Investment Adviser Examination Improvement Act of 2012

Implementation of H.R. 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act;SEC Proposed Rule on "Mutual Fund Distribution Fees"; SEC study on Investment Advisers and Broker-Dealers, as required by Section 913 of the Dodd-Frank Wall Street Reform and Consumer Protection Act; study required under Dodd-Frank Act Section 914 oversight of investment advisers; HR 4624 A bill to amend the Investment Advisers Act of 1940 to provide for registration and oversight over national investment advisers assn's HR 6204 Investment Adviser Examination Improvement Act of 2012.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC)

H.R. 940 - United States Covered Bond Act of 2011; entire bill H.R. 2577 - SAFE Data Act; provisions applicable to financial institutions H.R. 2827 - To amend the Securities Exchange Act of 1934 to clarify provisions relating to the regulation of municipal advisors, and for other purposes; provisions relating to broker dealers H.R. 3523 - Cyber Intelligence Sharing and Protection Act of 2011; entire bill H.R. 4624 - Investment Adviser Oversight Act of 2012; entire bill H.R. 6204 - Investment Adviser Examination Improvement Act of 2012; entire bill H.R. 6397 - Defending American Taxpayers From Abusive Government Takings Act of 2012; entire bill H.R. 6423 - Insurance Consumer Protection and Solvency Act of 2012; entire bill S. 1151 Personal Data Privacy and Security Act of 2011; provisions applicable to financial institutions S. 1207 Data Security and Breach Notification Act of 2011; provisions applicable to financial institutions S. 1434 Data Security Act of 2011; provisions applicable to financial institutions S. 1606 Regulatory Accountability Act of 2011; entire bill S. 1615 Financial Regulatory Responsibility Act of 2011; entire bill S. 3620 - A bill to amend the Securities Exchange Act of 1934 to clarify provisions relating to the regulation of municipal advisors; entire bill Impact of the Volcker Rule on market liquidity and international competitiveness of U.S.-owned asset managers Implementation of Sections 913/914 of Dodd-Frank Wall Street Reform and Consumer Protection Act and its inter-relationship with the DoL ERISA fiduciary definition proposal Impact of DFA and mortgage settlement initiatives on investors/creditors interests Congressional inquiry on corporate cybersecurity practices.

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

S. 1615 - Financial Regulatory Responsibility Act S. 1650 - Dodd-Frank Improvement Act of 2011 S. 1834 - Residential Mortgage Market Privatization and Standardization Act of 2011 S. 1835 - United States Covered Bond Act S. 3468 - Independent Agency Regulatory Analysis Act of 2012 S. 3497 - Terminating the Expansion of Too-Big-To-Fail Act of 2012 S. 3620 - Regulation of Municipal Advisors S. 3637 - Temporarily Extend the Transaction Account Guarantee Program S. 3709 - GAO Study of Too Big to Fail H.R. 940 - United States Covered Bond Act of 2011 H.R. 1182 - GSE Bailout Elimination and Taxpayer Protection Act H.R. 1539 - Asset-Backed Market Stabilization Act of 2011 H.R. 1573 - Delay Implementation of Title VII of Dodd-Frank H.R. 1838 - Repeal DFA provision prohibiting assistance to swap dealers or participants H.R. 1840 - Consideration by the CFTC of the costs and benefits of its regulations H.R. 2308 - SEC Regulatory Accountability Act H.R. 2483 - Whistleblower Improvement Act of 2011 H.R. 2577 - Secure and Fortify Electronic Data Act H.R. 2586 - Swap Execution Facility Clarification Act H.R. 2682 - Business Risk Mitigation and Price Stabilization Act of 2011 H.R. 2779 - To exempt inter-affiliate swaps from Dodd-Frank Act H.R. 2827 - Regulation of Municipal Advisors H.R. 3606 - JOBS Act H.R. 3644 - Private Mortgage Market Investment Act H.R. 3862 - Sunshine for Regulatory Decrees and Settlements Act of 2012 H.R. 4078 - Red Tape Reduction and Small Business Job Creation Act H.R. 4624 - Investment Adviser Oversight Act H.R. 5929 - Next Steps for Credit Availability Act H.R. 6127 - Liquidity Enhancement for Small Public Companies Act H.R. 6204 - Investment Adviser Examination Improvement Act of 2012 H.R. 6317 - Terminating the Expansion of Too-Big-to-Fail Act of 2012 Draft - SEC Modernization Act CFTC Rule 4.5 Money Market Mutual Funds SIFIs Volcker Rule Use of Commodities by Mutual Funds Exchange-Traded Funds Market Structure Mandatory Audit Firm Rotation Tri-Party Repo Market Mortgage Eminent Domain FX Forwards and FX Swaps Non-deliverable Forwards

Dodd-Frank Wall Street reform and Consumer Protection Act- related studies (Sections 913, 914, 919) Investment Advisers Oversight Act of 2012 (HR 4624) Investment Adviser Examination Improvement Act of 2012 (HR 6204)

Client expense: $108,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC)

Fiduciary Duty S. 1615 - Financial Regulatory Responsibility Act S. 1787 & H.R. 3313 - Wall Street Trading and Speculators Tax Act S. 3416 - A bill to enhance civil penalties under the Federal securities laws, and for other purposes. S. 3620 - A bill to amend the Securities Exchange Act of 1934 to clarify provisions relating to the regulation of municipal advisors, and for other purposes. H.R. 2483 - Whistleblower Improvement Act H. R. 2308 - SEC Regulatory Accountability Act H.R.2827 - To amend the Securities Exchange Act of 1934 to clarify provisions relating to the regulation of municipal advisors, and for other purposes H.R. 4624 - Investment Adviser Oversight Act of 2012 H.R. 5050 - Social Networking Online Protection Act H.R. 757 - Equitable Treatment of Investors Act H.R. 4078 - Red Tape Reduction and Small Business Job Creation Act H.R. 6204 - Investment Adviser Examination Improvement Act of 2012

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

H.R. 4624, INVESTMENT OVERSIGHT ACT OF 2012, OPPOSED LEGISLATION THAT WOULD DELEGATE GOVERNMENTAL AUTHORITY FOR OVERSIGHT OF INVESTMENT ADVISORS TO ONE OR MORE SELF-REGULATORY ORGANIZATION (SROs) H.R. 2483, WHISTLEBLOWER IMPROVEMENT ACT OF 2011, OPPOSEDREP. GRIMMS BILL THAT WOULD EVISCERATE THE SECS WHISTLEBLOWER PROGRAM (PASSED BY BY THE HOUSE FSCS SUBCOMMITTEE ON CAPITAL MARKETS 12/14/11) H.R. 6204, INVESTMENT ADVISER EXAMINATION IMPROVEMENT ACT OF 2012, OPPOSED EXPANDING SELF REGULATION OF INVESTMENT ADVISORS AND SUPPORTING OVERSIGHT BY THE SEC

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

Government targets: Centers For Disease Control & Prevention (CDC), Defense, Dept of (DOD), Energy, Dept of, Executive Office of the President (EOP), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Natl Aeronautics & Space Administration (NASA), Natl Archives & Records Administration (NARA), Office of Government Ethics (OGE), Office of Management & Budget (OMB), SENATE

H.R. 4624 H.R. 6204 Investment Adviser Act of 1940 financial services legislation

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC)

HR 4624, the Investment Adviser Oversight Act. HR 6204, the Investment Adviser Examination Improvement Act. HR 2308, the SEC Regulatory Accountability Act. S 1615, the Financial Regulatory Responsibility Act. HR 2434/HR 6020, the Financial Services and General Government Appropriations Act. HR 6317, the Terminating the Expansion of Too-Big-to-Fail Act. Regulatory proposals related to money market funds and to the implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act, including proposals related to harmonizing broker-dealers and investment advisers under similar standards of care; consumer protection; systemic risk; orderly liquidation authority; and the "Volcker Rule."

Client expense: $630,000 · Firm income: Not reported

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

Fiduciary Duty S. 1615 - Financial Regulatory Responsibility Act S. 1787 & H.R. 3313 - Wall Street Trading and Speculators Tax Act H.R. 2483 - Whistleblower Improvement Act H. R. 2308 - SEC Regulatory Accountability Act H.R.2827 - To amend the Securities Exchange Act of 1934 to clarify provisions relating to the regulation of municipal advisors, and for other purposes H.R. 4624 - Investment Adviser Oversight Act of 2012 H.R. 5050 - Social Networking Online Protection Act H.R. 757 - Equitable Treatment of Investors Act H.R. 4078 - Red Tape Reduction and Small Business Job Creation Act H.R. 6204 - Investment Adviser Examination Improvement 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)

Dodd-Frank Wall Street reform and Consumer Protection Act- related studies (Sections 913, 914, 919) Investment Advisers Oversight Act of 2012 (HR 4624) Investment Adviser Examination Improvement Act of 2012 (HR 6204)

Client expense: $108,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC)

H.R. 940 - United States Covered Bond Act of 2011; entire bill H.R. 2577 - SAFE Data Act; provisions applicable to financial institutions H.R. 2827 - To amend the Securities Exchange Act of 1934 to clarify provisions relating to the regulation of municipal advisors, and for other purposes; provisions relating to broker dealers H.R. 3523 - Cyber Intelligence Sharing and Protection Act of 2011; entire bill H.R. 4624 - Investment Adviser Oversight Act of 2012; entire bill H.R. 6204 - Investment Adviser Examination Improvement Act of 2012; entire bill H.R. 6397 - Defending American Taxpayers From Abusive Government Takings Act of 2012; entire bill H.R. 6423 - Insurance Consumer Protection and Solvency Act of 2012; entire bill S. 1151 Personal Data Privacy and Security Act of 2011; provisions applicable to financial institutions S. 1207 Data Security and Breach Notification Act of 2011; provisions applicable to financial institutions S. 1434 Data Security Act of 2011; provisions applicable to financial institutions S. 1606 Regulatory Accountability Act of 2011; entire bill S. 1615 Financial Regulatory Responsibility Act of 2011; entire bill S. 2223 - A bill to address the implementation of certain prohibitions under the Bank Holding Company Act of 1956, and for other purposes; entire bill S. 3620 - A bill to amend the Securities Exchange Act of 1934 to clarify provisions relating to the regulation of municipal advisors; entire bill Impact of the Volcker Rule on market liquidity and international competitiveness of U.S.-owned asset managers Implementation of Sections 913/914 of Dodd-Frank Wall Street Reform and Consumer Protection Act and its inter-relationship with the DoL ERISA fiduciary definition proposal Impact of DFA and mortgage settlement initiatives on investors/creditors interests