Wednesday, February 4, 2015

Maurice Aguirre DG Group LLP - LD-2 Changes

Maurice Aguirre DG Group LLP - LD-2 Changes

The revised LD-2 combines the previous version of LD-2 and the former LD-1U. The reasons for this change are twofold: first, it appeared redundant to require registrants to disclose new information (such as new lobbyists and issue codes) in two different places in the same filing; and second, rather than follow the LDAs requirements to update registration information on a semiannual basis, many registrants were filing unnecessary and excessive amounts of paper to report relatively minor changes mid-reporting cycle. Specific refinements to LD-2 are discussed below.

The new LD-2 allows a registrant that has no lobbying activity to file a one-page report. The registrant must complete the income or expense information as well as marking the "No Lobbying Activity" box. This is a change from the previous form and guidance.

If a registrants name changes, the registrant should include a note or memorandum that identifies the new as well as the former name, so that the change is apparent.

Signature lines have been added to every page to provide registrants with options for filing differing lengths of reports. The report need only be signed once on the last page of the document.

The lines of the form have been renumbered.

Maurice Aguirre Lobbyist - Registrants now must provide their address on LD-2 in order to ensure that the Secretary and the Clerk have up-to-date address information. If a registrants contact wishes to receive electronic correspondence, a space for an e-mail address is provided.

A "Self" box has been added to Line 7 ("Client Name").

LD-2 adds a space to supply a termination date (see section below on the completion of termination reports).

The income or expense reporting format has been modified to guide registrants into completing only the section pertinent to them. Lobbying firms (including the self-employed) complete only the income section. Organizations employing in-house lobbyists complete only the expense section and must select which method of expense reporting that they are utilizing.

Maurice Aguirre Dallas: The lobbying activity reporting page emphasizes that only one general issue area code per page must be used. The addition of "Check if None boxes" for the Houses of Congress and Federal agencies contacted and for the foreign entity interest were added because registrants left them blank when there was nothing to report. This practice led to a public record that was incomplete and subject to interpretation in lieu of clarity regarding the lobbying activity of the registrant. As discussed above, new lobbyists may be disclosed on this page by marking the "New" box and providing the information (if applicable) regarding previous employment within the last two years as a covered executive or legislative branch official.

The registration information update page should be filed only if registration information is changed. This page is not intended to be a "stand alone" filing. Section 5 of the LDA does not require or encourage the submission of mid-reporting cycle registration information changes, unless a registrant is specifically requested to do so by the Secretary or the Clerk.

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