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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# 400665998-48
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6. House ID# 414510003
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TYPE OF REPORT | 8. Year | 2019 |
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. | ||||||||
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: Andrew M. Siff |
Date | 10/17/2019 5:06:03 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
General education concerning the need to simplify anti-money laundering/Bank Secrecy Act reporting mandates and raising reporting thresholds. H.R. 1, the "For the People Act of 2019"; Title IV, Subtitle F repealing the prohibition on the Securities and Exchange Commission promulgating regulations to require a shareholder vote for a corporation to engage in spending that supports the best interests of the company on public issues directly and through trade associations and other entities. Office of Financial Research assessment of the U.S. leveraged loan market and associated markets, such as the market for collateralized loan obligations. Securities and Exchange Commission guidance to investment advisers on fulfilling their proxy voting responsibilities, particularly where they use the services of a proxy advisory firm, and proxy voting disclosures under Form N-1A, Form N-2, Form N-3, and Form N-CSR under the Investment Company Act of 1940. Securities and Exchange Commission interpretation of Exchange Act Rule 14a-1(l) that proxy voting advice under the federal proxy rules and related guidance regarding the application of the anti-fraud provisions in Exchange Act Rule 14a-9 to proxy advice. Securities and Exchange Commission Regulation Best Interest (83 Fed. Reg. 21574, May 9, 2018).
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Labor - Dept of (DOL), 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 RET
16. Specific lobbying issues
Department of Labor final fiduciary rule and the status of various Prohibited Transaction Exemptions following the 5th Circuit injunction of the final fiduciary rule. Section 5 of President Trump's April 10, 2019 Executive Order 13868, "Promoting Energy Infrastructure and Economic Growth," regarding the voting of proxies held by Employee Retirement Income Security Act funds. Standards governing fiduciaries under section 402, section 403, section 404, and section 405 of the Employee Retirement Income Security Act. State efforts to impose a patchwork of fiduciary obligations on retirement plans regulated under the Employee Retirement Income Security Act and the issues this poses for the uniformity Congress intended when it enacted the Employee Retirement Income Security Act with its preemption provision.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, Labor - Dept of (DOL), U.S. HOUSE OF REPRESENTATIVES, White House Office, 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
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 |
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) |