Lobbying Disclosure Modernization

A grassroots email is not a lobbying contact today, and NANA does not believe it should become one under a rule aimed at direct contacts with legislative staff. The proposal under NANA's watch would count a "call to action" email (a message asking members to contact their own representatives on a bill or rule) as a reportable lobbying contact, the same category currently reserved for an association's own staff or hired lobbyist calling a Hill office directly. NANA's public policy team, led by Senior Policy Manager Farah Qureshi-Lindgren, argues the rule conflates two different activities: an association speaking to a regulator on its members' behalf, and an association asking its own members to speak for themselves. Collapsing that distinction would put a reporting burden on associations that have never operated a compliance function built for lobbying disclosure at all.

Most NANA member associations run grassroots campaigns through their communications team, not their government-relations staff, if they have government-relations staff at all. Under the proposed rule, a routine "email your senator" campaign would need to be logged, timed, and disclosed the same way a paid lobbyist's meeting is today, recordkeeping that assumes an association already has a compliance office built for it. As Qureshi-Lindgren told members at the 2025 Fall Policy Forum, "a grassroots email isn't a lobbying contact today. Under this rule, it could be — and most of you don't have a compliance office built for that." Associations without a dedicated policy team, which run advocacy alongside communications rather than as a separate function, are the ones most exposed to an unfamiliar filing requirement landing on short notice.

NANA is asking the agency behind the proposed rule to keep the current, narrower definition of a reportable lobbying contact, or at minimum to build in a compliance on-ramp for associations that have never filed a lobbying disclosure before. Member associations are asked to file their own comments opposing the expanded definition, and, regardless of how the rule lands, to start logging grassroots campaigns now, so a filing under a new rule can be assembled from records rather than reconstructed from memory. NANA's policy team is asking members to send a rough count of how many grassroots campaigns they run in a typical year, so the association can show regulators the real scale of activity the rule would newly capture. The Lobbying Disclosure Compliance Brief and NANA's Grassroots Advocacy Campaigns course both walk through what to record starting now.