Public comments are due this Thursday, Dec. 2, on the detailed guidelines the Office of Management and Budget has proposed for restricting lobbyists from serving on federal boards and commissions.

The OMB created the guidelines to comply with an executive order from President Obama last June; that order forbids federal agencies and departments from appointing or reappointing federally registered lobbyists to advisory committees, boards or commissions.

In a memo, the OMB describes in detail those instances in which formerly registered lobbyists could serve on federal advisory boards and other bodies:

"Any individual who previously served as a federally registered lobbyist may be appointed or re-appointed only if he or she has either filed a bona fide de-registration or has been de-listed by his or her employer as an active lobbyist reflecting the actual cessation of lobbying activities or if they have not appeared on a quarterly lobbying report for three consecutive quarters as a result of their actual cessation of lobbying activities," the OMB memo reads.

As many observers predicted, Obama's directive convinced many lobbyists to drop their registrations under the federal Lobbying Disclosure Act, or LDA.

The OMB memo clarifies that Obama's policy would not apply to lobbyists working only at the state or local levels -- nor to non-lobbyists working at organizations registered under the federal LDA to lobby. The memo also says there can be no waivers for lobbyists to serve on government advisory boards.  

The OMB memo on proposed guidance for appointment of lobbyists to federal boards and commission is here.