This document provides guidance on tracking special interest influence through publicly available records of lobbying, campaign finance, and financial disclosures of public officials. It outlines the following steps: 1) Identify lobbyists working for the entity of interest through lobby records. 2) Determine the issues lobbyists work on through disclosure forms, testimony, or public records requests. 3) Identify politicians supporting those issues and search for campaign contributions from lobbyists to those politicians. 4) Cross-reference information from different records types to uncover patterns of influence. The document uses examples from Florida but notes this process can be applied to different levels of government.

1. Down the rabbit hole: identifying special interest public sector influence
through lobby records, campaign finance records and officeholder
disclosures
DBA Press
August, 2012
http://dbapress.com/wp-content/uploads/2012/09/DBA-Special-Interest-
Inluence-Tracking.pdf
Intro:
Increasingly it seems as though the average citizen needs a lobbyist, or a
team of lobbyists, with big bags of cash, in order to gain any entree to
the world of the American democratic process. But, since you, the
average citizen, likely do not have your own personal lobbyist, or a bag
of cash to give to such a lobbyist, you may be interested in the next best
thing: monitoring the activities of those who do have teams of cash-bag-
toting lobbyists.
There are three primary sets of publicly-available records you can utilize in analyzing the web of
influence at play in any level of government. Those tools are: lobby records, campaign finance records
and statements of disclosure (financial, gift, travel) filed by public officials and their staffers.
It is the aim of this tutorial to acquaint you with the use of these tools.
Step A: identifying types and sources of records
Lobbying exists at all four levels of American government: municipal, county, state and federal.
Thanks to the antics of Jack Abramoff and his ilk, federal lobby records are generally more detailed and
easy to access than such records at other levels of government. You may access and inspect federal
lobby disclosure reports (as well as lobbyist campaign spending) through both the Office of the Clerk
of the U.S. House of Representatives (http://clerk.house.gov/), as well as through the U.S. Senate
Office of Public Records (http://www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm).
Federal campaign finance records are maintained by the Federal Election Commission (FEC:
http://www.fec.gov/).
Federal officeholder/candidate statements of personal financial disclosures are maintained by the
House, the Senate, or the officeholder/candidates' respective executive or judicial agency/office (federal
judicial statements of financial disclosure, "Form AO 010A," are maintained by the Administrative
Office of the U.S. Courts: http://www.uscourts.gov/FormsAndFees/Forms/CourtForms.aspx).
The Senate and the House can be very difficult to deal with when seeking these types of records. For
example, the Office of the Clerk of the House of Representatives makes representatives' statements of
personal financial disclosure readily available on its website. However, staffer statements of financial
disclosure, and other disclosures filed by representatives, are only available through a computer kiosk

2. located in the Cannon House Office Building in Washington, D.C.. House personnel will not send you
records if you request them.
The Senate Office of Public Records offers some gift and travel disclosures on its website, but, in order
to obtain statements of financial disclosure filed by either staffers or senators, you must go (or get
someone to go) to the Hart Senate Office Building in Washington, D.C.. Senate staff will not send you
records if you request them.
County and municipal lobby/campaign/disclosure records can be more difficult to track down-- and, in
many cases, lobby records at either the municipal or county level may be non-existent. The best way to
determine whether such records exist is to call whatever municipal or county agency handles matters
relating to elections and ask. If this line of inquiry bears no fruit, try calling and asking around at the
central municipal/county administration offices. In some cases-- likely in municipalities or counties
with small populations-- your best bet for determining which entities have been lobbying officials on
specific issues will be to submit public records requests aimed at uncovering communications, meeting
minutes, et cetera.
Each state manages records relating to lobbying, campaign finance and financial/gift/travel disclosures
differently-- and each state has different laws governing who is required to file these records, how
records are made available to the public, and what information needs to be disclosed.
In many states campaign finance, lobby records and statements of officeholder financial disclosure are
maintained by the secretary of state's division of elections. Arizona is an example of one such state:
http://azsos.gov/.
Some states have an independent agency tasked with matters pertaining to lobbying, elections and
disclosure. Montana's Office of the Commissioner of Political Practices is an example of this:
http://politicalpractices.mt.gov/default.mcpx.
The third common arrangement found at the state level is one wherein one agency maintains lobby
reports, another entity maintains records related to political campaigns and campaign finance-- and yet
a third entity maintains records relating to officeholder disclosure. Florida is an example of this
arrangement. Florida legislative and executive lobby records are maintained by the legislature
(http://www.leg.state.fl.us/lobbyist/). Campaign finance records (and other records relating to
campaigns/committees) are maintained by the Florida Department of State Division of Elections
(http://election.dos.state.fl.us/campaign-finance/contrib.asp). And, lastly, officeholder/staffer statements
of personal financial/gift disclosure are maintained by the Florida Commission on Ethics
(http://www.ethics.state.fl.us/). (Legislative travel vouchers in Florida are maintained by the
Legislature and can be obtained through public records requests. For other travel records/disclosures--
executive or judicial-- you will likely need to contact the relevant office and submit a public records
request.)
If you are not sure which agencies maintain records in a specific state-- or if the records you are
looking for exist-- you may want to spend some time researching applicable state law (usually provided
online through a state's legislature), as the law usually specifies which offices are responsible for the
maintenance of which records. Reading the law is also useful in that you may discover prescribed time
periods for records retention, as well as information on which public employees (officeholder or staff)
are subject to various aspects of these laws, such as laws governing financial/gift/travel disclosures.

