As difficult as it was for Congress to enact lobbying and ethics changes last year, that may have been the easy part compared with actually carrying out and enforcing the new rules.

Lawmakers, congressional aides and regulators are scrambling to address problems and questions swirling around the Honest Leadership and Open Government Act of 2007.

The law banned gifts from lobbyists and greatly expanded their reporting requirements, but that's turning out to be even tougher to implement than expected. Regulations are overdue, disclosure forms and guidelines have come under fire, and a key congressional ethics office has failed to open on time.

"It was designed to fail. And I think we're seeing that happen at this point." --Craig Holman of Public Citizen on the planned Office of Congressional Ethics

The Federal Election Commission is already well past its statutory deadline for issuing regulations on the new law's bundling disclosure rules, which require lobbyists to report the campaign donations they round up on behalf of lawmakers. Last year, the FEC drafted bundling regulations, but the process stalled abruptly due to a commission shutdown in January. (A Senate dispute over FEC vacancies had left the commission without a quorum.)

Now finally up and running with five newly confirmed commissioners, the FEC held its first public meeting on July 10. But the commission faces an intimidating backlog of election inquiries and enforcement cases, and it must turn around immediately and act on the overdue bundling regulations. A public hearing on the bundling rules is expected shortly. The commission also faces pressure to act quickly on unfinished regulations to enforce new candidate travel restrictions.

There's also been a hurried push on Capitol Hill to fix problematic disclosure reporting forms and guidelines, following complaints from lobbyists and their lawyers. Lobbyists must file their first reports under the new law by July 30, but disclosure forms put out by the secretary of the Senate and the clerk of the House raised numerous questions.

Lawyers representing labor unions also publicly challenged certain guidelines that the clerk and the secretary had put out interpreting the law. The guidelines included overly broad examples of when lobbyists must report donations to organizations controlled by lawmakers, and events that "honor or recognize" a lawmaker or other official covered by the law, these critics said.

The guidelines "significantly misinterpret" the Honest Leadership and Open Government Act, wrote lawyers representing the AFL-CIO and other unions in a July 8 letter to the House clerk and the Senate secretary. Under the guidelines, even a generic legislative conference where a lawmaker made a speech could be interpreted as an event "honoring" that official, said Laurence E. Gold, a lawyer representing labor and other groups.

The guidelines as issued would "chill interactions with government to no end," Gold said in an interview. He added that the resulting overly exhaustive reports would become fodder for "demagoguery and unfair attack on both the organizations and the officials who want to participate in this event."

These and other complaints prompted House and Senate leaders to direct the secretary of the Senate and the clerk of the House to rewrite the guidelines.

But House leaders have yet to take action on a third piece of unfinished business from the lobbying and ethics overhaul: Opening a new Office of Congressional Ethics to beef up investigations and enforcement in the House. Following the recommendations of a task force headed by Rep. Michael Capuano, D-Mass., House members voted to set up the new office four months ago.

The idea was to improve the ethics process by bringing in a team of outside experts appointed by House leaders on both sides the aisle. But House leaders have yet to follow through on those appointments. Ethics enforcement has never been a priority for Congress, of course. And reform advocates had low expectations for the new ethics office to begin with. Still, the absence of strong enforcement is one more hole in the new lobbying and ethics regime.

"It was designed to fail," said Craig Holman, legislative representative for Public Citizen's Congress Watch, of the ethics office plan. "And I think we're seeing that happen at this point." The House's failure to follow through on ethics changes is an issue that "resonates with voters," he added.

Even if these problems are eventually resolved, Congress still won't be done with lobbying and ethics questions. Holman and his pro-reform allies are gearing up to pressure lawmakers to revisit the most glaring loopholes in last year's law. These include ethics rules that allow lobbyists to host parties at the national political conventions to honor groups of lawmakers -- despite a ban on fetes celebrating an individual member of Congress. Reform advocates also will push for tighter revolving-door rules, including better disclosure requirements for lawmakers engaged in private-sector job negotiations.

"Passing the law is only half the battle," Holman noted. "Afterwards you've got to monitor and pursue effective implementation of the law, as well as enforcement of the law." This is turning out to be particularly true for last year's lobbying and ethics package.