CLEARR Act of 2015

H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1210 Portfolio Lending and Mortgage Access Act H.R. 1233 CLEAR Relief Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 2213 Safe Harbor Protection in TRID S. 812 The CLEAR Relief Act S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act CFPB Ability to Repay Rule, Small Creditors/Rural GSE Capital Restoration Plans GSE Guarantee Fees as a Budget Offset GSE Reform Home Mortgage Disclosure Act (HMDA) Property Assessed Clean Energy (PACE) Loans Qualified Mortgages Suspension of GSE Dividend Payments to Treasury TRID Implementation Uniform Residential Loan Application Language Preference

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

S, 812 CLEAR Act, Regulatory Relief Legislation, S. 482 the Consumer Financial Protection Bureau Examination and Reporting Threshold Act of 2015, The Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (H.R. 1233), Mortgage Lending Reform, Consumer Financial Protection Bureau reform, Data Security Legislation, Cybersecurity,

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, 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 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 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. 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. 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) 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 Action Alerts - Action Alert - Regarding Payday Lending Rules - Urge CFPB to exempt community banks 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 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. 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

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

H.R. 601, the Eliminate Privacy Notice Confusion Act (to provide an exemption from the Gramm-Leach-Bliley Acts annual notice requirement for institutions that have not changed their privacy policies and only share personal information within the statutory exceptions. S. 423, the Privacy Notice Modernization Act (counterpart to H.R. 601). H.R. 1113, the Portfolio Lending and Mortgage Access Act; H.R. 1210, the Portfolio Lending and Mortgage Access Act (would provide that loans originated and held in portfolio are treated as Qualified Mortgages). H.R. 1233, the CLEARR Act of 2015 (to provide an exemption from the Gramm-Leach-Bliley Acts annual notice requirement). S. 812, the CLEAR Relief Act of 2015 (a companion bill to H.R. 1233). H.R. 888, Subsidy Reserve Act of 2015, to require nonbank financial companies supervised by the Federal Reserve Board and bank holding companies over $500 billion of assets to establish and maintain Subsidy Reserves. H.R. 1389, the American Jobs and Community Revitalization Act (provides a QM Safe Harbor for loans held in portfolio and establishes an application process for treatment as a rural or underserved area for purposes of QM. H.R. 1408, The Mortgage Servicing Asset Capital Requirements Act (postpones Basel III rules on mortgage servicing assets until their impact can be studied). H.R. 1529, the Community Institution Mortgage Relief Act (provides a legal safe harbor from escrow requirements for smaller institutions that hold loans in portfolio for three years). H.R. 3468, Credit Union Share Insurance Fund Parity Act (amended the Federal Credit Union Act to extend insurance coverage to IOLTAs.) H.R. 3791, to raise the consolidated assets threshold under the small bank holding company policy statement. H.R. 1334, the Holding Company Registration Threshold Equalization Act H.R. 1259/ S. 871, the Helping Expand Lending Practices (HELP) in Rural Communities Act S. 1484, the Financial Regulatory Improvement Act of 2015 H.R. 2896/S.3153, the TAILOR Act H.R. 766/S. 2790, the Financial Institution Consumer Protection Act of 2015 H.R. 1553, the Small Bank Exam Cycle Reform Act of 2015 H.R. 4116/S.3373, to ensure that the reciprocal deposits of an insured depository institution are not considered to be funds obtained by or through a deposit broker H.R. 5660, Retail Checking Account Protection Act of 2016 H.R. 4500, Community Bank Reporting Relief Act H.R 2209, to require the appropriate federal banking agencies to treat certain municipal obligations as level 2A liquid assets H.R. 5027, to amend the Federal Reserve Act to adjust the circumstances under which Federal Reserve bank stock is callable 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. 6162, to ensure that prepaid funds deposited in an insured depository institution satisfy the requirements of the primary purpose exclusion to the definition of deposit broker S. 3404, to require the appropriate Federal banking agencies to treat certain municipal obligations as level 2B liquid assets Basel Capital Rules Basel Liquidity Rules Accountability for Basel/FSB negotiations Volcker Rule Reform DoL Fiduciary Rule H.R. 5983, The Financial CHOICE Act De novo banks

