Financial Exploitation Prevention Act of 2021

Self-Regulatory Organization (SRO) Reform; H.R. 2265 - the Financial Exploitation Prevention Act of 2021; SEC Securities Lending Proposal; H.R. ____ - to amend the Securities Exchange Act of 1934 to add certain requirements for the filing and approval of proposed rule changes by self-regulatory organizations; H.R. ____ - the "Securities Exchange Reform Act of 2022" (Rep Sherman); H.R. 2288 - to amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds; H.R. 2634 - Local Infrastructure Financing Tools Act; S. 1676 - Rural Broadband Financing Flexibility Act; S. 1308 - American Infrastructure Bonds Act of 2021; H.R. 2954 - Securing a Strong Retirement Act of 2021; S. 1770 - Retirement Security and Savings Act of 2021; S. 1443/H.R. 2917 - Retirement Parity for Student Loans Act; H.R. ____ - Capital Markets Transparency Act; H.R. ____ - to amend the Securities Exchange Act of 1934 to establish certain requirements with respect to retail investor options trading; H.R. ____ - to amend the Securities Exchange Act of 1934 to prohibit payment for order flow in the form of exchange rebates; H.R. 4617 - To require the SEC to carry out a study on PFOF, to require the Investor Advocate of the Commission to provide recommendations on PFOF, and for other purposes; H.R. 4618 - the Short Sale Transparency and Market Fairness Act of 2021; H.R. 4619 - to amend the Securities Exchange Act of 1934 to prohibit trading ahead by market makers, and for other purposes; S. 4147 - Financial Freedom Act of 2022; Cyber incident notification issues; S. 1854 and H.R. 6323 - The National Critical Capabilities Defense Act; Electronic delivery of retail investor's SEC-required disclosures.

Client expense: $920,000 · Firm income: Not reported

Government targets: Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

ISSUE Investment Advice Standard of Conduct HR 699, Mutual Fund Litigation Reform Act - amend the Investment Company Act of 1940 to provide complaint and burden of proof requirements for certain actions for breach of fiduciary duty HR 725/S 153, Personalized Care Act - amend the Internal Revenue Code of 1986 to expand and improve health savings accounts, and for other purposes. HR 984, Retirement Inflation Protection Act - allows the basis of certain assets to be adjusted for inflation solely for the purpose of determining the gain or loss. S 380, Health Savings Act - modifies the requirements for health savings accounts (HSAs). HR 1584, Protecting Retirement Savers and Everyday Investors Act - impose a limitation on taxation and fees on transactions by certain securities industry participants. HR 1618/S 606, RESPOND Act - require the FRB and SEC to issue an annual report on the economic costs caused by the impacts of climate change, to require the Federal Retirement Thrift Investment Board to establish a Federal Advisory Panel on the Economics of Climate Change. S 1443Retirement Parity for Student Loans Act -- allows certain employer-sponsored retirement plans to make matching contributions for an employee's student loan payments HR 2951 To direct the Secretary of the Treasury to modify Treasury Regulations relating to insurance-dedicated exchange-traded funds - enables ETFs as investment option in variable insurance products HR 2944 Reducing the Maximum Service Requirement for Long-term Part-time Workers to Make Elective Deferrals to 401(k) Plans Act -- to reduce the retirement plan period of service requirements for long-term, part-time employees. S 1703Improving Access to Retirement Savings Act of 2021 -- to increase retirement savings, to improve retirement plan administration, and for other purposes. S 1770Retirement Security & Savings Act -- to increase retirement savings, to improve retirement plan administration, and for other purposes. HR 3387/S 1762 Financial Factors in Selecting Retirement Plan Investment Act -- to permit retirement plans to consider certain factors in investment decisions. S 1272SIMPLE Plan Modernization Act -- increases the contribution limits for certain SIMPLE IRAs and modifies the requirements for replacing SIMPLE IRAs with 401(k) plans. HR 2741 Public Service Retirement Fairness Act -- To modify rules relating to 403(b) plans. HR 4262 Increasing Investor Opportunities Act - To amend the Investment Company Act of 1940 to prohibit limitations on closed-end companies investing in private funds S 2206Young American Savers Act of 2021 - directs the Department of the Treasury to establish as a permanent program the Federal Child Savings Account Program HR 4289 Well-Being Insurance for Seniors to be at Home (WISH) Act - to provide for long-term care insurance benefits HR 2913/S 2452 Encouraging Americans to Save Act - to provide matching payments for retirement savings and establish MyRA HR 4678/S 2446 Womens Retirement Protection Act of 2021 - to provide for greater spousal protection under defined contribution plans HR 5334/S 2870 Portable Retirement and Investment Account (PRIA) Act of 2021 - to establish portable retirement accounts S 2602,Retirement Security Flexibility Act of 2021 - modifies the nondiscrimination requirements that apply to certain employer-sponsored 401(k) retirement plans that include automatic contribution arrangements HR 2265, Financial Exploitation Prevention Act - allows for the delay of the redemption of a security issued by an open-end investment management company if the company or transfer agent reasonably believes the redemption involves the financial exploitation HR 5723, Social Security 2100 Act: A Sacred Trust - protect our Social Security system and improve benefits for current and future generations HR 4865/S 3198, Registration for Index Linked Annuities (RILA) Act - direct SEC to revise any rules necessary to enable issuers of index-linked annuities to register on a form tailored specifically to registered index-linked annuities S 2583 Disaster Retirement Savings Act - amend the Internal Revenue Code of 1986 to provide for rules for the use of retirement funds in connection with federally declared disasters. S 2601Strengthening Financial Security Through Short-Term Savings Accounts Act of 2021 -- allows employers to enroll employees in short-term savings accounts that are funded using automatic contributions deducted from participating employees' wages. HR 6746 Lifetime Income for Employees Act -- allows fiduciaries of pension plans to make default investment arrangements in annuity contracts HR 6782/S 3712 Auto Reenroll Act of 2022 -- allows sponsors of automatic contribution arrangements to reenroll their employees HR 5877/S 3746 Pension Risk Transfer Accountability Act of 2021 -- requires the Department of Labor to review pension risk transfer standards HR 6912 Pooled Employer Plan (PEP) Fix Act -- to require that named fiduciaries collect contributions to pooled employer plans HR 7107/S 2415 Long-Term Care Affordability Act -- allows the use of tax-exempt retirement plan distributions to pay for long-term health care insurance HR 7146/S 1870 Enhancing Emergency and Retirement Savings Act of 2022 -- permits penalty-free distributions, up to $1,000, from tax-exempt retirement plans for emergency personal expenses, limited to one distribution in a calendar year HR 2954 Securing a Strong Retirement of 2022 -- makes various changes with respect to employer-sponsored retirement plans, including providing for the automatic enrollment of employees in certain plans and increasing the age at which participants are required to begin receiving mandatory distributions. HR 7310, Protecting America's Retirement Security Act -- To protect Americas retirement security S 3955, Starter-K Act of 2022 -- allows employers who do not provide a retirement plan to establish a starter 401(k) deferral-only arrangement for plan years beginning after 2022 HR 7284, Informed Savers Act -- requires the Department of Labor to review the fee disclosure requirements associated with the administration of defined contribution retirement plans S 4086,Increasing Small Business Retirement Choices Act -- amend the Employee Retirement Income Security Act of 1974 to better enable plan sponsors to implement beneficial plan features S 4087, Information Needed for Financial Options Risk Mitigation (INFORM) Act -- require pension plans that offer participants and beneficiaries the option of receiving lifetime annuity payments as lump sum payments, to meet certain notice and disclosure requirements S 4103, Helping Parents Save for College Act of 2022 -- allows a retirement savings tax credit for contributions to any qualified tuition program (e.g., a 529 qualified tuition plan). It also permits a rollover of unused contributions to a ROTH IRA savings account S 4147, Financial Freedom Act -- prohibit the Secretary of Labor from constraining the range or type of investments that may be offered in individual retirement accounts S 4154, Simplifying Small Business Retirement Savings Act -- provide better access to retirement plans through small businesses S 4153, Incentivizing Small Business Retirement Savings Act -- allows eligible small employers an additional pension plan startup cost tax credit HR 7740/S 4219, Employee and Retiree Access to Justice Act - limit mandatory arbitration agreements under ERISA ISSUE, Davis-Bacon Benefits Proposed Rule DOL S 4241, INDEX Act -- to require investment advisers for passively managed funds to arrange for pass-through voting of proxies HR 7594/S 4097, Too Narrow to Succeed Act - instruct DOL to conduct a survey of best practices for increasing the diversity of the asset management firms that invest American workers retirement plan funds S 4310, Emergency Savings Act of 2022 -- allow employers to offer pension-linked emergency savings accounts for financial emergencies S 4353, RISE and SHINE Act -- amend the Employee Retirement Income Security Act of 1974 and the Internal Revenue Code of 1986 to improve retirement plan provisions S 4361, Savvy Savers Act -- require reports to Congress on reporting and disclosure requirements related to retirement plans S 4406,Advancing Auto Portability Act -- to provide incentives for the use of automatic portability arrangements under defined contribution plans S 4102 SSI Savings Penalty Elimination Act - increases resource limits used to determine eligibility for the Supplemental Security Income (SSI) program HR 8521/S 4241 INDEX Act - guidelines for passively managed funds (e.g., index funds) that vote shares on behalf of fund investors in proxy shareholder votes S 4613 Maximize Americans Retirement Security Act - clarify the fiduciary duty of plan administrators to select and maintain investments based solely on pecuniary factors HR 8579 Retirement Protection Act of 2022 - increase retirement savings, simplify and clarify retirement plan rules S 4808 EARN Act - to reform retirement provisions

Equity market structure issues; Self-Regulatory Organization (SRO) Reform; SEC Rule 15c2-11; H.R. 2265 - the Financial Exploitation Prevention Act of 2021; SEC Securities Lending Proposal; H.R. ____ - to amend the Securities Exchange Act of 1934 to add certain requirements for the filing and approval of proposed rule changes by self-regulatory organizations; H.R. ____ - the "Securities Exchange Reform Act of 2022" (Rep Sherman); SEC short comment periods; H.R. 2288 - to amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds; H.R. 2634 - Local Infrastructure Financing Tools Act; S. 1676 - Rural Broadband Financing Flexibility Act; S. 1308 - American Infrastructure Bonds Act of 2021; H.R. 2954 - Securing a Strong Retirement Act of 2021; S. 1770 - Retirement Security and Savings Act of 2021; S. 1443/H.R. 2917 - Retirement Parity for Student Loans Act; H.R. ____ - Capital Markets Transparency Act; H.R. ____ - to amend the Securities Exchange Act of 1934 to establish certain requirements with respect to retail investor options trading; H.R. ____ - to amend the Securities Exchange Act of 1934 to prohibit payment for order flow in the form of exchange rebates; H.R. 4617 - To require the SEC to carry out a study on PFOF, to require the Investor Advocate of the Commission to provide recommendations on PFOF, and for other purposes; H.R. 4618 - the Short Sale Transparency and Market Fairness Act of 2021; H.R. 4619 - to amend the Securities Exchange Act of 1934 to prohibit trading ahead by market makers, and for other purposes; SEC Staff Accounting Bulletin 121 - SEC, House & Senate; S. 4147 - Financial Freedom Act of 2022.

