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B-129874 1 (1980-01-18)

handle is hein.gao/gaobabjqt0001 and id is 1 raw text is: 
*ji 1         CPt                              -7
               COMPTROLLER GENERAL OF THE UNITED STATES
                        WASHINGTON. D.C. 20548


                                           IN REY   B-129874
                                           R ER TO-

                                              January 18, 1980
The Honorable Abraham A. Ribicoff
Chairman, Committee on Governmental                    I
   Affairs                          IJO(   o            NIVVAO
United States Senate

Dear Mr. Chairman:

     This responds to your request for ourlews on S. 1782,
a-b4l-ent-it.lead the Lobbying Disclosure Act of 1979.2  We
provided our views and recommendations on S. 1564, the more
demanding and comprehensive of the disclosure proposals, in
testimony before the Committee on September 26, 1979. We note
that many of those recommendations have been incorporated in
S. 2160, a successor bill to S. 1564.
     S. 1782, like the other lobbying bills pending before
the Congress, would replace the present lobbying disclosure
law, the Federal Regulation of Lobbying Act (2 U.S.C. 9§261

et seq.), with a new statute defining the organizations that
must register and report as lobbyists, and specifically des-
cribing the information that those organizations must disclose.
Although we believe S. 1782 would represent an improvement over
the existing disclosure law, there are certain ambiguities,
omissions, and shortcomings in the bill that should be cor-
rected.

     I. Scope of Coverage (Section 4)

     Section 4 would define who must comply with the bill's
registration, recordkeeping, and reporting requirements.
S. 1782 would apply to any organization, a term defined by
subsection 3(10) of the bill, whose lobbying activities during
a quarterly filing period satisfied one of two so-called
threshold tests.

     A. Threshold Tests (Section 4)

     1. Retained Lobbyist Quarterly Expenditure Threshold
         (§4(a))

     Under subsection 4(a), the bill would apply to any
organization that spends in excess of $5,000 in any quarterly

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