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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 New York Ave. NW |
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City | Washington |
State | DC |
Zip Code | 20005 |
Country | USA |
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5. Senate ID# 317914-12
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6. House ID# 393430000
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TYPE OF REPORT | 8. Year | 2018 |
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. Bentsen, Jr. |
Date | 7/20/2021 1:02:00 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 BAN
16. Specific lobbying issues
H.R. 1624 (Municipal Finance Support Act of 2017);
H.R. 2121 (Pension, Endowment, and Mutual Fund Access to Banking Act);
Equity market structure issues;
Single Security/Common Securitization Platform (Federal Housing Finance Agency);
Federal Reserve Total Loss Absorbing Capacity (TLAC) proposal;
Federal Reserve G-SIB capital surcharge;
Dodd-Frank Wall Street Reform and Consumer Protection Act Implementation;
Structure of the U.S. Treasury.
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), Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Ginnie Mae, 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. |
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Carter |
McDowell |
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Dave |
Oxner |
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Kevin |
Carroll |
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Bradley |
Edgell |
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Chris |
Killian |
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Lindsey |
Keljo |
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Katie |
Malone |
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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 CDT
16. Specific lobbying issues
H.R. 238 (Commodity End-User Relief Act);
H.R. 316 (Futures Investor Protection Act);
H.R. 4659 (To require the appropriate Federal banking agencies to recognize the exposure-reducing nature of client margin for cleared derivatives);
H.R. 5749 (To require the appropriate Federal banking agencies to increase the risk-sensitivity of the capital treatment of certain centrally cleared exchange-listed options and derivatives, and for other purposes);
S. 1005 (Modernization of Derivatives Tax Act of 2017);
Regulation of over-the-counter (OTC) derivatives (standardization of derivatives - all aspects including exchange trading, clearing, and reporting requirements);
Core Principles and Other Requirements for Swap Execution Facilities (SEF Final Rule);
CFTC Cross-border Guidance and Exemptive Order (13-69);
Make available to trade determination for Swap Execution Facilities (SEFs);
Position limits;
Concept Release on Risk Controls and System Safeguards for Automated Trading Environments;
Transaction-Level Requirements in Certain Cross-Border Situations (CFTC letters Nos. 13-17 and 14-01);
CFTC Regulation 1.35;
Block trades on swap execution facilities (SEFs);
CFTC no action relief for packaged trades;
Security based swaps rules under Title VII;
Derivatives regulation (general);
CFTC Letter 14-140 on transaction-level requirements in certain cross-border situations;
Inter-affiliate swap transactions;
Margin requirements for uncleared swaps;
Swap Execution Facilities (SEFs) and clearing for swaps;
Global FX Code of Conduct;
Decision to delay implementation for margin for non-centrally cleared swaps;
CFTC proposed cross border rule;
CFTC capital requirements for swap dealers and major swap participants;
CFTC final rule on margin requirements for uncleared swaps;
SEC proposed rule on margin for uncleared swaps;
CFTC's Project Kiss;
Initial margin for inter-affiliate transactions;
Commodity Exchange Act reauthorization;
Issues related to H.R. 5961 and S. 2976 (Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2019);
Standardized Approach for Counterparty Credit Risk (SA-CCR Rule Making);
Fundamental Review of the Trading Book (FRTB) actions;
SEC Capital, Margin, and Segregation requirements;
Securities Exchange Act Rules 17a-1, 17a-3, and 17a-4;
CFTC Cross-border Swaps Regulation Version 2.0.
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 Deposit Insurance Corporation (FDIC), Federal Reserve System, 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 |
Kenneth |
Bentsen |
Jr. |
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Carter |
McDowell |
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Dave |
Oxner |
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Michael |
Decker |
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Bradley |
Edgell |
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Kyle |
Brandon |
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Katie |
Malone |
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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
H.R. 3280 (Financial Services and General Government Appropriations Act, 2018);
H.R. 3555 (Exchange Regulatory Improvement Act);
H.R. 6258 (Financial Services and General Government Appropriations Act, 2019);
S. 2098 (Foreign Investment Risk Review Modernization Act of 2017);
S. 2499 (A bill to require the Financial Industry Regulatory Authority to establish a relief fund to provide investors with the full value of unpaid arbitration awards issued against brokerage firms or brokers regulated by the Authority);
S. 3107 (Financial Services and General Government Appropriations Act, 2019);
Swap execution facilities;
Swap dealer, major swap participant, and futures commission merchant chief compliance officer;
Dodd-Frank Wall Street Reform and Consumer Protection Act Implementation (including Section 913; Section 914; Systemic risk regulation and liquidation authority; Section 342 (Office of Minority and Women Inclusion); Section 621; Section 941; Title I and Title II);
India Market Access Issues;
India Financial Sector Reform;
Accounting standards for municipalities;
Privacy and cybersecurity issues (general);
CFTC cross-border guidance exemptive order;
CFTC exemptive order on extraterritorial scope of Title VII;
Jumpstart our Business Startups (JOBS) Act implementation;
Commodity Pools and Securitization;
Securities and Exchange Commission Rules 15Ba1-1 through 15Ba1-8;
Release No. 34-71958, Security-Based Swap Dealers Recordkeeping;
Regulation AB II (asset backed securities - Securities and Exchange Commission, Consumer Financial Protection Bureau);
Futures Commission Merchant and Introducing Broker Conflicts of Interest Policies and Procedures;
Inter-affiliate swap transactions;
Trade policy issues (general);
China "Secure and Controllable" information and communication technologies (ICT) regulations;
Mutual Fund 12b-1 Fees;
Senior investors/diminished capacity investors;
Broker-dealers/investment advisers mitigation of accounts;
Diversity & Inclusion initiatives in the financial services industry;
Data localization requirements in the Trans-Pacific Partnership;
Swap Execution Facilities (SEFs) and clearing for swaps;
Global FX Code of Conduct;
Decision to delay implementation for margin for non-centrally cleared swaps;
North American Free Trade Act (NAFTA);
Municipal information disclosure regulation;
Executive Order 13771 (Reducing Regulation and Controlling Regulatory Cost);
Executive Order 13772 (Core Principles for Regulation of the US Financial System)
Executive Order 13777 (Enforcing the Regulatory Reform Agenda);
US and China 100-day trade talks;
Data Breach Notification Federal Standard;
ETF Regulation;
Issues relating to H.R. 6072 and S. 3023 (Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2019).
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), U.S. Trade Representative (USTR), Commerce - Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Natl Credit Union Administration (NCUA), Ginnie Mae, Homeland Security - Dept of (DHS), Natl Security Council (NSC), State - Dept of (DOS), Office of the Comptroller of the Currency (OCC), Housing & Urban Development - Dept of (HUD), 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. |
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Michael |
Decker |
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Lisa |
Bleier |
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Bradley |
Edgell |
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Kevin |
Carroll |
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Kyle |
Brandon |
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Carter |
McDowell |
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Dave |
Oxner |
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Melissa |
MacGregor |
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Chris |
Killian |
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Payson |
Peabody |
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Peter |
Matheson |
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Lindsey |
Keljo |
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Katie |
Malone |
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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
H.R. 2916 (Charities Helping Americans Regularly Throughout the Year Act of 2017);
H.R. 5003 (To amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds);
H.R. 6250 (To amend the Internal Revenue Code of 1986 to provide for lifelong learning accounts, and for other purposes);
H.R. 6444 (Capital Gains Inflation Relief Act);
S. 1343 (Charities Helping Americans Regularly Throughout the Year Act of 2017);
S. 3145 (A bill to amend the Internal Revenue Code of 1986 to provide for lifelong learning accounts, and for other purposes);
Tax treatment of capital gains and dividends;
Tax classification of independent contractors;
United States individual and business taxation;
Tax reform legislation;
Issues related to taxation of securities transactions, including market to market for derivatives;
Chapters 3 and 4 of Subtitle A of the Internal Revenue Code (responsibilities of financial institutions);
Proposals to modify tax incentives for retirement savings and investment;
Infrastructure tax;
Executive Order 13789 (Identifying and Reducing Tax Regulatory Burdens);
Regulations under the Foreign Account Taxpayer Compliance Act (FATCA);
Regulations implementing P.L. 115-97, Dec. 22, 2017, including regulations and guidance relating to IRC Sections 59A, 162(f), 163(j), 451, 199A, 512, 904, 951A, 958, and 1446;
Rev. Rul. 2018-24 relating to the proposed exchange of Freddie Mac Participation Certificates for
Universal Mortgage Backed Securities;
Taxation of contract modifications associated with transition from LIBOR to alternative reference rates, including SOFR;
Regulations under IRC Sec. 871(m) and IRC Sec. 385;
International tax reform;
Legislation to modify IRC Sec 1446(f) relating to withholding on partnership interests that are not publicly traded;
Technical and policy modifications to P.L. 115-97.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, Natl Security Council (NSC), 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. |
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Payson |
Peabody |
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Carter |
McDowell |
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Bradley |
Edgell |
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Michael |
Decker |
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Dave |
Oxner |
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Lisa |
Bleier |
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John |
Maurello |
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Tracy |
Eichler |
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Jillian |
Enoch |
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Lindsey |
Keljo |
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Katie |
Malone |
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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
H.R. 355 (Protecting American Families' Retirement Advice Act);
H.R. 854 (Retirement Security for American Workers Act);
H.R. 2823 (Affordable Retirement Advice for Savers Act);
H.R. 3857 (PASS Act of 2017);
H.R. 4158 (Retirement Plan Modernization Act);
H.R. 4189 (IRA Preservation Act of 2017);
H.R. 4523 (Automatic Retirement Plan Act of 2017);
H.R. 4604 (Increasing Access to a Secure Retirement Act of 2017);
H.R. 4610 (Receiving Electronic Statements To Improve Retiree Earnings Act);
H.R. 5282 (Retirement Enhancement and Savings Act of 2018);
S. 178 (Elder Abuse Prevention and Prosecution Act);
S. 1321 (Affordable Retirement Advice Protection Act);
S. 2526 (Retirement Enhancement and Savings Act of 2018);
DOL ERISA Fiduciary Duty Rulemaking;
Tax incentives for retirement savings;
SEC proposed Regulation Best Interest.
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. |
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Lisa |
Bleier |
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Kyle |
Brandon |
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Carter |
McDowell |
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Michael |
Decker |
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Bradley |
Edgell |
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Dave |
Oxner |
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Tracy |
Eichler |
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Jillian |
Enoch |
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John |
Maurello |
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Katie |
Malone |
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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) |