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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 | 2024 |
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 | 4/19/2024 1:02:15 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; and legislation to 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, overfunded pension plans, distributions to participants, ways to encourage pension plan formation
Defined Contribution Plan issues
ERISA preemption issues
State automatic IRA programs impacting sponsors of private sector retirement plans and their employees benefits
Fiduciary Rule, Retirement Income Security Rule, Definition of Investment Advice Fiduciary
Retirement plan audits, Congressional oversight issues
ROTH Catch-up provision delay guidance
SECURE 2.0 guidance
Long-term-Part-time (LTPT) employee guidance
Automatic Portability for Retirement Accounts
Qualified Professional Asset Manager (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), Pension Benefit Guaranty Corporation (PBGC), Treasury - Dept of, Office of the Comptroller of the Currency (OCC)
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), Bipartisan HSA Improvement Act, 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 Management Coverage
ERISA Preemption issues affecting health benefit plans
Cost Transparency and Competition in Health Care.
Lower Costs, More Transparency Act, PBM reform, Prescription drug pricing and transparency, Pharmacy Benefit Manager Reform Act, Health Care Price Transparency Act
Preventive Health Savings Act
Site-Neutral Health Care Payment Reform
Dialysis Coverage/End Stage Renal Disease
Surprise Medical Billing Guidance and Implementation, including Independent Dispute Resolution
Paid Family and Medical Leave. On-going legislative activity
Definition of essential health benefits (EHBs) under the Proposed 2025 Notice of Benefit and Payment Parameters
Medicare Part D Redesign following the Inflation Reduction Act; Proposed Medicare Part D Redesign Program instructions for 2025
Reallocation of excess assets in Voluntary Employees Beneficiary Associations (VEBAs)
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, Centers For Medicare and Medicaid Services (CMS)
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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4 |
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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) |