Client expense: $1,860,000 · Firm income: Not reported

H.R. 699- Mutual Fund Litigation Reform Act (Emmer) H.R. 1277- Improving Corporate Governance Through Diversity Act of 2021 (Meeks) H.R. 2123- Diversity and Inclusion Data Accountability and Transparency Act (Beatty) H.R. 2265- Financial Exploitation Prevention Act (Wagner) H.R. 3412- Alleviating Stress Test Burdens to Help Investors Act (Loudermilk) H.R. 3899- Financial Stability Oversight Council Improvement Act (Foster) H.R. 4262- Increasing Investor Opportunities Act (Gonzalez) H.R. 7066- Russia and Belarus Financial Sanctions Act (Sherman) H.R. 7151- Ensuring Sound Guidance Act (Barr) S. 374- Improving Corporate Governance Through Diversity Act of 2021 (Menendez) S. 2684- Consumer Financial Choice and Capital Markets Protection Act of 2021 (Toomey) S. 3919- Reporting Requirements Reduction Act of 2022 (Tillis) S. 3945- Restoring Shareholder Transparency Act of 2022 (Haggerty) S. 3948- Increasing Investor Opportunities Act (Daines) S. 3961- Access to Small Business Investor Capital Act (Daines) S. 3965- Increasing Access to Adviser Information Act (Moran) S. 4241- INvestor Democracy is EXpected (INDEX) Act (Sullivan) Diverse Investment Advisers Act (draft) Diversity and Inclusion in the Asset Management Industry Improving Disclosure for Investors Act (draft) Length of comment period for SEC proposals Processing fees for delivering investment materials Russia Sanctions/Executive Orders SEC data security/Consolidated Audit Trail breach notification SEC money market fund proposal SEC proposed amendments to the Fund Names Rule SEC proposed Investment Adviser and Fund Disclosures about ESG Investment Practices SEC public company climate disclosure proposal

Client expense: $1,010,000 · Firm income: Not reported

ISSUE Investment Advice Standard of Conduct HR 699, Mutual Fund Litigation Reform Act - amend the Investment Company Act of 1940 to provide complaint and burden of proof requirements for certain actions for breach of fiduciary duty HR 725/S 153, Personalized Care Act - amend the Internal Revenue Code of 1986 to expand and improve health savings accounts, and for other purposes. HR 984, Retirement Inflation Protection Act - allows the basis of certain assets to be adjusted for inflation solely for the purpose of determining the gain or loss. S 380, Health Savings Act - modifies the requirements for health savings accounts (HSAs). HR 1584, Protecting Retirement Savers and Everyday Investors Act - impose a limitation on taxation and fees on transactions by certain securities industry participants. HR 1618/S 606, RESPOND Act - require the FRB and SEC to issue an annual report on the economic costs caused by the impacts of climate change, to require the Federal Retirement Thrift Investment Board to establish a Federal Advisory Panel on the Economics of Climate Change. S 1443Retirement Parity for Student Loans Act -- allows certain employer-sponsored retirement plans to make matching contributions for an employee's student loan payments HR 2951 To direct the Secretary of the Treasury to modify Treasury Regulations relating to insurance-dedicated exchange-traded funds - enables ETFs as investment option in variable insurance products HR 2944 Reducing the Maximum Service Requirement for Long-term Part-time Workers to Make Elective Deferrals to 401(k) Plans Act -- to reduce the retirement plan period of service requirements for long-term, part-time employees. S 1703Improving Access to Retirement Savings Act of 2021 -- to increase retirement savings, to improve retirement plan administration, and for other purposes. S 1770Retirement Security & Savings Act -- to increase retirement savings, to improve retirement plan administration, and for other purposes. HR 3387/S 1762 Financial Factors in Selecting Retirement Plan Investment Act -- to permit retirement plans to consider certain factors in investment decisions. S 1272SIMPLE Plan Modernization Act -- increases the contribution limits for certain SIMPLE IRAs and modifies the requirements for replacing SIMPLE IRAs with 401(k) plans. HR 2741 Public Service Retirement Fairness Act -- To modify rules relating to 403(b) plans. HR 4262 Increasing Investor Opportunities Act - To amend the Investment Company Act of 1940 to prohibit limitations on closed-end companies investing in private funds S 2206Young American Savers Act of 2021 - directs the Department of the Treasury to establish as a permanent program the Federal Child Savings Account Program HR 4289 Well-Being Insurance for Seniors to be at Home (WISH) Act - to provide for long-term care insurance benefits HR 2913/S 2452 Encouraging Americans to Save Act - to provide matching payments for retirement savings and establish MyRA HR 4678/S 2446 Womens Retirement Protection Act of 2021 - to provide for greater spousal protection under defined contribution plans HR 5334/S 2870 Portable Retirement and Investment Account (PRIA) Act of 2021 - to establish portable retirement accounts S 2602,Retirement Security Flexibility Act of 2021 - modifies the nondiscrimination requirements that apply to certain employer-sponsored 401(k) retirement plans that include automatic contribution arrangements HR 2265, Financial Exploitation Prevention Act - allows for the delay of the redemption of a security issued by an open-end investment management company if the company or transfer agent reasonably believes the redemption involves the financial exploitation HR 5723, Social Security 2100 Act: A Sacred Trust - protect our Social Security system and improve benefits for current and future generations HR 5891, Retirement Improvement and Savings Enhancement (RISE) Act - to improve and enhance retirement savings HR 4865/S 3198, Registration for Index Linked Annuities (RILA) Act - direct SEC to revise any rules necessary to enable issuers of index-linked annuities to register on a form tailored specifically to registered index-linked annuities S 2583 Disaster Retirement Savings Act - amend the Internal Revenue Code of 1986 to provide for rules for the use of retirement funds in connection with federally declared disasters. S 2601Strengthening Financial Security Through Short-Term Savings Accounts Act of 2021 -- allows employers to enroll employees in short-term savings accounts that are funded using automatic contributions deducted from participating employees' wages. HR 6746 Lifetime Income for Employees Act -- allows fiduciaries of pension plans to make default investment arrangements in annuity contracts HR 6782/S 3712 Auto Reenroll Act of 2022 -- allows sponsors of automatic contribution arrangements to reenroll their employees HR 5877/S 3746 Pension Risk Transfer Accountability Act of 2021 -- requires the Department of Labor to review pension risk transfer standards HR 6912 Pooled Employer Plan (PEP) Fix Act -- to require that named fiduciaries collect contributions to pooled employer plans HR 7107/S 2415 Long-Term Care Affordability Act -- allows the use of tax-exempt retirement plan distributions to pay for long-term health care insurance HR 7146/S 1870 Enhancing Emergency and Retirement Savings Act of 2022 -- permits penalty-free distributions, up to $1,000, from tax-exempt retirement plans for emergency personal expenses, limited to one distribution in a calendar year HR 2954 Securing a Strong Retirement of 2022 -- makes various changes with respect to employer-sponsored retirement plans, including providing for the automatic enrollment of employees in certain plans and increasing the age at which participants are required to begin receiving mandatory distributions. HR 7310, Protecting America's Retirement Security Act -- To protect Americas retirement security S 3955, Starter-K Act of 2022 -- allows employers who do not provide a retirement plan to establish a starter 401(k) deferral-only arrangement for plan years beginning after 2022 HR 7284, Informed Savers Act -- requires the Department of Labor to review the fee disclosure requirements associated with the administration of defined contribution retirement plans S 4086,Increasing Small Business Retirement Choices Act -- amend the Employee Retirement Income Security Act of 1974 to better enable plan sponsors to implement beneficial plan features S 4087, Information Needed for Financial Options Risk Mitigation (INFORM) Act -- require pension plans that offer participants and beneficiaries the option of receiving lifetime annuity payments as lump sum payments, to meet certain notice and disclosure requirements S 4103, Helping Parents Save for College Act of 2022 -- allows a retirement savings tax credit for contributions to any qualified tuition program (e.g., a 529 qualified tuition plan). It also permits a rollover of unused contributions to a ROTH IRA savings account S 4147, Financial Freedom Act -- prohibit the Secretary of Labor from constraining the range or type of investments that may be offered in individual retirement accounts S 4154, Simplifying Small Business Retirement Savings Act -- provide better access to retirement plans through small businesses S 4153, Incentivizing Small Business Retirement Savings Act -- allows eligible small employers an additional pension plan startup cost tax credit HR 7740/S 4219, Employee and Retiree Access to Justice Act - limit mandatory arbitration agreements under ERISA ISSUE, Davis-Bacon Benefits Proposed Rule DOL S 4241, INDEX Act -- to require investment advisers for passively managed funds to arrange for pass-through voting of proxies HR 7594/S 4097, Too Narrow to Succeed Act - instruct DOL to conduct a survey of best practices for increasing the diversity of the asset management firms that invest American workers retirement plan funds S 4310, Emergency Savings Act of 2022 -- allow employers to offer pension-linked emergency savings accounts for financial emergencies S 4353, RISE and SHINE Act -- amend the Employee Retirement Income Security Act of 1974 and the Internal Revenue Code of 1986 to improve retirement plan provisions S 4361, Savvy Savers Act -- require reports to Congress on reporting and disclosure requirements related to retirement plans DRAFT, Enhancing American Retirement Now (EARN) Act - to improve retirement security S 4406,Advancing Auto Portability Act -- to provide incentives for the use of automatic portability arrangements under defined contribution plans

Equity market structure issues; Self-Regulatory Organization (SRO) Reform; SEC Rule 15c2-11; H.R. 2265 - the Financial Exploitation Prevention Act of 2021; SEC Securities Lending Proposal; H.R. ____ - to amend the Securities Exchange Act of 1934 to add certain requirements for the filing and approval of proposed rule changes by self-regulatory organizations; H.R. ____ - the "Securities Exchange Reform Act of 2022" (Rep Sherman); SEC short comment periods; H.R. 4616 - The Adjustable Interest Rate (LIBOR) Act of 2021; S. 479 - LOCAL Infrastructure Act; H.R. 2288 - to amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds; H.R. 2634 - Local Infrastructure Financing Tools Act; S. 1676 - Rural Broadband Financing Flexibility Act; S. 1308 - American Infrastructure Bonds Act of 2021; H.R. 2954 - Securing a Strong Retirement Act of 2021; S. 1770 - Retirement Security and Savings Act of 2021; S. 1443/H.R. 2917 - Retirement Parity for Student Loans Act; H.R. ____ - Capital Markets Transparency Act; H.R. ____ - to amend the Securities Exchange Act of 1934 to establish certain requirements with respect to retail investor options trading; H.R. ____ - to amend the Securities Exchange Act of 1934 to prohibit payment for order flow in the form of exchange rebates; H.R. 4617 - To require the SEC to carry out a study on PFOF, to require the Investor Advocate of the Commission to provide recommendations on PFOF, and for other purposes; H.R. 935 - the Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021; H.R. 4618 - the Short Sale Transparency and Market Fairness Act of 2021; H.R. 4619 - to amend the Securities Exchange Act of 1934 to prohibit trading ahead by market makers, and for other purposes; H.R. ____ "Close the ILC Loophole Act"

