Do lobbyists incur separate electronic filing obligations?
No. Lobbyists file their required Form 615 as an attachment to either the report of lobbyist employer (Form 635) or lobbying firm (Form 625) (See Gov. Code 86114 (a) (4) and Gov. Code 86116 (e)). As a result, if a lobbyist employer or lobbying firm is required to file electronically, it also must file any attached Form 615’s electronically.