Conflicted Investment Advice Prohibition Act of 2009

H.R. 1984 (401(k) Fair Disclosure Act); H.R. 1988 (Conflicted Investment Advice Prohibition Act of 2009); H.R. 2779 (Defined Contribution Plan Fee Transparency Act of 2009); H.R. 2989 (401(k) Fair Disclosure and Pension Security Act of 2009); H.R. 3308 (Secure America Through Verification and Enforcement Act of 2009) (SAVE Act of 2009); H.R. 4126 (Retirement Fairness Act of 2009); H.R. 4213 (American Jobs and Closing Tax Loopholes Act of 2010)(Fee Disclosure); H.R. 4742 (Small Business Add Value for Employees (SAVE) Act of 2009); S. 906 (Senior Investment Protection Act); S. Amdt. 3792 (Fiduciary Duty); DOL ERISA Fiduciary Duty Rulemaking; Partial rollovers.

Client expense: $1,280,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

Discussed financial regulatory reforms, including consumer and investor protections, a potential systemic risk regulator, and consolidation of agencies (no bill). H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act of 2009 - Lobbied for increased transparency of 401(k) fees paid for by plan participants. H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009 - Lobbied to ensure that individually directed account plan participants received investment advice from qualified advisors who are free from financial conflicts of interests. H.R. 2779, Defined Contribution Plan Fee Transparency Act of 2009 - Lobbied for increased transparency of 401(k) fees paid for by plan participants. H.R. 2989, 401(k) Fair Disclosure and Pension Security Act of 2009 - Lobbied for increased transparency of 401(k) fees paid for by plan participants and to ensure that individually directed account plan participants received investment advice from qualified advisors who are free from financial conflicts of interests. H.R. 3936 - Preserve Benefits and Jobs Acts of 2009 - Discussed need for pension funding relief in light of the combined impact of the U.S. recession and the funding requirements of the 2006 Pension Protection Act. S. 2832, Lifetime Income Disclosure Act - Lobbied in support of this legislation, which would provide individuals a better understanding of the lifetime value of their 401(k) plan assets by including in a yearly benefit statement a conversion of their total accrued benefits into a monthly dollar amount as if they had opted to receive a lifetime annuity. H.R. 4173, the Wall Street Reform and Consumer Protection Act of 2009 - Discussed implementation of legislation. H.R. 4849, the Small Business and Infrastructure Jobs Tax Act of 2010 - Discussed the potential inclusion of 401(k) fee disclosure and pension funding relief provisions within the bill. Ultimately, these provisions were not included in the legislation. H.R. 4213, the American Jobs and Closing Tax Loopholes Act - Lobbied for the inclusion of 401(k) fee disclosure provisions within the House version of the legislation. Senate Substitute Amendment to H.R. 4213, the American Jobs and Closing Tax Loopholes Act - Lobbied for the inclusion of 401(k) fee disclosure provisions within the Senate version of the legislation. Discussed issues surrounding lifetime income products, such as annuities, and provided written testimony for the Senate Special Committee on Aging hearing entitled "The Retirement Challenge-Making Savings Last a Lifetime." (no bill)

Client expense: $9,120,000 · Firm income: Not reported

Government targets: Administration on Aging, Centers For Medicare and Medicaid Services (CMS), Energy, Dept of, Equal Employment Opportunity Commission (EEOC), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), Federal Reserve System, Food & Drug Administration (FDA), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Medicare Payment Advisory Commission (MedPAC), Natl Highway Traffic Safety Administration (NHTSA), Office of Management & Budget (OMB), Office of Personnel Management (OPM), Office of the Vice President of the United States, SENATE, Securities & Exchange Commission (SEC), Social Security Administration (SSA), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

Discussed financial regulatory reforms, including consumer and investor protections, a potential systemic risk regulator, and consolidation of agencies (no bill). H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act of 2009 - Lobbied for increased transparency of 401(k) fees paid for by plan participants. H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009 - Lobbied to ensure that individually directed account plan participants received investment advice from qualified advisors who are free from financial conflicts of interests. H.R. 2779, Defined Contribution Plan Fee Transparency Act of 2009 - Lobbied for increased transparency of 401(k) fees paid for by plan participants. H.R. 2989, 401(k) Fair Disclosure and Pension Security Act of 2009 - Lobbied for increased transparency of 401(k) fees paid for by plan participants and to ensure that individually directed account plan participants received investment advice from qualified advisors who are free from financial conflicts of interests. H.R. 3936 - Preserve Benefits and Jobs Acts of 2009 - Discussed need for pension funding relief in light of the combined impact of the U.S. recession and the funding requirements of the 2006 Pension Protection Act. S. 2832, Lifetime Income Disclosure Act - Lobbied in support of this legislation, which would provide individuals a better understanding of the lifetime value of their 401(k) plan assets by including in a yearly benefit statement a conversion of their total accrued benefits into a monthly dollar amount as if they had opted to receive a lifetime annuity. H.R. 4173, the Wall Street Reform and Consumer Protection Act of 2009 - Discussed implementation of legislation. H.R. 4849, the Small Business and Infrastructure Jobs Tax Act of 2010 - Discussed the potential inclusion of 401(k) fee disclosure and pension funding relief provisions within the bill. Ultimately, these provisions were not included in the legislation. H.R. 4213, the American Jobs and Closing Tax Loopholes Act - Lobbied for the inclusion of 401(k) fee disclosure provisions within the House version of the legislation. Senate Substitute Amendment to H.R. 4213, the American Jobs and Closing Tax Loopholes Act - Lobbied for the inclusion of 401(k) fee disclosure provisions within the Senate version of the legislation. Discussed issues surrounding lifetime income products, such as annuities, and provided written testimony for the Senate Special Committee on Aging hearing entitled "The Retirement Challenge-Making Savings Last a Lifetime." (no bill)

Client expense: $9,120,000 · Firm income: Not reported

Government targets: Administration on Aging, Centers For Medicare and Medicaid Services (CMS), Energy, Dept of, Equal Employment Opportunity Commission (EEOC), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), Federal Reserve System, Food & Drug Administration (FDA), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Medicare Payment Advisory Commission (MedPAC), Natl Highway Traffic Safety Administration (NHTSA), Office of Management & Budget (OMB), Office of Personnel Management (OPM), Office of the Vice President of the United States, SENATE, Securities & Exchange Commission (SEC), Social Security Administration (SSA), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

H.R. 519: ELDER CAREGIVER SUPPORT AND INFORMATION ENHANCEMENT ACT OF 2009; PROVISIONS RELATED TO LONG TERM CARE INFORMATION CLEARINGHOUSE H.R. 1961: SAVINGS FOR AMERICAN FAMILIES FUTURE ACT OF 2009; PROVISIONS RELATED TO SAVERS' CREDIT H.R.1984: 401(K) FAIR DISCLOSURE FOR RETIREMENT SECURITY ACT OF 2009; PROVISIONS RELATED TO RETIREMENT PLAN FEE DISCLOSURE H.R. 1988: CONFLICTED INVESTMENT ADVICE PROHIBITION ACT OF 2009; PROVISIONS RELATED TO INVESTMENT ADVICE H.R. 2021: SAVINGS RECOVERY ACT OF 2009; PROVISIONS RELATED TO SAVERS CREDIT H.R. 2733/S. 1389: FIXED INDEXED ANNUITIES AND INSURANCE PRODUCTS CLASSIFICATION ACT OF 2009; PROVISIONS RELATED TO CLARIFICATION FOR FIXED ANNUITIES REGULATION H.R. 2748: RETIREMENT SECURITY NEEDS LIFETIME PAY ACT OF 2009; PROVISIONS RELATED TO TAX INCENTIVES FOR ANNUITIES H.R. 2779: DEFINED CONTRIBUTION PLAN FEE TRANSPARENCY ACT OF 2009; PROVISIONS RELATED TO 401(K) PLAN FEE DISCLOSURE H.R. 2792: RETIREMENT SAVINGS TRANSPARENCY ACT OF 2009; PROVISIONS RELATED TO PLAN FEE DISCLOSURE H.R. 2989: 401 (K) FAIR DISCLOSURE AND PENSION SECURITY ACT OF 2009; PROVISIONS RELATED TO RETIREMENT PLAN FEE DISCLOSURE H.R. 3551 /S. 1661/S. 906: SENIOR INVESTMENT PROTECTION ACT OF 2009; PROVISIONS RELATED TO PRODUCT SALES TO SENIORS AND ANNUITIES SALES H.R. 3590: THE PATIENT PROTECTION AND AFFORDABLE CARE ACT; PROVISIONS RELATED TO LONG TERM CARE FINANCING WITHIN HEALTH REFORM, AND MEDICARE TAX ON NONQUALIFIED ANNUITY INCOME H.R. 4126: RETIREMENT FAIRNESS ACT OF 2009; PROVISIONS RELATED TO MODIFICATION OF 401(K) PLAN RULES H.R. 4173: DODD-FRANK WALL STREET REFORM AND CONSUMER PROTECTION ACT (FKA: RESTORING AMERICAN FINANCIAL STABILITY ACT OF 2010); ALL PROVISIONS OF THE BILL H.R. 4213: UNEMPLOYMENT COMPENSATION EXTENSION ACT OF 2010 (FKA: AMERICAN JOBS AND CLOSING TAX LOOPHOLES ACT OF 2010); PROVISIONS RELATED TO 401(K) PLAN FEE DISCLOSURE H.R. 4626: HEALTH INSURANCE INDUSTRY FAIR COMPETITION ACT; PROVISIONS RELATED TO INSURANCE ANTI-TRUST REGULATIONS (MCCARRON-FERGUSON) H.R. 4742: SMALL BUSINESSES ADD VALUE FOR EMPLOYEES (SAVE) ACT OF 2009; PROVISIONS RELATED TO SIMPLIFICATION OF SIMPLE IRAS, AND VOLUNTARY AUTO IRAS H.R. 4872: HEALTH CARE AND EDUCATION RECONCILIATION ACT OF 2010; PROVISIONS RELATED TO LONG TERM CARE FINANCING WITHIN HEALTH CARE REFORM, AND UNEARNED INCOME TAXATION H.R. 5297: SMALL BUSINESS JOBS AND CREDIT ACT OF 2010; PROVISIONS RELATED TO PARTIAL ANNUITIZATION AND ROTH CONVERSIONS OF 401(K) SAVINGS S. 401: DEFINED CONTRIBUTION FEE DISCLOSURE ACT OF 2009; PROVISIONS RELATED TO 401(K) PLAN FEE DISCLOSURE S. 1177: CONFIDENCE IN LONG-TERM CARE INSURANCE ACT OF 2009; PROVISIONS RELATED TO CONSUMER PROTECTION IN LONG TERM CARE S. 1297: RETIREMENT SECURITY FOR LIFE ACT OF 2009; PROVISIONS RELATED TO NON-QUALIFIED ANNUITIES TAX INCENTIVES S. 1626: LONG TERM CARE INSURANCE INTEGRITY ACT OF 2009; PROVISIONS RELATED TO LONG TERM CARE S.1636: LONG TERM CARE INSURANCE CONSUMER RIGHT-TO-KNOW ACT OF 2009; PROVISIONS RELATED TO LONG TERM CARE CONSUMER PROTECTIONS S. 2832: LIFETIME INCOME DISCLOSURE ACT; PROVISIONS RELATED TO ANNUITY ILLUSTRATION ON BENEFIT STATEMENTS S. 3217: RESTORING AMERICAN FINANCIAL STABILITY ACT OF 2010; PROVISIONS RELATED TO REGULATORY REFORM

Client expense: $380,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Limit Executive Compensation Abuse Act - H.R. 857 The Savings for American Families Future Act of 2009 H.R. 1961 The 401 (k) Fair Disclosure for Retirement Security Act 0f 2009 H.R. 1984 Conflicted Investment Advice Prohibition Act of 2009 H.R. 1988 Savings Recovery Act H.R. 2021 Retirement Security Needs Lifetime Pay Act H.R. 2748 Retirement Savings Transparency Act of 2009 - H.R. 2792 The Defined Contribution Plan Fee Transparency Act H.R. 2779 401 (k) Fair Disclosure and Pension Security Act of 2009 H.R. 2989 Consumer Financial Protection Agency Act of 2009 H.R. 3126 Foreign Account Tax Compliance Act of 2009 H.R. 3933 Preserve Benefits and Jobs Act of 2009 H.R. 3936 Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act H.R. 3962/Public Law No: 111-192 Retirement Fairness Act H.R. 4126 Sensible Transparency for Retirement Plans Act H.R. 4146 Tax Technical Corrections Act of 2009 H.R. 4169 Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 American Workers, State, and Business Relief Act H.R. 4213/Unemployment Compensation Extension Act of 2010 (tax extenders) Public Law No: 111-205 Small Businesses Add Value for Employees Act of 2009 (SAVE Act) H.R. 4742 Middle Class Tax Cut Act (Senate Amendment 4727) package of tax extensions and other provisions to the defined benefit pension funding relief provisions, and a provision extending parity for employee transit subsidies Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act H.R. 4853 Amendment to a Federal Aviation Administration funding extension bill H.R. 4915 Medicare and Medicaid Extenders Act H.R. 4994 Employee Misclassification Prevention Act (EMPA) H.R. 5107 Small Business Jobs and Credit Act of 2010 H.R. 5297 tax extenders, defined benefit pension plan funding relief - technical corrections from H.R. 3962 Automatic IRA Act of 2010 H.R. 6099 Fair Playing Field Act of 2010 H.R. 6128 (worker classification) Public Employee Pension Transparency Act - H.R. 6484 Health Care Reform regulatory implementation and compliance issues from the Patient Protection and Affordable Care Act (PPACA) Public Law No: 111-148 & the Health Care and Education Reconciliation Act of 2010 (HCERA) Public Law 111-152 new compensation deduction limits on entities receiving health insurance premiums (162 (m)(6)) Financial Services Reform regulation of swaps transactions, major swap participants (MSPs), swaps, business conduct standards, fiduciary duty and liability issues; effects on pension, retirement, and health plans that use swaps; 401 (k) stable value funds and contracts, retirement plan administration, compensation disclosure issues Pension Funding - additional funding relief and technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, PBGC premium funding target methods and premium submission issues, plan termination issues Retirement Security nonqualified deferred compensation, executive compensation, defined contribution plan issues, 401 (k) plans, conversions to Roth 401 (k) plans, automatic IRAs, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures for retirement plans National Commission on Fiscal Responsibility and Reform implications for benefits Senate Cap Executive Officer Pay Act of 2009 - S. 360 The Defined Contribution Fee Disclosure Act of 2009 - S. 401 Shareholder Bill of Rights Act S. 1074 Retirement Security for Life Act of 2009 S. 1297 Pension Benefit Guaranty Corporation (PBGC) Governance Improvement Act of 2009 S. 1544 Foreign Account Tax Compliance Act of 2009 S. 1934 Lifetime Income Disclosure Act S. 2832 Create Jobs and Save Benefits Act of 2010 S. 3157 Restoring American Financial Stability Act/Wall Street Transparency and Accountability Act S. 3217 Employee Misclassification Prevention Act (EMPA) S. 3254 Automatic IRA Act of 2010 S. 3760 Paycheck Fairness Act S. 3772 Fair Playing Field Act of 2010 S. 3786 (worker classification) Job Creation and Tax Cuts Act of 2010 S. 3793 Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act H.R. 3962, Public Law No: 111-192 American Workers, State, and Business Relief Act /American Jobs and Closing Tax Loopholes Act (tax extenders) H.R. 4213, & Substitute amendments Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Middle Class Tax Cut Act (Senate Amendment 4727) package of tax extensions and other provisions to the defined benefit pension funding relief provisions, and a provision extending parity for employee transit subsidies Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act H.R. 4853 Amendment to a Federal Aviation Administration funding extension bill H.R. 4915 Medicare and Medicaid Extenders Act H.R. 4994 Small Business Jobs and Credit Act of 2010 H.R. 5297 (revised substitute) Health Care Reform regulatory implementation and compliance issues from the Patient Protection and Affordable Care Act (PPACA) Public Law No: 111-148 & the Health Care and Education Reconciliation Act of 2010 (HCERA) Public Law 111-152 new compensation deduction limits on entities receiving health insurance premiums (162 (m)(6)) Financial Services Reform regulation of swaps transactions, major swap participants (MSPs), swaps, business conduct standards, fiduciary duty and liability issues; effects on pension, retirement, and health plans that use swaps; 401 (k) stable value funds and contracts, retirement plan administration, compensation disclosure issues Pension funding additional funding relief and technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, PBGC premium funding target methods and premium submission issues, plan termination and governance issues Retirement Security nonqualified deferred compensation, executive compensation, defined contribution plan issues, 401 (k) plans, automatic IRAs, conversions to Roth 401(k) plans, investment advice, investment selection (target date funds), the Savers Credit, lifetime income issues, nondiscrimination rules for retirement plans, plan loans, tax expenditures for retirement plans, long-term disability policies (LTDs) National Commission on Fiscal Responsibility and Reform implications for benefits Pension funding relief - adequacy of defined benefit vehicles, hybrids, proposed hybrid retirement plan regulations, retirement plan designs, and tax treatment of expatriates Investment advice - adequacy of defined contribution vehicles, investment selection (target date funds) and annuity issues, automatic/mandatory individual retirement accounts (IRAs), proposed regulations regarding target date funds (TDFs) and qualified default investment alternatives (QDIAs) Disclosure for defined contribution (DC) and defined benefit (DB) plans and service providers -ERISA Section 408 (b) (2), Fiduciary requirements 401 (k) participant fee disclosure regulations, proposed definition of fiduciary for investment advice arrangements, in-plan Roth conversions issues Defined Benefit (DB) plan year filing issues Form 5500 (EFAST) Cash balance and pension equity plans, market rate of return for hybrid plans Nonqualified deferred compensation (NQDC), new compensation deduction limits on entities receiving health insurance premiums 162 (m) (6) Pension Benefits Guaranty Corporation (PBGC) premium funding target methods (variable rate premiums), premium submission and plan termination issues, proposed regulations - (ERISA Section 4062(e)) Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) Financial services regulatory reform, executive compensation disclosure issues, involvement with employee benefit plans, Swaps, definition of major swap participant and major security-based swap participant, business conduct standards, family offices, Domestic plan asset investment issues Puerto Rican plan trust issues Multiemployer plan issues

Client expense: $272,633 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

HR 1988: Conflicted Investment Advice Prohibition Act of 2009 HR 3306: Social Security Number PRivacy and Identity Tehft Prevention Act of 2009 HR 3962: Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010; P.L. 111-192

Client expense: $460,000 · Firm income: Not reported

Government targets: Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Natl Guard, SENATE

Retirement security issues including 401k fee disclosure, coverage expansion, and annuity issues. S.401 - Defined Contribution Fee Disclosure Act of 2009 - all provisions H.R.2779 - the Defined Contribution Plan Fee Transparency Act of 2009 - all provisions H.R.1984 - 401K Fair Disclosure for Retirement Security Act of 2009 - all provisions H.R.1988 Conflicted Investment Advice Prohibition Act of 2009 all provisions H.R.2989 - 401(k) Fair Disclosure and Pension Security Act of 2009 all provisions H.R.1961 Savings for American Families' Future Act of 2009 savings incentives provisions H.R.2748 - Retirement Security Needs Lifetime Pay Act all provisions S.1297 - Retirement Security for Life Act all provisions H.R.4742 SAVE Act of 2009 all provisions H.R.2733 / S.1389 - the Fixed Indexed Annuities and Insurance Products Classification Act of 2009 all provisions S.906 Senior Investor Protection Act (Kohl) suitability and agent titles provisions S.2832 Lifetime Income Disclosure Act all provisions H.R.4126 Retirement Fairness Act of 2009 all provisions H.R.3326 The Department of Defense Appropriations Act 2010 provisions to extend COBRA benefits S. 3760 - Automatic IRA Act of 2010 all provisions H.R. 6099 - Automatic IRA Act of 2010 all provisions H.R. 5297 - Small Business Jobs and Credit Act of 2010 / Small Business Lending Fund Act of 2010 provisions regarding partial annuitization

Client expense: $710,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Proposals to reform the defined contribution plan system. Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, the Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan Fee Transparency Act, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Index fund mandate provisions of H.R. 2989. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Proposals related to defined benefit plan funding, including H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, H.R. 2021, The Savings Recovery Act, and H.R. 3936, Preserve Benefits and Jobs Act. H.R. 4126, Retirement Fairness Act. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act of 2010. Proposals to expand the Savers Credit, including H.R. 1961, Savings for American Families Future Act. 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. 4742, Small Businesses Add Value for Employees Act. Issues related to retirement target date funds. Proposals to allow Roth in-plan conversions and to create a Roth 457 feature, including those contained in H.R. 5297, the Small Business Jobs Act. Issues related to tax incentives for retirement savings.

Client expense: Not reported · Firm income: $20,000

Government targets: SENATE

Proposals to reform the defined contribution plan system, including proposals related to inclusion of income options in defined contribution plans. Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan Fee Transparency Act, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act of 2010. 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. 4742, Small Businesses Add Value for Employees Act. Proposals to expand the Savers Credit, including H.R. 1961, Savings for American Families Future Act. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. H.R. 4126, Retirement Fairness Act.

Client expense: Not reported · Firm income: $10,000

H.R. 1961, Savings for American Families' Futures Act of 2009, all provisions H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009, all provisions H.R. 2779, Defined Contribution Plan Fee Transparency Act of 2009, all provisions H.R. 2989, H.R. 1984 The 401(k) Fair Disclosure and Pension Security Act of 2009, all provisions H.R. 2748, The Retirement Security Needs Lifetime Pay Act, all provisions H.R. 4742, Small Businesses Add Values for Employees Act of 2009 (The SAVE Act ), all provisions H.R. 4193, Guaranteed 3% COLA for Seniors Act of 2009, all provisions S. 401, Defined Contribution Fee Disclosure Act of 2009, all provisions S. 2832, Lifetime Income Disclosure Act, all provisions H.R. 4213 American Workers, State and Business Relief Act, all provisions S. 3760 / H.R. 6099, Automatic IRA Act of 2010, all provisions [No Bill Number], Administration's Automatic IRA Proposal [No Bill Number], Incentives for Annuities and Guaranteed Lifetime Income [No Bill Number], QDIA Guidance and Clarifications [No Bill Number], Section 408(b)(2) Service Provider Fee Disclosure, Incentives for Annuities [No Bill Number], Request for Information on lifetime income options [No Bill Number], Investment Advice Regulations [No Bill Number], Auto Annuitization [No Bill Number], Multiple Small Employer Plan Proposal [No Bill Number], Pension Funding Relief [No Bill Number], Tax Extenders/UI-Cobra Funding [No Bill Number], Department of Labor and Department of Treasury Request for Information on Guaranteed Lifetime Income [No Bill Number], Incentives for Annuities and Guaranteed Lifetime Income in DC Plans [No Bill Number], Department of Labor Redefinition of Fiduciary Regulatory Project [No Bill Number], Regulation of Asset-Backed Securities [No Bill Number], SEC Target Date Fund Disclosure Regulation [No Bill Number], SEC 12b-2 Proposed Rules

Client expense: $2,180,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 1961, Savings for American Families' Futures Act of 2009, all provisions H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009, all provisions H.R. 2779, Defined Contribution Plan Fee Transparency Act of 2009, all provisions H.R. 2989, H.R. 1984 The 401(k) Fair Disclosure and Pension Security Act of 2009, all provisions H.R. 2748, The Retirement Security Needs Lifetime Pay Act, all provisions H.R. 4742, Small Businesses Add Values for Employees Act of 2009 (The SAVE Act ), all provisions H.R. 4193, Guaranteed 3% COLA for Seniors Act of 2009, all provisions S. 401, Defined Contribution Fee Disclosure Act of 2009, all provisions S. 2832, Lifetime Income Disclosure Act, all provisions S. 3760 / H.R. 6099, Automatic IRA Act of 2010, all provisions [No Bill Number], Administration's Automatic IRA Proposal [No Bill Number], Incentives for Annuities and Guaranteed Lifetime Income [No Bill Number], QDIA Guidance and Clarifications [No Bill Number], Section 408(b)(2) Service Provider Fee Disclosure, Incentives for Annuities [No Bill Number], Request for Information on lifetime income options [No Bill Number], Department of Labor Investment Advice Regulations [No Bill Number], Auto Annuitization [No Bill Number], Multiple Small Employer Plan Proposal [No Bill Number], Pension Funding Relief [No Bill Number], Tax Extenders/UI-Cobra Funding [No Bill Number], Department of Labor and Department of Treasury Request for Information on Guaranteed Lifetime Income [No Bill Number], Incentives for Annuities and Guaranteed Lifetime Income in DC Plans [No Bill Number], Department of Labor Redefinition of Fiduciary Regulatory Project [No Bill Number], Regulation of Asset-Backed Securities [No Bill Number], SEC Target Date Fund Disclosure Regulation [No Bill Number], SEC 12b-2 Proposed Rules on Mutual Fund Distribution Fees, Confirmations [No Bill Number], Housing Finance Reform Discussion

Client expense: $2,000,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 1961, Savings for American Families' Futures Act of 2009, all provisions H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009, all provisions H.R. 2779, Defined Contribution Plan Fee Transparency Act of 2009, all provisions H.R. 2989, H.R. 1984 The 401(k) Fair Disclosure and Pension Security Act of 2009, all provisions H.R. 2748, The Retirement Security Needs Lifetime Pay Act, all provisions H.R. 4742, Small Businesses Add Values for Employees Act of 2009 (The SAVE Act ), all provisions H.R. 4193, Guaranteed 3% COLA for Seniors Act of 2009, all provisions S. 401, Defined Contribution Fee Disclosure Act of 2009, all provisions S. 2832, Lifetime Income Disclosure Act, all provisions S. 3760 / H.R. 6099, Automatic IRA Act of 2010, all provisions [No Bill Number], Administration's Automatic IRA Proposal [No Bill Number], Incentives for Annuities and Guaranteed Lifetime Income [No Bill Number], QDIA Guidance and Clarifications [No Bill Number], Section 408(b)(2) Service Provider Fee Disclosure, Incentives for Annuities [No Bill Number], Request for Information on lifetime income options [No Bill Number], Department of Labor Investment Advice Regulations [No Bill Number], Auto Annuitization [No Bill Number], Multiple Small Employer Plan Proposal [No Bill Number], Pension Funding Relief [No Bill Number], Tax Extenders/UI-Cobra Funding [No Bill Number], Department of Labor and Department of Treasury Request for Information on Guaranteed Lifetime Income [No Bill Number], Incentives for Annuities and Guaranteed Lifetime Income in DC Plans [No Bill Number], Department of Labor Redefinition of Fiduciary Regulatory Project [No Bill Number], Regulation of Asset-Backed Securities [No Bill Number], SEC Target Date Fund Disclosure Regulation [No Bill Number], SEC 12b-2 Proposed Rules on Mutual Fund Distribution Fees, Confirmations [No Bill Number], Housing Finance Reform Discussion

Client expense: $2,000,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

Proposals to reform the defined contribution plan system. Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan Fee Transparency Act, H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, and H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010. Index fund mandate provisions of H.R. 2989. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Proposals to reform the defined contribution plan system. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act of 2010. 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. 4742, the Small Businesses Add Value for Employees Act. H.R. 4126, the Retirement Fairness Act. Issues related to retirement target date funds. Issues related to tax incentives for retirement savings. Proposals related to stemming leakage from retirement plans.

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

401 (k) fee disclosures, investment advice; H.R. 2989- 401(k) fee disclosure H.R. 1984, 401(k) fee disclosure; H.R. 1988, investment advice; and H.R. 2021, retirement savings.

Client expense: Not reported · Firm income: $80,000

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Proposals to reform the defined contribution plan system. Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, the Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan Fee Transparency Act, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Index fund mandate provision of H.R. 2989. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009 and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. 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. 4742, Small Businesses Add Value for Employees Act. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act. Proposals to expand the Savers Credit, including H.R. 1961, Savings for American Families Future Act. Proposals relating to defined benefit plan funding, including H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, H.R. 2021, The Savings Recovery Act, H.R. 3936, The Preserve Benefits and Jobs Act, and S. 3793, Job Creation and Tax Cuts Act. H.R. 4126, the Retirement Fairness Act. Issues related to variable premium filings with the Pension Benefit Guaranty Corporation. Proposals related to the use of annuities in defined contribution plans. Proposals to allow loans from IRAs. Proposals and regulations related to cash balance, pension equity, and other hybrid pension plans. Proposals related to partial annuitization out of defined benefit plans. Issues related to regulations addressing liability for partial termination of defined benefit plans. Issues related to tax incentives for retirement savings. Guidance related to the definition of fiduciary for investment advice purposes. Retirement recommendations contained in the final report of the National Commission on Fiscal Responsibility and Reform.

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Proposals to reform the defined contribution plan system. Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan Fee Transparency Act, H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, and H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act of 2010. 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. 4742, Small Businesses Add Value for Employees Act. Proposals related to defined benefit plan funding, including H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, and H.R. 3936, Preserve Benefits and Jobs Act. H.R. 4126, Retirement Fairness Act. Issues related to variable premium filings with the Pension Benefit Guaranty Corporation. Issues related to tax incentives for retirement savings.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 3760 / H.R. 6099, Automatic IRA Act of 2010 H.R. 2989, 401(k) Fair Disclosure and Pension Security Act of 2009, including provisions related to impacting plan fee disclosures, investment advice, and defined benefit plan funding H.R.1984, 401(k) Fair Disclosure for Retirement Security Act Of 2009 H.R.1988, Conflicted Investment Advice Prohibition Act of 2009 H.R. 2779, Defined Contribution Plan Fee Transparency Act of 2009 H.R. 2021, Savings Recovery Act of 2009 H.R. 3200, Americas Affordable Health Choices Act of 2009, including provisions related to health care reform and provisions that prohibit employers from making certain changes to retiree health benefits H.R. 4126, Retirement Fairness Act of 2009 H.R. 3126, Consumer Financial Protection Agency Act of 2009, including provisions related to establishing the Consumer Financial Protection Agency and to have pension plans excluded from the authority of the agency H.R. 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act, including provisions related to the exclusion of pension plans from the authority of the Consumer Financial Protection Agency and also from new rules pertaining to derivatives legislation H.R. 4191, Let Wall Street Pay for the Restoration of Main Street Act of 2009 H.R. 4213, Tax Extenders Act of 2010, including provisions related to pension funding relief and plan conversions into Roth accounts H.R. 3962, Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010, including provisions related to pension funding relief H.R. 5297, Small Business Jobs and Credit Act of 2010 H.R. 6484, Public Employee Pension Transparency Act - Requires uniform reporting and disclosure by State and local public employee retirement pension plans H.R. 3936, Preserve Benefits and Jobs Act of 2009, including provisions related to pension funding relief and funding reform for multiemployer plans S. 3793, Job Creation and Tax Cuts Act of 2010, including provisions related to defined benefit funding relief S. 3157, Create Jobs and Save Benefits Act of 2010, including provisions related to funding reform for multiemployer plans S. 2832, Lifetime Income Disclosure Act P.L. 109-280, Pension Protection Act of 2006- Reform of funding rules for employer-provided retirement plans and amendments to the Employee Retirement Income Security Act of 1974 ERISA preemption (protecting the preemption structure in the Employee Retirement Income Security Act of 1974) Various issues regarding relief for single-employer, multiemployer, and multiple-employer pension funds (specific legislation not yet introduced) General issues including: pension and retirement, healthcare, tax, and finacial services (specific legislation not yet introduced)

Client expense: $36,360,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Election Commission (FEC), Federal Reserve System, Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Maritime Administration (MARAD), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Labor Relations Board (NLRB), Natl Security Council (NSC), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), St. Lawrence Seaway Development Corporation, State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Trade Representative (USTR), White House Office

Proposals responding to the effect of the stock market decline on retirement savings accounts. Proposals to expand retirement coverage, including proposals to mandate payroll deduction IRAs (not yet in legislative form) Proposals regarding annuitization of assets from defined contribution plans (not yet in legislative form) HR 2989 - "401k Fair Disclosure and Pension Security Act of 2009" - To amend the Employee Retirement Income Security Act of 1974 to provide special reporting and disclosure rules for individual account plans and to provide a minimum investment option requirement for such plans, to amend such Act to provide for independent investment advice for participants and beneficiaries under individual account plans, and to amend such Act and the Internal Revenue Code of 1986 to provide transitional relief under certain pension funding rules added by the Pension Protection Act of 2006 - to increase 401(k) fee disclosure requirements and make changes to investment advice rules HR 1984 - "401(k) Fair Disclosure for Retirement Security Act" - To amend title 1 of the Employee Retirement Income Security Act of 1974 to provide special reporting and disclosure rules for individual account plans and to provide a minimum investment option requirement for such plans HR 2779 - "Defined contribution Plan Fee Transparency Act" - To amend the Internal Revenue Code of 1986 to provide transparency with respect to fees and expenses charged to participant-directed defined contribution plans, and to improve participant communication HR 1988 - "Conflicted Investment Advice Prohibition Act of 2009" - To amend title I of the Employee Retirement Income Security Act of 1974 to provide for independent investment advice for participants and beneficiaries under individual account plans S 2832 - "Lifetime Income Disclosure Act" - A lifetime income disclosure shall set forth the annuity equivalent of the total benefits accrued with respect to the participant or beneficiary S 401 - "Defined Contribution Fee Disclosure Act" - A bill to amend the Employee Retirement Income Security Act of 1974 to provide special reporting and disclosure rules for individual accounts plans and for other purposes HR 3550 - "Senior Investor Protections Enhancement Act" - To enhance penalties for violations of securities protections that involve targeting seniors S 1659 - "Senior Investor Protections Enhancement Act" - To enhance penalties for violations of securities protections that involve targeting seniors HR 3669 - "Employer-Owned Life Insurance Limitation Act" - To prohibit employers from carrying life insurance policies on their rank and file employees HR 4213 - "American Jobs and Closing Loopholes Act of 2010" - Provides low income housing credits HR 4742 - "Save Act of 2009" - Reforms Retirement Plan System HR 4173 - "Dodd Frank Wall Street Reform and Consumer Protection Act" - overhauls regulation of financial markets HR 5297 - "Small Business Jobs and Credit Act - partial annuitizations Roth provisions

Client expense: $860,000 · Firm income: Not reported

Government targets: Federal Emergency Management Agency (FEMA), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Labor, Dept of (DOL), SENATE, Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office

H.R. 2989 - 401(k) Fair Disclosure and Pension Security Act of 2009 H.R. 1984 - 401(k) Fair Disclosure for Retirement Security Act H.R. 1988 Conflicted Investment Advice Prohibition Act of 2009 (see attached addendum page) H.R. 2021 Savings Recovery Act of 2009 H.R. 2779 Defined Contribution Plan Fee Transparency Act H.R. 2989 401(k) Fair Disclosure and Pension Security Act H.R. 4213 American Jobs and Closing Tax Loopholes Act of 2010 S. 401 Defined contribution Fee Disclosure Act of 2009 S. 3760 Automatic IRA Act of 2010 S. 6099 Automatic IRA Act of 2010 H.R. 4742 Small Businesses Add Value for Employees Act H.R. 4126 Retirement Fairness Act Proposals to reform of the defined contribution plan system Proposals related to retirement savings Proposals related to defined contribution plan fees and fee disclosure practices Proposals related to the index fund mandate provision of H.R. 2989 Proposals related to the investment advice rules provision in H.R. 1988 Proposals related to mandated workplace savings arrangements for employees without access to employer retirement plans as included in S. 3760 and H.R. 6099 Proposals related to expansion of SIMPLE IRAs Proposals related to the establishment of discretionary payroll deduction IRAs Proposals related to the creation of new qualified retirement plans for small business (H.R. 4742 and H.R. 4126) Proposals related to 401(k) plan loans and rollover loans to IRAs Proposals related to expanding the definition of fiduciary under ERISA Issues related to stable value funds in retirement plans Issues related to securities lending in retirement funds Issues related to retirement target date funds Issues related to tax incentives for retirement savings Proposals related to stemming leakage from retirement plans

Client expense: $300,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office

Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, The Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan Fee Transparency Act, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Proposals to reform the defined contribution plan system. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act of 2010. 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. 4742, Small Businesses Add Value for Employees Act. Proposals to reform the multiple employer plan rules. Guidance related to nondiscrimination rules for defined contribution plan annuity investment products.

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

H.R. 1984: The 401(k) Fair Disclosure for Retirement Security Act of 2009 H.R. 1988: Conflicted Investment Advice Prohibition Act of 2009 H.R. 2779: Defined Contribution Plan Fee Transparency Act of 2009 H.R. 2989: 401(k) Fair Disclosure and Pension Security Act of 2009 H.R. 1961: Savings for American Families' Act of 2009 S. 401: Defined Contribution Fee Disclosure Act of 2009 H.R. 4173: The Wall Street Reform and Consumer Protection Act of 2009 H.R. 3936: The Preserve Benefits and Jobs Act of 2009 H.R. 4126: The Retirement Fairness Act of 2009 S. 3217: Restoring American Financial Stability of 2010 H.R. 4213: American Workers, State, and Business Relief Act of 2010 H.R. 5297: Small Business Jobs Act of 2010 H.R. 6099: Automatic IRA Act of 2010 S. 3760: Automatic IRA Act of 2010

Client expense: $161,242 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), Securities & Exchange Commission (SEC), Treasury, Dept of

Pension & retirement issues HR 1, S. 1, HR 436, HR 1961, S. 401. HR 2989, HR 3936, S. 1297, HR 2748 , HR 2637, HR 1984, HR 2021, HR 1988 , HR 3962, HR 4123

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1984 (401(k) Fair Disclosure Act); H.R. 1988 (Conflicted Investment Advice Prohibition Act of 2009); H.R. 2779 (Defined Contribution Plan Fee Transparency Act of 2009); H.R. 2989 (401(k) Fair Disclosure and Pension Security Act of 2009); H.R. 3308 (Secure America Through Verification and Enforcement Act of 2009) (SAVE Act of 2009); H.R. 4126 (Retirement Fairness Act of 2009); H.R. 4213 (American Jobs and Closing Tax Loopholes Act of 2010)(Fee Disclosure); H.R. 4742 (Small Business Add Value for Employees (SAVE) Act of 2009); S. 906 (Senior Investment Protection Act); DOL Fiduciary Regulation; Partial rollovers.

Client expense: $1,270,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act; H.R. 4173, Wall Street Reform and Consumer Protection Act; H.R.1880, National Insurance Consumer Protection Act; H.R.1988, Conflicted Investment Advice Prohibition Act; H.R.3669, Employer-Owned Life Insurance Limitation Act; H.R.2609, Insurance Information Act; S. 3217, "Restoring American Financial Stability Act of 2010"

Client expense: $576,337 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 519: ELDER CAREGIVER SUPPORT AND INFORMATION ENHANCEMENT ACT OF 2009; PROVISIONS RELATED TO LONG TERM CARE INFORMATION CLEARINGHOUSE H.R. 1961: SAVINGS FOR AMERICAN FAMILIES FUTURE ACT OF 2009; PROVISIONS RELATED TO SAVERS' CREDIT H.R.1984: 401(K) FAIR DISCLOSURE FOR RETIREMENT SECURITY ACT OF 2009; PROVISIONS RELATED TO RETIREMENT PLAN FEE DISCLOSURE H.R. 1988: CONFLICTED INVESTMENT ADVICE PROHIBITION ACT OF 2009; PROVISIONS RELATED TO INVESTMENT ADVICE H.R. 2021: SAVINGS RECOVERY ACT OF 2009; PROVISIONS RELATED TO SAVERS CREDIT H.R. 2733/S. 1389: FIXED INDEXED ANNUITIES AND INSURANCE PRODUCTS CLASSIFICATION ACT OF 2009; PROVISIONS RELATED TO CLARIFICATION FOR FIXED ANNUITIES REGULATION H.R. 2748: RETIREMENT SECURITY NEEDS LIFETIME PAY ACT OF 2009; PROVISIONS RELATED TO TAX INCENTIVES FOR ANNUITIES H.R. 2779: DEFINED CONTRIBUTION PLAN FEE TRANSPARENCY ACT OF 2009; PROVISIONS RELATED TO 401(K) PLAN FEE DISCLOSURE H.R. 2792: RETIREMENT SAVINGS TRANSPARENCY ACT OF 2009; PROVISIONS RELATED TO PLAN FEE DISCLOSURE H.R. 2989: 401 (K) FAIR DISCLOSURE AND PENSION SECURITY ACT OF 2009; PROVISIONS RELATED TO RETIREMENT PLAN FEE DISCLOSURE H.R. 3551 /S. 1661/S. 906: SENIOR INVESTMENT PROTECTION ACT OF 2009; PROVISIONS RELATED TO PRODUCT SALES TO SENIORS AND ANNUITIES SALES H.R. 3590: THE PATIENT PROTECTION AND AFFORDABLE CARE ACT; PROVISIONS RELATED TO LONG TERM CARE FINANCING WITHIN HEALTH REFORM, AND MEDICARE TAX ON NONQUALIFIED ANNUITY INCOME H.R. 4126: RETIREMENT FAIRNESS ACT OF 2009; PROVISIONS RELATED TO MODIFICATION OF 401(K) PLAN RULES H.R. 4173: DODD-FRANK WALL STREET REFORM AND CONSUMER PROTECTION ACT (FKA: RESTORING AMERICAN FINANCIAL STABILITY ACT OF 2010); ALL PROVISIONS OF THE BILL H.R. 4213: AMERICAN JOBS AND CLOSING TAX LOOPHOLES ACT OF 2010; PROVISIONS RELATED TO 401(K) PLAN FEE DISCLOSURE H.R. 4626: HEALTH INSURANCE INDUSTRY FAIR COMPETITION ACT; PROVISIONS RELATED TO INSURANCE ANTI-TRUST REGULATIONS (MCCARRON-FERGUSON) H.R. 4742: SMALL BUSINESSES ADD VALUE FOR EMPLOYEES (SAVE) ACT OF 2009; PROVISIONS RELATED TO SIMPLIFICATION OF SIMPLE IRAS, AND VOLUNTARY AUTO IRAS H.R. 4872: HEALTH CARE AND EDUCATION RECONCILIATION ACT OF 2010; PROVISIONS RELATED TO LONG TERM CARE FINANCING WITHIN HEALTH CARE REFORM, AND UNEARNED INCOME TAXATION H.R. 5297: SMALL BUSINESS JOBS AND CREDIT ACT OF 2010; PROVISIONS RELATED TO PARTIAL ANNUITIZATION AND ROTH CONVERSIONS OF 401(K) SAVINGS S. 401: DEFINED CONTRIBUTION FEE DISCLOSURE ACT OF 2009; PROVISIONS RELATED TO 401(K) PLAN FEE DISCLOSURE S. 1177: CONFIDENCE IN LONG-TERM CARE INSURANCE ACT OF 2009; PROVISIONS RELATED TO CONSUMER PROTECTION IN LONG TERM CARE S. 1297: RETIREMENT SECURITY FOR LIFE ACT OF 2009; PROVISIONS RELATED TO NON-QUALIFIED ANNUITIES TAX INCENTIVES S. 1626: LONG TERM CARE INSURANCE INTEGRITY ACT OF 2009; PROVISIONS RELATED TO LONG TERM CARE S.1636: LONG TERM CARE INSURANCE CONSUMER RIGHT-TO-KNOW ACT OF 2009; PROVISIONS RELATED TO LONG TERM CARE CONSUMER PROTECTIONS S. 2832: LIFETIME INCOME DISCLOSURE ACT; PROVISIONS RELATED TO ANNUITY ILLUSTRATION ON BENEFIT STATEMENTS S. 3217: RESTORING AMERICAN FINANCIAL STABILITY ACT OF 2010; PROVISIONS RELATED TO REGULATORY REFORM

Client expense: $590,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Retirement security issues including 401k fee disclosure, coverage expansion, and annuity issues. S.401 Defined Contribution Fee Disclosure Act of 2009 all provisions H.R.2779 - the Defined Contribution Plan Fee Transparency Act of 2009 all provisions H.R.1984 - 401K Fair Disclosure for Retirement Security Act of 2009 all provisions H.R.1988 Conflicted Investment Advice Prohibition Act of 2009 all provisions H.R.2989 - 401(k) Fair Disclosure and Pension Security Act of 2009 all provisions H.R.1961 Savings for American Families' Future Act of 2009 savings incentives provisions H.R.2748 - Retirement Security Needs Lifetime Pay Act all provisions S.1297 - Retirement Security for Life Act all provisions H.R.2733 / S.1389 - the Fixed Indexed Annuities and Insurance Products Classification Act of 2009 all provisions S.906 Senior Investor Protection Act (Kohl) suitability and agent titles provisions S.2832 Lifetime Income Disclosure Act all provisions H.R.4126 Retirement Fairness Act of 2009 all provisions H.R.3326 The Department of Defense Appropriations Act 2010 provisions to extend COBRA benefits S. 3760 - Automatic IRA Act of 2010 all provisions H.R. 6099 - Automatic IRA Act of 2010 all provisions H.R. 5297 - Small Business Jobs and Credit Act of 2010 / Small Business Lending Fund Act of 2010 provisions regarding partial annuitization

Client expense: $440,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Proposals to reform the defined contribution plan system. Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, the Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan Fee Transparency Act, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, and H.R. 4213, The American Jobs and Closing Tax Loopholes Act of 2010. Index fund mandate provision of H.R. 2989. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009 and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. 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. 4742, Small Businesses Add Value for Employees Act. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act. Proposals to expand the Savers Credit, including H.R. 1961, Savings for American Families Future Act. Proposals relating to defined benefit plan funding, including H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, H.R. 2021, The Savings Recovery Act, H.R. 3936, The Preserve Benefits and Jobs Act, H.R. 3962, Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act, and S. 3793, Job Creation and Tax Cuts Act. H.R. 4126, the Retirement Fairness Act. Issues related to variable premium filings with the Pension Benefit Guaranty Corporation. Proposals related to the use of annuities in defined contribution plans. Proposals to allow loans from IRAs. Proposals and regulations related to cash balance, pension equity, and other hybrid pension plans. Proposals related to partial annuitization out of defined benefit plans. Issues related to regulations addressing liability for partial termination of defined benefit plans. Issues related to tax incentives for retirement savings.

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Treasury, Dept of

HR 1988: Conflicted Investment Advice Prohibition Act of 2009 HR 3306: Social Security Number PRivacy and Identity Tehft Prevention Act of 2009 HR 3962: Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010; P.L. 111-192

Client expense: $350,000 · Firm income: Not reported

Government targets: Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Natl Guard, SENATE

H.R. 1961, Savings for American Families' Futures Act of 2009, all provisions H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009, all provisions H.R. 2779, Defined Contribution Plan Fee Transparency Act of 2009, all provisions H.R. 2989, H.R. 1984 The 401(k) Fair Disclosure and Pension Security Act of 2009, all provisions H.R. 2748, The Retirement Security Needs Lifetime Pay Act, all provisions H.R. 4742, Small Businesses Add Values for Employees Act of 2009 (The SAVE Act ), all provisions H.R. 4193, Guaranteed 3% COLA for Seniors Act of 2009, all provisions S. 401, Defined Contribution Fee Disclosure Act of 2009, all provisions S. 2832, Lifetime Income Disclosure Act, all provisions H.R. 4213 American Workers, State and Business Relief Act, all provisions S. 3760 / H.R. 6099, Automatic IRA Act of 2010, all provisions [No Bill Number], Administration's Automatic IRA Proposal [No Bill Number], Incentives for Annuities and Guaranteed Lifetime Income [No Bill Number], QDIA Guidance and Clarifications [No Bill Number], Section 408(b)(2) Service Provider Fee Disclosure, Incentives for Annuities [No Bill Number], Request for Information on lifetime income options [No Bill Number], Investment Advice Regulations [No Bill Number], Auto Annuitization [No Bill Number], Multiple Small Employer Plan Proposal [No Bill Number], Pension Funding Relief [No Bill Number], Tax Extenders/UI-Cobra Funding [No Bill Number], Department of Labor and Department of Treasury Request for Information on Guaranteed Lifetime Income [No Bill Number], Incentives for Annuities and Guaranteed Lifetime Income in DC Plans [No Bill Number], Department of Labor Redefinition of Fiduciary Regulatory Project [No Bill Number], Regulation of Asset-Backed Securities [No Bill Number], SEC Target Date Fund Disclosure Regulation [No Bill Number], SEC 12b-2 Proposed Rules

Client expense: $2,460,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

401 (k) fee disclosures, investment advice; H.R. 2989- 401(k) fee disclosure H.R. 1984, 401(k) fee disclosure; H.R. 1988, investment advice; and H.R. 2021, retirement savings.

Client expense: Not reported · Firm income: $80,000

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Proposals to reform the defined contribution plan system. Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan fee Transparency Act, H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, and H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010. Index fund mandate provisions of H.R. 2989. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act of 2010. 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. 4742, the Small Businesses Add Value for Employees Act. Issues related to retirement target date funds. H.R. 4126, the Retirement Fairness Act.

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Discussed financial regulatory reforms, including consumer and investor protections, a potential systemic risk regulator, and consolidation of agencies (no bill). H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act of 2009 - Lobbied for increased transparency of 401(k) fees paid for by plan participants. H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009 - Lobbied to ensure that individually directed account plan participants received investment advice from qualified advisors who are free from financial conflicts of interests. H.R. 2779, Defined Contribution Plan Fee Transparency Act of 2009 - Lobbied for increased transparency of 401(k) fees paid for by plan participants. H.R. 2989, 401(k) Fair Disclosure and Pension Security Act of 2009 - Lobbied for increased transparency of 401(k) fees paid for by plan participants and to ensure that individually directed account plan participants received investment advice from qualified advisors who are free from financial conflicts of interests. H.R. 3936 - Preserve Benefits and Jobs Acts of 2009 - Discussed need for pension funding relief in light of the combined impact of the U.S. recession and the funding requirements of the 2006 Pension Protection Act. S. 2832, Lifetime Income Disclosure Act - Lobbied in support of this legislation, which would provide individuals a better understanding of the lifetime value of their 401(k) plan assets by including in a yearly benefit statement a conversion of their total accrued benefits into a monthly dollar amount as if they had opted to receive a lifetime annuity. H.R. 4173, the Wall Street Reform and Consumer Protection Act of 2009 - Discussed implementation of legislation. H.R. 4849, the Small Business and Infrastructure Jobs Tax Act of 2010 - Discussed the potential inclusion of 401(k) fee disclosure and pension funding relief provisions within the bill. Ultimately, these provisions were not included in the legislation. H.R. 4213, the American Jobs and Closing Tax Loopholes Act - Lobbied for the inclusion of 401(k) fee disclosure provisions within the House version of the legislation. Senate Substitute Amendment to H.R. 4213, the American Jobs and Closing Tax Loopholes Act - Lobbied for the inclusion of 401(k) fee disclosure provisions within the Senate version of the legislation. Discussed issues surrounding lifetime income products, such as annuities, and provided written testimony for the Senate Special Committee on Aging hearing entitled "The Retirement Challenge-Making Savings Last a Lifetime." (no bill)

Client expense: $4,710,000 · Firm income: Not reported

Government targets: Administration on Aging, Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Energy, Dept of, Federal Communications Commission (FCC), Food & Drug Administration (FDA), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of Personnel Management (OPM), Office of the Vice President of the United States, SENATE, Securities & Exchange Commission (SEC), Social Security Administration (SSA), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

Proposals to reform the defined contribution plan system, including proposals related to inclusion of income options in defined contribution plans. Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan Fee Transparency Act, H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, and H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act of 2010. 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. 4742, Small Businesses Add Value for Employees Act. Proposals to expand the Savers Credit, including H.R. 1961, Savings for American Families Future Act. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. H.R. 4126, Retirement Fairness Act.

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals to reform the defined contribution plan system. Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan Fee Transparency Act, H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, and H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act of 2010. 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. 4742, Small Businesses Add Value for Employees Act. Proposals related to defined benefit plan funding, including H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, H.R. 3936, Preserve Benefits and Jobs Act, H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010, and H.R. 3962, Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act. H.R. 4126, Retirement Fairness Act. Issues related to variable premium filings with the Pension Benefit Guaranty Corporation.

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals to reform the defined contribution plan system. Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, the Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan Fee Transparency Act, H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, and H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010. Index fund mandate provisions of H.R. 2989. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act of 2009, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Proposals related to defined benefit plan funding, including H.R. 2989, 401(k) Fair Disclosure and Pension Security Act, H.R. 2021, The Savings Recovery Act, H.R. 3936, Preserve Benefits and Jobs Act, H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010, and H.R. 3962, Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act. H.R. 4126, Retirement Fairness Act. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act of 2010. Proposals to expand the Savers Credit, including H.R. 1961, Savings for American Families Future Act. 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. 4742, Small Businesses Add Value for Employees Act. Issues related to retirement target date funds. Proposals to allow Roth in-plan conversions and to create a Roth 457 feature, including those contained in H.R. 5297, the Small Business Jobs Act.

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 6099 and S. 3760 Automatic IRA Act of 2010 H.R. 712 Pension Security Act of 2009 H.R. 1984 401(k) Fair Disclosure for Retirement Security Act of 2009 H.R. 1988 Conflicted Advice Prohibition Act H.R. 2779 Defined Contribution Plan Fee Transparency Act S.401 Defined Contribution Fee Disclosure Act Other - Early Retiree Reinsurance Program (ERRP) Other Employer Sponsored Retirement Plans (Issues specific to Defined Benefit pension plans; Issues specific to Defined Contribution pension plans)

Client expense: $18,595 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Personnel Management (OPM), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office

H.R. 3936, Preserve Benefits and Jobs Act of 2009 S. 3157, Create Jobs and Save Benefits Act of 2010 H.R. 2989, 401(k) Fair Disclosure and Pension Security Act of 2009, including provisions related to impacting plan fee disclosures, investment advice, and defined benefit plan funding H.R.1984, 401(k) Fair Disclosure for Retirement Security Act Of 2009 H.R.1988, Conflicted Investment Advice Prohibition Act of 2009 H.R. 2779, Defined Contribution Plan Fee Transparency Act of 2009 H.R. 2021, Savings Recovery Act of 2009 H.R. 3200, Americas Affordable Health Choices Act of 2009, including provisions related to health care reform and provisions that prohibit employers from making certain changes to retiree health benefits S. 2832, Lifetime Income Disclosure Act H.R. 4126, Retirement Fairness Act of 2009 H.R. 3126, Consumer Financial Protection Agency Act of 2009, including provisions related to establishing the Consumer Financial Protection Agency and to have pension plans excluded from the authority of the agency H.R. 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act, including provisions related to the exclusion of pension plans from the authority of the Consumer Financial Protection Agency and also from new rules pertaining to derivatives legislation H.R. 4191, Let Wall Street Pay for the Restoration of Main Street Act of 2009 H.R. 4213, Tax Extenders Act of 2010, including provisions related to pension funding relief and plan conversions into Roth accounts S. 3760/ H.R. 6099, Automatic IRA Act of 2010 S. 3793, American Jobs and Closing Tax Loopholes Act of 2010, including provisions related to defined benefit funding relief H.R. 3962, Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010, including provisions related to pension funding relief H.R. 3936, Preserve Benefits and Jobs Act of 2009, including provisions related to pension funding relief and funding reform for multiemployer plans S. 3157, Create Jobs and Save Benefits Act of 2010, including provisions related to funding reform for multiemployer plans H.R. 5297, Small Business Jobs and Credit Act of 2010 P.L. 109-280, Pension Protection Act of 2006- Reform of funding rules for employer-provided retirement plans and amendments to the Employee Retirement Income Security Act of 1974 ERISA Preemption - Protecting the preemption structure in the Employee Retirement Income Security Act of 1974 Issues relating to legislation to provide relief for single-employer, multiemployer, and multiple-employer pension funds (specific legislation not yet introduced) General issues including: pension and retirement, healthcare, tax, and finacial services (specific legislation not yet introduced)

Client expense: $29,250,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), Export-Import Bank of the United States (EXIM Bank), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Maritime Administration (MARAD), Natl Aeronautics & Space Administration (NASA), Natl Economic Council (NEC), Natl Highway Traffic Safety Administration (NHTSA), Natl Institute of Standards & Technology (NIST), Natl Labor Relations Board (NLRB), Natl Security Council (NSC), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), St. Lawrence Seaway Development Corporation, State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Proposals responding to the effect of the stock market decline on retirement savings accounts. Proposals to expand retirement coverage, including proposals to mandate payroll deduction IRAs (not yet in legislative form) Proposals regarding annuitization of assets from defined contribution plans (not yet in legislative form) HR 2989 - "401k Fair Disclosure and Pension Security Act of 2009" - To amend the Employee Retirement Income Security Act of 1974 to provide special reporting and disclosure rules for individual account plans and to provide a minimum investment option requirement for such plans, to amend such Act to provide for independent investment advice for participants and beneficiaries under individual account plans, and to amend such Act and the Internal Revenue Code of 1986 to provide transitional relief under certain pension funding rules added by the Pension Protection Act of 2006 - to increase 401(k) fee disclosure requirements and make changes to investment advice rules HR 1984 - "401(k) Fair Disclosure for Retirement Security Act" - To amend title 1 of the Employee Retirement Income Security Act of 1974 to provide special reporting and disclosure rules for individual account plans and to provide a minimum investment option requirement for such plans HR 2779 - "Defined contribution Plan Fee Transparency Act" - To amend the Internal Revenue Code of 1986 to provide transparency with respect to fees and expenses charged to participant-directed defined contribution plans, and to improve participant communication HR 1988 - "Conflicted Investment Advice Prohibition Act of 2009" - To amend title I of the Employee Retirement Income Security Act of 1974 to provide for independent investment advice for participants and beneficiaries under individual account plans S 2832 - "Lifetime Income Disclosure Act" - A lifetime income disclosure shall set forth the annuity equivalent of the total benefits accrued with respect to the participant or beneficiary S 401 - "Defined Contribution Fee Disclosure Act" - A bill to amend the Employee Retirement Income Security Act of 1974 to provide special reporting and disclosure rules for individual accounts plans and for other purposes HR 3550 - "Senior Investor Protections Enhancement Act" - To enhance penalties for violations of securities protections that involve targeting seniors S 1659 - "Senior Investor Protections Enhancement Act" - To enhance penalties for violations of securities protections that involve targeting seniors HR 3669 - "Employer-Owned Life Insurance Limitation Act" - To prohibit employers from carrying life insurance policies on their rank and file employees HR 4213 - "American Jobs and Closing Loopholes Act of 2010" - Provides low income housing credits HR 4742 - "Save Act of 2009" - Reforms Retirement Plan System HR 4173 - "Dodd Frank Wall Street Reform and Consumer Protection Act" - overhauls regulation of financial markets HR 5297 - "Small Business Jobs and Credit Act - partial annuitizations Roth provisions

Client expense: $760,000 · Firm income: Not reported

Government targets: Federal Emergency Management Agency (FEMA), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Labor, Dept of (DOL), SENATE, Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office

Legislation and regulatory proposals related to target-date funds, retirement savings (including the retirement savings provisions in HR 5297), HR 6099 and S 3760 (the Automatic IRA Act), fee disclosure in 401(k) plans (including HR 2989 and HR 2779, as well as the fee disclosure provisions included in HR 4213), investment advice for 401(k) plans (including HR 1988), lifetime income options for retirees (including S 2832 and Labor Department RIN 1210-AB33).

Client expense: $840,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Retirement Security in the following bills: S 2832 - Lifetime Income Disclosure Act Federal required reporting for pension plan sponsors Auto-Enroll Auto-Escalate Fee Transparency in the following bills: S 401 - Defined Contribution Fee Disclosure Act of 2009 HR 2779 - Defined Contribution Plan Fee Transparency Act of 2009 HR 2989 - 401(k) Fair Disclosure and Pension Security Act of 2009 Retiree Healthcare Investment Advice in the following bill: HR 1988 - Conflicted Investment Advice Prohibition Act of 2009 Pension Funding Relief in the following bill: HR 3962 - Affordable Health Care Improvement Act

Client expense: $400,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, White House Office

Proposals related to defined contribution plan fees and fee disclosure practices, including S. 401, The Defined Contribution Fee Disclosure Act, H.R. 1984, 401(k) Fair Disclosure for Retirement Security Act, H.R. 2779, Defined Contribution Plan Fee Transparency Act, and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Proposals related to investment advice rules, including H.R. 1988, Conflicted Investment Advice Prohibition Act and H.R. 2989, 401(k) Fair Disclosure and Pension Security Act. Proposals to reform the defined contribution plan system. Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including S. 3760 and H.R. 6099, Automatic IRA Act of 2010. 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. 4742, Small Businesses Add Value for Employees Act. Proposals to reform the multiple employer plan rules.

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

H.R. 2989 - 401(k) Fair Disclosure and Pension Security Act of 2009 H.R. 1984 - 401(k) Fair Disclosure and Pension Security Act of 2009 H.R. 2021 - Savings Recovery Act of 2009 (Please see addendum page) H.R. 2779 - Defined Contribution Plan Fee Transparency Act of 2009 H.R. 1988 - Conflicted Investment Advice Prohibition Act of 2009 H.R. 4213 - Unemployment Compensation Extension Act of 2010 H.R. 3760 - Home Buyer Tax Credit Act of 2009 H.R. 6099 - Automatic IRA Act of 2010 H.R. 4742 - SAVE Act of 2009 H.R. 4126 - Retirement Fairness Act of 2009 S. 401 - Defined Contribution Fee Disclosure Act of 2009 Proposals to reform the defined contribution plan system Proposals to mandate workplace savings arrangements for employees without access to employer retirement plans, including automatic IRAs Proposals related to expansion of SIMPLE IRAs, establishment of discretionary payroll deduction IRAs, and creation of new qualified retirement plans for small business Issues related to retirement target date funds Issues related to retirement income Issues related to delivery of advice to participants in qualified retirement plans Issues related to investment choices in qualified retirement plans

Client expense: $310,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC)

Limit Executive Compensation Abuse Act - H.R. 857 The Savings for American Families Future Act of 2009 H.R. 1961 The 401 (k) Fair Disclosure for Retirement Security Act 0f 2009 H.R. 1984 Conflicted Investment Advice Prohibition Act of 2009 H.R. 1988 Savings Recovery Act H.R. 2021 Retirement Security Needs Lifetime Pay Act H.R. 2748 Retirement Savings Transparency Act of 2009 - H.R. 2792 The Defined Contribution Plan Fee Transparency Act H.R. 2779 401 (k) Fair Disclosure and Pension Security Act of 2009 H.R. 2989 Consumer Financial Protection Agency Act of 2009 H.R. 3126 Foreign Account Tax Compliance Act of 2009 H.R. 3933 Preserve Benefits and Jobs Act of 2009 H.R. 3936 Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act H.R. 3962/Public Law No: 111-192 Retirement Fairness Act H.R. 4126 Sensible Transparency for Retirement Plans Act H.R. 4146 Tax Technical Corrections Act of 2009 H.R. 4169 Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 American Workers, State, and Business Relief Act H.R. 4213/Unemployment Compensation Extension Act of 2010 (tax extenders) Public Law No: 111-205 Small Businesses Add Value for Employees Act of 2009 (SAVE Act) H.R. 4742 Employee Misclassification Prevention Act (EMPA) H.R. 5107 Small Business Jobs and Credit Act of 2010 H.R. 5297 tax extenders, defined benefit pension plan funding relief - technical corrections from H.R. 3962 Automatic IRA Act of 2010 H.R. 6099 Fair Playing Field Act of 2010 H.R. 6128 (worker classification) Health Care Reform regulatory implementation and compliance issues from the Patient Protection and Affordable Care Act (PPACA) Public Law No: 111-148 & the Health Care and Education Reconciliation Act of 2010 (HCERA) Public Law 111-152 new compensation deduction limits on entities receiving health insurance premiums (162 (m)(6)) Financial Services Reform regulation of swaps transactions, major swap participants (MSPs), swaps, business conduct standards, fiduciary duty and liability issues; effects on pension, retirement, and health plans that use swaps; 401 (k) stable value funds and contracts, retirement plan administration, compensation disclosure issues Pension Funding - additional funding relief for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, PBGC premium funding target methods and premium submission issues, PBGC plan termination issues Retirement Security nonqualified deferred compensation, executive compensation, defined contribution plan issues, 401 (k) plans, conversions to Roth 401 (k) plans, automatic IRAs, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures for retirement plans Cap Executive Officer Pay Act of 2009 - S. 360 The Defined Contribution Fee Disclosure Act of 2009 - S. 401 Shareholder Bill of Rights Act S. 1074 Retirement Security for Life Act of 2009 S. 1297 Pension Benefit Guaranty Corporation (PBGC) Governance Improvement Act of 2009 S. 1544 Foreign Account Tax Compliance Act of 2009 S. 1934 Lifetime Income Disclosure Act S. 2832 Create Jobs and Save Benefits Act of 2010 S. 3157 Restoring American Financial Stability Act/Wall Street Transparency and Accountability Act S. 3217 Employee Misclassification Prevention Act (EMPA) S. 3254 Automatic IRA Act of 2010 S. 3760 Fair Playing Field Act of 2010 S. 3786 Job Creation and Tax Cuts Act of 2010 S. 3793 Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act H.R. 3962, Public Law No: 111-192 American Workers, State, and Business Relief Act /American Jobs and Closing Tax Loopholes Act (tax extenders) H.R. 4213, & Substitute amendments Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Small Business Jobs and Credit Act of 2010 H.R. 5297 (revised substitute) Health Care Reform regulatory implementation and compliance issues from the Patient Protection and Affordable Care Act (PPACA) Public Law No: 111-148 & the Health Care and Education Reconciliation Act of 2010 (HCERA) Public Law 111-152 new compensation deduction limits on entities receiving health insurance premiums (162 (m)(6)) Financial Services Reform regulation of swaps transactions, major swap participants (MSPs), swaps, business conduct standards, fiduciary duty and liability issues; effects on pension, retirement, and health plans that use swaps; 401 (k) stable value funds and contracts, retirement plan administration, compensation disclosure issues Pension funding additional funding relief for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, PBGC premium funding target methods and premium submission issues, PBGC plan termination issues Retirement Security nonqualified deferred compensation, executive compensation, defined contribution plan issues, 401 (k) plans, automatic IRAs, conversions to Roth 401(k) plans, investment advice, investment selection (target date funds), the Savers Credit, lifetime income issues, nondiscrimination rules for retirement plans, plan loans, tax expenditures for retirement plans Regulatory communication with covered federal officials on legislative issues Pension funding relief, adequacy of defined benefit vehicles, hybrids, retirement plan designs, tax treatment of expatriates Investment advice, adequacy of defined contribution vehicles, investment selection (target date funds) and annuity issues, automatic/mandatory individual retirement accounts (IRAs) Disclosure for defined contribution (DC) and defined benefit (DB) plans and service providers ERISA Section 408 (b) (2) Defined Benefit (DB) plan year filing issues Form 5500 (EFAST) Cash balance and pension equity plans, market rate of return for hybrid plans Nonqualified deferred compensation (NQDC), new compensation deduction limits on entities receiving health insurance premiums 162 (m) (6) PBGC premium funding target methods (variable rate premiums), premium submission and plan termination issues Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) Financial services regulatory reform, compensation disclosure issues Domestic plan asset investment issues Proposed rule on application of ERISA to state/local health reform efforts, ERISA preemption

Client expense: $199,380 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 1984: The 401(k) Fair Disclosure for Retirement Security Act of 2009 H.R. 1988: Conflicted Investment Advice Prohibition Act of 2009 H.R. 2779: Defined Contribution Plan Fee Transparency Act of 2009 H.R. 2989: 401(k) Fair Disclosure and Pension Security Act of 2009 H.R. 1961: Savings for American Families' Act of 2009 S. 401: Defined Contribution Fee Disclosure Act of 2009 H.R. 4173: The Wall Street Reform and Consumer Protection Act of 2009 H.R. 3936: The Preserve Benefits and Jobs Act of 2009 H.R. 4126: The Retirement Fairness Act of 2009 S. 3217: Restoring American Financial Stability of 2010 H.R. 4213: American Workers, State, and Business Relief Act of 2010 H.R. 5297: Small Business Jobs Act of 2010

Client expense: $185,067 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), Securities & Exchange Commission (SEC), Treasury, Dept of

Pension & retirement issues HR 1, S. 1, HR 436, HR 1961, S. 401. HR 2989, HR 3936, S. 1297, HR 2748 , HR 2637, HR 1984, HR 2021, HR 1988 , HR 3962, HR 4123

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE