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

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

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

CSP - Quarter 4 2022

Public Law 111-203, H.R. 4173- Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Implementation, Global Capital Standards and Regulatory reform.

H.R. 8152 - American Data Privacy and Protection Act. To provide consumers with foundational data privacy rights, create strong oversight mechanisms, and establish meaningful enforcement. Issue: Data Privacy

S. 4000 - Intragovernmental Cybersecurity Information Sharing Act. This bill would require the establishment of cybersecurity information sharing agreements between the Department of Homeland Security and Congress. Issue: Data Privacy

H.R. 1816 - Information Transparency and Personal Data Control Act. The legislation, which would preempt state law, would require companies to obtain opt-in consent from users to collect, transmit, sell, share or otherwise disclose their sensitive personal information, which is defined to include financial data, biometric information, geolocation data, citizenship and immigration status, and information from children under 13. Issue: Data Privacy

H.R. 4659 and S. 113 - the Browser Act. The measure would require opt-in consent for the collection of sensitive information and opt-out consent for non-sensitive information. Issue: Data Privacy

H.R. 2039 and S. 1209 - Protecting Investors Personally Identifiable Information Act. The bill would require the Securities and Exchange Commission (SEC) to obtain investors sensitive information from their stockbroker if needed instead of automatically storing every investors sensitive personal data in the agencys new Consolidated Audit Trail (CAT) database. Issue: Data Privacy

S. 919 - Data Care Act. The legislation would establish duties of care, loyalty, and confidentiality, and a violation of the duties would be treated as a violation of a Federal Trade Commission (FTC) rule with fine authority. Issue: Data Privacy

S. 1494 - Consumer Data Privacy and Security Act. The bill would establish a preemptive federal privacy standard. The legislation would provide users with the rights to access, correction, deletion, and it would also require businesses that collect and process a significant amount of personal data to take extra precautionary steps to protect such data. Issue: Data Privacy


S. 2134 - Data Protection Act of 2021. The measure would create the Data Protection Agency (DPA), an independent federal agency tasked with protecting Americans privacy. Issue: Data Privacy

S. 3195 - Consumer Online Privacy Rights Act. This bill places requirements on entities that process or transfer a consumer's data. Issue: Data Privacy.

H.R. 5807 and S. 3065 - DATA Privacy Act. A bill to establish national data privacy standards in the United States. Issue: Data Privacy

H.R. 6027 - Online Privacy Act. The bill, which would provide users with the rights to access, correction, and deletion and establish the Digital Privacy Agency (DPA). Issue: Data Privacy

H.R. 5440 and S. 2875 - Cyber Incident Reporting for Critical Infrastructure Act. To amend the Homeland Security Act of 2002 to establish the Cyber Incident Review Office in the Cybersecurity and Infrastructure Security Agency of the Department of Homeland Security. Issue: Data Privacy

S. 2499 - Setting an American Framework to Ensure Data Access, Transparency and Accountability (SAFE DATA) Act. This bill establishes various requirements relating to the collection of consumer data, data transparency and security, and corporate accountability, including limiting the amount of data a covered entity may collect. Issue: Data Privacy

H.R. 6580/S.3572 - Algorithmic Accountability Act of 2022. To direct the Federal Trade Commission to require impact assessments of automated decision systems and augmented critical decision processes, and for other purposes. Issue: Data Privacy.

S. 1667 - Social Media Privacy Protection and Consumer Rights Act. This bill requires online platform operators to inform a user, prior to a user creating an account or otherwise using the platform, that the user's personal data produced during online behavior will be collected and used by the operator and third parties. The operator must provide a user the option to specify privacy preferences, and an operator may deny certain services or complete access to a user if the user's privacy elections create inoperability in the platform. Issue: Data Privacy.

H.R. 9588 - Consumer Information Notification Requirement Act. This bill would codify breach notification requirements for financial institutions in the Gramm Leach Bliley Act and establish preemption of state law for data security and breach notification requirements. Issue: Data Privacy

H.R. __ - To amend the Gramm-Leach-Bliley Act to {modernize the protection of the nonpublic personal information of consumers}. Issue: Data Privacy

H.R. __ - Control Our Data Act. The bill would preempt state privacy laws and be enforceable by the Federal Trade Commission (FTC) and state attorneys general. Issue: Data Privacy

H.___ and S.___ - Draft data privacy legislation. Issue: Data Privacy


Issue: Draft legislation that would require notice of data security breaches. Issue: Cybersecurity and Privacy.

