Community Bank Access to Capital Act of 2015

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

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

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

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

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

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

General Issues related to public issuer disclosures on financial reports and other public filings; Issues related to implementation of the Sarbanes-Oxley Act (Pub. L. 107-204); HR 1523, Community Bank Access to Capital Act of 2015 (issues related to implementation of internal control requirements within the Sarbanes-Oxley Act (Pub. L. 107-204); S 812, CLEAR Relief Act of 2015 (issues related to implementation of internal control requirements within the Sarbanes-Oxley Act (Pub. L. 107-204).

Client expense: $400,000 · Firm income: Not reported

Government targets: Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

General Issues related to public issuer disclosures on financial reports and other public filings; Issues related to implementation of the Sarbanes-Oxley Act (Pub. L. 107-204); HR 1523, Community Bank Access to Capital Act of 2015 (issues related to implementation of internal control requirements within the Sarbanes-Oxley Act (Pub. L. 107-204); S 812, CLEAR Relief Act of 2015 (issues related to implementation of internal control requirements within the Sarbanes-Oxley Act (Pub. L. 107-204).

Client expense: $370,000 · Firm income: Not reported

Government targets: Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 766 Financial Institution Customer Protection Act H.R. 957 The CFPB -IG 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. 1408 The Community Bank Mortgage Servicing Asset Capital Requirements Study Act H.R. 1422 CU Residential Loan Parity 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. 1941 Financial Institutions Examination Fairness and Reform Act H.R. 2029 Consolidated Appropriations Act H.R. 2205 Data Security Act of 2015 H.R. 2213 TRID Safe Harbor Protection 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 S. 482 CFPB Exam and Reporting Threshold Act S. 774 Financial Institutions and Exam Fairness Reform S. 812 The CLEAR Relief Act S.961 Data Security Act of 2015 S. 927 CLEAR Relief Plus Act S. 970 18-Month Exam Cycle S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act S. 1711 TRID Safe Harbor Protection 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 Call Report Streamlining Capital Access for Community Banks Capital Rules--Basel III Capital Rules--Treatment of Equity Investment Securities 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 NCUA Proposed Rule to Extend Member Business Lending, Commercial Lending, Part 72B 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 Providing Opportunities for Savings, Transactions and Lending Act 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

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 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 TAILOR Act H.R. 3192, the Homebuyer Assistance Act, all provisions H.R. 4893, the Risk Management and Homeowner Stability 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

General Issues related to public issuer disclosures on financial reports and other public filings; Issues related to implementation of the Sarbanes-Oxley Act (Pub. L. 107-204); HR 1523, Community Bank Access to Capital Act of 2015 (issues related to implementation of internal control requirements within the Sarbanes-Oxley Act (Pub. L. 107-204); S 812, CLEAR Relief Act of 2015 (issues related to implementation of internal control requirements within the Sarbanes-Oxley Act (Pub. L. 107-204).

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

Government targets: Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 22 Developing a Reliable and Innovating Vision for the Economy -Section 52203 (Fed dividend pay for) H.R. 601 Eliminate Privacy Notice Confusion Act H.R. 766 Financial Institution Customer Protection Act H.R. 888 Subsidy Reserve Act H.R. 957 The CFPB -IG 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. 1259 The HELP Rural Communities Act H.R. 1266 The Financial Products Safety Commission Act H.R. 1334 Holding Company Registration Threshold Equalization Act of 2015 H.R. 1408 The Community Bank Mortgage Servicing Asset Capital Requirements Study Act H.R. 1422 CU Residential Loan Parity 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. 1737 The Reforming CFPB Indirect Auto Financing Guidance Act H.R. 1766 Right to Lend Act of 2015 H.R. 1941 Financial Institutions Examination Fairness and Reform Act H.R. 2029 Consolidated Appropriations Act H.R. 2205 Data Security Act of 2015 H.R. 2213 TRID Safe Harbor Protection H.R. 2209 To require the appropriate Federal banking agencies to treat certain municipal obligations as level 2A liquid assets, and for other purposes. H.R. 2896 Tailor Act of 2015 H.R. 2995 FY 2016 Financial Services Approps Bill - Opposed Amendment to Offer HR 1188 Bill H.R. 2987 Community Bank Capital Clarification Act H.R. 3038 Highway and Transportation Funding Act of 2015 (section 2003) H.R. 3048 Community Financial Institution Exemption Act H.R. 3236 Care Choice Improvement Act of 2015 (Highway Trust Fund 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. 3808 To require the withdrawal and study of the Federal Housing Finance Agencys proposed rule on Federal Home Loan Bank membership H.R. 4116 To amend the Federal Deposit Insurance Act to ensure that the reciprocal deposits are not considered to be funds obtained by or through a deposit broker S. 423 Privacy Notice Modernization Act S. 482 CFPB Exam and Reporting Threshold Act S. 754 Cybersecurity Information Sharing Act of 2015 S. 774 Financial Institutions and Exam Fairness Reform S. 812 The CLEAR Relief Act S. 871 HELP Rural Communities Act S.961 Data Security Act of 2015 S. 927 CLEAR Relief Plus Act S. 970 18-Month Exam Cycle S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act S. 1647 Developing a Reliable and Innovative Vision for the Economy Act - Fed Reserve Dividend S. 1711 TRID Safe Harbor Protection S. 1816 Community Bank Access to Capital Act S. 1974 The Relationship Lending Preservation Act Appraisal Exemption Basel III/Capital Access Call Report Burden CFPB Data Collection CFPB Overdraft CFPB Reforms/Governance CFPB Small Business Data Collection CFPB Small Dollar/Payday Lending Congressional Payments Technology Caucus Credit Union Business Lending Powers Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint Escrow Mortgage Requirements FASB Accounting Rules for Loan Loss Reserves Faster Payments FDIC Small Bank Assessments Federal Reserve Reform Federal Home Loan Bank Membership Rules Home Mortgage Disclosure Act (HMDA) Regulations House Payments Innovation Caucus Housing Finance Reform Military Lending Act Rules Mortgage Lending Reform Mutual Banks NCUA Proposed Rule to Extend Member Business Lending, Commercial Lending, Part 72B Online/Marketplace Lending Qualified Mortgages, Ability to Repay Rules Reduction in Dividend Rate on Federal Reserve Stock Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Lending Limit Senate Payments Innovation Caucus Small Bank Holding Company Policy Statement TILA/RESPA Integrated Disclosures Implementation Too Big To Fail Virtual Currency

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 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 TAILOR Act H.R. 3192, the Homebuyer Assistance 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 The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effective management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance versus community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a 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 and 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. 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 regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. 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 . 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]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. 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 - a 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. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost 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 Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (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 benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. 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. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the 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. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1309 - Systemic Risk Designation Act of 2105 (Amends Dodd-Frank Act and Consumer Protection Act regarding the designation of financial institutions as systemically important (SIFIs)) (all sections) (House) H.R. 1523 - Community Bank Access to Capital Act of 2015 (enhance community bank and thrift access to capital) (all sections) (House) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (all sections) (House and Senate, FDIC, OCC) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC) H.R. 3048 - Community Financial Institution Exemption Act (greater CFPB accountability in rulemaking to community financial institutions under $10 billion in assets) (all sections) (House) H.R. 1314 - Bipartisan Budget Act of 2015 (two year budget) (Title II - Agriculture, Section 201 - $3 billion crop insurance reduction) (House and Senate) H.R. 22 - DRIVE Act - highway and transportation funding (Amendment #86 Eliminate Privacy Notice Confusion Act, The Small Bank Exam Cycle Reform Act, The Holding Company Registration Threshold Equalization Act, and Amendment #34 Federal Reserve Bank stock dividend spending offset) (House) (House and Senate Conference Committee) S. 1484 - Financial Regulatory Improvement Act of 2015 (bank regulatory relief) (Title I - all sections) (House and Senate, FDIC, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, FDIC, OCC) Comment Letters - Comment Letter - House, OMB, OCC, FDIC, Federal Reserve System, Proposed Agency Information Collection Activities (Call Report regulatory reform, Call Report regulatory burden and credit unions, Agency advocacy for community banks) (FFIEC 031 and FFIEC 041) Comment Letter - House, Senate, OCC, FDIC, Federal Reserve System (Combined impact of various regulations on community banks) Comment Letter - Federal Reserve System, FDIC, OCC (Regulator advocacy for community banks with National Credit Union Administration and Farm Credit Administration) Comment Letter - Federal Reserve System, FDIC, OCC (Remarks of Russell G. Golden, Chairman, Financial Accounting Standards Board regarding cause of the financial crisis and FASBs proposed Current Expected Credit Loss model (CECL)). Action Alerts - H.R. 1314 - Bipartisan Budget Act of 2015 - (two year budget) (Title II - Agriculture, Section 201 - $3 billion crop insurance reduction) (House) Miscellaneous - Regarding - Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) - specifically Prompt Corrective Action, Community Reinvestment Act, presentation of proposed rules, de novo bank formation, Call Reports, Small Bank Holding Company Policy Statement (as contained in CBAI Comment Letters - Docket ID FFIEC-2014-0001 and Docket ID FFIEC-2014-0001, Docket No. OP-1491) (House) Regarding - Senate Banking Committee hearing to consider Federal Reserve Board nominations (Senate) Regarding - Member Letter - reduction in Federal Reserve Bank stock dividend rate (House, FDIC, OCC) Regarding - reduction in Federal Reserve Bank stock dividend rate (House and Senate, FDIC, OCC) Regarding - Member Letter - Call Report regulatory relief (House) Regarding - Comments provided to banking regulators at the Chicago Federal Reserve Banks Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) outreach meeting - combined impact of regulations to address the same regulatory issues, and de novo bank formation Regarding - financial innovation (House) Regarding - Testimony before House Agricultural Committee hearing on the Farm Credit System (House)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effective management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance versus community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a 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 and 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. 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 regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. 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 . 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]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. 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 - a 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. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost 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 Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (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 benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. 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. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the 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. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1309 - Systemic Risk Designation Act of 2105 (Amends Dodd-Frank Act and Consumer Protection Act regarding the designation of financial institutions as systemically important (SIFIs)) (all sections) (House) H.R. 1523 - Community Bank Access to Capital Act of 2015 (enhance community bank and thrift access to capital) (all sections) (House) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (all sections) (House and Senate, FDIC, OCC) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC) H.R. 3048 - Community Financial Institution Exemption Act (greater CFPB accountability in rulemaking to community financial institutions under $10 billion in assets) (all sections) (House) H.R. 1314 - Bipartisan Budget Act of 2015 (two year budget) (Title II - Agriculture, Section 201 - $3 billion crop insurance reduction) (House and Senate) H.R. 22 - DRIVE Act - highway and transportation funding (Amendment #86 Eliminate Privacy Notice Confusion Act, The Small Bank Exam Cycle Reform Act, The Holding Company Registration Threshold Equalization Act, and Amendment #34 Federal Reserve Bank stock dividend spending offset) (House) (House and Senate Conference Committee) S. 1484 - Financial Regulatory Improvement Act of 2015 (bank regulatory relief) (Title I - all sections) (House and Senate, FDIC, OCC) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, FDIC, OCC) Comment Letters - Comment Letter - House, OMB, OCC, FDIC, Federal Reserve System, Proposed Agency Information Collection Activities (Call Report regulatory reform, Call Report regulatory burden and credit unions, Agency advocacy for community banks) (FFIEC 031 and FFIEC 041) Comment Letter - House, Senate, OCC, FDIC, Federal Reserve System (Combined impact of various regulations on community banks) Comment Letter - Federal Reserve System, FDIC, OCC (Regulator advocacy for community banks with National Credit Union Administration and Farm Credit Administration) Comment Letter - Federal Reserve System, FDIC, OCC (Remarks of Russell G. Golden, Chairman, Financial Accounting Standards Board regarding cause of the financial crisis and FASBs proposed Current Expected Credit Loss model (CECL)). Action Alerts - H.R. 1314 - Bipartisan Budget Act of 2015 - (two year budget) (Title II - Agriculture, Section 201 - $3 billion crop insurance reduction) (House) Miscellaneous - Regarding - Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) - specifically Prompt Corrective Action, Community Reinvestment Act, presentation of proposed rules, de novo bank formation, Call Reports, Small Bank Holding Company Policy Statement (as contained in CBAI Comment Letters - Docket ID FFIEC-2014-0001 and Docket ID FFIEC-2014-0001, Docket No. OP-1491) (House) Regarding - Senate Banking Committee hearing to consider Federal Reserve Board nominations (Senate) Regarding - Member Letter - reduction in Federal Reserve Bank stock dividend rate (House, FDIC, OCC) Regarding - reduction in Federal Reserve Bank stock dividend rate (House and Senate, FDIC, OCC) Regarding - Member Letter - Call Report regulatory relief (House) Regarding - Comments provided to banking regulators at the Chicago Federal Reserve Banks Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) outreach meeting - combined impact of regulations to address the same regulatory issues, and de novo bank formation Regarding - financial innovation (House) Regarding - Testimony before House Agricultural Committee hearing on the Farm Credit System (House)

General Issues related to public issuer disclosures on financial reports and other public filings; Issues related to implementation of the Sarbanes-Oxley Act (Pub. L. 107-204); HR 1523, Community Bank Access to Capital Act of 2015 (issues related to implementation of internal control requirements within the Sarbanes-Oxley Act (Pub. L. 107-204); S 812, CLEAR Relief Act of 2015 (issues related to implementation of internal control requirements within the Sarbanes-Oxley Act (Pub. L. 107-204).

