So why file?

Lummis, despite retiring from the House of Representatives in 2016, has maintained an active political action committee since leaving Congress, using her remaining campaign cash to donate to other candidate committees and political groups, as well as assorted nonprofit organizations.

However, when a committee spends or raises $5,000 in an election cycle, candidates have to update their filings. In this case, Cubin explained, operations from her campaign committee in the first quarter exceeded that $5,000 threshold, requiring her to submit a statement of organization with the FEC.

Lummis always could have converted the campaign committee into another type of political action committee or otherwise shut it down, Cubin said. But — with Lummis seriously weighing a Senate bid and with numerous administrative headaches facing her if she did — that was never seriously considered as an option.

“If we were to wind it down or turn it into a multi-candidate committee, we could,” Cubin said. “But there were a thousand reasons why we didn’t want to. So that’s why we did that.”

Is she running, though?