Compliance Now

E-News from State and Federal Communications, Inc.

November 2007

HLOGA—Bless You
This is your New Year's Resolution!

At the 2007 COGEL Conference in Victoria, British Columbia Pam Gavin brought us a new acronym for the crazy work we do in compliance. HLOGA is the Honest Leadership and Open Government Act of 2007. Gavin is with the secretary of the senate’s office and is very busy these days making this new Act easy for us to comprehend and comply with beginning January 1, 2008.

I am going to give you a list to start your New Year’s Resolution...Your job will be making sure to maintain these resolutions. Pick up your sword and shield and be ready to hold your own at your organization. The change in your organization’s culture needs to start now.

Prepare a training program for your organization and make sure you are reaching into all levels of staff that could have any communication with federal officials. These folks may not cross the registration threshold, but the organization’s report does need to include compensation paid for non-lobbyist employees.

Know the definitions. HLOGA refers to lobbyists and registrants. Terry Draver from the General Accounting Office was involved in the 90s to help draft the Lobbying Disclosure Act. Now he is retired and no one bothered to see if common definitions could be used. Under HLOGA, everyone has to register—lobbyists, lobbying firms, and lobbyist employers with in-house lobbyists. The definition of registrants includes lobbying firms and lobbyist employers with in-house lobbyists. Who is currently listed as a lobbyist for your organization? Pick up the phone and review activities before you just include these names in the 2008 reports. You have the opportunity with the February report to make changes.

Think of HLOGA. The Act specifically does not use the L Word (and I am not talking about the series on Showtime). The problem New York is having is basically vendors do not consider they are lobbyists and do not take the time to determine whether the activity—and not the title—requires them to register. When Susan Bedsole was with the Ohio Joint Legislative Ethics Commission and later with State and Federal Communications, she always would say it does not matter if your title is “Hamburglar.” If your activities include communications with legislative and executive officials, there needs to be a review of whether registration is required.

Everyone needs to know gifts are prohibited. Yes, there are exemptions for widely attended events, receptions, and for senate events, but someone needs to oversee the gifts. My comment is someone at the company needs to be the adult and this is your opportunity to be the "go to" person.

Look at your 2008 calendar and make sure you are not planning a cruise the first two weeks of April, July, October, or January. Instead of the regular 45 days to prepare and file the report, you will now only have 20 days. This is going to require your contract lobbyists to provide you with the required filing information in a much shorter period of time. Send out notices with your 2008 contracts to remind your outside registrants to provide the needed info the first week of each new quarter so you can start preparing your report.

Contributions are now reportable (twice a year) by lobbyists, registrants, and PACs. This is not the FEC report. Your PAC administrator will need to provide the contributions to include in this new report.

Work with your legal and corporate offices to review the rules regarding usage of corporate aircraft and tickets by Members of Congress, staff, and congressional and presidential campaigns. Are policies in place to insure your organization is not making illegal in-kind contributions?

If you want to scare people, make sure they know of the civil and criminal penalties. And, more important, the public relations problems your company will have to deal with when the newspapers start reviewing reports.

I thought I would have 10 resolutions and only have eight…so, you can still include lose weight and exercise more!

State and Federal Communications has created a federal compliance team to help all of our clients with this issue. Consider us your 411 for HLOGA. In April, we will still be there to assist you, but then we will be your 911 for HLOGA!!!

Federal Team


Elizabeth Bartz Assistance with filing	Nola Werren General Compliance Questions	John Cozine General Compliance Questions	Brian Cassidy General Compliance Questions


Jamie Paulen Aircraft Issues	Cy Naumoff Aircraft Issues	Amber Fish Linke Tickets - Sports/Concerts	Chris Wheeler Tickets - Sports/Concerts

Elizabeth Z. Bartz
President and CEO
State and Federal Communications, Inc.

Requirements in Arizona

During the month of November of each odd-numbered year, Arizona requires lobbyists for compensation and designated lobbyists to renew current registrations. If you are not going to maintain a presence in the state for the upcoming year, you have the opportunity to terminate and should do so to eliminate reporting requirements.

In the month of November of each even-numbered year, principals must re-register until they no longer engage a lobbyist. Although electronic filing of reports is available, renewal registrations and terminations must be submitted in hard copy format by November 30^th to the Arizona Secretary of State, Attention: Election Services Division.

ALERTS Client Profile – Takeda Pharmaceuticals North America

State and Federal Communications, Inc. is in its fifth year serving Takeda Pharmaceuticals North America (TPNA) as an ALERTS client. TPNA is a wholly owned U.S. subsidiary of Japan’s largest pharmaceutical company, Takeda Pharmaceutical Company Limited, and was opened in 1998 in Deerfield, IL to accommodate its growing workforce.
TPNA’s 3,000 employees are dedicated to improving the lives of patients by presenting innovative products, and focusing on an assortment of therapeutic areas including: diabetes, cardiovascular disease, central nervous system, gastroenterology, and oncology.

Meet … Bobbi Simpson, Administrative Assistant

Bobbi is an Administrative Assistant at State and Federal Communications. She works closely with the Compliance Associates to ensure reports are delivered to our ALERTS clients on time. Since beginning her work with State and Federal Communications, Inc., Bobbi has a renewed thirst for politics in the U.S. She is taking two graduate level courses at the University of Akron: Lobbying and Voters/Elections. Additionally, on her lunch break, she attends a class on American Government and Politics. Bobbi volunteered at a local election post in November.

According to Bobbi, “I believe it is important to vote and to give back to your community. By working at the polls it enables me to give back and to exercise my right to vote.”

Landmarks Series – Arlington National Cemetery

This article is one of an ongoing series that focuses on historical and/or significant landmarks. Information gleaned from arlingtoncemetery.org, nps.gov, wikipedia, and other sources.

Only two U.S. presidents are buried at Arlington National Cemetery. Who are they?

With more than 300,000 buried at Arlington National Cemetery, on 624 acres, it has over four million visitors each year. Most come to pay their respects at graveside services, which occur Monday through Friday. Tthe cemetery hosts nearly 100 funerals each week. Of the 300,000 interred at the cemetery, two are past presidents of the United States - President William Howard Taft and President John F. Kennedy.

Located in Arlington, Virginia, it was established during the American Civil War as an American military cemetery. It is on the property of the Arlington House [also known as the Custis-Lee Mansion], which was formerly the land of Robert E. Lee’s wife Mary Anna Custis, a direct descendant of Martha Washington. This cemetery is located across the Potomac River by the Memorial Bridge that connects the cemetery to the Lincoln Monument and several other famous Washington, D.C. memorials. The Arlington House and its grounds are administered by the Department of the US Army, as a memorial to Lee. The National Park Service administers many other National Cemeteries along with the Department of Veterans Affairs.

Veterans from every one of the nation’s wars are interred here from the Revolutionary War through the current military actions in Iraq and Afghanistan.

Arlington National Cemetery’s list of people eligible for ground burial are as follows:

Any active-duty member of the US Armed Forces [except those who are serving active duty to train only];
Any retired veteran from active military service;
Any retired veteran from the Reserves, upon reaching 60 years of age and who is drawing retired pay, who had previously served in active duty;
Any former Armed Forces member separated honorably prior to October 1, 1949 for medical reasons and who was rated at 30% or greater disabled effective on the day of discharge;
Any veteran who has been awarded one of the following decorations:

Medal of Honor

Purple Heart

Silver Star

Distinguished Service Medal

Distinguished Service Cross, Navy Cross, or Air Force Cross;

The current or any former US President;
Any veteran who held any of the following positions:

An elective office of the U.S. Government ;

An office listed, at the time the person held the position, in 5 USC 5312 or 5313 (Levels I and II of the Executive Schedule);

Office of the Chief Justice of the United States or of an Associate Justice of the Supreme Court of the United States;

The chief of a mission who was at any time during his/her tenure classified in Class I under the provisions of Section 411, Act of 13 August 1946, 60 Stat. 1002, as amended (22 USC 866) or as listed in State Department memorandum dated March 21, 1988;

Any prisoner of war who served honorably on active duty in any of the Armed Forces, who died on or after November 30, 1993;
The spouse, widow or widower, minor child, or permanently dependent child, and some unmarried adult children of any of the above eligible veterans;
The widower or widow of:

a member of the Armed Forces who is buried in an overseas US military cemetery and is maintained by the American Battle Monuments Commission;

a member of the Armed Forces who was lost or buried at sea or officially determined to be missing in action;

a member of the Armed Forces who is interred in Arlington National Cemetery as part of a group burial;

The existing spouse, minor child, or permanently dependent child of any person already buried in Arlington National Cemetery;
The parents of a minor child, or permanently dependent child whose remains, based on the eligibility, are already buried in ANC. A divorced spouse from the primary eligible, or widowed and remarried, is not eligible for interment.
Provided certain conditions are met, a former member of the Armed Forces may be buried in the same grave with a close relative who is already buried and is the primary eligible.

The Tomb of the Unknowns

This tomb is also known as the Tomb of the Unknown Soldier. It stands on top of a hill, in Arlington National Cemetery, overlooking Washington, D.C. The World War I unknown is below the marble sarcophagus. Other unknowns are beneath the white slabs on the ground. They are the World War II and the Korean War unknowns. The remains of the former Vietnam War unknown were under the middle slab, however, after DNA analysis, he was identified as being Michael Blassie. Other unknowns from World War I, World War II, Korean War, and Vietnam War are also buried at the Tomb of the Unknowns.

For more information on the Arlington National Cemetery, visit www.arlingtoncemetery.org

Noteworthy

The State and Federal Communications, Inc. office will be closed
Thursday, November 22^nd and Friday, November 23^rd.

See Us in Person

Plan to say hello at future professional development events where State and Federal Communications will be attending and/or speaking regarding compliance issues.

November 17-20	Leaders' Policy Conference by SGAC, Miami Beach, Florida
December 5^th	SGAC Holiday Party, Washington, D.C.
December 11^th	WASRG Holiday Party, Washington, D.C.
January 13-16	2008 National Grassroots Conference - PAC, Key West, Florida
February 11-14	Innovate to Motivate - 2008, Orlando, Florida National Conference for Political Involvement Professionals
February 24–27	National PAC Conference, St. Petersburg, Florida
April 2–4	SGAC Annual Meeting, St. Petersburg, Florida

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