Financial Stability Oversight Council Improvement Act of 2023

Issues related to systemic risk regulation and non-bank financial intermediation including the FSOC Improvement Act (H.R. 3812 and S. 3601) Issues related to ETF regulation Issues related to municipal bonds and the structure of the municipal securities market Issues related to equity market structure matters Issues related to fund disclosure and investor experience Issues related to corporate governance, including ESG and proxy process, including the INDEX Act (S.2700), the Empowering Shareholders Act (H.R. 4645), and the Prioritizing Economic Growth Over Woke Policies Act (H.R. 4790) Issues related to fixed income funds Issues related to index funds Issues related to access to investment opportunities Issues in support of providing for electronic delivery of fund information, including the Improving Disclosure for Investors Act (H.R. 1807 and S.3815) Issues related to allowing collective investment trusts in 403(b) plans (H.R. 3063, S. 4917) Issued related to the SECs proposed rules regarding liquidity risk management for open-end funds and swing pricing Issues related to products and markets Issues related to the use of predictive data analytics by broker dealers and investment advisers

Client expense: $610,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act; H.R. 1807, Improving Disclosure for Investors Act; H.R. 3812, Financial Stability Oversight Council Improvement Act; SEC Rulemaking on Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting; H.R. 2627, Increasing Investor Opportunities Act; S. 4917, Retirement Fairness for Charities and Educational Institutions Act of 2024

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

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

Equity market structure and trading regulation, including the relevant provisions of H.R.2799, the Expanding Access to Capital Act of 2023; systemic risk regulation, including the relevant provisions of H.R.3812, the Financial Stability Oversight Council Improvement Act of 2023; e-delivery, including the relevant provisions of H.R.1807 and S.3815, the Improving Disclosure for Investors Act of 2023; investment advice regulation; digital assets, including the relevant provisions of H.R.4763, the Financial Innovation and Technology for the 21st Century Act, and H.R.4766, the Clarity for Payment Stablecoins Act of 2023; open-end fund liquidity proposal; predictive data analytics proposal.

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

Issues related to systemic risk regulation and non-bank financial intermediation including the FSOC Improvement Act (H.R. 3812 and S. 3601) Issues related to ETF regulation Issues related to municipal bonds and the structure of the municipal securities market Issues related to equity market structure matters Issues related to fund disclosure and investor experience Issues related to corporate governance, including ESG and proxy process, including the INDEX Act (S.2700), the Empowering Shareholders Act (H.R. 4645), and the Prioritizing Economic Growth Over Woke Policies Act (H.R. 4790) Issues related to fixed income funds Issues related to index funds Issues related to access to investment opportunities Issues in support of providing for electronic delivery of fund information, including the Improving Disclosure for Investors Act (H.R. 1807 and S.3815) Issues related to allowing collective investment trusts in 403(b) plans (H.R. 3063, S. 4917) Issued related to the SECs proposed rules regarding liquidity risk management for open-end funds and swing pricing Issues related to products and markets Issues related to the use of predictive data analytics by broker dealers and investment advisers

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

H.R. 500, Financial Exploitation Prevention Act of 2023 H.R. 1807, Improving Disclosure for Investors Act of 2023 H.R. 2627, Increasing Investor Opportunities Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act of 2023 H.R. 3812, Financial Stability Oversight Council Improvement Act of 2023 H.R. 4645, Empowering Shareholders Act of 2023 H.R. 4790, Prioritizing Economic Growth Over Woke Policies Act H.R. 6783, Capital Markets Financing and Economic Growth Investments Act of 2023 H.R. 7030, Review the Expansion of Government Act of 2024 H.R. 8339, SEC Reform and Restructuring Act H.R. 8478, Empowering States to Protect Seniors Against Bad Actors Act H.J. Res. 120, Congressional Disapproval of FSOC rule on "Guidance on Nonbank Financial Company Determinations" S. 1481, Financial Exploitation Prevention Act of 2023 S. 3601, Financial Stability Oversight Council Improvement Act of 2024 S. 3735, Protecting Innovation in Investment Act S. 3815, Improving Disclosure for Investors Act of 2024 S. 4371, Empowering States to Protect Seniors Against Bad Actors Act S. 4917, Retirement Fairness for Charities and Educational Institutions Act of 2024 S. 5139, Empowering Main Street in America Act Outbound investment screening General concerns regarding the volume, interconnectedness, and length of comment periods of SEC proposals SEC mandatory swing pricing, hard close, and liquidity risk management proposal SEC predictive data analytics proposal Streamline and modernize the SEC staff no-action letter/guidance and exemptive order process Resolution recognizing the 100th anniversary of the Mutual Fund

