FEDERAL LOBBYING REPORT REQUIREMENTS & RESTRICTIONS 
LD-203: SEMIANNUAL DISCLOSURE OF LOBBYING CONTRIBUTIONS 
The State University of New York 

September 2008 
Background: 
In addition to completing the federal quarterly lobbying expense report, SUNY must also file a new federal semi-annual report of lobbying contributions. As of 2008, the Honest Leadership and Open Government Act of 2007 requires SUNY to file new semi-annual reports disclosing any institutional contributions made by SUNY to members of the Federal Legislative and Executive branches of government and certain organizations associated with them. These new LD-203 reports must be filed in addition to SUNY�s quarterly reports of federal lobbying activities. 
SUNY files one report on behalf of the system, which reflects institutional contributions. 
Some individuals, �named lobbyists� affiliated with SUNY, may be required to file personal LD-203 
House Clerk and Senate Secretary can be found here: http://lobbyingdisclosure.house.gov/. 



SUNY is an active �registrant� and employs individuals who have been listed as active lobbyists by SUNY 
on Forms LD-1 and LD-2. SUNY and those named active lobbyists must file semiannual contributions reports on Form LD-203 by July 30 and January 30 (or on the next business day should either day occur on a weekend or holiday) for each semiannual period in which a registrant or lobbyist remains active. The coverage periods for the semiannual reports are January 1 through June 30, and July 1 through December 
31. 

The Secretary and the Clerk do not have the authority under the LDA to grant extensions for filing LDA documents. 
Q: Does my campus need to file a contributions report with the federal government? 
No. As the SUNY campuses are not separate legal entities, SUNY will file one report on behalf of its campuses beginning in 2008. 
Q: Why does my campus need to file federal contributions information with SUNY System Administration? 
As campus faculty and staff are employees of the State University of New York, and individual campuses are not distinctly separate legal entities, any lobbying �contributions� activity conducted by 
campuses for SUNY purposes must be reported to SUNY System Administration to be filed with the State University of New York semi-annual reports. 
Q: Are there special forms that calculate expenses for lobbying activities? 
The federal government does not provide these forms, but you will be provided with a form to complete by SUNY System Administration to assist in determining SUNY�s reportable contributions. 
The core information required by Section 5(d) of the LDA and incorporated into Form LD-203 are: (1) certain contributions that are not disclosed in the LD-2; and (2) a certification that the filer has read and 
to honor or recognize a covered Legislative Branch or covered Executive Branch official (except for information required to be disclosed by another entity under 2 U.S.C.�434). 


Q: Who are �covered officials�? 
Legislative Branch: Members of Congress, staff members of Members of Congress, congressional committees or caucuses, and the congressional leadership, and certain other congressional staff. 

Government Ethics, in order to determine if any event listed above is otherwise prohibited under law, Senate or House Rules, or Executive Branch regulations. 
Official Examples of Reportable Contributions 
From the US House of Representatives Guide to the Lobbying Disclosure Act 

Example 1: In State�"A,"�a group of constituents involved in widget manufacturing decide to honor Senator 

would have to be reported, even if the invitation did not indicate that such would be given. 
Example 7: Senator�"Y"�and Representative�"T"�are�"honorary co-hosts"�of an event sponsored by Registrant "R"�to raise funds for a charity, which is not established, financed, maintained, or controlled by either 

legislator.�"Y"�and�"T�s"�passive allowance of their names to be used as�"co-hosts,"�in and of itself, is not sufficient to be considered�"honored or recognized."�The purpose of the event is to raise funds for Charity V, not to honor or recognize�"Y"�or�"T."�Nor are these facts, in and of themselves, sufficient to treat the event as being held�"by or in the name"�of�"Y"�or�"T."�Supplemental facts might require reporting the cost of the event. 
Example 8: Registrant�"R"�sponsors an event to promote�"Widget Awareness."�"The Honorable Cabinet Secretary Z"�is listed on the invitation as an�"attendee"�or�"special invitee"�but will not receive an honor or award at the event. Based on these facts alone,�"R"�would not need to include the costs of this event on�"R�s"�disclosure under this section. Mere listing of�"Z�s"�anticipated attendance at an event the purpose of which is to promote Widget Awareness, in and of itself, is not sufficient to be considered�"honored or recognized". Use of the phrase�"The Honorable"�in this context is consistent with widely accepted notions of protocol applicable to referencing certain very senior government officials. Supplemental facts might require reporting the cost of the event. For instance, if�"Z"�received a special, award, honor, or recognition by�"R"�at the event,�"R"�would have to report the costs of the event noting that�"Z"�was being honored or recognized. 
Example 9: Registrant�"B"�buys a table at a dinner event sponsored by a 501(c) organization to honor 
Representative�"T"�but Registrant�"B"�is not considered a sponsor of the event under House and Senate gift rules. Lobbyist�"C"�pays the $150 individual ticket cost to attend the dinner, but is not considered a sponsor of the event under House and Senate gift rules. The purchase of a table or ticket to another entity�s event, in and of itself, is not sufficient to be considered paying the�"cost of an event."�Supplemental facts might require reporting the cost of the event. For example, if (1)�"B"�or�"C"�undertake activities such that�"B"�or�"C"�becomes a sponsor of the event for House and/or Senate gift rule purposes; or (2)�"B"�or�"�C"�purchase enough tickets/tables so that it would appear that they are paying the costs of the event and/or would not appear to be just ticket or table-buyers, then�"B"�or�"C"�would need to report the costs incurred by�"B"�or�"C"�(as the case may be) for the event, noting that Representative�"T"�was the honoree. 
Example 10: Lobbyists�"C"�and�"D"�serve on the board of a non-connected PAC as member and treasurer respectively. As board members, they are in positions that control direction of the PAC�s contributions. Since both are controlling to whom the PAC�s contributions are given, they must disclose applicable 
-annual reports. In regard to a Separate Segregated Fund (SSF) (i.e., a connected PAC), in order to avoid duplicative reporting a lobbyist may report that he or she is a board member of an SSF in lieu of reporting the SSF�s applicable contributions, so long as the SSF�s contributions are reported in a disclosure filed with the Clerk and the Secretary. 



Additional LD-203 Q &A 
Q: What if I bought a table, or ticket, to an event where a member of congress is a speaker? 
Disclosure is not required in most circumstances where a lobbyist or registrant merely purchases a table at an event or a registration fee for a conference where a congressional member or other covered official is honored. Under the guidance issued today,�"the purchase of a table or ticket to another entity's event, in and of itself, is not sufficient to be considered paying the�"cost of an event."�
Q: What about my attendance at SUNY Days in DC where Sen. Schumer was a speaker? Do I need to report those related expenses as a contribution? 
Disclosure is not required when a trade association holds a breakfast at which a congressional member or other covered officials speak to the association as part of a Washington�"fly-in,"�absent circumstances where the speaker is in some way recognized for his or her support of the group or its legislative agenda. 
Events simply featuring a covered elected or federal agency official such as graduations, conferences, and 
seminars, in most cases, do not need to be reported unless there was some type of honor or special recognition bestowed on the speaker. For example, under the revised guidance, SUNY would not need to report expenses affiliated with inviting Sen. Schumer to address the participants in SUNY Days in DC. If he was not honored at the event, we do not need to report this. However, if we had presented him with an award, the event would need to be reported. 
Disclosure is still required for an event where a congressional member receives an award�--even if the overall purpose of the event is to raise funds for charity or another organization. 
Q: What if my local congressman is an honorary co-host of a charitable event we contributed to? 
Disclosure is not required when a congressional member or other covered official serves as an honorary co�host for a charity event or gala. The guidance notes that passive allowance of [congressional members'] names as�"co-hosts,"�in and of itself, is not sufficient to be considered�"honored or recognized."