REG Act of 2024

Lobbied in support of FTC rulemaking to ban noncompete agreements and on issues related to antitrust, specifically self-preferencing in HR3816/S2992 - American Innovation and Choice Online Act; expanding access to Apple's App Store in HR7030/S2710 - Open Apps Market Act; preventing conflicts of interest and promoting competition in digital advertising in S1073 - AMERICA Act, and increased enforcement of the Robinson-Patman Act.

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

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

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: Not reported · Firm income: $40,000

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

Lobbied in support of FTC rulemaking to ban noncompete agreements and on issues related to antitrust, specifically self-preferencing in HR3816/S2992 - American Innovation and Choice Online Act; expanding access to Apple's App Store in HR7030/S2710 - Open Apps Market Act; preventing conflicts of interest and promoting competition in digital advertising in S1073 - AMERICA Act, and increased enforcement of the Robinson-Patman Act.

Client expense: $20,000 · Firm income: Not reported

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

H.R.760 - Chinese Military and Surveillance Company Sanctions Act of 2023; H.R. 1807, the Improving Disclosure for Investors Act of 2023; H.R. 1837, the Investing in Our Communities Act; H.R. 2590, Unlocking Capital for Small Business Act; H.R. 2799, Expanding Access of Capital Act of 2023; H.R. 3063, Retirement Fairness for Charities and Education Institutions Act, Expanding the Protection for Research Reports to Cover all Securities of All Issuers; H.R. 3136 - The National Critical Capabilities Defense Act; H.R. 4237, a bill 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; HR 4551, the "Protecting Investors Personally Identifiable Information Act" (attached to Capital Markets Subcommittee hearing on 3/20/24); H.R. 4664 and S. 2309, the Fiscal Year 2024 Financial Services and General Government Appropriations bill related to Consolidated Audit Trail and SEC regulatory agenda; H.R. 4763 - the Financial Innovation and Technology for the 21st Century Act; H.R.4766 - Clarity for Payment Stablecoins Act of 2023. H.R. 4767 - Protecting American's Retirement Savings from Politics Act; HR 7030, the Review the Expansion of Government Act of 2024 or the REG Act of 2024 (attached to Capital Markets Subcommittee hearing on 3/20/24); HR 7902, the "Protecting Private Job Creators Act" (exempts fixed income securities from 15c2-11 disclosure) (attached to Capital Markets Subcommittee hearing on 3/20/24); H.R. 8339, the "SEC Reform and Restructure Act; H.R. 8773, FY 2025 Financial Services and General Government Appropriations Bill (3 provisions in the FSGG Bill Report pertaining to the SEC: PDA rule withdrawal, economic analysis enhancement, sensible implementation); H.R. 8818, American Privacy Rights Act; H.J. Res. 100, Providing for congressional disapproval of SEC's Cybersecurity disclosure rule; H.J. Res. 109. Providing for congressional disapproval of the rule submitted by the SEC related to "Staff Accounting Bulletin No. 121."; H.J. Res. 116, providing for congressional disapproval of DOL's independent contractor rule; S. 1695, the American Infrastructure Bonds Act of 2023; S.2678 - Outbound Investment Transparency Act of 2023; S. 4760, Digital Commodities Consumer Protection Act of 2022; S.J.Res.__, a Joint Resolution providing for congressional disapproval of the rule submitted by the SEC related to "Staff Accounting Bulletin No. 121."; H.R. ____, to exempt 144a fixed income securities from Rule 15c2-11; HR ____, to require an assessment and report to Congress on the adequacy of the SECs cost-benefit analysis with respect to major rulemakings (attached to Capital Markets Subcommittee hearing on 3/20/24); HR ____, to mandate minimum comment periods of at least 60 days for all SEC-initiated rulemakings, with certain exceptions, calculated from the date published in the Federal Register (attached to Capital Markets Subcommittee hearing on 3/20/24); HR ____, to require the Commission to review certain reviewable actions by SEC staff (attached to Capital Markets Subcommittee hearing on 3/20/24); HR ____, to require the semi-annual testimony of the Chairman of the SEC before the Committee on Financial Services of the House of Representatives and the Committee on Banking, Housing, and Urban Affairs of the Senate, with testimony on at least one instance to include the testimony of the entire Commission (attached to Capital Markets Subcommittee hearing on 3/20/24); Prudential agency (Federal Reserve, OCC and FDIC) proposal to implement the Basel Endgame reforms in the U.S. and congressional (U.S. House and Senate) oversight of the same, including revisions to the trading book capital rules, stress testing, capital surcharges and buffers; Biden Administration executive order related to China; SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing proposed rule; SEC Amendments to NMS Plan for the Consolidated Audit Trail-Data Security; SEC Staff Accounting Bulletin 121; SEC Security-based Swaps Large Position Reporting proposed rule; SEC proposed rule regarding the safeguarding of client assets (custody proposal); SEC proposed rule on Predictive Data Analytics; SEC proposal regarding reporting of Securities Loans; SEC proposals to modify equity market structure; SEC final rule related to clearing of U.S. Treasury securities; SEC proposed rule to address Volume-Based Exchange Transaction Pricing for NMS Stocks; SEC final rule on short sale data.

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

Lobbied in support of FTC rulemaking to ban noncompete agreements and on issues related to antitrust, specifically self-preferencing in HR3816/S2992 - American Innovation and Choice Online Act; expanding access to Apple's App Store in HR7030/S2710 - Open Apps Market Act; preventing conflicts of interest and promoting competition in digital advertising in S1073 - AMERICA Act; and increased enforcement of the Robinson-Patman Act.

Client expense: $20,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

Prudential agency (Federal Reserve, OCC and FDIC) proposal to implement the Basel Endgame reforms in the U.S. and congressional (U.S. House and Senate) oversight of the same, including revisions to the trading book capital rules, stress testing, capital surcharges and buffers; SEC Prohibition Against Conflicts of Interest in Certain Securitizations proposed rule; H.R. 4168, a bill to amend the Securities Act of 1933 to require that information required to be disclosed to the Securities and Exchange Commission by issuers be material to voting or investment decisions regarding those issuers, and for other purposes; H.R. 4237, a bill 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; H.R. 1807, the Improving Disclosure for Investors Act of 2023; SEC proposed rule regarding the safeguarding of client assets (custody proposal); S. 2190, the RECOUP Act, a bill to amend the Federal Deposit Insurance Act to increase bank executive accountability and to improve financial stability; H.R. ____, to exempt 144a fixed income securities from Rule 15c2-11; S. 1695, the American Infrastructure Bonds Act of 2023; H.R. 1837, the Investing in Our Communities Act; H.R. 4664 and S. 2309, the Fiscal Year 2024 Financial Services and General Government Appropriations bill related to Consolidated Audit Trail and SEC regulatory agenda; SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing proposed rule; SEC Amendments to NMS Plan for the Consolidated Audit Trail-Data Security; SEC Staff Accounting Bulletin 121; SEC Security-based Swaps Large Position Reporting proposed rule; H.R.760 - Chinese Military and Surveillance Company Sanctions Act of 2023; H.R. 1177/S. 427, Financial Freedom Act of 2023; H.R. 4763 - the Financial Innovation and Technology for the 21st Century Act; H.R. 4767 - Protecting American's Retirement Savings from Politics Act; H.R. 3136 - The National Critical Capabilities Defense Act; S.2678 - Outbound Investment Transparency Act of 2023; S. 2251 - Cybersecurity Act of 2023 ; SEC proposed rule on Predictive Data Analytics; SEC proposal regarding reporting of Securities Loans; SEC proposals to modify equity market structure; Biden Administration executive order related to China; SEC final rule related to clearing of U.S. Treasury securities; SEC final rule to improve clearing agency governance; SEC proposed rule to address Volume-Based Exchange Transaction Pricing for NMS Stocks; SEC final rule on short sale data; SEC final rules on beneficial ownership; HR ____, the SEC Regulatory Accountability Act (H.R. 9603 in 117th Congress) (attached to Capital Markets Subcommittee hearing on 3/20/24); HR 7030, the Review the Expansion of Government Act of 2024 or the REG Act of 2024 (attached to Capital Markets Subcommittee hearing on 3/20/24); HR ____, to require an assessment and report to Congress on the adequacy of the SECs cost-benefit analysis with respect to major rulemakings (attached to Capital Markets Subcommittee hearing on 3/20/24); HR ____, to mandate minimum comment periods of at least 60 days for all SEC-initiated rulemakings, with certain exceptions, calculated from the date published in the Federal Register (attached to Capital Markets Subcommittee hearing on 3/20/24); HR ____, to require the Commission to review certain reviewable actions by SEC staff (attached to Capital Markets Subcommittee hearing on 3/20/24); HR ____, to require the semi-annual testimony of the Chairman of the SEC before the Committee on Financial Services of the House of Representatives and the Committee on Banking, Housing, and Urban Affairs of the Senate, with testimony on at least one instance to include the testimony of the entire Commission (attached to Capital Markets Subcommittee hearing on 3/20/24); HR 4551, the "Protecting Investors Personally Identifiable Information Act" (attached to Capital Markets Subcommittee hearing on 3/20/24); HR 7902, the "Protecting Private Job Creators Act" (exempts fixed income securities from 15c2-11 disclosure) (attached to Capital Markets Subcommittee hearing on 3/20/24); S. 3676 (Protecting Private Job Creators Act); H.R. 2799, Expanding Access of Capital Act of 2023; H.R. 2627, Increasing Investor Opportunities Act; H.R. 3063, Retirement Fairness for Charities and Education Institutions Act, Expanding the Protection for Research Reports to Cover all Securities of All Issuers; H.R. 2590, Unlocking Capital for Small Business Act; H.J. Res. 109. Providing for congressional disapproval of the rule submitted by the SEC related to "Staff Accounting Bulletin No. 121."; S.J.Res.__, a Joint Resolution providing for congressional disapproval of the rule submitted by the SEC related to "Staff Accounting Bulletin No. 121.".

Lobbied in support of FTC rulemaking to ban noncompete agreements and on issues related to antitrust, specifically self-preferencing in HR3816/S2992 - American Innovation and Choice Online Act; expanding access to Apple's App Store in HR7030/S2710 - Open Apps Market Act; preventing conflicts of interest and promoting competition in digital advertising in S1073 - AMERICA Act.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Lobbied in support of FTC rulemaking to ban noncompete agreements and on issues related to antitrust, specifically self-preferencing in HR3816/S2992 - American Innovation and Choice Online Act; expanding access to Apple's App Store in HR7030/S2710 - Open Apps Market Act; preventing conflicts of interest and promoting competition in digital advertising in S1073 - AMERICA Act.

Client expense: $20,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Lobbied in support of FTC rulemaking to ban noncompete agreements and on issues related to antitrust, specifically self-preferencing in HR3816/S2992 - American Innovation and Choice Online Act; expanding access to Apple's App Store in HR7030/S2710 - Open Apps Market Act; preventing conflicts of interest and promoting competition in digital advertising in S1073 - AMERICA Act; and banning noncompete agreements in H.R.731/S.220 - Workforce Mobility Act.

Client expense: $20,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General lobbying on issues related to digital trade policy. Specific lobbying on the following bills: S. 2710/H.R. 7030 - Open Apps Market Act [in-app payments (IAP) issues].

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE