Financial Institution Bankruptcy Act of 2014

Issues related to systemically significant institutions, including taxation of certain banking institutions included in tax reform draft H.R. 5421 - Financial Institution Bankruptcy Act of 2014 S.1898 - Truth in Settlements Act of 2014

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

Government targets: HOUSE OF REPRESENTATIVES

S. 1861; S. 474; H.R. 634, 677, 992, 1062, 1003, 1256, 1341; S.798, 1282, 985, 1369; H.R. 129, 2374; H. R. 391; H.R. 4167; H.R. 3623; S. 2124; H.R. 4413; H.R. 5016, 4800 (implementation of and potential modification of the Dodd-Frank Act only); H.R. 5421; H.R. 5461; H.R. 5405 - Discussed implementation of the Basel capital accord, including the Liquidity Coverage Ratio (LCR). Discussed commodities issues; CFTC re-authorization; SEC and equity market structure reform; rulemakings on the fiduciary standard for broker-dealers and investment advisers; proposals related to bank structure, capital requirements, capital formation and market structure; discussed issues related to financial institution bankruptcy reform.

Client expense: $1,520,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, U.S. Trade Representative (USTR)

Meetings and calls with Members and staff of House and Senate Committees and agency officials concerning possible legislation and regulatory measures and Congressional studies affecting hedge funds and other alternative investments.H.R.5421 - Financial Institution Bankruptcy Act of 2014 - To amend title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy.

Client expense: $880,000 · Firm income: Not reported

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

H.R. 4060: Systemic Risk Designation Improvement Act of 2014: A bill to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision; Provisions related to bank regulation. S. 1720: Patent Transparency and Improvements Act of 2013: A bill to promote transparency in patent ownership and make other improvements to the patent system and for other purposes; Provisions related to patent reform. S. 1897: Personal Data Privacy and Security Act of 2014: A bill to prevent and mitigate identity theft, to ensure privacy, to provide notice of security breaches, and to enhance criminal penalties, law enforcement assistance, and other protections against security breaches, fraudulent access, and uses of personally identifiable information; Provisions related to cyber security/data breach. S. 1927: Data Security Act of 2014: A bill to protect information relating to consumers, to require notice of security breaches, and for other purposes; Provisions related to cyber security/data breach. S. 1976: Data Security and Breach Notification Act of 2014: A bill to protect consumers by requiring reasonable security policies and procedures to protect data containing personal information, and to provide for nationwide notice in the event of a breach of security; Provisions related to cyber security/data breach. H.R. 3036: A bill to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision; Provisions related to SIFI Designation. S. 21: Cybersecurity and American Cyber Competitiveness Act of 2013: A bill to secure the United States against cyber-attack, to improve communication and collaboration between the private sector and the Federal Government, to enhance American competitiveness and create jobs in the information technology industry, and to protect the identities and sensitive information of American citizens and businesses; Provisions related to cyber security. S. 474: Swaps Regulatory Improvement Act: A bill to amend provisions in section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to Federal assistance for swaps entities; Provisions related to derivatives regulation. S. 1353: Cybersecurity Act of 2013: To provide for an ongoing, voluntary public-private partnership to improve cybersecurity and to strengthen cybersecurity research and development, workforce development and education, and public awareness and preparedness, and for other purposes; Provisions related to cyber security. S. 1612: Patent Litigation Integrity Act of 2013: To deter abusive patent litigation by targeting the economic incentives that fuel frivolous lawsuits; Provisions related to patent reform. H.R. 992: Swaps Regulatory Improvement Act: A bill to amend provisions in section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to Federal assistance for swaps entities; Provisions related to derivatives regulation. H.R. 4986: End Operation Choke Point Act of 2014: A bill to amend certain banking statutes in response to Operation Choke Point; Provisions related to payments regulation. H.R. 3309: To amend Title 35, United States Code, and the Leahy-Smith America Invents Act to make improvements and technical corrections, and for other purposes; Provisions related to patent reform. H.R. 4532: To amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision; Provisions related to bank regulation. H.R. 5421: A bill to amend Title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy; Provisions related to bank resolution. H.R. 83: Making consolidated appropriations for the fiscal year ending September 30, 2015; Provisions related to derivatives regulation. H.R. 3928: A bill to improve the accountability and transparency of the Board of Governors of the Federal Reserve System; Provisions related to bank regulation. H.R. 5758: A bill to provide requirements for the appropriate Federal banking agencies when requesting or ordering a depository institution to terminate a specific customer account, to provide for additional requirements related to subpoenas issued under the Financial Institutions Reform, Recovery, and Enforcement Act of 1989; Provisions related to bank regulation. S. 2049: A bill to curb unfair and deceptive practices during assertion of patents; Provisions related to patent reform. S. 2588: An original bill to improve cybersecurity in the United States through enhanced sharing of information about cybersecurity threats, and for other purposes; Provisions related to cybersecurity. S. 1995: A bill to protect consumers by mitigating the vulnerability of personally identifiable information to theft through a security breach, providing notice and remedies to consumers in the wake of such a breach, holding companies accountable for preventable breaches, facilitating the sharing of post-breach technical information between companies, and enhancing criminal and civil penalties and other protections against the unauthorized collection or use of personally identifiable information; Provisions related to cybersecurity/data breach. - Issues related to the implementation of Title I of Dodd-Frank; Provisions related to bank resolution. - Issues related to the implementation of Title II of Dodd-Frank; Provisions related to bank resolution.

