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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 1501 M STREET, N.W., Suite 600 |
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City | WASHINGTON |
State | DC |
Zip Code | 20005 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 4675-12
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6. House ID# 312420000
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TYPE OF REPORT | 8. Year | 2011 |
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 | |
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: Ralph P. Kass, Controller |
Date | 01/20/2012 |
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 HCR
16. Specific lobbying issues
Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 - H.R. 4 Public Law No: 112-009
Help Efficient, Accessible, Low Cost, Timely Healthcare (HEALTH) Act of 2011 H.R. 5
Patients Freedom to Choose Act H.R. 605
Medical FSA Improvement Act of 2011 H.R. 1004
Medicare Beneficiary Freedom to Choose Act of 2011 H.R. 1051
Fiscal Responsibility and Retirement Security Act of 2011 (To repeal the CLASS Program) H.R. 1173
PPACA De-Funding legislation H.R. 1213, 1214, 1215, 1216 & 1217
Family and Retirement Health Investment Act of 2011 H.R. 2010
The MLR Repeal Act of 2011 H.R. 2077
Tax Parity for Health Plan Beneficiaries Act of 2011 H.R. 2088
Health Care Reform regulatory implementation and compliance issues from the Patient Protection and Affordable Care Act (PPACA) Public Law No: 111-148 & the Health Care and Education Reconciliation Act of 2010 (HCERA) Public Law No: 111-152
Department of Defense and Full-Year Continuing Appropriations Act, 2011 H.R. 1473, repeal of certain PPACA provisions
Fiscal Year 2012 Budget Proposal budgetary impacts of health entitlement programs
National Commission on Fiscal Responsibility and Reform implications for benefits
Joint Select Committee on Deficit Reduction impact on employee benefits provisions
The American Jobs Act
Senate
Small Business Paperwork Reduction Act S. 18
Small Business Paperwork Mandate Elimination Act of 2011 - S. 72
State Leadership in Health Act S. 73
FAA Air Transportation Modernization and Safety Improvement Act S. 223 (Section 1099 repeal information reporting requirements under Section 9006 of PPACA
State Health Care Choice Act S. 244
Empowering States to Innovate Act S. 248
Patients Freedom to Choose Act S. 312
Repeal the CLASS Entitlement Act S. 720
Retiree Health Coverage Protection Act S.1088
Family and Retirement Health Investment Act S. 1098
Tax Parity for Health Plan Beneficiaries Act of 2011 S. 1171
Health Care Reform regulatory implementation and compliance issues from the Patient Protection and Affordable Care Act (PPACA) Public Law No: 111-148 & the Health Care and Education Reconciliation Act of 2010 (HCERA) Public Law 111-152
Fiscal Year 2012 Budget Proposal budgetary impacts of health and retirement entitlement programs
National Commission on Fiscal Responsibility and Reform implications for benefits
Joint Select Committee on Deficit Reduction impact on employee benefits provisions
The American Jobs Act
The Trade Adjustment Assistance (TAA) Extension Act employer sponsored health benefits
White House - Joint Select Committee on Deficit Reduction impact on employee benefits provisions health care policy provisions
Proposed Health Information Technology for Economic and Clinical Health (HITECH) Act regulations for HIPAA Accounting of Disclosures
Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563
2011-2012 Agency Guidance Priority List
Guidance for and implementation of the Patient Protection and Affordable Care Act (PPACA) & the Health Care and Education Reconciliation Act of 2010 (HCERA) employer responsibility provisions (shared responsibility/pay to play), essential benefits package, CLASS Act, tax treatment of certain plans, transition period and good faith compliance standard, Early Retiree Reinsurance Program (ERRP), retiree only plans, grandfathered plans, grandfathering rules as applied to collectively bargained health plans, coverage of adult children, medical loss ratios (MLRs), Mini-Med waiver program, internal claims and appeals processes, annual limit waivers, Constitutional issues, value-based insurance design, preventative services, Accountable Care Organizations (ACOs) Medicare Shared Savings Program (SSP), Medicare Secondary Payer Program (MSP), health care quality measurement, reporting and health information technology, Meaningful Use Incentive Program and definition, application of nondiscrimination rules for insured group health plans, W2 treatment and reporting, state waivers, definition of full-time employee, Comparative Effectiveness program, health exchanges, risk and reinsurance standards, new rules on subsidy eligibility and health insurance exchanges, availability of Medicare data for performance measurement, proposed regulations on required summary of benefits and coverage and the uniform glossary, health insurance premium tax credit, womens preventative health care
Health care provider compensation Internal Revenue Code Section 162 (m) (6)
Electronic disclosure, communication by employee benefit plans
Consumer directed health care plans
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Health & Human Services - Dept of (HHS), Centers For Medicare and Medicaid Services (CMS), Internal Revenue Service (IRS), Labor - Dept of (DOL), Federal Trade Commission (FTC), Natl Economic Council (NEC), White House Office
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 |
James |
Klein |
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Paul |
Dennett |
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Kathryn |
WIlber |
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Lynn |
Dudley |
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Diann |
Howland |
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Jill |
Randolph |
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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
Public Employee Pension Transparency Act - H.R. 567
Lifetime Income Disclosure Act - H.R. 677
Burdensome Data Collection Relief Act - H.R. 1062
Fiscal Responsibility and Retirement Security Act of 2011 (To repeal the CLASS Program) - H.R. 1173
Small Businesses Add Value for Employees Act of 2011 (SAVE Act) H.R. 1534
To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption H.R. 1573
Would repeal provision in the Dodd-Frank Wall Street Act prohibiting federal bailout of swap dealers or participants H.R. 1838
To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders H.R. 1840
SEC Regulatory Accountability Act H.R. 2308
Swap Execution Facility Clarification Act H.R. 2586
Pension Technical Modifications Act H.R. 2656
Business Risk Mitigation and Price Stabilization Act of 2011 H.R. 2682
Amends the Commodity Exchange Act and the Securities Exchange Act of 1934 H.R. 2779
Retirement Income Protection Act of 2011 H.R. 3045
Hardship Outlays to protect Mortgagee Equity Act of 2011 H.R. 3104
Employee Misclassification Prevention Act H.R. 3178
Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Savings Act H.R. 3287
Small Business Pension Protection Act of 2011 H.R. 3561
Fiscal Year 2012 Budget Proposal budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues
Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 H.R. 4 Public Law No: 112-009
Financial Services Reform implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Public Law No: 111-203
Pension Funding - additional funding relief and reform, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions
Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, , partial termination enforcement
Retirement Security - defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs)
National Commission on Fiscal Responsibility and Reform implications for benefits
Joint Select Committee on Deficit Reduction impact on employee benefits provisions PBGC premiums, contribution limits to defined contribution plans and worker classification issues
The American Jobs Act
Lifetime Income Disclosure Act S. 267
Public Employee Pension Transparency Act S. 347
Repeal the CLASS Entitlement Act S. 720
Payroll Fraud Prevention Act S. 770
Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Act) S. 1020
Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Act) S. 1121
Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act S. 1289
Automatic IRA Act of 2011 S. 1557
Hardship Outlays to protect Mortgagee Equity (HOME) Act S. 1656
National Commission on Fiscal Responsibility and Reform implications for benefits
Fiscal Year 2012 Budget Proposal budgetary impacts of health and retirement entitlement programs, PBGC insurance, premium issues
Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203
Pension funding additional funding relief and reform, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions
Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement
Retirement Security defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs)
National Commission on Fiscal Responsibility and Reform implications for benefits
Joint Select Committee on Deficit Reduction - impact on employee benefits provisions PBGC premiums, contribution limits to defined contribution plans and worker classification issues
The American Jobs Act
Joint Select Committee on Deficit Reduction impact on employee benefits provisions PBGC premiums, worker classification issues
Presidential Advisory Council on Financial Capability
Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563
2011-2012 Agency Guidance Priority List
Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 proposed regulations related to swap trades; process for review of swaps for mandatory clearing; provisions common to registered entities, legal entity identification for financial contracts; swap data recordkeeping and reporting requirements; real-time reporting of swap transaction data; reporting, recordkeeping, and daily trading records requirements for swap dealers and major swap participants; unique counterparty identifiers; definition of swap dealer, security-based swap dealer, major swap participant, major security-based swap participant, eligible contract participant; swap data repository (SDR); business conduct standards for swap dealers and major swap participants with counterparties; transparency and accountability of derivatives market; regulation of over-the-counter swaps transactions; stable value contracts.
Pension funding - adequacy of defined benefit vehicles, retirement plan designs, and tax treatment of expatriates
Hybrid retirement plan designs implementation of the Pension Protection Act (PPA)
Investment advice re-proposal of rule on definition of fiduciary, adequacy of defined contribution vehicles, investment selection and annuity issues, automatic/mandatory individual retirement accounts (IRAs), proposed regulations regarding target date funds (TDFs) and qualified default investment alternatives (QDIAs); electronic disclosure of 401 (k) fee information, disclosure for defined contribution (DC) and defined benefit (DB) plans and service providers -ERISA Section 408 (b) (2), Fiduciary requirements 401 (k) participant fee disclosure regulations, in-plan Roth conversions issues RFI Electronic disclosure for employee benefit plans
Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation
Pension Benefits Guaranty Corporation (PBGC) - premium and premium filing, submission issues, proposed regulations ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement
Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR)
International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits
Domestic plan asset investment issues
International benefits issues/Puerto Rican plan trust issues
Multiemployer plan issues
Public pension system issues
Plan audit issues
Worker classification issues
Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans
Plan distribution issues
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, White House Office, Office of Management & Budget (OMB), Pension Benefit Guaranty Corporation (PBGC), Labor - Dept of (DOL), Treasury - Dept of, Internal Revenue Service (IRS), Securities & Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC)
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 |
James |
Klein |
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Lynn |
Dudley |
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Janet |
Jacobson |
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Diann |
Howland |
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Jill |
Randolph |
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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 |