Uniform Treatment of NRSROs Act

COVID-19 related legislation and administrative actions; policies impacting NRSROs; S. 4586, the Access to Emergency Credit Facilities Act of 2020; H.R. 6934, the Uniform Treatment of NRSROs Act.

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

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

H.R. 56, Financial Technology Protection Act H.R. 87, Midnight Rules Relief Act of 2019 H.R. 189, Financial Institution Customer Protection Act of 2019 H.R. 748/ S. 3548, Coronavirus Aid, Relief, and Economic Security (CARES) Act H.R. 758, Cooperate with Law Enforcement Agencies and Watch Act of 2019 H.R. 969, TABS Act of 2019 H.R. 1018, Improving Corporate Governance Through Diversity Act of 2019 H.R. 1731, Cybersecurity Disclosure Act of 2019 H.R. 1815, SEC Disclosure Effectiveness Testing Act H.R. 2144, Token Taxonomy Act of 2019 H.R. 2154, Digital Taxonomy Act of 2019 H.R. 2409, Expanding Access to Capital for Rural Job Creators Act H.R. 2515, Whistleblower Protection Reform Act of 2019 H.R. 2534, Insider Trading Prohibition Act H.R. 2919, Improving Investment Research for Small and Emerging Issuers Act H.R. 3050, Expanding Investment in Small Businesses Act of 2019 H.R. 3279, Diversity in Corporate Leadership Act of 2019 H.R. 3355, Reward Work Act H.R. 3614, Restricting Credit Checks for Employment Decisions Act H.R. 3618, Free Credit Scores for Consumers Act of 2019 H.R. 3621, Student Borrower Credit Improvement Act H.R. 3622, Restoring Unfairly Impaired Credit and Protecting Consumers Act H.R. 3624/S. 1843 Outsourcing Accountability Act of 2019 H.R. 3625, PCAOB Whistleblower Protection Act of 2019 H.R. 3629, Clarity in Credit Score Formation Act of 2019 H.R. 3641/S. 1854, Stronger Enforcement of Civil Penalties Act of 2019 H.R. 3642, Improving Credit Reporting for All Consumers Act H.R. 3848/S. 2155, Stop Wall Street Looting Act H.R. 3987, Alleviating Stress Test Burdens to Help Investors Act H.R. 4242, Greater Accountability in Pay Act of 2019 H.R. 4320, Corporate Management Accountability Act of 2019 H.R. 4329, ESG Disclosure Simplification Act of 2019 H.R. 4335, 8-K Trading Gap Act of 2019 H.R. 4344, Investor Protection and Capital Markets Fairness Act H.R. 4492/S. 733, Consumer Financial Choice and Capital Markets Protection Act of 2019 H.R. 4726, Certainty for End-Users Act H.R. 4805, Access Business Credit Act of 2019 H.R. 4918, Helping Startups Continue to Grow Act H.R. 5013, Small Business Fair Debt Collection Protection Act H.R. 5084, Improving Corporate Governance Through Diversity Act of 2019 H.R. 5332, Protecting Your Credit Score Act of 2019 H.R. 5494, Catastrophe Loss Mitigation Incentive and Tax Parity Act of 2019 H.R. 5929, Shareholder Political Transparency Act of 2020 H.R. 5930, Workforce Investment Disclosure Act of 2020 H.R. 6116, Consumer Financial Protection Commission Act H.R. 6210, Uyghur Forced Labor Prevention Act H.R. 6270, Uyghur Forced Labor Disclosure Act of 2020 H.R. 6371, To amend the Securities Exchange Act of 1934 to require issuers to disclose risks related to global pandemics, and for other purposes H.R. 6375, To amend the Securities Exchange Act of 1934 to require issuers to make disclosures related to supply chain disruption risk, and for other purposes H.R. 6790, Business Borrowers Protection Act H.R. 6934, To amend the CARES Act to require the uniform treatment of nationally recognized statistical rating organizations under certain programs carried out in response to the COVID-19 emergency, and for other purposes H.R. 7000, Holding Foreign Companies Accountable Act H.R. 7617, Defense, Commerce, Justice, Science, Energy and Water Development, Financial Services and General Government, Labor, Health and Human Services, Education, Transportation, Housing, and Urban Development Appropriations Act, 2021 H.R. 7668, Financial Services and General Government Appropriations Act, 2021 S. 452, Fostering Innovation Act of 2019 S. 471, Litigation Funding Transparency Act of 2019 S. 566, Expanding Access to Capital for Rural Job Creators Act S. 603, Financial Stability Oversight Council Improvement Act of 2019 S. 1256, PCAOB Enforcement Transparency Act of 2019 S. 1731, Ensuring Quality Information and Transparency for Abroad-Based Listings on our Exchanges (EQUITABLE) Act S. 2391, Stock Buyback Reform and Worker Dividend Act of 2019 S. 3441, Fair Hiring in Banking Act S. 3548, Coronavirus Aid, Relief, and Economic Security (CARES) Act S. 3990, Financial Product Safety Commission Act of 2020 S. 4129, Lifting Our Communities through Advance Liquidity (LOCAL) Infrastructure Act S. 4159, E-SIGN Modernization Act of 2020 Draft legislation titled U.S. Investors and National Security Transparency Act Draft legislation that would extend the statute of limitations for civil penalties by the SEC Draft legislation, the Bad Actor Disqualification Act Draft legislation to require the SEC to study stock buybacks under rule 10b-18 Draft legislation titled the Diverse Asset Managers Act Draft legislation titled the Corporate Human Rights Risk Assessment, Prevention and Mitigation Act Draft legislation to provide certain financial end-users with relief from clearing and margin requirements Draft legislation relating to supplementary leverage ratio treatment of client initial margin Draft legislation to amend the Investment Advisers Act to require the SEC to establish a process to follow when it obtains source code or other sensitive information from investment advisers Draft legislation relating to the underwriting of automobile insurance Draft legislation COVID-19 Restitution Assistance Fund for Victims of Securities Violations Act Draft legislation to enhance civil penalties under the Federal securities laws for violations related to an attempt to exploit investors related to the COVID-19 crisis Draft legislation to temporarily prohibit federal financial regulators from adopting rules not directly related to responding to the coronavirus response through the length of the crisis Draft legislation to apply certain terms and conditions on making direct loans under the CARES Act to certain purchases of debt by the Federal Government, and for other purposes Potential legislation to require the SEC to complete rulemaking required by section 10D of the Securities Exchange Act of 1934 Potential legislation to require the SEC to complete rulemaking required by section 14(i) of the Securities Exchange Act of 1934 Nomination of Mark Calabria to be Director of the Federal Housing Finance Agency Proposed rule on auditor independence with respect to certain loans or debtor-creditor relationships (83 Fed. Reg. 20,753-20,773, May 8, 2018) Proposed regulation on Regulation Best Interest (83 Fed. Reg. 21,574-21,682, May 9, 2018) Proposed Commission interpretation regarding standard of conduct for investment advisers; request for