Client expense: $2,840,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE

Loans for component suppliers PL 111-203: Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 601 - Eliminate Privacy Notice Confusion Act S. 423 - Privacy Notice Modernization Act of 2015 H.R. 1233 - Community Lending Enhancement And Regulatory Relief (CLEARR) Act of 2015 H.R. 1265 - Bureau Advisory Commission Transparency Act H.R. 37 - Promoting Job Creation and Reducing Small Business Burdens Act H.R. 26 - Terrorism Risk Insurance Program Reauthorization Act of 2015 H.R. 2289 Commodity End-User Relief Act H.R. 1737 - Reforming CFPB Indirect Auto Financing Guidance Act S. 2663 - Reforming CFPB Indirect Auto Financing Guidance Act

Client expense: $1,134,183 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Surface Transportation Board (STB), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

PL 111-203: Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 601 - Eliminate Privacy Notice Confusion Act S. 423 - Privacy Notice Modernization Act of 2015 H.R. 1233 - Community Lending Enhancement And Regulatory Relief (CLEARR) Act of 2015 H.R. 1265 - Bureau Advisory Commission Transparency Act H.R. 37 - Promoting Job Creation and Reducing Small Business Burdens Act H.R. 26 - Terrorism Risk Insurance Program Reauthorization Act of 2015 H.R. 2289 - Commodity End-User Relief Act H.R. 1737 - Reforming CFPB Indirect Auto Financing Guidance Act S. 2663 - Reforming CFPB Indirect Auto Financing Guidance Act

Client expense: $1,134,183 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Surface Transportation Board (STB), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

H.R. 601- Consumer Financial Products H.R. 888- Dodd-Frank amendment H.R. 1233- Regulatory Relief H.R. 1262- Consumer Financial Products H.R. 1264- Consumer Financial Products H.R. 1266- Financial Product Safety Commission H.R. 1550- Financial Stability Oversight Council (FSOC) H.R. 1965- Securities and Exchange Commission (SEC) H.R. 2029- Appropriations H.R. 2099- Consumer Financial Products H.R. 3340- FSOC H.R. 3189- Federal Reserve H.R. 3557- FSOC H.R. 3738- Data Security H.R. 3857- FSOC H.R. 4538- Senior Citizens; Finance H.R. 5983- Financial CHOICE Act of 2016 S. 2038- Finance Reform S. 2216- Senior Citizens; Finance

Client expense: $790,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Highway Administration (FHA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Natl Geospatial Intelligence Agency, Natl Highway Traffic Safety Administration (NHTSA), Natl Transportation Safety Board (NTSB), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Issues related to: Anti-Money Laundering (AML); S. 3067 and H.R. 5485 - FY17 Financial Services and General Government appropriations; Credit Card/Interchange Fees; Retirement Security; Data Breach; Automobile Financing; Arbitration; Structure and Activities of the Office of Financial Research; S. 510 Bureau of Consumer Financial Protection-Inspector General Reform Act; S. 774 Financial Institutions Examination Fairness and Reform Act; H.R. 185 Regulatory Accountability Act; H.R. 601 Eliminate Privacy Notice Confusion Act; H.R.1233 Community Lending Enhancement and Regulatory Relief Act of 2015; H.R.37 Promoting Job Creation and Reducing Small Business Burdens Act; S. 961 The Data Security Act; H.R 2205 The Data Security Act; H.R.1550 Financial Stability Oversight Council Improvement Act of 2015; H.R 1266 Financial Product Safety Commission Act; Federal Reserve Dividend Revenue; S. 1484 Financial Regulatory Improvement Act; H.R. 3738, Office of Financial Research Accountability Act of 2015; Implications of the Federal Reserve dividend reduction section contained in PL 114-94, the Drive Act; Senior $afe Act (H.R.4538; S.2216); Financial Stability Oversight Council Reform Act (H.R.3340; issues related to cybersecurity and financial services; H.R. 1309 - Systemic Risk Designation Improvement Act of 2015; S.2251, Seniors And Veterans Emergency Benefits Act or the SAVE Benefits Act; Retirement Enhancement and Savings Act; H.R. 5983, Financial CHOICE Act,Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs.

