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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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5. Senate ID# 400665998-48
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6. House ID# 414510003
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TYPE OF REPORT | 8. Year | 2021 |
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: Andrew M. Siff |
Date | 10/18/2021 3:31:52 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
Amendments to Prohibited Transaction Exemption (PTE) 2020-02 to allow compliance with the SEC's Regulation Best Interest to be a safe harbor that satisfies PTE 2020-02's requirement that a financial institution have policies and procedures that mitigate conflicts of interest. Possible revisions to PTE 2020-02 permitting investment advice fiduciaries to receive compensation for providing advice, including for rollovers from a retirement plan to an IRA. Non-enforcement policy in Department of Labor Field Assistance Bulletin 2018-02 related to new compliance requirements from PTE 2020-02 and the expiration of this non-enforcement policy. Forthcoming Department of Labor proposal regarding the "Definition of the Term 'Fiduciary'" (RIN 1210-AC02). Forthcoming Department of Labor proposed rule on "Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights" (RIN 1210-AC03) to replace prior administration's final rules regarding "Financial Factors in Selecting Plan Investments" (85 Fed. Reg. 39113; June 30, 2020) and "Fiduciary Duties Regarding Proxy Voting and Shareholder Rights" (85 Fed. Reg. 81658; December 16, 2020). Internal Revenue Service "Proposed Revision of Annual Information Return/Reports" (86 Fed. Reg. 51488; Sept. 15, 2021) regarding section 202 of the SECURE Act requiring implementation of a consolidated Form 5500 annual report for certain groups of similar plans by no later than January 1, 2022.
17. House(s) of Congress and Federal agencies Check if None
Labor - Dept of (DOL), 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 HOU
16. Specific lobbying issues
CDC imposed federal moratorium on eviction of tenants unable to make rental payments to prevent the spread of COVID-19.
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
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
Proposals to include in Budget Reconciliation new requirements on financial institutions to file transaction reports with the IRS for bank accounts with more than $600. Appropriations rider to preclude the Securities and Exchange Commission (SEC) from engaging in rulemaking to require public companies to disclose spending on political and public policy advocacy even if it is not material for purposes of securities law. H.R. 3684, the "Infrastructure Investment and Jobs Act," a bill to authorize funds for Federal-aid highways, highway safety programs, and transit programs; Section 80603, amending Section 6045 of the Internal Revenue Code to require 1099-B information reporting by parties involved in cryptocurrency transactions. Implementation of H. Rept. 116-617 Conference Report to accompany H.R. 6395, the National Defense Authorization Act for Fiscal Year 2021; Title LXIV, establishing beneficial ownership information reporting requirements. Office of the Comptroller of the Currency proposed rule regarding "Community Reinvestment Act Regulations" (86 Fed. Reg. 52026; September 17, 2021) to rescind and replace prior rule implementing the Community Reinvestment Act for national banks and savings associations that was published on June 5, 2020 (85 Fed. Reg. 34734). SEC reconsideration of "Regulation Best Interest" final rule (84 Fed. Reg. 33318; July 12, 2019). SEC non-enforcement policy with respect to final rule regarding "Exemptions From the Proxy Rules for Proxy Voting Advice" (85 Fed. Reg. 55082; Sept. 3, 2020). SEC development of proposed rule on "Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers" (RIN 3235-AK67). SEC staff consideration of recommendations on human capital disclosures and related possible metrics and the SECs development of a proposed rule on Human Capital Management Disclosure (RIN 3235-AM88). Financial Stability Board public consultation regarding Policy Proposals to Enhance Money Market Fund Resilience suggesting regulations for money market fund reform.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, Labor - Dept of (DOL), Securities & Exchange Commission (SEC), 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 |
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 |
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) |