Retire through Ownership Act

ERISA Preemption Oversight of EBSA programs Alternative investments in qualified retirement plans Standard of review for fiduciary decisions Pooled Employer Plans Collective investment trusts (CITs) and insurance company separate accounts for use by 403(b) plans Age of required participation in retirement plans reduced from 21 to 18 Permitting automatic re-enrollment of unenrolled participants EBSA Investigations Transparency Act (HR 2869) Retire Through Ownership Act (HR 5169 / S 2403) Transparency for Secret Litigation Agreements (HR 2958) ERISA Litigation Reform Act (HR 6084) Pleading standards legislative proposal regarding standards applicable to ERISA, deference to fiduciary decisions Defined benefit pension plans and defined contribution plans; pension plan de-risking, retiree health accounts Pooled Employer Plans (PEPs) Market-based cash balance plans Pension Risk Transfers Roth Catch-up contributions Trump (child saving) Accounts Retirement plan limits for 2026 and segment rates

Client expense: $210,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Treasury, Dept of, White House Office

H.R. 20/S. 852, Richard L. Trumka Protecting the Right to Organize Act of 2025 H.R. 581/S. 169, Child Care Workforce and Facilities Act of 2025 H.R. 1119, Unemployment Integrity Act of 2025 H.R. 1177/S. 492, Improve & Enhance the Work Opportunity Tax Credit Act H.R. 1319/S. 2228, Modern Worker Empowerment Act H.R. 1320, Modern Worker Security Act H.R. 1801/S. 772, Employer Participation in Repayment Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 2572, Worker Enfranchisement Act H.R. 2952, SALT Act H.R. 2958, Balance the Scales Act Re: EBSA Investigation H.R. 3552/S. 1843, Second Chance Reauthorization Act of 2025 H.R. 3734, Essential Workers for Economic Advancement Act H.R. 4366, Save Local Business Act H.R. 4424, Securing Help for Involuntary Employment Loss and Displacement (SHIELD) Act H.R. 4896/S. 2613, Warehouse Worker Protection Act H.R. 5169, Retire through Ownership Act H.R. 5408/S. 844, Faster Labor Contracts Act H.R. 6655, A Stronger Workforce for America Act S. 1261, American Franchise Act S.2828, Child Care Modernization Act S.J.Res. 8, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Homeland Security relating to "Increase of the Automatic Extension Period of Employment Authorization and Documentation for Certain Employment Authorization Document Renewal Applicants" Draft legislation titled Working Families Flexibility Act Draft legislation titled Ensuring Workers Get PAID Act Draft legislation titled Fair and Open Competition Act Draft legislation titled Protecting the Right to Organize (PRO) Act Draft legislation titled Stop Unemployment Fraud Act Draft legislation titled Upward Mobility Act Potential legislation reauthorizing the Workforce Innovation and Opportunity Act Nominations of Scott Mayer and James Murphy to serve on the National Labor Relations Board Nomination of Crystal Carey to serve as General Counsel of the National Labor Relations Board Nomination of Janet Dhillon to be Director of the Pension Benefit Guaranty Corporation Labor Certification for Permanent Employment of Foreign Workers in the United States; Modernizing Schedule A To Include Consideration of Additional Occupations in Science, Technology, Engineering, and Mathematics (STEM) and Non-STEM Occupations (88 Fed. Reg. 88,290-88,295, February 13, 2024) OSHA Notice of Proposed Rulemaking Concerning Heat Injury and Illness Prevention in Outdoor and Indoor Settings (89 Fed. Reg. 70,698-70,699, August 30, 2024) Final Wage and Hour Division rulemaking defining classification of independent contractors and employees under FLSA (89 Fed. Reg. 1,638-1,743, January 10, 2024) Final Wage and Hour Division rulemaking Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales, and Computer Employees (89 Fed. Reg. 32,842-32,973, April 26, 2024) Solicitation for Public Comments on Provisions of Franchise Agreements and Franchisor Business Practices FTC Docket No: -2023-0026 Final OSHA rulemaking on Worker Walkaround Representative Designation Process (89 Fed. Reg. 22,558-22,601, April 1, 2024) Proposed Rule, National Labor Relations Board; Representation-Case Procedures: Election Bars; Proof of Majority Support in Construction Industry Collective-Bargaining Relationships (87 Fed. Reg. 66,890-66,933, November 4, 2022) Final rule regarding Representation-Case Procedures (88 Fed. Reg. 58,076-58,102, August 25, 2023) Various issues relating to unemployment insurance; paid leave including paid family and sick leave; reforms to the Fair Labor Standards Act (P.L. 75-178); debarment of federal contractors (blacklisting); Equal Employment Opportunity Commission (EEOC) conciliation regulation; rescission of the joint employer standard under the Fair Labor Standards Act (P.L. 75-718); priorities for reauthorization of the Workforce Innovation and Opportunity Act (P.L. 113-28); implementation of the Pregnant Workers Fairness Act (PWFA) (P.L. 117-328); implementation of the PUMP for Nursing Mothers (PUMP) Act (P.L. 117-328); FTC's Multilateral Pharmaceutical Merger Taskforce; USMCA Labor Council; proposed amendment to the U.S. Longshore and Harbor Workers Compensation Act (Longshore Act), relating to the establishment of statutory presumptions of coverage and compensability for illnesses; potential legislation on the minimum wage; legal and regulatory framework for evaluating mergers and acquisitions; corporate consolidation through serial acquisitions and roll-up strategies; accreditation of International Labor Conference delegation to the International Labor Organization; proposed restructuring plan for the National Institute for Occupational Safety and Health and its National Personal Protective Technology Laboratory; Talent Strategy: Building the Workforce for the Golden Age; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); employer speech rights concerns to the National Labor Relations Board; Executive Order 14036, Promoting Competition in the American Economy; implementation of Executive Order 14330, Democratizing Access to Alternative Assets for 401(k) Investors; Registered Apprenticeship Program; elimination of Executive Order 14063, Use of Project Labor Agreements for Federal Construction Projects; antitrust and consumer protection law grounded in economic analysis; competition policy chapters in trade negotiations and associated agreements; appropriations for the Federal Trade Commission and Department of Justice; international concerns in the areas of antitrust, standards and investment; domestic and international antitrust policy; authority under the Federal Trade Commission Act sections 5, 13b and 19; policies and practices related to the FTC expanding its authority; transparency at the FTC; duration of FTC consent orders; FTC rulemaking authority and procedure under Federal Trade Commission Act Section 18; enforcement of the antitrust laws regarding mergers; contract terms and their relationship to competition, particularly relating to worker non-compete clauses and exclusive contracts; regulation of digital platforms; Robinson-Patman Act-related policy and enforcement matters; concerns related to FTC Trade Regulation Rule rulemaking; concerns related to Protecting Americans Data from Foreign Adversaries Act (P .L. 118-50); changes to the FTCs Hart-Scott-Rodino Antitrust Improvements Act merger filing rule; workforce development; education; second chance hiring; International Labor Organization and the international labor conference; apprenticeships

H.R. 2540, SSI Savings Penalty Elimination Act H.R. 3383, Incentivizing New Ventures and Economic Strength Through Capital Formation Act of 2025 H.R. 5169, Retire through Ownership Act H.R. 6084, ERISA Litigation Reform Act Various issues relating to multiemployer pension plans; single employer defined contribution plans and defined benefit plans; fiduciary investment duties, alternative investments in 401(k) plans and fiduciary status; Employee Retirement Income Security Act (ERISA) litigation reform; funding for single employer pension plans; remote notarization and remote witnessing procedures; brokerage windows in self-directed retirement plans; retirement security for all and defined benefit plan improvements; U.S. Department of Labors review of the definition of investment advice fiduciary; auto-portability of retirement plans; implementation of Internal Revenue Code Section 411(d)(6), relationship to in-service early retirement distributions; implementation and technical corrections of the SECURE 2.0 Act (P.L. 117-328); retirement savings lost and found searchable database as provided for in section 303 of the SECURE 2.0 Act; proposed amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption) (RIN 1210-ZA07); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of Executive Order 14330, Democratizing Access to Alternative Assets for 401(k) Investors

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

H.R.4868 - College Athlete Economic Freedom Act. S.2470 - College Athlete Economic Freedom Act. General lobbying with regard to ending forced arbitration in employment claims. General lobbying and on draft legislation with regard to name, image, and likeness (NIL). S. 2026 Court Legal Access and Student Support Act (CLASS) Act. H.R. 3938 Court Legal Access and Student Support Act (CLASS) Act. H.R. 2688 Protecting Student Athletes Economic Freedom Act of 2025. H.R. 2663 Restore College Sports Act. H.R. 4312 SCORE Act. S.2932 Student Athlete Fairness and Enforcement Act. H.R.6350 - College Athletics Reform Act. H.R.5267 - American Franchise Act. H.R.2988 - Protecting Prudent Investment of Retirement Savings Act. H.R.5169 - Retire through Ownership Act.

Client expense: $1,770,000 · Firm income: Not reported

H.R. 20/S. 852, Richard L. Trumka Protecting the Right to Organize Act of 2025 H.R. 581/S. 169, Child Care Workforce and Facilities Act of 2025 H.R. 1119, Unemployment Integrity Act of 2025 H.R. 1177/ S. 492, Improve & Enhance the Work Opportunity Tax Credit Act H.R. 1319/S. 2228, Modern Worker Empowerment Act H.R. 1320, Modern Worker Security Act H.R. 1801/S. 772, Employer Participation in Repayment Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 2572, Worker Enfranchisement Act H.R. 2952, SALT Act H.R. 2958, Balance the Scales Act Re: EBSA Investigation H.R. 3552/S. 1843, Second Chance Reauthorization Act of 2025 H.R. 3734, Essential Workers for Economic Advancement Act H.R. 4366, Save Local Business Act H.R. 4424, Securing Help for Involuntary Employment Loss and Displacement Act (SHIELD) H.R. 4896/S. 2613, Warehouse Worker Protection Act H.R. 5169, Retire through Ownership Act H.R. 5408/S. 844, Faster Labor Contracts Act H.R. 6655, A Stronger Workforce for America Act S.J.Res. 8, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Homeland Security relating to "Increase of the Automatic Extension Period of Employment Authorization and Documentation for Certain Employment Authorization Document Renewal Applicants" Draft legislation titled Child Care Modernization Act Draft legislation titled Working Families Flexibility Act Draft legislation titled Ensuring Workers Get PAID Act Draft legislation titled Fair and Open Competition Act Draft legislation titled Protecting the Right to Organize (PRO) Act Potential legislation reauthorizing the Workforce Innovation and Opportunity Act (P.L.113-28) Nominations of Scott Mayer and James Murphy to serve on the National Labor Relations Board Nomination of Andrea Lucas to be Commissioner on the Equal Employment Opportunity Commission Nomination of Daniel Aronowitz to be Assistant Secretary for the Employee Benefits Security Administration Nomination of Janet Dhillon to be Director of the Pension Benefit Guaranty Corporation Labor Certification for Permanent Employment of Foreign Workers in the United States; Modernizing Schedule A To Include Consideration of Additional Occupations in Science, Technology, Engineering, and Mathematics (STEM) and Non-STEM Occupations (88 Fed. Reg. 88,290-88,295, February 13, 2024) OSHA Notice of Proposed Rulemaking Concerning Heat Injury and Illness Prevention in Outdoor and Indoor Settings (89 Fed. Reg. 70,698-70,699, August. 30, 2024) Final Wage and Hour Division rulemaking defining classification of independent contractors and employees under FLSA (89 Fed. Reg. 1,638-1,743, January 10, 2024) Final Wage and Hour Division rulemaking Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales, and Computer Employees (89 Fed. Reg. 32,842-32,973, April 26, 2024) Solicitation for Public Comments on Provisions of Franchise Agreements and Franchisor Business Practices FTC Docket No: -2023-0026 Final OSHA rulemaking on Worker Walkaround Representative Designation Process (89 Fed. Reg. 22,558-22,601, April 1, 2024) Proposed Rule, National Labor Relations Board; Representation-Case Procedures: Election Bars; Proof of Majority Support in Construction Industry Collective-Bargaining Relationships (87 Fed. Reg. 66,890-66,933, November 4, 2022) Final rule regarding Representation-Case Procedures (88 Fed. Reg. 58,076-58,102, August 25, 2023) Various issues relating to unemployment insurance; paid leave including paid family and sick leave; reforms to the Fair Labor Standards Act (P.L. 75-178); debarment of federal contractors (blacklisting); Equal Employment Opportunity Commission (EEOC) conciliation regulation; rescission of the joint employer standard under the Fair Labor Standards Act (P.L. 75-718); FTC's Multilateral Pharmaceutical Merger Taskforce; USMCA Labor Council; proposed amendment to the U.S. Longshore and Harbor Workers Compensation Act (Longshore Act), relating to the establishment of statutory presumptions of coverage and compensability for illnesses; potential legislation on the minimum wage; legal and regulatory framework for evaluating mergers and acquisitions; corporate consolidation through serial acquisitions and roll-up strategies; changes to the FTCs Hart-Scott-Rodino Antitrust Improvements Act merger filing rule; implementation of the Pregnant Workers Fairness Act (PWFA) (P.L. 117-328); implementation of the PUMP for Nursing Mothers (PUMP) Act (P.L. 117-328); accreditation of International Labor Conference delegation to the International Labor Organization; proposed restructuring plan for the National Institute for Occupational Safety and Health and its National Personal Protective Technology Laboratory; Talent Strategy: Building the Workforce for the Golden Age; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); employer speech rights concerns to the National Labor Relations Board; Executive Order 14036, Promoting Competition in the American Economy; elimination of Executive Order 14063, Use of Project Labor Agreements for Federal Construction Projects; antitrust grounded in economic analysis; competition policy chapters in trade negotiations and associated agreements; appropriations for the Federal Trade Commission and Department of Justice; international concerns in the areas of antitrust, standards and investment; domestic and international antitrust policy; authority under the Federal Trade Commission Act sections 5, 13b and 19; policies and practices related to the FTC expanding its authority; transparency at the FTC; duration of FTC consent orders; enforcement of the antitrust laws regarding mergers; contract terms and their relationship to competition, particularly relating to worker non-compete clauses and exclusive contracts; regulation of digital platforms; Robinson-Patman Act-related policy and enforcement matters; concerns related to FTC Trade Regulation Rule rulemaking; concerns related to Protecting Americans Data from Foreign Adversaries Act (P.L. 118-50); policy matters related to the FTCs unfair and deceptive acts and practices authority; negative option rule, including revocation under the Congressional Review Act (P.L. 104-121); workforce development; education; second chance hiring; International Labor Organization and the international labor conference

H.R. 2540, SSI Savings Penalty Elimination Act H.R. 5169, Retire through Ownership Act Various issues relating to multiemployer pension plans; single employer defined contribution plans and defined benefit plans; fiduciary investment duties and fiduciary status; qualified professional asset managers; retirement plans and reconciliation; Employee Retirement Income Security Act (ERISA) litigation reform; e-delivery of retirement plan disclosures and notices; funding for single employer pension plans; remote notarization and remote witnessing procedures; brokerage windows in self-directed retirement plans; retirement security for all and defined benefit plan improvements; U.S. Department of Labors review of the definition of investment advice fiduciary; auto-portability of retirement plans; implementation of Internal Revenue Code Section 411(d)(6), relationship to in-service early retirement distributions; implementation and technical corrections of the SECURE 2.0 Act (P.L. 117-328); retirement savings lost and found searchable database as provided for in section 303 of the SECURE 2.0 Act (P.L. 117-328); proposed amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption) (RIN 1210-ZA07); implementation of the One Big Beautiful Bill Act, (P.L. 119-21)

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

ERISA preemption Technical corrections to SECURE 2.0 Collective investment trusts (CITs) and insurance company separate accounts for use by 403(b) plans; Retirement Fairness for Charities and Educational Institutions, (HR 1013) Age of required participation in retirement plans reduced from 21 to 18, (S. 1707) Automatic re-enrollment of unenrolled plan participants permitted by (S. 1831) EBSA Investigations Transparency Act (HR 2869) Retire Through Ownership Act (HR 5169) Transparency for Secret Litigation Agreements (HR 2958) Common Interest Agreements used by the U.S. DOL Pleading standards, legislative proposal applicable to ERISA cases Defined benefit pension plans and defined contribution plans; pension plan de-risking, retiree health accounts Required Roth catch-up contributions and Roth optional matching and non-elective contributions guidance Pension Benefit Guaranty Corporation (PBGC) premiums and due date for premium payment Direct Final Rule Revocations by EBSA 401(k) plan investments in alternative assets and lifetime income Pooled Employer Plans (PEPs) Retirement benefits for independent workers white paper regarding Supreme Court petition, Johnson v. Parker Hannifin

Client expense: $220,000 · Firm income: Not reported