Client expense: $370,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.2588, Cyber Information Sharing Act of 2014, issues related to cybersecurity; HR614, American Discoveries and American Jobs Commission Act, issues related to cybersecurity; S1353, Cybersecurity Enhancement Act of 2014, issues related to cybersecurity; S2521, Federal Information Security Modernization Act, issues related to cybersecurity; S2519, National Cybersecurity Protection Act of 2014, issues related to cybersecurity; HR992, S474, Swaps Regulatory Improvement Act, issues related to derivatives; HR5016, Financial Services and General Government Appropriations Act, issues related to derivatives; HR5421, Financial Institution Bankruptcy Act of 2014, issues regarding Chapter 14 bankruptcy; HR3711, S1282, 21st Century Glass-Steagall Act of 2013, issues related to Glass-Steagall; HR624, Cyber Intelligence Sharing and Protection Act, issues regarding cyber security; S798, Terminating Bailouts for Taxpayer Fairness Act of 2013, issues regarding bank capital; General issues regarding data security; General issues related to privacy; General issues related to interchange; General issues related to Dodd-Frank Act.

Client expense: $1,200,000 · Firm income: Not reported

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

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of 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. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014 and S.1861: The Taxpayer Protection and Responsible Resolution Act. The Forum supports 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.

Client expense: $370,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

S. 1861, the Taxpayer Protection and Responsible Resolution Act (all provisions regarding repeal of the Dodd-Frank Acts orderly liquidation authority) H.R 5421, Financial Institution Bankruptcy Act of 2014

Client expense: $2,418,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

H.R. 5305 - Puerto Rico Chapter 9 Uniformity Act of 2014 (Pierluisi) H.R. 5421 - Financial Institution Bankruptcy Act of 2014 (Bachus)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Dodd-Frank Act implementation issues; Capital issues; S. 798, Terminating Bailouts for Taxpayer Fairness Act of 2013, all provisions; S. 1282, 21st Century Glass-Steagall Act of 2013; S. 114, Fairness for Struggling Students Act of 2013, Issues pertaining to Volcker Rule treatment of Collateralized Loan Obligations (CLOs) including HR 4167, the Restoring Proven Financing of American Employees Act; H.R. 4558 and S 2381, Flood Insurance Market Parity and Modernization Act, all provisions; Issues pertaining to reauthorization of the US Export Import Bank; S. 2244, Terrorism Risk Insurance Program Reauthorization Act; H.R. 4871, TRIA Reform; Issues relating to Department of Education rulemaking concerning campus card products; S. 1861, TheTaxpayer Protection and Responsible Resolution Act H.R. 5421, Financial Institution Bankruptcy Act of 2014; H.R. 5461, legislation combining Dodd Frank Act clarifications including Volcker CLO reforms, derivatives end user reforms, QM points/fee changes, insurance capital reforms; S. 2588, Cybersecurity Information Sharing Act of 2014, all provisions.

Client expense: $1,650,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), HOUSE OF REPRESENTATIVES, Risk Management Agency, SENATE, Treasury, Dept of

H.R. 5421 Financial Institution Bankruptcy Act of 2014

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 4060, Systemic Risk Designation Improvement Act of 2014 (all provisions). HR 992, Swaps Regulatory Improvement Act (all provisions). HR 5405, Promoting Job Creation and Reducing Small Business Burdens Act (all provisions). HR 5016, Financial Services and General Government Appropriations Act, 2015 (all provisions). HR 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 (all provisions). HR 5421, Financial Institution Bankruptcy Act of 2014 (all provisions). HR 83, Consolidated and Further Continuing Appropriations Act, 2015 (provisions related to swaps push-out and banking). Draft legislation that amends the Financial Stability Act of 2010 to specify when bank holding companies may be subject to certain enhanced supervision and prudential standards, and for other purposes (no specific bill). General discussions related to employment and re-employment programs (NextJob program), unemployment insurance and covering a draft proposal (Unemployment Insurance Jumpstart Program) (no specific bill). Issues related to bank fees, card fees and rate caps, and credit card interchange and debit card interchange (Senator Durbin amendment, electronic debit card transactions) (no specific bill). General discussions and issues related to policy development, legislative and regulatory implementation, process, systems and structures, general discussions and issues related to product new development, Volcker rule, CCAR and capital planning, resolution planning and stress test, living wills, bank liquidity (LCR), CLO, end user margins, point/fees and Basel, SIFI designation, corporate governance and general banking matters (no specific bill). H.R. 4173 (111th Congress, P.L. 111-203): Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act); regulatory implementation discussions covering rules and regulations, including discussions with the Consumer Financial Protection Bureau (for which there is no CFPB listing on Line 17 available), on structure, regulatory implementation, oversight, process, enforcement and compliant handling. General discussions covering the Dodd-Frank Act and provisions (Act repeal, amending and technical fixes), Volcker rule, Financial Stability Oversight Council, Office of Financial Research, systemically important financial institutions designations, prudential regulations, mortgage regulations (qualified mortgages, qualified residential mortgages), corporate governance, enhanced prudential standards (165/166), stress testing, capital planning, living will, remittance, 716, push-out, Title VII (swaps/derivatives), Title II, section 1071, overdraft, pre-paid cards, examinations and other banking and financial services related provisions. Issues related to cyber-security, data breach and privacy, protecting consumer information, general discussions (no specific bill).

