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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | P.O. BOX 2600 |
Address2 | |
City | VALLEY FORGE |
State | PA |
Zip Code | 19482 |
Country | USA |
3. Principal place of business (if different than line 2)
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Zip Code | |
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5. Senate ID# 291058-12
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6. House ID# 371950000
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TYPE OF REPORT | 8. Year | 2011 |
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: Brian S. Mattes, Principal - Government Relations |
Date | 01/19/2012 |
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. 4173 and issues related to Dodd-Frank Wall Street Reform and Consumer Protection Act implementation and regulations derivatives, systemic risk, and Orderly Liquidation Authority, SIFI Rules
Issues related to swap execution facility trading and reporting
(see attached addendum sheet)
Issues related to systemic risk regulation
Issues related to definition of major swap participants
Issues related to nature of collateral for cleared swaps
Issues related to systemic risk regulation
Issues related to market structure matters
Issues related to target date mutual funds
Issues related to investment advice
Issues related to municipal disclosure
Issues related to Basel III and Volcker rules
Issues related to the supervision and regulation of certain (systemically important) nonbank financial institutions
Issues related to the Financial Stability Oversight Council and mutual funds
Issues related to legislation and regulations affecting mutual funds and the mutual fund industry
Proposals related to money market funds (e.g. floating net asset value, liquidity protection, alternative regulatory approaches)
Issues related to securities transactions and holdings
Issues related to financial service institutions and industry
Issues related to standards for audited financial statement reports, auditor independence and audit firm rotation (PCAOB)
Issues regarding prohibition against conflicts of interest in certain securitizations
Issues relating to exchange traded funds
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), Federal Deposit Insurance Commission (FDIC)
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 |
Brian |
Mattes |
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Ann |
Combs |
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James |
Delaplane |
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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 RET
16. Specific lobbying issues
Proposals related to expansion of SIMPLE IRAs, establishment of discretionary payroll deduction IRAs, and creation of new qualified retirement plans for small business, including H.R.1534, Small Businesses Add Value for Employees Act
(see attached addendum page)
Proposal related to stemming leakage from retirement plans through reform of plan loan rules, including, S.1121/H.R. 3287- Savings Enhancement by Alleviating Leakage in 401(k) Savings Act
Issues related to retirement target date funds
Issues related to tax incentives for retirement savings
Issues related to the effect of the Department of Labors proposed fiduciary definition regulation
Issues related to stable value funds in retirement plans
Issues related to securities lending in retirement funds
401(k) fee disclosures
401(k) investment advice
Issues related to electronic delivery of employee plan notices and statements
Proposals to simplify retirement plan administration
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Labor - Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), Government Accountability Office (GAO)
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 |
Brian |
Mattes |
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Ann |
Combs |
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James |
Delaplane |
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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
General tax issues related to mutual funds
Tax Hike Prevention & Business Certainty Act, H.R. 3091 and S. 1647
Capital gains and dividend tax rates as they relate to mutual funds
(see attached addendum sheet)
Transaction tax proposals
Tax rules regarding mutual fund investments in commodities
Tax treatment of exchange traded notes
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 |
Brian |
Mattes |
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Ann |
Combs |
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James |
Delaplane |
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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 | 3 | 5 |
2 | 4 | 6 |
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 | 5 | 9 |
2 | 6 | 10 |
3 | 7 | 11 |
4 | 8 | 12 |