SEAL 401(k) Savings Act

Proposals related to expansion of SIMPLE IRAs, establishment of discretionary payroll deduction IRAs and creation of new qualified retirement plans for small business. Proposals relating to defined benefit plan funding. Issues related to regulations addressing liability for partial termination of defined benefit plans. Issues related to tax incentives for retirement savings and DOL fee disclosure proposals. Retirement recommendations contained in the final report of the National Commission on Fiscal Responsibility and Reform. Proposals 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. Proposals related to stable value investment offerings in defined contribution plans. Proposals related to phased retirement. Proposals to increase PBGC premiums, including those contained in the FY 2013 Obama Administration Budget proposal. Proposals related to retirement target date funds. Issues related to the Department of Labor's proposed regulation defining fiduciary for investment advice purposes. Proposals and regulations related to cash balance, pension equity, and other hybrid pension plans. Issues related to PBGC collections and PBGC disclosure issues. Proposals related to electronic disclosure of information under ERISA. Proposals regarding compliance of retirement plans. H.R. 3561, Small Business Pension Promotion Act. S. 1813/H.R. 4348, Moving Ahead for progress in the 21st Century, H.R. 4050, Retirement Plan Simplification and Enhancement Act. FASB pension accounting. USA Retirement proposal. Issues related to use of brokerage windows in defined contribution plans.

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

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

H.4348, HR 4050, S 1557, S 1020, HR 3287, H Con Res 101, S Con Res 62 S.1813 HR. 3656 HR. 4049

Client expense: $305,850 · Firm income: Not reported

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

S. 267 - Lifetime Income Disclosure Act S. 1121 - Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 S. 1557 - Automatic IRA Act of 2011 S. Con. Res. 62 - Sense of the Congress on Retirement Savings Incentives H.R. 677 - Lifetime Income Disclosure Act H.R. 3287 - Savings Enhancement by Alleviating Leaking in 401(k) Savngs Act of 2011 H.R. 4049 - Automatic IRA Act of 2012 H.R. 4050 - Retirement Plan Simplification and Enhancement Act of 2012 H. Con. Res. 101 - Sense of the Congress on Retirement Savings Incentives E-Delivery DOL Fiduciary Definition Target Date Funds 401(k) Disclosure

Client expense: $1,001,729 · Firm income: Not reported

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

American Taxpayer Relief Act of 2012 H.R. 8 fiscal cliff, employee benefits provisions Lifetime Income Disclosure Act H.R. 677/S. 267 Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection (Dodd-Frank) Act Burdensome Data Collection Relief Act - H.R. 1062 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption - H.R. 1573 Swaps Bailout Prevention Act - H.R. 1838 To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders - H.R. 1840 SEC Regulatory Accountability Act - H.R. 2308 Swap Execution Facility Clarification Act - H.R. 2586 Business Risk Mitigation and Price Stabilization Act of 2011 - H.R. 2682 To exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform and Consumer Protection Act - H.R. 2779 Pension Funding/Stabilization - defined benefit pension funding stabilization and related plan issues Pension Technical Modifications Act - H.R. 2656 Retirement Income Protection Act of 2011 - H.R. 3045 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act (SEAL 401 (k)) Act- H.R. 3287/S. 1020, S. 1121 Moving Ahead for Progress in the 21st Century (MAP-21) Act - S. 1813, S. 2343 - House/Senate passed version - H.R. 4348 (funding stabilization/Stop the Student Loan Interest Rate Hike Act of 2012) Retirement Savings Plan Issues Small Businesses Add Value for Employees Act of 2011 (SAVE Act) - H.R. 1534 Small Business Pension Protection Act of 2011 - H.R. 3561 Retirement Savings Security Act of 2011 - H.R. 3656 Automatic IRA Act of 2011 - S. 1557 Automatic IRA Act of 2012 - H.R. 4049 Retirement Plan Simplification and Enhancement Act - H.R. 4050 Bipartisan Concurrent Resolution (H.CON. RES. 101/S.CON.RES. 62) - tax incentives for retirement savings Worker Classification Issues Employee Misclassification Prevention Act - H.R. 3178/ Payroll Fraud Prevention Act - S. 770 Fair Playing Field Act of 2012 - H.R. 4123/S. 2145 (worker classification) Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act - S. 1289 Rebuild America Act - S. 2252 Pension modernization - The Retirement Crisis and a Plan to Solve It - USA Retirement Funds - Senate Health, Education, Labor & Pensions Committee Pension Benefit Guaranty Corporation (PBGC) - premiums, calculation of deficit and related governance issues Investment Advice - defined contribution plans, plan fees, definition of a fiduciary, electronic communication and related issues Distribution of retirement plan assets Nondiscrimination rules applicable to defined benefit (DB) plans Financial Accounting Standards Board (FASB) - retirement plans De-risking - defined benefit (DB) plans Other Issues Tax reform employee benefits issues ERISA Advisory Council 2012 Discussion Topics disability insurance & retirement stability, plan beneficiary designations Hybrid retirement plan designs implementation of the Pension Protection Act (PPA), finalization of proposed regulations Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans International benefits issues/Puerto Rican plan trust issues Domestic plan asset investment issues Regulation of money market funds Multiemployer plan issues Definition of governmental plans Distribution of retirement plan assets Nondiscrimination rules applicable to defined benefit (DB) plans Financial Accounting Standards Board (FASB) retirement plans De-risking defined benefit (DB) plans

Client expense: $328,952 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Commodity Futures Trading Commission (CFTC), Equal Employment Opportunity Commission (EEOC), Federal Accounting Standards Advisory Board (FASAB), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office

Tax Reform as it relates to preserving retirement benefits S.2145 & H.R. 4123 - Fair Playing field Act of 2012 H.R. 4049 - Automatic IRA Act of 2012 S. 1557 - Automatic IRA Act of 2011 H.R. 3178 - Employee Misclassification Prevention Act S. 770 - Payroll Fraud Prevention Act H.R. 3287 - Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 H.R. 4050 - Retirement Plan Simplification and Enhancement Act of 2012 H.Con.Res.101 - Expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement. S.Con.Res.62 - A concurrent resolution expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement.

