June 23, 2004

To all interested persons:

Pursuant to Iowa Code section 68B.32A(11) and rule 351β€”1.2, the Iowa Ethics and Campaign Disclosure Board issues this opinion on executive branch lobbyist client reporting. We note at the outset that the Board’s jurisdiction is limited to the application of Iowa Code chapters 68A and 68B and rules in Iowa Administrative Code chapter 351.


In IECDB Advisory Opinion 2003-08, the Board issued an opinion interpreting Iowa Code section 68B.38 as amended by 2003 Iowa Acts, HF 583. The issues in that opinion included the filing due date for executive branch lobbyist client reports and the cutoff date for information that needed to be disclosed on that report.

Iowa Code section 68B.38 as amended by 2004 Iowa Acts, SF 2179, section 13, codified the holding of the Board’s opinion on the time period the report covers (preceding twelve calendar months, concluding on June 30). The legislation also made the following change:

1. Executive branch lobbyist client reports are now to be filed on or before July 31 of each year.

In closing, the Board notes that it has amended rule 351β€”8.9 (Executive branch lobbyist client reporting) to reflect these statutory amendments.

IECDB Advisory Opinion 2003-08 is hereby rescinded.


James Albert, Board Chair
Phyllis Peters, Vice Chair
Janet Carl
Gerald Sullivan
Betsy Roe
John Walsh

Submitted by: W. Charles Smithson, Board Legal Counsel


*rule 8.9