SEAL 401(k)Savings Act

HR 677/S267- would require 401(k) plan sponsors to inform participating workers of the projected monthly income they could expect at retirement based on their current account balance. DOL proposed rules to amend the definition of fiduciary, and FAB that include Q&A30 relating to brokerage windonws HR. 1534: Amends Internal Revenue Code provisions relating to employer-established simple individual retirement accounts (IRAs) to: (1) repeal certain restrictions on rollovers from simple IRAs, (2) allow employers to elect to terminate qualified salary reduction arrangements at any time during the year, (3) repeal the enhanced 25% penalty on premature withdrawals made from simple IRAs within the first two plan years, (4) allow additional nonelective employer contributions to simple IRAs, (5) establish automatic deferral IRAs, (6) allow a transfer of unused balances in flexible spending arrangements to a qualified retirement or eligible deferred compensation plan, (7) increase the tax credit for small employer pension plan startup costs, and (8) establish multiple small employer retirement plans that provide for automatic employee contributions H.R.4049: Automatic IRA Act of 2012 - would require all employers that employ more than 10 employees, who do not sponsor a qualified retirement plan to automatically enroll their employees at 3% of pay into a payroll deduct IRA. H.R.4050: Retirement Plan Simplification and Enhancement Act of 2012 the bill would permit all required ERISA disclosures to be made available in an electronic manner (following advanced notice and with the right to opt out). H.CON.RES.101 : Expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement. S. 1020: To amend the Internal Revenue Code of 1986 to modify the rules relating to loans made from a qualified employer plan. S.1557 the Automatic IRA Act of 2011 Amends the Internal Revenue Code to: (1) require certain employers who do not maintain qualified retirement plans or arrangements to make available to their eligible employees a payroll deposit individual retirement account (IRA) arrangement (automatic IRA arrangement) which grants such employees the right to opt-out of participation, (2) require the Secretary of the Treasury to provide employers with a model notice for notifying employees of automatic IRS arrangements and to establish a program to assist employers in the implementation of such arrangements, (3) allow employers who do not have more than 100 employees a tax credit for costs associated with establishing an automatic IRA arrangement, (4) impose a penalty on employers who fail to provide eligible employees access to automatic IRA arrangements, and (5) increase the tax credit for small employer pension plan start-up costs. S. 1813: Highway Investment, Job Creation and Economic Growth Act of 2012 - defined benefit plan Funding Stabilization proposal which generates $9.5 billion in revenue. S.CON.RES.62: A concurrent resolution expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement.

Client expense: $394,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

American Taxpayer Relief Act of 2012 H.R. 8 fiscal cliff, employee benefits provisions Lifetime Income Disclosure Act H.R. 677/S. 267 Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection (Dodd-Frank) Act Burdensome Data Collection Relief Act - H.R. 1062 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption - H.R. 1573 Swaps Bailout Prevention Act - H.R. 1838 To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders - H.R. 1840 SEC Regulatory Accountability Act - H.R. 2308 Swap Execution Facility Clarification Act - H.R. 2586 Business Risk Mitigation and Price Stabilization Act of 2011 - H.R. 2682 To exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform and Consumer Protection Act - H.R. 2779 Pension Funding/Stabilization - defined benefit pension funding stabilization and related plan issues Pension Technical Modifications Act - H.R. 2656 Retirement Income Protection Act of 2011 - H.R. 3045 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act (SEAL 401 (k)) Act- H.R. 3287/S. 1020, S. 1121 Moving Ahead for Progress in the 21st Century (MAP-21) Act - S. 1813, S. 2343 - House/Senate passed version - H.R. 4348 (funding stabilization/Stop the Student Loan Interest Rate Hike Act of 2012) Retirement Savings Plan Issues Small Businesses Add Value for Employees Act of 2011 (SAVE Act) - H.R. 1534 Small Business Pension Protection Act of 2011 - H.R. 3561 Retirement Savings Security Act of 2011 - H.R. 3656 Automatic IRA Act of 2011 - S. 1557 Automatic IRA Act of 2012 - H.R. 4049 Retirement Plan Simplification and Enhancement Act - H.R. 4050 Bipartisan Concurrent Resolution (H.CON. RES. 101/S.CON.RES. 62) - tax incentives for retirement savings Worker Classification Issues Employee Misclassification Prevention Act - H.R. 3178/ Payroll Fraud Prevention Act - S. 770 Fair Playing Field Act of 2012 - H.R. 4123/S. 2145 (worker classification) Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act - S. 1289 Rebuild America Act - S. 2252 Pension modernization - The Retirement Crisis and a Plan to Solve It - USA Retirement Funds - Senate Health, Education, Labor & Pensions Committee Pension Benefit Guaranty Corporation (PBGC) - premiums, calculation of deficit and related governance issues Investment Advice - defined contribution plans, plan fees, definition of a fiduciary, electronic communication and related issues Distribution of retirement plan assets Nondiscrimination rules applicable to defined benefit (DB) plans Financial Accounting Standards Board (FASB) - retirement plans De-risking - defined benefit (DB) plans Other Issues Tax reform employee benefits issues ERISA Advisory Council 2012 Discussion Topics disability insurance & retirement stability, plan beneficiary designations Hybrid retirement plan designs implementation of the Pension Protection Act (PPA), finalization of proposed regulations Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans International benefits issues/Puerto Rican plan trust issues Domestic plan asset investment issues Regulation of money market funds Multiemployer plan issues Definition of governmental plans Distribution of retirement plan assets Nondiscrimination rules applicable to defined benefit (DB) plans Financial Accounting Standards Board (FASB) retirement plans De-risking defined benefit (DB) plans

Proposals responding to the effect of the stock market decline on retirement savings accounts. Proposals to expand retirement coverage, including proposals to mandate payroll deduction IRAs (not yet in legislative form) Proposals regarding annuitization of assets from defined contribution plans (not yet in legislative form) S 267; HR 677 - "Lifetime Income Disclosure Act" - A lifetime income disclosure shall set forth the annuity equivalent of the total benefits accrued with respect to the participant or beneficiary HR 1534 - "Save Act of 2011" - Reforms Retirement Plan System HR 774- "Senior Investor Protections Act "- To enhance penalties for violations of securities protections that involve targeting seniors Congressional activity surrounding the Department of Labor's proposed regulation to redefine "fiduciary" S. 1020- Savings Act of 2011 Savings Enhancement by alleviating leakage in 401(k) Savings Act of 2011 alleviates leakage in 401(k) plans HR 3561- Small Business Promotion Act - technical corrections and improvements to pension system H. Con. Res. 101 - "Concurrent resolution expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement" - Expresses sense of the Congress regarding tax incentives for retirement savings HR 4049 - "Automatic IRA Act of 2012" - regarding automatic IRA arrangements S. 1557 - "Automatic IRA Act of 2011" - regarding automatic IRA arrangements HR 4050 - "Retirement Plan Simplification and Enhancement Act of 2012" - To simplify and enhance qualified retirement plans HR 4348 - "The Surface Transportation Act of 2012"- defined benefit funding relief, transfers of excess pension funding assets S 2123 - "Highway Investment Job Creation & Economic Growth Act of 2012" would stretch IRA provision S 1534 - "Identity Theft & taax Fraud Prevention Act" Death master file limitations HR 3475 - "Keeping ID's Safe Act of 2011" Death master file limitations S 1121 -"Savings Enhancement by Alleviating Leakage in 401(k) Savings Act" - limits borrowng from 401(k) plans-credit insurance HR 3656 -"The Retirement Savings Security Act" - 401(k) plan loans HR 2827/S. 3620 - "Municipal Advisor Regulation" - investment advice regulation HR 6472 -"Saving for American Families Future Act of 2012" - saver's credit expansion HR 2656 - "Pensions Technical Modifications Act" - DB pensions S. Con. Res. 62 - "Concurrent resolution expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement" - Expresses sense of the Congress regarding tax incentives for retirement savings

HR 677/S267- would require 401(k) plan sponsors to inform participating workers of the projected monthly income they could expect at retirement based on their current account balance. DOL proposed rules to amend the definition of fiduciary, and FAB that include Q&A30 relating to brokerage windonws HR. 1534: Amends Internal Revenue Code provisions relating to employer-established simple individual retirement accounts (IRAs) to: (1) repeal certain restrictions on rollovers from simple IRAs, (2) allow employers to elect to terminate qualified salary reduction arrangements at any time during the year, (3) repeal the enhanced 25% penalty on premature withdrawals made from simple IRAs within the first two plan years, (4) allow additional nonelective employer contributions to simple IRAs, (5) establish automatic deferral IRAs, (6) allow a transfer of unused balances in flexible spending arrangements to a qualified retirement or eligible deferred compensation plan, (7) increase the tax credit for small employer pension plan startup costs, and (8) establish multiple small employer retirement plans that provide for automatic employee contributions H.R.4049: Automatic IRA Act of 2012 - would require all employers that employ more than 10 employees, who do not sponsor a qualified retirement plan to automatically enroll their employees at 3% of pay into a payroll deduct IRA. H.R.4050: Retirement Plan Simplification and Enhancement Act of 2012 the bill would permit all required ERISA disclosures to be made available in an electronic manner (following advanced notice and with the right to opt out). H.CON.RES.101 : Expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement. S. 1020: To amend the Internal Revenue Code of 1986 to modify the rules relating to loans made from a qualified employer plan. S.1557 the Automatic IRA Act of 2011 Amends the Internal Revenue Code to: (1) require certain employers who do not maintain qualified retirement plans or arrangements to make available to their eligible employees a payroll deposit individual retirement account (IRA) arrangement (automatic IRA arrangement) which grants such employees the right to opt-out of participation, (2) require the Secretary of the Treasury to provide employers with a model notice for notifying employees of automatic IRS arrangements and to establish a program to assist employers in the implementation of such arrangements, (3) allow employers who do not have more than 100 employees a tax credit for costs associated with establishing an automatic IRA arrangement, (4) impose a penalty on employers who fail to provide eligible employees access to automatic IRA arrangements, and (5) increase the tax credit for small employer pension plan start-up costs. S. 1813: Highway Investment, Job Creation and Economic Growth Act of 2012 - defined benefit plan Funding Stabilization proposal which generates $9.5 billion in revenue.

