January 14, 2025 •
Ask the Experts – When and Where do Investment Advisors Have to Register as Lobbyists in California?

Flag of California
Q: I am an investment advisor registered as a lobbyist in the state of California because I qualified as a placement agent on the state level. I also want to solicit municipal public investment and retirement systems such as San Francisco City and County Employees’ Retirement System and San Jose Federated City Employees’ Retirement System. Do I need to do anything else, or does my state registration cover me?
A: You need to consider the local laws. Your California state registration does not cover your activities on the local level.
Not all California municipalities have lobbying laws. The local jurisdictions that do have lobbying laws also do not always require registration for investment advisor activity. You must look closely at each jurisdiction’s laws where you are active to determine if registration or reporting is needed.
In San Francisco, local lobbyist registration requirements cover placement agents lobbying public investment and retirement systems (including the San Francisco City and County Employees’ Retirement System). Monthly lobbyist reports are also required after registration.
San Jose also has local lobbying laws that apply to placement agents. Registration is due annually and activity reports must be filed weekly for each calendar week a lobbyist has engaged in lobbying activity.
It is a good idea to always check the applicable laws on our website prior to any government outreach.
More information can be found in the Lobbying Compliance section of the State and Federal Communications website.
State and Federal Communications, Inc. provides research and consulting services for government relations professionals on lobbying laws, procurement lobbying laws, political contribution laws in the United States and Canada. Learn more by visiting stateandfed.com.