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES

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

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

FIN - Quarter 4 2022

Public Law 111-203, H.R. 4173 - Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Implementation and Regulatory reform. Captive Reinsurance Transactions, Insurance Capital Standards and Global Capital Standards. Roles of federal and state agencies at the International Association of Insurance Supervisors and the Financial Stability Board.

Implementation of S. 2270 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III

Implementation of S. 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act. Issue: Implementation and regulatory reform of the financial services industry.

H.R. 1996/S. 910 - Secure and Fair Enforcement Banking Act. Issue: Insurance companies working with legitimate marijuana businesses.

H.R. 4521 - America COMPETES Act of 2022. This bill addresses U.S. technology and communications, foreign relations and national security, domestic manufacturing, education, trade, and other matters. Issue: Insurance companies working with legitimate marijuana businesses.

H.R. 842/S.420 - Protecting Workers Freedom to Organize Act. To amend the National Labor Relations Act, the Labor Management Relations Act, 1947, and the Labor-Management Reporting and Disclosure Act of 1959. Issue: independent contractor status.

H.R. 1523/S. 526 - Modern Worker Empowerment Act. To amend the Fair Labor Standards Act of 1938 to harmonize the definition of employee with the common law. Issue: employee status.

H.R.3962/S.1625 - Securing and Enabling Commerce Using Remote and Electronic Notarization Act. To authorize and establish minimum standards for electronic and remote notarizations that occur in or affect interstate commerce, to require any Federal court located in a State to recognize notarizations performed by a notary public commissioned by another State when the notarization occurs in or affects interstate commerce, and to require any State to recognize notarizations performed by a notary public commissioned by another State when the notarization occurs in or affects interstate commerce or when the notarization was performed under or relates to a public act, record, or judicial proceeding of the State in which the notary public was commissioned. Issue: remote online notarization.

H.R. 4350 - National Defense Authorization Act for Fiscal Year 2022. This bill authorizes FY2022 appropriations for military activities and programs of the Department of Defense (e.g., personnel; research, development, test, and evaluation; and procurement of items such as aircraft, missiles, and ammunition). It also prescribes military personnel strengths for FY2022. Issue: remote online notarization and cannabis banking.

H.R. 4616/S. 3779 - To deem certain references to the London Interbank Offered Rate (LIBOR) as referring to a replacement benchmark rate in the case of LIBOR no longer being available. Issue: LIBOR.

H.R. 2471 - Consolidated Appropriations Act, 2022. This bill provides appropriations to federal agencies for the remainder of FY2022, provides supplemental appropriations for activities to support Ukraine, and modifies or establishes various programs that address a wide range of policy areas. Issue: LIBOR.

S. 3715 - Electronic Signatures in Global and National Commerce Act. To amend the Electronic Signatures in Global and National Commerce Act to accommodate emerging technologies. Issue: electronic signatures.

S.Con.Res.14 - Concurrent Resolution on the Budget, FY2022. The budget resolution calls for the $3.5 trillion in long-term investments to be fully offset by a combination of new tax revenues, health care savings, and long-term economic growth. In addition, the agreement would prohibit new taxes on families making less than $400,000 per year, and on small businesses and family farms. Issue: unemployment insurance.

H.R. 2617 Consolidated Appropriations Act, 2023. This legislation makes consolidated appropriations for the fiscal year ending September 30, 2023, and for providing emergency assistance for the situation in Ukraine, and for other purposes. Issue: registration for index linked annuities; cannabis banking.

Issue: Cannabis legislation

Issue: FHLBank System

Issue: Regulation Best Interest

Issue: Environmental, Social, and Corporate Governance (ESG). No bill number assigned.

Issue: Commercial mortgage-backed security (CMBS) debt. No bill number assigned.

Issue: Making Diversity and Inclusion Efforts more Intentional. No bill number assigned.

Issue: Unclaimed life insurance products. No bill number assigned.

Issue: Covered agreement on prudential measures with respect to the business of insurance and reinsurance. No bill number assigned.

Issue: Government Sponsored Enterprises (GSE) reform. No bill number assigned.

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES

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

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

INS - Quarter 4 2022

Public Law 111-203, H.R. 4173- Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Implementation and Regulatory reform. Captive Reinsurance Transactions, Insurance Capital Standards and Global Capital Standards.

Implementation of S. 2270 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III

H.R. 1255/S. 377 - Living Donor Protection Act of 2021. The bill would promote and protect from discrimination living organ donors. Issue: underwriting.

S. 862/H.R. 2068 - Clarifying Law Around Insurance of Marijuana Act. To create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related business. Issue: underwriting, anti-money laundering.

H.R. 2617 Consolidated Appropriations Act, 2023. This legislation makes consolidated appropriations for the fiscal year ending September 30, 2023, and for providing emergency assistance for the situation in Ukraine, and for other purposes. Issue: cannabis banking.

Issue: private equitys growing role in the insurance industry.

Issue: S&P proposal on the methodology that is used to rate insurance companies.

Issue: Request for information from Congress regarding the diversity and inclusion information in the insurance industry.

Issue: Housing Finance Reform. No bill number assigned.

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES

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

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

Retirement Security - Quarter 4 2022

1.H.R. 2954, Securing a Strong Retirement Act (SECURE 2.0) / Retirement Security and Savings Act: Comprehensive retirement savings legislation.
2.S. 1272, The SIMPLE Plan Modernization Act: The bill would raise the contribution limit for SIMPLE plans from $13,500 to $16,500 with a corresponding increase in the catch-up limit from $3,000 to $4,750.
3.S. 1770, The Retirement Security & Savings Act: Comprehensive retirement savings legislation.
4.H.R. 5891, The Retirement Improvement and Saving Enhancement (RISE) Act: Contains several retirement security provisions, also included within H.R. 2459 (SSRA). Also requires DOL, the Department of the Treasury, and the Pension Benefit Guaranty Corporation (PBGC) to review reporting and disclosure requirements for pension plans and make recommendations to Congress to consolidate, simplify, standardize, and improve such requirements.
5.The Enhancing American Retirement Now (EARN) Act: Builds upon S. 1770 with additional retirement provisions. Considered the Senate version of SECURE 2.0.
6.The Rise and Shine Act: Senate HELP provisions covered by ERISA to be included with a Senate retirement package (SECURE 2.0).
7.S. 2415 and H.R. 7107, the Long-Term Care Affordability Act: Would allow for tax free distributions from retirement accounts to fund LTC contracts.
8.Division T of the Consolidated Appropriations Act, 2023: Combines numerous retirement security bills, including the EARN act.. Would expand retirement savings for Americans.


Income Security
The Enhancing American Retirement Now (EARN) Act: Builds upon S. 1770 with additional retirement provisions. Considered the Senate version of SECURE 2.0.

S. 2415 and H.R. 7107, the Long-Term Care Affordability Act: Would allow for tax free distributions from retirement accounts to fund LTC contracts.

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES

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

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

TAX - Quarter 4 2022

Life Insurance Tax Stabilization Proposal (no bill introduced yet)

Ordinary Treatment of Bonds (Senate Wyden Modernization of Derivatives Act)

o S.2621 - 117th Congress (2021-2022) Modernization of Derivatives Tax Act of 2021

Build Back Better Act (H.R. 5376)

Wyden Tax Wealth Like Wages (mark-to-market) discussion paper (no bill introduced yet)

Long Term Care Suozzi WISH ACT

o H.R.4289 - 117th Congress (2021-2022) WISH Act

Long-Term Care Affordability Act

o S. 2415 - 117th Congress (2021-2022)
o H.R. 7107 - 117th Congress (2021-2022)

Inflation Reduction Act of 2022

o H.R. 5376 - 117th Congress (2021-2022)

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES

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

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

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

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

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

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

FOREIGN ENTITIES

27. Add the following foreign entities:

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

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?
No Yes