H.R. 677 - The Lifetime Income Disclosure Act; entire bill H.R. 1534 Small Businesses Add Value for Employees (SAVE) Act; entire bill H.R. 3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill H.R. 3561 Small Business Pension Promotion Act of 2011; entire bill H.R. 4049 Automatic IRA Act; entire bill H.R. 4050 Retirement Simplification and Enhancement Act; entire bill H.R. 4348 - Moving Ahead for Progress in the 21st Century Act; provisions relating to extension of the National Flood Insurance Program, student loans, and pension provisions S. 267 - Lifetime Income Disclosure Act; entire bill S. 1020 The Savings Enhancement by Alleviating Leakage in 401(k) Savings Act; entire bill S. 1121 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill S. 1557 Automatic IRA Act of 2011; entire bill S. 2132 Highway Investment, Job Creation, and Economic Growth Act of 2012; provisions relating to pension funding and inherited IRAs S. 2252 Rebuild America Act; entire bill Department of Labors proposed rule modifying the definition of ERISA fiduciary and its implications for the provision of advice on qualified retirement savings Department of Labors 408(b)(2) rules and accompanying Q&As as they impact 401(k) brokerage windows. Role retirement savings tax incentive play in assuring coverage of diverse workforces and long-term economic benefits

Client expense: $360,000 · Firm income: Not reported

Public Employee Pension Transparency Act H.R. 567 Lifetime Income Disclosure Act H.R. 677 Burdensome Data Collection Relief Act H.R. 1062 Small Businesses Add Value for Employees Act of 2011 (SAVE Act) H.R. 1534 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption H.R. 1573 Would repeal provision in the Dodd-Frank Wall Street Act prohibiting federal bailout of swap dealers or participants H.R. 1838 To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders H.R. 1840 SEC Regulatory Accountability Act H.R. 2308 Swap Execution Facility Clarification Act H.R. 2586 Pension Technical Modifications Act H.R. 2656 Business Risk Mitigation and Price Stabilization Act of 2011 H.R. 2682 To Exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 2779 Retirement Income Protection Act of 2011 H.R. 3045 Hardship Outlays to protect Mortgagee Equity Act of 2011 H.R. 3104 Employee Misclassification Prevention Act H.R. 3178 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Savings Act H.R. 3287 Small Business Pension Protection Act of 2011 H.R. 3561 Retirement Savings Security Act of 2011 H.R. 3656 Automatic IRA Act H.R. 4049 Retirement Plan Simplification and Enhancement Act H.R. 4050 Fair Playing Field Act of 2012 H.R. 4123 (worker classification) Moving Ahead for Progress in the 21st Century (MAP-21) Act S. 1813/ House/Senate passed version H.R. 4348 (funding stabilization) Pension Funding defined benefit pension funding stabilization, technical corrections for defined benefit pension plans, frozen defined benefit plan issues, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, , partial termination enforcement, premium relief for certain delinquent plans Retirement Security/Investment Advice - defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, plan limits, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, small business plans, lifetime income, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, tax incentives for workplace retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term care/disability policies (LTDs), disability insurance Transfer of Excess Pension Assets Bipartisan Concurrent Resolution (H.CON. RES. 101) supporting retirement savings tax incentives Nondiscrimination rules applicable to defined benefit (DB) plans Senate Lifetime Income Disclosure Act S. 267 Public Employee Pension Transparency Act S. 347 Repeal the CLASS Entitlement Act S. 720 Payroll Fraud Prevention Act S. 770 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1020 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1121 Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act S. 1289 Automatic IRA Act of 2011 S. 1557 Hardship Outlays to protect Mortgagee Equity (HOME) Act S. 1656 Moving Ahead for Progress in the 21st Century (MAP-21) Act S. 1813/ Stop the Student Loan Interest Rate Hike Act of 2012 S. 2343, Senate/House passed version H.R. 4348 (funding stabilization) Fair Playing Field Act of 2012 S. 2145 (worker classification) Rebuild America Act S. 2252 Pension modernization - The Retirement Crisis and a Plan to Solve It USA Retirement Funds Senate Health, Education, Labor & Pensions Committee Pension funding defined benefit pension funding stabilization, defined benefit funding regulations/25-Year Averages of the Segment Rate, technical corrections for defined benefit pension plans, frozen defined benefit plan issues, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Retirement Security/Investment Advice defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, plan limits, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, tax incentives for workplace retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs), disability insurance Nondiscrimination rules applicable to defined benefit (DB) plans Regulatory Retirement Report: Supporting Retirement for American Families; Lifetime Income Guidance Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563 Semi-Annual Regulatory Agendas Departments of Labor, Treasury ERISA Advisory Council 2012 Discussion Topics disability insurance & retirement stability, plan beneficiary designations Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Business conduct standards, segregation of swap collateral, pay ratio and other executive compensation disclosure issues, posting margin, stable value contracts Pension funding defined benefit pension funding stabilization, defined benefit funding stabilization regulations/25-Year Averages of the Segment Rate and lump sum valuation, adequacy of defined benefit vehicles, retirement plan designs, and tax treatment of expatriates Hybrid retirement plan designs implementation of the Pension Protection Act (PPA), finalization of proposed regulations Retirement Security/Investment advice disclosure of defined contribution plan fees under ERISA Section 408 (b) (2), plan limits, re-proposal of rule on definition of a fiduciary, pension benefit statements, amendment of abandoned plan program, ERISA claims procedures, investment selection and annuity issues, automatic/mandatory individual retirement accounts (IRAs), target date funds (TDFs) and qualified default investment alternatives (QDIAs); electronic disclosure of 401 (k) fee information, and defined benefit (DB) plans fiduciary requirements, 401 (k) participant fee disclosure regulations, in-plan Roth conversions issues RFI Electronic disclosure for employee benefit plans, electronic disclosure flexibility, longevity annuity contract regulations, partial annuity distribution regulations, income replacement Field Assistance Bulletin (FAB) 2012-02 Q & A 30 guidance on final regulations for participant-level retirement plan fee disclosure, brokerage windows, FAB 2012-02R (revision) Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Pension Benefits Guaranty Corporation (PBGC) guidance related to pension funding stabilization and premiums, premium and premium filing, submission issues, proposed regulations proposed ERISA Section 4062 (e) regulations, rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement, annual financial and actuarial reporting-ERISA Section 4010 Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Domestic plan asset investment issues International benefits issues/Puerto Rican plan trust issues Regulation of money market funds Multiemployer plan issues Public pension system issues Definition of governmental plans Worker classification issues Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans Distribution of retirement plan assets Nondiscrimination rules applicable to defined benefit (DB) plans Financial Accounting Standards Board (FASB) retirement plans De-risking defined benefit (DB) plans

Proposals responding to the effect of the stock market decline on retirement savings accounts. Proposals to expand retirement coverage, including proposals to mandate payroll deduction IRAs (not yet in legislative form) Proposals regarding annuitization of assets from defined contribution plans (not yet in legislative form) S 267; HR 677 - "Lifetime Income Disclosure Act" - A lifetime income disclosure shall set forth the annuity equivalent of the total benefits accrued with respect to the participant or beneficiary HR 1534 - "Save Act of 2011" - Reforms Retirement Plan System HR 774- "Senior Investor Protections Act "- To enhance penalties for violations of securities protections that involve targeting seniors Congressional activity surrounding the Department of Labor's proposed regulation to redefine "fiduciary" S. 1020- Savings Act of 2011 Savings Enhancement by alleviating leakage in 401(k) Savings Act of 2011 alleviates leakage in 401(k) plans HR 3561- Small Business Promotion Act - technical corrections and improvements to pension system H. Con. Res. 101 - "Concurrent resolution expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement" - Expresses sense of the Congress regarding tax incentives for retirement savings HR 4049 - "Automatic IRA Act of 2012" - regarding automatic IRA arrangements S. 1557 - "Automatic IRA Act of 2011" - regarding automatic IRA arrangements HR 4050 - "Retirement Plan Simplification and Enhancement Act of 2012" - To simplify and enhance qualified retirement plans HR 4348 - "The Surface Transportation Act of 2012"- defined benefit funding relief, transfers of excess pension funding assets S 2123 - "Highway Investment Job Creation & Economic Growth Act of 2012" would stretch IRA provision S 1534 - "Identity Theft & taax Fraud Prevention Act" Death master file limitations HR 3475 - "Keeping ID's Safe Act of 2011" Death master file limitations S 1121 -"Savings Enhancement by Alleviating Leakage in 401(k) Savings Act" - limits borrowng from 401(k) plans-credit insurance HR 3656 -"The Retirement Savings Security Act" - 401(k) plan loans HR 2827/S. 3620 - "Municipal Advisor Regulation" - investment advice regulation HR 6472 -"Saving for American Families Future Act of 2012" - saver's credit expansion HR 2656 - "Pensions Technical Modifications Act" - DB pensions

