Credit Union Small Business Jobs Creation Act

H.R. 766 Financial Institution Customer Protection Act H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1188 Credit Union Small Business Jobs Creation Act H.R. 1195 The Bureau of Consumer Financial Protection Small Business Advisory Board Act H.R. 1210 Portfolio Lending and Mortgage Access Act H.R. 1233 CLEAR Relief Act H.R. 1523 Community Bank Access to Capital Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 1553 Small Bank Exam Cycle Reform Act H.R. 1660 The Federal Savings Association Charter Flexibility Act H.R. 1661 Mutual Bank Capital Opportunity Act H.R. 1766 Right to Lend Act of 2015 H.R. 2205 Data Security Act of 2015 H.R. 3791 A bill to increase Small Bank Holding Policy Statement threshold from $1B to $5B in assets H.R. 4099 CFPB Exam and Reporting Threshold Act H.R. 4116 To amend the Federal Deposit Insurance Act to ensure that reciprocal deposits are not considered to be funds obtained by or through a deposit broker H.R. 4500 The Community Bank Reporting Relief Act H.R. 4909 National Defense Authorization Act of 2017 H.R. 4997 The Home Mortgage Disclosure Adjustment Act H.R. 5076 Main Street Parity Act H.R. 5485 Financial Services and General Government Appropriations Act of 2017 H.R. 5724 The Protecting Consumers Access to Credit Act of 2016 H.R. 5808 EGRPRA Review Frequency H.R. 5983 The Financial CHOICE Act H.R. 6244 To require the appropriate Federal banking agencies to treat certain non-significant investments in the capital of unconsolidated financial institutions as qualifying capital instruments, and for other purposes. S. 812 The CLEAR Relief Act S. 927 CLEAR Relief Plus Act S. 961 Data Security Act of 2015 S. 970 18-Month Exam Cycle S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act S. 1816 Community Bank Access to Capital Act S. 2471 401 (Kids) Education Savings Account Act of 2016 S. 2722 Federal Savings Association Charter Flexibility Act - all provisions S. 2992 Small Business Lending Oversight Act S. 3153 The Tailor Act. S. 3215 To amend the Home Mortgage Disclosure Act of 1975 to specify which depository institutions are subject to the maintenance of records and disclosure requirements of such Act, and for other purposes S. 3373 A bill to amend the Federal Deposit Insurance Act to ensure that the reciprocal deposits of an insured depository institution are not considered to be funds obtained by or through a deposit broker, and for other purposes S. 3404 A bill to amend the Federal Deposit Insurance Act to require the appropriate Federal banking agencies to treat certain municipal obligations as level 2B liquid assets, and for other purposes ADA Website Compliance Call Report Streamlining Capital Access for Community Banks Capital Rules--Basel III CFPB Data Aggregation CFPB Data Collection CFPB Overdraft CFPB Reforms/Governance CFPB Small Business Data Collection CFPB Small Dollar/Payday Lending Community Bank Examination Appeals Credit Union Business Lending Powers Credit Union Field of Membership Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint Durbin Debit Interchange and Routing Amendment EMV Chip Migration Escrow Mortgage Requirements FASB Accounting Rules for Loan Loss Reserves Faster Payments Federal Reserve Reform Fintech Limited Bank Charter Flood Insurance Reform Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Innovation Initiative (FinTech) Interchange Military Bank Leases Military Lending Act Rules Mortgage Lending Reform Mutual Banks Online/Marketplace Lending Qualified Mortgages, Ability to Repay Rules Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Lending Limit Small Bank Holding Company Policy Statement TILA/RESPA Integrated Disclosures Implementation Virtual Currency Wells Fargo Account Opening Fraud

Client expense: $1,000,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Farm Credit Administration, 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), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office

Credit Availability S1484 - The Financial Regulatory Improvement Act of 2015 Fees and Points in the QM ATR Rules of Dodd-Frank HR685 - Mortgage Choice Act of 2015 Student Loan Debt HR970 - Supporting Academic Freedom through Regulatory Relief Act HR1131 - Fairness in Student Loan Lending Act HR1434 - Bank on Students Emergency Loan Refinancing Act HR3179 - Empowering Students Through Enhanced Financial Counseling Act HR3180 - Flexible Pell Grant for 21st Century Students Act HR4162 - Credit Access and Inclusion Act of 2015 HR4652 - CLEAR Act S85 - Repay Act of 2015 S108 - Financial Aid Simplification and Transparency Act of 2015 S729 - Fairness for Struggling Students Act of 2015 S793 - Bank on Students Emergency Loan Refinancing Act S840 - Student Loan Borrower Bill of Rights S1948 - AFFORD Act S2043 - Know Before You Owe Federal Student Loan Act of 2015 S2677 - In the Red Act of 2016 Credit Union Lending HR1188 - Credit Union Small Business Job Creations Act CFPB Reform HR1266 - Financial Product Safety Commission Act of 2015 S510 - CFPB-IG Act of 2015 Access to Manufactured Housing HR650 - Preserving Access to Manufactured Housing Act of 2015 S682 - Preserving Access to Manufactured Housing Act of 2015 GSE Reform HR22 - DRIVE Act HR1491 - Partnership to Strengthen Homeownership Act of 2015 HR2029 - Consolidated Appropriations Act, 2016 HR4913 - Housing Finance Restructuring Act of 2016 HR__ - Moving Housing Forward Act S2038 - Jumpstart GSE Reform Act Guarantee Fees S752 - A bill to establish a scorekeeping rule to ensure that increases in guarantee fees of Fannie Mae and Freddie Mac shall not be used to offset provisions that increase the deficit. HConRes125 - Establishing the congressional budget for the United States Government for fiscal year 2017 and setting forth the appropriate budgetary levels for fiscal years 2018 through 2026. RESPA/TILA Amendments/TRID HR1113 - Portfolio Lending and Mortgage Access Act HR1210 - Portfolio Lending and Mortgage Access Act HR3192 - Homebuyers Assistance Act S1711 - A bill to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. Short Sales HR4812 - Prompt Notification of Short Sales Act Mortgage Servicing Assets HR2029 - Consolidated Appropriations Act, 2016 Alternative Credit Scoring HR3035 - Credit Access and Inclusion Act of 2015 HR4211 - Credit Score Competition Act of 2015 HR4893 - Risk Management and Homeowner Stability Act of 2016 S2355 - Credit Access and Inclusion Act of 2015 Service Members Foreclosure Relief S2393 - Foreclosure Relief and Extension for Servicemembers Act of 2015 Commercial Risk Retention Rules HR4620 - Preserving Access to CRE Capital Act of 2016 FHFA HR3808 - To require the withdrawal and study of the Federal Housing Finance Agency's proposed rule on Federal Home Loan Bank membership, and for other purposes. Financial Regulatory Reform HR1090 - Retail Investor Protection Act HR1523 - Community Bank Access to Capital Act of 2015 HR2642 - Community Lender Regulatory Relief and Consumer Protection Act of 2015 HR5983 - The Financial Choice Act S1484 - Financial Regulatory Improvement Act of 2015 S1491 - Community Lender Regulatory Relief and Consumer Protection Act of 2015 S1816 - Community Bank Access to Capital Act of 2015 Credit Reporting HR347 - The Facilitating Access to Credit Act HR5282 - The Comprehensive Consumer Credit Reporting Act of 2016 Federal Home Loan Bank HR__ - To amend the Federal Home Loan Bank Act to clarify the definition of an insurance company and to provide Federal Home Loan Bank membership standards for certain captive insurance companies Alternative Lending Sources HR4854 - Supporting America's Innovators Act of 2016 HR4855 - Fix Crowdfunding Act Zombie Foreclosures S3146 - Preserving Abandoned Foreclosures and Preserving Communities Act of 2016 Conversations with the Consumer Finance Protection Bureau (CFPB) on TRID, RESPA, TILA, and student loan debt. Discussions with the Federal Housing Finance Agency (FHFA) on GSE reform, duty-to-serve. Discussions with the Treasury on anti-money laundering and GSE reform. Conversations with the Office of the Comptroller of the Currency (OCC) on bank charters. Discussions with the Securities and Exchange Commission (SEC) on crowdfunding, small business lending.

Client expense: $19,540,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Consumer Financial Protection Bureau (CFPB), Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Telecommunications & Information Administration (NTIA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Geological Survey (USGS), Veterans Affairs, Dept of (VA)

S.924/H.R.2287, National Credit Union Administration Budget Transparency Act, all provisions; H.R.1188/S.2028, Credit Union Small Business Jobs Creation Act, all provisions; S.1484, Financial Regulatory Improvement Act of 2015, all provisions; S.961/H.R.2205, Data Security Act of 2015, all provisions; H.R.1770, the Data Security and Breach Notification Act, all provisions; H.R.5485/S.3067, FY2017 Financial Services and General Government Appropriations Act, issues involving CFPB regulatory authority; CFPB regulatory relief for small institutions.

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.924/H.R.2287, National Credit Union Administration Budget Transparency Act, all provisions; H.R.1188/S.2028, Credit Union Small Business Jobs Creation Act, all provisions; S.1484, Financial Regulatory Improvement Act of 2015, all provisions; S.961/H.R.2205, Data Security Act of 2015, all provisions; H.R.1770, the Data Security and Breach Notification Act, all provisions; H.R.5485/S.3067, FY2017 Financial Services and General Government Appropriations Act, issues involving CFPB regulatory authority; CFPB regulatory relief for small institutions.

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, OCC) Too-Big-To-Fail Banks and Financial Firms, Our Financial System, Economy, and American Taxpayers - Future Bailouts Reforming the financial system to reduce the possibility, probability, and severity of a future financial crisis - the perception and reality of too-big-to-fail (TBTF) - taxpayer bailouts of mega banks and financial firms - downsize TBTFs Growth, complexity, and interconnection of the TBTF banks - candidates for future bailouts - falling number of community banks representing less than one-fifth of banking professions assets TBTF banks and the mortgage meltdown and financial crisis - protection from massive financial destruction - taxpayer outrage at TBTFs - violations of the law (often criminal) and billions of dollars in fines, settlements and deferred prosecution agreements (conditional amnesty) TBTF effective management, supervision, discipline, and resolution - multi-trillion dollar financial assistance - rightful failure - little assistance for community banks - 500 subsequent failures and devastation U.S. Attorney General Eric Holder admission of a two-tiered system of justice, one for TBTF banks another for everyone else - board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution for community bank, directors, and officers - evidence of a double standard Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) in Title II - end TBTF bailouts - Wall Street TBTF "single point of entry" (SPOE) plan for resolving failed Systemically Important Financial Institutions (SIFIs) - ensuring future bailouts for SIFIs imposing costs of bailouts on ordinary investors and taxpayers. SIFIs special long-term bonds - conversion to equity when a SIFI fails - sale of bonds to non-systemic investors - ordinary investors primary losers upon conversion into equity - insufficient to recapitalize a failed SIFI, the FDIC borrowing needed funds from the Treasury Department through the Orderly Liquidation Fund (OLF) - OLF current zero balance - backstopped by American taxpayers. Consideration of alternate resolution plans of Arthur Wilmarth, George Washington University Law School - TBTF internalize systemic risks - reduction in size and complexity - prohibition from selling special long-term bonds to ordinary individuals - SIFIs pay risk-adjusted insurance-type premiums to prefund the OLF at a level of $300 billion or more - incentive compensation rule to require SIFIs to pay at least half of total compensation to senior executives and other key employees in the form of contingent convertible bonds - expose insiders to immediate losses if SIFI fail during employment or during post-employment holding period Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) Model Financial Accounting Standards Board (FASB) proposed Current Expected Credit Loss (CECL) model - implications for community banks - prepare financial institutions for a future crisis - use of forward looking information in calculating loan loss reserves The current Incurred Loss model vs. CECL - estimated day one loss and adjust estimated losses continually throughout the life of each loan - pure speculation - CECL models extensive operating system changes and cash flow modeling capabilities - cost and regulatory burden - added reserves - lower future profits, reduce capital levels, decrease community bank lending Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks De Novo Community Bank Formation and the Dual Banking System/Charter Choice Newly chartered (de novo) community banks importance in maintaining a strong, growing, evolving and vibrant banking profession - FDICs inhibiting de novo community bank formation during the financial crisis, FDICs indication of a change in policy direction by rescinding its Financial Institution Letter (FIL) 50-2009, Enhanced Supervisory Procedures for Newly Insured FDIC-Supervised Depository Institutions The importance of the dual banking system where chartering and supervision is divided between the federal government and the states - community banks choice of charters that best fits their business model - multi-agency (state and federal) regulators and charter choice providing necessary checks and balances on the power of the regulators, as well as improved rulemaking, the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues Federal Home Loan Bank System Federal Home Loan Banks (FHLBs) strong partnership with community banks - providing short-term liquidity, long-term funding and other financial products that serve the needs of all member-owners - providing lendable funds for the local communities - regional structure, special functions and purposes of the FHLBs recognized and maintained by the Federal Housing Finance Agency (FHFA). FHFAs proposed rulemaking to revise FHLB membership eligibility requirements - negative impact on the FHLB System and its members - precedent set to terminate through rulemaking FHLB membership and the threat to revisit the broader membership issue in the future - contrary to the will of Congress FHLB System position as a healthy, stable and reliable source of funding for its members - not as the sole aggregator or securitizer of residential mortgages for community banks - FHFAs imposition of an ongoing housing mission asset test on community financial institutions Excessive Intervention in Monetary Policy Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, OCC) H.R. 4500 and S. 927 - CLEAR Relief Act Plus Act (Call report regulatory relief for community banks) (All sections) (House and Senate, OCC) H.R.1523 and S. 1816 - Community Bank Access to Capital Act (exempt banks with assets of $50 billion or less from the Basel III regulatory capital rule, and provide an exemption from internal control attestation requirements for community banks with assets of less than $1 billion) (All sections) (House and Senate, OCC) H.R. 1210 and S. 2995 - Portfolio Lending and Mortgage Access Act (automatic Qualified Mortgage (QM) protection for community bank mortgages held in portfolio) (All sections) (House and Senate, OCC) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House and Senate, OCC) H.R. 4997 and S. 3215 - Home Mortgage Disclosure Adjustment Act (HMDA reporting relief for low volume mortgage lenders) (All sections) (House and Senate, OCC) H.R. 4950 - Small Financial Institution Advisory Committee Act of 2016 (creates a Treasury Department community bank advisory committee) (All sections) (House and Senate, OCC) H.R. 5733 - Beginning Farmer and Rancher Guaranteed Loan Modernization Act (modifies limits applicable to qualified conservation loan guarantees) (All sections) (House and Senate, OCC) H.R. 4116/ S. 3373 (allows reciprocal deposits to serve as a stable source of funding to support community bank lending by ensuring that reciprocal deposits are not treated by the FDIC as brokered deposits.) (All sections) (House and Senate, OCC) H.R. 1766 - Right to Lend Act (repeals new small business loan data collection requirement) (All sections) (House and Senate, OCC) H.R. 5754 and S. 3181 - S Corporation Modernization Act (creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments) (All sections) (House and Senate, OCC) H.R. 6100 and S. 3436 - (would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation) (All Sections) (House and Senate, OCC) H.R. 6244 - (would provide capital relief for community banks, many of them rural-based, that have made limited investments in trust preferred securities (TruPS) issued by other community banks) (All sections) (House and Senate, OCC) H.R. 4099 - Consumer Financial protection Bureau Examination and Reporting Threshold Act (increase the CFPBs examination, enforcement and reporting threshold) (All sections) (House and Senate, OCC) S. 1484 - Financial Regulatory Improvement Act and H.R. 5983 - Financial CHOICE Act - (both contain various community bank regulatory relief measures) (Title 1 in S. 1484) (All sections in H.R. 5983) (House and Senate, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, OCC) Comment Letters - Comment Letter - CFPB - Proposed Rule with Request for Public Comment - Payday, Vehicle Title, and Certain High-Cost Installment Loans: Docket No. CFPB-2016-0025 Comment Letter - OCC, FDIC, Federal Reserve and OMB - Proposed Agency Collection Activities (Call Reports), FFIEC 031, FFIEC 041 and FFIEC 051 Comment Letter - IRS - Proposed Rulemaking regarding Estate, Gift, and Generation-Skipping Transfer Taxes; Restrictions on Liquidation of an Interest; 26 CFR Part 25; REG-163112-02; RIN 1545-BB71 Action Alerts - Action Alert - Regarding Payday Lending Rules - Urge CFPB to exempt community banks (CFPB) Action Alert - Regarding Call Reports - Urge OCC, FDIC and the Federal Reserve for meaningful Call Report regulatory relief Action Alert - Regarding IRS estate tax increase - Urge Illinois members of the House to halt backdoor estate tax increases Action Alert - Regarding Lame Duck session - Urge Illinois House and Senate members to pass regulatory relief measures Miscellaneous - Trade Association Industry Letter regarding enacting meaningful regulatory relief measures in the Lame Duck (All sections all bills except where noted) (House and Senate) - The Community Bank Access to Capital Act (H.R. 1523/S. 1816) includes provisions to exempt banks with assets of $50 billion or less from the Basel III regulatory capital rule, and provide an exemption from internal control attestation requirements for community banks with assets of less than $1 billion. The CLEAR Relief Act (S. 812) includes automatic qualified mortgage (QM) status for community bank mortgages held in portfolio. The Home Mortgage Disclosure Adjustment Act (H.R. 4997/S. 3215) provides critical relief for low volume mortgage lenders without materially impacting the mortgage data available to the CFPB or impairing the purpose of the HMDA statute. H.R. 4116/ S. 3373 allows reciprocal deposits to serve as a stable source of funding to support community bank lending by ensuring that reciprocal deposits are not treated by the FDIC as brokered deposits. Right to Lend Act (H.R. 1766) repeals new small business loan data collection requirement. The S Corporation Modernization Act (H.R. 5754/S. 3181) creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments. (H.R. 6100/S. 3436) would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation. (H.R. 6244) would provide capital relief for community banks, many of them rural-based, that have made limited investments in trust preferred securities (TruPS) issued by other community banks. The Financial Regulatory Improvement Act (S. 1484): Title I of S. 1484 includes provisions to promote community bank mortgage lending, including QM status for mortgages held in portfolio; create an exam cycle commensurate with the risk posed by community banks; bring more accountability to exams by the creation of an Ombudsman; and exempt community banks from a Volcker Rule. Regarding the duration, scope and severity of the massive wrongdoing at Wells Fargo, differenced between Main Street and Wall Street, destructive business model, regulatory relief for community banks (House and Senate, OCC)

Client expense: $55,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, OCC) Too-Big-To-Fail Banks and Financial Firms, Our Financial System, Economy, and American Taxpayers - Future Bailouts Reforming the financial system to reduce the possibility, probability, and severity of a future financial crisis - the perception and reality of too-big-to-fail (TBTF) - taxpayer bailouts of mega banks and financial firms - downsize TBTFs Growth, complexity, and interconnection of the TBTF banks - candidates for future bailouts - falling number of community banks representing less than one-fifth of banking professions assets TBTF banks and the mortgage meltdown and financial crisis - protection from massive financial destruction - taxpayer outrage at TBTFs - violations of the law (often criminal) and billions of dollars in fines, settlements and deferred prosecution agreements (conditional amnesty) TBTF effective management, supervision, discipline, and resolution - multi-trillion dollar financial assistance - rightful failure - little assistance for community banks - 500 subsequent failures and devastation U.S. Attorney General Eric Holder admission of a two-tiered system of justice, one for TBTF banks another for everyone else - board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution for community bank, directors, and officers - evidence of a double standard Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) in Title II - end TBTF bailouts - Wall Street TBTF "single point of entry" (SPOE) plan for resolving failed Systemically Important Financial Institutions (SIFIs) - ensuring future bailouts for SIFIs imposing costs of bailouts on ordinary investors and taxpayers. SIFIs special long-term bonds - conversion to equity when a SIFI fails - sale of bonds to non-systemic investors - ordinary investors primary losers upon conversion into equity - insufficient to recapitalize a failed SIFI, the FDIC borrowing needed funds from the Treasury Department through the Orderly Liquidation Fund (OLF) - OLF current zero balance - backstopped by American taxpayers. Consideration of alternate resolution plans of Arthur Wilmarth, George Washington University Law School - TBTF internalize systemic risks - reduction in size and complexity - prohibition from selling special long-term bonds to ordinary individuals - SIFIs pay risk-adjusted insurance-type premiums to prefund the OLF at a level of $300 billion or more - incentive compensation rule to require SIFIs to pay at least half of total compensation to senior executives and other key employees in the form of contingent convertible bonds - expose insiders to immediate losses if SIFI fail during employment or during post-employment holding period Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) Model Financial Accounting Standards Board (FASB) proposed Current Expected Credit Loss (CECL) model - implications for community banks - prepare financial institutions for a future crisis - use of forward looking information in calculating loan loss reserves The current Incurred Loss model vs. CECL - estimated day one loss and adjust estimated losses continually throughout the life of each loan - pure speculation - CECL models extensive operating system changes and cash flow modeling capabilities - cost and regulatory burden - added reserves - lower future profits, reduce capital levels, decrease community bank lending Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks De Novo Community Bank Formation and the Dual Banking System/Charter Choice Newly chartered (de novo) community banks importance in maintaining a strong, growing, evolving and vibrant banking profession - FDICs inhibiting de novo community bank formation during the financial crisis, FDICs indication of a change in policy direction by rescinding its Financial Institution Letter (FIL) 50-2009, Enhanced Supervisory Procedures for Newly Insured FDIC-Supervised Depository Institutions The importance of the dual banking system where chartering and supervision is divided between the federal government and the states - community banks choice of charters that best fits their business model - multi-agency (state and federal) regulators and charter choice providing necessary checks and balances on the power of the regulators, as well as improved rulemaking, the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues Federal Home Loan Bank System Federal Home Loan Banks (FHLBs) strong partnership with community banks - providing short-term liquidity, long-term funding and other financial products that serve the needs of all member-owners - providing lendable funds for the local communities - regional structure, special functions and purposes of the FHLBs recognized and maintained by the Federal Housing Finance Agency (FHFA). FHFAs proposed rulemaking to revise FHLB membership eligibility requirements - negative impact on the FHLB System and its members - precedent set to terminate through rulemaking FHLB membership and the threat to revisit the broader membership issue in the future - contrary to the will of Congress FHLB System position as a healthy, stable and reliable source of funding for its members - not as the sole aggregator or securitizer of residential mortgages for community banks - FHFAs imposition of an ongoing housing mission asset test on community financial institutions Excessive Intervention in Monetary Policy Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, OCC) H.R. 4500 and S. 927 - CLEAR Relief Act Plus Act (Call report regulatory relief for community banks) (All sections) (House and Senate, OCC) H.R.1523 and S. 1816 - Community Bank Access to Capital Act (exempt banks with assets of $50 billion or less from the Basel III regulatory capital rule, and provide an exemption from internal control attestation requirements for community banks with assets of less than $1 billion) (All sections) (House and Senate, OCC) H.R. 1210 and S. 2995 - Portfolio Lending and Mortgage Access Act (automatic Qualified Mortgage (QM) protection for community bank mortgages held in portfolio) (All sections) (House and Senate, OCC) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House and Senate, OCC) H.R. 4997 and S. 3215 - Home Mortgage Disclosure Adjustment Act (HMDA reporting relief for low volume mortgage lenders) (All sections) (House and Senate, OCC) H.R. 4950 - Small Financial Institution Advisory Committee Act of 2016 (creates a Treasury Department community bank advisory committee) (All sections) (House and Senate, OCC) H.R. 5733 - Beginning Farmer and Rancher Guaranteed Loan Modernization Act (modifies limits applicable to qualified conservation loan guarantees) (All sections) (House and Senate, OCC) H.R. 4116/ S. 3373 (allows reciprocal deposits to serve as a stable source of funding to support community bank lending by ensuring that reciprocal deposits are not treated by the FDIC as brokered deposits.) (All sections) (House and Senate, OCC) H.R. 1766 - Right to Lend Act (repeals new small business loan data collection requirement) (All sections) (House and Senate, OCC) H.R. 5754 and S. 3181 - S Corporation Modernization Act (creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments) (All sections) (House and Senate, OCC) H.R. 6100 and S. 3436 - (would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation) (All Sections) (House and Senate, OCC) H.R. 6244 - (would provide capital relief for community banks, many of them rural-based, that have made limited investments in trust preferred securities (TruPS) issued by other community banks) (All sections) (House and Senate, OCC) H.R. 4099 - Consumer Financial protection Bureau Examination and Reporting Threshold Act (increase the CFPBs examination, enforcement and reporting threshold) (All sections) (House and Senate, OCC) S. 1484 - Financial Regulatory Improvement Act and H.R. 5983 - Financial CHOICE Act - (both contain various community bank regulatory relief measures) (Title 1 in S. 1484) (All sections in H.R. 5983) (House and Senate, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, OCC) Comment Letters - Comment Letter - CFPB - Proposed Rule with Request for Public Comment - Payday, Vehicle Title, and Certain High-Cost Installment Loans: Docket No. CFPB-2016-0025 Comment Letter - OCC, FDIC, Federal Reserve and OMB - Proposed Agency Collection Activities (Call Reports), FFIEC 031, FFIEC 041 and FFIEC 051 Comment Letter - IRS - Proposed Rulemaking regarding Estate, Gift, and Generation-Skipping Transfer Taxes; Restrictions on Liquidation of an Interest; 26 CFR Part 25; REG-163112-02; RIN 1545-BB71 Action Alerts - Action Alert - Regarding Payday Lending Rules - Urge CFPB to exempt community banks (CFPB) Action Alert - Regarding Call Reports - Urge OCC, FDIC and the Federal Reserve for meaningful Call Report regulatory relief Action Alert - Regarding IRS estate tax increase - Urge Illinois members of the House to halt backdoor estate tax increases Action Alert - Regarding Lame Duck session - Urge Illinois House and Senate members to pass regulatory relief measures Miscellaneous - Trade Association Industry Letter regarding enacting meaningful regulatory relief measures in the Lame Duck (All sections all bills except where noted) (House and Senate) - The Community Bank Access to Capital Act (H.R. 1523/S. 1816) includes provisions to exempt banks with assets of $50 billion or less from the Basel III regulatory capital rule, and provide an exemption from internal control attestation requirements for community banks with assets of less than $1 billion. The CLEAR Relief Act (S. 812) includes automatic qualified mortgage (QM) status for community bank mortgages held in portfolio. The Home Mortgage Disclosure Adjustment Act (H.R. 4997/S. 3215) provides critical relief for low volume mortgage lenders without materially impacting the mortgage data available to the CFPB or impairing the purpose of the HMDA statute. H.R. 4116/ S. 3373 allows reciprocal deposits to serve as a stable source of funding to support community bank lending by ensuring that reciprocal deposits are not treated by the FDIC as brokered deposits. Right to Lend Act (H.R. 1766) repeals new small business loan data collection requirement. The S Corporation Modernization Act (H.R. 5754/S. 3181) creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments. (H.R. 6100/S. 3436) would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation. (H.R. 6244) would provide capital relief for community banks, many of them rural-based, that have made limited investments in trust preferred securities (TruPS) issued by other community banks. The Financial Regulatory Improvement Act (S. 1484): Title I of S. 1484 includes provisions to promote community bank mortgage lending, including QM status for mortgages held in portfolio; create an exam cycle commensurate with the risk posed by community banks; bring more accountability to exams by the creation of an Ombudsman; and exempt community banks from a Volcker Rule. Regarding the duration, scope and severity of the massive wrongdoing at Wells Fargo, differenced between Main Street and Wall Street, destructive business model, regulatory relief for community banks (House and Senate, OCC)

Client expense: $55,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, OCC) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, OCC) H.R. 1766 - Right to Lend Act (repeals new small business loan data collection requirement) (All sections) (House and Senate, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, OCC) Action Alerts - Action Alert - Regarding Lame Duck session - Urge Illinois House and Senate members to pass regulatory relief measures Miscellaneous - Trade Association Industry Letter regarding enacting meaningful regulatory relief measures in the Lame Duck (All sections) (House and Senate) - Right to Lend Act (H.R. 1766) repeals new small business loan data collection requirement.

Client expense: $55,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, OCC) Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, OCC) H.R. 5754 and S. 3181 - S Corporation Modernization Act (creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments) (All sections) (House and Senate, OCC) H.R. 6100 and S. 3436 - (would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation) (All Sections) (House and Senate, OCC) S. 1484 - Financial Regulatory Improvement Act and H.R. 5983 - Financial CHOICE Act - (both contain various community bank regulatory relief measures) (Title 1 in S. 1484) (All sections in H.R. 5983) (House and Senate, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, OCC) Comment Letters - Comment Letter - IRS - Proposed Rulemaking Regarding Estate, Gift, and Generation-Skipping Transfer Taxes; Restrictions on Liquidation of an Interest; 26 CFR Part 25; REG-163112-02; RIN 1545-BB71 Action Alert - Action Alert - Regarding IRS estate tax increase - Urge Illinois members of the House to halt backdoor estate tax increases Miscellaneous - Trade Association Industry Letter regarding enacting meaningful regulatory relief measures in the Lame Duck (All sections all bills except where noted) (House and Senate) - The S Corporation Modernization Act (H.R. 5754/S. 3181) creates an additional source of capital for Subchapter S community banks by allowing them to accept IRA investments. (H.R. 6100/S. 3436) would block a Treasury and IRS proposal to effectively end estate-planning techniques commonly used to transfer community banks and other family-owned businesses to the next generation. The Financial Regulatory Improvement Act (S. 1484): Title I of S. 1484 includes provisions to promote community bank mortgage lending, including QM status for mortgages held in portfolio; create an exam cycle commensurate with the risk posed by community banks; bring more accountability to exams by the creation of an Ombudsman; and exempt community banks from a Volcker Rule.

Client expense: $55,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE

Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs interim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; NCUAs usury ceiling under the FCU Act; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits Act; CFPBs proposed rule related to Payday, Vehicle Title and Certain High-Cost Installment Loans; Single-Family Credit Risk Transfer and proposals to adopt additional front-end credit risk transfer structures; rebates to credit unions related to the Temporary Corporate Credit Union Stabilization Fund; CFPB request for comment on Amendments Relating to Disclosure of Records and Information; NCUAs 2017 and 2018 proposed budgets; NCUAs Equity Fund Ratio and 2017 Projections; Changes to NCUAs Chartering and Field of Membership Manual.

Client expense: $640,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), 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), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs interim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; NCUAs usury ceiling under the FCU Act; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits Act; CFPBs proposed rule related to Payday, Vehicle Title and Certain High-Cost Installment Loans; Single-Family Credit Risk Transfer and proposals to adopt additional front-end credit risk transfer structures; rebates to credit unions related to the Temporary Corporate Credit Union Stabilization Fund; CFPB request for comment on Amendments Relating to Disclosure of Records and Information; NCUAs 2017 and 2018 proposed budgets; NCUAs Equity Fund Ratio and 2017 Projections; Changes to NCUAs Chartering and Field of Membership Manual.

Client expense: $640,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), 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), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

Federal Regulatory Activity OCC guidance on derivatives under Dodd-Frank; CFPB Ability to Repay Rule and Qualified Mortgage Rule; CFPB mortgage servicing final rules (TILA and RESPA); CFPB escrow final rule under Dodd-Frank; CFPB loan originator and mortgage servicing rules; Basel Committee Liquidity Standard; FDIC appraisal requirements under Dodd-Frank; Federal Reserve proposed rule on enhanced prudential standards and early remediation requirements for large foreign banks under Dodd-Frank; Federal banking agency revisions to Call Report rules; FEMA/ National Flood Insurance; OCC lending limits rule; SEC municipal advisor rule, GSE repurchases; Section 619, Dodd-Frank Wall Street Reform and Consumer Protection Act. Final Rule, Volcker Rule, IRS Regulation 67(e), FDIC brokered Deposits rule; Department of Labor Fiduciary Rule Federal Legislative Activity Cybersecurity legislation: (H.R. 1731, S.1927, S.961); Regulatory Relief bills (H.R. 601, H.R. 1259, H.R.1480, H.R.1265, H.R. 685, S.774, S.1484, H.R.1553), Community Banks legislation (H.R. 1389, H.R. 1233), Portfolio Lending relief (H.R.1210); credit union tax treatment (H.R. 1188), Mutual Bank legislation (H.R.4252); Mutual Charter Relief (H.R. 1660, H.R. 1661), Patent Troll relief (S.1137), the TAILOR Act (H.R.2896), Highway Trust Fund/ Federal Reserve Dividend; Retail Investor Protection Act (H.R. 1090); TILA RESPA Safe Harbor (H.R.3192); Interchange Fees (H.R.5465); Data Security Act (H.R. 2205)

Client expense: $35,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA)

Banking issues Credit union member - business lending H.R. 1188 - Credit Union Small Business Jobs Creation Act

Client expense: Not reported · Firm income: $27,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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 low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process 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 CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator 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 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 relating to home-based credit unions 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 credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital 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 Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity Issues related to NCUA's Proposed Rule on Member Business Lending Issues related to the Department of Labor's Proposed Rule on the Definition of Fiduciary Issues related to the Telephone Consumer Protection Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the Department of Labor's Proposed Overtime Eligibility rule Issues related to credit union conversions Issues related to the CFPB's proposal on arbitration Issues related to secure payments Issues related to credit union call report modernization H.R. 9, the Innovation Act, all provisions H.R. 22, the FAST Act, Title LXXV, provisions related to privacy notice requirements; Title LXXXII, provisions related to the eligibility of privately insured credit unions to join a Federal Home Loan Bank; Title LXXXIX, provisions related to the designation of rural areas by the Consumer Financial Protection Bureau H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 650, Preserving Access to Manufactured Housing Act, all provision H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 957, the Bureau of Consumer Financial Protection Inspector General Reform Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1090, Retail Investor Protection Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1660, the Federal Savings Association Charter Flexibility Act, all provisions H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2769, the Risk-Based Capital Study Act, all provisions H.R. 2896, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act H.R. 3192, the Homebuyer Assistance Act, all provisions H.R. 4538, the Senior $afe Act, all provisions H.R. 4893, the Risk Management and Homeowner Stability Act, all provisions H.R. 4997, the Home Mortgage Disclosure Adjustment Act, all provisions H.R. 5465, a bill to repeal section 1075 of the Consumer Financial Protection Act of 2010 relating to rules for payment card transactions, all provisions H.R. 5983, the Financial CHOICE Act, all provisions S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I S. 2216, the Senior$afe Act, all provisions The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database Discussion draft of the Financial Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs (CHOICE) Act, all provisions

Client expense: $920,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of

Work to keep insurance regulated by the states and not by the Consumer Financial Protection Bureau (CFPB). Support legislation that would reduce regulatory burden on credit unions. Support passage of legislation to address credit union member business lending, including H.R. 1188 and S. 2028, The Small Business Lending Enhancement Act of 2015. Support adoption of the National Credit Union Administration's proposed MBL rule and proposed Field of Membership rule. Advocate for stronger data security - particularly with regard to merchant plastic card data breaches. Support S. 754, the Cybersecurity Information Sharing Act of 2015. Support credit union access to supplemental capital, including H.R. 989. Support H.R. 1266 which would establish a five-person board for the CFPB. Support H.R. 957, The Bureau of Consumer Financial Protection - Inspector General Reform Act of 2015. Support H.R. 3192, Homebuyers Assistance Act regarding TRID. Support S. 1484, Financial Regulatory Improvement Act of 2015. Support raising the CFPB examintion threshold under S. 482. Support a best interest fiduciary standard for retirement advice and products as proposed by the Department of Labor that is effectively and efficiently workable in the market. Support H.R. 1090 regarding DOL proposed rule. Support insurance and credit union reform provisions in the Financial CHOICE Act, H.R. 5983.

Client expense: $128,942 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE, Treasury, Dept of

H.R. 989, supplemental capital. H.R. 1188 member business lending. H.R. 1133 veterans exemption to member business lending cap. H.R. 299 privately insured credit unions. H.R. 601 privacy notifications.H.R. 1422 residential parity. H.R. 2679, risk based capital stop and study act. S. 1484, regulatory relief. S.2028, member business lending. S. 1440, residential parity. S. 961, data security. Merchant data breaches as they apply to financial institutions. EMV chip-card conversions. National Credit Union Administration and Consumer Financial Protection Bureau regulatory issues. Proposed rules on Field of Membership and Member Business Lending. Credit union examinations. Risk-based capital. Truth in lending disclosures (TRID). HMDA Home Mortgage Disclosure Act. Community lender exemption authority to Dodd-Frank Wall Street Reform and Consumer Protection Act. Property Assessed Clean Energy (PACE) lending and priority liens. Fair Credit Reporting Act - Federal Trade Commission. Cannabis banking.

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE

Annual Privacy Disclosure Notices:[H.R. 601, S.423, S.1484]; Capital Reform:[ H.R.2769]; Consumer Financial Protection Bureau Improvements:[H.R. 3193, H.R. 1266]; Consumer Financial Protection Bureaus Qualified Mortgage Definition:[H.R. 685, H.R. 1259, S. 871]; Credit Union Tax Exemption:[H.R. 1]; Data Security:[H.R. 2205, S. 961]; Defense Credit Union Issues:[H.R. 1735]; Housing Finance Reform:[S. 1217]; Interchange Fees;Member Business Lending:[H.R. 1133, H.R. 1188, H.R. 1422]; Regulatory Relief:[S. 1484, H.R. 3468]; Supplemental Capital:[H.R.719, H.R. 989]; Financial services and general government appropriations bill [H.R. 5485 FY 17].

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Credit Availability S1484 - The Financial Regulatory Improvement Act of 2015 Fees and Points in the QM ATR Rules of Dodd-Frank HR685 - Mortgage Choice Act of 2015 Student Loan Debt HR970 - Supporting Academic Freedom through Regulatory Relief Act HR1131 - Fairness in Student Loan Lending Act HR1434 - Bank on Students Emergency Loan Refinancing Act HR3179 - Empowering Students Through Enhanced Financial Counseling Act HR3180 - Flexible Pell Grant for 21st Century Students Act HR4162 - Credit Access and Inclusion Act of 2015 HR4652 - CLEAR Act S85 - Repay Act of 2015 S108 - Financial Aid Simplification and Transparency Act of 2015 S729 - Fairness for Struggling Students Act of 2015 S793 - Bank on Students Emergency Loan Refinancing Act S840 - Student Loan Borrower Bill of Rights S1948 - AFFORD Act S2043 - Know Before You Owe Federal Student Loan Act of 2015 S2677 - In the Red Act of 2016 Credit Union Lending HR1188 - Credit Union Small Business Job Creations Act CFPB Reform HR1266 - Financial Product Safety Commission Act of 2015 S510 - CFPB-IG Act of 2015 Access to Manufactured Housing HR650 - Preserving Access to Manufactured Housing Act of 2015 S682 - Preserving Access to Manufactured Housing Act of 2015 GSE Reform HR22 - DRIVE Act HR1491 - Partnership to Strengthen Homeownership Act of 2015 HR2029 - Consolidated Appropriations Act, 2016 HR4913 - Housing Finance Restructuring Act of 2016 HR__ - Moving Housing Forward Act S2038 - Jumpstart GSE Reform Act Guarantee Fees S752 - A bill to establish a scorekeeping rule to ensure that increases in guarantee fees of Fannie Mae and Freddie Mac shall not be used to offset provisions that increase the deficit. HConRes125 - Establishing the congressional budget for the United States Government for fiscal year 2017 and setting forth the appropriate budgetary levels for fiscal years 2018 through 2026. RESPA/TILA Amendments/TRID HR1113 - Portfolio Lending and Mortgage Access Act HR1210 - Portfolio Lending and Mortgage Access Act HR3192 - Homebuyers Assistance Act S1711 - A bill to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. Short Sales HR4812 - Prompt Notification of Short Sales Act Mortgage Servicing Assets HR2029 - Consolidated Appropriations Act, 2016 Alternative Credit Scoring HR3035 - Credit Access and Inclusion Act of 2015 HR4211 - Credit Score Competition Act of 2015 HR4893 - Risk Management and Homeowner Stability Act of 2016 S2355 - Credit Access and Inclusion Act of 2015 Service Members Foreclosure Relief S2393 - Foreclosure Relief and Extension for Servicemembers Act of 2015 Commercial Risk Retention Rules HR4620 - Preserving Access to CRE Capital Act of 2016 FHFA HR3808 - To require the withdrawal and study of the Federal Housing Finance Agency's proposed rule on Federal Home Loan Bank membership, and for other purposes. Financial Regulatory Reform HR1090 - Retail Investor Protection Act HR2642 - Community Lender Regulatory Relief and Consumer Protection Act of 2015 S1484 - Financial Regulatory Improvement Act of 2015 S1491 - Community Lender Regulatory Relief and Consumer Protection Act of 2015 HR__ - The Financial Choice Act Credit Reporting HR347 - The Facilitating Access to Credit Act HR5282 - The Comprehensive Consumer Credit Reporting Act of 2016 Federal Home Loan Bank HR__ - To amend the Federal Home Loan Bank Act to clarify the definition of an insurance company and to provide Federal Home Loan Bank membership standards for certain captive insurance companies Alternative Lending Sources HR4854 - Supporting America's Innovators Act of 2016 HR4855 - Fix Crowdfunding Act Zombie Foreclosures S3146 - Preserving Abandoned Foreclosures and Preserving Communities Act of 2016 Conversations with the Consumer Finance Protection Bureau (CFPB) on TRID/Know Before You Owe. Discussions with the Federal Housing Finance Agency (FHFA) on credit availability, appraisal issues, appraisal management companies (AMCs), GSE reform, and risk-sharing. Discussions with the Small Business Administration to discuss small business lending programs. Discussions with the Treasury on anti-money laundering and credit availability. Conversations with the Office of the Comptroller of the Currency (OCC) on appraisal issues, AMCs. Discussions with the Securities and Exchange Commission (SEC) on JOBS Act Rulemaking. Discussions with the Federal Reserve on appraisal issues, AMCs. Discussions with the Federal Deposit Insurance Corporation (FDIC) on appraisal issues, AMCs.

Client expense: $23,800,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Energy, Dept of, Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Telecommunications & Information Administration (NTIA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, U.S. Forest Service, Veterans Affairs, Dept of (VA), White House Office

S.924/H.R.2287, National Credit Union Administration Budget Transparency Act, all provisions; H.R.1188/S.2028, Credit Union Small Business Jobs Creation Act, all provisions; S.1484, Financial Regulatory Improvement Act of 2015, all provisions; S.961/H.R.2205, Data Security Act of 2015, all provisions; H.R.1770, the Data Security and Breach Notification Act, all provisions; H.R.5485/S.3067, FY2017 Financial Services and General Government Appropriations Act, issues involving CFPB regulatory authority; CFPB regulatory relief for small institutions.

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.924/H.R.2287, National Credit Union Administration Budget Transparency Act, all provisions; H.R.1188/S.2028, Credit Union Small Business Jobs Creation Act, all provisions; S.1484, Financial Regulatory Improvement Act of 2015, all provisions; S.961/H.R.2205, Data Security Act of 2015, all provisions; H.R.1770, the Data Security and Breach Notification Act, all provisions; H.R.5485/S.3067, FY2017 Financial Services and General Government Appropriations Act, issues involving CFPB regulatory authority; CFPB regulatory relief for small institutions.

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs inerim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits Act.

Client expense: $590,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), 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), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

Consumer Financial Protection Bureaus (CFPB) Notice and Request for Comment on Web-Based Quantitative Testing Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms; Comments responding to request for information on the FHFAs proposed collection of information relating to the NSEMB; Comments on Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis, RIN 1506-AB25; Concerns with CFPB future payday lending rulemakings; payday lending as related to the CFPB Proposals; H.R. 3192: Homebuyers Assistance Act; H.R. 2769: Risk-Based Capital Study Act; National Credit Union Administrations (NCUA) risk-based capital proposal; H.R. 2205: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; NCUAs budget; H.R. 1176: NCUA Budget Transparency Act/ GAO Study of NCUA budgeting practices; H.R. 1188: Credit Union Small Business Jobs Creation Act/ raising MBL cap; H.R. 1195: Bureau of Consumer Financial Protection Advisory Boards Act; H.R. 1210: Portfolio Lending and Mortgage Access Act; H.R. 2473: Preserving Capital Access and Mortgage Liquidity Act of 2015; H.R. 2896: the TAILOR Act of 2015; S. 754: Cyber Security Information Sharing Act; NAFCUs Five Point Plan for Regulatory Relief (capital reforms for credit unions; field of membership improvements for credit unions; reduced consumer financial protection bureaus on credit unions; operational improvements for credit unions; 21st century data security standards); Regulatory relief for credit unions; Impact of Federal Regulations on Credit Unions; S. 961: Data Security Act of 2015/ Subjects retailers to robust federal safekeeping standard; NCUAs efforts to allow credit unions to better serve rural areas; H.R. 1259: Helping Expand Lending Practices in Rural Communities Act; CFPBs inerim final rule amending Regulation Z; H.R. 1261: Bureau of Consumer Financial Protection Accountability Act/ Subjects CFPB to Congressional appropriations process; S. 774: Financial Institutions Examination Fairness and Reform Act; S. 871: HELP Rural Communities Act of 2015/ CFPB Rural Definition; H.R. 685: Mortgage Choice Act of 2015/ Points and Fees; H.R. 1408: Mortgage Servicing Asset Capital Requirements Act; H.R. 1422: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; H.R. 1529: Community Institution Mortgage Relief Act of 2015; H.R. 1941: Financial Institutions Examination Fairness and Reform Act; Regulatory Burdens; Qualified Mortgage Rule; S. 1484: Financial Regulatory Improvement Act; Federal Credit Union Act; S. 2028: A bill to amend the Federal Credit Union Act, to advance the ability of credit unions to promote small business growth and economic development opportunities, and for other purposes; H.R. 3738: the Office of Financial Research Accountability Act of 2015; H.R. 3557: the FSOC Transparency and Accountability Act; H.R. 1660: the Federal Savings Association Charter Flexibility Act; Improve the federal charter of credit unions through the FCU Act; H.R. 989: Capital Access for Small Businesses and Jobs Act/ Supplemental Capital; H.R. 1133: To exclude extensions of credit made to veterans from the definition of a member business loan under the Federal Credit Union Act; NCUA proposed rulemaking on a federal insured credit unions member business lending; NCUAs exam scheduling policy; NAFCUs Top Ten Regulations for Eliminate of Amend (improve process for credit unions seeking changes to their field of membership; provide more meaningful exemptions for small institutions; Dodd-Frank 1022 Authority; expand credit union investment authority; allowing more transfers per month from savings accounts per Federal Reserve Regulation D; flexibility for credit unions making member business loans; NCUAs member business lending rule: update requirement to disclose account numbers to protect privacy of members; update advertising requirements for loan products and share accounts; Accuracy of advertising and notice of insured status; seek improvements to the NCUA Central Liquidity Facility (CLF); CLF information collection; CLF modernization to obtain flexibility for federal credit unions to determine their choice of law; update simplify and make improvements to regulations governing check processing funds); S. 423: Privacy Notice Modernization Act of 2015; H.R. 22: the Surface Transportation Reauthorization and Reform Act of 2015; NCUAs proposed Field of Membership Amendments; H.R. 2995: Financial Services and General Government Appropriations Act; Require the CFPB to conduct a fair, comprehensive study before adopting a rule that would restrict arbitration and open the door to abusive class actions; prevent arbitration restrictions; NCUA third party vendor authority; CFPB request for approval under the Paperwork Reduction Act to conduct a national web-based survey relative to overdraft protection services; CFPB consumer complaint narrative database; CFPB and the student loan servicing market; Student Loan Borrower Communication ;CFPB integration of the Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) disclosures, consider good faith efforts to comply with TRID; financial regulators must level the playing field and promulgate rules that require non-traditional market lenders to meet basic consumer protection requirements such as those of TILA, underwriting standards for loans, and applicable state usury laws; FSOC should facilitate regulatory coordination among its member regulators; preserve the credit union tax exemption; regulatory relief including CFPB using their exemption authority more; Housing Finance Reform - it is vital that credit unions continue to have unfettered access to the secondary mortgage market and any reforms should have emphasis on fair pricing that reflects loan quality rather than quantity; Department of Labors proposed changes to the Fair Labor Standards Act for certain full-time salaried works to be eligible for overtime protections; Federal Communication Commission clarification for free end user calls made by financial institutions; Federal Communication Commission clarification regarding clarifications to the interpretations of the Telephone Consumer Protection Act; FCCs Declaratory Ruling and Order on TCPA; H.R. 1155: the Searching for and Cutting Regulations that are unnecessarily Burdensome (SCRUB) Act; prepaid cards - CFPB efforts to ensure that consumers using prepaid products are sufficiently informed and protected - they should find appropriate balance between adequate consumer protection and allowing consumers access to products they demand; compliance burdens related to CFPB amendments to Regulation C, HMDA; Uniform Residential Loan Application (URLA); Periodic Statements for Borrowers who have filed for bankruptcy; Statement production systems and CFPBs servicing regulations; Small Business Administration SBA 7(a) business loan program; H.R. 2499: Veterans Entrepreneurship Act of 2015; FY 2016 Financial Services and General Government Appropriations bill; H.R. 427: Regulations for the Executive in Need of Scrutiny Act of 2015; Improve agency use of regulatory guidance; Protect responsible overdraft services; Changes to requirements under the Home Mortgage Disclosure Act; H.R. 957: Bureau of Consumer Financial Protection Inspector General Reform Act; Reform of Fannie Mae and Freddie Mac; Credit risk-guarantee fees; Military Lending Act; H.R. 1735: National Defense Authorization Act for Fiscal Year 2016; Cost-benefit analysis at federal regulatory agencies; Regulatory coordination; Regulations related to remittance transfers; Legal opinion letters at the CFPB and NCUA; H.R. 9: Innovation Act; H.R. 185: Regulatory Accountability Act of 2015; H.R. 527: Small Business Regulatory Flexibility Improvements Act of 2015; H.R. 650: Preserving Access to Manufactured Housing Act; H.R. 766: Financial Institution Customer Protection Act/ Ending Operation Choke Point; H.R. 1262: Consumer Right to Financial Privacy Act of 2015; H.R. 1263: Consumer Financial Protection Safety and Soundness Improvement Act/ Changes veto authority of the Financial Stability Oversight Council; H.R. 1265: Bureau Advisory Commission Transparency Act/ Making credit union advisory council meetings public; H.R. 1266: Financial Product Safety Commission Act/ Replacing CFPB Director with Commission; H.R. 1309: Systemic Risk Designation Improvement Act of 2015; S. 881: Comprehensive Regulatory Review Act of 2015; S. 924: To require public hearings on NCUA's budget; S. 1137: PATENT Act; S. 1440: Credit Union Residential Loan Parity Act/ MBL 1-4 exemption; Ensure an Effective Payments system; Fairness under FCC ruling on autodialing and FCC oversight; Telephone Consumer Protection Act; modernize online lending laws and regulations; give NCUA greater flexibility with credit union lending including the ability to establish longer maturities for certain loans; preventing g-fees charged by Fannie and Freddie from being used as funding offset; NCUA 18-month Exam Cycle; Military Lending Act Database; Credit Losses Accounting Standard; FASB Accounting Standards; CFPBs expansion of data collection under Reg C, Privacy protections for data collected by CFPB; NIST notice and request for information on views on the Framework for Improving Critical Infrastructure Cybersecurity; Comments on Notice of proposed rulemaking regarding field of membership and chartering; CBSA population limit, combined statistical area, well defined local communities, rural population limits, multiple common bond charters, underserved areas, TIP charters; CFPB information collection on compliance costs and other effects of regulation; Duty to serve underserved markets; interchange rates as related to the Durbin Amendment to Dodd-Frank; Repeal Durbin Amendment; H.R. 5465 - to repeal Durbin Amendment; Federal Reserves EGRPRA review process; FHFAs principal reduction consideration; FFIEC Cybersecurity Assessment Tool; FFIEC proposed revision to the Uniform Interagency Consumer Compliance Rating System; Department of Labor Fiduciary Rule, Department of Labor overtime Rule; Administrative Procedures Act; Regulatory Flexibility for credit unions; Promote Consumer Protection and Financial Literacy; Financial Technology (FinTech); FinTech and online marketplace lending; Transparency for NCUAs Overhead Transfer Rate methodology; Transparency for NCUAs Operating Fee methodology; FY 2017 Financial Services and General Government Appropriations Bill; Community Development Financial Institution funding (CDFI); CDFI certification and reporting requirements; Dept. of Treasurys National Strategy for financial literacy and education; NCUAs information collection on investment and deposit activities; allow credit unions to purchase loans from other originators for purposes of issuing securities; mortgage servicing rights; extend exemption for consumer credit cards from MLA Rule requirements; Secondary Capital for low-income designated credit unions(LICU); LICU information collection burdens; Loan Level Price adjustments and Guaranty Fees; HR5541, Financial Services for the Underserved Act of 2016; NCUAs proposed rule regarding FCU occupancy, planning, and disposal of acquired and abandoned premises; HR 1486, Taking Account of Bureaucrats Spending Act (TABS); HR 4773, the Protection Workplace Advancement and Opportunity Act; HR 4538, the Senior$afe Act; NCUAs proposed rule on Incentive-Based Compensation Arrangement; NCUAs Exam Flexibility Initiative; issues related to the National Credit Union Share Insurance Funds Equity Ratio; NCUAs Regulatory Review; seeking guidance from NCUA on interpretation of overall financial performance; NCUAs Revised Examiner Guidance; NCUA to revise CUSO reporting requirements; CUSO accounting standards, Amend NCUA thresholds for supervisory committee audits and verifications; NCUA to address duplicative nature of Fair Credit Reporting regulations; Incidental Powers; requirements for share insurance; Update call reports; DOJs ANPR on accessibility of web information and services of State and Local Government entities; CFPBs amendment to Regulation Ps Annual Privacy Notice Requirement; NCUAs modernization of data collection for regulatory oversight of credit unions; CFPBs proposed rule on arbitration agreements; Property Assessed Clean Energy (PACE) Loans; NCUAs proposed amendments to the Community Development Revolving Loan Fund; modernization of Federal Credit union Bylaws; FHFAs development of a Common Securitization Platform; NIST request for comment on current and future states of cybersecurity in the digital economy; DOD to give better guidance and extend effective date on Military Lending Act Rule; comments on CFPBs Outline of Proposals Under Consideration and Alternatives Considered regarding Third-Party debt collection practices; comments on Consumer Response Company Response Survey; H.R. 5983, the Financial CHOICE Act; H.R. 4038, the Community Financial Institution Exemption Act; H.R. 6094, Regulatory Relief for Small Businesses, Schools, and Non-Profits Act.

Client expense: $590,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), 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), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

Annual Privacy Disclosure Notices:[H.R. 601, S.423, S.1484]; Capital Reform:[ H.R.2769]; Consumer Financial Protection Bureau Improvements:[H.R. 3193, H.R. 1266]; Consumer Financial Protection Bureaus Qualified Mortgage Definition:[H.R. 685, H.R. 1259, S. 871]; Credit Union Tax Exemption:[H.R. 1]; Data Security:[H.R. 2205, S. 961]; Defense Credit Union Issues:[H.R. 1735]; Housing Finance Reform:[S. 1217]; Interchange Fees; Member Business Lending:[H.R. 1133, H.R. 1188, H.R. 1422]; Regulatory Relief:[S. 1484, H.R. 3468]; Supplemental Capital:[H.R.719, H.R. 989]; Financial services and general government appropriations bill [H.R. 5485 FY 17]

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES

Supplemental capital issues, regulatory issues for credit unions and tax exemption status: HR185; HR 766; HR 957; HR 1133; HR 1176; HR 1188; HR 1266; HR 1422; HR 1486; HR 1529; HR 1550; HR 1660; HR 1661; HR 1941; HR 2099; HR 2213; HR 2473; HR 2642; HR 2769;HR 2896; HR 3557; HR 3738; HR 3808; HR 3857; HR 4099; HR 4210; HR 4248; HR 4500; HR 4538; HR 4647; HR 4894; HR 4913; HR 4997; HR 5112; HR 5211; HR 5413; HR 5419; HR 5453; HR 5465; HR 5490; HR 5491; HR 5521; HR 5522; HR 5523; HR 5527; HR 5569; HR 5724; HR 5869; HR 5991; HR 6118; HR 6162; HR 6244; HR 6266; S. 423; S. 482; S. 726; S. 774; S. 924; S. 970; S. 1383; S. 1440; S. 1484; S. 1491; S. 2038; S. 2216; S. 2315; S. 2663; S. 2722; S. 2760; S. 2790; S. 2995; 2.3083; S. 3153; S. 3196; S. 3215; S. 3219; S. 3321; data security and cybersecurity; patent reform; FHLB membership rules; CFPB and FSOC reform; and GSE reform.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Banking issues Credit union member - business lending H.R. 1188 - Credit Union Small Business Jobs Creation Act

Client expense: Not reported · Firm income: $27,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Work to keep insurance regulated by the states and not by the Consumer Financial Protection Bureau (CFPB). Support legislation that would reduce regulatory burden on credit unions. Support passage of legislation to address credit union member business lending, including H.R. 1188 and S. 2028, The Small Business Lending Enhancement Act of 2015. Support adoption of the National Credit Union Administration's proposed MBL rule and proposed Field of Membership rule. Advocate for stronger data security - particularly with regard to merchant plastic card data breaches. Support S. 754, the Cybersecurity Information Sharing Act of 2015. Support credit union access to supplemental capital, including H.R. 989. Support H.R. 1266 which would establish a five-person board for the CFPB. Support H.R. 957, The Bureau of Consumer Financial Protection - Inspector General Reform Act of 2015. Support H.R. 3192, Homebuyers Assistance Act regarding TRID. Support S. 1484, Financial Regulatory Improvement Act of 2015. Support raising the CFPB examintion threshold under S. 482. Support a best interest fiduciary standard for retirement advice and products as proposed by the Department of Labor that is effectively and efficiently workable in the market. Support H.R. 1090 regarding DOL proposed rule. Support insurance and credit union reform provisions in the Financial CHOICE Act, H.R. 5983.

Client expense: $113,823 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE, Treasury, Dept of

H.R. 766 Financial Institution Customer Protection Act H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1188 Credit Union Small Business Jobs Creation Act H.R. 1195 The Bureau of Consumer Financial Protection Small Business Advisory Board Act H.R. 1210 Portfolio Lending and Mortgage Access Act H.R. 1233 CLEAR Relief Act H.R. 1334 Holding Company Registration Threshold Equalization Act of 2015 H.R. 1523 Community Bank Access to Capital Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 1553 Small Bank Exam Cycle Reform Act H.R. 1660 The Federal Savings Association Charter Flexibility Act H.R. 1661 Mutual Bank Capital Opportunity Act H.R. 1766 Right to Lend Act of 2015 H.R. 2205 Data Security Act of 2015 H.R. 2896 Tailor Act of 2015 H.R. 2987 Community Bank Capital Clarification Act H.R. 3791 A bill to increase Small Bank Holding Policy Statement threshold from $1B to $5B in assets H.R. 4099 CFPB Exam and Reporting Threshold Act H.R. 4116 To amend the Federal Deposit Insurance Act to ensure that reciprocal deposits are not considered to be funds obtained by or through a deposit broker H.R. 4500 The Community Bank Reporting Relief Act H.R. 4909 National Defense Authorization Act of 2017 H.R. 4997 The Home Mortgage Disclosure Adjustment Act H.R. 5076 Main Street Parity Act H.R. 5465 To repeal section 1075 of the Consumer Financial Protection Act of 2010 relating to rules for payment card transactions, and for other purposes. H.R. 5485 Financial Services and General Government Appropriations Act of 2017 H.R. 5724 The Protecting Consumers Access to Credit Act of 2016 H.R. 5808 EGRPRA Review Frequency H.R. 5983 The Financial CHOICE Act S. 812 The CLEAR Relief Act S. 927 CLEAR Relief Plus Act S. 961 Data Security Act of 2015 S. 970 18-Month Exam Cycle S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act S. 1816 Community Bank Access to Capital Act S. 2471 401 (Kids) Education Savings Account Act of 2016 S. 2722 Federal Savings Association Charter Flexibility Act - all provisions S. 2943 National Defense Authorization Act of 2017 S. 2992 Small Business Lending Oversight Act S. 3067 Financial Services and General Government Appropriations Act of 2017 S. 3153 The Tailor Act. S. 3215 To amend the Home Mortgage Disclosure Act of 1975 to specify which depository institutions are subject to the maintenance of records and disclosure requirements of such Act, and for other purposes S. 3373 A bill to amend the Federal Deposit Insurance Act to ensure that the reciprocal deposits of an insured depository institution are not considered to be funds obtained by or through a deposit broker, and for other purposes S. 3404 A bill to amend the Federal Deposit Insurance Act to require the appropriate Federal banking agencies to treat certain municipal obligations as level 2B liquid assets, and for other purposes Call Report Streamlining Capital Access for Community Banks Capital Rules--Basel III CFPB Data Collection CFPB Overdraft CFPB Reforms/Governance CFPB Small Business Data Collection CFPB Small Dollar/Payday Lending Credit Union Business Lending Powers Credit Union Field of Membership Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint Durbin Debit Interchange and Routing Amendment EMV Chip Migration Escrow Mortgage Requirements FASB Accounting Rules for Loan Loss Reserves Faster Payments Federal Reserve Reform Fintech Limited Bank Charter Flood Insurance Reform Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Innovation Initiative (FinTech) Interchange Military Bank Leases Military Lending Act Rules Mortgage Lending Reform Mutual Banks Nominations of Allan Landon and Kathryn Dominguez to the Board of Governors of the Federal Reserve System Online/Marketplace Lending Qualified Mortgages, Ability to Repay Rules Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Lending Limit Small Bank Holding Company Policy Statement TILA/RESPA Integrated Disclosures Implementation Too Big To Fail Virtual Currency Wells Fargo Account Opening Fraud

Client expense: $860,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Veterans Affairs, Dept of (VA), White House Office

Annual Privacy Disclosure Notices:[H.R. 601, S.423, S.1484]; Capital Reform:[ H.R.2769]; Consumer Financial Protection Bureau Improvements:[H.R. 3193, H.R. 1266]; Consumer Financial Protection Bureaus Qualified Mortgage Definition:[H.R. 685, H.R. 1259, S. 871]; Credit Union Tax Exemption:[H.R. 1]; Data Security:[H.R. 2205, S. 961]; Defense Credit Union Issues:[H.R. 1735]; Housing Finance Reform:[S. 1217]; Interchange Fees;Member Business Lending:[H.R. 1133, H.R. 1188, H.R. 1422]; Regulatory Relief:[S. 1484, H.R. 3468]; Supplemental Capital:[H.R.719, H.R. 989]; Financial services and general government appropriations bill [H.R. 5485 FY 17].

