2nd Quarter - Report

AMERICAN BAR ASSOCIATION for AMERICAN BAR ASSOCIATION

Firm
Client
Income
—
Expenses
$260,000
Expense method
A: Lobbying Disclosure Act definitions

What was lobbied

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

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

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

Civil Rights/Civil Liberties CIV

S. 1723/H.R. 7227 - Truth and Healing Commission on Indian Boarding School Policies Act

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

Contacted: HOUSE OF REPRESENTATIVES; SENATE

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

Budget/Appropriations BUD

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

Education EDU

H.R. 6951, the College Cost Reduction Act - in support of tying borrower total debt to 10 year repayment plus interest, including for those in income-driven repayment; and in general opposition to static maximum loan caps that would force borrowers increasingly into a less-regulated private loan market for a law degree. Support for student loan debt forgiveness, reforming and strengthening the Public Service Loan Forgiveness (PSLF) program, reduced student loan interest rates and ability to refine loans, and the continued suspension of federal student loan payments. Activity in support of retaining lawyers in the federal Public Service Loan Forgiveness program. Department of Education Notice of Proposed Rulemaking-Student Debt Relief for the William D. Ford Federal Direct Loan Program (Direct Loans), the Federal Family Education Loan (FFEL) Program, the Federal Perkins Loan (Perkins) Program, and the Health Education Assistance Loan (HEAL) Program; Docket ID ED-2023-OPE-0123; RIN 1840-AD93, 89 Fed. Reg. 27564 (April 17, 2024).

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

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

Bills named: H.R. 6951 (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. H.R. 7947, Restoring Court Authority Over Litigation Act Department of the Treasury Financial Crimes Enforcement Network Notice of Proposed Rulemaking on Anti-Money Laundering Regulations for Residential Real Estate Transfers; Docket No. FINCEN-2024-0005; RIN 1506-AB54, 89 Fed. Reg. 12424 (February 16, 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: Treasury, Dept of; White House Office; SENATE; HOUSE OF REPRESENTATIVES

Bills named: H.R. 8070 (118th), S. 4638 (118th), H.R. 7947 (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; U.S. Agency for International Development (USAID); State, Dept of (DOS); SENATE

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 Funding for Tribal Court Systems - Seeking additional funding in response to Supreme Court decision conferring jurisdiction on tribal courts for crimes committed on tribal lands. Support for permanently establishing within the Department of Justice, the Office for Access to Justice. H.R. 8818, the American Privacy Rights Act Proposed federal laws/regulations related to artificial intelligence, cybersecurity, data security, digital/personal privacy, intellectual property, in addition to how these issues could impact the legal profession, such as undermining the attorney-client privilege, the lawyers ethical duty to protect client confidentiality, the work product doctrine, and access to justice, as well as questions related to the federal courts longstanding authority to regulate and oversee the legal profession. Opposed federal efforts that would seek to undermine the attorney-client privilege, work product protections, and the preservation of client confidentiality, such as by regulating attorneys as financial institutions. 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. General communications about the lawyer regulatory and disciplinary process. Communications regarding the Family First Prevention Services Act and implementation in state and local child welfare systems. 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. Draft Model Rules of Representative Conduct to be developed by an Administrative Conference of the United States working group that would regulate the conduct of attorneys and non-attorneys who represent parties and other interested persons in administrative adjudicative proceedings. 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: Justice, Dept of (DOJ); White House Office; Federal Energy Regulatory Commission (FERC); Congressional Budget Office (CBO); HOUSE OF REPRESENTATIVES; SENATE; Office of Management & Budget (OMB)

Bills named: S. 325 (118th), H.R. 927 (118th), S. 359 (118th), H.Res. 314 (118th), H.R. 8818 (118th), H.R. 926 (118th), S. 4638 (118th)

Immigration IMM

S.3178, H.R.6145 Immigration Court Efficiency and Childrens Court Act of 2023 S.1885, H.R.4285 Protect Vulnerable Immigrant Youth Act S. 365, Dream Act of 2023 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. Communications regarding immigration court backlog, children's dockets, and the Legal Orientation Program. Communications regarding transfers of of represented individuals detained in Otay Mesa Detention Center without proper notification of counsel. FR Doc. 2024-10390, 86 Fed. Reg. 41347 (May 12, 2024), DHS Docket No. USCIS-2024-0005 Application of Certain Mandatory Bars in Fear Screenings - ABA comments urging agency to rescind the proposed rule due to the likelihood of undermining due process and access to full and fair adjudication for noncitizens seeking asylum and withholding of removal. Issues relating to access to counsel and funding for the Legal Orientation Program. 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; HOUSE OF REPRESENTATIVES; U.S. Customs & Border Protection; Bureau of Citizenship & Immigration Services (BCIS); Health & Human Services, Dept of (HHS); Justice, Dept of (DOJ); Homeland Security, Dept of (DHS); White House Office

Bills named: H.R. 6145 (118th), H.R. 4627 (118th), S. 1885 (118th), S. 365 (118th), S. 2327 (118th), H.R. 4285 (118th), S. 3178 (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. General research and discussions surrounding Supreme Court ethics rule and funding for the federal courts and federal defender legal services. 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. 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. 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: Justice, Dept of (DOJ); White House Office; Homeland Security, Dept of (DHS); Federal Trade Commission (FTC); HOUSE OF REPRESENTATIVES; SENATE; Consumer Financial Protection Bureau (CFPB)

Bills named: S. 1351 (118th), H.R. 2955 (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: Labor, Dept of (DOL); White House Office; SENATE; HOUSE OF REPRESENTATIVES

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

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

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

Taxation/Internal Revenue Code TAX

H.R. 7024, the Tax Relief for American Families and Workers Act of 2024 -support for the increases to the refundable Child Tax Credit.

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

Contacted: SENATE

Bills named: H.R. 7024 (118th)

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.