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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 3222 N Street, NW |
Address2 | Suite 340 |
| City | Washington |
State | DC |
Zip Code | 20007 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 400665998-63
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6. House ID# 414510005
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| TYPE OF REPORT | 8. Year | 2018 |
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 |
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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. | ||||||||
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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 |
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| Signature | Digitally Signed By: Andrew M. Siff |
Date | 10/15/2018 3:14:35 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 RET
16. Specific lobbying issues
S. 2526, the "Retirement Enhancement and Savings Act of 2018," legislation encouraging employers to offer defined contribution plans, to expand access to various retirement savings options, and to permit e-delivery of financial documents; entire bill. General education concerning the interpretation and application of section 3(5) of ERISA and how it impacts employers' ability to join together to form open multiple employer plans (open MEPs) to promote retirement savings.
17. House(s) of Congress and Federal agencies Check if None
Labor - Dept of (DOL), U.S. SENATE, 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 |
Andrew |
Siff |
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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
SEC proposed Regulation Best Interest, 83 Fed. Reg. 21574 (May 9, 2018), and Form CRS Relationship Summary, 83 Fed. Reg. 21416 (May 9, 2018). Proposals to dictate the manner of delivery for communications to mutual fund investors, including those in ERISA covered plans. General education regarding amendments made to ERISA section 803 and IRC section 439 under section 2 of H.R. 4997, the "GROW Act," legislation to amend the Employee Retirement Income Security Act of 1974 and the Internal Revenue Code of 1986 to authorize a new composite multiemployer pension plan design and more generally the utility of e-delivery of financial disclosure forms. General education concerning issues faced by financial entities by the lack of coordination between states that allow legal marijuana businesses and federal banking laws that do not account for these state regimes.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, Labor - Dept of (DOL), 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 |
Andrew |
Siff |
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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
General education concerning the application of the Fair Labor Standards Act to the modern financial services industry.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, 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 |
Andrew |
Siff |
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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 | 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 | ||||||||||
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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 | 3 | 5 |
| 2 | 4 | 6 |