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, Federal Reserve) Too-Big-To-Fail Banks and Financial Firms, Our Financial System, Economy, and American Taxpayers - Future Bailouts Reforming the financial system to reduce the possibility, probability, and severity of a future financial crisis - the perception and reality of too-big-to-fail (TBTF) - taxpayer bailouts of mega banks and financial firms - downsize TBTFs Growth, complexity, and interconnection of the TBTF banks - candidates for future bailouts - falling number of community banks representing less than one-fifth of banking professions assets TBTF banks and the mortgage meltdown and financial crisis - protection from massive financial destruction - taxpayer outrage at TBTFs - violations of the law (often criminal) and billions of dollars in fines, settlements and deferred prosecution agreements (conditional amnesty) TBTF effective management, supervision, discipline, and resolution - multi-trillion dollar financial assistance - rightful failure - little assistance for community banks - 500 subsequent failures and devastation U.S. Attorney General Eric Holder admission of a two-tiered system of justice, one for TBTF banks another for everyone else - board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution for community bank, directors, and officers - evidence of a double standard Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) in Title II - end TBTF bailouts - Wall Street TBTF "single point of entry" (SPOE) plan for resolving failed Systemically Important Financial Institutions (SIFIs) - ensuring future bailouts for SIFIs imposing costs of bailouts on ordinary investors and taxpayers. SIFIs special long-term bonds - conversion to equity when a SIFI fails - sale of bonds to non-systemic investors - ordinary investors primary losers upon conversion into equity - insufficient to recapitalize a failed SIFI, the FDIC borrowing needed funds from the Treasury Department through the Orderly Liquidation Fund (OLF) - OLF current zero balance - backstopped by American taxpayers. Consideration of alternate resolution plans of Arthur Wilmarth, George Washington University Law School - TBTF internalize systemic risks - reduction in size and complexity - prohibition from selling special long-term bonds to ordinary individuals - SIFIs pay risk-adjusted insurance-type premiums to prefund the OLF at a level of $300 billion or more - incentive compensation rule to require SIFIs to pay at least half of total compensation to senior executives and other key employees in the form of contingent convertible bonds - expose insiders to immediate losses if SIFI fail during employment or during post-employment holding period Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) Model Financial Accounting Standards Board (FASB) proposed Current Expected Credit Loss (CECL) model - implications for community banks - prepare financial institutions for a future crisis - use of forward looking information in calculating loan loss reserves The current Incurred Loss model vs. CECL - estimated day one loss and adjust estimated losses continually throughout the life of each loan - pure speculation - CECL models extensive operating system changes and cash flow modeling capabilities - cost and regulatory burden - added reserves - lower future profits, reduce capital levels, decrease community bank lending Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks De Novo Community Bank Formation and the Dual Banking System/Charter Choice Newly chartered (de novo) community banks importance in maintaining a strong, growing, evolving and vibrant banking profession - FDICs inhibiting de novo community bank formation during the financial crisis, FDICs indication of a change in policy direction by rescinding its Financial Institution Letter (FIL) 50-2009, Enhanced Supervisory Procedures for Newly Insured FDIC-Supervised Depository Institutions The importance of the dual banking system where chartering and supervision is divided between the federal government and the states - community banks choice of charters that best fits their business model - multi-agency (state and federal) regulators and charter choice providing necessary checks and balances on the power of the regulators, as well as improved rulemaking, the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues Federal Home Loan Bank System Federal Home Loan Banks (FHLBs) strong partnership with community banks - providing short-term liquidity, long-term funding and other financial products that serve the needs of all member-owners - providing lendable funds for the local communities - regional structure, special functions and purposes of the FHLBs recognized and maintained by the Federal Housing Finance Agency (FHFA). FHFAs proposed rulemaking to revise FHLB membership eligibility requirements - negative impact on the FHLB System and its members - precedent set to terminate through rulemaking FHLB membership and the threat to revisit the broader membership issue in the future - contrary to the will of Congress FHLB System position as a healthy, stable and reliable source of funding for its members - not as the sole aggregator or securitizer of residential mortgages for community banks - FHFAs imposition of an ongoing housing mission asset test on community financial institutions Excessive Intervention in Monetary Policy Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House and Senate) H.R. 4950 - Small Financial Institution Advisory Committee Act of 2016 (creates a Treasury Department community bank advisory committee) (All sections) (House and Senate) Comment Letters - Comment Letter - OCC, FDIC and Federal Reserve - Incentive-Based Compensation Arrangements: OCC 12 CFR Part 42, Docket No. OCC-2011-0001, RIN 1557-AD39; Federal Reserve System 12 CFR Part 236, Docket No. R-1536, RIN 7100 AE-50; Federal Deposit Insurance Corporation 12 CFR Part 372, RIN 3064-AD86 Miscellaneous - Regarding Federal Reserve Bank of Chicago meeting - dual banking system, electronic delivery of loan files for examinations, prolonged low interest rate environment, shared examination responsibility with other regulators, Financial Accounting Standards Boards (FASB) Current Expected Credit Loss model (CECL) (Federal Reserve) Regarding letter to Illinois Congressional Delegation - the duration, scope and severity of the massive wrongdoing at Wells Fargo, differenced between Main Street and Wall Street, destructive business model, regulatory relief for community banks (House and Senate) Regarding House meeting - Treasury Department community bank study and Treasury Department Community Bank Advisory Committee (House)

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

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, Federal Reserve) Too-Big-To-Fail Banks and Financial Firms, Our Financial System, Economy, and American Taxpayers - Future Bailouts Reforming the financial system to reduce the possibility, probability, and severity of a future financial crisis - the perception and reality of too-big-to-fail (TBTF) - taxpayer bailouts of mega banks and financial firms - downsize TBTFs Growth, complexity, and interconnection of the TBTF banks - candidates for future bailouts - falling number of community banks representing less than one-fifth of banking professions assets TBTF banks and the mortgage meltdown and financial crisis - protection from massive financial destruction - taxpayer outrage at TBTFs - violations of the law (often criminal) and billions of dollars in fines, settlements and deferred prosecution agreements (conditional amnesty) TBTF effective management, supervision, discipline, and resolution - multi-trillion dollar financial assistance - rightful failure - little assistance for community banks - 500 subsequent failures and devastation U.S. Attorney General Eric Holder admission of a two-tiered system of justice, one for TBTF banks another for everyone else - board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution for community bank, directors, and officers - evidence of a double standard Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) in Title II - end TBTF bailouts - Wall Street TBTF "single point of entry" (SPOE) plan for resolving failed Systemically Important Financial Institutions (SIFIs) - ensuring future bailouts for SIFIs imposing costs of bailouts on ordinary investors and taxpayers. SIFIs special long-term bonds - conversion to equity when a SIFI fails - sale of bonds to non-systemic investors - ordinary investors primary losers upon conversion into equity - insufficient to recapitalize a failed SIFI, the FDIC borrowing needed funds from the Treasury Department through the Orderly Liquidation Fund (OLF) - OLF current zero balance - backstopped by American taxpayers. Consideration of alternate resolution plans of Arthur Wilmarth, George Washington University Law School - TBTF internalize systemic risks - reduction in size and complexity - prohibition from selling special long-term bonds to ordinary individuals - SIFIs pay risk-adjusted insurance-type premiums to prefund the OLF at a level of $300 billion or more - incentive compensation rule to require SIFIs to pay at least half of total compensation to senior executives and other key employees in the form of contingent convertible bonds - expose insiders to immediate losses if SIFI fail during employment or during post-employment holding period Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) Model Financial Accounting Standards Board (FASB) proposed Current Expected Credit Loss (CECL) model - implications for community banks - prepare financial institutions for a future crisis - use of forward looking information in calculating loan loss reserves The current Incurred Loss model vs. CECL - estimated day one loss and adjust estimated losses continually throughout the life of each loan - pure speculation - CECL models extensive operating system changes and cash flow modeling capabilities - cost and regulatory burden - added reserves - lower future profits, reduce capital levels, decrease community bank lending Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Mortgage Lending and Housing Finance Reform Imprudent mortgage lendings contribution to the mortgage meltdown and the financial crisis - community banks common sense relationship lending - no need for prescriptive regulations to compel doing what is right for their customers - not negatively impacting responsible community bank loan products to meet diverse needs of their customers including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers - recognize differences between the non-traditional lending practiced by community banks and the predatory lending practices of others All community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs) - an increase in the small servicer exemption, an increase in the HMDA reporting levels - a formalized safe harbor during the TRID implementation period - broad special accommodations for community banks to provide flexibility in serving the needs of their customers and communities, particularly in rural areas - and expand definition of underserved areas to include economically challenged areas Untenable long-term position of government sponsored entities (GSEs) Fannie Mae (Fannie) and Freddie Mac (Freddie) in conservatorship by the United States Treasury run by the Federal Housing Finance Agency (FHFA). In reforming to the housing GSEs, the need for the continued existence of an impartial secondary market for residential mortgages for community banks which is financially strong and reliable - the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress - no limit in full participation by community banks or disruption in the housing market - the return of private capital to reduce the reliance on government funding - protection of taxpayers from another bailout. Community bank sale of loans through an independent entity - not competing with community banks - no appropriation of community bank customer data for the purpose of cross selling financial services - the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market - the pricing of the governmental guaranty being fair and equal to all participants regardless of volume of loans guaranteed - no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt community banks or any products or services from the rules it writes - use of this authority to ensure community banks can continue to provide alternatives to large banks and non-banks for consumers seeking responsible financial service providers CFPB providing community banks with flexibility to meet unique needs of customers and not burden community banks with additional and unnecessary regulatory requirements to prevent them from serving their communities - no one-size-fits-all approach to CFPB regulations which harms community banks in meeting the unique needs of its local customers and communities - Community banks enduring any additional consumer regulatory burden on top of the existing burden they already face Single-Director governance of the CFPB vs. a five-member commission - residential regulators participate with the CFPB in the rule-writing process - Financial Stability Oversight Council (FSOC) power to veto CFPB rules under a practical and realistic standard - a broad definition of firms that grant credit being subject to the CFPB rules, and their supervision and examination Focus of any enhanced regulation of financial products on TBTF banks and financial firms and the unregulated shadow financial industry - efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products - holding all of the other financial service providers up to the existing high standards for compliance with consumer laws, rules and regulations as currently attained by community banks De Novo Community Bank Formation and the Dual Banking System/Charter Choice Newly chartered (de novo) community banks importance in maintaining a strong, growing, evolving and vibrant banking profession - FDICs inhibiting de novo community bank formation during the financial crisis, FDICs indication of a change in policy direction by rescinding its Financial Institution Letter (FIL) 50-2009, Enhanced Supervisory Procedures for Newly Insured FDIC-Supervised Depository Institutions The importance of the dual banking system where chartering and supervision is divided between the federal government and the states - community banks choice of charters that best fits their business model - multi-agency (state and federal) regulators and charter choice providing necessary checks and balances on the power of the regulators, as well as improved rulemaking, the benefit of each agencies expertise and experience is brought to bear on complex and controversial issues Federal Home Loan Bank System Federal Home Loan Banks (FHLBs) strong partnership with community banks - providing short-term liquidity, long-term funding and other financial products that serve the needs of all member-owners - providing lendable funds for the local communities - regional structure, special functions and purposes of the FHLBs recognized and maintained by the Federal Housing Finance Agency (FHFA). FHFAs proposed rulemaking to revise FHLB membership eligibility requirements - negative impact on the FHLB System and its members - precedent set to terminate through rulemaking FHLB membership and the threat to revisit the broader membership issue in the future - contrary to the will of Congress FHLB System position as a healthy, stable and reliable source of funding for its members - not as the sole aggregator or securitizer of residential mortgages for community banks - FHFAs imposition of an ongoing housing mission asset test on community financial institutions Excessive Intervention in Monetary Policy Sustained record-low zero interest rate policy (ZIRP) engineered and implemented by the Federal Reserve System - disproportionally impact on community banks, senior citizens and savers - a significant drag on the earnings of community banks - THBF banks with non-traditional banking business lines derive a much lower percentage of their earnings from net interest margins and are not as negatively impacted - limits to what Fed monetary policy can accomplish considering major offsetting negative effects on community banks, senior citizens, and savers Legislation - H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House and Senate) H.R. 4950 - Small Financial Institution Advisory Committee Act of 2016 (creates a Treasury Department community bank advisory committee) (All sections) (House and Senate) Comment Letters - Comment Letter - OCC, FDIC and Federal Reserve - Incentive-Based Compensation Arrangements: OCC 12 CFR Part 42, Docket No. OCC-2011-0001, RIN 1557-AD39; Federal Reserve System 12 CFR Part 236, Docket No. R-1536, RIN 7100 AE-50; Federal Deposit Insurance Corporation 12 CFR Part 372, RIN 3064-AD86 Miscellaneous - Regarding Federal Reserve Bank of Chicago meeting - dual banking system, electronic delivery of loan files for examinations, prolonged low interest rate environment, shared examination responsibility with other regulators, Financial Accounting Standards Boards (FASB) Current Expected Credit Loss model (CECL) (Federal Reserve) Regarding letter to Illinois Congressional Delegation - the duration, scope and severity of the massive wrongdoing at Wells Fargo, differenced between Main Street and Wall Street, destructive business model, regulatory relief for community banks (House and Senate) Regarding House meeting - Treasury Department community bank study and Treasury Department Community Bank Advisory Committee (House)

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

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate, Federal Reserve) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Data, Cyber and Payment Card Security (Data Security) Wide-scale data security breaches at national retail chain stores and other entities - community banks reissuing credit and debit cards at a significant cost - community banks on the frontline of defending against cyber security threats and strong guardians of the security and confidentiality of customer information - central to maintaining public trust and the key to long-term customer retention Core data security principals - cost of data breaches borne by that party that caused the breach - all participants in the payment system (including merchants) should be subject to Gramm-Leach-Bliley Act-like data security standards - a national data security breach and notification standard should replace the current patchwork of state laws - and any new data security standards should ensure that community banks are not burdened with having to implement and comply with new regulations to achieve the same superior results they currently attain - community banks reliance on third party service providers - delicate balance between securing/sharing appropriate customer information Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate)

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

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, Federal Reserve) Credit Union Taxation and Expansion of Powers - Credit unions distinguishable from community banks - grown to control a significant share of the banking services market - outdated original business model - straying from founding purpose of serving individuals of modest means and with a common bond - same financial services as community banks - justification for federal tax-exempt status in exchange for serving their original mission - credit unions paying their fair share of income taxes - credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district - tax subsidy and level the playing field between credit unions and tax-paying community banks Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L) - the exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks] Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL) - loan growth at the expense of tax-paying community banks - fundamental altering the exclusive member-focused character of credit unions - condition for their original tax exemption Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts - the same Call Report filing requirements for credit unions as those imposed on community banks Support and cooperation of NCUA the cheerleader regulator of credit unions - expansion of membership proposal - weaken the common bond requirement - disregarding Congressional limits - end around Congress. Farm Credit System (FCS) - Expansionist agenda of the Farm Credit System (FCS) - the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status - tax advantages - unfair competitive advantage - follow narrow historic mission - abolish or be subject to taxation and oversight and regulation Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives Support and cooperation of cheerleader regulator of FCS lenders -Farm Credit Administration (FCA) - straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities - FCS significant systemic and taxpayer bail-out risks FCS (the only GSE) in active competition with community banks - public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks) Funding and tax benefit impact on community banks - not following its narrow historical mission - follow narrow mission or abolish FCSystem - abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by TBTFs during the financial crisis - different/modest risks posed by community banks - regulations reflecting those differences - regulatory burden on community banks - one-size-fits-all approach - disproportionate burden of banking laws and regulations on community banks Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks - unlevel playing field - a significant competitive disadvantage for community banks Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies Address excessive, redundant and costly regulations - regulatory accountability - community banks dedicating resources to promoting economic growth - steady increase in regulations over many decades - regulatory threats to community banks and their communities. The Plan for Prosperity: Basel III original intent. accurately identify Systemic Risk additional capital for small holding companies - modernizing the Federal Reserves Policy Statement relief from Securities and Exchange Commission (SEC) rules robust housing market - reform mortgage lending community bank mortgage servicing accountability in bank exams - providing a workable appeals process bank oversight and examinations - better target risk risk targeting in the Volker Rule consumer regulation and inclusive and accountable CFPB governance arbitrary disparate impact fair lending causes of action viability of mutual banks - new charter and capital options rigorous and quantitative cost-benefit analysis - justify new rules red tape in small business lending - eliminating burdensome data collection credit for low and moderate income customers and American agriculture subchapter S corporation constraints Limited Liability Corporation (LLC) option for community banks Bank Qualified (BQ) bond issuer limitations five-year loss carryback to support lending during economic downturns. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation distinguishing and appropriately regulating community banks. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate)

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

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE

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 low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process 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 CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator 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 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 relating to home-based credit unions 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 credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital 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 Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity Issues related to NCUA's Proposed Rule on Member Business Lending Issues related to the Department of Labor's Proposed Rule on the Definition of Fiduciary Issues related to the Telephone Consumer Protection Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the Department of Labor's Proposed Overtime Eligibility rule Issues related to credit union conversions Issues related to the CFPB's proposal on arbitration Issues related to secure payments Issues related to credit union call report modernization H.R. 9, the Innovation Act, all provisions H.R. 22, the FAST Act, Title LXXV, provisions related to privacy notice requirements; Title LXXXII, provisions related to the eligibility of privately insured credit unions to join a Federal Home Loan Bank; Title LXXXIX, provisions related to the designation of rural areas by the Consumer Financial Protection Bureau H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 650, Preserving Access to Manufactured Housing Act, all provision H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 957, the Bureau of Consumer Financial Protection Inspector General Reform Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1090, Retail Investor Protection Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1660, the Federal Savings Association Charter Flexibility Act, all provisions H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2769, the Risk-Based Capital Study Act, all provisions H.R. 2896, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act H.R. 3192, the Homebuyer Assistance Act, all provisions H.R. 4638, the Senior $afe Act, all provisions H.R. 4893, the Risk Management and Homeowner Stability Act, all provisions H.R. 4997, the Home Mortgage Disclosure Adjustment Act, all provisions H.R. 5465, a bill to repeal section 1075 of the Consumer Financial Protection Act of 2010 relating to rules for payment card transactions, all provisions H.R. 5983, the Financial CHOICE Act, all provisions S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I S. 2216, the Senior$afe Act, all provisions The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database Discussion draft of the Financial Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs (CHOICE) Act, all provisions

Client expense: $940,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of

Federal Regulatory Activity OCC guidance on derivatives under Dodd-Frank; CFPB Ability to Repay Rule and Qualified Mortgage Rule; CFPB mortgage servicing final rules (TILA and RESPA); CFPB escrow final rule under Dodd-Frank; CFPB loan originator and mortgage servicing rules; Basel Committee Liquidity Standard; FDIC appraisal requirements under Dodd-Frank; Federal Reserve proposed rule on enhanced prudential standards and early remediation requirements for large foreign banks under Dodd-Frank; Federal banking agency revisions to Call Report rules; FEMA/ National Flood Insurance; OCC lending limits rule; SEC municipal advisor rule, GSE repurchases; Section 619, Dodd-Frank Wall Street Reform and Consumer Protection Act. Final Rule, Volcker Rule, IRS Regulation 67(e), FDIC brokered Deposits rule; Department of Labor Fiduciary Rule Federal Legislative Activity Cybersecurity legislation: (H.R. 1731, S.1927, S.961); Regulatory Relief bills (H.R. 601, H.R. 1259, H.R.1480, H.R.1265, H.R. 685, S.774, S.1484, H.R.1553), Community Banks legislation (H.R. 1389, H.R. 1233), Portfolio Lending relief (H.R.1210); credit union tax treatment (H.R. 1188), Mutual Bank legislation (H.R.4252); Mutual Charter Relief (H.R. 1660, H.R. 1661), Patent Troll relief (S.1137), the TAILOR Act (H.R.2896), Highway Trust Fund/ Federal Reserve Dividend; Retail Investor Protection Act (H.R. 1090); TILA RESPA Safe Harbor (H.R.3192); Interchange Fees (H.R.5465); Data Security Act (H.R. 2205)

Client expense: $35,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA)

H.R. 989, supplemental capital. H.R. 1188 member business lending. H.R. 1133 veterans exemption to member business lending cap. H.R. 299 privately insured credit unions. H.R. 601 privacy notifications.H.R. 1422 residential parity. H.R. 2679, risk based capital stop and study act. S. 1484, regulatory relief. S.2028, member business lending. S. 1440, residential parity. S. 961, data security. Merchant data breaches as they apply to financial institutions. EMV chip-card conversions. National Credit Union Administration and Consumer Financial Protection Bureau regulatory issues. Proposed rules on Field of Membership and Member Business Lending. Credit union examinations. Risk-based capital. Truth in lending disclosures (TRID). HMDA Home Mortgage Disclosure Act. Community lender exemption authority to Dodd-Frank Wall Street Reform and Consumer Protection Act. Property Assessed Clean Energy (PACE) lending and priority liens. Fair Credit Reporting Act - Federal Trade Commission.

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE

Supplemental capital issues, regulatory issues for credit unions and tax exemption status: HR185; HR 766; HR 957; HR 989; HR 1133; HR 1176; HR 1188; HR 1266; HR 1422; HR 1486; HR 1491; HR 1529; HR 1550; HR 1660; HR 1661; HR 1941; HR 2099; HR 2213; HR 2473; HR 2477; HR 2642; HR 2769;HR 2896; HR 3557; HR 3738; HR 3808; HR 3857; HR 4099; HR 4166; HR 4210; HR 4248; HR 4347; HR 4500; HR 4538; HR 4620; HR 4647; HR 4781; HR 4894; HR 4913; HR 4997; HR 5112; HR 5211; HR 5413; HR 5419; HR 5453; HR 5465; HR 5490; HR 5491; HR 5521; HR 5522; HR 5523; HR 5527; HR 5569; S. 423; S. 482; S. 726; S. 774; S. 924; S. 970; S. 1383; S. 1440; S. 1484; S. 1491; S. 2028; S. 2038; S. 2216; S. 2315; S.2663; S 2722; data security and cybersecurity; patent reform; FHLB membership rules; CFPB and FSOC reform; and GSE reform.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.924/H.R.2287, National Credit Union Administration Budget Transparency Act, all provisions; H.R.1188/S.2028, Credit Union Small Business Jobs Creation Act, all provisions; S.1484, Financial Regulatory Improvement Act of 2015, all provisions; S.961/H.R.2205, Data Security Act of 2015, all provisions; H.R.5485/S.3067, FY2017 Financial Services and General Government Appropriations Act, issues involving CFPB regulatory authority; CFPB regulatory relief for small institutions.

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.924/H.R.2287, National Credit Union Administration Budget Transparency Act, all provisions; H.R.1188/S.2028, Credit Union Small Business Jobs Creation Act, all provisions; S.1484, Financial Regulatory Improvement Act of 2015, all provisions; S.961/H.R.2205, Data Security Act of 2015, all provisions; H.R.5485/S.3067, FY2017 Financial Services and General Government Appropriations Act, issues involving CFPB regulatory authority; CFPB regulatory relief for small institutions.

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Credit Availability S1484 - The Financial Regulatory Improvement Act of 2015 Fees and Points in the QM ATR Rules of Dodd-Frank HR685 - Mortgage Choice Act of 2015 Student Loan Debt HR970 - Supporting Academic Freedom through Regulatory Relief Act HR1131 - Fairness in Student Loan Lending Act HR1434 - Bank on Students Emergency Loan Refinancing Act HR3179 - Empowering Students Through Enhanced Financial Counseling Act HR3180 - Flexible Pell Grant for 21st Century Students Act HR4162 - Credit Access and Inclusion Act of 2015 HR4652 - CLEAR Act S85 - Repay Act of 2015 S108 - Financial Aid Simplification and Transparency Act of 2015 S729 - Fairness for Struggling Students Act of 2015 S793 - Bank on Students Emergency Loan Refinancing Act S840 - Student Loan Borrower Bill of Rights S1948 - AFFORD Act S2043 - Know Before You Owe Federal Student Loan Act of 2015 S2677 - In the Red Act of 2016 Credit Union Lending HR1188 - Credit Union Small Business Job Creations Act CFPB Reform HR1266 - Financial Product Safety Commission Act of 2015 S510 - CFPB-IG Act of 2015 Access to Manufactured Housing HR650 - Preserving Access to Manufactured Housing Act of 2015 S682 - Preserving Access to Manufactured Housing Act of 2015 GSE Reform HR22 - DRIVE Act HR1491 - Partnership to Strengthen Homeownership Act of 2015 HR2029 - Consolidated Appropriations Act, 2016 HR__ - Housing Finance Restructuring Act of 2016 HR__ - Moving Housing Forward Act S2038 - Jumpstart GSE Reform Act Guarantee Fees S752 - A bill to establish a scorekeeping rule to ensure that increases in guarantee fees of Fannie Mae and Freddie Mac shall not be used to offset provisions that increase the deficit. HConRes125 - Establishing the congressional budget for the United States Government for fiscal year 2017 and setting forth the appropriate budgetary levels for fiscal years 2018 through 2026. RESPA/TILA Amendments/TRID HR1113 - Portfolio Lending and Mortgage Access Act HR1210 - Portfolio Lending and Mortgage Access Act HR3192 - Homebuyers Assistance Act S1711 - A bill to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. Short Sales HR4812 - Prompt Notification of Short Sales Act Mortgage Servicing Assets HR2029 - Consolidated Appropriations Act, 2016 Alternative Credit Scoring HR3035 - Credit Access and Inclusion Act of 2015 HR4211 - Credit Score Competition Act of 2015 HR4893 - Risk Management and Homeowner Stability Act of 2016 S2355 - Credit Access and Inclusion Act of 2015 Service Members Foreclosure Relief S2393 - Foreclosure Relief and Extension for Servicemembers Act of 2015 Commercial Risk Retention Rules HR4620 - Preserving Access to CRE Capital Act of 2016 FHFA HR3808 - To require the withdrawal and study of the Federal Housing Finance Agency's proposed rule on Federal Home Loan Bank membership, and for other purposes. Financial Regulatory Reform HR1090 - Retail Investor Protection Act HR2642 - Community Lender Regulatory Relief and Consumer Protection Act of 2015 S1484 - Financial Regulatory Improvement Act of 2015 S1491 - Community Lender Regulatory Relief and Consumer Protection Act of 2015 HR__ - The Financial Choice Act Credit Reporting HR347 - The Facilitating Access to Credit Act HR5282 - The Comprehensive Consumer Credit Reporting Act of 2016 Federal Home Loan Bank HR__ - To amend the Federal Home Loan Bank Act to clarify the definition of an insurance company and to provide Federal Home Loan Bank membership standards for certain captive insurance companies Alternative Lending Sources HR4854 - Supporting America's Innovators Act of 2016 HR4855 - Fix Crowdfunding Act Zombie Foreclosures S__ - Preserving Abandoned Foreclosures and Preserving Communities Act of 2016 Conversations with the Consumer Finance Protection Bureau (CFPB) on TRID/Know Before You Owe and credit reporting. Discussions with the Federal Housing Finance Agency (FHFA) on "Duty to Serve" and g-fees. Discussions with the Small Business Administration to discuss small business lending programs. Discussions with the Treasury on anti-money laundering and appraisal management companies (AMCs). Conversations with the Office of the Comptroller of the Currency (OCC) on banking regulations.

Client expense: $9,380,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Consumer Financial Protection Bureau (CFPB), Energy, Dept of, Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Telecommunications & Information Administration (NTIA), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA)

H.R. 766 Financial Institution Customer Protection Act H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1188 Credit Union Small Business Jobs Creation Act H.R. 1195 The Bureau of Consumer Financial Protection Small Business Advisory Board Act H.R. 1210 Portfolio Lending and Mortgage Access Act H.R. 1233 CLEAR Relief Act H.R. 1334 Holding Company Registration Threshold Equalization Act of 2015 H.R. 1486 The Taking Account of Bureaucrat's Spending Act H.R. 1523 Community Bank Access to Capital Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 1553 Small Bank Exam Cycle Reform Act H.R. 1660 The Federal Savings Association Charter Flexibility Act H.R. 1661 Mutual Bank Capital Opportunity Act H.R. 1766 Right to Lend Act of 2015 H.R. 2205 Data Security Act of 2015 H.R. 2896 Tailor Act of 2015 H.R. 2987 Community Bank Capital Clarification Act H.R. 3705 Financial Regulatory Clarity Act of 2015 H.R. 3791 A bill to increase Small Bank Holding Policy Statement threshold from $1B to $5B in assets H.R. 4099 CFPB Exam and Reporting Threshold Act H.R. 4116 To amend the Federal Deposit Insurance Act to ensure that reciprocal deposits are not considered to be funds obtained by or through a deposit broker H.R. 4500 The Community Bank Reporting Relief Act H.R. 4950 Small Financial Institution Advisory Committees Act of 2016 H.R. 4993 Homeowner Information Privacy Protection Act H.R. 4997 The Home Mortgage Disclosure Adjustment Act H.R. 5027 To amend the Federal Reserve Act to adjust the circumstances under which Federal reserve bank stock is callable, and for other purposes. H.R. 5076 Main Street Parity Act H.R. 5465 To repeal section 1075 of the Consumer Financial Protection Act of 2010 relating to rules for payment card transactions, and for other purposes. H.R. 5485 Financial Services and General Government Appropriations Act of 2017 S. 482 CFPB Exam and Reporting Threshold Act S. 774 Financial Institutions and Exam Fairness Reform S. 812 The CLEAR Relief Act S. 927 CLEAR Relief Plus Act S. 961 Data Security Act of 2015 S. 970 18-Month Exam Cycle S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act S. 1816 Community Bank Access to Capital Act S. 2471 401 (Kids) Education Savings Account Act of 2016 S. 2722 Federal Savings Association Charter Flexibility Act - all provisions S. 2790 Financial Institutions Customer Protection Act S. 2943 National Defense Authorization Act of 2017 S. 2992 Small Business Lending Oversight Act S. 3067 Financial Services and General Government Appropriations Act of 2017 Call Report Streamlining Capital Access for Community Banks Capital Rules--Basel III CFPB Data Collection CFPB Overdraft CFPB Reforms/Governance CFPB Small Business Data Collection CFPB Small Dollar/Payday Lending Credit Union Business Lending Powers Credit Union Field of Membership Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint EMV Chip Migration Escrow Mortgage Requirements FASB Accounting Rules for Loan Loss Reserves Faster Payments FDIC Small Bank Assessments Federal Reserve Reform Flood Insurance Reform Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Innovation Initiative (FinTech) Interchange Military Bank Leases Military Lending Act Rules Mortgage Lending Reform Mutual Banks Nomination of Amias Gerety as Treasury Asst Sec for Financial Institutions Nominations of Allan Landon and Kathryn Dominguez to the Board of Governors of the Federal Reserve System Online/Marketplace Lending Qualified Mortgages, Ability to Repay Rules Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks Repeal of Durbin Amendment SBA 7(a) Lending Limit Small Bank Holding Company Policy Statement TILA/RESPA Integrated Disclosures Implementation Too Big To Fail Virtual Currency

Client expense: $1,570,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), White House Office

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 low income designation regulations Issues related to NCUA examination procedures Issues related to NCUAs regulation regarding its regulatory flexibility program Issues related to NCUAs proposed rule regarding emergency liquidity Issues related to NCUAs rulemaking process 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 CFPBs Leadership Structure and Installing a Board Rather than Director Issues related to funding the CFPB through the Appropriations Process Issues related to increasing the CFPB Examination Threshold Issues related to conducting a cost-benefit analysis of all CFPB Proposals Issues related to codifying the CFPBs Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to standardizing the definition of mortgage originator 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 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 relating to home-based credit unions 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 credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union by-laws Issues related to credit unions incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to Ginnie Mae capital 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 Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to indirect auto lending Issues related to fixed assets Issues related to merchant data breaches Issues related to the payments system Issues related to FHFA proposed rules and FHLB eligibility for credit unions Issues related to Federal Reserve Regulatory D Issues related to 1-4 Family Non-Owner Occupied Residential Loan Treatment as Residential Rather than Business Loans Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to Housing Finance Reform Issues related to the implementation of the remittances provisions in the Dodd-Frank Act Issues related to NCUAs proposal rule on Member Business Lending Issues related to NCUAs proposed rule on Interest on Lawyer Trust Accounts (IOLTA) Issues related to credit union service to unbanked and underbanked consumers Issues related to the United States Postal Service Office of Inspector General report related to role of the postal service in financial services Issues related to the Feds implementation of same-day ACH Issues related to the regulation of corporate credit unions Issues related to the CFPBs proposed regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the payday, vehicle title, and similar lending Issues related to the CFPBs consumer complaint database Issues related to NCUAs Fixed Assets rule Issues related to NCUAs definition of small entity Issues related to NCUA's Proposed Rule on Member Business Lending Issues related to the Department of Labor's Proposed Rule on the Definition of Fiduciary Issues related to the Telephone Consumer Protection Act Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the Department of Labor's Proposed Overtime Eligibility rule Issues related to credit union conversions Issues related to the CFPB's proposal on arbitration Issues related to secure payments Issues related to credit union call report modernization H.R. 9, the Innovation Act, all provisions H.R. 22, the FAST Act, Title LXXV, provisions related to privacy notice requirements; Title LXXXII, provisions related to the eligibility of privately insured credit unions to join a Federal Home Loan Bank; Title LXXXIX, provisions related to the designation of rural areas by the Consumer Financial Protection Bureau H.R. 185, Regulatory Accountability Act of 2015 H.R. 299, the Capital Access for Small Community Financial Institutions Act of 2015, all provisions H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 H.R. 601, the Eliminate Privacy Notice Confusion Act, all provisions H.R. 650, Preserving Access to Manufactured Housing Act, all provision H.R. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 957, the Bureau of Consumer Financial Protection Inspector General Reform Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation Act, all provisions H.R. 1090, Retail Investor Protection Act, all provisions H.R. 1176, the NCUA Budget Transparency Act, all provisions H.R. 1188, the Credit Union Small Business Jobs Creation Act, all provisions H.R. 1195, the Bureau of Consumer Financial Protection Advisory Boards Act, all provisions H.R. 1210, the Portfolio Lending and Mortgage Access Act, H.R. 1233, the Community Lending Enhancement and Regulatory Relief Act of 2015 H.R. 1259, the Helping Expand Lending Practices in Rural Communities Act, all provisions H.R. 1263, Consumer Financial Protection Safety and Soundness Improvement Act of 2015 H.R. 1265, the Bureau Advisory Commission Transparency Act, all provision H.R. 1266, the Financial Products Safety Commission Act of 2015 H.R. 1408, requiring a study of the capital requirements for mortgage servicing assets H.R. 1422, the Credit Union Residential Loan Parity Act H.R. 1480, the SAFE Confidentiality and Privilege Enhancement Act H.R. 1523, Community Bank Access to Capital Act of 2015 H.R. 1529, the Community Institution Mortgage Relief Act Discussion Draft, Data Security and Breach Notification Act of 2015 H.R. 1660, the Federal Savings Association Charter Flexibility Act, all provisions H.R. 1941, the Financial Institution Examination Fairness and Reform Act H.R. 2205, the Data Security Act H.R. 2213, to provide for a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the Real Estate Settlement Procedures Act of 1974 and the Truth in Lending Act, and for other purposes. H.R. 2287, the National Credit Union Administration Budget Transparency Act H.R. 2473, the Preserving Capital Access and Mortgage Liquidity Act H.R. 2769, the Risk-Based Capital Study Act, all provisions H.R. 2896, the Taking Account of Institutions with Low Operation Risk (TAILOR) Act H.R. 3192, the Homebuyer Assistance Act, all provisions H.R. 4893, the Risk Management and Homeowner Stability Act, all provisions H.R. 5465, a bill to repeal section 1075 of the Consumer Financial Protection Act of 2010 relating to rules for payment card transactions, all provisions S. 423, the Privacy Notice Modernization Act, all provisions S. 482, the Consumer Financial Protection Bureau Examination Reporting Threshold Act of 2015, all provisions S. 774 Financial Institutions Examination Fairness and Reform Act, all provisions S. 871, the Helping Expand Lending Practices in (HELP) Rural Communities Act S. 924, the National Credit Union Administration Budget Transparency Act S. 961, the Data Security Act S. 1367, a bill to amend the Federal Home Loan Bank Act with respect to membership eligibility of certain institutions S. 1440, the Credit Union Residential Loan Parity Act S. 1484, the Financial Regulatory Improvement Act, Title I S. 2216, the Senior$afe Act, all provisions The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database Discussion draft of the Financial Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs (CHOICE) Act, all provisions

Client expense: $1,060,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Small Business Administration (SBA), Treasury, Dept of

Annual Privacy Disclosure Notices:[H.R. 601, S.423, S.1484]; Capital Reform:[ H.R.2769]; Consumer Financial Protection Bureau Improvements:[H.R. 3193, H.R. 1266]; Consumer Financial Protection Bureaus Qualified Mortgage Definition:[H.R. 685, H.R. 1259, S. 871]; Credit Union Tax Exemption:[H.R. 1]; Data Security:[H.R. 2205, S. 961]; Defense Credit Union Issues:[H.R. 1735]; Housing Finance Reform:[S. 1217]; Interchange Fees; Member Business Lending:[H.R. 1133, H.R. 1188, H.R. 1422]; Regulatory Relief:[S. 1484, H.R. 3468]; Supplemental Capital:[H.R.719, H.R. 989]; Financial services and general government appropriations bill [H.R. 5485 FY 17]

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Implementation of Dodd-Frank Wall Street Reform and Consumer Protection Act: Support legislation that would reduce regulatory burden on credit unions. Support passage of legislation to address credit union member business lending, including H.R. 1188. Advocate for stronger data security, particularly with regard to merchant plastic card data breaches. Support credit union access to supplemental capital, including H.R. 989. Support the Privacy Notice Modernization Act, S. 423. Work for a fair and balanced DOL fiduciary rule.

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Banking issues Credit union member - business lending H.R. 1188 - Credit Union Small Business Jobs Creation Act

Client expense: Not reported · Firm income: $27,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Federal Regulatory Activity OCC guidance on derivatives under Dodd-Frank; CFPB Ability to Repay Rule and Qualified Mortgage Rule; CFPB mortgage servicing final rules (TILA and RESPA); CFPB escrow final rule under Dodd-Frank; CFPB loan originator and mortgage servicing rules; Basel Committee Liquidity Standard; FDIC appraisal requirements under Dodd-Frank; Federal Reserve proposed rule on enhanced prudential standards and early remediation requirements for large foreign banks under Dodd-Frank; Federal banking agency revisions to Call Report rules; FEMA/ National Flood Insurance; OCC lending limits rule; SEC municipal advisor rule, GSE repurchases; Section 619, Dodd-Frank Wall Street Reform and Consumer Protection Act. Final Rule, Volcker Rule, IRS Regulation 67(e), FDIC brokered Deposits rule; Department of Labor Fiduciary Rule Federal Legislative Activity Cybersecurity legislation: (H.R. 1731, S.1927, S.961); Regulatory Relief bills (H.R. 601, H.R. 1259, H.R.1480, H.R.1265, H.R. 685, S.774, S.1484, H.R.1553), Community Banks legislation (H.R. 1389, H.R. 1233), Portfolio Lending relief (H.R.1210); credit union tax treatment (H.R. 1188), Mutual Bank legislation (H.R.4252); Mutual Charter Relief (H.R. 1660, H.R. 1661), Patent Troll relief (S.1137), the TAILOR Act (H.R.2896), Highway Trust Fund/ Federal Reserve Dividend; Retail Investor Protection Act (H.R. 1090); TILA RESPA Safe Harbor (H.R.3192); Interchange Fees (H.R.5465); Data Security Act (H.R. 2205)

Client expense: $45,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA)