Protecting Consumers from Unreasonable Credit Rates Act of 2009

HR 2563, Payday Lending Reform Act of 2009, all provisions; S. 500/HR 1608 - Protecting Consumers from Unreasonable Credit Rates Act of 2009, all provisions; H.R. 4173/S. 3217, the "Wall Street Reform and Consumer Protection Act." HR 1214 Payday Loan Reform Act of 2009, all provisions, to establish additional payday loan disclosure requirements and other protections for consumers, and for other purposes. S. 2824 Title: A bill to establish a small dollar loan-loss guarantee fund, and for other purposes. S. 257 - Consumer Credit Fairness Act, all provisions; H.R. 3126 Consumer Financial Protection Agency Act of 2009, all provisions. Sen. Dodd Mark-up/Reg Reform, no bill number H.R. 1846. CLEAR Act, To amend the Truth in Lending Act to establish additional payday loan disclosure requirements and preempt certain State laws, and for other purposes; Implementation of H.R. 4173, Wall Street Reform and Consumer Protection Act; Monitor data security and online privacy legislation.

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General financial issues and issues pertaining to the company; bills: S. 3632, H.R. 1214, H.R. 2563, H.R. 1846, H.R. 1608

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

REGULATORY REFORM, GENERALLY; HR 2563, Payday Lending Reform Act of 2009, all provisions; S. 500/HR 1608 - Protecting Consumers from Unreasonable Credit Rates Act of 2009, all provisions; HR 1846, Consumer Lending Education and Reform Act, all provisions; HR 1214 Payday Loan Reform Act of 2009, all provisions, to establish additional payday loan disclosure requirements and other protections for consumers, and for other purposes. S. 2824 Title: A bill to establish a small dollar loan-loss guarantee fund, and for other purposes. S. 257 - Consumer Credit Fairness Act, all provisions; H.R. 3126 Consumer Financial Protection Agency Act of 2009, all provisions. H.R.2563 Title: To amend the Truth in Lending Act to establish additional protections for consumers with regard to payday loans, and for other purposes. H.R. 1846. CLEAR Act, To amend the Truth in Lending Act to establish additional payday loan disclosure requirements and preempt certain State laws, and for other purposes; H.R. 4173/S. 3217, Wall Street Reform and Consumer Protection Act, To provide for financial regulatory reform, to protect consumers and investors, to enhance Federal understanding of insurance issues, to regulate the over-the-counter derivatives markets, and for other purposes.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 1214, HR 1608, HR 1640, HR 1846, HR 2309, Hr 2563, HR 5942 S 257, S 500

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues regarding commercial credit providers, including: S. 585, S. 582, S. 566, S. 500, S. 414, S. 399, S. 392, S. 257, S. 255, S. 235, S. 165, S. 131, H.R. 1882, H.R. 1846, H.R. 1705, H.R. 1640, H.R. 1637, H.R. 1608, H.R. 1479, H.R. 1456, H.R. 1365, H.R. 1325, H.R. 1214, H.R. 627. Issues related to proposed Consumer Financial Protection Agency. Dodd-Frank Wall Street Reform and Consumer Protection Act. Start up of Consumer Financial Protection Bureau.

Client expense: Not reported · Firm income: $90,000

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Issues related to commercial credit providers, including: S. 585, S. 582, S. 566, S. 500, S. 414, S. 399, S. 392, S. 257, S. 255, S. 235, S. 165, S. 131, H.R. 1882, H.R. 1846, H.R. 1705, H.R. 1640, H.R. 1637, H.R. 1608, H.R. 1479, H.R. 1456, H.R. 1365, H.R. 1325, H.R. 1214, H.R. 627. Issues related to proposed new Consumer Financial Protection Agency. Dodd-Frank Wall Street Reform and Consumer Protection Act. Start-up operations of the Consumer Financial Protection Bureau. NEED TO ADD CFPB TO LIST OF AGENCIES BELOW TO SELECT FROM

Client expense: Not reported · Firm income: $90,000

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

HR 1214, Hr 1608, HR 1640, HR 1846, HR 2309, HR 2563, HR 4173 S 257, S 500, S 3217

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 500/HR1608, Protecting Consumer from Unreasonable Credit Rates Act of 2009: HR 1640 Interest Rate Reduction Act; HB 1705/S.566, Financial Product Safety Commission Act of 2009, HR 1214, Payday Loan Reform Act of 2009;S 582, Interest Rate Reduction Act; HB 1456. Various bills relating the Truth & Lending Act (Overdraft, Service Charges & payday loan disclosures), H.R.4173, Dodd-Frank Wall Street Reform and Consumer Protection Act, issues related to regulatory reform

