According to Jeff Birnbaum at the Washington Post, the new lobbying disclosure forms, intended to shine a light on lobbyist contributions and gift giving, aren’t just riddled with loop holes, but are simply missing sections to fill out:

Jan W. Baran of Wiley Rein notes that the new law asks lobbyists to report any contributions they make to groups established, financed, maintained or controlled by members of Congress or their staff. Such groups include charities and schools named for sitting lawmakers. But he said there is no specific place on the form to list such expenditures.

Corporations and trade associations have to use the form to certify that they understand, and have complied with, tough new gift-giving restrictions that apply to members of Congress. But Kenneth A. Gross of Skadden, Arps, Slate, Meagher & Flom said there is no place on the form where one person from such organizations can sign and take responsibility for the certification.

This is evident if you take a look at the tutorial for the form provided by the Clerk of the House and the Secretary of the Senate. There are only a few ways to categorize contributions on the electronic form and there could be a lot of confusion when a contribution made by a lobbyist does not specifically fall under the name of the types of contribution provided.