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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 |
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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 | 2008 |
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. | ||||||||
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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: Peter A. Lefkin, Senior Vice President, Government and ExternalAffairs |
Date | 01/08/2009 |
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
Insurance reform: Advocate in support of an optional Federal Charter, .R. 3200 and S.40, both titled "The National Insurance Act of 2007". These bills would create an optional federal charter for insurance. Also advocate for H.R. 5840, the Insurance Information Act of 2008. This bill would create an office of Insurance Information with the Treasury Department to provide federal expertise on insurance matters and international negotiations.
Long Term Care Insurance: Advocate in support of HR 3363 and S.2337, both titled the Long-term Care Affordability and Security Act of 2007. These bills would allow long-term care insurance to be offered in employer-sponsored cafeteria plans flexible spending arrangements.
Annuities/Suitability: Followed S. 2794, the "Senior Investor Protection Act of 2008". a bill which would hold insurance and securities companies liable for any potential mis-selling of their products by agents and brokers. The bill also required disclosures of fees, costs, and commissions. Also, contacted Senate staff on the annuities suitability issues, separate from the introduction of the bill. Also followed SEC action on this issue, including the SEC's issuing of a finance rule affecting fixed-index annuities. This is Rule 151A.
Holocaust insurance issues/ICHEIC: Lobbied against a bill introduced in the House, H.R. 1746, the "Holocaust Insurance Accountability Act of 2007", which 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 would also require any European insurer with policies written between 1900 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 a bill introduced in the House, H.R. 5733, the "Nondiscriminatory Use of Consumer Reports and Consumer Information Act of 2008", which would restrict the ability of personal lines insurers to use credit information for underwriting or setting rates.
Bond insurance: Follow issue, including attending hearings, which is how the subprime crisis has affected the bond insurance industry and the municipal securities they insure.
Medicare secondary payer/workers compensation: Flow issue, including trade association efforts to meet with the Centers for Medicare and Medicaid Services (CM'S), an agency at the Department of Health and Human Services. CMS is working on guidance/rules on this issue and insurance trade associations are weighing in.
McCarran-Ferguson Reform: Follow and oppose two bills, S.618 and H.R. 1081, the Insurance Industry Competition Act, which would repeal the McCarran-Ferguston Act, which provides insurers a limited exemption from federal antitrust law.
Broker licensing: Followed introduction of bill H.R. 5611, the National Association of Registered Agents and Brokers Reform Act. This bill, which is generally opposed by trade groups we belong to, would create a self regulating organization for insurance producers.
Flood and national catastrophe insurance: Lobbied in the House for reform of the National Flood Insurance Program, which is set to expire in March. Also lobbied against the inclusion of wind in the NFIP. Lobbied against the adoption of legislation that would create a federal backstop for natural catastrophe insurance.
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 |
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 measure that would lead to imposition of an excise tax twice when insurance ore reinsurance is placed from the U.S. to a foreign company and then when the foreign company rreinsures the U.S. risck. The IRS issued a ruling on this in March (IRS Ruling 2008-15).
Exchange traded notes: For PIMCO followed issue through trade association Investment Company Institute. ETN'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.
Annuities tax relief: Support S.1010 in the Senate and H.R. 2205 in the House, titled the Retirement Security for Life Act, which would exclude from income taxes 50 percent of grossincome and annuity payments, not to exceed $20,000 per year.
Reinsurance taxation: Advocate against legislation (H.R. 6969, "To Amend the Internal Revenue Code of 1986 to disallow the deduction for Excess Non-Taxed Reinsurance Premiums with respect to United States risks paid to affiliates.") This bill would prohibit offshore reinsurance affiliates of insurance companies not required to pay U.S. taxes from taking deductions for "excess reinsurance premiums" for domestic risks.
Tax Extenders: Lobbied for extension of exemption for foreign shareholders of U.S. mutual funds from a U.S. withholding tax. This was included in the bailout bill. H.R. 1424 signed into law.
Tax Extenders: Lobbied for an extension of capital gain tax rate for 2009 and 2010.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Treasury - Dept of, 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 |
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 TRD
16. Specific lobbying issues
NAFTA Debenture Issue - FFIC seeks monetary relief from the Mexican government under NAFTA's Chapter 11 tribunal process.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, State - Dept of (DOS)
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 Serrvices 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
Subprime housing crisis: Follow issue for banking and asset management affiliates, including H.R. 3221, The "American Housing Rescue and Fooreclosure Prevention Act of 2008" and Senate bills.
Mark to market accounting: Follow WEC action regarding guidance and clarification for mark to market accounting
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.
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 RET
16. Specific lobbying issues
Retirement security/investment issues: Supports two pieces of legislation through the efforts of a trade association, that would promote investment and retirement securities. The bills are H.R. 2796 and S.2126, the Generating Ownership through Long Term HOLDING (GROWTH) Act, which would defer taxation of automatically reinvested capital gains taxes until the time the mutual fund shares are sold and H.R. 2167, the Automatic IRA act of 2007, which would allow employees not covered qualified retirement.
401 (k) fee disclosure: Oppose bill recently approved the House committee on Education and the Workforce, H.R. 3185, the 401(k) Fair Disclosure for Retirement Security Act, which 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.
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. Through trades, the federal government affairs team has been updated on several fills in Congress including S.1782/H.R. 3010, Arbitration Fairness Act of 200; S.204/H.R. 4854, False Claims Act Corrections Act: S.2449, sunshine in Litigation Act: S.2450, to amend the Federal Rules of Evidence to address the waiver of the attorney-client privilege and workproduct doctrine;
S.2133, HOMES Act: S.2136, Helping Families Save Their Homes in Bankruptcy Act: S. 2636, Foreclosure Prevention Act: S.22633/H.R. 4040, CPSC Reform Act: H.R. 3221, Dodd/Shelby Amendment 4387, in nature of a substitute, Foreclosure Prevention 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 FIN
16. Specific lobbying issues
Municipal bonds: Followed SEC action, including a recently proposed rule to bring equity-indexed annuities under the SEC's regulatory purview. Proposed rule: "indexed Annuities and certain other insurance contacts" Release number: 33-8933.
Commodities: Moitor action of the CFTC and Congress on speculation in the energy markets.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Commodity Futures Trading Commission (CFTC), 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 |
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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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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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 | 3 | 5 |
| 2 | 4 | 6 |
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
| 1 | 5 | 9 |
| 2 | 6 | 10 |
| 3 | 7 | 11 |
| 4 | 8 | 12 |