ZURICH AMERICAN INSURANCE COMPANY for ZURICH AMERICAN INSURANCE COMPANY

Labor Issues/Antitrust/Workplace LBR

Proposals/inquiries concerning potential reconfiguration and administration of current Defense Base Act coverage. Proposals to modernize the Medicare secondary payer process (specific to workers compensation liability).

Foreign entity interest: ZURICH FINANCIAL SERVICES - interests are those of parent company.

Contacted: Council on Environmental Quality (CEQ); White House Office; U.S. Trade Representative (USTR); Labor, Dept of (DOL); HOUSE OF REPRESENTATIVES; Interior, Dept of (DOI); Internal Revenue Service (IRS); Health & Human Services, Dept of (HHS); Federal Reserve System; Treasury, Dept of; Commerce, Dept of (DOC); SENATE; State, Dept of (DOS)

Agriculture AGR

Proposals for 2012 Farm Bill, specifically, general issues related to crop insurance funding.

Foreign entity interest: ZURICH FINANCIAL SERVICES - interests are those of parent company.

Contacted: State, Dept of (DOS); HOUSE OF REPRESENTATIVES; Health & Human Services, Dept of (HHS); Council on Environmental Quality (CEQ); Interior, Dept of (DOI); Treasury, Dept of; Internal Revenue Service (IRS); U.S. Trade Representative (USTR); SENATE; White House Office; Labor, Dept of (DOL); Federal Reserve System; Commerce, Dept of (DOC)

Taxation/Internal Revenue Code TAX

Implementation of the Foreign Account Tax Compliance Act of 2009 (specifically reporting and designation requirements for insurance), as included and passed in the Hiring Incentive to Restore Employment (HIRE) Act. TARP Responsibility Fee, specificially, initiatives to impose a TARP user tax on non-TARP recipients and property/casualty insurance firms. H.R. 3157/S. 1633, and other proposals to alter tax treatment of legitimate foreign affiliate reinsurance transactions undertaken by U.S. subsidiaries of foreign parent corporations, including in the context of FY 2012 Administration budget provisions and debt limit, free-trade agreement and trade adjustment authority negotiations. General discussions on the Swiss Tax treaty. H.R. 3765, Temporary Payroll Tax Cut Continuation Act of 2011, proposals to alter tax code treatment of life insurance products.

Foreign entity interest: ZURICH FINANCIAL SERVICES - interests are those of parent company.

Contacted: Federal Reserve System; Internal Revenue Service (IRS); Council on Environmental Quality (CEQ); U.S. Trade Representative (USTR); SENATE; Commerce, Dept of (DOC); State, Dept of (DOS); White House Office; Interior, Dept of (DOI); Labor, Dept of (DOL); Health & Human Services, Dept of (HHS); HOUSE OF REPRESENTATIVES; Treasury, Dept of

Bills named: S. 1633 (112th), H.R. 3157 (112th), H.R. 3765 (112th)

Health Issues HCR

Implementation of Sec. 111 Pub. Law No. 110-173, the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA), specifically reporting requirements for domestic/international carriers. Implementation of Pub. Law No. 111-148, the Patient Protection and Affordable Care Act, provisions related to excepted benefits and general applicability to non-health carriers. H.R. 1150, Competitive Health Insurance Reform Act of 2011. H.R. 1943, Health Insurance Industry Fair Competition Act.

Foreign entity interest: ZURICH FINANCIAL SERVICES - interests are those of parent company.

Contacted: Commerce, Dept of (DOC); Health & Human Services, Dept of (HHS); State, Dept of (DOS); Federal Reserve System; SENATE; White House Office; Interior, Dept of (DOI); U.S. Trade Representative (USTR); Council on Environmental Quality (CEQ); Treasury, Dept of; Internal Revenue Service (IRS); Labor, Dept of (DOL); HOUSE OF REPRESENTATIVES

Bills named: H.R. 1943 (112th), H.R. 1150 (112th)

Foreign Relations FOR

H.R. 890, Holocaust Insurance Accountability Act of 2011. S. 466, Restoration of Legal Rights for Claimants under Holocaust-Era Insurance Policies Act of 2011. H.R. 1193/S. 634, Holocaust Rail Justice Act.

Foreign entity interest: ZURICH FINANCIAL SERVICES - interests are those of parent company.

