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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 | 2023 |
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. | ||||||||
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: Nicholas Otto |
Date | 1/18/2024 1:50:29 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
Technical corrections to SECURE 2.0
Automatic re-enrollment for defined contribution plans; reduce retirement plan participation age to 18 from 21
Collective Investment Trusts (CITs) and insurance company separate accounts for section 403(b) plans
Enforcement of pleading standards for retirement plan litigation
Defined Benefit Plan issues: de-risking pensions, PBGC premiums, retiree health accounts, overfunding of plans, distributions to participants, ways to encourage pension plan formation, DOL pension plan de-risking report (expected)
Defined Contribution Plan issues: auto-re-enrollment of participants who opted out of the plan, lower participation age to 18, ways for multiple employer plans (MEPs) and pooled employer plans (PEPs) to increase participation and ease administration, tax credits to increase sponsorship among small businesses, contingent workers, portable benefit plans, emergency savings plans, student loan repayment deemed matching contributions
ERISA preemption
State automatic IRA programs affecting private sector employers and their employees
Fiduciary Rule, DOL Retirement Income Security Rule, definition of Investment Advice Fiduciary
Retirement Savings for Americans Act (American Worker Retirement Fund)
Environmental, social and governance (ESG) factors in retirement plan investing and lawsuits affecting ESG investments in retirement plans
Retirement plan audits
Required minimum distributions (RMDs)
Forfeitures of amounts in a defined contribution plan
SECURE 2.0 Implementation
ROTH Catch-up provision delay guidance
GRAB BAG of SECURE 2.0 guidance
Long-term-Part-time (LTPT) employee guidance
Corporate Alternative Minimum Tax (CAMT) application to defined benefit pensions
Qualified Professional Asset (QPAM) amendment
Basel III Endgame, Treatment of reserves by financial institutions and its effect on pension and retirement plans
Defined Benefit Pension Plan proposals
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), Office of Management & Budget (OMB), Pension Benefit Guaranty Corporation (PBGC), 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 |
James |
Klein |
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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
Health Savings Accounts (HSAs). HR 5688 Bipartisan HSA Improvement Act, HR 5687, HSA Modernization Act
Telehealth Expansion. Making permanent telehealth benefits for use by employer plans offering telehealth services on a pre-deductible basis for HSA-eligible High Deductible Health Plans
Chronic Disease Coverage by health benefit plans
ERISA Preemption
Cost Transparency and Competition in Health Care. H.R. 5378, Lower Costs, More Transparency Act (LCMT) Act, also pharmacy benefit manager, PBM (reform) and prescription drug pricing and transparency; S. 1339, Pharmacy Benefit Manager Reform Act; Health Care Price Transparency Act 2.0 S. 3548
End-Stage Renal Disease (ESRD), Restore Protections for Dialysis Patients Act
Site-Neutral Health Care Payment Reform. LCMT Act, SITE Act S. 1869
Electronic Prescribing for Controlled Substances Act - EPCS 2.0, S. 2666
Over-the-Counter Preventive Services (OTC)
Mental Health Parity
Fixed-Indemnity Plans. Short-term, Limited Duration, Independent Non-coordinated Excepted Benefits Coverage, and tax treatment of certain accident and health insurance fixed indemnity plans
Surprise Medical Billing Guidance. Court cases challenging the No Surprises Act, Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
Paid Family and Medical Leave. On-going legislative inquiry involving multiple Congressional Offices
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, Office of Management & Budget (OMB), Internal Revenue Service (IRS), Office of Personnel Management (OPM)
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 |
James |
Klein |
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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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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 |
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) |