|
LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 1099 New York Ave. NW |
Address2 | 6th Floor |
City | Washington |
State | DC |
Zip Code | 20001 |
Country | USA |
3. Principal place of business (if different than line 2)
City |
|
State |
|
Zip Code |
|
Country |
|
|
5. Senate ID# 317914-12
|
||||||||
|
6. House ID# 393430000
|
TYPE OF REPORT | 8. Year | 2024 |
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 | |||||||||
---|---|---|---|---|---|---|---|---|---|
12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
|
|
||||||||
|
|
||||||||
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. Bentsen, Jr. |
Date | 4/19/2024 2:12:52 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 BAN
16. Specific lobbying issues
Prudential agency (Federal Reserve, OCC and FDIC) proposal to implement the Basel Endgame reforms in the U.S. and congressional (U.S. House and Senate) oversight of the same, including revisions to the trading book capital rules, stress testing, capital surcharges and buffers;
SEC Prohibition Against Conflicts of Interest in Certain Securitizations proposed rule;
H.R. 4168, a bill to amend the Securities Act of 1933 to require that information required to be disclosed to the Securities and Exchange Commission by issuers be material to voting or investment decisions regarding those issuers, and for other purposes;
H.R. 4237, a bill to amend the Investment Advisers Act of 1940 and the Employee Retirement Income Security Act of 1974 to specify requirements concerning the consideration of pecuniary and non-pecuniary factors;
H.R. 1807, the Improving Disclosure for Investors Act of 2023;
SEC proposed rule regarding the safeguarding of client assets (custody proposal);
S. 2190, the RECOUP Act, a bill to amend the Federal Deposit Insurance Act to increase bank executive accountability and to improve financial stability;
H.R. ____, to exempt 144a fixed income securities from Rule 15c2-11;
S. 1695, the American Infrastructure Bonds Act of 2023;
H.R. 1837, the Investing in Our Communities Act;
H.R. 4664 and S. 2309, the Fiscal Year 2024 Financial Services and General Government Appropriations bill related to Consolidated Audit Trail and SEC regulatory agenda;
SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing proposed rule;
SEC Amendments to NMS Plan for the Consolidated Audit Trail-Data Security;
SEC Staff Accounting Bulletin 121;
SEC Security-based Swaps Large Position Reporting proposed rule;
H.R.760 - Chinese Military and Surveillance Company Sanctions Act of 2023;
H.R. 1177/S. 427, Financial Freedom Act of 2023;
H.R. 4763 - the Financial Innovation and Technology for the 21st Century Act;
H.R. 4767 - Protecting American's Retirement Savings from Politics Act;
H.R. 3136 - The National Critical Capabilities Defense Act;
S.2678 - Outbound Investment Transparency Act of 2023;
S. 2251 - Cybersecurity Act of 2023 ;
SEC proposed rule on Predictive Data Analytics;
SEC proposal regarding reporting of Securities Loans;
SEC proposals to modify equity market structure;
Biden Administration executive order related to China;
SEC final rule related to clearing of U.S. Treasury securities;
SEC final rule to improve clearing agency governance;
SEC proposed rule to address Volume-Based Exchange Transaction Pricing for NMS Stocks;
SEC final rule on short sale data;
SEC final rules on beneficial ownership;
HR ____, the SEC Regulatory Accountability Act (H.R. 9603 in 117th Congress) (attached to Capital Markets Subcommittee hearing on 3/20/24);
HR 7030, the Review the Expansion of Government Act of 2024 or the REG Act of 2024 (attached to Capital Markets Subcommittee hearing on 3/20/24);
HR ____, to require an assessment and report to Congress on the adequacy of the SECs cost-benefit analysis with respect to major rulemakings (attached to Capital Markets Subcommittee hearing on 3/20/24);
HR ____, to mandate minimum comment periods of at least 60 days for all SEC-initiated rulemakings, with certain exceptions, calculated from the date published in the Federal Register (attached to Capital Markets Subcommittee hearing on 3/20/24);
HR ____, to require the Commission to review certain reviewable actions by SEC staff (attached to Capital Markets Subcommittee hearing on 3/20/24);
HR ____, to require the semi-annual testimony of the Chairman of the SEC before the Committee on Financial Services of the House of Representatives and the Committee on Banking, Housing, and Urban Affairs of the Senate, with testimony on at least one instance to include the testimony of the entire Commission (attached to Capital Markets Subcommittee hearing on 3/20/24);
HR 4551, the "Protecting Investors Personally Identifiable Information Act" (attached to Capital Markets Subcommittee hearing on 3/20/24);
HR 7902, the "Protecting Private Job Creators Act" (exempts fixed income securities from 15c2-11 disclosure) (attached to Capital Markets Subcommittee hearing on 3/20/24);
S. 3676 (Protecting Private Job Creators Act);
H.R. 2799, Expanding Access of Capital Act of 2023;
H.R. 2627, Increasing Investor Opportunities Act;
H.R. 3063, Retirement Fairness for Charities and Education Institutions Act, Expanding the Protection for Research Reports to Cover all Securities of All Issuers;
H.R. 2590, Unlocking Capital for Small Business Act;
H.J. Res. 109. Providing for congressional disapproval of the rule submitted by the SEC related to "Staff Accounting Bulletin No. 121.";
S.J.Res.__, a Joint Resolution providing for congressional disapproval of the rule submitted by the SEC related to "Staff Accounting Bulletin No. 121.".
