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

Equity market structure issues;
Self-Regulatory Organization (SRO) Reform;
SEC Rule 15c2-11;
H.R. 2265 - the Financial Exploitation Prevention Act of 2021;
SEC Securities Lending Proposal;
H.R. ____ - to amend the Securities Exchange Act of 1934 to add certain requirements for the filing and approval of proposed rule changes by self-regulatory organizations;
H.R. ____ - the "Securities Exchange Reform Act of 2022" (Rep Sherman);
SEC short comment periods;
H.R. 4616 - The Adjustable Interest Rate (LIBOR) Act of 2021;
S. 479 - LOCAL Infrastructure Act;
H.R. 2288 - to amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds;
H.R. 2634 - Local Infrastructure Financing Tools Act;
S. 1676 - Rural Broadband Financing Flexibility Act;
S. 1308 - American Infrastructure Bonds Act of 2021;
H.R. 2954 - Securing a Strong Retirement Act of 2021;
S. 1770 - Retirement Security and Savings Act of 2021;
S. 1443/H.R. 2917 - Retirement Parity for Student Loans Act;
H.R. ____ - Capital Markets Transparency Act;
H.R. ____ - to amend the Securities Exchange Act of 1934 to establish certain requirements with respect to retail investor options trading;
H.R. ____ - to amend the Securities Exchange Act of 1934 to prohibit payment for order flow in the form of exchange rebates;
H.R. 4617 - To require the SEC to carry out a study on PFOF, to require the Investor Advocate of the Commission to provide recommendations on PFOF, and for other purposes;
H.R. 935 - the Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021;
H.R. 4618 - the Short Sale Transparency and Market Fairness Act of 2021;
H.R. 4619 - to amend the Securities Exchange Act of 1934 to prohibit trading ahead by market makers, and for other purposes;
H.R. ____ "Close the ILC Loophole Act"

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), Office of the Comptroller of the Currency (OCC), Federal Reserve System, Federal Housing Finance Agency (FHFA), Securities & Exchange Commission (SEC), 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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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

SEC Rule 15c2-11;
Fixed income securities.

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 Reserve System

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 FIN

16. Specific lobbying issues

Senior investors/diminished capacity investors;
Sustainable Finance;
H.R. 5376 - Build Back Better Act of 2021;
Private Fund Proposals (SEC);
H.R. 6285 - Accelerating Holding Foreign Companies Accountable Act;
S. 479 - LOCAL Infrastructure Act;
H.R. 2288 - a bill to amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds;
FTC Hart Scott Rodino Proposals;
S. 1308 - American Infrastructure Bonds Act of 2021;
H.R. 2634 - Local Infrastructure Financing Tools Act;
S. 1676 - Rural Broadband Financing Flexibility Act;
H.R. 2954 - Securing a Strong Retirement Act of 2021;
S. 1770 - Retirement Security and Savings Act of 2021;
S. 2184 - A bill to amend the Sarbanes-Oxley Act of 2002 to institute a trading prohibition for certain issuers that retain public accounting firms that have not been subject to inspection by the Public Company Accounting Oversight Board, and for other purposes.

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), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Homeland Security - Dept of (DHS), Natl Security Council (NSC), Office of the Comptroller of the Currency (OCC), 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 TAX

16. Specific lobbying issues

Proposals to modify tax incentives for retirement savings and investment;
Taxation of contract modifications associated with transition from LIBOR to alternative reference rates, including SOFR;
Proposals to expand bank information reporting requirements;
H.R. 328/S. 817 - Wall Street Tax Act of 2021;
H.R. 3684 - Infrastructure Investment and Jobs Act;
H.R. 5376 - Build Back Better Act;
Modernization Derivatives Tax Act;
Tax Incentives to preserve interest deduction related to municipal bonds;
S. 479 - LOCAL Infrastructure Act;
H.R. 2288 - To amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds;
H.R. 2954 - Securing a Strong Retirement Act of 2021;
S. 817/H.R. 328 - Wall Street Tax Act of 2021;
S. 1308 - American Infrastructure Bonds Act of 2021;
S. 1676 - Rural Broadband Financing Flexibility Act;
S. 1770 - Retirement Security and Savings Act of 2021;
S. 1443/H.R. 2917 - Retirement Parity for Student Loans Act of 2021.

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), 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

Tax incentives for retirement savings;
Electronic delivery of retirement plan documents and disclosures;
ESG Investing relating to retirement accounts;
S. 1443/H.R. 2917 - Retirement Parity for Student Loans Act of 2021;
S. 1770 - Retirement Security and Savings Act of 2021;
H.R. 2954 - Securing a Strong Retirement Act of 2021.

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

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?
No Yes