Contacted: Treasury, Dept of; U.S. Trade Representative (USTR); HOUSE OF REPRESENTATIVES; White House Office; Council on Environmental Quality (CEQ); SENATE; Internal Revenue Service (IRS); Interior, Dept of (DOI); State, Dept of (DOS); Federal Reserve System; Labor, Dept of (DOL); Commerce, Dept of (DOC); Health & Human Services, Dept of (HHS)

Bills named: H.R. 890 (112th), S. 634 (112th), S. 466 (112th), H.R. 1193 (112th)

Insurance INS

Implementation of Pub. Law No. 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act, specifically, provisions on systemic risk and FSOC composition, derivatives, insurance oversight (Federal Insurance Office), conflicting Department of Labor fiduciary standards, and mortgage servicing related to insurance coverage. Applicability of OFAC reporting to insurance. H.R. 1309, Flood Insurance Reform Act of 2011. Risk Retention draft proposal to modernize the Liability Risk Retention Act of 1986, provisions to expand commercial property coverage. H.R. 2577, Secure and Fortify Electronic Data Act ("SAFE Data Act"). S. 1207, Data Security and Breach Notification Act of 2011. S. 1151, Personal Data Privacy and Security Act of 2011. S. 1434, Data Security Act of 2011. H.R. 1573, To facilitate implementation of title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, promote regulatory coordination, and avoid market disruption. H.R. 1121, Responsible Consumer Financial Protection Regulations Act of 2011. H.R. 1315, Consumer Financial Protection Safety and Soundness Improvement Act of 2011. Terrorism Insurance, specifically amendments to the Flood Insurance reform bill to sunset the program. Continuing Resolution, provisions to extend the flood insurance program beyond its current expiration. H.R. 2055, Consolidated Appropriations Act, 2012. H.R. 3889, PARTS Act S. 2151, SECURE IT ACT. Reauthorization of the Terrorism Risk Insurance Program.

Foreign entity interest: ZURICH FINANCIAL SERVICES - interests are those of parent company.

Contacted: Council on Environmental Quality (CEQ); State, Dept of (DOS); U.S. Trade Representative (USTR); Treasury, Dept of; SENATE; Commerce, Dept of (DOC); Internal Revenue Service (IRS); White House Office; Interior, Dept of (DOI); Health & Human Services, Dept of (HHS); HOUSE OF REPRESENTATIVES; Labor, Dept of (DOL); Federal Reserve System

Bills named: H.R. 1315 (112th), H.R. 3889 (112th), H.R. 1573 (112th), H.R. 2055 (112th), H.R. 1309 (112th), H.R. 2577 (112th), S. 1434 (112th), S. 2151 (112th), S. 1151 (112th), H.R. 1121 (112th), S. 1207 (112th)

Government Issues GOV

Discussions related to the lawful advocacy activities of U.S. subsidiaries of foreign parent companies.

Foreign entity interest: ZURICH FINANCIAL SERVICES - interests are those of parent company.

Contacted: State, Dept of (DOS); Council on Environmental Quality (CEQ); Health & Human Services, Dept of (HHS); Interior, Dept of (DOI); Labor, Dept of (DOL); Internal Revenue Service (IRS); U.S. Trade Representative (USTR); White House Office; Federal Reserve System; Treasury, Dept of; HOUSE OF REPRESENTATIVES; Commerce, Dept of (DOC); SENATE

Energy/Nuclear ENG

S. 699, Department of Energy Carbon Capture and Sequestration Program Amendments Act of 2011. HR. 2846, American Energy Act. Proposals related to the creation of a carbon capture sequestration liability framework. Proposals related to financial assurance and liability regimes. H.R. 2273, Coal Residuals Reuse and Management Act, specifically the inclusion of insurance as an accepted form of financial assurance. FY 2012 House Interior-Environment Appropriations Bill. H.R. 2018, Clean Water Cooperative Federalism Act of 2011, specifically provisions relating to financial assurance and mining and oil and gas production. Proposals concerning federal financial assurance requirements related to hydro-carbon extraction. Proposals concerning new source performance standards for greenhouse gas emissions from fossil-fuel electric generating units.

Foreign entity interest: ZURICH FINANCIAL SERVICES - interests are those of parent company.

Contacted: Interior, Dept of (DOI); Health & Human Services, Dept of (HHS); State, Dept of (DOS); HOUSE OF REPRESENTATIVES; Internal Revenue Service (IRS); U.S. Trade Representative (USTR); SENATE; Federal Reserve System; White House Office; Treasury, Dept of; Commerce, Dept of (DOC); Labor, Dept of (DOL); Council on Environmental Quality (CEQ)

Bills named: H.R. 2018 (112th), H.R. 2273 (112th), S. 699 (112th), H.R. 2846 (112th)

Torts TOR

Proposals related to foreign manufacturers legal accountability. Proposals related to limitations of liability from injuries. Proposals to address 3rd party financing of litigation.

Foreign entity interest: ZURICH FINANCIAL SERVICES - interests are those of parent company.

Contacted: White House Office; Health & Human Services, Dept of (HHS); Internal Revenue Service (IRS); Interior, Dept of (DOI); SENATE; Commerce, Dept of (DOC); HOUSE OF REPRESENTATIVES; Federal Reserve System; Treasury, Dept of; Labor, Dept of (DOL); State, Dept of (DOS); U.S. Trade Representative (USTR); Council on Environmental Quality (CEQ)