Client expense: $390,000 · Firm income: Not reported

Government targets: Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 22 Developing a Reliable and Innovating Vision for the Economy -Section 52203 (Fed dividend pay for) H.R. 601 Eliminate Privacy Notice Confusion Act H.R. 766 Financial Institution Customer Protection Act H.R. 888 Subsidy Reserve Act H.R. 957 The CFPB -IG Act H.R. 1090 The Retail Investor 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. 1259 The HELP Rural Communities Act H.R. 1266 The Financial Products Safety Commission Act H.R. 1334 Holding Company Registration Threshold Equalization Act of 2015 H.R. 1389 American Jobs and Community Revitalization Act H.R. 1408 The Community Bank Mortgage Servicing Asset Capital Requirements Study Act H.R. 1422 CU Residential Loan Parity 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. 1737 The Reforming CFPB Indirect Auto Financing Guidance Act H.R. 1766 Right to Lend Act of 2015 H.R. 1941 Financial Institutions Examination Fairness and Reform Act H.R. 1974 Relationship Lending Preservation Act H.R. 2205 Data Security Act of 2015 H.R. 2213 TRID Safe Harbor Protection H.R. 2896 Tailor Act of 2015 H.R. 2995 FY 2016 Financial Services Approps Bill - Opposed Amendment to Offer HR 1188 Bill H.R. 2987 Community Bank Capital Clarification Act H.R. 3038 Highway and Transportation Funding Act of 2015 (section 2003) H.R. 3048 Community Financial Institution Exemption Act H.R. 3192 Homebuyers Assistance Act H.R. 3236 Care Choice Improvement Act of 2015 (Highway Trust Fund Act) S. 423 Privacy Notice Modernization Act S. 482 CFPB Exam and Reporting Threshold Act S. 754 Cybersecurity Information Sharing Act of 2015 S. 774 Financial Institutions and Exam Fairness Reform S. 812 The CLEAR Relief Act S. 871 HELP Rural Communities Act S. 881 A bill to ensure that Federal financial regulators perform a comprehensive review of regulations to identify outdated or otherwise unnecessary regulatory requirements imposed on financial institutions, and for other purposes (EGRPRA) S.961 Data Security Act of 2015 S. 966 Commercial Real Estate and Economic Development Act S. 927 CLEAR Relief Plus Act S. 970 18-Month Exam Cycle S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act S. 1647 Highway Transportation - Fed Reserve Dividend S. 1711 TRID Safe Harbor Protection S. 1816 Community Bank Access to Capital Act S. 1963 Bureau of Consumer Financial Protection Advisory Board Enhancement Act S. 1974 The Relationship Lending Preservation Act Appraisal Exemption Basel III/Capital Access Call Report Burden CFPB Data Collection CFPB Reforms/Governance CFPB Small Business Data Collection CFPB Small Dollar/Payday Lending Congressional Payments Technology Caucus Credit Union Business Lending Powers Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint Escrow Mortgage Requirements Fair Lending/Disparate Impact FASB Accounting Rules for Loan Loss Reserves Faster Payments FDIC Small Bank Assessments Federal Reserve Reform Federal Home Loan Bank Membership Rules Flood Insurance Reform Implementation of Biggert-Waters Act Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Military Lending Act Rules Mortgage Escrow Requirements Mortgage Lending Reform Mutual Banks Nomination of Mr. Amias Gerety to serve as Treasury Assistant Secretary for Financial Institutions Online/Marketplace Lending Qualified Mortgages, Ability to Repay Rules Reduction in Dividend Rate on Federal Reserve Stock Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Lending Limit Senate Payments Innovation Caucus Small Bank Holding Company Policy Statement Surface Transportation and Veterans Health Telephone Consumer Protection Act Exception Ruling TILA/RESPA Integrated Disclosures Implementation Too Big To Fail Virtual Currency

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 H.R. 9, the Innovation Act, all provisions 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. 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 TAILOR Act H.R. 3192, the Homebuyer Assistance 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 The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database

Community Bankers Association of Illinois (CBAI) 2015 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 Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a 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 and 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. 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 regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participate in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the 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. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation. Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. 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. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (All sections) (House and Senate) Comment Letters - Comment Letter - CFPB, grace period for enforcement and liability in the implementation, and delay in the implementation of the TRID Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate), and H.R. 1523 and S. 1816 - Community Bank Access to Capital (enhance community bank and thrift access to capital) (all sections) (House and Senate) Miscellaneous - Regarding CFPB, delay in implementation of TRID and period of restrained enforcement and liability, the definition of rural and underserved areas in the QM, regulatory burden on community banks, declining number of community banks and community bank consolidation (House)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effectively management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance. Community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a 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 and 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. 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 regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. 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 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]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. 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 - a 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. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost 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 Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (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 benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. 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. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the 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. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1523 - Community Bank Access to Capital Act of 2015 (enhance community bank and thrift access to capital) (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. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (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) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) H.R. 1941 - Financial Institutions Examination Fairness and Reform Act (regulatory examinations standards and FFIEC Ombudsman) (all sections) (House) S. 1440 and H.R. 1422 - Credit Union Residential Loan Parity Act (exclude loans to non-primary residence 1-4 family dwellings from member business lending cap) (all sections) (Senate) State of Illinois legislation - (sharing of IDFPR state bank examination reports with the Federal Home Loan Bank of Chicago) Comment Letters - Comment Letter - CFPB, grace period for enforcement and liability in the implementation, and delay in the implementation of the TRID Comment Letter - Department of Labor, proposed increase in the salary threshold for employees who are exempt from overtime mandates of the Fair Labor Standards Act Comment Letter - National Credit Union Administration, comments on proposed rulemaking for Part 723 (RIN 3133-AE37) to rewrite rules governing credit union member business lending (House and Senate) Comment Letter - FDIC, Notice of Proposed Rulemaking and request for Comments RIN 3064-AE37 to refine the deposit insurance assessment system for small depository institutions Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate), and H.R. 1523 and S. 1816 - Community Bank Access to Capital (enhance community bank and thrift access to capital) (all sections) (House and Senate) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) National Credit Union Administration regarding proposed rulemaking to rewrite rules governing credit union member business lending Miscellaneous - Regarding CFPB, delay in implementation of TRID and period of restrained enforcement and liability, the definition of rural and underserved areas in the QM, regulatory burden on community banks, declining number of community banks and community bank consolidation (House) Current community bank regulatory examination environment (Senate)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effectively management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance. Community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a 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 and 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. 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 regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. 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 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]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. 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 - a 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. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost 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 Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (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 benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. 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. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the 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. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1523 - Community Bank Access to Capital Act of 2015 (enhance community bank and thrift access to capital) (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. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (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) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) H.R. 1941 - Financial Institutions Examination Fairness and Reform Act (regulatory examinations standards and FFIEC Ombudsman) (all sections) (House) S. 1440 and H.R. 1422 - Credit Union Residential Loan Parity Act (exclude loans to non-primary residence 1-4 family dwellings from member business lending cap) (all sections) (Senate) State of Illinois legislation - (sharing of IDFPR state bank examination reports with the Federal Home Loan Bank of Chicago) Comment Letters - Comment Letter - CFPB, grace period for enforcement and liability in the implementation, and delay in the implementation of the TRID Comment Letter - Department of Labor, proposed increase in the salary threshold for employees who are exempt from overtime mandates of the Fair Labor Standards Act Comment Letter - National Credit Union Administration, comments on proposed rulemaking for Part 723 (RIN 3133-AE37) to rewrite rules governing credit union member business lending (House and Senate) Comment Letter - FDIC, Notice of Proposed Rulemaking and request for Comments RIN 3064-AE37 to refine the deposit insurance assessment system for small depository institutions Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate), and H.R. 1523 and S. 1816 - Community Bank Access to Capital (enhance community bank and thrift access to capital) (all sections) (House and Senate) Highway Trust Fund Reauthorization - (Senate versions proposed reduction of dividends paid on Federal Reserve Bank stock as pay-for) (Senate) National Credit Union Administration regarding proposed rulemaking to rewrite rules governing credit union member business lending Miscellaneous - Regarding CFPB, delay in implementation of TRID and period of restrained enforcement and liability, the definition of rural and underserved areas in the QM, regulatory burden on community banks, declining number of community banks and community bank consolidation (House) Current community bank regulatory examination environment (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 H.R. 9, the Innovation Act, all provisions 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. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation 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. 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. 2896, the TAILOR Act 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 The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database

H.R. 601 Eliminate Privacy Notice Confusion Act H.R. 766 Financial Institution Customer Protection Act H.R. 888 Subsidy Reserve 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. 1259 The HELP Rural Communities Act H.R. 1266 The Financial Products Safety Commission Act H.R. 1334 Holding Company Registration Threshold Equalization Act of 2015 H.R. 1389 American Jobs and Community Revitalization Act H.R. 1408 The Community Bank Mortgage Servicing Asset Capital Requirements Study Act H.R. 1422 CU Residential Loan Parity 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. 1560 Protecting Cyber Networks Act H.R. 1660 The Federal Savings Association Charter Flexibility Act H.R. 1661 Mutual Bank Capital Opportunity Act H.R. 1731 National Cybersecurity Protection Advancement Act H.R. 1766 Right to Lend Act of 2015 H.R. 1941 Financial Institutions Examination Fairness and Reform Act H.R. 2205 Data Security Act of 2015 H.R. 2213 TRID Safe Harbor Protection H.R. 2896 Tailor Act of 2015 H.R. 2995 FY 2016 Financial Services Approps Bill - Opposed Amendment to Offer HR 1188 Bill S. 423 Privacy Notice Modernization Act S. 482 CFPB Exam and Reporting Threshold Act S. 754 Cybersecurity Information Sharing Act of 2015 S. 774 Financial Institutions and Exam Fairness Reform S. 812 The CLEAR Relief Act S. 871 HELP Rural Communities Act S. 881 A bill to ensure that Federal financial regulators perform a comprehensive review of regulations to identify outdated or otherwise unnecessary regulatory requirements imposed on financial institutions, and for other purposes (EGRPRA) S.961 Data Security Act of 2015 S. 927 CLEAR Relief Plus Act S. 970 18-Month Exam Cycle S. 1206 TBTF Reform S. 1484 Financial Regulatory Improvement Act S. 1491 Community Lender Regulatory Relief and Consumer Protection Act Access to Capital for Community Banks Appraisal Exemption Basel III/Capital Access Call Report Burden CFPB Data Collection CFPB Mortgage Rate Tool CFPB Reforms/Governance CFTC Reauthorization Amendments Congressional Payments Technology Caucus Credit Union Business Lending Powers Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint Escrow Mortgage Requirements Fair Lending/Disparate Impact FASB Accounting Rules for Loan Loss Reserves Faster Payments Federal Reserve Reform Federal Home Loan Bank Membership Rules Flood Insurance Reform Implementation of Bigger-Waters Act Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Housing Government Sponsored Enterprises Job Act Thrift Fix Military Lending Act Rules Mortgage Escrow Requirements Mortgage Lending Reform Mortgage Servicing Standards Mutual Banks National Flood Insurance Program Overdraft Protection Services Qualified Mortgages, Ability to Repay Rules Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks Senate Payments Innovation Caucus Small Bank Holding Company Policy Statement TILA/RESPA Implementation Too Big To Fail Virtual Currency Waivers for Banks Pleading Guilty to Criminal Conduct

General Issues related to public issuer disclosures on financial reports and other public filings; Issues related to implementation of the Sarbanes-Oxley Act (Pub. L. 107-204); HR 1523, Community Bank Access to Capital Act of 2015 (issues related to implementation of internal control requirements within the Sarbanes-Oxley Act (Pub. L. 107-204); S 812, CLEAR Relief Act of 2015 (issues related to implementation of internal control requirements within the Sarbanes-Oxley Act (Pub. L. 107-204).

Client expense: $600,000 · Firm income: Not reported

Government targets: Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effectively management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance. Community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a 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. Un-level playing field and 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. 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 regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions should pay their fair share of income taxes. Credit unions not adhering to a common bond or operating within a well-defined local community, neighborhood or rural district. 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]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of assets 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 - a 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. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost 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 Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (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 benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. 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. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the 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. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit in full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. Not a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB with a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - Proposed HMDA legislation - (additional data points, exempting banks provided they have less than 250 home mortgage finance transactions; exempting banks from new HMDA requirements not directly authorized by the Dodd-Frank; exempt commercial purpose, home equity lines of credit, reverse mortgages, home improvement loans and repurchased loans from HMDA requirements) (House) H.R. 650 - Preserving Access to Manufactured Housing Act of 2015 (Amends TILA to exclude mortgage originators from retailers of manufactured housing) (all sections) (House) H.R. 1731 - National Cyber Security Protection Advancement Act of 2105 (Information sharing, collaboration coordination, preparation, and security improvements and resiliency, reporting) (all sections) (House) H.R. 1560 - Protecting Cyber Networks Act (Notification procedures, defensive measures, information sharing, monitoring information systems, liability protection) (all sections) (House) S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate) S. 1206 - Too Big to Fail, Too Big to Exist Act (addressing too-big-to-fail institutions) (all sections) (Senate) Comment Letters - Comment Letter - Illinois House Ways and Means Committee members, reforming tax code regarding tax subsidies for credit unions and Farm Credit System Comment Letter - CFPB, grace period of enforcement and liability in the implementation of the TRID Comment Letter - CFPB, data service providers requirement to provide data pertaining to overdraft programs Comment Letter - Federal Reserve Bank, Office of Comptroller of the Currency, Federal Deposit Insurance Corporation, Regulatory Review under EGRPRA (tiered regulation for community banks, Prompt Corrective Action (PCA), CRA asset thresholds), Docket ID FFIEC-2014-0001 Comment Letter - Farm Credit Administration, corporate governance standards of conduct proposed rule, 12CFR Parts 650, 651, 653 and 655; RIN 3052-AC89 Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate) S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate) H.R. 1523 - The Community Bank Access to Capital Act (enhance community bank access to capital) (all sections) (House) S. 423 - The Privacy Notice Modernization Act (redundant privacy notice relief) (Senate)

Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Too-to-Fail - Reform the financial system. The severity of a future financial crisis. The perception and reality of too-big-to-fail. Taxpayer bailouts of mega banks and financial firms. Mega bank size, complexity and interconnectedness, and candidacy for future bailouts. The number of community banks falling by more than half (currently 6,200 institutions) and now represent less than one-fifth of banking professions assets. Causes of the mortgage meltdown and financial crisis. Protection of the nation and the banking profession from a repeat of massive financial destruction. Taxpayer-funded bailouts of too-big-to-fail banks and financial firms and their numerous violations of the law, often criminal violations. Effectively management, supervision, discipline, or resolution of too-big-to-fail banks and financial firms. Mega bank multi-trillion dollars financial assistance. Community banks assistance and more than 500 failed community banks. Downsizing too-big-to-fail banks and financial firms. The fundamental American constitutional right of equal justice under the law applicability when it comes to the mega banks. The U.S. two-tiered system of justice - too-big-to-fail banks and financial firms and everyone else. The Department of Justice (DOJ) - laggard in prosecuting crimes stemming from the financial crisis. Banking regulators and the DOJ aggressively pursuing actions against community banks, their directors, and officers with board resolutions, MOUs, C&Ds, consent orders, monetary penalties, barring individuals from banking, criminal prosecution, and other actions. No mandatory Prompt Corrective Action (PCA) capital enforcement orders against any bank larger than $30 billion in assets, yet 1,400 PCAs against community banks. Evidence of a clear double standard. Opponents of downsizing the mega banks (include their paid association cheerleaders) consistently blocking meaningful reforms and obfuscating the issue of too-big-to-fail for the benefit of large members and the detriment of everyone else. Too-big-to-fail banks, directors, officers, or employees being - too-big-to-manage, too-big-to-regulate, too-big-to-fail, too-big-to-prosecute, too-big-to-jail, too-big-to-change, and clearly too-big-to-behave --- downsize. Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a 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 and 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. 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 regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions should pay their fair share of income taxes. Credit unions not adhering to a common bond or operating within a well-defined local community, neighborhood or rural district. 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]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of assets 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 - a 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. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost 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 Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (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 benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. 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. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participating in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the 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. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit in full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. Not a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB with a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Revised definitions in the Ability-to-Repay Qualified Mortgage rules of small creditor and rural areas, and expansion of the definition of underserved areas to include economically challenged areas. De Novo Community Bank Formation - Need for newly chartered (de novo) community banks. FDIC inhibiting de novo community bank formation. FDICs current position and a one-size-fits-all supervisory policy for de novos. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - Proposed HMDA legislation - (additional data points, exempting banks provided they have less than 250 home mortgage finance transactions; exempting banks from new HMDA requirements not directly authorized by the Dodd-Frank; exempt commercial purpose, home equity lines of credit, reverse mortgages, home improvement loans and repurchased loans from HMDA requirements) (House) H.R. 650 - Preserving Access to Manufactured Housing Act of 2015 (Amends TILA to exclude mortgage originators from retailers of manufactured housing) (all sections) (House) H.R. 1731 - National Cyber Security Protection Advancement Act of 2105 (Information sharing, collaboration coordination, preparation, and security improvements and resiliency, reporting) (all sections) (House) H.R. 1560 - Protecting Cyber Networks Act (Notification procedures, defensive measures, information sharing, monitoring information systems, liability protection) (all sections) (House) S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate) S. 1206 - Too Big to Fail, Too Big to Exist Act (addressing too-big-to-fail institutions) (all sections) (Senate) Comment Letters - Comment Letter - Illinois House Ways and Means Committee members, reforming tax code regarding tax subsidies for credit unions and Farm Credit System Comment Letter - CFPB, grace period of enforcement and liability in the implementation of the TRID Comment Letter - CFPB, data service providers requirement to provide data pertaining to overdraft programs Comment Letter - Federal Reserve Bank, Office of Comptroller of the Currency, Federal Deposit Insurance Corporation, Regulatory Review under EGRPRA (tiered regulation for community banks, Prompt Corrective Action (PCA), CRA asset thresholds), Docket ID FFIEC-2014-0001 Comment Letter - Farm Credit Administration, corporate governance standards of conduct proposed rule, 12CFR Parts 650, 651, 653 and 655; RIN 3052-AC89 Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate) S. 1484 - Financial Regulatory Improvement Act of 2015 (Title 1 community bank regulatory relief measures) (Title 1 - Sections 100-126) (Senate) H.R. 1523 - The Community Bank Access to Capital Act (enhance community bank access to capital) (all sections) (House) S. 423 - The Privacy Notice Modernization Act (redundant privacy notice relief) (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 H.R. 9, the Innovation Act, all provisions 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. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation 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. 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. 2896, the TAILOR Act 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 The Heck-Stivers Amendment to H.R. 1735, the National Defense Authorization Act, related to the Department of Defenses MLA Database

