NAICU Washington Update

NAICU Announces Projected Direct Lobbying Costs for 2010-11 Membership Cycle

June 03, 2010

In order to ease compliance efforts by member colleges, NAICU is adding its projection of the portion of dues that go to direct lobbying expenses to its 2010-11 membership dues invoice.  Until now, NAICU has provided that number to member institutions on an as-requested basis.

Non-profits have two options on how they calculate lobbying expenses.  NAICU has elected to use Internal Revenue Code (IRC) definitions, so that the numbers we report both on our IRS Form 990 and to Congress under the Lobbying Disclosure Act (LDA) are consistent.  Under IRC definitions, NAICU's estimated lobbying percentage -- 7 percent for the 2010-11 dues cycle -- does not reflect regulatory work, nor most advocacy with the executive branch (unless directly related to legislation).  Also excluded are NAICU's more general efforts to promote the good work of our sector with national media, think tanks, and the public.

In general, the lobbying percentage under IRC is the percent of the NAICU budget expended in direct time on lobbying employees of Congress, or in preparation, research, planning, and associated expenses relating to those efforts.  (This link provides additional details on reporting lobbying expenses.)

The exact statement appearing on the NAICU dues invoice is:

"NAICU's good-faith estimate of the percentage of membership dues that will be used for lobbying during the July 1, 2010-June 30, 2011 membership year is seven (7%) percent.

"IRS Form 990 requires a 501 (c) entity to report its lobbying expenditures on Schedule C.  An entity that makes a 501(h) safe harbor election in regard to the amount of its lobbying expenses completes Schedule C Part II-A.  An entity that does not make a 501(h) election must answer certain questions about its lobbying activities and report its lobbying expenditures on Schedule C Part II-B."

NAICU recommends that questions regarding your institution's reporting requirements under the Lobbying Disclosure Act or on IRS Form 990 be directed to your institution's legal counsel and accountants.  For more information on LDA, contact Sarah Flanagan at NAICU,  For more information on NAICU's calculation of its lobbying percentage, contact Linda Allison,

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