Client expense: $950,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), 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)

EGRPRA Regulatory Review - Identify provisions that my provide regulatory relief. HR 1660 - Federal Savings Association Charter Flexibility Act of 2015 - HOLA amendments providing flexibility to operate as a national bank. CFPB revision package - Provisions subjecting the agency to additional oversight. HR 9 - The Innovation Act - Provisions addressing vague demand letter of patent trolls. HR 601 - Provisions eliminating privacy notice disclosure requirements. HR 1265 - Bureau Advisory Commission Transparency Act - Advisory counsel for the CFPB HR 1480 SAFE Act - confidentiality of information banks share with state regulators. HR 1660-Federal Savings Association Charter Flexibility Act - charter flexibility HR 1233 - CLEARR Act - Regulatory reduction provisions S 1484-Financial Regulation Improvement Act - Regulatory reduction provisions. S 2896 - TAILOR Act- Regulatory reduction provisions H1941/S774 - Financial Institutions Examination Fairness & Reform Act - timely & consistent examination report provisions. HR 5465 - Durbin Amendment repeal bill - repeal provisions. HR 2213 - Provisions for a formal grace period from enforcement under TILA-RESPA. HR 601 - Eliminate Privacy Notice Confusion Act - privacy notice exemptions. HR 1478/S798 - Policyholder Protection Act - Source of strength provisions.

Client expense: $158,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), 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

H.R. 601- Consumer Financial Products H.R. 888- Dodd-Frank amendment H.R. 1233- Regulatory Relief H.R. 1262- Consumer Financial Products H.R. 1264- Consumer Financial Products H.R. 1266- Financial Product Safety Commission H.R. 1550- Financial Stability Oversight Council (FSOC) H.R. 1965- Securities and Exchange Commission (SEC) H.R. 2029- Appropriations H.R. 2099- Consumer Financial Products H.R. 3340- FSOC H.R. 3189- Federal Reserve H.R. 3557- FSOC H.R. 3738- Data Security H.R. 3857- FSOC H.R. 4538- Senior Citizens; Finance H.R. 5983- Financial CHOICE Act of 2016 S. 2038- Finance Reform S. 2216- Senior Citizens; Finance

Client expense: Not reported · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Highway Administration (FHA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Natl Geospatial Intelligence Agency, Natl Highway Traffic Safety Administration (NHTSA), Natl Transportation Safety Board (NTSB), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

S, 812 CLEAR Act, Regulatory Relief Legislation, S. 482 the Consumer Financial Protection Bureau Examination and Reporting Threshold Act of 2015, The Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (H.R. 1233), Mortgage Lending Reform, Consumer Financial Protection Bureau reform, Data Security Legislation, Cybersecurity,

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 601, the Eliminate Privacy Notice Confusion Act (to provide an exemption from the Gramm-Leach-Bliley Acts annual notice requirement for institutions that have not changed their privacy policies and only share personal information within the statutory exceptions. S. 423, the Privacy Notice Modernization Act (counterpart to H.R. 601). H.R. 1113, the Portfolio Lending and Mortgage Access Act; H.R. 1210, the Portfolio Lending and Mortgage Access Act (would provide that loans originated and held in portfolio are treated as Qualified Mortgages). H.R. 1233, the CLEARR Act of 2015 (to provide an exemption from the Gramm-Leach-Bliley Acts annual notice requirement). S. 812, the CLEAR Relief Act of 2015 (a companion bill to H.R. 1233). H.R. 888, Subsidy Reserve Act of 2015, to require nonbank financial companies supervised by the Federal Reserve Board and bank holding companies over $500 billion of assets to establish and maintain Subsidy Reserves. H.R. 1389, the American Jobs and Community Revitalization Act (provides a QM Safe Harbor for loans held in portfolio and establishes an application process for treatment as a rural or underserved area for purposes of QM. H.R. 1408, The Mortgage Servicing Asset Capital Requirements Act (postpones Basel III rules on mortgage servicing assets until their impact can be studied). H.R. 1529, the Community Institution Mortgage Relief Act (provides a legal safe harbor from escrow requirements for smaller institutions that hold loans in portfolio for 3 years). H.R. 3468, Credit Union Share Insurance Fund Parity Act (amended the Federal Credit Union Act to extend insurance coverage to IOLTAs.) H.R. 3791, to raise the consolidated assets threshold under the small bank holding company policy statement. H.R. 1334, the Holding Company Registration Threshold Equalization Act H.R. 1259/ S. 871, the Helping Expand Lending Practices (HELP) in Rural Communities Act S. 1484, the Financial Regulatory Improvement Act of 2015 H.R. 2896/S.3153, the TAILOR Act H.R. 766/S. 2790, the Financial Institution Consumer Protection Act of 2015 H.R. 1553, the Small Bank Exam Cycle Reform Act of 2015 H.R. 4116, to ensure that the reciprocal deposits of an insured depository institution are not considered to be funds obtained by or through a deposit broker H.R. 5660, Retail Checking Account Protection Act of 2016 H.R. 4500, Community Bank Reporting Relief Act H.R 2209, to require the appropriate federal banking agencies to treat certain municipal obligations as level 2A liquid assets H.R. 5027, to amend the Federal Reserve Act to adjust the circumstances under which Federal Reserve bank stock is callable 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. 6162, to ensure that prepaid funds deposited in an insured depository institution satisfy the requirements of the primary purpose exclusion to the definition of deposit broker S. 3404, to require the appropriate Federal banking agencies to treat certain municipal obligations as level 2B liquid assets Basel Capital Rules Basel Liquidity Rules Accountability for Basel/FSB negotiations Volcker Rule Reform DoL Fiduciary Rule H.R. 5983, The Financial CHOICE Act De novo banks

Client expense: $1,980,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE

Loans for component suppliers PL 111-203: Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 601 - Eliminate Privacy Notice Confusion Act S. 423 - Privacy Notice Modernization Act of 2015 H.R. 1233 - Community Lending Enhancement And Regulatory Relief (CLEARR) Act of 2015 H.R. 1265 - Bureau Advisory Commission Transparency Act H.R. 37 - Promoting Job Creation and Reducing Small Business Burdens Act H.R. 26 - Terrorism Risk Insurance Program Reauthorization Act of 2015 H.R. 2289 Commodity End-User Relief Act H.R. 1737 - Reforming CFPB Indirect Auto Financing Guidance Act S. 2663 - Reforming CFPB Indirect Auto Financing Guidance Act

Client expense: $1,157,821 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Surface Transportation Board (STB), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

PL 111-203: Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 601 - Eliminate Privacy Notice Confusion Act S. 423 - Privacy Notice Modernization Act of 2015 H.R. 1233 - Community Lending Enhancement And Regulatory Relief (CLEARR) Act of 2015 H.R. 1265 - Bureau Advisory Commission Transparency Act H.R. 37 - Promoting Job Creation and Reducing Small Business Burdens Act H.R. 26 - Terrorism Risk Insurance Program Reauthorization Act of 2015 H.R. 2289 - Commodity End-User Relief Act H.R. 1737 - Reforming CFPB Indirect Auto Financing Guidance Act S. 2663 - Reforming CFPB Indirect Auto Financing Guidance Act

Client expense: $1,157,821 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Surface Transportation Board (STB), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

EGRPRA Regulatory Review - Identify provisions that my provide regulatory relief. HR 1660 - Federal Savings Association Charter Flexibility Act of 2015 - HOLA amendments providing flexibility to operate as a national bank. CFPB revision package - Provisions subjecting the agency to additional oversight. HR 9 - The Innovation Act - Provisions addressing vague demand letter of patent trolls. HR 601 - Provisions eliminating privacy notice disclosure requirements. HR 1265 - Bureau Advisory Commission Transparency Act - Advisory counsel for the CFPB HR 1480 SAFE Act - confidentiality of information banks share with state regulators. HR 1660-Federal Savings Association Charter Flexibility Act - charter flexibility HR 1233 - CLEARR Act - Regulatory reduction provisions S 1484-Financial Regulation Improvement Act - Regulatory reduction provisions. S 2896 - TAILOR Act- Regulatory reduction provisions H1941/S774 - Financial Institutions Examination Fairness & Reform Act - timely & consistent examination report provisions. HR 5465 - Durbin Amendment repeal bill - repeal provisions. HR 2213 - Provisions for a formal grace period from enforcement under TILA-RESPA. HR 601 - Eliminate Privacy Notice Confusion Act - privacy notice exemptions. HR 1478/S798 - Policyholder Protection Act - Source of strength provisions.

Client expense: $288,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE

Issues related to: Anti-Money Laundering (AML); S. 3067 and H.R. 5485 - FY17 Financial Services and General Government appropriations; Credit Card/Interchange Fees; Retirement Security; Data Breach; Automobile Financing; Arbitration; Structure and Activities of the Office of Financial Research; S. 510 Bureau of Consumer Financial Protection-Inspector General Reform Act; S. 774 Financial Institutions Examination Fairness and Reform Act; H.R. 185 Regulatory Accountability Act; H.R. 601 Eliminate Privacy Notice Confusion Act; H.R.1233 Community Lending Enhancement and Regulatory Relief Act of 2015; H.R.37 Promoting Job Creation and Reducing Small Business Burdens Act; S. 961 The Data Security Act; H.R 2205 The Data Security Act; H.R.1550 Financial Stability Oversight Council Improvement Act of 2015; H.R 1266 Financial Product Safety Commission Act; Federal Reserve Dividend Revenue; S. 1484 Financial Regulatory Improvement Act; H.R. 3738, Office of Financial Research Accountability Act of 2015; Implications of the Federal Reserve dividend reduction section contained in PL 114-94, the Drive Act; Senior $afe Act (H.R.4538; S.2216); Financial Stability Oversight Council Reform Act (H.R.3340; issues related to cybersecurity and financial services; H.R. 1309 - Systemic Risk Designation Improvement Act of 2015; S.2251, Seniors And Veterans Emergency Benefits Act or the SAVE Benefits Act; Retirement Enhancement and Savings Act; H.R. 5983, Financial CHOICE Act,Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs.

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

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

H.R. 601- Consumer Financial Products H.R. 888- Dodd-Frank amendment H.R. 1233- Regulatory Relief H.R. 1262- Consumer Financial Products H.R. 1264- Consumer Financial Products H.R. 1266- Financial Product Safety Commission H.R. 1550- Financial Stability Oversight Council (FSOC) H.R. 1965- Securities and Exchange Commission (SEC) H.R. 2029- Appropriations H.R. 2099- Consumer Financial Products H.R. 3340- FSOC H.R. 3189- Federal Reserve H.R. 3557- FSOC H.R. 3738- Data Security H.R. 3857- FSOC H.R. 4538- Senior Citizens; Finance H.R. 5983- Financial CHOICE Act of 2016 S. 2038- Finance Reform S. 2216- Senior Citizens; Finance

Client expense: $1,010,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Highway Administration (FHA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Natl Geospatial Intelligence Agency, Natl Highway Traffic Safety Administration (NHTSA), Natl Oceanic & Atmospheric Administration (NOAA), Natl Transportation Safety Board (NTSB), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