H.R. 677 - The Lifetime Income Disclosure Act; entire bill H.R. 1534 Small Businesses Add Value for Employees (SAVE) Act; entire bill H.R. 3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill H.R. 3561 Small Business Pension Promotion Act of 2011; entire bill H.R. 4049 Automatic IRA Act; entire bill H.R. 4050 Retirement Simplification and Enhancement Act; entire bill H.R. 4348 - Moving Ahead for Progress in the 21st Century Act; provisions relating to extension of the National Flood Insurance Program, student loans, and pension provisions S. 267 - Lifetime Income Disclosure Act; entire bill S. 1020 The Savings Enhancement by Alleviating Leakage in 401(k) Savings Act; entire bill S. 1121 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill S. 1557 Automatic IRA Act of 2011; entire bill S. 2132 Highway Investment, Job Creation, and Economic Growth Act of 2012; provisions relating to pension funding and inherited IRAs S. 2252 Rebuild America Act; entire bill Department of Labors proposed rule modifying the definition of ERISA fiduciary and its implications for the provision of advice on qualified retirement savings Department of Labor's 408(b)(2) rules and accompanying Q&As as they impact 401(k) brokerage windows Role retirement savings tax incentives play in assuring coverage of diverse workforces and long-term economic benefits

Client expense: $310,000 · Firm income: Not reported

HR 677/S267- would require 401(k) plan sponsors to inform participating workers of the projected monthly income they could expect at retirement based on their current account balance. DOL proposed rules to amend the definition of fiduciary, and FAB that include Q&A30 relating to brokerage windonws HR. 1534: Amends Internal Revenue Code provisions relating to employer-established simple individual retirement accounts (IRAs) to: (1) repeal certain restrictions on rollovers from simple IRAs, (2) allow employers to elect to terminate qualified salary reduction arrangements at any time during the year, (3) repeal the enhanced 25% penalty on premature withdrawals made from simple IRAs within the first two plan years, (4) allow additional nonelective employer contributions to simple IRAs, (5) establish automatic deferral IRAs, (6) allow a transfer of unused balances in flexible spending arrangements to a qualified retirement or eligible deferred compensation plan, (7) increase the tax credit for small employer pension plan startup costs, and (8) establish multiple small employer retirement plans that provide for automatic employee contributions H.R.4049: Automatic IRA Act of 2012 - would require all employers that employ more than 10 employees, who do not sponsor a qualified retirement plan to automatically enroll their employees at 3% of pay into a payroll deduct IRA. H.R.4050: Retirement Plan Simplification and Enhancement Act of 2012 the bill would permit all required ERISA disclosures to be made available in an electronic manner (following advanced notice and with the right to opt out). H.CON.RES.101 : Expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement. S. 1020: To amend the Internal Revenue Code of 1986 to modify the rules relating to loans made from a qualified employer plan. S.1557 the Automatic IRA Act of 2011 Amends the Internal Revenue Code to: (1) require certain employers who do not maintain qualified retirement plans or arrangements to make available to their eligible employees a payroll deposit individual retirement account (IRA) arrangement (automatic IRA arrangement) which grants such employees the right to opt-out of participation, (2) require the Secretary of the Treasury to provide employers with a model notice for notifying employees of automatic IRS arrangements and to establish a program to assist employers in the implementation of such arrangements, (3) allow employers who do not have more than 100 employees a tax credit for costs associated with establishing an automatic IRA arrangement, (4) impose a penalty on employers who fail to provide eligible employees access to automatic IRA arrangements, and (5) increase the tax credit for small employer pension plan start-up costs. S. 1813: Highway Investment, Job Creation and Economic Growth Act of 2012 - defined benefit plan Funding Stabilization proposal which generates $9.5 billion in revenue.

Proposals responding to the effect of the stock market decline on retirement savings accounts. Proposals to expand retirement coverage, including proposals to mandate payroll deduction IRAs (not yet in legislative form) Proposals regarding annuitization of assets from defined contribution plans (not yet in legislative form) S 267; HR 677 - "Lifetime Income Disclosure Act" - A lifetime income disclosure shall set forth the annuity equivalent of the total benefits accrued with respect to the participant or beneficiary HR 1534 - "Save Act of 2011" - Reforms Retirement Plan System HR 774- "Senior Investor Protections Act "- To enhance penalties for violations of securities protections that involve targeting seniors Congressional activity surrounding the Department of Labor's proposed regulation to redefine "fiduciary" S. 1020- Savings Act of 2011 Savings Enhancement by alleviating leakage in 401(k) Savings Act of 2011 alleviates leakage in 401(k) plans HR 3561- Small Business Promotion Act - technical corrections and improvements to pension system H. Con. Res. 101 - "Concurrent resolution expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement" - Expresses sense of the Congress regarding tax incentives for retirement savings HR 4049 - "Automatic IRA Act of 2012" - regarding automatic IRA arrangements S. 1557 - "Automatic IRA Act of 2011" - regarding automatic IRA arrangements HR 4050 - "Retirement Plan Simplification and Enhancement Act of 2012" - To simplify and enhance qualified retirement plans HR 4348 - "The Surface Transportation Act of 2012"- defined benefit funding relief, transfers of excess pension funding assets S 2123 - "Highway Investment Job Creation & Economic Growth Act of 2012" would stretch IRA provision S 1534 - "Identity Theft & taax Fraud Prevention Act" Death master file limitations HR 3475 - "Keeping ID's Safe Act of 2011" Death master file limitations S 1121 -"Savings Enhancement by Alleviating Leakage in 401(k) Savings Act" - limits borrowng from 401(k) plans-credit insurance HR 3656 -"The Retirement Savings Security Act" - 401(k) plan loans

