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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | P.O. BOX 2600 |
Address2 | |
| City | VALLEY FORGE |
State | PA |
Zip Code | 19482 |
Country | USA |
3. Principal place of business (if different than line 2)
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State | |
Zip Code | |
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5. Senate ID# 291058-12
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6. House ID# 371950000
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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: Brian S. Mattes, Principal - Government Relations |
Date | 01/20/2013 |
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
Issues related to Dodd-Frank Wall Street Reform and Consumer Protection Act implementation and regulations, including derivatives, SIFI rules, and systemic risk
Issues related to use of derivatives by mutual funds
(see attached addendum page)
Issues related to exchange-traded funds (ETFs)
Issues related to swap execution facility trading and reporting
Issues related to definition of major swap participants
Issues related to enhancements to margin protection rules for swap participants
Issues related to nature of collateral for cleared swaps
Issues related to market structure and computerized trading matters
Issues related to H.R. 6127 - Liquidity Enhancement for Small Public Companies Act
Issues related to effect of the Volcker rule on fixed income and equity markets and mutual fund shareholders
Issues related to the supervision and regulation of certain (systemically important) nonbank financial institutions, including S. 3497 and H.R. 6317
Issues related to the Financial Stability Oversight Council and mutual funds
Issues related to legislation and regulations affecting mutual funds and the mutual fund industry
Issues related to retirement target date funds
Proposals related to potential money market fund regulations (e.g. floating net asset value, capital requirements, redemption hold-back)
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Reserve System, 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 |
Brian |
Mattes |
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Ann |
Combs |
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James |
Delaplane |
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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 BUD
16. Specific lobbying issues
Issues related to reductions in the federal debt and federal budget deficit
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 |
Brian |
Mattes |
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Ann |
Combs |
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James |
Delaplane |
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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
Proposals related to expansion of SIMPLE IRAs, establishment of discretionary payroll deduction IRAs, and creation of new qualified retirement plans for small business, including H.R. 1534, Small Businesses Add Value for Employees Act
(see attached addendum page)
Proposal related to stemming leakage from retirement plans through reform of plan loan rules, including, S. 1121/H.R. 3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act
Issues related to tax incentives for retirement savings
Issues related to the effect of the Department of Labors fiduciary definition regulation
Issues related to employee benefit plan administration and electronic delivery of ERISA-mandated statements and disclosures
Consolidation of ERISA-required notices
Issues related to Department of Labor defined contribution plan fee disclosure regulations
H.R. 4050, Retirement Plan Simplification and Enhancement Act
Issues related to retirement target date funds
Issues related to the USA Retirement Funds proposal (Senator Harkin)
Issues related to delivery of investment advice
Issues related to potential Treasury guidance on 401(k) plan design features
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Labor - Dept of (DOL), Securities & Exchange Commission (SEC)
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 |
Brian |
Mattes |
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Ann |
Combs |
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James |
Delaplane |
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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 Hike Prevention & Business Certainty Act H.R. 3091 and S. 1647
Capital gains and dividend tax rates as they relate to mutual funds
General tax issues related to mutual funds
(see attached addendum page)
Security or financial transaction tax proposals, including H.R. 6411
H.R. 6616 To protect securities transactions in the U.S. from enforcement of certain excise taxes imposed by any foreign government (imposition of foreign financial transaction tax in the U.S.)
Tax rules regarding mutual fund investments in commodities
Issues related to tax incentives for retirement savings
Issues involving commodity related investments
Issues related to the tax treatment of exchange traded notes (ETNs)
Issues related to limitations or exclusion of municipal bond interest
Issues related to fundamental tax reform
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 |
Brian |
Mattes |
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Ann |
Combs |
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James |
Delaplane |
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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 |