Financial Stability Oversight Council Improvement Act of 2014

Federal Reserve Boards Rules to Implement Basel III Regulatory Capital Reforms; Dodd-Frank Wall Street Reform and Consumer Protection Act in regards to:Systemic Risk Designation, Capital Requirements for the Savings & Loan Holding Company and Federal Reserve Oversight as in the following bills:HR4510/S2270 - Insurance Capital Standards Clarification Act of 2014; money market Reform; HR508 - Terrorism Risk Insurance Act / Reauthorization Act of 2013, HR4871 - TRIA Reform Act of 2014; Asset Manager issues, HR5180 - Financial Stability Oversight Council Improvement Act of 2014.

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

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

Implementation of Public Law No. 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act, specifically, provisions on risk, insurance oversight (Federal Insurance Office), and potential CFPB activities related to P&C insurance.Discussions on U.S. and global designation of systemically relevant non-bank financial firms. S.1369, A bill to provide additional flexibility to the Board of Governors of the Federal Reserve System to establish capital standards that are properly tailored to the unique characteristics of the business of insurance, and for other purposes. S. 2270, Insurance Capital Standards Clarification Act of 2014. S.2101, A bill to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act. H.R. 5180, Financial Stability Oversight Council Improvement Act of 2014. General discussions on Insurance Capital Investment. General discussions on Commercial Insurance regulation General issues related to resilience and mitigation, as related to P&C insurance. General discussions on natural catastrophe related proposals. S.2244, Terrorism Insurance Program Reauthorization Act of 2014. H.R. 83, Making consolidated appropriations for the fiscal year ending September 30, 2015, and for other purposes. H.R. 26, Terrorism Risk Insurance Program Reauthorization Act of 2015. General discussions on the insurability of cyber exposures. S.2519, National Cybersecurity Protection Act of 2014. S.1353, Cybersecurity Enhancement Act of 2014. General discussions on issues related to Surety Bonds. H.R. 4435, Howard P. "Buck" McKeon National Defense Authorization Act for Fiscal Year 2015, provisions on insurance issues. H.R. 3979, Carl Levin and Howard P. "Buck" McKeon National Defense Authorization Act for Fiscal Year 2015, provisions on insurance issues.

H.R. 624 - Cyber Intelligence Sharing and Protection Act; provisions relating to the financial services sector H.R. 1627 - The Investment Adviser Examination Improvement Act of 2013; entire bill H.R. 2374 - Retail Investor Protection Act; entire bill H.R. 2733 - Defending American Taxpayers From Abusive Government Takings Act of 2013; entire bill H.R. 3482 - Restoring Main Street Investor Protection Act; entire bill H.R. 3696 - National Cybersecurity and Critical Infrastructure Protection Act of 2013; entire bill H.R. 4060 - Systemic Risk Designation Improvement Act of 2014; entire bill H.R. 4167 - Restoring Proven Financing for American Employers Act; entire bill H.R. 4413 -Customer Protection and End-User Relief Act; provisions relating to the Garrett amendment on CPO registration H.R. 4510 - Insurance Capital Standards Clarification Act of 2014; entire bill H.R. 5180 - Financial Stability Oversight Council Improvement Act of 2014; entire bill H.R. 5461 - To clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes; provisions relating to capital standards for insurers H.R. 5471 - to Amend the Commodity Exchange Act and the Securities Exchange Act of 1934 to specify how Clearing Requirements Apply to Certain Affiliate Transactions, and for other purposes; entire bill H.R. 5490 - Wall Street Accountability Through Sustainable Funding Act; entire bill S. 21 - Cybersecurity and American Cyber Competitiveness Act of 2013; provisions relating to the financial services sector S. 1369 - A bill to provide additional flexibility to the Board of Governors of the Federal Reserve System to establish capital standards that are properly tailored to the unique characteristics of the business of insurance, and for other purposes; entire bill S. 1927 - Data Security Act of 2014; entire bill S. 2270 - Insurance Capital Standards Clarification Act of 2014; entire bill S. 2588 - Cybersecurity Information Sharing Act of 2014; provisions relating to safe harbor for information sharing for prevention of cybersecurity threats Need for greater transparency in the development of SIFI designation criteria and preparation of underlying government studies and data Congressional support for the SEC moving forward on implementing Section 913 of Dodd-Frank, other options for investor protection parity, and potential interplay with possible DOL regulatory activity

S. 215, the Federal Reserve Single Mandate Act of 2013 (all provisions) S. 450, the Financial Regulatory Responsibility Act of 2013 (all provisions) H.R. 1062, the SEC Regulatory Accountability Act (all provisions) H.R. 2446, the Responsible Consumer Financial Protection Regulations Act of 2013 H.R. 3193, the Consumer Financial Protection Safety and Soundness Improvement Act of 2013 H.R. 3928, Federal Reserve Accountability and Transparency Act of 2014 H.R. 3913, to amend the Bank Holding Company Act of 1956 to require agencies to make considerations relating to the promotion of efficiency, competition, and capital formation before issuing or modifying certain regulations. H.R. 4387, FSOC Transparency and Accountability Act H.R. 4383, Bureau of Consumer Financial Protection Small Business Advisory Board Act H.R. 4262, Bureau Advisory Commission Transparency Act H.R. 4539, Bureau Research Transparency Act H.R. 4684, Bureau Guidance Transparency Act H.R. 5018, Federal Reserve Accountability and Transparency Act of 2014 H.R. 5037, The Office of Financial Research Accountability Act of 2014 H.R. 5180, Financial Stability Oversight Council Improvement Act of 2014 H.R. 5188, to amend the Consumer Financial Protection Act of 2010 to require the CFPB to develop a model form for a disclosure notice for depository institutions and credit unions. S. 2696, a bill to require the Federal Reserve to make certain changes to the small bank holding company policy statement on assessment of financial and managerial factors. S. 2732, CFPB Examination and Reporting Threshold Act of 2014 S. 2937, a bill to require the president of the Federal Reserve Bank of NY to be appointed by the President, by and with the advice and consent of the Senate H.R. 5749, State Regulatory Representation Clarification Act of 2014

H.R. 3448 - Small Cap Liquidity Reform Act of 2013 (Duffy) H.R. 4387 - FSOC Transparency and Accountability Act (Garrett) H.R. 4570 - Private Placement Improvement Act of 2014 (Garrett) H.R. 4881 - One Year Moratorium on Authority of FSOC to Make SIFI Determinations (Neugebauer) H.R. 5037 - Office of Financial Research Accountability Act of 2014 (Royce) H.R. 5180 - Financial Stability Oversight Council Improvement Act of 2014 (Ross) Money Market Mutual Funds FSOC Review of Asset Management Sector for Potential SIFI Designations CFTC Rule 4.5 Exchange-Traded Funds Eminent Domain Structure of the U.S. Securities Markets Uniform Fiduciary Standard for Broker-Dealers and Investment Advisers Investment Company Act of 1940 Data Breaches

Client expense: $1,130,086 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Financial Regulatory Reform Federal Reserve Supervision of Savings and Loan Holding Companies Federal Reserve Boards Rules to Implement Basel III Regulatory Capital Reforms Dodd-Frank Wall Street Reform and Consumer Protection Act in regards to: Systemic Risk Designation Capital Requirements for the Savings & Loan Holding Company and Federal Reserve Oversight as in the following bills: HR4510/S2270 - Insurance Capital Standards Clarification Act of 2014 MMF Reform Terrorism Risk Insurance Extension as in the following bills: HR508 - Terrorism Risk Insurance Act of 2002 Reauthorization Act of 2013 HR4871 - TRIA Reform Act of 2014 GSE Reform Asset Manager SIFI Designation as in the following bill: HR5180 - Financial Stability Oversight Council Improvement Act of 2014 Equity Market Structure

