and escape the bill's regis-
                  tration and reporting re~uir~ments. If just one individual,
                  however, were to spend 20 percen·t of his time lobbying, the                                                                       . ·· ..
                  employer organization would b~ required to register.
                        We believe consideration should be given to alternate
                  or supplementary means by which the degree of an orgahiza~
                  tion' s lobbying efforts c_ou_ld more effectively be measured.                                  ·: .·

                  One. method, of which an example is contained in H.R. 557,
                  might be to apply a quarterly expenditure threshold to

                  organizations that employ indjviduals to engage in lobbying
                  activities.                               ·
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                       c.    eoverage-of-Lobbying-eommanications
                       Subseqtions 3 (a) ( 1) and ( 2) of H. R. 1180 would also
         t        require lobbying organizations subject to the bill.to register.              ,··.
                  and report as lobbyists when they attempt to influence certain
                  executive branch officials off-the-record with respect to any
                  report, in_vestigation (excluding civil or er iminal investiga-
                  tions or prosecutions by the Attorney General), or rule, as
                  well as when they attempt to influence the content ot outcome·
                  of legislation~ Executive branch activities of the type                                 :       :·.
                  covered by H.R. 1180 would also.be covered by H.R. 557~ they                                         .·;.,,               ..
                  would not be covered by H.R. 766. We th~nk it especially wise                                                   .·.·_: ..
                  that the disclosure provisions of ·H.R. 1180 currently cover                 .          :       .,        ·. ·..
                  lobbying d~rected at the described activities of the executi~e
                  branch whi6h, like legislation, may directly affect the public.              .         ·.;            .
                                                                                               :''.>: •,
                  As we testified before your Subcommittee on Admini~trative
                  Law and Governmental Relationi on September 12, 1975, we see
                  no convincing reason why the executive branch is less suscep-
                  tible than the legislative branch to the pressure of special
                  interest groups seeking favored treatment.
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          we note, however, that H.R. 1180, unlike H.R. 557, limits
    its coverage of lobbying communications· directed· to the execu-
    tive bran ch. to communications made to. the exec1:J,}i ve bran ch
    officials listed in sections 5312 through 53.16fof. title 5,
    Unit°ed States Code. These officials are paid at levels I
    through V of the Executive Sc.hedule. With ·certain exceptions,
    H.R. 1180 would cover lobbying communications directed to any
    Congressman or any congressional- :employee. Many officers and
    employees in the executive branch who are not paid at levels
    I through V of the Exec~tive Schedule may, like:congressiona~,
    employees who are covered by the bill, perform duties that

I   significantly impact on public ·and private inte.rests. . :Thus,
    we question· whether it is necessary· or desir_able to exclude
    from the. coverage of H. R. · 11sb organizations. that .lobby . ex€cu:.. .
    tive branch officials who are not listed in 5 u.s.c. §§5312-5316~
          Subsection· 3 (a) ( 1) of II .R. 1180 extends· the bill's cover-
    age to communications made to. influence· the .award of ·Government
    contracts. In pur opinion, this provision needs clarification.               ·:- ·:.•.·.

    As presently drafted, .subsection 3(a)(lJ could be construed to
    require that an organization otherwise subject to the bill keep·
    track of and report routine ·sal-e·s. contacts where the communica-
    tion involved merely relates to· a 'company's performance capa--
    Qili ties.                                          ·
         we note too that subsections.3{a)(l} and {2) of H.R. 1180
    could be· interpreted to apply only .to lobbying efforts under-
    taken in connection with matters actually pending in the Con-
    gress. Whether H.R. 1180 would .also apply when an organization
    attempts -to prevent the introduction of legislation is not clear.
    H.R. 766 specifically cover~ this type of lobbyihg effort~ To
    avoid unnecessary interpretive disputes in th~ application of                                  .....
    H.R. 1180, we believe this ambiguity should be clarified.·
                                                                                  '   . ·..· ·:: :.·:

         D.    Coverage·of·tobbying-communications·nirected·to ·
               Legislative Branch·Ag~ncies  ·   ..   .
         H.R. 1180 does not cover lobbying of the officers and
    employees of legislative branch agencies such as. the General
    Accounting Office, Cost Abcounting Standards Board, Office
    of Technology Assessment, the Congressional.Budget Office,
    and others. ·        ·
         The bill applies to organizations that seek to influence a
    "Feder al officer . or· employee," a key term defined by subsections

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·I·'     B-129874
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         2 ( 6 )(A)-( C). Essentially., this subsection defines a "Federal
         officer or employee". as any Member o~ Con.gress, any congres-
         sional employee, and any officer of the executive branch 1isted
         in sectior:is 5312 through 5316-(of title 5, United States Code.                                 . ._· ..   : ~.
         Officers and employees of legi'slative agencies are not within·
         the scope of this definition. Although subsection 3(a)(l) ·
         specifically exempts.from the bill's coverage organizations
         attempting to influence a lobbying-related investigation by
    j    the Comptroller General, this exemption seems somewhat anoma-
         lous because the Comptroll~r General is not, in our view, a
         "Federal officer or· employee" as that. tetm is presently.       ·
               We cannot speak .for. others. but insofar as the .General
         Accounting Office-; and the Cost Accounting Standards Board are
         concerned, we recommend· that they ·be cove·red by the· bi 11. We
         have no objection, however, to the. rete.ntion· of the· subsection
         3(a) (1) exempting provision.

