J JUDGE

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

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

S. 418, Military Personnel Financial Services Act S. 2169, Financial Data Protection Act Congressional Issues: Retirement plan expansion; Investment advice; Basel II; Privacy of customer financial information. ERISA modernization Executive Branch Issues: Coordination of SEC and banking regulatory examinations; Financial privacy rules; Regulations promulgating provisions of Gramm-Leach-Bliley Act, particularly provisions on financial privacy and functional regulation issues; Straight-through processing; H.R. 1224, Business Checking Freedom Act; HR 2830, Pension Protection Act S 1332, Personal Data Privacy Act S. 751, Notification of Risk to Personal Data Act

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

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

Bills: S. 1337, Personal Data Privacy Act; S. 751, Notification of Risk to Personal Data Act; S. 2169, Financial Data Protection Act; S. 2169, Financial Data Protection Act. Congressional Issues: Privacy of customer financial information; Unsolicited electronic mail; Business continuity planning; Protecting information security. Executive Branch Issues: Straight-through processing, privacy of customer financial information; Unsolicited electronic mail; Business continuity planning; Protecting information security; Internet securities trading, including day trading and suitability; Electronic payments to broker-dealers; Mutual fund late trading, market timing, revenue sharing, and differential compensation issues; Business Continuity Planning.

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

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

Bills: HR 1500, Investment Tax Simplification Act; HR 1417, Extension of Subpart F Exemption for Active Financing Income; HR 819, Retirement Security for Life Act; HR 3, Transportation Equity Act; S. 732, Safe, Accountable, Flexible, and Efficient Transportation Equity Act; S. 7, Jobs and Growth Tax Relief Act; HR 809 (Permanence of individual income tax rates fro capital gains and dividends); HR 4297, Tax Relief Extension Reconciliation Act of 2005; S. 2020, Tax Relief Act of 2005; H.Con.Res.95, Budget FY2006 Appropriations Resolution; S.Con.Res.18, Budget FY2006 Appropriations Resolution; S. 1159.IS, A bill to amend the Internal Revenue Code of 1986 to permanently extend subpart F exemption for active financing; HR 2471, Economic Development Act of 2005; S 1524, To repeal the sunset on the reduction of capital gains rates for individuals and on the taxation of dividends of individuals at capital gain rates HR 4297, Tax Reconciliation; HR 5367, S 2414, Simplification Through Additional Reporting Tax Act HR 809, S. 1524, Dividend Permanence; S. 1159, HR 1417, permanently extend the subpart F exemption for active financing; S. 2766, Defense Authorization (revenue offset for contingent convertible debt); S. 2020, Tax Relief Act. Congressional Issues: Integration of the corporate and individual income taxes; Reduced taxation of corporate earnings and dividend income; Treatment of payments in lieu of dividends under reduced dividend rates; Treatment of foreign distributions under reduced dividend rates; Capital gains reductions; Permanent reforms of Subpart F with respect to the active financial services income of financial services firms; Proposals to change IRC Section 163(j) (limiting interest deductions of subsidiaries of foreign companies); International tax rules concerning foreign tax credits (interest allocation rules, financial services income basket as “base case” basket for credits relating to permanent tax base differences, 10/50 companies, overall domestic loss); Exclusion for individuals of an amount of capital gains distributions from mutual funds; Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; Reform of Subpart F more generally, territorial tax systems generally; Changes to IRC Section 956 (deemed repatriation); Changes to IRC Section 904(g) (resourcing rules); Relief of double taxation on global dealing operations; Valuation of securities for purposes of mark-to-market tax rules (IRC Section 475); Due date for providing information returns to payees; Electronic provision of information returns to payees; Changes to IRC Section 162(f) (deductibility of settlement payments); Changes to IRC Section 163(l) (disallowance of certain interest payments); Changes to IRC Section 1059 (extraordinary dividends); Changes to the tax treatment of contingent payment convertible debt; Corporate rate reductions; Corporate and individual capital gains issues (e.g., rate reductions, exclusions from income); Pending legislative proposals concerning tax shelters; Internal Revenue Code (“IRC”) Section 6111 (registration of confidential tax shelters); IRC Section 6112 (investor lists and regulations thereunder, as well as associated penalties); IRC Section 6011 (taxpayer disclosure of certain transactions); Joint Committee on Taxation and Treasury studies on corporate tax shelters; Proposals to codify economic substance doctrine; Extension of the R&E tax credit (IRC Section 41) and treatment of expenses of internal use software; Possible legislative proposals relating to hybrid arrangements; Straddle rules and need for “qualified covered calls” exception; Changes to IRC Section 911 (exclusion for individuals of earnings abroad); Tax treatment of income deposit securities; IRC Section 355(e); IRC Section 470 and investment funds; Mutual fund investment in commodity swaps; IRC Section 6701 (tax shelters); IRC Section 409A (deferred compensation); Tax-exempt interest reporting and backup withholding; Basis reporting by brokers; Health savings accounts. Executive Branch Actions: Reduced taxation of dividends (securities lending transactions, treatment of payments in lieu of dividends; qualifying foreign equities, reporting of payments on foreign securities, backup withholding, and treatment of financial intermediaries); Permanent reform of Subpart F, especially with respect to the active financial services income of financial services firms; Reform of Subpart F more generally; Valuation of securities under IRC Section 475 (mark-to-market tax rules); Proposed regulations under IRC Section 482 that would provide rules for allocating among affiliates and sourcing the income from a global dealing operation; OECD Model treaty provision on arbitration; OECD proposals for attribution of profits to permanent establishments; Treaty withholding tax relief for investments through collective investment vehicles; Proposed Section 482 Services Regulations; International reforms, including issues relating to territorial tax system and allocation of deductions to foreign-source income; International tax changes concerning foreign tax credits (e.g., interest allocation rules); Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; IRC Section 956 (concerning making a market in a U.S. affiliate’s securities and other aspects to rationalize rules); IRC Section 904(g) (resourcing of foreign-source income); Pending legislative proposals concerning corporate tax shelters, including codification of economic substance doctrine; Regulations under IRC Sections 6011, 6111 and 6112 (addressing corporate tax shelters); Possible means of prevention of overtaxation of earnings from a global dealing operation (possible change to IRC Section 245(b)); Regulations under Section 1441 of the IRC (and related sections) and subsequent IRS notices concerning reporting and withholding obligations with respect to payments to foreign persons; IRC Section 263(g) (capitalization with respect to straddles); Issues relating to adjusted basis tracking by brokers; Withholding the treatment of Section 302 distributions; Katrina-related “B Notice” and backup withholding issues; Due date for providing information returns to payees generally (including proposal to move date to February 28 for nominees); Penalty relief in case of late, small corrections to 1099s; Electronic provision of information returns to customers; Corporate rate reductions; Corporate and individual capital gains issues generally (e.g., rate reductions, exclusions from income); IRC Section 41 (regulations concerning internal use software and other issues); Treasury Regulation Section 1.904-6 (concerning the allocation of foreign tax credits among various income “baskets”); Changes to IRC Section 162(f); Tax treatment of income deposit securities; Tax treatment of contingent convertible debt; Tax treatment of qualified covered calls; Tax treatment of variable prepaid forwards; Guidance under IRC Section 965 (one-time repatriation provision); ZIRC Section 470 and investment funds; U.S.-Japan income tax treaty (definition of “investment bank” for purposes of Article 11); Information return clearinghouse; IRS Schedule M-3 to Form 1120; Reporting of taxable stock transactions (under IRC Sec. 6043©, 6043A); Withholding with respect to Puerto Rico corporations; United Kingdom anti-arbitrage rules; Withholding on FIRPTA distributions of RICs and REITs; Reporting and backup withholding on tax-exempt interest; Tax consequences of JASDEC /Samurai bond market developments; Implementation of U.S.-Japan tax treaty MOU (definition of “investment bank”); Tax treatment of variable prepaid forwards; Revenue Ruling 2006-1 (commodities swaps and mutual funds); Withholding tax treatment of credit default swaps; Section 482 services regulations.