3. Relevant federal law is contained in the U.S. Code, available through the U.S. House of
Representatives Office of the Law Revision Council (http://uscode.house.gov/).
As access to different records vary from virtually every state, county, municipality and federal agency,
remember this: whenever in doubt, pick up a phone and call around. Public information officers and
clerks can be very helpful.
Step B: tracking influence
You've located the sources of your three primary tools: lobby disclosure, campaign finance records and
financial/gift/travel disclosures. So, now what do you do? Well, the basic idea is to use all three tools to
cross reference little pieces of data/clues turned up by each. The objective is to unearth and identify
patterns of influence.
For our purposes here, we will use an illustrative example in the state of Florida-- since all three
research tools are scattered across three different agencies. Floridian bureaucracy can be difficult to
navigate, therefore research in Florida is good practice. Please bear in mind that this pattern of research
can be applied to all levels of government nationwide.
-- 1.) First, you want to identify which lobbyists are working for the entity you suspect is influencing
some executive/legislative matter (judicial influence is a little harder to track, unless you are
researching some law/public policy related to the judiciary. Bear in mind, however, that many judges
are elected. As such, you can identify possible influences at work through campaign contributions). For
this task you will conduct lobbyist research through resources provided by the Florida Legislature
(http://www.leg.state.fl.us/Lobbyist/index.cfm?
Tab=lobbyist&CFID=245285951&CFTOKEN=82821551).
Unfortunately, the Florida legislative/executive lobbyist database is somewhat limited. There are three
ways you can search through this data: by lobbyist name, or by principal name ("principal" refers to the
lobby client). The downside to this is that it is very difficult to put together a complete list of all
lobbyists working for a given lobby firm. However, a complete list of clients employing a lobby firm
may be gathered through "compensation reports" (also available through the Legislature:
http://olcrpublic.leg.state.fl.us/) filed by individual lobby firms.
Another shortfall of the Florida system is that directories of lobbyists listed by principal name are only
made available for the current year and the preceding year. This can make research of past lobby
activity (more than one year in the past) difficult, as the Legislature does not retain these old lists.
In any event, let's say that through these available resources, you have developed a list of lobbyists who
are working for the particular entity you are interested in.
-- 2.) While this next step may seem pretty straightforward-- and sometimes it is very straightforward--
it can actually be the most difficult to complete. You now have a list of lobbyists who represent the
special interest you are researching. You may suspect that these lobbyists have lobbied on a specific
issue, but how can you be sure?
Sad to say, often times there is no definitive paper trail illustrating exactly what issues a lobbyists
opposes or promotes. One way to determine where a lobbyists stands on an issue is to call them and
ask. Sometimes lobbyists can surprise you with their candor. Alternately, you may find a press account

