Overdraft Protection Act of 2012

Monitored Implementation of Dodd Frank Wall Street Reform legislation and related regulations, HR 2125 Electronic Paycard Protection Act, S1731 Combating Money Laundering, Terrorist Financing and Counterfeiting Act, S2030 Prepaid Card Consumer Protection Act, S1534 Identity Theft and Tax Fraud Prevention Act, HR 3135 Identity Theft and Tax Fraud Prevention Act, HR 3482 Tax Crimes and Identity Theft Prevention Act, HR 5691 Overdraft Protection Act and S3636 Gift Card Consumer Protection Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 940 United States Covered Bonds Act of 2011 HR 1315 The Consumer Financial Protection Safety and Soundness Improvement Act HR 1356 Capital Access for Main Street Act of 2011 HR 1418 Small Business Lending Enhancement Act of 2011 HR 1697 Communities First Act HR 1840 Improve Consideration by CFTC of Costs and Benefits of Regulations and Orders HR 1965 The SEC Shareholder Registration Act HR 2167 The Private Company Flexibility and Growth Act HR 2308 SEC Regulatory Accountability Act HR 2827 Municipal Adviser SEC Reform HR 3461 Financial Instititions Examination Fairness and Reform Act HR 3606 Jumpstart Our Business Startups (Jobs) Act HR 4014 Confidentiality of Information Provided to the CFPB HR 4078 Red Tape Reduction and Small Business Job Creation Act HR 4293 Restore Main Street's Credit Act of 2012 HR 4348 Flood Insurance/ Student Loans HR 4367 Amend the Electronic Fund Transfer Act (to limit ATM fee disclosure requirements) HR 5691 Overdraft Act of 2012 HR 6139 Consumer Credit Access, Innovation and Modernization Act S 509 Small Business Lending Enhancement Act Credit Union MBL Expansion S 1548 National Flood Insurance Program Extension Act S 1600 Communities First Act S 2160 Bank Exam Reform S 2231 Small Business Lending Enhancement Act Credit Union MBL Expansion S 2237 Small Business Jobs and Tax Relief Act S 2278 Certain Escrow Exemptions for Community Bankers S 3204 ATM Fee Disclosure Requirements S 3394 ATM Fee Disclosure Act and CFPB Privilege S 3492, S 3620 To provide for exemptions from municipal advisor requirements Bank Examinations Capital Requirements/Regulations/Basel III Rules Consumer Data Security Consumer Financial Protection Bureau Consumer Protection for Financial Products and Services Credit Card/ Debit Card Interchange Fees Debit Interchange Fees Credit Union Business Lending Powers Credit Union Tax Exemption Fair Lending Enforcement FDIC Transaction Account Guarantee Program Extention FHA Loan Programs Financial Regulatory Reform Homeownership and Equity Protection Act Housing Finance Reform Housing Government Sponsored Enterprises Implementation of Basel III in the U.S. Implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act Mortgage Lending Disclosures (RESPA/TILA) Mortgage Lending Reform Mortgage Loan Origination Standards Mortgage Servicing Compensation National Flood Insurance Program Reauthorization Overdraft Payment Services Patents - American Invents Act Qualified Mortgages/ Ability to Repay Qualified Residential Mortgages/Risk Retention Registration of Municipal Advisors Regulation Z Establishment of ESCROW - Higher Priced Loans Regulatory and Tax Relief for Community Banks Remittance Transfer Rules Sarbnes-Oxley Internal Control Attestation SEC Shareholder Registration Threshold for Community Banks Small Business Lending Fund Implementation Social Security Direct Deposit Systemic Risk, Too-Big-To-Fail Regulation and Resolution Authority

Client expense: $890,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), 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 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