Client expense: $2,150,000 · 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 S 4917 - Retirement Fairness for Charities and Educational Institutions Act of 2024 - to amend the Federal securities laws to enhance 403(b) plans

Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act; H.R. 1807, Improving Disclosure for Investors Act; H.R. 3812, Financial Stability Oversight Council Improvement Act; SEC Rulemaking on Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting; H.R. 2627, Increasing Investor Opportunities Act Retirement Fairness for Charities and Educational Institutions Act of 2023 (Senate version of H.R. 3063)

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

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

H.R. 500, Financial Exploitation Prevention Act of 2023 H.R. 1807, Improving Disclosure for Investors Act of 2023 H.R. 2627, Increasing Investor Opportunities Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act of 2023 H.R. 3812, Financial Stability Oversight Council Improvement Act of 2023 H.R. 4168, Mandatory Materiality Requirement Act of 2023 H.R. 4237, Ensuring Sound Guidance Act H.R. 4600, Protecting Retail Investors Savings Act H.R. 4645, Empowering Shareholders Act of 2023 H.R. 4767, Protecting Americans Retirement Savings from Politics Act H.R. 4790, GUARDRAIL Act of 2023 H.R. 6783, Capital Markets Financing and Economic Growth Investments Act of 2023 H.R. 7030, Review the Expansion of Government Act of 2024 H.R. 8239, SEC Regulatory Accountability Act H.R. 8339, SEC Reform and Restructuring Act H.J. Res. 120, Congressional Disapproval of FSOC rule on "Guidance on Nonbank Financial Company Determinations" S. 1481, Financial Exploitation Prevention Act of 2023 S. 2005, Mandatory Materiality Requirement Act of 2023 S. 2700, INDEX Act S. 3601, Financial Stability Oversight Council Improvement Act of 2024 S. 3735, Protecting Innovation in Investment Act S. 3815, Improving Disclosure for Investors Act of 2024 S. 4586, Stop Funding the CCP Through A-Shares Act S. 4589, Safeguarding US Financial Leadership Against Communist China Act S. 4590, TRADE SAFE Act General concerns regarding the volume, interconnectedness, and length of comment periods of SEC proposals SEC mandatory swing pricing, hard close, and liquidity risk management proposal SEC predictive data analytics proposal Streamline and modernize the SEC staff no-action letter/guidance and exemptive order process Outbound investment screening Resolution recognizing the 100th anniversary of the Mutual Fund

Equity market structure and trading regulation; systemic risk legislation, including the relevant provisions of S.3601, the Financial Stability Oversight Council Improvement Act of 2025; systemic risk regulation, including the relevant provisions of H.R. 3812, the Financial Stability Oversight Council Improvement Act of 2024; e-delivery, including the relevant provisions of H.R.1807 and S.3815, the Improving Disclosure for Investors Act of 2023, and H.R.2799, the Expanding Access to Capital Act of 2024; digital assets, including the relevant provisions of H.R.4763, the Financial Innovation and Technology for the 21st Century Act, and H.R.4766, the Clarity for Payment Stablecoins Act of 2024; open-end fund liquidity; predictive data analytics proposal.

Client expense: $760,000 · 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

Issues related to systemic risk regulation and non-bank financial intermediation including the FSOC Improvement Act (H.R. 3812 and S. 3601) Issues related to ETF regulation Issues related to municipal bonds and the structure of the municipal securities market Issues related to equity market structure matters Issues related to fund disclosure and investor experience Issues related to corporate governance, including ESG and proxy process, including the INDEX Act (S.2700), and the Empowering Shareholders Act (H.R. 4645) Issues related to fixed income funds and money market funds Issues related to index funds Issues related to access to investment opportunities Issues in support of providing for electronic delivery of fund information, including the Improving Disclosure for Investors Act (H.R. 1807 and S.3815) Issues related to allowing collective investment trusts in 403(b) plans (H.R. 3063) Issued related to the SECs proposed rules regarding liquidity risk management for open-end funds and swing pricing Issues related to products and markets Issues related to the use of predictive data analytics by broker dealers and investment advisers

Client expense: $550,000 · Firm income: Not reported

H.R. 448, Putting Investors First Act of 2023 H.R. 500, Financial Exploitation Prevention Act of 2023 H.R. 760, Chinese Military and Surveillance Company Sanctions Act of 2023 H.R. 1807, Improving Disclosure for Investors Act of 2023 H.R. 2627, Increasing Investor Opportunities Act H.R. 2799, Expanding Access to Capital Act of 2023 H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act of 2023 H.R. 3812, Financial Stability Oversight Council Improvement Act of 2023 H.R. 4168, Mandatory Materiality Requirement Act of 2023 H.R. 4237, Ensuring Sound Guidance Act H.R. 4600, Protecting Retail Investors Savings Act H.R. 4645, Empowering Shareholders Act of 2023 H.R. 4767, Protecting Americans Retirement Savings from Politics Act H.R. 4790, GUARDRAIL Act of 2023 H.R. 6783, Capital Markets Financing and Economic Growth Investments Act of 2023 H.R. 7030, Review the Expansion of Government Act of 2024 SEC Regulatory Accountability Act S. 1481, Financial Exploitation Prevention Act of 2023 S. 1799, Putting Investors First Act of 2023 S. 2005, Mandatory Materiality Requirement Act of 2023 S. 2700, INDEX Act S. 3601, Financial Stability Oversight Council Improvement Act of 2024 S. 3735, Protecting Innovation in Investment Act S. 3815, Improving Disclosure for Investors Act of 2024 General concerns regarding the volume, interconnectedness, and length of comment periods of SEC proposals SEC mandatory swing pricing, hard close, and liquidity risk management proposal SEC predictive data analytics proposal Streamline and modernize the SEC staff no-action letter/guidance and exemptive order process

Client expense: $1,320,000 · 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)

Equity market structure and trading regulation; systemic risk legislation, including the relevant provisions of S.3601, the Financial Stability Oversight Council Improvement Act of 2024, and H.R. 3812, the Financial Stability Oversight Council Improvement Act of 2023; systemic risk regulation; e-delivery, including the relevant provisions of H.R.1807 and S.3815, the Improving Disclosure for Investors Act of 2023, and H.R.2799, the Expanding Access to Capital Act of 2023; investment advice regulation; digital assets, including the relevant provisions of H.R.4763, the Financial Innovation and Technology for the 21st Century Act, and H.R.4766, the Clarity for Payment Stablecoins Act of 2023; open-end fund liquidity; predictive data analytics proposal.

Client expense: $430,000 · 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

Issues related to systemic risk regulation and non-bank financial intermediation including the FSOC Improvement Act (H.R. 3812 and S. 3601) Issues related to ETF regulation Issues related to municipal bonds and the structure of the municipal securities market Issues related to equity market structure matters Issues related to fund disclosure and investor experience Issues related to corporate governance, including ESG and proxy process, including the INDEX Act (S.2700), and the Empowering Shareholders Act (H.R. 4645) Issues related to fixed income funds and money market funds Issues related to index funds Issues related to access to investment opportunities Issues in support of providing for electronic delivery of fund information, including the Improving Disclosure for Investors Act (H.R. 1807 and S.3815) Issues related to allowing collective investment trusts in 403(b) plans (H.R. 3063) Issued related to the SECs proposed rules regarding liquidity risk management for open-end funds and swing pricing Issues related to products and markets Issues related to the use of predictive data analytics by broker dealers and investment advisers

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

Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act; H.R. 1807, Improving Disclosure for Investors Act; Financial Stability Oversight Council Improvement Act (H.R. 3812); SEC Rulemaking on Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting; Increasing Investor Opportunities Act (H.R. 2627 RH)

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

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

Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act; H.R. 1807, Improving Disclosure for Investors Act; Financial Stability Oversight Council Improvement Act (H.R. 3812); SEC Rulemaking on Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting

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

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

Equity market structure and trading regulation; money market fund regulation; systemic risk legislation; systemic risk regulation, including the relevant provisions of H.R. 3812, the Financial Stability Oversight Council Act of 2023; e-delivery, including relevant provisions of H.R. 1807, the Improving Disclosure for Investors Act of 2023; investment advice regulation; data aggregation; digital assets; licensing and supervision for remote work; Environmental, Social, and Governance (ESG) legislation, including relevant provisions of H.R. 4600, the Protecting Retail Investors Savings Act; Environmental, Social and Governance (ESG) regulation; remote inspections; open-end fund liquidity.

Client expense: $410,000 · Firm income: Not reported

Equity market structure and trading regulation; money market fund regulation; systemic risk legislation; systemic risk regulation, including the relevant provisions of H.R. 3812, the Financial Stability Oversight Council Act of 2023; e-delivery, including relevant provisions of H.R. 1807, the Improving Disclosure for Investors Act of 2023; investment advice regulation; data aggregation; digital assets; licensing and supervision for remote work; Environmental, Social, and Governance (ESG) legislation, including relevant provisions of H.R. 4600, the Protecting Retail Investors Savings Act; Environmental, Social and Governance (ESG) regulation; remote inspections; open-end fund liquidity.

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

H.R. 448, Putting Investors First Act of 2023 H.R. 500, Financial Exploitation Prevention Act of 2023 H.R. 760, Chinese Military and Surveillance Company Sanctions Act of 2023 H.R. 1807, Improving Disclosure for Investors Act of 2023 H.R. 2627, Increasing Investor Opportunities Act H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act of 2023 H.R. 3812, Financial Stability Oversight Council Improvement Act of 2023 H.R. 4168, Mandatory Materiality Requirement Act of 2023 H.R. 4177, Improving Corporate Governance Through Diversity Act of 2023 H.R. 4237, Ensuring Sound Guidance Act H.R. 4589, To provide for the registration of proxy advisory firms H.R. 4590, To provide for liability for certain failures to disclose material information in connection with proxy voting advice H.R. 4600, Protecting Retail Investors Savings Act H.R. 4645, Empowering Shareholders Act of 2023 H.R. 4648, To provide for duties of certain investment advisors, asset managers, and pension funds with respect to voting on shareholder proposals H.R. 4767, Protecting Americans Retirement Savings from Politics Act H.R. 4790, GUARDRAIL Act of 2023 H.R. 6783, Capital Markets Financing and Economic Growth Investments Act of 2023 S. 1481, Financial Exploitation Prevention Act of 2023 S. 1799, Putting Investors First Act of 2023 S. 2005, Mandatory Materiality Requirement Act of 2023 S. 2007, Improving Corporate Governance Through Diversity Act of 2023 S. 2226, National Defense Authorization Act for Fiscal Year 2024 (outbound investment screening) S. 2700, INDEX Act General concerns regarding the volume, interconnectedness, and length of comment periods of SEC proposals SEC mandatory swing pricing, hard close, and liquidity risk management proposal SEC money market fund proposal SEC predictive data analytics proposal SEC Safeguarding Advisory Client Assets proposal FSOC revised guidance on designation of nonbank SIFIs Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern

Issues related to systemic risk regulation and non-bank financial intermediation including the FSOC Improvement Act (H.R. 3812) Issues related to ETF regulation Issues related to municipal bonds and the structure of the municipal securities market Issues related to equity market structure matters Issues related to fund disclosure and investor experience Issues related to corporate governance, including ESG and proxy process, including the INDEX Act (S.2700), and the Empowering Shareholders Act (H.R. 4645) Issues related to fixed income funds and money market funds Issues related to index funds Issues related to access to investment opportunities Issues in support of providing for electronic delivery of fund information, including the Improving Disclosure for Investors Act (H.R. 1807) Issues related to allowing collective investment trusts in 403(b) plans (H.R. 3063) Issued related to the SECs proposed rules regarding liquidity risk management for open-end funds and swing pricing Issues related to products and markets Issues related to the use of predictive data analytics by broker dealers and investment advisers

Client expense: $560,000 · 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

Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act; H.R. 1807, Improving Disclosure for Investors Act; Financial Stability Oversight Council Improvement Act (H.R. 3812); SEC Rulemaking on Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting

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

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

Equity market structure and trading regulation; fixed income market structure; money market fund regulation; systemic risk legislation; systemic risk regulation, including the relevant provisions of H.R. 3812, the Financial Stability Oversight Council Act of 2023; e-delivery, including relevant provisions of H.R. 1807, the Improving Disclosure for Investors Act of 2023; investment advice regulation; data aggregation; digital assets; licensing and supervision for remote work; remote notarization; Environmental, Social, and Governance (ESG) legislation, including relevant provisions of H.R. 4237, the Ensuring Sound Guidance Act; Environmental, Social and Governance (ESG) regulation; remote inspections; SAFE Banking Act safe harbor provisions, including the relevant provisions of H.R. 2891, the Secure and Fair Enforcement Banking Act of 2023 and S.1323, the Secure and Fair Enforcement Banking Act of 2023; open-end fund liquidity.

Client expense: $390,000 · Firm income: Not reported

Issues related to systemic risk regulation and non-bank financial intermediation including the FSOC Improvement Act (H.R. 3812) Issues related to ETF regulation Issues related to municipal bonds and the structure of the municipal securities market Issues related to equity market structure matters Issues related to fund disclosure and investor experience Issues related to corporate governance, including ESG and proxy process, including the INDEX Act (S.2700), and the Empowering Shareholders Act (H.R. 4645) Issues related to fixed income funds and money market funds Issues related to index funds Issues related to access to investment opportunities Issues in support of providing for electronic delivery of fund information, including the Improving Disclosure for Investors Act (H.R. 1807) Issues related to allowing collective investment trusts in 403(b) plans (H.R. 3063) Issued related to the SECs proposed rules regarding liquidity risk management for open-end funds and swing pricing Issues related to products and markets Issues related to the use of predictive data analytics by broker dealers and investment advisers

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

H.R. 448, Putting Investors First Act of 2023 H.R. 500, Financial Exploitation Prevention Act of 2023 H.R. 760, Chinese Military and Surveillance Company Sanctions Act of 2023 H.R. 1807, Improving Disclosure for Investors Act of 2023 H.R. 2627, Increasing Investor Opportunities Act H.R. 3063, Retirement Fairness for Charities and Educational Institutions Act of 2023 H.R. 3812, Financial Stability Oversight Council Improvement Act of 2023 H.R. 4168, Mandatory Materiality Requirement Act of 2023 H.R. 4177, Improving Corporate Governance Through Diversity Act of 2023 H.R. 4237, Ensuring Sound Guidance Act H.R. 4589, To provide for the registration of proxy advisory firms H.R. 4590, To provide for liability for certain failures to disclose material information in connection with proxy voting advice H.R. 4600, Protecting Retail Investors Savings Act H.R. 4628, To require the SEC to disclose and report on non-material disclosure mandates H.R. 4640, To authorize the exclusion of shareholder proposals from proxy or consent solicitation material if the subject matter of the shareholder proposal is environmental, social, or political H.R. 4641, Performance Over Politics Act H.R. 4642, International Regulatory Transparency and Accountability Act H.R. 4644, No Expensive, Stifling Governance Act H.R. 4645, Empowering Shareholders Act of 2023 H.R. 4648, To provide for duties of certain investment advisors, asset managers, and pension funds with respect to voting on shareholder proposals H.R. 4652, Public Company Advisory Committee Act H.R. 4653, Protecting U.S. Business Sovereignty Act H.R. 4655, Businesses over Activists Act H.R. 4656, Protecting Americans Savings Act H.R. 4657, To clarify that an issuer may exclude a shareholder proposal pursuant to section 240.14a-8(i) of title 17, Code of Federal Regulations, without regard to whether such proposal relates to a significant social policy issue H.R. 4662, Corporate Governance Examination Act H.R. 4767, Protecting Americans Retirement Savings from Politics Act H.R. 4790, GUARDRAIL Act of 2023 S. 1481, Financial Exploitation Prevention Act of 2023 S. 1799, Putting Investors First Act of 2023 S. 2005, Mandatory Materiality Requirement Act of 2023 S. 2007, Improving Corporate Governance Through Diversity Act of 2023 S. 2226, National Defense Authorization Act for Fiscal Year 2024 (outbound investment screening) S. 2700, INDEX Act General concerns regarding the volume, interconnectedness, and length of comment periods of SEC proposals SEC mandatory swing pricing, hard close, and liquidity risk management proposal SEC money market fund proposal SEC Fund Names Rule SEC Safeguarding Advisory Client Assets proposal FSOC revised guidance on designation of nonbank SIFIs

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

equity market structure and trading regulation; fixed income market structure; money market fund regulation; systemic risk legislation; systemic risk regulation, including the relevant provisions of H.R. 3812, the Financial Stability Oversight Council Improvement Act of 2023; e-delivery, including relevant provisions of H.R. 1807, the Improving Disclosure for Investors Act of 2023; investment advice regulation; data aggregation; digital assets; licensing and supervision for remote work; remote notarization; Environmental, Social, and Governance (ESG) legislation, including relevant provisions of H.R. 4237, To amend the Investment Advisers Act of 1940 and the Employee Retirement Income Security Act of 1974 to specify requirements concerning the consideration of pecuniary and non-pecuniary factors; Environmental, Social, and Governance (ESG) regulation; remote inspections; H.R. 1996 and S. 910, the SAFE Banking Act, safe harbor provisions; open-end fund liquidity

Client expense: $810,000 · Firm income: Not reported

H.R. 448- Putting Investors First Act of 2023 (Steil) H.R. 500- Financial Exploitation Prevention Act of 2023 (Wagner) H.R. 1807- Improving Disclosure for Investors Act of 2023 (Huizenga) H.R. 2627- Increasing Investor Opportunities Act (Wagner) H.R. 3063- Retirement Fairness for Charities and Educational Institutions Act of 2023 (Lucas) H.R. 3812- Financial Stability Oversight Council Improvement Act of 2023 (Foster) H.R. 4168- Mandatory Materiality Requirement Act of 2023 (Huizenga) H.R. 4177- Improving Corporate Governance Through Diversity Act of 2023 (Meeks) H.R. 4237- Ensuring Sound Guidance Act (Barr) S. 1481- Financial Exploitation Prevention Act of 2023 (Hagerty) S. 1799- Putting Investors First Act of 2023 (Hagerty) S. 2005- Mandatory Materiality Requirement Act of 2023 (Rounds) S. 2007- Improving Corporate Governance Through Diversity Act of 2023 (Menendez) SEC Regulatory Accountability Act (Wagner) INDEX Act (Huizenga) General concerns regarding the volume, interconnectedness, and length of comment periods of SEC proposals SEC mandatory swing pricing, hard close, and liquidity risk management proposal SEC public company climate disclosure proposal SEC money market fund proposal FSOC revised guidance on designation of nonbank SIFIs Exempting Rule 144A fixed-income securities from Rule 15c2-11

Client expense: $1,500,000 · Firm income: Not reported

Issues related to systemic risk regulation and non-bank financial intermediation including the FSOC Improvement Act (H.R. 3812) Issues related to ETF regulation Issues related to municipal bonds and the structure of the municipal securities market Issues related to equity market structure matters Issues related to fund disclosure and investor experience Issues related to corporate governance, including ESG and proxy process, including the INDEX Act Issues related to fixed income funds and money market funds Issues related to index funds Issues related to access to investment opportunities Issues in support of providing for electronic delivery of fund information, including the Improving Disclosure for Investors Act (H.R. 1807) Issues related to allowing collective investment trusts in 403(b) plans (H.R. 3063) Issued related to the SECs proposed rules regarding liquidity risk management for open-end funds and swing

Client expense: $510,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, 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 Issue Debt Limit 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