Client expense: $220,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Lobbying issues were: CFPA (encouraging Congress to create an effective federal consumer-focused banking regulator); credit cards (encouraging Congress to speed up the implementation of the Federal Reserve's new regulations and to add additional consumer protections); overdraft loans (encouraging Congress to implement restrictions on abusive overdraft practices); payday loans (encouraging Congress to prohibit abusive products and practices); [continued on next page] [continued from previous page] mortgage lending (encouraging Congress to prohibit abusive products and practices); mortgage loan modifications (encouraging Congress to provide incentive for servicers to modify loans to prevent foreclosures) Specific legislation that was the subject of lobbying activity: S61: Helping Families Save their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) S257: Consumer Credit Fairness Act (to require the bankruptcy court to disallow any claim arising from an abusive high cost consumer credit transaction) S500: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) S585: Taxpayer Abuse Prevention Act (to provide additional protections for recipients of the earned income tax credit) S786: Improving Access to Mainstream Financial Institutions Act of 2009 (to establishing alternative small-dollar lending program to payday loans) S2824: Amendment to Community Development Banking and Financial Institutions Act of 1994 (to establish a small dollar loan-loss guarantee fund that insures fair and affordable small dollar loans) S3217: Restoring American Financial Stability Act of 2010, and related amendments (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) S3245: The Payday Lending Limitation Act of 2010 (to limit abusive aspects of payday loans) S.AMDT.4311 to HR4213: Franken/Snowe Amendment (to create an Office of the Homeowner Advocate) HR200: Helping Families Save Their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modifications for primary residences through the bankruptcy code) HR225: Emergency Homeownership and Equity Protection Act (to allow for judicial loan modification for primary residences through the bankruptcy code) HR1106: Helping Families Save their Homes Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) HR1214: Payday Loan Reform Act of 2009 (to limit the most abusive aspects of payday loans) HR1456: Consumer Overdraft Protection Fair Practices Act (to create federal protections against abusive and unfair overdraft practices) HR1608: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) HR1637: Universal Default Prohibition Act of 2009 (to eliminate universal increases in interest rate on a credit card when cardholders default on accounts with other creditors) HR1782: Fairness for Homeowners Act of 2009 (to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR1846: Consumer Lending Education And Reform Act (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR2309: Consumer Credit and Debt Protection Act (to grant the FTC expedited rule-making authority) HR2563: Payday Lending Reform Act of 2009 (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR3904: Overdraft Protection Act of 2009 (to create federal protections against abusive and unfair overdraft practices) HR4173: The Wall Street Reform and Consumer Protection Act of 2009, and related amendments (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions, and to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR4229: Borrowers' Right to Inspect Closing Documents Act of 2009 (to require more timely delivery of loan and closing documents to borrower) HR4300: Restoring America's Commitment to Consumers Act of 2009 (favoring a 36% inclusive interest rate cap) HR5689: Predatory Lending Sunset Act (to place a cap on the rate of interest allowed on small-dollar consumer loans) HR5942: FFSCC Act of 2010 (to protect existing state laws limiting abusive payday lending practices) House and Senate GSE Bills, not yet introduced (to ensure there is a secondary housing market to serve low- and moderate-income communities) Freedom of Mobility in Banking Act, not yet introduced (to facilitate consumers' ability to change banking accounts, including protection from unfair related fees) Executive branch agencies and issues: Dept. of Treasury -- Consumer Financial Protection Agency, HAMP, GSE reform, Bank On program Federal Trade Commission -- debt settlement, auto financing Banking agencies (Federal Reserve System, FDIC, OCC, OTS) -- testified at hearing on reforms to Community Reinvestment Act HUD -- GSE reform FDIC -- overdraft loans

Client expense: $140,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

1)Reform Financial Services Regulation. Provided comments to hill, signed letters, testified, lobbied on all aspects of legislation and proposed regulations pertaining to reform Consumer Financial Protection Agency (HR 3126, HR 4173) and other reforms to expand prudential regulation and add mortgage reforms and improve safety net as the Wall Street Reform and Consumer Protection Act--HR 4173 and the (S 3217) Dodd companion bill in the Senate, Restoring American Financial Stability Act. Became Law 21 July 2010. 2) Support efforts against unfair bank fees, including support for HR 1456, the Consumer Overdraft Protection Fair Practices Act (testified in House in March 2009). 3) Support reinstatement of federal usury ceilings on financial transactions (S. 500/HR 1608). 4) Support efforts to implement strong consumer and transparency protections in various regulations including gift cards, credit cards, overdraft fees, before Federal Reserve and other financial agencies. 5) Testify (6/16/2010) before Senate Appropriations in support of Durbin interchange fee amendment to S 3217/HR 4173 and 4/28 before House Judiciary re support for antitrust interchange legislation, HR 2695. 6) Support efforts (Sec. 4901, HR 4173) to grant greater authority to FTC to better protect consumers against financial fraud and impose greater sanctions against wrongdoers. 8) Urged administration/DOJ to support state causes of actions/state attorneys general enforcement authority in various state and federal cases including Cuomo vs. Clearinghouse and OCC. 9) In various fora, urged administration, State and USTR to support international financial rules as floor not ceiling of consumer protection; 10) Support S 1595, Deceptive Loan Check Elimination Act.

Client expense: $90,000 · Firm income: Not reported

Government targets: Consumer Product Safety Commission (CPSC), Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Natl Economic Council (NEC), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Legislation surrounding maximum rates of interest, S.500 and HR 1608. HR 4173 Wall Street Reform and Consumer Protection Act of 2009; S. 3217 Restoring American Financial Stability Act of 2010

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Oppose "vulture funds". Support debt relief for poor nations, a.k.a. the Jubilee Act. Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowner facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support efforts to eliminate predatory loans; support 1728. Oppose payday loans; working to improve H.R. 1214. Support 36% interest rate cap; support H.R. 1608 / S. 500. Support legislation to toughen financial fraud investigations and sentences; support S. 386. Support legislation to make it easier for homeowners to modify their mortgages through federal programs; support S. 896. Support the creation of a Consumer Financial Protection Agency (CFPA) with strong civil rights mandates. Support financial literacy programs. Support an increase the demographic diversity of the financial services industry. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Support financial counseling. oppose exempting Rent-to-Own operations from CFPA oversight. Support for the Benefit Card Fairness Act, H.R. 4552. Support creation of a strong CFPA, without exempting car dealers or student lenders, rent-to-own stores or payday lenders from its purview. Oppose federal preemption of state consumer financial protection laws. Ensure that rogue auto dealers are not exempted from the authority of the newly created Consumer Financial Protection Bureau, while at the same time ensuring that small, minority owned auto dealers who are fair to consumers are not run out of business. Support the creation of a strong, independent Consumer Financial Protection Bureau in H.R. 4173. Support S. 3245, the Payday Limitation Act of 2010. This legislation takes an aggressive approach to eliminating the worst of the payday debt trap problems. Support final passage of the conference report for H.R. 4173, the Restoring American Financial Stability Act. Support S. 3217, the Restoring American Financial Stability Act of 2010. Support H.R. 3149, the Equal Employment for All Act, which would outlaw the use of credit scores by potential employers when making hiring decisions. Support Creation of the Offices of Minority and Women Inclusion Under the Restoring American Financial Stability Act of 2010. Support FDIC guidence issued on limiting abusive overdract practices. Support Elizabeth Warren to be the first head of the Consumer Financial Protection Bureau. Support allowing consumers to close a bank account without incurring onerous fees.

