Retirement Investment Choice Act

Issues related to crypto & digital assets including 1) digital assets market structure initiatives such as H.R. 3633, the Digital Asset Market Clarity (CLARITY) Act and Senate companion drafts such as S. 4356, the Responsible Financial Innovation Act (RFIA) and S. 3755, the Digital Commodity Intermediaries Act and 2) Stablecoins legislation clarification including S. 919, Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the GENIUS Act) Issues related to including digital assets in registered investment companies and the taxation of digital assets, including H.R. 9175, the Tax Clarity for Mining and Staking Act Increases in the stock buyback excise tax included in FY27 National Defense Authorization Act (NDAA) - H.R. 8800 and S. 4784 Various reconciliation issues in H.R.1, the One Big Beautiful Bill Act, including section 899 and implementation of Trump accounts Treasury meetings about Trump accounts. Protecting closed-end funds from activist investors and enhancing retail investor access to alternative investments & private markets - H.R. 3383, the Increasing Investor Opportunities Act Capital formation initiatives included in H.R. 3383, the Incentivizing New Ventures and Economic Strength Through Capital Formation (INVEST) Act (note same bill number as the CEF bill - two bills combined) and possible Senate companion legislation, the Empowering Main Street in America Act (EMSAA) Promoting inclusion of alternative investments in retirement plans, including H.R. 2544 & S. 1222, the Financial Freedom Act and H.R. 5748, the Retirement Investment Choice Act which codifies President Trumps executive order (14330) on alternative investments in 401(k)s Accredited investor reform initiatives including H.R. 3348, the Accredited Investor Definition Review Act, H.R. 3339, the Equal Opportunity for All Investors Act, and H.R. 3394, the Fair Investment Opportunities for Professional Experts Act Clarifications about restrictions on outbound investments to China included in the National Defense Authorization Act (NDAA) S. 1071 including the COINS Act, the Comprehensive Outbound Investment National Security Act of 2025 Business Development Company issues including H.R. 2225 & S. 1808 - the Access to Small Business Investor Capital Act E-delivery initiatives including H.R. 2441 & S 1877, the Improving Disclosure for Investors Act Retirement security initiatives, including S. 424 and H.R. 1013, the Retirement Fairness for Charities and Educational Institutions Retirement savings initiatives including promoting tax deferral for individuals participating in voluntary, employer provided retirement plans and IRAs and H.R. 2696 and S. 1526, the Retirement Savings for Americans Act (RSAA) that would create a federal retirement system ERISA litigation reform efforts such as H. R. 6084, the ERISA Litigation Reform Act Congressional oversight of ESG investing including proxy voting by asset managers and various legislative initiatives H.R. 3682 and S. 3578, the FSOC Improvement Act which reforms the Financial Stability Oversight Councils non-bank Systematically Important Financial Institution (SIFI) designation process.

Client expense: $270,000 · Firm income: Not reported

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

H.R.1013, S.424 Retirement Fairness for Charities and Educational Institutions Act of 2025: Allows 403(b) retirement plans to invest in Collective Investment Trust or Separate Accounts Insurance Products to establish investment parity with other defined contribution plans, like 401(k)s. H.R. 2082-WISH Act-- provide for long-term care insurance benefits H.R.2089 Generating Retirement Ownership through Long-Term Holding (GROWTH): The legislation provides that reinvested mutual fund dividends are not subject to capital gains taxation until the investor sells his or her shares. H.R.2163 No Penalties for Victims of Fraud Act: The bill ensures that victims of retirement account fraud are not subject to the 10% additional income tax on early retirement plan distributions. H.R.2696/ S.1526 - Retirement Savings for Americans Act This legislation establishes a federally run American Worker Retirement Plan for private-sector workers that do not have access to a workplace-based retirement plan. H.R.2748 First Time Homeowner Savings Plan Act: This legislation increases the amount first-time homebuyers could pull from their retirement savings from the $10,000 set in the 1990s to $25,000 (indexed to inflation) without the 10% additional income tax on early retirement plan distributions to use as a down payment on their home. H.R.2869 EBSA Investigations Transparency Act: This legislation requires the Department of Labors Employee Benefits Security Administration (EBSA) to submit annual reports to Congress on the status of its open employee plan audits and to explain why any audits open for more than 36 months have not been closed. H.R. 2988 Protecting Prudent Investment of Retirement Savings Act: This legislation clarifies the criteria for meeting the fiduciary duty of ERISA. H.R.3526, S.2867 Uplifting First-Time Homebuyers Act of 2025: This legislation allows individuals to take an early distribution out of an IRA of up to $50,000 for a qualified first-time home purchase without the 10% additional income tax penalty. Current rules only allow up to a $10,000 early distribution without penalty. H.R. 4718/S.1707 Helping Young Americans Save for Retirement Act: This legislation lowers the required minimum participation age in ERISA-covered retirement plans from age 21 to age 18. H.R.5748 Retirement Investment Choice Act: This legislation codifies Executive Order 14330 relating to democratizing access to alternative assets for 401(k) investors. H.R.6084 ERISA Litigation Reform Act: This legislation amends the pleading standard under ERISA Section 502 for certain claims to put the burden on the plaintiff to plausibly allege and prove that an ERISA prohibitive transaction occurred that is not exempt under ERISA section 408(b)(2). H.R.6324 Retirement Simplification and Clarity Act: This legislation would: (1) permit an in-service plan distribution to an individual retirement annuity on or after attainment of age 50; and (2) include a specific reference to an individual retirement annuity as a rollover option under a simplified 402(f) safe harbor notice. H.R.6450, S.3352 Retirement Rollover Flexibility Act: This legislation would permit rollover contributions from Roth IRAs to designated Roth accounts in qualified retirement plans, like 401(k)s. H.R.6722 Automatic IRA Act of 2025: The legislation would require employers with more than 10 employees that do not sponsor a retirement plan to automatically enroll their employees in IRAs (automatic IRAs) or other automatic contribution plans or arrangements, like 401(k) plans. The legislation also requires 401(k) plans with over 100 participants plans must permit participants to elect to receive at least 50 percent of their vested account balance in the form of lifetime income. This requirement does not apply to participants with balances below $200,000. H.R. 6729/S.1831 Auto Reenroll Act of 2025: This legislation amends the qualified automatic contribution arrangement (QACA) safe harbor in the tax code for 401(k) plans to allow for automatic periodic reenrollment into the plan H.R.7185 Home Savings Act: This legislation permits penalty-free withdrawals from a 401(k) account for up to five years when the funds are used for a down payment or closing costs on a primary residence. The legislation also allows an individual to make a penalty-free 401(k) withdrawal and gift those funds to a relative, exempt from gift tax, provided the relative uses the money for a down payment or closing costs on a primary residence. General Accounts Product Corrections Act: Would clarify fiduciary responsibilities for life insurance companies as it relates to investments in their general accounts.

H.R. 3383, Incentivizing New Ventures and Economic Strength Through Capital Formation Act of 2025 H.R. 3633, Digital Asset Market Clarity Act of 2025 H.R. 3682/S. 3578, Financial Stability Oversight Council Improvement Act of 2025 H.R. 3838, Streamlining Procurement for Effective Execution and Delivery and National Defense Authorization Act for Fiscal Year 2026 H.R. 5748, Retirement Investment Choice Act H.R. 6161, SEC Data Protection Act S. 2296, National Defense Authorization Act for Fiscal Year 2026 Regulation and oversight of investment advisers. Equity market structure issues including electronic and algorithmic trading. Protection for sensitive and proprietary data. Nonbank regulation. AML issues / beneficial ownership. Financial Stability Oversight Council (FSOC) interpretive guidance regarding authority to require supervision and regulation of certain nonbank financial companies. Retail access to alternatives. Accredited investor definition. Capital formation. Investment limitations on foreign assets. Outbound investment review process. Short selling. Digital assets and cryptocurrencies. Artificial intelligence. Private credit regulation. Treasury market structure.

Client expense: $1,100,000 · Firm income: Not reported

Retirement Security, Q4 2025 1.H.R.1013, S.424 Retirement Fairness for Charities and Educational Institutions Act of 2025: Allows 403(b) retirement plans to invest in Collective Investment Trust or Separate Accounts Insurance Products to establish investment parity with other defined contribution plans, like 401(k)s. 2.H.R.2023, S.988 Womens Retirement Protection Act (WRPA): This legislation imposes spousal consent requirements on nearly all distributions from defined contribution plans. The bill also seeks to enhance financial literacy through grants to community-based organizations and offers grants to such organizations to help low-income women and survivors of domestic abuse obtain qualified domestic relations orders. 3.H.R.2067, S.928 Protecting Americans Retirement Savings Act (PARSA): This bill prohibits ERISA-covered retirement plans from making new investments in companies controlled by or based in countries considered to be foreign adversaries. Foreign adversaries include China, Iran, North Korea, and Russia. The bill also requires fiduciaries to disclose continuing investments in such entities and sanctioned firms. 4.H.R.2089 Generating Retirement Ownership through Long-Term Holding (GROWTH): The legislation provides that reinvested mutual fund dividends are not subject to capital gains taxation until the investor sells his or her shares. 5.H.R.2163 No Penalties for Victims of Fraud Act: The bill ensures that victims of retirement account fraud are not subject to the 10% additional income tax on early retirement plan distributions. 6.H.R.2544, S.1222 Financial Freedom Act of 2025: The legislation prohibits the Secretary of Labor from restricting the investments available in self-directed 401(k) brokerage windows. The bill also prohibits the DOL from preventing a fiduciary from selecting, any particular type of investment alternative, provided that a fiduciary provides the participant or beneficiary an opportunity to choose, from a broad range of investment alternatives, nor can the DOL require that any particular type of investment be either favored or disfavored, other than on the basis of the investments risk-return characteristics. 7.H.R.2696, S.1526 Retirement Savings for Americans Act (RSAA): This legislation establishes a federally run American Worker Retirement Plan for private-sector workers that do not have access to a workplace-based retirement plan. The bill also includes an enhanced federal matching contribution that only applies to lower income workers that participate in the federal plan. 8.H.R.2748 First Time Homeowner Savings Plan Act: This legislation increases the amount first-time homebuyers could pull from their retirement savings from the $10,000 set in the 1990s to $25,000 (indexed to inflation) without the 10% additional income tax on early retirement plan distributions to use as a down payment on their home. 9.H.R.2869 EBSA Investigations Transparency Act: This legislation requires the Department of Labors Employee Benefits Security Administration (EBSA) to submit annual reports to Congress on the status of its open employee plan audits and to explain why any audits open for more than 36 months have not been closed. 10.H.R.2958 Balance the Scales Act: This legislation requires the Department of Labors Employee Benefits Security Administration (EBSA) to report annually to Congress about its use of common interest agreements. 11.H.R.2988 Protecting Prudent Investment of Retirement Savings Act: This legislation amends ERISA to specify that a retirement plan fiduciary shall be considered acting solely in the interest of participants only if: 1) the investment does not subordinate the interest of participants in their retirement income or financial benefits under the plan to other objectives, including ESG objectives and 2) the fiduciary does not sacrifice investment returns or take on additional investment risks to promote goals unrelated to the plan. 12.H.R.3526, S.2867 Uplifting First-Time Homebuyers Act of 2025: This legislation allows individuals to take an early distribution out of an IRA of up to $50,000 for a qualified first-time home purchase without the 10% additional income tax penalty. Current rules only allow up to a $10,000 early distribution without penalty. 13.H.R.4718, S.1707 Helping Young Americans Save for Retirement Act: This legislation lowers the required minimum participation age in ERISA-covered retirement plans from age 21 to age 18. 14.S.2003 Strengthening Benefits Plans Act of 2025: This legislation permits surplus assets in a retiree health account to be used for other benefits, like active employee health benefits. The legislation also permits surplus assets in a defined benefit plan to be used to provide contributions to the employers defined contribution plan without terminating the defined benefit plan. 15.S.2210 Unlocking Benefits for Independent Workers Act: This legislation establishes a safe harbor under federal law for companies that would like to voluntarily provide independent workers with any benefit or protection commonly provided to full-time employees, such as retirement and health care benefits. 16.S.2217 Independent Retirement Fairness Act: This legislation relaxes the audit rules for pooled employer plans (PEPs) and allows companies to enroll their independent workers in PEPs and simplified employer pensions (SEPs) IRAs without triggering employee classification. 17.H.R.4548, S.2365 Small Nonprofit Retirement Security Act of 2025: This legislation makes the credit for small employer pension plan startup costs and the retirement auto-enrollment credit available to tax-exempt eligible small employers. 18.H.R.5325 Unclaimed Retirement Rescue Plan: This legislation directs the Department of Labor (DOL) to issue a regulation that would permit retirement plan fiduciaries to transfer unclaimed retirement distributions to State unclaimed property programs. 19.H.R.5748 Retirement Investment Choice Act: This legislation codifies Executive Order 14330 relating to democratizing access to alternative assets for 401(k) investors. 20.S.3083 Providing Complete Information to Retirement Investors Act: This legislation adds a new notice requirement to participants investing through brokerage windows in 401(k) plans to explain that the investments in a brokerage window have not been prudently selected and are not monitored by a plan fiduciary. 21.S.3086 Restoring Integrity in Fiduciary Duty Act: This legislation limits fiduciary consideration of nonpecuniary factors for investments. The bill further states that ERISA fiduciaries must also make decisions regarding the exercise of shareholder rights and proxy voting based on pecuniary factors. 22.H.R.5887 Saving for the Future Act: This legislation establishes a hybrid emergency savings and 401(k)-type government-run program called the Federal Universal Personal Savings Investment Program and creates UP Retirement Accounts for every full-time and part-time worker not covered by an active defined benefit pension plan. The legislation also requires employers to make a minimum employer contribution to the workers retirement account. 23.H.R.6084 ERISA Litigation Reform Act: This legislation amends the pleading standard under ERISA Section 502 for certain claims to put the burden on the plaintiff to plausibly allege and prove that an ERISA prohibitive transaction occurred that is not exempt under ERISA section 408(b)(2). 24.H.R.6324 Retirement Simplification and Clarity Act: This legislation would: (1) permit an in-service plan distribution to an individual retirement annuity on or after attainment of age 50; and (2) include a specific reference to an individual retirement annuity as a rollover option under a simplified 402(f) safe harbor notice. 25.H.R.6417, S.3333 Emergency Savings Enhancement Act of 2025: This legislation would double the maximum balance limit for Pension-Linked Emergency Savings Accounts (PLESAs) from $2,500 to $5,000 and allows Highly Compensated Employees (HCEs) to participate. 26.H.R.6450, S.3352 Retirement Rollover Flexibility Act: This legislation would permit rollover contributions from Roth IRAs to designated Roth accounts in qualified retirement plans, like 401(k)s. 27.H.R.6722 Automatic IRA Act of 2025: The legislation would require employers with more than 10 employees that do not sponsor a retirement plan to automatically enroll their employees in IRAs (automatic IRAs) or other automatic contribution plans or arrangements, like 401(k) plans. The legislation also requires 401(k) plans with over 100 participants plans must permit participants to elect to receive at least 50 percent of their vested account balance in the form of lifetime income. This requirement does not apply to participants with balances below $200,000. 28.H.R.6729, S.1831 Auto Reenroll Act of 2025: This legislation amends the qualified automatic contribution arrangement (QACA) safe harbor in the tax code for 401(k) plans to allow for automatic periodic reenrollment into the plan. 29.H.R.7185 Home Savings Act: This legislation permits penalty-free withdrawals from a 401(k) account for up to five years when the funds are used for a down payment or closing costs on a primary residence. The legislation also allows an individual to make a penalty-free 401(k) withdrawal and gift those funds to a relative, exempt from gift tax, provided the relative uses the money for a down payment or closing costs on a primary residence. 30.H.R.7362 Form 5500 Filing Simplification Act: This legislation extends the Form 5500 filing deadline to October 15 (for calendar year retirement plans), thus eliminating the need for an extension. 31.H.R.7556, S.2335 Pensions for All Act: This legislation requires every employer to provide to their employees a retirement program with benefits equivalent to the Federal Employees Retirement System (FERS) or to elect for their employees to participate in FERS. 32.H.R.8273, S.4291 Catching Up Family Caregivers Act of 2026: This legislation allows full-time family caregivers to qualify for up to five additional years of retirement plan catch-up contributions. Catch-up contributions currently allow individuals over age 50 to contribute above the standard annual retirement plan contribution limit, with even higher limits available for those ages 60 to 63. 33.H.R.8274, S.4292 Improving Retirement for Family Caregivers Act of 2026: Current law limits Roth IRA contributions to the lesser of $7,000 or total annual income. This legislation eliminates the annual income requirement for family caregivers, thus allowing them to contribute to a Roth IRA even if they do not have any income. 34.H.R.8313 Trump Accounts for All Generations Act: The One Big Beautiful Bill Act (OBBBA) enacted last year created the Trump Account, which is a new individual tax-preferred savings vehicle for children, with a $1,000 government seed contribution for every child born in the United States from 2025 to 2029. This legislation makes the $1,000 government contribution for children permanent and indexes the $1,000 contribution amount to inflation beginning in 2029. 35.H.R.8314 OPTIONS Act: The legislation allows employees to allocate employer contributions among various pre-tax benefits, including retirement accounts, health savings accounts, health reimbursement accounts, and educational assistance programs. 36.S.4360 Investigation Status and Governance for Honest Transparency (INSIGHT) Act: This legislation requires the Employee Benefits Security Administration (EBSA) to submit annual reports to Congress on the status of its open employee plan audits and to explain why any audits open for more than 36 months have not been closed. And it also requires the Department of Labor to formalize and disclose situations in which it is providing adverse assistance which means assistance to plaintiffs lawyers suing ERISA benefit plan sponsors and fiduciaries. 37.H.R.8783, S.4511 Charity Parity Act: Current law allows retirement savers to exclude up to $111,000 in annual gross income to make qualified charitable distributions (QCDs), but only if the funds are donated directly from an IRA. This tax break excludes distributions from employer-sponsored retirement plans like 401(k)s and 403(b)s. So, under current law, individuals must first roll assets into an IRA to make a QCD. The Charity Parity Act would permit direct QCDs from employer-sponsored retirement plans. 38.H.R.8837, S.1840 Retirement Investment in Small Employers (RISE) Act: This legislation raises the floor for the existing $250 per-employee tax credit available to small businesses to create retirement plans, ensuring that all small businesses can receive a tax credit of at least $2,500. The House version of the legislation allows the service provider to claim the tax credit as payment for services that would ordinarily be charged to the employer for starting the plan. 39.General Accounts Product Corrections Act: This proposed legislation clarifies fiduciary responsibilities for life insurance companies as it relates to investments in their general accounts. Income Security S. 2415 and H.R. 7107, the Long-Term Care Affordability Act: Would allow for tax free distributions from retirement accounts to fund LTC contracts. H.R. 133, Both provisions are in the larger bill. H.R.1185 - FAMILY Act. Issue: paid family and medical leave proposal would offer paid leave benefits via a payroll tax for birth or adoption of a child or caring for a sick family member. H.R.1940 - New Parents Act of 2019. Issue: paid family and medical leave H.R.2163 - To amend the Internal Revenue Code of 1986 to allow for tax-advantaged distributions from health savings accounts during family or medical leave, and for other purposes. Issue: paid family and medical leave S.463 - FAMILY Act. Issue: paid family and medical leave- paid family and medical leave proposal would offer paid leave benefits via a payroll tax for birth or adoption of a child or caring for a sick family member S.920 - New Parents Act of 2019. Issue: paid family and medical leave Discussion draft - CRADLE Act. Issue: paid family and medical leave - allows for a deferment of retirement benefits for paid leave benefits. Proposed FY 2020 Budget proposal on paid family and medical leave. Issue: paid family and medical leave H.R. 2694 - Pregnant Workers Fairness Act. Issue: paid family and medical leave. Concurrent Resolution on the Budget, FY2022, S.Con.Res.14. The budget resolution calls for the $3.5 trillion in long-term investments to be fully offset by a combination of new tax revenues, health care savings, and long-term economic growth. In addition, the agreement would prohibit new taxes on families making less than $400,000 per year, and on small businesses and family farms. Issue: Medicare/Dental (Expanding Medicare to include dental, vision, hearing benefits and lowering the eligibility age). H.R. 5376- Build Back Better Act This bill provides funding, establishes programs, and otherwise modifies provisions relating to a broad array of areas, including education, labor, child-care, health care, taxes, immigration, and the environment. Excepted Benefits on Supplemental Benefits-proposed tri-agency rule through HHS, Treasury and Labor. S.3680 - Paid Family and Medical Leave Tax Credit Extension and Enhancement Act Diversity and Inclusion H.R. 5084 - Improving Corporate Governance Through Diversity Act. Issue: diversity and inclusion. H.R. 5360 - Closing the Racial Wealth Gap Act. Issue: diversity and inclusion. H.R. 281 - Ensuring Diverse Leadership Act. Issue: diversity and inclusion. H.R. 7946 and S. 4464 - Federal Reserve Racial and Economic Equity Act. Issue: diversity and inclusion.

Retirement Security, Q4 2025 1.H.R.1013, S.424 Retirement Fairness for Charities and Educational Institutions Act of 2025: Allows 403(b) retirement plans to invest in Collective Investment Trust or Separate Accounts Insurance Products to establish investment parity with other defined contribution plans, like 401(k)s. 2.H.R.2023, S.988 Womens Retirement Protection Act (WRPA): This legislation imposes spousal consent requirements on nearly all distributions from defined contribution plans. The bill also seeks to enhance financial literacy through grants to community-based organizations and offers grants to such organizations to help low-income women and survivors of domestic abuse obtain qualified domestic relations orders. 3.H.R.2067, S.928 Protecting Americans Retirement Savings Act (PARSA): This bill prohibits ERISA-covered retirement plans from making new investments in companies controlled by or based in countries considered to be foreign adversaries. Foreign adversaries include China, Iran, North Korea, and Russia. The bill also requires fiduciaries to disclose continuing investments in such entities and sanctioned firms. 4.H.R.2089 Generating Retirement Ownership through Long-Term Holding (GROWTH): The legislation provides that reinvested mutual fund dividends are not subject to capital gains taxation until the investor sells his or her shares. 5.H.R.2163 No Penalties for Victims of Fraud Act: The bill ensures that victims of retirement account fraud are not subject to the 10% additional income tax on early retirement plan distributions. 6.H.R.2544, S.1222 Financial Freedom Act of 2025: The legislation prohibits the Secretary of Labor from restricting the investments available in self-directed 401(k) brokerage windows. The bill also prohibits the DOL from preventing a fiduciary from selecting, any particular type of investment alternative, provided that a fiduciary provides the participant or beneficiary an opportunity to choose, from a broad range of investment alternatives, nor can the DOL require that any particular type of investment be either favored or disfavored, other than on the basis of the investments risk-return characteristics. 7.H.R.2696, S.1526 Retirement Savings for Americans Act (RSAA): This legislation establishes a federally run American Worker Retirement Plan for private-sector workers that do not have access to a workplace-based retirement plan. The bill also includes an enhanced federal matching contribution that only applies to lower income workers that participate in the federal plan. 8.H.R.2748 First Time Homeowner Savings Plan Act: This legislation increases the amount first-time homebuyers could pull from their retirement savings from the $10,000 set in the 1990s to $25,000 (indexed to inflation) without the 10% additional income tax on early retirement plan distributions to use as a down payment on their home. 9.H.R.2869 EBSA Investigations Transparency Act: This legislation requires the Department of Labors Employee Benefits Security Administration (EBSA) to submit annual reports to Congress on the status of its open employee plan audits and to explain why any audits open for more than 36 months have not been closed. 10.H.R.2958 Balance the Scales Act: This legislation requires the Department of Labors Employee Benefits Security Administration (EBSA) to report annually to Congress about its use of common interest agreements. 11.H.R.2988 Protecting Prudent Investment of Retirement Savings Act: This legislation amends ERISA to specify that a retirement plan fiduciary shall be considered acting solely in the interest of participants only if: 1) the investment does not subordinate the interest of participants in their retirement income or financial benefits under the plan to other objectives, including ESG objectives and 2) the fiduciary does not sacrifice investment returns or take on additional investment risks to promote goals unrelated to the plan. 12.H.R.3526, S.2867 Uplifting First-Time Homebuyers Act of 2025: This legislation allows individuals to take an early distribution out of an IRA of up to $50,000 for a qualified first-time home purchase without the 10% additional income tax penalty. Current rules only allow up to a $10,000 early distribution without penalty. 13.H.R.4718, S.1707 Helping Young Americans Save for Retirement Act: This legislation lowers the required minimum participation age in ERISA-covered retirement plans from age 21 to age 18. 14.S.2003 Strengthening Benefits Plans Act of 2025: This legislation permits surplus assets in a retiree health account to be used for other benefits, like active employee health benefits. The legislation also permits surplus assets in a defined benefit plan to be used to provide contributions to the employers defined contribution plan without terminating the defined benefit plan. 15.S.2210 Unlocking Benefits for Independent Workers Act: This legislation establishes a safe harbor under federal law for companies that would like to voluntarily provide independent workers with any benefit or protection commonly provided to full-time employees, such as retirement and health care benefits. 16.S.2217 Independent Retirement Fairness Act: This legislation relaxes the audit rules for pooled employer plans (PEPs) and allows companies to enroll their independent workers in PEPs and simplified employer pensions (SEPs) IRAs without triggering employee classification. 17.H.R.4548, S.2365 Small Nonprofit Retirement Security Act of 2025: This legislation makes the credit for small employer pension plan startup costs and the retirement auto-enrollment credit available to tax-exempt eligible small employers. 18.H.R.5325 Unclaimed Retirement Rescue Plan: This legislation directs the Department of Labor (DOL) to issue a regulation that would permit retirement plan fiduciaries to transfer unclaimed retirement distributions to State unclaimed property programs. 19.H.R.5748 Retirement Investment Choice Act: This legislation codifies Executive Order 14330 relating to democratizing access to alternative assets for 401(k) investors. 20.S.3083 Providing Complete Information to Retirement Investors Act: This legislation adds a new notice requirement to participants investing through brokerage windows in 401(k) plans to explain that the investments in a brokerage window have not been prudently selected and are not monitored by a plan fiduciary. 21.S.3086 Restoring Integrity in Fiduciary Duty Act: This legislation limits fiduciary consideration of nonpecuniary factors for investments. The bill further states that ERISA fiduciaries must also make decisions regarding the exercise of shareholder rights and proxy voting based on pecuniary factors. 22.H.R.5887 Saving for the Future Act: This legislation establishes a hybrid emergency savings and 401(k)-type government-run program called the Federal Universal Personal Savings Investment Program and creates UP Retirement Accounts for every full-time and part-time worker not covered by an active defined benefit pension plan. The legislation also requires employers to make a minimum employer contribution to the workers retirement account. 23.H.R.6084 ERISA Litigation Reform Act: This legislation amends the pleading standard under ERISA Section 502 for certain claims to put the burden on the plaintiff to plausibly allege and prove that an ERISA prohibitive transaction occurred that is not exempt under ERISA section 408(b)(2). 24.H.R.6324 Retirement Simplification and Clarity Act: This legislation would: (1) permit an in-service plan distribution to an individual retirement annuity on or after attainment of age 50; and (2) include a specific reference to an individual retirement annuity as a rollover option under a simplified 402(f) safe harbor notice. 25.H.R.6417, S.3333 Emergency Savings Enhancement Act of 2025: This legislation would double the maximum balance limit for Pension-Linked Emergency Savings Accounts (PLESAs) from $2,500 to $5,000 and allows Highly Compensated Employees (HCEs) to participate. 26.H.R.6450, S.3352 Retirement Rollover Flexibility Act: This legislation would permit rollover contributions from Roth IRAs to designated Roth accounts in qualified retirement plans, like 401(k)s. 27.H.R.6722 Automatic IRA Act of 2025: The legislation would require employers with more than 10 employees that do not sponsor a retirement plan to automatically enroll their employees in IRAs (automatic IRAs) or other automatic contribution plans or arrangements, like 401(k) plans. The legislation also requires 401(k) plans with over 100 participants plans must permit participants to elect to receive at least 50 percent of their vested account balance in the form of lifetime income. This requirement does not apply to participants with balances below $200,000. 28.H.R.6729, S.1831 Auto Reenroll Act of 2025: This legislation amends the qualified automatic contribution arrangement (QACA) safe harbor in the tax code for 401(k) plans to allow for automatic periodic reenrollment into the plan. 29.H.R.7185 Home Savings Act: This legislation permits penalty-free withdrawals from a 401(k) account for up to five years when the funds are used for a down payment or closing costs on a primary residence. The legislation also allows an individual to make a penalty-free 401(k) withdrawal and gift those funds to a relative, exempt from gift tax, provided the relative uses the money for a down payment or closing costs on a primary residence. 30.H.R.7362 Form 5500 Filing Simplification Act: This legislation extends the Form 5500 filing deadline to October 15 (for calendar year retirement plans), thus eliminating the need for an extension. 31.H.R.7556, S.2335 Pensions for All Act: This legislation requires every employer to provide to their employees a retirement program with benefits equivalent to the Federal Employees Retirement System (FERS) or to elect for their employees to participate in FERS. 32.H.R.8273, S.4291 Catching Up Family Caregivers Act of 2026: This legislation allows full-time family caregivers to qualify for up to five additional years of retirement plan catch-up contributions. Catch-up contributions currently allow individuals over age 50 to contribute above the standard annual retirement plan contribution limit, with even higher limits available for those ages 60 to 63. 33.H.R.8274, S.4292 Improving Retirement for Family Caregivers Act of 2026: Current law limits Roth IRA contributions to the lesser of $7,000 or total annual income. This legislation eliminates the annual income requirement for family caregivers, thus allowing them to contribute to a Roth IRA even if they do not have any income. 34.H.R.8313 Trump Accounts for All Generations Act: The One Big Beautiful Bill Act (OBBBA) enacted last year created the Trump Account, which is a new individual tax-preferred savings vehicle for children, with a $1,000 government seed contribution for every child born in the United States from 2025 to 2029. This legislation makes the $1,000 government contribution for children permanent and indexes the $1,000 contribution amount to inflation beginning in 2029. 35.H.R.8314 OPTIONS Act: The legislation allows employees to allocate employer contributions among various pre-tax benefits, including retirement accounts, health savings accounts, health reimbursement accounts, and educational assistance programs. 36.S.4360 Investigation Status and Governance for Honest Transparency (INSIGHT) Act: This legislation requires the Employee Benefits Security Administration (EBSA) to submit annual reports to Congress on the status of its open employee plan audits and to explain why any audits open for more than 36 months have not been closed. And it also requires the Department of Labor to formalize and disclose situations in which it is providing adverse assistance which means assistance to plaintiffs lawyers suing ERISA benefit plan sponsors and fiduciaries. 37.H.R.8783, S.4511 Charity Parity Act: Current law allows retirement savers to exclude up to $111,000 in annual gross income to make qualified charitable distributions (QCDs), but only if the funds are donated directly from an IRA. This tax break excludes distributions from employer-sponsored retirement plans like 401(k)s and 403(b)s. So, under current law, individuals must first roll assets into an IRA to make a QCD. The Charity Parity Act would permit direct QCDs from employer-sponsored retirement plans. 38.H.R.8837, S.1840 Retirement Investment in Small Employers (RISE) Act: This legislation raises the floor for the existing $250 per-employee tax credit available to small businesses to create retirement plans, ensuring that all small businesses can receive a tax credit of at least $2,500. The House version of the legislation allows the service provider to claim the tax credit as payment for services that would ordinarily be charged to the employer for starting the plan. 39.General Accounts Product Corrections Act: This proposed legislation clarifies fiduciary responsibilities for life insurance companies as it relates to investments in their general accounts. Income Security S. 2415 and H.R. 7107, the Long-Term Care Affordability Act: Would allow for tax free distributions from retirement accounts to fund LTC contracts. H.R. 133, Both provisions are in the larger bill. H.R.1185 - FAMILY Act. Issue: paid family and medical leave proposal would offer paid leave benefits via a payroll tax for birth or adoption of a child or caring for a sick family member. H.R.1940 - New Parents Act of 2019. Issue: paid family and medical leave H.R.2163 - To amend the Internal Revenue Code of 1986 to allow for tax-advantaged distributions from health savings accounts during family or medical leave, and for other purposes. Issue: paid family and medical leave S.463 - FAMILY Act. Issue: paid family and medical leave- paid family and medical leave proposal would offer paid leave benefits via a payroll tax for birth or adoption of a child or caring for a sick family member S.920 - New Parents Act of 2019. Issue: paid family and medical leave Discussion draft - CRADLE Act. Issue: paid family and medical leave - allows for a deferment of retirement benefits for paid leave benefits. Proposed FY 2020 Budget proposal on paid family and medical leave. Issue: paid family and medical leave H.R. 2694 - Pregnant Workers Fairness Act. Issue: paid family and medical leave. Concurrent Resolution on the Budget, FY2022, S.Con.Res.14. The budget resolution calls for the $3.5 trillion in long-term investments to be fully offset by a combination of new tax revenues, health care savings, and long-term economic growth. In addition, the agreement would prohibit new taxes on families making less than $400,000 per year, and on small businesses and family farms. Issue: Medicare/Dental (Expanding Medicare to include dental, vision, hearing benefits and lowering the eligibility age). H.R. 5376- Build Back Better Act This bill provides funding, establishes programs, and otherwise modifies provisions relating to a broad array of areas, including education, labor, child-care, health care, taxes, immigration, and the environment. Excepted Benefits on Supplemental Benefits-proposed tri-agency rule through HHS, Treasury and Labor. S.3680 - Paid Family and Medical Leave Tax Credit Extension and Enhancement Act Diversity and Inclusion H.R. 5084 - Improving Corporate Governance Through Diversity Act. Issue: diversity and inclusion. H.R. 5360 - Closing the Racial Wealth Gap Act. Issue: diversity and inclusion. H.R. 281 - Ensuring Diverse Leadership Act. Issue: diversity and inclusion. H.R. 7946 and S. 4464 - Federal Reserve Racial and Economic Equity Act. Issue: diversity and inclusion.

Issues related to crypto & digital assets including 1) digital assets market structure initiatives such as H.R. 3633, the Digital Asset Market Clarity (CLARITY) Act and Senate companion drafts such as S. 4356, the Responsible Financial Innovation Act (RFIA) and S. 3755, the Digital Commodity Intermediaries Act and 2) Stablecoins legislation clarification including S. 919, Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the GENIUS Act) Issues related to including digital assets in registered investment companies and the taxation of digital assets, including H.R. 9175, the Tax Clarity for Mining and Staking Act Increases in the stock buyback excise tax included in FY27 National Defense Authorization Act (NDAA) - H.R. 8800 and S. 4784 Various reconciliation issues in H.R.1, the One Big Beautiful Bill Act, including section 899 and implementation of Trump accounts Treasury meetings about Trump accounts. Protecting closed-end funds from activist investors and enhancing retail investor access to alternative investments & private markets - H.R. 3383, the Increasing Investor Opportunities Act Capital formation initiatives included in H.R. 3383, the Incentivizing New Ventures and Economic Strength Through Capital Formation (INVEST) Act (note same bill number as the CEF bill - two bills combined) and possible Senate companion legislation, the Empowering Main Street in America Act (EMSAA) Promoting inclusion of alternative investments in retirement plans, including H.R. 2544 & S. 1222, the Financial Freedom Act and H.R. 5748, the Retirement Investment Choice Act which codifies President Trumps executive order (14330) on alternative investments in 401(k)s Accredited investor reform initiatives including H.R. 3348, the Accredited Investor Definition Review Act, H.R. 3339, the Equal Opportunity for All Investors Act, and H.R. 3394, the Fair Investment Opportunities for Professional Experts Act Clarifications about restrictions on outbound investments to China included in the National Defense Authorization Act (NDAA) S. 1071 including the COINS Act, the Comprehensive Outbound Investment National Security Act of 2025 Business Development Company issues including H.R. 2225 & S. 1808 - the Access to Small Business Investor Capital Act E-delivery initiatives including H.R. 2441 & S 1877, the Improving Disclosure for Investors Act Retirement security initiatives, including S. 424 and H.R. 1013, the Retirement Fairness for Charities and Educational Institutions Retirement savings initiatives including promoting tax deferral for individuals participating in voluntary, employer provided retirement plans and IRAs and H.R. 2696 and S. 1526, the Retirement Savings for Americans Act (RSAA) that would create a federal retirement system ERISA litigation reform efforts such as H. R. 6084, the ERISA Litigation Reform Act Congressional oversight of ESG investing including proxy voting by asset managers and various legislative initiatives H.R. 3682 and S. 3578, the FSOC Improvement Act which reforms the Financial Stability Oversight Councils non-bank Systematically Important Financial Institution (SIFI) designation process.

Issues regarding retirement, tax, and financial services. Promoting inclusion of alternative investments in retirement plans, including H.R. 2544 & S. 1222, the Financial Freedom Act, and H.R. 5748, the Retirement Investment Choice Act. Accredited investor reform initiatives, including H.R. 3348, the Accredited Investor Definition Review Act, H.R. 3339, the Equal Opportunity for All Investors Act, and H.R. 3394, the Fair Investment Opportunities for Professional Experts Act.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

- Issues related to capital formation - Issues related to SEC and SRO reform, SRO constitutionality concerns - H.R. 3395, Middle Market IPO Cost Act - Issues related to investor fraud and foreign state-sponsored scams targeting US citizens - S.1053/H.R. 2246, the Foreign Investment Guardrails to Help Thwart China Act - Issues related to inbound and outbound investments to/from China - S.1877, H.R.2441, Improving Disclosure for Investors Act of 2025 - H.R. 3959, legislation codifying SEC Rule 15c2-11 - Issues relating to proxy advisors - Issues related to shareholder proposals - Issues related to SEC recordkeeping rules - Issues related to registered investment advisor regulations - Issues related to Sarbanes Oxley - Issues related to arbitration - H.R. 5748 and issues relating to Executive Order 14330, expansion opportunities for retirement plans - H.R. 3383, Incentivizing New Ventures and Economic Strength Through Capital Formation Act of 2025, and related Senate legislation - S.3935, Municipal Securities Rulemaking Board Reform Act of 2026 and related House legislation - Issues relating to the funding model and privacy concerns of the Consolidated Audit Trail (CAT) - H.R.8338, SAFER Act of 2026 - H.R.8800, National Defense Authorization Act for Fiscal Year 2027 - H.R.8286, Protecting Americans' Retirement Savings From Politics Act - Issues relating to artificial intelligence in financial services

Client expense: $90,000 · Firm income: Not reported

Retirement Security, Q4 2025 1.H.R.1013, S.424 Retirement Fairness for Charities and Educational Institutions Act of 2025: Allows 403(b) retirement plans to invest in Collective Investment Trust or Separate Accounts Insurance Products to establish investment parity with other defined contribution plans, like 401(k)s. 2.H.R.2023, S.988 Womens Retirement Protection Act (WRPA): This legislation imposes spousal consent requirements on nearly all distributions from defined contribution plans. The bill also seeks to enhance financial literacy through grants to community-based organizations and offers grants to such organizations to help low-income women and survivors of domestic abuse obtain qualified domestic relations orders. 3.H.R.2067, S.928 Protecting Americans Retirement Savings Act (PARSA): This bill prohibits ERISA-covered retirement plans from making new investments in companies controlled by or based in countries considered to be foreign adversaries. Foreign adversaries include China, Iran, North Korea, and Russia. The bill also requires fiduciaries to disclose continuing investments in such entities and sanctioned firms. 4.H.R.2089 Generating Retirement Ownership through Long-Term Holding (GROWTH): The legislation provides that reinvested mutual fund dividends are not subject to capital gains taxation until the investor sells his or her shares. 5.H.R.2163 No Penalties for Victims of Fraud Act: The bill ensures that victims of retirement account fraud are not subject to the 10% additional income tax on early retirement plan distributions. 6.H.R.2544, S.1222 Financial Freedom Act of 2025: The legislation prohibits the Secretary of Labor from restricting the investments available in self-directed 401(k) brokerage windows. The bill also prohibits the DOL from preventing a fiduciary from selecting, any particular type of investment alternative, provided that a fiduciary provides the participant or beneficiary an opportunity to choose, from a broad range of investment alternatives, nor can the DOL require that any particular type of investment be either favored or disfavored, other than on the basis of the investments risk-return characteristics. 7.H.R.2696, S.1526 Retirement Savings for Americans Act (RSAA): This legislation establishes a federally run American Worker Retirement Plan for private-sector workers that do not have access to a workplace-based retirement plan. The bill also includes an enhanced federal matching contribution that only applies to lower income workers that participate in the federal plan. 8.H.R.2748 First Time Homeowner Savings Plan Act: This legislation increases the amount first-time homebuyers could pull from their retirement savings from the $10,000 set in the 1990s to $25,000 (indexed to inflation) without the 10% additional income tax on early retirement plan distributions to use as a down payment on their home. 9.H.R.2869 EBSA Investigations Transparency Act: This legislation requires the Department of Labors Employee Benefits Security Administration (EBSA) to submit annual reports to Congress on the status of its open employee plan audits and to explain why any audits open for more than 36 months have not been closed. 10.H.R.2958 Balance the Scales Act: This legislation requires the Department of Labors Employee Benefits Security Administration (EBSA) to report annually to Congress about its use of common interest agreements. 11.H.R.2988 Protecting Prudent Investment of Retirement Savings Act: This legislation amends ERISA to specify that a retirement plan fiduciary shall be considered acting solely in the interest of participants only if: 1) the investment does not subordinate the interest of participants in their retirement income or financial benefits under the plan to other objectives, including ESG objectives and 2) the fiduciary does not sacrifice investment returns or take on additional investment risks to promote goals unrelated to the plan. 12.H.R.3526, S.2867 Uplifting First-Time Homebuyers Act of 2025: This legislation allows individuals to take an early distribution out of an IRA of up to $50,000 for a qualified first-time home purchase without the 10% additional income tax penalty. Current rules only allow up to a $10,000 early distribution without penalty. 13.H.R.4718, S.1707 Helping Young Americans Save for Retirement Act: This legislation lowers the required minimum participation age in ERISA-covered retirement plans from age 21 to age 18. 14.S.1840 Retirement Investment in Small Employers (RISE) Act: This legislation raises the floor for the existing $250 per-employee tax credit available to small businesses to create retirement plans, ensuring that all small businesses can receive a tax credit of at least $2,500. 15.S.2003 Strengthening Benefits Plans Act of 2025: This legislation permits surplus assets in a retiree health account to be used for other benefits, like active employee health benefits. The legislation also permits surplus assets in a defined benefit plan to be used to provide contributions to the employers defined contribution plan without terminating the defined benefit plan. 16.S.2210 Unlocking Benefits for Independent Workers Act: This legislation establishes a safe harbor under federal law for companies that would like to voluntarily provide independent workers with any benefit or protection commonly provided to full-time employees, such as retirement and health care benefits. 17.S.2217 Independent Retirement Fairness Act: This legislation relaxes the audit rules for pooled employer plans (PEPs) and allows companies to enroll their independent workers in PEPs and simplified employer pensions (SEPs) IRAs without triggering employee classification. 18.H.R.4548, S.2365 Small Nonprofit Retirement Security Act of 2025: This legislation makes the credit for small employer pension plan startup costs and the retirement auto-enrollment credit available to tax-exempt eligible small employers. 19.H.R.5325 Unclaimed Retirement Rescue Plan: This legislation directs the Department of Labor (DOL) to issue a regulation that would permit retirement plan fiduciaries to transfer unclaimed retirement distributions to State unclaimed property programs. 20.H.R.5748 Retirement Investment Choice Act: This legislation codifies Executive Order 14330 relating to democratizing access to alternative assets for 401(k) investors. 21.S.3083 Providing Complete Information to Retirement Investors Act: This legislation adds a new notice requirement to participants investing through brokerage windows in 401(k) plans to explain that the investments in a brokerage window have not been prudently selected and are not monitored by a plan fiduciary. 22.S.3086 Restoring Integrity in Fiduciary Duty Act: This legislation limits fiduciary consideration of nonpecuniary factors for investments. The bill further states that ERISA fiduciaries must also make decisions regarding the exercise of shareholder rights and proxy voting based on pecuniary factors. 23.H.R.5887 Saving for the Future Act: This legislation establishes a hybrid emergency savings and 401(k)-type government-run program called the Federal Universal Personal Savings Investment Program and creates UP Retirement Accounts for every full-time and part-time worker not covered by an active defined benefit pension plan. The legislation also requires employers to make a minimum employer contribution to the workers retirement account. 24.H.R.6084 ERISA Litigation Reform Act: This legislation amends the pleading standard under ERISA Section 502 for certain claims to put the burden on the plaintiff to plausibly allege and prove that an ERISA prohibitive transaction occurred that is not exempt under ERISA section 408(b)(2). 25.H.R.6324 Retirement Simplification and Clarity Act: This legislation would: (1) permit an in-service plan distribution to an individual retirement annuity on or after attainment of age 50; and (2) include a specific reference to an individual retirement annuity as a rollover option under a simplified 402(f) safe harbor notice. 26.H.R.6417, S.3333 Emergency Savings Enhancement Act of 2025: This legislation would double the maximum balance limit for Pension-Linked Emergency Savings Accounts (PLESAs) from $2,500 to $5,000 and allows Highly Compensated Employees (HCEs) to participate. 27.H.R.6450, S.3352 Retirement Rollover Flexibility Act: This legislation would permit rollover contributions from Roth IRAs to designated Roth accounts in qualified retirement plans, like 401(k)s. 28.H.R.6722 Automatic IRA Act of 2025: The legislation would require employers with more than 10 employees that do not sponsor a retirement plan to automatically enroll their employees in IRAs (automatic IRAs) or other automatic contribution plans or arrangements, like 401(k) plans. The legislation also requires 401(k) plans with over 100 participants plans must permit participants to elect to receive at least 50 percent of their vested account balance in the form of lifetime income. This requirement does not apply to participants with balances below $200,000. 29.H.R.6729, S.1831 Auto Reenroll Act of 2025: This legislation amends the qualified automatic contribution arrangement (QACA) safe harbor in the tax code for 401(k) plans to allow for automatic periodic reenrollment into the plan. 30.H.R.7185 Home Savings Act: This legislation permits penalty-free withdrawals from a 401(k) account for up to five years when the funds are used for a down payment or closing costs on a primary residence. The legislation also allows an individual to make a penalty-free 401(k) withdrawal and gift those funds to a relative, exempt from gift tax, provided the relative uses the money for a down payment or closing costs on a primary residence. 31.H.R.7362 Form 5500 Filing Simplification Act: This legislation extends the Form 5500 filing deadline to October 15 (for calendar year retirement plans), thus eliminating the need for an extension. 32.H.R.7556, S.2335 Pensions for All Act: This legislation requires every employer to provide to their employees a retirement program with benefits equivalent to the Federal Employees Retirement System (FERS) or to elect for their employees to participate in FERS. 33.General Accounts Product Corrections Act: This proposed legislation clarifies fiduciary responsibilities for life insurance companies as it relates to investments in their general accounts. Income Security S. 2415 and H.R. 7107, the Long-Term Care Affordability Act: Would allow for tax free distributions from retirement accounts to fund LTC contracts. H.R. 133, Both provisions are in the larger bill. H.R.1185 - FAMILY Act. Issue: paid family and medical leave proposal would offer paid leave benefits via a payroll tax for birth or adoption of a child or caring for a sick family member. H.R.1940 - New Parents Act of 2019. Issue: paid family and medical leave H.R.2163 - To amend the Internal Revenue Code of 1986 to allow for tax-advantaged distributions from health savings accounts during family or medical leave, and for other purposes. Issue: paid family and medical leave S.463 - FAMILY Act. Issue: paid family and medical leave- paid family and medical leave proposal would offer paid leave benefits via a payroll tax for birth or adoption of a child or caring for a sick family member S.920 - New Parents Act of 2019. Issue: paid family and medical leave Discussion draft - CRADLE Act. Issue: paid family and medical leave - allows for a deferment of retirement benefits for paid leave benefits. Proposed FY 2020 Budget proposal on paid family and medical leave. Issue: paid family and medical leave H.R. 2694 - Pregnant Workers Fairness Act. Issue: paid family and medical leave. Concurrent Resolution on the Budget, FY2022, S.Con.Res.14. The budget resolution calls for the $3.5 trillion in long-term investments to be fully offset by a combination of new tax revenues, health care savings, and long-term economic growth. In addition, the agreement would prohibit new taxes on families making less than $400,000 per year, and on small businesses and family farms. Issue: Medicare/Dental (Expanding Medicare to include dental, vision, hearing benefits and lowering the eligibility age). H.R. 5376- Build Back Better Act This bill provides funding, establishes programs, and otherwise modifies provisions relating to a broad array of areas, including education, labor, child-care, health care, taxes, immigration, and the environment. Excepted Benefits on Supplemental Benefits-proposed tri-agency rule through HHS, Treasury and Labor. S.3680 - Paid Family and Medical Leave Tax Credit Extension and Enhancement Act Diversity and Inclusion H.R. 5084 - Improving Corporate Governance Through Diversity Act. Issue: diversity and inclusion. H.R. 5360 - Closing the Racial Wealth Gap Act. Issue: diversity and inclusion. H.R. 281 - Ensuring Diverse Leadership Act. Issue: diversity and inclusion. H.R. 7946 and S. 4464 - Federal Reserve Racial and Economic Equity Act. Issue: diversity and inclusion.

H.R.1013, S.424 Retirement Fairness for Charities and Educational Institutions Act of 2025: Allows 403(b) retirement plans to invest in Collective Investment Trust or Separate Accounts Insurance Products to establish investment parity with other defined contribution plans, like 401(k)s. H.R. 2082-WISH Act-- provide for long-term care insurance benefits H.R.2089 Generating Retirement Ownership through Long-Term Holding (GROWTH): The legislation provides that reinvested mutual fund dividends are not subject to capital gains taxation until the investor sells his or her shares. H.R.2163 No Penalties for Victims of Fraud Act: The bill ensures that victims of retirement account fraud are not subject to the 10% additional income tax on early retirement plan distributions. H.R.2696/ S.1526 - Retirement Savings for Americans Act This legislation establishes a federally run American Worker Retirement Plan for private-sector workers that do not have access to a workplace-based retirement plan. H.R.2748 First Time Homeowner Savings Plan Act: This legislation increases the amount first-time homebuyers could pull from their retirement savings from the $10,000 set in the 1990s to $25,000 (indexed to inflation) without the 10% additional income tax on early retirement plan distributions to use as a down payment on their home. H.R.2869 EBSA Investigations Transparency Act: This legislation requires the Department of Labors Employee Benefits Security Administration (EBSA) to submit annual reports to Congress on the status of its open employee plan audits and to explain why any audits open for more than 36 months have not been closed. H.R. 2988 Protecting Prudent Investment of Retirement Savings Act: This legislation clarifies the criteria for meeting the fiduciary duty of ERISA. H.R.3526, S.2867 Uplifting First-Time Homebuyers Act of 2025: This legislation allows individuals to take an early distribution out of an IRA of up to $50,000 for a qualified first-time home purchase without the 10% additional income tax penalty. Current rules only allow up to a $10,000 early distribution without penalty. H.R. 4718/S.1707 Helping Young Americans Save for Retirement Act: This legislation lowers the required minimum participation age in ERISA-covered retirement plans from age 21 to age 18. H.R.5748 Retirement Investment Choice Act: This legislation codifies Executive Order 14330 relating to democratizing access to alternative assets for 401(k) investors. H.R.6084 ERISA Litigation Reform Act: This legislation amends the pleading standard under ERISA Section 502 for certain claims to put the burden on the plaintiff to plausibly allege and prove that an ERISA prohibitive transaction occurred that is not exempt under ERISA section 408(b)(2). H.R.6324 Retirement Simplification and Clarity Act: This legislation would: (1) permit an in-service plan distribution to an individual retirement annuity on or after attainment of age 50; and (2) include a specific reference to an individual retirement annuity as a rollover option under a simplified 402(f) safe harbor notice. H.R.6450, S.3352 Retirement Rollover Flexibility Act: This legislation would permit rollover contributions from Roth IRAs to designated Roth accounts in qualified retirement plans, like 401(k)s. H.R.6722 Automatic IRA Act of 2025: The legislation would require employers with more than 10 employees that do not sponsor a retirement plan to automatically enroll their employees in IRAs (automatic IRAs) or other automatic contribution plans or arrangements, like 401(k) plans. The legislation also requires 401(k) plans with over 100 participants plans must permit participants to elect to receive at least 50 percent of their vested account balance in the form of lifetime income. This requirement does not apply to participants with balances below $200,000. H.R. 6729/S.1831 Auto Reenroll Act of 2025: This legislation amends the qualified automatic contribution arrangement (QACA) safe harbor in the tax code for 401(k) plans to allow for automatic periodic reenrollment into the plan H.R.7185 Home Savings Act: This legislation permits penalty-free withdrawals from a 401(k) account for up to five years when the funds are used for a down payment or closing costs on a primary residence. The legislation also allows an individual to make a penalty-free 401(k) withdrawal and gift those funds to a relative, exempt from gift tax, provided the relative uses the money for a down payment or closing costs on a primary residence. General Accounts Product Corrections Act: Would clarify fiduciary responsibilities for life insurance companies as it relates to investments in their general accounts.

H.R. 3383, Incentivizing New Ventures and Economic Strength Through Capital Formation Act of 2025 H.R. 3633, Digital Asset Market Clarity Act of 2025 H.R. 3682/S. 3578, Financial Stability Oversight Council Improvement Act of 2025 Financial Services and General Government FY 2027 Appropriations Act, 2026 H.R. 3838, Streamlining Procurement for Effective Execution and Delivery and National Defense Authorization Act for Fiscal Year 2026 H.R. 5748, Retirement Investment Choice Act H.R. 6161, SEC Data Protection Act S. 2296, National Defense Authorization Act for Fiscal Year 2026 Regulation and oversight of investment advisers. Equity market structure issues including electronic and algorithmic trading. Protection for sensitive and proprietary data. Nonbank regulation. AML issues. Financial Stability Oversight Council (FSOC) interpretive guidance regarding authority to require supervision and regulation of certain nonbank financial companies. Retail access to alternatives. Accredited investor definition. Capital formation. Increasing initial public offerings (IPOs). Form PF rule. Beneficial ownership. Investment limitations on foreign assets. Outbound investment review process. Short selling. Digital assets and cryptocurrencies. Artificial intelligence. Securities lending. Private credit regulation. Treasury market structure.

Client expense: $1,630,000 · Firm income: Not reported

Issues related to crypto & digital assets including 1) digital assets market structure initiatives such as H.R. 3633, the Digital Asset Market Clarity (CLARITY) Act and Senate companion drafts such as S. 4356, the Responsible Financial Innovation Act (RFIA) and S. 3755, the Digital Commodity Intermediaries Act and 2) Stablecoins legislation clarification including S. 919, Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the GENIUS Act) Various reconciliation issues in H.R.1, the One Big Beautiful Bill Act, including section 899 and implementation of Trump accounts. Treasury meetings (Feb & March 2026) about Trump accounts. Protecting closed end funds from activist investors and enhancing retail investor access to alternative investments & private markets - H.R. 3383, the Increasing Investor Opportunities Act. Capital formation initiatives included in H.R. 3383, the Incentivizing New Ventures and Economic Strength Through Capital Formation (INVEST) Act. Promoting inclusion of alternative investments in retirement plans, including H.R. 2544 & S. 1222, the Financial Freedom Act and H.R. 5748, the Retirement Investment Choice Act which codifies President Trumps executive order (14330) on alternative investments in 401(k)s. Accredited investor reform initiatives including H.R. 3348, the Accredited Investor Definition Review Act, H.R. 3339, the Equal Opportunity for All Investors Act, and H.R. 3394, the Fair Investment Opportunities for Professional Experts Act. Clarifications about restrictions on outbound investments to China included in the National Defense Authorization Act (NDAA) S. 1071 including the COINS Act, the Comprehensive Outbound Investment National Security Act of 2025 Business Development Company issues including H.R. 2225 - the Access to Small Business Investor Capital Act. E-delivery initiatives including H.R. 2441 & S 1877, the Improving Disclosure for Investors Act. Retirement security initiatives, including S. 424 and H.R. 1013, the Retirement Fairness for Charities and Educational Institutions. Retirement savings initiatives including promoting tax deferral for individuals participating in voluntary, employer provided retirement plans and IRAs and H.R. 2696 and S. 1526, the Retirement Savings for Americans Act (RSAA) that would create a federal retirement system. ERISA litigation reform efforts such as H. R. 6084, the ERISA Litigation Reform Act. Congressional oversight of ESG investing including proxy voting by asset managers and various legislative initiatives. H.R. 3682 and S. 3578, the Financial Stability Oversight Council (FSOC) Improvement Act which reforms the Financial Stability Oversight Councils non- bank Systematically Important Financial Institution (SIFI) designation process. Met with Treasury about FSOC reworking guidance and supporting congressional legislation such as the FSOC Improvement Act.

- Issues related to capital formation - Issues related to SEC and SRO reform, SRO constitutionality concerns - H.R. 3395, Middle Market IPO Cost Act - Issues related to investor fraud and foreign state-sponsored scams targeting US citizens - S.1053/H.R. 2246, the Foreign Investment Guardrails to Help Thwart China Act - Issues related to inbound and outbound investments to/from China - S.1877, H.R.2441, Improving Disclosure for Investors Act of 2025 - H.R. 3959, legislation codifying SEC Rule 15c2-11 - Issues relating to proxy advisors - Issues related to shareholder proposals - Issues related to SEC recordkeeping rules - Issues related to registered investment advisor regulations - Issues related to Sarbanes Oxley - Issues related to arbitration - H.R. 5748 and issues relating to Executive Order 14330, expansion opportunities for retirement plans - H.R. 3383, Incentivizing New Ventures and Economic Strength Through Capital Formation Act of 2025, and related Senate legislation - S.3935, Municipal Securities Rulemaking Board Reform Act of 2026 and related House legislation - Issues relating to the funding model and privacy concerns of the Consolidated Audit Trail (CAT)

Client expense: $90,000 · Firm income: Not reported

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

Issues regarding retirement, tax, and financial services. Promoting inclusion of alternative investments in retirement plans, including H.R. 2544 & S. 1222, the Financial Freedom Act, and H.R. 5748, the Retirement Investment Choice Act. Accredited investor reform initiatives, including H.R. 3348, the Accredited Investor Definition Review Act, H.R. 3339, the Equal Opportunity for All Investors Act, and H.R. 3394, the Fair Investment Opportunities for Professional Experts Act.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1968, Full-Year Continuing Appropriations and Extensions Act, 2025 H.R. 2246/S. 1053, Foreign Investment Guardrails to Help Thwart (FIGHT) China Act of 2025 H.R. 3383, Incentivizing New Ventures and Economic Strength Through Capital Formation Act of 2025 H.R. 3633, Digital Asset Market Clarity Act of 2025 H.R. 3682/S. 3578, Financial Stability Oversight Council Improvement Act of 2025 Financial Services and General Government Appropriations Act, 2026 H.R. 3838, Streamlining Procurement for Effective Execution and Delivery and National Defense Authorization Act for Fiscal Year 2026 H.R. 5748, Retirement Investment Choice Act H.R. 6161, SEC Data Protection Act S. 1582, Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act S. 2296, National Defense Authorization Act for Fiscal Year 2026 Regulation and oversight of investment advisers. Equity market structure issues including electronic and algorithmic trading. Protection for sensitive and proprietary data. Nonbank regulation. AML issues. Financial Stability Oversight Council (FSOC) interpretive guidance regarding authority to require supervision and regulation of certain nonbank financial companies. Retail access to alternatives. Accredited investor definition. Capital formation. Increasing initial public offerings (IPOs). Form PF rule. Beneficial ownership. Investment limitations on foreign assets. Outbound investment review process. Short selling. Digital assets and cryptocurrencies. Artificial intelligence. Securities lending. Private credit regulation. Treasury market structure.

Client expense: $1,270,000 · Firm income: Not reported

Issues related to crypto & digital assets including 1) digital assets market structure initiatives such as H.R. 3633, the Digital Asset Market Clarity (CLARITY) Act and Senate companion drafts such as S. 4356, the Responsible Financial Innovation Act (RFIA) and 2) Stablecoins legislation including S. 919, Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the GENIUS Act) Various reconciliation issues in H.R.1, the One Big Beautiful Bill Act, including section 899 and implementation of Trump accounts Retail investor access to alternative investments & private markets, including H.R. 3383, the Increasing Investor Opportunities Act Promoting inclusion of alternative investments in retirement plans, including H.R. 2544 & S. 1222, the Financial Freedom Act and H.R. 5748, the Retirement Investment Choice Act which codifies President Trumps executive order (14330) on alternative investments in 401(k)s Accredited investor reform initiatives including H.R. 3348, the Accredited Investor Definition Review Act, H.R. 3339, the Equal Opportunity for All Investors Act, and H.R. 3394, the Fair Investment Opportunities for Professional Experts Act Restrictions on outbound investments to China included in the National Defense Authorization Act (NDAA) S. 2296 and H.R. 2246 & S.1053, the Foreign Investment Guardrails to Help Thwart (FIGHT) China Act Business Development Company issues including H.R. 2225 - the Access to Small Business Investor Capital Act E-delivery initiatives including H.R. 2441 & S 1877, the Improving Disclosure for Investors Act Retirement security initiatives, including S. 424 and H.R. 1013, the Retirement Fairness for Charities and Educational Institutions Retirement savings initiatives including promoting tax deferral for individuals participating in voluntary, employer provided retirement plans and IRAs and H.R. 2696 and S. 1526, the Retirement Savings for Americans Act (RSAA) that would create a federal retirement system ERISA litigation reform efforts such as H. R. 6084, the ERISA Litigation Reform Act Congressional oversight of ESG investing including proxy voting by asset managers and various legislative initiatives

- Issues related to capital formation - Issues related to SEC and SRO reform, SRO constitutionality concerns - H.R. 3395, Middle Market IPO Cost Act - Issues related to investor fraud and foreign state-sponsored scams targeting US citizens - S.1053/H.R. 2246, the Foreign Investment Guardrails to Help Thwart China Act - Issues related to inbound and outbound investments to/from China - S.1877, H.R.2441, Improving Disclosure for Investors Act of 2025 - H.R. 3959, legislation codifying SEC Rule 15c2-11 - Issues relating to proxy advisors - Issues related to shareholder proposals - Issues related to SEC recordkeeping rules - Issues related to registered investment advisor regulations - Issues related to Sarbanes Oxley - Issues related to arbitration - H.R. 5748 and issues relating to Executive Order 14330, expansion opportunities for retirement plans - H.R. 3383, Incentivizing New Ventures and Economic Strength Through Capital Formation Act of 2025, and related Senate legislation

Client expense: $80,000 · Firm income: Not reported

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

- Issues related to capital formation - Issues related to SEC and SRO reform, SRO constitutionality concerns - H.R. 3395, Middle Market IPO Cost Act - Issues related to investor fraud and foreign state-sponsored scams targeting US citizens - S.1053/H.R. 2246, the Foreign Investment Guardrails to Help Thwart China Act - Issues related to inbound and outbound investments to/from China - S.1877, H.R.2441, Improving Disclosure for Investors Act of 2025 - H.R. 3959, legislation codifying SEC Rule 15c2-11 - Issues relating to proxy advisors - Issues related to shareholder proposals - Issues related to SEC recordkeeping rules - Issues related to registered investment advisor regulations - Issues related to Sarbanes Oxley - Issues related to arbitration - HR 5748 and Issues relating to Executive Order 14330, expansion opportunities for retirement plans

Client expense: $90,000 · Firm income: Not reported

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