American FIRST Act of 2023

H.R. 1059 SECURE Notarization Act H.R. 1165 Data Privacy Act of 2023 H.R. 2656 Trigger Leads Abatement Act of 2023 H.R 7297 Homebuyers Privacy Protection Act of 2024 H.R. 4192 Small Business Financing Disclosure Act of 2023 H.R. 4198 Protecting Consumers from Abusive Mortgage Leads Act H.R. 4737 Stop Executive Capture of Banking Regulators Act H.R. 4823 American Financial Institution Regulator Sovereignty and Transparency Act S. 1212 SECURE Notarization Act S. 2021 Small Business Financing Disclosure Act of 2023 S. 3012 Deposit Security Act S. 3502 Homebuyers Privacy Protection Act H.R. 5648 Community Assistance for Recovery and Empowerment Act H.R. 3464 Affordable Homeownership Access Act H.J. Res. 120 Disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Stability Oversight Council (FSOC) relating to "Guidance on Non-Bank Financial Company Determinations Basel endgame rules

Client expense: $900,000 · Firm income: Not reported

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

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. 1059 SECURE Notarization Act H.R. 1165 Data Privacy Act of 2023 H.R. 2656 Trigger Leads Abatement Act of 2023 H.R 7297 Homebuyers Privacy Protection Act of 2024 H.R. 4192 Small Business Financing Disclosure Act of 2023 H.R. 4198 Protecting Consumers from Abusive Mortgage Leads Act H.R. 4737 Stop Executive Capture of Banking Regulators Act H.R. 4823 American Financial Institution Regulator Sovereignty and Transparency Act S. 1212 SECURE Notarization Act S. 2021 Small Business Financing Disclosure Act of 2023 S. 3012 Deposit Security Act S. 3502 Homebuyers Privacy Protection Act H.R. 5648 Community Assistance for Recovery and Empowerment Act H.R. 3464 Affordable Homeownership Access Act H.J. Res. 120 Disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Financial Stability Oversight Council (FSOC) relating to "Guidance on Non-Bank Financial Company Determinations Basel endgame rules FSOC Designation framework and process

Client expense: $940,000 · 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)

S. 427 - the Financial Freedom Act 16 CFR Parts 801-803-Hart-Scott-Rodino Coverage, Exemption, and Transmittal Rules, Project No. P239300 (Document ID: FTC-2023-0040-0001) Analytic Framework for Financial Stability Risk Identification, Assessment, and Response, RIN 4030-[XXXX], Docket No. FSOC-2023-0001 Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies, RIN 4030-[XXXX], Docket No. FSOC-2023-0002 S. 1838/H.R. 3881 - Credit Card Competition Act H.R. 2797 - Equal Opportunity for all Investors Act of 2023 H.R. 4655 - Businesses Over Activists Act 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 16 CFR Parts 801-803-Hart-Scott-Rodino Coverage, Exemption, and Transmittal Rules, Project No. P239300 (Document ID: FTC-2023-0040-0001) Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications (Docket No. CFPB-2023-0053) S. 3179, Stop Woke Investing Act

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

H.R. 1059 SECURE Notarization Act H.R. 1165 Data Privacy Act of 2023 H.R. 2656 Trigger Leads Abatement Act of 2023 H.R. 4192 Small Business Financing Disclosure Act of 2023 H.R. 4198 Protecting Consumers from Abusive Mortgage Leads Act H.R. 4737 Stop Executive Capture of Banking Regulators Act H.R. 4823 American Financial Institution Regulator Sovereignty and Transparency Act S. 1212 SECURE Notarization Act S. 2021 Small Business Financing Disclosure Act of 2023 S. 3012 Deposit Security Act S. 3502Homebuyers Privacy Protection Act Basel endgame rules FSOC Designation framework and process

Client expense: $400,000 · Firm income: Not reported

FIN ISSUE AREA:Financial Institutions/Investments/Securities Proxy voting policies Proxy advisors Systemic risks Shareholder proposal process Corporate disclosures FSOC regulation and authority H.R. 4790 The Guiding Uniform and Responsible Disclosure Requirements and Information Limits (GUARDRAIL) Act; H.R. 4767 The Protecting Americans Retirement Savings from Politics Act; H.R. 4655 The Businesses Over Activists Act; H.R. 4823 American Financial Institution Regulator Sovereignty and Transparency (American FIRST) Act LBR ISSUE AREA: Labor Issues/Antitrust/Workplace Systemic risks Pension fund investment practices Retirement security policies Proxy voting Proxy advisors ERISA implementation of fiduciary duty H.R. 5337 Retirement Proxy Protection Act; H.R. 5338 No Discrimination In My Benefits Act; H.R. 5339 RETIRE Act; H.R. 5340 Providing Complete Information To Retirement Investors Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proxy voting policies Proxy advisors Systemic risks Shareholder proposal process Corporate disclosures FSOC regulation and authority H.R. 4790 The Guiding Uniform and Responsible Disclosure Requirements and Information Limits (GUARDRAIL) Act; H.R. 4767 The Protecting Americans Retirement Savings from Politics Act; H.R. 4655 The Businesses Over Activists Act; H.R. 4823 American Financial Institution Regulator Sovereignty and Transparency (American FIRST) Act

Client expense: $10,000 · 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)

-Guiding Uniform and Responsible Disclosure Requirements and Information Limits (GUARDRAIL) Act (H.R. 4790), all -Protecting Americans Retirement Savings from Politics Act (H.R. 4767), all -Businesses Over Activists Act (H.R. 4655), all -American Financial Institution Regulatory Sovereignty and Transparency (American FIRST) Act (H.R. 4823), all -S. 1838 - Credit Card Competition Act, all

Client expense: $480,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 427 - the Financial Freedom Act 16 CFR Parts 801-803-Hart-Scott-Rodino Coverage, Exemption, and Transmittal Rules, Project No. P239300 (Document ID: FTC-2023-0040-0001) Analytic Framework for Financial Stability Risk Identification, Assessment, and Response, RIN 4030-[XXXX], Docket No. FSOC-2023-0001 Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies, RIN 4030-[XXXX], Docket No. FSOC-2023-0002 S. 1838/H.R. 3881 - Credit Card Competition Act H.R. 2797 - Equal Opportunity for all Investors Act of 2023 H.R. 4655 - Businesses Over Activists Act 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

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1059 SECURE Notarization Act H.R. 1165 Data Privacy Act of 2023 H.R. 2656 Trigger Leads Abatement Act of 2023 H.R. 4192 Small Business Financing Disclosure Act of 2023 H.R. 4198 Protecting Consumers from Abusive Mortgage Leads Act H.R. 4737 Stop Executive Capture of Banking Regulators Act H.R. 4823 American Financial Institution Regulator Sovereignty and Transparency Act S. 1212 SECURE Notarization Act S. 2021 Small Business Financing Disclosure Act of 2023 S. 3012 Deposit Security Act Basel endgame rules FSOC Designation framework and process

Client expense: $560,000 · Firm income: Not reported

Government targets: Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Treasury, Dept of

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)