Indirect Lobbying FAQs
What is indirect lobbying?
Indirect lobbying, also known as grassroots lobbying, occurs when any person has spent $1,500 or more within 3 months or $750 or more within 1 month to present a program to the public primarily to influence legislation.
Those who meet either of those spending thresholds are considered sponsors of an indirect lobbying campaign and must register within 30 days after becoming a sponsor.
Those who meet either of those spending thresholds are considered sponsors of an indirect lobbying campaign and must register within 30 days after becoming a sponsor.
If I meet the qualifications for indirect lobbying as a grassroots sponsor, what do I have to file?
Sponsor Registration - The first report upon meeting the threshold for reporting.
Monthly Reports - Due on the 10th of each subsequent month for the duration of the campaign.
Final Report – Last month of the campaign, along with a termination date for the end of the campaign.
How do I file indirect lobbying reports?
Reports can be filed using the City of Seattle Ethics and Elections Commission (SEEC) lobby filing application online. Contact Chrissy.Courtney@seattle.gov or call 206.437.6165 for login credentials.
Is there more information on the filing process for indirect lobbying reports?
Yes, more information, including an overview of indirect lobbying sponsorship, step by step reporting guides and law reviews can be found on the SEEC Lobby Disclosure Home page and the SEEC Lobbying Law & Filer Info page.
Direct Lobbying FAQs
Who is considered a direct lobbyist?
There are three kinds of lobbyists covered by the City of Seattle Municipal Code: someone expressly hired to lobby, someone who lobbies as part of their employment duties but not exclusively, and lobbying sponsors who spend money on a public campaign to influence legislation. The first two are considered direct lobbyists and the third is considered an indirect lobbyist.
- When a person or entity enters into a contract with someone to lobby on behalf of that person or entity, that lobbyist must register with the Commission. The direct lobbyist’s compensation is a function of the contract between the person or entity and the lobbyist, and that type of lobbyist is hired expressly for lobbying.
- When an employee lobbies in the course of their employment, that employee must file as a direct lobbyist as well. The distinction here is that the employee is providing lobbying services as part of their position, but they do not exclusively lobby in their position.
- When any person has spent $1,500 or more within 3 months or $750 or more within 1 month to present a program to the public primarily to influence legislation, they are considered an indirect lobbying sponsor and must register within 30 days of meeting the reporting threshold(s). See the Lobbying Disclosure Home page for more information regarding indirect, aka grassroots, lobbying sponsorships.
What is the 4-day rule?
Direct lobbyists must register and report if they are paid $5,000 or more to lobby in a quarter for more than four days, or parts thereof, (meaning any portion of a day counts as one day) for one or more clients/employers during any calendar quarter. Lobbying includes face-to-face meetings, mail, e-mail, online meetings or telephone contact.
Direct lobbyists who restrict their lobbying activities to no more than four days during any quarter and are paid no more than $5,000 for lobbying in that quarter are exempt from registration and reporting with the City but may still register and report if they wish to do so.
Direct lobbyists who restrict their lobbying activities to no more than four days during any quarter and are paid no more than $5,000 for lobbying in that quarter are exempt from registration and reporting with the City but may still register and report if they wish to do so.
Who is considered a contact that needs to be reported for direct lobbying?
Communications with City Council members, the Mayor, City officers or employees or agents either of the Legislative Department or working in the Mayor's office, a department director, or a deputy director or other employee who reports directly to a department director in an attempt to influence any of those individuals to develop, propose, draft, consider or reconsider, promote, adopt, enact, reject, take favorable action upon, approve, disapprove, veto, or fail to take action upon legislation need to be reported by direct lobbyists.
I am a direct lobbyist for a membership organization, do I have to list my members under the Employer/Client Information tab?
Yes. Unless your organization is mostly made up of members whose primary purpose in joining the organization was for other than influencing legislation.
I registered as a direct lobbyist, but I didn’t have any activity this quarter. Do I have to file a quarterly report?
Yes. If you have no activity for the quarter but you have not terminated your direct lobbying position, you should file a quarterly report, even if it is to report zero in compensation and no lobbying activity. Quarterly reports are filed for direct lobbying activity up to the date of termination.
I am the employer/client of a direct lobbyist. What do I have to file?
You must Authorize the lobbyist to file, by emailing ethicsandelections@seattle.gov.
Here is a suggested authorization template:
You must also either:
Here is a suggested certification template for option a):
For option b) please contact Chrissy Courtney at Chrissy.Courtney@seattle.gov for filing credentials.
Here is a suggested authorization template:
I, [Employing Officer’s Name], authorize [Lobbyist’s Name] to lobby on [Employing Organization’s] behalf. [Lobbyist Name] has registered as a Lobbyist for this purpose with the Employer/Client Registration report linked to here:
[Insert the link to the Employer/Client Registration report here]
Sincerely,
[Employing Officer’s Name]
[Insert the link to the Employer/Client Registration report here]
Sincerely,
[Employing Officer’s Name]
You must also either:
- Certify the lobbyist’s reports filed no later than the last day of February for the previous calendar year, or
- File quarterly reports.
