Empowering Shareholders 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

H.R.448: Putting Investors First Act H.R.4589 -To amend the Securities Exchange Act of 1934 to provide for the registration of proxy advisory firms H.R.4645 - To amend the Investment Advisers Act of 1940 with respect to proxy voting of passively managed funds, and for other purposes Investment policy related to surety bonding U.S. Securities and Exchange Commission (SEC) public company disclosure proposal including climate risk, cybersecurity, and stock buybacks Issues related to greenhouse gas emissions, net zero, and corporate climate policy Department of Labor Fiduciary Duty Rule

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

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

H.R. 448 Proxy Advisory Firms **Issues lobbied without specific bill number: Climate Change Disclosures S. 1799 Proxy Advisory Firms H.R. 4589 Proxy Advisor Registration H.R. 4590 Proxy Advisor Firms H.R. 4628 Proxy Advisor Disclosure H.R. 4640 Proxy Advisor Disclosure H.R. 4641 Shareholder Proposals H.R. 4645 Proxy Voting H.R. 4662 Proxy Advisor Firm Study H.R. 4767 Proxy Advisor Firms H.R. 4790 Financial Disclosure H.R. 4655 Shareholder Proposals S. 3179 Shareholder Proposals H.R. 7030 Securities and Exchange Commission Rulemaking

Client expense: $1,370,000 · Firm income: Not reported

H.R. 448 Proxy Advisory Firms **Issues lobbied without specific bill number: Climate Change Disclosures S. 1799 Proxy Advisory Firms H.R. 4589 Proxy Advisor Registration H.R. 4590 Proxy Advisor Firms H.R. 4628 Proxy Advisor Disclosure H.R. 4640 Proxy Advisor Disclosure H.R. 4641 Shareholder Proposals H.R. 4645 Proxy Voting H.R. 4662 Proxy Advisor Firm Study H.R. 4767 Proxy Advisor Firms H.R. 4790 Financial Disclosure H.R. 4655 Shareholder Proposals S. 3179 Shareholder Proposals H.R. 7030 Securities and Exchange Commission Rulemaking

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

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

H.R.448: Putting Investors First Act H.R.4589 -To amend the Securities Exchange Act of 1934 to provide for the registration of proxy advisory firms H.R.4645 - To amend the Investment Advisers Act of 1940 with respect to proxy voting of passively managed funds, and for other purposes Investment policy related to surety bonding U.S. Securities and Exchange Commission (SEC) public company disclosure proposal including climate risk, cybersecurity, and stock buybacks Issues related to greenhouse gas emissions, net zero, and corporate climate policy Department of Labor Fiduciary Duty Rule

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

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

Mutual fund, ETF, money market mutual fund, securities, and systemic risk issues; equity market structure. HR 4645, Empowering Shareholders Act of 2023; HR 4767, Protecting American's Retirement Savings from Politics Act. SEC proposal on liquidity risk management and swing pricing. H.R. 3066, Retirement Fairness for Charities and Educational Institutions Act of 2023; H.R. 1807, Improving Disclosure for Investors Act of 2023; H.R. 2799, the Expanding Access to Capital Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 448 Proxy Advisory Firms **Issues lobbied without specific bill number: Climate Change Disclosures S. 1799 Proxy Advisory Firms H.R. 4589 Proxy Advisor Registration H.R. 4590 Proxy Advisor Firms H.R. 4628 Proxy Advisor Disclosure H.R. 4640 Proxy Advisor Disclosure H.R. 4641 Shareholder Proposals H.R. 4645 Proxy Voting H.R. 4662 Proxy Advisor Firm Study H.R. 4767 Proxy Advisor Firms H.R. 4790 Financial Disclosure H.R. 4655 Shareholder Proposals S. 3179 Shareholder Proposals H.R. 7030 Securities and Exchange Commission Rulemaking

Client expense: $1,600,000 · 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. 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

