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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 1250 H Street NW |
Address2 | 605 |
| City | WASHINGTON |
State | DC |
Zip Code | 20005 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 4675-12
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6. House ID# 312420000
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| TYPE OF REPORT | 8. Year | 2026 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
| 10. Check if this is a Termination Report | Termination Date |
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11. No Lobbying Issue Activity |
| INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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| 12. Lobbying | 13. Organizations | ||||||||
| INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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| Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
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Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
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| Signature | Digitally Signed By: Nicholas Otto |
Date | 10/19/2026 2:16:52 PM |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code RET
16. Specific lobbying issues
ERISA Preemption
Tax treatment of retirement plans
Proposed regulation regarding investment selection in retirement plans (designated investment alternatives)
Tax treatment of retiree health accounts (S. 2003)
Market-based cash balance plans
Pooled Employer Plans (PEPs) and non-PEP Multiple Employer Plans
Defined benefit and defined contribution retirement plans
Caregiver retirement savings catch-up credit (S. 4291/ HR 8273)
Trump (child savings) accounts - nondiscrimination rules and dependent care assistance programs non-discrimination rules
Trump IRAs - SAVERS MATCH
Roth Catch-up - treatment of tips
Automatic re-enrollment of unenrolled plan participants (S. 1831)
Reduction of required age for participation in retirement plans from 21 to 18 (S. 1707 / HR 4718)
Pension Benefit Guaranty Corporation - penalty reporting
Charity Parity Act (S. 4511 / HR 8783)
Collective Investment Trusts and Insurance Company Separate Accounts
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Labor - Dept of (DOL), Internal Revenue Service (IRS), Pension Benefit Guaranty Corporation (PBGC), Treasury - Dept of, Securities & Exchange Commission (SEC)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Lynn |
Dudley |
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Diann |
Howland |
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Pension Policy Director for the Senate Health Education Labor and Pensions Committee, Pension Policy Advisor of the Senate Finance Committee |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code HCR
16. Specific lobbying issues
ERISA Preemption
Tax treatment of employer-sponsored health benefit plans
Site-neutral payment policies, anti-competitive practices, hospital consolidation, and reforms
No Surprises Act reforms and HR 4710
Patients Deserve Price Tags Act (HR 5582/ S 2355)
Excepted fertility benefits
DOL NPRM Pharmacy Benefit Fee Disclosure (sec. 408(b)(2))
Electronic disclosure for health and welfare benefit plans
Employer Innovations in Health Care
Sec. 340B pharmacy drug pricing program
End-Stage Renal Disease, Restore Protections for Dialysis Patients Act (HR 2199)
Lower Costs More Transparency Act (HR 9393)
Chronic disease coverage, on-site clinics, direct primary care
Mental Health Parity and Addiction Equity Act (MHPAEA)
Health care price transparency, prescription drug price transparency, PBM price transparency, hospital price transparency ERISA fiduciary duties for health care plans (S. 3345 / S. 526)
Prescription Drug Data Collection reporting
Medicare Operations Rule
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Labor - Dept of (DOL), Health & Human Services - Dept of (HHS), Internal Revenue Service (IRS), Office of Management & Budget (OMB), Centers For Medicare and Medicaid Services (CMS)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Diann |
Howland |
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Pension Policy Director for the Senate Health Education Labor and Pensions Committee, Pension Policy Advisor of the Senate Finance Committee |
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Ilyse |
Schuman |
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Senate HELP Committee, Chief Labor Counsel, Minority Staff Director |
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Kathryn |
Johnson |
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Attorney advisor, Office of Benefits Tax Counsel at the U.S. Department of Treasury; attorney, Office of Chief Counsel at the Internal Revenue Service |
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Matthew |
Muma |
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Legislation Counsel with the Joint Committee on Taxation; Attorney-Adviser with the Department of the Treasury |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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21. Client new principal place of business (if different than line 20)
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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4 |
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
| Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
| 1 | 2 | 3 |
FOREIGN ENTITIES
27. Add the following foreign entities:
| Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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% | |||||||||||||
28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
| 1 | 3 | 5 |
| 2 | 4 | 6 |
CONVICTIONS DISCLOSURE
29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery,
extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
| Lobbyist Name | Description of Offense(s) |