4. or a press release detailing the stance of a lobbyist (or their principal) on an issue.
Another way to determine lobbyist involvement and stance on an issue is to submit public records
request seeking either all communications with a particular lobbyist (or all records pertaining to the
lobbyist in question), or pertaining to the lobbyist's principal, or pertaining to the formation of a bill--
or all of the above. However, in many states, legislators have written exemptions into public records
law through which "legislative work product" may be withheld. As odd as it may seem,
communications with lobbyists often fall under this category. Similarly, public records law in many
states includes exemptions for both legislative and executive "privilege." Federal lawmakers have also
written themselves and their offices out of the Freedom of Information Act (FOIA)-- which essentially
means that a large portion of the American public is completely dependent of the whims of their elected
officials when it comes to this area of governmental transparency. Regardless, you should not be
discouraged from seeking information in this way. Sometimes this strategy yields surprisingly
informative results.
Some states, such as Wisconsin, have very good lobby disclosure laws that really take much of the pain
out of this research phase. Records relating to lobbying activity in Wisconsin are maintained by state's
Government Accountability Board
(http://ethics.state.wi.us/LobbyingRegistrationReports/LobbyingOverview.htm). These records contain
fairly detailed information on which specific issues/legislation individual lobbyists oppose or support.
Similarly, the Texas Ethics Commission (http://www.ethics.state.tx.us/dfs/loblists.htm) provides a
database of registered lobbyists by lobby issue.
Unfortunately, many states do not provide anywhere near this level of disclosure. Some states, such as
Kansas, maintain nothing but the bare-bones records listing off registered lobbyists and principals.
Arizona is somewhere between these two extremes; lobbyists are required by law to disclose the
recipients, sources, amounts and purposes of expenditures paid by lobbyists for the benefit of "covered
officials" (officeholders and public employees subject to Arizona lobby disclosure law). However, the
Office of the Arizona Secretary of State Division of Elections (http://azsos.gov/) is seen as little more
than a filing cabinet with virtually no compliance enforcement and many lobbyists do not bother to
honor state lobby disclosure law. When these laws are followed, however, the results can be
interesting-- showing lobbyists wining and dining public officials at events staged by special interests.
But, while enforcement of state lobby disclosure law is practically non-existent, such research in
Arizona can be very hit-or-miss.
Federal lobby records are fairly detailed and relate information on legislative bodies/agencies lobbied,
the amount expended, and the issues on which lobbyists worked. However, these records often do not
disclose on which side of an issue a lobbyist/principal stood.
One potential way of determining the stance a lobbyist or their principal took on a specific issue is to
check legislative hearings/committee records. For example, if a legislative committee (federal or state)
held a hearing on a specific issue, and a lobbyist (or a representative of their principal) either delivered
testimony or otherwise addressed the committee, there should be a record of this. This record will,
more often than not, disclose the lobbyist's stance on an issue. In many states, these records are
maintained by the relevant legislative body and can be obtained through the clerk's office.
At the federal level, transcripts of such hearings may be obtained either through the individual
legislative committee, or through the Government Printing Office (GPO:

5. http://www.gpo.gov/fdsys/browse/collection.action?collectionCode=CHRG).
At the county or municipal level-- when dealing with research centering on the possible influence of
bodies such as a county board of supervisors, or city council-- you will want to track down meeting
minutes and/or recordings of meetings. You should be able to obtain these records through public
records requests submitted to the relevant municipal/county entity.
But, back to our research exercise in Florida: if you need to track down records relating to speakers at
committee hearings (called "appearance forms," detailing speaker name, date of address, committee
name, hearing subject, and position held on the issue discussed), you would contact the Florida
Department of State Division of Library and Information Services State Archives (located in
Tallahassee: http://dlis.dos.state.fl.us/index_Researchers.cfm).
-- 3.) At this point in the game, you hopefully have determined which lobbyists are working for the
special interest you are researching and how they stand on the issue you suspect they have been
influencing. The next step is pretty simple: you take your list of names and search for campaign
contributions to committees that support officeholders you suspect may be influenced by these
lobbyists.
Typically, you can identify the names of legislators who may have been influenced by your lobbyists by
looking at bills sponsored or supported by lawmakers. Put plainly, if a lawmaker sponsored/supported a
bill (or slipped language into an existing bill) beneficial to a special interest represented by those on
your list of lobbyists, they may have also received campaign cash from these lobbyists. If you're
researching an elected official in the executive or judicial branch, you may want to look for patterns of
actions beneficial to the special interest you are researching.
In Florida, these legislative records may be accessed through either the Senate
(http://www.flsenate.gov/), the House (http://www.myfloridahouse.gov/), or through the Florida
Department of State Division of Library and Information Services State Archives (located in
Tallahassee: http://dlis.dos.state.fl.us/index_Researchers.cfm).
So, once you have identified officeholders who, through their actions, have demonstrated an affinity for
issues held dear by those on your list of lobbyists, you go to campaign records maintained by the
Florida Department of State Division of Elections (http://election.dos.state.fl.us/campaign-
finance/contrib.asp) and search for contributions given to candidates/committees by the lobbyists on
your list. If you find that the lobbyists you are researching have contributed to political action
committees (PACs) that are not affiliated with any one candidate, research the PAC and its spending
patterns.
There are a few different types of non-candidate-affiliated PACs, the two most common would be
industry/corporate PACs (administered by a trade association, union, or specific business entity) and
ideologically-driven PACs (administered by, or related to, a not-for-profit organization). Both of these
types of PAC exist at the state and federal level, so-- depending on the type of research you are
conducting-- you will either obtain these records from the FEC (http://www.fec.gov/), or through state
campaign records.
Volumes could be-- and have been-- written about ideologically-driven PACs. Suffice to say that many
of these are also supported by industries and corporate interests. It is worth your time to research the
funding base of these groups whenever possible. Many of these ideologically-driven PACs do not issue