Client expense: $150,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC)

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) Proposals related to stemming leakage from retirement plans through reform of plan loan rules, including, S. 1121 and 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 delivery of investment advice Issues related to potential Treasury guidance on 401(k) plan design features

Client expense: $500,000 · 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

Tax Reform as it relates to preserving retirement benefits S.2145 & H.R. 4123 - Fair Playing field Act of 2012 H.R. 4049 - Automatic IRA Act of 2012 S. 1557 - Automatic IRA Act of 2011 H.R. 3178 - Employee Misclassification Prevention Act S. 770 - Payroll Fraud Prevention Act H.R. 3287 - Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 H.R. 4050 - Retirement Plan Simplification and Enhancement Act of 2012

Client expense: $110,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC)

H.R. 3287, Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act H.R. 4049, Automatic IRA Act of 2012 H.R. 4050, Retirement Plan Simplification and Enhancement Act of 2012 S. 1813, MAP21, provisions relating to pensions Various issues relating to PBGC Premiums (changes to the structure and amount of premiums that defined benefit plan sponsors must pay to the Pension Benefit Guaranty Corporation); reform to tax incentives pertaining to private retirement plans; reform to defined benefit pension funding; regulatory activity relating to electronic disclosure of benefits; regulatory activity relating to the provision of annuities in DC plans; regulatory activity relating to plan fee disclosure requirements; regulatory activity relating to money market funds

Client expense: $31,650,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), Federal Highway Administration (FHA), Federal Reserve System, Federal Trade Commission (FTC), Federal Transit Administration (FTA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Internal Revenue Service (IRS), 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), Office of the Vice President of the United States, Patent & Trademark Office (PTO), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), White House Office

S.1813: Moving Ahead for Progress in the 21st Century (MAP-21), interest stabilization provisions; H.R.4050: Retirement Plan Simplification and Enhancement Act of 2012, e-delivery provisions; H.R. 3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011, 401(k) provisions; DOL participant-level disclosure requirements; DOL brokerage window regulations; ERISA Section 408(b)(2), disclosures provisions; Harkin proposal: The Retirement Crisis and a Plan to Solve It, all; DOL Field Assistance Bulletin No. 2012-02R, brokerage windows and fiduciary duty. Proposed regulations and general issues: hybrid plan regulations; cash balance regulations; PBGC premium strategy; proposed reforms to the regulation of money market funds; general retirement and pension issues.

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

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

Proposals related to expansion of SIMPLE IRAs, establishment of discretionary payroll deduction IRAs and creation of new qualified retirement plans for small business. Proposals relating to defined benefit plan funding. Issues related to regulations addressing liability for partial termination of defined benefit plans. Issues related to tax incentives for retirement savings and DOL fee disclosure proposals. Retirement recommendations contained in the final report of the National Commission on Fiscal Responsibility and Reform. Proposals 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. Proposals related to stable value investment offerings in defined contribution plans. Proposals related to phased retirement. Proposals to increase PBGC premiums, including those contained in the FY 2013 Obama Administration Budget proposal. Proposals related to retirement target date funds. Issues related to the Department of Labor's proposed regulation defining fiduciary for investment advice purposes. Proposals and regulations related to cash balance, pension equity, and other hybrid pension plans. Issues related to PBGC collections and PBGC disclosure issues. Proposals related to electronic disclosure of information under ERISA. Proposals regarding compliance of retirement plans. H.R. 3561, Small Business Pension Promotion Act. S. 1813/H.R. 4348, Moving Ahead for progress in the 21st Century, H.R. 4050, Retirement Plan Simplification and Enhancement Act. FASB pension accounting. USA Retirement proposal. Issues related to use of brokerage windows in defined contribution plans.

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, Pension Benefit Guaranty Corporation (PBGC), SENATE, Treasury, Dept of

H.R. 677 - The Lifetime Income Disclosure Act; entire bill H.R. 1534 Small Businesses Add Value for Employees (SAVE) Act; entire bill H.R. 3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill H.R. 3561 Small Business Pension Promotion Act of 2011; entire bill H.R. 4049 Automatic IRA Act; entire bill H.R. 4050 Retirement Simplification and Enhancement Act; entire bill H.R. 4348 - Moving Ahead for Progress in the 21st Century Act; provisions relating to extension of the National Flood Insurance Program, student loans, and pension provisions S. 267 - Lifetime Income Disclosure Act; entire bill S. 1020 The Savings Enhancement by Alleviating Leakage in 401(k) Savings Act; entire bill S. 1121 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill S. 1557 Automatic IRA Act of 2011; entire bill S. 2132 Highway Investment, Job Creation, and Economic Growth Act of 2012; provisions relating to pension funding and inherited IRAs S. 2252 Rebuild America Act; entire bill Department of Labors proposed rule modifying the definition of ERISA fiduciary and its implications for the provision of advice on qualified retirement savings Department of Labors 408(b)(2) rules and accompanying Q&As as they impact 401(k) brokerage windows. Role retirement savings tax incentive play in assuring coverage of diverse workforces and long-term economic benefits

