Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page

9. Check if this filing amends a previously filed version of this report

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 BAN

16. Specific lobbying issues

H.R. 10 (Financial CHOICE Act of 2017);
H.R. 1459 (Financial Stability Oversight Council Reform Act);
H.R. 1624 (Municipal Finance Support Act of 2017);
H.R. 2121 (Pension, Endowment, and Mutual Fund Access to Banking Act);
S. 828 (To amend the Federal Deposit Insurance Act to require the appropriate Federal banking agencies to treat certain municipal obligations as level 2B liquid assets, and for other purposes);
S. 2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act);
Equity market structure issues;
Single Security/Common Securitization Platform (Federal Housing Finance Agency);
Federal Reserve Total Loss Absorbing Capacity (TLAC) proposal;
Federal Reserve G-SIB capital surcharge;
Federal Reserve liquidity coverage ratio (LCR)/net stable funding ratio (NSFR);
Section 956 of the Dodd-Frank Act;
Fixed Income Investments Liquidity;
China banking regulation;
Dodd-Frank Wall Street Reform and Consumer Protection Act Implementation;
Volcker Rule;
High Quality Liquid Assets (HQLA) requirements;
Prudential matters with the U.S. agencies and international standard setting bodies;
Executive Order 13777 (Enforcing the Regulatory Reform Agenda).

17. House(s) of Congress and Federal agencies Check if None

U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Treasury - Dept of, Natl Economic Council (NEC), Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Ginnie Mae, Federal Housing Finance Agency (FHFA)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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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 CDT

16. Specific lobbying issues

H.R. 238 (Commodity End-User Relief Act);
H.R. 316 (Futures Investor Protection Act);
H.R. 3280 (Financial Services and General Government Appropriations Act, 2018);
H.R. 3268 (Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2018);
H.R. 3555 (Exchange Regulatory Improvement Act);
S. 1005 (Modernization of Derivatives Tax Act of 2017);
Regulation of over-the-counter (OTC) derivatives (standardization of derivatives - all aspects including exchange trading, clearing, and reporting requirements);
Core Principles and Other Requirements for Swap Execution Facilities (SEF Final Rule);
CFTC Cross-border Guidance and Exemptive Order (13-69);
Make available to trade determination for Swap Execution Facilities (SEFs);
Position limits;
Concept Release on Risk Controls and System Safeguards for Automated Trading Environments;
Transaction-Level Requirements in Certain Cross-Border Situations (CFTC letters Nos. 13-17 and 14-01);
CFTC Regulation 1.35;
Block trades on swap execution facilities (SEFs);
CFTC no action relief for packaged trades;
Security based swaps rules under Title VII;
Derivatives regulation (general);
CFTC Letter 14-140 on transaction-level requirements in certain cross-border situations;
Inter-affiliate swap transaction;
Margin requirements for uncleared swaps;
Swap Execution Facilities (SEFs) and clearing for swaps;
Global FX Code of Conduct;
Decision to delay implementation for margin for non-centrally cleared swaps;
CFTC proposed cross border rule;
CFTC capital requirements for swap dealers and major swap participants;
CFTC final rule on margin requirements for uncleared swaps;
SEC proposed rule on margin for uncleared swaps;
CFTC's Project Kiss;
Initial margin for inter-affiliate transactions;
Commodity Exchange Act reauthorization;
FY18 Financial Services and General Government (Senate).

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Securities & Exchange Commission (SEC), Office of the Comptroller of the Currency (OCC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Treasury - Dept of

18. Name of each individual who acted as a lobbyist in this issue area

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 FIN

16. Specific lobbying issues

H.R. 10 (Financial CHOICE Act of 2017);
H.R. 477 (Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2017);
H.R. 910 (Fair Access to Investment Research Act of 2017);
H.R. 1343 (Encouraging Employee Ownership Act of 2017);
H.R. 1459 (Financial Stability Oversight Council Reform Act);
H.R. 1585 (To amend the Securities Act of 1933 to codify certain qualifications of individuals as accredited investors for purposes of the securities laws);
H.R. 1645 (Fostering Innovation Act of 2017);
H.R. 1667 (Financial Institution Bankruptcy Act of 2017);
H.R. 3299 (Protecting Consumers' Access to Credit Act of 2017);
H.R. 3758 (Senior Safe Act of 2017);
H.R. 3857 (PASS Act of 2017);
H.R. 3903 (Encouraging Public Offerings Act of 2017);
S. 178 (Robert Matava Elder Abuse Prosecution Act of 2017);
S. 223 (Senior$afe Act of 2017);
S. 327 (Fair Access to Investment Research Act of 2017);
S. 488 (Encouraging Employee Ownership Act);
Swap dealer and major swap participant recordkeeping and reporting, duties, and conflicts of interest policies and procedures;
Swap execution facilities;
Swap dealer, major swap participant, and futures commission merchant chief compliance officer;
Dodd-Frank Wall Street Reform and Consumer Protection Act Implementation (including Section 913; Section 914; Systemic risk regulation and liquidation authority; Section 342 (Office of Minority and Women Inclusion); Section 621; Section 941; Title I and Title II);
China - strategic and economic dialogue;
Bilateral Investment Treaties, India, China;
Transpacific Partnership;
India Market Access Issues;
European Union proposal regarding Credit Default Swaps and Credit Rating Agencies and their impact on US Markets;
India Financial Sector Reform;
Accounting standards for municipalities;
Securities Investor Protection Corporation (SIPC) reform and funding fees;
Privacy and cybersecurity issues (general);
Municipal advisor regulation;
CFTC cross-border guidance exemptive order;
CFTC exemptive order on extraterritorial scope of Title VII;
Jumpstart our Business Startups (JOBS) Act implementation;
Commodity Pools and Securitization;
Securities and Exchange Commission Rules 15Ba1-1 through 15Ba1-8;
Release No. 34-71958, Security-Based Swap Dealers Recordkeeping;
Regulation AB II (asset backed securities - Securities and Exchange Commission, Consumer Financial Protection Bureau);
Futures Commission Merchant and Introducing Broker Conflicts of Interest Policies and Procedures;
Inter-affiliate swap transactions;
U.S./EU cross-border regulatory issues;
Trade policy issues (general);
China "Secure and Controllable" information and communication technologies (ICT) regulations;
Mutual Fund 12b-1 Fees;
Senior investors/diminished capacity investors;
Broker-dealers/investment advisers mitigation of accounts;
Public Company Accounting Oversight Board small broker/dealer exemption;
U.S./EU financial markets regulatory dialogue;
Trade and international issues (general);
Diversity & Inclusion initiatives in the financial services industry;
Data localization requirements in the Trans-Pacific Partnership;
Swap Execution Facilities (SEFs) and clearing for swaps;
Global FX Code of Conduct;
Decision to delay implementation for margin for non-centrally cleared swaps;
North American Free Trade Act (NAFTA);
Infrastructure finance and agenda;
Municipal information disclosure regulation;
Executive Order 13771 (Reducing Regulation and Controlling Regulatory Cost);
Executive Order 13772 (Core Principles for Regulation of the US Financial System)
Executive Order 13777 (Enforcing the Regulatory Reform Agenda);
US and China 100-day trade talks;
Fiscal Year 2018 Transportations, HUD Appropriations Bill;
Fiscal Year 2018 Financial Services and General Government Bill;
Housing finance reform.

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, Natl Economic Council (NEC), Securities & Exchange Commission (SEC), U.S. Trade Representative (USTR), Commerce - Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Natl Credit Union Administration (NCUA), Ginnie Mae, Homeland Security - Dept of (DHS), Natl Security Council (NSC), State - Dept of (DOS), Office of the Comptroller of the Currency (OCC), Housing & Urban Development - Dept of (HUD), Federal Housing Finance Agency (FHFA)

18. Name of each individual who acted as a lobbyist in this issue area

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

H.R. 1 (An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018);
S. 1 (An original bill to provide for reconciliation pursuant to title II of the concurrent resolution on the budget for fiscal year 2018);
S. 1005 (Modernization of Derivatives Tax Act of 2017);
Dodd-Frank Wall Street Reform and Consumer Protection Act Implementation;
Tax treatment of capital gains and dividends;
Tax classification of independent contractors;
International tax reform;
United States individual and business taxation;
Issues related to proposals to impose an asset tax on financial institutions;
Tax reform legislation;
Issues related to taxation of securities transactions, including market to market for derivatives;
Chapters 3 and 4 of Subtitle A of the Internal Revenue Code (responsibilities of financial institutions);
A Better Way Forward on Tax Reform Blueprint;
House proposal for a destination based cash flow tax;
House proposal to limit the section 162 deduction for interest expense;
House proposal for a deemed repatriation tax;
Proposals to modify or eliminate the Sec. 103 exclusion for interest on state and local debt;
Proposals to modify tax incentives for retirement savings and investment;
State and local bond exclusion;
Infrastructure tax;
Trump administration tax proposals;
Executive Order 13789 (Identifying and Reducing Tax Regulatory Burdens);
Regulations under IRC Sec. 871(m), IRC Sec. 367, and IRC Sec. 385;
Regulations under the Foreign Account Taxpayer Compliance Act (FATCA).

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, Natl Security Council (NSC), Securities & Exchange Commission (SEC), Internal Revenue Service (IRS)

18. Name of each individual who acted as a lobbyist in this issue area

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

H.R. 1 (An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018);
H.R. 355 (Protecting American Families' Retirement Advice Act);
H.R. 2823 (Affordable Retirement Advice for Savers Act);
H.R. 3758 (Senior Safe Act of 2017);
H.R. 3857 (PASS Act of 2017);
H.R. 4523 (Automatic Retirement Plan Act of 2017);
S. 178 (Elder Abuse Prevention and Prosecution Act);
S. 223 (Senior$afe Act of 2017);
S. 1321 (Affordable Retirement Advice Protection Act);
DOL ERISA Fiduciary Duty Rulemaking;
Tax incentives for retirement savings;
GOP Tax Reform blueprint.

17. House(s) of Congress and Federal agencies Check if None

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of, Securities & Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Labor - Dept of (DOL)

18. Name of each individual who acted as a lobbyist in this issue area

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

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Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

21. Client new principal place of business (if different than line 20)

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

ISSUE UPDATE

24. General lobbying issue that no longer pertains

AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

26. Name of each previously reported organization that is no longer affiliated with the registrant or client

FOREIGN ENTITIES

27. Add the following foreign entities:

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization