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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 1501 M STREET, N.W., Suite 600 |
Address2 |
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| City | WASHINGTON |
State | DC |
Zip Code | 20005-1700 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 4675-12
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6. House ID# 312420000
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| 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 |
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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: Nicholas Otto |
Date | 7/12/2024 4:54:49 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 RET
16. Specific lobbying issues
Technical corrections to SECURE 2.0
Automatic re-enrollment for defined contribution plan participants and reducing the participation age to 18
Collective Investment Trusts (CITs) and insurance company separate accounts for IRC Section 403(b) plans
Pleading standards and retirement plan litigation
ERISA preemption, state run automatic-IRA programs
Defined benefit and defined contribution plan issues
Tax incentives treatment of retirement plans
Retiree health benefits
Retirement savings and independent contractors and gig workers
Pension plan de-risking
American Privacy Rights Act
Fiduciary rule affecting retirement plans
Retirement plan audits
Information Collection Request (ICR) regarding missing plan participants
Roth catch-up and Roth optional provisions guidance
SECURE 2.0 guidance
Basel III endgame, treatment of reserves of financial institutions and its impact on pension and retirement plans
Pension Benefit Guaranty Corporation (PBGC) premiums and treatment of overfunded defined benefit plans and other accounts
Notices and disclosures for retirement plans
Emergency savings programs
H.R. 7293, the Automatic IRA Act; H.R. 6007, S. 4398, the RISE Act
Cybersecurity
Predictive Data Analytics
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Labor - Dept of (DOL), Internal Revenue Service (IRS), Pension Benefit Guaranty Corporation (PBGC), Treasury - Dept of, Office of the Comptroller of the Currency (OCC), 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 |
James |
Klein |
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Lynn |
Dudley |
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Diann |
Howland |
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Pension Policy Director for the Senate Health Education Labor and Pensions Committee, Pension Policy Advisor of the Senate Finance Committee |
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Jill |
Randolph |
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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
ERISA Preemption
Health care transparency
Pharmacy Benefit Manufacturers (PBMs), drug cost transparency, and rebates, medical management
Tax treatment of employer-sponsored health care plans
End-stage renal disease and Medicare secondary payer
American Privacy Rights Act
Hospital consolidation and billing practices
Health Savings Accounts (HSAs) and High-deductible health plans (HDHPs) and tax treatment
Surprise medical billing - Extension of relief for calculating the qualifying payment amount under the No Surprises Act
Telehealth expansion and permanency
Licensing of health care providers across state lines
Value-driven health care
Paid leave - federal and state law considerations
Mental health parity regulations and audits
Voluntary Employees Beneficiary Association (VEBA) use of excess assets
Health care non-discrimination rules under the Affordable Care Act
Fixed indemnity insurance requirements and tax treatment
Guidance related to the definition of essential health benefits
American Privacy Rights Act
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Labor - Dept of (DOL), Health & Human Services - Dept of (HHS), Treasury - Dept of, Internal Revenue Service (IRS), Federal Trade Commission (FTC)
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 |
James |
Klein |
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Diann |
Howland |
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Pension Policy Director for the Senate Health Education Labor and Pensions Committee, Pension Policy Advisor of the Senate Finance Committee |
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Jill |
Randolph |
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Ilyse |
Schuman |
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Senate HELP Committee, Chief Labor Counsel, Minority Staff Director |
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Kathryn |
Johnson |
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Attorney advisor, Office of Benefits Tax Counsel at the U.S. Department of Treasury; attorney, Office of Chief Counsel at the Internal Revenue Service |
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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4 |
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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) |