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

The association monitors and reacts to policy concepts that may impact its ability to continue offering its high quality Retirement Security Plans to members, their employees, and the association staff at affordable rates and on reasonable terms and conditions. During the reporting period, the following issues were focused upon. H.R. 3287 - The Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act, all sections H.R. 3656 - The Retirement Savings Security Act, To amend the Internal Revenue Code of 1986 to provide for death and disability protection for loans from qualified employer plans, all sections H.R. 4348 - Moving Ahead for Progress in the 21st Century (MAP-21) Act, An act to authorize funds for Federal-aid highways, highway safety programs, and transit programs, and for other purposes, all sections dealing with pensions

Client expense: $220,000 · Firm income: Not reported

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

S. 267 - Lifetime Income Disclosure Act H.R. 677 - Lifetime Income Disclosure Act H.R. 4049 - Automatic IRA Act of 2012 H.R. 4050 - Retirement Plan Simplification and Enhancement Act of 2012 S. 1121 - Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 S. 1557 - Automatic IRA Act of 2011 H.R. 3287 - Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 E-Delivery DOL Fiduciary Definition Target Date Funds 401(k) Disclosure

Client expense: $1,556,769 · Firm income: Not reported

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

Public Employee Pension Transparency Act H.R. 567 Lifetime Income Disclosure Act H.R. 677 Burdensome Data Collection Relief Act H.R. 1062 Small Businesses Add Value for Employees Act of 2011 (SAVE Act) H.R. 1534 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption H.R. 1573 Would repeal provision in the Dodd-Frank Wall Street Act prohibiting federal bailout of swap dealers or participants H.R. 1838 To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders H.R. 1840 SEC Regulatory Accountability Act H.R. 2308 Swap Execution Facility Clarification Act H.R. 2586 Pension Technical Modifications Act H.R. 2656 Business Risk Mitigation and Price Stabilization Act of 2011 H.R. 2682 To Exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 2779 Retirement Income Protection Act of 2011 H.R. 3045 Hardship Outlays to protect Mortgagee Equity Act of 2011 H.R. 3104 Employee Misclassification Prevention Act H.R. 3178 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Savings Act H.R. 3287 Small Business Pension Protection Act of 2011 H.R. 3561 Retirement Savings Security Act of 2011 H.R. 3656 Automatic IRA Act H.R. 4049 Retirement Plan Simplification and Enhancement Act H.R. 4050 Fair Playing Field Act of 2012 H.R. 4123 (worker classification) Moving Ahead for Progress in the 21st Century (MAP-21) Act S. 1813/ House/Senate passed version H.R. 4348 (funding stabilization) Pension Funding defined benefit pension funding stabilization, technical corrections for defined benefit pension plans, frozen defined benefit plan issues, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, , partial termination enforcement, premium relief for certain delinquent plans Retirement Security/Investment Advice - defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, plan limits, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, small business plans, lifetime income, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, tax incentives for workplace retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term care/disability policies (LTDs), disability insurance Transfer of Excess Pension Assets Bipartisan Concurrent Resolution (H.CON. RES. 101) supporting retirement savings tax incentives Nondiscrimination rules applicable to defined benefit (DB) plans Senate Lifetime Income Disclosure Act S. 267 Public Employee Pension Transparency Act S. 347 Repeal the CLASS Entitlement Act S. 720 Payroll Fraud Prevention Act S. 770 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1020 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1121 Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act S. 1289 Automatic IRA Act of 2011 S. 1557 Hardship Outlays to protect Mortgagee Equity (HOME) Act S. 1656 Moving Ahead for Progress in the 21st Century (MAP-21) Act S. 1813/ Stop the Student Loan Interest Rate Hike Act of 2012 S. 2343, Senate/House passed version H.R. 4348 (funding stabilization) Fair Playing Field Act of 2012 S. 2145 (worker classification) Rebuild America Act S. 2252 Pension modernization - The Retirement Crisis and a Plan to Solve It USA Retirement Funds Senate Health, Education, Labor & Pensions Committee Pension funding defined benefit pension funding stabilization, defined benefit funding regulations/25-Year Averages of the Segment Rate, technical corrections for defined benefit pension plans, frozen defined benefit plan issues, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Retirement Security/Investment Advice defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, plan limits, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, 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, tax incentives for workplace retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs), disability insurance Nondiscrimination rules applicable to defined benefit (DB) plans Regulatory Retirement Report: Supporting Retirement for American Families; Lifetime Income Guidance Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563 Semi-Annual Regulatory Agendas Departments of Labor, Treasury ERISA Advisory Council 2012 Discussion Topics disability insurance & retirement stability, plan beneficiary designations Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Business conduct standards, segregation of swap collateral, pay ratio and other executive compensation disclosure issues, posting margin, stable value contracts Pension funding defined benefit pension funding stabilization, defined benefit funding stabilization regulations/25-Year Averages of the Segment Rate and lump sum valuation, adequacy of defined benefit vehicles, retirement plan designs, and tax treatment of expatriates Hybrid retirement plan designs implementation of the Pension Protection Act (PPA), finalization of proposed regulations Retirement Security/Investment advice disclosure of defined contribution plan fees under ERISA Section 408 (b) (2), plan limits, re-proposal of rule on definition of a fiduciary, pension benefit statements, amendment of abandoned plan program, ERISA claims procedures, investment selection and annuity issues, automatic/mandatory individual retirement accounts (IRAs), target date funds (TDFs) and qualified default investment alternatives (QDIAs); electronic disclosure of 401 (k) fee information, and defined benefit (DB) plans fiduciary requirements, 401 (k) participant fee disclosure regulations, in-plan Roth conversions issues RFI Electronic disclosure for employee benefit plans, electronic disclosure flexibility, longevity annuity contract regulations, partial annuity distribution regulations, income replacement Field Assistance Bulletin (FAB) 2012-02 Q & A 30 guidance on final regulations for participant-level retirement plan fee disclosure, brokerage windows, FAB 2012-02R (revision) Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Pension Benefits Guaranty Corporation (PBGC) guidance related to pension funding stabilization and premiums, premium and premium filing, submission issues, proposed regulations proposed ERISA Section 4062 (e) regulations, rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement, annual financial and actuarial reporting-ERISA Section 4010 Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Domestic plan asset investment issues International benefits issues/Puerto Rican plan trust issues Regulation of money market funds Multiemployer plan issues Public pension system issues Definition of governmental plans Worker classification issues Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans Distribution of retirement plan assets Nondiscrimination rules applicable to defined benefit (DB) plans Financial Accounting Standards Board (FASB) retirement plans De-risking defined benefit (DB) plans

Client expense: $216,050 · 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), Office of Management & Budget (OMB), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office

H.R. 677 - The Lifetime Income Disclosure Act; entire bill H.R. 1534 Small Businesses Add Value for Employees (SAVE) Act; entire bill H.R. 3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill H.R. 3561 Small Business Pension Promotion Act of 2011; entire bill H.R. 4049 Automatic IRA Act; entire bill H.R. 4050 Retirement Simplification and Enhancement Act; entire bill H.R. 4348 - Moving Ahead for Progress in the 21st Century Act; provisions relating to extension of the National Flood Insurance Program, student loans, and pension provisions S. 267 - Lifetime Income Disclosure Act; entire bill S. 1020 The Savings Enhancement by Alleviating Leakage in 401(k) Savings Act; entire bill S. 1121 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill S. 1557 Automatic IRA Act of 2011; entire bill S. 2132 Highway Investment, Job Creation, and Economic Growth Act of 2012; provisions relating to pension funding and inherited IRAs S. 2252 Rebuild America Act; entire bill Department of Labors proposed rule modifying the definition of ERISA fiduciary and its implications for the provision of advice on qualified retirement savings Department of Labor's 408(b)(2) rules and accompanying Q&As as they impact 401(k) brokerage windows Role retirement savings tax incentives play in assuring coverage of diverse workforces and long-term economic benefits

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals related to expansion of SIMPLE IRAs, establishment of discretionary payroll deduction IRAs and creation of new qualified retirement plans for small business. Proposals relating to defined benefit plan funding. Issues related to regulations addressing liability for partial termination of defined benefit plans. Issues related to tax incentives for retirement savings and DOL fee disclosure proposals. Retirement recommendations contained in the final report of the National Commission on Fiscal Responsibility and Reform. Proposals 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. Proposals related to stable value investment offerings in defined contribution plans. Proposals related to phased retirement. Proposals to increase PBGC premiums, including those contained in the FY 2013 Obama Administration Budget proposal. Proposals related to retirement target date funds. Issues related to the Department of Labor's proposed regulation defining fiduciary for investment advice purposes. Proposals and regulations related to cash balance, pension equity, and other hybrid pension plans. Issues related to PBGC collections and PBGC disclosure issues. Proposals related to electronic disclosure of information under ERISA. Proposals regarding compliance of retirement plans. H.R. 3561, Small Business Pension Promotion Act. S. 1813/H.R. 4348, Moving Ahead for progress in the 21st Century, H.R. 4050, Retirement Plan Simplification and Enhancement Act. FASB pension accounting.

Client expense: Not reported · Firm income: $70,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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 H.R.4050, Retirement Plan Simplification and Enhancement Act Issues related to retirement target date funds Issues related to Department of Labor defined contribution plan fee disclosure regulations Issues related to potential Treasury guidance on 401(k) plan design features

Client expense: $430,000 · Firm income: Not reported

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

S. 267 LIFETIME INCOME DISCLOSURE ACT HR 677 LIFETIME INCOME DISCLOSURE ACT HR 4049 AUTOMATIC IRA ACT OF 2012 E-DELIVERY S. 1121 SAVINGS ENHANCEMENT BY ALLEVIATING LEAKAGE IN 401(K) SAVINGS ACT OF 2011 S. 1557 AUTOMATIC IRA ACT OF 2011 HR 3287 SAVINGS ENHANCEMENT BY ALLEVIATING LEAKAGE IN 401(K) SAVINGS ACT OF 2011 HR 4050 RETIREMENT PLAN SIMPLIFICATION AND ENHANCEMENT ACT OF 2012 DOL FIDUCIARY DEFINITION TARGET DATE FUNDS 401(K) FEE DISCLOSURE

