2nd Quarter - Report

AZOA SERVICES CORP(ALLIANZ OF AMERICA) FORMERLY AZOA SERIVCES CORP/FIREMAN'S FUND(ALLIANZ OF AMERICA for AZOA SERVICES CORP(ALLIANZ OF AMERICA) AND AFFILIATES

Firm
Client
Income
—
Expenses
$570,000
Expense method
A: Lobbying Disclosure Act definitions

What was lobbied

6 issue areas, each in the filer's own words, with who lobbied on it and where.

Banking BAN

Money market guaranty program: follow creation of Treasury Department money market guaranty program after concern about the financial stability of the Reserve management Corporations Primary Fund. H.R. 4173, the Dodd-Frank Wall Street Reform and Consumer Protection Act: Follow implementatation of this legislation which would create a new systemic risk regulation for systemically-significant firms and a resolution mechanism for failing firms. The President signed it into law on July 21, 2010. Follow meetings and proposed rules of the Financial Stability Oversight Council (FSOC) and the establishment of the Federal Insurance Office and Consumer Financial Protection Bureau. Closely follow the FSOC's proposed rule to implement Sec. 113 of the Dodd-Frank Act, which would establish criteria for the designation of non-bank firms a s "systemically important financial institutions." Mark to market accounting: follow SEC and FASBE action regarding guidance and clarifications for mark to market accounting.

LobbyistCovered position, as disclosed
PETER A LEFKIN —
RASHMI SUTTON —

Contacted: Risk Management Agency; Securities & Exchange Commission (SEC); Commodity Futures Trading Commission (CFTC); Labor, Dept of (DOL); HOUSE OF REPRESENTATIVES; SENATE; Treasury, Dept of

Bills named: H.R. 4173 (112th)

Financial Institutions/Investments/Securities FIN

Derivatives: Monitor new rules and changes of regulation for derivatives and commodity indexed funds, and activity within Congress, especially in the context of the HR 4173, the Wall Street Reform and Consumer Protection Act and implementation by the CFTC. Systemic Risk: Argue that mutual funds should not be designated as systemically important financial institutions under Sec. 113 of Dodd-Frank. Consumer Financial Protection Bureau: Monitor inclusion of this new agency in H.R. 4173, the Wall Street Reform and Consumer Protection Act and its implementation. Target Date Funds: Monitor possible legislation and SEC as well as Department of labor regulatory activities. SEC and money markets: Monitor and see proposed SEC regulations. Mutual funds: Advocate for the ability to defer annual capital gains taxation of dividends that are reinvested in mutual funds. Fiduciary Duty - Monitor the SEC's efforts to establish a uniform fiduciary duty standard of investment advisers and broker-dealers. Monitor the DO:'s efforts to change the fiduciary standard under ERISA. Whistleblower Program: Monitor and oppose SEC rulemaking implementing a provision in the Dodd-Frank Act that creates a new Whistleblower program within the agency. CFTC: Argue against imposing position limits on commodity index mutual funds.

LobbyistCovered position, as disclosed
PETER A LEFKIN —
RASHMI SUTTON —

Contacted: Securities & Exchange Commission (SEC); SENATE; HOUSE OF REPRESENTATIVES; Commodity Futures Trading Commission (CFTC); Labor, Dept of (DOL); Treasury, Dept of; Risk Management Agency

Bills named: H.R. 4173 (112th)

Taxation/Internal Revenue Code TAX

Cascading taxes for foreign-owned insurers: Advocate against measure in Congress and from the Obama Administration that would lead to imposition of an excise tax twice when insurance for reinsurance is placed from the U.S. to a foreign company and then when the foreign company reinsurers the U.S. risk. Executive Compensation: Monitor and oppose efforts to change carried interest tax treatment. Foreign Account Tax Compliance Act - Follow implementation of "FATCA" which became law in March, 2010. This Act increases reporting and withholding requirements for foreign financial firms. Exchange traded notes: for PIMCO followed issue through trade association, Investment Company Institute, ETN's are an alternative to mutual funds and enjoy a tax preference. treasury has recently weighted in and may view this current tax treatment as not appropriate. Related-party reinsurance taxation: Advocate against legislation introduced in previous Congress by Rep. Richard Neal (D-MA) that would prohibit offshore reinsurance affiliates of insurance companies and not required to pay U.S. taxes from taking deductions for "excel reinsurance premiums" for domestic risks. Monitor and oppose tax proposals in connection with deficit reduction negotiations that would change existing tax laws and increase tax requirements for life insurance.

LobbyistCovered position, as disclosed
PETER A LEFKIN —
RASHMI SUTTON —

Contacted: Securities & Exchange Commission (SEC); Labor, Dept of (DOL); Risk Management Agency; Commodity Futures Trading Commission (CFTC); SENATE; HOUSE OF REPRESENTATIVES; Treasury, Dept of

Retirement RET

401 (k) fee disclosure: Trade Department of labor rulemaking regarding 401 (k) fee disclosure. Lifetime Income Disclosure Act: Follow introduction of legislation that would require 401 (k) plan participants an annual statement projecting the monthly income that would be generated if the account balance were amortized as retirement.

LobbyistCovered position, as disclosed
PETER A LEFKIN —
RASHMI SUTTON —

Contacted: Treasury, Dept of; Securities & Exchange Commission (SEC); Risk Management Agency; Commodity Futures Trading Commission (CFTC); HOUSE OF REPRESENTATIVES; SENATE; Labor, Dept of (DOL)

Insurance INS

Financial Services Regulatory Reform: Lobby for favorable implementation of H.R. 4173, the Dodd-Frank Wall Street Reform and Consumer Protection Act regarding insurers, including a resolution fund for failing firms, and the possible designation of insurers as systemically important by the Financial Stability Oversight Council. Also, followed inclusion of section to create a Federal Insurance Office at Treasury including the appointment of that office's Director, Also with trade associations,commented on notice of Proposed Rulemaking by the Financial Stability oversight Council for systemic risk regulation of nonbank firms. Also, lobby for robust and effective Federal Insurance Office. Also, with key trade associations, worked on regulatory strategy for the implementation of Dodd-Frank. annuities/Suitability: followed implementation of amendments to H.R. 4173 that helps confirm that fixed index annuities are insurance products to be regulated by states. Holocaust insurance issues/ICHEIC: Monitored the reintroduction of legislation that would allow a cause of action against U.S.Insurance companies with European affiliates that may have written life insurance policies involving Holocaust victims in contravention of international agreements. Credit-based insurance scores: Monitor and lobbied possible reintroduction of legislation that would restrict the ability of personal lines insurers to use credit information of underwriting or setting rates. Climate and energy legislation: Monitored White House, Department of Energy and Environmental Protection Agency "Better Buildings initiative." Monitored General Services Administration initiative on green buildings and related sustainable products. National Catastrophe/Flood Insurance: Track reintroduction of National Flood Insurance Reform Legislation in the House, H.R. 1509. State Bankruptcy: Also with trade associations, monitor efforts by some members of congress to allow states to file for bankruptcy protection. Broker-dealer regulatory reform/standard of care: Monitor Securities and Exchange Commission and Department of Labor rulemaking and investment advisors and the fiduciary duty standard. Annuities: Support H.R. 2748, the Retirement Security Needs Lifetime Payment Act of 2009 and monitor through trade association.

LobbyistCovered position, as disclosed
PATRICK JAMES LA VECK —
PETER A LEFKIN —
RASHMI SUTTON —

Contacted: Commodity Futures Trading Commission (CFTC); Treasury, Dept of; HOUSE OF REPRESENTATIVES; SENATE; Securities & Exchange Commission (SEC); Labor, Dept of (DOL); Risk Management Agency

Bills named: H.R. 1509 (112th), H.R. 4173 (112th), H.R. 2748 (112th)

Torts TOR

Legal/Tort Reform: track the progress of the insurance industry's collaboration on legal reform tort issues at the federal and state levels.

LobbyistCovered position, as disclosed
PETER A LEFKIN —
RASHMI SUTTON —

Contacted: Treasury, Dept of; HOUSE OF REPRESENTATIVES; Securities & Exchange Commission (SEC); Risk Management Agency; Labor, Dept of (DOL); Commodity Futures Trading Commission (CFTC); SENATE

Shown as published by the Senate Office of Public Records and the House Clerk under the Lobbying Disclosure Act. The official filing is the record; open it for the full form.