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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 | 2018 |
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. | ||||||||
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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: Andrew M. Siff |
Date | 1/7/2019 2:30:46 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 FIN
16. Specific lobbying issues
H.R. 3089, the "Corporate Transparency Act of 2017," legislation directing the Treasury Department to require every business owner in the United States to file with the government the name, address, and a copy of a driver's license or unexpired passport of every individual who, directly or indirectly, derives a substantial economic benefit from, exercises substantial control over, or has certain other interests in a legal entity and further requiring business owners to update this information within 60 days of any change in individuals who, directly or indirectly, have such an interest or any change in the information about an individual already disclosed as having a reportable direct or indirect interest; entire bill. H.R. 5037, the "Securities Fraud Act of 2018," legislation to ensure that federal securities law is applied to securities traded on nationally-registered exchanges regulated by the SEC; entire bill. H.R. 6068, the "Counter Terrorism and Illicit Finance Act," legislation to update dollar amount thresholds for certain currency transaction reports and suspicious activity reports, to improve information sharing between financial institutions with respect to terrorism, money laundering, and other unlawful activities, and to provide an 18-month enforcement delay of FinCEN's final rulemaking on Customer Due Diligence (81 Fed. Reg. 29397, May 11, 2016); entire bill. H.R. 6239, the "DISCLOSE Act of 2018," legislation to amend the Federal Election Campaign Act of 1971 to provide for additional disclosure requirements for corporations, labor organizations, Super PACs and other entities; provisions related to beneficial ownership, the SEC requiring public companies to disclose political spending, and requirements for federal contractors to disclose their support for public issues and causes that are not otherwise subject to disclosure under federal law. S. 3150, the "DISCLOSE Act of 2018," legislation to amend the Federal Election Campaign Act of 1971 to provide for additional disclosure requirements for corporations, labor organizations, Super PACs and other entities; provisions related to beneficial ownership, the SEC requiring public companies to disclose political spending, and requirements for federal contractors to disclose their support for public issues and causes that are not otherwise subject to disclosure under federal law. S. 1454, the "True Incorporation Transparency for Law Enforcement (TITLE) Act," legislation to direct each state to amend their business formation laws to require every business owner in the United States to file with the government the name, address, and a copy of a driver's license or unexpired passport of every individual who, directly or indirectly, derives a substantial economic benefit from, exercises control over, or has certain other interests in a legal entity and further requiring business owners to update this information within 60 days of any change in individuals who, directly or indirectly, have such an interest or any change in the information about an individual already disclosed as having a reportable direct or indirect interest; entire bill. S. 3421, the "Blue Sky Harmonization Act," legislation to ensure uniform application of federal securities law is applied to securities traded on nationally registered exchanges regulated by the SEC; entire bill. Implementation of Pub. Law 115-174, the "Economic Growth, Regulatory Relief, and Consumer Protection Act." Nomination of Dino Falaschetti for Director of the Office of Financial Research. Efforts by states to impose fiduciary obligations on investment professionals who handle ERISA funds. General education concerning the need to include in the Senate Financial Services General Government Appropriations Bill the policy rider prohibiting the Securities and Exchange Commission from using funds to promulgate any rule compelling public companies to disclose payments made to entities, such as trade associations, that engage in political activity. General education concerning the Financial Stability Oversight Council's exercise of authority to designate entities for enhanced oversight under section 117 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. General education concerning the need for a uniform federal regulatory scheme for financial technology. General education concerning the need to modernize and improve the Bank Secrecy Act and Anti-Money Laundering (BSA/AML) regime applicable to financial institutions. General education concerning ways to rationalize and improve the Consumer Financial Protection Bureau's regulatory and enforcement policies. General education regarding the SEC's proposed Regulation Best Interest (83 Fed. Reg. 21574, May 9, 2018), and Form CRS Relationship Summary (83 Fed. Reg. 21416, May 9, 2018).
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Labor - Dept of (DOL), 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 |
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 LBR
16. Specific lobbying issues
Implementation of the Department of Labor / Occupational Safety and Health Administration whistleblower regime for the financial services industry pursuant to the Sarbanes-Oxley Act and the Dodd-Frank Act.
17. House(s) of Congress and Federal agencies Check if None
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 |
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 RET
16. Specific lobbying issues
Employee Benefits Security Administration Interpretive Bulletins 2018-01, 2016-01, 2015-01, and 2008-1 concerning fiduciary duties associated with plan assets. Regulatory guidance concerning the voting of proxies by ERISA funds.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, 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 |
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 |