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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 |
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City | VALLEY FORGE |
State | PA |
Zip Code | 19482 |
Country | USA |
3. Principal place of business (if different than line 2)
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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 | 2014 |
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: BRIAN S. MATTES |
Date | 1/20/2015 11:03:45 AM |
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
Issues related to Dodd-Frank Wall Street Reform and Consumer Protection Act (Public Law 111-203) implementation and regulations, including SIFI rules and designation, systemic risk, orderly liquidation authority and derivatives
Issues related to systemic risk regulation of non-bank financial institutions
Issues related to portfolio management of exchange-traded funds (ETFs), including transparency and custom baskets
Issues related to swap execution facility trading, interactions and reporting of swaps trading
Issues related to definition of major swap participants
Issues related to enhancements to margin protection rules for swap participants and effect of bankruptcy of a futures clearing merchant or clearinghouse on derivatives trading
Issues related to nature of collateral for cleared swaps
Issues related to margin for uncleared swaps, including cash-only margin
Issues related to capital requirements for cleared and uncleared swaps
Issues related to transaction recording obligation under the CFTCs SEF rules
Issues related to derivatives trading reforms including cross border provisions, FX settling, and commodity pool operator registration requirements
Issues related to market structure matters (computerized trading, trade-at, high frequency trading, minimizing latency of market data feeds, improving resiliency of technology and infrastructure to avoid single points of failure, Regulation NMS and the maker-taker model)
Issues related to effect of the Volcker rule on fixed income markets, equity markets, and mutual fund shareholders
Issues related to the Financial Stability Oversight Council (FSOC) and mutual funds, including H.R. 5180 (Financial Stability Oversight Council Improvement Act of 2014)
Issues related to the Financial Stability Board (FSB) and mutual funds
Issues related to the Office of Financial Research study of asset managers and its potential impact on mutual funds
Issues related to legislation and regulations affecting mutual funds and the mutual fund industry
Issues related to regulation of mortgage- and other asset-backed securities, housing finance reform, and Government Sponsored Enterprise reform
Proposals related to potential money market fund regulations (e.g. floating net asset value, capital requirements, redemption hold-back, liquidity gates and fees, treatment of municipal money market funds)
Issues related to the overnight reverse repurchase agreement proposal
Issues related to market activities and effects upon Treasury inflation protected securities
Issues related to the SECs enhanced fund reporting initiative
Issues related to the structure and offering of annuities
H.R. 2374 (Retail Investor Protection Act) for regulatory coordination between the DOL and the SEC
Issues surrounding the fiscal situation with Puerto Rico and its impact on the municipal bonds market
Issues related to disclosure of municipal bond transaction expenses
Issues related to a pilot program for expanded tick sizes for small capitalization stocks, including H.R. 1952 (Spread Pricing Liquidity Act of 2013) and H.R. 3448 (Small Cap Liquidity Reform Act of 2013)
Issues related to the regulation of the asset management industry
Issues related to the EU safe harbor framework
Issues related to the flash crash and availability of liquidity in the fixed income markets
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Securities & Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Federal Reserve System, Commerce - Dept of (DOC), 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 |
Brian |
Mattes |
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Ann |
Combs |
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Jerry |
Golden |
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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
Provisions included in S.1270 (SAFE Retirement Act of 2013)
Proposal related to stemming leakage from retirement plans through reform of plan loan rules
Issues related to tax incentives for retirement savings; encourage retention of their tax incentives
Issues related to employee benefit plan administration and electronic delivery of ERISA-mandated statements and disclosures
Consolidation of ERISA-required notices
Issues related to retirement target date funds and their marketing rule
Issues related to the MyRA proposal
Issues related to limitations on retirement plan contributions or assets
Issues related to the effect of the Department of Labors proposed ERISA fiduciary definition
Proposals related to expansion of SIMPLE IRAs, establishment of discretionary payroll deduction IRAs, and creation of new qualified retirement plans for small business
Provisions included in H.R. 2117 (Retirement Plan Simplification Act of 2013), including the use of a blended benchmark for target date funds
Issues related to retirement plan autoescalation safe harbor proposal
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Labor - Dept of (DOL)
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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Jerry |
Golden |
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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
Capital gains and dividend tax rates as they relate to mutual funds
Issues related to extending permanently the registered investment company flow-through provisions of Code section 871(k)
Issues related to tax incentives for retirement savings
Domestic security or financial transaction tax proposals, including H.R. 880 and S. 410 (Wall Street Trading and Speculators Tax Act) and H.R. 1579 (Inclusive Prosperity Act of 2013)
Proposals to protect securities transactions in the U.S. from enforcement of certain excise taxes imposed by any foreign government (imposition of foreign financial transaction tax in the U.S.), including S. 1257 and H.R. 2546 (Protect American Investments Act of 2013)
Issues related to limitations on exclusion of municipal bond interest
Issues related to fundamental tax reform
Issues related to savings
Issues related to taxation of derivatives
Issues related to basis reporting for stock, bond and money market funds
Issues related to commodity related investments
Issues related to 529 college savings plans; encourage retention of their tax incentives
Issues related to the design and function of the ABLE Act (S.313 and H.R.647)
Issues related to development of the 401(Kids) Education Savings Account Act proposal
General tax issues related to mutual funds
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, 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 |
Brian |
Mattes |
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Ann |
Combs |
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Jerry |
Golden |
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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
Issues related to reductions in the federal debt and federal budget deficit; encourage efforts to reduce the federal debt and budget deficits
Issues related to statutory debt ceiling; encourage Congress to raise the statutory debt ceiling when necessary
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, 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 |
Brian |
Mattes |
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Ann |
Combs |
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Jerry |
Golden |
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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 HOM
16. Specific lobbying issues
Issues related to cybersecurity, infrastructure protection, security technology, and coordination of information relating to cybersecurity measures including H.R.3696 (National Cybersecurity and Critical Infrastructure Protection Act of 2013), H.R. 2962 (Critical Infrastructure Research and Development Act), H.R. 3107 (Homeland Security Cybersecurity Boots-on-the-Ground Act, H.R. 3635 (Safe and Secure Federal Websites Act), S. 1353 (Cybersecurity Act of 2013), S. 2354 (DHS Cybersecurity Workforce Recruitment and Retention Act of 2014), S. 2519 (National Cybersecurity and Communications Integration Center Act of 2014), and S. 2521 (Federal Information Security Modernization Act of 2014)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, 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 |
Brian |
Mattes |
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Ann |
Combs |
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Jerry |
Golden |
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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:
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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 |