6. campaign contributions, but rather, dedicate their resources to electioneering communications, either
supporting or opposing a candidate.
As far as industry/corporate PACs are concerned, you will want to look at the spending patterns of
PACs administered not only by the principals of the lobbyists you are researching, but also those
administered by the lobby/law/"government relations" firms that employ the lobbyists you are
researching.
Another important note on lobbyists and PACs: when researching lobbyist campaign support, do not
limit yourself solely to tracking campaign/PAC contributions. Many candidate committees (or other
committees, such as political party committees) emply lobbyists/lobby firms as campaign managers,
research/fundraising consultants, or treasurers. So, aside from performing simple campaign
contribution searches, you will want to access actual committee reports that list committee
expenditures, as well as committee personnel. In many states, these reports are not available online, but
you should be able to obtain them from the relevant agencies with a quick phone call (this also applies
to committees created for municipal and county elections). As you go through these reports, cross
reference the names of consultants and committee personnel with state (and possibly federal or
municipal) lobby records. Committee reports are also often a valuable source of phone numbers,
addresses and email addresses.
-- 4.) By this stage, you will likely have a list of public officials who may be under the influence of the
special interest you are researching, and the lobbyists who represent that interest. This brings us to your
last step: check for special interest ties to officeholder personal finances.
In order to do this, you will want to get your hands on as many statements of disclosure filed by not
only the officeholder you are researching, but their staffers as well. Such disclosures may include (and
bear in mind that each state has different laws governing this): disclosures of personal finances, gift
disclosures and travel disclosures.
It is worth reviewing disclosures filed by staffers, as a surprising number of staffers are former
lobbyists who-- upon leaving the public sector-- tend to return to the lobby fold. And, in many cases,
the virtually unseen staffer acts as a gatekeeper to the public official/public office.
Laws governing disclosure requirements for staffers vary state to state. If you discover that a staffer
you are researching has filed no disclosures, when you believe they are required to by law, you will
want to check the definition of "covered position" /"covered official" (public employees affected by
disclosure law) in the applicable state disclosure law.
At times it can be difficult to determine exactly who is employed in a public office. Much of the time, a
simple call to the clerk's office at whatever governmental body/public office you are researching is
sufficient, but-- depending on how difficult the governmental body/public office wants to be-- you may
actually have to file a public records request for this information.
Many legislatures compile office staff directories that are generally easy to obtain. The U.S. Senate
produces a publication, the "Report of the Secretary of the Senate." This report is published biannually,
and contains a wealth of information on the offices of individual senators-- including information on
staffers employed by specific offices and information detailing office disbursements. The Senate
provides the two most recent editions of this publication on its website
(http://www.senate.gov/legislative/common/generic/report_secsen.htm). Older editions of this report

7. can be ordered through GPO (for a fee), or they can be accessed through federal depository libraries
(http://www.gpo.gov/libraries/).
Similarly, the U.S. House of Representatives publishes a report, "Statement of Disbursements of the
House." This report is published quarterly and contains information on the offices of individual
representatives-- including information on staffers employed by specific offices and information
detailing office disbursements. This report is published online by the U.S. House of Representin'
(http://disbursements.house.gov/). Editions of the report dating to July, 2009 are available online
through the House Statement of Disbursement archives (http://disbursements.house.gov/archive.shtml).
Older editions of this report can be ordered through GPO (for a fee), or they can be accessed through
federal depository libraries (http://www.gpo.gov/libraries/).
Officeholder travel disclosure requirements vary broadly from state to state. You will want to research
legislative rules and state laws pertaining to travel disclosures for each state you perform this research
in.
In Florida, legislative travel records (for travel reimbursed by the Legislature) can be obtained through
either the House or Senate.
All other disclosures (financial and gift) are maintained by the Florida Commission on Ethics
(http://www.ethics.state.fl.us/). These disclosures are not currently available online and must be
requested (though a formal public records request is not required). (In many states, these disclosure
records are maintained by the office of the secretary of state.)
While reviewing these disclosures, keep an eye out for special interest influence in the forms of shared
business interests/investments, stock owned by the reporting person, gifts given to the reporting person
by lobbyists, travel paid for by lobbyists (or their principals), travel to meetings with
lobbyists/principals, property transactions, et cetera.
While many public officials, their staffers and lobbyists may feel that few in the public are really
scrutinizing their actions, and may become sloppy due to this attitude, it is important to look for
connections/patterns that are not so obvious.
For example, Lawmaker X may list a partnership interest in some odd business (let's say "Legitimate
Business Consulting, LLC") on a statement of financial disclosure. There is nothing in this business
name that would cause you to think that the business is related to either the special interest you are
researching or any of its lobbyists. What you want to do is research this entity and see who is partnered
with Lawmaker X in this business.
There are two primary means of researching a business entity. If the business in question is publicly
traded, you can obtain a wealth of information on the company, its executives, directors, shareholders,
subsidiaries and holdings through records maintained by the Securities and Exchange Commission
(SEC: http://www.sec.gov/edgar/searchedgar/companysearch.html). If the business in question is not
publicly traded, you may still be able to find some limited information involving its holdings and
transactions of shares through SEC records, but your best bet will be to search state corporate records.
Typically-- though not uniformly-- these records are maintained by the corporations division of a state's
office of the secretary of state-- as is the case in Florida.
In some states corporate records are maintained by entities outside the office of the secretary of state,

