3rd 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
$353,843
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.

Insurance INS

Insurance Regulatory Reform: Advocate for favorable legislation affecting the regulation of property/casualty and life insurance, including H.R. 1880, the National Insurance Consumer Protection Act of 2009. This bill could create an optional federal charter for insurance. Long Term Care Insurance: through trade association, advocate in support of S.702, titled the "Long-Term Care Affordability and Security Act of 2009." This bill would allow long-term care insurance to be offered in employer-sponsored cafeteria plans flexible spending arrangements. Work through trade association to oppose inclusion of Class Act, which would create a federal long-term care insurance program, in House and Senate healthcare reform legislation. Annuities/Suitability: Advocated against rule 151A, adapted by the U.S. Securities and Exchange Commission. Lobbied both Congress and the SEC. This rule would make certain fixed annuities subject to federal securities laws. Holocaust insurance issues/ICHEIC: Lobbied against the possible reintroduction of legislation that would create a new cause of action against U.S. insurance companies with European affiliates that may have written life insurance policies involving Holocaust victims. The bill could also require any European insurer with policies written between 1990 and 1945 that may have involved holocaust victims to disclose all files on the policies, including names, to the U.S. Credit-based insurance scores: Lobbied against the reintroduction of legislation that would restrict the ability of personal lines insurers to use credit information of underwriting or setting rates. Medicare secondary payer/workers compensation: Follow issue, including trade association meetings with the Centers for Medicare and Medicaid Services (CMS), an agency of the Department of Health and Human Services. CMS is working on guidance/rules on this issue and insurance trade associations are weighing in. McCarran-Ferguson Reform: Follow and oppose H.R. 1503, the Insurance Industry Competition Act, which would repeal the McCarran-Ferguson Act, which provides insurers a limited exemption from federal antitrust law. Flood and national catastrophe insurance: In participation with a coalition, lobbied House and Senate staff to oppose legislation that would expand the National Flood Insurance Program to include wind insurance, specifically H.R. 1264 the Multiple Peril Insurance Act of 2009. Also lobbied against the possible reintroduction of legislation to create a national back stop for national catastrophe insurance. Also lobbied for inclusion of funding for structure mitigation, to protect houses and business against nat cat, in the stimulus bill. Also incorporated climate change arguments into natural catastrophe insurance lobbying efforts and promoted Fireman's Fund green products with Congressional staff and S.886, the Catastrophe Obligation Guarantee Act. Climate and energy legislation: Monitored the progress of HR 2454, the American Clean Energy and Security Act of 2009. Municipal bond legislation: Monitor municipal bond legislation, specifically HR 2589, Municipal Bond Insurance Enhancement Act of 2009, HR 2549, Municipal Bond Fairness Act, Municipal Bond Liquidity Act; and Municipal Financial Advisors Regulation Act. Right to Repair Act, HR.2057: support for bill which would enhance consumers' ability to take automobiles to independent shops for repairs. Broker-dealer regulatory reform: Monitor financial regulatory reform as it relates to broker-dealer and their existing regulation under the Financial Industry Regulatory Authority (FINRA). Surplus insurance lines: Monitor progress and support HR 2571, the Nonadmitted and Reinsurance Reform Act. State jurisdiction over annuity products: Support the continuing of state jurisdiction over fixed annuities: H.R. 2733, Fixed Indexed Annuities and Insurance Products Classification Act of 2009. Agents and brokers: Support NARAB II: H.R. 2554, the National Association of Registered Agents and Brokers Reform Act of 2009. Annuities: Support HR 2748, the Retirement Security Needs Lifetime Payment Act of 2009 and monitor through trade associations.

LobbyistCovered position, as disclosed
PATRICK JAMES LA VECK —
PETER A LEFKIN —
GRETCHEN ANN LINDQUIST New Senior Legislative Assistant
RASHMI SUTTON Counsel, House Financial Services Committee

Contacted: Risk Management Agency; Securities & Exchange Commission (SEC); HOUSE OF REPRESENTATIVES; SENATE; Treasury, Dept of

Bills named: H.R. 2057 (111th), S. 702 (111th), H.R. 1880 (111th), H.R. 1264 (111th), H.R. 2571 (111th), H.R. 2589 (111th), H.R. 2748 (111th), H.R. 2549 (111th), H.R. 2733 (111th), H.R. 2554 (111th), H.R. 2454 (111th), H.R. 1503 (111th), S. 886 (111th)

Banking BAN

Mark to market accounting: follow SEC and FASBE action regarding guidance and clarification for mark to market accounting. Financial Services regulatory reform: Followed discussions within Congress and the Administration to reform the financial services regulatory system, including "cram-down" legislation, legislation to create a resolution authority for non-bank entities, and potential systemic risk legislation. TARP: Followed developments regarding the Troubled Asset Relief Program at Treasury. 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. Bailout/Economic Recovery Legislation: Follow implementation of H.R. 1924 the "Emergency Economic Stabilization Act of 2008". The bill which Allianz of America supported, authorizes the U.S. Government to purchase up to $700 billion of troubled assets from financial institutions. The bill also included tax extender provisions which Allianz supported.

