lobbyistfirm

Lobbying Firms

An entity qualifies as a lobbying firm if it meets both of the following thresholds:

It is entitled to receive at least $1,000 in compensation for engaging (either directly or through its agents) in lobbying activities during a consecutive three-month period for the purpose of attempting to influence City action on behalf of other persons; and

It has a partner, owner, shareholder, officer, or employee who qualifies as a lobbyist.

A lobbying firm may be an individual lobbyist who is a sole proprietor.

REQUIREMENTS

Registration

An entity that qualifies as a lobbying firm must register with the Ethics Commission within 10 days after the end of the month in which an individual with the firm qualifies as a lobbyist. A lobbying firm must also register a client when both of the following occur in a calendar quarter:

The lobbying firm is entitled to receive $250 from the client for lobbying activities; and

A direct communication with a City official is made on the client’s behalf.

The fee to register a client is $75 if the registration criteria are met in the first three quarters of the year and $56 if the criteria are met in the fourth quarter of the year. All registrations automatically terminate on December 31 of each year but may be terminated earlier.

Registration is done electronically through the Lobbying Electronic Filing System (LEFS). Lobbyists must file Form 59 (Application for LEFS ID) to obtain an LEFS identification and password.

Disclosure

For every calendar quarter in which an entity qualifies or is registered as a lobbying firm, the entity must file a disclosure statement. These quarterly reports detail information about the lobbying firm’s lobbyists, City actions lobbied, City departments lobbied, clients, payments received from clients, activity expenses, expenses attributable to lobbying, City campaign contributions, City fundraising activity, campaign contributions and charitable donations behested by a City candidate or officeholder, services to a City committee, and contracts with the City.

Quarterly reports are due by the last day of the month following the end of a calendar quarter and must be filed through LEFS.

Additional disclosure requirements apply, including filing reports within one business day after reaching certain levels of contribution or fundraising activity, filing copies of written communications to neighborhood councils, and filing copies of fundraising solicitations sent to 50 or more people.

Detailed filing requirements can be found under “What Do I File?”.

Record Keeping

A lobbying firm is required to prepare and maintain detailed records needed to show compliance with the lobbying laws. This includes books, papers, receipts, invoices, fundraising information, contracts, and other documents. Records must be maintained for at least four years.

EXEMPTIONS

An entity is exempt from the lobbying laws if any of the following apply:

The entity is not being compensated to attempt to influence City action.

The entity is merely participating in a City procurement process.

The entity is a media outlet and is engaged only in the publishing or broadcasting of news, editorials, or paid advertising.

The entity is a 501(c)(3) organization that receives government funding to provide free services directly to indigent persons, and the entity is engaged only in providing those services.

LIMITATIONS

A lobbying firm is prohibited from doing the following:

Making a campaign contribution to a City candidate if the lobbyist is registered to lobby the office the candidate seeks or holds.

Making or arranging for (or acting as an intermediary in) a gift of any value to a City official who works in an office the lobbyist is registered to lobby. Very limited exceptions apply to the definition of gift.

Doing anything with the intent to place a City official under personal obligation to the lobbyist, the lobbyist’s employer or the lobbyist’s client.

Attempting to deceive a City official regarding a material fact that is pertinent to a pending City matter.

Causing or influencing the introduction of a City matter for the purpose of afterwards being employed to secure its passage or defeat.

Causing a communication to be sent to a City official in the name of a nonexistent person or in the name of an existing person without that person’s permission.

WHAT DO I FILE?

Registration

The following forms must be filed to register as a lobbying firm:

Form Required
Due Date
Must be filed before the first time a lobbying firm registers.
When the firm receives or is owed $1,000 for lobbying, and an individual with the firm qualifies as a lobbyist.
Filing Schedule

The following forms must be filed:

Form Required
Period Covered
Due Date
Oct 1, 2017 - Dec 31, 2017
Jan 31, 2018
Jan 1, 2018 - Mar 31, 2018
Apr 30, 2018
Apr 1, 2018 - Jun 30, 2018
Jul 31, 2018
Jul 1, 2018 - Sep 30, 2018
Oct 31, 2018
Oct 1, 2018 - Dec 31, 2018
Jan 31, 2019
Required Per Activity

The following forms are required when you perform certain activities:

Activity
Form Required
Due Date
Fundraising more than the following threshold amounts in a 12-month period:
  1. For the Mayor, City Attorney, or Controller--$35,000
  2. For a City Councilmember--$15,000
Within 1 business day of the activity.
Termination

The following form must be filed by lobbying firms who wish to terminate their registration before it automatically terminates on Dec 31, 2018.

Form Required
Due Date
On the day the lobbying firm wishes to terminate its registration.

FREQUENTLY ASKED QUESTIONS

For questions regarding specific scenarios, please contact us prior to taking action.

  • Are there limits on lobbying activity?

    There is no limit on properly reported lobbying activity. However, lobbying firms are limited in other types of activity, which are identified under Limitations.

  • How quickly can I view a lobbying firm’s quarterly report?

    A lobbying firm’s quarterly report is publicly available through the Public Data Portal the moment it is filed. The deadlines for filing quarterly reports are April 30 for the first quarter, July 31 for the second quarter, October 31 for the third quarter, and January 31 for the fourth quarter. If these dates fall on a holiday or weekend, the deadline is extended to the next business day.

  • My lobbying firm is authorized to lobby all City agencies would like to recognize outstanding City officials with an awards luncheon. Is that permitted?

    No. A lobbying firm cannot provide a gift of any value to a City official who works in a department the lobbyist is registered to lobby. Recognition is permitted in the form of personalized plaques valued at $250 or less, which state law exempts from the definition of “gift”.

  • Several City officials are visiting my lobbying firm’s office to learn more about a client’s project. Can the firm pay for their parking?

    Yes. Nominal and routine office courtesies received by a City official at a lobbying firm’s office are not considered gifts, as long as the courtesies are available to any person who visits that office.

PUBLIC DATA PORTAL

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REQUIREMENTS

Registration

An entity that qualifies as a lobbying firm must register with the Ethics Commission within 10 days after the end of the month in which an individual with the firm qualifies as a lobbyist. A lobbying firm must also register a client when both of the following occur in a calendar quarter:

The lobbying firm is entitled to receive $250 from the client for lobbying activities; and

A direct communication with a City official is made on the client’s behalf.

The fee to register a client is $75 if the registration criteria are met in the first three quarters of the year and $56 if the criteria are met in the fourth quarter of the year. All registrations automatically terminate on December 31 of each year but may be terminated earlier.

Registration is done electronically through the Lobbying Electronic Filing System (LEFS). Lobbyists must file Form 59 (Application for LEFS ID) to obtain an LEFS identification and password.

Disclosure

For every calendar quarter in which an entity qualifies or is registered as a lobbying firm, the entity must file a disclosure statement. These quarterly reports detail information about the lobbying firm’s lobbyists, City actions lobbied, City departments lobbied, clients, payments received from clients, activity expenses, expenses attributable to lobbying, City campaign contributions, City fundraising activity, campaign contributions and charitable donations behested by a City candidate or officeholder, services to a City committee, and contracts with the City.

Quarterly reports are due by the last day of the month following the end of a calendar quarter and must be filed through LEFS.

Additional disclosure requirements apply, including filing reports within one business day after reaching certain levels of contribution or fundraising activity, filing copies of written communications to neighborhood councils, and filing copies of fundraising solicitations sent to 50 or more people.

Detailed filing requirements can be found under “What Do I File?”.

Record Keeping

A lobbying firm is required to prepare and maintain detailed records needed to show compliance with the lobbying laws. This includes books, papers, receipts, invoices, fundraising information, contracts, and other documents. Records must be maintained for at least four years.

