After the Federal Election Commission (FEC) formulated a rule on reporting campaign contributions bundled by lobbyists, many were concerned that it was too narrow and would not quite capture very much information. Now, we see those points were not misguided. The situations under which a member of Congress is legally required to disclose a lobbyist's fundraising are limited. A recent analysis from the Associated Press found that only a few members of Congress are disclosing bundled contributions from lobbyists.

As part of the Honest Leadership and Open Government Act (HLOGA), lawmakers must report to the FEC lobbyists who have bundled money for their campaigns. A bundler collects contributions from others and then gives the money to a particular candidate.

The Sunlight Foundation has a database, Party Time!, that lists fundraisers hosted by lobbyists. "Lobbyists identified as hosts on at least 195 congressional fundraising invitations have yet to be publicly disclosed as fundraisers by the candidates who benefited, the review found. AP checked invitations that it and the nonpartisan Sunlight Foundation independently obtained against campaign finance reports filed with the Federal Election Commission and lobbyist registrations compiled by the Senate."

AP reviewed fundraisers held from March 19 through June, the first time period covered in the rules. The analysis found that there a few different ways to avoid the disclosure requirements. For example, the candidate only has to disclosure if they formally recognize the contributor as a fundraiser. In addition, someone could sponsor a fundraiser who are not themselves registered lobbyists.