Client expense: $1,362,595 · Firm income: Not reported

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

Public Employee Pension Transparency Act H.R. 567 Lifetime Income Disclosure Act H.R. 677 Burdensome Data Collection Relief Act H.R. 1062 Small Businesses Add Value for Employees Act of 2011 (SAVE Act) H.R. 1534 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption H.R. 1573 Would repeal provision in the Dodd-Frank Wall Street Act prohibiting federal bailout of swap dealers or participants H.R. 1838 To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders H.R. 1840 SEC Regulatory Accountability Act H.R. 2308 Swap Execution Facility Clarification Act H.R. 2586 Pension Technical Modifications Act H.R. 2656 Business Risk Mitigation and Price Stabilization Act of 2011 H.R. 2682 To Exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 2779 Retirement Income Protection Act of 2011 H.R. 3045 Hardship Outlays to protect Mortgagee Equity Act of 2011 H.R. 3104 Employee Misclassification Prevention Act H.R. 3178 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Savings Act H.R. 3287 Small Business Pension Protection Act of 2011 H.R. 3561 Retirement Savings Security Act of 2011 H.R. 3656 Automatic IRA Act H.R. 4049 Retirement Plan Simplification and Enhancement Act H.R. 4050 Fair Playing Field Act of 2012 H.R. 4123 (worker classification) Moving Ahead for Progress in the 21st Century (MAP-21) Act S. 1813/ House/Senate passed version H.R. 4348 (funding stabilization) Fiscal Year 2012 & 2013 Budget Proposals budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues, worker classification issues FY2013 GOP Budget Proposal Path to Prosperity Financial Services Reform implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Public Law No: 111-203 - pay ratio and other executive compensation disclosure issues, business conduct standards, segregation of swap collateral, posting margin Pension Funding defined benefit pension funding stabilization, technical corrections for defined benefit pension plans, frozen defined benefit plan issues, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, , partial termination enforcement, premium relief for certain delinquent plans Retirement Security/Investment Advice - defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, plan limits, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, small business plans, lifetime income, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, tax incentives for workplace retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term care/disability policies (LTDs), disability insurance Transfer of Excess Pension Assets Bipartisan Concurrent Resolution (H.CON. RES. 101) supporting retirement savings tax incentives Joint Select Committee on Deficit Reduction impact on employee benefits provisions PBGC premiums, contribution limits to defined contribution plans and worker classification issues Lifetime Income Disclosure Act S. 267 Public Employee Pension Transparency Act S. 347 Repeal the CLASS Entitlement Act S. 720 Payroll Fraud Prevention Act S. 770 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1020 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1121 Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act S. 1289 Automatic IRA Act of 2011 S. 1557 Hardship Outlays to protect Mortgagee Equity (HOME) Act S. 1656 Moving Ahead for Progress in the 21st Century (MAP-21) Act S. 1813/ Stop the Student Loan Interest Rate Hike Act of 2012 S. 2343, Senate/House passed version H.R. 4348 (funding stabilization) Fair Playing Field Act of 2012 S. 2145 (worker classification) Rebuild America Act S. 2252 Fiscal Year 2012 & 2013 Budget Proposal budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues, worker classification issues Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 pay ratio and other executive compensation disclosure issues, business conduct standards, segregation of swap collateral, posting margin Pension funding defined benefit pension funding stabilization, technical corrections for defined benefit pension plans, frozen defined benefit plan issues, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Retirement Security/Investment Advice defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, plan limits, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, 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, tax incentives for workplace retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs), disability insurance Joint Select Committee on Deficit Reduction -impact on employee benefits provisions, PBGC premiums, contribution limits to defined contribution plans and worker classification issues Transfer of Excess Pension Assets Equal Employment Opportunity Commission (EEOC) Final regulations on disparate impact, potential effects on retirement plans Retirement Report: Supporting Retirement for American Families; Lifetime Income Guidance Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563 Semi-Annual Regulatory Agendas Departments of Labor, Treasury ERISA Advisory Council 2012 Discussion Topics Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Business conduct standards, segregation of swap collateral, pay ratio and other executive compensation disclosure issues, posting margin, stable value contracts Pension funding defined benefit pension funding stabilization, adequacy of defined benefit vehicles, retirement plan designs, and tax treatment of expatriates Hybrid retirement plan designs implementation of the Pension Protection Act (PPA) Retirement Security/Investment advice disclosure of defined contribution plan fees under ERISA Section 408 (b) (2), plan limits, re-proposal of rule on definition of a fiduciary, pension benefit statements, amendment of abandoned plan program, ERISA claims procedures, investment selection and annuity issues, automatic/mandatory individual retirement accounts (IRAs), target date funds (TDFs) and qualified default investment alternatives (QDIAs); electronic disclosure of 401 (k) fee information, and defined benefit (DB) plans fiduciary requirements, 401 (k) participant fee disclosure regulations, in-plan Roth conversions issues RFI Electronic disclosure for employee benefit plans, electronic disclosure flexibility, longevity annuity contract regulations, partial annuity distribution regulations, income replacement Field Assistance Bulletin (FAB) 2012-02 Q & A guidance on final regulations for participant-level retirement plan fee disclosure, brokerage windows Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Pension Benefits Guaranty Corporation (PBGC) - premium and premium filing, submission issues, proposed regulations proposed ERISA Section 4062 (e) regulations, rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Domestic plan asset investment issues International benefits issues/Puerto Rican plan trust issues Regulation of money market funds Multiemployer plan issues Public pension system issues Definition of governmental plans Worker classification issues Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans Distribution of retirement plan assets

Client expense: $246,648 · Firm income: Not reported

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

S.1121 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 S.267 Lifetime Income Disclosure Act H.R.4050 Retirement Plan Simplification and Enhancement Act of 2012 H.R.4049 Automatic IRA Act of 2012 H.R.3656 Retirement Savings Security Act of 2011 H.R.3561 Small Business Pension Promotion Act of 2011 H.R.3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 or the SEAL 401(k) Savings Act H.R.1534 Small Businesses Add Values for Employees Act of 2011 or SAVE Act of 2011 H.R.677 Lifetime Income Disclosure Act S.1813

Client expense: $193,346 · Firm income: Not reported

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

H.R. 677 - The Lifetime Income Disclosure Act; entire bill H.R. 1534 Small Businesses Add Value for Employees (SAVE) Act; entire bill H.R. 3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill H.R. 3561 Small Business Pension Promotion Act of 2011; entire bill H.R. 4049 Automatic IRA Act; entire bill H.R. 4050 Retirement Simplification and Enhancement Act; entire bill S. 267 - Lifetime Income Disclosure Act; entire bill S. 1020 The Savings Enhancement by Alleviating Leakage in 401(k) Savings Act; entire bill S. 1120 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill S. 1557 Automatic IRA Act of 2011; entire bill S. 1813 The Highway Investment, Job Creation and Economic Growth Act; provisions relating to pension funding and inherited IRAs S. 2132 Highway Investment, Job Creation, and Economic Growth Act of 2012; provisions relating to pension funding and inherited IRAs S. 2252 Rebuild America Act; entire bill - Department of Labors proposed rule modifying the definition of ERISA fiduciary and its implications for the provision of advice on qualified retirement savings

Client expense: $410,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 267 Lifetime Income Disclosure Act (Bingaman) S. 1121 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (Kohl) H.R. 677 Lifetime Income Disclosure Act (Holt) H.R. 3287 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (Johnson) H.R. 4049 Automatic IRA Act of 2012 (Neal) H.R. 4050 Retirement Plan Simplification and Enhancement Act of 2012 (Neal) H. Con. Res 101 Sense of Congresss on Tax Incentives for Retirement Savings (Gerlach/Neal) E-Delivery DOL Fiduciary Definition Target Date Funds 401 (k) Fee Disclosure

Client expense: $1,144,013 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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 H.R. 4050, Retirement Plan Simplification and Enhancement Act

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

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

H.R. 3287

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals related to expansion of SIMPLE IRAs, establishment of discretionary payroll deduction IRAs and creation of new qualified retirement plans for small business. Proposals relating to defined benefit plan funding. Issues related to regulations addressing liability for partial termination of defined benefit plans. Issues related to tax incentives for retirement savings. Retirement recommendations contained in the final report of the National Commission on Fiscal Responsibility and Reform. Proposals 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. Proposals related to stable value investment offerings in defined contribution plans. Proposals related to phased retirement. Proposals to increase PBGC premiums, including those contained in the FY 2013 Obama Administration Budget proposal. Proposals related to retirement target date funds. Issues related to the Department of Labor's proposed regulation defining fiduciary for investment advice purposes. Proposals and regulations related to cash balance, pension equity, and other hybrid pension plans. Issues related to PBGC collections and PBGC disclosure issues. Proposals related to electronic disclosure of information under ERISA. Proposals regarding compliance of retirement plans. H.R. 3561, Small Business Pension Promotion Act. S. 1813, Moving Ahead for Progress in the 21st Century, H.R. 4050, Retirement Plan Simplification and Enhancement Act.

Client expense: Not reported · Firm income: $70,000

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

Public Employee Pension Transparency Act H.R. 567 Lifetime Income Disclosure Act H.R. 677 Burdensome Data Collection Relief Act H.R. 1062 Fiscal Responsibility and Retirement Security Act of 2011 (To repeal the CLASS Program) H.R. Small Businesses Add Value for Employees Act of 2011 (SAVE Act) H.R. 1534 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption H.R. 1573 Would repeal provision in the Dodd-Frank Wall Street Act prohibiting federal bailout of swap dealers or participants H.R. 1838 To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders H.R. 1840 SEC Regulatory Accountability Act H.R. 2308 Swap Execution Facility Clarification Act H.R. 2586 Pension Technical Modifications Act H.R. 2656 Business Risk Mitigation and Price Stabilization Act of 2011 H.R. 2682 To Exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 2779 Retirement Income Protection Act of 2011 H.R. 3045 Hardship Outlays to protect Mortgagee Equity Act of 2011 H.R. 3104 Employee Misclassification Prevention Act H.R. 3178 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Savings Act H.R. 3287 Small Business Pension Protection Act of 2011 H.R. 3561 Automatic IRA Act H.R. 4049 Retirement Plan Simplification and Enhancement Act H.R. 4050 Fiscal Year 2012 & 2013 Budget Proposals budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues, worker classification issues FY2013 GOP Budget Proposal Path to Prosperity Financial Services Reform implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Public Law No: 111-203 - pay ratio and other executive compensation disclosure issues, business conduct standards, segregation of swap collateral, posting margin Pension Funding pension funding stabilization, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, , partial termination enforcement, premium relief for certain delinquent plans Retirement Security/Investment Advice - defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, small business plans, lifetime income, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs), disability insurance Joint Select Committee on Deficit Reduction -impact on employee benefits provisions, PBGC premiums, contribution limits to defined contribution plans and worker classification issues Retirement Report: Supporting Retirement for American Families; Lifetime Income Guidance Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563 Semi-Annual Regulatory Agendas Departments of Labor, Treasury ERISA Advisory Council 2012 Discussion Topics Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Business conduct standards, segregation of swap collateral, pay ratio and other executive compensation disclosure issues, posting margin, stable value contracts Pension funding pension funding stabilization, adequacy of defined benefit vehicles, retirement plan designs, and tax treatment of expatriates Hybrid retirement plan designs implementation of the Pension Protection Act (PPA) Retirement Security/Investment advice disclosure of defined contribution plan fees under ERISA Section 408 (b) (2) , re-proposal of rule on definition of a fiduciary, pension benefit statement, amendment of abandoned plan program, ERISA claims procedures, investment selection and annuity issues, automatic/mandatory individual retirement accounts (IRAs), target date funds (TDFs) and qualified default investment alternatives (QDIAs); electronic disclosure of 401 (k) fee information, and defined benefit (DB) plans fiduciary requirements, 401 (k) participant fee disclosure regulations, in-plan Roth conversions issues RFI Electronic disclosure for employee benefit plans, electronic disclosure flexibility Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Pension Benefits Guaranty Corporation (PBGC) - premium and premium filing, submission issues, proposed regulations proposed ERISA Section 4062 (e) regulations, rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Domestic plan asset investment issues International benefits issues/Puerto Rican plan trust issues Multiemployer plan issues Public pension system issues Plan audit issues Worker classification issues Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans Distribution of retirement plan assets The Highway Investment, Job Creation, and Economic Growth Act of 2012 S. 1813 potential impacts to required minimum distribution (MRD) rules, Section 420 Transfers, Mass transit parity Lifetime Income Disclosure Act S. 267 Public Employee Pension Transparency Act S. 347 Repeal the CLASS Entitlement Act S. 720 Payroll Fraud Prevention Act S. 770 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1020 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1121 Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act S. 1289 Automatic IRA Act of 2011 S. 1557 Hardship Outlays to protect Mortgagee Equity (HOME) Act S. 1656 Fiscal Year 2012 & 2013 Budget Proposal budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues, worker classification issues Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 pay ratio and other executive compensation disclosure issues, business conduct standards, segregation of swap collateral, posting margin Pension funding pension funding stabilization, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Retirement Security/Investment Advice defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, 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, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs), disability insurance Joint Select Committee on Deficit Reduction -impact on employee benefits provisions, PBGC premiums, contribution limits to defined contribution plans and worker classification issues

Client expense: $343,266 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Commodity Futures Trading Commission (CFTC), Congressional Budget Office (CBO), Council of Economic Advisers (CEA), Government Accountability Office (GAO), 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, White House Office

S. 267: Lifetime Income Disclosure Act, H.R. 677: Lifetime Income Disclosure Act, H.R. 1534: SAVE Act of 2011, H.R. 3561: Small Business Pension Promotion Act of 2011, S.1121 and H.R. 3287: Savings Enhancement by Alleviating Leakage in 401(K) Savings Act of 2011, H.R. 3656: Retirement Savings Security Act of 2011

Client expense: $207,600 · Firm income: Not reported

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

S.267 : Lifetime Income Disclosure Act H.R. 677 Lifetime Income Disclosure Act H.R. 1534 SAVE Act of 2011 H.R. 3561: Small Business Pension Promotion Act of 2011 S. 1121 and H.R. 3287: Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 H.R. 3656: Retirement Savings Security Act of 2011

Client expense: $207,600 · Firm income: Not reported

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

H.R. 677 - The Lifetime Income Disclosure Act; entire bill H.R. 1534 Small Businesses Add Value for Employees (SAVE) Act; entire bill H.R. 3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill H.R. 3561 Small Business Pension Promotion Act of 2011; entire bill S. 267 - Lifetime Income Disclosure Act; entire bill S. 1020 The Savings Enhancement by Alleviating Leakage in 401(k) Savings Act; entire bill S. 1120 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill S. 1557 Automatic IRA Act of 2011; entire bill Department of Labors proposed rule modifying the definition of ERISA fiduciary and its implications for the provision of advice on qualified retirement savings

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

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

Public Employee Pension Transparency Act - H.R. 567 Lifetime Income Disclosure Act - H.R. 677 Burdensome Data Collection Relief Act - H.R. 1062 Fiscal Responsibility and Retirement Security Act of 2011 (To repeal the CLASS Program) - H.R. 1173 Small Businesses Add Value for Employees Act of 2011 (SAVE Act) H.R. 1534 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption H.R. 1573 Would repeal provision in the Dodd-Frank Wall Street Act prohibiting federal bailout of swap dealers or participants H.R. 1838 To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders H.R. 1840 SEC Regulatory Accountability Act H.R. 2308 Swap Execution Facility Clarification Act H.R. 2586 Pension Technical Modifications Act H.R. 2656 Business Risk Mitigation and Price Stabilization Act of 2011 H.R. 2682 Amends the Commodity Exchange Act and the Securities Exchange Act of 1934 H.R. 2779 Retirement Income Protection Act of 2011 H.R. 3045 Hardship Outlays to protect Mortgagee Equity Act of 2011 H.R. 3104 Employee Misclassification Prevention Act H.R. 3178 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Savings Act H.R. 3287 Small Business Pension Protection Act of 2011 H.R. 3561 Fiscal Year 2012 Budget Proposal budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 H.R. 4 Public Law No: 112-009 Financial Services Reform implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Public Law No: 111-203 Pension Funding - additional funding relief and reform, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, , partial termination enforcement Retirement Security - defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, 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, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs) National Commission on Fiscal Responsibility and Reform implications for benefits Joint Select Committee on Deficit Reduction impact on employee benefits provisions PBGC premiums, contribution limits to defined contribution plans and worker classification issues The American Jobs Act Lifetime Income Disclosure Act S. 267 Public Employee Pension Transparency Act S. 347 Repeal the CLASS Entitlement Act S. 720 Payroll Fraud Prevention Act S. 770 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Act) S. 1020 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Act) S. 1121 Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act S. 1289 Automatic IRA Act of 2011 S. 1557 Hardship Outlays to protect Mortgagee Equity (HOME) Act S. 1656 National Commission on Fiscal Responsibility and Reform implications for benefits Fiscal Year 2012 Budget Proposal budgetary impacts of health and retirement entitlement programs, PBGC insurance, premium issues Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Pension funding additional funding relief and reform, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Retirement Security defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, 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, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs) National Commission on Fiscal Responsibility and Reform implications for benefits Joint Select Committee on Deficit Reduction - impact on employee benefits provisions PBGC premiums, contribution limits to defined contribution plans and worker classification issues The American Jobs Act Joint Select Committee on Deficit Reduction impact on employee benefits provisions PBGC premiums, worker classification issues Presidential Advisory Council on Financial Capability Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563 2011-2012 Agency Guidance Priority List Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 proposed regulations related to swap trades; process for review of swaps for mandatory clearing; provisions common to registered entities, legal entity identification for financial contracts; swap data recordkeeping and reporting requirements; real-time reporting of swap transaction data; reporting, recordkeeping, and daily trading records requirements for swap dealers and major swap participants; unique counterparty identifiers; definition of swap dealer, security-based swap dealer, major swap participant, major security-based swap participant, eligible contract participant; swap data repository (SDR); business conduct standards for swap dealers and major swap participants with counterparties; transparency and accountability of derivatives market; regulation of over-the-counter swaps transactions; stable value contracts. Pension funding - adequacy of defined benefit vehicles, retirement plan designs, and tax treatment of expatriates Hybrid retirement plan designs implementation of the Pension Protection Act (PPA) Investment advice re-proposal of rule on definition of fiduciary, adequacy of defined contribution vehicles, investment selection and annuity issues, automatic/mandatory individual retirement accounts (IRAs), proposed regulations regarding target date funds (TDFs) and qualified default investment alternatives (QDIAs); electronic disclosure of 401 (k) fee information, 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, in-plan Roth conversions issues RFI Electronic disclosure for employee benefit plans Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Pension Benefits Guaranty Corporation (PBGC) - premium and premium filing, submission issues, proposed regulations ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Domestic plan asset investment issues International benefits issues/Puerto Rican plan trust issues Multiemployer plan issues Public pension system issues Plan audit issues Worker classification issues Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans Plan distribution issues

Client expense: $250,785 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Commodity Futures Trading Commission (CFTC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of Management & Budget (OMB), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office

S. 267 Lifetime Income Disclosure Act S. 1121 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 S. 1557 Automatic IRA Act of 2011 E-Delivery H.R. 677 Lifetime Income Disclosure Act H.R. 3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 DOL Fiduciary Definition Target Date Funds 401(k) Fee Disclosure Automatic IRA Sense of Congress on Retirement Savings

Client expense: $1,019,624 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals related to expansion of SIMPLE IRAs, establishment of discretionary payroll deduction IRAs and creation of new qualified retirement plans for small business. Proposals relating to defined benefit plan funding. Issues related to regulations addressing liability for partial termination of defined benefit plans. Issues related to tax incentives for retirement savings. Retirement recommendations contained in the final report of the National Commission on Fiscal Responsibility and Reform. Proposals 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. Proposals related to stable value investment offerings in defined contribution plans. Proposals related to phased retirement. Proposals to increase PBGC premiums, including those contained in the FY 2012 Obama Administration Budget proposal. Proposals related to retirement target date funds. Issues related to the Department of Labor's proposed regulation defining fiduciary for investment advice purposes. Proposals and regulations related to cash balance, pension equity, and other hybrid pension plans. Issues related to PBGC collections and PBGC disclosure issues. Proposals related to electronic disclosure of information under ERISA. Proposals regarding compliance of retirement plans. H.R. 3561, Small Business Pension Promotion Act.

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

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Treasury, Dept of

H.R. 3287

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES

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 retirement target date funds Issues related to tax incentives for retirement savings Issues related to the effect of the Department of Labors proposed fiduciary definition regulation Issues related to stable value funds in retirement plans Issues related to securities lending in retirement funds 401(k) fee disclosures 401(k) investment advice Issues related to electronic delivery of employee plan notices and statements Proposals to simplify retirement plan administration

Client expense: $450,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC)