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 SMB

16. Specific lobbying issues

Access to Capital and COVID-19:

Paycheck Protection Program (PPP): Advocated for an extension/restoration of the expired PPP loan program, increasing funds for the program, and fixes that include greater flexibility in use of funds for forgiveness (for example, PPE and cloud-based services), allowing small businesses to select their window for forgiveness, removing the 60-40 payroll-to-operational expense ratio to broaden the use of the program for more small businesses, clarifying that PPP forgiven expenses are tax deductible as intended by Congress in the original CARES Act, simplifying the forgiveness process, and greater targeting of the program to the smallest of businesses and disadvantaged businesses. Voiced support for full transparency of the PPP program. Supported PPP continuance as voted upon by the U.S. Senate in the Continuing Paycheck Protection Act. Supported the year-end spending and stimulus package passed by Congress and signed by President Trump that included PPP re-up, expansion and reform.

Supported a temporary, legal safe harbor for small businesses as provided by in the Safe to Work Act.

Economic Injury Disaster Loan (EIDL) Program: Advocated for small businesses to access the $10,000 grant as provided for by CARES Act legislation, for the Small Business Administration to remove the arbitrary $150,000 loan cap placed on loans, and additional EIDL funds in general, as called for and passed in the year-end spending and stimulus package.

Main Street Recovery Co-Investment Fund: Advocated for a government match co-investment fund for small businesses that would utilize the regulatory framework for investment crowdfunding, which will help to broadly deliver capital to small businesses across the country.

Other: Supported the development of a loan program for small businesses with low interest rates and long-term payment terms in order to help them recover from the shock of COVID-19.
Urged the Congress to advance a COVID-19 recovery and relief package.

SEC Action on Regulated Crowdfunding: Supported the final rules released by the Securities and Exchange Commission (SEC) on November 2, 2020 to: Increase the maximum, a company can raise from $1.07 million to $5 million; Amend the investment limits for investors in Regulation Crowdfunding offerings by not applying any investment limits to accredited investors while revising the calculation method for investment limits for non-accredited investors to allow them to rely on the greater of their annual income or net worth when calculating the limit on how much they can invest; Permit issuers to test-the-waters prior to filing an offering document with the Commission; Permit demo day communications that would not be deemed general solicitation or general advertising; Permit the use of Special Purpose Vehicles to facilitate investing in Regulation Crowdfunding issuers; and Extend for 18 months the existing temporary relief providing an exemption from certain Regulation Crowdfunding financial statement review requirements for issuers offering $250,000 or less of securities in reliance on the exemption within a 12-month period.

Access to Affordable Health Care:

Most Favored Nation Policy: Continue to oppose the Administrations most favored nation policy for U.S. drugs given its impact on costs, innovation and investment in this sector. This policy, also known as an International Price Index, marks foreign prices to U.S. drugs and many of these nations impose price controls.

Access to Broadband and Telecommunications Policy:

Broadband Infrastructure: Continue to support a federal allocation of funds to build out broadband in underserved and rural areas of the country. Supported the inclusion of infrastructure funds in the year end COVID-19 stimulus and relief package being considered by Congress. Urged the Administration to oppose 5G nationalization.

FCC Action: Supported four orders advanced by the Federal Communications Commission (FCC) on October 27, 2020 that included the establishment a 5G fund for rural America, increased unlicensed wireless opportunities in TV white spaces, a remand of the Restoring Internet Freedom Order, and the streamlining of state and local approval of certain wireless structure modifications to further accelerate the deployment of 5G.

Regulatory Reform, Relief and Transparency:

Corporate Transparency Act: Opposed this measure in the National Defense Authorization Act, which imposes new requirements on every small business in America.

DOL Comments: Filed comments in support of the Department of Labors proposed rule on Fiduciary Duties Regarding Proxy Voting and Shareholder Rights on Retirement Savings.

DOL Comments: Filed comments in general support of the Department of Labors proposed tule on Financial Factors in Selecting Plan Investments in relation to Environmental, Social and Governance (ESG) investing.

FCC Comments: Filed comments on Federal Communications Commission (FCC) CG Docket No. 02-278 Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991 and CG Docket No. 18-152 Consumer and Government Affairs Bureau Seeks Comments on Interpretation of the Telephone Consumer Protection Act (TCPA) in Light of the D.C. Circuits ACA International Decision. Comments focused on our organizations support of TCPA modernization given the broad adoption and standard use of technology by small businesses and consumers in two-way communications with each other.

EPA Transparency/Benefit-Cost Analysis Rule: Supported the Environmental Protection Agencys (EPAs) final rule: Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act (CAA) Rulemaking Process.

Competition and Anti-Trust Policy:

Technology Regulation and Actions: Expressed concern about the Federal Trade Commissions (FTCs) actions against Facebook and the impact on small business users of the platform to reach, market to and engage with customers and others.

Intellectual Property Rights

CASE Act (H.R. 2426, S. 1273): Supported passage of the Copyright Alternative in Small Claims Enforcement Act (CASE Act).

Advancing Americas Interests Act of 2020 (H.R. 8037): Support the legislation.

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

U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Federal Communications Commission (FCC), Environmental Protection Agency (EPA), Labor - Dept of (DOL), Small Business Administration (SBA), White House Office

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