Legislation: EO12333, United States intelligence activities-Issues Lobbied: Surveillance.EO13673, Rulemaking on Fair Pay and Safe Workplaces Executive Order-Issues Lobbied: Employment Discrimination; Womens Rights.SConRes11, FY 2016 Budget Resolution-Issues Lobbied: HIV/AIDS Discrimination, Racial Profiling, Voting Rights, Religious Liberty, Criminal Justice, Pregnancy Discrimination/Accomodations, Border Policy, Employment Discrimination, Unaccompanied immigrant children (Due process, Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA)); Birthright citizenship; Immigration executive actions.SJRes10, A resolution disapproving the action of the District of Columbia Council in approving the Reproductive Health Non-Discrimination Act of 2014-Issues Lobbied: Reproductive Rights & Religion and Belief.SJRes11, A joint resolution disapproving the action of the District of Columbia in approving the Human Rights Amendment Act of 2014-Issues Lobbied: LGBT Rights & Religion and Belief.SJRes19, Constitutional amendment to limit First Amendment on political speech-Issues Lobbied: First Amendment.S23, Copyright and Marriage Equality Act-Issues Lobbied: LGBT Rights.S50, Weldon Amendment/ Abortion Non-Discrimination Act of 2015-Issues Lobbied: Reproductive Rights.S165, Detaining Terrorists to Protect America Act of 2015-Issues Lobbied: GTMO.S178, Justice for Victims of Trafficking Act-Issues Lobbied: Reproductive Rights, 14th Amendment, Immigration Detention, Criminal Justice, Religious Liberty.S208, Secure the Borders First Act-Issues Lobbied: Border Security and Enforcement.S217, Womens Health Protection Act of 2015-Issues Lobbied: Reproductive Rights.S255, Fifth Amendment Integrity Restoration Act-Issues Lobbied: Civil Asset Forfeiture.S262, Runaway and Homeless Youth Act-Issues Lobbied: LGBT Rights and Religious Liberty.S270, Charlie Morgan Military Spouses Equal Treatment Act of 2015-Issues Lobbied: LGBT Rights.S353, The Justice Safety Valve Act-Issues Lobbied: Mandatory Minimums.S356, Electronic Communications Privacy Act Amendments Act of 2015-Issues Lobbied: Privacy.S358, Access to Contraception for Women Servicemembers and Dependents Act of 2015-Issues Lobbied: Women's Rights.S416, Pregnant and Parenting Students Access to Education Act of 2015-Issues Lobbied: Women's Rights.S435, State Marriage Defense Act of 2015-Issues Lobbied: LGBT Rights.S439, Student Non-Discrimination Act of 2015-Issues Lobbied: LGBT Rights.S447, Jury Access for Capable Citizens and Equality in Service Selection Act of 2015-Issues Lobbied: LGBT Rights.S456, Cyber Threat Sharing Act of 2015-Issues Lobbied: Cybersecurity.S467, CORRECTIONS Act-Issues Lobbied: Prison Early Release.S497, Healthy Families Act-Issues Lobbied: Women's Rights.S502, Smarter Sentencing Act-Issues Lobbied: Mandatory Minimums.S512, Law Enforcement Access to Data Stored Abroad Act-Issues Lobbied: Privacy.S534, Immigration Rule of Law Act of 2015-Issues Lobbied: Executive Action on Immigration.S582, No Taxpayer Funding for Abortion and Abortion Insurance Full Disclosure Act of 2015-Issues Lobbied: Reproductive Rights.S607, Electronic Communications Privacy Act Amendments Act of 2013-Issues Lobbied: Privacy.S675, Record Expungement Designed to Enhance Employment Act of 2015-Issues Lobbied: Criminal Records and Juvenile Solitary Confinement.S683, CARERS Act of 2015-Issues Lobbied: Medical Marijuana.S754, Cybersecurity Information Sharing (CISA) Act-Issues Lobbied: Privacy, Cybersecurity.S772, Democracy Restoration Act-Issues Lobbied: Voting Rights.S786, FAMILY Act-Issues Lobbied: Women's Rights.S877, Police CAMERA Act-Issues Lobbied: Body Worn Cameras.S987, Free Flow of Information Act-Issues Lobbied: First Amendment.S1599, USA Freedom Act (2013)-Issues Lobbied: National Security.S1631, FISA Improvements Act-Issues Lobbied: National Security.S1675, Recidivism Reducation and Public Safety Act of 2014-Issues Lobbied: Sentencing Reform.S1690, Second Chance Act Reauthorization-Issues Lobbied: Re-entry, PREA.S2536, Stop Advertising Victims of Exploitation (SAVE) Act-Issues Lobbied: Free Speech.S 2588, Cybersecurity Information Sharing Act (2014)-Issues Lobbied: Cybersecurity.S2611, HUMANE Act-Issues Lobbied: Unaccompanied immigrant children, Due process, Funding for immigration courts, Border enforcement, Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA).S2685, USA Freedom Act 2014-Issues Lobbied: Surveillance.HJRes 43, A resolution disapproving the action of the District of Columbia Council in approving the Reproductive Health Non-Discrimination Act of 2014-Issues Lobbied: Reproductive Rights & Religion and Belief.HR2, Medicare Access and CHIP Reauthorization Act of 2015-Issues Lobbied: Reproductive Rights.HR5, STUDENT SUCCESS ACT-Issues Lobbied: Reproductive Rights, Racial Justice, Religious Liberty, LGBT Rights, Criminal Justice, Education, School Discipline, School Climate.HR7, No Taxpayer Funding for Abortion and Abortion Insurance Full Disclosure Act of 2015-Issues Lobbied: Reproductive Rights.HR36, Pain-Capable Unborn Child Protection Act-Issues Lobbied: Reproductive Rights.HR234, Cyber Intelligence Sharing and Protection Act of 2015-Issues Lobbied: Cybersecurity.HR238, Copyright and Marriage Equality Act-Issues Lobbied: LGBT Rights.HR240, Department of Homeland Security Appropriations Act, 2015-Issues Lobbied: Surveillance, Legalization of Marijuana, Civil Rights, CBP/ICE oversight and Accountability, Deferred Action, Family detention, Immigration detention, Immigration enforcement, Presidents executive action on immigration (Federal administrative immigration relief: DAPA, Deferred Action for Childhood Arrivals (DACA) programFederal immigration enforcement reform: Secure Communities; Priority Enforcement Program (PEP); detainers; parole; deportations).HR283, Electronic Communications Privacy Act Amendments Act of 2015-Issues Lobbied: Privacy.HR448, Womens Health Protection Act of 2015-Issues Lobbied: Reproductive Rights.HR399, Secure Our Borders First Act of 2015-Issues Lobbied: Border Security and Enforcement.HR429, Grand Jury Reform Act of 2015-Issues Lobbied: Criminal Justice Reform.HR448, Womens Health Protection Act-Issues Lobbied: Reproductive Rights.HR540, FAIR Act-Issues Lobbied: Civil Asset Forfeiture.HR637, Preserving American Privacy Act of 2013-Issues Lobbied: Privacy.HR731, Justice and Mental Health Collaboration Act-Issues Lobbied: Mental Health and Criminal Justice.HR742, Access to Contraception for Women Servicemembers and Dependents Act of 2015-Issues Lobbied: Women's Rights.HR824, State Marriage Defense Act of 2015-Issues Lobbied: LGBT Rights.HR846, Student Non-Discrimination Act of 2015-Issues Lobbied: LGBT Rights.HR864, Jury Access for Capable Citizens and Equality in Service Selection Act of 2015-Issues Lobbied: LGBT Rights.HR885, Voting Rights Amendment Act of 2015-Issues Lobbied: Voting Rights.HR920, Smarter Sentencing Act-Issues Lobbied: Mandatory Minimums.HR932, Healthy Families Act-Issues Lobbied: Women's Rights.HR964, Respect States' and Citizens' Rights Act-Issues Lobbied: Drug Reform.HR983, Online Communications and Geolocation Protection Act-Issues Lobbied: Privacy.HR1148, Michael Davis, Jrin Honor of State and Local Law Enforcement Act-Issues Lobbied: Detainers; state and local immigration enforcement.HR1149, Protection of Children Act of 2015-Issues Lobbied: Unaccompanied Children, Due Process, Access to Counsel.HR1153, Asylum Reform and Border Protection Act of 2015-Issues Lobbied: Unaccompanied children, Due process, Access to counsel.HR1232, Stop Militarizing Law Enforcement Act-Issues Lobbied: Law Enforcement Militarization.HR1299, Runaway and Homeless Youth Act-Issues Lobbied: LGBT Rights and Religious Liberty.HR1439, FAMILY Act-Issues Lobbied: Women's Rights.HR1459, Democracy Restoration Act-Issues Lobbied: Voting Rights.HR1507, IN-STATE Act-Issues Lobbied: Deferred Action for Childhood Arrivals (DACA), Path to legal status.HR1523, The Respect States Marijuana Laws Act-Issues Lobbied: Drug Reform.HR1586, REPEAL HIV Discrimination Act of 2015-Issues Lobbied: LGBT Rights.HR1672, REDEEM Act-Issues Lobbied: Criminal Justice Reform.HR1680, Police CAMERA Act-Issues Lobbied: Body Worn Cameras.HR1700, Vulnerable Immigrant Voice Act-Issues Lobbied: Unaccompanied children, Access to counsel, Due process, Immigrants with disabilities.HR1962, Free Flow of Information Act-Issues Lobbied: First Amendment.HR3361, USA Freedom Act (2013)-Issues Lobbied: National Security.HR4225, Stop Advertising Victims of Exploitation (SAVE) Act-Issues Lobbied: Free Speech.HR 4291, FISA Transparency & Modernization Act-Issues Lobbied: National Security.HR4752, To limit ability of FCC to reclassify broadband-Issues Lobbied: First Amendment.HR5114, HUMANE Act-Issues Lobbied: Unaccompanied immigrant children, Due process, Funding for immigration courts, Border enforcement, Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA). Congressional Issues without Bill Numbers: Senate Select Committee on Intelligence Report on CIA Rendition, Detention, and Interrogation program-Issue Lobbied: Torture. Targeted Killing-Issue Lobbied: National Security. Guantanamo Bay-Issue Lobbied: National Security. National Defense Authorization Act for Fiscal Year 2016-Issue Lobbied: National Security, Guantanamo Bay, Authorization for Use of Military Force. Prison Rape Elimination Act of 2003-Issue Lobbied: Criminal Justice Reform. Student Non-Discrimination Act (SNDA)-Issue Lobbied: LGBT Rights. Pregnant Workers Fairness Act-Issue Lobbied: Accommodations for Pregnant Workers, Women's Rights. FY 2016 Budget Resolution-Issue Lobbied: National Security. Voting Rights Amendment Act-Issue Lobbied: Voting Rights. Readable Legislation Act-Issue Lobbied: Government Transparency. Joint resolutions disapproving of D.C. Council measures-Issue Lobbied: Use of Religion to Discriminate, LGBT Rights, Reproductive Rights. RFRA/RLUIPA-Issue Lobbied: Religious Liberty. Mass Incarceration-Issue Lobbied: Criminal Justice. Policing Reform-Issue Lobbied: Law Enforcement Reform. LGBT Non-Discrimination Bill-Issue Lobbied: LGBT Rights. Surveillance Reform-Issue Lobbied: First Amendment. Immigration Enforcement-Issue Lobbied: Immigration. Immigration Visas, Transparency-Issue Lobbied: Immigration. FOIA reform-Issue Lobbied: Government Transparency. Authorization for Use of Military Force-Issue Lobbied: National Security. Guantanamo Bay Transfers-Issue Lobbied: National Security. Body-worn Cameras-Issue Lobbied: Police Reform. Policing and Body-Worn Camera Briefing-Issue Lobbied: Police Reform. Border Prosecutions-Issue Lobbied: Border Security. Electronic Communications Privacy Act Reform-Issue Lobbied: Privacy. ESEA Reauthorization-Issue Lobbied: Racial Justice, Religious Liberty, School Discipline, Criminal Justice Reform, LGBT Rights, School Accountability. Criminal Justice Principles-Issue Lobbied: Criminal Justice Reform. E-Verify-Issue Lobbied: First Amendment. Executive Action on Immigration-Issue Lobbied: Immigration. Cybersecurity-Issue Lobbied: Privacy. Sexual Education Funding-Issue Lobbied: Reproductive Rights. Women in Combat-Issue Lobbied: Women's Rights. Every Child Achieves Act-Issue Lobbied: LGBT Rights, Criminal Justice. National Defense Authorization Act and Trans Military Service-Issue Lobbied: LGBT Rights. Senate appropriations-Issue Lobbied: Criminal justice. Criminal justice legislative proposals-Issue Lobbied: Criminal justice. Interior and Border enforcement, Unaccompanied Minors-Issue Lobbied: Immigration. Deportation and detention practices-Issue Lobbied: Immigration. Border enforcement/ CBP oversight and excessive use of force-Issue Lobbied: Immigration. Paycheck Fairness Act-Issue Lobbied: Employment Discrimination; Womens Rights. WAGE Act-Issue Lobbied: Employment Discrimination; Womens Rights. Fair Pay Act-Issue Lobbied: Employment Discrimination; Womens Rights. Fair Donations for All Act-Issue Lobbied: First Amendment. National Cybersecurity Protection Advancement Act of 2015-Issue Lobbied: Cybersecurity. DISCLOSE Act and other Campaign Finance Reform Measures-Issue Lobbied: Campaign Finance Reform, First Amendment. Broadband Adoption Act-Issue Lobbied: First Amendment. Follow the Money Act-Issue Lobbied: First Amendment. Force Multiplier Act-Issue Lobbied: Information Sharing. CORRECT Act-Issue Lobbied: First Amendment. FY 2016 Commerce, Justice, Science and Related Agencies Appropriations-Issue Lobbied: Immigration court, Access to counsel, Asylum. Family detention, Immigration detention, Treatment of refugee women and children/victims of violence-Issue Lobbied: Immigration. Bond Hearings-Issue Lobbied: Immigration. Helping Families in Mental Health Crisis Act of 2013-Issue Lobbied: Disability Rights, Access to Justice, Privacy Rights. Every Child Ready for College or Career Act of 2015-Issue Lobbied: ESEA reauthorization; Education; School discipline; School climate. End Racial Profiling Act (ERPA)-Issue Lobbied: Civil Rights, Criminal Justice, Racial Justice, Police Practices. June 2003 Guidance Regarding the Use of Race by Federal Law Enforcement Agencies-Issue Lobbied: Racial Profiling, Civil Rights, Criminal Justice, Racial Justice, Police Practices. The Youth PROMISE Act-Issue Lobbied: Civil Rights, Criminal Justice, Racial Justice, Juvenile Justice. The Juvenile Justice and Delinquency Prevention Reauthorization Act-Issue Lobbied: Civil Rights, Criminal Justice, Racial Justice, Juvenile Justice. Fair Housing, Disparate Impact-Issue Lobbied: Housing. Lifeline Program Reform/Broadband Access-Issue Lobbied: First Amendment. Whistleblower Protection-Issue Lobbied: First Amendment. DC Marijuana Ballot Initiative-Issue Lobbied: Criminal Justice. Over-criminalization Task Force-Issue Lobbied: Criminal Justice. Countering Violent Extremism Programs-Issue Lobbied: Religion & Belief, Human Rights. Agencies Lobbied: Bureau of Prisons-Issues Lobbied: Compassionate Release, Clemency Project 2014, Reentry, Criminal Justice, Mandatory Minimums, Access to Counsel, Immigrant Detention, Juvenile Solitary Confinement. Department of Defense-Issues Lobbied: Guantanamo Bay, Law Enforcement Militarization, EO 12333 and Section 702 surveillance. Department of Education-Issues Lobbied: Diversity Criteria, Every Child Ready for College or Career Act of 2015, ESEA reauthorization, School discipline, School climate. Department of Health and Human Services-Issues Lobbied: Weldon Amendment/Abortion Non-Discrimination Act of 2015, Ensuring Access to Over-The-Counter Emergency Contraception for Patients at IHS-operated Facilities, Standards To Prevent, Detect, and Respond to Sexual Abuse and Sexual Harassment Involving Unaccompanied Children, Contraception Coverage, Prison Rape Elimination Act, ACA Discrimination, Interior and Border enforcement, Unaccompanied Minors. Department of Homeland Security-Issues Lobbied: Immigration Enforcement Reform, Terrorism-Related Inadmissibility Grounds (TRIG), Unaccompanied minors; Law Enforcement Militarization, Interior and Border enforcement, Executive Action on Immigration, Bond Hearings, Immigration (Family) Detention, Treatment of Refugee Women and Children/Victims of Violence, Civil Rights, Racial Justice, Police Practices, End Racial Profiling Act (ERPA), June 2003 Guidance Regarding Use of Race by Federal Law Enforcement Agencies, REAL ID, Countering Violent Extremism Programs. Department of Housing and Urban Development-Issues Lobbied: Housing Discrimination, Housing Mobility, Fair Housing, Affirmatively Futhering Fair Housing, Disaparate Impact. Department of Justice-Issues Lobbied: Sentencing Reform, Law Enforcement Militarization, Willacy Uprising, EO 12333 and Section 702 surveillance, Location Tracking Devices, Stingrays, Indigent Defense, Police Reform, Criminal Justice (OIG), Interior and Border enforcement, Unaccompanied Minors, Voting Rights Amendment Act of 2015, Executive Action on Immigration, Immigration (Family) Detention, Treatment of Refugee Women and Children/Victims of Violence, Civil Rights, Racial Justice, Police Practices, End Racial Profiling Act (ERPA), June 2003 Guidance Regarding Use of Race by Federal Law Enforcement Agencies, Juvenile Justice and Delinquency Prevention Reauthorization Act, RFRA/2007 OLC Memo, Countering Violent Extremism Programs, Prison Overcrowding, Solitary Confinement. Department of Labor-Issues Lobbied: Contraception Coverage, Paycheck Fairness Act, Rulemaking on Fair Pay and Safe Workplaces Executive Order (EO 13673). Department of State-Issues Lobbied: Guantanamo Bay, Immigration, TRIG, UPR Surveillance, Detention, Privacy and Human Rights, Benefits for Same-Sex Domestic Partners, Overseas Detentions and Interrogations. Department of Treasury-Issues Lobbied: IRS rulemaking on 501c4. Director of National Intelligence-Issues Lobbied: EO 12333 and Section 702 surveillance. Domestic Policy Council-Issues Lobbied: Law Enforcement Militarization, Criminal Justice. Employee Benefits Security Administration-Issues Lobbied: Notice of Proposed Rulemaking for Summary of Benefits and Coverage and Uniform Glossary, Docket ID: EBSA-2014-0028. Executive Office of the President-Issues Lobbied: Policing, State of the Union, Background Checks, Racial Profiling, Countering Violent Extremism Summit, Immigration Enforcement and Policy, White House Communications, Religious Exemption OLC Memo. Federal Aviation Administration-Issues Lobbied: Domestic Drones. Federal Bureau of Investigation-Issues Lobbied: Torture, Location Tracking Devices, Stingrays, Encryption, government back doors, Overseas Detentions and Interrogations. Federal Communications Commission-Issues Lobbied: Net Neutrality; Prison Phone Rates; E911 (location privacy), Media Ownership Rule, Low Power FM Application Window, E-Rate Rulemaking, IP Transition, Open Internet Rule. Indian Health Service-Issues Lobbied: Reproductive Rights (Emergency contraception access). Internal Revenue Service-Issues Lobbied: Petition for IRS Rulemaking on 501c4. Inter-American Commission on Human Rights-Issues Lobbied: Race and Criminal Justice. National Security Agency-Issues Lobbied: EO 12333 and Section 702 surveillance. National Telecommunications and Information Administration-Issues Lobbied: Facial recognition. Office of Federal Contract Compliance Programs-Issues Lobbied: Data collection, Proposed Regulations Prohibiting Discrimination on the Basis of Sex. Office of Management and Budget-Issues Lobbied: REAL ID. Office of Justice Program-Issues Lobbied: Civil Rights, Criminal Justice, Racial Justice, Juvenile Justice. Office of Juvenile Justice & Delinquency Prevention-Issues Lobbied: Civil Rights, Criminal Justice, Racial Justice, Juvenile Justice. Office of Science & Technology Police-Issues Lobbied: Privacy and Tech Issues, Surveillance, Cybersecurity, Cell Phone Security, Encryption. U.S. Citizenship and Immigration Services-Issues Lobbied: Executive Action on Immigration, Immigration (Family) Detention, Treatment of Refugee Women and Children/Victims of Violence. U.S. Commission on Civil Rights-Issues Lobbied: Immigration Detention, Civil Rights, Human Rights, Racial Justice. U.S. Customs and Border Protection-Issues Lobbied: Border enforcement/ CBP oversight and excessive use of force. U.S. Immigration and Customs Enforcement-Issues Lobbied: Deportation and detention practices, Executive Action on Immigration, Immigration (Family) Detention, Treatment of Refugee Women and Children/Victims of Violence. U.S. Patent and Trademark Office-Issues Lobbied: Patent Eligibility. U.S. Postal Service-Issues Lobbied: Pregnant Worker Accommodations. U.S. Sentencing Commission-Issues Lobbied: Sentencing Reform. United States Trade Representative-Issues Lobbied: Trans-Pacific Partnership, First Amendment. White House-Issues Lobbied: Targeted Killing, National Security, Guantanamo Bay, Authorization for Use of Military Force, National Defense Authorization Act, Militarization of Police, 21st Century Policing Task Force, Sentencing Reform, Police Reform, Private Prisons, Clemency Project 2014, A resolution disapproving the action of the District of Columbia Council in approving the Reproductive Health Non-Discrimination Act of 2014, Civil Remedy for Violence Against Women Act, Women in Policing, Criminal Justice, Interior and Border enforcement, Unaccompanied Minors, Paycheck Fairness Act, Rulemaking on Fair Pay and Safe Workplaces Executive Order (EO 13673), Executive Action on Immigration, DHS Immigration Enforcement Reform, Immigration (Family) Detention, Treatment of Refugee Women and Children/Victims of Violence, School Discipline/Climate, End Racial Profiling Act, June 2003 Guidance Regarding Use of Race by Federal Law Enforcement Agencies, My Brother's Keeper Initiative, Racial Justice and Profiling, Education, Police Practices, Disparate Impact, RFRA/2007 OLC Memo, FY16 Budget Resolution, Countering Violent Extremism Programs, Solitary Confinement.