Public Employee Pension Transparency Act H.R. 567 Lifetime Income Disclosure Act H.R. 677 Burdensome Data Collection Relief Act H.R. 1062 Small Businesses Add Value for Employees Act of 2011 (SAVE Act) H.R. 1534 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption H.R. 1573 Would repeal provision in the Dodd-Frank Wall Street Act prohibiting federal bailout of swap dealers or participants H.R. 1838 To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders H.R. 1840 SEC Regulatory Accountability Act H.R. 2308 Swap Execution Facility Clarification Act H.R. 2586 Pension Technical Modifications Act H.R. 2656 Business Risk Mitigation and Price Stabilization Act of 2011 H.R. 2682 To Exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 2779 Retirement Income Protection Act of 2011 H.R. 3045 Hardship Outlays to protect Mortgagee Equity Act of 2011 H.R. 3104 Employee Misclassification Prevention Act H.R. 3178 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Savings Act H.R. 3287 Small Business Pension Protection Act of 2011 H.R. 3561 Retirement Savings Security Act of 2011 H.R. 3656 Automatic IRA Act H.R. 4049 Retirement Plan Simplification and Enhancement Act H.R. 4050 Fair Playing Field Act of 2012 H.R. 4123 (worker classification) Moving Ahead for Progress in the 21st Century (MAP-21) Act S. 1813/ House/Senate passed version H.R. 4348 (funding stabilization) Fiscal Year 2012 & 2013 Budget Proposals budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues, worker classification issues FY2013 GOP Budget Proposal Path to Prosperity Financial Services Reform implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Public Law No: 111-203 - pay ratio and other executive compensation disclosure issues, business conduct standards, segregation of swap collateral, posting margin Pension Funding defined benefit pension funding stabilization, technical corrections for defined benefit pension plans, frozen defined benefit plan issues, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, , partial termination enforcement, premium relief for certain delinquent plans Retirement Security/Investment Advice - defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, plan limits, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, small business plans, lifetime income, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, tax incentives for workplace retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term care/disability policies (LTDs), disability insurance Transfer of Excess Pension Assets Bipartisan Concurrent Resolution (H.CON. RES. 101) supporting retirement savings tax incentives Joint Select Committee on Deficit Reduction impact on employee benefits provisions PBGC premiums, contribution limits to defined contribution plans and worker classification issues Lifetime Income Disclosure Act S. 267 Public Employee Pension Transparency Act S. 347 Repeal the CLASS Entitlement Act S. 720 Payroll Fraud Prevention Act S. 770 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1020 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1121 Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act S. 1289 Automatic IRA Act of 2011 S. 1557 Hardship Outlays to protect Mortgagee Equity (HOME) Act S. 1656 Moving Ahead for Progress in the 21st Century (MAP-21) Act S. 1813/ Stop the Student Loan Interest Rate Hike Act of 2012 S. 2343, Senate/House passed version H.R. 4348 (funding stabilization) Fair Playing Field Act of 2012 S. 2145 (worker classification) Rebuild America Act S. 2252 Fiscal Year 2012 & 2013 Budget Proposal budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues, worker classification issues Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 pay ratio and other executive compensation disclosure issues, business conduct standards, segregation of swap collateral, posting margin Pension funding defined benefit pension funding stabilization, technical corrections for defined benefit pension plans, frozen defined benefit plan issues, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Retirement Security/Investment Advice defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, plan limits, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, tax incentives for workplace retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs), disability insurance Joint Select Committee on Deficit Reduction -impact on employee benefits provisions, PBGC premiums, contribution limits to defined contribution plans and worker classification issues Transfer of Excess Pension Assets Equal Employment Opportunity Commission (EEOC) Final regulations on disparate impact, potential effects on retirement plans Retirement Report: Supporting Retirement for American Families; Lifetime Income Guidance Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563 Semi-Annual Regulatory Agendas Departments of Labor, Treasury ERISA Advisory Council 2012 Discussion Topics Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Business conduct standards, segregation of swap collateral, pay ratio and other executive compensation disclosure issues, posting margin, stable value contracts Pension funding defined benefit pension funding stabilization, adequacy of defined benefit vehicles, retirement plan designs, and tax treatment of expatriates Hybrid retirement plan designs implementation of the Pension Protection Act (PPA) Retirement Security/Investment advice disclosure of defined contribution plan fees under ERISA Section 408 (b) (2), plan limits, re-proposal of rule on definition of a fiduciary, pension benefit statements, amendment of abandoned plan program, ERISA claims procedures, investment selection and annuity issues, automatic/mandatory individual retirement accounts (IRAs), target date funds (TDFs) and qualified default investment alternatives (QDIAs); electronic disclosure of 401 (k) fee information, and defined benefit (DB) plans fiduciary requirements, 401 (k) participant fee disclosure regulations, in-plan Roth conversions issues RFI Electronic disclosure for employee benefit plans, electronic disclosure flexibility, longevity annuity contract regulations, partial annuity distribution regulations, income replacement Field Assistance Bulletin (FAB) 2012-02 Q & A guidance on final regulations for participant-level retirement plan fee disclosure, brokerage windows Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Pension Benefits Guaranty Corporation (PBGC) - premium and premium filing, submission issues, proposed regulations proposed ERISA Section 4062 (e) regulations, rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Domestic plan asset investment issues International benefits issues/Puerto Rican plan trust issues Regulation of money market funds Multiemployer plan issues Public pension system issues Definition of governmental plans Worker classification issues Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans Distribution of retirement plan assets

Proposals responding to the effect of the stock market decline on retirement savings accounts. Proposals to expand retirement coverage, including proposals to mandate payroll deduction IRAs (not yet in legislative form) Proposals regarding annuitization of assets from defined contribution plans (not yet in legislative form) S 267; HR 677 - "Lifetime Income Disclosure Act" - A lifetime income disclosure shall set forth the annuity equivalent of the total benefits accrued with respect to the participant or beneficiary HR 1534 - "Save Act of 2011" - Reforms Retirement Plan System HR 774 "Senior Investor Protections Act "- To enhance penalties for violations of securities protections that involve targeting seniors Congressional activity surrounding the Department of Labor's proposed regulation to redefine "fiduciary" S. 1020 Savings Act of 2011 Savings Enhancement by alleviating leakage in 401(k) Savings Act of 2011 alleviates leakage in 401(k) plans HR 3561 Small Business Promotion Act - technical corrections and improvements to pension system H. Con. Res. 101 - "Concurrent resolution expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement" - Expresses sense of the Congress regarding tax incentives for retirement savings HR 4049 - "Automatic IRA Act of 2012" - regarding automatic IRA arrangements S. 1557 - "Automatic IRA Act of 2011" - regarding automatic IRA arrangements HR 4050 - "Retirement Plan Simplification and Enhancement Act of 2012" - To simplify and enhance qualified retirement plans

Client expense: $1,108,900 · Firm income: Not reported

H.R. 677 - The Lifetime Income Disclosure Act; entire bill H.R. 1534 Small Businesses Add Value for Employees (SAVE) Act; entire bill H.R. 3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill H.R. 3561 Small Business Pension Promotion Act of 2011; entire bill H.R. 4049 Automatic IRA Act; entire bill H.R. 4050 Retirement Simplification and Enhancement Act; entire bill S. 267 - Lifetime Income Disclosure Act; entire bill S. 1020 The Savings Enhancement by Alleviating Leakage in 401(k) Savings Act; entire bill S. 1120 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill S. 1557 Automatic IRA Act of 2011; entire bill S. 1813 The Highway Investment, Job Creation and Economic Growth Act; provisions relating to pension funding and inherited IRAs S. 2132 Highway Investment, Job Creation, and Economic Growth Act of 2012; provisions relating to pension funding and inherited IRAs S. 2252 Rebuild America Act; entire bill - Department of Labors proposed rule modifying the definition of ERISA fiduciary and its implications for the provision of advice on qualified retirement savings

Client expense: $410,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 677/S267- would require 401(k) plan sponsors to inform participating workers of the projected monthly income they could expect at retirement based on their current account balance. DOL proposed rules to amend the definition of fiduciary. HR. 1534: Amends Internal Revenue Code provisions relating to employer-established simple individual retirement accounts (IRAs) to: (1) repeal certain restrictions on rollovers from simple IRAs, (2) allow employers to elect to terminate qualified salary reduction arrangements at any time during the year, (3) repeal the enhanced 25% penalty on premature withdrawals made from simple IRAs within the first two plan years, (4) allow additional nonelective employer contributions to simple IRAs, (5) establish automatic deferral IRAs, (6) allow a transfer of unused balances in flexible spending arrangements to a qualified retirement or eligible deferred compensation plan, (7) increase the tax credit for small employer pension plan startup costs, and (8) establish multiple small employer retirement plans that provide for automatic employee contributions H.R.4049: Automatic IRA Act of 2012 - would require all employers that employ more than 10 employees, who do not sponsor a qualified retirement plan to automatically enroll their employees at 3% of pay into a payroll deduct IRA. H.R.4050: Retirement Plan Simplification and Enhancement Act of 2012 the bill would permit all required ERISA disclosures to be made available in an electronic manner (following advanced notice and with the right to opt out). H.CON.RES.101 : Expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement. S. 1020: To amend the Internal Revenue Code of 1986 to modify the rules relating to loans made from a qualified employer plan. S. 1121: Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 or the SEAL 401(k) Act - Amends the Internal Revenue Code, with respect to loans made from a qualified employer plan, to: (1) extend the period for repayment of loans if a plan terminates or a plan participant becomes unemployed, and (2) prohibit plans from allowing the use of credit cards or similar arrangements to access loan amounts. S. 1232: a bill to modify the definition of fiduciary under the Employee Retirement Income Security Act (ERISA) of 1974 to exclude appraisers of employee stock ownership plans. S.1557 the Automatic IRA Act of 2011 Amends the Internal Revenue Code to: (1) require certain employers who do not maintain qualified retirement plans or arrangements to make available to their eligible employees a payroll deposit individual retirement account (IRA) arrangement (automatic IRA arrangement) which grants such employees the right to opt-out of participation, (2) require the Secretary of the Treasury to provide employers with a model notice for notifying employees of automatic IRS arrangements and to establish a program to assist employers in the implementation of such arrangements, (3) allow employers who do not have more than 100 employees a tax credit for costs associated with establishing an automatic IRA arrangement, (4) impose a penalty on employers who fail to provide eligible employees access to automatic IRA arrangements, and (5) increase the tax credit for small employer pension plan start-up costs. S. 1813: Highway Investment, Job Creation and Economic Growth Act of 2012 - defined benefit plan Funding Stabilization proposal which generates $9.5 billion in revenue. S.2252: Rebuild America Act -- to rebuild the American middle class by creating jobs, investing in our future, building opportunity for working families, and restoring balance to the tax code.

HR 677/S267- would require 401(k) plan sponsors to inform participating workers of the projected monthly income they could expect at retirement based on their current account balance. DOL proposed rules to amend the definition of fiduciary. HR. 1534: Amends Internal Revenue Code provisions relating to employer-established simple individual retirement accounts (IRAs) to: (1) repeal certain restrictions on rollovers from simple IRAs, (2) allow employers to elect to terminate qualified salary reduction arrangements at any time during the year, (3) repeal the enhanced 25% penalty on premature withdrawals made from simple IRAs within the first two plan years, (4) allow additional nonelective employer contributions to simple IRAs, (5) establish automatic deferral IRAs, (6) allow a transfer of unused balances in flexible spending arrangements to a qualified retirement or eligible deferred compensation plan, (7) increase the tax credit for small employer pension plan startup costs, and (8) establish multiple small employer retirement plans that provide for automatic employee contributions H.R.4049: Automatic IRA Act of 2012 - would require all employers that employ more than 10 employees, who do not sponsor a qualified retirement plan to automatically enroll their employees at 3% of pay into a payroll deduct IRA. H.R.4050: Retirement Plan Simplification and Enhancement Act of 2012 the bill would permit all required ERISA disclosures to be made available in an electronic manner (following advanced notice and with the right to opt out). H.CON.RES.101 : Expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement. S. 1020: To amend the Internal Revenue Code of 1986 to modify the rules relating to loans made from a qualified employer plan. S. 1121: Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 or the SEAL 401(k) Act - Amends the Internal Revenue Code, with respect to loans made from a qualified employer plan, to: (1) extend the period for repayment of loans if a plan terminates or a plan participant becomes unemployed, and (2) prohibit plans from allowing the use of credit cards or similar arrangements to access loan amounts. S. 1232: a bill to modify the definition of fiduciary under the Employee Retirement Income Security Act (ERISA) of 1974 to exclude appraisers of employee stock ownership plans. S.1557 the Automatic IRA Act of 2011 Amends the Internal Revenue Code to: (1) require certain employers who do not maintain qualified retirement plans or arrangements to make available to their eligible employees a payroll deposit individual retirement account (IRA) arrangement (automatic IRA arrangement) which grants such employees the right to opt-out of participation, (2) require the Secretary of the Treasury to provide employers with a model notice for notifying employees of automatic IRS arrangements and to establish a program to assist employers in the implementation of such arrangements, (3) allow employers who do not have more than 100 employees a tax credit for costs associated with establishing an automatic IRA arrangement, (4) impose a penalty on employers who fail to provide eligible employees access to automatic IRA arrangements, and (5) increase the tax credit for small employer pension plan start-up costs. S. 1813: Highway Investment, Job Creation and Economic Growth Act of 2012 - defined benefit plan Funding Stabilization proposal which generates $9.5 billion in revenue. S.2252: Rebuild America Act -- to rebuild the American middle class by creating jobs, investing in our future, building opportunity for working families, and restoring balance to the tax code.

HR 677/S267- would require 401(k) plan sponsors to inform participating workers of the projected monthly income they could expect at retirement based on their current account balance. DOL proposed rules to amend the definition of fiduciary. HR. 1534: Amends Internal Revenue Code provisions relating to employer-established simple individual retirement accounts (IRAs) to: (1) repeal certain restrictions on rollovers from simple IRAs, (2) allow employers to elect to terminate qualified salary reduction arrangements at any time during the year, (3) repeal the enhanced 25% penalty on premature withdrawals made from simple IRAs within the first two plan years, (4) allow additional nonelective employer contributions to simple IRAs, (5) establish automatic deferral IRAs, (6) allow a transfer of unused balances in flexible spending arrangements to a qualified retirement or eligible deferred compensation plan, (7) increase the tax credit for small employer pension plan startup costs, and (8) establish multiple small employer retirement plans that provide for automatic employee contributions H.R.4049: Automatic IRA Act of 2012 - would require all employers that employ more than 10 employees, who do not sponsor a qualified retirement plan to automatically enroll their employees at 3% of pay into a payroll deduct IRA. H.R.4050: Retirement Plan Simplification and Enhancement Act of 2012 the bill would permit all required ERISA disclosures to be made available in an electronic manner (following advanced notice and with the right to opt out). H.CON.RES.101 : Expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement. S. 1020: To amend the Internal Revenue Code of 1986 to modify the rules relating to loans made from a qualified employer plan. S. 1121: Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 or the SEAL 401(k) Act - Amends the Internal Revenue Code, with respect to loans made from a qualified employer plan, to: (1) extend the period for repayment of loans if a plan terminates or a plan participant becomes unemployed, and (2) prohibit plans from allowing the use of credit cards or similar arrangements to access loan amounts. S. 1232: a bill to modify the definition of fiduciary under the Employee Retirement Income Security Act (ERISA) of 1974 to exclude appraisers of employee stock ownership plans. S.1557 the Automatic IRA Act of 2011 Amends the Internal Revenue Code to: (1) require certain employers who do not maintain qualified retirement plans or arrangements to make available to their eligible employees a payroll deposit individual retirement account (IRA) arrangement (automatic IRA arrangement) which grants such employees the right to opt-out of participation, (2) require the Secretary of the Treasury to provide employers with a model notice for notifying employees of automatic IRS arrangements and to establish a program to assist employers in the implementation of such arrangements, (3) allow employers who do not have more than 100 employees a tax credit for costs associated with establishing an automatic IRA arrangement, (4) impose a penalty on employers who fail to provide eligible employees access to automatic IRA arrangements, and (5) increase the tax credit for small employer pension plan start-up costs. S. 1813: Highway Investment, Job Creation and Economic Growth Act of 2012 - defined benefit plan Funding Stabilization proposal which generates $9.5 billion in revenue. S.2252: Rebuild America Act -- to rebuild the American middle class by creating jobs, investing in our future, building opportunity for working families, and restoring balance to the tax code.

Public Employee Pension Transparency Act H.R. 567 Lifetime Income Disclosure Act H.R. 677 Burdensome Data Collection Relief Act H.R. 1062 Fiscal Responsibility and Retirement Security Act of 2011 (To repeal the CLASS Program) H.R. Small Businesses Add Value for Employees Act of 2011 (SAVE Act) H.R. 1534 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption H.R. 1573 Would repeal provision in the Dodd-Frank Wall Street Act prohibiting federal bailout of swap dealers or participants H.R. 1838 To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders H.R. 1840 SEC Regulatory Accountability Act H.R. 2308 Swap Execution Facility Clarification Act H.R. 2586 Pension Technical Modifications Act H.R. 2656 Business Risk Mitigation and Price Stabilization Act of 2011 H.R. 2682 To Exempt inter-affiliate swaps from certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 2779 Retirement Income Protection Act of 2011 H.R. 3045 Hardship Outlays to protect Mortgagee Equity Act of 2011 H.R. 3104 Employee Misclassification Prevention Act H.R. 3178 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Savings Act H.R. 3287 Small Business Pension Protection Act of 2011 H.R. 3561 Automatic IRA Act H.R. 4049 Retirement Plan Simplification and Enhancement Act H.R. 4050 Fiscal Year 2012 & 2013 Budget Proposals budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues, worker classification issues FY2013 GOP Budget Proposal Path to Prosperity Financial Services Reform implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Public Law No: 111-203 - pay ratio and other executive compensation disclosure issues, business conduct standards, segregation of swap collateral, posting margin Pension Funding pension funding stabilization, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, , partial termination enforcement, premium relief for certain delinquent plans Retirement Security/Investment Advice - defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, small business plans, lifetime income, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs), disability insurance Joint Select Committee on Deficit Reduction -impact on employee benefits provisions, PBGC premiums, contribution limits to defined contribution plans and worker classification issues Retirement Report: Supporting Retirement for American Families; Lifetime Income Guidance Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563 Semi-Annual Regulatory Agendas Departments of Labor, Treasury ERISA Advisory Council 2012 Discussion Topics Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Business conduct standards, segregation of swap collateral, pay ratio and other executive compensation disclosure issues, posting margin, stable value contracts Pension funding pension funding stabilization, adequacy of defined benefit vehicles, retirement plan designs, and tax treatment of expatriates Hybrid retirement plan designs implementation of the Pension Protection Act (PPA) Retirement Security/Investment advice disclosure of defined contribution plan fees under ERISA Section 408 (b) (2) , re-proposal of rule on definition of a fiduciary, pension benefit statement, amendment of abandoned plan program, ERISA claims procedures, investment selection and annuity issues, automatic/mandatory individual retirement accounts (IRAs), target date funds (TDFs) and qualified default investment alternatives (QDIAs); electronic disclosure of 401 (k) fee information, and defined benefit (DB) plans fiduciary requirements, 401 (k) participant fee disclosure regulations, in-plan Roth conversions issues RFI Electronic disclosure for employee benefit plans, electronic disclosure flexibility Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Pension Benefits Guaranty Corporation (PBGC) - premium and premium filing, submission issues, proposed regulations proposed ERISA Section 4062 (e) regulations, rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Domestic plan asset investment issues International benefits issues/Puerto Rican plan trust issues Multiemployer plan issues Public pension system issues Plan audit issues Worker classification issues Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans Distribution of retirement plan assets The Highway Investment, Job Creation, and Economic Growth Act of 2012 S. 1813 potential impacts to required minimum distribution (MRD) rules, Section 420 Transfers, Mass transit parity Lifetime Income Disclosure Act S. 267 Public Employee Pension Transparency Act S. 347 Repeal the CLASS Entitlement Act S. 720 Payroll Fraud Prevention Act S. 770 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1020 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 (SEAL Act) S. 1121 Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act S. 1289 Automatic IRA Act of 2011 S. 1557 Hardship Outlays to protect Mortgagee Equity (HOME) Act S. 1656 Fiscal Year 2012 & 2013 Budget Proposal budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues, worker classification issues Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 pay ratio and other executive compensation disclosure issues, business conduct standards, segregation of swap collateral, posting margin Pension funding pension funding stabilization, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, hedge fund/private equity investments Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Retirement Security/Investment Advice defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs), disability insurance Joint Select Committee on Deficit Reduction -impact on employee benefits provisions, PBGC premiums, contribution limits to defined contribution plans and worker classification issues

HR 677/S267- would require 401(k) plan sponsors to inform participating workers of the projected monthly income they could expect at retirement based on their current account balance. DOL proposed rules to amend the definition of fiduciary. HR. 1534: Amends Internal Revenue Code provisions relating to employer-established simple individual retirement accounts (IRAs) to: (1) repeal certain restrictions on rollovers from simple IRAs, (2) allow employers to elect to terminate qualified salary reduction arrangements at any time during the year, (3) repeal the enhanced 25% penalty on premature withdrawals made from simple IRAs within the first two plan years, (4) allow additional nonelective employer contributions to simple IRAs, (5) establish automatic deferral IRAs, (6) allow a transfer of unused balances in flexible spending arrangements to a qualified retirement or eligible deferred compensation plan, (7) increase the tax credit for small employer pension plan startup costs, and (8) establish multiple small employer retirement plans that provide for automatic employee contributions H.R.4049: Automatic IRA Act of 2012 - would require all employers that employ more than 10 employees, who do not sponsor a qualified retirement plan to automatically enroll their employees at 3% of pay into a payroll deduct IRA. H.R.4050: Retirement Plan Simplification and Enhancement Act of 2012 the bill would permit all required ERISA disclosures to be made available in an electronic manner (following advanced notice and with the right to opt out). H.CON.RES.101 : Expressing the sense of the Congress that our current tax incentives for retirement savings provide important benefits to Americans to help plan for a financially secure retirement. S. 1020: To amend the Internal Revenue Code of 1986 to modify the rules relating to loans made from a qualified employer plan. S. 1121: Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 or the SEAL 401(k) Act - Amends the Internal Revenue Code, with respect to loans made from a qualified employer plan, to: (1) extend the period for repayment of loans if a plan terminates or a plan participant becomes unemployed, and (2) prohibit plans from allowing the use of credit cards or similar arrangements to access loan amounts. S. 1232: a bill to modify the definition of fiduciary under the Employee Retirement Income Security Act (ERISA) of 1974 to exclude appraisers of employee stock ownership plans. S.1557 the Automatic IRA Act of 2011 Amends the Internal Revenue Code to: (1) require certain employers who do not maintain qualified retirement plans or arrangements to make available to their eligible employees a payroll deposit individual retirement account (IRA) arrangement (automatic IRA arrangement) which grants such employees the right to opt-out of participation, (2) require the Secretary of the Treasury to provide employers with a model notice for notifying employees of automatic IRS arrangements and to establish a program to assist employers in the implementation of such arrangements, (3) allow employers who do not have more than 100 employees a tax credit for costs associated with establishing an automatic IRA arrangement, (4) impose a penalty on employers who fail to provide eligible employees access to automatic IRA arrangements, and (5) increase the tax credit for small employer pension plan start-up costs. S. 1813: Highway Investment, Job Creation and Economic Growth Act of 2012 - defined benefit plan Funding Stabilization proposal which generates $9.5 billion in revenue. S.2252: Rebuild America Act -- to rebuild the American middle class by creating jobs, investing in our future, building opportunity for working families, and restoring balance to the tax code.

H.R. 677 - The Lifetime Income Disclosure Act; entire bill H.R. 1534 Small Businesses Add Value for Employees (SAVE) Act; entire bill H.R. 3287 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill H.R. 3561 Small Business Pension Promotion Act of 2011; entire bill S. 267 - Lifetime Income Disclosure Act; entire bill S. 1020 The Savings Enhancement by Alleviating Leakage in 401(k) Savings Act; entire bill S. 1120 Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEAL) Act; entire bill S. 1557 Automatic IRA Act of 2011; entire bill Department of Labors proposed rule modifying the definition of ERISA fiduciary and its implications for the provision of advice on qualified retirement savings

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

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE

HR 677/S267- would require 401(k) plam sponsors to inform participating workers of the projected monthly income they could expect at retirement based on their current account balance. DOL proposed rules to amend the definition of fiduciary. HR. 1534: Amends Internal Revenue Code provisions relating to employer-established simple individual retirement accounts (IRAs) to: (1) repeal certain restrictions on rollovers from simple IRAs, (2) allow employers to elect to terminate qualified salary reduction arrangements at any time during the year, (3) repeal the enhanced 25% penalty on premature withdrawals made from simple IRAs within the first two plan years, (4) allow additional nonelective employer contributions to simple IRAs, (5) establish automatic deferral IRAs, (6) allow a transfer of unused balances in flexible spending arrangements to a qualified retirement or eligible deferred compensation plan, (7) increase the tax credit for small employer pension plan startup costs, and (8) establish multiple small employer retirement plans that provide for automatic employee contributions S. 1020: To amend the Internal Revenue Code of 1986 to modify the rules relating to loans made from a qualified employer plan. S. 1121: Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 or the SEAL 401(k) Act - Amends the Internal Revenue Code, with respect to loans made from a qualified employer plan, to: (1) extend the period for repayment of loans if a plan terminates or a plan participant becomes unemployed, and (2) prohibit plans from allowing the use of credit cards or similar arrangements to access loan amounts. S. 1232: a bill to modify the definition of fiduciary under the Employee Retirement Income Security Act (ERISA) of 1974 to exclude appraisers of employee stock ownership plans. S.1557 the Automatic IRA Act of 2011 Amends the Internal Revenue Code to: (1) require certain employers who do not maintain qualified retirement plans or arrangements to make available to their eligible employees a payroll deposit individual retirement account (IRA) arrangement (automatic IRA arrangement) which grants such employees the right to opt-out of participation, (2) require the Secretary of the Treasury to provide employers with a model notice for notifying employees of automatic IRS arrangements and to establish a program to assist employers in the implementation of such arrangements, (3) allow employers who do not have more than 100 employees a tax credit for costs associated with establishing an automatic IRA arrangement, (4) impose a penalty on employers who fail to provide eligible employees access to automatic IRA arrangements, and (5) increase the tax credit for small employer pension plan start-up costs.

Public Employee Pension Transparency Act - H.R. 567 Lifetime Income Disclosure Act - H.R. 677 Burdensome Data Collection Relief Act - H.R. 1062 Fiscal Responsibility and Retirement Security Act of 2011 (To repeal the CLASS Program) - H.R. 1173 Small Businesses Add Value for Employees Act of 2011 (SAVE Act) H.R. 1534 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption H.R. 1573 Would repeal provision in the Dodd-Frank Wall Street Act prohibiting federal bailout of swap dealers or participants H.R. 1838 To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders H.R. 1840 SEC Regulatory Accountability Act H.R. 2308 Swap Execution Facility Clarification Act H.R. 2586 Pension Technical Modifications Act H.R. 2656 Business Risk Mitigation and Price Stabilization Act of 2011 H.R. 2682 Amends the Commodity Exchange Act and the Securities Exchange Act of 1934 H.R. 2779 Retirement Income Protection Act of 2011 H.R. 3045 Hardship Outlays to protect Mortgagee Equity Act of 2011 H.R. 3104 Employee Misclassification Prevention Act H.R. 3178 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Savings Act H.R. 3287 Small Business Pension Protection Act of 2011 H.R. 3561 Fiscal Year 2012 Budget Proposal budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 H.R. 4 Public Law No: 112-009 Financial Services Reform implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Public Law No: 111-203 Pension Funding - additional funding relief and reform, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, , partial termination enforcement Retirement Security - defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs) National Commission on Fiscal Responsibility and Reform implications for benefits Joint Select Committee on Deficit Reduction impact on employee benefits provisions PBGC premiums, contribution limits to defined contribution plans and worker classification issues The American Jobs Act Lifetime Income Disclosure Act S. 267 Public Employee Pension Transparency Act S. 347 Repeal the CLASS Entitlement Act S. 720 Payroll Fraud Prevention Act S. 770 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Act) S. 1020 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Act) S. 1121 Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act S. 1289 Automatic IRA Act of 2011 S. 1557 Hardship Outlays to protect Mortgagee Equity (HOME) Act S. 1656 National Commission on Fiscal Responsibility and Reform implications for benefits Fiscal Year 2012 Budget Proposal budgetary impacts of health and retirement entitlement programs, PBGC insurance, premium issues Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Pension funding additional funding relief and reform, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Retirement Security defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, electronic disclosure guidance, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs) National Commission on Fiscal Responsibility and Reform implications for benefits Joint Select Committee on Deficit Reduction - impact on employee benefits provisions PBGC premiums, contribution limits to defined contribution plans and worker classification issues The American Jobs Act Joint Select Committee on Deficit Reduction impact on employee benefits provisions PBGC premiums, worker classification issues Presidential Advisory Council on Financial Capability Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563 2011-2012 Agency Guidance Priority List Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 proposed regulations related to swap trades; process for review of swaps for mandatory clearing; provisions common to registered entities, legal entity identification for financial contracts; swap data recordkeeping and reporting requirements; real-time reporting of swap transaction data; reporting, recordkeeping, and daily trading records requirements for swap dealers and major swap participants; unique counterparty identifiers; definition of swap dealer, security-based swap dealer, major swap participant, major security-based swap participant, eligible contract participant; swap data repository (SDR); business conduct standards for swap dealers and major swap participants with counterparties; transparency and accountability of derivatives market; regulation of over-the-counter swaps transactions; stable value contracts. Pension funding - adequacy of defined benefit vehicles, retirement plan designs, and tax treatment of expatriates Hybrid retirement plan designs implementation of the Pension Protection Act (PPA) Investment advice re-proposal of rule on definition of fiduciary, adequacy of defined contribution vehicles, investment selection and annuity issues, automatic/mandatory individual retirement accounts (IRAs), proposed regulations regarding target date funds (TDFs) and qualified default investment alternatives (QDIAs); electronic disclosure of 401 (k) fee information, disclosure for defined contribution (DC) and defined benefit (DB) plans and service providers -ERISA Section 408 (b) (2), Fiduciary requirements 401 (k) participant fee disclosure regulations, in-plan Roth conversions issues RFI Electronic disclosure for employee benefit plans Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Pension Benefits Guaranty Corporation (PBGC) - premium and premium filing, submission issues, proposed regulations ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues, re-characterization of contributions, partial termination enforcement Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Domestic plan asset investment issues International benefits issues/Puerto Rican plan trust issues Multiemployer plan issues Public pension system issues Plan audit issues Worker classification issues Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans Plan distribution issues

H.R. 567/S. 347, Public Employee Pension Transparency Act S. 267, Lifetime Income Disclosure Act S. 1020, Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEALS) Act of 2011 The Pension Protection Act of 2006 - Reform of funding rules for employer-provided retirement plans and amendments to the Employee Retirement Income Security Act of 1974 Tax Reform - Reform to tax incentives pertaining to private retirement plans ERISA Section 4062(e) - Reporting of and Liability for Certain Substantial Cessations of Operations - Asking Congress to ensure that the Pension Benefit Guaranty Corporation does not continue to enforce as current law a proposed regulation under ERISA section 4062(e) that the agency has stated will be reconsidered pursuant to Executive Order 13563 on Improving Regulation and Regulatory Review Regulatory activity relating to: cash balance plans; notice requirements; multiemployer Plan Accounting - The Financial Accounting Standards Board proposes to require multiemployer plan sponsors to include additional disclosures on their financial statements; definition of a Fiduciary - the Department of Labor proposes amend the definition of a fiduciary under ERISA to more broadly define the circumstances under which a person or entity is considered to be a fiduciary when giving investment advice to an employee benefit plan or a plan's participants; electronic disclosure of benefit notices; stable value funds Various issues relating to issues relating to the implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act (P.L. 111-203); PBGC Premiums - the Administration and Congress are discussing changes to the structure and amount of premiums that defined benefit plan sponsors must pay to the Pension Benefit Guaranty Corporation

Client expense: $14,250,000 · Firm income: Not reported

Proposals responding to the effect of the stock market decline on retirement savings accounts. Proposals to expand retirement coverage, including proposals to mandate payroll deduction IRAs (not yet in legislative form) Proposals regarding annuitization of assets from defined contribution plans (not yet in legislative form) S 267; HR 677 - "Lifetime Income Disclosure Act" - A lifetime income disclosure shall set forth the annuity equivalent of the total benefits accrued with respect to the participant or beneficiary HR 1534 - "Save Act of 2011" - Reforms Retirement Plan System HR 774 "Senior Investor Protections Act "- To enhance penalties for violations of securities protections that involve targeting seniors Congressional activity surrounding the Department of Labor's proposed regulation to redefine "fiduciary" S. 1020 Savings Act of 2011 Savings Enhancement by alleviating leakage in 401(k) Savings Act of 2011 alleviates leakage in 401(k) plans HR 3561 Small Business Promotion Act - technical corrections and improvements to pension system

Client expense: $610,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office

H.R. 677 - The Lifetime Income Disclosure Act; entire bill H.R. 1534 Small Businesses Add Value for Employees (SAVE) Act; entire bill S. 267 - Lifetime Income Disclosure Act; entire bill S. 1020 The Savings Enhancement by Alleviating Leakage in 401(k) Savings Act; entire bill S. 1557 Automatic IRA Act of 2011; entire bill Department of Labors proposed rule modifying the definition of ERISA fiduciary and its implications for the provision of advice on qualified retirement savings Deficit Reduction: importance and value of existing tax incentives designed to promote long-term savings (both qualified and non-qualified) and insurance coverage protection; transitional considerations associated with tax law modifications

Client expense: $400,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Treasury, Dept of, White House Office

H.R.1322, Earned Retiree Healthcare Benefits Protection Act of 2011 S. 267, Lifetime Income Disclosure Act (requiring plan sponsors to include the annuity equivalent of the participants 401(k) balance) S. 1020, Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEALS) Act of 2011 (restricts certain activities in retirement plans that encourage participants to use savings before retirement) H.R. 567/S. 347, Public Employee Pension Transparency Act (requiring greater disclosure of the funding status of state and local government retirement plans) The Pension Protection Act of 2006 --reform of funding rules for employer-provided retirement plans and amendments to the Employee Retirement Income Security Act of 1974. Work on regulatory activity relating to cash balance plans and notice requirements. Regulatory activity relating to: cash balance plans; notice requirements; Multiemployer Plan Accounting - the Financial Accounting Standards Board proposes to require multiemployer plan sponsors to include additional disclosures on their financial statements; definition of a Fiduciary - the Department of Labor proposes amend the definition of a fiduciary under ERISA to more broadly define the circumstances under which a person or entity is considered to be a fiduciary when giving investment advice to an employee benefit plan or a plan's participants; electronic disclosure of benefit notices; stable value funds; issues relating to the implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act; PBGC Premiums - the Administration and Congress are discussing changes to the structure and amount of premiums that defined benefit plan sponsors must pay to the Pension Benefit Guaranty Corporation; reform to tax incentives pertaining to private retirement plans Daniel Hillenbrand - Covered Official Positions: Intern - Office of Congressman John Kline

House Public Employee Pension Transparency Act - H.R. 567 Lifetime Income Disclosure Act - H.R. 677 Burdensome Data Collection Relief Act - H.R. 1062 Fiscal Responsibility and Retirement Security Act of 2011 (To repeal the CLASS Program) H.R. 1173 Small Businesses Add Value for Employees Act of 2011 (SAVE Act) H.R. 1534 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption H.R. 1573 To Improve Consideration by the Commodity Futures Trading Commission of the Costs and Benefits of its Regulations and Orders H.R. 1840 SEC Regulatory Accountability Act H.R. 2308 Swap Execution Facility Clarification Act H.R. 2586 Pension Technical Modifications Act H.R. 2656 Retirement Income Protection Act of 2011 H.R. 3045 Fiscal Year 2012 Budget Proposal budgetary impacts of retirement entitlement programs - PBGC insurance, premium issues Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 H.R. 4 Public Law No: 112-009 Financial Services Reform implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Public Law No: 111-203 Pension Funding - additional funding relief and reform, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues Retirement Security - defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs) National Commission on Fiscal Responsibility and Reform implications for benefits Joint Select Committee on Deficit Reduction impact on employee benefits provisions PBGC premiums, worker classification issues The American Jobs Act Senate Lifetime Income Disclosure Act S. 267 Public Employee Pension Transparency Act S. 347 Repeal the CLASS Entitlement Act S. 720 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Act) S. 1020 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Act) S. 1121 Taxpayer Advocacy and Government Accountability Promotion (TAX GAP) Act S. 1289 Automatic IRA Act of 2011 S. 1557 National Commission on Fiscal Responsibility and Reform implications for benefits Fiscal Year 2012 Budget Proposal budgetary impacts of health and retirement entitlement programs, PBGC insurance, premium issues Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Pension funding additional funding relief and reform, technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions Pension Benefit Guaranty Corporation (PBGC) calculation of deficit, proposed premium increase for plan sponsors, premium submission issues, ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues Retirement Security defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, electronic communication, re-proposal on definition of a fiduciary, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures, incentives for retirement plans, tax reform, phased retirement, financial literacy, nonqualified deferred compensation, executive compensation, multiple employer plan issues, long-term disability policies (LTDs) National Commission on Fiscal Responsibility and Reform implications for benefits Joint Select Committee on Deficit Reduction impact on employee benefits provisions The American Jobs Act Regulatory White House - Joint Select Committee on Deficit Reduction impact on employee benefits provisions PBGC premiums, worker classification issues Presidential Advisory Council on Financial Capability Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563 2011-2012 Agency Guidance Priority List Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 proposed regulations related to swap trades; process for review of swaps for mandatory clearing; provisions common to registered entities, legal entity identification for financial contracts; swap data recordkeeping and reporting requirements; real-time reporting of swap transaction data; reporting, recordkeeping, and daily trading records requirements for swap dealers and major swap participants; unique counterparty identifiers; definition of swap dealer, security-based swap dealer, major swap participant, major security-based swap participant, eligible contract participant; swap data repository (SDR); business conduct standards for swap dealers and major swap participants with counterparties; transparency and accountability of derivatives market; regulation of over-the-counter swaps transactions; stable value contracts Pension funding relief - adequacy of defined benefit vehicles, retirement plan designs, and tax treatment of expatriates Hybrid retirement plan designs implementation of the Pension Protection Act (PPA) Investment advice re-proposal of rule on definition of fiduciary, adequacy of defined contribution vehicles, investment selection and annuity issues, automatic/mandatory individual retirement accounts (IRAs), proposed regulations regarding target date funds (TDFs) and qualified default investment alternatives (QDIAs); electronic disclosure of 401 (k) fee information, disclosure for defined contribution (DC) and defined benefit (DB) plans and service providers -ERISA Section 408 (b) (2), Fiduciary requirements 401 (k) participant fee disclosure regulations, in-plan Roth conversions issues RFI Electronic disclosure for employee benefit plans Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Pension Benefits Guaranty Corporation (PBGC) - premium and premium filing, submission issues, proposed regulations ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Domestic plan asset investment issues Puerto Rican plan trust issues Multiemployer plan issues Public pension system issues Plan audit issues Worker classification issues Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans

Proposals responding to the effect of the stock market decline on retirement savings accounts. Proposals to expand retirement coverage, including proposals to mandate payroll deduction IRAs (not yet in legislative form) Proposals regarding annuitization of assets from defined contribution plans (not yet in legislative form) S 267; HR 677 - "Lifetime Income Disclosure Act" - A lifetime income disclosure shall set forth the annuity equivalent of the total benefits accrued with respect to the participant or beneficiary HR 1534 - "Save Act of 2011" - Reforms Retirement Plan System HR 774 "Senior Investor Protections Act "- To enhance penalties for violations of securities protections that involve targeting seniors Congressional activity surrounding the Department of Labor's proposed regulation to redefine "fiduciary" S. 1020/ S. 1021 Savings Enhancement by alleviating leakage in 401(k) Savings Act of 2011 alleviates leakage in 401(k) plans

Client expense: $702,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office

H.R. 677 - The Lifetime Income Disclosure Act; entire bill H.R. 1534 Small Businesses Add Value for Employees (SAVE) Act; entire bill S. 267 - Lifetime Income Disclosure Act; entire bill S. 1020 Savings Enhancement by Alleviating Leakage in 401(k) Savings Act; entire bill Department of Labors proposed rule modifying the definition of ERISA fiduciary

Client expense: $450,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, White House Office

H.R. 677/S. 267, which would require 401(k) plan sponsors to inform participating workers of the projected monthly income they could expect at retirement based on their current account balance. DOL proposed regulation to amend the definition of fiduciary HR. 1534: Amends Internal Revenue Code provisions relating to employer-established simple individual retirement accounts (IRAs) to: (1) repeal certain restrictions on rollovers from simple IRAs, (2) allow employers to elect to terminate qualified salary reduction arrangements at any time during the year, (3) repeal the enhanced 25% penalty on premature withdrawals made from simple IRAs within the first two plan years, (4) allow additional nonelective employer contributions to simple IRAs, (5) establish automatic deferral IRAs, (6) allow a transfer of unused balances in flexible spending arrangements to a qualified retirement or eligible deferred compensation plan, (7) increase the tax credit for small employer pension plan startup costs, and (8) establish multiple small employer retirement plans that provide for automatic employee contributions S. 1020: To amend the Internal Revenue Code of 1986 to modify the rules relating to loans made from a qualified employer plan. S. 1121: Savings Enhancement by Alleviating Leakage in 401(k) Savings Act of 2011 or the SEAL 401(k) Act - Amends the Internal Revenue Code, with respect to loans made from a qualified employer plan, to: (1) extend the period for repayment of loans if a plan terminates or a plan participant becomes unemployed, and (2) prohibit plans from allowing the use of credit cards or similar arrangements to access loan amounts. S. 1232: a bill to modify the definition of fiduciary under the Employee Retirement Income Security Act (ERISA) of 1974 to exclude appraisers of employee stock ownership plans.

Client expense: $550,000 · Firm income: Not reported

H.R. 567, Public Employee Pension Transparency Act S. 267, Lifetime Income Disclosure Act S. 347, Public Employee Pension Transparency Act S. 1020, Savings Enhancement by Alleviating Leakage in 401(k) Savings (SEALS) Act of 2011 The Pension Protection Act of 2006 - Reform of funding rules for employer-provided retirement plans and amendments to the Employee Retirement Income Security Act of 1974. Work on regulatory activity relating to cash balance plans and notice requirements. Various issues relating to Pension Benefit Guaranty Corporation (PBGC) premiums; pension and retirement issues, healthcare, tax, and financial services issues; Multiemployer Plan Accounting - The Financial Accounting Standards Board proposes to require multiemployer plan sponsors to include additional disclosures on their financial statements; Definition of a Fiduciary - the Department of Labor proposes amend the definition of a fiduciary under ERISA to more broadly define the circumstances under which a person or entity is considered to be a fiduciary when giving investment advice to an employee benefit plan or a plan's participants; PBGC Premiums - The Administration and Congress are discussing changes to the structure and amount of premiums that defined benefit plan sponsors must pay to the Pension Benefit Guaranty Corporation; issues relating to the implementation of the Dodd-Frank Wall Street Reform and Consumer Protect Act; Congressional oversight of Employee Benefits Security Administration

Client expense: $9,040,000 · Firm income: Not reported

Public Employee Pension Transparency Act H.R. 567 Lifetime Income Disclosure Act H.R. 677 Burdensome Data Collection Relief Act H.R. 1062 Fiscal Responsibility and Retirement Security Act of 2011 (To repeal the CLASS Program) H.R. 1173 To Facilitate implementation of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption H.R. 1573 Small Businesses Add Value for Employees Act of 2011 (SAVE Act) H.R. 1534 National Commission on Fiscal Responsibility and Reform implications for benefits Fiscal Year 2012 Budget Proposal budgetary impacts of retirement entitlement programs; PBGC insurance, premium issues Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 H.R. 4 Public Law No: 112-009 Financial Services Reform implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act - Public Law No: 111-203 Pension Funding - additional funding relief and technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, PBGC calculation of deficit, proposed premium increase for plan sponsors, premium submission issues Retirement Security nonqualified deferred compensation, executive compensation, defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, proposed definition of fiduciary, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures for retirement plans, tax reform, phased retirement, financial literacy, long-term disability policies (LTDs) Senate Lifetime Income Disclosure Act S. 267 Public Employee Pension Transparency Act S. 347 Repeal the CLASS Entitlement Act S. 720 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Act) S. 1020 Savings Enhancement by Alleviating Leakage in 401 (k) Savings Act of 2011 (SEAL 401 (k) Act) S. 1121 National Commission on Fiscal Responsibility and Reform implications for benefits Fiscal Year 2012 Budget Proposal budgetary impacts of health and retirement entitlement programs, PBGC insurance, premium issues Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Pension funding additional funding relief and technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, PBGC calculation of deficit, proposed premium increase for plan sponsors, premium submission issues Retirement Security nonqualified deferred compensation, executive compensation, defined contribution plan issues, 401 (k) plans: design and operation, automatic IRAs, investment advice, proposed definition of fiduciary, investment selection (target date funds), the Savers Credit, lifetime income issues, nondiscrimination rules for retirement plans, plan loans, tax expenditures for retirement plans, tax reform, phased retirement, financial literacy, long-term disability policies (LTDs) Regulatory Request for Information (RFI) streamlining regulations to reduce regulatory burdens - Improving Regulation and Regulatory Review Executive Order 13563 2011-2012 Agency Guidance Priority List Financial Services Reform implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 proposed regulations related to swap trades; process for review of swaps for mandatory clearing; provisions common to registered entities, legal entity identification for financial contracts; swap data recordkeeping and reporting requirements; real-time; reporting of swap transaction data; reporting, recordkeeping, and daily trading records requirements for swap dealers and major swap participants; unique counterparty identifiers; definition of swap dealer, security-based swap dealer, major swap participant, major security-based swap participant, eligible contract participant; swap data repository (SDR); business conduct standards for swap dealers and major swap participants with counterparties; transparency and accountability of derivatives market; regulation of over-the-counter swaps transactions; Pension funding relief - adequacy of defined benefit vehicles, retirement plan designs, and tax treatment of expatriates Hybrid retirement plan designs implementation of the Pension Protection Act (PPA) Investment advice proposed definition of Fiduciary, adequacy of defined contribution vehicles, investment selection and annuity issues, automatic/mandatory individual retirement accounts (IRAs), proposed regulations regarding target date funds (TDFs) and qualified default investment alternatives (QDIAs) Disclosure for defined contribution (DC) and defined benefit (DB) plans and service providers -ERISA Section 408 (b) (2), Fiduciary requirements 401 (k) participant fee disclosure regulations, in-plan Roth conversions issues RFI Electronic disclosure for employee benefit plans Health care provider compensation Internal Revenue Code Section 162 (m) (6) performance-based compensation Pension Benefits Guaranty Corporation (PBGC) - premium and premium submission issues, proposed regulations ERISA Section 4062 (e), rules for companies in bankruptcy, investment strategy and governance issues Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) International Accounting Standards Board (IASB) accounting rules for pensions and other post-employment benefits Domestic plan asset investment issues Puerto Rican plan trust issues Multiemployer plan issues Public pension system issues Plan audit issues Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans