vs 5,821 other HR bills in the 113th — cohort avg 49d
Summary
No CRS summary is available for this bill yet. The source title, actions, sponsors, and text versions below come from Congress.gov.
Lobbying filings that explicitly cite this bill (50)
These links require the bill number to appear in the filing's source-reported specific issue text. Client expenses and lobbying-firm income are separate disclosure fields.
Cited source text, amounts, lobbyists, and targets
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. 673 (to amend TILA to establish a national usury rate for consumer credit transactions)
S. 690 (to create an Office of the Homeowner Advocate)
S. 727 (to improve the examination of depository institutions, and for other purposes)
S. 737 (to keep current regulatory structure of CFPB)
S. 824 (to require minimum mortgage servicing standards)
S. 949 (to oppose to oppose amending the Truth in Lending Act to improve upon definitions provided for points and fees in connection with a mortgage transaction)
S. 967 (to require minimum mortgage servicing standards)
S. 1054 (to ensure that the bankruptcy process is fair for consumers)
S. 1187 (to prevent homeowners from being forced to pay taxes on forgiven mortgage loan debt).
S. 1217 (to provide secondary mortgage market reform, and for other purposes)
S. 1349 (to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes)
S. 1376 (a bill to improve FHA and to ensure the solvency of the Mutual Mortgage Insurance Fund, and for other purposes)
S. 1577 (to oppose to oppose amending the Truth in Lending Act to improve upon definitions provided for points and fees in connection with a mortgage transaction)
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. 2641 (to oppose amending the Truth in Lending Act to provide that residential mortgage loans held in portfolio qualify as qualified mortgages for purposes of the presumption of the ability to repay requirements under such Act)
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 )
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. 1077 (to oppose amending TILA to improve upon the definitions provided for points and fees in connection with a mortgage transaction)
H.R. 1121 (to keep current regulatory structure of CFPB)
H.R. 1261 (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, and for other purposes)
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. 1553 (to improve the examination of depository institutions, and for other purposes)
H.R. 1566 (to oppose creating a federal charter for Internet consumer credit corporations, and for other purposes)
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. 1750 (to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes)
H.R. 1783 (to require minimum mortgage servicing standards)
H.R. 1779 (to oppose amending the Truth in Lending Act to modify the definitions of a mortgage originator and a high-cost mortgage)
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. 2672 (to oppose amending the Dodd-Frank Wall Street Reform and Consumer Protection Act to provide for an application process for interested parties to apply for an area to be designated as a rural area, and for other purposes)
H.R. 2673 (to oppose amending the Truth in Lending Act to provide that residential mortgage loans held on portfolio qualify as qualified mortgages for purposes of the presumption of the ability to repay requirements under such Act).
H.R. 2767 (to oppose legislation to protect American taxpayers and homeowners by creating a sustainable housing finance system for the 21st century)
H.R. 2788 (to prevent homeowners from being forced to pay taxes on forgiven mortgage loan debt)
H.R. 2892 (to oppose amending the Fair Debt Collection Practices Act to preclude law firms and licensed attorneys from the definition of a debt collector when taking certain actions)
H.R. 2994 (to amend the Internal Revenue Code of 1986 to extend for one year the exclusion from gross income of discharges of qualified principal residence indebtedness)
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. 3211 (to oppose amending the Truth in Lending Act to improve upon definitions provided for points and fees in connection with a mortgage transaction)
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. 3648 (to support amending the Internal Revenue Code of 1986 to exclude discharges of indebtness on principal residences from gross income, and for other purposes)
H.R. 3770 (to oppose requiring Senate confirmation of Inspector General of the Bureau of Consumer Financial Protection, and for other purposes)
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. 4262 (to oppose applying the requirements of the Federal Advisory Committee Act to the Bureau of Consumer Financial Protection)
H.R. 4310 (to support amending the Military Lending Act to provide additional enhancements of protections on consumer credit for members of the armed forces and their dependents)
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. 4383 (to oppose mend the Consumer Financial Protection Act of 2010 to establish a Small Business Advisory Board, and for other purposes)
H.R. 4466 (to oppose requiring certain financial regulators to determine whether new regulations or orders are duplicative or inconsistent with existing Federal regulations, and for other purposes.
H.R. 4521 (to oppose modifying exemptions for small creditors and mortgage loan servicers, to require a study of appropriate capital requirements for mortgage servicing assets for non-systemic banking institutions, and for other purposes)
H.R. 4539 (to oppose requiring the Bureau of Consumer Financial Protection, when issuing a research paper, to include all studies, data, and other analyses on which the paper was based)
H.R. 4604 (to oppose amending the Consumer Financial Protection Act of 2010 to create a consumer opt-out list for data collected by the Bureau, to put time limits on data held by the Bureau, and for other purposes)
H.R. 4684 (to oppose providing for a notice and comment period before the Bureau of Consumer Financial Protection issues guidance, and for other purposes)
H.R. 4986 (to oppose amending certain banking statutes in response to Operation Choke Point)
H.R. 5130 (to amend the Truth in Lending Act to establish a national usury rate for consumer credit transactions)
H.R. 5403 (to oppose nullifying guidance of the Bureau of Consumer Financial Protection and to provide requirements for guidance issued by the Bureau with respect to indirect auto lending)
H.R. 5461 (to oppose clarifying the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes)
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)
BILLS UNDER DISCUSSION/NOT YET INTRODUCED
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 to amend the Real Estate Settlement Procedures Act of 1974 to prohibit certain financial benefits for referrals of business and to improve the judicial relief for certain violations, and for other purposes.
House legislation to amend the Truth in Lending Act to strengthen consumer protection in automobile lending and to establish requirements for the collection of data related to automobile lending.
House legislation on debit cards (to ensure there are fair consumer protections for debit card users)
House legislation to provide secondary mortgage market reform, and for other purposes (The HOME Forward Act of 2014)
House legislation to amend the Truth in Lending Act to exempt certain higher-risk mortgages from property appraisal requirements and to exempt individuals from penalties for failure to report certain appraisers, and to amend the Financial Institutions Reform, Recovery, and Enforcement Act of
1989 to exempt certain higher-risk mortgages from property appraisal requirements, and for other purposes (The Access to Affordable Mortgages Act of 2014).
Client expense: $35,000 · Firm income: Not reported
Government targets: Education, Dept of, 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), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), Postal Regulatory Commission, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
Cited source text, amounts, lobbyists, and targets
S. 474, the Swaps Regulatory Improvement Act (all provisions)
S. 635, the Privacy Notice Modernization Act of 2013 (all provisions)
S. 710, the Municipal Advisors Relief Act of 2013 (all provisions to exempt commercial banks and savings and loan associations from the Dodd-Frank Act provisions requiring regulation of municipal advisors)
S. 731, the Basel III CASE Act (all provisions)
S. 737, the Basel III Impact Study Act (all provisions)
S. 798, the Terminating Bailouts for Taxpayer Fairness Act of 2013 (all provisions)
S. 872, the Holding Company Registration Threshold Equalization Act of 2013 (provisions to extend to savings and loan holding companies the new SEC shareholder registration and deregistration thresholds under the JOBS Act)
S. 968, the Small Business Lending Enhancement Act of 2013 (all provisions to increase credit union business lending limits)
H.R. 613, the Systemic Risk Mitigation Act (all provisions)
H.R. 634, Business Risk Mitigation and Price Stabilization Act of 2013 (provisions to clarify that end users would not be subject to margin requirements for un-cleared swaps)
H.R. 677, the Inter-Affiliate Swap Clarification Act (all provisions
H.R. 701, to amend a provision of the Securities Act of 1933 directing the Securities and Exchange Commission to add a particular class of securities to those exempted under such Act to provide a deadline for such action
H.R. 742, the Swap Data Repository and Clearinghouse Indemnification Correction Act
H.R. 749, the Eliminate Privacy Notice Confusion Act (all provisions)
H.R.797, the Municipal Advisor Oversight Improvement Act of 2013
H.R. 801, the Holding Company Registration Threshold Equalization Act of 2013 (all provisions)
H.R. 992, the Swaps Regulatory Improvement Act (all provisions)
H.R. 1003, to provide for a full assessment of the costs and benefits of Commodity Futures Trading Commission (CFTC) regulations
H.R. 1062, the SEC Regulatory Accountability Act (all provisions to require the SEC to do a thorough cost-benefit analysis before proposing a new regulation)
H.R. 1256, the Swap Jurisdiction Certainty Act
H.R. 1341, the Financial Competitive Act of 2013 (all provisions)
H.R. 1553, the Financial Institutions Examination Fairness and Reform Act (all provisions)
H.R. 1750, the Community Lending Enhancement and Regulatory Relief Act
H.R. 2672, the CFPB Rural Designation Petition and Correction Act
H.R. 3584, to amend the Federal Home Loan Bank Act to authorize privately insured credit unions to become members of a Federal home loan bank, and for other purposes
H.R. 3329, to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes.
Draft Senate legislation to exempt commercial banks from municipal advisor regulation
Discussion Draft of the Swap Jurisdiction Certainty Act (all provisions)
Draft legislation that would require the Treasury Department to determine which commercial banks, investment banks, hedge funds, and insurance companies are too-big-to-fail, and to break up those institutions within one year.
Clarity in Regulations Discussion Draft
H. Res. 496, Recognizing the importance of savings to financial security.
S. 1927, Data Security Act of 2014
S. 2114, Bond Transparency Act of 2014
H.R. 4252, Mutual Bank Choice and Continuity Act of 2014
H.R. 4569, Disclosure Modernization and Simplification Act of 2014
H.R. 4466, Financial Regulatory Clarity Act of 2014
S. 2698, Regulatory Easement for Lending Institutions that Enable a Vibrant Economy Act of 2014
H.R. 5758, Financial Institution Customer Protection Act of 2014
H.R. 5786, Small Financial Institutions Regulatory Relief Act of 2014
S. 2976, Derivatives End-Users Clarification Act
Cited source text, amounts, lobbyists, and targets
HR 688 Credit Union Small Business Job Creation Act of 2013
HR 719 Capital Access for Small Businesses and Jobs Act
HR 749 Eliminate Privacy Notice Confusion Act
HR 797 Municipal Adviser Oversight Improvement Act of 2013HR 801 The Holding Company Restriction Threshold Equalization Act
HR 892 The S Corporation Modernization Act
HR 1062 SEC Regulatory Accountability Act
HR 1603 The Mutual Community Bank Competitive Equality Act
HR 1750 The Community Lending Enhancement and Regulatory Relief Act
HR 2199 Flood Insurance
HR 2402 The Consumer Financial Protection Commission Act
HR 2446 The Responsible Consumer Financial Protection Regulations Act
HR 2542 The Regulatory Flexibility Improvements Act of 2013
HR 2672 The CFPB Rural Designation Petition and Correction Act
HR 2673 The Portfolio Lending and Mortgage Access Act of 2013
HR 3193 The Consumer Financial Protection Safety and Soundness Improvement Act
HR 3329 To Enhance the Ability of Community Financial Institutions to Foster Economic Growth
HR 4042 Community Bank Mortgage Servicing Asset Capital Requirements Study Act of 2014
HR 4252 Mutual Bank Choice and Continuity Act of 2014
HR 4466 Financial Regulatory Clarity Act
HR 4521 Community Institution Mortgage Relief Act
HR 4986 End Operation Choke Point Act of 2014
HR 5148 Access to Affordable Mortgages Act of 2014
HR 5199 Municipal Bond Market Support Act of 2014
HR 5405 Promoting Job Creation and Reducing Small Business Burdens Act of 2014
HR 5461 Dodd Frank Reforms
HR 5758 Financial Institutions Consumer Protection Act of 2014
HR 5786 Small Financial Institutions Regulatory Relief Act of 2014
S 635 Privacy Notice Modernization Act
S 727 The Financial Institutions Examination Fairness and Reform Act
S 1349 The Community Lending Enhancement and Regulatory Relief Act
S 1916 HELP Rural Communities Act of 2014
S 1927 Data Secuity Act of 2014
S 2244 Amendment 3550 to the Terrorism Risk Insurance Program Reauthoriation Act of 2014
S 2588 Cybersecurity Information Sharing Act of 2014
S 2732 The CFPB Examination and Reporting Threshhold Act of 2014
S 2937 NY Federal Reserve Bank
Access to Capital for Community Banks
Call Report Burden
Capital Requirements/Regulations/Basel III Rules/Treatment of Mortgage Servicing Assets
CFPB Reforms
Credit Union Business Lending Powers
Credit Union IOLTAs
Credit Union Tax Exemption
Cybersecurity
Data Security and Breaches
DeNovo Bank Applications
Department of Justice Operation Chokepoint
Federal Reserve Vacancy
FHFA - FHLB Membership Rules
Flood Insurance Reform Implementation of Bigger-Waters Act
Home Mortgage Disclosure Act (HMDA) Regulations
Housing Finance Reform
Housing Government Sponsored Enterprises
Military Lending ActMortgage Escrow Requirements
Mortgage Lending Reform
Mortgage Servicing Standards
National Flood Insurance Program
Nomination of Antonio Weiss for Treasury Undersecretary for Domestic Finance
Overdraft Protection
Patent Litigation Reform
Patent Trolling/Demand Letters
Qualified Mortgages, Ability to Repay Rules
Qualified Residential Mortgages/Risk Retention
Regulation Z Establishment of Escrow - Higher Priced Loans
Regulatory and Tax Relief for Community Banks
Tila/RESPA Final Rule Implementation
Virtual Currency - CFPB
Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA)
Cited source text, amounts, lobbyists, and targets
Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to debit card interchange fees.
Issues relating to mobile payments.
H.R.1750, CLEAR Relief Act of 2013, provisions relating to international ACH transactions.
Issues relating to anti-money laundering and the Bank Secrecy Act generally.
Issues relating to cyber-security.
Client expense: Not reported · Firm income: $22,500
Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA)
Cited source text, amounts, lobbyists, and targets
S.1349/H.R.1750 The Community Lending Enhancement and Regulatory Relief Act of 2013.
S.1927, the Data Security Act of 2014.
H.R. 3370/S.1846, the Homeowner Flood Insurance Affordability Act of 2013.
H.R. 1077/S.949, the Consumer Mortgage Choice Act
Client expense: Not reported · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA)
Cited source text, amounts, lobbyists, and targets
Data Transparency, DATA Act, S. 994, HR 2061; Medicaid Integrity Act of 2013; H.R. 162 (audits of Medicaid Managed Care programs); Revisions to the JOBS Act, including mandatory audit firm rotation; Auditor liability; Audit Integrity and Job Protection Act, HR1564/S 1526; PCAOB Enforcement Transparency Act of 2013, S 848; CLEAR Relief Act of 2013, HR 1750
Client expense: $1,130,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
Please see addendum.Issues related to credit union operations
Issues related to credit union field of membership
Issues related to credit union service organizations
Issues related to vacancies on the National Credit Union Administration (NCUA) Board
Issues related to NCUAs proposed rule on credit union service organizations
Issues related to NCUAs rule on net worth and bargain purchase agreements
Issues related to NCUAs low income designation regulations
Issues related to NCUA examination procedures
Issues related to NCUAs proposed rule regarding loan participations
Issues related to NCUAs regulation regarding its regulatory flexibility program
Issues related to NCUAs proposed rule regarding emergency liquidity
Issues related to material loss reports of the NCUA Office of Inspector General
Issues related to the authority of the CFPB to exempt credit unions from its rulemaking
Issues related to the CFPB proposal related to remittances and international wire transfers
Issues related to the proposed CFPB form on RESPA/TILA
Issues related to overdraft protection and check ordering practices
Issues related to mortgage servicing
Issues related to mortgage loan originator compensation and qualifications
Issues related to high-cost mortgage loans (HOEPA)
Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay
Issues related to reverse mortgages
Issues related to the Financial Accounting Standards Board (FASB)
Issues related to mark-to-market accounting
Issues related to private equity standards
Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act
Issues related to data and cyber security
Issues related to mobile banking and mobile payments
Issues related to the oversight of the Federal Housing Administration
Issues related to USDA Rural Development Loan program
Issues related to identity theft and fraud reduction
Issues related to student lending
Issues related to derivatives and NCUAs proposed rule related to credit union use of derivatives
Issues related to the Federal Home Loan Bank System
Issues related to short term lending products and advance deposit products
Issues related to patent reform
Issues related to Federal Credit Union bylaws
Issues related to NCUAs Minority Depository Institution program
Issues relating to home-based credit unions
Issues related to NCUAs Appraisal Management Company proposal
Issues related to NCUAs risk-based capital proposal
Issues related to the Johnson-Crapo Housing Finance Reform proposal
Issues related to NCUAs proposed rule on securitization
Issues related to NCUAs regulatory review process
Issues related to Ginnie Mae capital
Issues related to the nomination of J. Mark McWatters to be a member of the National Credit Union Administration Board
Issues related to a discussion draft of legislation entitled, The Bureau Guidance Transparency Act
Issues related to a discussion draft of legislation entitled, Preventing Regulatory Abuse Act of 2014
Issues related to a discussion draft of legislation entitled, Bureau Examination Fairness Act
Issues related to credit union service to marijuana businesses
Issues related to financial literacy
Issues related to the Department of Justices investigation entitled, Operation Choke Point
Issues related to membership eligibility in the Federal Home Loan Bank System.Issues related to the Department of Defense proposal regarding Credit Extending to Service Members under MLA
H.R. 450, Bureau of Consumer Financial Protection Accountability Act, all provisions
H.R. 688, Credit Union Small Business Jobs Creation Act of 2013, all provisions
H.R. 719, Capital Access for Small Businesses and Jobs Act of 2013, all provisions
H.R. 736, Responsible Homeowner Refinancing Act of 2013, all provisions
H.R. 749, Eliminate Privacy Notice Confusion Act of 2013, all provisions
H.R. 801, Holding Company Registration Threshold Equalization Act of 2013, all provisions
H.R. 839, Prompt Notification of Short Sale Act, all provisions
H.R. 861, Elder Abuse Victims Act of 2013, all provisions
H.R. 927, Common Sense Economic Recovery Act of 2013, all provisions
H.R. 1077, Consumer Mortgage Choice Act
H.R. 1255, Home Construction Lending Regulatory Improvement Act of 2013, all provisions
H.R. 1261, Overdraft Protection Act of 2013, all provisions
H.R. 1538, a bill to provide incentives to encourage financial institutions and small businesses to provide continuing financial education to customers, borrowers and employees, all provisions
H.R. 1553, Financial Institution Examination Fairness and Reform Act, all provisions
H.R. 1566, a bill to create a Federal Charter for Internet consumer credit corporations, all provisions
H.R. 1603, a bill to support and promote community financial institutions in the mutual form, all provisions
H.R. 1646, a bill to amend the Federal Credit Union Act to provide an exception from the member business loan cap for loans made to aid in the recovery from a disaster, all provisions
H.R. 1694, a bill to allow the Secretary of Treasury to rely on State examinations for certain financial institutions, all provisions
H.R. 1750, the CLEAR Relief Act, all provisions
H.R. 1754, Preserving American Homeownership Act of 2013, all provisions
H.R. 1779, Preserving Access to Manufactured Housing Act of 2013, all provisions
H.R. 1862, Capital Access for Small Community Financial Institutions, all provisions
H.R. 2136, Small Business Credit Availability Act, all provisions
H.R. 2295, Basel III CASE Act, all provisions
H.R. 2379, Qualified Mortgage Loan Originator Transitional Authority Act, all provisions
H.R. 2419, a bill to amend the Truth in Lending Act to provide coverage under such Act for credit cards issued to small businesses, all provisions
H.R. 2512, a bill to amend the Truth in Lending Act to establish clear regulatory standards for mortgage servicers, all provisions
H.R. 2547, a bill to determine appropriate risk based capital requirements for community, mid-size, and regional institutions, all provisions
H.R. 2561, a bill to provide for the removal of default information form a borrowers credit report with respect to certain rehabilitated education loans, all provisions
H.R. 2571, a bill to amend the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act to require the Bureau of Consumer Financial Protection to notify and obtain permission from consumers before collecting nonpublic personal information about such consumers, all provisions
H.R. 2572, a bill to improve the regulation of credit unions and depository institutions and to provide regulatory relief, all provisions
H.R. 2580, a bill to allow homeowners of moderate-value homes who are subject to mortgage foreclosure proceedings to remain in their homes as renters, all provisions
H.R. 2652, Marijuana Businesses Access to Banking Act of 2013
H.R. 2672, CFPB Rural Designation Petition and Correction Act
H.R. 2673, the Portfolio Lending Mortgage Access Act, all provisions
H.R. 2733, Defending American Taxpayers From Abusive Government Takings Act of 2013
H.R. 2767, Protecting American Taxpayers and Homeowners Act of 2013
H.R. 2816, To extend the pilot program under section 258 of the National Housing Act that establishes an automated process for providing alternative credit rating information for mortgagors and prospective mortgagors under certain mortgages.
H.R. 2917, Financial Security Credit Act of 2013
H.R. 2961, To amend the Truth in Lending Act and the Higher Education Act of 1965 to require additional disclosures and protections for students and cosigners with respect to student loans, and for other purposes.H.R. 3036, a bill to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision, and for other purposes.
H.R. 3137, Freedom and Mobility in Consumer Banking Act, all provisions
H.R. 3310, Annuity Safety and Security under Reasonable Enforcement Act, all provisions
H.R. 3312, Homeowners Flood Insurance Relief Act, all provisions
H.R. 3317, Holding Individual Accountable and Deterring Money Laundering Act, all provisions
H.R. 3329, a bill to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, all provisions.
H.R. 3370, Homeowner Flood Insurance Affordability Act, all provisions
H.R. 3374, the American Savings Promotion Act, all provisions
H.R. 3468, the Credit Union Share Insurance Parity Act, all provisions
H.R. 3584, a bill to amend the Federal Home Loan Bank Act to authorize privately insured credit unions to become members of a Federal home loan bank, all provisions
H.R. 3770, Inspector General Act
H.R. 4042, Community Bank Mortgage Servicing Asset Capital Requirements Study Act, all provisions
H.R. 4167, the Restoring Proven Financing for American Employers Act
H.R. 4226, Credit Union Residential Loan Parity Act, all provisions
H.R. 4466, the Financial Regulatory Clarity Act of 2014
H.R. 4521, the Community Institution Mortgage Relief Act, all provisions
H.R. 4626, the SAFE Act Confidentiality and Privilege Enhancement Act, all provisions
H.R. 4804, the Bureau Examination Fairness Act, all provisions
H.R. 4986, End Operation Choke Point Act, all provisions
H.R. 5148, Access to Affordable Mortgages Act, all provisions
H.R. 5403, Reforming CFPB Indirect Auto Financing Guidance Act, all provisions
H.R. 5461, the Insurance Capital Standards Clarification Act of 2014
H.R. 5758, Financial Institutions Customer Protection Act of 2014
Kildee Amendment to H.R. 1960, National Defense Authorization Act, related to disclosures required under the Military Lending Act
S. 113, Know Before You Owe Private Student Loan Act, all provisions
S. 114, Fairness for Struggling Student Act, all provisions
S. 172, Stopping Abuse and Fraud in Electronic (SAFE) Lending Act of 2013, all provisions
S. 187, Deceptive Loan Check Elimination Act, all provisions
S. 205, Responsible Consumer Financial Protection Regulations Act of 2013, all provisions
S. 249, Responsible Homeowner Refinancing Act of 2013, all provisions
S. 361, Prompt Notification of Short Sale Act of 2013, all provisions
S. 450, Financial Regulatory Responsibility Act of 2013, all provisions
S. 451, a bill to make technical corrections to the Dodd-Frank Wall Street Reform and Consumer Protection Act, all provisions
S. 563, Jumpstart GSE Reform Act, all provisions
S. 635, Privacy Notice Modernization Act of 2013, all provisions
S. 673, Protecting Consumers from Unreasonable Credit Rates Act, all provisions
S. 676, Identity Theft and Tax Fraud Prevention Act of 2013, all provisions
S. 727, Financial Institutions Examination Fairness and Reform Act, all provisions
S. 731, Basel III CASE Act, all provisions
S. 733, Basel III Impact Study Act, all provisions
S. 798, Terminating Bailouts for Taxpayer Fairness Act, all provisions
S. 872, Holding Company Registration Threshold Equalization Act, all provisions
S. 947, SAFE Act Confidentiality and Privilege Enhancement Act, all provisions
S. 968, Small Business Lending Enhancement Act, all provisions
S. 985, a bill to repeal certain provisions of the Gramm-Leach-Bliley Act and revive the separation between commercial banking and the securities business, in the manner provided in the Banking Act of 1933, the so-called "Glass-Steagall Act," all provisionsS. 996, a bill to improve the National Flood Insurance Program, all provisions
S. 1002, Home Building Lending Improvement Act, all provisions
S. 1048, the Mortgage Finance Act, all provisions
S. 1098, a bill to reform the Biggert-Waters Flood Insurance Reform Act of 2012 to responsibly protect homeownership, all provisions
S. 1176, a bill to impose a fine with respect to international remittance transfers if the sender is unable to verify legal status in the United States, all provisions
S. 1217, Housing Finance Reform and Taxpayer Protection Act, all provisions
S. 1229, a bill to amend the Truth in Lending Act to empower the States to set the maximum annual percentage rates applicable to consumer credit transactions, all provisions
S. 1282, 21st Century Glass-Steagall Act of 2013
S. 1349, a bill to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes.
S. 1511, the Mortgage Choice Act, all provisions
S. 1534, Freedom and Mobility in Consumer Banking Act, all provisions
S. 1538, FIX Credit Reporting Errors Act, all provisions
S. 1577, Mortgage Choice Act, all provisions
S. 1597, the American Savings Promotion Act, all provisions
S. 1610, Homeowner Flood Insurance Affordability Act, all provisions
S. 1806, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions, all provisions
S. 1867, Prepaid Card Consumer Protection Act of 2013, all provisions
S. 1916, the HELP Rural Communities Act, all provisions
S. 2641, the Portfolio Lending Enhancement Act, all provisions
S. 2698, the Regulatory Easement for Lending Institutions Act, Title II and Title III.
S. 2699, a Bill to require the National Credit Union Administration to provide pass-through share insurance for the deposits or shares of any interest on lawyers trust accounts, and for other purposes.
S. Res. 105, a resolution designating April 2013 as Financial Literacy Month
Johnson / Crapo amendment to S. 1217, the Housing Finance Reform and Taxpayer Protection Act, all provisions
Moran / Manchin amendment to S. 1217, the Housing Finance Reform and Taxpayer Protection Act, all provisions
Toomey / Coburn amendment to S. 1217, the Housing Finance Reform and Taxpayer Protection Act, all provisions
Client expense: $1,000,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of Government Ethics (OGE), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Cited source text, amounts, lobbyists, and targets
HR 1261 - Overdraft Protection Act of 2013 - Provisions related to caps & limitations on overdraft charges
S 710 - Bill to provide commercial banks & S&Ls an exemption from Dodd-Frank Act provisions requiring the regulation of municipal advisors - provisions to exempt certain bank employees from being considered municipal advisors for purposes of Dodd-Frank.HR 1750 - Regulatory Relief Act - Provisions related to exemptions from the qualified mortgage requirements and privacy notice requirements.
HR 3317 - Holding Individuals Accountable & Deterring Money Laundering Act - Provisions to strengthen the Federal statutes designed to deter money laundering and terrorism financing.
HR 3770 - Homeowner Flood Insurance Affordability Act - Provisions addressing issues with the affordability of the National Flood Insurance program and mapping issues.
S 1720 - Patent reform legislation that addresses nuisance litigation of patent trolls - Provisions addressing patent reform.
S 1926 - Combining National Flood Insurance Programs reforms with NARAB II - Provisions regarding escrow requirements under flood insurance program.
HR 4466 - Financial Regulatory Clarity Act - Provisions regarding regulatory processes to determine duplicative rules and regulations
S 635 - Privacy Notice Bill - Eliminating the need to send GLBA privacy notices if a financial institution has not changed its privacy policy in the last year.
Client expense: $141,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
Revision of Sarbanes-Oxley rules on disclosure of disciplinary proceedings; Revisions to the JOBS Act, including mandatory audit firm rotation; Auditor liability; Audit Integrity and Job Protection Act, HR 1564/S 1526
PCAOB Enforcement Transparency Act of 2013, S 848
CLEAR Relief Act of 2013, HR 1750
S 1526 (Audit Integrity and Job Protection Act)
Client expense: $520,000 · Firm income: Not reported
Government targets: Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC)
Cited source text, amounts, lobbyists, and targets
Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities -
Downsize too-big-to-fail banks and financial firms to protect our financial system, economy, and American Taxpayers from future bailouts - downsize (restructure) too-big-to-fail (TBTF) banks and financial firms, reduce the probability and severity of future financial crisis and taxpayer bailouts, moral hazard, numerous TBTF misdeeds (abuse, fraud, manipulation and scandal),too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, Department of Justices reluctance to prosecute TBTFs versus community banks, and Government Accountability Offices (GAO) confirmation of TBTFs funding advantages (Senate)
Tiered regulation supervision and exemptions for community banks - recognition of the different business model and risks posed by TBTF banks and financial firms, one size fits all legislation and regulation, separate regulation - supervision - capital - liquidity requirements, disproportionate burden on community banks, unlevel playing field, and significant community bank competitive disadvantages
Including, the qualifying threshold under the Federal Reserves Small Bank Holding Company Policy Statement from $500 million to $5 billion and allowing small savings and loan holding companies to be covered by the Policy Statement, the internal control attestation requirements of Section 404(b) of the Sarbanes Oxley Act from $75 million in market capitalization to $350 million, and savings and loan holding companies being able to take advantage of the increased Securities and Exchange Commission (SEC) shareholder registration and deregistration thresholds under the JOBS Act (Senate)
Community bank regulatory relief as contained in the Independent Community Bankers of America Plan for Prosperity
Including, community bank exemption from certain mortgage reforms to support the housing recovery, redundant annual privacy notices, municipal advisor registration burdens to help serve local governments, Assistant Treasury Secretary for Community Banks, CFPBs more balanced regulations, improved accountability in bank exams with a workable appeals process, accounting and auditing expenses for publicly traded institutions, mutual bank new charter and dividend rules, rigorous and quantitative justification of new rules, additional capital for small bank holding companies, red tape in small-business lending, capital formation and reforming Subchapter S corporation regulations, and extending the net-operating-loss carry-back (Senate)
Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (Senate)
Expanded powers for tax-exempt credit unions - outdated original business model and straying from founding purpose, federal tax-exemption status, expansion of powers, level the playing field between community banks and credit unions, regulatory requirements including the Community Reinvestment Act (CRA)
Including, expanded lending powers by increasing percentage of asset cap on business lending, and raising capital from outside investors (House and Senate)
Expansion of the Farm Credit System - funding & tax advantages, expansionist agenda, competitive advantages over rural community banks, regulatory safeguards and controls, Co-Banks $725 million participation in commitment to Verizon Communications (House and Senate)
Mortgage lending reforms - imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, differences between non-traditional versus predatory lending practices, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, prepayment penalties, originator compensation, limited credit availability
Including, Qualified Mortgage (QM) status from the CFPBs Ability-to-Repay rules for loans originated and held in portfolio by community banks, balloon mortgages regardless of pricing, use of rural and underserved designations for QM eligibility for community banks and greatly expanding the definition of each, annual loan origination and asset threshold limits for small creditors, small servicer exemption for loans held in portfolio, community banks exemption from escrow requirements for loans held in portfolio and for small dollar amount loans, proposed adoption of the QM definition for Qualified Residential Mortgages (QRM) that would not require a high down-payment requirement (Senate)Housing Finance (GSE Secondary Market) Reform - Fannie Mae/Freddie Mac/FHFA unsustainable long-term conservatorship, community bank access to an impartial secondary market for residential mortgage loans, financial stable and reliable, government tie to secondary market (continued flow of credit and market liquidity), aggressive repurchase requests of transferred residential mortgages for technical violations
Including, selling loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market, pricing of any governmental guaranties, fairness and equality to all participants regardless of volume of loans guaranteed, and further consolidation of housing finance system that would result in several mega banks and financial firms dominating the market (Senate)
Tax, accounting and auditing changes - community bank focus supporting robust economic activity, savings & investments, accommodation/exemption for community banks, undue regulatory burden or cost on community banks
Including, tax reform that preserves the pass-through option, including the Subchapter S corporation and the ability of business borrowers to deduct interest, taxation of capital gains and dividends held in parity and at a preferential rate, tax-exempt status of interest paid on municipal bonds together with an increase in the Bank Qualified (BQ) annual threshold to $30 million and indexed for inflation, the ability of business and mortgage borrowers to deduct interest without further limitations must also be preserved, changes to the tax laws that disadvantage one form of corporate entity versus another should include a phase-in period and an amnesty to allow for a penalty-free corporate conversion, S corporation banks ability to raise capital to be enhanced by giving them the ability to issue preferred stock, increasing their shareholder limits and allowing new IRA shareholder investments, end to the tax subsidies for credit unions and the FCS lenders, community banks amortizing CRE losses over 10 years (versus in the year in which they are taken), capital standards that recognize the loss-absorbing abilities of the entire amount of the Allowance for Loan and Lease Losses (ALLL), the 1.25% ALLL disallowance (for regulatory capital purposes) should be eliminated which would encourage banks to reserve more and would strengthen capital positions, the work of the Financial Accounting Foundations Private Company Council to seek recognition, measurement and disclosure alternatives for small private companies including non-public community banks.