Equity market structure issues; Self-Regulatory Organization (SRO) Reform; SEC Rule 15c2-11; H.R. 2265 - the Financial Exploitation Prevention Act of 2021; SEC Securities Lending Proposal; H.R. ____ - to amend the Securities Exchange Act of 1934 to add certain requirements for the filing and approval of proposed rule changes by self-regulatory organizations; H.R. ____ - the "Securities Exchange Reform Act of 2022" (Rep Sherman); SEC short comment periods; H.R. 4616 - The Adjustable Interest Rate (LIBOR) Act of 2021; S. 479 - LOCAL Infrastructure Act; H.R. 2288 - to amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds; H.R. 2634 - Local Infrastructure Financing Tools Act; S. 1676 - Rural Broadband Financing Flexibility Act; S. 1308 - American Infrastructure Bonds Act of 2021; H.R. 2954 - Securing a Strong Retirement Act of 2021; S. 1770 - Retirement Security and Savings Act of 2021; S. 1443/H.R. 2917 - Retirement Parity for Student Loans Act; H.R. ____ - Capital Markets Transparency Act; H.R. ____ - to amend the Securities Exchange Act of 1934 to establish certain requirements with respect to retail investor options trading; H.R. ____ - to amend the Securities Exchange Act of 1934 to prohibit payment for order flow in the form of exchange rebates; H.R. 4617 - To require the SEC to carry out a study on PFOF, to require the Investor Advocate of the Commission to provide recommendations on PFOF, and for other purposes; H.R. 935 - the Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021; H.R. 4618 - the Short Sale Transparency and Market Fairness Act of 2021; H.R. 4619 - to amend the Securities Exchange Act of 1934 to prohibit trading ahead by market makers, and for other purposes; H.R. ____ "Close the ILC Loophole Act"

H.R. 699- Mutual Fund Litigation Reform Act (Emmer) H.R. 1277- Improving Corporate Governance Through Diversity Act of 2021 (Meeks) H.R. 2123- Diversity and Inclusion Data Accountability and Transparency Act (Beatty) H.R. 2265- Financial Exploitation Prevention Act (Wagner) H.R. 3412- Alleviating Stress Test Burdens to Help Investors Act (Loudermilk) H.R. 3899- Financial Stability Oversight Council Improvement Act (Foster) H.R. 4262- Increasing Investor Opportunities Act (Gonzalez) H.R. 4616- Adjustable Interest Rate (LIBOR) Act of 2021 (Sherman) H.R. 4618- Short Sale Transparency and Market Fairness Act (Waters) H.R. 6285- Accelerating Holding Foreign Companies Accountable Act (Sherman) H.R. 7066- Russia and Belarus Financial Sanctions Act (Sherman) H.R. 7151- Ensuring Sound Guidance Act (Barr) S. 374- Improving Corporate Governance Through Diversity Act of 2021 (Menendez) S. 2184- Accelerating Holding Foreign Companies Accountable Act (Kennedy) S. 2684- Consumer Financial Choice and Capital Markets Protection Act of 2021 (Toomey) S. 3779- Adjustable Interest Rate (LIBOR) Act (Tester) S. 3948- Increasing Investor Opportunities Act (Daines) Improving Disclosure for Investors Act (draft) Processing fees for delivering investment materials Consolidated Audit Trail data security/breach notification Diverse Investment Advisers Act (draft) Diversity and Inclusion in the Asset Management Industry ESG Reporting Standards Proxy Voting by Asset Managers Russia Sanctions/Executive Orders SEC public company climate disclosure proposal SEC money market fund proposal Shorten US securities settlement cycle to trade date plus one day

Client expense: $950,000 · Firm income: Not reported

ISSUE Investment Advice Standard of Conduct HR 699, Mutual Fund Litigation Reform Act - amend the Investment Company Act of 1940 to provide complaint and burden of proof requirements for certain actions for breach of fiduciary duty HR 725/S 153, Personalized Care Act - amend the Internal Revenue Code of 1986 to expand and improve health savings accounts, and for other purposes. HR 984, Retirement Inflation Protection Act - allows the basis of certain assets to be adjusted for inflation solely for the purpose of determining the gain or loss. S 380, Health Savings Act - modifies the requirements for health savings accounts (HSAs). HR 1584, Protecting Retirement Savers and Everyday Investors Act - impose a limitation on taxation and fees on transactions by certain securities industry participants. HR 1618/S 606, RESPOND Act - require the FRB and SEC to issue an annual report on the economic costs caused by the impacts of climate change, to require the Federal Retirement Thrift Investment Board to establish a Federal Advisory Panel on the Economics of Climate Change. S 1443Retirement Parity for Student Loans Act -- allows certain employer-sponsored retirement plans to make matching contributions for an employee's student loan payments HR 2951 To direct the Secretary of the Treasury to modify Treasury Regulations relating to insurance-dedicated exchange-traded funds - enables ETFs as investment option in variable insurance products HR 2944 Reducing the Maximum Service Requirement for Long-term Part-time Workers to Make Elective Deferrals to 401(k) Plans Act -- to reduce the retirement plan period of service requirements for long-term, part-time employees. S 1703Improving Access to Retirement Savings Act of 2021 -- to increase retirement savings, to improve retirement plan administration, and for other purposes. S 1770Retirement Security & Savings Act -- to increase retirement savings, to improve retirement plan administration, and for other purposes. HR 3387/S 1762 Financial Factors in Selecting Retirement Plan Investment Act -- to permit retirement plans to consider certain factors in investment decisions. S 1272SIMPLE Plan Modernization Act -- increases the contribution limits for certain SIMPLE IRAs and modifies the requirements for replacing SIMPLE IRAs with 401(k) plans. HR 2741 Public Service Retirement Fairness Act -- To modify rules relating to 403(b) plans. HR 4262 Increasing Investor Opportunities Act - To amend the Investment Company Act of 1940 to prohibit limitations on closed-end companies investing in private funds S 2206Young American Savers Act of 2021 - directs the Department of the Treasury to establish as a permanent program the Federal Child Savings Account Program HR 4289 Well-Being Insurance for Seniors to be at Home (WISH) Act - to provide for long-term care insurance benefits HR 2913/S 2452 Encouraging Americans to Save Act - to provide matching payments for retirement savings and establish MyRA HR 4678/S 2446 Womens Retirement Protection Act of 2021 - to provide for greater spousal protection under defined contribution plans HR 5334/S 2870 Portable Retirement and Investment Account (PRIA) Act of 2021 - to establish portable retirement accounts S 2602,Retirement Security Flexibility Act of 2021 - modifies the nondiscrimination requirements that apply to certain employer-sponsored 401(k) retirement plans that include automatic contribution arrangements HR 2265, Financial Exploitation Prevention Act - allows for the delay of the redemption of a security issued by an open-end investment management company if the company or transfer agent reasonably believes the redemption involves the financial exploitation HR 5723, Social Security 2100 Act: A Sacred Trust - protect our Social Security system and improve benefits for current and future generations HR 5891, Retirement Improvement and Savings Enhancement (RISE) Act - to improve and enhance retirement savings HR 4865/S 3198, Registration for Index Linked Annuities (RILA) Act - direct SEC to revise any rules necessary to enable issuers of index-linked annuities to register on a form tailored specifically to registered index-linked annuities S 2583 Disaster Retirement Savings Act - amend the Internal Revenue Code of 1986 to provide for rules for the use of retirement funds in connection with federally declared disasters. S 2601Strengthening Financial Security Through Short-Term Savings Accounts Act of 2021 -- allows employers to enroll employees in short-term savings accounts that are funded using automatic contributions deducted from participating employees' wages. HR 6746 Lifetime Income for Employees Act -- allows fiduciaries of pension plans to make default investment arrangements in annuity contracts HR 6782/S 3712 Auto Reenroll Act of 2022 -- allows sponsors of automatic contribution arrangements to reenroll their employees HR 5877/S 3746 Pension Risk Transfer Accountability Act of 2021 -- requires the Department of Labor to review pension risk transfer standards HR 6912 Pooled Employer Plan (PEP) Fix Act -- to require that named fiduciaries collect contributions to pooled employer plans DRAFT Emergency Savings Act of 2022 - to facilitate emergency savings options through employer provided accounts HR 7107/S 2415 Long-Term Care Affordability Act -- allows the use of tax-exempt retirement plan distributions to pay for long-term health care insurance HR 7146/S 1870 Enhancing Emergency and Retirement Savings Act of 2022 -- permits penalty-free distributions, up to $1,000, from tax-exempt retirement plans for emergency personal expenses, limited to one distribution in a calendar year HR 2954 Securing a Strong Retirement of 2022 -- makes various changes with respect to employer-sponsored retirement plans, including providing for the automatic enrollment of employees in certain plans and increasing the age at which participants are required to begin receiving mandatory distributions.

H.R. 699- Mutual Fund Litigation Reform Act (Emmer) H.R. 1277- Improving Corporate Governance Through Diversity Act of 2021 (Meeks) H.R. 1996- Secure and Fair Enforcement Banking Act of 2021 (Perlmutter) H.R. 2123- Diversity and Inclusion Data Accountability and Transparency Act (Beatty) H.R. 2265- Financial Exploitation Prevention Act (Wagner) H.R. 3412- Alleviating Stress Test Burdens to Help Investors Act (Loudermilk) H.R. 3899- Financial Stability Oversight Council Improvement Act (Foster) H.R. 4262- Increasing Investor Opportunities Act (Gonzalez) H.R. 4616- Adjustable Interest Rate (LIBOR) Act of 2021 (Sherman) H.R. 4618- Short Sale Transparency and Market Fairness Act (Waters) H.R. 5598- Access to Small Business Investor Capital Act (Sherman) H.R. 6285- Accelerating Holding Foreign Companies Accountable Act (Sherman) S. 374- Improving Corporate Governance Through Diversity Act of 2021 (Menendez) S. 910- Secure and Fair Enforcement Banking Act of 2021 (Merkley) S. 1605- National Defense Authorization Act for Fiscal Year 2022 S. 2184- Accelerating Holding Foreign Companies Accountable Act (Kennedy) S. 2684- Consumer Financial Choice and Capital Markets Protection Act of 2021 (Toomey) Improving Disclosure for Investors Act Processing fees for delivering investment materials Adjustable Interest Rate (LIBOR) Act (Senate draft) Consolidated Audit Trail SEC Cybersecurity and Data Protection Diverse Investment Advisers Act (House draft) Diversity and Inclusion in the Asset Management Industry Enhanced ESG Disclosure SEC's proposed money market fund reforms Shorten US securities settlement cycle to trade date plus one day Stablecoins

