Drug Free Water Act of 2011

Lobbying issues were: CFPB (encouraging Congress to keep in place an effective federal consumer-focused banking regulator); overdraft loans (encouraging Congress to implement restrictions on abusive overdraft practices); payday loans (encouraging Congress to prohibit abusive products and practices); the future of the GSEs and the federal housing finance system [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: S. 222 (to allow for voluntary loss mitigation program in bankruptcy) S. 299 (to oppose requirement that major rules of the executive branch would have no force or effect unless a joint resolution of approval is enacted into law). S. 489 (to require minimum mortgage servicing standards) S. 527 (to continue HAMP) S. 690 (to create an Office of the Homeowner Advocate) S. 737 (to keep current regulatory structure of CFPB) S. 824 (to require minimum mortgage servicing standards) S. 967 (to require minimum mortgage servicing standards) S. 1054 (to ensure that the bankruptcy process is fair for consumers) S. 1606 (to oppose reforms to the process by which federal agencies analyze and formulate new regulations and guidance documents) S. 1615 (to oppose enhanced economic analysis and justification of regulations proposed by certain federal financial regulators) S. Amdt. 1294 to S. 1867, the Defense Authorization Bill (to enhance consumer credit protections for service members and their families) S. 1963 (to oppose revoking the charters for the government-sponsored enterprises and creating a new Mortgage Finance Agency for the securitization of single family and multifamily mortgages, and for other purposes) S. 2072 (a bill to discourage disincentives to the housing missions of the government-sponsored enterprises and require consistent putback risks at the enterprises to assist homeowners) S. 3047 (a bill to encourage responsible homeowners to refinance mortgages, and for other purposes) S. 3085 (a bill to provide for the expansion of affordable refinancing of mortgages held by the Federal National Mortgage Assoc. and the Federal Home Loan Mortgage Corp.) S. 3254 (to provide for stronger credit protections for servicemembers and their dependent family members) S. 3426 (to amend the Truth in Lending Act to address certain issues related to the extension of consumer credit) S. 3452 (to amend the Truth in Lending Act to establish a national usury rate for consumer credit transactions). S. 3468 (to oppose affirming the authority of the president to require independent regulatory agencies to comply with regulatory analysis applicable to executive agencies) S. 3522 (to provide for the expansion of affordable refinancing of mortgages held by FNMA and FHLMC ) [continued from previous page] S. 3571 (to oppose requiring the Bureau of Consumer Financial Protection to conduct a small business review panel on the qualified mortgage rule before the Bureau can go forward with a final rule) S. 4041 (to amend the Electronic Fund Transfer Act to provide protection for consumers who have prepaid cards, and other purposes) H.R. 10 (to oppose requirement that major rules of the executive branch would have no force or effect unless a joint resolution of approval is enacted into law). H.R. 31 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R. 527 (to oppose a complete analysis of potential impacts on small entities of rules, and for other purposes). H.R. 830 (to continue to FHA short refinance program) H.R. 836 (to continue the Emergency Homeowner Relief Program) H.R. 839 (to continue HAMP) H.R. 861 (to continue NSP) H.R. 1121 (to keep current regulatory structure of CFPB) H.R. 1221 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R 1222 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R. 1223 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R. 1224 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R. 1225 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R. 1226 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R. 1227 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R. 1315 (to keep current FSOC veto authority structure in CFPB) H.R. 1355 (to maintain the current CFPB regulatory structure and funding system) H.R. 1477 (to require minimum mortgage servicing standards) H.R. 1567 (to require minimum mortgage servicing standards) H.R. 1677 (to keep the current CFPB transfer date in place) H.R. 1697 (to oppose amendments to the Consumer Financial Protection Act of 2010) H.R. 1783 (to require minimum mortgage servicing standards) H.R. 1909 (to oppose the federal chartering of Federal Financial Servicing and Credit Companies) H.R. 2081 (to keep the current CFPB regulatory structure) H.R. 3010 (to oppose reforms to the process by which federal agencies analyze and formulate new regulations and guidance documents) H.R. 3077 (to ensure customers have the right to close depository account without unreasonable cost or other barriers) H.R. 3461 (to oppose purported improvements to the examination of depository institutions, and for other purposes) H.R. 3644 (to oppose purported standardization and transparency in the mortgage backed security system) H.R. 4101 (to oppose amending the Fair Debt Collection Practices Act to exempt a debt collector from liability when leaving certain voice messages for a consumer with respect