LobbyistCovered position, as disclosed
PETER A LEFKIN —
GRETCHEN ANN LINDQUIST New Senior Legilative Assistant
RASHMI SUTTON Counsel, House Financial Services Committee

Contacted: Risk Management Agency; SENATE; Securities & Exchange Commission (SEC); Treasury, Dept of; HOUSE OF REPRESENTATIVES

Bills named: H.R. 1924 (111th)

Financial Institutions/Investments/Securities FIN

Annuities: Followed SEC action, including a recently proposed rule to bring equity-indexed annuities under the SEC's regulatory purviews. Proposed rule: "indexed Annuities and certain other insurance contacts." Release number: 33-8933. Commodities: Monitor action of the CFTC and Congress on speculation in the energy markets. Short Selling: Followed SEC's action regarding reinstating the uptick rule for short selling. Hedge funds and private equity: Monitor S.344 Hedge Fund Transparency Act; S.1276 private Fund Transparency Act of 2009. Consumer Financial Protection Agency: Monitor H.R.3126, legislation to create a new agency to oversee the financial services industry. Derivatives: Monitor new rules and changes of regulation for derivatives and commodity indexed funds, and activity within Congress. Senior Investor Protection Act, S.906: Monitor legislation designed to protect seniors wishing to buy financial products from unqualified advisors: monitor together with trade association. Target Date Funds: Monitor possible legislation and SEC as well as Department of Labor regulatory activities. Credit default swap regulation: Monitor S.961 Authorizing the Regulation of Swaps Act Restructuring of the Commodity Futures Trading Commission: Monitor Obama Administration proposals. 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, GROWTH Act, S.1082

LobbyistCovered position, as disclosed
PETER A LEFKIN —
GRETCHEN ANN LINDQUIST Senior Legislative Assistant
RASHMI SUTTON Counsel, House Financial Services Committee

Contacted: Securities & Exchange Commission (SEC); SENATE; Treasury, Dept of; Risk Management Agency; HOUSE OF REPRESENTATIVES

Bills named: S. 1082 (111th), S. 906 (111th), S. 961 (111th), S. 1276 (111th), H.R. 3126 (111th), S. 344 (111th)

Taxation/Internal Revenue Code TAX

Cascading taxes for foreign-owned insurers: Advocate against measures 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 reinsures the U.S. risk. The IRS issued a ruling on this in March (IRS Ruling 2009-15). Exchange traded notes: For PIMCO followed issue through trade association Investment Company Institute. EIN's are an alternative to mutual funds and enjoy a tax preference. Treasury has recently weighed in and may view this current tax treatment as not appropriate. Reinsurance taxation: Advocate against the introduction of legislation. This legislation would prohibit offshore reinsurance affiliates of insurance companies not required to pay U.S. taxes from taking deduction for "excel reinsurance premiums" for domestic risks. Let Wall Street Pay tax proposal: Oppose provision of H.R. 1068, the Let Wall Street Pay for Wall Street's Bailout Act of 2009, that would tax securities transfer and transactions. Monitor and oppose Obama Administration tax proposals that would change existing tax laws and increase tax requirements for life insurers.

LobbyistCovered position, as disclosed
PETER A LEFKIN —
GRETCHEN ANN LINDQUIST Senior Legilsative Assistant
RASHMI SUTTON Counsel, House Financial Services Committee

Contacted: Securities & Exchange Commission (SEC); HOUSE OF REPRESENTATIVES; Risk Management Agency; SENATE; Treasury, Dept of

Bills named: H.R. 1068 (111th)

Retirement RET

401(k)fee disclosure: Oppose reintroduction of legislation that would require 401 (k) plan administrators to reveal charges associated with four categories of fees: administrative fees, investment management fees, transaction fees, and other costs.

LobbyistCovered position, as disclosed
PETER A LEFKIN —
GRETCHEN ANN LINDQUIST Senior Legislative Assistant
RASHMI SUTTON Counsel, House Financial Services Committee

Contacted: Securities & Exchange Commission (SEC); Risk Management Agency; SENATE; HOUSE OF REPRESENTATIVES; Treasury, Dept of

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 Counsel, House Financial Services Committee

Contacted: Securities & Exchange Commission (SEC); SENATE; HOUSE OF REPRESENTATIVES; Treasury, Dept of; Risk Management Agency

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.