When Investor Relations Become Procurement Lobbying

Employees in the investor relations departments of hedge fund managers and private equity firms typically do not consider themselves "lobbyists." But state and local regulators sometimes have a different view. This article explains the types of investor relations activities that could trigger lobbying requirements; summarizes the state lobbying registration and reporting requirements that may apply to investment firms; and describes the potential penalties for violations of the rules. It also highlights elements of investment firms' compliance programs that can help ensure they remain on the right side of these laws and includes a list of practical questions CCOs can consider.