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

Prudential agency (Federal Reserve, OCC and FDIC) proposal to implement the Basel Endgame reforms in the U.S. and congressional (U.S. House and Senate) oversight of the same, including revisions to the trading book capital rules, stress testing, capital surcharges and buffers;
SEC Prohibition Against Conflicts of Interest in Certain Securitizations proposed rule;
H.R. 4168, a bill to amend the Securities Act of 1933 to require that information required to be disclosed to the Securities and Exchange Commission by issuers be material to voting or investment decisions regarding those issuers, and for other purposes;
H.R. 4237, a bill to amend the Investment Advisers Act of 1940 and the Employee Retirement Income Security Act of 1974 to specify requirements concerning the consideration of pecuniary and non-pecuniary factors;
H.R. 1807, the Improving Disclosure for Investors Act of 2023;
SEC proposed rule regarding the safeguarding of client assets (custody proposal);
S. 2190, the RECOUP Act, a bill to amend the Federal Deposit Insurance Act to increase bank executive accountability and to improve financial stability;
SEC no-action letter regarding compliance with the provisions relating to research in the Markets in Financial Instruments Directive II (MiFID II), including H.R. 2622 and S. 2141, to codify certain SEC no action letters that allow broker-dealers to continue accepting cash or "hard dollar" payments for research reports, in order to comply with international regulations such as MiFID and MiFID II;
H.R. ____, to exempt 144a fixed income securities from Rule 15c2-11;
S. 1695, the American Infrastructure Bonds Act of 2023;
H.R. 1837, the Investing in Our Communities Act;
H.R. 4664 and S. 2309, the Fiscal Year 2024 Financial Services and General Government Appropriations bill related to Consolidated Audit Trail and SEC regulatory agenda;
SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing proposed rule;
SEC Amendments to NMS Plan for the Consolidated Audit Trail-Data Security;
SEC Staff Accounting Bulletin 121;
SEC Security-based Swaps Large Position Reporting proposed rule;
SEC Securities Loans proposed rule.
H.R.760 - Chinese Military and Surveillance Company Sanctions Act of 2023;
H.R. 1177/S. 427, Financial Freedom Act of 2023
H.R.4552 - Federal Information Security Modernization Act of 2023
H.R. 4763 - the Financial Innovation and Technology for the 21st Century Act
H.R. 4767 - Protecting American's Retirement Savings from Politics Act
H.R. 3136 - The National Critical Capabilities Defense Act;
S.2678 - Outbound Investment Transparency Act of 2023
S. 2251 - Cybersecurity Act of 2023
SEC Proposed Rule on Predictive Data Analytics
SEC proposal regarding Reporting of Securities Loans
SEC proposals to modify equity market structure
Biden Administration Executive Order related to China

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 proposal related to security-based swaps large trader reporting;
H.R. 4763 - the Financial Innovation and Technology for the 21st Century Act;
SEC proposal regarding Safeguarding Advisory Client Assets

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

SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing proposed rule;
H.R. 1837, the Investing in Our Communities Act;
S. 1453, the LOCAL Infrastructure Act;
H.R. 4664 and S. 2309, the Fiscal Year 2024 Financial Services and General Government Appropriations bill related to the Consolidated Audit Trail and SEC regulatory agenda.
H.R.760 - Chinese Military and Surveillance Company Sanctions Act of 2023
H.R. 1807 - Improving Disclosure for Investors Act of 2023
SEC no-action letter regarding compliance with the provisions relating to research in the Markets in Financial Instruments Directive II (MiFID II), including H.R. 2622 and S. 2141, to codify certain SEC no action letters that allow broker-dealers to continue accepting cash or "hard dollar" payments for research reports, in order to comply with international regulations such as MiFID and MiFID II;
H.R.4552 - Federal Information Security Modernization Act of 2023
S. 1695, American Infrastructure Bond Act of 2023, U.S. Senate
H.R. 3136 - The National Critical Capabilities Defense Act;
S.2678 - Outbound Investment Transparency Act of 2023
S. 2251 Cybersecurity Act of 2023
SEC 15c2-11 staff interpretation to impact 144A private securities
SEC proposals to modify equity market structure
SEC proposal regarding Reporting of Securities Loans
SEC proposal regarding Position Reporting of Large Security-Based Swap Positions
SEC proposal regarding Safeguarding Advisory Client Assets
SEC proposal regarding Prohibition of Conflicts of Interest in Certain Securitizations
Public Law 117-328 - Consolidated Appropriations Law (FSGG report language related to the Consolidated Audit Trail)
Senior investors/diminished capacity investors regarding the event for Word Elder Abuse Awareness Day
Sustainable Finance - Legislative proposals related to Environmental, Social, and Governance considerations in investment decisions
FTC Hart Scott Rodino Proposal
Private Fund Legislative Proposals
Fiscal Year 2024 Financial Services and General Government Appropriations bill (all provisions)

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

H.R. 1837, the Investing in Our Communities Act;
S. 1990, Tax on Wall Street Speculation Act.
Federal Register No. 2023-12799: Section 6418 Transfer of Certain Credits under Internal Revenue Service
S. 1695, American Infrastructure Bonds Act of 2023
S. 2491/H.R. 4870, Wall Street Tax Act of 2023
Taxation of contract modifications associated with transition from LIBOR to alternative reference rates, including SOFR
Modernization Derivatives Tax Act
Proposals to expand bank information reporting requirements
Public Law 117-328 - Consolidated Appropriations Law (Secure 2.0 retirement provisions).
IRS Transmitter Control Codes and Electronic Filing of Form 1042
IRS Draft Revised W-8EXP
IRS Tax Treatment of Digital Assets
U.S. Senate Draft Form W-9
IRS Stock Buyback Excise Tax
U.S. Treasury, IRS Request for Extension of Comment Period for REG-122793-19 Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions (proposed regulations)

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

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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 RET

16. Specific lobbying issues

SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing proposed rule;
H.R. 1177 and S. 427, the Financial Freedom Act of 2023
H.R. 5337 Retirement Proxy Protection Act
H.R. 5338 No Discrimination in My Benefits Act
H.R. 5339 RETIRE Act
H.R. 5340 Providing Complete Information to Retirement Investors Act
DOL Fiduciary Rule
General Education on DOL Amendments to Qualified Professional Asset Manager
PTE Changes
Public Law 117-328 - Consolidated Appropriations Law (Secure 2.0 retirement provisions)
Enhancing American Retirement Now (EARN) Act

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