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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 3222 N Street, NW |
Address2 | Suite 340 |
City | Washington |
State | DC |
Zip Code | 20007 |
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# 400665998-48
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6. House ID# 414510003
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TYPE OF REPORT | 8. Year | 2013 |
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: Andrew M. Siff, Principal |
Date | 10/15/2013 |
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
"Money Market Fund Reform," SEC regulations to transition Money Market Mutual Funds to a floating Net Asset Value (NAV) and impose restrictions on redemptions from such funds as well as additional capital buffers; RIN 3235-AK61. Supplemental notice of proposed rulemaking regarding definition of "Financial Activity and Activities Incidental Thereto;" RIN 3064-AD73. Definitions of "Predominantly Engaged in Financial Activities" and "Significant" Nonbank Financial Company and Bank Holding Company;
RIN 7100-AD64. Proposed regulations under consideration at the SEC in responseto rulemaking petition File # 4-637 (RIN 3235-AL36) that asks the SEC to consider mandating that issuers disclose payments to intermediaries and nonprofit organizations that are not restricted from using them for political activity. General education concerning the legal constructs and operations of services that provide advice concerning the voting of proxies. Advocating confirmation of all pending nominees to the Securities and Exchange Commission.
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 |
Andrew |
Siff |
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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 BUD
16. Specific lobbying issues
FY 2014 Financial and Government Appropriations Bill, seeking an amendment to prohibit the SEC from proposing any rule in response to Rulemaking petition File #4-637 (RIN 3235-AL36) that asks the SEC to consider mandating that issuers disclose payments to intermediaries and nonprofit organizations that are not restricted from using them for political activity.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES,
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 |
Andrew |
Siff |
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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 GOV
16. Specific lobbying issues
Legislative proposals under discussion in response to the SEC's initiation of an investigation into Height Securities and allegations that the firm obtained and conveyed to investors material, non-public information concerning the federal government's decision to keep certain medical payment rates in place, rather than cutting them.
17. House(s) of Congress and Federal agencies Check if None
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 |
Andrew |
Siff |
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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 | 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 |