to a debt as long as the debt collector follows regulations prescribed by the Bureau of Consumer Financial Protection on the appropriate manner in which to leave such a message, and for other purposes) H.R. 4323 (to oppose amending the Truth in Lending Act to improve upon the definitions provided for points and fees in connection with a mortgage transaction) H.R. 5691 (to amend the Truth in Lending Act to establish fair and transparent practices related to the marketing and provision of overdraft coverage programs at depository institutions). H.R. 6139 (to oppose federal chartering of national consumer credit corporations) [continued from previous page] BILLS UNDER DISCUSSION/NOT YET INTRODUCED Senate legislation on government sponsored enterprises (to ensure that there is a secondary market to serve low- and moderate-income communities) Senate legislation on checking account overdraft practices (to require fair practices related to overdraft fees) Senate legislation to address abusive payday lending practices House legislation on debit cards (to ensure there are fair consumer protections for debit card users) Executive branch agencies and issues: Consumer Financial Protection Bureau overdraft fees, bank payday loans, payday loans, mortgage servicing, larger nonbank participants, credit cards, prepaid cards, auto lending, rules to be enforced, lending issues as related to military, interim legal authorities, Alternative Mortgage Transaction Parity Act (AMTPA), mortgage origination rules, depository supervision, qualified mortgage Dept of the Treasury--Office of the Comptroller of the Currency overdraft fees, bank payday loans, preemption, risk retention rules, servicing standards, servicing consent order/independent foreclosure review, mortgage origination rules Dept of the Treasury HAMP, GSE reform, risk retention rules, mortgage origination rules Federal Reserve Board overdraft fees, bank payday loans, mortgage origination rules, risk retention rules, servicing standards, credit card rules, interchange revenue, Dodd-Frank implementation, servicing consent order/independent foreclosure review FDIC -- overdraft fees, risk retention rules, servicing standards, bank payday loans, prepaid cards National Credit Union Administration -- regulation of credit union service organizations, payday lending Federal Trade Commission -- auto financing HUD -- GSE reform, risk retention rules, mortgage origination rules White House -- foreclosure prevention, risk retention rules, mortgage refinance Federal Housing Finance Administration -- foreclosure prevention, servicing standards

Client expense: $100,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, White House Office

Lobbying issues were: CFPB (encouraging Congress to keep in place an effective federal consumer-focused banking regulator); overdraft loans (encouraging Congress to implement restrictions on abusive overdraft practices); payday loans (encouraging Congress to prohibit abusive products and practices); the future of the GSEs and the federal housing finance system [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: S. 222 (to allow for voluntary loss mitigation program in bankruptcy) S. 299 (to oppose requirement that major rules of the executive branch would have no force or effect unless a joint resolution of approval is enacted into law) S. 489 (to require minimum mortgage servicing standards) S. 527 (to continue HAMP) S. 690 (to create an Office of the Homeowner Advocate) S. 737 (to keep current regulatory structure of CFPB) S. 824 (to require minimum mortgage servicing standards) S. 967 (to require minimum mortgage servicing standards) S. 1054 (to ensure that the bankruptcy process is fair for consumers) S. 1606 (to oppose reforms to process by which federal agencies analyze/formulate new regulations/guidance documents) S. 1615 (to oppose enhanced economic analysis and justification of regulations proposed by certain federal financial regulators) S. Amdt. 1294 to S. 1867, the Defense Authorization Bill (to enhance consumer credit protections for service members and their families) S. 1963 (to oppose revoking the charters for government-sponsored enterprises and creating a new Mortgage Finance Agency for the securitization of single family and multifamily mortgages, and for other purposes) S. 2072 (a bill to discourage disincentives to the housing missions of GSEs and require consistent putback risks at the enterprises to assist homeowners) S. 2909 (a bill to require closing costs to be paid by the enterprises with respect to certain refinanced mortgage loans, and for other purposes) S. 3047 (a bill to encourage responsible homeowners to refinance mortgages, and for other purposes) S. 3085 (a bill to provide for the expansion of affordable refinancing of mortgages held by the Federal National Mortgage Association and the Federal Home Loan Mortgage Corporation) S. 4041 (to amend Electronic Fund Transfer Act to provide protection for consumers with prepaid cards, and other purposes) H.R. 10 (to oppose requirement that major rules of the executive branch would have no force or effect unless a joint resolution of approval is enacted into law) H.R. 31 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R. 527 (to oppose a complete analysis of potential impacts on small entities of rules, and