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EXEMPTIONS

An entity is exempt from the lobbying laws if any of the following apply:

The entity is not being compensated to attempt to influence City action.

The entity is merely participating in a City procurement process.

The entity is a media outlet and is engaged only in the publishing or broadcasting of news, editorials, or paid advertising.

The entity is a 501(c)(3) organization that receives government funding to provide free services directly to indigent persons, and the entity is engaged only in providing those services.

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LIMITATIONS

A lobbying firm is prohibited from doing the following:

Making a campaign contribution to a City candidate if the lobbyist is registered to lobby the office the candidate seeks or holds.

Making or arranging for (or acting as an intermediary in) a gift of any value to a City official who works in an office the lobbyist is registered to lobby. Very limited exceptions apply to the definition of gift.

Doing anything with the intent to place a City official under personal obligation to the lobbyist, the lobbyist’s employer or the lobbyist’s client.

Attempting to deceive a City official regarding a material fact that is pertinent to a pending City matter.

Causing or influencing the introduction of a City matter for the purpose of afterwards being employed to secure its passage or defeat.

Causing a communication to be sent to a City official in the name of a nonexistent person or in the name of an existing person without that person’s permission.

? ?

WHAT DO I FILE?

Registration

The following forms must be filed to register as a lobbying firm:

Form Required
Due Date
Must be filed before the first time a lobbying firm registers.
When the firm receives or is owed $1,000 for lobbying, and an individual with the firm qualifies as a lobbyist.
Filing Schedule

The following forms must be filed:

Form Required
Period Covered
Due Date
Oct 1, 2017 - Dec 31, 2017
Jan 31, 2018
Jan 1, 2018 - Mar 31, 2018
Apr 30, 2018
Apr 1, 2018 - Jun 30, 2018
Jul 31, 2018
Jul 1, 2018 - Sep 30, 2018
Oct 31, 2018
Oct 1, 2018 - Dec 31, 2018
Jan 31, 2019
Required Per Activity

The following forms are required when you perform certain activities:

Activity
Form Required
Due Date
Fundraising more than the following threshold amounts in a 12-month period:
  1. For the Mayor, City Attorney, or Controller--$35,000
  2. For a City Councilmember--$15,000
Within 1 business day of the activity.
Termination

The following form must be filed by lobbying firms who wish to terminate their registration before it automatically terminates on Dec 31, 2018.

Form Required
Due Date
On the day the lobbying firm wishes to terminate its registration.
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FREQUENTLY ASKED QUESTIONS

For questions regarding specific scenarios, please contact us prior to taking action.

  • Are there limits on lobbying activity?

    There is no limit on properly reported lobbying activity. However, lobbying firms are limited in other types of activity, which are identified under Limitations.

  • How quickly can I view a lobbying firm’s quarterly report?

    A lobbying firm’s quarterly report is publicly available through the Public Data Portal the moment it is filed. The deadlines for filing quarterly reports are April 30 for the first quarter, July 31 for the second quarter, October 31 for the third quarter, and January 31 for the fourth quarter. If these dates fall on a holiday or weekend, the deadline is extended to the next business day.

  • My lobbying firm is authorized to lobby all City agencies would like to recognize outstanding City officials with an awards luncheon. Is that permitted?

    No. A lobbying firm cannot provide a gift of any value to a City official who works in a department the lobbyist is registered to lobby. Recognition is permitted in the form of personalized plaques valued at $250 or less, which state law exempts from the definition of “gift”.

  • Several City officials are visiting my lobbying firm’s office to learn more about a client’s project. Can the firm pay for their parking?

    Yes. Nominal and routine office courtesies received by a City official at a lobbying firm’s office are not considered gifts, as long as the courtesies are available to any person who visits that office.

? ?

PUBLIC DATA PORTAL

Search Former Website: Campaign | Lobbying

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