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

H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1210 Portfolio Lending and Mortgage Access Act H.R. 1233 CLEAR Relief Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 2213 Safe Harbor Protection in TRID S. 812 The CLEAR Relief Act S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act CFPB Ability to Repay Rule, Small Creditors/Rural GSE Capital Restoration Plans GSE Guarantee Fees as a Budget Offset GSE Reform Home Mortgage Disclosure Act (HMDA) Property Assessed Clean Energy (PACE) Loans Qualified Mortgages Suspension of GSE Dividend Payments to Treasury TRID Implementation Uniform Residential Loan Application Language Preference

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

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) 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 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 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) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (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)

S, 812 CLEAR Act, Regulatory Relief Legislation, S. 482 the Consumer Financial Protection Bureau Examination and Reporting Threshold Act of 2015, The Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (H.R. 1233), Mortgage Lending Reform, Consumer Financial Protection Bureau reform, Data Security Legislation, Cybersecurity,

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

PL 111-203: Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 601 - Eliminate Privacy Notice Confusion Act S. 423 - Privacy Notice Modernization Act of 2015 H.R. 1233 - Community Lending Enhancement And Regulatory Relief (CLEARR) Act of 2015 H.R. 1265 - Bureau Advisory Commission Transparency Act H.R. 37 - Promoting Job Creation and Reducing Small Business Burdens Act H.R. 26 - Terrorism Risk Insurance Program Reauthorization Act of 2015 H.R. 2289 - Commodity End-User Relief Act H.R. 1737 - Reforming CFPB Indirect Auto Financing Guidance Act S. 2663 - Reforming CFPB Indirect Auto Financing Guidance Act

Client expense: $1,177,805 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Surface Transportation Board (STB), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Loans for component suppliers PL 111-203: Dodd-Frank Wall Street Reform and Consumer Protection Act H.R. 601 - Eliminate Privacy Notice Confusion Act S. 423 - Privacy Notice Modernization Act of 2015 H.R. 1233 - Community Lending Enhancement And Regulatory Relief (CLEARR) Act of 2015 H.R. 1265 - Bureau Advisory Commission Transparency Act H.R. 37 - Promoting Job Creation and Reducing Small Business Burdens Act H.R. 26 - Terrorism Risk Insurance Program Reauthorization Act of 2015 H.R. 2289 Commodity End-User Relief Act H.R. 1737 - Reforming CFPB Indirect Auto Financing Guidance Act S. 2663 - Reforming CFPB Indirect Auto Financing Guidance Act

Client expense: $1,177,805 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Surface Transportation Board (STB), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