Mutual fund, ETF, money market mutual fund, securities, and systemic risk issues; equity market structure. HR 4645, Empowering Shareholders Act of 2023; HR 4767, Protecting American's Retirement Savings from Politics Act. SEC proposal on liquidity risk management and swing pricing. H.R. 3066, Retirement Fairness for Charities and Educational Institutions Act of 2023; H.R. 1807, Improving Disclosure for Investors Act of 2023; H.R. 2799, the Expanding Access to Capital Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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 H.R.4589 -To amend the Securities Exchange Act of 1934 to provide for the registration of proxy advisory firms H.R.4645 - To amend the Investment Advisers Act of 1940 with respect to proxy voting of passively managed funds, and for other purposes Investment policy related to surety bonding U.S. Securities and Exchange Commission (SEC) public company disclosure proposal including climate risk, cybersecurity, and stock buybacks Issues related to greenhouse gas emissions, net zero, and corporate climate policy Department of Labor Fiduciary Duty Rule

Client expense: $420,000 · Firm income: Not reported

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

H.R. 448 Proxy Advisory Firms **Issues lobbied without specific bill number: Climate Change Disclosures S. 1799 Proxy Advisory Firms H.R. 4589 Proxy Advisor Registration H.R. 4590 Proxy Advisor Firms H.R. 4628 Proxy Advisor Disclosure H.R. 4640 Proxy Advisor Disclosure H.R. 4641 Shareholder Proposals H.R. 4645 Proxy Voting H.R. 4662 Proxy Advisor Firm Study H.R. 4767 Proxy Advisor Firms H.R. 4790 Financial Disclosure H.R. 4655 Shareholder Proposals S. 3179 Shareholder Proposals H.R. 7030 Securities and Exchange Commission Rulemaking

Client expense: Not reported · Firm income: $44,000

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 Proxy Advisory Firms **Issues lobbied without specific bill number: Climate Change Disclosures S. 1799 Proxy Advisory Firms H.R. 4589 Proxy Advisor Registration H.R. 4590 Proxy Advisor Firms H.R. 4628 Proxy Advisor Disclosure H.R. 4640 Proxy Advisor Disclosure H.R. 4641 Shareholder Proposals H.R. 4645 Proxy Voting H.R. 4662 Proxy Advisor Firm Study H.R. 4767 Proxy Advisor Firms H.R. 4790 Financial Disclosure H.R. 4655 Shareholder Proposals S. 3179 Shareholder Proposals H.R. 7030 Securities and Exchange Commission Rulemaking

Client expense: $1,490,000 · Firm income: Not reported

H.R. 448 Proxy Advisory Firms **Issues lobbied without specific bill number: Climate Change Disclosures S. 1799 Proxy Advisory Firms H.R. 4589 Proxy Advisor Registration H.R. 4590 Proxy Advisor Firms H.R. 4628 Proxy Advisor Disclosure H.R. 4640 Proxy Advisor Disclosure H.R. 4641 Shareholder Proposals H.R. 4645 Proxy Voting H.R. 4662 Proxy Advisor Firm Study H.R. 4767 Proxy Advisor Firms H.R. 4790 Financial Disclosure H.R. 4655 Shareholder Proposals S. 3179 Shareholder Proposals H.R. 7030 Securities and Exchange Commission Rulemaking

Client expense: Not reported · Firm income: $44,000

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

H.R.448: Putting Investors First Act H.R.4589 -To amend the Securities Exchange Act of 1934 to provide for the registration of proxy advisory firms H.R.4645 - To amend the Investment Advisers Act of 1940 with respect to proxy voting of passively managed funds, and for other purposes Investment policy related to surety bonding U.S. Securities and Exchange Commission (SEC) public company disclosure proposal including climate risk, cybersecurity, and stock buybacks Issues related to greenhouse gas emissions, net zero, and corporate climate policy Department of Labor Fiduciary Duty Rule

Client expense: $700,000 · Firm income: Not reported

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

H.R.448: Putting Investors First Act H.R.4589 -To amend the Securities Exchange Act of 1934 to provide for the registration of proxy advisory firms H.R.4645 - To amend the Investment Advisers Act of 1940 with respect to proxy voting of passively managed funds, and for other purposes Investment policy related to surety bonding U.S. Securities and Exchange Commission (SEC) public company disclosure proposal including climate risk, cybersecurity, and stock buybacks Issues related to greenhouse gas emissions, net zero, and corporate climate policy Department of Labor Fiduciary Duty Rule

