This is the week that lobbyists had to file their first quarter reports on Capitol Hill, and while there’s been lots of interesting analysis of what has been disclosed, we here at Sunlight got to thinking about what wasn’t:

In the first three months of 2014, only 18 individuals and organizations were named by federal campaign committees as lobbyist “bundlers”–those credited with raising money from others and delivering it in one convenient (and large) package to a candidate or party committee, according to Sunlight’s analysis of records filed with the Federal Election Commission.

While the FEC list includes high profile lobbyists (Tony Podesta and his estranged wife Heather Podesta are reported to have bundled $289,400 and $97,400, respectively, to the Democratic Senatorial Campaign Committee), other names you’d expect to find aren’t there.

Over at Sunlight’s Party Time website, which tracks campaign fundraising parties, we count 513 people and organizations listed as hosts over the same time period. In other words, they are helping these candidates and party committees raise hard money by bringing together other donors. Sounds like bundling, no? Yet none of the Party Time hosts are reported as bundlers by campaign committees in the 2014 calendar year.

What gives?

No. 1: What looks like a bundle might not be a bundle, at least not in the strict legal sense. The Honest Leadership and Open Government Act of 2007  brought us official disclosure of bundled contributions by registered lobbyists. But the rules allow plenty of bundles to be dropped down the black hole of non-disclosure.

Campaigns have to report only bundles of $17,300 or more. These totals do not count any money contributed personally by a lobbyist.

So if lobbyist A convinces six of her colleagues to each contribute the maximum amount to Representative Z, and her spouse and herself each kick in another $2,600 apiece, for a total of $20,800, Representative Z would not need to report that as a bundle. Or, say ten lobbyists serve as hosts of a single fundraiser and the event raises $100,000. If that amount is allocated evenly among the ten hosts, the reporting threshold will not be triggered. Bingo: no disclosure.

Of the 137 lobbyist bundlers reported by campaigns in 2012, 52 appear in the Party Time database as hosting fundraising parties. At these same parties, they shared their hosting duties with 295 other registered lobbyists, none of whom show up in the official lobbying bundling reports, according to analysis by Craig Holman of Public Citizen in a recent article for the Election Law Journal (subscription required).

This is likely an underestimate of the number of lobbyists involved in fundraising–the Party Time database is fueled by volunteers who send us invitations, and is far from a complete dataset.

“What is clear is that the public is not getting a full picture of bundling activity, and that many lobbyists who are participating in bundling events are going undisclosed in the FECA bundling database,” writes Holman.

No. 2: The bundling disclosure law is limited to lobbyists. Many of the most prolific donors and bundlers in campaigns, however, are not registered as lobbyists–which is a very different thing from saying that they don’t have a pecuniary interest in a politician’s policies.

For example, Texas-based Republican donor Robert Rowling has opened his Dallas home to raise funds for the National Republican Senatorial Campaign Committee, and as head of the privately held TRT Holdings, he oversees an empire that includes Omni Hotels & Resorts, Tana Exploration Company, and Gold’s Gym.  Rowling’s giving patterns have supported his business interests: In 2009, he contributed generously to oppose a ballot initiative that would have squashed a Dallas development benefitting Omni; in the end, the Dallas City Council unanimously  voted to award TRT Holdings $2.3 million in tax abatements over ten years and a $200,000 economic development grant.

In the 2012 presidential campaign, President Barack Obama declared he would not take any campaign money from registered lobbyists. But he still voluntarily disclosed plenty of bundlers supporting his campaign, nearly 770 of them. The top industry represented were law firms, many of which house lobbying outfits.  GOP candidate Mitt Romney made no such promise, but also reported plenty of bundlers, according to OpenSecrets.org. The federal bundling disclosure law would not capture the lion’s share of these people.

In his Election Law Review article, Holman argues that an opportunity was lost in the 2007 lobbying reform law. “[T]he disclosure provision continues to apply only to lobbyists when it, too, should have been expanded to include all campaign finance bundlers,” he writes.

That doesn’t mean the law couldn’t be changed now. Sunlight has long advocated for exactly this: our 2008 Model Transparency bill included a provision expanding bundling disclosure to all bundlers, not just registered lobbyists. But meanwhile, it’s important to remember that what’s disclosed is only a very small part of the picture–particularly troubling following the U.S. Supreme Court’s in the McCutcheon case, which is expected to encourage more old fashioned maxed out hard money contributions to campaigns.

Also seen:  The Middle East is once again in the news with peace talks on life support. We took a look at some of the players in the crisis through the prism of Sunlight trackers.

Mentions of Hamas by lawmakers on the floor peaked in January 2009, when Israel invaded Gaza; mentions of Palestine Liberation Organization much lower overall (Capitol Words); Palestine and Israel foreign agent registration profiles (Foreign Influence Explorer); Hamas and Israel in legislation (Open Congress).