H.R. 601, the Eliminate Privacy Notice Confusion Act (to provide an exemption from the Gramm-Leach-Bliley Acts annual notice requirement for institutions that have not changed their privacy policies and only share personal information within the statutory exceptions. S. 423, the Privacy Notice Modernization Act (counterpart to H.R. 601). H.R. 1113, the Portfolio Lending and Mortgage Access Act; H.R. 1210, the Portfolio Lending and Mortgage Access Act (would provide that loans originated and held in portfolio are treated as Qualified Mortgages). H.R. 1233, the CLEARR Act of 2015 (to provide an exemption from the Gramm-Leach-Bliley Acts annual notice requirement). S. 812, the CLEAR Relief Act of 2015 (a companion bill to H.R. 1233). H.R. 888, Subsidy Reserve Act of 2015, to require nonbank financial companies supervised by the Federal Reserve Board and bank holding companies over $500 billion of assets to establish and maintain Subsidy Reserves. H.R. 1389, the American Jobs and Community Revitalization Act (provides a QM Safe Harbor for loans held in portfolio and establishes an application process for treatment as a rural or underserved area for purposes of QM. H.R. 1408, The Mortgage Servicing Asset Capital Requirements Act (postpones Basel III rules on mortgage servicing assets until their impact can be studied). H.R. 1529, the Community Institution Mortgage Relief Act (provides a legal safe harbor from escrow requirements for smaller institutions that hold loans in portfolio for 3 years). H.R. 3468, Credit Union Share Insurance Fund Parity Act (amended the Federal Credit Union Act to extend insurance coverage to IOLTAs.) H.R. 3791, to raise the consolidated assets threshold under the small bank holding company policy statement. H.R. 1334, the Holding Company Registration Threshold Equalization Act H.R. 1259/ S. 871, the Helping Expand Lending Practices (HELP) in Rural Communities Act S. 1484, the Financial Regulatory Improvement Act of 2015 H.R. 2896, the TAILOR Act H.R. 766/S. 2790, the Financial Institution Consumer Protection Act of 2015 H.R. 1553, the Small Bank Exam Cycle Reform Act of 2015 H.R. 4500, Community Bank Reporting Relief Act H.R 2209, to require the appropriate federal banking agencies to treat certain municipal obligations as level 2A liquid assets H.R. 5027, to amend the Federal Reserve Act to adjust the circumstances under which Federal reserve bank stock is callable 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 Basel Capital Rules Basel Liquidity Rules Accountability for Basel/FSB negotiations Volcker Rule Reform DoL Fiduciary Rule CHOICE Act

Client expense: $2,300,000 · Firm income: Not reported

Government targets: Defense, Dept of (DOD), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE

H.R. 601- Consumer Financial Products H.R. 888- Dodd-Frank amendment H.R. 1233- Regulatory Relief H.R. 1262- Consumer Financial Products H.R. 1264- Consumer Financial Products H.R. 1266- Financial Product Safety Commission H.R. 1550- Financial Stability Oversight Council (FSOC) H.R. 1965- Securities and Exchange Commission (SEC) H.R. 2029- Appropriations H.R. 2099- Consumer Financial Products H.R. 3340- FSOC H.R. 3189- Federal Reserve H.R. 3557- FSOC H.R. 3738- Data Security H.R. 3857- FSOC No#- Financial CHOICE Act of 2016 S. 2038- Finance Reform

Client expense: $1,420,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Highway Administration (FHA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Natl Geospatial Intelligence Agency, Natl Highway Traffic Safety Administration (NHTSA), Natl Oceanic & Atmospheric Administration (NOAA), Natl Transportation Safety Board (NTSB), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

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

H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1233 CLEAR Relief Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 2213 Safe Harbor Protection in TRID S. 812 The CLEAR Relief Act S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act CFPB Ability to Repay Rule, Small Creditors/Rural GSE Capital Restoration Plans GSE Guarantee Fees as a Budget Offset GSE Reform Home Mortgage Disclosure Act (HMDA) Qualified Mortgages Suspension of GSE Dividend Payments to Treasury TRID Implementation Uniform Residential Loan Application Language Preference

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

Financial Services, Implementation of Dodd-Frank Legislation Regulatory Reform Legislation Community Banking Relief Legislation HR 1529 - Community Institution Mortgage Relief Act of 2015 HR 1210 - Portfolio Lending and Mortgage Access Act of 2015 Export-Import Bank Reauthorization HR 1233 - CLEARR Act of 2015 HR 1309 - Systemic Risk Designation Improvement Act of 2015 HE 1389 - The American Jobs and Community Revitalization Act of 2015

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

Government targets: Consumer Product Safety Commission (CPSC), Federal Deposit Insurance Corporation (FDIC), HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