Client expense: $700,000 · Firm income: Not reported

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

Mutual fund, ETF, money market mutual fund, securities, and systemic risk issues; equity market structure. HR 4645, Empowering Shareholders Act of 2023; HR 4767, Protecting American's Retirement Savings from Politics Act. SEC proposal on liquidity risk management and swing pricing. H.R. 3066, Retirement Fairness for Charities and Educational Institutions Act of 2023; H.R. 1807, Improving Disclosure for Investors Act of 2023; H.R. 2799, the Expanding Access to Capital Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.448: Putting Investors First Act H.R.4589 -To amend the Securities Exchange Act of 1934 to provide for the registration of proxy advisory firms H.R.4645 - To amend the Investment Advisers Act of 1940 with respect to proxy voting of passively managed funds, and for other purposes Transportation Infrastructure Finance and Innovation Act (TIFIA) Investment policy related to surety bonding U.S. Securities and Exchange Commission (SEC) public company disclosure proposal including climate risk, cybersecurity, and stock buybacks Issues related to U.S. Department of Treasury T-list limits Issues related to greenhouse gas emissions, net zero, and corporate climate policy

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

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

H.R.448: Putting Investors First Act H.R.4589 -To amend the Securities Exchange Act of 1934 to provide for the registration of proxy advisory firms H.R.4645 - To amend the Investment Advisers Act of 1940 with respect to proxy voting of passively managed funds, and for other purposes Transportation Infrastructure Finance and Innovation Act (TIFIA) Investment policy related to surety bonding U.S. Securities and Exchange Commission (SEC) public company disclosure proposal including climate risk, cybersecurity, and stock buybacks Issues related to U.S. Department of Treasury T-list limits Issues related to greenhouse gas emissions, net zero, and corporate climate policy

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

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

H.R. 448 Proxy Advisory Firms **Issues lobbied without specific bill number: Climate Change Disclosures S. 1799 Proxy Advisory Firms H.R. 4589 Proxy Advisor Registration H.R. 4590 Proxy Advisor Firms H.R. 4628 Proxy Advisor Disclosure H.R. 4640 Proxy Advisor Disclosure H.R. 4641 Shareholder Proposals H.R. 4645 Proxy Voting H.R. 4662 Proxy Advisor Firm Study H.R. 4767 Proxy Advisor Firms H.R. 4790 Financial Disclosure H.R. 4655 Shareholder Proposals S. 3179 Shareholder Proposals

Client expense: $1,360,000 · Firm income: Not reported

H.R. 448 Proxy Advisory Firms **Issues lobbied without specific bill number: Climate Change Disclosures S. 1799 Proxy Advisory Firms H.R. 4589 Proxy Advisor Registration H.R. 4590 Proxy Advisor Firms H.R. 4628 Proxy Advisor Disclosure H.R. 4640 Proxy Advisor Disclosure H.R. 4641 Shareholder Proposals H.R. 4645 Proxy Voting H.R. 4662 Proxy Advisor Firm Study H.R. 4767 Proxy Advisor Firms H.R. 4790 Financial Disclosure H.R. 4655 Shareholder Proposals S. 3179 Shareholder Proposals

Client expense: Not reported · Firm income: $44,000

H.R.448: Putting Investors First Act H.R.4589 -To amend the Securities Exchange Act of 1934 to provide for the registration of proxy advisory firms H.R.4645 - To amend the Investment Advisers Act of 1940 with respect to proxy voting of passively managed funds, and for other purposes Transportation Infrastructure Finance and Innovation Act (TIFIA) Investment policy related to surety bonding U.S. Securities and Exchange Commission (SEC) public company disclosure proposal including climate risk, cybersecurity, and stock buybacks Issues related to U.S. Department of Treasury T-list limits Issues related to greenhouse gas emissions, net zero, and corporate climate policy

