majorfiler

Major Filers

A major filer is a person who makes payments or incurs expenditures totaling at least $5,000 in a calendar quarter for indirect attempts to influence City action. This may include public relations, media relations, advertising, public outreach, research, investigation, reports, analyses, studies, and similar activities. A lobbyist, lobbying firm, or lobbyist employer cannot qualify as a major filer by virtue of a direct communication on behalf of a client. However, clients can qualify as major filers if they meet the expenditure threshold independently of expenses that must be reported by a lobbying entity that represents them.

REQUIREMENTS

Disclosure

For every calendar quarter in which a person qualifies as a major filer, the person must file a disclosure statement. These quarterly reports detail information about the City actions the major filer attempted to indirectly influence City action and payments attributable to those attempts to influence.

Quarterly reports are due by the last day of the month following the end of a calendar quarter and must be filed by submitting Form 37 (Major Filer Report) to the Ethics Commission.

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

Record Keeping

A major filer 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

A person is exempt from the lobbying laws if any of the following apply:

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

The person is merely participating in a City procurement process.

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

The person 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

Depending on a major filer’s level of activity with the City, a major filer may be prohibited from offering or making (or acting as an intermediary in) gifts to a City official that exceed a total of $100 in a calendar year.

WHAT DO I FILE?

Filing Schedule

The following forms must be filed in or for 2018:

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

FREQUENTLY ASKED QUESTIONS

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

  • Can anyone qualify as a lobbyist?

    Yes, except that a lobbyist, lobbying firm, or lobbyist employer cannot qualify as a major filer by virtue of a direct communication on behalf of a client.

  • Can Business Improvement Districts and nonprofit organizations qualify as major filers?

    Yes. Any person may qualify as a major filer. A very limited exception applies for certain 501(c)(3) organizations.

  • I hired a lobbyist to represent me in a City development project. I also hired a public relations firm to engage in outreach to residents near the project site, and I am paying the firm $10,000 over two months in the same calendar quarter. My lobbyist and my public relations firm are not working together. Do I have to report the payments to the public relations firm?

    Yes. Because you are spending more than $5,000 in a calendar quarter on public relations activity that is aimed at indirectly influencing City action, you qualify as a major filer. You must file a quarterly report for each quarter in which you qualify.

  • I oppose a City ordinance that would affect my neighborhood. I asked 100 volunteers to go to City Hall to help me voice opposition when the ordinance was on a City Council agenda. I spent $5,000 to rent a bus, provide the volunteers with t-shirts, and buy lunch for the volunteers. I did not spend 30 hours on this. Do I have any reporting obligations?

    Yes. Because you are spending more than $5,000 in a calendar quarter on public relations activity that is aimed at indirectly influencing City action, you qualify as a major filer. You must file a quarterly report for each quarter in which you qualify.

  • My nonprofit organization spent $7,000 in advertising that asked City residents to tell their City Council members that they should support a proposed City project. None of our staff members communicated directly with City officials. Do we have to report this?

    Yes. Advertising expenses aimed at indirect attempts to influence City action count toward the qualification threshold. Because your nonprofit organization met the $5,000 threshold, it qualifies as a major filer and must file a quarterly report to disclose this activity.

  • How can I view a major filer’s quarterly report?

    A major filer’s quarterly report is publicly available through the Public Data Portal.

PUBLIC DATA PORTAL

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REQUIREMENTS

Disclosure

For every calendar quarter in which a person qualifies as a major filer, the person must file a disclosure statement. These quarterly reports detail information about the City actions the major filer attempted to indirectly influence City action and payments attributable to those attempts to influence.

Quarterly reports are due by the last day of the month following the end of a calendar quarter and must be filed by submitting Form 37 (Major Filer Report) to the Ethics Commission.

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

Record Keeping

A major filer 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

A person is exempt from the lobbying laws if any of the following apply:

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

The person is merely participating in a City procurement process.

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

The person 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

Depending on a major filer’s level of activity with the City, a major filer may be prohibited from offering or making (or acting as an intermediary in) gifts to a City official that exceed a total of $100 in a calendar year.

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WHAT DO I FILE?

Filing Schedule

The following forms must be filed in or for 2018:

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
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FREQUENTLY ASKED QUESTIONS

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

  • Can anyone qualify as a lobbyist?

    Yes, except that a lobbyist, lobbying firm, or lobbyist employer cannot qualify as a major filer by virtue of a direct communication on behalf of a client.

  • Can Business Improvement Districts and nonprofit organizations qualify as major filers?

    Yes. Any person may qualify as a major filer. A very limited exception applies for certain 501(c)(3) organizations.

  • I hired a lobbyist to represent me in a City development project. I also hired a public relations firm to engage in outreach to residents near the project site, and I am paying the firm $10,000 over two months in the same calendar quarter. My lobbyist and my public relations firm are not working together. Do I have to report the payments to the public relations firm?

    Yes. Because you are spending more than $5,000 in a calendar quarter on public relations activity that is aimed at indirectly influencing City action, you qualify as a major filer. You must file a quarterly report for each quarter in which you qualify.

  • I oppose a City ordinance that would affect my neighborhood. I asked 100 volunteers to go to City Hall to help me voice opposition when the ordinance was on a City Council agenda. I spent $5,000 to rent a bus, provide the volunteers with t-shirts, and buy lunch for the volunteers. I did not spend 30 hours on this. Do I have any reporting obligations?

    Yes. Because you are spending more than $5,000 in a calendar quarter on public relations activity that is aimed at indirectly influencing City action, you qualify as a major filer. You must file a quarterly report for each quarter in which you qualify.

  • My nonprofit organization spent $7,000 in advertising that asked City residents to tell their City Council members that they should support a proposed City project. None of our staff members communicated directly with City officials. Do we have to report this?

    Yes. Advertising expenses aimed at indirect attempts to influence City action count toward the qualification threshold. Because your nonprofit organization met the $5,000 threshold, it qualifies as a major filer and must file a quarterly report to disclose this activity.

  • How can I view a major filer’s quarterly report?

    A major filer’s quarterly report is publicly available through the Public Data Portal.

? ?

PUBLIC DATA PORTAL

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