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
Standard 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. 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 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:
http://www.statestreet.com/about/regulatory-industry-government-affairs.html.
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 and evaluate the benefit of continued membership. Our principal U.S.
trade organizations are identified below.
Principal U.S. Trade Organizations
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American Bankers Association
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Bank Policy Institute
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Business Roundtable
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Financial Services Forum
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Greater Boston Chamber of Commerce
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Insured Retirement Institute
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International Swaps and Derivatives Association
(ISDA)
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Investment Company Institute (ICI)
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Massachusetts Bankers Association
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Securities Industry and Financial Markets
Association - Asset
Management Group
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Securities Industry and Financial Markets
Association
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U.S.-Kuwait Business Council
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