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Treasury - Dept of, Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Federal Housing Finance Agency (FHFA), Securities & Exchange Commission (SEC), 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 |
Kenneth |
Bentsen |
Jr. |
|
|
Bradley |
Edgell |
|
|
|
Leslie |
Norwood |
|
|
|
Jennie |
Jacoby |
|
|
|
Matt |
Grinney |
|
|
|
Nick |
Key |
|
|
|
Joshua |
Wilsusen |
|
|
|
Lucas |
West |
|
|
|
Joseph |
Corcoran |
|
|
|
Peter |
Matheson |
|
|
|
Carter |
McDowell |
|
|
|
Lindsey |
Keljo |
|
|
|
Melissa |
MacGregor |
|
|
|
Kevin |
Carson |
|
SEC (Chief Counsel in the Office of Legislative and Intergovernmental Affairs); Sen Manchin (Chief Counsel/Legislative Assistant); Rep. Beatty (Legislative Assistant and Counsel) |
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 CDT
16. Specific lobbying issues
SEC proposal related to security-based swaps large trader reporting;
SEC proposal regarding Safeguarding Advisory Client Assets
CFTC Rule 4.7 amendments - comment letter
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Securities & Exchange Commission (SEC), Office of the Comptroller of the Currency (OCC), Commodity Futures Trading Commission (CFTC), Federal Reserve System
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 |
Kenneth |
Bentsen |
Jr. |
|
|
Bradley |
Edgell |
|
|
|
Joshua |
Wilsusen |
|
|
|
Matt |
Grinney |
|
|
|
Lucas |
West |
|
|
|
Lindsey |
Keljo |
|
|
|
Joseph |
Corcoran |
|
|
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
SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing proposed rule;
H.R. 1837, the Investing in Our Communities Act;
S. 1453, the LOCAL Infrastructure Act;
H.R. 4664 and S. 2309, the Fiscal Year 2024 Financial Services and General Government Appropriations bill related to the Consolidated Audit Trail and SEC regulatory agenda;
H.R.760 - Chinese Military and Surveillance Company Sanctions Act of 2023;
H.R. 1807 - Improving Disclosure for Investors Act of 2023;
S. 1695, American Infrastructure Bond Act of 2023;
H.R. 3136 - The National Critical Capabilities Defense Act;
S.2678 - Outbound Investment Transparency Act of 2023;
S. 2251 Cybersecurity Act of 2023;
H.R. 7092, S. 3676, Protecting Private Job Creators Act;
H.R. ____, to exempt 144a fixed income securities from Rule 15c2-11;
SEC proposals to modify equity market structure;
SEC proposal regarding reporting of securities loans;
SEC proposal regarding position reporting of Large Security-Based Swap Positions;
SEC proposal regarding safeguarding Advisory Client Assets;
SEC proposal regarding prohibition of conflicts of interest in certain securitizations;
Sustainable Finance - Legislative proposals related to Environmental, Social, and Governance considerations in investment decisions;
Artificial intelligence and predictive data analytics;
Legislation related to buying OTC securities on Margin.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, Natl Economic Council (NEC), Securities & Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Homeland Security - Dept of (DHS), Natl Security Council (NSC), Office of the Comptroller of the Currency (OCC), Federal Housing Finance Agency (FHFA)
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 |
Kenneth |
Bentsen |
Jr. |
|
|
Bradley |
Edgell |
|
|
|
Leslie |
Norwood |
|
|
|
Nick |
Key |
|
|
|
Matt |
Grinney |
|
|
|
Lucas |
West |
|
|
|
Joshua |
Wilsusen |
|
|
|
Joseph |
Corcoran |
|
|
|
Margaret |
Morgan |
|
|
|
Lisa |
Bleier |
|
|
|
Peter |
Matheson |
|
|
|
Philip |
Austin |
|
|
|
Carter |
McDowell |
|
|
|
Melissa |
MacGregor |
|
|
|
Jennie |
Jacoby |
|
|
|
Lindsey |
Keljo |
|
|
|
Kevin |
Carson |
|
SEC (Chief Counsel in the Office of Legislative and Intergovernmental Affairs); Sen Manchin (Chief Counsel/Legislative Assistant); Rep. Beatty (Legislative Assistant and Counsel) |
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
H.R. 1837, the Investing in Our Communities Act;
H.R.7024 - Tax Relief for American Families and Workers Act of 2024;
S. 1695, American Infrastructure Bonds Act of 2023;
S. 1453, the LOCAL Infrastructure Act.
Public Law 117-328 - Consolidated Appropriations Law (Secure 2.0 retirement provisions);
IRS Tax Treatment of Digital Assets;
IRS Stock Buyback Excise Tax;
U.S. Treasury, IRS Request for Extension of Comment Period for REG-122793-19 Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions (proposed regulations);
OECD BEPS 2.0;
Form W-9 requester instructions;
Proposed Regulations for Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions;
IRC Section 871(m);
IRC Section 987;
U.S. Taiwan Expedited Double Tax Relief Act;
Issues related to 529 plans;
OMB Number: 1545-2313, Form 15397 (November 2023), Application for Extension of Time to Furnish Recipient Statements;
Appendix III of the Qualified Intermediary (QI) Agreement, Revenue Procedure 2022-43.
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), Internal Revenue Service (IRS)
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 |
Kenneth |
Bentsen |
Jr. |
|
|
Bradley |
Edgell |
|
|
|
Leslie |
Norwood |
|
|
|
Philip |
Austin |
|
|
|
Nick |
Key |
|
|
|
Margaret |
Morgan |
|
|
|
Joshua |
Wilsusen |
|
|
|
Lisa |
Bleier |
|
|
|
Lucas |
West |
|
|
|
Lindsey |
Keljo |
|
|
|
Joseph |
Corcoran |
|
|
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
H.R. 5337 Retirement Proxy Protection Act;
H.R. 5338 No Discrimination in My Benefits Act;
H.R. 5339 RETIRE Act;
H.R. 5340 Providing Complete Information to Retirement Investors Act;
H.R.5673, Responsible Legislating Act;
H.R. 6065/ S. 3102 Retirement Savings for Americans Act;
H.R. 6007, Retirement Investment in Small Employers Act;
H.R. 7293, Automatic IRA Act of 2024 ;
H.R. 1818/S. 1561 the Aviation Workforce Development Act;
S. 3716/ H.R. 7162 A bill to create children's lifetime savings accounts, and for other purposes;
Amendments to H.R. 2670, the National Defense Authorization Act for Fiscal Year 2024 (FDTA exemption for state and local governments);
SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing proposed rule;
DOL Fiduciary Rule proposed rule on retirement security and related proposed changes to prohibited transaction exemptions including Qualified Professional Asset Manager;
Public Law 117-328 - Consolidated Appropriations Law (Secure 2.0 retirement provisions);
Retirement Security Rule: Definition of an Investment Advice Fiduciary (EBSA) and related exemptions;
Independent Contractor Rule discussions;
RIN 0985-AA18 NPRM - Adult Protective Services Functions and Grant Programs, Administration for Community Living, HHS To amend the Internal Revenue Code of 1986 and the Employee Retirement Income Security Act of 1974 to make technical corrections relating to the SECURE 2.0 Act of 2022, and for other purposes;
SECURE 2.0 Implementation RIN 1210-AC23 RFI - SECURE 2.0 Reporting and Disclosure, EBSA Basel III End Game and Retirement;
Employee Identification Number (EIN) / Unrelated Business Taxable Income (UBTI);
Amendment No. 83 to H.R. 5894 - Labor, Health and Human Services, Education, and Related Agencies Appropriations Act, 2024;
IRS proposed rule regarding Section 4966 Donor Advised Funds;
Appropriations Rider Funds May only be Used on DOL Fiduciary;
APS Funding.
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), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), 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 |
Kenneth |
Bentsen |
Jr. |
|
|
Lisa |
Bleier |
|
|
|
Bradley |
Edgell |
|
|
|
Matt |
Grinney |
|
|
|
Joshua |
Wilsusen |
|
|
|
Lucas |
West |
|
|
|
Margaret |
Morgan |
|
|
|
Nick |
Key |
|
|
|
Philip |
Austin |
|
|
|
Lindsey |
Keljo |
|
|
|
Leslie |
Norwood |
|
|
|
Joseph |
Corcoran |
|
|
|
Kevin |
Carson |
|
SEC (Chief Counsel in the Office of Legislative and Intergovernmental Affairs); Sen Manchin (Chief Counsel/Legislative Assistant); Rep. Beatty (Legislative Assistant and Counsel) |
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
Address |
|
||||||
City |
|
State |
|
Zip Code |
|
Country |
|
21. Client new principal place of business (if different than line 20)
City |
|
State |
|
Zip Code |
|
Country |
|
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
|
|
||||||||
1 |
|
3 |
|
||||||
2 |
|
4 |
|
ISSUE UPDATE
24. General lobbying issue that no longer pertains
|
|
|
|
|
|
|
|
|
AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
Name | Address |
Principal Place of Business (city and state or country) |
||||||||||||
| ||||||||||||||
|
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 | ||||||||||
| ||||||||||||||
|
% |
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) |