Including, Financial Accounting Standard Boards (FASB) proposed expected loss model requiring community banks to develop costly complex cash flow models for loans and investment securities to generate expected losses over the lives of these assets where implementing this proposal will be to frontload loss recognition which would harm both community bank earnings and capital, FASBs proposal to restrict the ability of community banks to classify mortgage loans and investment securities at amortized cost when their intent is to collect contractual cash flows which is based on the exit price of a loan or security and on the current value in a non-distressed market and which would require costly robust pricing engines and complex valuation methodologies to satisfy the standard, FASBs proposal to require extensive liquidity risk and interest rate risk footnote disclosures that would be required to be audited which would undermine the work of the prudential regulators whose job entails assessing the safety and soundness of community banks including an assessment of liquidity and interest rate risk, and new bank specific fees or punitive tax levies specifically targeting the financial service sector (Senate)
Remaining Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Including, rein in Significantly Important Financial Institution (SIFI) with enhanced prudential standards and rigorous focused regulation, higher capital requirements, capital surcharges, concentration limits, liquidity requirements, orderly liquidation rules, credible contingency resolution plan, shielding community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%, Volcker Rules prohibition on propriety trading and investment in and sponsorship of hedge funds and private equity funds, effectively exempting community banks
Including, ensure the Consumer Financial Protection Bureau (CFPB) focuses on large banks, financial firms and shadow financial companies, holding the mega banks and financial firms up to the same high standards for compliance with consumer laws as required and attained by community banks, governance (single Director versus five member commission), prudential regulators participation with CFPB in the rule writing process, FSOC veto of CFPB rules, CFPB exemption authorityregarding community banks, revision in the definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules, consistent and transparent standards in the evaluation of community bank fair lending standards, disparate impact and unintentional discrimination (Senate)
De novo community bank formation - need to maintain growing, vibrant & evolving banking profession, Federal Deposit Insurance Corporations (FDIC) actively inhibiting de novo community bank formation, inappropriate and restrictive one-size-fits-all supervisory policy (Senate)
Maintain the Federal Home Loan Bank (FHLB)System - strong partnership with community banks, healthy, stable & reliable source of funding for community banks, FHLBs should not be the sole aggregators for residential mortgages for community banks in the reform of the housing GSEs, preservation of the FHLBs special functions and purposes (Senate)
Excessive (Federal Reserve) intervention in monetary policy - significant drag on community banks net interest margins and earnings, limits on what monetary policy can accomplish, impact on community banks, savers and senior citizens (Senate)
*****
S. 798 Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (House and Senate)
H.R. 749 Privacy Notice Act (redundant privacy notice regulatory relief) (all sections) (House and Senate)
S. 635 Privacy Act Notice Modernization Act of 2013 (redundant privacy notice regulatory relief) (all sections) (House and Senate)
H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House and Senate)
S. 1349 CLEAR Relief Act (community lending enhancement and regulatory relief) (all sections) (House and Senate)
H.R. 1553 Financial Institutions Fairness Act (regulatory examinations standards and FFIEC Ombudsman) (all sections) (House and Senate)
S. 727 Financial Institutions Fairness Act (regulatory examination standards and FFIEC Ombudsman) (all sections) (House and Senate)
S. 2252 Community Bank Preservation Act of 2014 (Federal Reserve Board to include one member with small bank supervisory experience) (all sections) (Senate)
H.R. 4986 End Operation Choke Point Act of 2014 (prohibits federal regulators from pressuring insured depository institutions from dealing with legal and licensed businesses) (all sections) (House and Senate)
H.R. 688 Credit Union Small Business Jobs Creation Act (increase member business lending percentage of capital) (all sections) (House and Senate)
S. 968 Small Business lending Enhancement Act of 2013 (increase member business lending percentage of capital) (all sections) (House and Senate)
H.R. 719 Capital Access for Small business and Jobs Act (capital raising from outside investors) (all sections) (House and Senate)
Expanded CFPBs definitions of rural and underserved areas in the ATR/QM Rule to include various economically challenged areas (House and Senate, CFPB, FHFA)Reform of the Housing GSEs regarding: consolidation of the housing finance system, equal and direct access to the secondary market regardless of loan volume, loan pricing, right to service loans, appropriation of customer data, government footprint and private capital in the market (House and Senate)
Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (House and Senate)
CBAI Comment and Association Letters
Comment Letter CFPB Amendment to the Annual Privacy Notice Requirement under Gramm-Leach-Bliley Act (Regulation P) Docket No. CFPB-2014-0010/RIN 3170-AA39
Associations Letter CFPB ATR/QM Rule and escrow requirements for higher-priced loans regarding loans held in portfolio for the life of the loan and automatic QM safe harbor status and exemption from the escrow requirements (for higher-priced loans)
Comment letter OCC, Federal Reserve Board, FDIC Regulatory Review under Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA), Docket ID FFIEC-2014-0001, Docket No. OP-1491 regarding: tiered regulation, de novo bank formation, Call Report (regulatory relief), Small Bank Holding Company Policy Statement thresholds
Comment Letter FHFA FHFA Proposed Rule members of Federal Home Loan Banks, RIN 2590-AA39 (membership eligibility requirements)
CBAI Action Alerts
FFIEC, FDIC, OCC, Federal Reserve Board Petition to streamline Call Report requirements
Client expense: $50,000 · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities -
Downsize too-big-to-fail banks and financial firms to protect our financial system, economy, and American Taxpayers from future bailouts - downsize (restructure) too-big-to-fail (TBTF) banks and financial firms, reduce the probability and severity of future financial crisis and taxpayer bailouts, moral hazard, numerous TBTF misdeeds (abuse, fraud, manipulation and scandal),too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, Department of Justices reluctance to prosecute TBTFs versus community banks, and Government Accountability Offices (GAO) confirmation of TBTFs funding advantages (Senate)
Tiered regulation supervision and exemptions for community banks - recognition of the different business model and risks posed by TBTF banks and financial firms, one size fits all legislation and regulation, separate regulation - supervision - capital - liquidity requirements, disproportionate burden on community banks, unlevel playing field, and significant community bank competitive disadvantages
Including, the qualifying threshold under the Federal Reserves Small Bank Holding Company Policy Statement from $500 million to $5 billion and allowing small savings and loan holding companies to be covered by the Policy Statement, the internal control attestation requirements of Section 404(b) of the Sarbanes Oxley Act from $75 million in market capitalization to $350 million, and savings and loan holding companies being able to take advantage of the increased Securities and Exchange Commission (SEC) shareholder registration and deregistration thresholds under the JOBS Act (Senate)
Community bank regulatory relief as contained in the Independent Community Bankers of America Plan for Prosperity
Including, community bank exemption from certain mortgage reforms to support the housing recovery, redundant annual privacy notices, municipal advisor registration burdens to help serve local governments, Assistant Treasury Secretary for Community Banks, CFPBs more balanced regulations, improved accountability in bank exams with a workable appeals process, accounting and auditing expenses for publicly traded institutions, mutual bank new charter and dividend rules, rigorous and quantitative justification of new rules, additional capital for small bank holding companies, red tape in small-business lending, capital formation and reforming Subchapter S corporation regulations, and extending the net-operating-loss carry-back (Senate)
Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (Senate)
Expanded powers for tax-exempt credit unions - outdated original business model and straying from founding purpose, federal tax-exemption status, expansion of powers, level the playing field between community banks and credit unions, regulatory requirements including the Community Reinvestment Act (CRA)
Including, expanded lending powers by increasing percentage of asset cap on business lending, and raising capital from outside investors (House and Senate)
Expansion of the Farm Credit System - funding & tax advantages, expansionist agenda, competitive advantages over rural community banks, regulatory safeguards and controls, Co-Banks $725 million participation in commitment to Verizon Communications (House and Senate)
Mortgage lending reforms - imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, differences between non-traditional versus predatory lending practices, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, prepayment penalties, originator compensation, limited credit availability
Including, Qualified Mortgage (QM) status from the CFPBs Ability-to-Repay rules for loans originated and held in portfolio by community banks, balloon mortgages regardless of pricing, use of rural and underserved designations for QM eligibility for community banks and greatly expanding the definition of each, annual loan origination and asset threshold limits for small creditors, small servicer exemption for loans held in portfolio, community banks exemption from escrow requirements for loans held in portfolio and for small dollar amount loans, proposed adoption of the QM definition for Qualified Residential Mortgages (QRM) that would not require a high down-payment requirement (Senate)Housing Finance (GSE Secondary Market) Reform - Fannie Mae/Freddie Mac/FHFA unsustainable long-term conservatorship, community bank access to an impartial secondary market for residential mortgage loans, financial stable and reliable, government tie to secondary market (continued flow of credit and market liquidity), aggressive repurchase requests of transferred residential mortgages for technical violations
Including, selling loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market, pricing of any governmental guaranties, fairness and equality to all participants regardless of volume of loans guaranteed, and further consolidation of housing finance system that would result in several mega banks and financial firms dominating the market (Senate)
Tax, accounting and auditing changes - community bank focus supporting robust economic activity, savings & investments, accommodation/exemption for community banks, undue regulatory burden or cost on community banks
Including, tax reform that preserves the pass-through option, including the Subchapter S corporation and the ability of business borrowers to deduct interest, taxation of capital gains and dividends held in parity and at a preferential rate, tax-exempt status of interest paid on municipal bonds together with an increase in the Bank Qualified (BQ) annual threshold to $30 million and indexed for inflation, the ability of business and mortgage borrowers to deduct interest without further limitations must also be preserved, changes to the tax laws that disadvantage one form of corporate entity versus another should include a phase-in period and an amnesty to allow for a penalty-free corporate conversion, S corporation banks ability to raise capital to be enhanced by giving them the ability to issue preferred stock, increasing their shareholder limits and allowing new IRA shareholder investments, end to the tax subsidies for credit unions and the FCS lenders, community banks amortizing CRE losses over 10 years (versus in the year in which they are taken), capital standards that recognize the loss-absorbing abilities of the entire amount of the Allowance for Loan and Lease Losses (ALLL), the 1.25% ALLL disallowance (for regulatory capital purposes) should be eliminated which would encourage banks to reserve more and would strengthen capital positions, the work of the Financial Accounting Foundations Private Company Council to seek recognition, measurement and disclosure alternatives for small private companies including non-public community banks.
Including, Financial Accounting Standard Boards (FASB) proposed expected loss model requiring community banks to develop costly complex cash flow models for loans and investment securities to generate expected losses over the lives of these assets where implementing this proposal will be to frontload loss recognition which would harm both community bank earnings and capital, FASBs proposal to restrict the ability of community banks to classify mortgage loans and investment securities at amortized cost when their intent is to collect contractual cash flows which is based on the exit price of a loan or security and on the current value in a non-distressed market and which would require costly robust pricing engines and complex valuation methodologies to satisfy the standard, FASBs proposal to require extensive liquidity risk and interest rate risk footnote disclosures that would be required to be audited which would undermine the work of the prudential regulators whose job entails assessing the safety and soundness of community banks including an assessment of liquidity and interest rate risk, and new bank specific fees or punitive tax levies specifically targeting the financial service sector (Senate)
Remaining Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Including, rein in Significantly Important Financial Institution (SIFI) with enhanced prudential standards and rigorous focused regulation, higher capital requirements, capital surcharges, concentration limits, liquidity requirements, orderly liquidation rules, credible contingency resolution plan, shielding community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%, Volcker Rules prohibition on propriety trading and investment in and sponsorship of hedge funds and private equity funds, effectively exempting community banks
Including, ensure the Consumer Financial Protection Bureau (CFPB) focuses on large banks, financial firms and shadow financial companies, holding the mega banks and financial firms up to the same high standards for compliance with consumer laws as required and attained by community banks, governance (single Director versus five member commission), prudential regulators participation with CFPB in the rule writing process, FSOC veto of CFPB rules, CFPB exemption authorityregarding community banks, revision in the definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules, consistent and transparent standards in the evaluation of community bank fair lending standards, disparate impact and unintentional discrimination (Senate)
De novo community bank formation - need to maintain growing, vibrant & evolving banking profession, Federal Deposit Insurance Corporations (FDIC) actively inhibiting de novo community bank formation, inappropriate and restrictive one-size-fits-all supervisory policy (Senate)
Maintain the Federal Home Loan Bank (FHLB)System - strong partnership with community banks, healthy, stable & reliable source of funding for community banks, FHLBs should not be the sole aggregators for residential mortgages for community banks in the reform of the housing GSEs, preservation of the FHLBs special functions and purposes (Senate)
Excessive (Federal Reserve) intervention in monetary policy - significant drag on community banks net interest margins and earnings, limits on what monetary policy can accomplish, impact on community banks, savers and senior citizens (Senate)
*****
S. 798 Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (House and Senate)
H.R. 749 Privacy Notice Act (redundant privacy notice regulatory relief) (all sections) (House and Senate)
S. 635 Privacy Act Notice Modernization Act of 2013 (redundant privacy notice regulatory relief) (all sections) (House and Senate)
H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House and Senate)
S. 1349 CLEAR Relief Act (community lending enhancement and regulatory relief) (all sections) (House and Senate)
H.R. 1553 Financial Institutions Fairness Act (regulatory examinations standards and FFIEC Ombudsman) (all sections) (House and Senate)
S. 727 Financial Institutions Fairness Act (regulatory examination standards and FFIEC Ombudsman) (all sections) (House and Senate)
S. 2252 Community Bank Preservation Act of 2014 (Federal Reserve Board to include one member with small bank supervisory experience) (all sections) (Senate)
H.R. 4986 End Operation Choke Point Act of 2014 (prohibits federal regulators from pressuring insured depository institutions from dealing with legal and licensed businesses) (all sections) (House and Senate)
H.R. 688 Credit Union Small Business Jobs Creation Act (increase member business lending percentage of capital) (all sections) (House and Senate)
S. 968 Small Business lending Enhancement Act of 2013 (increase member business lending percentage of capital) (all sections) (House and Senate)
H.R. 719 Capital Access for Small business and Jobs Act (capital raising from outside investors) (all sections) (House and Senate)
Expanded CFPBs definitions of rural and underserved areas in the ATR/QM Rule to include various economically challenged areas (House and Senate, CFPB, FHFA)Reform of the Housing GSEs regarding: consolidation of the housing finance system, equal and direct access to the secondary market regardless of loan volume, loan pricing, right to service loans, appropriation of customer data, government footprint and private capital in the market (House and Senate)
Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (House and Senate)
CBAI Comment and Association Letters
Comment Letter CFPB Amendment to the Annual Privacy Notice Requirement under Gramm-Leach-Bliley Act (Regulation P) Docket No. CFPB-2014-0010/RIN 3170-AA39
Associations Letter CFPB ATR/QM Rule and escrow requirements for higher-priced loans regarding loans held in portfolio for the life of the loan and automatic QM safe harbor status and exemption from the escrow requirements (for higher-priced loans)
Comment letter OCC, Federal Reserve Board, FDIC Regulatory Review under Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA), Docket ID FFIEC-2014-0001, Docket No. OP-1491 regarding: tiered regulation, de novo bank formation, Call Report (regulatory relief), Small Bank Holding Company Policy Statement thresholds
Comment Letter FHFA FHFA Proposed Rule members of Federal Home Loan Banks, RIN 2590-AA39 (membership eligibility requirements)
CBAI Action Alerts
FFIEC, FDIC, OCC, Federal Reserve Board Petition to streamline Call Report requirements
Client expense: $50,000 · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities -
Mortgage lending reforms - imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, differences between non-traditional versus predatory lending practices, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrowrequirements, prepayment penalties, originator compensation, limited credit availability
Including, Qualified Mortgage (QM) status from the CFPBs Ability-to-Repay rules for loans originated and held in portfolio by community banks, balloon mortgages regardless of pricing, use of rural and underserved designations for QM eligibility for community banks and greatly expanding the definition of each, annual loan origination and asset threshold limits for small creditors, small servicer exemption for loans held in portfolio, community banks exemption from escrow requirements for loans held in portfolio and for small dollar amount loans, proposed adoption of the QM definition for Qualified Residential Mortgages (QRM) that would not require a high down-payment requirement (Senate)
Housing Finance (GSE Secondary Market) Reform - Fannie Mae/Freddie Mac/FHFA unsustainable long-term conservatorship, community bank access to an impartial secondary market for residential loans, financial stable and reliable, government tie to secondary market (continued flow of credit and market liquidity), aggressive repurchase requests of transferred residential mortgages for technical violations
Including, selling loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market, pricing of any governmental guaranties, fairness and equality to all participants regardless of volume of loans guaranteed, and further consolidation of housing finance system that would result in several mega banks and financial firms dominating the market (Senate)
Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (House and Senate)
Remaining Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Including, ensure the Consumer Financial Protection Bureau (CFPB) focuses on large banks, financial firms and shadow financial companies, holding the mega banks and financial firms up to the same high standards for compliance with consumer laws as required and attained by community banks, governance (single Director versus five member commission), prudential regulators participation with CFPB in the rule writing process, FSOC veto of CFPB rules, CFPB exemption authority regarding community banks, revision in the definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules, consistent and transparent standards in the evaluation of community bank fair lending standards, disparate impact and unintentional discrimination (Senate)
Expanded CFPBs definitions of rural and underserved areas in the ATR/QM Rule to include various economically challenged areas (House and Senate, CFPB, FHFA)
Reform of the Housing GSEs regarding: consolidation of the housing finance system, equal and direct access to the secondary market regardless of loan volume, loan pricing, right to service loans, appropriation of customer data, government footprint and private capital in the market (House and Senate)
H.R. 749 Privacy Notice Act (redundant privacy notice regulatory relief) (all sections) (House and Senate)
S. 635 Privacy Act Notice Modernization Act of 2013 (redundant privacy notice regulatory relief) (all sections) (House and Senate)
H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House and Senate)
S. 1349 CLEAR Relief Act (community lending enhancement and regulatory relief) (all sections) (House and Senate)CBAI Comment and Association Letters -
Comment Letter CFPB Amendment to the Annual Privacy Notice Requirement under Gramm-Leach-Bliley Act (Regulation P) Docket No. CFPB-2014-0010/RIN 3170-AA39
Associations Letter CFPB ATR/QM Rule and escrow requirements for higher-priced loans regarding loans held in portfolio for the life of the loan and automatic QM safe harbor status and exemption from the escrow requirements (for higher-priced loans)
Client expense: $50,000 · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
See addendum.S.474, the Swaps Regulatory Improvement Act (all provisions)
S. 635, the Privacy Notice Modernization Act of 2013 (all provisions)
S. 710, the Municipal Advisors Relief Act of 2013 (all provisions to exempt commercial banks and savings and loan associations from the Dodd-Frank Act provisions requiring regulation of municipal advisors)
S. 731, the Basel III CASE Act (all provisions)
S. 737, the Basel III Impact Study Act (all provisions)
S. 798, the Terminating Bailouts for Taxpayer Fairness Act of 2013 (all provisions)
S. 872, the Holding Company Registration Threshold Equalization Act of 2013 (provisions to extend to savings and loan holding companies the new SEC shareholder registration and deregistration thresholds under the JOBS Act)
S. 968, the Small Business Lending Enhancement Act of 2013 (all provisions to increase credit union business lending limits)
H.R. 613, the Systemic Risk Mitigation Act (all provisions)
H.R. 634, Business Risk Mitigation and Price Stabilization Act of 2013 (provisions to clarify that end users would not be subject to margin requirements for un-cleared swaps)
H.R. 677, the Inter-Affiliate Swap Clarification Act (all provisions
H.R. 701, to amend a provision of the Securities Act of 1933 directing the Securities and Exchange Commission to add a particular class of securities to those exempted under such Act to provide a deadline for such action
H.R. 742, the Swap Data Repository and Clearinghouse Indemnification Correction Act
H.R. 749, the Eliminate Privacy Notice Confusion Act (all provisions)
H.R.797 , the Municipal Advisor Oversight Improvement Act of 2013
H.R. 801, the Holding Company Registration Threshold Equalization Act of 2013 (all provisions)
H.R. 992, the Swaps Regulatory Improvement Act (all provisions)
H.R. 1003, to provide for a full assessment of the costs and benefits of Commodity Futures Trading Commission (CFTC) regulations
H.R. 1062, the SEC Regulatory Accountability Act (all provisions to require the SEC to do a thorough cost-benefit analysis before proposing a new regulation)
H.R. 1256, the Swap Jurisdiction Certainty Act
H.R. 1341, the Financial Competitive Act of 2013 (all provisions)H.R. 1553, the Financial Institutions Examination Fairness and Reform Act (all provisions)
H.R. 1750, the Community Lending Enhancement and Regulatory Relief Act
H.R. 2672, the CFPB Rural Designation Petition and Correction Act
H.R. 3584, to amend the Federal Home Loan Bank Act to authorize privately insured credit unions to become members of a Federal home loan bank, and for other purposes.
H.R. 3329, to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes.
Draft Senate legislation to exempt commercial banks from municipal advisor regulation
Discussion Draft of the Swap Jurisdiction Certainty Act (all provisions)
Draft legislation that would require the Treasury Department to determine which commercial banks, investment banks, hedge funds, and insurance companies are too-big-to-fail, and to break up those institutions within one year.
Clarity in Regulations Discussion Draft
H.R. 496, Recognizing the importance of savings to financial security.
S. 1927, Data Security Act of 2014
S. 2114, Bond Transparency Act of 2014
H.R. 4252, Mutual Bank Choice and Continuity Act of 2014
H.R. 4569, Disclosure Modernization and Simplification Act of 2014
H.R. 4466, Financial Regulatory Clarity Act of 2014
S. 2698, Regulatory Easement for Lending Institutions that Enable a Vibrant Economy Act of 2014
Client expense: $2,560,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to debit card interchange fees.
Issues relating to mobile payments.
H.R.1750, CLEAR Relief Act of 2013, provisions relating to international ACH transactions.
Issues relating to anti-money laundering and the Bank Secrecy Act generally.
Issues relating to cyber-security.
