Consumer Identity Protection and Security Act

S. 1326, Notification of Risk to Personal Data Act; S. 1332, Personal Data Privacy and Security Act; S. 1336, Consumer Identity Protection and Security Act; S. 1408, Identity Theft Protection Act; S. 1461, Consumer Identity Protection and Security Act; S. 1566 Bills: S. 3171, United States Direct Investment Act; S. 1004, Enhanced Consumer Protection Against Spyware Act; S. 115, Notification of Risk to Personal Data Act; S. 116, Privacy Act; S. 1216, Financial Privacy Breach Notification Act; Commodity Exchange Act Reauthorization; S. 1789, Personal Data Privacy and Security Act; S. 2169, Financial Data Protection Act; S. 2380, U.S. National Security Protection Act; S. 2856, Financial Services Regulatory Relief Act; S. 29, Social Security Number Misuse Prevention Act; S. 3549, Foreign Investment and National Security Act; S. 467, Terrorism Risk Insurance Extension Act; S. 751, Notification of Risk to Personal Data Act; S. 768, Comprehensive Theft Identity Prevention Act; S. 810, SAFE-ID Act; HR 1069, Notification of Risk to Personal Data Act; HR 1078, Social Security Number Protection Act; HR 1080, Information and Security Protection Act HR 1263, Consumer Privacy Protection Act; HR 1653, SAFE-ID Act; HR 2795, the Patent Act; HR 3140, Consumer Data Security and Notification Act; HR 3374, Consumer Privacy Protection Act; HR 3375, Financial Data Security Act; HR 3505, Financial Services Regulatory Relief Act; HR 3997, Financial Data Security Act; HR 4127, Data Accountability and Trust Act; HR 4127, Financial Data Accountability Act. Congressional Issues: Arbitration of employment disputes; Reduction in and Calculation of Section 31 fees; Basel II Capital Accords; SEC disclosure rules for public offerings; Protection of data and databases from misappropriation; President’s Working Group recommendations on OTC derivatives and financial reporting of risk exposure to hedge funds; Hedge fund issues generally; Expansion of SEC enforcement powers; Mutual fund issues, including late trading, market timing, disclosure of fees and revenue streams, 4:00 PM close on mutual fund redemption orders, soft dollars, and directed brokerage; Treasury Attaché to European Union; Reauthorization of Commodity Exchange Act; Trade-through rule and related market structure issues; Proposed merger of NYSE and Archipelago; Consolidation of NYSE and NASD broker-dealer regulation; Committee on Foreign Investments in the United States; Alleged manipulation of markets by uncovered short-sellers. Executive Branch Actions: SEC Rule 10b-10; Basel II Capital Accord; Investment Banking Holding Companies; SEC Framework for Consolidated Supervised Entities; Clarification of distinctions between definitions of “broker-dealer” and “investment adviser”; Hedge funds, including investment adviser and investment company compliance programs; Electronic Communication Network (ECN) access fees; Potential candidates for senior SEC staff positions; IPO allocation and pricing practices under Regulation M; Supervision of branch offices; Public Company Accounting Oversight Board regulation of audits of non-public broker-dealers and of foreign issuers; Disclosure of after-tax yield on mutual funds; Securities analyst independence and performance; Auditor participation in securities offering due diligence; Proxy solicitation; Revisions to SEC record storage rules; Fixed income price transparency; Use of electronic media to satisfy federal securities law delivery requirements (SEC interpretations); Electronic record retention issues; Independent firm compliance activities; Insurance and annuity compliance activities; SEC “principal trading” relief proposal (Rule 206(3) of the Investment Advisers Act); Best execution and payment for order flow; Privacy requirements of Gramm-Leach-Bliley Act; Proposed interpretations of Rule 15c3-1, including reducing capital charges for certain securities held in broker-dealer inventory; Reform to rules under Section 17(a) of the Investment Company Act and Section 206(3) of the Investment Advisers Act; World Trade Organization and access of U.S. broker-dealers to foreign markets; Proposed revisions to the securities offering process under the Securities Act of 1933; Interpretations of net capital rules; Regulation of derivative products; Broker-dealer retention of e-mail and interpretation of Exchange Act Rule 17a-3; Soft dollar payments among broker-dealers and other market participants; Possible consolidation or restructuring of self-regulatory organizations; Information required to be maintained by fiduciaries such as investment advisers under Rule 17a-3; Modification of restrictions on principal transactions under rule 206(3) of the Advisers Act; Exemption from bonding requirements of Section 412 of ERISA; Agency cross-trading restrictions under ERISA; Broker-dealer advertising practices; Disclosure of 401(k) fees to consumers; Proposals to SEC regarding filing requirements for certain mutual fund advertising and sales literature; Proposals to SEC regarding mutual fund fees; Proposals by the NASD and private-sector bodies to improve trade reporting and transparency in the corporate debt markets; Financial Stability forum of the G-7 nations; Prohibited transaction class exemption application regarding sections 406(a)(I)(A)-(D) and 406(b) of ERISA; Regulatory and compliance issues regarding trading restricted by the U.S. Treasury Department’s Office of Foreign Assets Control; Coordination of SEC and banking regulatory examinations; Patents of financial products;Certificate of deposit sales practices;Point of sale and confirmation disclosure on mutual fund fees;Global straight-through processing; SEC Release 34-52635 (guidance on client commission practices under Exchange Act Sec. 28(e)); Regulatory treatment of Investment Bank Holding Companies under the Gramm-Leach-Bliley Act and the requests for no-action letters under the SEC’s capital rules; Possible promulgation of rules for capital treatment and registration of Investment Bank Holding Companies; Regulation of variable annuities; Financial analysis of securities industry profitability; Best execution for options; Options market linkages; Dealer accounting issues and FASB; Proposal for reduced capital early warning requirements for broker-dealers that have strong policies and procedures for managing customer debits; Request for permitting broader range of securities to be used as collateral for Rule 15c3-3 deposits; Proposal for SEC regulation of Investment Bank Holding Companies; Implementation of Commodity Futures Modernization Act; Investment adviser referral fees; Nasdaq supermontage; Allocation of IPOs by underwriters; Reduction in and calculation of Section 31 fees; Regulatory framework for 529 plans; Broker-dealer rules under Form ADV Part 2; Government Accountability Office study of investment banks; SEC study of market structure issues; Mutual fund advertising proposed regulations; Mutual fund affiliate transactions; Mutual fund proxy disclosures; Implementation of new rules under the Sarbanes-Oxley Act; Efforts to obtain a regulation that would permit “portfolio margining” for customers of a broker-dealer; Mutual fund breakpoints; Accounting for derivatives and fair-value accounting; Possible reforms of Soft Dollars; Directed brokerage; Mutual fund issues, including late trading, market timing, disclosure of fees and revenue streams, 4:00 PM close on mutual fund redemption orders, revenue flows between mutual funds and broker-dealers, point-of-sale disclosures to mutual fund customers; Pricing of new issue securities by underwriters; Proposals to improve issuer disclosure of management discussion and analysis and critical accounting policies; SEC Short Sale Rule Proposal (Regulation SHO); Locked and crossed markets; Trading halts; Stock index pricing and markets, certification proposal for chief compliance officers and chief executive officers; SEC’s Proposed Regulation National Market System (NMS) Rule Proposal; Coordination and duplication of SEC and SRO examinations; Ability of broker-dealers to offer fee-based brokerage services outside Investment Advisers Act; Financial analysis of securities industry profitability; Proposed structural finance guidance by SEC and bank regulators; New York Stock Exchange hybrid market proposal published by SEC; SEC proposed Rule 15c-22; Business continuity planning sound practices and rules; Information security of government agencies; SEC Rule 202(a)(11)-1 (broker-dealers deemed not to be investment advisers); Mutual fund point-of-sale disclosure proposal; NASD proposed fairness opinion letter; Options market-quote migration; Application of Fair Labor Standards Act and 29 CFR Part 541 to registered representatives of broker-dealers; Gender/ethnic diversity in the securities industry; Regulation of securities analysts; Hybrid SRO/ SRO regulatory consolidation; Office of Foreign Asset Controls requirements for financial service firms; NYSE outsourcing rule proposal; NASDAQ exchange application; NYSE governance reform rule proposal; 17 CFR Part 275 (broker-dealers deemed to be investment advisers); Waiver of filing requirements for brokers and investments advisers due to Katrina; Implementation of Regulation NMS; Anti-money laundering rules under the Patriot Act; Implementation of new SEC rules on public securities offerings; SEC participation in U.S.-European Union dialogue on financial services regulatory convergence; NYSE trading rules; Proposed amendments to mutual fund redemption fee rule 22c-2; Exemptive relief from Investment Company Act Section 11(d)(1) for money market funds; Compliance with broker-dealer books and records requirements; SEC electronic proxy rule proposal; State of Utah legislation on fails-to-deliver securities on Regulation SHO threshold list; Application of SEC Rule 17a-3(A)(17) to subscription-way sales; Broker-dealer registered investment advisers; International convergence of rules regarding research regulation; International convergence of rules regarding access to cross-border markets of institutional clients and counterparties.

Client expense: Not reported · Firm income: $2,352,673

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Reserve System, Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State Justice Institute, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Foreign Workers - H.R. 2899/S.1461 Secure America & Orderly Immigration of 2005 S.1033/H.R. 2330 Immigration S. 2611 & H.R. 4437

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Privacy S. 1408 Identity Theft Protection Act Security Breach Notification/Security Standards S. 1332 Personal Data Privacy and Security Act House of Representatives Commerce Committee -Staff Discussion Draft on data protection H.R. 4127 Data Accountability and Trust Act (DATA) H.R. 3997 Financial Data Protection Act of 2005 S. 1789 Personal Data Privacy and Security Act of 2005 S. 1461 Consumer Identity Protection and Security Act Standards-Setting Bodies RFID

Client expense: $3,700,000 · Firm income: Not reported

Government targets: Agency for Healthcare Research & Quality (AHRQ), Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Council of Economic Advisers (CEA), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Export-Import Bank of the United States (EXIM Bank), Federal Communications Commission (FCC), Federal Trade Commission (FTC), Food & Drug Administration (FDA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Intl Trade Administration (ITA), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institutes of Health (NIH), Natl Science Foundation (NSF), Natl Security Council (NSC), Natl Telecommunications & Information Administration (NTIA), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP), Office of the Vice President of the United States, Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Technology Administration, Treasury, Dept of, U.S. Agency for International Development (USAID), U.S. Customs & Border Protection, U.S. Trade Representative (USTR), White House Office

H.R.4: the `Pension Protection Act of 2006'. H.R.3374: the ‘Consumer Notification and Financial Data Protection Act of 2005’. H.R.3375: the ‘Financial Data Security Act of 2005’. H.R.3997: the “Financial Data Protection Act of 2006’. H.R.4127: the “Data Accountability and Trust Act’. H.R.5318: the “Cyber-Security Enhancement and Consumer Data Protection Act of 2006’. H.R.5835: the ‘Veterans Identity and Credit Security Act of 2006’. H.R.6109: the ‘Stop Endangering the Records of Veterans (SERVE) Act of 2006’. H.R.6129: the ‘Credit Monitoring Clarification Act’. H.R.6163: the ‘Federal Agency Data Breach Protection Act’. H.R.6189: the ‘Protection from Telemarketers Act’. H.R.6273: a bill to direct the Secretary of Veterans Affairs to provide for enhanced protections against identity theft related to the public filing of separation forms of members of the Armed Forces and for other purposes. S.3662: the ‘Credit Monitoring Enhancement Act of 2006’. S.3713: the ‘Privacy Rights and Oversight for Electronic and Commercial Transactions Act of 2006’. S.3978: the ‘Debit and Check Card Consumer Protection Act of 2006’. S.1216: the ‘Financial Privacy Breach Notification Act of 2005’. S.3662: the ‘Credit Monitoring Enhancement Act of 2006’. S.1461: the ‘Consumer Identity Protection and Security Act’. See attached

Client expense: Not reported · Firm income: $40,000

Government targets: Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

H.R. 5746: the ‘Industrial Bank Holding Company Act of 2006’. S.2856: the ‘Financial Services Regulatory Relief Act of 2006’. S. 3978: the ‘Debit and Check Card Consumer Protection Act of 2006’. S. 4037: the ‘Rent-To-Own Reform Act of 2006’. S.1502: the ‘Preservation of Federalism in Banking Act’. H.R.3426.: the ‘Preservation of Federalism in Banking Act’. H.R.5341: the `Seasoned Customer CTR Exemption Act of 2006'. H.R.5350: `Federal Payday Loan Consumer Protection Amendments of 2006'. H.R. 5783: the ‘Comprehensive Credit Services for Veterans Act of 2006’. H.R. 6072: the ‘Financial Services Regulatory Relief Amendments Act of 2006’ H.R. 6297: the ‘Freedom to Bank Act’. H. R. 5024: the `Promoting Transparency in Financial Reporting Act of 2006'. S.4116: To amend the Federal Deposit Insurance Act, to clarify the scope of provisions relating to applicable rates of interest and other charge limitations. S.3850: the ‘Credit Rating Agency Reform Act of 2006’. S.3518: To amend the Credit Repair Organizations Act to establish a new disclosure statement. S.2655: the ‘Credit Card Reform Act of 2006’. S.1216: the ‘Financial Privacy Breach Notification Act of 2005’. S.1040: the ‘Credit Card Minimum Payment Notification Act’. S.3662: the ‘Credit Monitoring Enhancement Act of 2006’. H.R.2990: the ‘Credit Rating Agency Duopoly Relief Act of 2006’. S.1461: the ‘Consumer Identity Protection and Security Act’. See attached

Client expense: Not reported · Firm income: $40,000

Government targets: Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

H.R. 5746: the ‘Industrial Bank Holding Company Act of 2006’. S.2856: the ‘Financial Services Regulatory Relief Act of 2006’. S. 3978: the ‘Debit and Check Card Consumer Protection Act of 2006’. S. 4037: the ‘Rent-To-Own Reform Act of 2006’. S.1502: the ‘Preservation of Federalism in Banking Act’. H.R.3426.: the ‘Preservation of Federalism in Banking Act’. H.R.5341: the `Seasoned Customer CTR Exemption Act of 2006'. H.R.5350: `Federal Payday Loan Consumer Protection Amendments of 2006'. H.R. 5783: the ‘Comprehensive Credit Services for Veterans Act of 2006’. H.R. 6072: the ‘Financial Services Regulatory Relief Amendments Act of 2006’ H.R. 6297: the ‘Freedom to Bank Act’. H. R. 5024: the `Promoting Transparency in Financial Reporting Act of 2006'. S.4116: To amend the Federal Deposit Insurance Act, to clarify the scope of provisions relating to applicable rates of interest and other charge limitations. S.3850: the ‘Credit Rating Agency Reform Act of 2006’. S.3518: To amend the Credit Repair Organizations Act to establish a new disclosure statement. S.2655: the ‘Credit Card Reform Act of 2006’. S.1216: the ‘Financial Privacy Breach Notification Act of 2005’. S.1040: the ‘Credit Card Minimum Payment Notification Act’. S.3662: the ‘Credit Monitoring Enhancement Act of 2006’. H.R.2990: the ‘Credit Rating Agency Duopoly Relief Act of 2006’. S.1461: the ‘Consumer Identity Protection and Security Act’. See Addendum

Client expense: $2,669,687 · Firm income: Not reported

Government targets: Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

See Addendum H.R.4: the `Pension Protection Act of 2006'. H.R.3374: the ‘Consumer Notification and Financial Data Protection Act of 2005’. H.R.3375: the ‘Financial Data Security Act of 2005’. H.R.3997: the “Financial Data Protection Act of 2006’. H.R.4127: the “Data Accountability and Trust Act’. H.R.5318: the “Cyber-Security Enhancement and Consumer Data Protection Act of 2006’. H.R.5835: the ‘Veterans Identity and Credit Security Act of 2006’. H.R.6109: the ‘Stop Endangering the Records of Veterans (SERVE) Act of 2006’. H.R.6129: the ‘Credit Monitoring Clarification Act’. H.R.6163: the ‘Federal Agency Data Breach Protection Act’. H.R.6189: the ‘Protection from Telemarketers Act’. H.R.6273: a bill to direct the Secretary of Veterans Affairs to provide for enhanced protections against identity theft related to the public filing of separation forms of members of the Armed Forces and for other purposes. S.3662: the ‘Credit Monitoring Enhancement Act of 2006’. S.3713: the ‘Privacy Rights and Oversight for Electronic and Commercial Transactions Act of 2006’. S.3978: the ‘Debit and Check Card Consumer Protection Act of 2006’. S.1216: the ‘Financial Privacy Breach Notification Act of 2005’. S.3662: the ‘Credit Monitoring Enhancement Act of 2006’. S.1461: the ‘Consumer Identity Protection and Security Act’.]

Client expense: $2,669,687 · Firm income: Not reported

Government targets: Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

S. 1326 - Notification of Risk to Personal Data Act S. 1332 - Personal Data Privacy and Security Act of 2005 S. 1408 - Identity Theft Protection Act S. 1461 - Consumer Identity Protection and Security Act S. 1789 - Personal Data Privacy and Security Act of 2005 S. 3568 - Data Security Act of 2006 S. 3713 - Privacy Rights and OversighT for Electronic and Commercial Transactions Act of 2006 (PROTECT Act) H.R. 29 - Securely Protect Yourself Against Cyber Trespass Act (SPY Act) H.R. 744 - Internet Spyware (I-SPY) Prevention Act of 2005 H.R. 1080 - Information Protection and Security Act H.R. 1263 - Consumer Privacy Protection Act of 2005 H.R. 3997 - Financial Data Protection Act H.R. 4127 - Data Accountability and Trust Act H.R. 4731 - Eliminate Warehousing of Consumer Internet Data Act of 2006 Federal Trade Commission rulemakings concerning children's online privacy and implementation of the Children's Online Privacy Protection Act. S. 116 - Privacy Act of 2005 S. 500 - Information Protection and Security Act S. 687 - Software Principles Yielding Better Levels of Consumer Knowledge Act (Spyblock Act) S. 768 - Comprehensive Identity Theft Prevention Act

Client expense: $440,000 · Firm income: Not reported

Government targets: Federal Communications Commission (FCC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE

S 751 - The Notification of Risk to Personal Data Act S 1332 - The Personal Data Privacy and Security Act S 1326 - The Notification of Risk to Personal Data Act S 1461 - Consumer Identity Protection and Security Act S 1783 - Pension Reform S 1789 - The Personal Data Privacy and Security Act S 2654 - The Protection of Young Consumers Act HR 2830 - Increase in Employers' defined-benefit program premiums to the Pension Benefit Guaranty Corporation HR 3140 - The Consumer Data Security and Notification Act HR 3997 - The Financial Data Protection Act HR 4127 - Data Security Legislation

Client expense: $35,878 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE

H.Con. Res. 257 – Expressing the sense of the Congress with regard to a moratorium on the payment of principal or interest on certain mortgage loans, small business loans, and consumer loans for residents. H.Con. Res. 257 – Expressing the sense of the Congress with regard to a moratorium on the payment of principal or interest on certain mortgage loans, small business loans, and consumer loans for residents. Pub. L. No. 109-40, Military Personnel Financial Services Protection Act – To amend the federal securities laws to address abuses involving periodic payment plans sold to military personnel. (all provisions) H.R. 799, Consumer Checking Account Fairness Act – To amend the Expedited Funds Availability Act to redress imbalances between the faster withdrawals permitted under the Check 21 and the slower rates for crediting deposits, and for other purposes. H.R. 815, Financial Customer Identification Verification Improvement Act – To amend section 5318 of title 31, United States Code, to prohibit financial institutions from accepting matricula consular issued in the United States as a valid form of identification. (all provisions) H.R. 858, Identity Theft Penalty Enhancement Act – To amend Title 18, United State Code to establish penalties for aggravated identity theft, and for other purposes. (all provisions) H.R. 913, Broad-based Stock Option Plan Transparency Act – To direct the SEC to require enhanced disclosures of employee stock options and to require a study on the economic impact of broad-based employee stock option plans. H.R. 1208, College Student Credit Card Protection Act – To amend the Consumer Credit Protection Act to prevent credit card issuers from taking unfair advantage of full-time, traditional-aged, college students, to protect parents of traditional college student credit card holders, and for other purposes. H.R. 1224, the Business Checking Freedom Act – To repeal the prohibition on the payment of interest on demand deposits, and for other purposes. (all provisions) H.R. 1226 U.S. Financial Policy Committee for Fair Capital Standards Act – To establish a mechanism for developing uniform United States positions on issues before the Basel Committee on Banking Supervision at the Bank for International Settlements, to require a review on the most recent recommendation of the Basel Committee for an accord on capital standards, and for other purposes. Pub. L. No. 109-291, Credit Rating Agency Duopoly Relief Act of 2005 – To amend the Securities Exchange Act of 1934 to revise the definition of statistical rating organization (SRO) to include an entity: (1) whose primary business, for at least the most recent three consecutive years, has been the issuance of publicly available ratings; and (2) that employs either a quantitative or qualitative model to determine its publicly available ratings. (all provisions) H.R. 3007, Combating Terrorism Financing Act of 2005 – To add certain new crimes to Title 18 section on money laundering. H.R. 3140, Consumer Data Security and Notification Act of 2005 – To expand the protections for sensitive personal information in Federal law to cover the information collection and sharing practices of unregulated information brokers, to enhance information security requirements for consumer reporting agencies and information brokers and to require consumer reporting agencies, financial institutions, and other entities to notify consumers of data security breaches involving sensitive consumer information for other purposes. H.R. 3206, the CU Charter Choice Act -- To amend the Federal Credit Union Act provisions relating to any conversion of a credit union charter to a mutual savings bank or savings association charter, and for other purposes. (all provisions) H.R. 3375, Financial Data Security Act of 2005 – To amend the Fair Credit Reporting Act to provide for secure financial data, and for other purposes. HR. 3449, the Consumer Overdraft Protection Fair Practices Act – To extend the protections of the Truth in Lending Act to overdraft protection programs and services provided by depository institutions, to require customer consent before a depository institution may initiate overdraft protection services and fees, to enhance the information made available to consumers relating to overdraft protection services and fees, to prohibit systematic manipulation in the posting of checks and other debits to a depository account for the purpose of generating overdraft protection fees, and for other purposes. (all provisions) H.R. 3492, the Consumer Credit Card Protection Act of 2005 – To amend the Truth in Lending Act to protect consumers from unfair practices of credit card issuers, and for other purposes. (all provisions) Pub. L. No. 109-351, Financial Services Regulatory Relief Act of 2005 – To provide regulatory relief and improve productivity for insured depository institutions, and for other purposes. H.R. 4636, the Federal Deposit Insurance Reform Conforming Amendments Act of 2005 – To enact the technical and conforming amendments necessary to implement the Federal Deposit Insurance Reform Act of 2005, and for other purposes. (all provisions) H.R. 5068, the Export-Import Bank Reauthorization Act of 2006 – To reauthorize the operations of the Export-Import Bank, and to reform certain operations of the Bank, and for other purposes. (all provisions) H.R. 5122, National Defense Authorization Act for Fiscal Year 2007. (provisions on payday lending interest rate limits) H.R. 5177, to amend the Internal Revenue Code of 1986 to allow bonds guaranteed by the Federal home loan banks to be treated as tax exempt bonds. (all provisions) H.R. 5341, the Seasoned Customer CTR Exemption Act of 2006 –To amend section 5313 of title 31, United States Code, to reform certain requirements for reporting cash transactions, and for other purposes. (all provisions) H.R. 5522, the Foreign Operations, Export Financing, and Related Programs Appropriations Act, 2007. (provisions to prevent Export-Import Bank from funding oil and gas exploration projects) H.R. 5576, the Transportation, Treasury, Housing and Urban Development, the Judiciary, the District of Columbia and Independent Agencies Appropriations Act, 2007. (bank real estate activity, matricula consular cards provisions) Pub. L. No. 109-390, Financial Netting Improvements Act of 2006 – To improve the netting process for financial contracts, and for other purposes. (all provisions) H.R. 6062, Community Development Investment Enhancements Act of 2006 – To enhance community development by financial institutions, and for other purposes. (all provisions) S. 12, Targeting Terrorists More Effectively Act of 2005 – Sets forth provisions to detect terrorist financing. (all provisions) S. 98, the Community Choice in Real Estate Act – To amend the Bank Holding Company Act of 1956 and the Revised Statutes of the United States to prohibit financial holding companies and national banks from engaging, directly or indirectly, in real estate brokerage or real estate management activities, and for other purposes. (all provisions) S. 393, Credit Card Minimum Payment Warning Act of 2005 – To require enhanced disclosure to consumers regarding the consequences of making only minimum required payments in the repayment of credit card debt, and for other purposes. (all provisions) S. 499, Credit Card Accountability Responsibility and Disclosure Act of 2005 – To amend the consumer Credit Protection Act to ban abusive credit practices, enhance consumer disclosures, protect underage consumers, and for other purposes. (all provisions) S. 1037, Mutual Fund Transparency Act of 2005 – To require disclosure of financial relationships between brokers and mutual fund companies and of certain brokerage commissions paid by mutual fund companies. (all provisions) S. 1040, Credit Card Minimum Payment Notification Act – To amend the Truth in Lending Act to provide for enhanced disclosure under an open end credit plan. (all provisions) S. 1461, Consumer Identity Protection and Security Act – To establish procedures for the protection of consumers from misuse of, and unauthorized access to, sensitive personal information contained in private information files maintained by commercial entities engaged in, or affecting, interstate commerce, provide for enforcement of those procedures by the Federal Trade Commission, and for other purposes. (all provisions) S. 1562, Safe and Fair Deposit Insurance Act of 2005 (all provisions) – To provide for the merger of the bank and savings association deposit insurance funds, to modernize and improve the safety and fairness of the federal deposit insurance system, and for other purposes. (all provisions) S. 1586, the Interest on Business Checking Act of 2005 – To allow all businesses to make up to 24 transfers each month from interest-bearing transaction accounts to other transaction accounts, to require the payment of interest on reserves held for depository institutions at Federal reserve banks, to repeal the prohibition of interest on business accounts, and for other purposes. (all provisions) S. 2654, the Protection of Young Consumers Act – To protect consumers, and especially young consumers, from skyrocketing consumer debt and the barrage of credit card solicitations, to establish a financial literacy and education program in elementary and secondary schools to help prepare young people to be financially responsible consumers, and for other purposes. (all provisions) S. 2766, National Defense Authorization Act for Fiscal Year 2007. (provisions on payday lending interest rate limits). Basel Testimony (No bill number) – The ongoing efforts to implement the Basel II risk-based capital requirements, and regarding the proposed guidance concerning commercial real estate concentrations. Basel II Testimony (No bill number) – The ongoing efforts to implement the Basel II risk-based capital requirements, and regarding the proposed guidance concerning commercial real estate concentrations. Avian Flu Testimony (No bill number) – Presented ABA’s view on the three letter rulings by the OCC. The OCC made it possible for national banks to continue serving as economic catalysts for communities across America and to meet the changing needs of bank customers within the existing legal framework. Developed Lobbying/Educational materials on: Credit Cards Farm Credit Systems Credit Unions Mutual Savings Banks President’s proposal to create health savings accounts. Proposals on Credit Card Interchange Fees. “Dear Colleague” Letter regarding Credit Card Industry Standards. OCC Letter Rulings on Bank-Owned Real Estate. Fiscal year 2007 budget proposal to require credit and debit card issuers to report to the IRS each year the aggregate reimbursement payments made to merchants. Implementation of Basel II Capital Accords.

Client expense: $2,680,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 3140 - Consumer Data Security and Notification Act of 2005 HR 3374 - Consumer Notification and Financial Data Protection Act of 2005 HR 3375 - Financial Data Security Act of 2005 HR 3997- Financial Data Protection Act of 2005 S 1332 - Personal Data Privacy and Security Act of 2005 S 1461 - Consumer Identity Protection and Security Act S 1408 - Identity Theft Protection Act S 1789 - Personal Data Privacy & Security Act of 2005 HR 1078 - Social Security Number Protection Act of 2005 S 3568 - Data Security Act of 2006 HR 5813 - Department of Homeland Security Management and Operations Improvement Act of 2006 S 3850 - Credit Rating Agency Reform Act S 1326 & S 751 - Notification of Risk to Personal Data Act HR 1069 - Notification of Risk to Personal Data Act S 714 - Junk Fax Prevention Act of 2005 HR 4127 - Data Accountability and Trust Act

Client expense: $1,720,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.4662, to prohibit the obtaining of customer information from telecommunications carriers by false pretenses, and the sale or disclosure of such records obtained by false pretenses H.R.4709, to amend title 18, United States Code, to strengthen protections for law enforcement officers and the public by providing criminal penalties for the fraudulent acquisition or unauthorized disclosure of phone records H.R.4731, to require owners of Internet websites to destroy obsolete data containing personal information H.R.4943, to prohibit fraudulent access to telephone records S.29, to prohibit the sale or purchase of SSN’s without the affirmatively expressed consent of an individual S.115, to require federal agencies, and persons engaged in interstate commerce, in possession of electronic data containing personal information, to disclose any unauthorized acquisition of such information S.472, Anti-Phishing Act of 2005, to criminalize Internet scams involving fraudulently obtained personal information, commonly known as phishing S.500, to regulate information brokers and protect individual rights with respect to personally identifiable information S.622, to amend the Homeland Security Act of 2002 (Pub.L #107-296) to provide for the protection of voluntarily furnished confidential information S.687, to regulate the unauthorized installation of computer software, to require clear disclosure to computer users of certain computer software features that may pose a threat to user privacy S.751, to require federal agencies, and persons engaged in interstate commerce, in possession of data containing personal information, to disclose any unauthorized acquisition of such information S.768, to provide for comprehensive identity theft prevention S.810, to regulate the transmission of personally identifiable information to foreign affiliates and subcontractors S.1326, Notification of Risk to Personal Data Act S.1332, the Personal Data Privacy and Security Act of 2005--a comprehensive data protection and breach notification bill S.1336, to establish procedures for the protection of consumers from misuse of, and unauthorized access to, sensitive personal information contained in private information files maintained by commercial entities and to provide for enforcement of those procedures by the FTC S.1350, to amend the Communications Act of 1934 to protect the privacy rights of subscribers to wireless communications services S.1408, Identity Theft Protection Act, to set national standards for notifying consumers about data security breaches, require businesses to improve their safeguards for sensitive information, allow individuals to freeze their credit report, and limit the solicitation of SSNs S.1461, to establish procedures for consumers to place credit freezes on their consumer credit agency reports H.R.4987, to amend title 18,US Code, to provide an increased maximum penalty for telemarketing fraud targeting seniors S.1594, to require financial services providers to maintain customer information security systems and to notify customers of unauthorized access to personal information S.1608, to enhance FTC enforcement against illegal spam, spyware, and cross-border fraud and deception S.1789, Personal Data Privacy and Security Act of 2005, to prevent and mitigate identity theft, to ensure privacy, to provide notice of security breaches, and to enhance criminal penalties, law enforcement assistance, and other protections against security breaches, fraudulent access, and misuse of personally identifiable information S.2178, to make the stealing and selling of telephone records a criminal offense S.2264, to provide enhanced consumer protection from unauthorized sales and use of confidential telephone information by amending the Communications Act of 1934, prohibiting certain practices, and providing for enforcement by the FTC and States S.2389, a bill to amend the Communications Act of 1934 to prohibit the unlawful acquisition and use of confidential customer proprietary network information, and for other purposes S. 3568, To protect information relating to consumers, to require notice of security breaches, and for other purposes S.936, to ensure privacy for e-mail communications—introduced by Leahy and Sununu on 4/28/05 to Judiciary. S.1350, to amend the Communications Act of 1934 to protect the privacy rights of subscribers to wireless communications services H.R.516, to amend the procedures that apply to consideration of interstate class actions to assure fairer outcomes for class members and defendants, to assure attorneys do not receive a disproportionate amount of settlements H.R.29, to protect users of the Internet from unknowing transmission of their personally identifiable information through spyware programs H.R.744, to amend title 18, US Code, to discourage spyware H.R.1069, to require federal agencies, and persons engaged in interstate commerce, in possession of electronic data containing personal information to disclose any unauthorized acquisition of such information and for other purposes H.R.1078, to strengthen the authority of the federal government to protect individuals from certain acts and practices in the sale and purchase of Social Security numbers and SSN account numbers H.R.1080, to regulate information brokers and protect individual rights with respect to personally identifiable information H.R.1099, to criminalize Internet scams involving fraudulently obtaining personal information, commonly known as phishing H.R.1139, to amend the Communications Act of 1934 to protect the privacy rights of subscribers to wireless communications services H.R.1263, Consumer Privacy Protection Act of 2005, to protect and enhance consumer privacy H.R.1653, to prohibit the transfer of personal information to any person outside the US, without notice and consent H.R.1745, to amend the Social Security Act to enhance Social Security account number privacy protections, to prevent fraudulent misuse of the Social Security account number, and to otherwise enhance protection against identity theft H.R.3140, to expand the protections for sensitive personal information in federal law to cover the information collection and sharing practices of unregulated information brokers, to enhance information security requirements for consumer reporting agencies and information brokers, and to require consumer reporting agencies, financial institutions, and other entities to notify consumers of data security breaches involving sensitive consumer information H.R.3374, to provide for the uniform and timely notification of consumers whose sensitive financial personal information has been placed at risk by a breach of data security, to enhance data security safeguards, to provide appropriate consumer mitigation services, and for other purposes H.R.3375, to amend the Fair Credit Reporting Act to provide for secure financial data, and for other purposes H.R.3501, to require financial institutions and financial service providers to notify customers of the unauthorized use of personal financial information H.R.3503, to ensure privacy for e-mail communications H.R.3997, to amend the Fair Credit Reporting Act to provide for secure financial data H.R.4127, to protect consumers by requiring reasonable security policies and procedures to protect computerized data containing personal information, and to provide for nationwide notice in the event of a security breach H.R.4244, to provide grants for regional task forces to more effectively investigate and prosecute identity theft and other economic crimes H.R.4657, to prevent the selling of telephone customer proprietary network information

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

Government targets: Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, SENATE

H.R. 3882 Financial Safety and Equity Act of 2005 For H.R. 3505 Financial Services Regulatory Relief Act of 2005 For H.R. 3909 Hurricane Check Cashing Relief Act of 2005 For H.R. 3922 Retroactive Flood Insurance NP H.R. 3945 Hurricane Katrina Financial Services Relief Act of 2005 For H.R. 3997 Financial Data Protection Act of 2005 For H.R. 4100 Louisiana Recovery Corporation Act For H.R. 4127 Data Accountability and Trust Act NP H.R. 4133 National Flood Insurance Program Further Enhanced Borrowing Authority Act ’05 For H.R. 4146 Hurricanes Rita and Wilma Financial Services Relief Act of 2005 For H.R. 4320 National Flood Insurance Program Reform For H.R. 4411 Internet Gambling Prohibition and Enforcement Act (as introduced) NP H.R. 4411 Internet Gambling Prohibition and Enforcement Act (as passed) For H.R. 4777 Internet Gambling Prohibition Act NP H.R. 5122 Talent “Payday Lending” Amendment (to DoD Approps bill Against H.R. 5341 Seasoned Customer CTR Exemption Act of 2006 For H.R. 5405 COMPETE Act For H.R. 5746 Industrial Bank Holding Company Act of 2006 For H.R. 4973 Flood Insurance Reform and Modernization act of 2006 NP Bank broker regulations NP Consumer data security NP Regulatory Relief For Legislation to bar federal pre-emption by the OCC Against Risk-based capital requirements for banks NP Sarbanes-Oxley Act relief for community banks For Corporate governance requirements NP Relief from securities law requirements for small companies For Federal Home Loan Bank advances and collateral NP Federal Home Loan Bank System issues NP Separation of banking and commerce For Payments system issues NP Bank Secrecy Act and anti-money laundering issues NP Securities activities of banks NP Bringing ILC’s under the Bank Holding Company Act For Credit card/debit card interchange fees NP Deposit insurance reform implementation rules NP Commercial real estate lending guidelines, as proposed Against Federal Housing Finance Board retained earnings capital rule, as proposed Against ILC applications by commercial companies Against S. 190 Federal Housing Enterprise Regulatory Reform Act of 2005 (as introduced) For S. 190 Federal Housing Enterprise Regulatory Reform Act of 2005 (as passed by SBC) Against S. 500 Information Protection and Security Act NP S. 751 Notification of Risk to Personal Data Act NP S. 768 Comprehensive Identity Theft Prevention Act NP S. 1326 Notification of Risk to Personal Data Act NP S. 1332 Personal Data Privacy and Security Act of 2005 NP S. 1408 Identity Theft Protection Act NP S. 1461 Consumer Identity Protection and Security Act NP S. 1568 Communities First Act For S. 1765 Louisiana Katrina Reconstruction Act For S. 1766 Louisiana Katrina Reconstruction Act For S. 1932 Deficit Reduction Act for 2005 For S. 2856 Financial Services Regulatory Relief Act of 2006 For S. 3568 Data Security Act of 2006 For S. 3589 Flood Insurance Reform and Modernization Act of 2006 NP H.R. 111 Community Choice in Real Estate Act Against H.R 399 Rural Economic Investment Act of 2005 NP H.R. 461 Military Personnel Financial Services Protection Act NP H.R. 1080 Information Protection and Security Act NP H.R. 1099 Anti-phishing Act of 2005 NP H.R. 1182 Prohibit Predatory Lending Act NP H.R. 1263 Consumer Privacy Protection Act of 2005 NP H.R. 1295 Responsible Lending Act NP H.R. 1461 Federal Housing Enterprise Regulatory Reform Act of 2005 For H.R. 1745 Social Security Number Privacy and Identity Theft Prevention Act of 2005 NP H.R. 2061 Communities First Act For H.R. 2317 Credit Union Regulatory Improvements Act of 2005 Against H.R. 2660 Fair Choice and Competition in Real Estate Act of 2005 For H.R. 3206 Credit Union Charter Choice Act For S. 238 Rural Economic Investment Act of 2005 NP S. 29 Social Security Number Misuse Prevention Act NP S. 98 Community Choice in Real Estate Act Against S. 116 Privacy Act of 2005 NP

Client expense: $941,428 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Economic Council (NEC), Office of Management & Budget (OMB), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

H.Con. Res. 257 – Expressing the sense of the Congress with regard to a moratorium on the payment of principal or interest on certain mortgage loans, small business loans, and consumer loans for residents. H.Con. Res. 257 – Expressing the sense of the Congress with regard to a moratorium on the payment of principal or interest on certain mortgage loans, small business loans, and consumer loans for residents. Pub. L. No. 109-40, Military Personnel Financial Services Protection Act – To amend the federal securities laws to address abuses involving periodic payment plans sold to military personnel. (all provisions) H.R. 799, Consumer Checking Account Fairness Act – To amend the Expedited Funds Availability Act to redress imbalances between the faster withdrawals permitted under the Check 21 and the slower rates for crediting deposits, and for other purposes. H.R. 815, Financial Customer Identification Verification Improvement Act – To amend section 5318 of title 31, United States Code, to prohibit financial institutions from accepting matricula consular issued in the United States as a valid form of identification. (all provisions) H.R. 858, Identity Theft Penalty Enhancement Act – To amend Title 18, United State Code to establish penalties for aggravated identity theft, and for other purposes. (all provisions) H.R. 913, Broad-based Stock Option Plan Transparency Act – To direct the SEC to require enhanced disclosures of employee stock options and to require a study on the economic impact of broad-based employee stock option plans. H.R. 1208, College Student Credit Card Protection Act – To amend the Consumer Credit Protection Act to prevent credit card issuers from taking unfair advantage of full-time, traditional-aged, college students, to protect parents of traditional college student credit card holders, and for other purposes. H.R. 1224, the Business Checking Freedom Act – To repeal the prohibition on the payment of interest on demand deposits, and for other purposes. (all provisions) H.R. 1226 U.S. Financial Policy Committee for Fair Capital Standards Act – To establish a mechanism for developing uniform United States positions on issues before the Basel Committee on Banking Supervision at the Bank for International Settlements, to require a review on the most recent recommendation of the Basel Committee for an accord on capital standards, and for other purposes. Pub. L. No. 109-291, Credit Rating Agency Duopoly Relief Act of 2005 – To amend the Securities Exchange Act of 1934 to revise the definition of statistical rating organization (SRO) to include an entity: (1) whose primary business, for at least the most recent three consecutive years, has been the issuance of publicly available ratings; and (2) that employs either a quantitative or qualitative model to determine its publicly available ratings. (all provisions) H.R. 3007, Combating Terrorism Financing Act of 2005 – To add certain new crimes to Title 18 section on money laundering. H.R. 3140, Consumer Data Security and Notification Act of 2005 – To expand the protections for sensitive personal information in Federal law to cover the information collection and sharing practices of unregulated information brokers, to enhance information security requirements for consumer reporting agencies and information brokers and to require consumer reporting agencies, financial institutions, and other entities to notify consumers of data security breaches involving sensitive consumer information for other purposes. H.R. 3206, the CU Charter Choice Act -- To amend the Federal Credit Union Act provisions relating to any conversion of a credit union charter to a mutual savings bank or savings association charter, and for other purposes. (all provisions) H.R. 3375, Financial Data Security Act of 2005 – To amend the Fair Credit Reporting Act to provide for secure financial data, and for other purposes. HR. 3449, the Consumer Overdraft Protection Fair Practices Act – To extend the protections of the Truth in Lending Act to overdraft protection programs and services provided by depository institutions, to require customer consent before a depository institution may initiate overdraft protection services and fees, to enhance the information made available to consumers relating to overdraft protection services and fees, to prohibit systematic manipulation in the posting of checks and other debits to a depository account for the purpose of generating overdraft protection fees, and for other purposes. (all provisions) H.R. 3492, the Consumer Credit Card Protection Act of 2005 – To amend the Truth in Lending Act to protect consumers from unfair practices of credit card issuers, and for other purposes. (all provisions) Pub. L. No. 109-351, Financial Services Regulatory Relief Act of 2005 – To provide regulatory relief and improve productivity for insured depository institutions, and for other purposes. H.R. 4636, the Federal Deposit Insurance Reform Conforming Amendments Act of 2005 – To enact the technical and conforming amendments necessary to implement the Federal Deposit Insurance Reform Act of 2005, and for other purposes. (all provisions) H.R. 5068, the Export-Import Bank Reauthorization Act of 2006 – To reauthorize the operations of the Export-Import Bank, and to reform certain operations of the Bank, and for other purposes. (all provisions) H.R. 5122, National Defense Authorization Act for Fiscal Year 2007. (provisions on payday lending interest rate limits) H.R. 5177, to amend the Internal Revenue Code of 1986 to allow bonds guaranteed by the Federal home loan banks to be treated as tax exempt bonds. (all provisions) H.R. 5341, the Seasoned Customer CTR Exemption Act of 2006 –To amend section 5313 of title 31, United States Code, to reform certain requirements for reporting cash transactions, and for other purposes. (all provisions) H.R. 5522, the Foreign Operations, Export Financing, and Related Programs Appropriations Act, 2007. (provisions to prevent Export-Import Bank from funding oil and gas exploration projects) H.R. 5576, the Transportation, Treasury, Housing and Urban Development, the Judiciary, the District of Columbia and Independent Agencies Appropriations Act, 2007. (bank real estate activity, matricula consular cards provisions) Pub. L. No. 109-390, Financial Netting Improvements Act of 2006 – To improve the netting process for financial contracts, and for other purposes. (all provisions) H.R. 6062, Community Development Investment Enhancements Act of 2006 – To enhance community development by financial institutions, and for other purposes. (all provisions) S. 12, Targeting Terrorists More Effectively Act of 2005 – Sets forth provisions to detect terrorist financing. (all provisions) S. 98, the Community Choice in Real Estate Act – To amend the Bank Holding Company Act of 1956 and the Revised Statutes of the United States to prohibit financial holding companies and national banks from engaging, directly or indirectly, in real estate brokerage or real estate management activities, and for other purposes. (all provisions) S. 393, Credit Card Minimum Payment Warning Act of 2005 – To require enhanced disclosure to consumers regarding the consequences of making only minimum required payments in the repayment of credit card debt, and for other purposes. (all provisions) S. 499, Credit Card Accountability Responsibility and Disclosure Act of 2005 – To amend the consumer Credit Protection Act to ban abusive credit practices, enhance consumer disclosures, protect underage consumers, and for other purposes. (all provisions) S. 1037, Mutual Fund Transparency Act of 2005 – To require disclosure of financial relationships between brokers and mutual fund companies and of certain brokerage commissions paid by mutual fund companies. (all provisions) S. 1040, Credit Card Minimum Payment Notification Act – To amend the Truth in Lending Act to provide for enhanced disclosure under an open end credit plan. (all provisions) S. 1461, Consumer Identity Protection and Security Act – To establish procedures for the protection of consumers from misuse of, and unauthorized access to, sensitive personal information contained in private information files maintained by commercial entities engaged in, or affecting, interstate commerce, provide for enforcement of those procedures by the Federal Trade Commission, and for other purposes. (all provisions) S. 1562, Safe and Fair Deposit Insurance Act of 2005 (all provisions) – To provide for the merger of the bank and savings association deposit insurance funds, to modernize and improve the safety and fairness of the federal deposit insurance system, and for other purposes. (all provisions) S. 1586, the Interest on Business Checking Act of 2005 – To allow all businesses to make up to 24 transfers each month from interest-bearing transaction accounts to other transaction accounts, to require the payment of interest on reserves held for depository institutions at Federal reserve banks, to repeal the prohibition of interest on business accounts, and for other purposes. (all provisions) S. 2654, the Protection of Young Consumers Act – To protect consumers, and especially young consumers, from skyrocketing consumer debt and the barrage of credit card solicitations, to establish a financial literacy and education program in elementary and secondary schools to help prepare young people to be financially responsible consumers, and for other purposes. (all provisions) S. 2766, National Defense Authorization Act for Fiscal Year 2007. (provisions on payday lending interest rate limits). Basel Testimony (No bill number) – The ongoing efforts to implement the Basel II risk-based capital requirements, and regarding the proposed guidance concerning commercial real estate concentrations. Basel II Testimony (No bill number) – The ongoing efforts to implement the Basel II risk-based capital requirements, and regarding the proposed guidance concerning commercial real estate concentrations. Avian Flu Testimony (No bill number) – Presented ABA’s view on the three letter rulings by the OCC. The OCC made it possible for national banks to continue serving as economic catalysts for communities across America and to meet the changing needs of bank customers within the existing legal framework. Developed Lobbying/Educational materials on: Credit Cards Farm Credit Systems Credit Unions Mutual Savings Banks President’s proposal to create health savings accounts. Proposals on Credit Card Interchange Fees. “Dear Colleague” Letter regarding Credit Card Industry Standards. OCC Letter Rulings on Bank-Owned Real Estate. Fiscal year 2007 budget proposal to require credit and debit card issuers to report to the IRS each year the aggregate reimbursement payments made to merchants. Implementation of Basel II Capital Accords.

Client expense: $2,680,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 1789, The Personal Data Privacy and Security Act; S. 2169, The Financial Data Protection Act; S. 369, The Free Speech Act, S. 394, The Open Government Act; HR 4127, the Data Accountability and Trust Act; S. 1408, The Identity Theft Protection Act; S. 1461; The Consumer Identity Protection Security Act,. HR 5167, The Child Nutrition Promotion and School Lunch Protection Act; HR 3993, The Financial Data Protection Act; HR 867, The Open Speech Act; S. 2952, The Child Nutrition Promotion and School Lunch Protection Act,

Client expense: $554,400 · Firm income: Not reported

Government targets: Federal Communications Commission (FCC), Federal Trade Commission (FTC), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Copyright Office, U.S. Postal Service (USPS)

H.R.3140, the Consumer Data Security and Notification Act S. 115, the Notification of Risk to Personal Data Act S. 1408, the Identity Theft Protection Act S. 1461, the Consumer Identity Protection and Security Act Issues pertaining to data security and privacy: H.R. 29, the Spy Act S. 687, the Spy Block Act H.R. 1069, the Notification of Risk to Personal Data Act

Client expense: Not reported · Firm income: $75,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.3140, the Consumer Data Security and Notification Act S. 115, the Notification of Risk to Personal Data Act S. 1408, the Identity Theft Protection Act S. 1461, the Consumer Identity Protection and Security Act Issues pertaining to data security and privacy: H.R. 29, the Spy Act S. 687, the Spy Block Act H.R. 1069, the Notification of Risk to Personal Data Act

Client expense: Not reported · Firm income: $75,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S 115, Notification of Risk to Personal Data Act S 1216, Financial Privacy Breach Notification Act of 2005 S 1461, Consumer Identity Protection and Security Act S 1594, Financial Privacy Protection Act of 2005 S 1608, Undertaking Spam, Spyware, and Fraud Enforcement with Enforcers Beyond Borders Act of 2005 (U.S. SAFE WEB ACT of 2005). S 687, Software Principles Yielding Better Level of Consumer Knowledge Act (SPY BLOCK Act) S 1408, Identity Theft Protection Act S 116, Privacy Act of 2005 S 1321, Notification of Risk to Personal Data Act S 1004, Enhanced Consumer Protection Against Spyware Act of 2005 S 1336, A Bill to establish procedures for the protection of consumers from misuse of, and unauthorized access to, sensitive personal information contained in private information files maintained by commercial entities engaged in, or affecting, interstate commerce. S 1332, A bill to prevent and mitigate identity theft; to ensure privacy; and to enhance criminal penalties, law enforcement assistance, and other protections against security breaches, fraudulent access, and misuse of personally identifiable information. S 500, Information Protection and Security Act S 751, Notification of Risk to Personal Data Act S 768, Comprehensive Identity Theft Prevention Act S 1789, Personal Data Privacy and Security Act of 2005 S 687, SAFE WEB Act, provisions dealing with data security, phishing, Spyware, privacy; data retention HR 3997, Financial Data Protection Act of 2005 HR 4127, Data Accountability and Trust Act (DATA)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 3140, To expand the protections for sensitive personal information in Federal law to cover the information collection and sharing practices of unregulated information brokers, to enhance information security requirements for consumer reporting agencies and information. S 115, Notification of Risk to Personal Data Act S 1216, Financial Privacy Breach Notification Act of 2005 S 1408, Identity Theft Protection Act S 1461, Consumer Identity Protection and Security Act S 1594, Financial Privacy Protection Act of 2005 S 687, Software Principles Yielding Better Level of Consumer Knowledge Act (SPY BLOCK Act) HR 4709, Law Enforcement and Phone Privacy Protection Act of 2006 HR 744, Internet Spyware (I-SPY) Prevention Act of 2005 HR 4943, To prohibit fraudulent access to telephone records HR 5126, To amend the Communications Act of 1934 to prohibit manipulation of caller identification information, and for other purposes. S 2169, Financial Data Protection Act of 2005 S 2178, A bill to make the stealing and selling of telephone records a criminal offense S 3568, A bill to protect information relating to consumers, to require notice of security breaches, and for other purposes S 3518, A bill to amend the Credit Repair Organizations Act to establish a new disclosure statement S 1326, Notification of Risk to Personal Data Act S 2389, A bill to amend the Communications Act of 1934 to prohibit the unlawful acquisition and use of confidential customer proprietary network information, and for other purposes. S 1004, Enhanced Consumer Protection Against Spyware Act of 2005 S 1336, Consumer Identity Protection and Security Act HR 3501, Consumer Access Rights Defense Act (CARD) of 2005 S 1332, Personal Data Privacy and Security Act of 2005 S 500, Information Protection and Security Act S 751, Notification of Risk to Personal Data Act S 768, Comprehensive Identity Theft Prevention Act HR 3374, Consumer Notification and Financial Data Protection Act of 2005 S 1789, Personal Data Privacy and Security Act of 2005 HR 3997, Financial Data Protection Act HR 4127, the Data Accountability and Trust Act (DATA) HR 3375, Financial Data Security Act of 2005 HR 5318, Cyber-Security Enhancement and Consumer Data Protection Act of 2006 HR 1069, Notification of Risk to Personal Data Act HR 1080, Information Protection and Security Act HR 29, Securely Protect Yourself Against Cyber Trespass Act (SPY ACT)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 5126, To amend the Communications Act of 1934 to prohibit manipulation of caller identification information, and for other purposes. HR 5318, Cyber-Security Enhancement and Consumer Data Protection Act of 2006 HR 1684, To amend the Internet Tax Freedom Act to make permanent the moratorium on certain taxes relating to the Internet and to electronic commerce. HR 1685, To provide for the recognition of electronic signatures for the conduct of interstate and foreign commerce, to restrict the transmission of certain electronic mail advertisements, to authorize the Federal Trade Commission to prescribe rules to protect the privacy of users of commercial Internet websites, to promote the rapid deployment of broadband Internet services, and for other purposes. S 849, A bill to make the moratorium on Internet access taxes and multiple and discriminatory taxes on electronic commerce permanent. HR 5252, To promote the deployment of broadband networks and services HR 3140, To expand the protections for sensitive personal information in Federal law to cover the information collection and sharing practices of unregulated information brokers, to enhance information security requirements for consumer reporting agencies and information. S 115, Notification of Risk to Personal Data Act S 1216, Financial Privacy Breach Notification Act of 2005 S 1461, Consumer Identity Protection and Security Act S 1594, Financial Privacy Protection Act of 2005 S 1608, Undertaking Spam, Spyware, and Fraud Enforcement with Enforcers Beyond Borders Act of 2005 (U.S. SAFE WEB ACT of 2005). S 687, Software Principles Yielding Better Level of Consumer Knowledge Act (SPY BLOCK Act) S 714, Junk Fax Prevention Act of 2005 S 116, Privacy Act of 2005 S 1326, Notification of Risk to Personal Data Act S 2389, A bill to amend the Communications Act of 1934 to prohibit the unlawful acquisition and use of confidential customer proprietary network information, and for other purposes. S 1004, Enhanced Consumer Protection Against Spyware Act of 2005 S 1336, A Bill to establish procedures for the protection of consumers from misuse of, and unauthorized access to, sensitive personal information contained in private information files maintained by commercial entities engaged in, or affecting, interstate commerce HR 3501, Consumer Access Rights Defense Act (CARD) of 2005 S 1332, A bill to prevent and mitigate identity theft; to ensure privacy; and to enhance criminal penalties, law enforcement assistance, and other protections against security breaches, fraudulent access, and misuse of personally identifiable information. S 500, Information Protection and Security Act S 751, Notification of Risk to Personal Data Act S 768, Comprehensive Identity Theft Prevention Act HR 3374, Consumer Notification and Financial Data Protection Act of 2005 S 1789, Personal Data Privacy and Security Act of 2005 HR 3997, Financial Data Protection Act of 2005 HR 4127, the Data Accountability and Trust Act (DATA) HR 3375, Financial Data Security Act of 2005 HR 5318, Cyber-Security Enhancement and Consumer Data Protection Act of 2006 HR 4943, To prohibit fraudulent access to telephone records HR 4709, Law Enforcement and Phone Privacy Protection Act of 2006 S 2178, A bill to make the stealing and selling of telephone records a criminal offense S 3568, A bill to protect information relating to consumers, to require notice of security breaches, and for other purposes HR 1069, Notification of Risk to Personal Data Act HR 1080, Information Protection and Security Act HR 1263, Consumer Privacy Protection Act of 2005 HR 29, Securely Protect Yourself Against Cyber Trespass Act (SPY ACT)

Client expense: Not reported · Firm income: $160,000

Government targets: Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE

Foreign Workers - H.R. 2899 and S. 1461 Secure America & Orderly Immigration of 2005 S. 1033/H.R. 2330 Immigration S.2611 & H.R. 4437

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 1461 -- Establish procedures for the protection of consumers from misues or unauthorized access of personal information. H.R. 3374 -- Proved for uniform and timely notification to consumers who's data has been breached. H.R. 3375 -- Amend the Fair Credit Reporting Act to provide for secure financial data. H.R. 4127 -- Protect consumers by requiring reasonalbe security policies to protect computerized data.

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

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

Various Security Breach Notification bills, including S. 1408 Identity Theft Protection Act of 2005; S. 1332, Personal Data Privacy and Security Act of 2005; S. 1461 Consumer Identity Protection and Security Act of 2005; HR 3375, Financial Data Security Act of 2005; HR 3997 Financial Data Protection Act of 2005; HR 4127, Data Accountability and Trust Act; S. 1326 Notification of Risk to Personal Data Act; S. 1789 Personal Data Privacy and Security Act. Issues addressed: the need for pre-emption of state laws, definition of security breach, manner and timing of notices.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Privacy, data protection/breach and safeguards, including S. 1461 (Shelby), HR 3997 (House Financial Services Committee), HR 4127 (House Energy and Commerce Committee), S 1408 (Smith), S 1789 (Specter/Leahy), S 1326 (Sessions), and S 751 Feinstein; Anti-Spyware legislation, including HR 744 (Goodlatte), HR 29 (Bono), S 1004 (Allen), and S 687 (Burns).

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Natl Security Council (NSC), SENATE, Treasury, Dept of, White House Office

S751 - NOTIFICATION OF RISK TO PERSONAL DATA ACT S 768 - COMPREHENSIVE ID THEFT PREVENTION ACT S 810 - SAFEGUARDING AMERICANS FROM EXPORTING IDENTIFICATION ACT S 1332- PERSONAL DATA PRIVACY AND SECURITY ACT OF 2005 S 1408 -ID THEFT PREVENTION ACT S 1461 - CONSUMER IDENTITY PROTECTION AND SECURITY ACT HR 1263 - SAFEGUARDING AMERICANS FROM EXPORTING IDENTIFICATION DATA ACT HR 4032 AMENDMENT TO IMMIGRATION AND NATIONALITITY ACT HR 1653- CONSUMER PRIVACY PROTECTION ACT OF 2005 HR 1653 - SAFEGUARDING AMERICANS FROM EXPORTING IDENTIFICATION DATA ACT HR 3140 - CONSUMER DATA SECURITY AND NOTIFICATION ACT FACTA IMPLEMENTATION ISSUES HR 3375 FINANCIAL DATA SECURITY ACT OF 2005 S 2169 - FINANCIAL DATA PROTECTION ACT OF 2005

Client expense: $883,400 · Firm income: Not reported

Government targets: Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Patent & Trademark Office (PTO), SENATE

Issues related to regulation of the mutual fund industry; privacy, data protection/breach and safeguards, including S. 1461 (Shelby), HR 3997 (House Financial Services Committee), HR 4127 (House Energy and Commerce Committee), S 1408 (Smith), S 1789 (Specter/Leahy), S 1326 (Sessions), and S 751 Feinstein; Anti-Spyware legislation, including HR 744 (Goodlatte), HR 29 (Bono), S 1004 (Allen), and S 687 (Burns); Pension reform, including HR 2830 and HR 2831 (Boehner), and S 1783 and S 1953 (Grassley), regarding retirement investment advice and ERISA exempt transactions.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Katrina credit protection; Credit card reform; ID theft-banking and financial services; HR3492 Consumer Credit Card Protection Act; S1408 Security Freeze Amendment; HR4127 Data Accountability Trust Act; S1461 Federal Housing Finance Reform Act; HR3997 Financial Data Protection Act

Client expense: $278,948 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Product Safety Commission (CPSC), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, State, Dept of (DOS)

Foreign Workers - H.R. 2899 and S. 1461 Secure America & Orderly Immigration of 2005 S. 1033/H.R. 2330

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, U.S. Trade & Development Agency (USTDA)

S 751 - NOTIFICATION OF RISK TO PERSONAL DATA ACT S 768 - COMPREHENSIVE ID THEFT PREVENTION ACT S 810 - SAFEGUARDING AMERICAN S FROM EXPORTING IDENTIFICATION ACT S 1332 - PERSONAL DATA PRIVACY AND SECURITY ACT OF 2005 S 1408 ID THEFT PREVENTION ACT S 1461 - CONSUMER IDENTITY PROTECTION AND SECURITY ACT HR 1263 - SAFEGUARDING AMERICANS FROM EXPORTING IDENTIFICATION DATA ACT HR 1653 - CONSUMER PRIVACY PROTECTION ACT OF 2005 HR 1653 - SAFEGUARDING AMERICANS FROM EXPORTING IDENTIFICATION DATA ACT HR 3140 - CONSUMER DATA SECURITY AND NOTIFICATION ACT FACTA IMPLEMENTATION ISSUES

Client expense: $637,000 · Firm income: Not reported

Government targets: Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Patent & Trademark Office (PTO), SENATE