comment on enhancing investment advisor regulation (83 Fed. Reg. 21,203-21,214, May 9, 2018) Proposed rule on form CRS relationship summary; amendments to form ADV; required disclosures in retail communications and restrictions on the use of certain names or titles (83 Fed. Reg. 21,416-21,575, May 9, 2018) Policy to Encourage Trial Disclosure Programs (83 Fed. Reg. 45,574-45,578, September 10, 2018) Proposed changes to applicability thresholds for regulatory capital and liquidity requirements (83 Fed. Reg. 66,024-66,059, December 12, 2018) Proposed rule on prudential standards for large bank holding companies and savings and loan holding companies (83 Fed. Reg. 61,408-61,460, November 29, 2018) Proposed rule regarding standardized approach for calculating the exposure amount of derivative Contracts (84 Fed. Reg. 64,660-64,728, December 17, 2018) Proposed rule on payday, vehicle title, and certain high-cost installment loans; delay of compliance date (84 Fed. Reg. 4,298-4,305, February 14, 2019) Proposed rule on self-regulatory organizations; Financial Industry Regulatory Authority, Inc.; notice of filing of a proposed rule change to establish a corporate bond new issue reference data service (84 Fed. Reg. 13,977-13,983, April 8, 2019) Proposed rule to exemptions from the proxy rules for proxy voting advice (84 Fed. Reg. 66,518-66,559, December 4, 2019) Proposed rule on procedural requirements and resubmission thresholds under Exchange Act Rule 14a-8 (84 Fed. Reg. 66,458-66,515, December 4, 2019) Proposed rule on modernization of Regulation S-K Items 101, 103, and 105 (84 Fed. Reg. 44,358-44,390, August 8, 2019) Proposed rule on regarding margin and capital requirements for covered swap entities (84 Fed. Reg. 59,970-59,989, November 7, 2019) Proposed rule for amendments to Rule 2-01, qualifications of accountants (85 Fed. Reg. 2,332-2,354, January 15, 2020) Proposed rule amending the accredited investor definition (85 Fed. Reg. 2,574-2,613, January 15, 2020) Proposed rule on disclosure of payments by resource extraction issuers (85 Fed. Reg. 2,522-2,571, January 15, 2020) Electronic consent based Social Security number verification (84 Fed. Reg. 66,704-66,705, December 5, 2019) Proposed rule on permissible interest on loans that are sold, assigned, or otherwise transferred (84 Fed. Reg. 64,229-64,232, November 21, 2019) Proposed rule on remittance transfers under the Electronic Fund Transfer Act (Regulation E) (84 Fed. Reg. 67,132-67,167, December 6, 2019) Request for information regarding the integrated mortgage disclosures under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z) rule assessment (84 Fed. Reg. 64,436-64,441, November 22, 2019) Various issues relating to CFPB regulatory sandbox for disclosures; Potential closing of the financial markets in response to the coronavirus pandemic Securities Exchange Commission strategic plan; Securities Exchange Commission Rule 701 Form S-8 reforms; potential legislation related to the rulemaking and enforcement authority of Sec. 619 of the Dodd-Frank Act (P.L.111-203); beneficial ownership; reforms to the Committee on Foreign Investment in the United States; modernization of the Community Reinvestment Act (P.L. 95-128); implementation of the John S. McCain National Defense Authorization Act for Fiscal Year 2019, Title XVII, Foreign Investment Risk Review Modernization Act (P.L. 115-232), including provisions relating to sections 1654 and 1655; application of Customer Identification Program requirements under anti-money laundering rules to bank-affiliated premium finance companies; application of the May 2016 Customer Due Diligence Rule to routine cash refunds issued by bank-affiliated premium finance companies; proposals to audit the Board of Governors of the Federal Reserve System; Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTC Proposed rulemaking on the De Minimis Exception to the Swap Dealer Definition; CFPB policy on no-action letters and compliance assistance sandbox policy; Securities Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; comment on fund of funds arrangements; interest rate restrictions; margin and capital requirements for covered swap entities; Office of the Comptroller of the Currency (OCC) Innovation Pilot Program; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); implementation of section 215 of the Economic Growth Regulatory Relief and Consumer Protection Act (P.L. 115-174); qualified mortgage definition under the Truth and Lending Act (P.L. 90-321) regulation Z; Financial Stability Oversight Council and the designation of nonbank financial firms as systemically important; Federal Reserve System and large institution supervision coordinating committee; updated disclosure requirements and summary prospectus for variable annuity and variable life insurance contracts; amendments to the accelerated filer and large accelerated filer definitions; potential housing finance reform legislation; enforcement of Securities Exchange Commission penalties; order instituting proceedings to determine whether to approve or disapprove a proposed rule change to establish a corporate bond new issue reference data service; comments on modernization of regulation S-K Items 101, 103 and 105 17 CFR Parts 229, 239 and 240; comments on bond reference data proposal; comment period extension request for regulatory capital rules: risk based capital requirements for depository institution holding companies significantly engaged in insurance activities; comments on proposed rule change to introduce a liquidity provider protection on Cboe EDGA; inter-affiliate initial margin relief; substituted compliance and equivalence between the U.S. derivatives regulatory regime and the European Unions European Market Infrastructure Regulation (EMIR); European Supervisory Authority review and provisions regarding portfolio delegation; EU third country equivalency process; EU sustainable finance action plan and incorporating ESG factors into financial services; EU solvency II review; EU review of prudential regime for investment firms; Brexit risks; SEC concept release on harmonization of securities offering exemptions; SEC digital assets; transition from London Interbank Offered Rate (LIBOR) to Secured Overnight Financing Rate (SOFR); Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), valid when made doctrine; Department of Labor Field Assistance Bulletin No. 2018-01 regarding compliance with Interpretive Bulletin 2016-01 and 2015-01; Incentive based executive compensation regulation under Dodd-Frank Section 956; potential repeal of the State and Local Tax (SALT) cap; amending the accredited investor definition; amendments to exemptions from the proxy rules for proxy voting advice; disclosure of payments by resource extraction issuers; PCAOB concept release on potential approach to revisions to PCAOB quality control standards; procedural requirements and resubmission thresholds under Exchange Act Rule 14a-8; proposed amendments to Rule 2-01, qualifications of accountants; proposed revisions to prohibitions and restrictions on proprietary trading and certain interests in, and relationships with, hedge funds and private equity funds; regulatory capital rules: risk-based capital requirements for depository institution holding companies significantly engaged in insurance activities; revised draft eCBSV user agreement and related materials; credit risk retention-notice of commencement of review; issues relating to federal interest rate authority; comments on margin requirements for non-centrally cleared swaps margin - impact of COVID-19 on initial margin phase-in; Main Street New Loan Facility and Main Street Expanded Loan Facility; Managements Discussion and Analysis, Selected Financial Data, and Supplementary Financial Information; Securities and Exchange Commission Fixed Income Market Structure Advisory Committee; Federal Deposit Insurance Corporation: Unsafe and Unsound Banking Practices: Brokered Deposits; Furthering Economic Stabilization by Encouraging Financial Institutions to Work Constructively with All Borrowers Affected by COVID-19; Liquidity Programs Coronavirus; PCAOB Request for Comment: Interim Analysis of Critical Audit Matter Requirements; Proposed Rule Change to Add a New Discretionary Limit Order Type Called D-Limit; Proposed Rule Change to Align Certain MSRB Rules to Securities and Exchange Act Rule 15l-1, Regulation Best Interest; Proposed Rule Change to FINRAs Suitability, Non-Cash Compensation, and Capital Acquisition Broker Rules in Response to Regulation Best Interest; Federal Reserve Board request for public feedback proposal to expand its Main Street Lending Program to provide access to credit for nonprofit organizations; Regulatory Capital Rule: Revised Transition of the Current Expected Credit Losses (CECL) Methodology for Allowances; Request for Further Clarifications and Modifications to Risk-Based Guidance; RFI to Assist the Taskforce on Federal Consumer Financial Law-CFPB; Sec. 171 DFA Collins Amendment; Use of Derivatives by Registered Investment Companies and Business Development Companies; Required Due Diligence by Broker-Dealers and Registered Investment Advisers Regarding Retail Customers Transactions in Certain Leveraged/Inverse Investment Vehicles; EU renewed sustainable finance strategy consultation; access to capital for minority owned businesses; CFPB comment on changes to Regulation Z to facilitate the upcoming LIBOR transition; debt collection practices (Regulation F): supplemental notice of proposed rulemaking; European Supervisory Authorities consultation paper on ESG Disclosures; FDIC request for information on standard setting and voluntary certification for models and third-party providers of technology and other services; opposing credit suppression; margin and capital requirements for covered swap entities interim final rule; margin requirements for uncleared swaps for swap dealers and major swap participants; national banks and federal savings associations as lenders; proposed rule on financial factors in selecting plan investments; qualified mortgage definition under the Truth In Lending Act (Regulation Z); response to OCC ANPR on National Bank and Federal Savings Association digital activities; proposed rule reporting threshold for institutional investment managers; Housing and Urban Development implementation of the Fair Housing Acts disparate impact standard; FDIC notice of proposed rulemaking on interest rate restrictions on institutions that are less than well capitalized; federal regulatory capital rules: risk-based capital requirements for depository institution holding companies significantly engaged in insurance activities; proposed revisions to prohibitions and restrictions on proprietary trading and certain interests in, and relationships with, hedge funds and private equity funds; FDIC, incorporation of existing statement of policy regarding requests for participation in the affairs of an insured depository institution by convicted individuals; SEC: Proposed Rule Change to FINRAs Suitability, Non-Cash Compensation and Capital Acquisition Broker Rules in Response to Regulation Best Interest; SEC: Proposed Rule Change to Add a New Discretionary Limit Order Type Called D-Limit; SEC: Proposed Rule Change to Align Certain MSRB Rules to Securities and Exchange Act Rule 15l-1, Regulation Best Interest; SEC: Proposed Rule Change on Form 13F Reporting Threshold for Institutional Investment Managers; development of an international insurance capital standard by the International Association of Insurance Supervisors; development of a new program to replace revenue due to business interruption or event cancelation; International Organization of Securities Commissions (IOSCO) consultation on leverage metrics; potential legislation dealing with third party litigation financing and lawsuit lending

H.R. 56, Financial Technology Protection Act H.R. 87, Midnight Rules Relief Act of 2019 H.R. 189, Financial Institution Customer Protection Act of 2019 H.R. 748/ S. 3548, Coronavirus Aid, Relief, and Economic Security (CARES) Act H.R. 758, Cooperate with Law Enforcement Agencies and Watch Act of 2019 H.R. 969, TABS Act of 2019 H.R. 1018, Improving Corporate Governance Through Diversity Act of 2019 H.R. 1731, Cybersecurity Disclosure Act of 2019 H.R. 1815, SEC Disclosure Effectiveness Testing Act H.R. 2144, Token Taxonomy Act of 2019 H.R. 2154, Digital Taxonomy Act of 2019 H.R. 2409, Expanding Access to Capital for Rural Job Creators Act H.R. 2515, Whistleblower Protection Reform Act of 2019 H.R. 2534, Insider Trading Prohibition Act H.R. 2919, Improving Investment Research for Small and Emerging Issuers Act H.R. 3050, Expanding Investment in Small Businesses Act of 2019 H.R. 3279, Diversity in Corporate Leadership Act of 2019 H.R. 3355, Reward Work Act H.R. 3614, Restricting Credit Checks for Employment Decisions Act H.R. 3618, Free Credit Scores for Consumers Act of 2019 H.R. 3621, Student Borrower Credit Improvement Act H.R. 3622, Restoring Unfairly Impaired Credit and Protecting Consumers Act H.R. 3624/S. 1843 Outsourcing Accountability Act of 2019 H.R. 3625, PCAOB Whistleblower Protection Act of 2019 H.R. 3629, Clarity in Credit Score Formation Act of 2019 H.R. 3641/S. 1854, Stronger Enforcement of Civil Penalties Act of 2019 H.R. 3642, Improving Credit Reporting for All Consumers Act H.R. 3848/S. 2155, Stop Wall Street Looting Act H.R. 3987, Alleviating Stress Test Burdens to Help Investors Act H.R. 4242, Greater Accountability in Pay Act of 2019 H.R. 4320, Corporate Management Accountability Act of 2019 H.R. 4329, ESG Disclosure Simplification Act of 2019 H.R. 4335, 8-K Trading Gap Act of 2019 H.R. 4344, Investor Protection and Capital Markets Fairness Act H.R. 4492/S. 733, Consumer Financial Choice and Capital Markets Protection Act of 2019 H.R. 4726, Certainty for End-Users Act H.R. 4805, Access Business Credit Act of 2019 H.R. 4918, Helping Startups Continue to Grow Act H.R. 5013, Small Business Fair Debt Collection Protection Act H.R. 5084, Improving Corporate Governance Through Diversity Act of 2019 H.R. 5332, Protecting Your Credit Score Act of 2019 H.R. 5494, Catastrophe Loss Mitigation Incentive and Tax Parity Act of 2019 H.R. 5929, Shareholder Political Transparency Act of 2020 H.R. 5930, Workforce Investment Disclosure Act of 2020 H.R. 6116, Consumer Financial Protection Commission Act H.R. 6210, Uyghur Forced Labor Prevention Act H.R. 6270, Uyghur Forced Labor Disclosure Act of 2020 H.R. 6371, To amend the Securities Exchange Act of 1934 to require issuers to disclose risks related to global pandemics, and for other purposes H.R. 6375, To amend the Securities Exchange Act of 1934 to require issuers to make disclosures related to supply chain disruption risk, and for other purposes H.R. 6790, Business Borrowers Protection Act H.R. 6934, To amend the CARES Act to require the uniform treatment of nationally recognized statistical rating organizations under certain programs carried out in response to the COVID-19 emergency, and for other purposes H.R. 7000, Holding Foreign Companies Accountable Act H.R. 7617, Defense, Commerce, Justice, Science, Energy and Water Development, Financial Services and General Government, Labor, Health and Human Services, Education, Transportation, Housing, and Urban Development Appropriations Act, 2021 H.R. 7668, Financial Services and General Government Appropriations Act, 2021 S. 452, Fostering Innovation Act of 2019 S. 471, Litigation Funding Transparency Act of 2019 S. 566, Expanding Access to Capital for Rural Job Creators Act S. 603, Financial Stability Oversight Council Improvement Act of 2019 S. 1256, PCAOB Enforcement Transparency Act of 2019 S. 1731, Ensuring Quality Information and Transparency for Abroad-Based Listings on our Exchanges (EQUITABLE) Act S. 2391, Stock Buyback Reform and Worker Dividend Act of 2019 S. 3441, Fair Hiring in Banking Act S. 3548, Coronavirus Aid, Relief, and Economic Security (CARES) Act S. 3990, Financial Product Safety Commission Act of 2020 S. 4129, Lifting Our Communities through Advance Liquidity (LOCAL) Infrastructure Act S. 4159, E-SIGN Modernization Act of 2020 Draft legislation titled U.S. Investors and National Security Transparency Act Draft legislation that would extend the statute of limitations for civil penalties by the SEC Draft legislation, the Bad Actor Disqualification Act Draft legislation to require the SEC to study stock buybacks under rule 10b-18 Draft legislation titled the Diverse Asset Managers Act Draft legislation titled the Corporate Human Rights Risk Assessment, Prevention and Mitigation Act Draft legislation to provide certain financial end-users with relief from clearing and margin requirements Draft legislation relating to supplementary leverage ratio treatment of client initial margin Draft legislation to amend the Investment Advisers Act to require the SEC to establish a process to follow when it obtains source code or other sensitive information from investment advisers Draft legislation relating to the underwriting of automobile insurance Draft legislation COVID-19 Restitution Assistance Fund for Victims of Securities Violations Act Draft legislation to enhance civil penalties under the Federal securities laws for violations related to an attempt to exploit investors related to the COVID-19 crisis Draft legislation to temporarily prohibit federal financial regulators from adopting rules not directly related to responding to the coronavirus response through the length of the crisis Draft legislation to apply certain terms and conditions on making direct loans under the CARES Act to certain purchases of debt by the Federal Government, and for other purposes Potential legislation to require the SEC to complete rulemaking required by section 10D of the Securities Exchange Act of 1934 Potential legislation to require the SEC to complete rulemaking required by section 14(i) of the Securities Exchange Act of 1934 Nomination of Mark Calabria to be Director of the Federal Housing Finance Agency Proposed rule on auditor independence with respect to certain loans or debtor-creditor relationships (83 Fed. Reg. 20,753-20,773, May 8, 2018) Proposed regulation on Regulation Best Interest (83 Fed. Reg. 21,574-21,682, May 9, 2018) Proposed Commission interpretation regarding standard of conduct for investment advisers; request for comment on enhancing investment advisor regulation (83 Fed. Reg. 21,203-21,214, May 9, 2018) Proposed rule on form CRS relationship summary; amendments to form ADV; required disclosures in retail communications and restrictions on the use of certain names or titles (83 Fed. Reg. 21,416-21,575, May 9, 2018) Policy to Encourage Trial Disclosure Programs (83 Fed. Reg. 45,574-45,578, September 10, 2018) Proposed changes to applicability thresholds for regulatory capital and liquidity requirements (83 Fed. Reg. 66,024-66,059, December 12, 2018) Proposed rule on prudential standards for large bank holding companies and savings and loan holding companies (83 Fed. Reg. 61,408-61,460, November 29, 2018) Proposed rule regarding standardized approach for calculating the exposure amount of derivative Contracts (84 Fed. Reg. 64,660-64,728, December 17, 2018) Proposed rule on payday, vehicle title, and certain high-cost installment loans; delay of compliance date (84 Fed. Reg. 4,298-4,305, February 14, 2019) Proposed rule on self-regulatory organizations; Financial Industry Regulatory Authority, Inc.; notice of filing of a proposed rule change to establish a corporate bond new issue reference data service (84 Fed. Reg. 13,977-13,983, April 8, 2019) Proposed rule to exemptions from the proxy rules for proxy voting advice (84 Fed. Reg. 66,518-66,559, December 4, 2019) Proposed rule on procedural requirements and resubmission thresholds under Exchange Act Rule 14a-8 (84 Fed. Reg. 66,458-66,515, December 4, 2019) Proposed rule on modernization of Regulation S-K Items 101, 103, and 105 (84 Fed. Reg. 44,358-44,390, August 8, 2019) Proposed rule on regarding margin and capital requirements for covered swap entities (84 Fed. Reg. 59,970-59,989, November 7, 2019) Proposed rule for amendments to Rule 2-01, qualifications of accountants (85 Fed. Reg. 2,332-2,354, January 15, 2020) Proposed rule amending the accredited investor definition (85 Fed. Reg. 2,574-2,613, January 15, 2020) Proposed rule on disclosure of payments by resource extraction issuers (85 Fed. Reg. 2,522-2,571, January 15, 2020) Electronic consent based Social Security number verification (84 Fed. Reg. 66,704-66,705, December 