Accredited Investor Definition Review Act

Banking Policy Impacting Emerging Companies Capital Formation Incentives ---H.R.368: American Innovation Act of 2023 ---H.R.448: Putting Investors First Act of 2023 ---H.R.835: Fair Investment Opportunities for Professional Experts Act ---H.R.1579: Accredited Investor Definition Review Act ---H.R.2608: To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes. ---H.R.2610: To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes. ---H.R.2624: Helping Startups Continue to Grow Act ---H.R.2673: American Innovation and R&D Competitiveness Act ---H.R.2792: Small Entity Update Act ---H.R.2797: Equal Opportunity for All Investors Act of 2023 ---H.R.2799: Expanding Access to Capital Act of 2023 ---H.R.7515: Infectious Disease Therapies Research and Innovation Act ---S.866: American Innovation and Jobs Act ---H.R.9562 Adjusting the well known seasoned issuers definition to allow for a larger financing round using ---Net Operating Loss Advance Refunds Capital Market Enhancements ---Accredited Investor Definition ---Amended Definition of Smaller Reporting Company ---Market Liquidity Proposals ---Public Float Threshold Update ---SEC Small Business Forum Small Business Innovation Research (SBIR) Program ---Reauthorization of SBIR and STTR ---Implementation of the SBIR and STTR Extension Act of 2022

Client expense: $1,460,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Natl Institutes of Health (NIH), SENATE, Securities & Exchange Commission (SEC)

H.R. 448, Putting Investors First Act of 2023 H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 835, Fair Investment Opportunities for Professional Experts Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 1410, Consumer Financial Protection Commission Act H.R. 1548, Improving Access to Small Business Information Act H.R. 1553, Helping Angels Lead our Startups (HALOS) Act H.R. 1579, Accredited Investor Definition Review Act H.R. 1807/S 3815, Improving Disclosures for Investors Act H.R. 2608, To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes H.R. 2610, To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes H.R. 2612, Gig Worker Equity Compensation Act H.R. 2627, Increasing Investor Opportunities Act H.R. 2652, Investment Opportunity Expansion Act H.R. 2792, Small Entity Update Act H.R. 2793, Encouraging Public Offerings Act of 2023 H.R. 2795, Enhancing Multi-Class Share Disclosures Act H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2797, Equal Opportunity for All Investors Act H.R. 2798, CFPB Transparency and Accountability Reform Act H.R. 2799/S. 3815, Expanding Access to Capital Act of 2023 H.R. 2812, Middle Market IPO Underwriting Cost Act H.R. 3063/S. 4917, Retirement Fairness for Charities and Educational Institutions Act H.R. 3161, CDFI Fund Transparency Act H.R. 4035, Protecting Small Business Information Act of 2023 H.R. 4168/S. 2005, Mandatory Materiality Requirement Act of 2023 H.R. 4177/S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 4366, Consolidated Appropriations Act, 2024, including provisions related to Senate Amendments 1092 and 1217 H.R. 4664/S. 2309, Making appropriations for financial services and general government for the fiscal year ending September 30, 2024, and for other purposes H.R. 4790, Prioritizing Economic Growth Over Woke Policies Act H.R. 4823, American Financial Institution Regulator Sovereignty and Transparency Act H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 H.R. 7000/S. 3592, Business of Insurance Regulatory Reform Act of 2024 H.R. 7092/S. 3676, Protecting Private Job Creators Act H.R. 7470/S.3823, Secure U.S. Leadership in Space Act of 2024 H.R. 8337, Bank Resilience and Regulatory Improvement Act H.R. 8338, Clarity in Lending Act H.R. 8339, SEC Reform and Restructuring Act H.R. 8773, Financial Services and General Government Appropriations Act, 2025 H.R. 9512, Congressional Banking Regulation Priorities and Accountability Act of 2024 H.R. 9922, Litigation Transparency Act of 2024 S. 638, Disclosure of Tax Havens and Offshoring Act S. 3541, Fair Audits and Inspections for Regulators Exams Act S. 5139, Empowering Main Street in America Act of 2024 S. 5254, Child Care for American Families Act H.J.Res. 100/S.J.Res. 50, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to "Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure" H.J.Res. 120, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Stability Oversight Council related to "Guidance on Nonbank Financial Company Determinations" H.J.Res. 122/H.J.Res. 121/S.J.Res. 70, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z)" H.J.Res. 201, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders" SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Proposed Rule, Securities and Exchange Commission; Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (87 Fed. Reg. 77,172-77,296, December 16, 2022) Proposed Rule, Public Company Accounting Oversight Board; Amendments to Reporting Requirements for Registered Firms (PCAOB Release No. 2024-003, April 9, 2024; PCAOB Rulemaking Docket Matter No. 055) Proposed Rule, Public Company Accounting Oversight Board; Amendments to Firm and Engagement Metrics (PCAOB Release No. 2024-002, April 9, 2024; PCAOB Rulemaking Docket Matter No. 041) Adopting Order of the Securities and Exchange Commission: Public Company Accounting Oversight Board Amendments to QC 1000, A Firms System of Quality Control and Related Amendments to PCAOB Standards, Rules, and Forms (SEC Release No. 34-100968; PCAOB File No. PCAOB-2024-002) Request for Information, U.S. Treasury, Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector (TREAS-DO-2024-0011, June 12, 2024) Request for Comment, Commodity Futures Trading Commission (CFTC), The Use of Artificial Intelligence (AI) in CFTC-regulated derivatives markets (89 Fed. Reg. 65,606, August 12, 2024) Final Rule, Securities Exchange Commission, on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (88 Fed. Reg. 51,896-51,945, September 5, 2023) Proposed Rule, Securities Exchange Commission, on Changes to 14a-8 (87 Fed. Reg. 45,052-45,075, July 27, 2022) Proposed Rule, Securities and Exchange Commission, Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices (87 Fed. Reg. 63,016-63,017, October 18, 2022) Proposed Rule, Securities and Exchange Commission, Outsourcing by Investment Advisers (87 Fed. Reg. 68,816-68,883, November 16, 2022) Proposed Rule, Securities and Exchange Commission; Conflicts of Interest Associated with the use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (88 Fed. Reg. 53,960-54,024, August 9, 2023) Proposed Rule, Securities Exchange Commission, on Safeguarding Advisory Client Assets (88 Fed. Reg 14,672-14,792, March 9, 2023) Proposed Rule, Public Company Accounting Oversight Board; Amendments to PCAOB Auditing Standards related to a Companys Noncompliance with Laws and Regulations (PCAOB Release No. 2023-003/PCAOB Rulemaking Docket Matter No. 051, June 6, 2023) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTCs de minimis exception for swap dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council activities, including the approach to and designation of systemic importance and risk of nonbank financial companies and firms; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Financial Accounting Standards Board improvements to income tax disclosures; Climate-Related Financial Risk Management for Large Banks; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; Basel III Endgame Rule; FDIC Monitoring of Investment Funds Passivity Agreements; the Export-Import Bank of the United States; Consumer Financial Protection Circular 2024-05, Improper Overdraft Opt-In Practices; European Unions Corporate Sustainability Due Diligence Directive (CSDDD); EU sustainable finance action plan and incorporating ESG factors into financial services; reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; reporting metrics for private companies under Securities and Exchange Commission rules; reform to the function of the Public Company Accounting Oversight Board; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); SEC Staff Report Review of the Accredited Investor Definition under the Dodd Frank Act; index fund passivity; oversight issues and potential legislation on third party litigation funding (including its national security implications)

PL 111-203 Dodd-Frank Wall Street Reform and Consumer Protection Act - various financial reforms HR 448 Putting Investors First Act - requires a proxy advisory firm to register with the SEC and other restrictions HR 500 Financial Exploitation Prevention Act - allows for the delay of the redemption of a security if it is reasonably believed the redemption involves the financial exploitation HR 8521 (117th) Investor Democracy is Expected (INDEX) Act - guidelines for passively index funds that vote shares on behalf of fund investors HR 9408/S 5005 (117th) Mandatory Materiality Requirement Act - limits additional disclosure requirements applicable to issuers of securities Issue Mutual Fund Swing Pricing/Hard Close Requirements Issue Insurance Capital Standards and Systemic Risk Issue SEC Rule 15c2-11/144A Securities Issue Environmental, Social, Governance Issue Federal Home Loan Bank Issues HR 1807 Improving Disclosure for Investors Act - Direct SEC to promulgate rules with respect to the electronic delivery of certain required disclosures DRAFT To except quotations of Rule 144A fixed-income securities from certain regulatory requirements HR 2891/S 1323 SAFE Banking Act -- To create protections for financial institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses HR 835Fair Investment Opportunities for Professional Experts Act -- expands the eligibility criteria for an accredited investor HR 1579 Accredited Investor Definition Review Act -- expands the eligibility criteria for an accredited investor HR 3746 Fiscal Responsibility Act of 2023 - increases the federal debt limit, establishes new discretionary spending limits, rescinds unobligated funds, expands work requirements for federal programs, and modifies other requirements related to the federal budget process. HR 3812 FSOC Improvement Act -- amend the Financial Stability Act of 2010 to require the Financial Stability Oversight Council to consider alternative approaches before determining that a U.S. nonbank financial company shall be supervised by the Board of Governors of the Federal Reserve System HR 2891/S 1323 SAFER Banking Act - prohibits a federal banking regulator from penalizing a depository institution for providing banking services to a legitimate cannabis-related business S 3815-Improving Disclosures for Investors Act of 2024 S 3815 - Improving Disclosures for Investors Act of 2024 S 4371 - Empowering States to Protect Seniors from Bad Actors Act S 4917 - Retirement Fairness for Charities and Educational Institutions Act of 2024 - to amend the Federal securities laws to enhance 403(b) plans HR 10545 American Relief Act, 2025 Draft - CDA Registration Streamlining

Issues related to Securities and Exchange Commission Regulation Best Interest (Regulation BI). Proposed Securities and Exchange Commission Rule 223-1: Safeguarding Advisory Client Assets (Custody Rule). Conflicts of Interest and Predictive Data Analytics Proposal. Regulation D and Accredited Investor Definition. Share Repurchase Disclosure Modernization Proposal. Issues relating to 401(k) defined contributions. H.R. 835, Fair Investment Opportunities for Professional Experts Act, all provisions. H.R. 1579, Accredited Investor Definition Review Act, all provisions. H.R. 2797, Equal Opportunity for All Investors Act of 2023, all provisions. H.R. 2593, Senior Security Act of 2023, all provisions. H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act, all provisions. H.R. 2799, Expanding Access to Capital Act of 2023, all provisions. H.R. 2627, Increasing Investor Opportunities Act, all provisions. Issues relating to fiduciary duties regarding asset classes under ERISA (Retirement Savings Modernization Act).