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

HR 6, The Energy Policy Act; HR 4473, Commodities Futures Trading Commission Reauthorization Act; S. 1566, Commodities Futures Trading Commission Reauthorization Act; S.2642, The Oil and Gas Traders Oversight Act. Executive Branch Issues: Implementation of Commodity Futures Modernization Act of 2000.

Bills: HR 4840, Retirement Securities Act; HR 743, Social Security Protection Act; HR 819, Retirement Security for Life Act; HR 2830, Pension Protection Act; H. Con. Res. 95 (social security); S. Con. Res. 18 (social security); S. 1783, Pension Security and Transparency Act. Congressional Issues: Permanence of 529 plans; Retirement Savings Initiatives; ERISA Modernization. Executive Branch Actions: Exemption from bonding requirements of Section 412 of ERISA; Agency cross-trading restrictions under ERISA; Affiliated transactions under ERISA; Interpretations of Section 404(c) of ERISA; Administration’s FY 2005 budget – LSA, Retirement Savings Account, ERSA; Retirement plan expenses; Regulations under EGTRRA – IRA, pension, and education savings accounts and 529 plans; Application of IRS regulations 2001-14, -72 and -73 to stock options; Education savings: IRS regulations 2001-73 and 2001-81; Initiatives in response to the collapse of Enron and the impact of bankruptcy on 401(k) plans invested in company stock; IRS Plan Determination Letter – Request for information on reforms to the process for obtaining a determination letter for employer-sponsored retirement plans; Regulation of qualified tuition plans, disclosure issues and other sales practice guidance; SEC task force on 529 plans; Proposed rules for late-trading and market timing; Treasury budget proposals clarifying designated beneficiary for 529 plans; DOL reporting for Form LM-10 (payments to union officials); Request for guidance on 409A deferred compensation rules; Revenue ruing request on asset-based fees for retirement plan accounts.

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

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

Bills: S. 1337, Personal Data Privacy Act; S. 751, Notification of Risk to Personal Data Act; S. 2169, Financial Data Protection Act; S. 2169, Financial Data Protection Act. Congressional Issues: Privacy of customer financial information; Unsolicited electronic mail; Business continuity planning; Protecting information security. Executive Branch Issues: Straight-through processing, privacy of customer financial information; Unsolicited electronic mail; Business continuity planning; Protecting information security; Internet securities trading, including day trading and suitability; Electronic payments to broker-dealers; Mutual fund late trading, market timing, revenue sharing, and differential compensation issues; Business Continuity Planning.

S. 418, Military Personnel Financial Services Act S. 2169, Financial Data Protection Act Congressional Issues: Retirement plan expansion; Investment advice; Basel II; Privacy of customer financial information. ERISA modernization Executive Branch Issues: Coordination of SEC and banking regulatory examinations; Financial privacy rules; Regulations promulgating provisions of Gramm-Leach-Bliley Act, particularly provisions on financial privacy and functional regulation issues; Straight-through processing; H.R. 1224, Business Checking Freedom Act; HR 2830, Pension Protection Act S 1332, Personal Data Privacy Act S. 751, Notification of Risk to Personal Data Act

European Union data protection directive; European Union Financial Services Action Plan; Foreign Sales Corp./ Extraterritorial Income ruling of World Trade Organization and needed U.S. international tax changes/reforms; Free Trade Agreements; Status of Committee for Investment in the United States. Executive Branch Actions: Financial Stability forum of the G-7 nations; Financial privacy; Principles for greater transparency in foreign regulatory regimes; Tax impediments to expanding trade; World Trade Organization discussion regarding inclusion of “financial services”; World Trade Organization investment issues; Indonesia Investment Climate; China market access; World Trade Organization financial service negotiations/capital market sanctions; Establishment of U.S. Treasury attaché in Brussels; Sarbanes-Oxley Act extraterritorial applications; Russian accession to the World Trade Organization; Australia Free Trade Access; NJ Call Center Legislation; SEC Framework on Consolidated Supervise Entities; Qualification requirements of patent examiners and attorneys; Bi-lateral Investment Treaty; CFTC Capital Requirements for Broker-dealers that are part of Consolidated Supervisory Entity registrant; Basel II capital and regulatory standards U.S. - Thailand trade issues; Russian tax administration; U.S. - European Union dialogue on financial services regulatory convergence; U.S. - Korea Free Trade Agreement; U.S. - Malaysia Free Trade Agreement Accounting convergence of U.S. Generally Accepted Accounting Principles and International Financial Reporting Standards. Bills: S. 3549, Foreign Investment and National Security Act; S. 2380, U.S. National Security Protection Act; HR 4917, Protect America First Act of 2006; S. 3171, United States Direct Investment Act. Congressional Issues:

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

Bills: HR 1500, Investment Tax Simplification Act; HR 1417, Extension of Subpart F Exemption for Active Financing Income; HR 819, Retirement Security for Life Act; HR 3, Transportation Equity Act; S. 732, Safe, Accountable, Flexible, and Efficient Transportation Equity Act; S. 7, Jobs and Growth Tax Relief Act; HR 809 (Permanence of individual income tax rates fro capital gains and dividends); HR 4297, Tax Relief Extension Reconciliation Act of 2005; S. 2020, Tax Relief Act of 2005; H.Con.Res.95, Budget FY2006 Appropriations Resolution; S.Con.Res.18, Budget FY2006 Appropriations Resolution; S. 1159.IS, A bill to amend the Internal Revenue Code of 1986 to permanently extend subpart F exemption for active financing; HR 2471, Economic Development Act of 2005; S 1524, To repeal the sunset on the reduction of capital gains rates for individuals and on the taxation of dividends of individuals at capital gain rates HR 4297, Tax Reconciliation; HR 5367, S 2414, Simplification Through Additional Reporting Tax Act HR 809, S. 1524, Dividend Permanence; S. 1159, HR 1417, permanently extend the subpart F exemption for active financing; S. 2766, Defense Authorization (revenue offset for contingent convertible debt); S. 2020, Tax Relief Act. Congressional Issues: Integration of the corporate and individual income taxes; Reduced taxation of corporate earnings and dividend income; Treatment of payments in lieu of dividends under reduced dividend rates; Treatment of foreign distributions under reduced dividend rates; Capital gains reductions; Permanent reforms of Subpart F with respect to the active financial services income of financial services firms; Proposals to change IRC Section 163(j) (limiting interest deductions of subsidiaries of foreign companies); International tax rules concerning foreign tax credits (interest allocation rules, financial services income basket as “base case” basket for credits relating to permanent tax base differences, 10/50 companies, overall domestic loss); Exclusion for individuals of an amount of capital gains distributions from mutual funds; Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; Reform of Subpart F more generally, territorial tax systems generally; Changes to IRC Section 956 (deemed repatriation); Changes to IRC Section 904(g) (resourcing rules); Relief of double taxation on global dealing operations; Valuation of securities for purposes of mark-to-market tax rules (IRC Section 475); Due date for providing information returns to payees; Electronic provision of information returns to payees; Changes to IRC Section 162(f) (deductibility of settlement payments); Changes to IRC Section 163(l) (disallowance of certain interest payments); Changes to IRC Section 1059 (extraordinary dividends); Changes to the tax treatment of contingent payment convertible debt; Corporate rate reductions; Corporate and individual capital gains issues (e.g., rate reductions, exclusions from income); Pending legislative proposals concerning tax shelters; Internal Revenue Code (“IRC”) Section 6111 (registration of confidential tax shelters); IRC Section 6112 (investor lists and regulations thereunder, as well as associated penalties); IRC Section 6011 (taxpayer disclosure of certain transactions); Joint Committee on Taxation and Treasury studies on corporate tax shelters; Proposals to codify economic substance doctrine; Extension of the R&E tax credit (IRC Section 41) and treatment of expenses of internal use software; Possible legislative proposals relating to hybrid arrangements; Straddle rules and need for “qualified covered calls” exception; Changes to IRC Section 911 (exclusion for individuals of earnings abroad); Tax treatment of income deposit securities; IRC Section 355(e); IRC Section 470 and investment funds; Mutual fund investment in commodity swaps; IRC Section 6701 (tax shelters); IRC Section 409A (deferred compensation); Tax-exempt interest reporting and backup withholding; Basis reporting by brokers; Health savings accounts. Executive Branch Actions: Reduced taxation of dividends (securities lending transactions, treatment of payments in lieu of dividends; qualifying foreign equities, reporting of payments on foreign securities, backup withholding, and treatment of financial intermediaries); Permanent reform of Subpart F, especially with respect to the active financial services income of financial services firms; Reform of Subpart F more generally; Valuation of securities under IRC Section 475 (mark-to-market tax rules); Proposed regulations under IRC Section 482 that would provide rules for allocating among affiliates and sourcing the income from a global dealing operation; OECD Model treaty provision on arbitration; OECD proposals for attribution of profits to permanent establishments; Treaty withholding tax relief for investments through collective investment vehicles; Proposed Section 482 Services Regulations; International reforms, including issues relating to territorial tax system and allocation of deductions to foreign-source income; International tax changes concerning foreign tax credits (e.g., interest allocation rules); Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; IRC Section 956 (concerning making a market in a U.S. affiliate’s securities and other aspects to rationalize rules); IRC Section 904(g) (resourcing of foreign-source income); Pending legislative proposals concerning corporate tax shelters, including codification of economic substance doctrine; Regulations under IRC Sections 6011, 6111 and 6112 (addressing corporate tax shelters); Possible means of prevention of overtaxation of earnings from a global dealing operation (possible change to IRC Section 245(b)); Regulations under Section 1441 of the IRC (and related sections) and subsequent IRS notices concerning reporting and withholding obligations with respect to payments to foreign persons; IRC Section 263(g) (capitalization with respect to straddles); Issues relating to adjusted basis tracking by brokers; Withholding the treatment of Section 302 distributions; Katrina-related “B Notice” and backup withholding issues; Due date for providing information returns to payees generally (including proposal to move date to February 28 for nominees); Penalty relief in case of late, small corrections to 1099s; Electronic provision of information returns to customers; Corporate rate reductions; Corporate and individual capital gains issues generally (e.g., rate reductions, exclusions from income); IRC Section 41 (regulations concerning internal use software and other issues); Treasury Regulation Section 1.904-6 (concerning the allocation of foreign tax credits among various income “baskets”); Changes to IRC Section 162(f); Tax treatment of income deposit securities; Tax treatment of contingent convertible debt; Tax treatment of qualified covered calls; Tax treatment of variable prepaid forwards; Guidance under IRC Section 965 (one-time repatriation provision); ZIRC Section 470 and investment funds; U.S.-Japan income tax treaty (definition of “investment bank” for purposes of Article 11); Information return clearinghouse; IRS Schedule M-3 to Form 1120; Reporting of taxable stock transactions (under IRC Sec. 6043©, 6043A); Withholding with respect to Puerto Rico corporations; United Kingdom anti-arbitrage rules; Withholding on FIRPTA distributions of RICs and REITs; Reporting and backup withholding on tax-exempt interest; Tax consequences of JASDEC /Samurai bond market developments; Implementation of U.S.-Japan tax treaty MOU (definition of “investment bank”); Tax treatment of variable prepaid forwards; Revenue Ruling 2006-1 (commodities swaps and mutual funds); Withholding tax treatment of credit default swaps; Section 482 services regulations.