Client expense: $50,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Bureau of Investigation (FBI), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Personnel Management (OPM), SENATE, Small Business Administration (SBA), Social Security Administration (SSA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Commission on Civil Rights, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA), Voice of America, White House Office

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowners facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Oppose payday lending, working to help improve H.R. 1214. Support efforts to eliminate predatory lending. Support H.R. 1728. Support the establishment of a Consumer Financial Protection Agency (working to improve H.R. 3126). Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support 36% interest rate cap; support H.R. 1608 / S. 500. Work to eliminate the debt trap caused by payday lenders. Support financial literacy programs. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Oppose the proposed Adverse Market Delivery Charge (AMDC) as well as the series of Loan Level Price Adjustments (LLPAs) under consideration by Fannie Mae and Freddie Mac. Ensure that rogue auto dealers are not exempted from the authority of the newly created Consumer Financial Protection Bureau, while at the same time ensuring that small, minority owned auto dealers who are fair to consumers are not run out of business. Support the creation of a strong, independent Consumer Financial Protection Bureau in H.R. 4173. Support S. 3245, the Payday Limitation Act of 2010. This legislation takes an aggressive approach to eliminating the worst of the payday debt trap problems. Support final passage of the conference report for H.R. 4173, the Restoring American financial Stability Act. Support S. 3217, the Restoring American Financial Stability Act of 2010. Support H.R. 3421, the The Medical Debt Relief Act of 2009. Support the creation of the Offices of Minority and Women Inclusion Under the Restoring American Financial Stability Act of 2010. Support a ban on the use of credit reports by potential employers. Support H.R. 3149. Support FDIC guidence issued on limiting abusive overdract practices. Support Elizabeth Warren to be the first head of the Consumer Financial Protection Bureau. Support allowing consumers to close a bank account without incurring onerous fees.

Client expense: $50,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Bureau of Investigation (FBI), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Personnel Management (OPM), SENATE, Small Business Administration (SBA), Social Security Administration (SSA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Commission on Civil Rights, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA), Voice of America, White House Office

REGULATORY REFORM, GENERALLY; HR 2563, Payday Lending Reform Act of 2009, all provisions; S. 500/HR 1608 - Protecting Consumers from Unreasonable Credit Rates Act of 2009, all provisions; HR 1846, Consumer Lending Education and Reform Act, all provisions; HR 1214 Payday Loan Reform Act of 2009, all provisions, to establish additional payday loan disclosure requirements and other protections for consumers, and for other purposes. S. 2824 Title: A bill to establish a small dollar loan-loss guarantee fund, and for other purposes. S. 257 - Consumer Credit Fairness Act, all provisions; H.R. 3126 Consumer Financial Protection Agency Act of 2009, all provisions. H.R.2563 Title: To amend the Truth in Lending Act to establish additional protections for consumers with regard to payday loans, and for other purposes. H.R. 1846. CLEAR Act, To amend the Truth in Lending Act to establish additional payday loan disclosure requirements and preempt certain State laws, and for other purposes; H.R. 4173/S. 3217, Wall Street Reform and Consumer Protection Act, To provide for financial regulatory reform, to protect consumers and investors, to enhance Federal understanding of insurance issues, to regulate the over-the-counter derivatives markets, and for other purposes.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 2563, Payday Lending Reform Act of 2009, all provisions; S. 500/HR 1608 - Protecting Consumers from Unreasonable Credit Rates Act of 2009, all provisions; H.R. 4173/S. 3217, the "Wall Street Reform and Consumer Protection Act." HR 1214 Payday Loan Reform Act of 2009, all provisions, to establish additional payday loan disclosure requirements and other protections for consumers, and for other purposes. S. 2824 Title: A bill to establish a small dollar loan-loss guarantee fund, and for other purposes. S. 257 - Consumer Credit Fairness Act, all provisions; H.R. 3126 Consumer Financial Protection Agency Act of 2009, all provisions. Sen. Dodd Mark-up/Reg Reform, no bill number H.R. 1846. CLEAR Act, To amend the Truth in Lending Act to establish additional payday loan disclosure requirements and preempt certain State laws, and for other purposes; Implementation of H.R. 4173, Wall Street Reform and Consumer Protection Act; Monitor data security and online privacy legislation.

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General financial issues and issues pertaining to the company; bills: S. 3632, H.R. 1214, H.R. 2563, H.R. 1846, H.R. 1608

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues regarding commercial credit providers, including: S. 585, S. 582, S. 566, S. 500, S. 414, S. 399, S. 392, S. 257, S. 255, S. 235, S. 165, S. 131, H.R. 1882, H.R. 1846, H.R. 1705, H.R. 1640, H.R. 1637, H.R. 1608, H.R. 1479, H.R. 1456, H.R. 1365, H.R. 1325, H.R. 1214, H.R. 627. Issues related to proposed Consumer Financial Protection Agency. Dodd-Frank Wall Street Reform and Consumer Protection Act

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to commercial credit providers, including: S. 585, S. 582, S. 566, S. 500, S. 414, S. 399, S. 392, S. 257, S. 255, S. 235, S. 165, S. 131, H.R. 1882, H.R. 1846, H.R. 1705, H.R. 1640, H.R. 1637, H.R. 1608, H.R. 1479, H.R. 1456, H.R. 1365, H.R. 1325, H.R. 1214, H.R. 627. Issues related to proposed new Consumer Financial Protection Agency. Dodd-Frank Wall Street Reform and Consumer Protection Act

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Payday Loan Reform Act of 2009, H.R. 1214 Financial Product Safety Commission Act of 2009, S. 566 Protecting Consumers from Unreasonable Credit Rates Act of 2009, H.R. 1608, S. 500 Universal Default Prohibition Act of 2009, H.R. 1637 Consumer Financial Protection Agency Act of 2009, H.R. 3126 The Consumer Credit Fairness Act, S. 257

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 1214, HR 1608, HR 1640, HR 1846, HR 2309, HR 2563, HR 3126, HR 4173 S 257, S 500, S 3217

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 500/HR1608, Protecting Consumer from Unreasonable Credit Rates Act of 2009: HR 1640 Interest Rate Reduction Act; HB 1705/S.566, Financial Product Safety Commission Act of 2009, HR 1214, Payday Loan Reform Act of 2009;S 582, Interest Rate Reduction Act; HB 1456. Various bills relating the Truth & Lending Act (Overdraft, Service Charges & payday loan disclosures), HB 4173 Regulatory Reform, S. 3217 - "Restoring American Financial Stability Act of 2010".

Client expense: $240,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 500/HR1608, Protecting Consumer from Unreasonable Credit Rates Act of 2009: HR 1640 Interest Rate Reduction Act; HB 1705/S.566, Financial Product Safety Commission Act of 2009, HR 1214, Payday Loan Reform Act of 2009;S 582, Interest Rate Reduction Act; HB 1456. Various bills relating the Truth & Lending Act (Overdraft, Service Charges & payday loan disclosures), HB 4173 Regulatory Reform, S. 3217 - "Restoring American Financial Stability Act of 2010".

Client expense: $240,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Lobbying issues were: CFPA (encouraging Congress to create an effective federal consumer-focused banking regulator); credit cards (encouraging Congress to speed up the implementation of the Federal Reserve's new regulations and to add additional consumer protections); overdraft loans (encouraging Congress to implement restrictions on abusive overdraft practices); payday loans (encouraging Congress to pass a 36% rate cap on consumer loans); [continued on next page] [continued from previous page] mortgage lending (encouraging Congress to prohibit abusive products and practices); mortgage loan modifications (encouraging Congress to provide incentives for servicers to modify loans to prevent foreclosures) Specific legislation that was subject of lobbying activity: S61: Helping Families Save their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) S257: Consumer Credit Fairness Act (to require the bankruptcy court to disallow any claim arising from an abusive high cost consumer credit transaction) S500: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) S585: Taxpayer Abuse Prevention Act (to provide additional protections for recipients of the earned income tax credit) S1799: FAIR Overdraft Coverage Act of 2009 (to create federal protections against abusive and unfair overdraft practices) S2824: Amendment to Community Development Banking and Financial Institutions Act of 1994 to establish a small dollar loan-loss guarantee fund, and for other purposes (to establish a small dollar loan-loss guarantee fund that insures fair and affordable small dollar loans) S3217: Restoring American Financial Stability Act of 2010, and related amendments (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) S3245: The Payday Loan Limitation Act (to place a cap on the rate of interest allowed on payday loans) HR200: Helping Families Save Their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) HR225: Emergency Homeownership and Equity Protection Act (to allow for judicial loan modification for primary residences through the bankruptcy code) HR1106: Helping Families Save their Homes Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) HR1214: Payday Loan Reform Act of 2009 (to limit the most abusive aspects of payday loans) HR1456: Consumer Overdraft Protection Fair Practices Act (to create federal protections against abusive and unfair overdraft practices) HR1608: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) HR1637: Universal Default Prohibition Act of 2009 (to eliminate universal increases in interest rate on a credit card when cardholders default on accounts with other creditors) HR1728: Mortgage Reform and Anti-Predatory Lending Act (to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR1782: Fairness for Homeowners Act of 2009 (to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR1846: Consumer Lending Education And Reform Act (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR2309: Consumer Credit and Debt Protection Act (to grant the FTC expedited rule-making authority) HR2563: Payday Lending Reform Act of 2009 (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR3126: Consumer Financial Protection Agency Act of 2009 (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) HR3639: Expedited CARD Reform for Consumers Act of 2009 (to move up the effective date of the Credit CARD Act to December 1, 2009) HR3904: Overdraft Protection Act of 2009 (to create federal protections against abusive and unfair overdraft practices) HR4173: The Wall Street Reform and Consumer Protection Act of 2009, and related amendments (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) HR4229: Borrowers' Right to Inspect Closing Documents Act of 2009 (to require more timely delivery of loan and closing documents to borrower) HR5689: Predatory Lending Sunset Act (to place a cap on the rate of interest allowed on small-dollar consumer loans) Senate regulatory reform draft bill (not yet introduced) (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) Senate payday alternatives amendment (not yet introduced) (to create an alterative for abusive small-dollar loans) Senate FDIC payday standard (not yet introduced) (to create consumer protections for payday loan borrowers) Executive branch agencies and issues: Federal Reserve - Truth In Lending rescission rules Dept. of Treasury - Consumer Financial Protection Agency, HAMP Federal Trade Commission - debt settlement