Client expense: $200,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE

Public Law 111-203, H.R. 4173 - Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Implementation and Regulatory reform. Captive Reinsurance Transactions and Global Capital Standards. Roles of federal and state agencies at the International Association of Insurance Supervisors and the Financial Stability Board. H.AMDT.64 to H.R. 1062, Amendment expresses the sense of Congress that rules adopted by the Public Company Accounting Oversight Board (PCAOB) comply with the same standards required of the SEC. It also requires the SEC to ensure that any rules adopted by the Municipal Securities Rulemaking Board (MSRB), and other national securities associations comply with the standards set forth in the bill. Issue: FINRA, Securities Rulemaking Draft H.AMDT to HR 2610, Transportation, Housing & Urban Development Appropriations, to prohibit federal guarantees for mortgages seized through eminent domain. Issue: Mortgage Investments. H.R._____, Draft legislation on the development of global insurance standards. Issue: global insurance standards. H.Res.735 - Expressing the sense of the House of Representatives that recently proposed measures that will reduce transparency and public participation at the International Association of Insurance Supervisors (IAIS) should be disapproved by United States representatives to the IAIS. Issue: global insurance standards. H.R. 749 - Eliminate Privacy Notice Confusion Act. This bill amends the Gramm-Leach-Bliley Act to exempt from its annual privacy policy notice requirement any financial institution which: (1) provides nonpublic personal information only in accordance with specified requirements, and (2) has not changed its policies and practices with regard to disclosing nonpublic personal information from those disclosed in the most recent disclosure sent to consumers. Issue: privacy H.R. 1062, SEC Regulatory Accountability Act. Issue: SEC Rulemaking, Cost-Benefit Analysis, Derivatives H.R. 2140, the Insurance Capital and Accounting Standards Act of 2013. Amends the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) and the Home Owners' Loan Act to make minimum leverage and risk-based capital requirements governing insurance companies under the state law also apply to insurance companies that are either depository holding companies or subsidiaries of depository holding companies. Issue: Capital Standards, Basel III H.R. 2374, the Retail Investor Protection Act. To amend the Securities Exchange Act of 1934 to provide protections for retail customers, and for other purposes. Issue: Fiduciary Duties H.R 2547, the Determination of Appropriate Risk-Based Capital Requirements for Community Financial Institutions Act of 2013. To determine appropriate risk based capital requirements for community, mid-size, and regional institutions. Issue: Capital Standards for Community Banks H.R. 2733, Defending American Taxpayers From Abusive Government Takings Act of 2013 to prohibit Fannie Mae and Freddie Mac from purchasing, the FHA from insuring, and the Department of Agriculture from guaranteeing, making, or insuring, a mortgage that is secured by a residence or residential structure located in a county in which the State has used the power of eminent domain to take a residential mortgage. Issue: Mortgage Investments H.R. 2767, the Protect American Taxpayers & Homeowners (PATH) Act. Issue: Mortgage Investments and Government Sponsored Enterprises/Federal Home Loan Banks H.R. 4510 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III H.R. 4557 - Policyholder Protection Act of 2014. To amend the Federal Deposit Insurance Act to provide for notice to, and input by, State insurance commissioners when requiring an insurance company to serve as a source of financial strength pursuant to such Act. Issue: Source of strength Provision in H.R. 4745, Transportation, Housing & Urban Development Appropriations, to prohibit federal guarantees for mortgages seized through eminent domain. Issue: Mortgage Investments. 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. Issue: Global insurance standards. H.R. 5016 - Financial Services and General Government Appropriations Act, 2015. Making appropriations for financial services and general government for the fiscal year ending September 30, 2015, and for other purposes. Issue: Global insurance standards H.R. 5018 - Federal Reserve Accountability and Transparency Act of 2014. This bill amends the Federal Reserve Act to establish requirements for policy rules and blackout periods of the Federal Open Market Committee, to establish requirements for certain activities of the Board of Governors of the Federal Reserve System. Issue: global insurance standards. H.R. 5421 - Financial Institution Bankruptcy Act of 2014. To amend title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy. Issue: early termination rights. S.Res. 561 - A resolution expressing the sense of the Senate that recently proposed measures that will reduce transparency and public participation at the International Association of Insurance Supervisors (IAIS) should be disapproved by United States representatives to the IAIS. Issue: global insurance standards. S. 635 - Privacy Notice Modernization Act of 2013. This bill amends the Gramm-Leach-Bliley Act to exempt from its annual written privacy policy notice requirement any financial institution which: (1) provides nonpublic personal information only in accordance with specified requirements, (2) has not changed its policies and practices with respect to disclosing nonpublic personal information from those disclosed in the most recent disclosure sent to consumers, and (3) otherwise provides customers access to such most recent disclosure in electronic or other form permitted by specified regulations. Issue: privacy S. 731, the Basel III CASE Act. Directs the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency, before issuing any final rule in relation to proposals they have issued for the International Basel III agreement on general risk-based capital requirements, to conduct an empirical study that includes: (1) a quantitative analysis of the rule's impact on the U.S. financial services sector, specifically community, mid-size, and regional financial institutions; and (2) a determination of the long-term impact of the rule, including changes to the current risk weight framework. Issue: Capital Standards for Community Banks S. 798, TBTF Act. Requires federal banking agencies to establish capital requirements for the ratio of equity capital to total consolidated assets for all financial institutions. Issue: Capital Standards S. 1217- Housing Finance Reform and Taxpayer Protection Act of 2013. Authorizes the Federal Mortgage Insurance Corporation to provide insurance to any covered security regardless of whether it has satisfied credit-risk sharing requirements if unusual and exigent circumstances have created an anomalous lack of mortgage credit availability. Issue: Government Sponsored Enterprises. Senate ADMT to S. 1217-Housing Finance Reform and Taxpayer Protection Act of 2014. To provide for prohibitions relating to the use of the power of eminent domain. Issue: Mortgage Investments 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. Issue: Capital Standards S. 2102, a bill to clarify the application of certain leverage and risk based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Capital Standards. S. 2270 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III Draft Senate bill on Financial Services and General Government Appropriations Act, 2015. Making appropriations for financial services and general government for the fiscal year ending September 30, 2015, and for other purposes. Issue: Global insurance standards Margin and capital requirements for covered swap entities proposed rule. Issue: eligible collateral. No bill number assigned. Issue: Federal Housing Finance Agency proposed rule on federal home loan bank membership. No bill number assigned. Issue: Holocaust era insurance policy claims. No bill number assigned. Issue: Covered agreements on prudential measurers with respect to the business of insurance and reinsurance. No bill number assigned. Tracking: H.R. 634, the Business Risk Mitigation and Price Stabilization Act of 2013. Issue: Derivatives, DFA Title VII

Client expense: $1,440,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General issues surrounding Commodities Exchange Act reauthorization General issues surrounding insolvency H.R. 5421 Financial Institution Bankruptcy Act of 2014

Client expense: $4,340,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Intl Trade Administration (ITA), Patent & Trademark Office (PTO), SENATE, U.S. Trade Representative (USTR)

H.R.5421 Financial Institution Bankruptcy Act of 2014; Entire Bill

Client expense: $4,340,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Intl Trade Administration (ITA), Patent & Trademark Office (PTO), SENATE, U.S. Trade Representative (USTR)

Public Law 111-203, H.R. 4173 - Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Implementation and Regulatory reform. Captive Reinsurance Transactions and Global Capital Standards. Roles of federal and state agencies at the International Association of Insurance Supervisors and the Financial Stability Board. H.R. 2140, the Insurance Capital and Accounting Standards Act of 2013. Amends the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) and the Home Owners' Loan Act to make minimum leverage and risk-based capital requirements governing insurance companies under the state law also apply to insurance companies that are either depository holding companies or subsidiaries of depository holding companies. Issue: Capital Standards, Basel III H.R. 1062, SEC Regulatory Accountability Act. Issue: SEC Rulemaking, Cost-Benefit Analysis, Derivatives H.AMDT.64 to H.R. 1062, Amendment expresses the sense of Congress that rules adopted by the Public Company Accounting Oversight Board (PCAOB) comply with the same standards required of the SEC. It also requires the SEC to ensure that any rules adopted by the Municipal Securities Rulemaking Board (MSRB), and other national securities associations comply with the standards set forth in the bill. Issue: FINRA, Securities Rulemaking H.R. 1564, the Audit Integrity and Job Protection Act. Amends the Sarbanes-Oxley Act of 2002 (SOX) to deny the Public Company Accounting Oversight Board any authority to require that audits conducted for a particular issuer of securities in accordance with SOX standards be conducted by specific auditors, or that such audits be conducted for an issuer by different auditors on a rotating basis. Issue: Mandatory Auditor Rotation H.R. 2374, the Retail Investor Protection Act. To amend the Securities Exchange Act of 1934 to provide protections for retail customers, and for other purposes. Issue: Fiduciary Duties S. 731, the Basel III CASE Act. Directs the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency, before issuing any final rule in relation to proposals they have issued for the International Basel III agreement on general risk-based capital requirements, to conduct an empirical study that includes: (1) a quantitative analysis of the rule's impact on the U.S. financial services sector, specifically community, mid-size, and regional financial institutions; and (2) a determination of the long-term impact of the rule, including changes to the current risk weight framework. Issue: Capital Standards for Community Banks H.R 2547, the Determination of Appropriate Risk-Based Capital Requirements for Community Financial Institutions Act of 2013. To determine appropriate risk based capital requirements for community, mid-size, and regional institutions. Issue: Capital Standards for Community Banks S. 798, TBTF Act. Requires federal banking agencies to establish capital requirements for the ratio of equity capital to total consolidated assets for all financial institutions. Issue: Capital Standards 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. Issue: Capital Standards S. 1526, The Audit Integrity and Job Protection Act, to prevent the Public Company Accounting Oversight Board (PCAOB) from requiring public companies to use a specific auditor or to change auditors on a rotating basis. Issue: Mandatory Auditor Rotation H.R. 2733, Defending American Taxpayers From Abusive Government Takings Act of 2013 to prohibit Fannie Mae and Freddie Mac from purchasing, the FHA from insuring, and the Department of Agriculture from guaranteeing, making, or insuring, a mortgage that is secured by a residence or residential structure located in a county in which the State has used the power of eminent domain to take a residential mortgage. Issue: Mortgage Investments H.R. 2767, the Protect American Taxpayers & Homeowners (PATH) Act. Issue: Mortgage Investments and Government Sponsored Enterprises/Federal Home Loan Banks Draft H.AMDT to HR 2610, Transportation, Housing & Urban Development Appropriations, to prohibit federal guarantees for mortgages seized through eminent domain. Issue: Mortgage Investments. Provision in H.R. 4745, Transportation, Housing & Urban Development Appropriations, to prohibit federal guarantees for mortgages seized through eminent domain. Issue: Mortgage Investments. S. 2102, a bill to clarify the application of certain leverage and risk based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Capital Standards. H.R. 4510 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III S. 2270 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III H.R. 5016 - Financial Services and General Government Appropriations Act, 2015. Making appropriations for financial services and general government for the fiscal year ending September 30, 2015, and for other purposes. Issue: Global insurance standards Draft Senate bill on Financial Services and General Government Appropriations Act, 2015. Making appropriations for financial services and general government for the fiscal year ending September 30, 2015, and for other purposes. Issue: Global insurance standards H.R. 4557 - Policyholder Protection Act of 2014. To amend the Federal Deposit Insurance Act to provide for notice to, and input by, State insurance commissioners when requiring an insurance company to serve as a source of financial strength pursuant to such Act. Issue: Source of strength S. 1217- Housing Finance Reform and Taxpayer Protection Act of 2013. Authorizes the Federal Mortgage Insurance Corporation to provide insurance to any covered security regardless of whether it has satisfied credit-risk sharing requirements if unusual and exigent circumstances have created an anomalous lack of mortgage credit availability. Issue: Government Sponsored Enterprises. Senate ADMT to S. 1217-Housing Finance Reform and Taxpayer Protection Act of 2014. To provide for prohibitions relating to the use of the power of eminent domain. Issue: Mortgage Investments 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. Issue: Global insurance standards. H.R. 749 - Eliminate Privacy Notice Confusion Act. This bill amends the Gramm-Leach-Bliley Act to exempt from its annual privacy policy notice requirement any financial institution which: (1) provides nonpublic personal information only in accordance with specified requirements, and (2) has not changed its policies and practices with regard to disclosing nonpublic personal information from those disclosed in the most recent disclosure sent to consumers. Issue: privacy S. 635 - Privacy Notice Modernization Act of 2013. This bill amends the Gramm-Leach-Bliley Act to exempt from its annual written privacy policy notice requirement any financial institution which: (1) provides nonpublic personal information only in accordance with specified requirements, (2) has not changed its policies and practices with respect to disclosing nonpublic personal information from those disclosed in the most recent disclosure sent to consumers, and (3) otherwise provides customers access to such most recent disclosure in electronic or other form permitted by specified regulations. Issue: privacy H.R. 5018 - Federal Reserve Accountability and Transparency Act of 2014. This bill amends the Federal Reserve Act to establish requirements for policy rules and blackout periods of the Federal Open Market Committee, to establish requirements for certain activities of the Board of Governors of the Federal Reserve System. Issue: global insurance standards. H.Res.735 - Expressing the sense of the House of Representatives that recently proposed measures that will reduce transparency and public participation at the International Association of Insurance Supervisors (IAIS) should be disapproved by United States representatives to the IAIS. Issue: global insurance standards. S.Res. 561 - A resolution expressing the sense of the Senate that recently proposed measures that will reduce transparency and public participation at the International Association of Insurance Supervisors (IAIS) should be disapproved by United States representatives to the IAIS. Issue: global insurance standards. H.R._____, Draft legislation on the development of global insurance standards. Issue: global insurance standards. H.R. 5421 - Financial Institution Bankruptcy Act of 2014. To amend title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy. Is

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

FIN - Third Quarter Report - 2014 Public Law 111-203, H.R. 4173 - Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Implementation and Regulatory reform. Captive Reinsurance Transactions and Global Capital Standards. Roles of federal and state agencies at the International Association of Insurance Supervisors and the Financial Stability Board. H.R. 749 - Eliminate Privacy Notice Confusion Act. This bill amends the Gramm-Leach-Bliley Act to exempt from its annual privacy policy notice requirement any financial institution which: (1) provides nonpublic personal information only in accordance with specified requirements, and (2) has not changed its policies and practices with regard to disclosing nonpublic personal information from those disclosed in the most recent disclosure sent to consumers. Issue: privacy H.R. 1062, SEC Regulatory Accountability Act. Issue: SEC Rulemaking, Cost-Benefit Analysis, Derivatives H.AMDT.64 to H.R. 1062, Amendment expresses the sense of Congress that rules adopted by the Public Company Accounting Oversight Board (PCAOB) comply with the same standards required of the SEC. It also requires the SEC to ensure that any rules adopted by the Municipal Securities Rulemaking Board (MSRB), and other national securities associations comply with the standards set forth in the bill. Issue: FINRA, Securities Rulemaking H.R. 1564, the Audit Integrity and Job Protection Act. Amends the Sarbanes-Oxley Act of 2002 (SOX) to deny the Public Company Accounting Oversight Board any authority to require that audits conducted for a particular issuer of securities in accordance with SOX standards be conducted by specific auditors, or that such audits be conducted for an issuer by different auditors on a rotating basis. Issue: Mandatory Auditor Rotation H.R. 2140, the Insurance Capital and Accounting Standards Act of 2013. Amends the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) and the Home Owners' Loan Act to make minimum leverage and risk-based capital requirements governing insurance companies under the state law also apply to insurance companies that are either depository holding companies or subsidiaries of depository holding companies. Issue: Capital Standards, Basel III H.R. 2374, the Retail Investor Protection Act. To amend the Securities Exchange Act of 1934 to provide protections for retail customers, and for other purposes. Issue: Fiduciary Duties H.R. 2547, the Determination of Appropriate Risk-Based Capital Requirements for Community Financial Institutions Act of 2013. To determine appropriate risk based capital requirements for community, mid-size, and regional institutions. Issue: Capital Standards for Community Banks H.R. 2733, Defending American Taxpayers From Abusive Government Takings Act of 2013 to prohibit Fannie Mae and Freddie Mac from purchasing, the FHA from insuring, and the Department of Agriculture from guaranteeing, making, or insuring, a mortgage that is secured by a residence or residential structure located in a county in which the State has used the power of eminent domain to take a residential mortgage. Issue: Mortgage Investments H.R. 2767, the Protect American Taxpayers & Homeowners (PATH) Act. Issue: Mortgage Investments and Government Sponsored Enterprises/Federal Home Loan Banks H.R. 4510 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III H.R. 4557 - Policyholder Protection Act of 2014. To amend the Federal Deposit Insurance Act to provide for notice to, and input by, State insurance commissioners when requiring an insurance company to serve as a source of financial strength pursuant to such Act. Issue: Source of strength Provision in H.R. 4745, Transportation, Housing & Urban Development Appropriations, to prohibit federal guarantees for mortgages seized through eminent domain. Issue: Mortgage Investments. 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. Issue: Global insurance standards. H.R. 5016 - Financial Services and General Government Appropriations Act, 2015. Making appropriations for financial services and general government for the fiscal year ending September 30, 2015, and for other purposes. Issue: Global insurance standards H.R. 5018 - Federal Reserve Accountability and Transparency Act of 2014. This bill amends the Federal Reserve Act to establish requirements for policy rules and blackout periods of the Federal Open Market Committee, to establish requirements for certain activities of the Board of Governors of the Federal Reserve System. Issue: global insurance standards. H.R. 5421 - Financial Institution Bankruptcy Act of 2014. To amend title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy. Issue: early termination rights. Draft H.AMDT to HR 2610, Transportation, Housing & Urban Development Appropriations, to prohibit federal guarantees for mortgages seized through eminent domain. Issue: Mortgage Investments. H.Res.735 - Expressing the sense of the House of Representatives that recently proposed measures that will reduce transparency and public participation at the International Association of Insurance Supervisors (IAIS) should be disapproved by United States representatives to the IAIS. Issue: global insurance standards. H.R._____, Draft legislation on the development of global insurance standards. Issue: global insurance standards. S. 635 - Privacy Notice Modernization Act of 2013. This bill amends the Gramm-Leach-Bliley Act to exempt from its annual written privacy policy notice requirement any financial institution which: (1) provides nonpublic personal information only in accordance with specified requirements, (2) has not changed its policies and practices with respect to disclosing nonpublic personal information from those disclosed in the most recent disclosure sent to consumers, and (3) otherwise provides customers access to such most recent disclosure in electronic or other form permitted by specified regulations. Issue: privacy S. 731, the Basel III CASE Act. Directs the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency, before issuing any final rule in relation to proposals they have issued for the International Basel III agreement on general risk-based capital requirements, to conduct an empirical study that includes: (1) a quantitative analysis of the rule's impact on the U.S. financial services sector, specifically community, mid-size, and regional financial institutions; and (2) a determination of the long-term impact of the rule, including changes to the current risk weight framework. Issue: Capital Standards for Community Banks S. 798, TBTF Act. Requires federal banking agencies to establish capital requirements for the ratio of equity capital to total consolidated assets for all financial institutions. Issue: Capital Standards S. 1217- Housing Finance Reform and Taxpayer Protection Act of 2013. Authorizes the Federal Mortgage Insurance Corporation to provide insurance to any covered security regardless of whether it has satisfied credit-risk sharing requirements if unusual and exigent circumstances have created an anomalous lack of mortgage credit availability. Issue: Government Sponsored Enterprises. Senate ADMT to S. 1217-Housing Finance Reform and Taxpayer Protection Act of 2014. To provide for prohibitions relating to the use of the power of eminent domain. Issue: Mortgage Investments 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. Issue: Capital Standards S. 2102, a bill to clarify the application of certain leverage and risk based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Capital Standards. S. 2270 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III Draft Senate bill on Financial Services and General Government Appropriations Act, 2015. Making appropriations for financial services and general government for the fiscal year ending September 30, 2015, and for other purposes. Issue: Global insurance standards S.Res. 561 - A resolution expressing the sense of the Senate that recently proposed measures that will reduce transparency and public participation at the International Association of Insurance Supervisors (IAIS) should be disapproved by United States representatives to the IAIS. Issue: global insurance standards. Margin and capital requirements for covered swap entities proposed rule. Issue: eligible collateral. No bill number assigned.

Client expense: $1,690,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 4060: Systemic Risk Designation Improvement Act of 2014: A bill to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision; Provisions related to bank regulation. S. 1720: Patent Transparency and Improvements Act of 2013: A bill to promote transparency in patent ownership and make other improvements to the patent system and for other purposes; Provisions related to patent reform. S. 1897: Personal Data Privacy and Security Act of 2014: A bill to prevent and mitigate identity theft, to ensure privacy, to provide notice of security breaches, and to enhance criminal penalties, law enforcement assistance, and other protections against security breaches, fraudulent access, and uses of personally identifiable information; Provisions related to cyber security/data breach. S. 1927: Data Security Act of 2014: A bill to protect information relating to consumers, to require notice of security breaches,and for other purposes; Provisions related to cyber security/data breach. S. 1976: Data Security and Breach Notification Act of 2014: A bill to protect consumers by requiring reasonable security policies and procedures to protect data containing personal information, and to provide for nationwide notice in the event of a breach of security; Provisions related to cyber security/data breach. H.R. 3036: A bill to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision; Provisions related to SIFI Designation. S. 21: Cybersecurity and American Cyber Competitiveness Act of 2013: A bill to secure the United States against cyber attack, to improve communication and collaboration between the private sector and the Federal Government, to enhance American competitiveness and create jobs in the information technology industry, and to protect the identities and sensitive information of American citizens and businesses; Provisions related to cyber security. S. 474: Swaps Regulatory Improvement Act: A bill to amend provisions in section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to Federal assistance for swaps entities; Provisons related to derivatives regulation. S. 1353: Cybersecurity Act of 2013: To provide for an ongoing, voluntary public-private partnership to improve cybersecurity,and to strengthen cybersecurity research and development, workforce development and education, and public awareness and preparedness, and for other purposes; Provisions related to cyber security. S. 1612: Patent Litigation Integrity Act of 2013: To deter abusive patent litigation by targeting the economic incentives that fuel frivolous lawsuits; Provisions related to patent reform. H.R. 992: Swaps Regulatory Improvement Act: A bill to amend provisions in section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to Federal assistance for swaps entities; Provisions related to derivatives regulation. H.R. 4986: End Operation Choke Point Act of 2014: A bill to amend certain banking statutes in response to Operation Choke Point; Provisions related to payments. H.R. 624: A bill to provide for the sharing of certain cyber threat intelligence and cyber threat information between the intelligence community and cyber security entities, and for other purposes; Provisions related to cybersecurity. H.R. 3309: To amend title 35, United States Code, and the Leahy-Smith America Invents Act to make improvements and technical corrections, and for other purposes; Provisions related to patent reform. H.R. 4532: To amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision; Provisions related to bank regulation. H.R. 5421: A bill to amend title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy; Provisions related to bank resolution. S. 798: A bill to address equity capital requirements for financial institutions, bank holding companies, subsidiaries, and affiliates, and for other purposes; Provisions related to bank regulation. S. 2588: An original bill to improve cybersecurity in the United States through enhanced sharing of information about cybersecurity threats, and for other purposes; Provisions related to cybersecurity. H.R. 5461: A bill to clarify the application of certain leverage and risk-basked 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 related to bank regulation. S. 1995: A bill to protect consumers by mitigating the vulnerability of personally identifiable information to theft through a security breach, providing notice and remedies to consumers in the wake of such a breach, holding companies accountable for preventable breaches, facilitating the sharing of post-breach technical information between companies, and enhancing criminal and civil penalties and other protections against the unauthorized collection or use of personally identifiable information; Provisions related to cybersecurity/data breach. - Issues related to the implementation of Title I of Dodd-Frank; Provisions related to bank resolution. - Issues related to the implementation of Title II of Dodd-Frank; Provisions related to bank resolution. - General AML / BSA compliance issues.

Client expense: $370,000 · Firm income: Not reported

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

Met with House and Senate on large bank issues Met with House and Senate on credit card issues Met with House and Senate staff on capital leverage matters Met with House and Senate staff on flood insurance issues Met with House and Senate issues related to data security and payments system integrity 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 - all provisions H.R.5421 - The Financial Institution Bankruptcy Act of 2014 - all provisions H.R.613 - Systemic Risk Mitigation Act - all provisions H.R.677 - Inter-Affiliate Swap Clarification Act - all provisions H.R.992 - Swaps Regulatory Improvement Act - all provisions H.R.1256 - Swap Jurisdiction Certainty Act - all provisions H.R.1341 - Financial Competitive Act of 2013 - all provisions H.R.2767 - Protecting American Taxpayer and Homeowners (PATH) Act of 2013 - all provisions H.R.3448 - the Small Cap Liquidity Reform Act of 2013 - all provisions H.R.4167 - the Restoring Proven Financing for American Employers Act - all provisions H.R.4413 - Customer Protection and End User Relief Act - all provisions S.169 - I-Squared Act of 2013 - all provisions S.296 - Uniting American Families Act of 2013 - all provisions S.474 - Swaps Regulatory Improvement Act - all provisions S.798 - Terminating Bailouts for Taxpayer Fairness Act - all provisions S.1217 - Housing Finance Reform Act - all provisions S.1282 - 21st Century Glass-Steagall Act of 2013 - all provisions

Client expense: $1,290,000 · Firm income: Not reported

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

Meetings and calls with Members and staff of House and Senate Committees and agency officials concerning possible legislation and regulatory measures and Congressional studies affecting hedge funds and other alternative investments.H.R.5421 - Financial Institution Bankruptcy Act of 2014 - To amend title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy.

Client expense: $910,000 · Firm income: Not reported

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

S. 1861; S. 474; H.R. 634, 677, 992, 1062, 1003, 1256, 1341; S.798, 1282, 985, 1369, H.R. 129, 2374; H. R. 391; H.R. 4167; H.R.3623; S. 2124; H.R. 4413; H.R. 5016, 4800 (implementation of and potential modification of the Dodd-Frank Act only); H.R. 5421; H.R. 5461; H.R. 5405 - Discussed implementation of the Basel capital accord, including the Liquidity Coverage Ratio (LCR). Discussed commodities issues; CFTC re-authorization; SEC and equity market structure reform; rulemakings on the fiduciary standard for broker-dealers and investment advisers; proposals related to bank structure, capital requirements, capital formation and market structure; discussed issues related to financial institution bankruptcy reform.

Client expense: $1,590,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, U.S. Trade Representative (USTR)

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the saftey and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investorsThe "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. The Forum is also of the view that any cost of funding advantage enjoyed by large diversified banking companies is not associated with an expectation on the part of market participants regarding future bailouts, but rather is due to the market-recognized benefits of institutional size, diversification of activities and income streams, and the stability and predictability of large institution earnings.Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of 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. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014.

Client expense: $375,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Dodd-Frank Act implementation issues; Capital issues; H.R. 613, Systemic Risk Mitigation Act, all provisions; S. 798, Terminating Bailouts for Taxpayer Fairness Act of 2013, all provisions; S. 1282, 21st Century Glass-Steagall Act of 2013, all provisions; S. 114, Fairness for Struggling Students Act of 2013, issues pertaining to Volcker Rule treatment of Collateralized Loan Obligations (CLOs) including HR 4167, the Restoring Proven Financing for American Employees Act; H.R. 4558 and S. 2381, Flood Insurance Market Parity and Modernization Act, all provisions; Issues pertaining to reauthorization of the US Export Import Bank; S. 2244, Terrorism Risk Insurance Program Reauthorization Act, all provisions; H.R. 4871, TRIA Reform, all provisions; Issues relating to Department of Education rulemaking concerning campus card products; S. 1861, The Taxpayer Protection and Responsible Resolution Act, all provisions; H.R. 5421, Financial Institution Bankruptcy Act of 2014, all provisions; H.R. 5461, Legislation combining Dodd Frank Act clarifications including Volcker CLO reforms, derivatives end user reforms, QM points/fee changes, insurance capital reforms, all provisions; S. 2588, Cybersecurity Information Sharing Act of 2014, all provisions.

Client expense: $1,580,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Risk Management Agency, SENATE, Treasury, Dept of

H.R. 5305 - Puerto Rico Chapter 9 Uniformity Act of 2014 (Pierluisi) H.R. 5421 - Financial Institution Bankruptcy Act of 2014 (Bachus)

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

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

H.R.5421 Financial Institution Bankruptcy Act of 2014; Entire Bill

Client expense: $4,030,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Intl Trade Administration (ITA), Patent & Trademark Office (PTO), SENATE, U.S. Trade Representative (USTR)

Public Law 111-203, H.R. 4173 - Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Implementation and Regulatory reform. Captive Reinsurance Transactions and Global Capital Standards. Roles of federal and state agencies at the International Association of Insurance Supervisors and the Financial Stability Board. H.R. 2140, the Insurance Capital and Accounting Standards Act of 2013. Amends the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) and the Home Owners' Loan Act to make minimum leverage and risk-based capital requirements governing insurance companies under the state law also apply to insurance companies that are either depository holding companies or subsidiaries of depository holding companies. Issue: Capital Standards, Basel III H.R. 1062, SEC Regulatory Accountability Act. Issue: SEC Rulemaking, Cost-Benefit Analysis, Derivatives H.AMDT.64 to H.R. 1062, Amendment expresses the sense of Congress that rules adopted by the Public Company Accounting Oversight Board (PCAOB) comply with the same standards required of the SEC. It also requires the SEC to ensure that any rules adopted by the Municipal Securities Rulemaking Board (MSRB), and other national securities associations comply with the standards set forth in the bill. Issue: FINRA, Securities Rulemaking H.R. 1564, the Audit Integrity and Job Protection Act. Amends the Sarbanes-Oxley Act of 2002 (SOX) to deny the Public Company Accounting Oversight Board any authority to require that audits conducted for a particular issuer of securities in accordance with SOX standards be conducted by specific auditors, or that such audits be conducted for an issuer by different auditors on a rotating basis. Issue: Mandatory Auditor Rotation H.R. 2374, the Retail Investor Protection Act. To amend the Securities Exchange Act of 1934 to provide protections for retail customers, and for other purposes. Issue: Fiduciary Duties S. 731, the Basel III CASE Act. Directs the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency, before issuing any final rule in relation to proposals they have issued for the International Basel III agreement on general risk-based capital requirements, to conduct an empirical study that includes: (1) a quantitative analysis of the rule's impact on the U.S. financial services sector, specifically community, mid-size, and regional financial institutions; and (2) a determination of the long-term impact of the rule, including changes to the current risk weight framework. Issue: Capital Standards for Community Banks H.R 2547, the Determination of Appropriate Risk-Based Capital Requirements for Community Financial Institutions Act of 2013. To determine appropriate risk based capital requirements for community, mid-size, and regional institutions. Issue: Capital Standards for Community Banks S. 798, TBTF Act. Requires federal banking agencies to establish capital requirements for the ratio of equity capital to total consolidated assets for all financial institutions. Issue: Capital Standards 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. Issue: Capital Standards S. 1526, The Audit Integrity and Job Protection Act, to prevent the Public Company Accounting Oversight Board (PCAOB) from requiring public companies to use a specific auditor or to change auditors on a rotating basis. Issue: Mandatory Auditor Rotation H.R. 2733, Defending American Taxpayers From Abusive Government Takings Act of 2013 to prohibit Fannie Mae and Freddie Mac from purchasing, the FHA from insuring, and the Department of Agriculture from guaranteeing, making, or insuring, a mortgage that is secured by a residence or residential structure located in a county in which the State has used the power of eminent domain to take a residential mortgage. Issue: Mortgage Investments H.R. 2767, the Protect American Taxpayers & Homeowners (PATH) Act. Issue: Mortgage Investments and Government Sponsored Enterprises/Federal Home Loan Banks Draft H.AMDT to HR 2610, Transportation, Housing & Urban Development Appropriations, to prohibit federal guarantees for mortgages seized through eminent domain. Issue: Mortgage Investments. Provision in H.R. 4745, Transportation, Housing & Urban Development Appropriations, to prohibit federal guarantees for mortgages seized through eminent domain. Issue: Mortgage Investments. S. 2102, a bill to clarify the application of certain leverage and risk based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Capital Standards. H.R. 4510 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III S. 2270 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III H.R. 5016 - Financial Services and General Government Appropriations Act, 2015. Making appropriations for financial services and general government for the fiscal year ending September 30, 2015, and for other purposes. Issue: Global insurance standards Draft Senate bill on Financial Services and General Government Appropriations Act, 2015. Making appropriations for financial services and general government for the fiscal year ending September 30, 2015, and for other purposes. Issue: Global insurance standards H.R. 4557 - Policyholder Protection Act of 2014. To amend the Federal Deposit Insurance Act to provide for notice to, and input by, State insurance commissioners when requiring an insurance company to serve as a source of financial strength pursuant to such Act. Issue: Source of strength S. 1217- Housing Finance Reform and Taxpayer Protection Act of 2013. Authorizes the Federal Mortgage Insurance Corporation to provide insurance to any covered security regardless of whether it has satisfied credit-risk sharing requirements if unusual and exigent circumstances have created an anomalous lack of mortgage credit availability. Issue: Government Sponsored Enterprises. Senate ADMT to S. 1217-Housing Finance Reform and Taxpayer Protection Act of 2014. To provide for prohibitions relating to the use of the power of eminent domain. Issue: Mortgage Investments 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. Issue: Global insurance standards. H.R. 749 - Eliminate Privacy Notice Confusion Act. This bill amends the Gramm-Leach-Bliley Act to exempt from its annual privacy policy notice requirement any financial institution which: (1) provides nonpublic personal information only in accordance with specified requirements, and (2) has not changed its policies and practices with regard to disclosing nonpublic personal information from those disclosed in the most recent disclosure sent to consumers. Issue: privacy S. 635 - Privacy Notice Modernization Act of 2013. This bill amends the Gramm-Leach-Bliley Act to exempt from its annual written privacy policy notice requirement any financial institution which: (1) provides nonpublic personal information only in accordance with specified requirements, (2) has not changed its policies and practices with respect to disclosing nonpublic personal information from those disclosed in the most recent disclosure sent to consumers, and (3) otherwise provides customers access to such most recent disclosure in electronic or other form permitted by specified regulations. Issue: privacy H.R. 5018 - Federal Reserve Accountability and Transparency Act of 2014. This bill amends the Federal Reserve Act to establish requirements for policy rules and blackout periods of the Federal Open Market Committee, to establish requirements for certain activities of the Board of Governors of the Federal Reserve System. Issue: global insurance standards. H.Res.735 - Expressing the sense of the House of Representatives that recently proposed measures that will reduce transparency and public participation at the International Association of Insurance Supervisors (IAIS) should be disapproved by United States representatives to the IAIS. Issue: global insurance standards. S.Res. 561 - A resolution expressing the sense of the Senate that recently proposed measures that will reduce transparency and public participation at the International Association of Insurance Supervisors (IAIS) should be disapproved by United States representatives to the IAIS. Issue: global insurance standards. H.R._____, Draft legislation on the development of global insurance standards. Issue: global insurance standards. H.R. 5421 - Financial Institution Bankruptcy Act of 2014. To amend title 11 of the United States Code in order to facilitate the resolution of an insolvent financial institution in bankruptcy. Is

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

See addendum.S. 1861, the Taxpayer Protection and Responsible Resolution Act (all provisions regarding repeal of the Dodd-Frank Acts orderly liquidation authority) H.R 5421, Financial Institution Bankruptcy Act of 2014

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

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of