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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 1101 CONNECTICUT AVENUE, NW, #950 |
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City | WASHINGTON |
State | DC |
Zip Code | 20036 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 14611-12
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6. House ID# 333770000
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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: Peter A. Lefkin, Senior Vice President, Government and External Affairs |
Date | 04/15/2011 |
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 INS
16. Specific lobbying issues
Financial Services Regulatory Reform: Lobby for favorable implementation of H.R. 4173, the Dodd-Frank Wall Street Reform and Consumer Protection Act regarding insurers, including a resolution fund for failing firms, and the treatment of insurers under the "Volcker rule" ban on proprietary trading and investment in hedge and private equity funds. Also, followed inclusion of section to create a Federal insurance Office at Treasury including the appointment of that office's Director. Along with trade associations,
commented on notice of Proposed Rulemaking by the Financial Stability oversight Council for systemic risk regulation of nonbank firms.
Also, lobby for robust and effective Federal insurance Office. Also, with key trade associations, worked on regulatory strategy for the implementation of Dodd-Frank.
Annuities/Suitability: followed implementation of amendments to H.R. 4173 that helps confirm that fixed index annuities are insurance products to be regulated by states.
Holocaust insurance issues/ICHEIC: Monitored the reintroduction of legislation that would allow a cause of action against U.S. Insurance companies with European affiliates that may have written life insurance policies involving Holocaust victims in contravention of international agreements.
Credit-based insurance scores: Monitor and lobbied possible reintroduction of legislation that would restrict the ability of personal lines insurers to use credit information of underwriting or setting rates.
Climate and energy legislation: Monitored White House, Department of Energy and Environmental Protection Agency "Better Buildings initiative." Monitored General Services Administration initiative on green buildings and related sustainable products.
National Catastrophe/Flood Insurance: Track drafting reintroduction of national Flood Insurance Reform legislation.
State Bankruptcy: Along with trade associations, monitor efforts by some members of Congress to allow states to file for bankruptcy protection.
Broker-dealer regulatory reform/standard of care: Monitor Securities and Exchange Commission and Department of Labor rulemaking and investment advisors and the fiduciary duty standard.
Annuities: Support H.R. 2748, the Retirement Security Needs Lifetime Payment Act of 2009 and monitor through trade association.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Risk Management Agency, 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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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Patrick |
LaVeck |
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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
Cascading taxes for foreign-owned insurers: Advocate against measure in Congress and from the Obama Administration that would lead to imposition of an excise tax twice when insurance for reinsurance is placed from the U.S. to a foreign company and then when the foreign company reinsures the U.S. risk.
Executive Compensation: Monitor and oppose efforts to change carried interest tax treatment.
Foreign Account Tax Compliance Act - Follow implementation of "FATCA" which became law in March, 2010. This Act increases reporting and withholding requirements for foreign financial firms.
Exchange traded notes: for PIMCO followed issue through trade association, Investment Company Institute, ETN's are an alternative to mutual funds and enjoy a tax preference. Treasury has recently weighted in and may view this current tax treatment as not appropriate.
Related-party reinsurance taxation: Advocate against legislation introduced in previous Congress by Rep. Richard Neal (D-MA) that would prohibit offshore reinsurance affiliates of insurance companies and not required to pay U.S. Taxes from taking deductions for "excel reinsurance premiums" for domestic risks.
Monitor and oppose Obama Administration tax proposals that would change existing tax laws and increase tax requirements for life insurance.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Securities & Exchange Commission (SEC), 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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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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
Money market guaranty program: follow creation of Treasury Department money market guaranty program after concern about the financial stability of the Reserve Management Corporations Primary Fund.
H.R. 4173, the Dodd-Frank Wall Street Reform and Consumer Protection Act: Follow implementation of this legislation which would create a new systemic risk regulation for systemically-significant firms and a resolution mechanism for failing firms.
The president signed it into law on July 21, 2010.
Follow meetings and proposed rules of the Financial Stability Oversight Council (FSOL) and the establishment of the Federal Insurance Office and Consumer Financial Protection Bureau. Closely follow the FSOL's proposed rule to implement Sec. 113 of the Dodd-Frank Act, which would establish criteria for the designation of non-bank firms as "systemically important financial institutions."
Mark to market accounting: follow SEC and FASBE action regarding guidance and clarifications for mark to market accounting.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, 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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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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 TOR
16. Specific lobbying issues
Legal/Tort reform: track the progress of the insurance industry's collaboration on legal reform tort issues at the federal and state levels.
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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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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
Derivatives: Monitor new rules and changes of regulation for derivatives and commodity indexed funds, and activity within Congress, especially in the context of the HR 4173, the Wall Street Reform and Consumer Protection Act and implementation by the CFTC.
Consumer Financial Protection Bureau: Monitor inclusion of this new agency in H.R. 4173, the Wall Street Reform and Consumer Protection Act and its implementation.
Target Date Funds: Monitor possible legislation and SEC as well as Department of Labor regulatory activities
SEC and money markets: Monitor and see proposed SEC regulations.
Mutual funds: Advocate for the ability to defer annual capital gains taxation of dividends that are reinvested in mutual funds.
Proprietary Trading: Along with trade associations, monitor implementation of the "Volcker Rule", included as part of HR 4173, the Wall Street Reform and Consumer Protection Act. This will restart the ability of some institutions to engage in proprietary trading and investing in hedge and private equity funds.
Fiduciary Duty - Monitor the SEC's efforts to establish a uniform fiduciary duty standard for investment advisers and broker-dealers
Whistleblower Program: Monitor and oppose SEC rulemaking implementing a provision in the Dodd-Frank Act that creates a new Whistleblower program within the agency.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Commodity Futures Trading Commission (CFTC), 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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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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
401 (k) fee disclosure: Trade Department of Labor rulemaking regarding 401 (k) fee disclosure.
Lifetime Income Disclosure Act: Follow introduction of legislation that would require 401 (k) plans to give plan participants an annual statement projecting the monthly income that could be generate if the account balance were amortized as retirement.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Labor - Dept of (DOL)
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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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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 |