l              Enactment of this recoriunendatiort would," of course, necessi-
         tate a change in the definition· ·of a "Federal officer or
         employee" (§2(6)). We noted earlier that all-congressional
                                                                                                      --, ..

         employees are currently covered by this definition. In con-
!        trast, the ·coverage of executive branch officials.· is limited
                                                                                                                            .·.   _:,

         to onl.y those officials in._ levels I. through V of the Executive
         Schedule who are listed in 5 u.s.c .. §§5312-5316.} We questioned
         whether it was necessary or· d.esirable to exclude from H.R.
         1180's coverage organizations that lobby ~ecutive branch
                                                                                                      ..·: .. : ..

l        officials .n.ot listed in the cited. sections .of title. 5. Simi-
         larly, we recmnmend ·that lobbying communications directed to.
         an ·officer or employee of. the General Accounting Office or the

I        cost Accounting· Standards: Boa:rd, · 1ike communications·. directed·
         to congressional empJ,oyees, be subject to the bill! s. reg is-
         tration, tecordkeeping, and reportinij requirements. Were this
         done, lobbying activities unrelated to the subsection 3 (a} ( 1}
         exemption would be subject to the bill's registration·, report-                                                            . ...:
         ing, and recordkeeping requirements.          ·                                              .
                                                                                                          .. ··

)             E.    Coverage -of· Indirect· or· Grassroots ··Lobbying
                    Communications        ·
              The registration, recordkeeping, and reporting require-
         ments of H.R. 1180 apply to organizations· whose. lobbying·
         activities include .the retention of ano.ther ( §3 (a} ( 1)) or
         the use of an organization's employee {§3(a)(2)) to.make a
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     B-129874                                                                                .         ·.     ,.

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                                                                                           ,                     .:             ...·.
     communication "directed to" a Federal officer. An organi za-                                 ....

     tion whose sole lobbying activity. is to encourage the general
     public to communicate a particular viewpo1nt to a Federal      ·
     officer would not be subject to the provisions of H.R·. 1180
     because no communications of that organization woul4 be
     "directed to" Federal officers.
j          Under subsection 6(b)(6) of H.R. 1180, an.organization
     that had either (1) spent ·$1,250 in a quarterly filing period
     for the retention of another to make communications directed
     to Federal officers: or (2) employed at least one individual
     who had spent 20. percent of his time .or more in a quarterly
1{   filing period in making communications. directed. to a Federal
     officer, would be .required to report lobbying solicitations·
     to. the public it had either paid for or initiated. When the.                         ·. . .                ',

     organization's lobbying· activities satisfy neither of these
     criteria, however~ the organizatibn is ndt subject tp the
I    bill and solicitations .may go unreported·. Thus, indirect or
     grassroots lobbying-..:that is, encouraging the general public,

     through a solici tat~ort, to cornmunica.te ·a position of ·the
     organization to Congress--would not always be subject to
     full disclosure.                                     ·
          H.R. 5.57 and H.R~. 766 both apply when an organization,
     through its own paid employees or. through the. retention of             .   .    •',

     others, encourages ·the· general public to communicate a ·
     specific position of the organization directly to. Federal                        .· ... ,

          It has been widely reported that certain lobbying organi-                    f·:·

     zations are extremely adept at generating mas~-lett~r-wiiting                     ;··,::::.·                       ..

     campaigns through solicitations to the general public. As a
     result, much criticism has focused on the exclusion of grass-                                                          ~   ..   '   ..
     roots lobb~ing from the disclosbre provisions of the current
     lobbying law. We reconunend, therefore,·· that ·subsections 3 (a) ( 1)
     and (2) of H.R. 1180 be amended to extend' the bill rs applica-
     tion to indirect· or grassroots .·lobbying when the totai direct
     expenses of such lobbying exceed ·a specified dollar amount.

           F.   Exempt·communications
             Subsection 3(b} of H.R. 1186 would qualify s~hsections
       3(a) (1) and (2) by specifically exempting certain types of                                               ....
                                                                                                 ...         .        '·,

       communications from the bill's coverage •. This ·provision con-
     . tains several important exemptions that are ·not included in

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     B-129874                                                                                             ••        • ••• w

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     H.R. 557 or H.R. 766. Subsection 3(b) (3), for example, care-
     fully excludes from the bill's coverage commun.ications by
     an individual citizen, acting solely on his own behalf, for
     redress of a personal grievance or to express his personal
          Another subsection 3(b) exemption piovides that the bill
     shall not apply to:
!               "a communication· (A) made at the request                                                          . ;. . .
                of a Federal officer or employee, (B)
                su.bmitted for. inclusion in a report or·
                in. response. to a publi$hed notice of
                opportunity ·to ·comment on a proposed agency
\               action, or- ( C) su.bmi tted for inclusion in                                 .·.·..
f               the.record, public docket, or public file
                of .a hearing or agency ~roceeding."
I'   A literal construction of the exemption for communications
I    "made at .the request· of a Feder al officer or employee" would
     exempt from disclosure all communications made by a lobbying

l    organization if the communications were made at the request of
     a Congressman. Under this exemption,· any Congressman could
     ask an organization to lobby other Congressmen. Since the
     resultant communicat,ic:m would be made "at the request" of
                                                                                                          .·         .. ·

     a Congre.ssman,, the lobbying organization could escape the                         .. ·.