Client expense: Not reported · Firm income: $22,500
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA)
Cited source text, amounts, lobbyists, and targets
HR 688 Credit Union Small Business Job Creation Act of 2013
HR 719 Capital Access for Small Businesses and Jobs Act
HR 749 Eliminate Privacy Notice Confusion Act
HR 797 Municipal Adviser Oversight Improvement Act of 2013HR 801 The Holding Company Restriction Threshold Equalization Act
HR 892 The S Corporation Modernization Act
HR 1062 SEC Regulatory Accountability Act
HR 1603 The Mutual Community Bank Competitive Equality Act
HR 1750 The Community Lending Enhancement and Regulatory Relief Act
HR 2199 Flood Insurance
HR 2266 The Subsidy Reserve Act (All provisions)
HR 2402 The Consumer Financial Protection Commission Act
HR 2446 The Responsible Consumer Financial Protection Regulations Act
HR 2542 The Regulatory Flexibility Improvements Act of 2013
HR 2672 The CFPB Rural Designation Petition and Correction Act
HR 2673 The Portfolio Lending and Mortgage Access Act of 2013
HR 3193 The Consumer Financial Protection Safety and Soundness Improvement Act
HR 3329 To Enhance the Ability of Community Financial Institutions to Foster Economic Growth
HR 3389 CFPB Slush Fund Elimination Act of 2013
HR 3474 Expiring Provisions Improvement Act
HR 4042 Community Bank Mortgage Servicing Asset Capital Requirements Study Act of 2014
HR 4167 Restoring Proven Financing for American Employers Act
HR 4252 Mutual Bank Choice and Continuity Act of 2014
HR 4383 Bureau of Consumer Financial Protection Small Business Advisory Board Act (All provisions)
HR 4466 Financial Regulatory Clarity Act
HR 4521 Community Institution Mortgage Relief Act
HR4662 The Bureau Advisory Opinion Act
HR 4986 End Operation Choke Point Act of 2014
HR 5148 Access to Affordable Mortgages Act of 2014
HR 5405 Promoting Job Creation and Reducing Small Business Burdens Act of 2014
HR 5461 Dodd Frank Reforms
S 635 Privacy Notice Modernization Act
S 727 The Financial Institutions Examination Fairness and Reform Act
S 1217 Housing Finance Reform and Taxpayer Protection Act
S 1349 The Community Lending Enhancement and Regulatory Relief Act
S 1916 HELP Rural Communities Act of 2014
S 1927 Data Secuity Act of 2014
S 2244 Amendment 3550 to the Terrorism Risk Insurance Program Reauthoriation Act of 2014
S 2252 Community Bank Preservation Act
S 2588 Cybersecurity Information Sharing Act of 2014
S 2732 The CFPB Examination and Reporting Threshhold Act of 2014
Access to Capital for Community Banks
Call Report Changes
Capital Requirements/Regulations/Basel III Rules
CFPB eRegulations Tool
CFPB Reforms
Credit Union Business Lending Powers
Credit Union Tax Exemption
Cybersecurity
Data Security and Breaches
DeNovo Bank Applications
Department of Justice Operation Chokepoint
Federal Reserve Vacancy
Flood Insurance Reform Implementation of Bigger-Waters Act
Home Mortgage Disclosure Act (HMDA) Regulations
Housing Finance Reform
Housing Government Sponsored EnterprisesMortgage Escrow Requirements
Mortgage Lending Reform
Mortgage Loan Origination Standards
Mortgage Servicing Standards
National Flood Insurance Program
Patent Litigation Reform
Patent Trolling/Demand Letters
Qualified Mortgages, Ability to Repay Rules
Qualified Residential Mortgages/Risk Retention
Regulation Z Establishment of Escrow - Higher Priced Loans
Regulatory and Tax Relief for Community Banks
TILA/RESPA Final Rule Implementation
Virtual Currency - CFPB
Client expense: $880,000 · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA)
Cited source text, amounts, lobbyists, and targets
Data Transparency, DATA Act, S. 994, HR 2061; Medicaid Integrity Act of 2013; H.R. 162 (audits of Medicaid Managed Care programs); Revisions to the JOBS Act, including mandatory audit firm rotation; Auditor liability; Audit Integrity and Job Protection Act, HR1564/S 1526; PCAOB Enforcement Transparency Act of 2013, S 848; CLEAR Relief Act of 2013, HR 1750
Client expense: Not reported · Firm income: $1,130,000
Government targets: Agriculture, Dept of (USDA), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA)
Cited source text, amounts, lobbyists, and targets
Please see addendum.Issues related to credit union operations
Issues related to credit union field of membership
Issues related to credit union service organizations
Issues related to vacancies on the National Credit Union Administration (NCUA) Board
Issues related to NCUAs proposed rule on credit union service organizations
Issues related to NCUAs rule on net worth and bargain purchase agreements
Issues related to NCUAs low income designation regulations
Issues related to NCUA examination procedures
Issues related to NCUAs proposed rule regarding loan participations
Issues related to NCUAs regulation regarding its regulatory flexibility program
Issues related to NCUAs proposed rule regarding emergency liquidity
Issues related to material loss reports of the NCUA Office of Inspector General
Issues related to the authority of the CFPB to exempt credit unions from its rulemaking
Issues related to the CFPB proposal related to remittances and international wire transfers
Issues related to the proposed CFPB form on RESPA/TILA
Issues related to overdraft protection and check ordering practices
Issues related to mortgage servicing
Issues related to mortgage loan originator compensation and qualifications
Issues related to high-cost mortgage loans (HOEPA)
Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay
Issues related to reverse mortgages
Issues related to the Financial Accounting Standards Board (FASB)
Issues related to mark-to-market accounting
Issues related to private equity standards
Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act
Issues related to data and cyber security
Issues related to mobile banking and mobile payments
Issues related to the oversight of the Federal Housing Administration
Issues related to USDA Rural Development Loan program
Issues related to identity theft and fraud reduction
Issues related to student lending
Issues related to derivatives and NCUAs proposed rule related to credit union use of derivatives
Issues related to the Federal Home Loan Bank System
Issues related to short term lending products and advance deposit products
Issues related to patent reform
Issues related to Federal Credit Union bylaws
Issues related to NCUAs Minority Depository Institution program
Issues relating to home-based credit unions
Issues related to NCUAs Appraisal Management Company proposal
Issues related to NCUAs risk-based capital proposal
Issues related to the Johnson-Crapo Housing Finance Reform proposal
Issues related to NCUAs proposed rule on securitization
Issues related to NCUAs regulatory review process
Issues related to Ginnie Mae capital
Issues related to the nomination of J. Mark McWatters to be a member of the National Credit Union Administration Board
Issues related to a discussion draft of legislation entitled, The Bureau Guidance Transparency Act
Issues related to a discussion draft of legislation entitled, Preventing Regulatory Abuse Act of 2014
Issues related to a discussion draft of legislation entitled, Bureau Examination Fairness Act
Issues related to credit union service to marijuana businesses
Issues related to financial literacy
Issues related to the Department of Justices investigation entitled, Operation Choke Point
Issues related to membership eligibility in the Federal Home Loan Bank System.H.R. 450, Bureau of Consumer Financial Protection Accountability Act, all provisions
H.R. 688, Credit Union Small Business Jobs Creation Act of 2013, all provisions
H.R. 719, Capital Access for Small Businesses and Jobs Act of 2013, all provisions
H.R. 736, Responsible Homeowner Refinancing Act of 2013, all provisions
H.R. 749, Eliminate Privacy Notice Confusion Act of 2013, all provisions
H.R. 801, Holding Company Registration Threshold Equalization Act of 2013, all provisions
H.R. 839, Prompt Notification of Short Sale Act, all provisions
H.R. 861, Elder Abuse Victims Act of 2013, all provisions
H.R. 927, Common Sense Economic Recovery Act of 2013, all provisions
H.R. 1077, Consumer Mortgage Choice Act
H.R. 1255, Home Construction Lending Regulatory Improvement Act of 2013, all provisions
H.R. 1261, Overdraft Protection Act of 2013, all provisions
H.R. 1538, a bill to provide incentives to encourage financial institutions and small businesses to provide continuing financial education to customers, borrowers and employees, all provisions
H.R. 1553, Financial Institution Examination Fairness and Reform Act, all provisions
H.R. 1566, a bill to create a Federal Charter for Internet consumer credit corporations, all provisions
H.R. 1603, a bill to support and promote community financial institutions in the mutual form, all provisions
H.R. 1646, a bill to amend the Federal Credit Union Act to provide an exception from the member business loan cap for loans made to aid in the recovery from a disaster, all provisions
H.R. 1694, a bill to allow the Secretary of Treasury to rely on State examinations for certain financial institutions, all provisions
H.R. 1750, the CLEAR Relief Act, all provisions
H.R. 1754, Preserving American Homeownership Act of 2013, all provisions
H.R. 1779, Preserving Access to Manufactured Housing Act of 2013, all provisions
H.R. 1862, Capital Access for Small Community Financial Institutions, all provisions
H.R. 2136, Small Business Credit Availability Act, all provisions
H.R. 2295, Basel III CASE Act, all provisions
H.R. 2379, Qualified Mortgage Loan Originator Transitional Authority Act, all provisions
H.R. 2419, a bill to amend the Truth in Lending Act to provide coverage under such Act for credit cards issued to small businesses, all provisions
H.R. 2512, a bill to amend the Truth in Lending Act to establish clear regulatory standards for mortgage servicers, all provisions
H.R. 2547, a bill to determine appropriate risk based capital requirements for community, mid-size, and regional institutions, all provisions
H.R. 2561, a bill to provide for the removal of default information form a borrowers credit report with respect to certain rehabilitated education loans, all provisions
H.R. 2571, a bill to amend the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act to require the Bureau of Consumer Financial Protection to notify and obtain permission from consumers before collecting nonpublic personal information about such consumers, all provisions
H.R. 2572, a bill to improve the regulation of credit unions and depository institutions and to provide regulatory relief, all provisions
H.R. 2580, a bill to allow homeowners of moderate-value homes who are subject to mortgage foreclosure proceedings to remain in their homes as renters, all provisions
H.R. 2652, Marijuana Businesses Access to Banking Act of 2013
H.R. 2672, CFPB Rural Designation Petition and Correction Act
H.R. 2673, the Portfolio Lending Mortgage Access Act, all provisions
H.R. 2733, Defending American Taxpayers From Abusive Government Takings Act of 2013
H.R. 2767, Protecting American Taxpayers and Homeowners Act of 2013
H.R. 2816, To extend the pilot program under section 258 of the National Housing Act that establishes an automated process for providing alternative credit rating information for mortgagors and prospective mortgagors under certain mortgages.
H.R. 2917, Financial Security Credit Act of 2013
H.R. 2961, To amend the Truth in Lending Act and the Higher Education Act of 1965 to require additional disclosures and protections for students and cosigners with respect to student loans, and for other purposes.
H.R. 3036, a bill to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision, and for other purposes.H.R. 3137, Freedom and Mobility in Consumer Banking Act, all provisions
H.R. 3310, Annuity Safety and Security under Reasonable Enforcement Act, all provisions
H.R. 3312, Homeowners Flood Insurance Relief Act, all provisions
H.R. 3317, Holding Individual Accountable and Deterring Money Laundering Act, all provisions
H.R. 3329, a bill to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, all provisions.
H.R. 3370, Homeowner Flood Insurance Affordability Act, all provisions
H.R. 3374, the American Savings Promotion Act, all provisions
H.R. 3468, the Credit Union Share Insurance Parity Act, all provisions
H.R. 3584, a bill to amend the Federal Home Loan Bank Act to authorize privately insured credit unions to become members of a Federal home loan bank, all provisions
H.R. 4042, Community Bank Mortgage Servicing Asset Capital Requirements Study Act, all provisions
H.R. 4226, Credit Union Residential Loan Parity Act, all provisions
H.R. 4466, the Financial Regulatory Clarity Act of 2014
H.R. 4521, the Community Institution Mortgage Relief Act, all provisions
H.R. 4626, the SAFE Act Confidentiality and Privilege Enhancement Act, all provisions
H.R. 4804, the Bureau Examination Fairness Act, all provisions
H.R. 4986, End Operation Choke Point Act, all provisions
H.R. 5148, Access to Affordable Mortgages Act, all provisions
H.R. 5403, Reforming CFPB Indirect Auto Financing Guidance Act, all provisions
H.R. 5461, a Bill to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes, Title II and Title III.
Kildee Amendment to H.R. 1960, National Defense Authorization Act, related to disclosures required under the Military Lending Act
S. 113, Know Before You Owe Private Student Loan Act, all provisions
S. 114, Fairness for Struggling Student Act, all provisions
S. 172, Stopping Abuse and Fraud in Electronic (SAFE) Lending Act of 2013, all provisions
S. 187, Deceptive Loan Check Elimination Act, all provisions
S. 205, Responsible Consumer Financial Protection Regulations Act of 2013, all provisions
S. 249, Responsible Homeowner Refinancing Act of 2013, all provisions
S. 361, Prompt Notification of Short Sale Act of 2013, all provisions
S. 450, Financial Regulatory Responsibility Act of 2013, all provisions
S. 451, a bill to make technical corrections to the Dodd-Frank Wall Street Reform and Consumer Protection Act, all provisions
S. 563, Jumpstart GSE Reform Act, all provisions
S. 635, Privacy Notice Modernization Act of 2013, all provisions
S. 673, Protecting Consumers from Unreasonable Credit Rates Act, all provisions
S. 676, Identity Theft and Tax Fraud Prevention Act of 2013, all provisions
S. 727, Financial Institutions Examination Fairness and Reform Act, all provisions
S. 731, Basel III CASE Act, all provisions
S. 733, Basel III Impact Study Act, all provisions
S. 798, Terminating Bailouts for Taxpayer Fairness Act, all provisions
S. 872, Holding Company Registration Threshold Equalization Act, all provisions
S. 947, SAFE Act Confidentiality and Privilege Enhancement Act, all provisions
S. 968, Small Business Lending Enhancement Act, all provisions
S. 985, a bill to repeal certain provisions of the Gramm-Leach-Bliley Act and revive the separation between commercial banking and the securities business, in the manner provided in the Banking Act of 1933, the so-called Glass-Steagall Act, all provisions
S. 996, a bill to improve the National Flood Insurance Program, all provisions
S. 1002, Home Building Lending Improvement Act, all provisions
S. 1048, the Mortgage Finance Act, all provisionsS. 1098, a bill to reform the Biggert-Waters Flood Insurance Reform Act of 2012 to responsibly protect homeownership, all provisions
S. 1176, a bill to impose a fine with respect to international remittance transfers if the sender is unable to verify legal status in the United States, all provisions
S. 1217, Housing Finance Reform and Taxpayer Protection Act, all provisions
S. 1229, a bill to amend the Truth in Lending Act to empower the States to set the maximum annual percentage rates applicable to consumer credit transactions, all provisions
S. 1282, 21st Century Glass-Steagall Act of 2013
S. 1349, a bill to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes.
S. 1511, the Mortgage Choice Act, all provisions
S. 1534, Freedom and Mobility in Consumer Banking Act, all provisions
S. 1538, FIX Credit Reporting Errors Act, all provisions
S. 1577, Mortgage Choice Act, all provisions
S. 1597, the American Savings Promotion Act, all provisions
S. 1610, Homeowner Flood Insurance Affordability Act, all provisions
S. 1806, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions, all provisions
S. 1867, Prepaid Card Consumer Protection Act of 2013, all provisions
S. 1916, the HELP Rural Communities Act, all provisions
S. 2641, the Portfolio Lending Enhancement Act, all provisions
S. 2698, the Regulatory Easement for Lending Institutions Act, Title II and Title III.
S. 2699, a Bill to require the National Credit Union Administration to provide pass-through share insurance for the deposits or shares of any interest on lawyers trust accounts, and for other purposes.
S. Res. 105, a resolution designating April 2013 as Financial Literacy Month
Johnson / Crapo amendment to S. 1217, the Housing Finance Reform and Taxpayer Protection Act, all provisions
Moran / Manchin amendment to S. 1217, the Housing Finance Reform and Taxpayer Protection Act, all provisions
Toomey / Coburn amendment to S. 1217, the Housing Finance Reform and Taxpayer Protection Act, all provisions
Client expense: $1,060,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of Government Ethics (OGE), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Cited source text, amounts, lobbyists, and targets
Revision of Sarbanes-Oxley rules on disclosure of disciplinary proceedings; Revisions to the JOBS Act, including mandatory audit firm rotation; Auditor liability; Audit Integrity and Job Protection Act, HR 1564/S 1526
PCAOB Enforcement Transparency Act of 2013, S 848
CLEAR Relief Act of 2013, HR 1750
S 1526 (Audit Integrity and Job Protection Act)
Client expense: $630,000 · Firm income: Not reported
Government targets: Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC)
Cited source text, amounts, lobbyists, and targets
HR 1261 - Overdraft Protection Act of 2013 - Provisions related to caps & limitations on overdraft charges.
S 710 - A bill to provide commercial banks & S&Ls an exemption from Dodd-Frank Act provisions requiring the regulation of municipal advisors - Provisions to exempt certain bank employees from being considered municipal advisors.HR 1750 - Regulatory Relief Act - Provisions related to exemptions from the qualified mortgage requirements & privacy notice requirements.
HR 3317 - Holding Individuals Accountable & Deterring Money Laundering Act - Provisions that would strengthen the Federal statutes designed to deter money laundering & terrorism financing.
HR 3770 - Homeowner Flood Insurance Affordability Act - Provisions addressing issues with the affordability of the National Flood Insurance program and mapping issues.
S 1720 - Patent reform legislation - Provisions addressing patent reform.
S 1926 - A bill combining the National Flood Insurance Program reforms with NARAB II - Provisions regarding escrow requirements under flood insurance program.
HR 4466 - Financial Regulatory Clarity Act - Provisions regarding regulatory processes to determine duplicative rules and regulations.
S 635 - Privacy Notice Bill - eliminating the need to send GLBA privacy notices if a financial institution has not changed its privacy policy in the last year.
Client expense: $300,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
Data Transparency, DATA Act, S. 994, HR 2061; Medicaid Integrity Act of 2013; H.R. 162 (audits of Medicaid Managed Care programs); Revisions to the JOBS Act, including mandatory audit firm rotation; Auditor liability; Audit Integrity and Job Protection Act, HR1564/S 1526; PCAOB Enforcement Transparency Act of 2013, S 848; CLEAR Relief Act of 2013, HR 1750
Client expense: $1,020,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to debit card interchange fees.
Issues relating to mobile payments.
H.R.1750, CLEAR Relief Act of 2013, provisions relating to international ACH transactions.
Issues relating to anti-money laundering and the Bank Secrecy Act generally.
Issues relating to cyber-security.
Client expense: Not reported · Firm income: $22,500
Cited source text, amounts, lobbyists, and targets
See addendum.S. 474, the Swaps Regulatory Improvement Act (all provisions)
S. 635, the Privacy Notice Modernization Act of 2013 (all provisions)
S. 710, the Municipal Advisors Relief Act of 2013 (all provisions to exempt commercial banks and savings and loan associations from the Dodd-Frank Act provisions requiring regulation of municipal advisors)
S. 731, the Basel III CASE Act (all provisions)
S. 737, the Basel III Impact Study Act (all provisions)
S. 798, the Terminating Bailouts for Taxpayer Fairness Act of 2013 (all provisions)
S. 872, the Holding Company Registration Threshold Equalization Act of 2013 (provisions to extend to savings and loan holding companies the new SEC shareholder registration and deregistration thresholds under the JOBS Act)
S. 968, the Small Business Lending Enhancement Act of 2013 (all provisions to increase credit union business lending limits)
H.R. 613, the Systemic Risk Mitigation Act (all provisions)
H.R. 634, Business Risk Mitigation and Price Stabilization Act of 2013 (provisions to clarify that end users would not be subject to margin requirements for un-cleared swaps)
H.R. 677, the Inter-Affiliate Swap Clarification Act (all provisions
H.R. 701, to amend a provision of the Securities Act of 1933 directing the Securities and Exchange Commission to add a particular class of securities to those exempted under such Act to provide a deadline for such action
H.R. 742, the Swap Data Repository and Clearinghouse Indemnification Correction Act
H.R. 749, the Eliminate Privacy Notice Confusion Act (all provisions)
H.R.797 , the Municipal Advisor Oversight Improvement Act of 2013
H.R. 801, the Holding Company Registration Threshold Equalization Act of 2013 (all provisions)
H.R. 992, the Swaps Regulatory Improvement Act (all provisions)
H.R. 1003, to provide for a full assessment of the costs and benefits of Commodity Futures Trading Commission (CFTC) regulations
H.R. 1062, the SEC Regulatory Accountability Act (all provisions to require the SEC to do a thorough cost-benefit analysis before proposing a new regulation)
H.R. 1256, the Swap Jurisdiction Certainty Act
H.R. 1341, the Financial Competitive Act of 2013 (all provisions)
H.R. 1553, the Financial Institutions Examination Fairness and Reform Act (all provisions)H.R. 1750, the Community Lending Enhancement and Regulatory Relief Act
H.R. 2672, the CFPB Rural Designation Petition and Correction Act
H.R. 3584, to amend the Federal Home Loan Bank Act to authorize privately insured credit unions to become members of a Federal home loan bank, and for other purposes
H.R. 3329, to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes.
Draft Senate legislation to exempt commercial banks from municipal advisor regulation
Discussion Draft of the Swap Jurisdiction Certainty Act (all provisions)
Draft legislation that would require the Treasury Department to determine which commercial banks, investment banks, hedge funds, and insurance companies are too-big-to-fail, and to break up those institutions within one year.
Clarity in Regulations Discussion Draft
H.Res. 496, Recognizing the importance of savings to financial security.
S. 1927, Data Security Act of 2014
S. 2114, Bond Transparency Act of 2014
H.R. 4252, Mutual Bank Choice and Continuity Act of 2014
H.R. 4569, Disclosure Modernization and Simplification Act of 2014
H.R. 4466, Financial Regulatory Clarity Act of 2014
Client expense: $1,960,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
HR 1261 - Overdraft Protection Act of 2013 - Provisions related to caps and limitations on overdraft charges.
S 710 - A bill to provide commercial banks and S&Ls an exemption from Dodd-Frank Act provisions requiring the regulation of municipal advisors.
HR 1750 - Regulatory Relief Act - Exemptiosn from the qualified mortgage requirements & privacy notice requirements.HR 3317 - Holiding Individuals Accountable and Deterring Money Laundering Act - Provisions that would strengthen the Federal statutes designed to deter money laundering and terrorism financing.
HR 3770 - Homeowner Flood Insurance Affordability Act - Provisions addressing issues with the affordability of National Flood Insurance program and mapping issues.
S 1720 - Patent reform legislation - provisions addressing patent reform.
S 1926 - A bill combining the National Flood Insurance Program reforms with NARAB II - escrow requirements under flood insurance program.
HR 4466 - Financial Regulatory Clarity Act - Provisions regarding regulatory processes to determine duplicative rules and regulations.
S 635 - Privacy Notice Bill - to eliminate the need to send GLBA privacy notices if a financial institution has not changed its privacy policy in the last year.
Client expense: $175,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
Please see addendum.Issues related to credit union operations
Issues related to credit union field of membership
Issues related to credit union service organizations
Issues related to vacancies on the National Credit Union Administration (NCUA) Board
Issues related to NCUAs proposed rule on credit union service organizations
Issues related to NCUAs rule on net worth and bargain purchase agreements
Issues related to NCUAs low income designation regulations
Issues related to NCUA examination procedures
Issues related to NCUAs proposed rule regarding loan participations
Issues related to NCUAs regulation regarding its regulatory flexibility program
Issues related to NCUAs proposed rule regarding emergency liquidity
Issues related to material loss reports of the NCUA Office of Inspector General
Issues related to the authority of the CFPB to exempt credit unions from its rulemaking
Issues related to the CFPB proposal related to remittances and international wire transfers
Issues related to the proposed CFPB form on RESPA/TILA
Issues related to overdraft protection and check ordering practices
Issues related to mortgage servicing
Issues related to mortgage loan originator compensation and qualifications
Issues related to high-cost mortgage loans (HOEPA)
Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay
Issues related to reverse mortgages
Issues related to the Financial Accounting Standards Board (FASB)
Issues related to mark-to-market accounting
Issues related to private equity standards
Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act
Issues related to data and cyber security
Issues related to mobile banking and mobile payments
Issues related to the oversight of the Federal Housing Administration
Issues related to USDA Rural Development Loan program
Issues related to identity theft and fraud reduction
Issues related to student lending
Issues related to derivatives and NCUAs proposed rule related to credit union use of derivatives
Issues related to the Federal Home Loan Bank System
Issues related to short term lending products and advance deposit products
Issues related to patent reform
Issues related to Federal Credit Union bylaws
Issues related to NCUAs Minority Depository Institution program
Issues relating to home-based credit unions
Issues related to NCUAs Appraisal Management Company proposal
Issues related to NCUAs risk-based capital proposal
Issues related to NCUAs proposed rule on securitization
Issues related to NCUAs regulatory review process
Issues related to Ginnie Mae capital
Issues related to the nomination of J. Mark McWatters to be a member of the National Credit Union Administration Board
Issues related to a discussion draft of legislation entitled, The Bureau Guidance Transparency Act
Issues related to a discussion draft of legislation entitled, Preventing Regulatory Abuse Act of 2014
Issues related to a discussion draft of legislation entitled, Bureau Examination Fairness Act
Issues related to credit union service to marijuana businesses
Issues related to financial literacy
Issues related to the Department of Justices investigation entitled, Operation Choke Point
H.R. 450, Bureau of Consumer Financial Protection Accountability Act, all provisionsH.R. 688, Credit Union Small Business Jobs Creation Act of 2013, all provisions
H.R. 719, Capital Access for Small Businesses and Jobs Act of 2013, all provisions
H.R. 736, Responsible Homeowner Refinancing Act of 2013, all provisions
H.R. 749, Eliminate Privacy Notice Confusion Act of 2013, all provisions
H.R. 801, Holding Company Registration Threshold Equalization Act of 2013, all provisions
H.R. 839, Prompt Notification of Short Sale Act, all provisions
H.R. 861, Elder Abuse Victims Act of 2013, all provisions
H.R. 927, Common Sense Economic Recovery Act of 2013, all provisions
H.R. 1077, Consumer Mortgage Choice Act
H.R. 1255, Home Construction Lending Regulatory Improvement Act of 2013, all provisions
H.R. 1261, Overdraft Protection Act of 2013, all provisions
H.R. 1538, a bill to provide incentives to encourage financial institutions and small businesses to provide continuing financial education to customers, borrowers and employees, all provisions
H.R. 1553, Financial Institution Examination Fairness and Reform Act, all provisions
H.R. 1566, a bill to create a Federal Charter for Internet consumer credit corporations, all provisions
H.R. 1603, a bill to support and promote community financial institutions in the mutual form, all provisions
H.R. 1646, a bill to amend the Federal Credit Union Act to provide an exception from the member business loan cap for loans made to aid in the recovery from a disaster, all provisions
H.R. 1694, a bill to allow the Secretary of Treasury to rely on State examinations for certain financial institutions, all provisions
H.R. 1750, the CLEAR Relief Act, all provisions
H.R. 1754, Preserving American Homeownership Act of 2013, all provisions
H.R. 1779, Preserving Access to Manufactured Housing Act of 2013, all provisions
H.R. 1862, Capital Access for Small Community Financial Institutions, all provisions
H.R. 2136, Small Business Credit Availability Act, all provisions
H.R. 2295, Basel III CASE Act, all provisions
H.R. 2379, Qualified Mortgage Loan Originator Transitional Authority Act, all provisions
H.R. 2419, a bill to amend the Truth in Lending Act to provide coverage under such Act for credit cards issued to small businesses, all provisions
H.R. 2512, a bill to amend the Truth in Lending Act to establish clear regulatory standards for mortgage servicers, all provisions
H.R. 2547, a bill to determine appropriate risk based capital requirements for community, mid-size, and regional institutions, all provisions
H.R. 2561, a bill to provide for the removal of default information form a borrowers credit report with respect to certain rehabilitated education loans, all provisions
H.R. 2571, a bill to amend the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act to require the Bureau of Consumer Financial Protection to notify and obtain permission from consumers before collecting nonpublic personal information about such consumers, all provisions
H.R. 2572, a bill to improve the regulation of credit unions and depository institutions and to provide regulatory relief, all provisions
H.R. 2580, a bill to allow homeowners of moderate-value homes who are subject to mortgage foreclosure proceedings to remain in their homes as renters, all provisions
H.R. 2652, Marijuana Businesses Access to Banking Act of 2013
H.R. 2672, CFPB Rural Designation Petition and Correction Act
H.R. 2673, the Portfolio Lending Mortgage Access Act, all provisions
H.R. 2733, Defending American Taxpayers From Abusive Government Takings Act of 2013
H.R. 2767, Protecting American Taxpayers and Homeowners Act of 2013
H.R. 2816, To extend the pilot program under section 258 of the National Housing Act that establishes an automated process for providing alternative credit rating information for mortgagors and prospective mortgagors under certain mortgages.
H.R. 2917, Financial Security Credit Act of 2013
H.R. 2961, To amend the Truth in Lending Act and the Higher Education Act of 1965 to require additional disclosures and protections for students and cosigners with respect to student loans, and for other purposes.
H.R. 3036, a bill to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision, and for other purposes.
H.R. 3137, Freedom and Mobility in Consumer Banking Act, all provisionsH.R. 3310, Annuity Safety and Security under Reasonable Enforcement Act, all provisions
H.R. 3312, Homeowners Flood Insurance Relief Act, all provisions
H.R. 3317, Holding Individual Accountable and Deterring Money Laundering Act, all provisions
H.R. 3329, a bill to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, all provisions.
H.R. 3370, Homeowner Flood Insurance Affordability Act, all provisions
H.R. 3374, the American Savings Promotion Act, all provisions
H.R. 3468, the Credit Union Share Insurance Parity Act, all provisions
H.R. 3584, a bill to amend the Federal Home Loan Bank Act to authorize privately insured credit unions to become members of a Federal home loan bank, all provisions
H.R. 4226, Credit Union Residential Loan Parity Act, all provisions
H.R. 4466, the Financial Regulatory Clarity Act of 2014
H.R. 4521, the Community Institution Mortgage Relief Act, all provisions
Kildee Amendment to H.R. 1960, National Defense Authorization Act, related to disclosures required under the Military Lending Act
S. 113, Know Before You Owe Private Student Loan Act, all provisions
S. 114, Fairness for Struggling Student Act, all provisions
S. 172, Stopping Abuse and Fraud in Electronic (SAFE) Lending Act of 2013, all provisions
S. 187, Deceptive Loan Check Elimination Act, all provisions
S. 205, Responsible Consumer Financial Protection Regulations Act of 2013, all provisions
S. 249, Responsible Homeowner Refinancing Act of 2013, all provisions
S. 361, Prompt Notification of Short Sale Act of 2013, all provisions
S. 450, Financial Regulatory Responsibility Act of 2013, all provisions
S. 451, a bill to make technical corrections to the Dodd-Frank Wall Street Reform and Consumer Protection Act, all provisions
S. 563, Jumpstart GSE Reform Act, all provisions
S. 635, Privacy Notice Modernization Act of 2013, all provisions
S. 673, Protecting Consumers from Unreasonable Credit Rates Act, all provisions
S. 676, Identity Theft and Tax Fraud Prevention Act of 2013, all provisions
S. 727, Financial Institutions Examination Fairness and Reform Act, all provisions
S. 731, Basel III CASE Act, all provisions
S. 733, Basel III Impact Study Act, all provisions
S. 798, Terminating Bailouts for Taxpayer Fairness Act, all provisions
S. 872, Holding Company Registration Threshold Equalization Act, all provisions
S. 947, SAFE Act Confidentiality and Privilege Enhancement Act, all provisions
S. 968, Small Business Lending Enhancement Act, all provisions
S. 985, a bill to repeal certain provisions of the Gramm-Leach-Bliley Act and revive the separation between commercial banking and the securities business, in the manner provided in the Banking Act of 1933, the so-called Glass-Steagall Act, all provisions
S. 996, a bill to improve the National Flood Insurance Program, all provisions
S. 1002, Home Building Lending Improvement Act, all provisions
S. 1048, the Mortgage Finance Act, all provisions
S. 1098, a bill to reform the Biggert-Waters Flood Insurance Reform Act of 2012 to responsibly protect homeownership, all provisions
S. 1176, a bill to impose a fine with respect to international remittance transfers if the sender is unable to verify legal status in the United States, all provisions
S. 1217, Housing Finance Reform and Taxpayer Protection Act, all provisions
S. 1229, a bill to amend the Truth in Lending Act to empower the States to set the maximum annual percentage rates applicable to consumer credit transactions, all provisions
S. 1282, 21st Century Glass-Steagall Act of 2013
S. 1349, a bill to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes.S. 1534, Freedom and Mobility in Consumer Banking Act, all provisions
S. 1538, FIX Credit Reporting Errors Act, all provisions
S. 1577, Mortgage Choice Act, all provisions
S. 1597, the American Savings Promotion Act, all provisions
S. 1610, Homeowner Flood Insurance Affordability Act, all provisions
S. 1806, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions, all provisions
S. 1867, Prepaid Card Consumer Protection Act of 2013, all provisions
S. 1916, the HELP Rural Communities Act, all provisions
S. Res. 105, a resolution designating April 2013 as Financial Literacy Month
Johnson / Crapo amendment to S. 1217, the Housing Finance Reform and Taxpayer Protection Act, all provisions
Moran / Manchin amendment to S. 1217, the Housing Finance Reform and Taxpayer Protection Act, all provisions
Toomey / Coburn amendment to S. 1217, the Housing Finance Reform and Taxpayer Protection Act, all provisions
Client expense: $1,340,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of Government Ethics (OGE), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA)
Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA)
Cited source text, amounts, lobbyists, and targets
HR 688 Credit Union Small Business Job Creation Act of 2013
HR 719 Capital Access for Small Businesses and Jobs Act
HR 749 Eliminate Privacy Notice Confusion Act
HR 797 Municipal Adviser Oversight Improvement Act of 2013HR 801 The Holding Company Restriction Threshold Equalization Act
HR 892 The S Corporation Modernization Act
HR 1062 SEC Regulatory Accountability Act
HR 1603 The Mutual Community Bank Competitive Equality Act
HR 1750 The Community Lending Enhancement and Regulatory Relief Act
HR 2199 Flood Insurance
HR 2266 The Subsidy Reserve Act (All provisions)
HR 2402 The Consumer Financial Protection Commission Act
HR 2446 The Responsible Consumer Financial Protection Regulations Act
HR 2542 The Regulatory Flexibility Improvements Act of 2013
HR 2672 The CFPB Rural Designation Petition and Correction Act
HR 2673 The Portfolio Lending and Mortgage Access Act of 2013
HR 2767 The Protecting American Taxpayers Homeowners Act
HR 3193 The Consumer Financial Protection Safety and Soundness Improvement Act
HR 3329 To Enhance the Ability of Community Financial Institutions to Foster Economic Growth
HR 3370 Homeowner Flood Insurance Affordability Act of 2014
HR 3389 CFPB Slush Fund Elimination Act of 2013
HR 3474 Expiring Provisions Improvement Act
HR 3770 CFPB - IG Act of 2013
HR 3819 Fairness for Community Job Creators Act
HR 4042 Community Bank Mortgage Servicing Asset Capital Requirements Study Act of 2014
HR 4167 Restoring Proven Financing for American Employers Act
HR 4252 Mutual Bank Choice and Continuity Act of 2014
HR 4383 Bureau of Consumer Financial Protection Small Business Advisory Board Act (All provisions)
HR 4466 Financial Regulatory Clarity Act
HR 4521 Community Institution Mortgage Relief Act
HR 4539 The Bureau Research Transparency Act (All)
HR 4660 CJS Appropriations Act Amendment
HR4662 The Bureau Advisory Opinion Act
HR 4684 The Bureau Guidance Transparency Act (All)
HR 4986 End Operation Choke Point Act of 2014
S 635 Privacy Notice Modernization Act
S 727 The Financial Institutions Examination Fairness and Reform Act
S 1217 Housing Finance Reform and Taxpayer Protection Act
S 1349 The Community Lending Enhancement and Regulatory Relief Act
S 1907 Fairness for Community Job Creators Act
S 1916 HELP Rural Communities Act of 2014
S 1927 Data Secuity Act of 2014
S 2252 Community Bank Preservation Act
Access to Capital for Community Banks
Bank Deposit Account Disclosures
Call Report Changes
Capital Requirements/Regulations/Basel III Rules
CFPB eRegulations Tool
CFPB Reforms
Credit Union Business Lending Powers
Credit Union Tax Exemption
Cybersecurity
Data Security and Breaches
DeNovo Bank Applications
Department of Justice Operation Chokepoint
Federal Reserve Vacancy
Flood Insurance Reform Implementation of Bigger-Waters ActHome Mortgage Disclosure Act (HMDA) Regulations
Housing Finance Reform
Housing Government Sponsored Enterprises
Mortgage Escrow Requirements
Mortgage Lending Reform
Mortgage Loan Origination Standards
Mortgage Servicing Standards
National Flood Insurance Program Reauthorization
Patent Litigation Reform
Postal Reform-provision of banking services
Qualified Mortgages, Ability to Repay Rules
Qualified Residential Mortgages/Risk Retention
Regulation Z Establishment of Escrow - Higher Priced Loans
Regulatory and Tax Relief for Community Banks
Client expense: $1,460,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA)
Cited source text, amounts, lobbyists, and targets
Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities -
Downsize too-big-to-fail banks and financial firms to protect our financial system, economy, and American Taxpayers from future bailouts - downsize (restructure) too-big-to-fail (TBTF) banks and financial firms, reduce the probability and severity of future financial crisis and taxpayer bailouts, moral hazard, numerous TBTF misdeeds (abuse, fraud, manipulation and scandal),too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, Department of Justices reluctance to prosecute TBTFs versus community banks, and Government Accountability Offices (GAO) confirmation of TBTFs funding advantages (House and Senate)
Tiered regulation supervision and exemptions for community banks - recognition of the different business model and risks posed by TBTF banks and financial firms, one size fits all legislation and regulation, separate regulation - supervision - capital - liquidity requirements, disproportionate burden on community banks, unlevel playing field, and significant community bank competitive disadvantages
