Financial Disclosures: Client Identification

2/23/2020

Public office may be either a full-time job or only one of several sources of income. Outside income sources may include providing professional services to clients. Personal financial disclosure requirements often ask for information pertaining to outside employment and may also mandate the identification of clients.

Client identification requirements vary widely. Some states do not ask for any disclosures, including client names, absent a potential conflict of interest. Several others ask for only numbers of clients by industry category.

On the other end of the spectrum, jurisdictions may require all clients to be named unless otherwise legally privileged. A legislator who works as a health care provider, for example, may be exempt from providing patent names due to privacy laws, but only if naming the patient would reveal privileged information.

This chart answers the question for each state and territory’s laws, “Are individual client names required to be disclosed?” Worth noting, however, is that some states may authorize the promulgation of non-statutory rules regarding client identification, such as those provided by ethics commissions. This table only addresses statutory requirements. Additionally, conflict of interest laws, particularly those regarding representation of others before the government, may require additional disclosures not reflected in general financial disclosure requirements.

If statutes do not specify if clients need be identified, general income disclosure requirements may apply to individual clients.

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. All content is up to date through 02/23/2020.

Client Names in Financial Disclosures
State Are individual client names required to be disclosed?
Alabama

If providing a qualifying category of business service, filers must include a) number of clients by category, and b) income by category. Ala. Code § 36-25-14.

 

Qualifying categories of business services: legal, accounting, medical or health related, real estate, banking, insurance, educational, farming, engineering, architectural management, or other professional services or consultations. Ala. Code § 36-25-14.

 

Client categories are: Electric utilities, gas utilities, telephone utilities, water utilities, cable television companies, intrastate transportation companies, pipeline companies, oil or gas exploration companies, or both, oil and gas retail companies, banks, savings and loan associations, loan or finance companies, or both, manufacturing firms, mining companies, life insurance companies, casualty insurance companies, other insurance companies, retail companies, beer, wine or liquor companies or distributors, or combination thereof, trade associations, professional associations, governmental associations, associations of public employees or public officials, counties, and any other businesses or associations that the commission may deem appropriate. Ala. Code § 36-25-14.

 

Income categories are: less than $1,000; $1,000-$10,000; $10,000-$50,000; $50,000-$150,000; $150,000-$250,000; $250,000 or more. Ala. Code § 36-25-14.

Alaska

If income over $1,000 earned for personal services, filers must describe the names and addresses of the source and recipient, amount, how it was earned, dates and number of hours worked, and nature of service performed. Alaska Stat. Ann. § 24.60.200.

Arizona If compensation source for a controlled or dependent business is a business, shall disclose a description of business activities engaged in by the income source. For a controlled business, disclosure requirement triggered if single source of compensation is more than $10,000 or 25% gross income. For a dependent business, disclosure requirements triggered if single source of compensation is more than $10,000 or 50% gross income. Ariz. Rev. Stat. Ann. § 18-444.
Arkansas For filer and spouse: If an officer, director, stockholder owning more than 10% of stock of the company, and the owner, trustee, or partner shall sell any goods or services valued over $1,000 to the governmental body in which the public servant serves or is employed, then shall identify the governmental body to which they were sold, along with other information about the sale. Ark. Code Ann. § 21-8-701.
California Filers must disclose the name of every person from whom a business received payments if the filer’s share of gross receipts was $10,000 or more. Cal. Gov't Code § 87207.
Colorado  Shall include any source or sources of income for the filer, spouse, and minor children residing with the filer. Filers must also identify any entity lobbied on behalf of for compensation. Colo. Rev. Stat. Ann. § 24-6-202.
Connecticut Disclose all sources of income, including the name of each employer, if over $1,000. Conn. Gen. Stat. Ann. § 1-83.
Delaware No. Del. Code Ann. tit. 29, § 5813.
District of Columbia Required disclosures include the identity of any client for whom the official performed a service in connection with the official's outside income if the client has a contract with the government of the District of Columbia or the client stands to gain a direct financial benefit from legislation that was pending before the Council during the calendar year. The report shall include a narrative description of the nature of the service performed in connection with the official's outside income. D.C. Code Ann. § 1-1162.24.
Florida Sources of income if over 5% of gross income received, sources to a business if over 10% of gross income of a business if filer has a material interest where filer received over 10% of gross income and is over $1,500. Shall disclose the names of clients represented for a fee or commission, except for appearances in ministerial matters, before agencies at his or her level of government. Fla. Stat. Ann. § 112.3145. Filers must also disclose sources of income exceeding $1000. Fla. Stat. Ann. § 112.3144.
Georgia For each transaction or transactions aggregating over $9,000 or more in a year, whether for the candidate or on behalf of any business, or if a business in which the candidate or a family member thereof has a substantial financial interest or is an officer of such business that a) has transacted with Georgia, or any political subdivision or agency thereof, or b) such business received any income from any person who was at the time represented by a lobbyist: MUST disclose an itemized list of the transactions, including the date, dollar amount of, and parties to each transaction. With respect to privileged transactions, only the total amount shall be required to be reported, and names, dates, amounts of individual transactions, and other identifying data may be omitted. Privileged transactions include those between an attorney and client, psychiatrist and patient, between physician and patient, or any other similar privileged and confidential transaction. Ga. Code Ann., § 21-5-50.
Guam

Filers must list all sources of income on financial disclosure statements, including names and addresses of all individual sources of income. Filers must also provide itemized income or benefits derived from distribution of the official or candidate's share in any partnership or professional group if valued at over $1,000 except where privileged by law. 4 G.C.A. § 13104.

Hawaii Source of all income of $1,000 or more for services rendered; provided, individual items of compensation that constitute a portion of gross income of the business or profession from which income is derived need not be disclosed. The names of clients personally represented before state agencies, except in ministerial matters, for a fee or compensation must be disclosed. Haw. Rev. Stat. Ann. § 84-17.
Idaho Not specified by statute. See generally: Idaho Code Ann. § 74-101 et seq.
Illinois Filers must disclose the nature of professional services and the nature of the entity to which they were rendered if fees exceeding $5,000. 5 Ill. Comp. Stat. Ann. 420/4A-102.
Indiana Filers must disclose the name of any person from which the filer or the filer's spouse derived 25% or more of the filer's or the filer's spouse's income. Ind. Code Ann. § 2-2.2-2-3.
Iowa List any sources of income, by category, if over $1,000. Categories include: securities, instruments of financial institutions, trusts, real estate, retirement systems, other categories specified in income tax regulations. Iowa Code Ann. § 68B.35.
Kansas Filers must disclose client if: receives compensation which is a portion or percentage of a fee paid to a business, portion received is $2,000 or more. Kan. Stat. Ann. § 46-229.
Kentucky Disclosures include the names of any of the filer's clients who are legislative agents or employers. Ky. Rev. Stat. Ann. § 6.787.
Louisiana Disclosures include the name, address, type and amount of each income source received by the filer or spouse or any business in which an ownership interest exceeds 10% if received from services performed related to a gaming interest or the state or any political subdivision. Filers must also disclose the name and address of any part or full-time employer, and a description of any other income over $1,000. La. Stat. Ann. § 42:1124.2.
Maine Each source of income identified by name, address and principal type of economic or business activity. If disclosure is prohibited by statute, rule or an established code of professional ethics, it is sufficient to specify the principal type of economic or business activity from which the income is derived. Me. Rev. Stat. tit. 1, § 1016-G.
Maryland Not specified in the statutory disclosure requirements, although the statement may include a schedule listing of additional interests or information that the individual chooses to disclose. MD Code, General Provisions § 5-607.
Massachusetts Not specified by statute. Mass. Gen. Laws Ann. ch. 268B, § 5.
Michigan Not specified by statute. See generally: Mich. Comp. Laws Ann. § 15.1 et seq.
Minnesota Not specified by statute. Mich. Comp. Laws Ann. § 15.302.
Mississippi Filers must disclose any representation for any person or business before any authority of state or local government, excluding the courts, excluding ministerial matters. Miss. Code. Ann. § 25-4-27.
Missouri Not specified by statute. Mo. Ann. Stat. § 105.485.
Montana Not specified by statute. Mont. Code Ann. § 2-2-106.
Nebraska Identification of individual clients explicitly not required to be disclosed. Neb. Rev. Stat. Ann. § 49-1496.
Nevada No listing of individual clients, customers or patients is required, but, a general source such as “professional services” must be disclosed. Nev. Rev. Stat. Ann. § 281.571.
New Hampshire Filers must disclose the name, address, and type of any business, profession, or other organization in which the reporting individual or household member thereof served in any professional or advisory capacity and from which income over $10,000 was received during the preceding calendar year. N.H. Rev. Stat. Ann. § 14-B:8.
New Jersey Not specified by statute. See generally: N.J.S.A. 52:13D-12 et seq.
New Mexico Filers must identify sources of gross income over $5,000 by general category, such as: law practice, consulting operation, finance and banking, farming and ranching, medicine and health care, or insurance. The names and addresses of all clients if represented for lobbying purposes during the current reporting or previous reporting years. N.M. Stat. Ann. § 10-16A-3.
New York Filers must disclose if filer received $10,000 or more from an employer; client or customer paid the reporting individual $5,000 or more for services, and; client was billed knowing that the filer would receive $5,000 or more. N.Y. Pub. Off. Law § 73-a.
North Carolina Name of each source of income over $5,000 by business or industry type. N.C. Gen. Stat. Ann. § 163A-189.
North Dakota Not specified by statute. N.D. Cent. Code Ann. § 16.1-09-03.
Ohio Identification of every income source. Applies to attorneys, physicians, and others who engage in a profession generally privileged, unless identification would violate confidentiality. Ohio Rev. Code Ann. § 102.02.
Oklahoma Not specified by statute. Ethics Commission Rule 3.16 specifies required disclosures and does not appear to require client identification. (Current as of 02/20/2020).
Oregon The names, principal addresses and brief descriptions of the sources of income that produce 10% or more of total annual household income, or $1,000 or more if from an individual or business with an interest in business with the agency over which the public official exercises any authority. Or. Rev. Stat. Ann. § 244.060.
Pennsylvania Name and address of any source of income of $1,300 or more, excluding confidential information protected by statute or professional codes of ethics or common law privileges. 65 Pa.C.S.A. § 1105.
Puerto Rico Not specified by statute. 3 L.P.R.A. § 1858c.
Rhode Island Not specified by statute. RI ST § 36-14-17.
South Carolina If a public official or employee receives compensation from an individual or business which contracts with the governmental entity with which the public official or employee serves or is employed, must report the name and address of that individual or business and the amount of compensation received. S.C. Code Ann. § 8-13-1120. 
South Dakota Not specified by statute. SDCL § 12-25-31.
Tennessee In general terms by areas of the client's interest, entities to which professional services, such as those of an attorney, accountant, or architect, are furnished. Tenn. Code Ann. § 8-50-502.
Texas All sources of occupational income, identified by employer, or if self-employed, by the nature of the occupation, including identification of a person or other organization from which a fee was received as a retainer for a claim on future services in case of need. Tex. Gov't Code Ann. § 572.023.
Utah Name of each entity from which $5,000 or more was received. Applies only to the entity or practice through which the officeholder provides goods or services, not individual customers or clients. U.C.A. 1953 § 20A-11-1604.
Vermont Each candidate for State office, State Senator, or State Representative shall file a disclosure form prepared by the State Ethics Commission containing, among other requirements, each source, but not amount, of personal income of the candidate or a domestic partner, and of the candidate that totals more than $5,000, including sources from employment, but if self-employed, a description of the nature of the self-employment without needing to disclose any individual clients. 17 V.S.A. § 2414.
Virginia Not specified by statute. VA Code Ann. § 30-110.
Virgin Islands Filers must list the source of any income for services rendered exceeding $5,000, which may include individual clients under some circumstances. 3 V.I.C. § 1105.
Washington Not specified by statute. Wash. Rev. Code Ann. § 42.17A.710.
West Virginia The identification, by category, of every source of income over $1,000, including distributions from retirement accounts received during the preceding calendar year, in his or her own name or by any other person for his or her use or benefit, by the person filing the statement, or that person's spouse, and a brief description of the nature of the income producing activities for which the income was received. This subdivision does not require a person filing the statement who derives income from a business, profession or occupation, or who's spouse derives income from a business, profession or occupation, to disclose the individual sources and items of income that constitute the gross income of that business, profession or occupation. W. Va. Code Ann. § 6B-2-7.
Wisconsin The identity of each payer if received $1,000 or more, unless the filer identifies the general nature of the business, then no identification need be made of a decedent's estate or an individual, unless the individual is a lobbyist. Wis. Stat. Ann. § 19.44.
Wyoming Filers must provide a list generally describing the sources of, but not the amount of, the member's income. Wyo. Stat. Ann. § 9-13-108.