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

Banking Policy Impacting Emerging Companies ---Regulatory Burden Capital Formation Incentives ---H.R.368: American Innovation Act of 2023 ---H.R.448: Putting Investors First Act of 2023 ---H.R.835: Fair Investment Opportunities for Professional Experts Act ---H.R.1579: Accredited Investor Definition Review Act ---H.R.2608: To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes. ---H.R.2610: To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes. ---H.R.2624: Helping Startups Continue to Grow Act ---H.R.2673: American Innovation and R&D Competitiveness Act ---H.R.2792: Small Entity Update Act ---H.R.2797: Equal Opportunity for All Investors Act of 2023 ---H.R.2799: Expanding Access to Capital Act of 2023 ---H.R.7515: Infectious Disease Therapies Research and Innovation Act ---S.866: American Innovation and Jobs Act ---H.R.9562 Adjusting the well known seasoned issuers definition to allow for a larger financing round using ---Implementation of the Inflation Reduction Act (IRA) of 2022 ---Convert public float thresholds to soft triggers from hard triggers to avoid surprise expenses by implementing a rolling average window ---Net Operating Loss Advance Refunds ---Update Form S-3 holding period from 12 months to six months to reflect Wall Street standards ---Update public float threshold triggers to align with current market conditions Capital Market Enhancements ---Accredited Investor Definition ---Amended Definition of Smaller Reporting Company ---JOBS Act 4.0 ---Market Liquidity Proposals ---Public Float Threshold Update ---SEC Small Business Forum ---Small Business Capital Formation Enhancement Act Mergers and Acquisitions Reform of SEC Regulation D ---Accredited Investor Certification Sarbanes Oxley Section 404 (b) ---Small Issuer Exemption Small Business Innovation Research (SBIR) Program ---Reauthorization of SBIR and STTR ---Implementation of the SBIR and STTR Extension Act of 2022

Issues related to crypto & digital assets including digital assets market structure (H.R.4763, the Financial Innovation and Technology for the 21st Century Act and S. 2281, the Responsible Financial Innovation Act) and Stablecoins legislation including H.R. 4766, the Clarity for Payment Stablecoins Act and S. 4155, the Lummis, Gillibrand Payment Stablecoins Act Restrictions on outbound investments to China SAB-121and its accounting and capital impacts on firms offering / holding crypto assets Money Market Fund (MMF) regulation Retail investor access to alternative investments & private markets, including H.R. 2627, the Increasing Investor Opportunities Act and draft Senate companion legislation Accredited investor reform initiatives including H.R.835, the Fair Investment Opportunities for Professional Experts Act, H.R. 2797, the Equal Opportunity for All Investors Act, H.R. 1579, the Accredited Investor Definition Review Act, and H.R. 2773 which amends the definition of an accredited investor to include individuals receiving advice from certain professionals Capital formation initiatives including H.R. 2799, the Expanding Access to Capital Act and the Senate Empowering Main Street in America Act E-delivery initiatives including H.R. 1807 the Improving Disclosure for Investors Act and Senate proposals Retirement security initiatives, including H.R. 3063, the Retirement Fairness for Charities and Educational Institutions Act and Securing a Strong Retirement Act (SECURE Act) 2.0 implementation and modifications Retirement savings tax incentives including tax deferral for individuals participating in voluntary, employer provided retirement plans and IRAs Legislation and oversight of ESG investing including proxy voting by asset managers Congressional oversight of SEC rulemakings such as mandatory swing pricing, hard close, liquidity risk management proposal, predictive data analytics, and the NYSE proposal to eliminate annual meeting requirements for CEFs. Congressional oversight of the DOL Fiduciary rule proposal and CRA initiatives to disapprove the rule such as H.J.Res. 142 and S.J.Res 79 Basel III proposal and bank capital standards impact on asset managers

H.R. 448, Putting Investors First Act of 2023 H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 835, Fair Investment Opportunities for Professional Experts Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 1410, Consumer Financial Protection Commission Act H.R. 1548, Improving Access to Small Business Information Act H.R. 1553, Helping Angels Lead our Startups (HALOS) Act H.R. 1579, Accredited Investor Definition Review Act H.R. 2608, To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes H.R. 2610, To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes H.R. 2612, Gig Worker Equity Compensation Act H.R. 2627, Increasing Investor Opportunities Act H.R. 2652, Investment Opportunity Expansion Act H.R. 2792, Small Entity Update Act H.R. 2793, Encouraging Public Offerings Act of 2023 H.R. 2795, Enhancing Multi-Class Share Disclosures Act H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2797, Equal Opportunity for All Investors Act H.R. 2798, CFPB Transparency and Accountability Reform Act H.R. 2799/S. 3815, Expanding Access to Capital Act of 2023 H.R. 2812, Middle Market IPO Underwriting Cost Act H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act H.R. 3161, CDFI Fund Transparency Act H.R. 4035, Protecting Small Business Information Act of 2023 H.R. 4168/S. 2005, Mandatory Materiality Requirement Act of 2023 H.R. 4177/S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 4366, Consolidated Appropriations Act, 2024, including provisions related to Senate Amendment 1217 and Senate Amendments 1092 H.R. 4664/S. 2309, Making appropriations for financial services and general government for the fiscal year ending September 30, 2024, and for other purposes H.R. 4790, Prioritizing Economic Growth Over Woke Policies Act H.R. 4823, American Financial Institution Regulator Sovereignty and Transparency Act H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 H.R. 7000/S. 3592, Business of Insurance Regulatory Reform Act of 2024 H.R. 7092/S. 3676, Protecting Private Job Creators Act H.R. 7470/S.3823, Secure U.S. Leadership in Space Act of 2024 H.R. 8337, Bank Resilience and Regulatory Improvement Act H.R. 8338, Clarity in Lending Act H.R. 8339, SEC Reform and Restructuring Act H.R. 8773, Financial Services and General Government Appropriations Act, 2025 S. 638, Disclosure of Tax Havens and Offshoring Act S. 3541, Fair Audits and Inspections for Regulators Exams Act S. 5139, Empowering Main Street in America Act of 2024 H.J.Res. 100/S.J.Res. 50, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to "Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure" H.J.Res. 120, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Stability Oversight Council related to "Guidance on Nonbank Financial Company Determinations" H.J.Res. 122/H.J.Res.121/S.J.Res.70, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z)" H.J.Res. 201, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders" Potential legislation similar to H.R. 5598, Access to Small Business Investor Capital Act Potential legislation similar to H.R. 2025/S. 840, Litigation Funding Transparency Act SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Proposed Rule, Securities and Exchange Commission; Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (87 Fed. Reg. 77,172-77,296, December 16, 2022) Proposed Rule, Public Company Accounting Oversight Board; Amendments to Reporting Requirements for Registered Firms (PCAOB Release No. 2024-003, April 9, 2024; PCAOB Rulemaking Docket Matter No. 055) Proposed Rule, Public Company Accounting Oversight Board; Amendments to False or Misleading Statements Concerning PCAOB Registration and Oversight and Constructive Requests to Withdraw from Registration (PCAOB Release No. 2024-001, February 27, 2024; PCAOB Rulemaking Docket Matter No. 054) Proposed Rule, Public Company Accounting Oversight Board; Amendments to Firm and Engagement Metrics (PCAOB Release No. 2024-002, April 9, 2024; PCAOB Rulemaking Docket Matter No. 041) Adopting Order of the Securities and Exchange Commission: Public Company Accounting Oversight Board Amendments to QC 1000, A Firms System of Quality Control and Related Amendments to PCAOB Standards, Rules, and Forms (SEC Release No 34-100968; PCAOB File No. PCAOB-2024-002) Request for Information, U.S. Treasury, Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector (TREAS-DO-2024-0011, June 12, 2024) Request for Comment, Commodity Futures Trading Commission (CFTC), The Use of Artificial Intelligence (AI) in CFTC-regulated derivatives markets (Fed. Reg. 89, 65,606, August 12, 2024) Final Rule, Security Exchange Commission, on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (88 Fed. Reg. 51,896-51,945, September 5, 2023) Proposed Rule, Security Exchange Commission, on Changes to 14a-8 (87 Fed. Reg. 45,052-45,075, July 27, 2022) Final Rule, Security Exchange Commission, on Share Repurchase Disclosure Modernization (88 Fed. Reg. 36,002-36,063, July 31, 2023) Proposed Rule, Securities and Exchange Commission, Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices (87 Fed. Reg. 63,016-63,017, October 18, 2022) Proposed Rule, Securities and Exchange Commission, Outsourcing by Investment Advisers (87 Fed. Reg. 68,816-68,883, November 16, 2022) Proposed Rule, Securities and Exchange Commission; Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (88 Fed. Reg. 53,960- 54,024, August 9, 2023) Proposed Rule, Security Exchange Commission, on Private Fund Advisers (87 FR 16,886, February 9, 2022) Proposed Rule, Security Exchange Commission, on Safeguarding Advisory Client Assets (88 Fed. Reg 14,672-14,792, March 9, 2023) Proposed Rule, Public Company Accounting Oversight Board; Amendments to PCAOB Auditing Standards related to a Companys Noncompliance with Laws and Regulations (PCAOB Release No. 2023-003/PCAOB Rulemaking Docket Matter No. 051, June 6, 2023) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council activities, including the approach to and designation of systemic importance and risk of nonbank financial companies and firms; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Financial Accounting Standards Board improvements to income tax disclosures; climate-related financial risk management for large banks; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; Basel III Endgame Rule; FDIC Monitoring of Investment Funds Passivity Agreements; issues related to the Export-Import Bank of the United States; European Commission debates over stricter rules on third-party delegation; European Union Capital Markets Union; retail participation in capital markets; United Kingdom pensions reform; European Unions Corporate Sustainability Due Diligence Directive (CSDDD); EU sustainable finance action plan and incorporating ESG factors into financial services; reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; reporting metrics of American companies under the California climate disclosure laws; reporting metrics of American companies on diversity, equity, and inclusion; reporting metrics of American companies on executive compensation; reporting metrics for private companies under Securities and Exchange Commission rules; reform to the function of the Public Company Accounting Oversight Board; interconnectedness of the SECs rulemaking agenda; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); SEC Staff Report Review of the Accredited Investor Definition under the Dodd Frank Act; index fund passivity; oversight issues and potential legislation on third party litigation funding (including its national security implications)

H.R. 1379/ S. 4890, Access to Small Business Investor Capital Act, regarding all provisions. H.R. 2627, Increasing Investor Opportunities Act, regarding all provisions. H.R. 835, Fair Investment Opportunities for Professionals Act, regarding all provisions. H.R. 2797, Equal Opportunity for All Investors Act, regarding all provisions. H.R. 1579, Accredited Investor Definition Review Act, regarding all provisions. H.R. 2799, Expanding Access to Capital Act, provisions related to accredited investors and provisions related to closed-end funds. Issues related to co-investment for business development companies.

