Last month rules were released regarding communications with federally registered lobbyists concerning the Troubled Asset Relief Program (TARP). Since then, there has not been much news about disclosure reports or any follow through. The Sunlight Foundation has done a very detailed analysis of the rules noting; "they are hard to understand, difficult to apply, and full of contradictions and omissions that undermine stated policy objectives. The rules should be clarified, rewritten, simplified, and broadened."

TARP lobbying disclosure rules prohibit oral communications covering specific applications for funds in certain circumstances, and Sunlight's post breaks down the various circumstances and exceptions to the rules. There are even informative graphs detailing the reporting requirements. Sunlight also makes some recommendations, such as creating an online searchable lobbying database of all disclosures required, which is updated in real time.

Interestingly, after commenting on the difficulty in finding any lobbying communication reports on Treasury's website, two disclosure reports now appear. A second blog from Sunlight notes; "What is also interesting is that there are only two lobbying contacts reported. This leads to a couple of possible implications: (1) Treasury has more forms to publish, perhaps some of which are late; or (2) Treasury has no more forms to publish right now. For the latter to be true, either no one has talked to Treasury about spending TARP funds over the last month, or the lobbying disclosure rules don’t have a lot of bite and missed capturing lobbying communications."