Here is a suggested certification template for option a):
I, [Employer/Client/Officer Name] verify, for those portions of the report that relate to [Employer/Client Name], the truth and completeness of the quarterly reports filed by my lobbyist, [Lobbyist’s Name].
[Insert the quarterly link(s) to the Lobbyist Expenditure Report(s) here – Q1, Q2, Q3, Q4]
Sincerely, [Officer’s Name] [Employer’s Name]
[Insert the quarterly link(s) to the Lobbyist Expenditure Report(s) here – Q1, Q2, Q3, Q4]
Sincerely, [Officer’s Name] [Employer’s Name]
For option b) please contact Chrissy Courtney at Chrissy.Courtney@seattle.gov for filing credentials.
As a direct lobbyist, do I have to include benefits under compensation, e.g. health, transit passes, annual/monthly parking, etc.?
No. Compensation in a quarterly report should be the amount the lobbyist earned for their direct lobbying activity during the quarter. Those expenses for which the lobbyist is reimbursed, such as parking, mileage or meals, should also be reported as compensation when the reimbursement occurs during the quarter.
I’m the Executive Director of the non-profit for whom I lobby directly. Can I authorize myself to lobby on the organization’s behalf?
Yes. If you’re not the Executive Director, have a supervisor or manager authorize you.
If not all of my work is direct lobbying, when I report my compensation on my employer/client registration, should I report a pro-rated amount of salary that represents my lobbying work or my entire salary amount?
If you only do direct lobbying some of the time for your employer then you can report an estimated pro-rated amount of your salary when registering. Remember to report the rate of compensation over time, such as $3,000 per quarter or $1,000 per month. On your quarterly reports, you will report the actual amount of compensation due to your lobbying activities in that given quarter.
As a direct lobbyist, what do I report in the Compensation field in my Employer/Client registration?
Report the amount of money you expect to be paid per a specific period, e.g. $50 per hour, or $5,000 for 3 months as per the agreement with the employer/client. In your quarterly reports for that employer/client report the actual amount of compensation received during that quarter.
If only part of my job requires me to lobby for my employer/client, what do I report as my compensation on my quarterly report? Do I have to report my entire salary for the quarter?
Report the portion of your salary that will be attributable to lobbying and preparation for lobbying. For example, if you earn $100 per hour and spend 20 hours in a quarter lobbying or preparing to lobby, then you should report $2,000 as compensation for lobbying for that calendar quarter.
If I meet the qualifications for direct lobbying, what do I have to file?
Direct lobbyists will file a New Registration when the lobbyist is registering with the City of Seattle for the first time. When the lobbyist takes on a new employer/client they will file an Employer/Client Registration. The new employer/client will provide an Employer Authorization to the Ethics and Elections Commission. The lobbyist will file Quarterly Reports of their activity for each employer/client. The employer/client will provide an Employer Certification confirming the accuracy of the quarterly reports.
New Registration - Information about the direct lobbyist
Employer/Client Registration - Information about the employer of the direct lobbyist
Employer Authorization - Employer acknowledgement of direct lobbyist registration
Quarterly Reports - Compensation earned by direct lobbyist and who was lobbied and when regarding what
Employer Certification - Employer acknowledgement of accuracy of quarterly reporting by lobbyist
New Registration - Information about the direct lobbyist
Employer/Client Registration - Information about the employer of the direct lobbyist
Employer Authorization - Employer acknowledgement of direct lobbyist registration
Quarterly Reports - Compensation earned by direct lobbyist and who was lobbied and when regarding what
Employer Certification - Employer acknowledgement of accuracy of quarterly reporting by lobbyist
Does a phone call to set up a meeting constitute a direct lobbying activity?
No, only those contacts meant to influence legislation are counted as lobbying activity.
What if I am employed in a position that lobbies directly, but I don’t know when I will hit the minimum required reporting threshold. When do I file?
If you are employed as a direct lobbyist, you should register even if you have nothing to report until you hit the minimum threshold. If you were not hired expressly to lobby, but direct lobbying will be part of your job, then once you do hit the minimum reporting threshold, you have 30 days to register and an obligation to report for that quarter.
As a direct lobbyist, I have 3 clients for whom I lobby on City issues. In the last quarter, I didn’t meet the threshold for reporting for any one client. That is, I lobbied for 4 days (or parts thereof) or less for each client. Altogether, I lobbied a total of seven days, but only made $1,000. Do I have to file a quarterly report? Do my clients have to file Employer reports?
No. Even though you lobbied for more than 4 days, since you were paid less than $5,000 in the quarter, you do not have to register or report, and your clients do not have to file.
Where can I look up recent legislation?
On the City Clerk’s website.
I’m an unpaid volunteer for a neighborhood group. Do I have to register as a direct lobbyist? Do I have to register as an indirect or grassroots sponsor?
No, unpaid volunteers do not have a reporting obligation as either a direct lobbyist or as an indirect aka grassroots lobbying sponsor.