HR 6, The Energy Policy Act; HR 4473, Commodities Futures Trading Commission Reauthorization Act; S. 1566, Commodities Futures Trading Commission Reauthorization Act; S.2642, The Oil and Gas Traders Oversight Act. Executive Branch Issues: Implementation of Commodity Futures Modernization Act of 2000.

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

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

European Union data protection directive; European Union Financial Services Action Plan; Foreign Sales Corp./ Extraterritorial Income ruling of World Trade Organization and needed U.S. international tax changes/reforms; Free Trade Agreements; Status of Committee for Investment in the United States. Executive Branch Actions: Financial Stability forum of the G-7 nations; Financial privacy; Principles for greater transparency in foreign regulatory regimes; Tax impediments to expanding trade; World Trade Organization discussion regarding inclusion of “financial services”; World Trade Organization investment issues; Indonesia Investment Climate; China market access; World Trade Organization financial service negotiations/capital market sanctions; Establishment of U.S. Treasury attaché in Brussels; Sarbanes-Oxley Act extraterritorial applications; Russian accession to the World Trade Organization; Australia Free Trade Access; NJ Call Center Legislation; SEC Framework on Consolidated Supervise Entities; Qualification requirements of patent examiners and attorneys; Bi-lateral Investment Treaty; CFTC Capital Requirements for Broker-dealers that are part of Consolidated Supervisory Entity registrant; Basel II capital and regulatory standards U.S. - Thailand trade issues; Russian tax administration; U.S. - European Union dialogue on financial services regulatory convergence; U.S. - Korea Free Trade Agreement; U.S. - Malaysia Free Trade Agreement Accounting convergence of U.S. Generally Accepted Accounting Principles and International Financial Reporting Standards. Bills: S. 3549, Foreign Investment and National Security Act; S. 2380, U.S. National Security Protection Act; HR 4917, Protect America First Act of 2006; S. 3171, United States Direct Investment Act. Congressional Issues:

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

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

European Union data protection directive; European Union Financial Services Action Plan; Foreign Sales Corp./ Extraterritorial Income ruling of World Trade Organization and needed U.S. international tax changes/reforms; Free Trade Agreements; Status of Committee for Investment in the United States. Executive Branch Actions: Financial Stability forum of the G-7 nations; Financial privacy; Principles for greater transparency in foreign regulatory regimes; Tax impediments to expanding trade; World Trade Organization discussion regarding inclusion of “financial services”; World Trade Organization investment issues; Indonesia Investment Climate; China market access; World Trade Organization financial service negotiations/capital market sanctions; Establishment of U.S. Treasury attaché in Brussels; Sarbanes-Oxley Act extraterritorial applications; Russian accession to the World Trade Organization; Australia Free Trade Access; NJ Call Center Legislation; SEC Framework on Consolidated Supervise Entities; Qualification requirements of patent examiners and attorneys; Bi-lateral Investment Treaty; CFTC Capital Requirements for Broker-dealers that are part of Consolidated Supervisory Entity registrant; Basel II capital and regulatory standards U.S. - Thailand trade issues; Russian tax administration; U.S. - European Union dialogue on financial services regulatory convergence; U.S. - Korea Free Trade Agreement; U.S. - Malaysia Free Trade Agreement Accounting convergence of U.S. Generally Accepted Accounting Principles and International Financial Reporting Standards. Bills: S. 3549, Foreign Investment and National Security Act; S. 2380, U.S. National Security Protection Act; HR 4917, Protect America First Act of 2006; S. 3171, United States Direct Investment Act. Congressional Issues:

S. 418, Military Personnel Financial Services Act S. 2169, Financial Data Protection Act Congressional Issues: Retirement plan expansion; Investment advice; Basel II; Privacy of customer financial information. ERISA modernization Executive Branch Issues: Coordination of SEC and banking regulatory examinations; Financial privacy rules; Regulations promulgating provisions of Gramm-Leach-Bliley Act, particularly provisions on financial privacy and functional regulation issues; Straight-through processing; H.R. 1224, Business Checking Freedom Act; HR 2830, Pension Protection Act S 1332, Personal Data Privacy Act S. 751, Notification of Risk to Personal Data Act

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

Implementation of anti-money-laundering provisions of the Patriot Act, Pub. L. No. 107-56; Business Continuity Planning practices and rules Bills: S. 467, Terrorism Risk Insurance Extension Act Congressional Issues: Business continuity planning; Anti-money laundering proposals. Executive Branch Issues: Money-laundering regulations for broker-dealers; .