Client expense: $205,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowners facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Oppose payday lending, working to help improve H.R. 1214. Support efforts to eliminate predatory lending. Support H.R. 1728. Support the establishment of a Consumer Financial Protection Agency (working to improve H.R. 3126). Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support 36% interest rate cap; support H.R. 1608 / S. 500. Work to eliminate the debt trap caused by payday lenders. Support financial literacy programs. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Oppose the proposed Adverse Market Delivery Charge (AMDC) as well as the series of Loan Level Price Adjustments (LLPAs) under consideration by Fannie Mae and Freddie Mac. Ensure that rogue auto dealers are not exempted from the authority of the newly created Consumer Financial Protection Bureau, while at the same time ensuring that small, minority owned auto dealers who are fair to consumers are not run out of business. Support the creation of a strong, independent Consumer Financial Protection Bureau in H.R. 4173. Support S. 3245, the Payday Limitation Act of 2010. This legislation takes an aggressive approach to eliminating the worst of the payday debt trap problems. Support final passage of the conference report for H.R. 4173, the Restoring American financial Stability Act. Support S. 3217, the Restoring American Financial Stability Act of 2010. Support H.R. 3421, the The Medical Debt Relief Act of 2009. Support the creation of the Offices of Minority and Women Inclusion Under the Restoring American Financial Stability Act of 2010

Client expense: $50,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Bureau of Investigation (FBI), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Personnel Management (OPM), SENATE, Small Business Administration (SBA), Social Security Administration (SSA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Commission on Civil Rights, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA), Voice of America, White House Office

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Oppose "vulture funds". Support debt relief for poor nations, a.k.a. the Jubilee Act. Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowner facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support efforts to eliminate predatory loans; support 1728. Oppose payday loans; working to improve H.R. 1214. Support 36% interest rate cap; support H.R. 1608 / S. 500. Support legislation to toughen financial fraud investigations and sentences; support S. 386. Support legislation to make it easier for homeowners to modify their mortgages through federal programs; support S. 896. Support the creation of a Consumer Financial Protection Agency (CFPA) with strong civil rights mandates. Support financial literacy programs. Support an increase the demographic diversity of the financial services industry. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Support financial counseling. oppose exempting Rent-to-Own operations from CFPA oversight. Support for the Benefit Card Fairness Act, H.R. 4552. Support creation of a strong CFPA, without exempting car dealers or student lenders, rent-to-own stores or payday lenders from its purview. Oppose federal preemption of state consumer financial protection laws. Ensure that rogue auto dealers are not exempted from the authority of the newly created Consumer Financial Protection Bureau, while at the same time ensuring that small, minority owned auto dealers who are fair to consumers are not run out of business. Support the creation of a strong, independent Consumer Financial Protection Bureau in H.R. 4173. Support S. 3245, the Payday Limitation Act of 2010. This legislation takes an aggressive approach to eliminating the worst of the payday debt trap problems. Support final passage of the conference report for H.R. 4173, the Restoring American Financial Stability Act. Support S. 3217, the Restoring American Financial Stability Act of 2010. Support H.R. 3149, the Equal Employment for All Act, which would outlaw the use of credit scores by potential employers when making hiring decisions. Support Creation of the Offices of Minority and Women Inclusion Under the Restoring American Financial Stability Act of 2010.

Client expense: $50,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Bureau of Investigation (FBI), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Personnel Management (OPM), SENATE, Small Business Administration (SBA), Social Security Administration (SSA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Commission on Civil Rights, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA), Voice of America, White House Office

Legislation surrounding maximum rates of interest, S.500 and HR 1608. HR 4173 Wall Street Reform and Consumer Protection Act of 2009; S. 3217 Restoring American Financial Stability Act of 2010

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

1)Reform Financial Services Regulation. Provided comments to hill, signed letters, testified, lobbied on all aspects of legislation and proposed regulations pertaining to reform Consumer Financial Protection Agency (HR 3126, HR 4173) and other reforms to expand prudential regulation and add mortgage reforms and improve safety net as the Wall Street Reform and Consumer Protection Act--HR 4173 and the (S 3217) Dodd companion bill in the Senate, Restoring American Financial Stability Act. 2) Support efforts against unfair bank fees, including support for HR 1456, the Consumer Overdraft Protection Fair Practices Act (testified in House in March 2009). 3) Support reinstatement of federal usury ceilings on financial transactions (S. 500/HR 1608). 4) Support efforts to implement strong consumer and transparency protections in various regulations including gift cards, credit cards, overdraft fees, before Federal Reserve and other financial agencies. 5) Testify (6/16) before Senate Appropriations in support of Durbin interchange fee amendment to S 3217/HR 4173 and 4/28 before House Judiciary re support for antitrust interchange legislation, HR 2695. 6) Support efforts (Sec. 4901, HR 4173) to grant greater authority to FTC to better protect consumers against financial fraud and impose greater sanctions against wrongdoers. 8) Urged administration/DOJ to support state causes of actions/state attorneys general enforcement authority in various state and federal cases including Cuomo vs. Clearinghouse and OCC. 9) In various fora, urged administration, State and USTR to support international financial rules as floor not ceiling of consumer protection; 10) Support S 1595, Deceptive Loan Check Elimination Act.

Client expense: $120,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Product Safety Commission (CPSC), Environmental Protection Agency (EPA), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Natl Economic Council (NEC), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

HR 2563, Payday Lending Reform Act of 2009, all provisions; S. 500/HR 1608 - Protecting Consumers from Unreasonable Credit Rates Act of 2009, all provisions; H.R. 4173/S. 3217, the "Wall Street Reform and Consumer Protection Act." HR 1214 Payday Loan Reform Act of 2009, all provisions, to establish additional payday loan disclosure requirements and other protections for consumers, and for other purposes. S. 2824 Title: A bill to establish a small dollar loan-loss guarantee fund, and for other purposes. S. 257 - Consumer Credit Fairness Act, all provisions; H.R. 3126 Consumer Financial Protection Agency Act of 2009, all provisions. Sen. Dodd Mark-up/Reg Reform, no bill number H.R. 1846. CLEAR Act, To amend the Truth in Lending Act to establish additional payday loan disclosure requirements and preempt certain State laws, and for other purposes; H.R. 4173, Wall Street Reform and Consumer Protection Act.

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

REGULATORY REFORM, GENERALLY; HR 2563, Payday Lending Reform Act of 2009, all provisions; S. 500/HR 1608 - Protecting Consumers from Unreasonable Credit Rates Act of 2009, all provisions; HR 1846, Consumer Lending Education and Reform Act, all provisions; HR 1214 Payday Loan Reform Act of 2009, all provisions, to establish additional payday loan disclosure requirements and other protections for consumers, and for other purposes. S. 2824 Title: A bill to establish a small dollar loan-loss guarantee fund, and for other purposes. S. 257 - Consumer Credit Fairness Act, all provisions; H.R. 3126 Consumer Financial Protection Agency Act of 2009, all provisions. H.R.2563 Title: To amend the Truth in Lending Act to establish additional protections for consumers with regard to payday loans, and for other purposes. H.R. 1846. CLEAR Act, To amend the Truth in Lending Act to establish additional payday loan disclosure requirements and preempt certain State laws, and for other purposes; H.R. 4173/S. 3217, Wall Street Reform and Consumer Protection Act, To provide for financial regulatory reform, to protect consumers and investors, to enhance Federal understanding of insurance issues, to regulate the over-the-counter derivatives markets, and for other purposes. Sen. Dodd draft version of the financial regulatory reform legislation

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

general financial services issues and issues pertaining to the company, Bills- S.3632, HR 1214, HR 2563, HR 1846, HR 1608

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues regarding commercial credit providers, including: S. 585, S. 582, S. 566, S. 500, S. 414, S. 399, S. 392, S. 257, S. 255, S. 235, S. 165, S. 131, H.R. 1882, H.R. 1846, H.R. 1705, H.R. 1640, H.R. 1637, H.R. 1608, H.R. 1479, H.R. 1456, H.R. 1365, H.R. 1325, H.R. 1214, H.R. 627. Issues related to proposed Consumer Financial Protection Agency. Dodd-Frank Wall Street Reform and Consumer Protection Act

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to commercial credit providers, including: S. 585, S. 582, S. 566, S. 500, S. 414, S. 399, S. 392, S. 257, S. 255, S. 235, S. 165, S. 131, H.R. 1882, H.R. 1846, H.R. 1705, H.R. 1640, H.R. 1637, H.R. 1608, H.R. 1479, H.R. 1456, H.R. 1365, H.R. 1325, H.R. 1214, H.R. 627. Issues related to proposed new Consumer Financial Protection Agency. Dodd-Frank Wall Street Reform and Consumer Protection Act

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Payday Loan Reform Act of 2009, H.R. 1214 Financial Product Safety Commission Act of 2009, S. 566 Protecting Consumers from Unreasonable Credit Rates Act of 2009, H.R. 1608, S. 500 Universal Default Prohibition Act of 2009, H.R. 1637 Consumer Financial Protection Agency Act of 2009, H.R. 3126 The Consumer Credit Fairness Act, S. 257

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Financial Regulation Reform S.500: Protecting Consumers from Unreasonable Credit Rates Act of 2009 H.R. 1608: Protecting Consumers from Unreasonable Credit Rates Act of 2009 Financial Stability Act of 2010

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 1214, HR 1608, HR 1640, HR 1846, HR 2309, HR 2563, HR 3126, HR 4173, S 257, S 500

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Oppose "vulture funds". Support debt relief for poor nations, a.k.a. the Jubilee Act. Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowner facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support efforts to eliminate predatory loans; support 1728. Oppose payday loans; working to improve H.R. 1214. Support 36% interest rate cap; support H.R. 1608 / S. 500. Support legislation to toughen financial fraud investigations and sentences; support S. 386. Support legislation to make it easier for homeowners to modify their mortgages through federal programs; support S. 896. Support the creation of a Consumer Financial Protection Agency (CFPA) with strong civil rights mandates. Support financial literacy programs. Support an increase the demographic diversity of the financial services industry. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Support financial counseling. oppose exempting Rent-to-Own operations from CFPA oversight. Support for the Benefit Card Fairness Act, H.R. 4552. Support creation of a strong CFPA, without exempting car dealers or student lenders, rent-to-own stores or payday lenders from its purview. Oppose federal preemption of state consumer financial protection laws.

Client expense: $50,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Bureau of Investigation (FBI), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Personnel Management (OPM), SENATE, Small Business Administration (SBA), Social Security Administration (SSA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Commission on Civil Rights, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA), Voice of America, White House Office

Eliminate predatory lending; ensure equal access to financial services to all Americans. Eliminate disparities in credit reporting. Ease home mortgage foreclosure crisis. Eliminate pay day lending (concerns about H.R. 1214). Support capping all interest rates at 36% APR (support H.R. 1608 / S. 500). Support a foreclosure moratorium (H.R. 527 / S. 241). Reform the mortgage servicers industry so that more loans are modified and fewer homes are foreclosed upon. Try to ensure that homeowners facing foreclosure are not forgotten in the Wall Street bailout. Try to stop abusive credit card practices (support H.R. 627 / S. 414). Support H.R. 200 / H.R. 1106 / S. 61, which allows bankruptcy judges to require loan modifications on primary residence mortgages. Oppose payday lending, working to help improve H.R. 1214. Support efforts to eliminate predatory lending. Support H.R. 1728. Support the establishment of a Consumer Financial Protection Agency (working to improve H.R. 3126). Support reauthorization, modernization and expansion of the Community Reinvestment Act (CRA), support H.R. 1479. Support 36% interest rate cap; support H.R. 1608 / S. 500. Work to eliminate the debt trap caused by payday lenders. Support financial literacy programs. Support H.R. 4173. Oppose exempting auto dealers from newly created CFPA. Oppose exempting college loans from CFPA. Oppose allowing CFPA, and all federal lending laws, to preempt stronger state laws. Support regulations to shut down yield spread premiums to mortgage brokers. Oppose the proposed Adverse Market Delivery Charge (AMDC) as well as the series of Loan Level Price Adjustments (LLPAs) under consideration by Fannie Mae and Freddie Mac.

Client expense: $50,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Bureau of Investigation (FBI), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Personnel Management (OPM), SENATE, Small Business Administration (SBA), Social Security Administration (SSA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Commission on Civil Rights, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA), Voice of America, White House Office

Lobbying issues were: CFPA (encouraging Congress to create an effective federal consumer-focused banking regulator); credit cards (encouraging Congress to speed up the implementation of the Federal Reserve's new regulations and to add additional consumer protections); overdraft loans (encouraging Congress to implement restrictions on abusive overdraft practices); payday loans (encouraging Congress to pass a 36% rate cap on consumer loans); [continued on next page] [continued from previous page] mortgage lending (encouraging Congress to prohibit abusive products and practices); mortgage loan modifications (encouraging Congress to provide incentives for servicers to modify loans to prevent foreclosures) Specific legislation that was subject of lobbying activity: S61: Helping Families Save their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) S257: Consumer Credit Fairness Act (to require the bankruptcy court to disallow any claim arising from an abusive high cost consumer credit transaction) S414: Credit Card Accountability Responsibility and Disclosure Act of 2009 (to create consumer protections against credit card abusive practices) S500: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) S566: Financial Product Safety Commission Act of 2009 (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) S585: Taxpayer Abuse Prevention Act (to provide additional protections for recipients of the earned income tax credit) S1799: FAIR Overdraft Coverage Act of 2009 (to create federal protections against abusive and unfair overdraft practices) S2824: Amendment to Community Development Banking and Financial Institutions Act of 1994 to establish a small dollar loan-loss guarantee fund, and for other purposes (to establish a small dollar loan-loss guarantee fund that insures fair and affordable small dollar loans) HR200: Helping Families Save Their Homes in Bankruptcy Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) HR225: Emergency Homeownership and Equity Protection Act (to allow for judicial loan modification for primary residences through the bankruptcy code) HR627: Credit Cardholders' Bill of Rights Act of 2009 (to create consumer protections against credit card abusive practices) HR1106: Helping Families Save their Homes Act of 2009 (to allow for judicial loan modification for primary residences through the bankruptcy code) HR1214: Payday Loan Reform Act of 2009 (to limit the most abusive aspects of payday loans) HR1456: Consumer Overdraft Protection Fair Practices Act (to create federal protections against abusive and unfair overdraft practices) HR1608: Protecting Consumers from Unreasonable Credit Rates Act of 2009 (to create a federal 36% APR usury cap) HR1637: Universal Default Prohibition Act of 2009 (to eliminate universal increases in interest rate on a credit card when cardholders default on accounts with other creditors) HR1705: Financial Product Safety Commission Act of 2009 (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) HR1728: Mortgage Reform and Anti-Predatory Lending Act (to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR1782: Fairness for Homeowners Act of 2009 (to protect consumers against abusive, unfair, or deceptive practices in the mortgage marketplace) HR1846: Consumer Lending Education And Reform Act (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR2309: Consumer Credit and Debt Protection Act (to grant the FTC expedited rule-making authority) HR2563: Payday Lending Reform Act of 2009 (opposed the mere disclosure of abusive terms in payday loans and favored substantive consumer protections) HR3126: Consumer Financial Protection Agency Act of 2009 (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) HR3639: Expedited CARD Reform for Consumers Act of 2009 (to move up the effective date of the Credit CARD Act to December 1, 2009) HR3904: Overdraft Protection Act of 2009 (to create federal protections against abusive and unfair overdraft practices) HR4173: The Wall Street Reform and Consumer Protection Act of 2009 (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) HR4229: Borrowers' Right to Inspect Closing Documents Act of 2009 (to require more timely delivery of loan and closing documents to borrower) Senate regulatory reform draft bill (not yet introduced) (to create a single agency to have strong rulewriting and enforcement authority in consumer financial transactions) Senate payday alternatives amendment (not yet introduced) (to create an alterative for abusive small-dollar loans) Senate FDIC payday standard (not yet introduced) (to create consumer protections for payday loan borrowers) Executive branch agencies and issues: Federal Reserve - Truth In Lending rescission rules Dept. of Treasury - Consumer Financial Protection Agency FDIC GAO

Client expense: $130,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Legislation of the deferred desposit industry including H.R. 2309, Consumer Credit and Debt Protection Act; H.R. 1214, the Payday Loan Reform Act; H.R. 1846, the CLEAR Act; H.R. 1640, the Interest Rate Reduction Act, H.R. 1608 and S. 500, the Protecting Consumers from Unreasonable Credit Rates Act; and H.R. 2563, the Payday Lending Reform Act and the Restoring American Financial Stability Act, including regulation of non-bank lenders.

Client expense: Not reported · Firm income: $240,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Legislation surrounding maximum rates of interest, S.500 and HR 1608. HR 4173 Wall Street Reform and Consumer Protection Act of 2009; Restoring American Financial Stability Act of 2010

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Transparency in the Federal Reserve; 1) Reform Credit Card Practices. Provided comments to hill, signed letters, lobbied on all aspects of legislation and proposed regulations pertaining to reform of unfair practices of credit card industry. Bills include S 414, Credit CARD Act; HR 627, Credit Cardholders Bill of Rights Act, which became law. (As part of HR 627, unsuccessfully supported efforts to make interchange fees fairer and extend bill to include small business owners.) 2) Reform Mortgage Practices and Reform Financial Services Regulation. Provided comments to hill, signed letters, testified, lobbied on all aspects of legislation and proposed regulations pertaining to reform of mortgage and predatory lending. Bills included HR 1728 and HR 1782 on mortgage reform, supporting in part and opposing in part. 3) Provided comments to hill, signed letters, testified, lobbied on all aspects of legislation and proposed regulations pertaining to reform of financial industry by establishment of Financial Product Safety Commission, S. 566 and HR 1705 and renamed Consumer Financial Protection Agency (HR 3126) and other reforms to expand prudential regulation and improve safety net including the Wall Street Reform and Consumer Protection Act--HR 4173 and the (unnumbered) Dodd companion bill in the Senate, Restoring American Financial Stabiity Act. 4) Support efforts against unfair bank fees, including support for HR 1456, the Consumer Overdraft Protection Fair Practices Act (testified in House in March 2009). 5) Support reinstatement of federal usury ceilings on financial transactions (S. 500/HR 1608). 6) Support efforts to implement strong consumer and transparency protections in regulations and enforcement of the Emergency Economic Stabilization Act (HR 1424-Division A, became PL 110-343) and related bills. Supported bills including HR 384 and S 195 to reform the Troubled Asset Relief Program (TARP) and other programs established either by EESA or by federal regulators concerning financial reform and bailout funding. These and other similar bills would restore original purposes of bailout funds, increase transparency, limit executive compensation, grant greater authority to oversight agencies, etc. 7) Supported Section 626 of HR 1105 (Omnibus Appropriations) to grant greater authority to FTC and state attorneys general to better protect consumers against financial fraud and impose greater sanctions against wrongdoers. 8) urged administration/DOJ to support state causes of actions/state attorneys general enforcement authority in various state and federal cases including Cuomo vs. Clearinghouse and OCC. Testified in March 2010 before Senate Commerce Committee in support of stronger FTC authority in these areas. 8) In various fora, urged administration, State and USTR to support international financial rules as floor not ceiling of consumer protection; 9) Support S 1595, Deceptive Loan Check Elimination Act.

Client expense: $107,000 · Firm income: Not reported

Government targets: Consumer Product Safety Commission (CPSC), Education, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Natl Economic Council (NEC), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

S. 500/HR1608, Protecting Consumer from Unreasonable Credit Rates Act of 2009: HR 1640 Interest Rate Reduction Act; HB 1705/S.566, Financial Product Safety Commission Act of 2009, HR 1214, Payday Loan Reform Act of 2009;S 582, Interest Rate Reduction Act; HB 1456. Various bills relating the Truth & Lending Act (Overdraft, Service Charges & payday loan disclosures), HB 4173 Regulatory Reform, S. 3217 - "Restoring American Financial Stability Act of 2010".

Client expense: $270,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 2563, Payday Lending Reform Act of 2009, all provisions; S. 500/HR 1608 - Protecting Consumers from Unreasonable Credit Rates Act of 2009, all provisions; HR 1214 Payday Loan Reform Act of 2009, all provisions, to establish additional payday loan disclosure requirements and other protections for consumers, and for other purposes. S. 2824 Title: A bill to establish a small dollar loan-loss guarantee fund, and for other purposes. S. 257 - Consumer Credit Fairness Act, all provisions; H.R. 3126 Consumer Financial Protection Agency Act of 2009, all provisions. Sen. Dodd Mark-up/Reg Reform, no bill number H.R. 1846. CLEAR Act, To amend the Truth in Lending Act to establish additional payday loan disclosure requirements and preempt certain State laws, and for other purposes; H.R. 4173, Wall Street Reform and Consumer Protection Act.

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

REGULATORY REFORM, GENERALLY; HR 2563, Payday Lending Reform Act of 2009, all provisions; S. 500/HR 1608 - Protecting Consumers from Unreasonable Credit Rates Act of 2009, all provisions; HR 1846, Consumer Lending Education and Reform Act, all provisions; HR 1214 Payday Loan Reform Act of 2009, all provisions, to establish additional payday loan disclosure requirements and other protections for consumers, and for other purposes. S. 2824 Title: A bill to establish a small dollar loan-loss guarantee fund, and for other purposes. S. 257 - Consumer Credit Fairness Act, all provisions; H.R. 3126 Consumer Financial Protection Agency Act of 2009, all provisions. H.R.2563 Title: To amend the Truth in Lending Act to establish additional protections for consumers with regard to payday loans, and for other purposes. H.R. 1846. CLEAR Act, To amend the Truth in Lending Act to establish additional payday loan disclosure requirements and preempt certain State laws, and for other purposes; H.R. 4173, Wall Street Reform and Consumer Protection Act, To provide for financial regulatory reform, to protect consumers and investors, to enhance Federal understanding of insurance issues, to regulate the over-the-counter derivatives markets, and for other purposes. Sen. Dodd draft version of the financial regulatory reform legislation

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE