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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | PO Box 480 |
Address2 |
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City | Ellicott City |
State | MD |
Zip Code | 21041 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 401104677-12
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6. House ID# 438450001
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TYPE OF REPORT | 8. Year | 2023 |
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: Kenneth E Swab |
Date | 1/19/2024 12:45:00 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
Issues related to Securities and Exchange Commission Regulation BI (Regulation Best Interest). Proposed Securities and Exchange Commission Rule 223-1: Safeguarding Advisory Client Assets (Custody Rule) and Conflicts of Interest and Predictive Data Analytics Proposal.
Issues relating to Opportunity Zones.
Issues relating to 401(k) defined contributions.
H.R. 835, Fair Investment Opportunities for Professional Experts Act, all provisions.
H.R. 1579, Accredited Investor Definition Review Act, all provisions.
H.R. 2797, Equal Opportunity for All Investors Act of 2023, all provisions.
H.R. 2593, Senior Security Act of 2023, all provisions.
H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act, all provisions.
H.R. 2799, Expanding Access to Capital Act of 2023, all provisions.
H.R. 2627, Increasing Investor Opportunities Act, all provisions.
Issues relating to fiduciary duties regarding asset classes under ERISA (Retirement
Savings Modernization Act).
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, Labor - Dept of (DOL), Securities & Exchange Commission (SEC), Office of Management & Budget (OMB)
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 |
Anya |
Coverman |
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Gina |
Gombar |
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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
Issues pertaining to the application of the Foreign Investment in Real Property Tax Act.
Issues relating to IRC section 1031 like-kind exchanges and issues related to individual retirement accounts.
Issues related to non-traded REITs and Business Development Corporations (BDCs).
Issues related to the definition of domestically controlled qualified investment entities (DCQIEs).
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)
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 |
Anya |
Coverman |
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Gina |
Gombar |
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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
Issues relating to 401(k) defined contributions.
Issues relating to Fiduciary Duties Regarding Asset Classes under ERISA (Retirement
Savings Modernization Act),
Department of Labor Retirement Security Rule: Definition of Investment Advice Fiduciary and Related Exemptions.
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 |
Anya |
Coverman |
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Gina |
Gombar |
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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 BAN
16. Specific lobbying issues
Issues pertaining to Basel III Endgame.
Issues relating to capital requirements applicable to banking organizations with total assets of $100 billion or more.
Issues related to regulatory capital calculation and calculation of risk-weighted assets across large banking institutions.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Office of the Comptroller of the Currency (OCC)
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 |
Anya |
Coverman |
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Gina |
Gombar |
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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) |