Bills: HR 1500, Investment Tax Simplification Act; HR 1417, Extension of Subpart F Exemption for Active Financing Income; HR 819, Retirement Security for Life Act; HR 3, Transportation Equity Act; S. 732, Safe, Accountable, Flexible, and Efficient Transportation Equity Act; S. 7, Jobs and Growth Tax Relief Act; HR 809 (Permanence of individual income tax rates fro capital gains and dividends); HR 4297, Tax Relief Extension Reconciliation Act of 2005; S. 2020, Tax Relief Act of 2005; H.Con.Res.95, Budget FY2006 Appropriations Resolution; S.Con.Res.18, Budget FY2006 Appropriations Resolution; S. 1159.IS, A bill to amend the Internal Revenue Code of 1986 to permanently extend subpart F exemption for active financing; HR 2471, Economic Development Act of 2005; S 1524, To repeal the sunset on the reduction of capital gains rates for individuals and on the taxation of dividends of individuals at capital gain rates HR 4297, Tax Reconciliation; HR 5367, S 2414, Simplification Through Additional Reporting Tax Act HR 809, S. 1524, Dividend Permanence; S. 1159, HR 1417, permanently extend the subpart F exemption for active financing; S. 2766, Defense Authorization (revenue offset for contingent convertible debt); S. 2020, Tax Relief Act. Congressional Issues: Integration of the corporate and individual income taxes; Reduced taxation of corporate earnings and dividend income; Treatment of payments in lieu of dividends under reduced dividend rates; Treatment of foreign distributions under reduced dividend rates; Capital gains reductions; Permanent reforms of Subpart F with respect to the active financial services income of financial services firms; Proposals to change IRC Section 163(j) (limiting interest deductions of subsidiaries of foreign companies); International tax rules concerning foreign tax credits (interest allocation rules, financial services income basket as “base case” basket for credits relating to permanent tax base differences, 10/50 companies, overall domestic loss); Exclusion for individuals of an amount of capital gains distributions from mutual funds; Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; Reform of Subpart F more generally, territorial tax systems generally; Changes to IRC Section 956 (deemed repatriation); Changes to IRC Section 904(g) (resourcing rules); Relief of double taxation on global dealing operations; Valuation of securities for purposes of mark-to-market tax rules (IRC Section 475); Due date for providing information returns to payees; Electronic provision of information returns to payees; Changes to IRC Section 162(f) (deductibility of settlement payments); Changes to IRC Section 163(l) (disallowance of certain interest payments); Changes to IRC Section 1059 (extraordinary dividends); Changes to the tax treatment of contingent payment convertible debt; Corporate rate reductions; Corporate and individual capital gains issues (e.g., rate reductions, exclusions from income); Pending legislative proposals concerning tax shelters; Internal Revenue Code (“IRC”) Section 6111 (registration of confidential tax shelters); IRC Section 6112 (investor lists and regulations thereunder, as well as associated penalties); IRC Section 6011 (taxpayer disclosure of certain transactions); Joint Committee on Taxation and Treasury studies on corporate tax shelters; Proposals to codify economic substance doctrine; Extension of the R&E tax credit (IRC Section 41) and treatment of expenses of internal use software; Possible legislative proposals relating to hybrid arrangements; Straddle rules and need for “qualified covered calls” exception; Changes to IRC Section 911 (exclusion for individuals of earnings abroad); Tax treatment of income deposit securities; IRC Section 355(e); IRC Section 470 and investment funds; Mutual fund investment in commodity swaps; IRC Section 6701 (tax shelters); IRC Section 409A (deferred compensation); Tax-exempt interest reporting and backup withholding; Basis reporting by brokers; Health savings accounts. Executive Branch Actions: Reduced taxation of dividends (securities lending transactions, treatment of payments in lieu of dividends; qualifying foreign equities, reporting of payments on foreign securities, backup withholding, and treatment of financial intermediaries); Permanent reform of Subpart F, especially with respect to the active financial services income of financial services firms; Reform of Subpart F more generally; Valuation of securities under IRC Section 475 (mark-to-market tax rules); Proposed regulations under IRC Section 482 that would provide rules for allocating among affiliates and sourcing the income from a global dealing operation; OECD Model treaty provision on arbitration; OECD proposals for attribution of profits to permanent establishments; Treaty withholding tax relief for investments through collective investment vehicles; Proposed Section 482 Services Regulations; International reforms, including issues relating to territorial tax system and allocation of deductions to foreign-source income; International tax changes concerning foreign tax credits (e.g., interest allocation rules); Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; IRC Section 956 (concerning making a market in a U.S. affiliate’s securities and other aspects to rationalize rules); IRC Section 904(g) (resourcing of foreign-source income); Pending legislative proposals concerning corporate tax shelters, including codification of economic substance doctrine; Regulations under IRC Sections 6011, 6111 and 6112 (addressing corporate tax shelters); Possible means of prevention of overtaxation of earnings from a global dealing operation (possible change to IRC Section 245(b)); Regulations under Section 1441 of the IRC (and related sections) and subsequent IRS notices concerning reporting and withholding obligations with respect to payments to foreign persons; IRC Section 263(g) (capitalization with respect to straddles); Issues relating to adjusted basis tracking by brokers; Withholding the treatment of Section 302 distributions; Katrina-related “B Notice” and backup withholding issues; Due date for providing information returns to payees generally (including proposal to move date to February 28 for nominees); Penalty relief in case of late, small corrections to 1099s; Electronic provision of information returns to customers; Corporate rate reductions; Corporate and individual capital gains issues generally (e.g., rate reductions, exclusions from income); IRC Section 41 (regulations concerning internal use software and other issues); Treasury Regulation Section 1.904-6 (concerning the allocation of foreign tax credits among various income “baskets”); Changes to IRC Section 162(f); Tax treatment of income deposit securities; Tax treatment of contingent convertible debt; Tax treatment of qualified covered calls; Tax treatment of variable prepaid forwards; Guidance under IRC Section 965 (one-time repatriation provision); ZIRC Section 470 and investment funds; U.S.-Japan income tax treaty (definition of “investment bank” for purposes of Article 11); Information return clearinghouse; IRS Schedule M-3 to Form 1120; Reporting of taxable stock transactions (under IRC Sec. 6043©, 6043A); Withholding with respect to Puerto Rico corporations; United Kingdom anti-arbitrage rules; Withholding on FIRPTA distributions of RICs and REITs; Reporting and backup withholding on tax-exempt interest; Tax consequences of JASDEC /Samurai bond market developments; Implementation of U.S.-Japan tax treaty MOU (definition of “investment bank”); Tax treatment of variable prepaid forwards; Revenue Ruling 2006-1 (commodities swaps and mutual funds); Withholding tax treatment of credit default swaps; Section 482 services regulations.