H.R. 37 Promoting Job Creation and Reducing Small Business Burdens Act H.R. 601 Eliminate Privacy Notice Confusion Act H.R. 766 Financial Institution Customer Protection Act H.R. 888 Subsidy Reserve Act H.R. 957 CFPB-IG Act H.R. 1188 Credit Union Small Business Jobs Creation Act H.R. 1113 Portfolio Lending and Mortgage Access Act H.R. 1195 The Bureau of Consumer Financial Protection Small Business Advisory Board Act H.R. 1233 CLEAR Relief Act H.R. 1259 The HELP Rural Communities Act H.R. 1266 The Financial Products Safety Commission Act H.R. 1389 American Jobs and Community Revitalization Act H.R. 1408 The Community Bank Mortgage Servicing Asset Capital Requirements Study Act H.R. 1523 Community Bank Access to Capital Act H.R. 1529 The Community Institution Mortgage Relief Act H.R. 1660 The Federal Savings Association Charter Flexibility Act H.R. 1661 Mutual Bank Capital Opportunity Act S. 423 Privacy Notice Modernization Act S. 482 CFPB Exam and Reporting Threshold Act S. 530 Federal Reserve Confirmation S. 754 Cybersecurity Information Sharing Act of 2015 S. 774 Financial Institutions and Exam Fairness Reform S. 812 The CLEAR Relief Act S. 871 Rural Designation Appeals S. 881 A bill to ensure that Federal financial regulators perform a comprehensive review of regulations to identify outdated or otherwise unnecessary regulatory requirements imposed on financial institutions, and for other purposes (EGRPRA) S.961 Data Security Act of 2015 Access to Capital for Community Banks Appraisal Exemption Basel III/Capital Access Call Report Burden CFPB Mortgage Rate Tool CFPB Reforms/Governance Credit Union Business Lending Powers Credit Union Tax Exemptions Cybersecurity - Information Sharing Data Security and Breaches De Novo Bank Applications Department of Justice Operation Chokepoint Escrow Mortgage Requirements Fair Lending/Disparate Impact Faster Payments Federal Reserve Reform Federal Home Loan Bank Membership Rules Flood Insurance Reform Implementation of Bigger-Waters Act Home Mortgage Disclosure Act (HMDA) Regulations Housing Finance Reform Housing Government Sponsored Enterprises Job Act Thrift Fix Military Lending Act rules Mortgage Escrow Requirements Mortgage Lending Reform Mortgage Servicing Standards Mutual Banks National Flood Insurance Program Nomination of Amias Gerety as Treasury Assistant Secretary for Financial Institutions Overdraft Protection Services Qualified Mortgages, Ability to Repay Rules Regulation Z Establishment of Escrow - Higher Priced Loans Regulatory Burden for Community Banks Regulatory and Tax Relief for Community Banks Small Bank Holding Company Policy Statement Small Business Lending Fund TILA/RESPA Implementation Too Big To Fail Virtual Currency

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 H.R. 9, the Innovation Act, all provisions 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. 685, the Mortgage Choice Act, all provisions H.R. 766, Financial Institution Consumer Protection Act, all provisions H.R. 989, the Capital Access for Small Businesses Jobs Creation 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 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