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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 1850 M STREET, NW |
Address2 | Suite 540 |
| City | WASHINGTON |
State | DC |
Zip Code | 20036 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 28220-12
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6. House ID# 306880000
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| TYPE OF REPORT | 8. Year | 2012 |
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. | ||||||||
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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 |
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| Signature | Digitally Signed By: Cynthia Chetti, Senior Vice President of Government Affairs |
Date | 10/19/2012 |
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 CAW
16. Specific lobbying issues
Clean Water Act, Sections 303, 308, 311, 401, 402, 404, 502
Federal Water Pollution Control Act, 33 U.S.C. Section 1318
Clean Air Act, Title VI; "Protection of Stratospheric Ozone: Adjustments to the allowance System for Controlling HCFC Production, Import and Export"
S. 2245 "Preserve Waters of the U.S. Act" (all provisions)
H.R. 4965 - Preserve the Waters of the U.S. Act (all provisions)
EPA Army Corp Wetland Guidance
FY 2013 EPA/Interior Approps
FY 2013 Energy and Water Approps
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Environmental Protection Agency (EPA), Small Business Adminstration (SBA), Office of Management & Budget (OMB), Army - Dept of (Corps of Engineers),
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 |
Cynthia |
Chetti |
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Eileen |
Lee |
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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 ENG
16. Specific lobbying issues
S.1000, the Energy Savings and Industrial Competitiveness Act of 2011 - Section #101 - Building Energy Codes, Section #201 - Building Efficiency Finance
PL 94-385 - Energy Conservation and Production Act, Section 6833 & 6836
S. 1737 Save Act: Sensible Accounting to Value Energy (all provisions)
H.R. 4017 - Smart Energy Act (all provisions)
H.R. 4230 - Home Owner Managing Energy Savings Act (all provisions)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Housing & Urban Development - Dept of (HUD), Energy - Dept of, Environmental Protection Agency (EPA)
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 |
Cynthia |
Chetti |
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Eileen |
Lee |
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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
Balanced Housing Policy
Section 8 Reform
Section 8 - Affordable Housing and Self -Sufficiency Improvment Act of 2012 (No bill number at this time.), Section 101: Inspection of dwelling units, Section 102: Rent reform and income reviews, Section 103: Eligibility for assistance based on assets, Section 201: Demonstration to expand role of private capital in affordable housing, Section 501: Access to HUD programs for persons with limited English proficiency.
HUDs FY 2013 Budget - HUD Assisted Housing Programs
Hud Section 8 Renewal Guide for Project Based Rental Properties
FHA Housing and Health Care FY 2013 Mortgage Insurance Premium Changes Prevention (CFR)
HUD Small Multi Family Risk Sharing Proposal
GSE Reform: Proposals discussed to ensure liquidity in multifamily mortgage markets in post Fannie Mae/Freddie Mac
environment.
FHA Multifamily Accelerated Processing Guide
FHFA Residential Home Purchase Rental Program
Federal Sales of Foreclosed Houses
Federal Affordable Housing Programs
H.R. 4970 - Violence Against Women Act - Section 601
S. 1925 Violence Against Women Act Reauthorization Act of 2011, Section 601: Housing Protections for Victims of Domestic Violence, Dating Violence, Sexual Assault, and Stalking (Specifically, the portion of Section 601 that would include the Low-Income Housing Tax Credit program as a covered program for purposes of the Violence Against Women Act), Sec. 602: Transitional housing assistance grants for victims of domestic violence, dating violence, sexual assault, and stalking, Sec. 603: Addressing the housing needs of victims of domestic violence, dating violence, sexual assault, and stalking.
H.R. 4264 - The FHA Emergency Fiscal Solvency Act of 2012 (all provisions)
FHA Housing Notice H 2011-36 - Large Loan Risk Mitigation Policies.
FHA Housing Notice H 2012-1 - Multi Family LIHTC Pilot Program.
FHA Housing Notice H 2012-3 - Guidance on elligiblity for tenant protection vouchers following certain housing actions.
HUD-Docket FR 5508-P-01 - Regulations on Implementation of the Fair Housing Acts Discriminatory Effects Standard
The General Accountability Office (GAO) - Multifamily Study
HUD Fair Market Rent/Small Area Fair Market Rent issue
HUD FHA Guidance to Expedite Loan Processing, Notice H-2011-35
HUD Housing Notice 2012-5 - Guidelines on Addressing Infestations in HUD-insured and Assisted Multifamily
Housing
HUD Guidance on Project Capital Needs Assessments (PCNA) and Reserve for Replacement Escrow
Lease Accounting Rules: File Reference: No. 1850-100, Exposure Draft: Leases and Exposure Draft, Leases, ED/2010/9
S. 3179 - Servicemember Housing Protection Act of 2012 (all provisions)
H.R. 2440 - Market Transparency and Taxpayer Protection Act; Section 2 - Disposition of Non-Mission Critical Assets.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Housing & Urban Development - Dept of (HUD), Natl Economic Council (NEC), Federal Housing Finance Board (FHFB), Federal Reserve System, Treasury - Dept of, Office of the Comptroller of the Currency (OCC), White House Office, Energy - 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 |
Cynthia |
Chetti |
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Jeanne |
McGlynn Delgado |
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Lisa |
Blackwell |
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David |
Cardwell |
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Eileen |
Lee |
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Matthew |
Berger |
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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 LBR
16. Specific lobbying issues
H.R. 972 - Secret Ballot Protection Act (all provisions)
S. 217 - Secret Ballot Protection Act (all provisions)
S. 1843 Representation Fairness Act (all provisions)
H.J. Res. 103 - Providing for congressional disapproval under Chapter 8 of Title 5, United States code of the rule submitted by the National Labor Relations Board relating to representation election procedures. (all provisions)
S.J. Res. 36 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the National Labor Relations Board relating to representation election procedures. (all provisions)
S. 770 Payroll Fraud Prevention Act - Amends the Fair Labor Standards Act to require employee and
non-employee classification for all workers, and notification of classification status to workers. Amends employer penalties for
non-compliance and authorizes the US Department of Labor to report noncompliance to the Internal Revenue Service. (all provisions)
Contacted the House of Representatives, US Department of Labor and the National Labor Relations Board regarding provisions
of the National Labor Relations Act covering representation elections, collective bargaining, bargaining units, and reporting and
notice requirements including proposed and finalized regulatory changes (NLRB 76 Fed. Register 36812, and DOL 76 Fed. Register 36178, and NLRB 76 Fed. Register 54006 and NLRB 76 Fed. Register 80138)
H.R. 3487 Job Creation Act of 2011 - Title VII Secret Ballot Protection Act (all provisions)
H.R. 3178 Employee Misclassification Prevention Act - amends the Fair Labor Standards Act to require
recordkeeping for non-employee workers and to notify new employees and non-employee workers of their classification and
legal rights. Sets employer penalties and federal agency requirments for communication and intra-governmental information
sharing. (all provisions)
S. 1507 - "Employee Rights Act" (all provisions)
H.R. 5326 - Commerce, Justice, Science, and Related Agencies Appropriations Act - Provisions related to funding for the Equal Employment Opportunity Commission (FY 2013) and funding for the Dept. of Justice defense of NLRB actions on secret ballots in union elections. (all provisions)
S. 3070 - DOL, HHS, DOEd and Related Agencies Approps. Act of 2013 - Provisions related to funding appropriations for DOL and NLRB. (all provisions)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Natl Labor Relations Board (NLRB), Equal Employment Opportunity Commission (EEOC), 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 |
Cynthia |
Chetti |
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Elizabeth |
Feigin Befus |
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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
H.R. 940, United States Covered Bond Act of 2011 (all provisions)
H.R. 2779 - To exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform and Consumer Protection Act (all provisions)
H.R. 2682 - Business Risk Mitigation and Price Stabilization Act of 2011 (all provisions)
S. 3480 - A bill to provide end user exemptions from certain provisions of the Commodity Exchange Act and the Securities Exchange Act of 1934 (all provisions).
Premium Capture Cash Reserve Account provision of the proposed rule on credit risk retention under the Dodd-Frank Act (76 Fed. Reg. 24090 (April 29, 2011)). Letter sent to Federal Reserve, SEC, FDIC, Treasury, HUD, and FHFA.
GSE Reform: NMHC/NAA GSE proposal and other proposals discussed to ensure liquidity in multifamily mortgage markets in
post Fannie Mae/Freddie Mac environment.
P.L. 111-203, DoddFrank Wall Street Reform and Consumer Protection Act
HUD Fair Market Rents
Public Proposals for the Future of the Housing Finance System
Section 538 Multifamily Loan Guarantee program which is administered by the United States Department of Agricultures
Lease Accounting Rules: Monitored Financial Accounting Standards Board (FASB) action on proposed lease accounting rules
that FASB has agreed to reexpose for comment, File Reference: No. 1850-100, Exposure Draft: Leases and Exposure Draft.
Leases
Financial Regulatory Reform: End-Users of Swaps and Other Derivatives
H.R. 3644 - Private Mortgage Market Investment Act. (all provisions)
S.1834 - Residential Mortgage Market Privatization and Standardization Act of 2011 (all provisions)
S.1963 - Mortgage Finance Act of 2011 (all provisions)
Comments on Dodd-Frank financial reform law (P.L. 111-203)
H.R. 2586 - Swap Execution Facility Clarification Act (all provisions)
H.R. 2779 - Legislation to exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank
Wall Street Reform and Consumer Protection Act. (all provisions)
H.R. 2682 - Business Risk Mitigation and Price Stabilization Act of 2011 (all provisions)
H.R. 4014 - Legislation to amend the Federal Deposit Insurance Act with respect to information provided to the Bureau of
Consumer Financial Protection. (all provisions)
S. 2099- A bill to amend the Federal Deposit Insurance Act with respect to information provided to the Bureau of Consumer
Financial Protection. (all provisions)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Reserve System, Treasury - Dept of, Housing & Urban Development - Dept of (HUD), Securities & Exchange Commission (SEC), Federal Deposit Insurance Commission (FDIC), Federal Housing Finance Board (FHFB)
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 |
Cynthia |
Chetti |
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David |
Cardwell |
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Lisa |
Blackwell |
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Eileen |
Lee |
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Jeanne |
McGlynn Delgado |
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Matthew |
Berger |
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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 ENV
16. Specific lobbying issues
P.L. 102-550, Residential Lead Based Paint Hazard Reduction Act, Section 402, Section 403, and Section 404; Lead Safe Housing Rule
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, Environmental Protection Agency (EPA), Small Business Adminstration (SBA), Housing & Urban Development - Dept of (HUD), 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 |
Cynthia |
Chetti |
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Eileen |
Lee |
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Lisa |
Blackwell |
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David |
Cardwell |
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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 IMM
16. Specific lobbying issues
H.R. 2885 Legal Workforce Act of 2011 (all provisions)
S. 1196 Accountability Through Electronic Verification Act (all sections)-Requires participation in, and establishes rules for, the
E-Verify worker eligibility screening program.
H.R. 5855 - DHS Approps Act 2013 - Provisions related to the e-Verify Program
S. 3216 - DHS Approps Act 2013 - Provisions related to the e-Verify Program
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Homeland Security - Dept of (DHS), U.S. Citizenship & Immigration Services (USCIS)
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 |
Cynthia |
Chetti |
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Elizabeth |
Feigin Befus |
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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 CIV
16. Specific lobbying issues
H.R. 3358 - ADA Compliance for Customer Entry to Stores and Services Act (Access Act) (all provisions)
ADA Revised Requirements - Accessible Pools Means of Entry and Exit
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, Justice - Dept of (DOJ)
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 |
Cynthia |
Chetti |
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Jeanne |
McGlynn Delgado |
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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 TEC
16. Specific lobbying issues
Federal policies impacting availability and reliability of spectrum and wireless access within apartment communities. Federal regulations impacting telecommunications services to multifamily buildings including telephone, internet, and television services via various technologies.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, Federal Communications Commission (FCC)
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 |
Cynthia |
Chetti |
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Elizabeth |
Feigin Befus |
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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
Tax reform: No specific bill but asked that Congress take a comprehensive approach to tax reform and not enact reform for C corporations at the expense of flow-thru entities, including partnerships, S Corporations, and LLCs. We also asked policymakers not to tax flow-through entities with revenues over certain thresholds as C corporations or to pass legislation that would disadvantage real estate relative to other industries.
We further requested that Congress maintain the deductibility of business interest and the Low-Income Housing Tax Credit. Finally, we urged Congress to enact permanent estate tax reform with a $5 million exemption, 35 percent top rate, and a retention of stepped-up basis rules.
H.R. 6169, Pathway to Job Creation through a Simpler, Fairer Tax Code Act of 2012. Section 3: Expedited Consideration of a Measure Providing for Comprehensive Tax Reform.
Small Business Tax Legislation:
H.R. 9 and S. Amdt. 2524, Small Business Tax Cut (all provisions).
S. 2237. Small Business Jobs and Tax Relief Act. Section 2: Temporary Tax Credit for Increased Payroll. Section 3: Extension of Allowance of Bonus Depreciation for Certain Business Assets.
2001 and 2003 Tax Cuts: We supported an extension of tax rates applicable to income, capital gains and dividends, and the estate tax. The specific bills in which we engaged in lobbying activities were:
S. 3412, Middle Class Tax Cut Act. Section 101: Temporary Extension of 2001 Tax Relief. Section 102: Temporary Extension of 2003 Tax Relief. Section 201: Temporary Extension of Increased Alternative Minimum Tax Exemption Amount.
S. 3413, Tax Hike Prevention Act of 2012. Section 2: Temporary Extension of 2001 Tax Relief. Section 3: Temporary Extension of 2003 Tax Relief. Section 4. Alternative Minimum Tax Relief.
S. Amdt. 2573. Section 2: Temporary Extension of 2001 Tax Relief. Section 3: Temporary Extension of 2003 Tax Relief. Section 4. Alternative Minimum Tax Relief.
H.R. 8. Job Protection and Recession Prevention Act of 2012. Section 2: Extension of 2001 and 2003 Tax Relief. Section 4: Extension of Alternative Minimum Tax Relief for Individuals
Tax Extenders: We supported extending the following expiring tax provisions: New Markets Tax Credit (IRC Section 45D); Energy Efficient New Homes Tax Credit (IRC Section 45L); Increased AMT exemption amount (IRC Section 55(d)); Additional 100 Bonus Depreciation (IRC Section 168(k)); Expensing of Brownfield Remediation Costs (IRC Section 198). Additionally, we engaged in lobbying activities on the following bill:
S. 3521, Family and Business Tax Cut Certainty Act of 2012: Section 101. Extension of increased alternative minimum tax exemption amount. Section 202. Extension of temporary minimum low-income tax credit rate for non-federally subsidized new buildings. Section 205. Extension of New Markets Tax Credit. Section 308. Extension of credit for energy efficient new homes.
Carried Interest: We opposed changes to current law as part of any legislation. We also specifically opposed H.R. 4016, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities (all provisions).
Low-Income Housing Tax Credit:
H.R. 3661 and S. 1989, to make permanent the 9 percent tax credit for the Low-Income Housing Tax Credit (LIHTC) and to extend the same policy to 4 percent LIHTCs for acquisition (all provisions).
We also urged Congress to preserve the Low-Income Housing Tax Credit as part of any tax reform effort.
Although no bill is pending, we urged Congress to support making the Low-Income Housing Tax Credit more flexible by allowing developments to qualify if 40 percent of units go to families with income that averages no more than 60 percent of area median income.
S. 3494: LIHTC legislation to allow homeless and formerly homeless youth to be eligible for LIHTC housing without giving up their status as full-time students (all provisions).
H.R. 5746, Update and Streamline REIT Act of 2012 (all provisions).
IRS Temporary (T.D. 9564) and proposed rules (REG-168745-03) regarding deduction and capitalization of expenditures related to tangible property under IRC 263(a).
IRS REG-136491 regarding regulations applicable to utility charges and the Low-Income Housing Tax Credit
S. 3591, Commercial Building Modernization Act (IRC 179D reform) (proposed IRC 179F) - To amend the IRC of 1986 to improve and extend the deduction for new and existing energy efficient commercial buildings, and for other purposes (all provisions).
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 |
Cynthia |
Chetti |
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Matthew |
Berger |
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Eileen |
Lee |
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David |
Cardwell |
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Jeanne |
McGlynn Delgado |
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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
S.A. 2641 - Carper/Blunt Amendment to the Data Security Act of 2012 (S. 1434)
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 |
Cynthia |
Chetti |
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Jeanne |
McGlynn Delgado |
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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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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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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
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FOREIGN ENTITIES
27. Add the following foreign entities:
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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 | 5 | 9 |
| 2 | 6 | 10 |
| 3 | 7 | 11 |
| 4 | 8 | 12 |