Clerk of the House of Representatives
Legislative Resource Center
135 Cannon Building
Washington, DC 20515
http://lobbyingdisclosure.house.gov 		Secretary of the Senate
Office of Public Records
232 Hart Building
Washington, DC 20510
http://www.senate.gov/lobby
LOBBYING REPORT

Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page

1. Registrant Name Organization/Lobbying Firm Self Employed Individual
Vanguard Group

2. Address

Address1
P.O. BOX 2600
 Address2
​
City
VALLEY FORGE
 State
PA
 Zip Code
19482
 Country
USA

3. Principal place of business (if different than line 2)

City
​
State
​
Zip Code
​
Country
​
4a. Contact Name b. Telephone Number c. E-mail
​Ms.
​Carolyn Downs
​2028241281
​carolyn_downs@vanguard.com
5. Senate ID#
​291058-12
7. Client Name Self Check if client is a state or local government or instrumentality
​Vanguard Group
6. House ID#
​371950000
TYPE OF REPORT 8. Year
​2025
 Q1 (1/1 - 3/31) Q2 (4/1 - 6/30) Q3 (7/1 - 9/30) Q4 (10/1 - 12/31)

9. Check if this filing amends a previously filed version of this report

10. Check if this is a Termination Report Termination Date
​
11. No Lobbying Issue Activity
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13
12. Lobbying 13. Organizations
INCOME relating to lobbying activities for this reporting period was: EXPENSE relating to lobbying activities for this reporting period were:
Less than $5,000
Less than $5,000
$5,000 or more $
​
$5,000 or more $
​650,000.00
Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options.
Method A. Reporting amounts using LDA definitions only

Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code

Method C. Reporting amounts under section 162(e) of the Internal Revenue Code

Signature
Digitally Signed By: Carolyn Downs
 Date
1/20/2026 4:23:35 PM

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code FIN

16. Specific lobbying issues

Issues related to ETF regulation
Issues related to municipal bonds and the structure of the municipal securities market
Issues related to equity market structure matters
Issues related to fund disclosure and investor experience, including providing for electronic delivery of fund information, and the Improving Disclosure for Investors Act (H.R. 2441, S. 1877)
Issues related to corporate governance, including proxy process, and the INDEX Act (S.1670)
Issues related to fixed income funds
Issues related to index funds and index fund regulation
Issues related to access to investment opportunities
Issues related to allowing collective investment trusts in 403(b) plans, including the Retirement Fairness for Charities and Educational Institutions Act (H.R. 1013, S. 424)
Issues related to products and markets, including Foreign Investment Guardrails to Help Thwart China Act (H.R. 2246, S.1055), and the National Defense Authorization Act (S.1071)
Issues related to systemic risk regulation and non-bank financial intermediation including the FSOC Improvement Act (H.R.3682)
Issues related to the INVEST Act (H.R.3383)

17. House(s) of Congress and Federal agencies Check if None

U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Treasury - Dept of, Securities & Exchange Commission (SEC), Federal Energy Regulatory Commission (FERC), Natl Economic Council (NEC)

18. Name of each individual who acted as a lobbyist in this issue area

First Name Last Name Suffix Covered Official Position (if applicable) New
Ben
Barasky
​
​
Marliss
McManus
​
​

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code RET

16. Specific lobbying issues

Issues related to employee benefit plan administration, and investments in IRAs, including default investments and child savings accounts
Issues related to allowing collective investment trusts in 403(b) plans, including the Retirement Fairness for Charities and Educational Institutions Act (H.R. 1013, S. 424)
Issues related to access to investment opportunities
Issues related to considerations for plan fiduciaries
Issues related to automatic portability
Issues related to corporate governance, including proxy process
Issues related to the INVEST Act (H.R.3383)

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Labor - Dept of (DOL)

18. Name of each individual who acted as a lobbyist in this issue area

First Name Last Name Suffix Covered Official Position (if applicable) New
Ben
Barasky
​
​
Marliss
McManus
​
​

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code TAX

16. Specific lobbying issues

General tax issues related to mutual funds and ETFs, including the GROWTH Act (H.R. 2089), and the One Big Beautiful Bill Act (H.R. 1)
Issues related to municipal bonds and the structure of the municipal securities market
Issues related to retirement savings tax incentives and Trump Accounts

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Treasury - Dept of

18. Name of each individual who acted as a lobbyist in this issue area

First Name Last Name Suffix Covered Official Position (if applicable) New
Ben
Barasky
​
​
Marliss
McManus
​
​

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

Address
​
City
​
State
​
Zip Code
​
Country
​

21. Client new principal place of business (if different than line 20)

City
​
State
​
Zip Code
​
Country
​

22. New General description of client’s business or activities

​

LOBBYIST UPDATE

23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client

First Name
Last Name
Suffix
First Name
Last Name
Suffix
1
​
​
​
3
​
​
​
2
​
​
​
4
​
​
​

ISSUE UPDATE

24. General lobbying issue that no longer pertains

​
​
​
​
​
​
​
​
​

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

Name Address Principal Place of Business
(city and state or country)
Street Address
City State/Province Zip Country
City
State Country

26. Name of each previously reported organization that is no longer affiliated with the registrant or client

1 2 3

FOREIGN ENTITIES

27. Add the following foreign entities:

Name Address Principal place of business
(city and state or country) 		Amount of contribution for lobbying activities Ownership percentage in client
Street Address
City State/Province Country
City
State Country
%

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization

1 3 5
2 4 6

CONVICTIONS DISCLOSURE

29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery, extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?

Lobbyist Name Description of Offense(s)