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 BAN

16. Specific lobbying issues

H.R.760 - Chinese Military and Surveillance Company Sanctions Act of 2023;
H.R. 1807, the Improving Disclosure for Investors Act of 2023;
H.R. 1837, the Investing in Our Communities Act;
H.R. 2590, Unlocking Capital for Small Business Act;
H.R. 2627 - Increasing Investor Opportunities Act (closed-end fund bill);
H.R. 2799, Expanding Access of Capital Act of 2023;
H.R. 3063, Retirement Fairness for Charities and Education Institutions Act;
H.R. 3136 - The National Critical Capabilities Defense Act;
H.R. 4237, a bill to amend the Investment Advisers Act of 1940 and the Employee Retirement Income Security Act of 1974 to specify requirements concerning the consideration of pecuniary and non-pecuniary factors;
HR 4551, the "Protecting Investors Personally Identifiable Information Act" (attached to Capital Markets Subcommittee hearing on 3/20/24);
H.R. 4763 - the Financial Innovation and Technology for the 21st Century Act;
H.R.4766 - Clarity for Payment Stablecoins Act of 2023;
H.R. 4767 - Protecting American's Retirement Savings from Politics Act;
H.R. 8339, the "SEC Reform and Restructure Act;
H.R. 8773, FY 2025 Financial Services and General Government Appropriations Bill (3 provisions in the FSGG Bill Report pertaining to the SEC: PDA rule withdrawal, economic analysis enhancement, sensible implementation);
H.R. 8818, American Privacy Rights Act;
H.J. Res. 109. Providing for congressional disapproval of the rule submitted by the SEC related to "Staff Accounting Bulletin No. 121.";
H.J. Res. 116, providing for congressional disapproval of DOL's independent contractor rule;
H. J. Res 142, Providing for congressional disapproval of the Department of Labor fiduciary rule;
S.2678 - Outbound Investment Transparency Act of 2023;
S. 3815 - the Improving Disclosure for Investors Act of 2024;
S. 4628, National Defense Authorization Act for Fiscal Year 2025 (China-related provisions);
S. 4760, Digital Commodities Consumer Protection Act of 2022;
S. 4917 - Retirement Fairness for Charities and Educational Institutions Act of 2024;
S.5139 - A bill to amend the Securities Act of 1933 to address emerging growth companies, and for other purposes (the Empowering Main Street in America Act);
S.J. Res.__, a Joint Resolution providing for congressional disapproval of the rule submitted by the SEC related to "Staff Accounting Bulletin No. 121.";
H.R. ___, To codify the special purpose broker dealer, and for other purposes;
H.R. ____, to exempt 144a fixed income securities from Rule 15c2-11;
HR ____, to require an assessment and report to Congress on the adequacy of the SECs cost-benefit analysis with respect to major rulemakings (attached to Capital Markets Subcommittee hearing on 3/20/24);
HR ____, to mandate minimum comment periods of at least 60 days for all SEC-initiated rulemakings, with certain exceptions, calculated from the date published in the Federal Register (attached to Capital Markets Subcommittee hearing on 3/20/24);
HR ____, to require the Commission to review certain reviewable actions by SEC staff (attached to Capital Markets Subcommittee hearing on 3/20/24);
HR ____, to require the semi-annual testimony of the Chairman of the SEC before the Committee on Financial Services of the House of Representatives and the Committee on Banking, Housing, and Urban Affairs of the Senate, with testimony on at least one instance to include the testimony of the entire Commission (attached to Capital Markets Subcommittee hearing on 3/20/24);
Prudential agency (Federal Reserve, OCC and FDIC) proposal to implement the Basel Endgame reforms in the U.S. and congressional (U.S. House and Senate) oversight of the same, including revisions to the trading book capital rules, stress testing, capital surcharges and buffers;
Biden Administration executive order related to China;
SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing proposed rule;
SEC Amendments to NMS Plan for the Consolidated Audit Trail-Data Security;
SEC Staff Accounting Bulletin 121;
SEC Security-based Swaps Large Position Reporting proposed rule;
SEC proposed rule regarding the safeguarding of client assets (custody proposal);
SEC proposed rule on Predictive Data Analytics;
SEC proposal regarding reporting of Securities Loans;
SEC proposals to modify equity market structure;
SEC final rule related to clearing of U.S. Treasury securities;
SEC proposed rule to address Volume-Based Exchange Transaction Pricing for NMS Stocks;
Senator Stabenow's Discussion Draft cryptocurrency legislation;
SEC CAT Fee filings by the SROs;
SEC approval of SROs rules limiting exchange liability;
SEC enforcement cases related to off-channel communications;
CFPB enforcement action relating to the National Collegiate Student Loan Trusts;
FDIC Brokered Deposit Proposal;
FDIC Proposal to amend change in Bank Control Action Regulations.

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

U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Treasury - Dept of, Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Federal Housing Finance Agency (FHFA), Securities & Exchange Commission (SEC), Labor - Dept of (DOL)

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

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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 CDT

16. Specific lobbying issues

H.R. 4763, the Financial Innovation and Technology Act;
S. 4760, Digital Commodities Consumer Protection Act of 2022;
SEC proposal related to security-based swaps large trader reporting;
SEC proposal regarding Safeguarding Advisory Client Assets;
Senator Stabenow's Cryptocurrency Discussion Draft legislation.

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Securities & Exchange Commission (SEC), Office of the Comptroller of the Currency (OCC), Commodity Futures Trading Commission (CFTC), Federal Reserve System

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

H.R.760 - Chinese Military and Surveillance Company Sanctions Act of 2023;
H.R. 1807 - Improving Disclosure for Investors Act of 2023;
H.R. 1837, the Investing in Our Communities Act;
H.R. 7780 Safeguarding Options for Retirement Act;
S. 1453, the LOCAL Infrastructure Act;
S. 1695, American Infrastructure Bond Act of 2023;
S.2678 - Outbound Investment Transparency Act of 2023;
H.R. ____, to exempt 144a fixed income securities from Rule 15c2-11;
SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing proposed rule;
SEC proposals to modify equity market structure;
SEC proposal regarding reporting of securities loans;
SEC proposal regarding position reporting of Large Security-Based Swap Positions;
SEC proposal regarding safeguarding Advisory Client Assets;
SEC No-Action Letter on Rule 15c2-11;
Sustainable Finance - Legislative proposals related to Environmental, Social, and Governance considerations in investment decisions;
Artificial intelligence and predictive data analytics;
Legislation related to buying OTC securities on Margin.

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, Natl Economic Council (NEC), Securities & Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Homeland Security - Dept of (DHS), Natl Security Council (NSC), Office of the Comptroller of the Currency (OCC), Federal Housing Finance Agency (FHFA)

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

H.R. 1837, the Investing in Our Communities Act;
S. 1695, American Infrastructure Bonds Act of 2023;
S. 1453, the LOCAL Infrastructure Act;
Public Law 117-328 - Consolidated Appropriations Law (SECURE 2.0 retirement provisions);
IRS Stock Buyback Excise Tax;
OECD BEPS 2.0 - an effort to address tax avoidance and ensure coherence of international tax rules;
IRC Section 871(m);
IRC Section 987;
Issues related to 529 plans;
BEAT QDP - regulations regarding the reporting of qualified derivative payments that are not considered base erosion payments;
2024 Proposed Regulations for the Identification of Basket Contract Transactions as Listed Transactions;
2024 Dual Consolidated Loss Regulations;
Tax Treatment of Digital Assets;
Appendix III of the Qualified Intermediary (QI) Agreement, Revenue Procedure 2022-43;
Information Reporting and Withholding with respect to Bitcoin ETFs;
GILTI;
BEAT.

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, Securities & Exchange Commission (SEC), Internal Revenue Service (IRS)

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

H.R. 5339, the RETIRE Act;
H.R. 6065/ S. 3102 Retirement Savings for Americans Act;
S. 4371, Empowering States to Protect Seniors from Bad Actors Act;
H.R. 4767 - Protecting American's Retirement Savings from Politics Act;
H. J. Res 142, Providing for congressional disapproval of the Department of Labor fiduciary rule;
H.J. Res. 116, providing for congressional disapproval of DOL's independent contractor rule;
S. 4917, a bill to amend the Federal securities laws to enhance 403(b) plans;
S. 4965, the Small Nonprofit Retirement Security Act of 2024;
S. 4371, Empowering States to Protect Seniors from Bad Actors Act;
S. 5149/H.R. 9764, A bill to amend the Internal Revenue Code of 1986 to allow additional catch-up contributions for certain family caregivers;
S.5148/H.R. 9765, A bill to amend the Internal Revenue Code of 1986 to allow certain family caregivers to contribute to a Roth IRA;
SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing proposed rule;
DOL Fiduciary Rule proposed rule on retirement security and related proposed changes to prohibited transaction exemptions including Qualified Professional Asset Manager;
Public Law 117-328 - Consolidated Appropriations Law (Secure 2.0 retirement provisions);
Retirement Security Rule: Definition of an Investment Advice Fiduciary (EBSA) and related exemptions;
SECURE 2.0 Implementation RIN 1210-AC23 RFI - SECURE 2.0 Reporting and Disclosure, EBSA Basel III End Game and Retirement;
Preservation of Private Sector Retirement System;
SECURE 2.0 Technical Corrections Act of 2023.

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, Securities & Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Labor - Dept of (DOL)

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

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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