Like all companies in the financial services industry, State Street is greatly impacted by
regulatory decisions on the federal, state and local levels. Where appropriate, we seek to
ensure that the firm's interests are represented as these policies are taking shape.
Articulating State Street's views on legislation or regulation impacting our business to
relevant decision makers benefits our stakeholders. Lobbying is an important and legitimate
part of the legislative and policy-making process, and such interactions with government
officials and legislators may be subject to a variety of regulatory or reporting obligations
in various jurisdictions. In all contacts with government officials, State Street employees
are required to fully comply with all applicable rules and regulations and the
Standards of Conduct.
At State Street, our Regulatory, Industry and Government Affairs (RIGA) division is
responsible for monitoring policy, legislative and regulatory developments globally, and for
engaging regulators and policymakers on these issues on behalf of State Street, either
directly or through trade organizations or outside consultants. As outlined in the Standard
of Conduct and the employee Political Contributions and Activities Policy, only State
Street's RIGA division is authorized to retain legislative lobbyists on behalf of State
Street. The activities of RIGA's lobbying professionals and their outside consultant(s) are
closely monitored. RIGA's lobbying professionals must comply with any requirements to attend
trainings on applicable laws, adhere to internal compliance policies including the
Anti-Bribery and Corruption Policy, and are expected to demonstrate the highest standards of
professional integrity. The
Nominating and Corporate Governance Committee of the Board of Directors
receives periodic reports from the head of RIGA on current legislative trends, upcoming
regulatory issues, trade association memberships and lobbying initiatives, expenses and
processes. More information on the RIGA division, including recent comment letters filed
with regulatory bodies, can be found online at:
https://www.statestreet.com/disclosures-and-disclaimers/regulatory-industry-government-affairs.
Lobbying Disclosures:
Consistent with the reporting requirements of the U.S. Lobbying Disclosure Act and the
related guidance regularly issued by the Secretary of the U.S. Senate and the Clerk of the
U.S. House of Representatives, we file a quarterly report (Form LD-2) of our U.S. lobbying
activities. This report contains a good faith estimate of our total expenditures for U.S.
lobbying, including internal expenses, payments to lobbying firms and portions of industry
association dues attributable to lobbying activities. The report also includes a general
description of our lobbying activity for the relevant quarter, as well as the name of each
individual who acted as a lobbyist for each lobbied issue. Our quarterly lobbying reports on
Forms LD-2 can be found online at: https://disclosurespreview.house.gov/.
We also file semi-annual lobbying reports with the Commonwealth of Massachusetts with
respect to our Massachusetts lobbying. As with U.S. filings, these reports include estimates
of internal expenses and payments to lobbying firms. The following is a link to find more
detailed semi-annual reporting information on our Massachusetts lobbying expenditures: http://www.sec.state.ma.us/lob/lobidx.htm.
Trade Organizations:
State Street participates in and pays membership dues to a number of industry trade
organizations. Participation in these organizations is important to gain industry insight,
foster relationships and professional opportunities within the business and to collaborate
on topics of mutual interest.
Our principal U.S. trade organizations are those to which we pay annual membership fees in
excess of $50,000 and, for these purposes, which notify us that a portion of those fees is
nondeductible for U.S. income tax purposes. We may not always support or align with the
stated position of these organizations or their members, but recognize the importance and
overall benefit of our participation in groups that advocate and help to shape public
policy. We periodically assess an organization's scope and purpose to identify where their
positions may materially diverge from State Street's positions, including on environmental,
social, and governance (ESG) issues, and evaluate the benefit of continued membership. Our
principal U.S. trade organizations in 2022 are identified below.
Principal U.S. Trade Organizations |
American Bankers Association |
Bank Policy Institute |
Business Roundtable |
Chamber of Digital Commerce |
Financial Services Forum |
Greater Boston Chamber of Commerce |
Insured Retirement Institute |
International Swaps and Derivatives Association |
Investment Company Institute |
Managed Funds Association |
Massachusetts Bankers Association |
Securities Industry and Financial Markets Association - Asset Management Group
|
Securities Industry and Financial Markets Association |
U.S.-Kuwait Business Council |