Promoting Opportunities for Non-Traditional Capital Formation Act

Advocating for democracy reforms that make elections more transparent, get more people involved in the political process, and expand voting rights. HR 8824, S 4573, HR 8873, HR 3867, HR 3422, S 1616 Advocating for judicial nominees that will uphold civil liberties, respect for the rule of law, and support workers' rights.

Client expense: $215,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 145, Risk Disclosure and Investor Attestation Act H.R. 654, Taking Account of Bureaucrats Spending (TABS) Act of 2025 H.R. 1013/S. 424, Retirement Fairness for Charities and Educational Institutions Act of 2025 H.R. 1109, Litigation Transparency Act of 2025 H.R. 1190/S. 577, Expanding Access to Capital for Rural Job Creators Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1900, Bank Failure Prevention Act of 2025 H.R. 2225/S. 1808, Access to Small Business Investor Capital Act H.R. 2441/S. 1877, Improving Disclosure for Investors Act of 2025 H.R. 2675/S. 3180, Protecting Our Courts From Foreign Manipulation Act of 2025 H.R. 2702/S. 875, Financial Integrity and Regulation Management (FIRM) Act H.R. 3230, Financial Institution Regulatory Tailoring Enhancement Act H.R. 3301, ELEVATE Act of 2025 H.R. 3323, Helping Startups Continue to Grow Act H.R. 3339, Equal Opportunity for Investors Act of 2025 H.R. 3343, Greenlighting Growth Act of 2025 H.R. 3348, Accredited Investor Definition Review Act H.R. 3351, Improving Access to Small Business Information Act H.R. 3352, HALOS Act of 2025 H.R. 3357, Enhancing Multi-Class Share Disclosures Act H.R. 3379, HUMPS Act of 2025 H.R. 3380, TAILOR Act of 2025 H.R. 3381, Encouraging Public Offerings Act of 2025 H.R. 3382/S. 2924, Small Entity Update Act H.R. 3383, Increasing Investor Opportunities Act H.R. 3390, Bringing the Discount Window into the 21st Century Act H.R. 3394, Fair Investment Opportunities for Professional Experts Act H.R. 3395, Middle Market IPO Cost Act H.R. 3422, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 3446, The FDIC Board Accountability Act H.R. 3645, ACCESS Act of 2025 H.R. 3672, Securities Research Modernization Act H.R. 3673, Small Business Investor Capital Access Act H.R. 3682/S. 3578, Financial Stability Oversight Council Improvement Act of 2025 H.R. 3959, Protecting Private Job Creators Act H.R. 4429, Developing and Empowering Our Aspiring Leaders (DEAL) Act H.R. 4430, Expanding WKSI Eligibility Act H.R. 4431, Improving Capital Formation for Newcomers (ICAN) Act H.R. 4437, Supervisory Modifications for Appropriate Risk-based Testing (SMART) Act of 2025 H.R. 4478, Tailored Regulatory Updates for Supervisory Testing (TRUST) Act of 2025 H.R. 5291/S. 2663, Merchant Banking Modernization Act S. 985, PROTECT USA Act S. 1605, International Competition for American Jobs Act H.J.Res. 74/S.J.Res. 36, A joint resolution 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 "Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V)" Potential legislation similar to H.R. 448, Putting Investors First Act Potential legislation similar to H.R. 2590, Unlocking Capital for Small Business Act of 2023 Potential legislation similar to H.R. 2607, Improving Crowdfunding Opportunities Act, 2023 Potential legislation similar to H.R. 2609, Small Entrepreneur Empowerment and Development Act of 2023 Potential legislation similar to H.R. 2622, to amend the Investment Advisers Act of 1940 to codify certain Securities and Exchange Commission no-action letters that exclude brokers and dealers compensated for certain research services from the definition of investment adviser Potential legislation similar to H.R. 2651, Regulation A+ Improvement Act of 2023 Potential legislation similar to H.R. 2790, the Improving Capital Allocation for Newcomers Act of 2021 Potential legislation similar to H.R. 2799, the Investment Opportunity Expansion Act, 2023 Potential legislation similar to H.R. 4168/S. 2005, Mandatory Materiality Act Potential legislation similar to H.R. 4767, Protecting Americans Retirement Savings from Politics Act Potential legislation similar to H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 Potential legislation similar to H.R. 6623/S. 2068, Main Street Growth Act Potential legislation to repeal the SECs Universal Proxy Rule of 2021 Potential legislation to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements 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, Consumer Financial Protection Bureau; Protecting Americans from Harmful Data Broker Practices (Regulation V) (89 Fed. Reg. 101,402, December 13, 2024) 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; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Financial Accounting Standards Board improvements to income tax disclosures; Climate-Related Financial Risk Management for Large Banks; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; Basel III Endgame Rule; FDIC Monitoring of Investment Funds Passivity Agreements; issues related to the Export-Import Bank of the United States; European Unions (EU) Corporate Sustainability Due Diligence Directive (CSDDD); Consumer Financial Protection Circular 2024-05, Improper Overdraft Opt-In Practices; Executive Order 14036, Promoting Competition in the American Economy; recommendations for Securities and Exchange Commission regulatory agenda; reforming SEC Rule 14a-8; FSOC restoration of 2019 Guidance governing the designation of nonbank financial institutions; reauthorization of the U.S. International Development Finance Corporation; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" (P.L. No: 119-10); implementation of A joint resolution disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" (P.L. 119-11); proxy process and shareholder proposal system overseen by SEC; FSOC Nonbank Guidance - request to restore the 2019 Guidance (July 14, 2025, letter to Treasury); reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; index fund passivity; reform to the function of the Public Company Accounting Oversight Board; rulemaking regarding corporate exemptions for shareholder proposals under SEC Rule 14a-8; rulemaking regarding reform to the proxy voting advice industry at the SEC; request for comment from SEC on potential revisions to executive compensation disclosure; request for comment from SEC on potential revisions to definition of Foreign Private Issuer; SEC Compliance and Disclosure Interpretations: Regulation 13D-G (February 11, 2025); potential policy affirming materiality as the standard for corporate disclosure at the SEC; Executive Order 14366, Protecting American Investors from Foreign-Owned and Politically-Motivated Proxy Advisors; Executive Order 14330, Democratizing Access to Alternative Assets for 401(K) Investors; SEC Staff Review ADI 2025-16 on Registered Closed-End Funds of Private Funds (August 15, 2025); acquired fund fees and expenses mandate under Rule 12d1-4 (impact of AFFE on BDCs and inclusion of alternative assets in 401(K)s); potential policy from SEC on electronic delivery of investor disclosure information; oversight issues and potential legislation on third party litigation funding, including its national security implications

Client expense: $17,960,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 145, Risk Disclosure and Investor Attestation Act H.R. 654, Taking Account of Bureaucrats Spending (TABS) Act of 2025 H.R. 1013/S. 424, Retirement Fairness for Charities and Educational Institutions Act of 2025 H.R. 1109, Litigation Transparency Act of 2025 H.R. 1190/S. 577, Expanding Access to Capital for Rural Job Creators Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1900, Bank Failure Prevention Act of 2025 H.R. 2225/S. 1808, Access to Small Business Investor Capital Act H.R. 2441/S. 1877, the Improving Disclosure for Investors Act of 2025 H.R. 2675, Protecting Our Courts From Foreign Manipulation Act of 2025 H.R. 2702/S. 875, Financial Integrity and Regulation Management (FIRM) Act H.R. 3230, Financial Institution Regulatory Tailoring Enhancement Act H.R. 3301, ELEVATE Act of 2025 H.R. 3323, Helping Startups Continue to Grow Act H.R. 3339, Equal Opportunity for Investors Act of 2025 H.R. 3343, Greenlighting Growth Act of 2025 H.R. 3348, Accredited Investor Definition Review Act H.R. 3351, Improving Access to Small Business Information Act H.R. 3352, HALOS Act of 2025 H.R. 3357, Enhancing Multi-Class Share Disclosures Act H.R. 3379, HUMPS Act of 2025 H.R. 3380, TAILOR Act of 2025 H.R. 3381, Encouraging Public Offerings Act of 2025 H.R. 3382, Small Entity Update Act H.R. 3383, Increasing Investor Opportunities Act H.R. 3390, Bringing the Discount Window into the 21st Century Act H.R. 3394, Fair Investment Opportunities for Professional Experts Act H.R. 3395, Middle Market IPO Cost Act H.R. 3422, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 3446, The FDIC Board Accountability Act H.R. 3645, ACCESS Act of 2025 H.R. 3672, Securities Research Modernization Act H.R. 3673, Small Business Investor Capital Access Act H.R. 3682, Financial Stability Oversight Council Improvement Act of 2025 H.R. 3959, Protecting Private Job Creators Act H.R. 4429, Developing and Empowering Our Aspiring Leaders (DEAL) Act H.R. 4430, Expanding WKSI Eligibility Act H.R. 4431, Improving Capital Formation for Newcomers (ICAN) Act H.R. 4429, Developing and Empowering Our Aspiring Leaders (DEAL) Act H.R. 4437, Supervisory Modifications for Appropriate Risk-based Testing (SMART) Act of 2025 H.R. 4478, Tailored Regulatory Updates for Supervisory Testing (TRUST) Act of 2025 H.R. 5291/S. 2663, Merchant Banking Modernization Act S. 985, PROTECT USA Act S. 1605, International Competition for American Jobs Act H.J. Res. 74/S.J. Res. 36, A joint resolution 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 "Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V)" Potential legislation similar to H.R. 448, Putting Investors First Act Potential legislation similar to H.R. 2590, Unlocking Capital for Small Business Act of 2023 Potential legislation similar to H.R. 2607, Improving Crowdfunding Opportunities Act, 2023 Potential legislation similar to H.R. 2609, Small Entrepreneur Empowerment and Development Act of 2023 Potential legislation similar to H.R. 2622, to amend the Investment Advisers Act of 1940 to codify certain Securities and Exchange Commission no-action letters that exclude brokers and dealers compensated for certain research services from the definition of investment adviser Potential legislation similar to H.R. 2651, Regulation A+ Improvement Act of 2023 Potential legislation similar to H.R. 2790, the Improving Capital Allocation for Newcomers Act of 2021 Potential legislation similar to H.R. 2799, the Investment Opportunity Expansion Act, 2023 Potential legislation similar to H.R. 4168/S. 2005, Mandatory Materiality Act Potential legislation similar to H.R. 5488/S. 2805, Protecting Our Courts from Foreign Manipulation Act of 2023 Potential legislation similar to H.R. 6623/S. 2068, Main Street Growth Act Potential legislation to repeal the SECs Universal Proxy Rule of 2021 Potential legislation to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain rulemaking requirements 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, Consumer Financial Protection Bureau; Protecting Americans from Harmful Data Broker Practices (Regulation V) (89 Fed. Reg. 101,402, December 13, 2024) 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; modernization of the Credit Repair Organizations Act (enacted as Title IV of the Consumer Credit Protection Act, P.L. 90-321); Internal Revenue Service Priority Guidance Plan; Financial Accounting Standards Board improvements to income tax disclosures; Climate-Related Financial Risk Management for Large Banks; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; CFPB Small Business Advisory Review Panels Rulemaking on Personal Financial Data Rights; CFPB implementation of the Small Business Lending Data Collection Rule (the 1071 Rule); SEC Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting (File Number S7-26-22); Federal Deposit Insurance Corporation Proposal on Corporate Governance and Risk Management; Basel III Endgame Rule; FDIC Monitoring of Investment Funds Passivity Agreements; issues related to the Export-Import Bank of the United States; European Unions (EU) Corporate Sustainability Due Diligence Directive (CSDDD); Consumer Financial Protection Circular 2024-05, Improper Overdraft Opt-In Practices; Executive Order 14036, Promoting Competition in the American Economy; recommendations for Securities and Exchange Commission regulatory agenda; Reforming SEC Rule 14a-8; FSOC restoration of 2019 Guidance governing the designation of nonbank financial institutions; reauthorization of the U.S. International Development Finance Corporation; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of Disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Overdraft Lending: Very Large Financial Institutions" (P.L. No: 119-10); implementation of a joint resolution disapproving the rule submitted by the Bureau of Consumer Financial Protection relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications" (P.L. No: 119-11); proxy process and shareholder proposal system overseen by SEC; FSOC Nonbank Guidance - request to restore the 2019 Guidance (July 14, 2025, letter to Treasury); reporting metrics of American companies under the EUs Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive; index fund passivity; reform to the function of the Public Company Accounting Oversight Board; rulemaking regarding corporate exemptions for shareholder proposals under SEC Rule 14a-8; rulemaking regarding reform to the proxy voting advice industry at the SEC; request for comment from SEC on potential revisions to executive compensation disclosure; request for comment from SEC on potential revisions to definition of Foreign Private Issuer; SEC Compliance and Disclosure Interpretations: Regulation 13D-G (February 11, 2025); potential policy affirming materiality as the standard for corporate disclosure at the SEC; Executive Order 14330, Democratizing Access to Alternative Assets for 401(K) Investors; SEC Staff Review ADI 2025-16 on Registered Closed-End Funds of Private Funds (August 15, 2025); acquired fund fees and expenses mandate under Rule 12d1-4 (impact of AFFE on BDCs and inclusion of alternative assets in 401(K)s); oversight issues and potential legislation on third party litigation funding, including its national security implications

Client expense: $13,650,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)