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

Issues related to Dodd-Frank Wall Street Reform and Consumer Protection Act (Public Law 111-203) implementation and regulations, including SIFI rules and designation, systemic risk, orderly liquidation authority and derivatives Issues related to systemic risk regulation of non-bank financial institutions Issues related to portfolio management of exchange-traded funds (ETFs), including transparency and custom baskets Issues related to swap execution facility trading, interactions and reporting of swaps trading Issues related to definition of major swap participants Issues related to enhancements to margin protection rules for swap participants and effect of bankruptcy of a futures clearing merchant or clearinghouse on derivatives trading Issues related to nature of collateral for cleared swaps Issues related to margin for uncleared swaps, including cash-only margin Issues related to capital requirements for cleared and uncleared swaps Issues related to transaction recording obligation under the CFTCs SEF rules Issues related to derivatives trading reforms including cross border provisions, FX settling, and commodity pool operator registration requirements Issues related to market structure matters (computerized trading, trade-at, high frequency trading, minimizing latency of market data feeds, improving resiliency of technology and infrastructure to avoid single points of failure, Regulation NMS and the maker-taker model) Issues related to effect of the Volcker rule on fixed income markets, equity markets, and mutual fund shareholders Issues related to the Financial Stability Oversight Council (FSOC) and mutual funds, including H.R. 5180 (Financial Stability Oversight Council Improvement Act of 2014) Issues related to the Financial Stability Board (FSB) and mutual funds Issues related to the Office of Financial Research study of asset managers and its potential impact on mutual funds Issues related to legislation and regulations affecting mutual funds and the mutual fund industry Issues related to regulation of mortgage- and other asset-backed securities, housing finance reform, and Government Sponsored Enterprise reform Proposals related to potential money market fund regulations (e.g. floating net asset value, capital requirements, redemption hold-back, liquidity gates and fees, treatment of municipal money market funds) Issues related to the overnight reverse repurchase agreement proposal Issues related to market activities and effects upon Treasury inflation protected securities Issues related to the SECs enhanced fund reporting initiative Issues related to the structure and offering of annuities H.R. 2374 (Retail Investor Protection Act) for regulatory coordination between the DOL and the SEC Issues surrounding the fiscal situation with Puerto Rico and its impact on the municipal bonds market Issues related to disclosure of municipal bond transaction expenses Issues related to a pilot program for expanded tick sizes for small capitalization stocks, including H.R. 1952 (Spread Pricing Liquidity Act of 2013) and H.R. 3448 (Small Cap Liquidity Reform Act of 2013) Issues related to the regulation of the asset management industry Issues related to the EU safe harbor framework Issues related to the flash crash and availability of liquidity in the fixed income markets

Issues related to the regulation of money market mutual funds. Issues relating to the modification of Rule 4.5 under the Commodity Exchange Act. H.R. 5180, the Financial Stability Oversight Council Improvement Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

See AddendumS.1927, Data Security Act of 2014 Various proposals related to cyber and data security and privacy issues. No Bill Number - A Senate Banking Committee proposal regarding housing finance reform based on S. 1217 - "Housing Finance Reform and Taxpayer Protection Act of 2013". NIST framework and incentives for the adoption of the NIST framework. H.R. 4167, Restoring Proven Financing for American Employers Act - Amends the Bank Holding Company Act of 1956 with respect to certain prohibitions on proprietary trading by banking entities and certain relationships with hedge funds and private equity funds (Volcker Rule). H.R. 5180, the Financial Stability Oversight Council Improvement Act of 2014 - Amends the Financial Stability Act of 2010 to subject the Financial Stability Oversight Council (Council) to the Administrative Procedure Act. FDIC Interim Final Rule of Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective Action, Standardized Approach for Risk-Weighted Assets, Market Discipline and Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule and Market Risk Capital Rule (7/9/13). Financial Stability Oversight Council, Notice of proposed rulemaking regarding authority to require supervision of certain non-bank financial companies, (1/26/11). SEC Final Rule, Registration of Municipal Advisors, 17 CFR, Parts 240 and 249, 78 FR 59814 (9/30/2013). CFTC Exemptive Order Regarding Compliance with Certain Swap Regulations (Cross-Border Phase-In Exemptive Order) (7/12/13). Department of Treasury, IAIS Common Framework for the Supervision of Internationally Active Insurance Groups (7/1/11). Section 619, "Dodd Frank Wall Street Reform and Consumer Protection Act", Final Rule, 12 CFR Part 44, 12 CFR Part 248, 12 CFR Part 351, 17 CFR Part 255 (12/10/2013). Section 941, Dodd Frank Wall Street Reform & Consumer Protection Act, Notice of proposed rulemaking, Credit Risk Retention SEC, 17 CFR Part 246, 78 FR 57928 (9/20/13). "The Dodd-Frank Wall Street Reform and Consumer Protection Act", P.L. No. 111-203 - Regulatory implementation of provisions relating to insurance companies.

Implementation of Financial Regulatory Reform - HR 4173/S 3217 derivatives, systemically important, orderly liquidation, prudential requirements, Federal Insurance Office study. Financial Stability Oversight Council Final Rule Interpretive Guidance on the authority to Require Supervision and Regulation of Certain Nonbank Financial Companies (RIN 4030-AA00) H.R. 5180, Financial Stability Oversight Council Improvement Act - all provisions Federal Reserve Board Rulemaking on Enhanced Prudential Standards and Early Remediation Requirements for Covered Companies (RIN 7100-AD-86) Federal Reserve Board Notice of Proposed Rulemaking on Concentration Limits on Large Financial Companies (Docket No. R-1489 & RIN 7100 AE 18) Federal Reserve Board Notice of Proposed Rulemaking on Amendments to the Capital Plan and Stress Test Rules (Docket No. 1492; RIN 7100 AE 20) Federal Reserve Rulemaking on Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Minimum Regulatory Capital Ratios, Capital Adequacy, Transition Provisions, and Prompt Corrective Action (FRS Docket No. R-1438 & RIN 3064-AD95); Standardized Approach for Risk-weighted Assets; Market Discipline and Disclosure Requirements (FRS Docket No. R-1442 & RIN 3064-AD96); Advanced Approaches Risk-Based Capital Rule; Market Risk Capital Rule (FRS Docket No. R-1442 & RIN 3064-AD97) S.2270, HR 5461 and H.R. 4510 (Insurance Capital Standards Clarification Act of 2014) - To provide additional flexibility to the Board of Governors of the Federal Reserve System to establish capital standards that are properly tailored to the unique characteristics of the business of insurance, and for other purposes. H.R. 2374 - Retail Investor Protection Act - all provisions H.R. 4881, a bill to place a 6-month moratorium on the authority of the Financial Stability Oversight Council to make financial stability determinations - all provisions H.R. 4387 - the FSOC Transparency and Accountability Act - To amend the Financial Stability Act of 2010 to require the Financial Stability Oversight Council to hold open meetings and comply with the requirements of the Federal Advisory Committee Act, to provide additional improvements to the Council, and for other purposes - all provisions Joint agency proposed rulemaking on Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants; RIN 3038-AC97

H.R. 624 Cyber Intelligence Sharing and Protection Act; provisions relating to the financial services sector H.R. 1627 The Investment Adviser Examination Improvement Act of 2013; entire bill H.R. 2374 Retail Investor Protection Act; entire billH.R. 2733 Defending American Taxpayers From Abusive Government Takings Act of 2013; entire bill H.R. 3482 Restoring Main Street Investor Protection Act; entire bill H.R. 3696 National Cybersecurity and Critical Infrastructure Protection Act of 2013; entire bill H.R. 4060 - Systemic Risk Designation Improvement Act of 2014; entire bill H.R. 4167 Restoring Proven Financing for American Employers Act; entire bill H.R. 4413 Customer Protection and End-User Relief Act; provisions relating to the Garrett amendment on CPO registration H.R. 4510 - Insurance Capital Standards Clarification Act of 2014; entire bill H.R. 5180 Financial Stability Oversight Council Improvement Act of 2014; entire bill H.R. 5461 - To clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes; provisions relating to capital standards for insurers H.R. 5471 to Amend the Commodity Exchange Act and the Securities Exchange Act of 1934 to specify how Clearing Requirements Apply to Certain Affiliate Transactions, and for other purposes; entire bill H.R. 5490 Wall Street Accountability Through Sustainable Funding Act; entire bill S. 21 Cybersecurity and American Cyber Competitiveness Act of 2013; provisions relating to the financial services sector S. 1369 A bill to provide additional flexibility to the Board of Governors of the Federal Reserve System to establish capital standards that are properly tailored to the unique characteristics of the business of insurance, and for other purposes; entire bill S. 1927 Data Security Act of 2014; entire bill S. 2270 - Insurance Capital Standards Clarification Act of 2014; entire bill S. 2588 - Cybersecurity Information Sharing Act of 2014; provisions relating to safe harbor for information sharing for prevention of cybersecurity threats Need for greater transparency in the development of SIFI designation criteria and preparation of underlying government studies and data Congressional support for the SEC moving forward on implementing Section 913 of Dodd-Frank, other options for investor protection parity, and potential interplay with possible DOL regulatory activity

Issues related to Dodd-Frank Wall Street Reform and Consumer Protection Act (Public Law 111-203) implementation and regulations, including SIFI rules and designation, systemic risk, orderly liquidation authority and derivatives Issues related to systemic risk regulation of non-bank financial institutions Issues related to portfolio management of exchange-traded funds (ETFs), including transparency and custom baskets Issues related to swap execution facility trading and reporting Issues related to definition of major swap participants Issues related to enhancements to margin protection rules for swap participants and effect of bankruptcy of a futures clearing merchant or clearinghouse on derivatives trading Issues related to nature of collateral for cleared swaps Issues related to margin for uncleared swaps, including cash-only margin Issues related to capital requirements for cleared and uncleared swaps Issues related to transaction recording obligation under the CFTCs SEF rules Issues related to derivatives trading reforms including cross border provisions, FX settling, and commodity pool operator registration requirements Issues related to market structure matters (computerized trading, trade-at, high frequency trading, market data feeds, Regulation NMS and the maker-taker model) Issues related to effect of the Volcker rule on fixed income markets, equity markets, and mutual fund shareholders Issues related to the Financial Stability Oversight Council (FSOC) and mutual funds, including H.R. 5180 (Financial Stability Oversight Council Improvement Act of 2014) Issues related to the Financial Stability Board (FSB) and mutual funds Issues related to the Office of Financial Research study of asset managers and its potential impact on mutual funds Issues related to legislation and regulations affecting mutual funds and the mutual fund industry Issues related to mortgage-backed securities, housing finance reform, and Government Sponsored Enterprise reform Proposals related to potential money market fund regulations (e.g. floating net asset value, capital requirements, redemption hold-back, liquidity gates and fees, treatment of municipal money market funds) Issues related to the overnight reverse repurchase agreement proposal Issues related to market activities and effects upon Treasury inflation protected securities Issues related to the SECs enhanced fund reporting initiative Issues related to the structure and offering of annuities H.R. 2374 (Retail Investor Protection Act) for regulatory coordination between the DOL and the SEC Issues surrounding the fiscal situation with Puerto Rico and its impact on the municipal bonds market Issues related to disclosure of municipal bond transaction expenses Issues related to a pilot program for expanded tick sizes for small capitalization stocks, including H.R. 1952 (Spread Pricing Liquidity Act of 2013) and H.R. 3448 (Small Cap Liquidity Reform Act of 2013) Issues related to the regulation of the asset management industry

Financial Regulatory Reform Federal Reserve Supervision of Savings and Loan Holding Companies Federal Reserve Board's Rules to Implement Basel III Regulatory Capital ReformsDodd-Frank Wall Street Reform and Consumer Protection Act in regards to: Systemic Risk Designation Capital Requirements for the Savings & Loan Holding Company and Federal Reserve Oversight as in the following bills: HR4510/S2270 - Insurance Capital Standards Clarification Act of 2014 MMF Reform SEC Fiduciary Project (DFA Sec. 913) Terrorism Risk Insurance Extension as in the following bill: HR508 - Terrorism Risk Insurance Act of 2002 Reauthorization Act of 2013 HR4871 - TRIA Reform Act of 2014 GSE Reform Asset Manager SIFI Designation as in the following bill: HR5180 - Financial Stability Oversight Council Improvement Act of 2014 Death Master File Equity Market Structure

Client expense: $500,000 · Firm income: Not reported

S. 1927 - Data Security Act of 2014 (Carper) H.R. 3448 - Small Cap Liquidity Reform Act of 2013 (Duffy) H.R. 4387 - FSOC Transparency and Accountability Act (Garrett) H.R. 4881 - One Year Moratorium on Authority of FSOC to make SIFI Determinations (Neugebauer)H.R. 5037 - Office of Financial Research Accountability Act of 2014 (Royce) H.R. 5180 - Financial Stability Oversight Council Improvement Act of 2014 (Ross) Money Market Mutual Funds FSOC Review of Asset Management Sector for Potential SIFI Designations CFTC Rule 4.5 Volcker Rule Exchange-Traded Funds Structure of the U.S. Securities Markets Uniform Fiduciary Standard for Broker-Dealers and Investment Advisers Investment Company Act of 1940

Client expense: $1,502,069 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office

Issues related to the regulation of money market mutual funds. Issues relating to the modification of Rule 4.5 under the Commodity Exchange Act H.R. 4413, CFTC Reauthorization H.R. 5180, the Financial Stability Oversight Council Improvement Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

See addendum.S. 215, the Federal Reserve Single Mandate Act of 2013 (all provisions) S. 450, the Financial Regulatory Responsibility Act of 2013 (all provisions) H.R. 1062, the SEC Regulatory Accountability Act (all provisions) H.R. 2446, the Responsible Consumer Financial Protection Regulations Act of 2013 H.R. 3193, the Consumer Financial Protection Safety and Soundness Improvement Act of 2013 H.R. 3928, Federal Reserve Accountability and Transparency Act of 2014 H.R. 3913, to amend the Bank Holding Company Act of 1956 to require agencies to make considerations relating to the promotion of efficiency, competition, and capital formation before issuing or modifying certain regulations. H.R. 4387, FSOC Transparency and Accountability Act H.R. 4383, Bureau of Consumer Financial Protection Small Business Advisory Board Act H.R. 4262, Bureau Advisory Commission Transparency Act H.R. 4539, Bureau Research Transparency Act H.R. 4684, Bureau Guidance Transparency Act H.R. 5018, Federal Reserve Accountability and Transparency Act of 2014 H.R. 5037, the Office of Financial Research Accountability Act of 2014 H.R. 5180, Financial Stability Oversight Council Improvement Act of 2014 H.R. 5188, to amend the Consumer Financial Protection Act of 2010 to require the CFPB to develop a model form for a disclosure notice for depository institutions and credit unions. S. 2696, a bill to require the Federal Reserve to make certain changes to the small bank holding company policy statement on assessment of financial and managerial factors. S. 2732, CFPB Examination and Reporting Threshold Act of 2014

Client expense: $2,560,000 · Firm income: Not reported