8. such as a corporations commission (as is the case with the Arizona Corporation Commission:
http://starpas.azcc.gov/scripts/cgiip.exe/WService=wsbroker1/main.p, or the New Mexico Public
Regulation Commission: http://www.nmprc.state.nm.us/corporations/index.html). In the District of
Columbia, these records are maintained by the Department of Consumer and Regulatory Affairs
(https://corp.dcra.dc.gov/Account.aspx/LogOn?ReturnUrl=%2f).
Some states, such as Florida, are very open with corporate information, while other states-- such as
Virginia and Delaware (and the District of Columbia)-- are extremely tight with corporate records and
often charge exorbitant fees for copies of such records.
Records pertaining to both Florida-based corporations, as well as "foreign corporations" (corporations
not based in Florida, but doing business in Florida), are maintained by the Florida Department of State
Division of Corporations (http://www.sunbiz.org/search.html). Such records include articles of
incorporation, notices of mergers, annual reports and other items.
So, let's say you go to the Florida Department of State Division of Corporations database and you pull
up the articles of incorporation for our fictitious "Legitimate Business Consulting, LLC." As you are
reading through the articles of incorporation, you notice that the business address given is the same
address as "Smoke and Mirrors, LLP"-- a lobby firm that employs one of the lobbyists on your special
interest lobbyist list.
Now, let's say that Lawmaker X is the sole listed director/incorporator on the articles of incorporation
for Legitimate Business Consulting, LLC. We pull up a subsequent annual report to find out who
joined Lawmaker X as a partner in the business. The report shows that Lawmaker X was joined at
Legitimate Business Consulting, LLC by a partner, "Eddie Basura," the year following incorporation.
Now, you run "Eddie Basura" through the Division of Corporations database (as a possible director or
registered agent) and you find that Basura is, in fact, one of the directors of "Smoke and Mirrors, LLP."
Now you've got something-- this would be your eureka moment.
You will now want to check Lawmaker X's statements of financial disclosure to determine what his rate
of compensation from this business venture has been-- and, if possible, to determine who his clients at
Legitimate Business Consulting, LLC are.
While other pieces of information provided on disclosures filed by officeholders and their staffers may
provide overt ties to special interests/lobbyists (items such as paid travel, gifts, stock owned in a
corporation), there is another less-than-obvious avenue of research I'd like to point out: look at property
holdings listed on disclosures of financial interest. You never know what you will find. For example,
you may find that some individual/entity tied to some special interest is renting out a rental property
owned by a public official at a padded rate. You may find that a lawmaker owns a piece of property
that, for some reason or another, is about to boom in value due to some legislative action. You may find
that some corporation sold your public official a $250,000 piece of land for $10.
In order to research property records, you will have to go to the county level. Typically, property
records are either found with the office of the county recorder or the county tax appraiser/assessor-- or
both.
Many counties (particularly urbanized counties) have excellent property records databases available
online. One example of such a system is the Leon County Property Appraiser (Leon County, Florida)

9. property records database: http://www.leonpa.org/searchAgreement.html. However, many counties--
mostly rural counties-- still require the use of a telephone. Either way-- for the sake of thoroughness-- it
is worth your time to research properties owned by individuals you are researching.
Outro:
I hope that you now have a better understanding of the tools available to you than you did when you
began reading this. And, I think you get the idea: leave no stone unturned, leave no rabbit hole
unprobed. Happy hunting.