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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 1775 Pennsylvania Avenue, NW |
Address2 | Suite 625 |
| City | Washington |
State | DC |
Zip Code | 20006-4758 |
Country | USA |
3. Principal place of business (if different than line 2)
| City | Washington |
State | DC |
Zip Code | 20006-4758 |
Country | USA |
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5. Senate ID# 401103239-12
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6. House ID# 425350000
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| TYPE OF REPORT | 8. Year | 2016 |
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. | ||||||||
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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 |
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| Signature | Digitally Signed By: Thomas C. McCrocklin |
Date | 1/23/2017 10:04:03 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 FIN
16. Specific lobbying issues
1. Collateralized Loan Obligations (CLOs) - General issues concerning changes to the compliance requirements for CLOs (H.R. 4166, Expanding Proven Financing for American Employers Act - supporting a qualified CLO retention regime as an alternative to the final risk-retention rules).
2. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, Step-In risk, and efforts to create "Simple, Transparent and Comparable" securitizations).
3. Marketplace Lending - General issues concerning securitization regulation as it relates to marketplace lending prior to making new regulatory or legislative decisions for this new form of funding.
4. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS classes, such as auto, credit card, equipment lease and student loans.
5. General Dodd-Frank Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention and the Liquidity Coverage Ratio (LCR); reform proposals as they relate to securitization and capital markets generally; H.R. 5983, The Financial CHOICE Act of 2016, specifically provisions related to risk retention and arbitration clauses in financial contracts.
6. Proposed rulemaking concerning single counterparty credit limits.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Treasury - Dept of, Securities & Exchange Commission (SEC), Federal Housing Finance Agency (FHFA), 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 |
Thomas |
McCrocklin |
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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
1. GSE Reform - General issues related to the preservation of a federal guaranty and the TBA (To-Be-Announced) market; support for increased participation of private capital; discussions/proposals related to credit risk transfer (CRT)
2. General Housing Finance Issues - Issues concerning FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP), including increased risk sharing, transparency, and industry participation.
3. Mortgage REITs - H.R. 6487, The Taxpayer Protection and Market Access for Mortgage Finance Act, specifically provisions supporting the allowance of mortgage REITs to fully invest in credit-risk sharing transactions created by either Fannie Mae or Freddie Mac.
4. Private-Label Securities (PLS) - General issues related to support for industry agreed-upon solutions arrived at in its RMBS 3.0 project for inclusion as part of any new structure for the return of private-label mortgage-backed securities; issues related to the facilitation of deal agent initiatives (PLS initiatives).
5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Housing Finance Agency (FHFA), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC)
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 |
Thomas |
McCrocklin |
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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
General issues concerning international efforts to establish "high-quality securitization" criteria.
Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, the Fundamental Review of the Trading Book and Step-in risk).
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, 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 |
Thomas |
McCrocklin |
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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 |