Regulation D Study Act

National Credit Union Administrations risk-based capital proposal; Community Bank Mortgage Servicing Asset Capital Requirements Study Act (H.R. 4042); Exam fairness for credit unions (use of documents of resolution; consistency; independent appeals process); Financial Institutions Examination Fairness and Reform Act (H.R. 1553 / S. 727); Share insurance parity for credit union Interest on Lawyers Trust Accounts (H.R.3468; S. 2699; S. 2698); The CFPBs qualified mortgage/ ability-to-repay rule; CFPBs calculation of points and fees under the qualified mortgage/ ability-to-repay rule; The Mortgage Choice Act (H.R. 3211 / S. 1577); Relief from redundant annual privacy notice requirements; Privacy Notice Modernization Act (S. 635 / H.R. 749); Administrative Improvements for the Powers of the NCUA including allowing a federal credit union to petition NCUA for a waiver of a federal rule in favor of a state rule; providing NCUA authority to delay implementation of CFPB rules; more robust cost-benefit analysis on rule making; examination fairness provisions; improving the Central Liquidity Facility. Capital Reforms for Credit Unions including a properly designed risk-based capital proposal for credit unions; Structural improvements for credit unions including a study of outdated corporate governance provisions in the Federal Credit Union Act and expanding the process for expanding credit unions field of membership; Operational improvements for credit unions including raising the arbitrary member business lending cap; Credit Union Small Business Jobs Creation Act (H.R. 688); Small Business Lending Enhancement Act (S. 968); H.R. 4226 to exclude loans made for non-owner occupied 1 to 4 family dwellings from the definition of member business loan; H.R. 5061 to exempt from the member business lending cap loans made to veterans; allowing credit unions greater investment authority; credit union member business lending; Requirements for credit unions to be members of the Federal Home Loan Bank system; Data security; Federal data security standards for merchants; Data Security Act of 2014 (S.1927); Federal Reserve Regulation D; Regulation D Study Act (H.R. 3240); Credit Union Tax Exemption; Tax reform; Patent reform; Patent reform relative to demand letters; Draft House legislation to address illegitimate patent demand letters; NCUA budget transparency; CFPB exemption authority for credit unions; Financial Stability Oversight Council (FSOC) mandate to coordinate on rule making; SAFE Act Confidentiality and Privilege Enhancement Act (H.R. 4626); American Savings and Promotion Act (H.R. 3374); End Operation Choke Point Act (H.R. 4986); Access to supplemental capital for credit unions; Capital Access for Small Business and Jobs Act (H.R. 719); The CFPB Examination and Reporting Threshold Act (S. 2732); Help Expand Lending Practices in Rural Communities Act (H.R. 2672/ S. 1916); Housing Finance Reform; The PATH Act (H.R. 2767); Housing Finance Reform and Taxpayer Protection Act of 2013 (S. 1217);NCUAs request for comment on the review of its regulations pursuant to the Economic Growth and Regulatory Paperwork Reduction Act - field of membership issues; definition of Rural District; charter conversions; associational common bond; quality assurance review; federal credit union bylaws; fees paid by credit unions; mergers of federal insured credit unions; member business lending waiver process; investment and deposit activities; fixed assets; credit union service organizations. NCUAs proposed rule for asset securitization; NCUAs 2014 mid-year budget review; NCUAs 2014 regulatory review - records preservation program and guidelines; budget transparency; security program; interest rate risk and the risk-based capital proposal; loans in areas having special flood hazards; procedure for debt collection; fair credit reporting; accuracy advertising and notice of insured status; examinations; fixed assets; increased investment authority; Board of Governors of the Federal Reserve Systems notice of regulatory review and request for comments under the Economic Growth and Regulatory Paperwork Reduction Act - availability of funds and collection of checks (Regulation cc); collection of checks and others items by the Federal Reserve Banks and Funds Transfers Through Fedwire (Regulation J); Reserve requirements of depository institutions; reimbursement for providing financial records, recordkeeping for certain financial records; Consumer Financial Protection Bureaus proposed rule with request for comment on two modifications to the Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act and the Truth in Lending Act. CFPBs proposed changes to the collection and reporting requirements under the Home Mortgage Disclosure Act; Department of Defense proposed rule on Limitations on Terms of Consumer Credit Extended to Service Members and Dependents; Military Lending Act; H.R. 4435 - Howard P. Buck McKeon National Defense Authorization Act for Fiscal Year 2015; Defense Department Allotment System; Federal Housing Finance Agencys request for input regarding the proposed single security structure; Federal Housing Finance Agencys request for input regarding Enterprise Housing Goals 2015-2017; FinCEN proposed customer due diligence requirements for financial institutions; Comments on proposed rulemaking regarding loans in areas having special floor hazards; NCUA proposal regarding federal credit union ownership of fixed assets; NACHA / The Electronic Payments Association proposal on compliance and operational topics; Improving the process for credit unions seeking changes to their field of membership; Flexibility for credit unions that offer member business loans; Update to requirement to disclose account numbers to protect the privacy of members under Regulation E; Advertising requirements for loan products and share accounts; Modernization of the NCUAs advertising requirements; Reauthorization of the Terrorism Risk Insurance Act;Federal Reserve Board seat for individual with credit union experience.

Client expense: $520,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

Credit Union Tax Exemption; Patent reform; Patent reform relative to demand letters; Draft House legislation to address illegitimate patent demand letters; National Credit Union Administrations risk-based capital proposal; Stop and study of NCUAs risk-based capital proposal; Providing Opportunities for Savings, Transactions, and Lending Act (H.R. 5179); Community Bank Mortgage Servicing Asset Capital Requirements Study Act (H.R. 4042); Data security breaches; Federal data security standards for merchants;Call on Congress to establish a bipartisan-bicameral data breach working group; Regulatory burden placed on credit unions stemming from the Dodd-Frank Act; Administrative Improvements for the Powers of the NCUA including allowing a federal credit union to petition NCUA for a waiver of a federal rule in favor of a state rule; providing NCUA authority to delay implementation of CFPB rules; more robust cost-benefit analysis on rule making; examination fairness provisions; improving the Central Liquidity Facility. Capital Reforms for Credit Unions including a properly designed risk-based capital proposal for credit unions; Structural improvements for credit unions including a study of outdated corporate governance provisions in the Federal Credit Union Act; and expanding the process for expanding credit union's field of membership. Operational improvements for credit unions including raising the arbitrary member business lending cap; removing requirements that credit unions mail redundant annual privacy notices; allowing credit unions greater investment authority; and providing share insurance coverage on Interest on Lawyers Trust Accounts (IOLTAs). Credit Union Small Business Jobs Creation Act (H.R. 688); Small Business Lending Enhancement Act (S. 968); H.R. 4226 to exclude loans made for non-owner occupied 1 to 4 family dwellings from the definition of member business loan; H.R. 5061 to exempt from the member business lending cap loans made to veterans; Financial Institutions Examination Fairness and Reform Act (S. 727 / H.R. 1553); NCUA budget transparency; CFPB exemption authority for credit unions; Federal Housing Finance Agency (FHFA) proposal relative to Federal Home Loan Bank membership requirements; Financial Stability Oversight Council (FSOC) mandate to coordinate on rule making; SAFE Act Confidentiality and Privilege Enhancement Act (H.R. 4626); American Savings and Promotion Act (H.R. 3374); End Operation Choke Point Act (H.R. 4986); The Regulation D Study Act (H.R. 3240); Appraiser requirements under the Truth in Lending Act; H.R. 3193 requiring certain considerations before issuing regulations; Access to supplemental capital for credit unions; Capital Access for Small Business and Jobs Act (H.R. 719); Privacy Notice Modernization Act (S.635); Eliminate Privacy Notice Confusion Act (H.R. 749); 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. 2699); The RELIEVE Act (S. 2698); The CFPB Examination and Reporting Threshold Act (S. 2732); Updates and modernizations of the NCUA's fixed assets rule; Improving the process for credit unions seeking changes to their field of membership; Increase the number of transfers allowed to be made per month from savings accounts under Federal Reserve Regulation D; Flexibility for credit unions that offer member business loans; Update to requirement to disclose account numbers to protect the privacy of members under Regulation E; Advertising requirements for loan products and share accounts; Modernization of the NCUA's advertising requirements; CFPB's Qualified Mortgage rule; Points and Fees relative to CFPB's Qualified Mortgage rule; Mortgage Choice Act (H.R. 3211/ H.R. 1077 S. 1577); CFPB's consumer complaint database narrative; CFPB's implementation of the new TILA/RESPA integrated mortgage disclosures rule; CFPB's request for information regarding the use of mobile financial services by consumers and its potential for improving the financial lives of economically vulnerable consumers; CFPB's proposed changes to Regulation P regarding annual privacy notices; CFPB's request for comment regarding a correction or cure of debt-to-income ratio overages and the credit extension limit for the small creditor definition; Federal Reserve System's notice of regulatory review and request for comments under the Economic Growth and Regulatory Paperwork Reduction Act - availability of funds and collection of checks; collection of checks and other items by Federal Reserve Banks and funds transfers through Fedwire; Reserve requirements for depository institutions; reimbursement for providing financial records, recordkeeping requirements for certain financial records. FHFA's strategic plan for Fiscal Years 2015-2019; FHFA request for comment on the guarantee fees that Fannie Mae and Freddie Mac charge lenders; FHFA's proposed rule regarding revisions to the membership requirements for the Federal Home Loan Banks; Department of Defense's proposed changes to the regulations implementing the Military Lending Act; NCUA's request for comment on the review of its regulations pursuant to the Economic Growth and Regulatory Paperwork Reduction Act - field of membership issues; definition of "Rural District"; charter conversions; associational common bond; quality assurance review; federal credit union bylaws; fees paid by credit unions; mergers of federal insured credit unions; member business lending waiver process; investment and deposit activities; fixed assets; credit union service organizations. NCUA's proposed rule for asset securitization; NCUA's 2014 mid-year budget review; NCUA's 2014 regulatory review - records preservation program and guidelines; budget transparency; security program; interest rate risk and the risk-based capital proposal; loans in areas having special flood hazards; procedure for debt collection; fair credit reporting; accuracy advertising and notice of insured status; examinations; fixed assets; increased investment authority; Interest on Lawyers Trust Accounts. HELP Rural Communities Act (S. 1916); Help Expand Lending Practices in Rural Communities Act (S. 2672); Housing Finance Reform; The PATH Act (H.R. 2767); Housing Finance Reform and Taxpayer Protection Act of 2013 (S. 1217); 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 (H.R. 5461).

Client expense: $620,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

Credit Union Tax Exemption; Patent reform; Patent reform relative to demand letters; Draft House legislation to address illegitimate patent demand letters; National Credit Union Administrations risk-based capital proposal; Stop and study of NCUAs risk-based capital proposal; Providing Opportunities for Savings, Transactions, and Lending Act (H.R. 5179); Community Bank Mortgage Servicing Asset Capital Requirements Study Act (H.R. 4042); Data security breaches; Federal data security standards for merchants;Call on Congress to establish a bipartisan-bicameral data breach working group; Regulatory burden placed on credit unions stemming from the Dodd-Frank Act; Administrative Improvements for the Powers of the NCUA including allowing a federal credit union to petition NCUA for a waiver of a federal rule in favor of a state rule; providing NCUA authority to delay implementation of CFPB rules; more robust cost-benefit analysis on rule making; examination fairness provisions; improving the Central Liquidity Facility. Capital Reforms for Credit Unions including a properly designed risk-based capital proposal for credit unions; Structural improvements for credit unions including a study of outdated corporate governance provisions in the Federal Credit Union Act; and expanding the process for expanding credit unions field of membership. Operational improvements for credit unions including raising the arbitrary member business lending cap; removing requirements that credit unions mail redundant annual privacy notices; allowing credit unions greater investment authority; and providing share insurance coverage on Interest on Lawyers Trust Accounts (IOLTAs). Credit Union Small Business Jobs Creation Act (H.R. 688); Small Business Lending Enhancement Act (S. 968); H.R. 4226 to exclude loans made for non-owner occupied 1 to 4 family dwellings from the definition of member business loan; H.R. 5061 to exempt from the member business lending cap loans made to veterans; Financial Institutions Examination Fairness and Reform Act (S. 727 / H.R. 1553); NCUA budget transparency; CFPB exemption authority for credit unions; Federal Housing Finance Agency (FHFA) proposal relative to Federal Home Loan Bank membership requirements; Financial Stability Oversight Council (FSOC) mandate to coordinate on rule making; SAFE Act Confidentiality and Privilege Enhancement Act (H.R. 4626); American Savings and Promotion Act (H.R. 3374); End Operation Choke Point Act (H.R. 4986); The Regulation D Study Act (H.R. 3240); Appraiser requirements under the Truth in Lending Act; H.R. 3193 requiring certain considerations before issuing regulations; Access to supplemental capital for credit unions; Capital Access for Small Business and Jobs Act (H.R. 719); Privacy Notice Modernization Act (S.635); Eliminate Privacy Notice Confusion Act (H.R. 749); 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. 2699); The RELIEVE Act (S. 2698); The CFPB Examination and Reporting Threshold Act (S. 2732); Updates and modernizations of the NCUAs fixed assets rule; Improving the process for credit unions seeking changes to their field of membership; Increase the number of transfers allowed to be made per month from savings accounts under Federal Reserve Regulation D; Flexibility for credit unions that offer member business loans; Update to requirement to disclose account numbers to protect the privacy of members under Regulation E; Advertising requirements for loan products and share accounts; Modernization of the NCUAs advertising requirements; CFPBs Qualified Mortgage rule; Points and Fees relative to CFPBs Qualified Mortgage rule; Mortgage Choice Act (H.R. 3211/ H.R. 1077 S. 1577); CFPBs consumer complaint database narrative; CFPBs implementation of the new TILA/RESPA integrated mortgage disclosures rule; CFPBs request for information regarding the use of mobile financial services by consumers and its potential for improving the financial lives of economically vulnerable consumers; CFPBs proposed changes to Regulation P regarding annual privacy notices; CFPBs request for comment regarding a correction or cure of debt-to-income ratio overages and the credit extension limit for the small creditor definition; Federal Reserve Systems notice of regulatory review and request for comments under the Economic Growth and Regulatory Paperwork Reduction Act availability of funds and collection of checks; collection of checks and other items by Federal Reserve Banks and funds transfers through Fedwire; Reserve requirements for depository institutions; reimbursement for providing financial records, recordkeeping requirements for certain financial records. FHFAs strategic plan for Fiscal Years 2015-2019; FHFA request for comment on the guarantee fees that Fannie Mae and Freddie Mac charge lenders; FHFAs proposed rule regarding revisions to the membership requirements for the Federal Home Loan Banks; Department of Defenses proposed changes to the regulations implementing the Military Lending Act; NCUAs request for comment on the review of its regulations pursuant to the Economic Growth and Regulatory Paperwork Reduction Act field of membership issues; definition of Rural District; charter conversions; associational common bond; quality assurance review; federal credit union bylaws; fees paid by credit unions; mergers of federal insured credit unions; member business lending waiver process; investment and deposit activities; fixed assets; credit union service organizations. NCUAs proposed rule for asset securitization; NCUAs 2014 mid-year budget review; NCUAs 2014 regulatory review records preservation program and guidelines; budget transparency; security program; interest rate risk and the risk-based capital proposal; loans in areas having special flood hazards; procedure for debt collection; fair credit reporting; accuracy advertising and notice of insured status; examinations; fixed assets; increased investment authority; Interest on Lawyers Trust Accounts. HELP Rural Communities Act (S. 1916); Help Expand Lending Practices in Rural Communities Act (S. 2672); Housing Finance Reform; The PATH Act (H.R. 2767); Housing Finance Reform and Taxpayer Protection Act of 2013 (S. 1217); 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 (H.R. 5461).

Client expense: $620,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office