A national lobbying firm is still being paid $75,000 per quarter by a client, although the firm filed a lobbying report stating it had no contacts with either house of Congress or any federal agencies.

In some cases, organizations will pay lobbying firms a retainer to have an expert and lobbyist with exceptional contacts available for immediate use, whether they are needed or not during the year. In other cases, the expert may be offering advice on what others should do, or providing background on what the client needs to know. A former member of Congress may fit the bill.

The lobbying firm of Baker & Hostetler reported it was paid $75,000 in the third quarter of 2013 by the Financial Industry Regulatory Authority (FINRA) to handle the issue of the regulation of the securities industry and markets. Their lobbyist was former Rep.  Michael Oxley , R-Ohio. Oxley was chairman of the House Committee on Financial Services from 2001-2007, and was the co-author of the Sarbanes-Oxley Act of 2002 that created a new accounting oversight board for publicly traded companies. Peggy Peterson was also a listed lobbyist.

The 2013 third quarter lobbying report indicated that no houses of Congress or federal agencies were contacted during the quarter. Their reports for the fourth quarter of 2012 and the first quarter of 2013 also indicated they were paid $75,000 per quarter and had no contacts with the houses of Congress or federal agencies.