Predatory Lending Sunset Act

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 Federal Reserve -- overdraft loans, bank payday loans, mortgage rules, credit card rules, Dodd-Frank implementation NCUA -- overdraft loans and small dollar loans White House Office -- foreclosure prevention

Client expense: $102,000 · Firm income: Not reported

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

Issues involving payment cards, interchange fees, card issuer practices, and the regulation of consumer financial products, including H.R. 4173 (the Dodd-Frank Wall Street Reform and Consumer Protection Act), H.R. 2382 (the Credit Card Interchange Fees Act), H.R. 2695 (the Credit Card Fair Fee Act), S. 1212 (the Credit Card Fair Fee Act), and H.R. 5689 (the Predatory Lending Sunset Act). Issues pertaining to data security, including S. 3480 (the Protecting Cyberspace as a National Asset Act), and S. 3742 (the Data Security and Breach Notification Act). Issues related to the use of payment cards for purchases made over the Internet, including S. 3804 (the Combating Online Infringement and Counterfeits Act). Issues related to the use of payment cards regarding the regulation of Internet gambling, including H.R. 2267 (the Internet Gambling Regulation, Consumer Protection, and Enforcement Act). Market access issues in global markets. Issues related to the White Houses Joint Strategic Plan on Intellectual Property Enforcement as it pertains to credit card usage.

Client expense: $840,000 · Firm income: Not reported

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

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

Issues involving payment cards, interchange fees, card issuer practices, and the regulation of consumer financial products, including H.R. 4173 (the Dodd-Frank Wall Street Reform and Consumer Protection Act), H.R. 2382 (the Credit Card Interchange Fees Act), H.R. 2695 (the Credit Card Fair Fee Act), S. 1212 (the Credit Card Fair Fee Act), and H.R. 5689 (the Predatory Lending Sunset Act); issues pertaining to data security, including S. 3480 (the Protecting Cyberspace as a National Asset Act), and S. 3742 (the Data Security and Breach Notification Act); issues related to the use of payment cards for purchases made over the Internet, including S. 3804 (the Combating Online Infringement and Counterfeits Act); issues related to the regulation of Internet gambling, including H.R. 2267 (the Internet Gambling Regulation, Consumer Protection, and Enforcement Act); market access issues in global markets; and issues related to the White Houses Joint Strategic Plan on Intellectual Property Enforcement.

Client expense: Not reported · Firm income: $200,000

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