Client expense: $840,000 · Firm income: Not reported

H.R. 699- Mutual Fund Litigation Reform Act (Emmer) H.R. 1277- Improving Corporate Governance Through Diversity Act of 2021 (Meeks) H.R. 1996- Secure and Fair Enforcement Banking Act of 2021 (Perlmutter) H.R. 2123- Diversity and Inclusion Data Accountability and Transparency Act (Beatty) H.R. 2265- Financial Exploitation Prevention Act (Wagner) H.R. 3412- Alleviating Stress Test Burdens to Help Investors Act (Loudermilk) H.R. 3899- Financial Stability Oversight Council Improvement Act (Foster) H.R. 4262- Increasing Investor Opportunities Act (Gonzalez) H.R. 4616- Adjustable Interest Rate (LIBOR) Act of 2021 (Sherman) H.R. 4618- Short Sale Transparency and Market Fairness Act (Waters) H.R. 5598- Access to Small Business Investor Capital Act (Sherman) H.R. 6285- Accelerating Holding Foreign Companies Accountable Act (Sherman) S. 374- Improving Corporate Governance Through Diversity Act of 2021 (Menendez) S. 910- Secure and Fair Enforcement Banking Act of 2021 (Merkley) S. 1605- National Defense Authorization Act for Fiscal Year 2022 S. 2184- Accelerating Holding Foreign Companies Accountable Act (Kennedy) S. 2684- Consumer Financial Choice and Capital Markets Protection Act of 2021 (Toomey) Improving Disclosure for Investors Act Processing fees for delivering investment materials Adjustable Interest Rate (LIBOR) Act (Senate draft) Consolidated Audit Trail SEC Cybersecurity and Data Protection Diverse Investment Advisers Act (House draft) Diversity and Inclusion in the Asset Management Industry Enhanced ESG Disclosure SEC's proposed money market fund reforms Shorten US securities settlement cycle to trade date plus one day Stablecoins

Client expense: $840,000 · Firm income: Not reported

Equity market structure issues; H.R.4616 - The Adjustable Interest Rate (LIBOR) Act of 2021; SEC Final Regulation Best Interest; Federal Reserve Board and Prudential Agency Covid-19 Actions; Self-Regulatory Organization (SRO) Reform; H.R. 2923 (116th Cong.) - Inclusive Prosperity Act of 2019; Department of Labor - Proposed Rule - Independent Contractor Status Under the Fair Labor Standards Act; S. 479, LOCAL Infrastructure Act; H.R. 2288 - To amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds; H.R. 842/S. 420 - Protecting the Right to Organize Act of 2021; Increase in the bank qualified bond limit - Rep. Sewell Bill; Cryptocurrency and digital assets; H.R. 2634 - Local Infrastructure Financing Tools Act; S. 1676 - Rural Broadband Financing Flexibility Act; S. 1308 - American Infrastructure Bonds Act of 2021; H.R. 2954 - Securing a Strong Retirement Act of 2021; S. 1770 - Retirement Security and Savings Act of 2021; S. 1443/H.R. 2917 - Retirement Parity for Student Loans Act; H.R. ___ Capital Markets Transparency Act H.R.___ to amend the Securities Exchange Act of 1934 to establish certain requirements with respect to retail investor options trading. H.R. ___ to amend the Securities Exchange Act of 1934 to prohibit payment for order flow in the form of exchange rebates; S. 2407 - Cyber Incident Notification Act of 2021; SEC Rule 15c2-11; H.R. 4617 - To require the Securities and Exchange Commission to carry out a study on payment for order flow, to require the Investor Advocate of the Commission to provide recommendations on payment for order flow, and for other purposes.; H.R. 935 - the Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021; H.R. 2265 - the Financial Exploitation Prevention Act of 2021; H.R. 4618 - the Short Sale Transparency and Market Fairness Act; H.R. 4619 - To amend the Securities Exchange Act of 1934 to prohibit trading ahead by market makers, and for other purposes; H.R. ___ "Close the ILC Loophole Act"; SEC Securities Lending Proposal; Prudential Agency ESG/Climate Finance Rules and inquiries; Prudential Agency Capital and Liquidity Regulations, including Basel Implementation.

Equity market structure issues; H.R.4616 - The Adjustable Interest Rate (LIBOR) Act of 2021; SEC Final Regulation Best Interest; Federal Reserve Board and Prudential Agency Covid-19 Actions; Self-Regulatory Organization (SRO) Reform; H.R. 2923 (116th Cong.) - Inclusive Prosperity Act of 2019; Department of Labor - Proposed Rule - Independent Contractor Status Under the Fair Labor Standards Act; S. 479, LOCAL Infrastructure Act; H.R. 2288 - To amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds; H.R. 842/S. 420 - Protecting the Right to Organize Act of 2021; Increase in the bank qualified bond limit - Rep. Sewell Bill; Cryptocurrency and digital assets; H.R. 2634 - Local Infrastructure Financing Tools Act; S. 1676 - Rural Broadband Financing Flexibility Act; S. 1308 - American Infrastructure Bonds Act of 2021; H.R. 2954 - Securing a Strong Retirement Act of 2021; S. 1770 - Retirement Security and Savings Act of 2021; S. 1443/H.R. 2917 - Retirement Parity for Student Loans Act; H.R. ___ Capital Markets Transparency Act H.R.___ to amend the Securities Exchange Act of 1934 to establish certain requirements with respect to retail investor options trading. H.R. ___ to amend the Securities Exchange Act of 1934 to prohibit payment for order flow in the form of exchange rebates; S. 2407 - Cyber Incident Notification Act of 2021; SEC Rule 15c2-11; H.R. 4617 - To require the Securities and Exchange Commission to carry out a study on payment for order flow, to require the Investor Advocate of the Commission to provide recommendations on payment for order flow, and for other purposes.; H.R. 935 - the Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021; H.R. 2265 - the Financial Exploitation Prevention Act of 2021; H.R. 4618 - the Short Sale Transparency and Market Fairness Act; H.R. 4619 - To amend the Securities Exchange Act of 1934 to prohibit trading ahead by market makers, and for other purposes; H.R. ___ "Close the ILC Loophole Act"; SEC Securities Lending Proposal; Prudential Agency ESG/Climate Finance Rules and inquiries; Prudential Agency Capital and Liquidity Regulations, including Basel Implementation.

Legislation and rulemaking affecting annuities, variable life products and retirement savings including Biden Administration and Congressional proposals on tax reform. DOL - EBSA - Cybersecurity Guidance for Plan Sponsors, Fiduciaries, Record Keepers and Participants. DOL - EBSA - PTE 2020-02 - Improving Investment Advice for Workers & Retirees. DOL - EBSA - Financial Factors in Selecting Plan Investments - ZRIN 1210-AB95. DOL - EBSA - Improving Investment Advice for Workers and Retirees - ZRIN 1210-ZA29. DOL - EBSA - Pension Benefit Statements-Lifetime Income Illustrations - RIN 1210-AB20. DOL - EBSA - Fiduciary Duties Regarding Proxy Voting and Shareholder Rights - RIN 1210-AB91. DOL - OSEC - Rescission of Department of Labor Rule on Guidance (29 CFR Part 89 - RIN 1290-AA41). DOL - EBSA - Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Consultants, Insurance Companies, and Investment Company Principal Underwriters. DOL - EBSA - Definition of the Term Fiduciary - RIN 1210-AC02. DOL - EBSA - Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights (RIN - 1210-AC03/ 29 CFR 2550). EOP - Executive Order on Climate-Related Financial Risk. EOP - Amending Executive Order 13959 - Addressing the Threat from Securities Investments That Finance Communist Chinese Military Companies (E.O. 13974 of Jan 13, 2021 - 86 FR 4875). EOP - Executive Order 13990 - Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis (Federal Register/Vol. 86, No. 14 - Monday, January 25, 2021). FINRA - Comment on Lessons From the COVID-19 Pandemic (Regulatory Notice 20-42). Proposals at the Department of Treasury for increasing Americans' access to guaranteed lifetime income solutions. Treasury - IRS Proposed Rulemaking: Multiple Employer Plans (26 CFR Part 1 [REG-121508-18] RIN 1545-BO97). Treasury - IRS Proposed Rulemaking: Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions (26 CFR Part 1 [REG-132210-18] RIN 1545-BP11). Proposals at the Department of Labor for increasing Americans' access to guaranteed lifetime income solutions. SEC - Implementation and Enforcement of Regulation BI and Form CRS. SEC - Updated Disclosure Requirements and Summary Prospectus for Variable Annuity and Variable Life Insurance Contracts (17 CFR Parts 230, 232, 239, 240, 270, and 274). SEC - Request for Information and Comments on Broker-Dealer and Investment Adviser Digital Engagement Practices, Related Tools and Methods, and Regulatory Considerations and Potential Approaches; Information and Comments on Investment Adviser Use of Technology to Develop and Provide Investment Advice - RIN 3235-AN00 (Release Nos. 34-92766; IA-5833; File No. S7-10-21). SEC - FINRA - Proposed Rule Change to Amend FINRA Rule 2231 (Customer Account Statements) - SR-FINRA-2021-024. SEC - FINRA - Proposed Rule Change to Extend the Effectiveness of Temporary FINRA Rule 3110.17 - SR-FINRA-2021-023. SEC - Electronic Recordkeeping Requirements for Broker-Dealers, Security-Based Swap Dealers, and Major Security-Based Swap Participants - (RIN 3235-AM76 - Release No. 34-93614; File No. S7-19-2 - 17 CFR Part 240). The Automatic Retirement Plan Act of 2017 (H.R. 4523 - 115th Congress). The Retirement Plan Simplification Act of 2017 (H.R. 4524 - 115th Congress). The Expanding Access to Retirement Savings for Caregivers Act (H.R. 3078 - 116th Congress). The Application of ERISA to Insurance Company General Accounts and General Account Contracts (H.R. 7278 - 115th Congress). Senior Investor Pandemic and Fraud Protection Act - House Financial Services National Security, International Development and Monetary Policy Subcommittee (Discussion Draft). The Enhancing Emergency and Retirement Savings Act (S.1870-117th Congress). The Financial Exploitation Prevention Act (H.R. 2265 - 117th Congress). The Financial Factors in Selecting Retirement Plan Investment Act (S.1762/H.R. 3387-117th Congress). The Financial Services and General Government Appropriations Act, 2022 (H.R.4345 - 117th Congress). The Improving Access to Retirement Savings Act of 2021 (S.1703 - 117th Congress). The Military Spouses Retirement Security Act (S.1273/HR 1453 - 117th Congress). The Protecting the Right to Organize (PRO) Act (S.420/H.R. 842-117th Congress). The Retirement Parity for Student Loans Act (S.1443/HR 2917 - 117th Congress). The Retirement Savings Lost and Found Act (S.1730 - 117th Congress). The Retirement Security and Savings Act of 2021 (S.1770 - 117th Congress). The Securing a Strong Retirement Act (H.R.2954 - 117th Congress). The Securing and Enabling Commerce Using Remote and Electronic Notarization Act (S.1625/H.R. 3962 - 117th Congress). The Senior Security Act (S.856/H.R.1565 - 117th Congress). The Servicemember Retirement Improvement Act (H.R. 905 - 116th Congress). The E-SIGN Modernization Act. (S.4159 - 116th Congress). The Lifetime Income for Employees Act (H.R. 8990 - 116th Congress). The Secure and Fair Enforcement (SAFE) Banking Act (S.910/H.R. 1996 - 117th Congress). Build Back Better Act (H.R. 5367 - 117th Congress). Womens Retirement Protection Act (S.2446/H.R. 4678 - 117th Congress). National Defense Authorization Act for Fiscal Year 2022 (S.2792/H.R. 4350 - 117th Congress). Elder Justice Reauthorization and Modernization Act of 2021 (S.2674/H.R.4969 - 117th Congress). The Retirement Improvement and Savings Enhancement (RISE) Act (H.R. 5891 - 117th Congress). The Registration for Index-Linked Annuities (RILA) Act (S.3198/H.R. 4865 - 117th Congress). Build Back Better Act (H.R. 5367 - 117th Congress). The Long-Term Care Affordability Act (S.2415 - 117th Congress). The Financial Fitness Act (H.R. 5779 - 117th Congress). DOL implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). Treasury/IRS implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). SEC implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). Treasury - IRS - Draft of the 2022 IRS Form W-4P and W4-R, Withholding Certificate for Periodic Pension or Annuity Payments. Treasury - IRS - Notice 2021-03 - Extension of Temporary Relief from the Physical Presence Requirement for Spousal Consents Under Qualified Retirement Plans.

Legislation and rulemaking affecting annuities, variable life products and retirement savings including Biden Administration and Congressional proposals on tax reform. EOP - Executive Order on Climate-Related Financial Risk. EOP - Amending Executive Order 13959 - Addressing the Threat from Securities Investments That Finance Communist Chinese Military Companies (E.O. 13974 of Jan 13, 2021 - 86 FR 4875). EOP - Executive Order 13990 - Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis (Federal Register/Vol. 86, No. 14 - Monday, January 25, 2021). FINRA - Comment on Lessons From the COVID-19 Pandemic (Regulatory Notice 20-42). DOL - EBSA - Cybersecurity Guidance for Plan Sponsors, Fiduciaries, Record Keepers and Participants. DOL - EBSA - PTE 2020-02 - Improving Investment Advice for Workers & Retirees. DOL - EBSA - Financial Factors in Selecting Plan Investments - ZRIN 1210-AB95. DOL - EBSA - Improving Investment Advice for Workers and Retirees - ZRIN 1210-ZA29. DOL - EBSA - Pension Benefit Statements-Lifetime Income Illustrations - RIN 1210-AB20. DOL - EBSA - Fiduciary Duties Regarding Proxy Voting and Shareholder Rights - RIN 1210-AB91. DOL - EBSA - Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Consultants, Insurance Companies, and Investment Company Principal Underwriters. DOL - EBSA - Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights (RIN - 1210-AC03/ 29 CFR 2550). DOL - EBSA - Definition of the Term Fiduciary - RIN 1210-AC02. SEC - Reporting Threshold for Institutional Investment Managers - RIN 3235-AM65. SEC - Request for Information and Comments on Broker-Dealer and Investment Adviser Digital Engagement Practices, Related Tools and Methods, and Regulatory Considerations and Potential Approaches; Information and Comments on Investment Adviser Use of Technology to Develop and Provide Investment Advice - RIN 3235-AN00 (Release Nos. 34-92766; IA-5833; File No. S7-10-21). SEC - FINRA - Proposed Rule Change to Amend FINRA Rule 2231 (Customer Account Statements) - SR-FINRA-2021-024. SEC - FINRA - Proposed Rule Change to Extend the Effectiveness of Temporary FINRA Rule 3110.17 - SR-FINRA-2021-023. SEC - Electronic Recordkeeping Requirements for Broker-Dealers, Security-Based Swap Dealers, and Major Security-Based Swap Participants - (RIN 3235-AM76 - Release No. 34-93614; File No. S7-19-2 - 17 CFR Part 240). Treasury - IRS Proposed Rulemaking: Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions (26 CFR Part 1 [REG-132210-18] RIN 1545-BP11). Proposals at the Department of Treasury for increasing Americans' access to guaranteed lifetime income solutions. Proposals at the Department of Labor for increasing Americans' access to guaranteed lifetime income solutions. Department of Labor rule to expand the scope of persons and entities that would be considered a fiduciary under the Employee Retirement Income Security Act. The Consumer Data Privacy Act - (Sen. Wyden (D-OR) - Discussion Draft). The CECL Consumer Impact and Study Bill of 2019 (H.R. 3182 - 116th Congress). The Corporate Management Accountability Act of 2019 (S.1885/H.R. 4320 - 116th Congress). The Cybersecurity and Financial System Resilience Act of 2019 (H.R. 4458 - 116th Congress). Senior Investor Pandemic and Fraud Protection Act - House Financial Services National Security, International Development and Monetary Policy Subcommittee (Discussion Draft). House Energy and Commerce Committee - Privacy Bill (Discussion Draft). The American Families Plan. The Bipartisan Infrastructure Framework. The Diversity and Inclusion Data Accountability and Transparency Act. (H.R. 2123 - 117th Congress). The Diversity Data Accountability Act (H.R.2001 - 117th Congress). The ESG Disclosure Simplification Act. (H.R. 1187 - 117th Congress). The Financial Exploitation Prevention Act (H.R. 2265 - 117th Congress). The Financial Factors in Selecting Retirement Plan Investment Act (S.1762/H.R. 3387-117th Congress). The Financial Services and General Government Appropriations Act, 2022 (H.R. 4345 - 117th Congress). The Improving Corporate Governance Through Diversity Act. (H.R. 1277 - 117th Congress). The INVEST in America Act (H.R. 3684 - 117th Congress). The Primary Regulators of Insurance Vote Act (H.R.3099 - 117th Congress). The Promoting Diversity and Inclusion in Banking Act. (H.R. 2516 - 117th Congress). The Protecting the Right to Organize (PRO) Act (S.420/H.R. 842-117th Congress). The Secure and Fair Enforcement (SAFE) Banking Act (S.910/H.R. 1996-117th Congress). The Securing and Enabling Commerce Using Remote and Electronic Notarization Act (S.1625/H.R. 3962 - 117th Congress). The Senior Security Act (S.856/H.R. 1565 - 117th Congress). The Shareholder Political Transparency Act. (H.R. 1087 - 117th Congress). The E-SIGN Modernization Act. (S.4159 - 116th Congress). The SAFE Banking Act (S.910/H.R. 1996 - 117th Congress). National Defense Authorization Act for Fiscal Year 2022 (S.2792/H.R. 4350 - 117th Congress). Elder Justice Reauthorization and Modernization Act of 2021 (S.2674/H.R. 4969 - 117th Congress). The Empowering States to Protect Seniors from Bad Actors Act (H.R. 5914 - 117th Congress). The Registration for Index-Linked Annuities (RILA) Act (S.3198/H.R. 4865 - 117th Congress). The Financial Fitness Act (H.R. 5779 - 117th Congress). DOL implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). Treasury/IRS implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). SEC implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). SEC - Implementation and Enforcement of Regulation BI and Form CRS.

ISSUE Investment Advice Standard of Conduct HR 699, Mutual Fund Litigation Reform Act - amend the Investment Company Act of 1940 to provide complaint and burden of proof requirements for certain actions for breach of fiduciary duty HR 725/S 153, Personalized Care Act - amend the Internal Revenue Code of 1986 to expand and improve health savings accounts, and for other purposes. HR 984, Retirement Inflation Protection Act - allows the basis of certain assets to be adjusted for inflation solely for the purpose of determining the gain or loss. S 380, Health Savings Act - modifies the requirements for health savings accounts (HSAs). HR 1584, Protecting Retirement Savers and Everyday Investors Act - impose a limitation on taxation and fees on transactions by certain securities industry participants. HR 1618/S 606, RESPOND Act - require the FRB and SEC to issue an annual report on the economic costs caused by the impacts of climate change, to require the Federal Retirement Thrift Investment Board to establish a Federal Advisory Panel on the Economics of Climate Change. S 1443Retirement Parity for Student Loans Act -- allows certain employer-sponsored retirement plans to make matching contributions for an employee's student loan payments HR 2951 To direct the Secretary of the Treasury to modify Treasury Regulations relating to insurance-dedicated exchange-traded funds - enables ETFs as investment option in variable insurance products HR 2954 Securing a Strong Retirement Act of 2021 -- To increase retirement savings, simplify and clarify retirement plan rules, and for other purposes. HR 2944 Reducing the Maximum Service Requirement for Long-term Part-time Workers to Make Elective Deferrals to 401(k) Plans Act -- to reduce the retirement plan period of service requirements for long-term, part-time employees. S 1703Improving Access to Retirement Savings Act of 2021 -- to increase retirement savings, to improve retirement plan administration, and for other purposes. S 1770Retirement Security & Savings Act -- to increase retirement savings, to improve retirement plan administration, and for other purposes. HR 3387/S 1762 Financial Factors in Selecting Retirement Plan Investment Act -- to permit retirement plans to consider certain factors in investment decisions. S 1870Enhancing Emergency and Retirement Savings Act of 2021 -- permits penalty-free distributions from tax-exempt retirement plans for emergency personal expenses. S 1272SIMPLE Plan Modernization Act -- increases the contribution limits for certain SIMPLE IRAs and modifies the requirements for replacing SIMPLE IRAs with 401(k) plans. HR 2741 Public Service Retirement Fairness Act -- To modify rules relating to 403(b) plans. HR 4262 Increasing Investor Opportunities Act - To amend the Investment Company Act of 1940 to prohibit limitations on closed-end companies investing in private funds S 2206Young American Savers Act of 2021 - directs the Department of the Treasury to establish as a permanent program the Federal Child Savings Account Program HR 4289 Well-Being Insurance for Seniors to be at Home (WISH) Act - to provide for long-term care insurance benefits HR 2913/S 2452 Encouraging Americans to Save Act - to provide matching payments for retirement savings and establish MyRA HR 4678/S 2446 Womens Retirement Protection Act of 2021 - to provide for greater spousal protection under defined contribution plans S 2415Long-Term Care Affordability Act - allows the use of tax-exempt retirement plan distributions to pay for long-term health care insurance S 2583To amend the Internal Revenue Code of 1986 to provide for rules for the use of retirement funds in connection with federally declared disasters - allows penalty-free distributions from tax-exempt retirement plans for a federally declared disaster HR 5334/S 2870 Portable Retirement and Investment Account (PRIA) Act of 2021 - to establish portable retirement accounts S 2602Retirement Security Flexibility Act of 2021 - auto enrollment safe harbor S 2602,Retirement Security Flexibility Act of 2021 - modifies the nondiscrimination requirements that apply to certain employer-sponsored 401(k) retirement plans that include automatic contribution arrangements HR 2265, Financial Exploitation Prevention Act - allows for the delay of the redemption of a security issued by an open-end investment management company if the company or transfer agent reasonably believes the redemption involves the financial exploitation HR 5723, Social Security 2100 Act: A Sacred Trust - protect our Social Security system and improve benefits for current and future generations HR 5891, Retirement Improvement and Savings Enhancement (RISE) Act - to improve and enhance retirement savings HR 4865/S 3198, Registration for Index Linked Annuities (RILA) Act - direct SEC to revise any rules necessary to enable issuers of index-linked annuities to register on a form tailored specifically to registered index-linked annuities HR 5877, Pension Risk Transfer Accountability Act - require the Secretary of Labor to review certain provisions of the Code of Federal Regulations related to fiduciary standards under ERISA

Equity market structure issues; LIBOR transition issues; SEC Final Regulation Best Interest; Implementation of Electronic Signature in Global and National Commerce Act; Consolidated Audit Trail (CAT) - US House and US Senate; Legislation related to changes in certain private activity bond treatment; H.R. 3967 (116th Cong.) - Municipal Bond Market Support Act of 2019; Federal Reserve Board and Prudential Agency Covid-19 Actions; S. 3550 (116th Cong.) - Municipal Bonds Emergency Relief Act; Self-Regulatory Organization (SRO) Reform; S. 1236 (116th Cong.) - Municipal Securities Rulemaking Board Reform Act of 2019; Federal government market support programs (e.g. TALF); LIBOR; Stress Testing Reform; H.R. 2923 (116th Cong.) - Inclusive Prosperity Act of 2019; Department of Labor - Proposed Rule - Independent Contractor Status Under the Fair Labor Standards Act; Privacy Bills - various; S. 479, LOCAL Infrastructure Act; H.R. 2288 - To amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds; H.R. 842/S. 420 - Protecting the Right to Organize Act of 2021; Increase in the bank qualified bond limit - Rep. Sewell Bill; S.910 - SAFE Banking Act of 2021; Cryptocurrency and digital assets; H.R. 2634 - Local Infrastructure Financing Tools Act; S. 1676 - Rural Broadband Financing Flexibility Act; S. 1308 - American Infrastructure Bonds Act of 2021; H.R. 2954 - Securing a Strong Retirement Act of 2021; S. 1770 - Retirement Security and Savings Act of 2021; S. 1443/H.R. 2917 - Retirement Parity for Student Loans Act; H.R. 2977 - Connect America Now (CAN) Act; H.R. ___ Capital Markets Transparency Act H.R.___ to amend the Securities Exchange Act of 1934 to establish certain requirements with respect to retail investor options trading. H.R. ___ to amend the Securities Exchange Act of 1934 to prohibit payment for order flow in the form of exchange rebates; S. 2407 - Cyber Incident Notification Act of 2021; SEC Rule 15c2-11; H.R. 4617 - To require the Securities and Exchange Commission to carry out a study on payment for order flow, to require the Investor Advocate of the Commission to provide recommendations on payment for order flow, and for other purposes.; H.R. 935 - the Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021; H.R. 2265 - the Financial Exploitation Prevention Act of 2021; H.R. 4618 - the Short Sale Transparency and Market Fairness Act; H.R. 4619 - To amend the Securities Exchange Act of 1934 to prohibit trading ahead by market makers, and for other purposes.

H.R. 699- Mutual Fund Litigation Reform Act (Emmer) H.R. 1187- Corporate Governance Improvement and Investor Protection Act H.R. 1277- Improving Corporate Governance Through Diversity Act of 2021 (Meeks) H.R. 1996- Secure and Fair Enforcement Banking Act of 2021 (Perlmutter) H.R. 2123- Diversity and Inclusion Data Accountability and Transparency Act (Beatty) H.R. 2265- Financial Exploitation Prevention Act (Wagner) H.R. 2570- Climate Risk Disclosure Act of 2021 (Casten) H.R. 3412- Alleviating Stress Test Burdens to Help Investors Act (Loudermilk) H.R. 3899- Financial Stability Oversight Council Improvement Act (Foster) H.R. 4262- Increasing Investor Opportunities Act (Gonzalez) H.R. 4616- Adjustable Interest Rate (LIBOR) Act of 2021 (Sherman) H.R. 4618- Short Sale Transparency and Market Fairness Act (Waters) S. 374- Improving Corporate Governance Through Diversity Act of 2021 (Menendez) S. 910- Secure and Fair Enforcement Banking Act of 2021 (Merkley) S. 2184- Accelerating Holding Foreign Companies Accountable Act (Kennedy) S. 2684- Consumer Financial Choice and Capital Markets Protection Act of 2021 (Toomey) Improving Disclosure for Investors Act of 2021 Processing fees for delivering investment materials Consolidated Audit Trail SEC Cybersecurity and Data Protection Diverse Investment Advisers Act Enhanced ESG Disclosure by Corporate Issuers

Client expense: $1,720,000 · Firm income: Not reported

Legislation and rulemaking affecting annuities, variable life products and retirement savings including Biden Administration and Congressional proposals on tax reform. EOP - Executive Order on Climate-Related Financial Risk. EOP - Amending Executive Order 13959 - Addressing the Threat from Securities Investments That Finance Communist Chinese Military Companies (E.O. 13974 of Jan 13, 2021 - 86 FR 4875). EOP - Executive Order 13990 - Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis (Federal Register/Vol. 86, No. 14 - Monday, January 25, 2021). FINRA - Comment on Lessons From the COVID-19 Pandemic (Regulatory Notice 20-42). DOL - EBSA - Cybersecurity Guidance for Plan Sponsors, Fiduciaries, Record Keepers and Participants. DOL - EBSA - PTE 2020-02 - Improving Investment Advice for Workers & Retirees. DOL - EBSA - Financial Factors in Selecting Plan Investments - ZRIN 1210-AB95. DOL - EBSA - Improving Investment Advice for Workers and Retirees - ZRIN 1210-ZA29. DOL - EBSA - Pension Benefit Statements-Lifetime Income Illustrations - RIN 1210-AB20. DOL - EBSA - Fiduciary Duties Regarding Proxy Voting and Shareholder Rights - RIN 1210-AB91. DOL - EBSA - Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Consultants, Insurance Companies, and Investment Company Principal Underwriters. SEC - Reporting Threshold for Institutional Investment Managers - RIN 3235-AM65. SEC - Request for Information and Comments on Broker-Dealer and Investment Adviser Digital Engagement Practices, Related Tools and Methods, and Regulatory Considerations and Potential Approaches; Information and Comments on Investment Adviser Use of Technology to Develop and Provide Investment Advice - RIN 3235-AN00 (Release Nos. 34-92766; IA-5833; File No. S7-10-21). SEC - FINRA - Proposed Rule Change to Amend FINRA Rule 2231 (Customer Account Statements) - SR-FINRA-2021-024. SEC - FINRA - Proposed Rule Change to Extend the Effectiveness of Temporary FINRA Rule 3110.17 - SR-FINRA-2021-023. Treasury - IRS Proposed Rulemaking: Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions (26 CFR Part 1 [REG-132210-18] RIN 1545-BP11). Proposals at the Department of Treasury for increasing Americans' access to guaranteed lifetime income solutions. Proposals at the Department of Labor for increasing Americans' access to guaranteed lifetime income solutions. Department of Labor rule to expand the scope of persons and entities that would be considered a fiduciary under the Employee Retirement Income Security Act. The Consumer Data Privacy Act - (Sen. Wyden (D-OR) - Discussion Draft). The CECL Consumer Impact and Study Bill of 2019 (H.R. 3182 - 116th Congress). The Corporate Management Accountability Act of 2019 (S.1885/H.R. 4320 - 116th Congress). The Cybersecurity and Financial System Resilience Act of 2019 (H.R. 4458 - 116th Congress). Senior Investor Pandemic and Fraud Protection Act - House Financial Services National Security, International Development and Monetary Policy Subcommittee (Discussion Draft). House Energy and Commerce Committee - Privacy Bill (Discussion Draft). The American Families Plan. The Bipartisan Infrastructure Framework. The Diversity and Inclusion Data Accountability and Transparency Act. (H.R. 2123 - 117th Congress). The Diversity Data Accountability Act (H.R.2001 - 117th Congress). The ESG Disclosure Simplification Act. (H.R. 1187 - 117th Congress). The Financial Exploitation Prevention Act (H.R. 2265 - 117th Congress). The Financial Factors in Selecting Retirement Plan Investment Act (S.1762/H.R. 3387-117th Congress). The Financial Services and General Government Appropriations Act, 2022 (H.R.4345 - 117th Congress). The Improving Corporate Governance Through Diversity Act. (H.R. 1277 - 117th Congress). The INVEST in America Act (H.R. 3684 - 117th Congress). The Primary Regulators of Insurance Vote Act (H.R.3099 - 117th Congress). The Promoting Diversity and Inclusion in Banking Act. (H.R. 2516 - 117th Congress). The Protecting the Right to Organize (PRO) Act (S. 420/H.R. 842-117th Congress). The Secure and Fair Enforcement (SAFE) Banking Act (S.910/H.R. 1996-117th Congress). The Securing and Enabling Commerce Using Remote and Electronic Notarization Act (S.1625/H.R. 3962 - 117th Congress). The Senior Security Act (S.856/H.R.1565 - 117th Congress). The Shareholder Political Transparency Act. (H.R. 1087 - 117th Congress). The Registration for Index Linked Annuities Act of 2020 (S.3795/H.R.6994 - 116th Congress). The E-SIGN Modernization Act. (S.4159 - 116th Congress). The SAFE Banking Act (S.910/H.R. 1996 - 117th Congress). The Registration for Indexed Linked Annuity (RILA) Act (H.R. 4865 - 117th Congress). National Defense Authorization Act for Fiscal Year 2022 (S. 2792/H.R. 4350 - 117th Congress). Elder Justice Reauthorization and Modernization Act of 2021 (S.2674/H.R.4969 - 117th Congress). DOL implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). Treasury/IRS implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). SEC implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). SEC - Implementation and Enforcement of Regulation BI and Form CRS.

Legislation and rulemaking affecting annuities, variable life products and retirement savings including Biden Administration and Congressional proposals on tax reform. DOL - EBSA - Cybersecurity Guidance for Plan Sponsors, Fiduciaries, Record Keepers and Participants. DOL - EBSA - PTE 2020-02 - Improving Investment Advice for Workers & Retirees. DOL - EBSA - Financial Factors in Selecting Plan Investments - ZRIN 1210-AB95. DOL - EBSA - Improving Investment Advice for Workers and Retirees - ZRIN 1210-ZA29. DOL - EBSA - Pension Benefit Statements-Lifetime Income Illustrations - RIN 1210-AB20. DOL - EBSA - Fiduciary Duties Regarding Proxy Voting and Shareholder Rights - RIN 1210-AB91. DOL - OSEC - Rescission of Department of Labor Rule on Guidance (29 CFR Part 89 - RIN 1290-AA41). DOL - EBSA - Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Consultants, Insurance Companies, and Investment Company Principal Underwriters. EOP - Executive Order on Climate-Related Financial Risk. EOP - Amending Executive Order 13959 - Addressing the Threat from Securities Investments That Finance Communist Chinese Military Companies (E.O. 13974 of Jan 13, 2021 - 86 FR 4875). EOP - Executive Order 13990 - Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis (Federal Register/Vol. 86, No. 14 - Monday, January 25, 2021). FINRA - Comment on Lessons From the COVID-19 Pandemic (Regulatory Notice 20-42). Proposals at the Department of Treasury for increasing Americans' access to guaranteed lifetime income solutions. Treasury - IRS Proposed Rulemaking: Multiple Employer Plans (26 CFR Part 1 [REG-121508-18] RIN 1545-BO97). Treasury - IRS Proposed Rulemaking: Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions (26 CFR Part 1 [REG-132210-18] RIN 1545-BP11). Proposals at the Department of Labor for increasing Americans' access to guaranteed lifetime income solutions. SEC - Implementation and Enforcement of Regulation BI and Form CRS. SEC - Updated Disclosure Requirements and Summary Prospectus for Variable Annuity and Variable Life Insurance Contracts (17 CFR Parts 230, 232, 239, 240, 270, and 274). SEC - Request for Information and Comments on Broker-Dealer and Investment Adviser Digital Engagement Practices, Related Tools and Methods, and Regulatory Considerations and Potential Approaches; Information and Comments on Investment Adviser Use of Technology to Develop and Provide Investment Advice - RIN 3235-AN00 (Release Nos. 34-92766; IA-5833; File No. S7-10-21). SEC - FINRA - Proposed Rule Change to Amend FINRA Rule 2231 (Customer Account Statements) - SR-FINRA-2021-024. SEC - FINRA - Proposed Rule Change to Extend the Effectiveness of Temporary FINRA Rule 3110.17 - SR-FINRA-2021-023. The Automatic Retirement Plan Act of 2017 (H.R. 4523 - 115th Congress). The Retirement Plan Simplification Act of 2017 (H.R. 4524 - 115th Congress). The Expanding Access to Retirement Savings for Caregivers Act (H.R. 3078 - 116th Congress). The Application of ERISA to Insurance Company General Accounts and General Account Contracts (H.R. 7278 - 115th Congress). Senior Investor Pandemic and Fraud Protection Act - House Financial Services National Security, International Development and Monetary Policy Subcommittee (Discussion Draft). The Enhancing Emergency and Retirement Savings Act (S.1870-117th Congress). The Financial Exploitation Prevention Act (H.R. 2265 - 117th Congress). The Financial Factors in Selecting Retirement Plan Investment Act (S.1762/H.R. 3387-117th Congress). The Financial Services and General Government Appropriations Act, 2022 (H.R.4345 - 117th Congress). The Improving Access to Retirement Savings Act of 2021 (S.1703 - 117th Congress). The Long-Term Care Affordability Act (S.4820 - 116th Congress). The Military Spouses Retirement Security Act (S. 1273/HR 1453 - 117th Congress). The Protecting the Right to Organize (PRO) Act (S. 420/H.R. 842-117th Congress). The Retirement Parity for Student Loans Act (S. 1443/HR 2917 - 117th Congress). The Retirement Savings Lost and Found Act (S.1730 - 117th Congress). The Retirement Security and Savings Act of 2021 (S. 1770 - 117th Congress). The Securing a Strong Retirement Act (H.R.2954 - 117th Congress). The Securing and Enabling Commerce Using Remote and Electronic Notarization Act (S.1625/H.R. 3962 - 117th Congress). The Senior Security Act (S.856/H.R.1565 - 117th Congress). The Servicemember Retirement Improvement Act (H.R. 905 - 116th Congress). The E-SIGN Modernization Act. (S.4159 - 116th Congress). The Lifetime Income for Employees Act (HR. 8990 - 116th Congress). The Secure and Fair Enforcement (SAFE) Banking Act (S.910/H.R. 1996 - 117th Congress). The Registration for Indexed Linked Annuity (RILA) Act (H.R. 4865 - 117th Congress). Build Back Better Act (H.R. 5367 - 117th Congress). Womens Retirement Protection Act (S. 2446/H.R. 4678 - 117th Congress). National Defense Authorization Act for Fiscal Year 2022 (S. 2792/H.R. 4350 - 117th Congress). Elder Justice Reauthorization and Modernization Act of 2021 (S.2674/H.R.4969 - 117th Congress). DOL implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). Treasury/IRS implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). SEC implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). Treasury - IRS - Draft of the 2022 IRS Form W-4P and W4-R, Withholding Certificate for Periodic Pension or Annuity Payments. Treasury - IRS - Notice 2021-03 - Extension of Temporary Relief from the Physical Presence Requirement for Spousal Consents Under Qualified Retirement Plans.

Legislation and rulemaking affecting annuities, variable life products and retirement savings including Biden Administration and Congressional proposals on tax reform. DOL - EBSA - Cybersecurity Guidance for Plan Sponsors, Fiduciaries, Record Keepers and Participants. DOL - EBSA - PTE 2020-02 - Improving Investment Advice for Workers & Retirees. DOL - EBSA - Financial Factors in Selecting Plan Investments - ZRIN 1210-AB95. DOL - EBSA - Improving Investment Advice for Workers and Retirees - ZRIN 1210-ZA29. DOL - EBSA - Pension Benefit Statements-Lifetime Income Illustrations - RIN 1210-AB20. DOL - EBSA - Fiduciary Duties Regarding Proxy Voting and Shareholder Rights - RIN 1210-AB91. DOL - OSEC - Rescission of Department of Labor Rule on Guidance (29 CFR Part 89 - RIN 1290-AA41). EOP - Executive Order on Climate-Related Financial Risk. EOP - Amending Executive Order 13959 - Addressing the Threat from Securities Investments That Finance Communist Chinese Military Companies (E.O. 13974 of Jan 13, 2021 - 86 FR 4875). EOP - Executive Order 13990 - Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis (Federal Register/Vol. 86, No. 14 - Monday, January 25, 2021). FINRA - Comment on Lessons From the COVID-19 Pandemic (Regulatory Notice 20-42). Proposals at the Department of Treasury for increasing Americans' access to guaranteed lifetime income solutions. Treasury - IRS Proposed Rulemaking: Multiple Employer Plans (26 CFR Part 1 [REG-121508-18] RIN 1545-BO97). Treasury - IRS Proposed Rulemaking: Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions (26 CFR Part 1 [REG-132210-18] RIN 1545-BP11). Proposals at the Department of Labor for increasing Americans' access to guaranteed lifetime income solutions. SEC - Implementation and Enforcement of Regulation BI and Form CRS. SEC - Updated Disclosure Requirements and Summary Prospectus for Variable Annuity and Variable Life Insurance Contracts (17 CFR Parts 230, 232, 239, 240, 270, and 274). The Automatic Retirement Plan Act of 2017 (H.R. 4523 - 115th Congress). The Retirement Plan Simplification Act of 2017 (H.R. 4524 - 115th Congress). The Expanding Access to Retirement Savings for Caregivers Act (H.R. 3078 - 116th Congress). The Application of ERISA to Insurance Company General Accounts and General Account Contracts (H.R. 7278 - 115th Congress). Senior Investor Pandemic and Fraud Protection Act - House Financial Services National Security, International Development and Monetary Policy Subcommittee (Discussion Draft). The Enhancing Emergency and Retirement Savings Act (S.1870-117th Congress). The Financial Exploitation Prevention Act (H.R. 2265 - 117th Congress). The Financial Factors in Selecting Retirement Plan Investment Act (S.1762/H.R. 3387-117th Congress). The Financial Services and General Government Appropriations Act, 2022 (H.R.4345 - 117th Congress). The Improving Access to Retirement Savings Act of 2021 (S.1703 - 117th Congress). The Long-Term Care Affordability Act (S.4820 - 116th Congress). The Military Spouses Retirement Security Act (S. 1273/HR 1453 - 117th Congress). The Protecting the Right to Organize (PRO) Act (S. 420/H.R. 842-117th Congress). The Retirement Parity for Student Loans Act (S. 1443/HR 2917 - 117th Congress). The Retirement Savings Lost and Found Act (S.1730 - 117th Congress). The Retirement Security and Savings Act of 2021 (S. 1770 - 117th Congress). The Securing a Strong Retirement Act (H.R.2954 - 117th Congress). The Securing and Enabling Commerce Using Remote and Electronic Notarization Act (S.1625 - 117th Congress). The Senior Security Act (S.856/H.R.1565 - 117th Congress). The Servicemember Retirement Improvement Act (H.R. 905 - 116th Congress). The Registration for Index Linked Annuities Act of 2020 (S.3795/H.R.6994 - 116th Congress). The E-SIGN Modernization Act. (S.4159 - 116th Congress). The Lifetime Income for Employees Act (HR. 8990 - 116th Congress). The Secure and Fair Enforcement (SAFE) Banking Act (S.910/H.R. 1996 - 117th Congress). DOL implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). Treasury/IRS implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). SEC implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). Treasury - IRS - Draft of the 2022 IRS Form W-4P and W4-R, Withholding Certificate for Periodic Pension or Annuity Payments. Treasury - IRS - Notice 2021-03 - Extension of Temporary Relief from the Physical Presence Requirement for Spousal Consents Under Qualified Retirement Plans.

Legislation and rulemaking affecting annuities, variable life products and retirement savings including Biden Administration and Congressional proposals on tax reform. EOP - Executive Order on Climate-Related Financial Risk. EOP - Amending Executive Order 13959 - Addressing the Threat from Securities Investments That Finance Communist Chinese Military Companies (E.O. 13974 of Jan 13, 2021 - 86 FR 4875). EOP - Executive Order 13990 - Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis (Federal Register/Vol. 86, No. 14 - Monday, January 25, 2021). FINRA - Comment on Lessons From the COVID-19 Pandemic (Regulatory Notice 20-42). DOL - EBSA - Cybersecurity Guidance for Plan Sponsors, Fiduciaries, Record Keepers and Participants. DOL - EBSA - PTE 2020-02 - Improving Investment Advice for Workers & Retirees. DOL - EBSA - Financial Factors in Selecting Plan Investments - ZRIN 1210-AB95. DOL - EBSA - Improving Investment Advice for Workers and Retirees - ZRIN 1210-ZA29. DOL - EBSA - Pension Benefit Statements-Lifetime Income Illustrations - RIN 1210-AB20. DOL - EBSA - Fiduciary Duties Regarding Proxy Voting and Shareholder Rights - RIN 1210-AB91. SEC - Implementation and Enforcement of Regulation BI and Form CRS. SEC - Reporting Threshold for Institutional Investment Managers - RIN 3235-AM65. Treasury - IRS Proposed Rulemaking: Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions (26 CFR Part 1 [REG-132210-18] RIN 1545-BP11). Proposals at the Department of Treasury for increasing Americans' access to guaranteed lifetime income solutions. Proposals at the Department of Labor for increasing Americans' access to guaranteed lifetime income solutions. Department of Labor rule to expand the scope of persons and entities that would be considered a fiduciary under the Employee Retirement Income Security Act. The Consumer Data Privacy Act - (Sen. Wyden (D-OR) - Discussion Draft). The CECL Consumer Impact and Study Bill of 2019 (H.R. 3182 - 116th Congress). The Corporate Management Accountability Act of 2019 (S.1885/H.R. 4320 - 116th Congress). The Cybersecurity and Financial System Resilience Act of 2019 (H.R. 4458 - 116th Congress). Senior Investor Pandemic and Fraud Protection Act - House Financial Services National Security, International Development and Monetary Policy Subcommittee (Discussion Draft). House Energy and Commerce Committee - Privacy Bill (Discussion Draft). The American Families Plan. The Bipartisan Infrastructure Framework. The Diversity and Inclusion Data Accountability and Transparency Act. (H.R. 2123 - 117th Congress). The Diversity Data Accountability Act (H.R.2001 - 117th Congress). The ESG Disclosure Simplification Act. (H.R. 1187 - 117th Congress). The Financial Exploitation Prevention Act (H.R. 2265 - 117th Congress). The Financial Factors in Selecting Retirement Plan Investment Act (S.1762/H.R. 3387-117th Congress). The Financial Services and General Government Appropriations Act, 2022 (H.R.4345 - 117th Congress). The Improving Corporate Governance Through Diversity Act. (H.R. 1277 - 117th Congress). The INVEST in America Act (H.R. 3684 - 117th Congress). The Primary Regulators of Insurance Vote Act (H.R.3099 - 117th Congress). The Promoting Diversity and Inclusion in Banking Act. (H.R. 2516 - 117th Congress). The Protecting the Right to Organize (PRO) Act (S. 420/H.R. 842-117th Congress). The Secure and Fair Enforcement (SAFE) Banking Act (S.910/H.R. 1996-117th Congress). The Securing and Enabling Commerce Using Remote and Electronic Notarization Act (S.1625 - 117th Congress). The Senior Security Act (S.856/H.R.1565 - 117th Congress). The Shareholder Political Transparency Act. (H.R. 1087 - 117th Congress). The Registration for Index Linked Annuities Act of 2020 (S.3795/H.R.6994 - 116th Congress). The E-SIGN Modernization Act. (S.4159 - 116th Congress). The SAFE Banking Act (S.910/H.R. 1996 - 117th Congress). DOL implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). Treasury/IRS implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). SEC implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94).

H.R. 699- Mutual Fund Litigation Reform Act (Emmer) H.R. 1187- Corporate Governance Improvement and Investor Protection Act H.R. 1277- Improving Corporate Governance Through Diversity Act of 2021 (Meeks) H.R. 1996- Secure and Fair Enforcement Banking Act of 2021 (Perlmutter) H.R. 2123- Diversity and Inclusion Data Accountability and Transparency Act (Beatty) H.R. 2265- Financial Exploitation Prevention Act (Wagner) H.R. 2570- Climate Risk Disclosure Act of 2021 (Casten) H.R. 3007- Disclosure of Tax Havens and Offshoring Act (Axne) H.R. 3412- Alleviating Stress Test Burdens to Help Investors Act (Loudermilk) H.R. 3899- Financial Stability Oversight Council Improvement Act (Foster) H.R. 4262- Increasing Investor Opportunities Act (Gonzalez) S. 374- Improving Corporate Governance Through Diversity Act of 2021 (Menendez) S. 910- Secure and Fair Enforcement Banking Act of 2021 (Merkley) S. 2184- Accelerating Holding Foreign Companies Accountable Act (Kennedy) Consolidated Audit Trail Diverse Investment Advisers Act Enhanced ESG Disclosure by Corporate Issuers Exchange-Traded Funds Improving Disclosure for Investors Act of 2021 Money Market Mutual Funds SEC Form 13F SEC Cybersecurity and Data Protection

Client expense: $1,030,000 · Firm income: Not reported

EOP - Amending Executive Order 13959 - Addressing the Threat from Securities Investments That Finance Communist Chinese Military Companies (E.O. 13974 of Jan 13, 2021 - 86 FR 4875). EOP - Executive Order 13990 - Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis (Federal Register/Vol. 86, No. 14 - Monday, January 25, 2021). FINRA - Comment on Lessons From the COVID-19 Pandemic (Regulatory Notice 20-42). DOL - EBSA - Financial Factors in Selecting Plan Investments - ZRIN 1210-AB95. DOL - EBSA - Improving Investment Advice for Workers and Retirees - ZRIN 1210-ZA29. DOL - EBSA - Registration Requirements for Pooled Plan Providers - RIN 1210-AB94. DOL - EBSA - Pension Benefit Statements-Lifetime Income Illustrations - RIN 1210-AB20. DOL - EBSA - Fiduciary Duties Regarding Proxy Voting and Shareholder Rights - RIN 1210-AB91. SEC - Reporting Threshold for Institutional Investment Managers - RIN 3235-AM65. SEC Regulation Best Interest (17 CFR Part 240). SEC Commission Interpretation Regarding Standard of Conduct for Investment Advisers; Request for Comment on Enhancing Investment Adviser Regulation (17 CFR Part 275). SEC Form CRS Relationship Summary; Amendments to Form ADV; Required Disclosures in Retail Communications and Restrictions on the use of Certain Names or Titles (17 CFR Parts 240, 249, 275 and 279). SEC - Updated Disclosure Requirements and Summary Prospectus for Variable Annuity and Variable Life Insurance Contracts (17 CFR Parts 230, 232, 239, 240, 270, and 274). Treasury - IRS Proposed Rulemaking: Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions (26 CFR Part 1 [REG-132210-18] RIN 1545-BP11.) Legislation and rulemaking affecting annuities, variable life products and retirement savings including Trump Administration and Congressional proposals on tax reform. Public Law 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act, implementation and regulatory reform. Implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption. Proposals at the Department of Treasury for increasing Americans' access to guaranteed lifetime income solutions. Proposals at the Department of Labor for increasing Americans' access to guaranteed lifetime income solutions. Department of Labor rule to expand the scope of persons and entities that would be considered a fiduciary under the Employee Retirement Income Security Act. Elder Protection and Abuse Prevention Act (H.R. 6744 - 115th Congress). Consumer Data Privacy Act - (Sen. Wyden (D-OR) - Discussion Draft). Consumer Information Notification Requirement Act (H.R. 6743 - 115th Congress). Refund to Rainy Day Savings Act (S.1018 - 116th Congress). Strengthening Financial Security Through Short-Term Savings Accounts Act of 2019 (S.1019 - 116th Congress). Wall Street Tax Act of 2019 (S.647/H.R. 1516 - 116th Congress). SEC Disclosure Effectiveness Testing Act (H.R. 1815 - 116th Congress). Primary Regulators of Insurance Vote Act of 2019 (S.1298/H.R. 2479 - 116th Congress). Advancing Innovation to Assist Law Enforcement Act (H.R. 2613 - 116th Congress). Inclusive Prosperity Act of 2019 (S.1587/H.R. 2923 - 116th Congress). Financial Services and General Government Appropriations Act, 2020 (H.R. 3351 - 116th Congress). CECL Consumer Impact and Study Bill of 2019 (H.R. 3182 - 116th Congress). Continued Encouragement for Consumer Lending Act (S.1564 - 116th Congress). Corporate Management Accountability Act of 2019 (S.1885/H.R. 4320 - 116th Congress). Cybersecurity and Financial System Resilience Act of 2019 (H.R. 4458 - 116th Congress). Diversity in Corporate Leadership Act of 2019 (H.R.3279 - 116th Congress). Ensuring Diverse Leadership Act of 2019 (S.65/H.R.281 - 116th Congress). ESG Disclosure Simplification Act of 2019 (H.R. 4329 - 116th Congress). Financial Transparency Act of 2019 (H.R. 4476 - 116th Congress). Forced Arbitration Injustice Repeal (FAIR) Act (H.R. 1423 - 116th Congress). Greater Accountability in Pay Act of 2019 (H.R. 4242 - 116th Congress). International Insurance Standards Act (H.R. 4592 - 116th Congress). Investor Protection & Capital Markets Fairness Act (H.R. 4344 - 116th Congress). Stop Debt Collection Abuse Act (S.2516/H.R. 4403 - 116th Congress). The Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act (H.R. 6800). Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2020 (H.R. 6364). Senior Investor Pandemic and Fraud Protection Act - House Financial Services National Security, International Development and Monetary Policy Subcommittee (Discussion Draft). House Energy and Commerce Committee - Privacy Bill (Discussion Draft). COVID-19 Consumer Data Protection Act (S.3663 - 116th Congress). Registered Index Linked Annuity Act (S.3795/H.R. 6994 - 116th Congress). 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.7617 -- 116th Congress). Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2020 (S.3533/H.R.6364 - 116th Congress). The Edith Shorougian Senior Victims of Fraud Compensation Act (Ediths Bill) (S.3487/H.R.7620 - 116th Congress). The E-SIGN Modernization Act. (S.4159 - 116th Congress). The HEROES Act (H.R. 925 - 116th Congress). Safe to Work Act (S.4317 - 116th Congress). Senior Security Act (S.856/H.R. 1565 - 117th Congress). SAFE Banking Act (S.910/H.R. 1996 - 117th Congress). Financial Exploitation Prevention Act (H.R. 2265 - 117th Congress). American Rescue Plan Act of 2021 (Public Law No: 117-2). Continuing Small Business Recovery and Paycheck Protection Program Act (S.4321 - 116th Congress). Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2020 (H.R. 6364). Senior Investor Pandemic and Fraud Protection Act - House Financial Services National Security, International Development and Monetary Policy Subcommittee (Discussion Draft). House Energy and Commerce Committee - Privacy Bill (Discussion Draft). Implementation of Continuing Appropriations Act, 2021 and Other Extensions Act (P.L. 116-159 - 116th Congress). Implementation of the Coronavirus Aid, Relief and Economic Security (CARES) Act (Public Law No: 116-136). DOL implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). Treasury/IRS implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94). SEC implementation of Division O of the Further Consolidated Appropriations Act 2020 (Public Law No: 116-94).

H.R. 699- Mutual Fund Litigation Reform Act (Emmer) H.R. 1277- Improving Corporate Governance Through Diversity Act of 2021 (Meeks) H.R. 1996- Secure and Fair Enforcement Banking Act of 2021 (Perlmutter) H.R. 2123- Diversity Data Accountability Act (Beatty) H.R. 2265- Financial Exploitation Prevention Act (Wagner) S. 374- Improving Corporate Governance Through Diversity Act of 2021 (Menendez) S. 910- Secure and Fair Enforcement Banking Act of 2021 (Merkley) CFTC Rule 4.5 China Divestment Climate Risk Disclosure Act of 2021 (Casten) Consolidated Audit Trail Diverse Investment Advisers Act Enhanced ESG Disclosure by Corporate Issuers Exchange-Traded Funds Financial Stability Oversight Council Improvement Act (Rounds/Foster) Improving Disclosure Accessibility Act of 2021 Increasing Investor Opportunities Act (Gonzalez) LIBOR Transition Money Market Mutual Funds SEC Cybersecurity and Data Protection

Client expense: $990,000 · Firm income: Not reported