Employees in the investor relations departments of fund managers typically do not consider themselves “lobbyists.” State and local regulators sometimes have a different view, however, in the event that firms attempt to secure investments from public pension funds, university endowments and other government funds. In those scenarios, fund managers can incur various types of penalties if they fail to adhere to each applicable state’s registration and reporting requirements for lobbyists. A guest article by Covington lawyers Zachary G. Parks, Derek Lawlor and Kimberly Railey 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. See our two-part series on clashes between investor relations and compliance: “Contexts and Reasons for the Strained Relationship and Potential Ramifications” (Mar. 16, 2021); and “Practical Tips for Building a Strong Partnership Between the Teams” (Mar. 23, 2021).