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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 1100 Vermont Avenue, NW |
Address2 | 10th Floor |
| City | Washington |
State | DC |
Zip Code | 20005 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 285494-12
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6. House ID# 369900000
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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: Wayne Chopus, President & CEO |
Date | 7/22/2024 1:42:34 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 INS
16. Specific lobbying issues
DOL - EBSA - Implementation of the Consolidated Appropriations Act, 2023, Division T - SECURE 2.0 Act of 2022 (Public Law No: 117-328).
DOL - EBSA - Request for Information-SECURE 2.0 Reporting and Disclosure (RIN 1210-AC23).
DOL - Wage and Hour Division - Final Rule - Employee or Independent Contractor Classification Under the Fair Labor Standards Act - 87 FR 62218 (RIN 1235-AA43).
DOL - Proposed Rule on Automatic Portability Transactions Exemption - 29 CFR 255 (RIN 1210-AC21).
DOL- EBSA - Final Rule - Retirement Security Rule: Definition of an Investment Fiduciary - 29 CFR 2510, RIN 1210-AC02.
DOL-EBSA- FINAL Amendments to PTE 2020-02 - 29 CFR 2550, RIN 1210-ZA32.
DOL- EBSA - FINAL Amendments to PTE 84-24 - 29 CFR 2550, RIN 1210-ZA33.
DOL-EBSA- FINAL Amendments to PTEs 75-1, 77-4, 80-83, 83-1, and 86-128 - 29 CFR 2550, RIN 1210-ZA34.
Elder Justice Reauthorization and Modernization Act of 2021 (S.1198/H.R.2718 - 118th Congress).
Legislation and rulemaking affecting annuities, variable life products and retirement savings including Biden Administration and Congressional proposals on tax reform, ERISA, and securities laws.
Legislation to maintain and protect the diverse array of retirement plan structures.
Legislation to provide favorable tax treatment for guaranteed lifetime income.
Legislation to provide technical corrections and extension of effective dates to implement the SECURE 2.0 Act.
Proposals at the Department of Labor for increasing access to guaranteed, protected lifetime solutions.
Proposals at the Department of Treasury/IRS for increasing access to guaranteed, protected lifetime income solutions.
SEC - Implementation and Enforcement of Regulation BI and Form CRS.
SEC - Implementation of Public Law No: 117-328, the Consolidated Appropriations Act, 2023, Division AA - Financial Services Matters, Title I-Registration for Index linked Annuities, Sec. 101. Parity for Registered Index-Linked Annuities Regarding Registration Rules.
SEC - Proposed Rule - Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers - 17 CFR 240 and 17 CFR 275, RIN: 3235-AN00 and RIN: 3235-AN14.
SEC - Proposed Rule Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social, and Governance Investment Practices - 17 CFR Part 200, 230, 232, 239, 249, 274, and 279 (RIN: 3235-AM96).
SEC - Proposed Rule Enhancement and Standardization of Climate-Related Disclosures for Investors - 17 CFR 210, 229, 232, 239, and 249 (RIN 3235-AM87).
SEC - Stay Order - Final Rule on Enhancement and Standardization of Climate-Related Disclosures during pending litigation.
SEC - Final Rule - Registration for Index-Linked Annuities and Registered Market Value Adjustment Annuities; Amendments to Form N-4 for Index-Linked Annuities, Registered Market Value Adjustment Annuities, and Variable Annuities; Other Technical Amendments - 17 CFR Parts 230, 232, 239, and 274, RIN 3235-AN30.
SEC/Treasury - Joint Proposed Rule by SEC & FinCEN - Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - 17 CFR 275, 31 CFR 1032, RIN 1506-AB66, RIN 3235-AN34.
Treasury - Request for Information on Uses, Opportunities, and Risks of Artificial Intelligence on Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector - 89 FR 50048.
The Auto Reenroll Act (S.2517/H.R.4924 - 118th Congress).
The Data Privacy Act (H.R.1165 - 118th Congress).
The Empowering States to Protect Seniors from Bad Actors Act (H.R.5914 - 117th Congress).
The E-SIGN Modernization Act of 2022 (S.3715 - 117th Congress).
The General Accounts Product Clarifications Act (H.R.9515 - 117th Congress).
The Lifetime Income for Employees Act of 2023 (H.R.3942 - 118th Congress).
The Richard L. Trumka Protecting the Right to Organize (PRO) Act of 2023 (S.567/H.R.20 - 118th Congress).
The SAFER Banking Act (S.2860 - 118th Congress).
The Secure And Fair Enforcement (SAFE) Banking Act of 2023 (S.1323/H.R.2891 - 118th Congress).
The Securing and Enabling Commerce Using Remote and Electronic (SECURE) Notarization Act of 2023 (S.1212/H.R.1059 - 118th Congress).
The Financial Fitness Act (H.R.8944-118th Congress).
Departments of Labor, Health And Human Services, And Education, And Related Agencies Appropriations Bill, FY 2025 Subcommittee Mark.
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Amendment to PTE 2020-02" (H.J.Res.140-118th Congress).
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Amendment to PTE 84-24" (H.J.Res.141-118th Congress).
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Amendment to PTEs 75-1, 77-4, 80-83, 83-1, and 86-128)" (H.J.Res.143-118th Congress).
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Retirement Security Rule: Definition of an Investment Advice Fiduciary" (H.J.Res.142-118th Congress).
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Securities & Exchange Commission (SEC), Treasury - Dept of, Internal Revenue Service (IRS), 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 |
Paul |
Richman |
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John |
Jennings |
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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
Amends IRS Code to establish Auto Reenrollment Tax Credit (S.2512 - 118th Congress).
DOL - EBSA - Implementation of the Consolidated Appropriations Act, 2023, Division T - SECURE 2.0 Act of 2022 (Public Law No: 117-328).
DOL - EBSA - Request for Information - SECURE 2.0 Reporting and Disclosure (RIN 1210-AC23).
DOL - Implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94).
DOL - Wage and Hour Division - Final Rule - Employee or Independent Contractor Classification Under the Fair Labor Standards Act - 87 FR 62218 (RIN 1235-AA43).
DOL - Proposed Rule on Automatic Portability Transactions Exemption - 29 CFR 255 (RIN 1210-AC21).
DOL Guidance on Pension‑Linked Emergency Savings Accounts.
DOL- EBSA - Final Rule - Retirement Security Rule: Definition of an Investment Fiduciary - 29 CFR 2510, RIN 1210-AC02.
DOL-EBSA- FINAL Amendments to PTE 2020-02 - 29 CFR 2550, RIN 1210-ZA32.
DOL- EBSA - FINAL Amendments to PTE 84-24 - 29 CFR 2550, RIN 1210-ZA33.
DOL-EBSA- FINAL Amendments to PTEs 75-1, 77-4, 80-83, 83-1, and 86-128 - 29 CFR 2550, RIN 1210-ZA34.
Joint Resolution providing for congressional disapproval of the Department of Labors Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights Rule (S.J.Res.8/H.J. Res.30 - 118th Congress).
Legislation and rulemaking affecting 403(b) retirement plans and federal and state regulations governing their administration and operation.
Legislation and rulemaking affecting annuities, variable life products and retirement savings including Biden Administration and Congressional proposals on tax reform, ERISA, and securities laws.
Legislation establishing a federal regulatory framework to oversee the cryptocurrency market in and use of cryptocurrency in retirement plans.
Legislation to clarify Form 5500 reporting requirement for retirement plans filing under a Group of Plans.
Legislation to maintain and protect the diverse array of retirement plan structures.
Legislation to prohibit IRSs use of private debt collection agencies for individuals over the age of 65.
Legislation to promote, preserve and maintain tax-deferred treatment of retirement savings.
Legislation to provide favorable tax treatment for guaranteed lifetime income.
Legislation to provide technical corrections and extension of effective dates to implement the SECURE 2.0 Act.
Proposals at the Department of Labor for increasing access to guaranteed, protected lifetime solutions.
Proposals at the Department of Treasury/IRS for increasing access to guaranteed, protected lifetime income solutions.
SEC - Final Rule Investment Company Names - 17 CFR Parts 232, 270 and 274 (RIN: 3235-AM72).
SEC - FINRA - Proposed Rule Change to Extend the Effectiveness of Temporary FINRA Rule 3110.17 - SR-FINRA-2021-023.
SEC - Implementation and Enforcement of Regulation BI and Form CRS.
SEC - Implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94).
SEC - Implementation of Public Law No: 117-328, the Consolidated Appropriations Act, 2023, Division AA - Financial Services Matters, Title I-Registration for Index linked Annuities, Sec. 101. Parity for Registered Index-Linked Annuities Regarding Registration Rules.
SEC - Proposed Rule - Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers - 17 CFR 240 and 17 CFR 275 (RIN: 3235-AN00 and RIN: 3235-AN14).
SEC - Proposed Rule - Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting, 17 CFR Parts 270 and 274 (RIN 3235-AM98).
SEC - Proposed Rule - Safeguarding Advisory Client Assets - 17 CFR Parts 275 and 279 (RIN 3235-AM32).
SEC - Proposed Rule Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social, and Governance Investment Practices - 17 CFR Part 200, 230, 232, 239, 249, 274, and 279 (RIN: 3235-AM96).
SEC - Proposed Rule Enhancement and Standardization of Climate-Related Disclosures for Investors - 17 CFR 210, 229, 232, 239, and 249 (RIN 3235-AM87).
SEC - Request for Information and Comments on Broker-Dealer and Investment Adviser Digital Engagement Practices, Related Tools and Methods, and Regulatory Considerations and Potential Approaches; Information and Comments on Investment Adviser Use of Technology to Develop and Provide Investment Advice - (Release Nos. 34-92766; IA-5833; File No. S7-10-21) (RIN 3235-AN00).
SEC - Stay Order - Final Rule on Enhancement and Standardization of Climate-Related Disclosures during pending litigation.
SEC - Final Rule - Registration for Index-Linked Annuities and Registered Market Value Adjustment Annuities; Amendments to Form N-4 for Index-Linked Annuities, Registered Market Value Adjustment Annuities, and Variable Annuities; Other Technical Amendments - 17 CFR Parts 230, 232, 239, and 274, RIN 3235-AN30.
The Advice and Consent Act (S. 2727 - 118th Congress).
The Auto Reenroll Act (S.2517/H.R.4924 - 118th Congress).
The Data Privacy Act (H.R.1165 - 118th Congress).
The Department of Labor Succession Act (H.R.4957 - 118th Congress).
The Empowering States to Protect Seniors from Bad Actors Act (H.R.5914 - 117th Congress).
The E-SIGN Modernization Act of 2022 (S.3715 - 117th Congress).
The Financial Freedom Act of 2023 (S.427/H.R.1177 - 118th Congress).
The Financial Innovation and Technology for the 21st Century Act (H.R.4763 - 118th Congress).
The General Accounts Product Clarifications Act (H.R.9515 - 117th Congress).
The Lifetime Income for Employees Act of 2023 (H.R.3942 - 118th Congress).
The Lummis-Gillibrand Responsible Financial Innovation Act (S.2281 - 118th Congress).
The No Discrimination in My Benefits Act (H.R.5338 - 118th Congress).
The Portable Benefits for Independent Workers Pilot Program Act (S.1696/H.R.3482 - 118th Congress).
The Providing Complete Information to Retirement Investors Act (H.R.5340 - 118th Congress).
The RETIRE Act (H.R. 5339 - 118th Congress).
The Retirement Fairness for Charities and Educational Institutions Act of 2023 (H.R.3063 - 118th Congress).
The Retirement Proxy Protection Act (H.R.5337 - 118th Congress).
The Retirement Savings for Americans Act of 2022 (S.5271/H.R.9462 - 117th Congress).
The Richard L. Trumka Protecting the Right to Organize (PRO) Act of 2023 (S.567/H.R.20 - 118th Congress).
The SAFER Banking Act (S.2860 - 118th Congress).
The Secure And Fair Enforcement (SAFE) Banking Act of 2023 (S.1323/H.R.2891 - 118th Congress).
The Securing and Enabling Commerce Using Remote and Electronic (SECURE) Notarization Act of 2023 (S.1212/H.R.1059 - 118th Congress).
The Senior Security Act of 2023 (S.955/H.R.2593 - 118th Congress).
The Small Business Tax Fairness Act (S.2387 - 117th Congress).
The Small Businesses Add Value for Employees (SAVE) Act (H.R.4637 - 115th Congress).
To amend the Internal Revenue Code of 1986 to permit the rollover contributions from Roth IRAs to designated Roth accounts (H.R.6757 - 118th Congress).
The Expanding Access to Retirement Savings for Caregivers Act (H.R.6772 - 118th Congress).
The Helping Young Americans Save for Retirement Act (S.3305 - 118th Congress).
The Automatic IRA Act of 2024 (H.R.7293-118th Congress).
The Elder Justice Reauthorization and Modernization Act of 2023 (S.1198/H.R.2718-118th Congress).
The Ensuring Sound Guidance Act (S.2282/H.R.4237 - 118th Congress).
The Expanding Access to Capital Act (H.R.2799-118th Congress).
The Further Consolidated Appropriations Act, 2024 (S.2309/H.R.2882 - 118th Congress).
The Improving Disclosure for Investors Act (S.3815/H.R.1807-118th Congress).
The Financial Fitness Act (H.R.8944-118th Congress).
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Retirement Security Rule: Definition of an Investment Advice Fiduciary" (H.J.Res.142-118th Congress).
Departments of Labor, Health And Human Services, And Education, And Related Agencies Appropriations Bill, FY 2025 Subcommittee Mark.
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Amendment to PTE 2020-02" (H.J.Res.140-118th Congress).
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Amendment to PTE 84-24" (H.J.Res.141-118th Congress).
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Amendment to PTEs 75-1, 77-4, 80-83, 83-1, and 86-128)" (H.J.Res.143-118th Congress).
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Retirement Security Rule: Definition of an Investment Advice Fiduciary" (H.J.Res.142-118th Congress).
Treasury - IRS - Request for SECURE 2.0 Guidance.
Treasury - IRS - Notice 2023-54 - Transition Relief and Guidance Relating to Certain Required Minimum Distributions.
Treasury - IRS - Implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94).
Treasury - IRS - Implementation of Public Law No: 117-328, the Consolidated Appropriations Act, 2023, Division T - SECURE 2.0 Act of 2022.
Treasury - IRS - Notice 2023-62 - Guidance on Section 603 of the SECURE 2.0 Act with Respect to Catch-Up Contributions.
Treasury - IRS - Proposed Rule Required Minimum Distributions - 87 FR 10504, 26 CFR 1 and 26 CFR 54, REG-105954-20 (RIN: 1545-BP82).
Treasury - IRS - Proposed Rulemaking: Multiple Employer Plans - 26 CFR Part 1 [REG-121508-18] (RIN 1545-BO97).
Treasury - IRS - Guidance on Anti-Abuse Rules Under Sec. 127 of SECURE 2.0 and Other Issues for Pension-Linked Emergency Savings Accounts.
Treasury - Request for Information on Financial Inclusion - 88 FR 88702 - Treas-Do-2023-0014.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Securities & Exchange Commission (SEC), Treasury - Dept of, Internal Revenue Service (IRS), Labor - Dept of (DOL), Government Accountability Office (GAO)
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 |
Paul |
Richman |
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|
|
John |
Jennings |
|
|
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
Amends IRS Code to establish Auto Reenrollment Tax Credit (S.2512 - 118th Congress).
DOL - EBSA - Implementation of the Consolidated Appropriations Act, 2023, Division T - SECURE 2.0 Act of 2022 (Public Law No: 117-328).
DOL - Implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94).
DOL Guidance on Pension‑Linked Emergency Savings Accounts.
Legislation and rulemaking affecting 403(b) retirement plans and federal and state regulations governing their administration and operation.
Legislation and rulemaking affecting annuities, variable life products and retirement savings including Biden Administration and Congressional proposals on tax reform, ERISA, and securities laws.
Legislation to prohibit IRSs use of private debt collection agencies for individuals over the age of 65.
Legislation to promote, preserve and maintain tax-deferred treatment of retirement savings.
Legislation to provide favorable tax treatment for guaranteed lifetime income.
Legislation to provide technical corrections and extension of effective dates to implement the SECURE 2.0 Act.
Proposals at the Department of Labor for increasing access to guaranteed, protected lifetime solutions.
Proposals at the Department of Treasury/IRS for increasing access to guaranteed, protected lifetime income solutions.
SEC - Implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94).
SEC/Treasury - Joint Proposed Rule by SEC & FinCEN - Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - 17 CFR 275, 31 CFR 1032, RIN 1506-AB66, RIN 3235-AN34
The Auto Reenroll Act (S.2517/H.R.4924 - 118th Congress).
The Lifetime Income for Employees Act of 2023 (H.R.3942 - 118th Congress).
The Portable Benefits for Independent Workers Pilot Program Act (S.1696/H.R.3482 - 118th Congress).
The Retirement Savings for Americans Act of 2022 (S.5271/H.R.9462 - 117th Congress).
The Securing and Enabling Commerce Using Remote and Electronic (SECURE) Notarization Act of 2023 (S.1212/H.R.1059 - 118th Congress).
The Small Business Tax Fairness Act (S.2387 - 117th Congress).
The Small Businesses Add Value for Employees (SAVE) Act (H.R.4637 - 115th Congress).
To amend the Internal Revenue Code of 1986 to permit the rollover contributions from Roth IRAs to designated Roth accounts (H.R.6757 - 118th Congress).
The Expanding Access to Retirement Savings for Caregivers Act (H.R.6772 - 118th Congress).
The Helping Young Americans Save for Retirement Act (S.3305 - 118th Congress).
The Automatic IRA Act of 2024 (H.R.7293-118th Congress).
The Further Consolidated Appropriations Act, 2024 (S.2309/H.R.2882 - 118th Congress).
Treasury - IRS - Request for SECURE 2.0 Guidance.
Treasury - IRS - Notice 2023-54 - Transition Relief and Guidance Relating to Certain Required Minimum Distributions.
Treasury - IRS - Implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94).
Treasury - IRS - Implementation of Public Law No: 117-328, the Consolidated Appropriations Act, 2023, Division T - SECURE 2.0 Act of 2022.
Treasury - IRS - Notice 2023-62 - Guidance on Section 603 of the SECURE 2.0 Act with Respect to Catch-Up Contributions.
Treasury - IRS - Proposed Rule Required Minimum Distributions - 87 FR 10504, 26 CFR 1 and 26 CFR 54, REG-105954-20 (RIN: 1545-BP82).
Treasury - IRS - Proposed Rulemaking: Multiple Employer Plans (26 CFR Part 1 [REG-121508-18] (RIN 1545-BO97).
Treasury - IRS - Guidance on Anti-Abuse Rules Under Sec. 127 of SECURE 2.0 and Other Issues for Pension-Linked Emergency Savings Accounts.
Treasury - IRS - Proposed Rule for Long-Term, Part-Time Employees - 26 CFR 1 (RIN 1545-BQ70).
Treasury-FinCEN - Proposed Rule on AML/CFT Program and Suspicious Activity Report Filing Requirements for RIAs and Exempt Reporting Advisers.
Treasury - Request for Information on Uses, Opportunities, and Risks of Artificial Intelligence on Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector - 89 FR 50048
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Securities & Exchange Commission (SEC), Treasury - Dept of, Internal Revenue Service (IRS), Labor - Dept of (DOL), Government Accountability Office (GAO)
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 |
Paul |
Richman |
|
|
|
John |
Jennings |
|
|
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
DOL - Wage and Hour Division - Final Rule - Employee or Independent Contractor Classification Under the Fair Labor Standards Act - 87 FR 62218 (RIN 1235-AA43).
DOL - Proposed Rule on Automatic Portability Transactions Exemption - 29 CFR 255 (RIN 1210-AC21).
DOL- EBSA - Final Rule - Retirement Security Rule: Definition of an Investment Fiduciary - 29 CFR 2510, RIN 1210-AC02.
DOL-EBSA- FINAL Amendments to PTE 2020-02 - 29 CFR 2550, RIN 1210-ZA32.
DOL- EBSA - FINAL Amendments to PTE 84-24 - 29 CFR 2550, RIN 1210-ZA33.
DOL-EBSA- FINAL Amendments to PTEs 75-1, 77-4, 80-83, 83-1, and 86-128 - 29 CFR 2550, RIN 1210-ZA34.
Legislation and rulemaking affecting annuities, variable life products and retirement savings including Biden Administration and Congressional proposals on tax reform, ERISA, and securities laws.
Legislation establishing a federal regulatory framework to oversee the cryptocurrency market in and use of cryptocurrency in retirement plans.
Legislation to provide favorable tax treatment for guaranteed lifetime income.
Proposals at the Department of Labor for increasing access to guaranteed, protected lifetime solutions.
Proposals at the Department of Treasury/IRS for increasing access to guaranteed, protected lifetime income solutions.
SEC - Final Rule Investment Company Names (17 CFR Parts 232, 270 and 274 (RIN: 3235-AM72).
SEC - Implementation and Enforcement of Regulation BI and Form CRS.
SEC - Implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94).
SEC - Implementation of Public Law No: 117-328, the Consolidated Appropriations Act, 2023, Division AA - Financial Services Matters, Title I-Registration for Index linked Annuities, Sec. 101. Parity for Registered Index-Linked Annuities Regarding Registration Rules.
SEC - Proposed Rule - Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers - 17 CFR 240 and 17 CFR 275 (RIN: 3235-AN00 and RIN: 3235-AN14).
SEC - Proposed Rule - Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting - 17 CFR Parts 270 and 274 (RIN 3235-AM98).
SEC - Proposed Rule - Safeguarding Advisory Client Assets - 17 CFR Parts 275 and 279 (RIN 3235-AM32).
SEC - Proposed Rule Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social, and Governance Investment Practices - 17 CFR Part 200, 230, 232, 239, 249, 274, and 279 (RIN: 3235-AM96).
SEC - Proposed Rule Enhancement and Standardization of Climate-Related Disclosures for Investors - 17 CFR 210, 229, 232, 239, and 249 (RIN 3235-AM87).
SEC - Request for Information and Comments on Broker-Dealer and Investment Adviser Digital Engagement Practices, Related Tools and Methods, and Regulatory Considerations and Potential Approaches; Information and Comments on Investment Adviser Use of Technology to Develop and Provide Investment Advice - (Release Nos. 34-92766; IA-5833; File No. S7-10-21) (RIN 3235-AN00).
SEC - Stay Order - Final Rule on Enhancement and Standardization of Climate-Related Disclosures during pending litigation.
SEC/Treasury - Joint Proposed Rule by SEC & FinCEN - Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - 17 CFR 275, 31 CFR 1032, RIN 1506-AB66, RIN 3235-AN34.
SEC - Final Rule - Registration for Index-Linked Annuities and Registered Market Value Adjustment Annuities; Amendments to Form N-4 for Index-Linked Annuities, Registered Market Value Adjustment Annuities, and Variable Annuities; Other Technical Amendments - 17 CFR Parts 230, 232, 239, and 274, RIN 3235-AN30.
The Data Privacy Act (H.R.1165 - 118th Congress).
The Empowering States to Protect Seniors from Bad Actors Act (H.R.5914 - 117th Congress).
The E-SIGN Modernization Act of 2022 (S.3715 - 117th Congress).
The Financial Freedom Act of 2023(S.427/H.R.1177 - 118th Congress).
The Financial Innovation and Technology for the 21st Century Act (H.R.4763 - 118th Congress).
The Improving Corporate Governance Through Diversity Act of 2023 (S.2007/H.R.4177 - 118th Congress).
The Lummis-Gillibrand Responsible Financial Innovation Act (S.2281 - 118th Congress).
The No Discrimination in My Benefits Act (H.R.5338 - 118th Congress).
The Providing Complete Information to Retirement Investors Act (H.R.5340 - 118th Congress).
The RETIRE Act (H.R.5339 - 118th Congress).
The Retirement Fairness for Charities and Educational Institutions Act of 2023 (H.R.3063 - 118th Congress).
The Retirement Proxy Protection Act (H.R.5337 - 118th Congress).
The SAFER Banking Act (S.2860 - 118th Congress).
The Secure And Fair Enforcement (SAFE) Banking Act of 2023 (S.1323/H.R.2891 - 118th Congress).
The Senior Security Act of 2023 (S.955/H.R.2593 - 118th Congress).
The Elder Justice Reauthorization and Modernization Act of 2023 (S.1198/H.R.2718-118th Congress).
The Ensuring Sound Guidance Act (S.2282/H.R.4237 - 118th Congress).
The Expanding Access to Capital Act (H.R.2799-118th Congress).
The Further Consolidated Appropriations Act, 2024 (S.2309/H.R.2882 - 118th Congress).
The Improving Disclosure for Investors Act (S.3815/H.R.1807-118th Congress).
Departments of Labor, Health And Human Services, And Education, And Related Agencies Appropriations Bill, FY 2025 Subcommittee Mark.
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Amendment to PTE 2020-02" (H.J.Res.140-118th Congress).
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Amendment to PTE 84-24" (H.J.Res.141-118th Congress).
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Amendment to PTEs 75-1, 77-4, 80-83, 83-1, and 86-128)" (H.J.Res.143-118th Congress).
Resolution providing for congressional disapproval under chapter 8 of title 5, USC, of the rule submitted by the DOL relating to "Retirement Security Rule: Definition of an Investment Advice Fiduciary" (H.J.Res.142-118th Congress).
Treasury - IRS - Implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94).
Treasury - Request for Information on Financial Inclusion - 88 FR 88702 - Treas-Do-2023-0014.
Treasury - Request for Information on Uses, Opportunities, and Risks of Artificial Intelligence on Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector - 89 FR 50048.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Securities & Exchange Commission (SEC), Treasury - Dept of, Internal Revenue Service (IRS), 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 |
Paul |
Richman |
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John |
Jennings |
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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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State |
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Zip Code |
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21. Client new principal place of business (if different than line 20)
| City |
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State |
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Zip Code |
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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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3 |
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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) |