US Client Identification Requirements Resources in United States

US Client Identification Requirements Resources

The Center for Ethics in Government – UPDATED April, 2007–reflects statutes in effect as of 12/31/06

This table is intended to provide general information and does not necessarily address all aspects of this topic. Because the facts of each situation may vary, this information may need to be supplemented by consulting legal advisors. It reflects in summary form statutes in effect as of 12/31/06 or statutes set to take effect shortly thereafter.

State/Reference	Are individual client names ever required to be disclosed?
Ala. 36.25.14	No, but: if employed in one of 11 professional fields, include the number of clients in each of several dozen fields and the categorical amounts of income received from each field.
Alaska 24.60.100 24.60.200	In some cases: if they have or may have an interest in legislation or if filer has represented a client before a state agency for payment.
Ariz. 38-542	No: Individual items that make up a portion of gross income exempt.
Ark. 21-8-701	No: Individual items that make up a portion of gross income exempt.
Calif. Gov. Code Title 9, Chapter 7, Article 2, 87200- 87210	In some cases: Names of clients from whom filer’s proportionate share of income was >$10,000.
Colo.	No: Clients not covered.
Conn. Title 1 Chapter 10 Section 1-83	No: Clients not covered.
Del. Title 29, Part V Chapter 58 Subchapter II Section 5813	No: Client names specifically not required.
Fla. Title X Chapter 112.3144 112.3148 112.3149	In some cases: Sources paying >10% of the gross income to a business with which the filer is associated must be named if the amount comprises >10% of the filer’s gross income and is >$1,500 OR sources providing >10% of associated business’s income if that business has paid filer >$5,000. Also, if filer has represented a client before a state agency for payment, that client’s name must be disclosed.
Ga.	No: Clients not covered.
Hawaii 84-17	In some cases: Names of clients the legislator represented before a state agency for payment. But for income sources, individual sources that constitute a portion of gross income are exempt.
Idaho	State has no financial disclosure requirements.
Ill. 5ILCS420/ 4A-101	No, but: nature of clients’ business is required for those who paid filer >$5,000 for professional services.
Ind. IC 2-2.1-3-2	In some cases: Names of any clients represented before a state agency for a fee. Names of lobbyists who purchased over a certain dollar amount of goods from filer or filer’s business or partnership. See “Lobbyist Connections.”
Iowa	No: Clients not covered.
Kan. 46-229 46-239 46-248	Sort of. Names of clients or customers who paid a portion of fees to a business from which filer or spouse receive $2,000+ income. Client or customer is defined as a business or combination of businesses. See “State Agency Connections.”
Ky. KRS 6.787	No: Names of individual clients or customers specifically not required.
La.	No: Clients not covered.
Maine Title 1 Chapter 25 Subchapter 2 Section 1016-A	In some cases: If self-employed, names of sources that paid >$10% or $1,000 of the legislator’s gross income. If law, rule or professional code of ethics prohibits disclosure, reveal only the “principle type of economic activity” from which income is derived.
Md.	Yes, but only “if representing a person for compensation before a state or local government agency.” Representation of a client in a judicial or quasi-judicial proceeding before such agencies does not require disclosure of client’s name.
Mass.	No: Clients not covered.
Mich.	State has no financial disclosure requirements.
Minn.	No: Clients not covered.
Miss.	No: Clients not covered.
Mo. 105.483 105.485	No, but: Nature of sole proprietorships required, but not names of clients.
Mont.	No: Clients not covered.
Neb. 49-1493- 49-1497	No: Patrons, customers, patients and clients specifically exempt.
Nev. 281.571- 281.581	No: Individual clients, customers and patients are specifically exempt. If income is derived from them, filer can attribute that to “professional services,” or similar source.
N.H.	No, but: New Hampshire has unique requirements
N.J.	No: Clients not covered.
N.M. 10-16A-2 10-16A-3	No, but: law practices, consulting operations or similar businesses must describe the major area of specialization or income sources.
N.Y. Consolidated Laws Chapter 47 Article 4 Section 73a	No, but: Names of individual clients, customers and patients are specifically exempt. Lawyers, real estate brokers and professions licensed by the department of education must give a general description of the principal subject area of the matters he or she undertakes.
N.C. 120-89	No, but: a list of classifications of clients who are members of a class that charged $2,500+ for services rendered by filer or associated firm or partnership is required. Names of clients not required, but clients’ types of business are required, as is a description of the services rendered.
N.D.	No: Clients not covered.
Ohio 102.01	In some cases: Individual items that constitute a portion of gross income are exempt, unless a lobbyist is involved. Attorneys or persons licensed under 4732.12 must disclose their clients who are lobbyists and patients of persons certified under section 4731.14 must disclose the names of patients who are lobbyists unless disclosure would threaten the client, patient or recipient or services or if disclosure would reveal details of the subject matter for which services were sought, or if disclosure would reveal an otherwise privileged communication. See “Lobbyist Connections.”
Okla. Rule 257:15-1-1	In some cases: Names of clients represented before state agencies for a fee. But for income received from proprietorships or similar situations, names of patrons, customers, patients and clients are exempt. Filer may list as sources a business or corporation instead.
Ore. 244.050	In some cases: Disclose each person for whom the public official has performed services for a fee >$1,000, except for any disclosure otherwise prohibited by law or professional code of ethics. If client is a lobbyist, he or she may have to be disclosed under other parts of the law as well. See “Lobbyist Connections.”
Pa. PCS Title 65 Chapter 11	In some cases: Disclose the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more. However, filer does not have to divulge confidential information protected by statute or professional codes of ethics or common law privileges.
R.I. 36-14-1	No, but: If self-employed, list sources of occupational income by nature of occupation or profession.
S.C. Article 11 Section 8-13-1110	In some cases: Names would have to be disclosed if client is a lobbyist who is “associated with” the filer, or if the client is a lobbyist who purchased >$200 in goods from filer or associated business.
S.D.	No: Clients not covered.
Tenn. 8-50-502	No: Disclosures of client or customer names specifically exempt.
Texas Chapter 572	In some cases: Names of clients who are also lobbyists must be disclosed in some cases. For more information, see “Lobbyist Connections.” Names of clients who filer has represented before a state agency for a fee. In the general income category, though, self-employed filers disclose their income sources by occupation, rather than by name.
Utah Joint Rules 16.05	No: Clients not covered; left up to legislator to disclose if he believes dealings with any clients, as with other sources, constitute a conflict of interest.
Vt.	State has no financial disclosure requirements.
Va. 30-111	In some cases: Client names not required unless they are lobbyists. In that case, “disclosure of a lobbyist relationship shall not constitute a waiver of any attorney-client privilege.” See “Lobbyist connections.” A section of the form requires filers to disclose which of a list of dozens of professions he has received more than $1,000 for services rendered. He must also disclose what types of services were rendered and the amount category of income received. Client names also required if filer represented client before a state agency for a fee of >$1,000.
Wash.RCW 42.17.240-241; 42.17.370(10)	The names of business customers paying more than $7,500 to corporations, joint ventures, etc. in which an ownership interest of 10 percent or more is held by legislators are reportable. Names of business clients of law firms employing legislators are reportable if the $7,500 threshold is met, unless protected by privilege. Government agency client names are likewise reportable. Exemptions to reporting (‘modifications’) may be granted if statutory criteria are met.”
W.Va. 6B-2-6	No, but: Filers must disclose which from a list of dozens of professions he or she has done business with and received >20 % of gross income from. Filers must identify, by category every source of income > $1,000 during calendar year, but specifically exempts filers from disclosing individual sources or items of income that constitute the gross income of the filer.
Wis. Subchapter III 19.41	In some cases: Any individuals who contribute $1,000+ to filer’s income may be identified by the general nature of the contributor’s business, unless the contributor is a lobbyist, in which case the lobbyist’s name must be disclosed.
Wyo.	No: Clients not covered.

Notes:

Statutes referenced are the beginning of sections discussing financial disclosure.
This research list states’ disclosure requirements. It does not comprehensively list bans states may have on practices other states require to be disclosed. For example, one state may ban honoraria, while another requires legislators to report any they receive. So states with broad reporting requirements shouldn’t always be considered to have stricter laws.
Read numbers written “$5,000+” as “at least $5,000,” or “$5,000 or more.”
Generally, states exempt privileged information from income reporting requirements. In many cases, they exempt individual sources that constitute a part of gross income. When this exemption is present, it is not always noted in the above table.