Including, the qualifying threshold under the Federal Reserves Small Bank Holding Company Policy Statement from $500 million to $5 billion and allowing small savings and loan holding companies to be covered by the Policy Statement, the internal control attestation requirements of Section 404(b) of the Sarbanes Oxley Act from $75 million in market capitalization to $350 million, and savings and loan holding companies being able to take advantage of the increased Securities and Exchange Commission (SEC) shareholder registration and deregistration thresholds under the JOBS Act (House and Senate)
Community bank regulatory relief as contained in the Independent Community Bankers of America Plan for Prosperity
Including, community bank exemption from certain mortgage reforms to support the housing recovery, redundant annual privacy notices, municipal advisor registration burdens to help serve local governments, Assistant Treasury Secretary for Community Banks, CFPBs more balanced regulations, improved accountability in bank exams with a workable appeals process, accounting and auditing expenses for publicly traded institutions, mutual bank new charter and dividend rules, rigorous and quantitative justification of new rules, additional capital for small bank holding companies, red tape in small-business lending, capital formation and reforming Subchapter S corporation regulations, and extending the net-operating-loss carry-back (House and Senate)
Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (House and Senate)
Expanded powers for tax-exempt credit unions - outdated original business model and straying from founding purpose, federal tax-exemption status, expansion of powers, level the playing field between community banks and credit unions, regulatory requirements including the Community Reinvestment Act (CRA)
Including, expanded lending powers by increasing percentage of asset cap on business lending, and raising capital from outside investors (House and Senate)
Expansion of the Farm Credit System - funding & tax advantages, expansionist agenda, competitive advantages over rural community banks, regulatory safeguards and controls, Co-Banks $725 million participation in commitment to Verizon Communications (House and Senate)
Mortgage lending reforms - imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, differences between non-traditional versus predatory lending practices, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, prepayment penalties, originator compensation, limited credit availability
Including, Qualified Mortgage (QM) status from the CFPBs Ability-to-Repay rules for loans originated and held in portfolio by community banks, balloon mortgages regardless of pricing, use of rural and underserved designations for QM eligibility for community banks and greatly expanding the definition of each, annual loan origination and asset threshold limits for small creditors, small servicer exemption for loans held in portfolio, community banks exemption from escrow requirements for loans held in portfolio and for small dollar amount loans, proposed adoption of the QM definition for Qualified Residential Mortgages (QRM) that would not require a high down-payment requirement (House and Senate)Housing Finance (GSE Secondary Market) Reform - Fannie Mae/Freddie Mac/FHFA unsustainable long-term conservatorship, community bank access to an impartial secondary market for residential mortgage loans, financial stable and reliable, government tie to secondary market (continued flow of credit and market liquidity), aggressive repurchase requests of transferred residential mortgages for technical violations
Including, selling loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market, pricing of any governmental guaranties, fairness and equality to all participants regardless of volume of loans guaranteed, and further consolidation of housing finance system that would result in several mega banks and financial firms dominating the market (House and Senate)
Tax, accounting and auditing changes - community bank focus supporting robust economic activity, savings & investments, accommodation/exemption for community banks, undue regulatory burden or cost on community banks
Including, tax reform that preserves the pass-through option, including the Subchapter S corporation and the ability of business borrowers to deduct interest, taxation of capital gains and dividends held in parity and at a preferential rate, tax-exempt status of interest paid on municipal bonds together with an increase in the Bank Qualified (BQ) annual threshold to $30 million and indexed for inflation, the ability of business and mortgage borrowers to deduct interest without further limitations must also be preserved, changes to the tax laws that disadvantage one form of corporate entity versus another should include a phase-in period and an amnesty to allow for a penalty-free corporate conversion, S corporation banks ability to raise capital to be enhanced by giving them the ability to issue preferred stock, increasing their shareholder limits and allowing new IRA shareholder investments, end to the tax subsidies for credit unions and the FCS lenders, community banks amortizing CRE losses over 10 years (versus in the year in which they are taken), capital standards that recognize the loss-absorbing abilities of the entire amount of the Allowance for Loan and Lease Losses (ALLL), the 1.25% ALLL disallowance (for regulatory capital purposes) should be eliminated which would encourage banks to reserve more and would strengthen capital positions, the work of the Financial Accounting Foundations Private Company Council to seek recognition, measurement and disclosure alternatives for small private companies including non-public community banks.
Including, Financial Accounting Standard Boards (FASB) proposed expected loss model requiring community banks to develop costly complex cash flow models for loans and investment securities to generate expected losses over the lives of these assets where implementing this proposal will be to frontload loss recognition which would harm both community bank earnings and capital, FASBs proposal to restrict the ability of community banks to classify mortgage loans and investment securities at amortized cost when their intent is to collect contractual cash flows which is based on the exit price of a loan or security and on the current value in a non-distressed market and which would require costly robust pricing engines and complex valuation methodologies to satisfy the standard, FASBs proposal to require extensive liquidity risk and interest rate risk footnote disclosures that would be required to be audited which would undermine the work of the prudential regulators whose job entails assessing the safety and soundness of community banks including an assessment of liquidity and interest rate risk, and new bank specific fees or punitive tax levies specifically targeting the financial service sector (House and Senate)
Remaining Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Including, rein in Significantly Important Financial Institution (SIFI) with enhanced prudential standards and rigorous focused regulation, higher capital requirements, capital surcharges, concentration limits, liquidity requirements, orderly liquidation rules, credible contingency resolution plan, shielding community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%, Volcker Rules prohibition on propriety trading and investment in and sponsorship of hedge funds and private equity funds, effectively exempting community banks
Including, ensure the Consumer Financial Protection Bureau (CFPB) focuses on large banks, financial firms and shadow financial companies, holding the mega banks and financial firms up to the same high standards for compliance with consumer laws as required and attained by community banks, governance (single Director versus five member commission), prudential regulators participation with CFPB in the rule writing process, FSOC veto of CFPB rules, CFPB exemption authority regardingcommunity banks, revision in the definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules, consistent and transparent standards in the evaluation of community bank fair lending standards, disparate impact and unintentional discrimination (House and Senate)
De novo community bank formation - need to maintain growing, vibrant & evolving banking profession, Federal Deposit Insurance Corporations (FDIC) actively inhibiting de novo community bank formation, inappropriate and restrictive one-size-fits-all supervisory policy (House and Senate)
Maintain the Federal Home Loan Bank (FHLB)System - strong partnership with community banks, healthy, stable & reliable source of funding for community banks, FHLBs should not be the sole aggregators for residential mortgages for community banks in the reform of the housing GSEs, preservation of the FHLBs special functions and purposes (House and Senate)
Excessive (Federal Reserve) intervention in monetary policy - significant drag on community banks net interest margins and earnings, limits on what monetary policy can accomplish, impact on community banks, savers and senior citizens (House and Senate)
*****
S. 798 Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (Senate)
S. 635 Privacy Act Notice Modernization Act of 2013 (redundant privacy notice regulatory relief) (all sections) (Senate)
H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House)
CBAI Comment Letters -
Comment Letter CFPB Advanced Notice of Proposed Rulemaking, Debt Collection (Regulation F), Docket No. CFPB-2013-0033-0001, RIN 3170-AA41
Comment Letter FHFA Fannie Mae and Freddie Mac Loan Purchase Limits: Request for Public Input on Implementation Issues No. 2013-N-18
Comment Letter Federal Reserve Bank of Chicago, Federal Deposit Insurance Corporation (Chicago Regional Office), and Illinois Department of financial and Professional Regulation (IDFPR) Regarding TruPS and Consent Order Dividend Restrictions
CBAI Action Alerts
H.R. 4521 Community Institution Mortgage Relief Act (exempt community bank portfolio loans from new escrow requirements and raise the small services exemption) (all sections) (House)
H.R. 4466 Financial Regulatory Clarity Act (requires federal regulators to consider whether proposed regulations are duplicative or inconsistent with existing regulations) (all sections) (House)
H.R. 2673 Portfolio Lending and Mortgage Access Act (any residential mortgage held in portfolio by the originator is a Qualified Mortgage) (all sections) (House)
Client expense: $50,000 · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities -
Mortgage lending reforms - imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, differences between non-traditional versus predatory lending practices, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirementsprepayment penalties, originator compensation, limited credit availability
Including, Qualified Mortgage (QM) status from the CFPBs Ability-to-Repay rules for loans originated and held in portfolio by community banks, balloon mortgages regardless of pricing, use of rural and underserved designations for QM eligibility for community banks and greatly expanding the definition of each, annual loan origination and asset threshold limits for small creditors, small servicer exemption for loans held in portfolio, community banks exemption from escrow requirements for loans held in portfolio and for small dollar amount loans, proposed adoption of the QM definition for Qualified Residential Mortgages (QRM) that would not require a high down-payment requirement (House and Senate)
Housing Finance (GSE Secondary Market) Reform - Fannie Mae/Freddie Mac/FHFA unsustainable long-term conservatorship, community bank access to an impartial secondary market for residential loans, financial stable and reliable, government tie to secondary market (continued flow of credit and market liquidity), aggressive repurchase requests of transferred residential mortgages for technical violations
Including, selling loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market, pricing of any governmental guaranties, fairness and equality to all participants regardless of volume of loans guaranteed, and further consolidation of housing finance system that would result in several mega banks and financial firms dominating the market (House and Senate)
Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (House and Senate)
Remaining Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Including, ensure the Consumer Financial Protection Bureau (CFPB) focuses on large banks, financial firms and shadow financial companies, holding the mega banks and financial firms up to the same high standards for compliance with consumer laws as required and attained by community banks, governance (single Director versus five member commission), prudential regulators participation with CFPB in the rule writing process, FSOC veto of CFPB rules, CFPB exemption authority regarding community banks, revision in the definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules, consistent and transparent standards in the evaluation of community bank fair lending standards, disparate impact and unintentional discrimination (House and Senate)
*****
S. 635 Privacy Act Notice Modernization Act of 2013 (redundant privacy notice regulatory relief) (all sections) (Senate)
H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House)CBAI Comment Letters -
Comment Letter CFPB Advanced Notice of Proposed Rulemaking, Debt Collection (Regulation F), Docket No. CFPB-2013-0033-0001, RIN 3170-AA41
Comment Letter FHFA Fannie Mae and Freddie Mac Loan Purchase Limits: Request for Public Input on Implementation Issues No. 2013-N-18
CBAI Action Alerts
H.R. 4521 Community Institution Mortgage Relief Act (exempt community bank portfolio loans from new escrow requirements and raise the small services exemption) (all sections) (House)
H.R. 4466 Financial Regulatory Clarity Act (requires federal regulators to consider whether proposed regulations are duplicative or inconsistent with existing regulations) (all sections) (House)
H.R. 2673 Portfolio Lending and Mortgage Access Act (any residential mortgage held in portfolio by the originator is a Qualified Mortgage) (all sections) (House)
Client expense: $50,000 · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
Community Bankers Association of Illinois (CBAI) 2014 Federal Policy Priorities -
Downsize too-big-to-fail banks and financial firms to protect our financial system, economy, and American Taxpayers from future bailouts - downsize (restructure) too-big-to-fail (TBTF) banks and financial firms, reduce the probability and severity of future financial crisis and taxpayer bailouts, moral hazard, numerous TBTF misdeeds (abuse, fraud, manipulation and scandal),too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, Department of Justices reluctance to prosecute TBTFs versus community banks, and Government Accountability Offices (GAO) confirmation of TBTFs funding advantages (House and Senate)
Tiered regulation supervision and exemptions for community banks - recognition of the different business model and risks posed by TBTF banks and financial firms, one size fits all legislation and regulation, separate regulation - supervision - capital - liquidity requirements, disproportionate burden on community banks, unlevel playing field, and significant community bank competitive disadvantages
Including, the qualifying threshold under the Federal Reserves Small Bank Holding Company Policy Statement from $500 million to $5 billion and allowing small savings and loan holding companies to be covered by the Policy Statement, the internal control attestation requirements of Section 404(b) of the Sarbanes Oxley Act from $75 million in market capitalization to $350 million, and savings and loan holding companies being able to take advantage of the increased Securities and Exchange Commission (SEC) shareholder registration and deregistration thresholds under the JOBS Act (House and Senate)
Community bank regulatory relief as contained in the Independent Community Bankers of America Plan for Prosperity
Including, community bank exemption from certain mortgage reforms to support the housing recovery, redundant annual privacy notices, municipal advisor registration burdens to help serve local governments, Assistant Treasury Secretary for Community Banks, CFPBs more balanced regulations, improved accountability in bank exams with a workable appeals process, accounting and auditing expenses for publicly traded institutions, mutual bank new charter and dividend rules, rigorous and quantitative justification of new rules, additional capital for small bank holding companies, red tape in small-business lending, capital formation and reforming Subchapter S corporation regulations, and extending the net-operating-loss carry-back (House and Senate)
Enhanced security for consumer data (data breaches) - responsible parties responsibility for fraud losses and the cost of mitigation, sharing of information, and a national standard for notification, community banks bearing the majority of fraud losses and reissuance costs, retailers responsibility to protect sensitive customer data (House and Senate)
Expanded powers for tax-exempt credit unions - outdated original business model and straying from founding purpose, federal tax-exemption status, expansion of powers, level the playing field between community banks and credit unions, regulatory requirements including the Community Reinvestment Act (CRA)
Including, expanded lending powers by increasing percentage of asset cap on business lending, and raising capital from outside investors (House and Senate)
Expansion of the Farm Credit System - funding & tax advantages, expansionist agenda, competitive advantages over rural community banks, regulatory safeguards and controls, Co-Banks $725 million participation in commitment to Verizon Communications (House and Senate)
Mortgage lending reforms - imprudent lending practices, impacting responsible lenders and loan products, meeting the diverse needs of community bank customers and their communities, differences between non-traditional versus predatory lending practices, exemption of community bank mortgage loans held in portfolio, restrictions on balloon mortgages and escrow requirements, prepayment penalties, originator compensation, limited credit availability
Including, Qualified Mortgage (QM) status from the CFPBs Ability-to-Repay rules for loans originated and held in portfolio by community banks, balloon mortgages regardless of pricing, use of rural and underserved designations for QM eligibility for community banks and greatly expanding the definition of each, annual loan origination and asset threshold limits for small creditors, small servicer exemption for loans held in portfolio, community banks exemption from escrow requirements for loans held in portfolio and for small dollar amount loans, proposed adoption of the QM definition for Qualified Residential Mortgages (QRM) that would not require a high down-payment requirement (House and Senate)Housing Finance (GSE Secondary Market) Reform - Fannie Mae/Freddie Mac/FHFA unsustainable long-term conservatorship, community bank access to an impartial secondary market for residential mortgage loans, financial stable and reliable, government tie to secondary market (continued flow of credit and market liquidity), aggressive repurchase requests of transferred residential mortgages for technical violations
Including, selling loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market, pricing of any governmental guaranties, fairness and equality to all participants regardless of volume of loans guaranteed, and further consolidation of housing finance system that would result in several mega banks and financial firms dominating the market (House and Senate)
Tax, accounting and auditing changes - community bank focus supporting robust economic activity, savings & investments, accommodation/exemption for community banks, undue regulatory burden or cost on community banks
Including, tax reform that preserves the pass-through option, including the Subchapter S corporation and the ability of business borrowers to deduct interest, taxation of capital gains and dividends held in parity and at a preferential rate, tax-exempt status of interest paid on municipal bonds together with an increase in the Bank Qualified (BQ) annual threshold to $30 million and indexed for inflation, the ability of business and mortgage borrowers to deduct interest without further limitations must also be preserved, changes to the tax laws that disadvantage one form of corporate entity versus another should include a phase-in period and an amnesty to allow for a penalty-free corporate conversion, S corporation banks ability to raise capital to be enhanced by giving them the ability to issue preferred stock, increasing their shareholder limits and allowing new IRA shareholder investments, end to the tax subsidies for credit unions and the FCS lenders, community banks amortizing CRE losses over 10 years (versus in the year in which they are taken), capital standards that recognize the loss-absorbing abilities of the entire amount of the Allowance for Loan and Lease Losses (ALLL), the 1.25% ALLL disallowance (for regulatory capital purposes) should be eliminated which would encourage banks to reserve more and would strengthen capital positions, the work of the Financial Accounting Foundations Private Company Council to seek recognition, measurement and disclosure alternatives for small private companies including non-public community banks.
Including, Financial Accounting Standard Boards (FASB) proposed expected loss model requiring community banks to develop costly complex cash flow models for loans and investment securities to generate expected losses over the lives of these assets where implementing this proposal will be to frontload loss recognition which would harm both community bank earnings and capital, FASBs proposal to restrict the ability of community banks to classify mortgage loans and investment securities at amortized cost when their intent is to collect contractual cash flows which is based on the exit price of a loan or security and on the current value in a non-distressed market and which would require costly robust pricing engines and complex valuation methodologies to satisfy the standard, FASBs proposal to require extensive liquidity risk and interest rate risk footnote disclosures that would be required to be audited which would undermine the work of the prudential regulators whose job entails assessing the safety and soundness of community banks including an assessment of liquidity and interest rate risk, and new bank specific fees or punitive tax levies specifically targeting the financial service sector (House and Senate)
Remaining Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Including, rein in Significantly Important Financial Institution (SIFI) with enhanced prudential standards and rigorous focused regulation, higher capital requirements, capital surcharges, concentration limits, liquidity requirements, orderly liquidation rules, credible contingency resolution plan, shielding community banks from the Dodd-Frank required increase in the deposit insurance fund reserve ratio from 1.15% to 1.35%, Volcker Rules prohibition on propriety trading and investment in and sponsorship of hedge funds and private equity funds, effectively exempting community banks
Including, ensure the Consumer Financial Protection Bureau (CFPB) focuses on large banks, financial firms and shadow financial companies, holding the mega banks and financial firms up to the same high standards for compliance with consumer laws as required and attained by community banks, governance (single Director versus five member commission), prudential regulators participation with CFPB in the rule writing process, FSOC veto of CFPB rules, CFPB exemption authority regardingcommunity banks, revision in the definitions of rural and underserved areas in the Ability to Repays Qualified Mortgage (QM) rules, consistent and transparent standards in the evaluation of community bank fair lending standards, disparate impact and unintentional discrimination (House and Senate)
De novo community bank formation - need to maintain growing, vibrant & evolving banking profession, Federal Deposit Insurance Corporations (FDIC) actively inhibiting de novo community bank formation, inappropriate and restrictive one-size-fits-all supervisory policy (House and Senate)
Maintain the Federal Home Loan Bank (FHLB)System - strong partnership with community banks, healthy, stable & reliable source of funding for community banks, FHLBs should not be the sole aggregators for residential mortgages for community banks in the reform of the housing GSEs, preservation of the FHLBs special functions and purposes (House and Senate)
Excessive (Federal Reserve) intervention in monetary policy - significant drag on community banks net interest margins and earnings, limits on what monetary policy can accomplish, impact on community banks, savers and senior citizens (House and Senate)
*****
S. 798 Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (Senate)
S. 635 Privacy Act Notice Modernization Act of 2013 (redundant privacy notice regulatory relief) (all sections) (Senate)
H.R. 1750 CLEAR Relief Act of 2013 (community lending enhancement and regulatory relief) (all sections) (House)
CBAI Comment Letters -
Comment Letter CFPB Advanced Notice of Proposed Rulemaking, Debt Collection (Regulation F), Docket No. CFPB-2013-0033-0001, RIN 3170-AA41
Comment Letter FHFA Fannie Mae and Freddie Mac Loan Purchase Limits: Request for Public Input on Implementation Issues No. 2013-N-18
Comment Letter Federal Reserve Bank of Chicago, Federal Deposit Insurance Corporation (Chicago Regional Office), and Illinois Department of financial and Professional Regulation (IDFPR) Regarding TruPS and Consent Order Dividend Restrictions
CBAI Action Alerts
H.R. 4521 Community Institution Mortgage Relief Act (exempt community bank portfolio loans from new escrow requirements and raise the small services exemption) (all sections) (House)
H.R. 4466 Financial Regulatory Clarity Act (requires federal regulators to consider whether proposed regulations are duplicative or inconsistent with existing regulations) (all sections) (House)
H.R. 2673 Portfolio Lending and Mortgage Access Act (any residential mortgage held in portfolio by the originator is a Qualified Mortgage) (all sections) (House)
Client expense: $50,000 · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), White House Office
Cited source text, amounts, lobbyists, and targets
HR 688 Credit Union Small Business Job Creation Act of 2013
HR 719 Capital Access for Small Businesses and Jobs Act
HR 749 Eliminate Privacy Notice Confusion Act
HR 797 Municipal Adviser Oversight Improvement Act of 2013HR 801 The Holding Company Restriction Threshold Equalization Act
HR 892 The S Corporation Modernization Act
HR 1062 SEC Regulatory Accountability Act
HR 1603 The Mutual Community Bank Competitive Equality Act
HR 1750 The Community Lending Enhancement and Regulatory Relief Act
HR 2199 Flood Insurance
HR 2402 The Consumer Financial Protection Commission Act
HR 2446 The Responsible Consumer Financial Protection Regulations Act
HR 2542 The Regulatory Flexibility Improvements Act of 2013
HR 2672 The CFPB Rural Designation Petition and Correction Act
HR 2673 The Portfolio Lending and Mortgage Access Act of 2013
HR 2767 The Protecting American Taxpayers Homeowners Act
HR 3193 The Consumer Financial Protection Safety and Soundness Improvement Act
HR 3370 Homeowner Flood Insurance Affordability Act of 2014
HR 3696 The National Cybersecurity and Critical Infrastructure Protection Act
HR 3819 Fairness for Community Job Creators Act
HR 4167 Restoring Proven Financing for American Employers Act
S 635 Privacy Notice Modernization Act
S 710 Municipal Adviser Relief Act
S 727 The Financial Institutions Examination Fairness and Reform Act
S 996 Flood Insurance
S 1217 Housing Finance Reform and Taxpayer Protection
S 1349 The Community Lending Enhancement and Regulatory Relief Act
S 1907 Fairness for Community Job Creators Act
S 1916 HELP Rural Communities Act of 2014
S 1927 Data Secuity Act of 2014
Bank Examinations
Call Report Changes
Capital Requirements/Regulations/Basel III Rules
CFPB Reforms
Credit Union Business Lending Powers
Credit Union Tax Exemption
Cybersecurity
Data Security and Breaches
DeNovo Bank Applications
Federal Reserve Vacancy
FHA Loan Programs
Flood Insurance Reform Implementation of Bigger-Waters Act
GAO Study of Too Big To Fail
GSE Conforming Loan Limits
Housing Finance Reform
Housing Government Sponsored Enterprises
Mortgage Escrow Requirements
Mortgage Lending Reform
Mortgage Loan Origination Standards
Mortgage Servicing Standards
National Flood Insurance Program Reauthorization
Nomination of Janet Yellen as Chairman, Federal Reserve Board
Patent Litigation Reform
Postal Reform-provision of banking services
Qualified Mortgages, Ability to Repay Rules
Qualified Residential Mortgages/Risk Retention
Regulation Z Establishment of Escrow - Higher Priced LoansRegulatory and Tax Relief for Community Banks
Systemic Risk Regulation
Volcker Rule Treatment of CDO and CLO Investments
Client expense: $990,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), White House Office
Cited source text, amounts, lobbyists, and targets
See AddendumS.474, the Swaps Regulatory Improvement Act (all provisions)
S. 635, the Privacy Notice Modernization Act of 2013 (all provisions)
S. 710, the Municipal Advisors Relief Act of 2013 (all provisions to exempt commercial banks and savings and loan associations from the Dodd-Frank Act provisions requiring regulation of municipal advisors)
S. 731, the Basel III CASE Act (all provisions)
S. 737, the Basel III Impact Study Act (all provisions)
S. 798, the Terminating Bailouts for Taxpayer Fairness Act of 2013 (all provisions)
S. 872, the Holding Company Registration Threshold Equalization Act of 2013 (provisions to extend to savings and loan holding companies the new SEC shareholder registration and deregistration thresholds under the JOBS Act)
S. 968, the Small Business Lending Enhancement Act of 2013 (all provisions to increase credit union business lending limits)
H.R. 613, the Systemic Risk Mitigation Act (all provisions)
H.R. 634, Business Risk Mitigation and Price Stabilization Act of 2013 (provisions to clarify that end users would not be subject to margin requirements for un-cleared swaps)
H.R. 677, the Inter-Affiliate Swap Clarification Act (all provisions
H.R. 701, to amend a provision of the Securities Act of 1933 directing the Securities and Exchange Commission to add a particular class of securities to those exempted under such Act to provide a deadline for such action
H.R. 742, the Swap Data Repository and Clearinghouse Indemnification Correction Act
H.R. 749, the Eliminate Privacy Notice Confusion Act (all provisions)
H.R.797 , the Municipal Advisor Oversight Improvement Act of 2013
H.R. 801, the Holding Company Registration Threshold Equalization Act of 2013 (all provisions)
H.R. 992, the Swaps Regulatory Improvement Act (all provisions)
H.R. 1003, to provide for a full assessment of the costs and benefits of Commodity Futures Trading Commission (CFTC) regulations
H.R. 1062, the SEC Regulatory Accountability Act (all provisions to require the SEC to do a thorough cost-benefit analysis before proposing a new regulation)
H.R. 1256, the Swap Jurisdiction Certainty Act
H.R. 1341, the Financial Competitive Act of 2013 (all provisions)
H.R. 701, to amend a provision of the Securities Act of 1933 directing the Securities and Exchange Commission to add a particular class of securities to those exempted under such Act to provide a deadline for such action
H.R. 742, the Swap Data Repository and Clearinghouse Indemnification Correction ActH.R. 749, the Eliminate Privacy Notice Confusion Act (all provisions)
H.R.797 , the Municipal Advisor Oversight Improvement Act of 2013
H.R. 801, the Holding Company Registration Threshold Equalization Act of 2013 (all provisions)
H.R. 992, the Swaps Regulatory Improvement Act (all provisions)
H.R. 1003, to provide for a full assessment of the costs and benefits of Commodity Futures Trading Commission (CFTC) regulations
H.R. 1062, the SEC Regulatory Accountability Act (all provisions to require the SEC to do a thorough cost-benefit analysis before proposing a new regulation)
H.R. 1256, the Swap Jurisdiction Certainty Act
H.R. 1341, the Financial Competitive Act of 2013 (all provisions)
H.R. 1553, the Financial Institutions Examination Fairness and Reform Act (all provisions)
H.R. 1750, the Community Lending Enhancement and Regulatory Relief Act
H.R. 2672, the CFPB Rural Designation Petition and Correction Act
H.R. 3584, to amend the Federal Home Loan Bank Act to authorize privately insured credit unions to become members of a Federal home loan bank, and for other purposes
H.R. 3329, to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes.
Draft Senate legislation to exempt commercial banks from municipal advisor regulation
Discussion Draft of the Swap Jurisdiction
Certainty Act (all provisions)
Draft legislation that would require the Treasury Department to determine which commercial banks, investment banks, hedge funds, and insurance companies are too-big-to-fail, and to break up those institutions within one year.
Clarity in Regulations Discussion Draft
H.Res. 496: Recognizing the importance of savings to financial security.
H.R. 4252: Mutual Bank Choice and Continuity Act of 2014
S. 1927: Data Security Act of 2014
S. 2114: Bond Transparency Act of 2014
Client expense: $1,730,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
S. 798 - Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (House and Senate)
H.R. 1750 - CLEAR Act (community lending enhancement and regulatory relief) (all sections) (House and Senate)
S. 1349 - CLEAR Act (community lending enhancement and regulatory relief) (all sections) (House and Senate)S. 635 Privacy Notice Modernization Act (redundant privacy notices) (all sections) (House and Senate)
H.R. 1553 Financial Institution Examination Fairness and Reform Act (amends FFIEC Act, examination standards/deadlines, FFIEC Office of Examination Ombudsman to appeal examination findings, right to appeal before independent administrative law judge ) (all sections) (House and Senate)
S. 727 Financial Institution Fairness Reform Act (amends FFIEC Act, examination standards/deadlines, FFIEC Office of Examination Ombudsman to appeal examination findings, right to appeal before independent administrative law judge ) (all sections) (House and Senate)
S. 872 Holding Company Registration Act (thrift holding companies and SEC registration and deregistration thresholds) (all sections) (House and Senate)
H.R. 797 Municipal Advisory Oversight improvement Act (exempts traditional banking activities from registration requirements) (all sections) (House and Senate)
S. 710 Municipal Advisor Relief Act of 2013 (exempts traditional banking activities from registration requirements) (all sections) (House and Senate)
Credit unions tax exemption and expansion of powers, level the playing field between community banks and credit unions (House and Senate)
H.R. 688 Credit Union Small Business Job Creation Act (credit union member business lending cap) (all sections) (House and Senate)
S. 968 Small Business Lending Enhancement Act of 2013 (credit union member business lending cap) (all sections) (House and Senate)
H.R. 719 Capital Access for Small Business and Jobs Act (credit union capital) (all sections) (House and Senate)
Consumer Data Security (data breaches), banking standards for confidential personal information, allocating financial responsibility for fraud losses and reissuance costs, single national standard for consumer notifications (House and Senate)
Definitions of rural and underserved areas in the Ability to Repay Qualified Mortgage (QM) Rules (House and Senate)
Comment letter Federal Housing Finance Agency - Fannie Mae and Freddie Mac Loan Purchase Limits: Request for Public Input on Implementation Issues No. 2013-N-18 (FHFA conforming loan limits for the Chicago Metropolitan Statistical Area (MSA)) (House and Senate, FHFA)
Expansion of the Farm Credit Administrations Farm Credit System (House and Senate)
CoBank participation in a loan to Verizon Communications. (House and Senate)
Municipal Bond tax exemption, Bank Qualified (BQ) small issuer exemption threshold/index for inflation (House and Senate)
Principals of housing finance reform including: equal and direct access on a loan by loan basis, financial strength and reliability and liquidity, loan pricing on equal terms, no appropriation of customer information, originators option to retain servicing, limited purpose and activity, private capital to protect taxpayers, FHLBs as an access point for community banks, consolidation of the housing finance system (House and Senate)
H.R. 2642 - Agricultural Act of 2014 (five year farm bill, expanded crop insurance and revenue- and price-triggered supports) (Senate)Community bank experience on the Federal Reserve Board (Senate)
Fair Lending disparate impact (House)
Comment Letter Consumer Financial Protection Bureau Advanced Notice of Proposed Rulemaking, Debt Collection (Regulation F), Docket No. CFPB-2013-0033-0001, RIN 3170-AA41 (new debt collection rules) (CFPB)
Comment Letter Consumer Financial Protection Bureau, Federal Reserve Board, Office of Comptroller of the Currency, Federal Deposit Insurance Corporation, National Credit Union Administration, Securities and Exchange Commission Proposed Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies (Dodd-Frank diversity regulations) (CFPB, Fed Reserve Board, OCC, FDIC, NCUA, SEC)
Client expense: $50,000 · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
S. 798 - Terminating Bailouts for Taxpayers Fairness Act of 2013 (capital requirements, Basel III, and community bank regulatory relief) (all sections) (House and Senate)
H.R. 1750 - CLEAR Act (community lending enhancement and regulatory relief) (all sections) (House and Senate)
S. 1349 - CLEAR Act (community lending enhancement and regulatory relief) (all sections) (House and Senate)S. 635 Privacy Notice Modernization Act (redundant privacy notices) (all sections) (House and Senate)
H.R. 1553 Financial Institution Examination Fairness and Reform Act (amends FFIEC Act, examination standards/deadlines, FFIEC Office of Examination Ombudsman to appeal examination findings, right to appeal before independent administrative law judge ) (all sections) (House and Senate)
S. 727 Financial Institution Fairness Reform Act (amends FFIEC Act, examination standards/deadlines, FFIEC Office of Examination Ombudsman to appeal examination findings, right to appeal before independent administrative law judge ) (all sections) (House and Senate)
S. 872 Holding Company Registration Act (thrift holding companies and SEC registration and deregistration thresholds) (all sections) (House and Senate)
H.R. 797 Municipal Advisory Oversight improvement Act (exempts traditional banking activities from registration requirements) (all sections) (House and Senate)
S. 710 Municipal Advisor Relief Act of 2013 (exempts traditional banking activities from registration requirements) (all sections) (House and Senate)
Credit unions tax exemption and expansion of powers, level the playing field between community banks and credit unions (House and Senate)
H.R. 688 Credit Union Small Business Job Creation Act (credit union member business lending cap) (all sections) (House and Senate)
S. 968 Small Business Lending Enhancement Act of 2013 (credit union member business lending cap) (all sections) (House and Senate)
H.R. 719 Capital Access for Small Business and Jobs Act (credit union capital) (all sections) (House and Senate)
Consumer Data Security (data breaches), banking standards for confidential personal information, allocating financial responsibility for fraud losses and reissuance costs, single national standard for consumer notifications (House and Senate)
Definitions of rural and underserved areas in the Ability to Repay Qualified Mortgage (QM) Rules (House and Senate)
Comment letter Federal Housing Finance Agency - Fannie Mae and Freddie Mac Loan Purchase Limits: Request for Public Input on Implementation Issues No. 2013-N-18 (FHFA conforming loan limits for the Chicago Metropolitan Statistical Area (MSA)) (House and Senate, FHFA)
Expansion of the Farm Credit Administrations Farm Credit System (House and Senate)
CoBank participation in a loan to Verizon Communications. (House and Senate)
Municipal Bond tax exemption, Bank Qualified (BQ) small issuer exemption threshold/index for inflation (House and Senate)
Principals of housing finance reform including: equal and direct access on a loan by loan basis, financial strength and reliability and liquidity, loan pricing on equal terms, no appropriation of customer information, originators option to retain servicing, limited purpose and activity, private capital to protect taxpayers, FHLBs as an access point for community banks, consolidation of the housing finance system (House and Senate)
H.R. 2642 - Agricultural Act of 2014 (five year farm bill, expanded crop insurance and revenue- and price-triggered supports) (Senate)Community bank experience on the Federal Reserve Board (Senate)
Fair Lending disparate impact (House)
Comment Letter Consumer Financial Protection Bureau Advanced Notice of Proposed Rulemaking, Debt Collection (Regulation F), Docket No. CFPB-2013-0033-0001, RIN 3170-AA41 (new debt collection rules) (CFPB)
Comment Letter Consumer Financial Protection Bureau, Federal Reserve Board, Office of Comptroller of the Currency, Federal Deposit Insurance Corporation, National Credit Union Administration, Securities and Exchange Commission Proposed Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies (Dodd-Frank diversity regulations) (CFPB, Fed Reserve Board, OCC, FDIC, NCUA, SEC)
Client expense: $50,000 · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), White House Office
Cited source text, amounts, lobbyists, and targets
HR 688 Credit Union Small Business Job Creation Act of 2013
HR 719 Capital Access for Small Businesses and Jobs Act
HR 749 Eliminate Privacy Notice Confusion Act
HR 797 Municipal Adviser Oversight Improvement Act of 2013HR 801 The Holding Company Restriction Threshold Equalization Act
HR 892 The S Corporation Modernization Act
HR 1062 SEC Regulatory Accountability Act
HR 1603 The Mutual Community Bank Competitive Equality Act
HR 1750 The Community Lending Enhancement and Regulatory Relief Act
HR 2199 Flood Insurance
HR 2402 The Consumer Financial Protection Commission Act
HR 2446 The Responsible Consumer Financial Protection Regulations Act
HR 2542 The Regulatory Flexibility Improvements Act of 2013
HR 2672 The CFPB Rural Designation Petition and Correction Act
HR 2673 The Portfolio Lending and Mortgage Access Act of 2013
HR 2767 The Protecting American Taxpayers Homeowners Act
HR 3193 The Consumer Financial Protection Safety and Soundness Improvement Act
HR 3370 Homeowner Flood Insurance Affordability Act of 2014
HR 3696 The National Cybersecurity and Critical Infrastructure Protection Act
HR 4167 Restoring Proven Financing for American Employers Act
S 635 Privacy Notice Modernization Act
S 710 Municipal Adviser Relief Act
S 727 The Financial Institutions Examination Fairness and Reform Act
S 996 Flood Insurance
S 1217 Housing Finance Reform and Taxpayer Protection
S 1349 The Community Lending Enhancement and Regulatory Relief Act
S 1907 Fairness for Community Job Creators Act
S 1916 HELP Rural Communities Act of 2014
S 1927 Data Secuity Act of 2014
Bank Examinations
Capital Requirements/Regulations/Basel III Rules
CFPB Reforms
Credit Union Business Lending Powers
Credit Union Tax Exemption
Cybersecurity
Data Security and Breaches
DeNovo Bank Applications
FHA Loan Programs
Flood Insurance Reform Implementation of Bigger-Waters Act
GAO Study of Too Big To Fail
GSE Conforming Loan Limits
Housing Finance Reform
Housing Government Sponsored Enterprises
Mortgage Escrow Requirements
Mortgage Lending Reform
Mortgage Loan Origination Standards
Mortgage Servicing Standards
National Flood Insurance Program Reauthorization
Nomination of Janet Yellen as Chairman, Federal Reserve Board
Patent Litigation Reform
Qualified Mortgages, Ability to Repay Rules
Qualified Residential Mortgages/Risk Retention
Regulation Z Establishment of Escrow - Higher Priced Loans
Regulatory and Tax Relief for Community Banks
Volcker Rule Treatment of CDO and CLO Investments
Client expense: $990,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), White House Office
Cited source text, amounts, lobbyists, and targets
Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to debit card interchange fees.
Issues relating to mobile payments.
H.R.1750, CLEAR Relief Act of 2013, provisions relating to international ACH transactions.
Issues relating to anti-money laundering and the Bank Secrecy Act generally.Issues relating to cyber-security.
Client expense: Not reported · Firm income: $22,500
Cited source text, amounts, lobbyists, and targets
Please see addendum.Issues related to credit union operations
Issues related to credit union field of membership
Issues related to credit union service organizations
Issues related to vacancies on the National Credit Union Administration (NCUA) Board
Issues related to NCUAs proposed rule on credit union service organizations
Issues related to NCUAs rule on net worth and bargain purchase agreements
Issues related to NCUAs low income designation regulations
Issues related to NCUA examination procedures
Issues related to NCUAs proposed rule regarding loan participations
Issues related to NCUAs regulation regarding its regulatory flexibility program
Issues related to NCUAs proposed rule regarding emergency liquidity
Issues related to material loss reports of the NCUA Office of Inspector General
Issues related to the authority of the CFPB to exempt credit unions from its rulemaking
Issues related to the CFPB proposal related to remittances and international wire transfers
Issues related to the proposed CFPB form on RESPA/TILA
Issues related to overdraft protection and check ordering practices
Issues related to mortgage servicing
Issues related to mortgage loan originator compensation and qualifications
Issues related to high-cost mortgage loans (HOEPA)
Issues related to the CFPBs proposed rule regarding qualified mortgage / ability to repay
Issues related to reverse mortgages
Issues related to the Financial Accounting Standards Board (FASB)
Issues related to mark-to-market accounting
Issues related to private equity standards
Issues related to the implementation of the Unlawful Internet Gambling Prohibition Act
Issues related to data and cyber security
Issues related to mobile banking and mobile payments
Issues related to the oversight of the Federal Housing Administration
Issues related to USDA Rural Development Loan program
Issues related to identity theft and fraud reduction
Issues related to student lending
Issues related to derivatives and NCUAs proposed rule related to credit union use of derivatives
Issues related to the Federal Home Loan Bank System
Issues related to short term lending products and advance deposit products
Issues related to patent reform
Issues related to Federal Credit Union bylaws
Issues related to NCUAs Minority Depository Institution program
Issues relating to home-based credit unions
Issues related to NCUAs Appraisal Management Company proposal
Issues related to NCUAs risk-based capital proposal
Issues related to the Johnson-Crapo Housing Finance Reform proposal
H.R. 450, Bureau of Consumer Financial Protection Accountability Act, all provisions
H.R. 688, Credit Union Small Business Jobs Creation Act of 2013, all provisions
H.R. 719, Capital Access for Small Businesses and Jobs Act of 2013, all provisions
H.R. 736, Responsible Homeowner Refinancing Act of 2013, all provisions
H.R. 749, Eliminate Privacy Notice Confusion Act of 2013, all provisions
H.R. 801, Holding Company Registration Threshold Equalization Act of 2013, all provisions
H.R. 839, Prompt Notification of Short Sale Act, all provisions
H.R. 861, Elder Abuse Victims Act of 2013, all provisions
H.R. 927, Common Sense Economic Recovery Act of 2013, all provisions
H.R. 1077, Consumer Mortgage Choice Act
H.R. 1255, Home Construction Lending Regulatory Improvement Act of 2013, all provisionsH.R. 1261, Overdraft Protection Act of 2013, all provisions
H.R. 1538, a bill to provide incentives to encourage financial institutions and small businesses to provide continuing financial education to customers, borrowers and employees, all provisions
H.R. 1553, Financial Institution Examination Fairness and Reform Act, all provisions
H.R. 1566, a bill to create a Federal Charter for Internet consumer credit corporations, all provisions
H.R. 1603, a bill to support and promote community financial institutions in the mutual form, all provisions
H.R. 1646, a bill to amend the Federal Credit Union Act to provide an exception from the member business loan cap for loans made to aid in the recovery from a disaster, all provisions
H.R. 1694, a bill to allow the Secretary of Treasury to rely on State examinations for certain financial institutions, all provisions
H.R. 1750, the CLEAR Relief Act, all provisions
H.R. 1754, Preserving American Homeownership Act of 2013, all provisions
H.R. 1779, Preserving Access to Manufactured Housing Act of 2013, all provisions
H.R. 1862, Capital Access for Small Community Financial Institutions, all provisions
H.R. 2136, Small Business Credit Availability Act, all provisions
H.R. 2295, Basel III CASE Act, all provisions
H.R. 2379, Qualified Mortgage Loan Originator Transitional Authority Act, all provisions
H.R. 2419, a bill to amend the Truth in Lending Act to provide coverage under such Act for credit cards issued to small businesses, all provisions
H.R. 2512, a bill to amend the Truth in Lending Act to establish clear regulatory standards for mortgage servicers, all provisions
H.R. 2547, a bill to determine appropriate risk based capital requirements for community, mid-size, and regional institutions, all provisions
H.R. 2561, a bill to provide for the removal of default information form a borrowers credit report with respect to certain rehabilitated education loans, all provisions
H.R. 2571, a bill to amend the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act to require the Bureau of Consumer Financial Protection to notify and obtain permission from consumers before collecting nonpublic personal information about such consumers, all provisions
H.R. 2572, a bill to improve the regulation of credit unions and depository institutions and to provide regulatory relief, all provisions
H.R. 2580, a bill to allow homeowners of moderate-value homes who are subject to mortgage foreclosure proceedings to remain in their homes as renters, all provisions
H.R. 2652, Marijuana Businesses Access to Banking Act of 2013
H.R. 2672, CFPB Rural Designation Petition and Correction Act
H.R. 2673, Portfolio Lending and Mortgage Access Act
H.R. 2733, Defending American Taxpayers From Abusive Government Takings Act of 2013
H.R. 2767, Protecting American Taxpayers and Homeowners Act of 2013
H.R. 2816, To extend the pilot program under section 258 of the National Housing Act that establishes an automated process for providing alternative credit rating information for mortgagors and prospective mortgagors under certain mortgages.
H.R. 2917, Financial Security Credit Act of 2013
H.R. 2961, To amend the Truth in Lending Act and the Higher Education Act of 1965 to require additional disclosures and protections for students and cosigners with respect to student loans, and for other purposes.
H.R. 3036, a bill to amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to specify when bank holding companies may be subject to certain enhanced supervision, and for other purposes.
H.R. 3137, Freedom and Mobility in Consumer Banking Act, all provisions
H.R. 3310, Annuity Safety and Security under Reasonable Enforcement Act, all provisions
H.R. 3312, Homeowners Flood Insurance Relief Act, all provisions
H.R. 3317, Holding Individual Accountable and Deterring Money Laundering Act, all provisions
H.R. 3329, a bill to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, all provisions.
H.R. 3370, Homeowner Flood Insurance Affordability Act, all provisions
H.R. 3374, the American Savings Promotion Act, all provisions
H.R. 3468, the Credit Union Share Insurance Parity Act, all provisions
H.R. 3584, a bill to amend the Federal Home Loan Bank Act to authorize privately insured credit unions to become members of a Federal home loan bank, all provisionsH.R. 4226, Credit Union Residential Loan Parity Act, all provisions
Kildee Amendment to H.R. 1960, National Defense Authorization Act, related to disclosures required under the Military Lending Act
S. 113, Know Before You Owe Private Student Loan Act, all provisions
S. 114, Fairness for Struggling Student Act, all provisions
S. 172, Stopping Abuse and Fraud in Electronic (SAFE) Lending Act of 2013, all provisions
S. 187, Deceptive Loan Check Elimination Act, all provisions
S. 205, Responsible Consumer Financial Protection Regulations Act of 2013, all provisions
S. 249, Responsible Homeowner Refinancing Act of 2013, all provisions
S. 361, Prompt Notification of Short Sale Act of 2013, all provisions
S. 450, Financial Regulatory Responsibility Act of 2013, all provisions
S. 451, a bill to make technical corrections to the Dodd-Frank Wall Street Reform and Consumer Protection Act, all provisions
S. 563, Jumpstart GSE Reform Act, all provisions
S. 635, Privacy Notice Modernization Act of 2013, all provisions
S. 673, Protecting Consumers from Unreasonable Credit Rates Act, all provisions
S. 676, Identity Theft and Tax Fraud Prevention Act of 2013, all provisions
S. 727, Financial Institutions Examination Fairness and Reform Act, all provisions
S. 731, Basel III CASE Act, all provisions
S. 733, Basel III Impact Study Act, all provisions
S. 798, Terminating Bailouts for Taxpayer Fairness Act, all provisions
S. 872, Holding Company Registration Threshold Equalization Act, all provisions
S. 947, SAFE Act Confidentiality and Privilege Enhancement Act, all provisions
S. 968, Small Business Lending Enhancement Act, all provisions
S. 985, a bill to repeal certain provisions of the Gramm-Leach-Bliley Act and revive the separation between commercial banking and the securities business, in the manner provided in the Banking Act of 1933, the so-called Glass-Steagall Act, all provisions
S. 996, a bill to improve the National Flood Insurance Program, all provisions
S. 1002, Home Building Lending Improvement Act, all provisions
S. 1048, the Mortgage Finance Act, all provisions
S. 1098, a bill to reform the Biggert-Waters Flood Insurance Reform Act of 2012 to responsibly protect homeownership, all provisions
S. 1176, a bill to impose a fine with respect to international remittance transfers if the sender is unable to verify legal status in the United States, all provisions
S. 1217, Housing Finance Reform and Taxpayer Protection Act, all provisions
S. 1229, a bill to amend the Truth in Lending Act to empower the States to set the maximum annual percentage rates applicable to consumer credit transactions, all provisions
S. 1282, 21st Century Glass-Steagall Act of 2013
S. 1349, a bill to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes.
S. 1534, Freedom and Mobility in Consumer Banking Act, all provisions
S. 1538, FIX Credit Reporting Errors Act, all provisions
S. 1577, Mortgage Choice Act, all provisions
S. 1597, the American Savings Promotion Act, all provisions
S. 1610, Homeowner Flood Insurance Affordability Act, all provisions
S. 1806, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions, all provisions
S. 1867, Prepaid Card Consumer Protection Act of 2013, all provisions
S. Res. 105, a resolution designating April 2013 as Financial Literacy Month
Client expense: $1,200,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of Government Ethics (OGE), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA)
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA)
Cited source text, amounts, lobbyists, and targets
HR 1261 - Overdraft Protection Act of 2013 - Provisions related to caps & limitations on overdraft charges
S 710 - exemption from Dodd-Frank Act provisions - provisions to exempt certain bank employees from being considered municipal advisors for purposes of Dodd-Frank Act regulation.
HR 1750 - Regulatory Relief Act - Provisions related to exemptions from qualified mortgage requirements and privacy noticerequirements.
HR 3317 - Holding Individuals Accountable & Deterring Money Laundering Act - Provisions that would strengthen the Federal statutes designed to deter money laundering and terrorism financing.
HR 3770 Homeowner Flood Insurance Affordability Act - Provisions addressing issues with the affordability of National Flood Insurance program and mapping issues.
S 1720 - Patent reform legislation - Provisions addressing patent reform
S1926 - Combining National Flood Insurance Program reforms with NARAB II - provisions regarding escrow requirements under flood insurance program
S 635 - Privacy Notice Bill - eliminate the need to send GLBA privacy notices if a financial institution has not changed its privacy policy in the last year.
Client expense: $346,600 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
Data Transparency; DATA Act, S 994, HR 2061; Medicaid Integrity Act of 2013, H.R. 162 (audits of Medicaid Managed Care programs). Revisions to the JOBS Act, including mandatory audit firm rotation. Auditor liability; Audit Integrity and Job Protection Act, HR 1564/S 1526; PCAOB Enforcement Transparency Act of 2013, S 848; CLEAR Relief Act of 2013, HR 1750
Client expense: $1,040,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
Financial Services and Community Bank Regulatory Relief, S. 798 Brown Vitter, S. 1349 CLEAR Act, HR 1750 CLEAR Act, CFPB Regulations related to Dodd Frank
Client expense: Not reported · Firm income: $60,000
Cited source text, amounts, lobbyists, and targets
HR 1750: COMMUNITY LENDING ENHANCEMENT AND REGULATORY (CLEAR) RELIEF ACT OF 2013; PROVISIONS RELATED TO SOX 404H RES 359: EXPRESSING THE SENSE OF THE HOUSE OF REPRESENTATIVES THAT TAX REFORM SHOULD JOINTLY ADDRESS CORPORATE AND PASS-THROUGH ENTITIES IN A FISCALLY RESPONSIBLE MANNER, AND THAT REFORM SHOULD REDUCE THE CURRENT TAX RATE DIFFERENCE BETWEEN CORPORATE AND PASS- THROUGH ENTITIES WHILE MAINTAINING ADEQUATE FORMS OF ORGANIZATION FOR BUSINESSES; PROVISIONS RELATED TO PASS-THROUGHS
HR 2629: FOSTERING INNOVATION ACT OF 2013; PROVISIONS RELATED TO SOX 404
S 848: PUBLIC COMPANY ACCOUNTING OVERSIGHT BOARD (PCAOB) ENFORCEMENT TRANSPARENCY ACT OF 2013; PROVISIONS RELATED TO DISCIPLINARY HEARINGS
S 1349: COMMUNITY LENDING ENHANCEMENT AND REGULATORY (CLEAR) RELIEF ACT OF 2013; PROVISIONS RELATED TO SOX 404
Client expense: $190,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
S.474, the Swaps Regulatory Improvement Act (all provisions); S. 635, the Privacy Notice Modernization Act of 2013 (all provisions); S. 710, the Municipal Advisors Relief Act of 2013 (all provisions to exempt commercial banks and savings and loan associations from the Dodd-Frank Act provisions requiring regulation of municipal advisors);S. 731, the Basel III CASE Act (all provisions); S. 737, the Basel III Impact Study Act (all provisions); S. 798, the Terminating Bailouts for Taxpayer Fairness Act of 2013 (all provisions); S. 872, the Holding Company Registration Threshold Equalization Act of 2013 (provisions to extend to savings and loan holding companies the new SEC shareholder registration and deregistration thresholds under the JOBS Act); S. 968, the Small Business Lending Enhancement Act of 2013 (all provisions to increase credit union business lending limits); H.R. 613, the Systemic Risk Mitigation Act (all provisions); H.R. 634, Business Risk Mitigation and Price Stabilization Act of 2013 (provisions to clarify that end users would not be subject to margin requirements for un-cleared swaps); H.R. 677, the Inter-Affiliate Swap Clarification Act (all provisions); H.R. 701, to amend a provision of the Securities Act of 1933 directing the Securities and Exchange Commission to add a particular class of securities to those exempted under such Act to provide a deadline for such action; H.R. 742, the Swap Data Repository and Clearinghouse Indemnification Correction Act; H.R. 749, the Eliminate Privacy Notice Confusion Act (all provisions); H.R.797 , the Municipal Advisor Oversight Improvement Act of 2013; H.R. 801, the Holding Company Registration Threshold Equalization Act of 2013 (all provisions); H.R. 992, the Swaps Regulatory Improvement Act (all provisions); H.R. 1003, to provide for a full assessment of the costs and benefits of Commodity Futures Trading Commission (CFTC) regulations; H.R. 1062, the SEC Regulatory Accountability Act (all provisions to require the SEC to do a thorough cost-benefit analysis before proposing a new regulation); H.R. 1256, the Swap Jurisdiction Certainty Act; H.R. 1341, the Financial Competitive Act of 2013 (all provisions); H.R. 1553, the Financial Institutions Examination Fairness and Reform Act (all provisions); H.R. 1750, the Community Lending Enhancement and Regulatory Relief Act; H.R. 2672, the CFPB Rural Designation Petition and Correction Act; H.R. 3584, to amend the Federal Home Loan Bank Act to authorize privately insured credit unions to become members of a Federal home loan bank, and for other purposes; H.R. 3329, to enhance the ability of community financial institutions to foster economic growth and serve their communities, boost small businesses, increase individual savings, and for other purposes; Draft Senate legislation to exempt commercial banks from municipal advisor regulation; Discussion Draft of the Swap Jurisdiction
Certainty Act (all provisions); Draft legislation that would require the Treasury Department to determine which commercial banks, investment banks, hedge funds, and insurance companies are too-big-to-fail, and to break up those institutions within one year; Clarity in Regulations Discussion Draft.
Client expense: $2,140,000 · Firm income: Not reported