Client expense: $140,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 5139, the Empowering Main Street in America Act H.R. 835, the Fair Investment Opportunities for Professional Experts Act H.R. 1579, the Accredited Investor Definition Review Act H.R. 1548, the Improving Access to Small Business Information Act H.R. 2797, the Equal Opportunity for All Investors Act H.R. 1807, the Improving Disclosure for Investors Act of 2023 H.R. 2796, the Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2799, the Expanding Access to Capital Act H.R. 2612, the Gig Worker Equity Compensation Act H.R. 2579, the Developing and Empowering our Aspiring Leaders Act of 2023 H.R.2799, the Expanding Access to Capital Act of 2023 H.R.2590, the Unlocking Capital for Small Businesses Act of 2023 Corporate Transparency Act: Pub. L. No. 116-283 (January 1, 2021) Private markets & capital formation generally

Client expense: $100,000 · Firm income: Not reported

Government targets: Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

PL 111-203 Dodd-Frank Wall Street Reform and Consumer Protection Act - various financial reforms HR 448 Putting Investors First Act - requires a proxy advisory firm to register with the SEC and other restrictions HR 500 Financial Exploitation Prevention Act - allows for the delay of the redemption of a security if it is reasonably believed the redemption involves the financial exploitation HR 8521 (117th) Investor Democracy is Expected (INDEX) Act - guidelines for passively index funds that vote shares on behalf of fund investors HR 9408/S 5005 (117th) Mandatory Materiality Requirement Act - limits additional disclosure requirements applicable to issuers of securities Issue Mutual Fund Swing Pricing/Hard Close Requirements Issue Insurance Capital Standards and Systemic Risk Issue SEC Rule 15c2-11/144A Securities Issue Environmental, Social, Governance Issue Federal Home Loan Bank Issues HR 1807 Improving Disclosure for Investors Act - Direct SEC to promulgate rules with respect to the electronic delivery of certain required disclosures DRAFT To except quotations of Rule 144A fixed-income securities from certain regulatory requirements HR 2891/S 1323 SAFE Banking Act -- To create protections for financial institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses HR 835Fair Investment Opportunities for Professional Experts Act -- expands the eligibility criteria for an accredited investor HR 1579 Accredited Investor Definition Review Act -- expands the eligibility criteria for an accredited investor HR 3746 Fiscal Responsibility Act of 2023 - increases the federal debt limit, establishes new discretionary spending limits, rescinds unobligated funds, expands work requirements for federal programs, and modifies other requirements related to the federal budget process. HR 3812 FSOC Improvement Act -- amend the Financial Stability Act of 2010 to require the Financial Stability Oversight Council to consider alternative approaches before determining that a U.S. nonbank financial company shall be supervised by the Board of Governors of the Federal Reserve System HR 2891/S 1323 SAFER Banking Act - prohibits a federal banking regulator from penalizing a depository institution for providing banking services to a legitimate cannabis-related business S 3815-Improving Disclosures for Investors Act of 2024 S 3815 - Improving Disclosures for Investors Act of 2024 S 4371 - Empowering States to Protect Seniors from Bad Actors Act S 4917 - Retirement Fairness for Charities and Educational Institutions Act of 2024 - to amend the Federal securities laws to enhance 403(b) plans

Issues related to crypto & digital assets including digital assets market structure (H.R.4763, the Financial Innovation and Technology for the 21st Century Act and S. 2281, the Responsible Financial Innovation Act) and Stablecoins legislation including H.R. 4766, the Clarity for Payment Stablecoins Act and S. 4155, the Lummis, Gillibrand Payment Stablecoins Act SAB-121 and its accounting and capital impacts on firms offering / holding crypto assets Money Market Fund (MMF) regulation Retail investor access to alternative investments & private markets, including H.R. 2627, the Increasing Investor Opportunities Act and draft Senate legislation Accredited investor reform initiatives including H.R.835, the Fair Investment Opportunities for Professional Experts Act, H.R. 2797, the Equal Opportunity for All Investors Act, H.R. 1579, the Accredited Investor Definition Review Act, and H.R. 2773 which amends the definition of an accredited investor to include individuals receiving advice from certain professionals Capital formation initiatives including H.R. 2799, the Expanding Access to Capital Act and draft Senate proposals E-delivery initiatives including H.R. 1807 the Improving Disclosure for Investors Act Retirement security initiatives, including H.R. 3063, the Retirement Fairness for Charities and Educational Institutions Act and Securing a Strong Retirement Act (SECURE Act) 2.0 implementation and modifications Retirement savings tax incentives including tax deferral for individuals participating in voluntary, employer provided retirement plans and IRAs Legislation and oversight of ESG investing including proxy voting by asset managers Congressional oversight of SEC rulemakings such as mandatory swing pricing, hard close, liquidity risk management proposal, and predictive data analytics Congressional oversight of the DOL Fiduciary rule proposal and CRA initiatives to disapprove the rule such as H.J.Res. 142 and S.J.Res 79 Basel III proposal and bank capital standards impact on asset managers

H.R. 448, Putting Investors First Act of 2023 H.R. 758, Promoting Access to Capital in Underbanked Communities Act of 2023 H.R. 835, Fair Investment Opportunities for Professional Experts Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 1410, Consumer Financial Protection Commission Act H.R. 1548, Improving Access to Small Business Information Act H.R. 1553, Helping Angels Lead our Startups (HALOS) Act H.R. 1579, Accredited Investor Definition Review Act H.R. 2608, To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes H.R. 2610, To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes H.R. 2612, Gig Worker Equity Compensation Act H.R. 2627, Increasing Investor Opportunities Act H.R. 2652, Investment Opportunity Expansion Act H.R. 2792, Small Entity Update Act H.R. 2793, Encouraging Public Offerings Act of 2023 H.R. 2795, Enhancing Multi-Class Share Disclosures Act H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2797, Equal Opportunity for All Investors Act H.R. 2798, CFPB Transparency and Accountability Reform Act H.R. 2799/S. 3815, Expanding Access to Capital Act of 2023 H.R. 2812, Middle Market IPO Underwriting Cost Act H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act H.R. 3161, CDFI Fund Transparency Act H.R. 4035, Protecting Small Business Information Act of 2023 H.R. 4168/S. 2005, Mandatory Materiality Requirement Act of 2023 H.R. 4177/S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 4366, Consolidated Appropriations Act, 2024, including provisions related to Senate Amendment 1217 and Senate Amendment 1092 H.R. 4664/S. 2309, Making appropriations for financial services and general government for the fiscal year ending September 30, 2024, and for other purposes H.R. 4823, American Financial Institution Regulator Sovereignty and Transparency Act H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 H.R. 7000/S. 3592, Business of Insurance Regulatory Reform Act of 2024 H.R. 7092/S. 3676, Protecting Private Job Creators Act H.R. 7470/S.3823, Secure U.S. Leadership in Space Act of 2024 H.R. 8070, Service Member Quality of Life Improvement and National Defense Authorization for Fiscal Year 2025 H.R. 8337, Bank Resilience and Regulatory Improvement Act H.R. 8338, Clarity in Lending Act H.R. 8339, SEC Reform and Restructuring Act H.R. 8773, Financial Services and General Government Appropriations Act, 2025 S. 638, Disclosure of Tax Havens and Offshoring Act S. 3541, Fair Audits and Inspections for Regulators Exams Act H.J.Res. 100 / S.J.Res. 50, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to "Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure" H.J.Res. 120, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Stability Oversight Council related to "Guidance on Nonbank Financial Company Determinations" H.J.Res. 122/H.J.Res.121/S.J.Res.70, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to "Credit Card Penalty Fees (Regulation Z)" Draft legislation titled Accredited Investor Self-Certification Act Potential legislation on environmental, social, and governance issues Potential legislation to reform the Securities and Exchange Commission Potential legislation similar to H.R. 5598, Access to Small Business Investor Capital Act Potential legislation similar to H.R. 2025/S. 840, Litigation Funding Transparency Act SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Proposed Rule, Securities and Exchange Commission; Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (87 Fed. Reg. 77,172-77,296, December 16, 2022) Notice of Proposed Rulemaking, Internal Revenue Service (IRS), Treasury; Excise Tax on Repurchase of Corporate Stock-Procedure and Administration (89 Fed. Reg. 25,829-25,834, April 12, 2024) Notice of Proposed Rulemaking, Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property (89 Fed. Reg. 25,551-25,553, April 11, 2024) Proposed Rule, Public Company Accounting Oversight Board; Amendments to Reporting Requirements for Registered Firms (PCAOB Release No. 2024-003, April 9, 2024; PCAOB Rulemaking Docket Matter No. 055) Proposed Rule, Public Company Accounting Oversight Board; Amendments to False or Misleading Statements Concerning PCAOB Registration and Oversight and Constructive Requests to Withdraw from Registration (PCAOB Release No. 2024-001, February 27, 2024; PCAOB Rulemaking Docket Matter No. 054) Proposed Rule, Public Company Accounting Oversight Board; Amendments to Firm and Engagement Metrics (PCAOB Release No. 2024-002, April 9, 2024; PCAOB Rulemaking Docket Matter No. 041) Final Rule, Security Exchange Commission on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (88 Fed. Reg. 51,896-51,945, September 5, 2023) Proposed Rule, Security Exchange Commission on Changes to 14a-8 (87 Fed. Reg. 45,052-45,075, July 27, 2022) Proposed Rule, Consumer Financial Protection Bureau; Overdraft Lending: Very Large Financial Institutions (89 Fed. Reg. 13,852-13,908, February 23, 2024) Final Rule, Security Exchange Commission on Share Repurchase Disclosure Modernization (88 Fed. Reg. 36,002-36,063, July 31, 2023) Proposed Rule, FSOC Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies, Proposed Interpretive Guidance (88 Fed. Reg. 26,234-26,244, April 28, 2023) Proposed Rule, FSOC Analytic Framework for Financial Stability Risk Identification, Assessment, and Response, Proposed Analytic Framework (88 Fed. Reg. 26,305-26,311, April 28, 2023) Proposed Rule, Securities and Exchange Commission; Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (88 Fed. Reg. 53,960- 54,024, August 9, 2023) Proposed Rule, Security Exchange Commission on Private Fund Advisers (87 FR 16,886, February 9, 2022) Proposed Rule, Security Exchange Commission on Safeguarding Advisory Client Assets (88 Fed. Reg 14,672-14,792, March 9, 2023) Proposed Rule, Federal Deposit Insurance Corporation; Request for Comment on Proposed Statement of Policy on Bank Merger Transactions (89 Fed. Reg. 29,222-29,244, April 19, 2024) Proposed Rule, Public Company Accounting Oversight Board; Amendments to PCAOB Auditing Standards related to a Companys Noncompliance with Laws and Regulations (PCAOB Release No. 2023-003/PCAOB Rulemaking Docket Matter No. 051, June 6, 2023) Notice and Request for Comment, Consumer Financial Protection Bureau; Agency Information Collection Activities (89 Fed. Reg 4,281-4,282, January 23, 2024) Proposed Rule, Consumer Financial Protection Bureau; Defining Larger Participants of a Market for General Use Digital Consumer Payment Applications (88 Fed. Reg. 80,197-80,216, November 17, 2023) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council activities, including the approach to and designation of systemic importance and risk of nonbank financial companies and firms; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Financial Accounting Standards Board improvements to income tax disclosures; Climate-Related Financial Risk Management for Large Banks; CFPB regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; Basel III Endgame Rule; FDIC Monitoring of Investment Funds Passivity Agreements; issues related to the Export-Import Bank of the United States; EU sustainable finance action plan and incorporating ESG factors into financial services; reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; reporting metrics of American companies under the California climate disclosure laws; interconnectedness of the SECs rulemaking agenda; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); SEC Staff Report Review of the Accredited Investor Definition under the Dodd Frank Act index fund passivity; oversight issues and potential legislation on third party litigation funding (including its national security implications)

H.R. 835, the Fair Investment Opportunities for Professional Experts Act H.R. 1579, the Accredited Investor Definition Review Act H.R. 1548, the Improving Access to Small Business Information Act H.R. 2797, the Equal Opportunity for All Investors Act H.R. 1807, the Improving Disclosure for Investors Act of 2023 H.R. 2796, the Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2799, the Expanding Access to Capital Act H.R. 2612, the Gig Worker Equity Compensation Act H.R. 2579, the Developing and Empowering our Aspiring Leaders Act of 2023 H.R. 2799, the Expanding Access to Capital Act of 2023 H.R. 2590, the Unlocking Capital for Small Businesses Act of 2023 Corporate Transparency Act: Pub. L. No. 116-283 (January 1, 2021)

Client expense: $110,000 · Firm income: Not reported

Government targets: Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

H.R. 1379, Access to Small Business Investor Capital Act, regarding all provisions. H.R. 2627, Increasing Investor Opportunities Act, regarding all provisions. H.R. 835, Fair Investment Opportunities for Professionals Act, regarding all provisions. H.R. 2797, Equal Opportunity for All Investors Act, regarding all provisions. H.R. 1579, Accredited Investor Definition Review Act, regarding all provisions. H.R. 2799, Expanding Access to Capital Act, provisions related to accredited investors and provisions related to closed-end funds. Issues related to co-investment for business development companies. Issues related to financial literacy.

Client expense: $160,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Banking Policy Impacting Emerging Companies ---Regulatory Burden Capital Formation Incentives ---H.R.368: American Innovation Act of 2023 ---H.R.448: Putting Investors First Act of 2023 ---H.R.835: Fair Investment Opportunities for Professional Experts Act ---H.R.1579: Accredited Investor Definition Review Act ---H.R.2608: To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes. ---H.R.2610: To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes. ---H.R.2624: Helping Startups Continue to Grow Act ---H.R.2673: American Innovation and R&D Competitiveness Act ---H.R.2792: Small Entity Update Act ---H.R.2797: Equal Opportunity for All Investors Act of 2023 ---H.R.2799: Expanding Access to Capital Act of 2023 ---H.R.7515: Infectious Disease Therapies Research and Innovation Act ---S.866: American Innovation and Jobs Act ---H.R.9562 Adjusting the well known seasoned issuers definition to allow for a larger financing round using ---Implementation of the Inflation Reduction Act (IRA) of 2022 ---Convert public float thresholds to soft triggers from hard triggers to avoid surprise expenses by implementing a rolling average window ---Net Operating Loss Advance Refunds ---Update Form S-3 holding period from 12 months to six months to reflect Wall Street standards ---Update public float threshold triggers to align with current market conditions Capital Market Enhancements ---Accredited Investor Definition ---Amended Definition of Smaller Reporting Company ---JOBS Act 4.0 ---Market Liquidity Proposals ---Public Float Threshold Update ---SEC Small Business Forum ---Small Business Capital Formation Enhancement Act Mergers and Acquisitions Reform of SEC Regulation D ---Accredited Investor Certification Sarbanes Oxley Section 404 (b) ---Small Issuer Exemption Small Business Innovation Research (SBIR) Program ---Reauthorization of SBIR and STTR ---Implementation of the SBIR and STTR Extension Act of 2022

Biofuels (Non-Funding) ---Incentives for Sustainable Aviation Fuels ---Sustainable Aviation Fuels Tax Credit Capital Formation Incentives ---H.R.368: American Innovation Act of 2023 ---H.R.448: Putting Investors First Act of 2023 ---H.R.835: Fair Investment Opportunities for Professional Experts Act ---H.R.1579: Accredited Investor Definition Review Act ---H.R.2608: To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes. ---H.R.2610: To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes. ---H.R.2624: Helping Startups Continue to Grow Act ---H.R.2673: American Innovation and R&D Competitiveness Act ---H.R.2792: Small Entity Update Act ---H.R.2799: Expanding Access to Capital Act of 2023 ---H.R.2797: Equal Opportunity for All Investors Act of 2023 ---H.R.7515: Infectious Disease Therapies Research and Innovation Act ---H.R. 9562 Adjusting the well-known seasoned issues definition to allow for a larger financing round using ---S.866: American Innovation and Jobs Act ---Convert public float thresholds to soft triggers from hard triggers to avoid surprise expenses by implementing a rolling average window ---Implementation of the Inflation Reduction Act (IRA) of 2022 ---Net Operating Loss Advance Refunds ---Update Form S-3 holding period from 12 months to six months to reflect Wall Street standards ---Update public float threshold triggers to align with current market conditions Orphan Drug Issues Pandemic Preparedness Renewable Chemicals/Bio-based Products (Non-Funding) ---Climate Issues & impact on the agriculture and food sectors Research & Development Tax Credit Reforms ---H.R.2673: American Innovation and R&D Competitiveness Act ---H.R.7024: Tax Relief for American Families and Workers Act of 2024 ---S.866: American Innovation and Jobs Act ---Expensing of R&D Expenditures ---NOL ---R&D Payroll Credit Vaccine Injury Compensation Program ---FY 2025 Appropriations ---H.R.7551: Let Injured Americans Be Legally Empowered (LIABLE) Act ---S.3810: Countermeasure Injury Compensation Fund Amendment Act ---H.R.5142: Vaccine Injury Compensation Modernization Act of 2023 ---H.R.5143: Vaccine Access Improvement Act of 2023 ---VICP CICP (Discussion Draft)

Issues related to Securities and Exchange Commission Regulation Best Interest (Regulation BI). Proposed Securities and Exchange Commission Rule 223-1: Safeguarding Advisory Client Assets (Custody Rule). Conflicts of Interest and Predictive Data Analytics Proposal. Regulation D and Accredited Investor Definition. Share Repurchase Disclosure Modernization Proposal. Issues relating to 401(k) defined contributions. H.R. 835, Fair Investment Opportunities for Professional Experts Act, all provisions. H.R. 1579, Accredited Investor Definition Review Act, all provisions. H.R. 2797, Equal Opportunity for All Investors Act of 2023, all provisions. H.R. 2593, Senior Security Act of 2023, all provisions. H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act, all provisions. H.R. 2799, Expanding Access to Capital Act of 2023, all provisions. H.R. 2627, Increasing Investor Opportunities Act, all provisions. Issues relating to fiduciary duties regarding asset classes under ERISA (Retirement Savings Modernization Act).

Client expense: $70,000 · Firm income: Not reported

PL 111-203 Dodd-Frank Wall Street Reform and Consumer Protection Act - various financial reforms HR 448 Putting Investors First Act - requires a proxy advisory firm to register with the SEC and other restrictions HR 500 Financial Exploitation Prevention Act - allows for the delay of the redemption of a security if it is reasonably believed the redemption involves the financial exploitation HR 8521 (117th) Investor Democracy is Expected (INDEX) Act - guidelines for passively index funds that vote shares on behalf of fund investors HR 9408/S 5005 (117th) Mandatory Materiality Requirement Act - limits additional disclosure requirements applicable to issuers of securities Issue Mutual Fund Swing Pricing/Hard Close Requirements Issue Insurance Capital Standards and Systemic Risk Issue SEC Rule 15c2-11/144A Securities Issue Environmental, Social, Governance Issue Federal Home Loan Bank Issues HR 1807 Improving Disclosure for Investors Act - Direct SEC to promulgate rules with respect to the electronic delivery of certain required disclosures DRAFT To except quotations of Rule 144A fixed-income securities from certain regulatory requirements HR 2891/S 1323 SAFE Banking Act -- To create protections for financial institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses HR 835Fair Investment Opportunities for Professional Experts Act -- expands the eligibility criteria for an accredited investor HR 1579 Accredited Investor Definition Review Act -- expands the eligibility criteria for an accredited investor HR 3746 Fiscal Responsibility Act of 2023 - increases the federal debt limit, establishes new discretionary spending limits, rescinds unobligated funds, expands work requirements for federal programs, and modifies other requirements related to the federal budget process. HR 3812 FSOC Improvement Act -- amend the Financial Stability Act of 2010 to require the Financial Stability Oversight Council to consider alternative approaches before determining that a U.S. nonbank financial company shall be supervised by the Board of Governors of the Federal Reserve System HR 2891/S 1323 SAFER Banking Act - prohibits a federal banking regulator from penalizing a depository institution for providing banking services to a legitimate cannabis-related business S 3815-Improving Disclosures for Investors Act of 2024 S 3815 - Improving Disclosures for Investors Act of 2024 S 4371 - Empowering States to Protect Seniors from Bad Actors Act

