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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 |
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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 | 2025 |
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 | 10/17/2025 3:24:54 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
ERISA preemption
Technical corrections to SECURE 2.0
Collective investment trusts (CITs) and insurance company separate accounts for use by 403(b) plans; Retirement Fairness for Charities and Educational Institutions, (HR 1013)
Age of required participation in retirement plans reduced from 21 to 18, (S. 1707)
Automatic re-enrollment of unenrolled plan participants permitted by (S. 1831)
EBSA Investigations Transparency Act (HR 2869)
Retire Through Ownership Act (HR 5169)
Transparency for Secret Litigation Agreements (HR 2958)
Common Interest Agreements used by the U.S. DOL
Pleading standards, legislative proposal applicable to ERISA cases
Defined benefit pension plans and defined contribution plans; pension plan de-risking, retiree health accounts
Required Roth catch-up contributions and Roth optional matching and non-elective contributions guidance
Pension Benefit Guaranty Corporation (PBGC) premiums and due date for premium payment
Direct Final Rule Revocations by EBSA
401(k) plan investments in alternative assets and lifetime income
Pooled Employer Plans (PEPs)
Retirement benefits for independent workers
white paper regarding Supreme Court petition, Johnson v. Parker Hannifin
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, White House Office
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 |
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
Tax treatment of employer-sponsored health benefit plans; budget reconciliation
Health Savings Accounts and High-Deductible Health Plans; permanent safe harbor for HSA-eligible health plans to cover telehealth pre-deductible, HSA flexibility primary care and chronic disease; budget reconciliation; Telehealth Expansion Act (HR 1650 / S. 763 - 119th Congress)
Health care cost transparency, prescription drugs, PBM pricing and transparency and hospital and health plan price transparency
Hospital consolidation and billing practices, site neutral payment reform; Healthy Competition for Better Care Act
Voluntary Employee Beneficiary Associations (VEBAs)
End-stage renal disease and Medicare secondary payer issues
340B Prescription Drug Program
408(b)(2) Fee disclosure for health plans
Surprise Medical Billing rules
Chronic Disease Flexible Coverage Act (HR 919 - 119th Congress)
Paid leave, Interstate Paid Leave Action Network (I-PLAN) Act, (HR 3090) More Paid Leave for More Americans Act (HR 3089)
Fair Billing Act (S. 2497)
Prescription Drug Machine Readable Files (MRF)
Prescription Drug Cost
ERISA electronic reporting and disclosure, mental health parity, allow HSAs to cover chronic conditions on a pre-deductible basis
Form 5500 Simplification legislation
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), Centers For Medicare and Medicaid Services (CMS), White House Office
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 |
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 |
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Kerri |
Willis |
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Senior Counsel, Health Policy |
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:
| 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) |