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Board of Ethical Conduct asks Metro Clerk for report on clients tied to repeat lobbyist noncompliance
Summary
After reviewing the Metro Clerk's 2024 lobbying report showing six lobbyists failed to file annual reports, the Board voted unanimously to request a follow-up analysis identifying clients with repeated compliance failures and to reconvene once the clerk provides the data.
The Board of Ethical Conduct voted 5-0 to request a data report from the Metro Clerk's Office identifying clients whose registered lobbyists repeatedly failed to file required annual reports.
Board members discussed the Metro Clerk's 2024 lobbying and expense report, which showed 94 registered lobbyists, 88 reports received and six lobbyists who did not file the January 31 annual report, equal to 93.6% compliance for the reporting year. The clerk's packet noted that only one client on the nonfiling list had new lobbyists registered for 2025: Old Town Trolley Tours of Nashville, which listed two new lobbyists for 2025.
Metro Clerk's Office staff told the board they track filings historically and compiled four years of data for the packet. The clerk's summary noted some registrants formally withdrew (one withdrawal recorded July 29, 2024) and that withdrawn registrations may still be obligated to file an annual report for the year in which they engaged in lobbying.
Board members raised concerns about a practical loophole: a lobbyist who fails to file may simply not reregister in the following year, avoiding immediate sanctions and allowing a client to hire a different lobbyist later. One board member said that, where a lobbyist "withdraws, they could potentially resume that if they filed all the appropriate reports and registration in a subsequent year." The clerk confirmed withdrawals are recorded and that the office retains withdrawal records for five years, but said the code does not expressly bar re-registration after a withdrawal.
The clerk also described the board's enhanced enforcement authority under recent code revisions: new provisions allow revocation of a registration for noncompliance if a lobbyist reregisters for 2025 but fails to file required reports or pay assessed late fees by the March 1 list date. The clerk said several lobbyists filed late but paid late fees before the March 1 listing and therefore were not subject to revocation; the clerk estimated roughly five or six late filers paid fees and were brought into compliance.
After discussing possible next steps'including whether to notify clients directly, reinstate a client-signoff requirement, or track repeat noncompliance over multiple years'the board adopted a motion to request that the Metro Clerk's Office prepare a report identifying clients whose lobbyists have a history of repeated failures to comply with reporting requirements. The motion, seconded, passed on a recorded vote of five in favor, zero opposed. The board directed that the clerk aim to deliver the data within two weeks and that the board reconvene to consider potential recommendations to the council if the data shows repeat problems.
The clerk reminded the board that disclosure reports and lobbyist registrations are publicly available; members of the public who see potential violations may file a complaint with the board for investigation.
The clerk also said the office is exploring ethics administration software to replace spreadsheet-based tracking; the software would be phased in, beginning with annual disclosure reports and later adding lobbyist registration and reporting functions to provide a public-facing site and better reporting capabilities.
No further enforcement action was taken at this meeting; follow-up depends on the clerk's forthcoming data.