Bills: HR 1500, Investment Tax Simplification Act; HR 1417, Extension of Subpart F Exemption for Active Financing Income; HR 819, Retirement Security for Life Act; HR 3, Transportation Equity Act; S. 732, Safe, Accountable, Flexible, and Efficient Transportation Equity Act; S. 7, Jobs and Growth Tax Relief Act; HR 809 (Permanence of individual income tax rates fro capital gains and dividends); HR 4297, Tax Relief Extension Reconciliation Act of 2005; S. 2020, Tax Relief Act of 2005; H.Con.Res.95, Budget FY2006 Appropriations Resolution; S.Con.Res.18, Budget FY2006 Appropriations Resolution; S. 1159.IS, A bill to amend the Internal Revenue Code of 1986 to permanently extend subpart F exemption for active financing; HR 2471, Economic Development Act of 2005; S 1524, To repeal the sunset on the reduction of capital gains rates for individuals and on the taxation of dividends of individuals at capital gain rates HR 4297, Tax Reconciliation; HR 5367, S 2414, Simplification Through Additional Reporting Tax Act HR 809, S. 1524, Dividend Permanence; S. 1159, HR 1417, permanently extend the subpart F exemption for active financing; S. 2766, Defense Authorization (revenue offset for contingent convertible debt); S. 2020, Tax Relief Act. Congressional Issues: Integration of the corporate and individual income taxes; Reduced taxation of corporate earnings and dividend income; Treatment of payments in lieu of dividends under reduced dividend rates; Treatment of foreign distributions under reduced dividend rates; Capital gains reductions; Permanent reforms of Subpart F with respect to the active financial services income of financial services firms; Proposals to change IRC Section 163(j) (limiting interest deductions of subsidiaries of foreign companies); International tax rules concerning foreign tax credits (interest allocation rules, financial services income basket as “base case” basket for credits relating to permanent tax base differences, 10/50 companies, overall domestic loss); Exclusion for individuals of an amount of capital gains distributions from mutual funds; Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; Reform of Subpart F more generally, territorial tax systems generally; Changes to IRC Section 956 (deemed repatriation); Changes to IRC Section 904(g) (resourcing rules); Relief of double taxation on global dealing operations; Valuation of securities for purposes of mark-to-market tax rules (IRC Section 475); Due date for providing information returns to payees; Electronic provision of information returns to payees; Changes to IRC Section 162(f) (deductibility of settlement payments); Changes to IRC Section 163(l) (disallowance of certain interest payments); Changes to IRC Section 1059 (extraordinary dividends); Changes to the tax treatment of contingent payment convertible debt; Corporate rate reductions; Corporate and individual capital gains issues (e.g., rate reductions, exclusions from income); Pending legislative proposals concerning tax shelters; Internal Revenue Code (“IRC”) Section 6111 (registration of confidential tax shelters); IRC Section 6112 (investor lists and regulations thereunder, as well as associated penalties); IRC Section 6011 (taxpayer disclosure of certain transactions); Joint Committee on Taxation and Treasury studies on corporate tax shelters; Proposals to codify economic substance doctrine; Extension of the R&E tax credit (IRC Section 41) and treatment of expenses of internal use software; Possible legislative proposals relating to hybrid arrangements; Straddle rules and need for “qualified covered calls” exception; Changes to IRC Section 911 (exclusion for individuals of earnings abroad); Tax treatment of income deposit securities; IRC Section 355(e); IRC Section 470 and investment funds; Mutual fund investment in commodity swaps; IRC Section 6701 (tax shelters); IRC Section 409A (deferred compensation); Tax-exempt interest reporting and backup withholding; Basis reporting by brokers; Health savings accounts. Executive Branch Actions: Reduced taxation of dividends (securities lending transactions, treatment of payments in lieu of dividends; qualifying foreign equities, reporting of payments on foreign securities, backup withholding, and treatment of financial intermediaries); Permanent reform of Subpart F, especially with respect to the active financial services income of financial services firms; Reform of Subpart F more generally; Valuation of securities under IRC Section 475 (mark-to-market tax rules); Proposed regulations under IRC Section 482 that would provide rules for allocating among affiliates and sourcing the income from a global dealing operation; OECD Model treaty provision on arbitration; OECD proposals for attribution of profits to permanent establishments; Treaty withholding tax relief for investments through collective investment vehicles; Proposed Section 482 Services Regulations; International reforms, including issues relating to territorial tax system and allocation of deductions to foreign-source income; International tax changes concerning foreign tax credits (e.g., interest allocation rules); Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; IRC Section 956 (concerning making a market in a U.S. affiliate’s securities and other aspects to rationalize rules); IRC Section 904(g) (resourcing of foreign-source income); Pending legislative proposals concerning corporate tax shelters, including codification of economic substance doctrine; Regulations under IRC Sections 6011, 6111 and 6112 (addressing corporate tax shelters); Possible means of prevention of overtaxation of earnings from a global dealing operation (possible change to IRC Section 245(b)); Regulations under Section 1441 of the IRC (and related sections) and subsequent IRS notices concerning reporting and withholding obligations with respect to payments to foreign persons; IRC Section 263(g) (capitalization with respect to straddles); Issues relating to adjusted basis tracking by brokers; Withholding the treatment of Section 302 distributions; Katrina-related “B Notice” and backup withholding issues; Due date for providing information returns to payees generally (including proposal to move date to February 28 for nominees); Penalty relief in case of late, small corrections to 1099s; Electronic provision of information returns to customers; Corporate rate reductions; Corporate and individual capital gains issues generally (e.g., rate reductions, exclusions from income); IRC Section 41 (regulations concerning internal use software and other issues); Treasury Regulation Section 1.904-6 (concerning the allocation of foreign tax credits among various income “baskets”); Changes to IRC Section 162(f); Tax treatment of income deposit securities; Tax treatment of contingent convertible debt; Tax treatment of qualified covered calls; Tax treatment of variable prepaid forwards; Guidance under IRC Section 965 (one-time repatriation provision); ZIRC Section 470 and investment funds; U.S.-Japan income tax treaty (definition of “investment bank” for purposes of Article 11); Information return clearinghouse; IRS Schedule M-3 to Form 1120; Reporting of taxable stock transactions (under IRC Sec. 6043©, 6043A); Withholding with respect to Puerto Rico corporations; United Kingdom anti-arbitrage rules; Withholding on FIRPTA distributions of RICs and REITs; Reporting and backup withholding on tax-exempt interest; Tax consequences of JASDEC /Samurai bond market developments; Implementation of U.S.-Japan tax treaty MOU (definition of “investment bank”); Tax treatment of variable prepaid forwards; Revenue Ruling 2006-1 (commodities swaps and mutual funds); Withholding tax treatment of credit default swaps; Section 482 services regulations.

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

Bills: S. 1337, Personal Data Privacy Act; S. 751, Notification of Risk to Personal Data Act; S. 2169, Financial Data Protection Act; S. 2169, Financial Data Protection Act. Congressional Issues: Privacy of customer financial information; Unsolicited electronic mail; Business continuity planning; Protecting information security. Executive Branch Issues: Straight-through processing, privacy of customer financial information; Unsolicited electronic mail; Business continuity planning; Protecting information security; Internet securities trading, including day trading and suitability; Electronic payments to broker-dealers; Mutual fund late trading, market timing, revenue sharing, and differential compensation issues; Business Continuity Planning.

S. 418, Military Personnel Financial Services Act S. 2169, Financial Data Protection Act Congressional Issues: Retirement plan expansion; Investment advice; Basel II; Privacy of customer financial information. ERISA modernization Executive Branch Issues: Coordination of SEC and banking regulatory examinations; Financial privacy rules; Regulations promulgating provisions of Gramm-Leach-Bliley Act, particularly provisions on financial privacy and functional regulation issues; Straight-through processing; H.R. 1224, Business Checking Freedom Act; HR 2830, Pension Protection Act S 1332, Personal Data Privacy Act S. 751, Notification of Risk to Personal Data Act

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

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

Bills: HR 4840, Retirement Securities Act; HR 743, Social Security Protection Act; HR 819, Retirement Security for Life Act; HR 2830, Pension Protection Act; H. Con. Res. 95 (social security); S. Con. Res. 18 (social security); S. 1783, Pension Security and Transparency Act. Congressional Issues: Permanence of 529 plans; Retirement Savings Initiatives; ERISA Modernization. Executive Branch Actions: Exemption from bonding requirements of Section 412 of ERISA; Agency cross-trading restrictions under ERISA; Affiliated transactions under ERISA; Interpretations of Section 404(c) of ERISA; Administration’s FY 2005 budget – LSA, Retirement Savings Account, ERSA; Retirement plan expenses; Regulations under EGTRRA – IRA, pension, and education savings accounts and 529 plans; Application of IRS regulations 2001-14, -72 and -73 to stock options; Education savings: IRS regulations 2001-73 and 2001-81; Initiatives in response to the collapse of Enron and the impact of bankruptcy on 401(k) plans invested in company stock; IRS Plan Determination Letter – Request for information on reforms to the process for obtaining a determination letter for employer-sponsored retirement plans; Regulation of qualified tuition plans, disclosure issues and other sales practice guidance; SEC task force on 529 plans; Proposed rules for late-trading and market timing; Treasury budget proposals clarifying designated beneficiary for 529 plans; DOL reporting for Form LM-10 (payments to union officials); Request for guidance on 409A deferred compensation rules; Revenue ruing request on asset-based fees for retirement plan accounts.

Bills: HR 1500, Investment Tax Simplification Act; HR 1417, Extension of Subpart F Exemption for Active Financing Income; HR 819, Retirement Security for Life Act; HR 3, Transportation Equity Act; S. 732, Safe, Accountable, Flexible, and Efficient Transportation Equity Act; S. 7, Jobs and Growth Tax Relief Act; HR 809 (Permanence of individual income tax rates fro capital gains and dividends); HR 4297, Tax Relief Extension Reconciliation Act of 2005; S. 2020, Tax Relief Act of 2005; H.Con.Res.95, Budget FY2006 Appropriations Resolution; S.Con.Res.18, Budget FY2006 Appropriations Resolution; S. 1159.IS, A bill to amend the Internal Revenue Code of 1986 to permanently extend subpart F exemption for active financing; HR 2471, Economic Development Act of 2005; S 1524, To repeal the sunset on the reduction of capital gains rates for individuals and on the taxation of dividends of individuals at capital gain rates HR 4297, Tax Reconciliation; HR 5367, S 2414, Simplification Through Additional Reporting Tax Act HR 809, S. 1524, Dividend Permanence; S. 1159, HR 1417, permanently extend the subpart F exemption for active financing; S. 2766, Defense Authorization (revenue offset for contingent convertible debt); S. 2020, Tax Relief Act. Congressional Issues: Integration of the corporate and individual income taxes; Reduced taxation of corporate earnings and dividend income; Treatment of payments in lieu of dividends under reduced dividend rates; Treatment of foreign distributions under reduced dividend rates; Capital gains reductions; Permanent reforms of Subpart F with respect to the active financial services income of financial services firms; Proposals to change IRC Section 163(j) (limiting interest deductions of subsidiaries of foreign companies); International tax rules concerning foreign tax credits (interest allocation rules, financial services income basket as “base case” basket for credits relating to permanent tax base differences, 10/50 companies, overall domestic loss); Exclusion for individuals of an amount of capital gains distributions from mutual funds; Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; Reform of Subpart F more generally, territorial tax systems generally; Changes to IRC Section 956 (deemed repatriation); Changes to IRC Section 904(g) (resourcing rules); Relief of double taxation on global dealing operations; Valuation of securities for purposes of mark-to-market tax rules (IRC Section 475); Due date for providing information returns to payees; Electronic provision of information returns to payees; Changes to IRC Section 162(f) (deductibility of settlement payments); Changes to IRC Section 163(l) (disallowance of certain interest payments); Changes to IRC Section 1059 (extraordinary dividends); Changes to the tax treatment of contingent payment convertible debt; Corporate rate reductions; Corporate and individual capital gains issues (e.g., rate reductions, exclusions from income); Pending legislative proposals concerning tax shelters; Internal Revenue Code (“IRC”) Section 6111 (registration of confidential tax shelters); IRC Section 6112 (investor lists and regulations thereunder, as well as associated penalties); IRC Section 6011 (taxpayer disclosure of certain transactions); Joint Committee on Taxation and Treasury studies on corporate tax shelters; Proposals to codify economic substance doctrine; Extension of the R&E tax credit (IRC Section 41) and treatment of expenses of internal use software; Possible legislative proposals relating to hybrid arrangements; Straddle rules and need for “qualified covered calls” exception; Changes to IRC Section 911 (exclusion for individuals of earnings abroad); Tax treatment of income deposit securities; IRC Section 355(e); IRC Section 470 and investment funds; Mutual fund investment in commodity swaps; IRC Section 6701 (tax shelters); IRC Section 409A (deferred compensation); Tax-exempt interest reporting and backup withholding; Basis reporting by brokers; Health savings accounts. Executive Branch Actions: Reduced taxation of dividends (securities lending transactions, treatment of payments in lieu of dividends; qualifying foreign equities, reporting of payments on foreign securities, backup withholding, and treatment of financial intermediaries); Permanent reform of Subpart F, especially with respect to the active financial services income of financial services firms; Reform of Subpart F more generally; Valuation of securities under IRC Section 475 (mark-to-market tax rules); Proposed regulations under IRC Section 482 that would provide rules for allocating among affiliates and sourcing the income from a global dealing operation; OECD Model treaty provision on arbitration; OECD proposals for attribution of profits to permanent establishments; Treaty withholding tax relief for investments through collective investment vehicles; Proposed Section 482 Services Regulations; International reforms, including issues relating to territorial tax system and allocation of deductions to foreign-source income; International tax changes concerning foreign tax credits (e.g., interest allocation rules); Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; IRC Section 956 (concerning making a market in a U.S. affiliate’s securities and other aspects to rationalize rules); IRC Section 904(g) (resourcing of foreign-source income); Pending legislative proposals concerning corporate tax shelters, including codification of economic substance doctrine; Regulations under IRC Sections 6011, 6111 and 6112 (addressing corporate tax shelters); Possible means of prevention of overtaxation of earnings from a global dealing operation (possible change to IRC Section 245(b)); Regulations under Section 1441 of the IRC (and related sections) and subsequent IRS notices concerning reporting and withholding obligations with respect to payments to foreign persons; IRC Section 263(g) (capitalization with respect to straddles); Issues relating to adjusted basis tracking by brokers; Withholding the treatment of Section 302 distributions; Katrina-related “B Notice” and backup withholding issues; Due date for providing information returns to payees generally (including proposal to move date to February 28 for nominees); Penalty relief in case of late, small corrections to 1099s; Electronic provision of information returns to customers; Corporate rate reductions; Corporate and individual capital gains issues generally (e.g., rate reductions, exclusions from income); IRC Section 41 (regulations concerning internal use software and other issues); Treasury Regulation Section 1.904-6 (concerning the allocation of foreign tax credits among various income “baskets”); Changes to IRC Section 162(f); Tax treatment of income deposit securities; Tax treatment of contingent convertible debt; Tax treatment of qualified covered calls; Tax treatment of variable prepaid forwards; Guidance under IRC Section 965 (one-time repatriation provision); ZIRC Section 470 and investment funds; U.S.-Japan income tax treaty (definition of “investment bank” for purposes of Article 11); Information return clearinghouse; IRS Schedule M-3 to Form 1120; Reporting of taxable stock transactions (under IRC Sec. 6043©, 6043A); Withholding with respect to Puerto Rico corporations; United Kingdom anti-arbitrage rules; Withholding on FIRPTA distributions of RICs and REITs; Reporting and backup withholding on tax-exempt interest; Tax consequences of JASDEC /Samurai bond market developments; Implementation of U.S.-Japan tax treaty MOU (definition of “investment bank”); Tax treatment of variable prepaid forwards; Revenue Ruling 2006-1 (commodities swaps and mutual funds); Withholding tax treatment of credit default swaps; Section 482 services regulations.

HR 6, The Energy Policy Act; HR 4473, Commodities Futures Trading Commission Reauthorization Act; S. 1566, Commodities Futures Trading Commission Reauthorization Act; S.2642, The Oil and Gas Traders Oversight Act. Executive Branch Issues: Implementation of Commodity Futures Modernization Act of 2000.

Bills: HR 4840, Retirement Securities Act; HR 743, Social Security Protection Act; HR 819, Retirement Security for Life Act; HR 2830, Pension Protection Act; H. Con. Res. 95 (social security); S. Con. Res. 18 (social security); S. 1783, Pension Security and Transparency Act. Congressional Issues: Permanence of 529 plans; Retirement Savings Initiatives; ERISA Modernization. Executive Branch Actions: Exemption from bonding requirements of Section 412 of ERISA; Agency cross-trading restrictions under ERISA; Affiliated transactions under ERISA; Interpretations of Section 404(c) of ERISA; Administration’s FY 2005 budget – LSA, Retirement Savings Account, ERSA; Retirement plan expenses; Regulations under EGTRRA – IRA, pension, and education savings accounts and 529 plans; Application of IRS regulations 2001-14, -72 and -73 to stock options; Education savings: IRS regulations 2001-73 and 2001-81; Initiatives in response to the collapse of Enron and the impact of bankruptcy on 401(k) plans invested in company stock; IRS Plan Determination Letter – Request for information on reforms to the process for obtaining a determination letter for employer-sponsored retirement plans; Regulation of qualified tuition plans, disclosure issues and other sales practice guidance; SEC task force on 529 plans; Proposed rules for late-trading and market timing; Treasury budget proposals clarifying designated beneficiary for 529 plans; DOL reporting for Form LM-10 (payments to union officials); Request for guidance on 409A deferred compensation rules; Revenue ruing request on asset-based fees for retirement plan accounts.