At least 23 reported contributors to the White House ballroom should have disclosed those donations as part of their regular lobbying disclosure filings, according to a CREW analysis of the project and lobbying law. But only one company that is known to have provided funds for the ballroom, Vantive Healthcare, actually disclosed their donation when they filed their 2025 year-end lobbying contribution report last month. 

Other companies, including Lockheed Martin, Palantir and T-Mobile, that are active registrants under the Lobbying Disclosure Act and have been reported as ballroom donors did not disclose the money they provided for the project. According to CREW’s analysis, the ballroom donations qualify as contributions to an entity designated by a covered executive branch official that should be disclosed.

As the White House’s East Wing was being demolished last fall to make way for the construction of a gigantic new White House ballroom, President Donald Trump declared, “we’ve raised I think $350 million, all donor money and money that we put up, we’ve raised.” The White House has released a list of 37 donors it says have contributed funds for the project, whose cost estimates have since ballooned to $400 million, but they have not disclosed the specific amounts each donor has committed and have acknowledged to reporters that they are letting donors remain anonymous if they desire. 

The incomplete disclosure of who is funding Trump’s prized project only underscores the “tremendous ethics implications” of his effort to fund the ballroom with private donations from individuals and companies that have significant interests before the federal government and whose financial support could influence the administration’s decisionmaking. Although the contributions are technically being given to the Trust for the National Mall, a nonprofit charitable organization, which is not required to disclose its donors, the project is clearly effectively being directed by Trump and his White House.

As a result of Trump’s intimate involvement with the project and its funding, however, there appears to be a mechanism in federal lobbying law that should lead at least some of the donors to publicly disclose their contributions to the project, including the specific amounts they provided. In the Honest Leadership and Open Government Act of 2007 (HLOGA), the Lobbying Disclosure Act (LDA) was amended to require lobbyists and organizations employing lobbyists to file semi-annual reports disclosing various types of political contributions. 

Under section 203 of the HLOGA, covered persons or organizations are required to file reports with Congress disclosing, among other things, “the date, recipient, and amount of funds contributed or disbursed during the semiannual period by the person or organization or a political committee established or controlled by the person or organization” to “an entity established, financed, maintained, or controlled by a covered legislative branch official or covered executive branch official, or an entity designated by such official.”

There is good reason to conclude that contributions to the Trust for the National Mall for the White House ballroom project were given to an “entity designated by” Trump and thus are captured by this provision. If they are, at least the 19 contributors disclosed by the White House who are active registrants under the LDA should publicly report their donations as contributions to an entity designated by a covered executive branch official. Four additional  companies whose contributions have been revealed by news outlets–Blackrock, Nvidia, Parsons Corporation and Vantive–are also active lobbying disclosure registrants. 

Although punishment is rare and typically involves chronic offenders, failure to meet the disclosure requirements of the Lobbying Disclosure Act can come with consequences. In addition to providing guidance on the registration and reporting requirements, the Secretary of the Senate and the Clerk of the House are tasked with notifying lobbyists and lobbying firms of their possible noncompliance with the law. If a registrant fails to provide an appropriate response within 60 days of a written notification, the Secretary of the Senate and the Clerk of the House can notify the United States Attorney for the District of Columbia of the potential noncompliance, who can pursue both civil and criminal enforcement actions. 

Why ballroom donations are contributions to an “entity designated” by Trump

There is no doubt that the president is a covered executive branch official. The LDA explicitly includes the president in the definition of a covered executive branch official. In terms of what it means to be an “entity designated” by a covered official, neither the LDA nor the HLOGA provide a specific definition, but the Secretary of the Senate and the Clerk of the House of Representatives have provided some guidance:

A non-voting board member (e.g. honorary or ex-officio) does not control an organization for these purposes. For purposes of the LDA, the term “designated,” for instance, includes a covered legislative branch official’s or covered executive branch official’s directing a charitable contribution in lieu of an honoraria pursuant to House, Senate, or executive branch Ethics rules. It also includes a payment that is directed to an entity by a covered official who is also on the board of the entity. In contrast, a contribution following a mere statement of support or solicitation does not necessarily constitute a reportable event under (2 U.S.C. § 1604(d)), without some further role by a covered official.

The contributions to the Trust for the National Mall for the ballroom project do not appear analogous to “a charitable contribution directed to an entity in lieu of an honoraria” pursuant to ethics rules and Trump is not a member of the nonprofit’s board, so those scenarios described in the guidance do not readily apply to the ballroom contributions. Trump and his White House instead appear to have solicited contributions for the Trust for the ballroom project, a scenario that the guidance indicates could require disclosure depending on the circumstances. 

While the guidance states that “a contribution following a mere statement of support or solicitation does not necessarily constitute a reportable event,” that statement is limited by the use of the word “mere,” which is commonly defined to mean “nothing more than.” The guidance further confirms that the solicitation of contributions for third party entities can potentially trigger disclosure by stating that “some further role by a covered official” could make such a contribution reportable. 

The guidance does not provide an additional description of what would constitute a “further role” and none of the examples it explicates are relevant to such an analysis. But the facts around the ballroom contributions and project make clear that Trump has such extensive involvement that the situation is easily more than just his soliciting contributions for an entity he supports. As a result, Trump’s fundraising for a project he is centrally engaged in likely makes the contributions reportable. 

Trump began discussing his desire to build the ballroom within weeks of his second inauguration and repeatedly cast the project as something he was going to personally pursue. At one point, he even described the ballroom as a “gift” he would give the White House. 

Members of his administration have also emphasized Trump’s central role in the ballroom project. The Justice Department described how Trump was “intimately engaged in the implementation phase, including participation in discussions regarding design and footprint and personally selecting the architect” while a White House official even referred to Trump as the “principal” on the ballroom project after reports surfaced of disagreements between Trump and the initial architect he selected. 

Trump has also described himself as being involved in awarding contracts for the project, telling a room full of donors that he negotiated the contract for the excavation down to $2 million, with The New York Times further reporting that Trump has personally selected contractors. 

Trump also indicated that he was personally involved in soliciting contributions, recounting a conversation where someone said to him, “Sir, would $25 million be appropriate?” and he said he replied, “I’ll take it.” Trump has reportedly held meetings about raising money for the project and engaged business executives in personal conversations about “chipping in.” 

In addition to soliciting contributions for the ballroom, Trump designated that funds from a legal settlement should be directed towards the project via the Trust for the National Mall. In late September 2025, when Trump settled his lawsuit against YouTube, he agreed to accept $22 million from YouTube’s parent company, Alphabet, “to be contributed, on his behalf, to the Trust for the National Mall, a 501(c)(3) tax-exempt entity dedicated to restoring, preserving, and elevating the National Mall, to support the construction of the White House State Ballroom.”

Contributions also appear to have been solicited with the suggestion that the completed ballroom will be named after Trump. According to CBS News, potential donors have received a pledge agreement for “The Donald J. Trump Ballroom at the White House.” Although Trump subsequently denied plans to name it after himself, ABC News reported that the ballroom is referred to internally by some Trump administration officials as “The President Donald J. Trump Ballroom” and noted that the list of donors the White House distributed also used his name to describe the ballroom. 

Donors also appear to be making contributions with the goal of earning goodwill from Trump, with CBS News reporting that officials at some companies were giving money in order to show support for Trump while supporting a “nonpartisan cause.” Among the known ballroom donors are federal contractors, companies facing adverse government action and individual members of Trump’s administration or their families.  

Finally, although the Trust for the National Mall is accepting donations, it is not responsible for the actual ballroom project. A spokesperson for the charity “told CBS News the White House and National Park Service are responsible for construction and design.” NBC News reported that Trust officials have stressed that they’re only managing the donations. A board member of the Trust told NBC News that the organization was “the partner of the National Park Service” on the project, but the Washington Post reported that the National Park Service “has been shut out of the most important planning decisions,” according to a commissioner on the National Capital Planning Commission who said “it’s all being managed by a single person at the highest level.”

In sum, the available evidence indicates that contributions to the Trust for the National Mall to fund the new White House ballroom meet the current disclosure requirements under section 203 and are obligated to be disclosed by all registrants who donate. Notably, although under different circumstances, multiple companies, including two–Facebook (Meta) and Comcast–that the White House disclosed as ballroom donors, have previously reported donations to the Trust for the National Mall in their lobbying contribution reports. So far, only Vantive has disclosed its contribution to the Trust for the National Mall in relation to the ballroom project.

Even if there is disagreement about whether the ballroom donations qualify under section 203, the contributions, which have sparked intense public interest and raise serious corruption concerns, clearly meet the spirit of the disclosure rules and the donors who otherwise file lobbying contribution reports should act as though they are required to be disclosed. In such a case, Congress should update the rules and guidance to make crystal clear that these types of contributions should be reported publicly.

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