Retirement Security Preservation Act of 2014

Retirement Plan Simplification and Enhancement Act of 2013 (H.R. 2117), provisions related to nondiscrimination testing; Retirement Security Preservation Act of 2014 (S. 2855), all provisions; To amend the nondiscrimination provisions of the Internal Revenue Code of 1986 to protect older, longer service participants.(H.R. 5381), all provisions; A bill to amend the Employee Retirement Income Security Act of 1974 to clarify the definition of substantial cessation of operations.(S. 2511), all provisions. Issues related to PBGC premium increases.

Client expense: $1,850,000 · Firm income: Not reported

Government targets: Central Intelligence Agency (CIA), Commerce, Dept of (DOC), Defense Intelligence Agency (DIA), Defense Security Cooperation Agency (DSCA), Defense, Dept of (DOD), Federal Aviation Administration (FAA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Natl Aeronautics & Space Administration (NASA), Natl Geospatial Intelligence Agency, Natl Oceanic & Atmospheric Administration (NOAA), Natl Security Agency (NSA), SENATE, State, Dept of (DOS), Treasury, Dept of

H.R. 83, Consolidated and Further Continuing Appropriations Act, 2015 H.R. 5381, To amend the nondiscrimination provisions of the Internal Revenue Code of 1986 to protect older, longer service participants H.R. 5771, Tax Increase Prevention Act of 2014, including provisions relating to multiemployer pension provisions under the Pension Protection Act of 2006 S. 2511, A bill to amend the Employee Retirement Income Security Act of 1974 to clarify the definition of substantial cessation of operations S. 2855, Retirement Security Preservation Act of 2014 Proposed Regulations issued by the Department of Labor under ERISA section 408(b)(2) pertaining to plan fee disclosures (79 Fed. Reg. 13,949-13,962, March 12, 2014) Various issues relating to potential changes to the definition of a fiduciary under the Employee Retirement Income Security Act (P.L. 93-604); Pension Benefit Guaranty Corporation, including enforcement activity pertaining to ERISA section 4062(e)(the substantial cessation of operations) and regulations issued on de-risking activity; Department of Treasury, including mortality table issued by the Society of Actuaries; ensuring tax incentives are maintained for retirement plans during discussion of tax reform

Client expense: $21,250,000 · Firm income: Not reported

Administration Proposed FY 2015 Budget MyRA proposal Cap on retirement savings Tax Incentives - limitation on itemized deductions and exclusions affecting retirement savings Defined Benefit Plan Issues Pension funding stabilization Mortality Tables De-Risking methods Preserving Americas Transit and Highways Act (PATH) of 2014 - pension funding stabilization (Senate Consolidated and Further Continuing Appropriations Act, 2015 - H.R. 83/Public Law No: 113-235, pension provisions Highway and Transportation Funding Act - H.R. 5021 (House) PBGC premiums A bill to clarify the definition of substantial cessation of operations under ERISA Section 4062 (e) - S. 2511 Retirement Security Preservation Act, non-discrimination provisions - S. 2855/H.R. 5381 Late retirement actuarial equivalence Pension Protection Act definition of liquidity shortfall Tax Increase Prevention Act, employee benefit plan provisions - H.R. 5771/ Public Law No: 113-295 (tax extenders; Achieving a Better Life Experience (ABLE) Act of 2013 - S. 313/H.R. 647) Defined contribution plan issues Automatic enrollment, automatic escalation Plan fees; Brokerage windows Investment advice to retirement plan participants, DOL definition of fiduciary Roth 401(k)s and Roth IRAs Electronic disclosure of retirement plan information, fees and distribution notices to participants Secure Annuities for Employee (SAFE) Retirement Act of 2013 - S. 1270 Retirement Plan Simplification And Enhancement Act of 2013 - H.R. 2117 Lifetime Income Disclosure Act - S. 1145/H.R. 2171 Retirement Security Act of 2014 - S. 1970/H.R. 4376 The Universal, Secure, and Adaptable (USA) Retirement Funds Act - S. 1979 21st Century Worker Tax Cut Act - S. 2162 - 162 m, (executive compensation) Tax Reform - employer-sponsored retirement plans Tax Reform Act of 2014 - H.R. 1 Comprehensive Tax Reform for 2015 and Beyond - Republican Staff, Committee on Finance, United States Senate Other Issues Hybrid retirement plans -Treasury Department finalization of proposed regulations & legislation Executive compensation - pay for performance, timing of taxation, substantial risk of forfeiture, Internal Revenue Code Sec. 409A, sec. 953(b) of Dodd-Frank (pay ratio provision) Derivatives issues (Dodd-Frank impact on retirement plan investments) Financial Accounting Standards Board (FASB) accounting rules for pensions and other post-employment benefits Foreign Account Taxpayer Compliance Act (FATCA) - exemption for foreign retirement plans Puerto Rico retirement plan regulation Regulation of Money Market Funds Multiemployer pension plan issues ESOP dividend deduction Disability plan automatic enrollment Inherited retirement plans including IRAs and tax treatment Defense of Marriage Act (DOMA), U.S. Supreme Court case - regulatory implementation issues related to retirement plan administration Retirement plan access proposals

Proposals related to expansion of SIMPLE IRAs, establishment of discretionary payroll deduction IRAs and creation of new qualified retirement plans for small business. Proposals relating to defined benefit plan funding. Issues related to regulations addressing liability for partial termination of defined benefit plans. Issues related to tax incentives for retirement savings and DOL fee disclosure proposals. H.R. 2117, Retirement Plan Simplification Act.Retirement recommendations contained in the final report of the National Commission on Fiscal Responsibility and Reform. Proposals related to stemming leakage from retirement plans through reform of plan loan rules. Proposals related to stable value investment offerings in defined contribution plans. Proposals related to phased retirement. Proposals to increase PBGC premiums. Proposals related to retirement target date funds. Issues related to the Department of Labor's proposed regulation defining fiduciary for investment advice purposes. Proposals and regulations related to cash balance, pension equity, and other hybrid pension plans. Issues related to PBGC collections and PBGC disclosure issues. Proposals related to electronic disclosure of information under ERISA. Proposals regarding compliance of retirement plans. FASB pension accounting. S. 1979, USA Retirement Act. Issues related to use of brokerage windows in defined contribution plans. Proposals to reform the multiple employer plan rules. Proposals to modify required minimum distribution rules. Proposals that would modify limits on retirement plan contributions. S. 1270, SAFE Retirement Act. Proposals related to stretch IRAs, including S. 953, The Student Loan Affordability Act. S. 1970, Retirement Security Act. Retirement provisions in the President's FY 2015 budget. Issues related to access to death master file. S. 2540, Patriot Employee Tax Credit Act. H. R. 5021, Highway and Transportation Funding Act. S. 2855, Retirement Security Preservation Act. H. R. 5381, to amend the nondiscrimination provisions to protect older, longer service employees. Issues related to government issued mortality tables. H.R. 83, Consolidated and Further Continuing Appropriations Act. H.R. 5771, Tax Increase Prevention Act.

Normal retirement age proposals, including Preserving America's Transit and Highways Act. Proposals related to increased PBGC premiums. Proposals related to plan funding. Proposals to facilitate new growth of pension plans. Proposals to reform the multiple employer plan rules. S. 1270, SAFE Retirement Act. H.R. 5381, to preserve the nondiscrimination provisions to protect older, longer service participants. S. 2855, Retirment Security Preservation Act. H.R. 83, Consolidated and Further ContinuingAppropriations Act.

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

Government targets: HOUSE OF REPRESENTATIVES, Pension Benefit Guaranty Corporation (PBGC), SENATE

Normal retirement age proposals, including Preserving America's Transit and Highways Act. Proposals related to increased PBGC premiums. Proposals related to plan funding. Proposals to facilitate new growth of pension plans. Proposals to reform the multiple employer plan rules. S. 1270, SAFE Retirement Act. H.R. 5381, to preserve the nondiscrimination provisions to protect older, longer service participants. S. 2855, Retirment Security Preservation Act. H.R. 83, Consolidated and Further ContinuingAppropriations Act.

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

Government targets: HOUSE OF REPRESENTATIVES, Pension Benefit Guaranty Corporation (PBGC), SENATE

Retirement plans in tax reform debate; Nondiscrimination testing in pension plans H.R.5381 and S.2855; Preserving the tax treatment of retirement savings; Multiemployer defined benefit pension plan reform; ERISA Sec.4062(e) enforcement S.2511

Client expense: $109,613 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 5381, To Amend the Nondiscrimination provisions of the Internal Revenue Code of 1986 to protect older, longer service participants (entire bill) S. 2855, Retirement Security Preservation Act of 2014 (entire bill) Treasury Notice 2014-5 (changes) Pension Benefit Guarantee Corporation Premiums (no bill)

Client expense: $1,320,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Environmental Protection Agency (EPA), Executive Office of the President (EOP), Export-Import Bank of the United States (EXIM Bank), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Security Council (NSC), SENATE, Treasury, Dept of, U.S. Agency for International Development (USAID), U.S. Trade Representative (USTR)

Retirement Plan Simplification and Enhancement Act of 2013 (H.R. 2117), provisions related to nondiscrimination testing; Retirement Security Preservation Act of 2014 (S. 2855), all provisions; To amend the nondiscrimination provisions of the Internal Revenue Code of 1986 to protect older, longer service participants.(H.R. 5381), all provisions; A bill to amend the Employee Retirement Income Security Act of 1974 to clarify the definition of substantial cessation of operations.(S. 2511), all provisions. Issues related to PBGC premium increases.

Client expense: $1,410,000 · Firm income: Not reported

Government targets: Central Intelligence Agency (CIA), Commerce, Dept of (DOC), Defense Intelligence Agency (DIA), Defense Security Cooperation Agency (DSCA), Defense, Dept of (DOD), Export-Import Bank of the United States (EXIM Bank), Federal Aviation Administration (FAA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Natl Aeronautics & Space Administration (NASA), Natl Geospatial Intelligence Agency, Natl Oceanic & Atmospheric Administration (NOAA), Natl Security Agency (NSA), SENATE, State, Dept of (DOS), Treasury, Dept of

H.R. 5381, To amend the nondiscrimination provisions of the Internal Revenue Code of 1986 to protect older, longer service participants S. 1970, Retirement Security Act of 2014 S. 2511, A bill to amend the Employee Retirement Income Security Act of 1974 to clarify the definition of substantial cessation of operations S. 2855, Retirement Security Preservation Act of 2014 Regulations issued by the Department of Labor under ERISA section 408(b)(2) pertaining to plan fee disclosures (79 Fed. Reg. 13,949-13,962, March 12, 2014) Various issues relating to potential changes to the definition of a fiduciary under the Employee Retirement Income Security Act (P.L. 93-604); Pension Benefit Guaranty Corporation: comprehensive reform, opposition to premium increases, enforcement activity pertaining to ERISA section 4062(e)(the substantial cessation of operations); comprehensive funding reform for multi-employer pension plans

Client expense: $28,350,000 · Firm income: Not reported

The association monitors and reacts to policy concepts that may impact its ability to continue offering its high quality RetirementSecurity Plans to members, their employees, and the association staff at affordable rates and on reasonable terms and conditions. During the reporting period, the association focused on the following introduced bills: S.2260 - Expiring Provisions Improvement Reform and Efficiency (EXPIRE) Act - sections pertaining to retirement plans. S.2855 - Retirement Security Preservation Act of 2014 - all sections. H.R.5021 - Highway and Transportation Funding Act - sections on Preserving America's Transit and Highways (PATH) Act.

Client expense: $120,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), HOUSE OF REPRESENTATIVES, SENATE

Proposals related to expansion of SIMPLE IRAs, establishment of discretionary payroll deduction IRAs and creation of new qualified retirement plans for small business. Proposals relating to defined benefit plan funding. Issues related to regulations addressing liability for partial termination of defined benefit plans. Issues related to tax incentives for retirement savings and DOL fee disclosure proposals. H.R. 2117, Retirement Plan Simplification Act.Retirement recommendations contained in the final report of the National Commission on Fiscal Responsibility and Reform. Proposals related to stemming leakage from retirement plans through reform of plan loan rules. Proposals related to stable value investment offerings in defined contribution plans. Proposals related to phased retirement. Proposals to increase PBGC premiums. Proposals related to retirement target date funds. Issues related to the Department of Labor's proposed regulation defining fiduciary for investment advice purposes. Proposals and regulations related to cash balance, pension equity, and other hybrid pension plans. Issues related to PBGC collections and PBGC disclosure issues. Proposals related to electronic disclosure of information under ERISA. Proposals regarding compliance of retirement plans. FASB pension accounting. S. 1979, USA Retirement Act. Issues related to use of brokerage windows in defined contribution plans. Proposals to reform the multiple employer plan rules. Proposals to modify required minimum distribution rules. Proposals that would modify limits on retirement plan contributions. S. 1270, SAFE Retirement Act. Proposals related to stretch IRAs, including S. 953, The Student Loan Affordability Act. S. 1970, Retirement Security Act. Retirement provisions in the President's FY 2015 budget. Issues related to access to death master file. S. 2540, Patriot Employee Tax Credit Act. H. R. 5021, Highway and Transportation Funding Act. S. 2855, Retirement Security Preservation Act. H. R. 5381, to amend the nondiscrimination provisions to protect older, longer service employees. Issues related to government issued mortality tables.

S. 606: Shrinking Emergency Account Losses Act of 2013 - 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. DOL and SEC proposed rules to amend the definition of fiduciary.HR 2117: Retirement Plan Simplification and Enhancement Act of 2013 - Amends the Internal Revenue Code (IRC) to repeal the 10% cap on the qualified percentage of an employee's compensation as the standard for an employer's contribution to an automatic cash or deferred contribution arrangement under the alternative method for meeting nondiscrimination requirements. HR 2374: Retail Investor Protection Act of 2013 - Amends the Securities Exchange Act of 1934 to provide protections for retail customers and for other purposes. Also defines the circumstances under which an individual is considered a fiduciary. H.R.2171/S.1145: Lifetime Income Disclosure Act-Amends the Employee Retirement Income Security Act of 1974 (ERISA) to require the quarterly pension benefit statement furnished to a participant or beneficiary with the right to direct the investment of assets in his or her account under an individual account plan to include a lifetime income disclosure at least once during any 12-month period. H.R.5381/S.2855: Amends the Internal Revenue Code, with respect to nondiscrimination requirements for tax-exempt employee pension, profit-sharing, and stock bonus plans, to include protections for older, longer service participants in such plans, including the grandfathering of such participants under defined benefit plans. S. 1270: SAFE Retirement Act-A bill to amend the Internal Revenue Code of 1986 to provide for reform of public and private pension plans. S. 1970: Retiremetn Security Act-Retirement Security act of 2013-provides enhancements to the existing defined contributions system and multiple employer plans. S.1979: USA Retirement Funds Act-A bill that proposes the creation of a new type of private-run retirement plan that combines attributes of defined benefit and defined contribution plans.

Normal retirement age proposals, including Preserving America's Transit and Highways Act. Proposals related to increased PBGC premiums. Proposals related to plan funding. Proposals to facilitate new growth of pension plans. Proposals to reform the multiple employer plan rules. S. 1270, SAFE Retirement Act. H.R. 5381, to preserve the nondiscrimination provisions to protect older, longer service participants. S. 2855, Retirment Security Preservation Act.

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Normal retirement age proposals, including Preserving America's Transit and Highways Act. Proposals related to increased PBGC premiums. Proposals related to plan funding. Proposals to facilitate new growth of pension plans. Proposals to reform the multiple employer plan rules. S. 1270, SAFE Retirement Act. H.R. 5381, to preserve the nondiscrimination provisions to protect older, longer service participants. S. 2855, Retirment Security Preservation Act.

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Administration Proposed FY 2015 Budget MyRA proposal Lifetime cap on retirement savings Tax Incentives - limitation on itemized deductions and exclusions affecting retirement savingsDefined Benefit Plan Issues Pension funding stabilization Mortality Tables De-Risking methods Preserving Americas Transit and Highways Act (PATH) of 2014 pension funding stabilization (Senate) Highway and Transportation Funding Act H.R. 5021 (House) PBGC premiums ERISA 4062(e) A bill to clarify the definition of substantial cessation of operations under ERISA Section 4062 (e) S. 2511 Retirement Security Preservation Act S. 2855 To amend the nondiscrimination provisions of the Internal Revenue Code of 1986 to protect older, longer service participants H.R. 5381 Late retirement actuarial equivalence Pension Protection Act definition of liquidity shortfall Tax Extenders Defined contribution plan issues Plan fees; Brokerage windows Investment advice to retirement plan participants, DOL definition of fiduciary Roth 401(k)s and Roth IRAs Electronic disclosure of retirement plan information, fees and distribution notices to participants Tax Reform Act of 2014 comprehensive tax reform discussion draft proposed changes to employee benefits tax policy Secure Annuities for Employee (SAFE) Retirement Act of 2013 S. 1270 Lifetime Income Disclosure Act S. 1145/H.R. 2171 Retirement Security Act of 2014 S. 1970/H.R. 4376 The Universal, Secure, and Adaptable (USA) Retirement Funds Act S. 1979 21st Century Worker Tax Cut Act S. 2162 162 m, (executive compensation) Achieving a Better Life Experience (ABLE) Act of 2013 S. 313/H.R. 647 Tax Extenders Other Issues Hybrid retirement plans Treasury Department finalization of proposed regulations & legislation Executive compensation pay for performance, timing of taxation, substantial risk of forfeiture, Internal Revenue Code Sec. 409A, sec. 953(b) of Dodd-Frank (pay ratio provision) Derivatives issues (Dodd-Frank impact on retirement plan investments) Financial Accounting Standards Board (FASB) accounting rules for pensions and other post-employment benefits Foreign Account Taxpayer Compliance Act (FATCA) exemption for foreign retirement plans Puerto Rico retirement plan regulation Regulation of Money Market Funds Multiemployer pension plan issues ESOP dividend deduction Disability plan automatic enrollment Inherited retirement plans including IRAs and tax treatment Defense of Marriage Act (DOMA), U.S. Supreme Court case regulatory implementation issues related to retirement plan administration