5, 2019) Proposed rule on permissible interest on loans that are sold, assigned, or otherwise transferred (84 Fed. Reg. 64,229-64,232, November 21, 2019) Proposed rule on remittance transfers under the Electronic Fund Transfer Act (Regulation E) (84 Fed. Reg. 67,132-67,167, December 6, 2019) Request for information regarding the integrated mortgage disclosures under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z) rule assessment (84 Fed. Reg. 64,436-64,441, November 22, 2019) Various issues relating to CFPB regulatory sandbox for disclosures; Potential closing of the financial markets in response to the coronavirus pandemic Securities Exchange Commission strategic plan; Securities Exchange Commission Rule 701 Form S-8 reforms; potential legislation related to the rulemaking and enforcement authority of Sec. 619 of the Dodd-Frank Act (P.L.111-203); beneficial ownership; reforms to the Committee on Foreign Investment in the United States; modernization of the Community Reinvestment Act (P.L. 95-128); implementation of the John S. McCain National Defense Authorization Act for Fiscal Year 2019, Title XVII, Foreign Investment Risk Review Modernization Act (P.L. 115-232), including provisions relating to sections 1654 and 1655; application of Customer Identification Program requirements under anti-money laundering rules to bank-affiliated premium finance companies; application of the May 2016 Customer Due Diligence Rule to routine cash refunds issued by bank-affiliated premium finance companies; proposals to audit the Board of Governors of the Federal Reserve System; Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTC Proposed rulemaking on the De Minimis Exception to the Swap Dealer Definition; CFPB policy on no-action letters and compliance assistance sandbox policy; Securities Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; comment on fund of funds arrangements; interest rate restrictions; margin and capital requirements for covered swap entities; Office of the Comptroller of the Currency (OCC) Innovation Pilot Program; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); implementation of section 215 of the Economic Growth Regulatory Relief and Consumer Protection Act (P.L. 115-174); qualified mortgage definition under the Truth and Lending Act (P.L. 90-321) regulation Z; Financial Stability Oversight Council and the designation of nonbank financial firms as systemically important; Federal Reserve System and large institution supervision coordinating committee; updated disclosure requirements and summary prospectus for variable annuity and variable life insurance contracts; amendments to the accelerated filer and large accelerated filer definitions; potential housing finance reform legislation; enforcement of Securities Exchange Commission penalties; order instituting proceedings to determine whether to approve or disapprove a proposed rule change to establish a corporate bond new issue reference data service; comments on modernization of regulation S-K Items 101, 103 and 105 17 CFR Parts 229, 239 and 240; comments on bond reference data proposal; comment period extension request for regulatory capital rules: risk based capital requirements for depository institution holding companies significantly engaged in insurance activities; comments on proposed rule change to introduce a liquidity provider protection on Cboe EDGA; inter-affiliate initial margin relief; substituted compliance and equivalence between the U.S. derivatives regulatory regime and the European Unions European Market Infrastructure Regulation (EMIR); European Supervisory Authority review and provisions regarding portfolio delegation; EU third country equivalency process; EU sustainable finance action plan and incorporating ESG factors into financial services; EU solvency II review; EU review of prudential regime for investment firms; Brexit risks; SEC concept release on harmonization of securities offering exemptions; SEC digital assets; transition from London Interbank Offered Rate (LIBOR) to Secured Overnight Financing Rate (SOFR); Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), valid when made doctrine; Department of Labor Field Assistance Bulletin No. 2018-01 regarding compliance with Interpretive Bulletin 2016-01 and 2015-01; Incentive based executive compensation regulation under Dodd-Frank Section 956; potential repeal of the State and Local Tax (SALT) cap; amending the accredited investor definition; amendments to exemptions from the proxy rules for proxy voting advice; disclosure of payments by resource extraction issuers; PCAOB concept release on potential approach to revisions to PCAOB quality control standards; procedural requirements and resubmission thresholds under Exchange Act Rule 14a-8; proposed amendments to Rule 2-01, qualifications of accountants; proposed revisions to prohibitions and restrictions on proprietary trading and certain interests in, and relationships with, hedge funds and private equity funds; regulatory capital rules: risk-based capital requirements for depository institution holding companies significantly engaged in insurance activities; revised draft eCBSV user agreement and related materials; credit risk retention-notice of commencement of review; issues relating to federal interest rate authority; comments on margin requirements for non-centrally cleared swaps margin - impact of COVID-19 on initial margin phase-in; Main Street New Loan Facility and Main Street Expanded Loan Facility; Managements Discussion and Analysis, Selected Financial Data, and Supplementary Financial Information; Securities and Exchange Commission Fixed Income Market Structure Advisory Committee; Federal Deposit Insurance Corporation: Unsafe and Unsound Banking Practices: Brokered Deposits; Furthering Economic Stabilization by Encouraging Financial Institutions to Work Constructively with All Borrowers Affected by COVID-19; Liquidity Programs Coronavirus; PCAOB Request for Comment: Interim Analysis of Critical Audit Matter Requirements; Proposed Rule Change to Add a New Discretionary Limit Order Type Called D-Limit; Proposed Rule Change to Align Certain MSRB Rules to Securities and Exchange Act Rule 15l-1, Regulation Best Interest; Proposed Rule Change to FINRAs Suitability, Non-Cash Compensation, and Capital Acquisition Broker Rules in Response to Regulation Best Interest; Federal Reserve Board request for public feedback proposal to expand its Main Street Lending Program to provide access to credit for nonprofit organizations; Regulatory Capital Rule: Revised Transition of the Current Expected Credit Losses (CECL) Methodology for Allowances; Request for Further Clarifications and Modifications to Risk-Based Guidance; RFI to Assist the Taskforce on Federal Consumer Financial Law-CFPB; Sec. 171 DFA Collins Amendment; Use of Derivatives by Registered Investment Companies and Business Development Companies; Required Due Diligence by Broker-Dealers and Registered Investment Advisers Regarding Retail Customers Transactions in Certain Leveraged/Inverse Investment Vehicles; EU renewed sustainable finance strategy consultation; access to capital for minority owned businesses; CFPB comment on changes to Regulation Z to facilitate the upcoming LIBOR transition; debt collection practices (Regulation F): supplemental notice of proposed rulemaking; European Supervisory Authorities consultation paper on ESG Disclosures; FDIC request for information on standard setting and voluntary certification for models and third-party providers of technology and other services; opposing credit suppression; margin and capital requirements for covered swap entities interim final rule; margin requirements for uncleared swaps for swap dealers and major swap participants; national banks and federal savings associations as lenders; proposed rule on financial factors in selecting plan investments; qualified mortgage definition under the Truth In Lending Act (Regulation Z); response to OCC ANPR on National Bank and Federal Savings Association digital activities; proposed rule reporting threshold for institutional investment managers; Housing and Urban Development implementation of the Fair Housing Acts disparate impact standard; FDIC notice of proposed rulemaking on interest rate restrictions on institutions that are less than well capitalized; federal regulatory capital rules: risk-based capital requirements for depository institution holding companies significantly engaged in insurance activities; proposed revisions to prohibitions and restrictions on proprietary trading and certain interests in, and relationships with, hedge funds and private equity funds; FDIC, incorporation of existing statement of policy regarding requests for participation in the affairs of an insured depository institution by convicted individuals; SEC: Proposed Rule Change to FINRAs Suitability, Non-Cash Compensation and Capital Acquisition Broker Rules in Response to Regulation Best Interest; SEC: Proposed Rule Change to Add a New Discretionary Limit Order Type Called D-Limit; SEC: Proposed Rule Change to Align Certain MSRB Rules to Securities and Exchange Act Rule 15l-1, Regulation Best Interest; SEC: Proposed Rule Change on Form 13F Reporting Threshold for Institutional Investment Managers; development of an international insurance capital standard by the International Association of Insurance Supervisors; development of a new program to replace revenue due to business interruption or event cancelation; International Organization of Securities Commissions (IOSCO) consultation on leverage metrics; potential legislation dealing with third party litigation financing and lawsuit lending

Treatment of credit rating agencies in Federal Reserve emergency credit facilities (H.R. 6934); other federal policy issues related to NRSROs.

Client expense: Not reported · Firm income: $60,000

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

H.R. 56, Financial Technology Protection Act H.R. 87, Midnight Rules Relief Act of 2019 H.R. 189, Financial Institution Customer Protection Act of 2019 H.R. 758, Cooperate with Law Enforcement Agencies and Watch Act of 2019 H.R. 969, TABS Act of 2019 H.R. 1018, Improving Corporate Governance Through Diversity Act of 2019 H.R. 1731, Cybersecurity Disclosure Act of 2019 H.R. 1815, SEC Disclosure Effectiveness Testing Act H.R. 2144, Token Taxonomy Act of 2019 H.R. 2154, Digital Taxonomy Act of 2019 H.R. 2409, Expanding Access to Capital for Rural Job Creators Act H.R. 2515, Whistleblower Protection Reform Act of 2019 H.R. 2534, Insider Trading Prohibition Act H.R. 2919, Improving Investment Research for Small and Emerging Issuers Act H.R. 3050, Expanding Investment in Small Businesses Act of 2019 H.R. 3279, Diversity in Corporate Leadership Act of 2019 H.R. 3351, Financial Services and General Government Appropriations Act, 2020 H.R. 3355, Reward Work Act H.R. 3614, Restricting Credit Checks for Employment Decisions Act H.R. 3618, Free Credit Scores for Consumers Act of 2019 H.R. 3621, Student Borrower Credit Improvement Act H.R. 3622, Restoring Unfairly Impaired Credit and Protecting Consumers Act H.R. 3623/ S. 2075, Climate Risk Disclosure Act of 2019 H.R. 3624 Outsourcing Accountability Act of 2019 H.R. 3625, PCAOB Whistleblower Protection Act of 2019 H.R. 3629, Clarity in Credit Score Formation Act of 2019 H.R. 3641/S. 1854, Stronger Enforcement of Civil Penalties Act of 2019 H.R. 3642, Improving Credit Reporting for All Consumers Act H.R. 3848/S. 2155, Stop Wall Street Looting Act H.R. 3987, Alleviating Stress Test Burdens to Help Investors Act H.R. 4242, Greater Accountability in Pay Act of 2019 H.R. 4320, Corporate Management Accountability Act of 2019 H.R. 4329, ESG Disclosure Simplification Act of 2019 H.R. 4335, 8-K Trading Gap Act of 2019 H.R. 4344, To amend the Securities Exchange Act of 1934 to allow the Securities and Exchange Commission to seek and Federal courts to grant disgorgement of unjust enrichment, and for other purposes H.R. 4492/S733, Consumer Financial Choice and Capital Markets Protection Act of 2019 H.R. 4726, Certainty for End-Users Act H.R. 4805, Access Business Credit Act of 2019 H.R. 4918, Helping Startups Continue to Grow Act H.R. 5013, Small Business Fair Debt Collection Protection Act H.R. 5084, Improving Corporate Governance Through Diversity Act of 2019 H.R. 5332, Protecting Your Credit Score Act of 2019 H.R. 5494, Catastrophe Loss Mitigation Incentive and Tax Parity Act of 2019 H.R. 5929, Shareholder Political Transparency Act of 2020 H.R. 5930, Workforce Investment Disclosure Act of 2020 H.R. 6116, Consumer Financial Protection Commission Act H.R. 6371, To amend the Securities Exchange Act of 1934 to require issuers to disclose risks related to global pandemics, and for other purposes H.R. 6375, To amend the Securities Exchange Act of 1934 to require issuers to make disclosures related to supply chain disruption risk, and for other purposes H.R. 6551, CARES Act Section 4014 Technical Corrections Act H.R. 6790, Business Borrowers Protection Act H.R. 6934, To amend the CARES Act to require the uniform treatment of nationally recognized statistical rating organizations under certain programs carried out in response to the COVID-19 emergency, and for other purposes H.R. 7000, Holding Foreign Companies Accountable Act S. 452, Fostering Innovation Act of 2019 S. 566, Expanding Access to Capital for Rural Job Creators Act S. 603, Financial Stability Oversight Council Improvement Act of 2019 S. 1256, PCAOB Enforcement Transparency Act of 2019 S. 1731, Ensuring Quality Information and Transparency for Abroad-Based Listings on our Exchanges (EQUITABLE) Act S. 2391, Stock Buyback Reform and Worker Dividend Act of 2019 S. 2563, Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings (ILLICIT CASH) Act S. 3548, Coronavirus Aid, Relief, and Economic Security (CARES) Act S. 3990, A bill to amend the Consumer Financial Protection Act of 2010 to make the Bureau of Consumer Financial Protection an independent Financial Product Safety Commission, and for other purposes Draft legislation titled Primary Market Corporate Credit Facility Draft legislation titled Rulemaking Suspension Draft legislation titled Increase Penalties for COVID-related Securities Law Violations Draft legislation titled COVID-19 Restitution Assistance Fund for Victims of Securities Violations Act Draft legislation that would extend the statute of limitations for civil penalties by the SEC Draft legislation, the Bad Actor Disqualification Act Draft legislation to require the SEC to study stock buybacks under rule 10b-18 Draft legislation titled the Diverse Asset Managers Act Draft legislation titled the Corporate Human Rights Risk Assessment, Prevention and Mitigation Act Draft legislation to provide certain financial end-users with relief from clearing and margin requirements Draft legislation relating to supplementary leverage ratio treatment of client initial margin Draft legislation to amend the Investment Advisers Act to require the SEC to establish a process to follow when it obtains source code or other sensitive information from investment advisers Draft legislation relating to the underwriting of automobile insurance Draft legislation COVID-19 Restitution Assistance Fund for Victims of Securities Violations Act Draft legislation to enhance civil penalties under the Federal securities laws for violations related to an attempt to exploit investors related to the COVID-19 crisis Draft legislation to temporarily prohibit federal financial regulators from adopting rules not directly related to responding to the coronavirus response through the length of the crisis Draft legislation to apply certain terms and conditions on making direct loans under the CARES Act to certain purchases of debt by the Federal Government, and for other purposes Potential legislation to require the SEC to complete rulemaking required by section 10D of the Securities Exchange Act of 1934 Potential legislation to require the SEC to complete rulemaking required by section 14(i) of the Securities Exchange Act of 1934 Proposed rule on auditor independence with respect to certain loans or debtor-creditor relationships (83 Fed. Reg. 20,753-20,773, May 8, 2018) Proposed regulation on Regulation Best Interest (83 Fed. Reg. 21,574-21,682, May 9, 2018) Proposed Commission interpretation regarding standard of conduct for investment advisers; request for comment on enhancing investment (83 Fed. Reg. 21,203-21,214, May 9, 2018) Proposed rule on form CRS relationship summary; amendments to form ADV; required disclosures in retail communications and restrictions on the use of certain names or titles (83 Fed. Reg. 21,416-21,575, May 9, 2018) Policy to Encourage Trial Disclosure Programs (83 Fed. Reg. 45,574-45,578, September 10, 2018) Proposed changes to applicability thresholds for regulatory capital and liquidity requirements (83 Fed. Reg. 66,024-66,059, December 21, 2018) Proposed rule on prudential standards for large bank holding companies and savings and loan holding companies (83 Fed. Reg. 61,408-61,460, November 29, 2018) Proposed rule regarding standardized approach for calculating the exposure amount of derivative Contracts (83 Fed. Reg. 64,660-64,728, December 17, 2018) Proposed rule on payday, vehicle title, and certain high-cost installment loans; delay of compliance date (84 Fed. Reg. 4,298-4,305, February 14, 2019) Proposed rule on self-regulatory organizations; Financial Industry Regulatory Authority, Inc.; notice of filing of a proposed rule change to establish a corporate bond new issue reference data service (84 Fed. Reg. 13,977-13,983, April 8, 2019) Proposed rule to exemptions from the proxy rules for proxy voting advice (84 Fed. Reg. 66,518-66,559, December 4, 2019) Proposed rule on procedural requirements and resubmission thresholds under Exchange Act Rule 14a-8 (84 Fed. Reg. 66,458-66,515, December 4, 2019) Proposed rule on modernization of Regulation S-K Items 101, 103, and 105 (84 Fed. Reg. 44,358-44,390, August 23, 2019) Proposed rule on regarding margin and capital requirements for covered swap entities (84 Fed. Reg. 59,970-59,989, November 7, 2019) Proposed rule for amendments to Rule 2-01, qualifications of accountants (85 Fed. Reg. 2,332-2,354, January 15, 2020) Proposed rule amending the accredited investor definition (85 Fed. Reg. 2,574-2,613, January 15, 2020) Proposed rule on disclosure of payments by resource extraction issuers (85 Fed. Reg. 2,522-2,571, January 15, 2020) Electronic consent based Social Security number verification (84 Fed. Reg. 66,704-66,705, December 5, 2019) Proposed rule on permissible interest on loans that are sold, assigned, or otherwise transferred (84 Fed. Reg. 64,229-64,232, November 21, 2019) Proposed rule on remittance transfers under the Electronic Fund Transfer Act (Regulation E) (84 Fed. Reg. 67,132-67,167, December 6, 2019) Request for information regarding the integrated mortgage disclosures under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z) rule assessment (84 Fed. Reg. 64,436-64,441, November 22, 2019) Various issues relating CFPB regulatory sandbox for disclosures; Securities Exchange Commission strategic plan; Securities Exchange Commission Rule 701 Form S-8 reforms; Securities Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; Public Company Accounting Oversight Board (PCAOB); potential legislation related to the rulemaking and enforcement authority of Sec. 619 of the Dodd-Frank Act (P.L.111-203); beneficial ownership; reforms to the Committee on Foreign Investment in the United States; modernization of the Community Reinvestment Act (P.L. 95-128); implementation of the John S. McCain National Defense Authorization Act for Fiscal Year 2019, Title XVII, Foreign Investment Risk Review Modernization Act (P.L. 115-232), including provisions relating to sections 1654 and 1655; application of Customer Identification Program requirements under anti-money laundering rules to bank-affiliated premium finance companies; application of the May 2016 Customer Due Diligence Rule to routine cash refunds issued by bank-affiliated premium finance companies; proposals to audit the Board of Governors of the Federal Reserve System; Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTC Proposed rulemaking on the De Minimis Exception to the Swap Dealer Definition; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; comment on fund of funds arrangements; interest rate restrictions; margin and capital requirements for covered swap entities; Office of the Comptroller of the Currency (OCC) Innovation Pilot Program; debt collection practices (regulation F) under the Fair Debt Collection Act (P.L. 95-109); implementation of section 215 of the Economic Growth Regulatory Relief and Consumer Protection Act (P.L. 115-174); CFPB policy on no-action letters and compliance assistance sandbox policy; qualified mortgage definition under the Truth and Lending Act (P.L. 90-321) regulation Z; Financial Stability Oversight Council and the designation of nonbank financial firms as systemically important; Federal Reserve System and large institution supervision coordinating committee; updated disclosure requirements and summary prospectus for variable annuity and variable life insurance contracts; amendments to the accelerated filer and large accelerated filer definitions; potential housing finance reform legislation; enforcement of Securities Exchange Commission penalties; order instituting proceedings to determine whether to approve or disapprove a proposed rule change to establish a corporate bond new issue reference data service; comments on modernization of regulation S-K Items 101, 103 and 105 17 CFR Parts 229, 239 and 240; comments on bond reference data proposal; comment period extension request for regulatory capital rules: risk based capital requirements for depository institution holding companies significantly engaged in insurance activities; comments on proposed rule change to introduce a liquidity provider protection on Cboe EDGA; inter-affiliate initial margin relief; substituted compliance and equivalence between the U.S. derivatives regulatory regime and the European Unions European Market Infrastructure Regulation (EMIR); European Supervisory Authority review and provisions regarding portfolio delegation; EU third country equivalency process; EU sustainable finance and incorporating ESG factors into financial services; EU solvency II review; EU review of prudential regime for investment firms; Brexit risks; SEC concept release on harmonization of securities offering exemptions; SEC digital assets; transition from London Interbank Offered Rate (LIBOR) to Secured Overnight Financing Rate (SOFR); Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), valid when made doctrine; Department of Labor Field Assistance Bulletin No. 2018-01 regarding compliance with Interpretive Bulletin 2016-01 and 2015-01; Incentive based executive compensation regulation under Dodd-Frank Section 956; potential repeal of the State and Local Tax (SALT) cap; amending the accredited investor definition; amendments to exemptions from the proxy rules for proxy voting advice; disclosure of payments by resource extraction issuers; PCAOB concept release on potential approach to revisions to PCAOB quality control standards; procedural requirements and resubmission thresholds under Exchange Act Rule 14a-8; proposed amendments to Rule 2-01, qualifications of accountants; proposed revisions to prohibitions and restrictions on proprietary trading and certain interests in, and relationships with, hedge funds and private equity funds; regulatory capital rules: risk-based capital requirements for depository institution holding companies significantly engaged in insurance activities; revised draft eCBSV user agreement and related materials; credit risk retention-notice of commencement of review; issues relating to federal interest rate authority; comments on margin requirements for non-centrally cleared swaps margin - impact of COVID-19 on initial margin phase-in; issues relating to potential closing of the financial markets in response to the coronavirus pandemic; Main Street New Loan Facility and Main Street Expanded Loan Facility; Managements Discussion and Analysis, Selected Financial Data, and Supplementary Financial Information; Securities and Exchange Commission Fixed Income Market Structure Advisory Committee; Federal Deposit Insurance Corporation: Unsafe and Unsound Banking Practices: Brokered Deposits; Furthering Economic Stabilization by Encouraging Financial Institutions to Work Constructively with All Borrowers Affected by COVID-19; Liquidity Programs Coronavirus; PCAOB Request for Comment: Interim Analysis of Critical Audit Matter Requirements; Proposed Rule Change to Add a New Discretionary Limit Order Type Called D-Limit; Proposed Rule Change to Align Certain MSRB Rules to Securities and Exchange Act Rule 15l-1, Regulation Best Interest; Proposed Rule Change to FINRAs Suitability, Non-Cash Compensation, and Capital Acquisition Broker Rules in Response to Regulation Best Interest; Federal Reserve Board request for public feedback proposal to expand its Main Street Lending Program to provide access to credit for nonprofit organizations; Regulatory Capital Rule: Revised Transition of the Current Expected Credit Losses (CECL) Methodology for Allowances; Request for Further Clarifications and Modifications to Risk-Based Guidance; RFI to Assist the Taskforce on Federal Consumer Financial Law-CFPB; Sec. 171 DFA Collins Amendment; Use of Derivatives by Registered Investment Companies and Business Development Companies; Required Due Diligence by Broker-Dealers and Registered Investment Advisers Regarding Retail Customers Transactions in Certain Leveraged/Inverse Investment Vehicles; Federal Reserve and Treasury to Establish a Short Term Receivable Facility (Fed 13(3) Facility Accounts Receivable); Housing and Urban Development implementation of the Fair Housing Acts disparate impact standard; FDIC notice of proposed rulemaking on interest rate restrictions on institutions that are less than well capitalized; federal regulatory capital rules: risk-based capital requirements for depository institution holding companies significantly engaged in insurance activities; proposed revisions to prohibitions and restrictions on proprietary trading and certain interests in, and relationships with, hedge funds and private equity funds; FDIC, incorporation of existing statement of policy regarding requests for participation in the affairs of an insured depository institution by convicted individuals; SEC: Proposed Rule Change to FINRAs Suitability, Non-Cash Compensation and Capital Acquisition Broker Rules in Response to Regulation Best Interest; SEC: Proposed Rule Change to Add a New Discretionary Limit Order Type Called D-Limit; SEC: Proposed Rule Change to Align Certain MSRB Rules to Securities and Exchange Act Rule 15l-1, Regulation Best Interest; development of an insurance capital standard by the International Association of Insurance Supervisors; International Organization of Securities Commissions (IOSCO) consultation on leverage metrics; utility liquidity issues resulting from the pandemic

Treatment of credit rating agencies in Federal Reserve emergency credit facilities (H.R. 6934)

Client expense: Not reported · Firm income: $60,000

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