New Filing Requirements Will Reveal New Information

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Here’s a pleasant surprise in the just passed Honest Leadership and Open Government Act (HLOGA). One of the law’s new filing requirements is that individual lobbyists have to report all "covered official positions" held for 20 years prior to their current filing period. This could provide an amazing amount of new information about where people have lobbied in the past — information that we’ve never seen before.

The new provision will be quite significant for lobbying firms. For them, the 20-year lookback applies to all lobbyists listed on any new registration filed for any client with an effective date of Jan. 1, 2008 or later. For most lobbying firms, this means that eventually all lobbyist employees will need to disclose their prior employment under the 20-year lookback.

The new requirement will have little impact on non-lobbying firm organizations with in-house lobbyists who were already registered as of December 31, 2007. For those organizations, only new lobbyists disclosed as of Jan. 1, 2008 or later will have to report their previous employment in accordance with the 20-year lookback.