for other purposes) H.R. 830 (to continue FHA short refinance program) [continued from previous page] H.R. 836 (to continue the Emergency Homeowner Relief Program) H.R. 839 (to continue HAMP) H.R. 861 (to continue NSP) H.R. 1121 (to keep current regulatory structure of CFPB) H.R. 1221 -- HR 1227 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R. 1315 (to keep current FSOC veto authority structure in CFPB) H.R. 1355 (to maintain the current CFPB regulatory structure and funding system) H.R. 1477 & 1567 (to require minimum mortgage servicing standards) H.R. 1677 (to keep the current CFPB transfer date in place) H.R. 1697 (to oppose amendments to the Consumer Financial Protection Act of 2010) H.R. 1783 (to require minimum mortgage servicing standards) H.R. 1909 (to oppose the federal chartering of Federal Financial Servicing and Credit Companies) H.R. 2081 (to keep the current CFPB regulatory structure) H.R. 3010 (to oppose reforms to the process by which federal agencies analyze and formulate new regulations and guidance documents) H.R. 3077 (to ensure customers have the right to close depository accounts without unreasonable cost or other barriers) H.R. 3461 (to oppose purported improvements to the examination of depository institutions, and for other purposes) H.R. 3644 (to oppose purported standardization and transparency in the mortgage backed security system) H.R. 4101 (to oppose amending the Fair Debt Collection Practices Act to exempt a debt collector from liability when leaving certain voice messages for a consumer) H.R. 4323 (to oppose amending the Truth in Lending Act to change the definitions provided for points and fees in connection with a mortgage transaction) Bills under discussion/not yet introduced: Senate legislation to enhance protections on consumer credit for members of the armed forces and their dependents. Senate legislation to amend the Truth in Lending Act to address certain issues related to the extension of consumer credit, and for other purposes. Senate legislation to amend the Truth in Lending Act to establish a national usury rate for consumer credit transactions. Senate legislation on government sponsored enterprises (to ensure that there is a secondary market to serve low- and moderate-income communities) Senate legislation on checking account overdraft practices (to require fair practices related to overdraft fees) Senate legislation to protect consumers from abusive Internet payday lending practices Senate legislation to address abusive payday lending practices House legislation on debit cards (to ensure there are fair consumer protections for debit card users) House legislation on the federal Fair Debt Collection Practices Act (to ensure consumers' privacy rights regarding voice messages left by debt collectors) House legislation on checking account overdraft practices (to require fair practices related to overdraft fees) [continued from previous page] Executive branch agencies and issues: Consumer Financial Protection Bureau overdraft fees, bank payday loans, payday loans, mortgage servicing, larger nonbank participants, credit cards, prepaid cards, auto lending, rules to be enforced, lending issues as related to military, interim legal authorities, Alternative Mortgage Transaction Parity Act (AMTPA), mortgage origination rules, depository supervision, qualified mortgage Dept of the Treasury--Office of the Comptroller of the Currency overdraft fees, bank payday loans, preemption, risk retention rules, servicing standards, servicing consent order/independent foreclosure review, mortgage origination rules Dept of the Treasury HAMP, GSE reform, risk retention rules, mortgage origination rules Federal Reserve Board overdraft fees, bank payday loans, mortgage origination rules, risk retention rules, servicing standards, credit card rules, interchange revenue, Dodd-Frank implementation, servicing consent order/independent foreclosure review FDIC -- overdraft fees, risk retention rules, servicing standards, bank payday loans, prepaid cards National Credit Union Administration -- regulation of credit union service organizations, payday lending Federal Trade Commission -- auto financing HUD -- GSE reform, risk retention rules, mortgage origination rules White House -- foreclosure prevention, risk retention rules, mortgage refinance Federal Housing Finance Administration -- foreclosure prevention, servicing standards

Client expense: $280,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, White House Office

Lobbying issues were: CFPB (encouraging Congress to keep in place an effective federal consumer-focused banking regulator); overdraft loans (encouraging Congress to implement restrictions on abusive overdraft practices); payday loans (encouraging Congress to prohibit abusive products and practices); the future of the GSEs and the federal housing finance system [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: S. 222 (to allow for voluntary loss mitigation program in bankruptcy) S. 299 (to oppose requirement that major rules of the executive branch would have no force or effect unless a joint resolution of approval is enacted into law) S. 489 (to require minimum mortgage servicing standards) S. 527 (to continue HAMP) S. 690 (to create an Office of the Homeowner Advocate) S. 737 (to keep current regulatory structure of CFPB) S. 824 (to require minimum mortgage servicing standards) S. 967 (to require minimum mortgage servicing standards) S. 1054 (to ensure that the bankruptcy process is fair for consumers) S. 1606 (to oppose reforms to the process by which federal agencies analyze and formulate new regulations and guidance documents) S. 1615 (to oppose enhanced economic analysis and justification of regulations proposed by certain federal financial regulators) S. Amdt. 1294 to S. 1867, the Defense Authorization Bill (to enhance consumer credit protections for service members and their families) S. 1963 (to oppose revoking the charters for government-sponsored enterprises and creating a new Mortgage Finance Agency for the securitization of single family and multifamily mortgages, and for other purposes) S. 2072 (a bill to discourage disincentives to the housing missions of government-sponsored enterprises and require consistent putback risks at the enterprises to assist homeowners) S. 4041 (to amend the Electronic Fund Transfer Act to provide protection for consumers who have prepaid cards, and other purposes) H.R. 10 (to oppose requirement that major rules of the executive branch would have no force or effect unless a joint resolution of approval is enacted into law) H.R. 31 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R. 527 (to oppose a complete analysis of potential impacts on small entities of rules, and for other purposes) H.R. 830 (to continue FHA short refinance program) H.R. 836 (to continue the Emergency Homeowner Relief Program) H.R. 839 (to continue HAMP) [continued from previous page] H.R. 861 (to continue NSP) H.R. 1121 (to keep current regulatory structure of CFPB) H.R. 1221 -- HR 1227 (to ensure that there is a secondary market to serve low- and moderate-income communities) H.R. 1315 (to keep current FSOC veto authority structure in CFPB) H.R. 1355 (to maintain the current CFPB regulatory structure and funding system) H.R. 1477 & 1567 (to require minimum mortgage servicing standards) H.R. 1677 (to keep the current CFPB transfer date in place) H.R. 1697 (to oppose amendments to the Consumer Financial Protection Act of 2010) H.R. 1783 (to require minimum mortgage servicing standards) H.R. 2081 (to keep the current CFPB regulatory structure) H.R. 3010 (to oppose reforms to the process by which federal agencies analyze and formulate new regulations and guidance documents) H.R. 3077 (to ensure customers have the right to close depository accounts without unreasonable cost or other barriers) H.R. 3461 (to oppose purported improvements to the examination of depository institutions, and for other purposes) H.R. 3644 (to oppose purported standardization and transparency in the mortgage backed security system) H.R. 4101 (to oppose amending the Fair Debt Collection Practices Act to exempt a debt collector from liability when leaving certain voice messages for a consumer) Bills under discussion/not yet introduced: Senate legislation on government sponsored enterprises (to ensure that there is a secondary market to serve low- and moderate-income communities) Senate legislation on checking account overdraft practices (to require fair practices related to overdraft fees) Senate legislation to protect consumers from abusive Internet payday lending practices Senate legislation to address abusive payday lending practices House legislation on debit cards (to ensure there are fair consumer protections for debit card users) House legislation on the federal Fair Debt Collection Practices Act (to ensure consumers' privacy rights regarding voice messages left by debt collectors) House legislation on checking account overdraft practices (to require fair practices related to overdraft fees) Executive branch agencies and issues: Consumer Financial Protection Bureau overdraft fees, bank payday loans, payday loans, mortgage servicing, larger nonbank participants, credit cards, prepaid cards, auto lending, rules to be enforced, lending issues as related to military, interim legal authorities, Alternative Mortgage Transaction Parity Act (AMTPA), mortgage origination rules, depository supervision Dept of the Treasury--Office of the Comptroller of the Currency overdraft fees, bank payday loans, preemption, risk retention rules, servicing standards, servicing consent order/independent foreclosure review, mortgage origination rules Dept of the Treasury HAMP, GSE reform, risk retention rules, mortgage origination rules Federal Reserve Board overdraft fees, bank payday loans, mortgage origination rules, risk retention rules, servicing standards, credit card rules, interchange revenue, Dodd-Frank implementation, Capital Ones proposed acquisition of ING Direct, servicing consent order/independent foreclosure review FDIC -- overdraft fees, risk retention rules, servicing standards, bank payday loans, prepaid cards National Credit Union Administration -- regulation of credit union service organizations, payday lending [continued from previous page] Federal Trade Commission -- auto financing HUD -- GSE reform, risk retention rules, mortgage origination rules White House -- foreclosure prevention Federal Housing Finance Administration -- foreclosure prevention, servicing standards

Client expense: $110,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, White House Office