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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 500 NEW JERSEY AVE, NW |
Address2 | |
City | WASHINGTON |
State | DC |
Zip Code | 20001 |
Country | USA |
3. Principal place of business (if different than line 2)
City | CHICAGO |
State | IL |
Zip Code | 60611 |
Country | USA |
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5. Senate ID# 27070-12
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6. House ID# 317330000
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TYPE OF REPORT | 8. Year | 2014 |
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: JERRY GIOVANIELLO, SENIOR VICE PRESIDENT, GOVERNMENT AFFAIRS |
Date | 04/21/2014 |
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
Data Privacy and Security
HR624 - Cyber Information Sharing and Protection Act
S1193 - Data Security and Breach Notification Act of 2013
Truth in Lending Act (TILA) Amendments
HR1077 - Consumer Mortgage Choice Act
HR 3211 - A bill to Amend the Truth In Lending Act to Improve Upon the Definitions Provided for Points and Fees in Connection with a Mortgage Transaction
The Interstate Land Sales Act
S2101 - A Bill to Amend the Interstate Land Sales Full Disclosure Act to clarify how the act applies to condominiums
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE,
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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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Melanie |
Wyne |
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Kenneth |
Trepeta |
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Joe |
Ventrone |
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Marcia |
Salkin |
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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 DIS
16. Specific lobbying issues
Natural Disaster Policy
HR152 - Disaster Relief Appropriations Act of 2013
HR240 - Homeowners Insurance Protection Act of 2013
HR960 - Flood Victim Premium Relief Act of 2013
Natural Disaster Policy (cont'd)
HR1101 - Homeowners and Taxpayers Protection Act of 2013
HR1267 - Flood Insurance Premium Relief Act of 2013
HR1485 - A bill to amend the National Flood Insurance Act of 1968 to modify the phase-in increases in flood insurance premium rates for certain properties, and for other purposes
HR2199 - York River Wild and Scenic River Study Act of 2013
HR2217 - Fiscal 2014 Homeland Security Appropriations
HR3298 - A bill to amend the Internal Revenue Code of 1986 to allow individuals a deduction for amounts contributed to disaster savings accounts to help defray the cost of preparing their homes to withstand a disaster
HR3989 - A bill to amend the Internal Revenue Code of 1986 to allow individuals a deduction for amounts contributed to disaster savings accounts to help defray the cost of preparing their homes to withstand a disaster and to repair or replace property damaged or destroyed in a disaster.
HR3370 - Homeowner Flood Insurance Affordability Act of 2013
HR3547 - Fiscal 2014 Omnibus Appropriations Act
HR3693 - Flood Insurance Relief and Transparency Act of 2013
S601 - Water Resources Development Act of 2013
S954 - FARM Bill
S996 - A bill to improve the National Flood Insurance Program, and for other purposes
S1610 - Homeowner Flood Insurance Affordability Act of 2013
S1846 - Homeowner Flood Insurance Affordability Bill
S1926 - Homeowner Flood Insurace Affordability Bill
S1991 - A bill to amend the Internal Revenue Code of 1986 to allow individuals a deduction for amounts contributed to disaster savings accounts to help defray the cost of preparing their homes to withstand a disaster and to repair or replace property damaged or destroyed in a disaster.
Terrorism Risk Insurance
HR508 - Terrorism Risk Insurace Act of 2002 (TRIA) Reauthorization Act of 2013
HR1945 - Fostering Resilience to Terrorism Act of 2013
HR2146 - Terrorism Risk Insurance Program Reauthorization Act of 2013
Discussions with the Federal Emergency Management Agency (FEMA) within the Department of Homeland Security (DHS) on flood insurance and the National Flood Insurance Program.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Emergency Management Agency (FEMA), Homeland Security - Dept of (DHS),
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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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Austin |
Perez |
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Russell |
Riggs |
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Joe |
Ventrone |
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Erin |
Stackley |
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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 ENG
16. Specific lobbying issues
Energy Efficiency & Climate Change
HR332 - Climate Protection Act of 2013
HR1616 - Energy Savings and Industrial Competetiveness Act of 2013
HR2126 - Better Buildings Act of 2013
Energy Efficiency & Climate Change (cont'd)
HR2128 - HOMES Act of 2013
S761 - Energy Savings and Industrial Competetiveness Act of 2013
S1106 - Sensible Accounting to Value Energy Act of 2013 (SAVE)
S1191 - Better Buildings Act of 2013
S1200 - Residential Energy Savings Act of 2013
S1206 - A bill to encourage benchmarking and disclosure of energy information for commercial buildings
S1392 - Energy Savings and Industrial Competetiveness Act of 2013
S.2074 - Energy Savings and Industrial Competitiveness Act of 2014
Discussions with the Department of Energy (DOE) on energy labels and home energy performance scores.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Energy - 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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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Austin |
Perez |
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Vijay |
Yadlapati |
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Russell |
Riggs |
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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 FIN
16. Specific lobbying issues
Improvement of Short Sales Process
HR839 - Prompt Decision for Qualification for Short Sales Act
S361 - Prompt Notification of Short Sales Act
GSE Modifications
HR736 - Responsible Homeowner Refinancing Act of 2013
HR1712 - Housing Opportunity and Mortgage Equity Act of 2013
HR2767 - The Protecting American Taxpayers and Homeowners Act of 2013
HR3550 - The New Fair Deal Banking and Housing Stability Act of 2013
S249 - Responsible Homeowner Refinancing Act of 2013
S536 - Jumpstart GSE Reform
S1217 - Housing Finance and Taxpayer Protection Act of 2013
Basel III Capital Standards
HR1693 - A bill to provide an exemption for community banks from the application of Basel III capital standards
S737 - Basel III Impact Study Act
Commercial Real Estate Refinancing
HR1240 - A bill to extend the low-interest refinancing provisions under the Local Development Business Loan Program of the Small Business Administration
S289 - Commercial Real Estate and Economic Development Act of 2013
S968 - Small Business Lending Enhancement Act of 2013
Fees and Points in the QM ATR Rules of Dodd-Frank
HR3211 - Mortgage Choice Act of 2013
S949 - Consumer Mortgage Choice Act
S1577 - Mortgage Choice Act of 2013
Credit Union Lending
HR688 - A bill to amend the Federal Credit Union Act to provide certain credit unions with the authority to make additional member business loans, and for other purposes
Conversations with the Treasury Department about Qualified Residential Mortgages (QRM) and the Home Affordable Modification Program (HAMP).
Discussions with the Department of Housing and Urban Development (HUD) on loan limits, Qualified Residential Mortgages (QRM), condominiums, the FHA premium structure, and FHA loan limits.
Conversations with the Consumer Finance Protection Board (CFPB) on the 3% cap, Qualified Residential Mortgages (QRM), Qualified Mortgages (QM), loan servicing, the "Know Before You Owe" program, and the Real Estate Settlement Procedures Act (RESPA).
Conversations with the Federal Housing Finance Agency (FHFA) about loan limits and Government Sponsored Enterprises (GSE) refrom.
Discussions with the Federal Deposit Insurance Corporation (FDIC) about Qualified Residential Mortgages (QRM).
Discussions with the Office of the Comptroller of the Currency (OCC) about Qualified Residential Mortgages (QRM).
Discussions with the Securities and Exchange Commission about Qualified Residential Mortgages (QRM).
Conversations with the White House National Economic Council regarding housing finance.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Treasury - Dept of, Securities & Exchange Commission (SEC), Housing & Urban Development - Dept of (HUD), Natl Economic Council (NEC), Federal Deposit Insurance Commission (FDIC), 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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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Vijay |
Yadlapati |
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Megan |
Booth |
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Kenneth |
Trepeta |
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Joe |
Ventrone |
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Charles |
Dawson |
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William |
Gilmartin |
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Marcia |
Salkin |
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Sarah |
Young |
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Melanie |
Wyne |
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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 HCR
16. Specific lobbying issues
Changes in Health Insurance Markets
HR544 - LIBERTY Act
HR763 - A bill to repeal the annual fee on health insurance providers enacted by the Patient Protection and Affordable Care Act.
S40 - American Liberty Restoration Act
Individual and Employer Mandates in the Patient Protection/ACA
HR2575 - Save American Workers Act of 2013
HR2577 - Small Business Job Protection Act of 2013
S701 - Forty Hours is Full Time Act
S1188 - Forty Hours is Full Time Act
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE,
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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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Marcia |
Salkin |
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Evan |
Liddiard |
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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 HOU
16. Specific lobbying issues
FHA Programs
HR1145 - FHA Emergency Fiscal Solvency Act of 2013
S1376 - The FHA Solvency Act
FHA Programs (cont'd)
HR1872 - Budget and Accounting Transparency Act of 2014
HR1997 - Communities Achieving Sustainability Act
Rural Housing Provisions
HR858 - Rural Housing Preservation Act of 2013
HR933 - Department of Defense, Military Construction, and Veterans Affairs Full-Year Continuing Appropriations Act of 2013
HR1947 - FARRM Act of 2013
HR2410 - Fiscal 2014 Agriculture Appropriations
HR3547 - Fiscal 2014 Omnibus Appropriations
HR2642 - Agriculture Act of 2014
HR2672 - CFPB Rural Designation Petition and Correction Act
HR2774 - Continuing Appropriations Act, 2014
HJRes59 - Continuing Appropriations Resolution, 2014
S766 - A bill to amend section 520 of the Housing Act of 1949 to revise the census data and population requirements for areas to be considered as rural areas for purposes of such act
S954 - Agriculture Reform, Food and Jobs Act of 2013 (FARM Bill)
S1244 - Fiscal 2014 Agriculture Appropriations
S1916 - Helping Expand Lending Practices (HELP) in Rural Communities Act
Department of Housing and Urban Development (HUD) Appropriations
HR2610 - Fiscal 2014 Transportation-HUD Appropriations
Housing Finance System Reform
HR2767 - The Protecting American Taxpayers and Homeowners Act of 2013
Conversations with the Department of Housing and Urban Development (HUD) on the FHA and federally-assisted housing.
Discussions with the Rural Housing Service (RHS) of the USDA on the Section 502 loan program and multifamily rental housing.
Discussions with the Department of Veterans Affairs (VA) on the VA Home Loan Guarantee program.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Housing & Urban Development - Dept of (HUD), Agriculture - Dept of (USDA), Veterans Affairs - Dept of (VA)
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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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Megan |
Booth |
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Joe |
Ventrone |
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William |
Gilmartin |
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Kenneth |
Trepeta |
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Russell |
Riggs |
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Charles |
Dawson |
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Sarah |
Young |
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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 IMM
16. Specific lobbying issues
Use of "g-fees" to offset the cost of the STEM Visa Program
S303 - STEM Jobs Act of 2013
Encouraging foreign investment in US Real Estate
HR459 - STEM Visa Act of 2013
S169 - Immigration Innovation Act of 2013
Immigration and Visa Reform
S744 - Border Security Economic Opportunity and Immigration Modernization Act
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE,
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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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Marcia |
Salkin |
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Vijay |
Yadlapati |
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Charles |
Dawson |
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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
Carried Interest Tax Treatment
S268 - Cut Unjustified Tax Loopholes Act
State and Local Use Tax Laws for Remote Sellers
S336 - Marketplace Fairness Act
S743 - Marketplace Fairness Act
HR684 - Marketplace Fairness Act
Tax Relief for Forgiven Mortgage Debt
HR2788 - Mortgage Forgiveness Tax Relief Act
HR2994 - Mortgage Forgiveness Tax Relief Act of 2013
S1187 - Mortgage Forgiveness Tax Relief Act of 2013
Tax Incentives for Safety Upgrades in Commercial Buildings
S1163 - Fire Sprinkler Incentive Act
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE,
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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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Evan |
Liddiard |
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Vijay |
Yadlapati |
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Erin |
Stackley |
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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 CPT
16. Specific lobbying issues
Patent Litigation Reform
HR845 - SHIELD Act
HR2639 - Patent Litigation and Innovation Act of 2013
Patent Litigation Reform (cont'd)
HR3309 - The Innovation Act
S1720 - Patent Transparency and Improvements Act of 2013
S1612 - Patent Litigation Integrity Act of 2013
S2049 - Transparency in the Assertion of Patents Act
Patent Reform
HR2024 - End Anonymous Patents Act
S866 - Patent Quality Improvement Act of 2013
S1013 - Patent Abuse Reduction Act of 2013
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE,
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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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Melanie |
Wyne |
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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 ENV
16. Specific lobbying issues
Improvements to Implementing Lead Paint Regulations
S484 - Lead Exposure Reduction Amendments Act of 2013
HR2093 - Lead Exposure Reduction Amendments Act or 2013
Federal Forest Policy
HR1526 - Restoring Healthy Forests for Healthy Communities Act
Discussions with the Environmental Protection Agency (EPA) regarding the proposed rule on Waters of the U.S. Jurisdiction.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Environmental Protection Agency (EPA),
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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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Russell |
Riggs |
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Vijay |
Yadlapati |
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Megan |
Booth |
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Austin |
Perez |
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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 TRA
16. Specific lobbying issues
Complete Streets and Livable Communities
HR2468 - Safe Streets Act of 2013
HR3494 - Bicycle and Pedestrian Safety Act
Complete Streets and Livable Communities (cont'd)
S1708 - A bill to amend Title 23, United States Code, with respect to the establishment of performance measures for the highway safety improvement program, and for other purposes.
S2004 - A bill to ensure the safety of all users of the transportation system, including pedestrians, bicyclists, transit users, children, older individuals and individuals with disabilities, as they travel on and across federally funded streets and highways
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE,
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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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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 RES
16. Specific lobbying issues
Discussions with the Federal Aviation Authority (FAA) regarding building height requirements.
Conversations with the General Services Administration (GSA) regarding federal real property sales issues.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Aviation Administration (FAA), General Services Administration (GSA)
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 |
Jerry |
Giovaniello |
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James |
Gregory |
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Helen |
Devlin |
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Colin |
Allen |
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Dan |
Blair |
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Ken |
Wingert |
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Kevin |
Donnelly |
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Joe |
Ventrone |
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Vijay |
Yadlapati |
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William |
Gilmartin |
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Erin |
Stackley |
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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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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 | 3 | 5 |
2 | 4 | 6 |
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 | 5 | 9 |
2 | 6 | 10 |
3 | 7 | 11 |
4 | 8 | 12 |