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

Issues related to: Anti-Money Laundering (AML); S. 3067 and H.R. 5485 - FY17 Financial Services and General Government appropriations; Credit Card/Interchange Fees; Retirement Security, Department of Labor definition of fiduciary duty (H.J.Res.88; S.J.Res.33); Data Breach; Automobile Financing; Arbitration; Structure and Activities of the Office of Financial Research; S. 510 Bureau of Consumer Financial Protection-Inspector General Reform Act; S. 774 Financial Institutions Examination Fairness and Reform Act; H.R. 185 Regulatory Accountability Act; H.R. 601 Eliminate Privacy Notice Confusion Act; H.R.1233 Community Lending Enhancement and Regulatory Relief Act of 2015; H.R.37 Promoting Job Creation and Reducing Small Business Burdens Act; S.1484 Financial Regulatory Improvement Act of 2015; S. 961 The Data Security Act; H.R 2205 The Data Security Act; H.R.1550 Financial Stability Oversight Council Improvement Act of 2015; H.R 1266 Financial Product Safety Commission Act; Federal Reserve Dividend Revenue; H.R. 1090 Retail Investor Protection Act; S. 1484 Financial Regulatory Improvement Act; H.R. 3738, Office of Financial Research Accountability Act of 2015; H.R.4293, Affordable Retirement Advice Protection Act; H.R.4294, Strengthening Access to Valuable Education and Retirement Support Act (SAVERS Act) of 2015; S.2502, Affordable Retirement Advice Protection Act; S.2505, SAVERS Act of 2016; S.2497, Retail Investor Protection Act of 2016; Implications of the Federal Reserve dividend reduction section contained in PL 114-94, the Drive Act; Senior $afe Act (H.R.4538; S.2216); Financial Stability Oversight Council Reform Act (H.R.3340); issues related to cybersecurity and financial services; H.R. 1309 - Systemic Risk Designation Improvement Act of 2015.

Client expense: $1,100,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

EGRPRA Regulatory Review - Identify provisions that my provide regulatory relief. HR 1660 - Federal Savings Association Charter Flexibility Act of 2015 - HOLA amendments providing flexibility to operate as a national bank. CFPB revision package - Provisions subjecting the agency to additional oversight. HR 9 - The Innovation Act - Provisions addressing vague demand letter of patent trolls. HR 601 - Provisions eliminating privacy notice disclosure requirements. HR 1265 - Bureau Advisory Commission Transparency Act - Advisory counsel for the CFPB HR 1480 SAFE Act - confidentiality of information banks share with state regulators. HR 1660-Federal Savings Association Charter Flexibility Act - charter flexibility HR 1233 - CLEARR Act - Regulatory reduction provisions S 1484-Financial Regulation Improvement Act - Regulatory reduction provisions. S 2896 - TAILOR Act- Regulatory reduction provisions H1941/S774 - Financial Institutions Examination Fairness & Reform Act - timely & consistent examination report provisions. HR 5465 - Durbin Amendment repeal bill - repeal provisions. HR 2213 - Provisions for a formal grace period from enforcement under TILA-RESPA. HR 601 - Eliminate Privacy Notice Confusion Act - privacy notice exemptions. HR 1478/S798 - Policyholder Protection Act - Source of strength provisions.

Client expense: $125,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), 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)

Community Bankers Association of Illinois (CBAI) 2016 Federal Policy Priorities (House and Senate) 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 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 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) H.R. 4993 - Homeowners Information Privacy Protection Act (study privacy implications of new HMDA data fields) (All sections) (House) Comment Letters - Comment Letter - Federal Financial Institutions Examination Council (FFIEC, FDIC, Federal Reserve, OCC), Uniform Interagency Consumer Compliance Rating System - FFEIC-2016-00 - undertake a new and thorough analysis of the burden, remove the opportunity for misguided interpretation, elevate the legal standard for accountability, and clarify that consumer harm can only be caused by violations of law) Miscellaneous - Regarding CFPB rulemaking - specifically regarding Qualified Mortgage (QM) exemption for small creditors and those operating in rural and underserved areas, recommendation that future rulemaking justifiably grant community banks the broad regulatory relief they deserve at the outset of rulemaking, not after a long and painful rulemaking process which only adds to the frustration and regulatory burden on community banks (CFPB)

Client expense: $50,000 · 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, Office of the Comptroller of the Currency (OCC), SENATE