l    bill's disclosure requirements.
            The definition of "lobbying" in H.R. 557 only exempts a
     commmunication maae·to the requesting Congressman or to an
     entity., such· as a congressional committee,· that the requesting
     Congressman officially represents, H.R. 766 contains· an exemp-                    .      ·~·   ..
     tion comparable to that of H.R. 557, Although the subsection
     3 ( b) exemption for communications made •rat ..the request of a                                     ·· ...
     Fed~ral officer or employee" may have .been intended to be lim-                                               . :   .. :·... ·.
     ited to communications made to the requesting Federal officer
     or employee, we recommend the provision be amended to exempt
     those communications made to the requesting official.
          Subsection 3(b)(S) of H.• R.·1180; unlike the.other lobby-·
     ing disclosure. proposals, would also exempt from the bill's
     coverage a communication by an organization on any subject
     if the communication is directed to the two Senators and the
     Representative that represent the State and the congressional                                                              .:   .·
     district, respectively, where the organization maintains its
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           I    B-129874

               principal place of business. This exemption is commonly
               referred to as the "home.-S.tate" e:l{emption. This particular                                                             ··.·.·.
               version of the exemption, by not e'.Xte·nding ~ts applicability
               to all Representatives of a State, avo_ids the disparate treat-
               ment and inequities that could result where one organization's
               principal place of business is iri a State having a- large con-                      .. :
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                                                                                                                                ....           ..
               gressional. delegation and wbere.another organization's prin-                                 .        .~.   . .. · '.

                                                                                                        .            ··· . .
               cipal place of business is in. a S_tate having a smaller                                          ·';                .     ,·.'
               congressional delegation.          ·                                                                         ·'•
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                    All States have two Senators and an organization other-·                            ~        . ·.               ..
       f       wise satisfying the subsection 3(b)(S)·crj.teria can,·w'ithout
               triggering the bill's disclosure requirements, communicate
               with either or both of the Senators w~o represent. the State
       I       where the organization has its principal place of business.
       !       In the· case of communicatiOns to Repre·sen_tatives, the exemp....:
               tion applies only to communications directed to the Represen-
                                                                                                   : ~-      .        .,

               tative who represents the cong'iessional district where the                              .·.·                                   -
       J       organization has its principal place o~ busiriess.                                                     .·.·                ..

                        The "home-State" exemption i-s qualified in two other ways                               .      ·.;

                 that should limit the ability of parent. organizations to uti""'.'
               . lize their State 11 affiliates, 11 a term defined in $ubsection

                                                                                                  .. .                  .   ~       ...        ~   ..·        .
                 2 ( 1) of· the bill, ·to evade the pil;L' s disclosure requirements.                                                                 '::·.
                                                                                                                           ·· ...
                 To be exempt, an "affiliate" must lobby on its own initiative.                         ... · .. ·
                 and not at the "suggestion, request, or direction;" of any
                 other person and the costs of the lobbying must be bo~ne by
   1             the local organization·.•·                  ·
   i                 Finally, H.R. 1180 does not include several exemptions
               contained iri the other lobbying disclosure. bills. For example,
  1            H.R. 557 excludes communications by a Federal officer or employee                 : ..·.
                                                                                                                    ·....           ....
               from its definition· of 11 lobbying. 11 H.R. 766 contains an analogous                                           _

               exemption. It .may 'be that communications between officers and                               - . ·...                      ;   .
               employees of the executive and legislative. bran ch es are ·exempt                '·''

               under other provisions of H.R. 1180, such as the <lefinition of                      :-.        ·,

  i            "organization" in subsection 2(8). We. believe, however, that                                                              ·.. ··
  '            clar if±cation of the bill's application to this special category

               of communication would be .desirable. Since subsection 2(8)
               defines the term "organization" as includini "any coiporation,"
               we also recommend clarification of the bill's a.pplicabili ty
               to communications- by Gover;nment corporations.

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       II.   H~R.   1180--Registration· (Section 4)
            Section 4 of H.R. 1180 would require each organization
       subject to the bill's .disclosure requirements to register with
       the Comptroller General within 15 days after becoming ·a lobby.-
       ist. A registration in any calendar year would be effective          :-;.·.                •.•       ..
       until January 15 ·of the suqceeding calendar year.
             H.R. 1180 would place the primary onus of registration
       on the organization on who_se ·behalf lobbying services are per-
       formed. H.R. 557 and H.R. 766, on the other hand, place the
       responsibility to register directly on the .person who will
       perform lobbying servicesj not ·necessarily on the person or                      .              ..::. . .·
       organization on whose b~half the services will be performed.                                              .    ~·   .
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  L    Further, H.R~ 766, unlike both H.R. 557 and H.R. 1180,                                      ~·

       requires registrationj .except in unspecified "extenuating
       circumstances," before· any lobbying activity may properly be•                '       : . . ..
       engaged in •. This requirement could prove unduly burdensome to                       :· ··.

  \    the registrant and .monitoring compliance with a pre-lobbying
       registration provision would, in our view, be admiriistra:-
·~     tively impracticable.     ·         ·
, 'I         The amount and types of information that an organization
       must disclose when registering under B.R. 1180 would be lim-
       ited when compared to the registration information -required
       under the other lobbying disclosure proposals. Subsection 4(b)
       of H.R. · 11so would require that an organ·ization' s registration
       ·statement contain ( 1) ·an identification of the organization
       and a general description of the methods used to arrive at                ;           ::
                                                                             .                                   ..
       a position on an· issue before the legislative or executive               ~                           '

       branch, except that the registration need not disclose the
        identity of the organization's members;· and (2) an identifi-
       cation of the person retained by the organization (§3(a}(l))
       or the persons employed by the organization (§3(a) (2)) to                                  ... :·
       engage in certain lobbying activities. Subsection 4(b)(l) pro-

       vides that the registration need not identify an qrganization's
       members and subsection 4(b)(2) would reauire disclosure of
       persons retained or em~loyed to engage In lobbying activities.
       We recommend clarification of H~R •. 1180's registration disclo-              ·'
       sure requirements when a_member of an organization is also
       an employee who lobbies on behalf of the registrant.
                                                                             _:', :: .
             Under H.R. 557 and H.R. 766, the regi~trant would be
       required,: to disclose· substantially all of the information
       required under H.R. 1180. In addition,. the registrant would be
                                    - 9 -
           . B-129874

            required to identify the issues or measures to be lobbied and
            describe the financial terms or conditions under which an
            employed or retained ·lobbyist per formed services. Under H. R.
            557, the Comptroller.General could direct the registrant to
            furnish additional information not specifically required by
            the bill.
            I I I . H.R~·ll80-~Recordkeeping (Section                     S)
                 Section 5 of H.R. 1180 would require lobby·ing organiza-
            tions and. pe.rsons retained .bY such organizations to maintain
            records relating· to . their lobbying activities· in acco.rdance                                             :   . ·· ...           ··

            with regulations prescribed by the Comptroller General. Under
            subsection 5(b), records would be preserved by the lobbying
            organization for a period. of not less than. 5 years after the.
            close of the quarterly . filing. period to which the records                                                                               ·.·;
                                                                                                                                                                .. ·...~..
            relate. The fact thab'.persons retained .by a· lobbying organi-                                                                    .....      -:'     .·

            zation will also be required to maintain and preserve records
            should facilitate verification of the iobbying organization's
            registration and reports, as· well as investigations of the                                                      :· .. · ...
            organization's lobbying activities.

                  H.R. 557 and. H.R~ 766 specifically describ~ the informa-                                                     ...    _.
       J    tion that must be contained in a registrant's re~ords but,
            unlike H. R. 1180, do .not author.ize the issuance of regulations·
            governing the· maintenance of records. While·we think it des-ir-
            able that lobbyists be. sufficiently apprised of the records ·                                                   ··.··.-.

            they must maintain and of the information those records must,       .

       l    contain, we· consider the authority to issue regulations govern..,.
            ing the maintenance of records essential to establish fair,
            realistic and necessary recordkeeping requirements as experi-
            ence· is acquired in administering a new lobbying disclosure
                                                                                                                                            ·.. ·. - .. : ..
                                                                                                                                               ..... •..; .
                                                                                                                             ·:,. -~· ...... -: .:.
                                                                                                                                                        :·'. .··
                 The final major difference between the recordkeeping                                                    :... ~~        ...

            requirements of H.R. 1180 and those of the other l.obbying
            disclosure bills is the time period prescribed for the preser-
            vation' Qf lobbying records by lobbyists. H.R. 1180 would
            establish a 5-year record· retention period; H.R •.557 ·and R.R.
      Jl    766 prescribe a 2-year retention period. Requiring a lobbyist
      ~     to retain his records for a period of 5 years strike~ us as
            fair apd not overly burdensoni.e. Such a retention· period should
            allow sufficient time to thoroughly verify and investigate an
            organization's reported lobbying ·activities and, where neces-                                                            ..
            sary, to seek civil or criminal sanctions. A s~bstantially
                                                                                                                         . ·_....
                                                     - 10 -                                                              :·, ·::..

     ·~~~T:.c~iiwiitir~~-HFif&1r~•~4Wtt•~f§~tm}~t~t~~~~it!tl!!fi~i1•111~:JHi.;?.i:K~}trfri1{·~;~"~>:~ c-·~~r.r::·;:s;~_>:: ·
r~   ,.;

                                                                                                                           ·..   ~

      shorter retention period, such as that adopted by H.R. 557 and
      H.R. 766, could result in the destruction of records essential
      to the enforcement of any new lobbying ··disclosure law. ·
      IV.   H~R~   -1180-'--Reports · (Se.ctJop. .6)

           Section 6 of the bill would° require· lobbying organizations
      to file quarterly reports with the Comptr.oller General. The
      information required .in :these reports would be considerably
      more detailed than the information required for registration
      under subse.ction 4(b) • . Once again, however:., the·.reporting             ~·    . ·•' ;      .
      requirements of H.R. 1180 are different from the reporting
      provisions of the other lobb1ing disclosure proposals, includ-               . ·.··.
      ing H.R. 230.l.
             H.R. 1180 arid ·H.R. 2301' are similar in th~t they would
       require lobbyists.' repo·rts ·to include,, among· other information-,
       the "total expenditures 11 that· ·an organization made for .subsec-
       tion 3 {a)' lobbying activiti~·s. an9 an identific:::ation of persons
       retained or employed: to lobby and expenditures made in · connec-
       tion with such retention or employment. Both bills would                                 ... .                      .     .,

       require an itemized disclosure of each expenditure in excess                         .        '·,,. '·· ...

       of $25 made to or for the benefit of identified Federal offi-
       cials. With regard to this l:a-tter category of expenditures,
       B.R. 1180, but not H.R. 2301, would re~uire a lobbying .organ- .
      .ization's expenditures to individual Congressmen to be referred                                                         • ·-: !
       by the Comptroller General to Congress' Committee on St.andards.
       of Official Conduct if the~aggregate expenditdte ·exceeded $100~                     ,.,       ........

           A report filed under H~R. 1180 wou,ld contain a descrip-:-
      tion of the "primary issues" on ~hich the organization spent .
      a "significant amount 11 of its efforts~ ·An H~R. 2301 report,
      on the other hand, would contain (1) a description: of the 25
      issues on which the organization spent the greatest portion
      of it~ lobbying efforts and (2) a general description of all
      other lobbied issues.                                                    ;._      ::-··.

           Reports filed.under H~R. 5~7 would disclose each issue
      that an individual lobbyist sought to influence and would
      identify each lobbyist as well as the person or organization
      on whose behalf the specific lobbying servibes were·p~rformed.
      And reports filed under H.R. 766 would contain substantially
      all of the information required to be reported under the other
      lobbying disclosure proposals as well as. ·any other informa-
      tion required by the Compt:rollei, General.
                                                                                   ·· .. ·,
                                           11 -
                                                                               ·.-·: ..
                                                                               -  ·--'·                    ·,

                                                                                   ··.·: .. ·:· ·.
                                                                               ..       .         ·. :-~        :.
                                                                                                    .'          ..     .


                                                                                                    ·. .
                                                                                                      . ·: ...
        take testimony by deposition, issue subpoenas, and initiate
        civil actions for the sole purpose Of compelling compliance
        with a subpoena.                                                                  :·· ... ·

             The administrative powers and proced~res. prescribed in                      ..·: .... · : ...,.·
        H.R. 1180 should significantly improve the·effectiveness of.                                  ..        ..         \~,

        lobbying disclosure. We do have reservations, however, about
        an apparent condition attached to one of. the powers prescribed
        by subsection 8(a}(7) of H.R. 1180.

             A.    Author.ity-· to. Issue ·-Rules· and· Regulations

             Subsection 8 (a) ( 7) authorizes the -Comptroller General
        to prescribe· only· "procedural rules .and regulations·" considered
        necessary to carry out the provisions .of the bill in an effec-
        tive and effi.cient mariner. (Emphasis added.). We believe the·
        characterization "procedural" may be misleading •. If the only
        effect of the "procedural" pro'vision is t·o prohibit the Comp-
        troller General from requ.iring more information or ·greater
        specificity than would be allowed under the regist.ratioh and
        reporting sections of the bill, we certainly have no objection
    J   to the purpose of the condition. We cannot be certain, however,
        that the courts will adopt such a .narrow interpretation of      ·
        the provision~                                                             ·... ·:

             Subsection 8 (a) { 7) ·contains the. general rule-making author-      .· .. · :.: . . ··
        ity for implementing .. the .bill. anq the •"prOCedUr al II prOViSiOn        :.: ::· ·: .···
        could af feet. rule-making· under. other sections of the bill. If,
                                                                                   .     .      . ·.. ~·             ...
        for example, a gener:al. principle ¢oneerning the bill "s appli-
        cability evolved in a series. of ·aavisO:=ry opinions ( §9) and the
        Comptroller General sought to promulgate a regulation embodying
        this principle, would ·a court conside.r the regulation "pro-
        cedural" and enforce the regulation,· or would· the· court hold         ,. .. ··

        that the rule was. substantive and that the.Comptroller General                .. ,.        :'.~

        exceeded his authority under subsection 8{a) (7)?. If such a
        principle were not formally embodied in a.regulation, but was
        nevertheless generally applied as pr~cedent in subsequent
        advisory opinion determinatio~s~· would a court ~onclude that
        the principle as applied was really a· de· .facto regulation
        having substantive characte_ristics? · -

             In short, due to the lack of specificity in subsection              ···!-''

        8(a}(7), we do not know what effect the "procedural" condition
        may have on the Comptroller General's ability to implement H.R.
                                                                                                      .    ;_'

                                       - 13 -

                                                                                 ',:           ·.

                                                                                                    :: ·~·'-.,_ .: .;·
                                                                                                           .. • ...··'


     1180 in an effective·andefficient manner. We must recommend,
     therefore, that the "procedural" provisi:on be deleted.
          B.    Congressional· Veto.

          We believe section 12 bf S~R. 1190 ~reates an unn~cessary
     obstacle to the effective discharge of the Comptroller General's
     responsibilities under ·other .provisions of H.R. 1180. Under
     section 12, all proposed regulations must. be transmitted to
     the Congress before they may take. ef feet. Either House of the .
I    Congress inay veto .a regulation within 90 calendar days of. con-
     tinuous session following transmittal ·0£ a proposed regulation~
lI        This provision has several drawbacks. It would add
     another administrative step prior to· implementation of the
     bill and prevent the expeditious modification .of existing
     regulations. It would prevent the timeJy impte·mentation of H ~R.
     1180 and the issuance .of urgently needed regulations. The
     delay that would be caused by this provisiori, Jn our opinion,

     is unnecessary since the Comptroller General, .under . section
     B(b) of the bill, would typically obtairi and consider comments                   ... ·. . . .
                                                                                             - ···.,· ..
     from the public and, of course the Congress, before the regu-
     lations could become effective.                  · ·

            Moreover, if the Comptroiler General incorporated a
     ·judicial interpretation of H.R. 1180 in a proposed regula-                                           ·.:·· ...
      tion or proposed .a . r.egulation implementing, for example., H.R.
      1180 's definitional section, either· House of the Congres.s ·                   ·.         .
                                                                                            ... : ,.···
                                                                                                                   .~· :
      could veto the rule within the prescribed time· period, This         ..      .         .'       ..     :.
      latter situation could result in the . anomalous situation where
      H. R. 1180. had become .law in the usual manner by passing the.
      Senate and the House arid receiving the President's appro.val,
      but either House could effectively frustrate the law's imple-
      mentation by a single-house veto.                 ·

          H .R. 766, like H.R. 1180, would designate the Comptroller       ;....   :::
                                                                                                      . ._... ::           .
     General as the official responsible for administering the. new
     lobbying disclosure law. Although H.R. 766 ·imposes administra-
     tive duties on the Comptroller General much in the same ·manner
     as H.R. 1180, the authority to promµlgci;te rules and regulations
     under H.R. 766 is not encumbered by 'the ttprocedural limitation"
     found in subsection S(a)(7)· of H.R. 1180.

                                       14 -

                                                                                                                          : :·..

                                                                   292                                                                       .:
                                                                                                                      :·.' :. ....


         H.R. 557 places responsibi.lity. for adm:j.nistration in the
    Federal Election Commission and H.R •. 1035 would place the
    responsibility. in a new Federal Lobbying Disclosure· Commission,
    an independent agency in the executive branch. We have no
    special information bearing on the advantages of transferring
    the administration of lobbying disclosure to· the Federal Elec-
    tion Commission. With·respect to the establishment of a Federal
    Lobbying Disclosure Commission, .we have reservations whether                                                   :·    .. :
    the task warrants the· establishment of a new agency for the                                                           ..· ·.' ·." ..
                                                                                                                                . . ·...
    sole purpose of disclosing 1.obby.ing ·activities.
    VI.   H.R~   ·11so--Enforcement· (Sections·9 ana-10)

          Finally, we would like to discuss :the enforcement: provi-
    sions of H.R. 1180. The enforcement scheme envisioned by H.R.
    1180 would impose primary enforcement responsibility on the·
    Attorney Gener al,: with the Comptroller. Gener al playing a ·limited
    role.                                  ·

           Under section 9 of the ·bill, the Comptroller General, at                                               .:.:.
     the request of any individual or organization,. must .. render
                                                                                                                 ..-:-. ...
     written advisory opinions ·respecting the applicability of
      the bill's recordkeeping, registr~tion~ or r~porting require-
     ments to a.ny specific set .of facts involving the .requesting.
      individual' or organiza~ion, "or other. individual or organiza~
     tions similarly situated." Section 9 goe~ on to provide,
                                                                                                                          : . .··
    ·however, that an. -individual or · org anizat.ion "with respect to
     whom an advisory opinion is rendered" is presumptively in
)    compliance ·with the law if the advisory opinion. is .adhered to
      in good faith. (Emphasis added.) And subsection 9 ( 3) provides
      that any individual or organization "whd has received and is
     aggrieved" by an· advisory opinion may file a civil declaratory
     action against the Comptroller General in Federal court.
    · (Emphasis added.)

          We r.ecommend that section 9 be clarified to specifically                                                                 :        . ·...    ·~    ..
    indicate whether "individuals.or organizations similarly
    situated" who have not specifically requested ·an advisory
    opinion may ( 1} claim the compliance· with the law: presumption
    ( §9} or ( 2) file a declaratory action as a party aggrieved by
    the advisory opinion (§9(e)).

         Under section 10, the Comptroller General would be
    responsible for conducting investigations ~hen he has reason

                                    15 -                                                                         .' ·:·
                                                                                                                                        ·.    ~:.     ' ..

                                                                    '..-,..-.··c··-·····c·•   ·~ ~.·~ .   ·...

       to believe that an individual or an. organization violated any
       provision of the bill.
                                                                                                 .•, :>_. :
                                                                                                      :     .·
            Based exc:t,usively on the language of. this provision, it                                                ...·
       could be argued that before the Comptroller General may order
       an investigation, there must be.some basis--such as a com-
       plaint or apparent inconsiste·ncy in a registration statement
       or report--for forming a belief that the law may have been
       violated. In short, the Comptroller General may be prohibited
       from conducting investigati.ons on his own initiative, without                            ~·:    .': :"' ... :
       some evidence that a violation has occurred or is -about to                                                                  ~·

       occur. In our opinion, such·. a restriction on the Comptroller                            ..
                                                                                                  .         ·. . . .

       General's investigative authority could prove troublesome
       because it could conceivably bar genetal compliance audits or                                        ...........
       investigations, thereby handicapping our ability to ·ensure                                ·~·       .-•            .

       that organizations are complying
                                          with the law's

            Subsection lO(b) provides that if the Comptroller General
       determines, after· any investigation, that there is reason
       to believe that a lobbyist has.--eng aged in acts that constitute

       an apparent civil violation of the law, he shall attempt to·
       correct the c:tpparent civil· violation through informal methods                                                        ·.             :-           .
       of conference and conciliation.
             If these informal methods fail,· or if the apparent viola-                          .· .                          ..                      ;
       tion seems criminal in· nature~ the C9mptroller General would                              :··          :.·

       be required to refer the matter to the ~ttorney .General. H.R. ·

   I   il80 would require the AttornE;!y General to report.· back period-
       ically to the Comptroller ·G-eneral on the status of all matters
       that have been refer·r:ed. It is the Atto·rney General, however,
       who would have the exclusive authority to· enforce the sub-
       stantive provisions of the bill through civil and criminal                                                  '.      . .. . . .
       enforcement proceedings. In addition, the Attorney General
       would be empowered to defend all de:-claratory actions· that
                                                                                                 "·:· . ·.:
       challenged advisory opinions rendered by the Comptroller
  l    General on the regi~tration, recordkeeping, and reporting
       requirernen ts. Al though H.R •. 1180 would authorize the Comp-
                                                                                                   :.-···.' ...:

                                                                                                                       •                      ·· .. · . :


   I   troller General to -seek .. court enforcef[\ent of subpoenas
       (S7(a)(6)), a matter we ·alluded' to earlier, the. bill does
                                                                                                 .        .:          '.

       not authorize the Comptroller General to bring a civil·
       enforcement action under   anx    circumstances.
            we believe .the administering. agency should be vested
       with civil enforcement o,uthority generally, and the authority
       to conduct civil litigation in particular~ we· have serious
                                                                                                 '.         ·.

I~                      .          .
                                                                                                                  ..           ·;   ...·•·
                                                                            . ·.~ ... :.::·~-:·. ~                                                             •' :·   .
                                                                              . .. .   .   ·~   ;.      .

         reservations whether th-e bill's.pret:ient allocation of ·author-
         ity between the Comptroller General and the Attorney General
         would prove to be workable or effective.

              Disputes undoubtedly would· ari·se between the Comptroller
         General and the Attorney General ove.r questions of statutory
         interpretation, the disposition of particular cases, and other
         legal and policy matters. . The bill would establish no pro-
         cedure for resolving.these ·disputes. Moreover, althouqh the
         Comptroller. General wouid have primary responsibility ~or
         implementing the. law,. the :Attorney General would have ultimate.
         control because. he alone would have· authority to go to court
         to compel complia.nce. ·                          ·
                                                                                                        :   .··..... .
                Granting the Attorney General exclusive authority to
           initiate civil enforcement actions also wpuld tend. to under--
           cut several important functions specifically given to the
         . Comptroller General in the ·bill. For example, enforcement              ~    .. ·.               .       ., . .       .   ..
           through informal methods. of conference and conciliation could                     ·   ...... ;                 .
           be rendered ineffective if the Attorney General refused to
           file a civil enforcement action after the Comptroller.General
           had s'ought and failed to enforce the law through the. informal
                                                                               .                                     .
           methods. Similarly, advisory opinions .issued by the Comp-          . ."·. ···....

           troller General could be rendered meanin~less if the Attorney                      ·

           General failed to defend a declaratory action filed by a
           lobbyist against the Comptroller General pursuant to subsec-
     t     tion 9(e) of the bill. In short, the bill would place the Comp-
           troller General in the awkward position of having his actions       .   ~-   ...
     r     effectively overruled by th-e Attorney General.                         ·.· ·.

                                                                                   :·:                 .. ·· . . . ·
               Finally, several provisions of the bill underscore the
         importance of timely disclosure ·of lobbyists'· activities.
         The enforcement scheme of the bill, however, may encourage
     l   dilatory tactics ·by lobbyists, and would create ur:mecessary
         delay and duplication of effort. The Attorpey General, in all
         likelihood, would want to repeat many of. the investigative
                                                                                         .. ·.· ..

                                                                                         I        ';

                                                                                                       .•· , •        ',   "".

     J                                                                         .         ·,
         steps already taken by. the C6rn~troller General,   ·

              It is fo~ these reasons that we have consistently stated
         that the agency responsible for. administering a new lobbying
         disclosure law should be given all civil enforcement authority,
         including the authority to li tigfite, and that the Attorney              .........
         General should retain all criminal enforcement powers. This
         authority should, of course, include the authority to go to

                                    - 17 -                                     ..·"

;'   ~


                                                                                                                                ...   {

             court to defend civil challenges to the Comptroller General's
             advisory opinions. and to compel compliance with the· civil                     ,·,
                                                                                             ':           .                     .•.·.
             provisions of any new lobbying disclosure law.
                     Clearly, there· is ample statt:ito.ry precedent for authorizing
               the Comptroller Gener al to go to ·court in his own right or on·
               behalf of the Congress. Specifically, section 504(a) of the
               Energy Policy and Conservayion Act, Pub. L~ No~ 94-163, 89 Stat.
               871, 959, 42 u.s.c. §6384,Vdirects the Comptroller General to
               collect energy information for the Congress and empowers him,
         j     through atttorneys of his ·own selection, to institute a civil               . ···.';
     d!        action to collect civil penalties or enforce subpoenas he issues
               under the Act. Similarly,. pectiot:i 12 ·of the Federal Energy           .
               Adrninistr a ti on Act of. 197.1f,. Pu~ t. No. 93-27 5, 88 Stat. 9·6 ,.
                                                                                            -~ :.: ·..
               106-107, 15 u. S .c. §§ 761, t'{77 l, ~authorizes the Comptroller Gen"'."'                           ·.

               er al to institute a civil. act.i,on in Federal Court to compel.
               compliance with subpoenas issued under that Ac.t. See alt.,
               United States v. Rtjmely,f345 u.s. 41, .43 (1953); McGrain J',.
               Daugherty,. 273 U. s. 135·, 17:5. ( ~9 27); Ass6ciated Indus tr 1 sflv •
             . Ickes, 134 F.2d 694, 704 (2d Cir. 1943); Reade v. Ewing, 05
               F.2a 630, 631 (2d cir. 1953).             ·

                  We note too that section 1016 of the Impoundment·COntrol.
             Act of 1974, ¥pb. L. No. 93-344, 88 Stat. 297, 336-337, 31
             u.s.c. §1406,\fauthorizes the Comptroller Gerieral to bring a                        . .:.'.
             civil action in Fede.ral. court, again through attorneys of his
             own selection, . to compel the release of impounded budget                            _;:

     l       authority.            ·

                  We· be.lieve that· vesting. ci.vil enforcement powers in the
                                                                                                               .·_: .. .

     J       Comptroller Gene·r al not only wi 11 place the enforcement of the
             legislative branch's information-gathering power within the                                                       ·.. ··.
                                                                                                                              .. •
             legislative branch where it should be, but will, in our. view,                       ; ..   ·.                               ...
             eliminate· potential conflict between· the Comptroller. Gen~al                                                   ,.,.. ....    ·: .
             and the Atto~ney Gen~~al. See, Uriitea·states v. Harrissq347                                     ·..        ,•

             u.s. 612, 625-626 (1954).                                                                        ..    .                 .    ....
                                                                                                               ·r        ··.

                  We do.not believe, however, that the ·agency responsible
     l       for administering a new lobbying law should .be given crimi.nal                ··.··......
             enforcement powers. As· a general principle, enforcement of
             the Feder~l ~riminal laws through formal criminal proceedings
             is a function of· the Attorriey General.·. We can see no reason
             for departing from this principle in the proposed lobbying
             legislation.                                                                   ',~    ....

                                            - 18 -

i   ·~                                                           .   .         .



                  Alternatives to vesting complete qivi1 enforcement power~
             in the Comptro.ller General have. been proposed in the past, most
             recently by s. 2477, a lobbyin~ disclosure bill passed by the
             Senate during the 94th. Congress. S. 24 77 contained a. provision
             authorizing the Comptroller Gener.al to institute a civil action
             in Federal court whenever, after notifying the Attorney General,           :···

             the Attorney General failed to bring a civil suit within a spec-
             ified period of time. Although adoption· of thi_s alternati_ve
             could conceivably strengthen the civil enforcement provisions
             of H.R. 1180, it would also enable -the Comptroller General to
             second-guess and effectively overrule the Attorney General, and.·
             like the provisions of H.R. 1180, could. cause needless friction
             between the Comptroller General and the Attorney General.
                                                                    •         I

                                                                                        < ; .. '
                  We recommend, therefore, that H.R. 1180 be amenaea to vest            .       ·...

             in the Comptroller General civil enforcement powers, including             ·.: ,·

             the authority to· file civil· enforcement actions and to defend
             civil challenges to advisory opinions.     · · .-      ·..

                  We also have serious reservations about the enforcement
             schemes adO'pted by the. other lobbying disclosure proposal_s.
                   H.R. 766 suffers from substantially· the same enforcement
                                                                                                .      ·.~   ,.
              deficiencies that are present in H.R. 1180--the Comptroller
            . General, the Federal official responsi.ble for administering.                            .'         .•'   ..
              the bill, would have no meaningful civil enforcement powers.              .. . '               ..
        7     H.R. 766~ like H.R. llBU, vests virtually all civil enforcement
      {       power in the Attorney. Ge·neral. Although H~R~ 766 is silent
              on the point, criminal enforcement wo~ld presumably be the
     :(       Attorn~y General's responsibility.        . .·  .·  ·.

     1            The responsibility for administering the disclosure pro-
             visions of H.R. 557 would be the responsibility of the Federal
             Election Commission. H.R. 1035 would place the .. same responsi-
       !     bility in a new Federal agency, a fact we comminented on                       :   ;·

             earlier in this letter. Both bills vest all civil and criminal
             enforcement powers in· the administering agency. As we indicated
             in our comments on H.R. 11·80,. we believe .the administering
             agency should be gi~en civil enforcement authority but do not
             believe that the ag~ncy responsible for administering a new
             lobbying law should be given criminal enforcement powers.
  ...              we hope this information will prove useful to you, and
            . we are ready to provide whatever additional· assistance. you                       .. , .
                                                                                                  ,,.. ·:··             •.

                                                       - 19 -
                                        -..   ....._


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              might require. At your request, we have enclosed ·four copies
              of our April 1975 report, ent.itled- ."The FeQ:~ral. Regulation
              Of Lobbying Act--Difficulties-Ih Enforcement And Administra-
                                                                                Sincerely ,you.rs,
                                                                                          I   ..;.',,   •

                                                                                                                                                                  :: .
                                                                                                                                                                 ~ .           '

                                                                  L.Pe.PUty Comptroller. General
                                                                                of the United States
                                                                                                                                                                                             :_,·.. ·   ,.


                                                                                                                                                                              ...._· ..:

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                                                                             20 ...                                                                              .. :
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