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The group was formed in early September and did not file a disclosure report in October.
It said they evaded a federal law that requires anyone moving more than $10,000 to file a disclosure form.
Failure to file a disclosure or lying on a filed disclosure can be evidence of tax fraud, and the penalties are severe.
If they are deemed to be lobbying, the companies would be required to file a disclosure form with the state, or risk being fined.
Citigroup Inc. said through a spokeswoman that it carefully followed the letter of the law when it planned its event, and that it would file a disclosure form with the lobbying commission.
At its core, Whitehouse's bill would require any "covered organization" which spends $10,000 or more on a "campaign-related disbursement" to file a disclosure report with the Federal Election Commission within 24 hours of the expenditure, and to file a new report for each additional $10,000 or more that is spent.
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Microsoft, based in Redmond, Wash., will not disclose the number of shares Mr. Ballmer is selling until he files a disclosure with the Securities and Exchange Commission, said Rachel Wayne, a spokeswoman.
The firm filed a disclosure form with Congress saying it stopped the lobbying on July 11, but no one at the firm would return repeated phone calls seeking comment.
As of mid-October, when her campaign last filed a disclosure statement with the Federal Election Commission, the senator had about $14 million on hand.
Portfolio wrote: He suggested to Mr. Hohn that TCI was happy to have some funds, such as 3G "front run" its position in stock, and pressed Hohn on whether TCI could have filed a disclosure with the Securities and Exchange Commission showing it had an "economic" position through swaps contracts with Deutsche and Citigroup, but also "disclaim any beneficial ownership of shares".
"I've published throughout my career in [a leading] astrophysics journal and I don't think I've ever filed a disclosure statement.
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