Banking Policy Impacting Emerging Companies Capital Formation Incentives ---H.R.368: American Innovation Act of 2023 ---H.R.448: Putting Investors First Act of 2023 ---H.R.835: Fair Investment Opportunities for Professional Experts Act ---H.R.1579: Accredited Investor Definition Review Act ---H.R.2608: To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes. ---H.R.2610: To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes. ---H.R.2624: Helping Startups Continue to Grow Act ---H.R.2673: American Innovation and R&D Competitiveness Act ---H.R.2792: Small Entity Update Act ---H.R.2797: Equal Opportunity for All Investors Act of 2023 ---H.R.2799: Expanding Access to Capital Act of 2023 ---H.R.7515: Infectious Disease Therapies Research and Innovation Act ---S.866: American Innovation and Jobs Act ---Implementation of the Inflation Reduction Act (IRA) of 2022 ---Net Operating Loss Advance Refunds Capital Market Enhancements ---Accredited Investor Definition ---Amended Definition of Smaller Reporting Company ---Market Liquidity Proposals ---Public Float Threshold Update ---SEC Small Business Forum Reform of SEC Regulation D ---Accredited Investor Certification Sarbanes Oxley Section 404 (b) ---Small Issuer Exemption Small Business Innovation Research (SBIR) Program ---Reauthorization of SBIR and STTR

Client expense: $1,760,000 · Firm income: Not reported

Biofuels (Non-Funding) ---Incentives for Sustainable Aviation Fuels ---Sustainable Aviation Fuels Tax Credit Capital Formation Incentives ---H.R.368: American Innovation Act of 2023 ---H.R.448: Putting Investors First Act of 2023 ---H.R.835: Fair Investment Opportunities for Professional Experts Act ---H.R.1579: Accredited Investor Definition Review Act ---H.R.2608: To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes. ---H.R.2610: To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes. ---H.R.2624: Helping Startups Continue to Grow Act ---H.R.2673: American Innovation and R&D Competitiveness Act ---H.R.2792: Small Entity Update Act ---H.R.2797: Equal Opportunity for All Investors Act of 2023 ---H.R.2799: Expanding Access to Capital Act of 2023 ---H.R.7515: Infectious Disease Therapies Research and Innovation Act ---S.866: American Innovation and Jobs Act ---Implementation of the Inflation Reduction Act (IRA) of 2022 ---Net Operating Loss Advance Refunds Coronavirus (COVID-19) Pandemic Orphan Drug Issues Qualified Small Business Stock (QSBS) Renewable Chemicals/Bio-based Products (Non-Funding) ---Climate Issues & impact on the agriculture, food, and forestry sectors ---Investment Tax Credit ---Production Tax Credit Research & Development Tax Credit Reforms ---H.R.2673: American Innovation and R&D Competitiveness Act ---H.R.7024: Tax Relief for American Families and Workers Act of 2024 ---S.866: American Innovation and Jobs Act ---Expensing of R&D Expenditures Vaccine Injury Compensation Program ---FY 2024 Appropriations ---FY 2025 Appropriations ---H.R.7551: Let Injured Americans Be Legally Empowered (LIABLE) Act ---S.3810: Countermeasure Injury Compensation Fund Amendment Act ---H.R.5142: Vaccine Injury Compensation Modernization Act of 2023 ---H.R.5143: Vaccine Access Improvement Act of 2023 ---VICP CICP (Discussion Draft)

Biofuels (Non-Funding) ---Incentives for Sustainable Aviation Fuels ---Sustainable Aviation Fuels Tax Credit Capital Formation Incentives ---H.R.368: American Innovation Act of 2023 ---H.R.448: Putting Investors First Act of 2023 ---H.R.835: Fair Investment Opportunities for Professional Experts Act ---H.R.1579: Accredited Investor Definition Review Act ---H.R.2608: To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes. ---H.R.2610: To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes. ---H.R.2624: Helping Startups Continue to Grow Act ---H.R.2673: American Innovation and R&D Competitiveness Act ---H.R.2792: Small Entity Update Act ---H.R.2797: Equal Opportunity for All Investors Act of 2023 ---H.R.2799: Expanding Access to Capital Act of 2023 ---H.R.7515: Infectious Disease Therapies Research and Innovation Act ---S.866: American Innovation and Jobs Act ---Implementation of the Inflation Reduction Act (IRA) of 2022 ---Net Operating Loss Advance Refunds Coronavirus (COVID-19) Pandemic Orphan Drug Issues Qualified Small Business Stock (QSBS) Renewable Chemicals/Bio-based Products (Non-Funding) ---Climate Issues & impact on the agriculture, food, and forestry sectors ---Investment Tax Credit ---Production Tax Credit Research & Development Tax Credit Reforms ---H.R.2673: American Innovation and R&D Competitiveness Act ---H.R.7024: Tax Relief for American Families and Workers Act of 2024 ---S.866: American Innovation and Jobs Act ---Expensing of R&D Expenditures Vaccine Injury Compensation Program ---FY 2024 Appropriations ---FY 2025 Appropriations ---H.R.7551: Let Injured Americans Be Legally Empowered (LIABLE) Act ---S.3810: Countermeasure Injury Compensation Fund Amendment Act ---H.R.5142: Vaccine Injury Compensation Modernization Act of 2023 ---H.R.5143: Vaccine Access Improvement Act of 2023 ---VICP CICP (Discussion Draft)

Banking Policy Impacting Emerging Companies Capital Formation Incentives ---H.R.368: American Innovation Act of 2023 ---H.R.448: Putting Investors First Act of 2023 ---H.R.835: Fair Investment Opportunities for Professional Experts Act ---H.R.1579: Accredited Investor Definition Review Act ---H.R.2608: To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes. ---H.R.2610: To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes. ---H.R.2624: Helping Startups Continue to Grow Act ---H.R.2673: American Innovation and R&D Competitiveness Act ---H.R.2792: Small Entity Update Act ---H.R.2797: Equal Opportunity for All Investors Act of 2023 ---H.R.2799: Expanding Access to Capital Act of 2023 ---H.R.7515: Infectious Disease Therapies Research and Innovation Act ---S.866: American Innovation and Jobs Act ---Implementation of the Inflation Reduction Act (IRA) of 2022 ---Net Operating Loss Advance Refunds Capital Market Enhancements ---Accredited Investor Definition ---Amended Definition of Smaller Reporting Company ---Market Liquidity Proposals ---Public Float Threshold Update ---SEC Small Business Forum Reform of SEC Regulation D ---Accredited Investor Certification Sarbanes Oxley Section 404 (b) ---Small Issuer Exemption Small Business Innovation Research (SBIR) Program ---Reauthorization of SBIR and STTR

Client expense: $1,760,000 · Firm income: Not reported

H.R. 448, Putting Investors First Act of 2023 H.R. 835, Fair Investment Opportunities for Professional Experts Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 1410, Consumer Financial Protection Commission Act H.R. 1548, Improving Access to Small Business Information Act H.R. 1553, Helping Angels Lead our Startups (HALOS) Act H.R. 1579, Accredited Investor Definition Review Act H.R. 2608, To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes H.R. 2610, To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes H.R. 2612, Gig Worker Equity Compensation Act H.R. 2627, Increasing Investor Opportunities Act H.R. 2652, Investment Opportunity Expansion Act H.R. 2792, Small Entity Update Act H.R. 2793, Encouraging Public Offerings Act of 2023 H.R. 2795, Enhancing Multi-Class Share Disclosures Act H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2797, Equal Opportunity for All Investors Act H.R. 2798, CFPB Transparency and Accountability Reform Act H.R. 2799, Expanding Access to Capital Act of 2023, H.R. 2812, Middle Market IPO Underwriting Cost Act H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act H.R. 3466, To enhance Financial Stability Oversight Council transparency H.R. 3812/S. 3601, Financial Stability Oversight Council Improvement Act of 2023 H.R. 4035, Protecting Small Business Information Act of 2023 H.R. 4168/S. 2005, Mandatory Materiality Requirement Act of 2023 H.R. 4177/S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 4366, Consolidated Appropriations Act, 2024, including provisions related to Senate Amendment 1217 and Senate Amendment 1092 H.R. 4664/S. 2309, Making appropriations for financial services and general government for the fiscal year ending September 30, 2024, and for other purposes H.R. 4823, American Financial Institution Regulator Sovereignty and Transparency Act H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 H.R. 7000/S. 3592, Business of Insurance Regulatory Reform Act of 2024 H.R. 7092/S. 3676, Protecting Private Job Creators Act S. 638, Disclosure of Tax Havens and Offshoring Act S. 3735, Protecting Innovation in Investment Act H.J.Res.100 / S.J.Res.50, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to "Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure" Draft legislation titled Accredited Investor Self-Certification Act Potential legislation on environmental, social, and governance Potential legislation to reform the Securities and Exchange Commission Potential legislation related to the Foreign Agents Registration Act Potential legislation similar to H.R. 5598, Access to Small Business Investor Capital Act Potential legislation similar to H.R. 2025/S. 840, Litigation Funding Transparency Act SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Proposed Rule, Securities and Exchange Commission; Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (87 Fed. Reg. 77,172-77,296, December 16, 2022) SEC Final Rule on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (88 Fed. Reg. 51,896-51,945, September 5, 2023) SEC Proposed Rule on Changes to 14a-8 (87 Fed. Reg. 45,052-45,075, July 27, 2022) SEC Final Rule on Share Repurchase Disclosure Modernization (88 Fed. Reg. 36,002-36,063, July 31, 2023) Proposed Rule, FSOC Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies, Proposed Interpretive Guidance (88 Fed. Reg. 26,234-26,244, April 28, 2023) Proposed Rule, FSOC Analytic Framework for Financial Stability Risk Identification, Assessment, and Response, Proposed Analytic Framework (88 Fed. Reg. 26,305-26,311, April 28, 2023) Proposed Rule, Securities and Exchange Commission; Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (88 Fed. Reg. 53,960- 54,024, August 9, 2023) Proposed Rule, Public Company Accounting Oversight Board; Amendments to PCAOB Auditing Standards related to a Companys Noncompliance with Laws and Regulations (PCAOB Release No. 2023-003/PCAOB Rulemaking Docket Matter No. 051, June 6, 2023) Notice and Request for Comment, Consumer Financial Protection Bureau; Agency Information Collection Activities (89 Fed. Reg 4,281-4,282, January 23, 2024) Proposed Rule, Consumer Financial Protection Bureau; Defining Larger Participants of a Market for General Use Digital Consumer Payment Applications (88 Fed. Reg. 80,197-80,216, November 17, 2023) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council activities, including the approach to and designation of systemic importance and risk of nonbank financial companies and firms; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Financial Accounting Standards Board improvements to income tax disclosures; Climate-Related Financial Risk Management for Large Banks; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Proposed Rule, Securities and Exchange Commission; Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (SEC Rel. Nos. 34-97990; IA-6353; File No. S7-12-23, July 26, 2023); Proposing Release: Amendments to PCAOB Auditing Standards related to a Companys Noncompliance with Laws and Regulations; Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; Basel III Endgame Rule; EU sustainable finance action plan and incorporating ESG factors into financial services; potential regulations to require public companies to disclose information related to human capital management; reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; reporting metrics of American companies under the California climate disclosure laws; interconnectedness of the SECs rulemaking agenda; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); SEC Staff Report Review of the Accredited Investor Definition under the Dodd Frank Act; oversight issues and potential legislation on third party litigation funding (including its national security implications)

Issues related to crypto & digital assets including digital assets market structure (H.R.4763, the Financial Innovation and Technology for the 21st Century Act and S. 2281, the Responsible Financial Innovation Act) and Stablecoins legislation including H.R. 4766, the Clarity for Payment Stablecoins Act Money Market Fund (MMF) regulation Retail investor access to alternative investments & private markets, including H.R. 2627, the Increasing Investor Opportunities Act and draft Senate legislation Accredited investor reform initiatives including H.R.835, the Fair Investment Opportunities for Professional Experts Act, H.R. 2797, the Equal Opportunity for All Investors Act, and H.R. 1579, the Accredited Investor Definition Review Act Capital formation initiatives including H.R. 2799, the Expanding Access to Capital Act and draft Senate proposals E-delivery initiatives including H.R. 1807 the Improving Disclosure for Investors Act Retirement security initiatives, including H.R. 3063, the Retirement Fairness for Charities and Educational Institutions Act and Securing a Strong Retirement Act (SECURE Act) 2.0 implementation and modifications Legislation and oversight of ESG investing including proxy voting by asset managers Congressional oversight of SEC rulemakings such as mandatory swing pricing, hard close, liquidity risk management proposal, and predictive data analytics Congressional oversight of the DOL Fiduciary rule proposal Basel III proposal and bank capital standards impact on asset managers

Client expense: $240,000 · Firm income: Not reported

H.R. 835, the Fair Investment Opportunities for Professional Experts Act H.R. 1579, the Accredited Investor Definition Review Act H.R. 1548, the Improving Access to Small Business Information Act H.R. 2797, the Equal Opportunity for All Investors Act H.R. 1807, the Improving Disclosure for Investors Act of 2023 H.R. 2796, the Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2799, the Expanding Access to Capital Act H.R. 2612, the Gig Worker Equity Compensation Act H.R. 2579, the Developing and Empowering our Aspiring Leaders Act of 2023 H.R.2799, the Expanding Access to Capital Act of 2023 H.R.2590, the Unlocking Capital for Small Businesses Act of 2023 Corporate Transparency Act: Pub. L. No. 116-283 (January 1, 2021) Private markets & capital formation generally

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

Government targets: Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

H.R. 1379, Access to Small Business Investor Capital Act, regarding all provisions. H.R. 2627, Increasing Investor Opportunities Act, regarding all provisions. H.R. 835, Fair Investment Opportunities for Professionals Act, regarding all provisions. H.R. 2797, Equal Opportunity for All Investors Act, regarding all provisions. H.R. 1579, Accredited Investor Definition Review Act, regarding all provisions. Issues related to co-investment for business development companies.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

PL 111-203 Dodd-Frank Wall Street Reform and Consumer Protection Act - various financial reforms HR 448 Putting Investors First Act - requires a proxy advisory firm to register with the SEC and other restrictions HR 500 Financial Exploitation Prevention Act - allows for the delay of the redemption of a security if it is reasonably believed the redemption involves the financial exploitation HR 8521 (117th) Investor Democracy is Expected (INDEX) Act - guidelines for passively index funds that vote shares on behalf of fund investors HR 9408/S 5005 (117th) Mandatory Materiality Requirement Act - limits additional disclosure requirements applicable to issuers of securities Issue Mutual Fund Swing Pricing/Hard Close Requirements Issue Insurance Capital Standards and Systemic Risk Issue SEC Rule 15c2-11/144A Securities Issue Environmental, Social, Governance Issue Federal Home Loan Bank Issues HR 1807 Improving Disclosure for Investors Act - Direct SEC to promulgate rules with respect to the electronic delivery of certain required disclosures DRAFT To except quotations of Rule 144A fixed-income securities from certain regulatory requirements HR 2891/S 1323 SAFE Banking Act -- To create protections for financial institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses HR 835Fair Investment Opportunities for Professional Experts Act -- expands the eligibility criteria for an accredited investor HR 1579 Accredited Investor Definition Review Act -- expands the eligibility criteria for an accredited investor HR 3746 Fiscal Responsibility Act of 2023 - increases the federal debt limit, establishes new discretionary spending limits, rescinds unobligated funds, expands work requirements for federal programs, and modifies other requirements related to the federal budget process. HR 3812 FSOC Improvement Act -- amend the Financial Stability Act of 2010 to require the Financial Stability Oversight Council to consider alternative approaches before determining that a U.S. nonbank financial company shall be supervised by the Board of Governors of the Federal Reserve System HR 2891/S 1323 SAFER Banking Act - prohibits a federal banking regulator from penalizing a depository institution for providing banking services to a legitimate cannabis-related business S 3815-Improving Disclosures for Investors Act of 2024

Issues related to Securities and Exchange Commission Regulation BI (Regulation Best Interest). Proposed Securities and Exchange Commission Rule 223-1: Safeguarding Advisory Client Assets (Custody Rule) and Conflicts of Interest and Predictive Data Analytics Proposal. Issues relating to 401(k) defined contributions. H.R. 835, Fair Investment Opportunities for Professional Experts Act, all provisions. H.R. 1579, Accredited Investor Definition Review Act, all provisions. H.R. 2797, Equal Opportunity for All Investors Act of 2023, all provisions. H.R. 2593, Senior Security Act of 2023, all provisions. H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act, all provisions. H.R. 2799, Expanding Access to Capital Act of 2023, all provisions. H.R. 2627, Increasing Investor Opportunities Act, all provisions. Issues relating to fiduciary duties regarding asset classes under ERISA (Retirement Savings Modernization Act).

Client expense: $55,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 1379, Access to Small Business Investor Capital Act, regarding all provisions. H.R. 2627, Increasing Investor Opportunities Act, regarding all provisions. H.R. 835, Fair Investment Opportunities for Professionals Act, regarding all provisions. H.R. 2797, Equal Opportunity for All Investors Act, regarding all provisions. H.R. 1579, Accredited Investor Definition Review Act, regarding all provisions.

Client expense: $110,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Biofuels (Non-Funding) ---Incentives for Sustainable Aviation Fuels ---Sustainable Aviation Fuels Tax Credit Capital Formation Incentives ---H.R.3623/S.2529: Innovation and Growth Now by Investing in Tomorrow's Enterprises (IGNITE) American Innovation Act ---H.R.368: American Innovation Act of 2023 ---H.R.448: Putting Investors First Act of 2023 ---H.R.835: Fair Investment Opportunities for Professional Experts Act ---H.R.1579: Accredited Investor Definition Review Act ---H.R.2608: To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes. ---H.R.2610: To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes. ---H.R.2624: Helping Startups Continue to Grow Act ---H.R.7024: Tax Relief for American Families and Workers Act of 2024 ---H.R.2792: Small Entity Update Act ---H.R.2797: Equal Opportunity for All Investors Act of 2023 ---H.R.2799: Expanding Access to Capital Act of 2023 ---S.866: American Innovation and Jobs Act ---H.R.2673: American Innovation and R&D Competitiveness Act ---A bill to amend the Internal Revenue Code of 1986 to add a new medical research component to the credit for increasing research activities (Discussion Draft) ---A bill to amend the Internal Revenue Code of 1986 to make a portion of research credit refundable for certain small businesses engaging in specified medical research. (Discussion Draft) ---Implementation of the Inflation Reduction Act (IRA) of 2022 ---JOBS Act 4.0 ---Net Operating Loss Advance Refunds Orphan Drug Issues Qualified Small Business Stock (QSBS) Renewable Chemicals/Bio-based Products (Non-Funding) ---Climate Issues & impact on the agriculture, food, and forestry sectors Research & Development Tax Credit Reforms ---H.R.2673: American Innovation and R&D Competitiveness Act ---S.866: American Innovation and Jobs Act ---Expensing of R&D Expenditures ---House - Section 174 Amortization ---R&D Payroll Credit Vaccine Injury Compensation Program ---FY 2024 Appropriations ---Countermeasure Injury Compensation Fund Amendment Act (Discussion Draft) ---H.R. 5142: Vaccine Injury Compensation Modernization Act ---H.R. 5143: Vaccine Access Improvement Act ---VICP CICP (Discussion Draft)

Banking Policy Impacting Emerging Companies Capital Formation Incentives ---H.R.3623/S.2529: Innovation and Growth Now by Investing in Tomorrow's Enterprises (IGNITE) American Innovation Act ---H.R.368: American Innovation Act of 2023 ---H.R.448: Putting Investors First Act of 2023 ---H.R.835: Fair Investment Opportunities for Professional Experts Act ---H.R.1579: Accredited Investor Definition Review Act ---H.R.2608: To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes. ---H.R.2610: To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes. ---H.R.2624: Helping Startups Continue to Grow Act ---H.R.7024: Tax Relief for American Families and Workers Act of 2024 ---H.R.2792: Small Entity Update Act ---H.R.2797: Equal Opportunity for All Investors Act of 2023 ---H.R.2799: Expanding Access to Capital Act of 2023 ---S.866: American Innovation and Jobs Act ---H.R.2673: American Innovation and R&D Competitiveness Act ---A bill to amend the Internal Revenue Code of 1986 to add a new medical research component to the credit for increasing research activities (Discussion Draft) ---A bill to amend the Internal Revenue Code of 1986 to make a portion of research credit refundable for certain small businesses engaging in specified medical research. (Discussion Draft) ---Implementation of the Inflation Reduction Act (IRA) of 2022 ---JOBS Act 4.0 ---Net Operating Loss Advance Refunds Capital Market Enhancements ---Accredited Investor Definition ---Amended Definition of Smaller Reporting Company ---JOBS Act 4.0 ---Market Liquidity Proposals ---SEC Small Business Forum Mergers and Acquisitions Proxy Advisory Services Reform of SEC Regulation D Sarbanes Oxley Section 404 (b) Small Business Innovation Research (SBIR) Program ---Implementation of SBIR and STTR Extension Act of 2022

H.R. 835, the Fair Investment Opportunities for Professional Experts Act H.R. 1579, the Accredited Investor Definition Review Act H.R. 1548, the Improving Access to Small Business Information Act H.R. 2797, the Equal Opportunity for All Investors Act H.R. 1807, the Improving Disclosure for Investors Act of 2023 H.R. 2796, the Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2799, the Expanding Access to Capital Act H.R. 2612, the Gig Worker Equity Compensation Act H.R. 2579, the Developing and Empowering our Aspiring Leaders Act of 2023 H.R.2799, the Expanding Access to Capital Act of 2023 H.R.2590, the Unlocking Capital for Small Businesses Act of 2023 Corporate Transparency Act: Pub. L. No. 116-283 (January 1, 2021)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 448, Putting Investors First Act of 2023 H.R. 835, Fair Investment Opportunities for Professional Experts Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 1410, Consumer Financial Protection Commission Act H.R. 1548, Improving Access to Small Business Information Act H.R. 1553, Helping Angels Lead our Startups (HALOS) Act H.R. 1579, Accredited Investor Definition Review Act H.R. 2608, To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes H.R. 2610, To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes H.R. 2612, Gig Worker Equity Compensation Act H.R. 2627, Increasing Investor Opportunities Act H.R. 2652, Investment Opportunity Expansion Act H.R. 2792, Small Entity Update Act H.R. 2793, Encouraging Public Offerings Act of 2023 H.R. 2795, Enhancing Multi-Class Share Disclosures Act H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2797, Equal Opportunity for All Investors Act H.R. 2798, CFPB Transparency and Accountability Reform Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 2812, Middle Market IPO Underwriting Cost Act H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act H.R. 4035, Protecting Small Business Information Act of 2023 H.R. 4168/S. 2005, Mandatory Materiality Requirement Act of 2023 H.R. 4177/S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 4366, Consolidated Appropriations Act, 2024, including provisions related to Senate Amendment 1217 and Senate Amendment 1092 H.R. 4664/S. 2309, Making appropriations for financial services and general government for the fiscal year ending September 30, 2024, and for other purposes H.R. 4767, Protecting Americans Retirement Savings from Politics Act H.R. 4790, Guiding Uniform and Responsible Disclosure Requirements and Information Limits (GUARDRAIL) Act of 2023 H.R. 4823, American Financial Institution Regulator Sovereignty and Transparency Act H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 S. 638, Disclosure of Tax Havens and Offshoring Act H.J.Res.100 / S.J.Res.50, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to "Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure" Draft legislation titled Accredited Investor Self-Certification Act Potential legislation on environmental, social, and governance Potential legislation dealing with third party litigation funding including its national security implications Potential legislation similar to H.R. 2025/S. 840, Litigation Funding Transparency Act SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Proposed Rule, Securities and Exchange Commission; Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (87 Fed. Reg. 77,172-77,296, December 16, 2022) SEC Final Rule on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (88 Fed. Reg. 51,896-51945, September 5, 2023) SEC Proposed Rule on Changes to 14a-8 (87 FR 45,052-45,075, July 27, 2022) SEC Final Rule on Share Repurchase Disclosure Modernization (88 FR 36,002-36,063, July 31, 2023) Proposed Rule, FSOC Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies, Proposed Interpretive Guidance (88 Fed. Reg. 26,234-26,244, April 28, 2023) Proposed Rule, FSOC Analytic Framework for Financial Stability Risk Identification, Assessment, and Response, Proposed Analytic Framework (88 Fed. Reg. 26,305-26,311, April 28, 2023) Notice of Proposed Rulemaking, Internal Revenue Service and Department of the Treasury; Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions (88 Fed. Reg. 59,576-59,659, August 29, 2023) Proposed Rule, Securities and Exchange Commission; Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (88 Fed. Reg. 53,960- 54,024, August 9, 2023) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council activities, including the approach to and designation of systemic importance and risk of nonbank financial companies and firms; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Financial Accounting Standards Board improvements to income tax disclosures; Climate-Related Financial Risk Management for Large Banks; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Proposed Rule, Securities and Exchange Commission; Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (SEC Rel. Nos. 34-97990; IA-6353; File No. S7-12-23, July 26, 2023); Proposing Release: Amendments to PCAOB Auditing Standards related to a Companys Noncompliance with Laws and Regulations; the Federal Reserve Boards Supervision and regulation of Silicon Valley Bank and ongoing Holistic Capital; Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; SEC Shareholder Proposals: Staff Legal Bulletin No. 14L (CF); EU sustainable finance action plan and incorporating ESG factors into financial services; potential regulations to require public companies to disclose information related to human capital management; reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; reporting metrics of American companies under the California climate disclosure laws; interconnectedness of the SECs rulemaking agenda; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); oversight issues and potential legislation on third party litigation funding (including its national security implications)

Issues related to crypto & digital assets including digital assets market structure (H.R.4763, the Financial Innovation and Technology for the 21st Century Act and S. 2281, the Responsible Financial Innovation Act) and Stablecoins legislation (H.R. 4766, the Clarity for Payment Stablecoins Act) Money Market Fund (MMF) regulation Retail investor access to alternative investments & private markets, including H.R. 2627, the Increasing Investor Opportunities Act and draft Senate legislation Accredited investor reform initiatives including H.R.835, the Fair Investment Opportunities for Professional Experts Act, H.R. 2797, the Equal Opportunity for All Investors Act, and H.R. 1579, the Accredited Investor Definition Review Act E-delivery initiatives including H.R. 1807 the Improving Disclosure for Investors Act Retirement security initiatives, including H.R. 3063, the Retirement Fairness for Charities and Educational Institutions Act and Securing a Strong Retirement Act (SECURE Act) 2.0 implementation and modifications Legislation and oversight of ESG investing including proxy voting by asset managers Congressional oversight of SEC rulemakings such as mandatory swing pricing, hard close, liquidity risk management proposal, and predictive data analytics Congressional oversight of the DOL Fiduciary rule proposal Basel III proposal and bank capital standards impact on asset managers

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

Issues related to Securities and Exchange Commission Regulation BI (Regulation Best Interest). Proposed Securities and Exchange Commission Rule 223-1: Safeguarding Advisory Client Assets (Custody Rule) and Conflicts of Interest and Predictive Data Analytics Proposal. Issues relating to Opportunity Zones. Issues relating to 401(k) defined contributions. H.R. 835, Fair Investment Opportunities for Professional Experts Act, all provisions. H.R. 1579, Accredited Investor Definition Review Act, all provisions. H.R. 2797, Equal Opportunity for All Investors Act of 2023, all provisions. H.R. 2593, Senior Security Act of 2023, all provisions. H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act, all provisions. H.R. 2799, Expanding Access to Capital Act of 2023, all provisions. H.R. 2627, Increasing Investor Opportunities Act, all provisions. Issues relating to fiduciary duties regarding asset classes under ERISA (Retirement Savings Modernization Act).

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

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

PL 111-203 Dodd-Frank Wall Street Reform and Consumer Protection Act - various financial reforms HR 448 Putting Investors First Act - requires a proxy advisory firm to register with the SEC and other restrictions HR 500 Financial Exploitation Prevention Act - allows for the delay of the redemption of a security if it is reasonably believed the redemption involves the financial exploitation HR 8521 (117th) Investor Democracy is Expected (INDEX) Act - guidelines for passively index funds that vote shares on behalf of fund investors HR 9408/S 5005 (117th) Mandatory Materiality Requirement Act - limits additional disclosure requirements applicable to issuers of securities Issue Mutual Fund Swing Pricing/Hard Close Requirements Issue Insurance Capital Standards and Systemic Risk Issue SEC Rule 15c2-11/144A Securities Issue Environmental, Social, Governance Issue Federal Home Loan Bank Issues HR 1807 Improving Disclosure for Investors Act - Direct SEC to promulgate rules with respect to the electronic delivery of certain required disclosures DRAFT To except quotations of Rule 144A fixed-income securities from certain regulatory requirements HR 2891/S 1323 SAFE Banking Act -- To create protections for financial institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses HR 835Fair Investment Opportunities for Professional Experts Act -- expands the eligibility criteria for an accredited investor HR 1579 Accredited Investor Definition Review Act -- expands the eligibility criteria for an accredited investor HR 3746 Fiscal Responsibility Act of 2023 - increases the federal debt limit, establishes new discretionary spending limits, rescinds unobligated funds, expands work requirements for federal programs, and modifies other requirements related to the federal budget process. HR 3812 FSOC Improvement Act -- amend the Financial Stability Act of 2010 to require the Financial Stability Oversight Council to consider alternative approaches before determining that a U.S. nonbank financial company shall be supervised by the Board of Governors of the Federal Reserve System HR 2891/S 1323 SAFER Banking Act - prohibits a federal banking regulator from penalizing a depository institution for providing banking services to a legitimate cannabis-related business

No bill number. Discussed Person to Person (P2P) platform reforms and P.L. 95-630 Electronic Funds Transfer Act. No bill number. Discussed cryptocurrency fraud. No bill number. Discussed the Edith Shorougian Senior Victims of Fraud Compensation Act. No bill number. Discussed accredited investor definition. No bill number. Discussed digital engagement practices and securities. H.R. 1579 the Accredited Investor Definition Act. H.R. 1807 the Improving Disclosure for Investors Act of 2023.

Client expense: $3,650,000 · Firm income: Not reported

H.R. 835, the Fair Investment Opportunities for Professional Experts Act H.R. 1579, the Accredited Investor Definition Review Act H.R. 1548, the Improving Access to Small Business Information Act H.R. 2797, the Equal Opportunity for All Investors Act H.R. 1807, the Improving Disclosure for Investors Act of 2023 H.R. 2796, the Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2799, the Expanding Access to Capital Act H.R. 2612, the Gig Worker Equity Compensation Act H.R. 2579, the Developing and Empowering our Aspiring Leaders Act of 2023 H.R.2799, the Expanding Access to Capital Act of 2023 H.R.2590, the Unlocking Capital for Small Businesses Act of 2023 Corporate Transparency Act: Pub. L. No. 116-283 (January 1, 2021) Private markets & capital formation generally

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Banking Policy Impacting Emerging Companies Capital Formation Incentives ---H.R.3623/S.2529: Innovation and Growth Now by Investing in Tomorrow's Enterprises (IGNITE) American Innovation Act ---H.R.368: American Innovation Act of 2023 ---H.R.448: Putting Investors First Act of 2023 ---H.R.835: Fair Investment Opportunities for Professional Experts Act ---H.R.1579: Accredited Investor Definition Review Act ---H.R.2608: To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes. ---H.R.2610: To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes. ---H.R.2624: Helping Startups Continue to Grow Act ---H.R.2792: Small Entity Update Act ---H.R.2797: Equal Opportunity for All Investors Act of 2023 ---H.R.2799: Expanding Access to Capital Act of 2023 ---S.866: American Innovation and Jobs Act ---H.R.2673: American Innovation and R&D Competitiveness Act ---Implementation of the Inflation Reduction Act (IRA) of 2022 ---JOBS Act 4.0 ---Net Operating Loss Advance Refunds Capital Market Enhancements ---Accredited Investor Definition ---Amended Definition of Smaller Reporting Company ---JOBS Act 4.0 ---Market Liquidity Proposals ---SEC Small Business Forum Coronavirus (COVID-19) Pandemic Mergers and Acquisitions Proxy Advisory Services Reform of SEC Regulation D Sarbanes Oxley Section 404 (b) Small Business Innovation Research (SBIR) Program ---Implementation of SBIR and STTR Extension Act of 2022

Client expense: $2,200,000 · Firm income: Not reported

Issues related to crypto & digital assets including digital assets market structure (H.R.4763, the Financial Innovation and Technology for the 21st Century Act and S. 2281, the Responsible Financial Innovation Act) and Stablecoins legislation (H.R. 4766, the Clarity for Payment Stablecoins Act). Money Market Fund (MMF) regulation Retail investor access to alternative investments & private markets, including H.R. 2627, the Increasing Investor Opportunities Act. Accredited investor reform initiatives including H.R.835, the Fair Investment Opportunities for Professional Experts Act, H.R. 2797, the Equal Opportunity for All Investors Act, and H.R. 1579, the Accredited Investor Definition Review Act E-delivery initiatives including H.R. 1807 the Improving Disclosure for Investors Act. Retirement security initiatives, including H.R. 3063, the Retirement Fairness for Charities and Educational Institutions Act and Securing a Strong Retirement Act (SECURE Act) 2.0 implementation. ESG investing and oversight, and legislative monitoring. SEC mandatory swing pricing, hard close, and liquidity risk management proposal.

Client expense: $300,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1379, Access to Small Business Investor Capital Act, regarding all provisions. H.R. 2627, Increasing Investor Opportunities Act, regarding all provisions. H.R. 835, Fair Investment Opportunities for Professionals Act, regarding all provisions. H.R. 2797, Equal Opportunity for All Investors Act, regarding all provisions. H.R. 1579, Accredited Investor Definition Review Act, regarding all provisions.

Client expense: $120,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 448, Putting Investors First Act of 2023 H.R. 835, Fair Investment Opportunities for Professional Experts Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 1410, Consumer Financial Protection Commission Act H.R. 1548, Improving Access to Small Business Information Act H.R. 1553, Helping Angels Lead our Startups (HALOS) Act H.R. 1579, Accredited Investor Definition Review Act H.R. 2608, To amend the Federal securities laws to specify the periods for which financial statements are required to be provided by an emerging growth company, and for other purposes H.R. 2610, To amend the Securities Exchange Act of 1934 to specify certain registration statement contents for emerging growth companies, to permit issuers to file draft registration statements with the Securities and Exchange Commission for confidential review, and for other purposes H.R. 2612, Gig Worker Equity Compensation Act H.R. 2627, Increasing Investor Opportunities Act H.R. 2652, Investment Opportunity Expansion Act H.R. 2792, Small Entity Update Act H.R. 2793, Encouraging Public Offerings Act of 2023 H.R. 2795, Enhancing Multi-Class Share Disclosures Act H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 2797, Equal Opportunity for All Investors Act H.R. 2798, CFPB Transparency and Accountability Reform Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 2812, Middle Market IPO Underwriting Cost Act H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act H.R. 4035, Protecting Small Business Information Act of 2023 H.R. 4177/S. 2007, Improving Corporate Governance Through Diversity Act of 2023 H.R. 4655, Business Over Activists Act H.R. 4664/S. 2309, Making appropriations for financial services and general government for the fiscal year ending September 30, 2024, and for other purposes H.R. 4767, Protecting Americans Retirement Savings from Politics Act H.R. 4790, Guiding Uniform and Responsible Disclosure Requirements and Information Limits (GUARDRAIL) Act of 2023 H.R. 4823, American Financial Institution Regulator Sovereignty and Transparency Act H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 S. 638, Disclosure of Tax Havens and Offshoring Act Draft legislation titled Accredited Investor Self-Certification Act Potential legislation on environmental, social, and governance Potential legislation to codify certain reforms to the nonbank designation process of the Financial Stability Oversight Council Potential legislation to except quotations of Rule 144A fixed-income securities from certain regulatory requirements Potential legislation to make changes to the SEC 14a-8 shareholder proposal process Potential legislation dealing with third party litigation funding including its national security implications Potential legislation similar to H.R. 2025/S. 840, Litigation Funding Transparency Act SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11, 2022) Proposed Rule, Securities and Exchange Commission; Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (87 Fed. Reg. 77,172-77,296, December 16, 2022) SEC Final Rule on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (88 Fed. Reg. 51,896-51,945, September 5, 2023) Proposed Rule, SEC Safeguarding Advisory Client Assets (88 Fed. Reg. 14,672-14,792, March 9, 2023) Proposed Rule, FSOC Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies, Proposed Interpretive Guidance (88 Fed. Reg. 26,234-26,244, April 28, 2023) Proposed Rule, FSOC Analytic Framework for Financial Stability Risk Identification, Assessment, and Response, Proposed Analytic Framework (88 Fed. Reg. 26,305-26,311, April 28, 2023) Proposed Rule, SEC Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (88 Fed. Reg. 53,960, August 9, 2023) Proposed Rule, Office of the Comptroller of the Currency, Treasury, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation; Regulatory Capital Rule: Large Banking Organizations and Banking Organizations With Significant Trading Activity (88 Fed. Reg. 64,028-64,343, September 18, 2023) Request for Information, Consumer Financial Protection Bureau; Data Brokers and Other Business Practices Involving the Collection and Sale of Consumer Information (88 Fed. Reg. 16,951-16,954, March 21, 2023) Request for Information Regarding Medical Payments Products, Consumer Financial Protection Bureau, Centers for Medicare & Medicaid Services, Department of Health and Human Services, and Department of the Treasury (88 Fed. Reg. 44,281-44,290, July 12, 2023) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Financial Stability Oversight Councils Activities-Based Approach to Nonbank Financial Company Systemic Risk; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Financial Accounting Standards Board improvements to income tax disclosures; Climate-Related Financial Risk Management for Large Banks; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Proposed Rule, Securities and Exchange Commission; Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (SEC Rel. Nos. 34-97990; IA-6353; File No. S7-12-23, July 26, 2023); Proposing Release: Amendments to PCAOB Auditing Standards related to a Companys Noncompliance with Laws and Regulations; the Federal Reserve Boards Supervision and regulation of Silicon Valley Bank and ongoing Holistic Capital; EU sustainable finance action plan and incorporating ESG factors into financial services; potential regulations to require public companies to disclose information related to human capital management; reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; potential rulemaking regarding Section 956 of the Dodd-Frank Act (P.L. 111-203); oversight issues and potential legislation on third party litigation funding (including its national security implications)

Issues related to Securities and Exchange Commission Regulation BI (Regulation Best Interest). Issues relating to Opportunity Zones. Issues relating to 401(k) defined contributions. H.R. 835, Fair Investment Opportunities for Professional Experts Act, all provisions. H.R. 1579, Accredited Investor Definition Review Act, all provisions. H.R. 2797, Equal Opportunity for All Investors Act of 2023, all provisions. H.R. 2593, Senior Security Act of 2023, all provisions. H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act, all provisions. H.R. 2799, Expanding Access to Capital Act of 2023, all provisions. H.R. 2627, Increasing Investor Opportunities Act, all provisions.

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

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Issues related to Securities and Exchange Commission Regulation BI (Regulation Best Interest). Issues relating to Opportunity Zones. Issues relating to 401(k) defined contributions. H.R. 835, Fair Investment Opportunities for Professional Experts Act, all provisions. H.R. 1579, Accredited Investor Definition Review Act, all provisions. H.R. 2797, Equal Opportunity for All Investors Act of 2023, all provisions. H.R. 2593, Senior Security Act of 2023, all provisions. H.R. 2796, Promoting Opportunities for Non-Traditional Capital Formation Act, all provisions. H.R. 2799, Expanding Access to Capital Act of 2023, all provisions. H.R. 2627, Increasing Investor Opportunities Act, all provisions. Issues relating to fiduciary duties regarding asset classes under ERISA (Retirement Savings Modernization Act).

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

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

PL 111-203 Dodd-Frank Wall Street Reform and Consumer Protection Act - various financial reforms HR 448 Putting Investors First Act - requires a proxy advisory firm to register with the SEC and other restrictions HR 500 Financial Exploitation Prevention Act - allows for the delay of the redemption of a security if it is reasonably believed the redemption involves the financial exploitation HR 8521 (117th) Investor Democracy is Expected (INDEX) Act - guidelines for passively index funds that vote shares on behalf of fund investors HR 9408/S 5005 (117th) Mandatory Materiality Requirement Act - limits additional disclosure requirements applicable to issuers of securities Issue Mutual Fund Swing Pricing/Hard Close Requirements Issue Insurance Capital Standards and Systemic Risk Issue SEC Rule 15c2-11/144A Securities Issue Environmental, Social, Governance Issue Federal Home Loan Bank Issues HR 1807 Improving Disclosure for Investors Act - Direct SEC to promulgate rules with respect to the electronic delivery of certain required disclosures DRAFT To except quotations of Rule 144A fixed-income securities from certain regulatory requirements HR 2891/S 1323 SAFE Banking Act -- To create protections for financial institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses HR 835Fair Investment Opportunities for Professional Experts Act -- expands the eligibility criteria for an accredited investor HR 1579 Accredited Investor Definition Review Act -- expands the eligibility criteria for an accredited investor HR 3746 Fiscal Responsibility Act of 2023 - increases the federal debt limit, establishes new discretionary spending limits, rescinds unobligated funds, expands work requirements for federal programs, and modifies other requirements related to the federal budget process. HR 3812 FSOC Improvement Act -- amend the Financial Stability Act of 2010 to require the Financial Stability Oversight Council to consider alternative approaches before determining that a U.S. nonbank financial company shall be supervised by the Board of Governors of the Federal Reserve System HR 2891/S 1323 SAFER Banking Act - prohibits a federal banking regulator from penalizing a depository institution for providing banking services to a legitimate cannabis-related business

H.R.1579 - Accredited Investor Definition Review Act. H.R.1410 - Consumer Financial Protection Commission Act. Form ADV/40 Act Legislation.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE