Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page

9. Check if this filing amends a previously filed version of this report

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

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;
Stress testing reform;
Foreign Banking Organizations Tailoring Proposal comment letter;
Living Will comment letters from the Federal Reserve Board and the Federal Deposit Insurance Corporation;
Control Proposal by the Federal Reserve Board;
Standardized Approach for Counterparty Credit Risk (SA-CCR) reform proposal;
Housing Finance Reform;
LIBOR transition issues;
SEC Final Regulation Best Interest;
Implementation of Electronic Signature in Global and National Commerce Act;
Consolidated Audit Trail (CAT) - US House and US Senate;
Comprehensive Capital Analysis and Review - US Senate;
Legislation related to changes in certain private activity bond treatment;
H.R. 2513 - Corporate Transparency Act of 2019;
H.R. 2474/S. 1306 - Protecting the Right to Organize Act of 2019;
H.R. 1595 and S. 1200 - Secure and Fair Enforcement Banking Act of 2019;
SEC Proposed Exemptive Order on Municipal Advisors Acting As Placement Agents;
S. 1236, the Municipal Securities Rulemaking Board Reform Act of 2019;
H.R. 4762, Fair Investment Opportunities for Professional Experts Act;
S. 2724, Small Business Audit Correction Act of 2019;
H.R. 3967, Municipal Bond Market Support Act of 2019;
SEC Regulation Best Interest;
S. 482 - Defending American Security from Kremlin Aggression Act of 2019 and other Issues related to foreign policy and the blocking of and/or trade restrictions;
H.R. 2923, Inclusive Prosperity Act of 2019;
H.R. 748 - The CARES Act;
Federal Reserve Board and Prudential Agency Covid-19 Actions;
Brokered Deposit Comment Proposal from the FDIC;
H.R. 5336 - Investor Choice Act of 2019;
Diverse Investment Advisers Act (not introduced);
H.R. 5084 - Improving Corporate Governance Through Diversity Act of 2019;
S. 2563 - ILLICIT Cash Act;
S. 3550 - Municipal Bonds Emergency Relief Act;
Self-Regulatory Organization (SRO) Reform;
H.R. 2772 - Investing in Our Communities Act;
S. 2992 - Investor Choice Act of 2019;
Increase in the bank qualified bond limit, Rep. Sewell Bill;
MSRB Bill, Rep. Kennedy Bill.

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), Securities & Exchange Commission (SEC)

18. Name of each individual who acted as a lobbyist in this issue area

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

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;
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;
Initial margin for inter-affiliate transactions;
Commodity Exchange Act reauthorization;
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;
Issues related to H.R. 648, Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2019;
H.R. 4233, Options Markets Stability Act of 2019;
Global FX Code of Conduct.

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

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. 609 (Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2019);
H.R. 1815 (SEC Disclosure Effectiveness Testing Act);
H.R. 1876 (Senior Security Act of 2019);
H.R. 2513 (Corporate Transparency Act of 2019);
H.R. 2515 (To amend the Securities and Exchange Act of 1934 to amend the definition of whistleblower);
H.R. 3351 (Financial Services and General Government Appropriations Act, 2020);
S. 452 (Fostering Innovation Act of 2019);
S. 536 (Encouraging Public Offerings Act of 2019);
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. 115th Cong.);
Senate Banking Committee request for information on privacy and data protection for consumers.
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, cybersecurity, and data aggregation issues (general);
CFTC cross-border guidance exemptive order;
CFTC exemptive order on extraterritorial scope of Title VII;
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;
Municipal information disclosure regulation;
US and China 100-day trade talks;
Data Breach Notification Federal Standard;
The Brokaw Act (not yet reintroduced);
Exchange Regulatory Improvement Act (not yet reintroduced);
Fair Investment Opportunities for Professional Experts Act (not yet reintroduced);
Small Business Audit Correction Act of 2018 (not yet reintroduced);
Options Markets Stability Act (not yet reintroduced);
National Senior Investor Initiative Act of 2018 (not yet reintroduced);
Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2018 (not yet reintroduced);
Improving Investment Research for Small and Emerging Issuers Act (not yet reintroduced);
P.L. 106-229 (E-Sign Act);
Section 956 of the Dodd Frank Act (Incentive Compensation);
United States-Mexico-Canada Agreement (USMCA);
Legislation related to Securities and Exchange Commission Regulation A;
Issues related to restitution and disgorgement (not yet introduced);
Legislation related to the FINRA arbitration system for broker-dealers;
Housing finance reform (general);
Financial technology (FinTech) issues (general);
Issues related to the proposed Bad Actor Disqualification Act of 2019;
Issues related to H.R.264, the Fiscal Year 2019 Financial Services and General Government Appropriations Act;
Options Markets Stability Act (not yet reintroduced);
Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2018 (not yet reintroduced);
Improving Investment Research for Small and Emerging Issuers Act (not yet reintroduced);
SEC Proposed Exemptive Order on Municipal Advisors Acting As Placement Agents;
S. 1236, the Municipal Securities Rulemaking Board Reform Act of 2019;
H.R. 609, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2019;
H.R. 1815, SEC Disclosure Effectiveness Testing Act of 2019;
SEC Regulation Best Interest;
S. 1719 - Senior Security Act of 2019;
H.R. 4233 - Options Markets Stability Act;
H.R. 5336 - Investor Choice Act of 2019;
S. 2992 - Investor Choice Act of 2019;
Fiscal Year 2021 Financial Services and General Government Appropriations bill;
H.R. 748 - CARES Act;
S. 3550 - Municipal Bonds Emergency Relief Act.

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

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. 1516 (Wall Street Tax Act of 2019);
H.R. 2772 (Investing in Our Communities Act);
S. 647 (Wall Street Tax Act of 2019);
United States individual and business taxation;
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;
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;
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;
Technical and policy modifications to P.L. 115-97;
Tax Incentives to preserve interest deduction related to municipal bonds;
Tax Incentives to reinstate advance refunding bonds;
Tax Incentives to provide for direct pay municipal bonds;
Issues related to taxation of ownership of securities and securities transactions;
Technical correction related to the repeal of Section 958(b)(4) in P.L. 115-97 (Tax Cuts and Jobs Act);
H.R. 748 - CARES Act;
H.R. 3967 - Municipal Bond Market Support Act of 2019;
Proposals to expand Private Activity Bonds, U.S House, U.S. Senate.

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

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. 1439 (Increase Access to a Secure Retirement Act of 2019);
H.R. 1516 (Wall Street Tax Act of 2019);
H.R. 1815 (SEC Disclosure Effectiveness Testing Act);
H.R. 1876 (Senior Security Act of 2019);
H.R. 1907 (Retirement Security for American Workers Act);
H.R. 1993 (To amend the Internal Revenue Code of 1986 and the Employee Retirement Income Security Act of 1974 to modify the rules relating to multiple employer plans and pooled employer plans and to modify PBGC premiums for CSEC plans);
H.R. 1994 (Setting Every Community up for Retirement Enhancement (SECURE) Act of 2019);
S. 647 (Wall Street Tax Act of 2019);
S. 1431 (Retirement Security and Savings Act of 2019);
S. 1719 (Senior Security Act of 2019);
Senior investor protection legislation;
Tax incentives for retirement savings;
SEC Final Regulation Best Interest;
Senior Investor Report and Hold concept legislation;
Electronic delivery of retirement plan documents and disclosures;
H.R. 748 CARES Act.

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

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

21. Client new principal place of business (if different than line 20)

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

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

26. Name of each previously reported organization that is no longer affiliated with the registrant or client

FOREIGN ENTITIES

27. Add the following foreign entities:

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization

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?
No Yes