Client expense: $330,000 · Firm income: Not reported

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

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

Mutual fund, ETF, money market mutual fund, securities, and systemic risk issues; equity market structure. HR 4645, Empowering Shareholders Act of 2023; HR 4767, Protecting American's Retirement Savings from Politics Act. SEC proposal on liquidity risk management and swing pricing.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.448: Putting Investors First Act H.R.4589 -To amend the Securities Exchange Act of 1934 to provide for the registration of proxy advisory firms H.R.4645 - To amend the Investment Advisers Act of 1940 with respect to proxy voting of passively managed funds, and for other purposes Transportation Infrastructure Finance and Innovation Act (TIFIA) Investment policy related to surety bonding U.S. Securities and Exchange Commission (SEC) public company disclosure proposal including climate risk, cybersecurity, and stock buybacks Issues related to U.S. Department of Treasury T-list limits Issues related to greenhouse gas emissions, net zero, and corporate climate policy

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

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

Beneficial Ownership Capital Formation Climate Disclosures ESG Disclosures FAR Proposal re: Federal Contractor Climate Disclosures H.R. 4161, Performance Over Politics H.R. 4168, Mandatory Materiality Requirement H.R. 4589, Registration of Proxy Advisory Firms H.R. 4590, Liability for Certain Failures to Disclose Material Information or Making of Material Misstatements H.R. 4600, Protecting Retail Investors Savings H.R. 4628, SEC Justification of Non-Material Disclosure Mandates H.R. 4640, Exclusion of Certain ESG Shareholder Proposals H.R. 4644, No Expensive, Stifling Governance H.R. 4645, Empowering Shareholders H.R. 4648, Duties of Investment Advisors, Asset Managers, and Pension Funds H.R. 4652, Public Company Advisory Committee H.R. 4653, Protecting U.S. Business Sovereignty H.R. 4655, Businesses Over Activists Act H.R. 4656, Protecting Americans Savings H.R. 4657, Exclusions Available Regardless of Significant Social Policy Issue H.R. 4662, Corporate Governance Examination H.R. 4767, Protecting Americans Retirement Savings from Politics Act H.R. 4790, the GUARDRAIL Act Human Capital Management Proposed Rule on Climate Disclosures Proposed Rule on Cybersecurity Disclosures Proposed Rule on Shareholder Proposal Exclusions Proxy Advisory Firm Oversight Proxy Process Reforms Proxy Resubmission Thresholds Rule 144A Shareholder Activism

Client expense: $2,060,000 · Firm income: Not reported

H.R. 448 Proxy Advisory Firms **Issues lobbied without specific bill number: Climate Change Disclosures S. 1799 Proxy Advisory Firms H.R. 4589 Proxy Advisor Registration H.R. 4590 Proxy Advisor Firms H.R. 4628 Proxy Advisor Disclosure H.R. 4640 Proxy Advisor Disclosure H.R. 4641 Shareholder Proposals H.R. 4645 Proxy Voting H.R. 4662 Proxy Advisor Firm Study H.R. 4767 Proxy Advisor Firms H.R. 4790 Financial Disclosure H.R. 4655 Shareholder Proposals

Client expense: $1,490,000 · 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 Proxy Advisory Firms **Issues lobbied without specific bill number: Climate Change Disclosures S. 1799 Proxy Advisory Firms H.R. 4589 Proxy Advisor Registration H.R. 4590 Proxy Advisor Firms H.R. 4628 Proxy Advisor Disclosure H.R. 4640 Proxy Advisor Disclosure H.R. 4641 Shareholder Proposals H.R. 4645 Proxy Voting H.R. 4662 Proxy Advisor Firm Study H.R. 4767 Proxy Advisor Firms H.R. 4790 Financial Disclosure H.R. 4655 Shareholder Proposals

Client expense: Not reported · Firm income: $44,000

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

Mutual fund, ETF, money market mutual fund, securities, and systemic risk issues; equity market structure. HR 4645, Empowering Shareholders Act of 2023; HR 4767, Protecting American's Retirement Savings from Politics Act.

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

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

H.R.448: Putting Investors First Act H.R.4589 -To amend the Securities Exchange Act of 1934 to provide for the registration of proxy advisory firms H.R.4645 - To amend the Investment Advisers Act of 1940 with respect to proxy voting of passively managed funds, and for other purposes Transportation Infrastructure Finance and Innovation Act (TIFIA) Investment policy related to surety bonding U.S. Securities and Exchange Commission (SEC) public company disclosure proposal including climate risk, cybersecurity, and stock buybacks Issues related to U.S. Department of Treasury T-list limits

Client expense: $260,000 · Firm income: Not reported

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