4th 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
$420,000
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.

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 CFTL. Hedge funds and private equity: Monitor S.244 Hedge Fund Transaprency Act, S.12276 Private Fund Transparency Act of 2009. Consumer Financial Protection Bureau: Monitor inclusion of this new agency in HR 4173, the Wall Street Reform and Consumer Protection Act and its implementation. Senior Investor Protection Act, S.906: Monitor legislation designed to protect seniors wishing to buy financial products from unqualified advisors; monitor together with trade associations. 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, GROWTH act S.1082. Proprietary Trading: Along with trade associations, monitor implementation of the "Volcker Rule", included as part of HR 4173, the Wall Street Reform and Consumer Protection Act. This will restart the ability of some institutions to engage in proprietary trading and investing in hedge and private equity funds.

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

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

Bills named: H.R. 4173 (111th), S. 244 (111th), S. 12276 (111th), S. 906 (111th), S. 1082 (111th)

Banking BAN

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. H.R. 4173, the Dodd-Frank wall Street Reform and Consumer Protection Act, follow implementation 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 of the Financial Stability Oversight council and the establishment of the Federal Insurance Office and Consumer Financial Protection Agency. 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: SENATE; Treasury, Dept of; Securities & Exchange Commission (SEC); HOUSE OF REPRESENTATIVES; Commodity Futures Trading Commission (CFTC); Risk Management Agency; Labor, Dept of (DOL)

Bills named: H.R. 1924 (111th), H.R. 4173 (111th)

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 reinsures the U.S. risk. The IRS issued a ruling of this in March (IRS ruling 2009-15). 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 weighed in and may view this current tax treatment as not appropriate. Related-party reinsurance taxation: Advocate against legislation, H.R. 3424 by Rep. Richard Neal (D-MA). This legislation would prohibit offshore reinsurance affiliates of insurance companies not required to pay U.S. taxes from taking deductions for "excel reinsurance premiums" for domestic risks. Monitor and oppose Obama Administration tax proposals that would change existing tax laws and increase tax requirements for life insurance. Monitor and oppose provision in "tax extenders" legislation (HR 4213, the American Jobs and Closing Tax Loopholes Act) that would increase taxes on carried interest. Monitor extension of Bush-era tax cuts, H.R. 4853, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010.

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

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

Bills named: H.R. 4853 (111th), H.R. 4213 (111th), H.R. 3424 (111th)

Retirement RET

401 (k) fee disclosure: Oppose 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. Monitor rule proposed by Department of Labor to increase 401 (k) fee disclosure.

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

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

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 treatment of insurers under the "Volcker rule" ban on proprietary trading and investment in hedge and private equity funds. Also, followed inclusion of section to create a Federal Insurance Office at Treasury. Along with trade associations, commented on advanced 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: Lobbied against the possible 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: Monitored 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 the progress of HR 2454, the American Clean Energy and Security Act of 2009/ Also through consultants, lobbied for passage of "home Star" legislation to provide incentives for residential energy efficiency retrofits. Also, lobbied for "Building Star" legislation, which would provide similar incentives for community building energy efficient retrofits. Municipal bond legislation: Monitor municipal bond legislation, specifically H.R. 2589, the 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, H.R. 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). Agents and Brokers: support NARABII: 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 association.

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

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

Bills named: H.R. 4173 (111th), H.R. 2554 (111th), H.R. 2454 (111th), H.R. 2589 (111th), H.R. 2549 (111th), H.R. 2748 (111th), H.R. 2057 (111th)

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

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.