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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 CONNECTICUT AVENUE, NW, #950 |
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City | WASHINGTON |
State | DC |
Zip Code | 20036 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 14611-12
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6. House ID# 333770000
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TYPE OF REPORT | 8. Year | 2010 |
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 | |||||||||
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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: Peter A. Lefkin, Senior Vice President, Government and External Affairs |
Date | 04/19/2010 |
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
Financial Services Regulatory Reform: Lobby against certain provision in the Restoring American Financial Stability Act of 2010 that would affect insurers, including a resolution fund for failing firms. worked with other foreign owned U.S. Insurance companies to provide protection against potential discrimination against US affiliates.
Also, lobby for robust and effective Office of National Insurance.
Also, monitored member positions in the House on H.R. 4173, the Wall Street Reform and Consumer Protection Act of 2009,
which passed the House of Representatives in December.
Long Term Care Insurance: through trade association to oppose inclusion of Class Act, which would create a federal long-term care insurance program, in health care reform package.
Annuities/Suitability: Advocated against rule 151A, adapted by the U.S. Securities and Exchange Commission. Lobbied both
Congress and the SEC. This rule would make certain fixed annuities subject to federal securities laws.
Holocaust insurance issues/ICHEIC: Lobbied against the possible reintroduction of legislation that would create a new cause of action against U.S. insurance companies with European affiliates that may have written life insurance policies involving Holocaust victims. The bill could also require any European insurer with policies written between 1990 and 1945 that may have involved holocaust victims to disclose all files on the policies, including names, to the U.S.
Credit-based insurance scores: Lobbied against the reintroduction of legislation that would restrict the ability of personal lines insurers to used credit information of underwriting or setting rates.
McCarran-Ferguson Reform: follow and oppose the inclusion of medical malpractice insurance in H.R. 4626, The Health Insurance Fair Competition Act, which would repeal the McCarran-Ferguson Act for health insurance. The McCarran-Ferguson Act provides insurers a limited exemption from federal antitrust law. Also oppose any similar efforts in the Senate.
Flood and national catastrophe insurance: In participation with a coalition, lobbied House and Senate staff to oppose legislation that would expand the national Flood Insurance Program to include wind insurance, specifically H.R. 1264 the Multiple Peril Insurance Act of 2009. Also lobbied against the reintroduction of legislation to create a national back stop for natural catastrophe insurance. Also incorporated climate change arguments into natural catastrophe insurance lobbying efforts and promoted Fireman's Fund green products with Congressional staff and S.886, the catastrophe Obligation Guarantee Act. Lobbied for H.R.3026, H.R. 3027 and H.R. 3028 which funds insurance grants and loans for federal mitigation programs.
Climate and energy legislation: Monitored the progress of HR 2454, the American clean Energy and Security Act of 2009.
Also, through consultants, lobbied for passage of"Home Star" legislation to provide incentives for residential energy effiency retrofits. Also, lobbied for "building Star" legislation, which would provide similar incentives for community building energy efficient retrofits.
Municipal bond legislation: Monitor municipal bond legislation, specifically HR 2589, the Municipal bond Insurance Enhancement Act of 2009, HR 25249, Municipal Bond Fairness Act, Municipal Bond Liquidity Act; and Municipal Financial Advisors Regulation Act.
Right to Repair Act, HR 2057: support for bill which would enhance consumers' ability to take automobiles to independent shops for repairs.
Broker-dealer regulatory reform: Monitor financial regulatory reform as it relates to broker-dealer and their existing regulation under the financial Industry Regulatory Authority (FINRA).
Surplus insurance lines: Monitor progress and support HR 2571, the Nonadmitted and Reinsurance Reform Act and its inclusion in financial services reform legislation.
State jurisdiction over annuity products: Support the continuing of state jurisdiction over fixed annuities: H.R. 2733, Fixed Indexed Annuities and Insurance Products classification Act of 2009.
Agents and Brokers: Support NARABII: H.R. 2554, the National Association of registered Agents and Brokers Reform Act of 2009.
Annuities: Support HR 2748, the Retirement Security Needs Lifetime Payment Act of 2009 and monitor through trade association.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Risk Management Agency, 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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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Counsel, House Financial Services Committee |
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Patrick |
La Veck |
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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
Cascading taxes for foreign-owned insurers: Advocate against measures that would lead to imposition of an excise tax twice when insurance for reinsurance is placed from the U.S. to a foreign company and then when the foreign company reinsurers the U.S. risk. The IRS issued a ruling on this in March (IRS Ruling 2009-15).
Executive Compensation: Monitor and oppose efforts to change carried interest tax treatment.
Exchange traded notes: For PIMCO followed issue through trade association Investment company Institute, EIN's are an alternative to mutual funds and enjoy a tax preference. Treasury has recently weighed in and may view this current tax treatment as not appropriate.
reinsurance taxation: Advocate against the introduction of legislation. This legislation would prohibit offshore reinsurance affiliates of insurance companies not required to pay U.S. taxes from taking deduction for "excel reinsurance premiums" for domestic risks.
Let Wall Street Pay tax proposal: Oppose provision of H.R. 1068, the Let Wall Street Pay for Wall Street's Bailout Act of 2009, that would tax securities transfer and transactions.
Monitor and oppose Obama Administration tax proposals that would change existing tax laws and increase tax requirements for life insurance.
Monitor and oppose provision in heath insurance reform package that would tax unearned income such as annuities.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Securities & Exchange Commission (SEC), 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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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Counsel, House Financial Services Committee |
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
Mark to market accounting: follow SEC and FASBE action regarding guidance and clarification for mark to market accounting. Financial Services regulatory reform: followed discussions within Congress and the Administration to reform the financial services regulatory system, including "cram-down" legislation to create a resolution authority for failing firms systemic risk legislation, and a new consumer financial protection agency.
TARP: Followed developments regarding the Troubled Asset Relief Program at Treasury.
money market guaranty program: Follow creation of Treasury Department money market guaranty program after concern about the financial stability of the Reserve Management Corporations Primary Fund.
Bailout/Economic Recovery Legislation: Follow implementation of H.R 1924 the "Emergency Economic Stabilization Act of 2008". The bill which Allianz of America supported, authorizes the U.S. Government to purchase up to $700 billion of troubled assets from financial institutions. The bill also included tax extender provisions which Allianz supported.
H.R. 4173, the Wall Street reform and Consumer Protection Act of 2009, follow action on this legislation, which would create a new systemic risk regulation for systemically-significant firms and a resolution mechanism for failing firms. Also, followed the mark-up of similar legislation in the Senate, the "Restoring American Financial Stability Act."
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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Counsel, House Financial Services Committee |
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 TOR
16. Specific lobbying issues
Legal/Tort reform: track the progress of the insurance industry's collaboration on legal reform tort issues at the federal and state levels.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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Counsel, House Financial Services Committee |
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
Annuities: Followed SEC action on rule to bring equity-indexed annuities under the SEC's regulatory purviews. Proposed rule:
"indexed Annuities and certain other insurance contacts." Release number: 33-8933. also followed litigation in opposition to rule.
commodities: Monitor action of the CFTC and Congress on speculation in the energy markets. Short Selling: Followed SEC's action regarding reinstating the uptick rule for short selling.
Hedge funds and private equity: Monitor S.244 Hedge fund Transparency Act; S.12276 private Fund Transparency Act of 2009.
Consumer Financial Protection Agency: Monitor inclusion of this new agency in H.R.4193, the Wall Street Reform and Consumer Protection Act and in parallel Senate legislation, the Restoring American Financial Stability Act.
Derivatives: Monitor new rules and changes of regulation for derivatives and commodity indexed funds, and activity within Congress, especially in the context of the H.R. 4173, the Wall Street Reform and Consumer Protection Act of 2009 and parallel legislation in the Senate, the Restoring American Financial Stability Act.
Senior Investor Protection Act, S.906: monitor legislation designed to protect seniors wishing to buy financial products from unqualified advisors; monitor together with trade associations.
Target Date funds: Monitor possible legislation and SEC as well as Department of Labor regulatory activities.
SEC and money markets: Monitor and see proposed SEC regulations.
Mutual funds: Advocate for the ability to defer annual capital gains taxation of dividends that are reinvested in mutual funds, GROWTH act S. 1082.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Commodity Futures Trading Commission (CFTC)
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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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Counsel, House Financial Services Committee |
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
401(k) fee disclosure: Oppose reintroduction of legislation that would require 401 (k) plan administrators to reveal charges associated with four categories of fees; administrative fees, investment management fees, transaction fees, and other costs.
401(k) automatic enrollment: through trade associations, support efforts to expand automatic 401(k) enrollment for workers.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
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 |
Peter |
Lefkin |
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Rashmi |
Sutton |
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Counsel, House Financial Services Committee |
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:
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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:
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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
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2 | 4 | 6 |