3rd Quarter - Report

AMERICAN BAR ASSOCIATION for AMERICAN BAR ASSOCIATION

Firm
Client
Income
—
Expenses
$210,000
Expense method
A: Lobbying Disclosure Act definitions

What was lobbied

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

Medicare/Medicaid MMM

Support legislation that would establish clear criteria for when a Medicare set-aside may be reviewed by Medicare, provides a time frame for CMS to review set-aside submissions and provides an optional direct payment of set-aside amounts to Medicare.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
DAVID EPPSTEIN —

Contacted: HOUSE OF REPRESENTATIVES; SENATE

Trade (domestic/foreign) TRD

Communications regarding international trade in legal services and overseas market access for U.S. firms and lawyers.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
KRISTI GAINES —

Contacted: Commerce, Dept of (DOC); U.S. Trade Representative (USTR)

Health Issues HCR

Communications regarding implementing a Guardianship Court Improvement Program.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
DAVID EPPSTEIN —

Contacted: SENATE; HOUSE OF REPRESENTATIVES

Budget/Appropriations BUD

Support supplemental disaster relief funding for legal services. FY2025 Commerce, Justice, Science and Related Agencies Appropriations - funding for the Legal Services Corporation; funding for the Department of Justice Executive Office for Immigration Review's Legal Orientation Program. FY2025 Financial Services and General Government Appropriations - funding for the Defender Services Office Administrative Office of the US Courts. FY2025 Department of State, Foreign Operations, and Related Programs Appropriations - funding for democracy, human rights, and rule of law programs. FY2025 Legislative Branch Appropriations - funding for the Library and Law Library of Congress.

Contacted: Patent & Trademark Office (PTO); Office of Management & Budget (OMB); State, Dept of (DOS); Health & Human Services, Dept of (HHS); Justice, Dept of (DOJ); Legal Services Corporation; SENATE; HOUSE OF REPRESENTATIVES; White House Office

Civil Rights/Civil Liberties CIV

S. 1723/H.R. 7227, the Truth and Healing Commission on Indian Boarding School Policies Act. S.4091/H.R.7921, the Countering Antisemitism Act - support for most key provisions.

LobbyistCovered position, as disclosed
DENISE A CARDMAN —
HOLLY O'GRADY COOK —
CHRISTINA ENNIS —

Contacted: SENATE; HOUSE OF REPRESENTATIVES

Bills named: H.R. 7921 (118th), H.R. 7227 (118th), S. 1723 (118th), S. 4091 (118th)

Financial Institutions/Investments/Securities FIN

Consumer Financial Protection Bureau Statement of Policy Regarding Prohibition on Abusive Acts or Practices; Docket No CFPB-2023-0018; 88 Fed. Reg. 21883 (April 12, 2023)-provisions that could require creditor attorneys and law firms to act in the interests of consumers instead of their creditor clients in violation of the attorneys' existing ethical obligations or that would conflict with other existing state court ethical obligations S.4638,H.R. 8070, FY2025 National Defense Authorization Act - draft amendment regulating certain attorneys and law firms as financial institutions under the Bank Secrecy Act and requiring them to report certain attorney-client privileged and other protected client information to the Treasury Department. S. 4638 and H.R. 8070, FY 2025 National Defense Authorization Act-Amendment No. 2169 sponsored by Sen. Tim Scott (R-SC) extending several deadlines for companies to report and update beneficial ownership information to the Treasury Department under the Corporate Transparency Act H.R. 5119 and S. 3625, Protect Small Business and Prevent Illicit Financial Activity Act H.R. 9278, legislation providing existing small businesses with an additional year to report beneficial ownership information to the Treasury Department under the Corporate Transparency Act H.R. 7947, Restoring Court Authority Over Litigation Act Department of the Treasury Financial Crimes Enforcement Network Rule on Anti-Money Laundering Regulations for Residential Real Estate Transfers; Document No. 2024-19198; RIN 1506-AB54, 89 Fed. Reg. 70258 (August 29, 2024) Department of the Treasury Financial Crimes Enforcement Network Final Rule on Beneficial Ownership Information Access and Safeguards; Document No. 2023-27973; RIN 1506-AB59, 88 Fed. Reg. 88732 (December 22, 2023) Department of the Treasury Financial Crimes Enforcement Network Final Rule on Beneficial Ownership Information Reporting Requirements; Document No. 2022-21020; RIN 1506-AB49, 87 Fed. Reg. 59498 (September 30, 2022). Financial Action Task Force Public Consultation Paper, Proposed Updates to Risk-Based Guidance to the Real Estate Sector-provisions requiring attorneys to submit suspicious transaction reports on their clients high-risk real estate transactions even when the information is protected by the attorney-client privilege. Financial Action Task Force White Paper for Public Consultation, Potential Amendments to Recommendation 24 (Transparency and Beneficial Ownership of Legal Persons)-provisions considering requiring attorneys to hold their company clients' beneficial ownership information and disclose it to government authorities.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
LARSON FRISBY —

Contacted: SENATE; Treasury, Dept of; HOUSE OF REPRESENTATIVES; White House Office

Bills named: H.R. 9278 (118th), S. 4638 (118th), H.R. 8070 (118th), H.R. 7947 (118th), S. 3625 (118th), H.R. 5119 (118th)

Foreign Relations FOR

Support for U.S. ratification of the United Nations Convention on the Law of the Sea. Communications regarding increased support for investigation and prosecution of atrocity crimes, particularly crimes committed by Russian forces in Ukraine. Draft legislation to amend U.S. law to extend domestic jurisdiction over crimes against humanity. Support for U.S. ratification of the United Nations Convention on International Settlement Agreements Resulting from Mediation (Singapore Convention on Mediation). Issues relating to facilitating U.S. support and engagement with the International Criminal Court. Support for increased funding for democracy, human rights, and rule of law programs.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
LARSON FRISBY —
KRISTI GAINES —
THOMAS MICHAEL SUSMAN —

Contacted: HOUSE OF REPRESENTATIVES; SENATE; U.S. Agency for International Development (USAID); State, Dept of (DOS)

Government Issues GOV

H.R. 927, S. 325 - Supreme Court Ethics Act H.R. 926, S. 359 - Supreme Court Ethics, Recusal, and Transparency Act of 2023 H. Res. 314 - Territorial Incorporation Doctrine Support for authorizing new federal judgeships. Issues regarding diversity jurisdiction - treating unincorporated and incorporated entities the same to determine if diversity jurisdiction exists. Judicial Security - efforts to expand judicial security protection to Administrative Law Judges Support the original intent of H.R.9278 to extend the current deadline for millions of existing small businesses to file their initial beneficial ownership reports required under the Corporate Transparency Act for one year to January 1, 2026. Oppose efforts by Congress, such as the provision contained in S.4638, the National Defense Authorization Act for Fiscal Year 2025, to regulate the practice of law by mandating that attorneys married to an active duty servicemembers in the armed forces be automatically admitted to practice law in the state where the servicemember has been stationed. This would undermine the longstanding principle and doctrine supported by the ABA which believes state supreme courts have the power of licensure. Federal Energy Regulatory Commission Notice of Proposed Rulemaking on Duty of Candor; Docket No. RM22-20-000, 87 Fed. Reg. 49784 (August 12, 2022)-provisions regulating certain attorneys engaged in the practice of law and requiring them to disclose certain attorney-client privileged and other protected client information. Model Rules of Representative Conduct developed by an Administrative Conference of the United States working group that, if adopted by individual federal agencies, would regulate the conduct of attorneys and non-attorneys who represent parties and other interested persons in administrative adjudicative proceedings before those agencies. Administrative Conference of the United States study on Regulation of Representatives in Agency Proceedings to explore how federal agencies regulate the conduct of attorneys and non-attorneys who represent parties and other interested persons in administrative adjudicative proceedings, and related best practices for federal agencies. Proposed Department of Justice Office of Legal Counsel legal opinion further clarifying the ability of government attorneys and other employees to participate more fully in outside organizations, including legal professional associations. Revised Department of Justice ethics guidance (Representations Before the Government) further clarifying the ability of government attorneys and other employees to participate more fully in outside organizations, including legal professional associations.

LobbyistCovered position, as disclosed
DENISE A CARDMAN —
HOLLY O'GRADY COOK —
LARSON FRISBY —
KRISTI GAINES —
JAMES MICHAEL O'NEILL —

Contacted: Congressional Budget Office (CBO); White House Office; Office of Management & Budget (OMB); Federal Energy Regulatory Commission (FERC); SENATE; Justice, Dept of (DOJ); HOUSE OF REPRESENTATIVES

Bills named: H.R. 9278 (118th), H.R. 927 (118th), S. 4638 (118th), S. 325 (118th), S. 359 (118th), H.R. 926 (118th), H.Res. 314 (118th)

Immigration IMM

Discussions regarding draft legislation to revise the current standard for assessing a motion to reopen an immigration matter based on ineffective assistance of counsel. Issues regarding collection and publication of race and ethnicity data of individuals seeking benefits or subject to enforcement processing and adjudications. Communications regarding implementation of best practices for the care, representation, and adjudication of unaccompanied immigrant children. Issues relating to access to counsel and the Legal Orientation Program, particularly for individuals in immigration detention. S.2327, H.R.4627, the Afghan Adjustment Act and other measures to facilitate permanent legal status for certain Afghans present in the U.S. Issues related to unaccompanied alien children, including access to counsel and Special Immigrant Juvenile Status. Issues regarding the operations of the immigration courts, including establishing an independent Article I immigration court system. Issues relating to decreasing the use of detention and expanding alternatives to detention.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
CHRISTINA ENNIS —
KRISTI GAINES —

Contacted: SENATE; Justice, Dept of (DOJ); Health & Human Services, Dept of (HHS); White House Office; Bureau of Citizenship & Immigration Services (BCIS); Homeland Security, Dept of (DHS); U.S. Customs & Border Protection; HOUSE OF REPRESENTATIVES

Bills named: H.R. 4627 (118th), S. 2327 (118th)

Law Enforcement/Crime/Criminal Justice LAW

Activity in support of reintroduction of the Effective Assistance of Counsel in the Digital Era Act concerning attorney-client confidentiality between attorneys and their incarcerated clients. Activity in support of a repeal of the lifetime federal prohibition on access to the Supplemental Nutrition Assistance Program (SNAP) for those with a prior drug conviction. Activity in support of the study and reduction of coercive practices in plea bargaining that undermine the right to jury trial. H.R. 8846, the Right to Trial Act in support of ending coercive plea-bargaining tactics that undermine the right to jury trial. H.R. 4987S. 1677, the Democracy Restoration Act and other activity in support of restoring the right to vote in federal elections for those leaving prison. S. 1401, the Federal Prison Oversight Act, and other activity in support of increased transparency and oversight of the conditions of federal prisons. H.R. 2955,S. 1351, the Stop Institutional Child Abuse Act - to provide greater oversight for youth treatment programs and promote best practices for identifying and preventing institutional child abuse. General research and discussions surrounding Supreme Court ethics rule and funding for the federal courts and federal defender legal services. Proposed changes to Customs and Border Protection Directive No. 3340-049 (Border Search of Electronic Devices Containing Information, dated August 20, 2009), Customs and Border Protection Directive No. 3340-049A (Border Search of Electronic Devices, dated January 4, 2018), and Immigration and Customs Enforcement Directive No. 7-6.1 (Border Searches of Electronic Devices, dated August 18, 2009) to prevent border officials from reading, duplicating, seizing, or sharing attorney-client privileged or confidential client documents or information contained on attorneys laptop computers, cell phones, and other electronic devices at U.S. border crossings unless the officials first obtain a subpoena based on reasonable suspicion or a warrant supported by probable cause.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
DAVID EPPSTEIN —
LARSON FRISBY —
KENNETH GOLDSMITH —

Contacted: Consumer Financial Protection Bureau (CFPB); Justice, Dept of (DOJ); White House Office; SENATE; HOUSE OF REPRESENTATIVES; Federal Trade Commission (FTC); Homeland Security, Dept of (DHS)

Bills named: S. 1351 (118th), H.R. 2955 (118th), H.R. 8846 (118th), H.R. 4987 (118th), S. 1401 (118th)

Labor Issues/Antitrust/Workplace LBR

H.R. 20 and S. 567, Richard L. Trumka Protecting the Right to Organize Act-provisions in Section 202 that would amend Section 203(c) of the Labor-Management Reporting and Disclosure Act of 1959, 29 U.S.C. 433(c), to require attorneys to report certain confidential client information to the Department of Labor.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
LARSON FRISBY —

Contacted: HOUSE OF REPRESENTATIVES; Labor, Dept of (DOL); White House Office; SENATE

Bills named: S. 567 (118th), H.R. 20 (118th)

Banking BAN

S.2860, the Secure and Fair Enforcement Regulation Banking Act, or the SAFER Banking Act - a bill would allow financial institutions to provide legally-operating cannabis businesses access to critical banking services - including bank accounts, credit cards, and checks - without fear of retribution by federal regulators.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
DAVID EPPSTEIN —

Contacted: SENATE

Bills named: S. 2860 (118th)

Defense DEF

Draft legislation making it easier for spouses of U.S. servicemembers to practice law in the jurisdictions to which they move without undue delay or burden.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
LARSON FRISBY —
JAMES MICHAEL O'NEILL —

Contacted: HOUSE OF REPRESENTATIVES; Justice, Dept of (DOJ); SENATE; Defense, Dept of (DOD)

Family issues/Abortion/Adoption FAM

H.R. 9076, the Protecting Americas Children by Strengthening Families Act - provisions related to courts and legal system support that will positively affect children, parents, and families, as well as increase funding for the Court Improvement Program. Comments to provide recommendations regarding the draft non-regulatory guidance for Title I, Part D of the Elementary and Secondary Education Act of 1965 (ESEA), which was reauthorized and amended by the Every Student Succeeds Act (ESSA) in 2015, and how it can better serve the educational needs of youth in foster care.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
DAVID EPPSTEIN —

Contacted: HOUSE OF REPRESENTATIVES

Bills named: H.R. 9076 (118th)

Telecommunications TEC

H.R. 8818, the American Privacy Rights Act Analyzed federal laws/regulations related to artificial intelligence, cybersecurity, data security, digital/personal privacy, intellectual property, in addition to to ensure they did not seek to harm or regulate the legal profession, such as by undermining the attorney-client privilege, the lawyers ethical duty to protect client confidentiality, the work product doctrine, and do not limit the ability to access the justice system and counsel.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —
JAMES MICHAEL O'NEILL —

Contacted: SENATE; HOUSE OF REPRESENTATIVES

Bills named: H.R. 8818 (118th)

Education EDU

General policy research and discussions surrounding student debt relief developments, including the Freedom to Invest in Tomorrows Workforce Act that would allow the use of 529 accounts for professional degrees and certifications.

LobbyistCovered position, as disclosed
HOLLY O'GRADY COOK —

Contacted: HOUSE OF REPRESENTATIVES

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.