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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 321 D Street, NE |
Address2 | |
City | Washington |
State | DC |
Zip Code | 20002 |
Country | USA |
3. Principal place of business (if different than line 2)
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State | |
Zip Code | |
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5. Senate ID# 400609853-12
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6. House ID# 413270000
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TYPE OF REPORT | 8. Year | 2014 |
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 | |||||||||
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12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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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: Timothy Chapman, Chief Operating Officer |
Date | 07/21/2014 |
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 BAN
16. Specific lobbying issues
Issues related to problems arising from Consumer Financial Protection Bureau rules. Issues related to the possibility of a bill to repeal the Financial Stability Oversight Council. Issues relating to the re-authorization of the Export-Import Bank and the need for expiration. Issues relating to the Farm Credit System. HR 2548 "Electrify Africa Act of 2014," all provisions relating to reauthorization of OPIC. Issues related to the ongoing investigation into DOJ's Operation Choke Point.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Erin |
Siefring |
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Cari |
Kelly |
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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 BUD
16. Specific lobbying issues
Issues related to the upcoming appropriations bills, specifically pertaining to importance of the policy as well as the top line number, the options of a CR or the mini-bus for FY15 funding, the importance of maintaining the congressional earmark ban, potential budget process reforms, and the need to reform entitlements. H.Con.Res.96 "Establishing the budget for the United States Government for fiscal year 2015 and setting forth appropriate budgetary levels for fiscal years 2016 through 2024," all provisions.
"Departments of Labor, Health and Human Services, and Education, and Related Agencies Fiscal Year 2015 Appropriations Bill," all provisions. HR 1871 "Baseline Reform Act of 2014," all provisions. HR 4660 "Commerce, Justice, Science, and Related Agencies Appropriations Act, 2015," all provisions. HR 4487 "Legislative Branch Appropriations Act, 2015," all provisions. HR 4745 "Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2015," all provisions. HR 4800 "Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2015," all provisions. HR 4435 "Howard P. "Buck" McKeon National Defense Authorization Act for Fiscal Year 2015," all provisions. HR 4870 "Department of Defense Appropriations Act, 2015," all provisions.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Erin |
Siefring |
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Jason |
Yaworske |
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Andrew |
White |
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Frederick |
Baird |
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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 CPT
16. Specific lobbying issues
S 2146 "Patent Fee Integrity Act," all provisions related to the expansion of the FTC's authority to regulate 1st amendment freedom of speech in demand letters.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE
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 |
Frederick |
Baird |
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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 CIV
16. Specific lobbying issues
Issues relating to Electronic Communications Privacy Act (ECPA) reform.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Frederick |
Baird |
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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 EDU
16. Specific lobbying issues
HR 4612 "Higher Education Reform and Opportunity Act of 2014" / S 1904 "Higher Education Reform and Opportunity Act of 2013," all provisions.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Andrew |
White |
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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 FAM
16. Specific lobbying issues
Issues relating to language in the State and Foreign Operations Appropriations bill for FY15 regarding expanded federal funding of abortions to include rape, incest, and the life of the mother. Issues relating to marriage.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Cari |
Kelly |
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Erin |
Siefring |
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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 HCR
16. Specific lobbying issues
Issues relating to the repeal of and possible replacements for Obamacare. Issues relating to health care reform.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Erin |
Siefring |
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Jason |
Yaworske |
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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 IMM
16. Specific lobbying issues
HR 2377 "ENLIST Act," all provisions. HR 4435 "National Defense Authorization Act for Fiscal Year 2015," all provisions relating to the ENLIST Act. S 744 "Border Security, Economic Opportunity, and Immigration Modernization Act," all provisions. Issues relating to the potential for new immigration and/or amnesty bills to be introduced. Issues relating to unaccompanied minors at the border, the border crisis in general and Central America. Issues relating to New Zealand E visas bills.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Frederick |
Baird |
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Erin |
Siefring |
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Cari |
Kelly |
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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 LBR
16. Specific lobbying issues
S 2223 "Minimum Wage Fairness Act," all provisions.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE,
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 |
Andrew |
White |
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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
HR 3086 "Permanent Internet Tax Freedom Act," all provisions relating to the Marketplace Fairness Act. HR 684/S 743 "Marketplace Fairness Act of 2013," all provisions. HR 4718 "To amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation," all provisions. Issues relating to expiring tax provisions/tax extenders. S 2260 "EXPIRE Act of 2014," all provisions. Issues relating to the IRS targeting of conservative and religious groups.
Issues relating to the importance of tax reform for economic growth and global competitiveness and the adverse impact on US competitiveness.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Jason |
Yaworske |
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Erin |
Siefring |
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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 TRA
16. Specific lobbying issues
HR 3486/S 1702 "Transportation Empowerment Act," all provisions. Issues relating to the Highway Trust Fund, gas tax diversions, the Mass Transit Account in MAP-21, and transportation reform. H.Rept. 113-449 "Water Resources Reform and Development Act of 2014," all provisions.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Andrew |
White |
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Erin |
Siefring |
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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 MMM
16. Specific lobbying issues
Issues relating to Medicaid and Sustainable Growth Rate (SGR) reform. HR 2305 "Preventing and Reducing Improper Medicare and Medicaid Expenditures (PRIME) Act of 2013," all provisions.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Jason |
Yaworske |
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Erin |
Siefring |
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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 FOR
16. Specific lobbying issues
Issues relating to United Nations reform. Issues relating to current and upcoming general foreign policy.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES,
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 |
Erin |
Siefring |
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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 LAW
16. Specific lobbying issues
S 987 "Free Flow of Information Act of 2013," all provisions. S 1410 "Smarter Sentencing Act of 2014," all provisions.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Frederick |
Baird |
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Cari |
Kelly |
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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 WEL
16. Specific lobbying issues
Issues relating to Social Security Disability Insurance (SSDI) program reform.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Jason |
Yaworske |
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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 FIN
16. Specific lobbying issues
HR 4387 "FSOC Transparency and Accountability Act," all provisions. HR 3482 "Restoring Main Street Investor Protection and Confidence Act," all provisions. Issues relating to repeal of the Financial Stability Oversight Council.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Erin |
Siefring |
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Cari |
Kelly |
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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 INS
16. Specific lobbying issues
Issues relating to flood insurance reform.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES,
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 |
Erin |
Siefring |
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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 TEC
16. Specific lobbying issues
Issues relating to the Internet Corporation for Assigned Names and Numbers (ICANN) autonomy.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Frederick |
Baird |
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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 ENG
16. Specific lobbying issues
S 2262 "Energy Savings and Industrial Competitiveness Act of 2014," all provisions.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE,
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 |
Andrew |
White |
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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 TOU
16. Specific lobbying issues
HR 4450 "Travel Promotion, Enhancement, and Modernization Act of 2014," all provisions relating to extension of BrandUSA.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES
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 |
Cari |
Kelly |
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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 VET
16. Specific lobbying issues
Issues relating to a huge unpaid for expansion of the VA program, particularly using mandatory, unoffset, non-BCA compliant funds in the process.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Jason |
Yaworske |
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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 CSP
16. Specific lobbying issues
HR 1563 "Concrete Masonry Products Research, Education, and Promotion Act of 2013," all provisions relating to establishment of a government-administered trade organization for concrete masonry products.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES
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 |
Jason |
Yaworske |
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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 GOV
16. Specific lobbying issues
HR 863 "Commission to Study the Potential Creation of a National Women's History Museum Act," all provisions. Issues relating to regulatory reform and the impact of regulation on business development and competitiveness and the adverse impact of our regulatory structure in the US on competitiveness and economic growth.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Cari |
Kelly |
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Erin |
Siefring |
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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 HOU
16. Specific lobbying issues
HR 2767 "Protecting American Taxpayers and Homeowners Act of 2013," all provisions. S 1217 "Housing Finance Reform and Taxpayer Protection Act of 2013," all provisions relating to the Johnson-Crapo markup. Issues relating to GSE reform.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Cari |
Kelly |
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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 POS
16. Specific lobbying issues
Issues relating to the connection of postal reform and the Highway Trust Fund.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Jason |
Yaworske |
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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 REL
16. Specific lobbying issues
S 1808 "Marriage and Religious Freedom Act," all provisions. Issues relating to the "Hobby Lobby" decision.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Cari |
Kelly |
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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
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21. Client new principal place of business (if different than line 20)
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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
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
1 | 3 | 5 |
2 | 4 | 6 |
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 | ||||||||||
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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 | 5 | 9 |
2 | 6 | 10 |
3 | 7 | 11 |
4 | 8 | 12 |