Protect Family Farms and Businesses Act

Maintaining timber tax provisions that allow forest owners to pay capital gains on income from a timber sale, deduct forest management costs, and deduct reforestation costs; estate tax; Protect Family Farms and Business Act-S. 3436/H.R. 6100; H.R.6042 - To nullify certain proposed regulations relating to restrictions on liquidation of an interest with respect to estate, gift, and generation-skipping transfer taxes.

Client expense: $40,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Council on Environmental Quality (CEQ), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE, U.S. Fish & Wildlife Service (USFWS)

H.R. 235, Permanent Internet Tax Freedom Act H.R. 625, Infrastructure 2.0 Act H.R. 1105/S. 860, Death Tax Repeal Act of 2015 H.R. 2775, Remote Transactions Parity Act of 2015 H.R. 5053, Preventing IRS Abuse and Protecting Free Speech Act H.R. 6100/S. 3436, Protect Family Farms and Businesses Act S. 431, Internet Tax Freedom Forever Act S. 698, Marketplace Fairness Act of 2015 S. 2809, A bill to amend the Internal Revenue Code of 1986 to preserve taxpayers' rights to administrative appeal of deficiency determinations, and for other purposes Online Sales Simplification Act of 2015 (discussion draft) Proposed rules on the treatment of certain interests in corporations as stock or indebtedness (81 Fed. Reg. 20,912, April 8, 2016) Proposed rules on deemed distributions under section 305(c) of stock and rights to acquire stock (81 Fed. Reg. 21,795, April 13, 2016) Proposed rules on estate, gift, and generation-skipping transfer taxes; restrictions on liquidation of an interest (81 Fed. Reg. 51,413, August 4, 2016) Various issues relating to tax extenders, including bonus depreciation, deferral tax provisions, S-Corp tax provisions, and flow-throughs; corporate tax inversions; repatriation of multinational business earnings; bilateral income tax treaties and protocols, including those with Chile, Hungary, Switzerland, Luxembourg, Spain, Japan and Poland and a protocol amending the Convention on Mutual Administrative Assistance in Tax Matters; tax reform; pension reform; international competitiveness of corporate tax rates; patent box or innovation box proposals; corporate integration proposals; House Republican tax reform blueprint

Client expense: $18,590,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Bureau of Industry and Security (BIS), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Consumer Product Safety Commission (CPSC), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), Federal Bureau of Investigation (FBI), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Labor Relations Board (NLRB), Natl Security Council (NSC), Occupational Safety & Health Administration (OSHA), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Customs & Border Protection, U.S. Fish & Wildlife Service (USFWS), U.S. Geological Survey (USGS), U.S. Trade Representative (USTR), White House Office

H.R. 5818 Mandated Expenses Tax Relief Act; H.R. 1087 Wireless Telecommunications Tax and Fee Collection Fairness Act; H.R. 1397 Seniors Tax Simplification Act; H.R. 1528 End Discriminatory State Taxes for Automobile Rentals; H.R. 1643 Digital Goods and Services Tax Fairness Act; H.R. 1855/S.987 Small Business Tax Equity Act of 2015 ; H.R. 2315 Mobile Workforce State Income Tax Simplification Act; H.R. 27 Tax Code Termination Act; H.R. 2775 Remote Transactions parity Act ; H.R. 2842 Individual Rate Simplification Act; H.R. 2946 IncentivizeCorporate America Act; H.R. 3017 Invest in America Act; H.R. 3083 Bring Jobs Back to America Act; H.R. 3213 Fixed Asset Relief Act; H.R. 3267 Paycheck Relief Act; H.R. 4377 American Business Competiveness Act; H.R. 4518 Corporate Rate Equality and Trade Empowerment Jobs Act; H.R. 4581 Stop Corporate Earnings Stripping Act; H.R. 6098 Transparent Recognition of Unjustified Tax Hoarding in Government Act; H.R.2584 Buisness Activity Tax Simplification Act; H.R.5076 MainStreetFairnessAct; HR ___ Hybrid Origin Discussion Draft; S. 1261 Wireless Telecommunications Tax and Fee Collection Fairness Act; S. 3436/H.R. 6100 Protect Family Farms and Businesses Act.; S. 698 Marketplace Fairness Act; S.2650/H.R. 5946 United States Appreciation for Olympians and Paralympians Act; H.R. 4377 American Business Competiveness Act; H.R. 6270/S. 3424 To amend the Internal Revenue Code of 1986 to prevent the avoidance of tax by insurance companies through reinsurance with non-taxed affiliates; H.R. 6246 The Retirement Inflation Protection Act of 2016; H.R. 6098 TRUTH in Government Act; Issues relating to the Better Way Tax Reform Blueprint; Issues relating to 1031 "Like-Kind Exchanges"; H.R. 3687 the Cuba Agricultural Exports Act; Issues relating to the Trans-Pacific Partnership

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

Government targets: Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, SENATE

Timber provision in tax reform proposals. Estate tax issues. H.R. 1105, S. 860. Section 2704 estate tax regulations Estate tax regulation: Protect Family Farms & Business S.3436, H.R.6100

Client expense: Not reported · Firm income: $40,000

Government targets: Agriculture, Dept of (USDA), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Fish & Wildlife Service (USFWS)

Supported S. 3436 and H.R. 6100, the Protect Family Farms and Businesses Act, which would prevent the IRS from issuing rules that would restrict estate tax discount valuation.

Client expense: $40,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

MFB encouraged members of Congress to support a letter to Treasury Secretary Lew opposing proposed changes to estate tax discount valuation rules. MFB also supported H.R. 6100, Protect Family Farms and Businesses Act, which would prevent the IRS from issuing rules that would restrict estate tax discount valuation from taking effect. The bill was introduced by Rep. Warren Davidson (R-Ohio). MFB has serious concerns about how this proposed change to negatively impact estate planning and transferring family farms to the next generation when a family death occurs leading to increased tax burdens on the heirs.

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

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

Timber provision in tax reform proposals. Estate tax issues. H.R. 1105, S. 860. Section 2704 estate tax regulations Estate tax regulation: Protect Family Farms and Business: S 3436, HR6100

Client expense: $100,906 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Fish & Wildlife Service (USFWS)

In support the Protect Family Farms and Businesses Act (S.3436, H.R. 6100), which prevents the implementation of regulations which repeal the use of valuation discounts upon transferring a business to a family member.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE

Alternative minimum tax; Cash basis method of accounting; Corporate integration; Deductions for adjusted gross income (certain attorney fees and court costs); Disaster Relief; National Disaster Tax Relief Act of 2015 (H.R. 3110 / S. 1795); Tax Extension Assurance Bill; Education-related provisions; Estates & Trusts; Estate valuation discounts under section 2704 (H.R. 6042, H.R. 6100, and S. 3436); Modify the deadline for estate basis reporting; Allow administrative relief for late portability, inter vivos qualified terminal interest property, and qualified revocable trust elections; Treat consistently all federal tax payments of trusts and estates; Amend section 67(e) to simplify the law and allow estates and nongrantor trusts to fully deduct the cost of complying with fiduciary duties in administering estates and trusts; Exempt from the filing requirement of section 6034(a) trusts with charitable deductions only from flow-through entities; Subject estates, certain qualified revocable trusts, and qualified disability trusts to the income tax and net investment income tax in the same manner as married persons filing separate returns; Require Form 1099 reporting of interest and dividends paid to charitable remainder trusts; Foreign trust withholding credit to U.S. beneficiaries; Modify Form 3520-A due date from March 15th to April 15th; Section 2801 estate tax expatriation guidance; Estate tax closing letters; Estate tax basis consistency reporting; Filing election/tax return 15 months after death; Simplified Form 706 EZ; Surviving spouse elections; Executive Compensation; Section 409A; Excise tax on excess tax-exempt organization executive compensation; Exempt Organizations; Form 990 series; Jeopardizing investments; Unrelated Business Income Tax (name and logo royalties treated as unrelated business taxable income; parity of charitable contribution limitation between trusts and corporations; increased specific deduction; qualified sponsorship payments; dual use facility expense allocation; definition of a patient); Penalties (increase in information return penalties; manager-level accuracy-related penalty on underpayment of unrelated business income tax); Remove the binding contract requirement under section 512(b)(13)(E)(iii); Tax Exempt Entities/Excise Taxes (modification of intermediate sanctions; modification of taxes on self-dealing; excise tax on failure to distribute within five years contribution to donor advised fund; repeal of exception for private operating foundation failure to distribute income; excise tax based on investment income of private colleges and universities); Mandate the electronic filing of the IRS except organization forms, as proposed in the FY 2017 Budget of the US Government and accompanying Treasury Explanations; Supporting organizations; SSNs on EO tax forms; Section 501(r); Form 1023; Group rulings and group filings; Section 1441 foreign equivalency determination; Foreign trusts; Compliance issues continuing monitoring/discussing; Withholding issues with FATCA for foreign trusts and U.S. beneficiaries; Form 3520-A filing deadline; Health insurance deduction; Provide full deductibility of health insurance for small businesses; Identity theft; The Chairman's Mark of A Bill To Prevent Identity Theft And Tax Refund Fraud (JCX-108-15); Identity Theft and Tax Fraud Prevention Act of 2015 (H.R. 3981); Stolen Identity Refund Fraud Prevention Act of 2015 (H.R. 2991); Form W-2 due date acceleration; Identity Theft Mark-up Amendment Related to the Regulation of Tax Return Preparers; IRS Security Summit International Taxation; BEPS - country-by-country reporting; Information reporting for Disregarded Entities with foreign owners; Innovation Box; Inversion guidance under Section 7874; Pending Income Tax Treaties and Protocols; PFIC reporting requirements; Taxation of Foreign Income; Taxation of 529 Plans, ABLE accounts, ROTH IRAs and their foreign equivalents; Voluntary Disclosure and Streamlined Filing Programs for delinquent taxpayers with foreign assets and income; Notice 2016-48, Expiration & Renewal procedures for ITINs; Reporting requirements for foreign accounts held by U.S. taxpayers resident overseas; FinCEN Form 114 (FBAR) reporting requirements (RIN 1506-AB26); Tax treatment of retirement plans for taxpayers working overseas; IRS authority over tax return preparers and contingency fees; Taxpayer Protection and Preparer Proficiency Act of 2015 (S. 137); Tax Return Preparer Competency Act of 2015 (H.R. 4141); Tax Return Preparer Accountability Act of 2015 (H.R. 1609); IRS determination letter program; IRS budget, IRS customer service, IRS Future State; IRS proposed regulations guidance under Section 2801; Kiddie Tax rules; Listed property issues; Removing computer equipment from the definition of listed property; Internet sales and use tax collection; Marketplace Fairness Act of 2015, S. 698; Remote Transactions Parity Act of 2015, H.R. 2775; Medical lodging deduction limitation with the allowable business per diem rates; Methods/Periods/Credits; Cost recovery issues/UNICAP (including Sections 168, 179 and 263A); Mischaracterized section 174 expenditures; Modification of Rev. Proc. 2004-34 and Treas. Reg. 1.451-5 concerning the deferral of advance payments; Research credit; Tangible property regulations; Amortization of certain research and experimental expenditures.; Amortization of certain advertising expenditures;Tax treatment of deferred revenue in taxable asset acquisitions; Revenue Procedure 2015-20, de minimis safe harbor limit; Accounting method changes for mischaracterized section 174 expenditures needing a section 481(a) adjustment and audit protection; Section 170 charitable contribution of inventory; Notice 2015-40 Revenue Recognition; Revenue Procedure 2015-40; Section 199; Revenue Procedures 2015-13 and 2015-14 and 2016-29; Modify the enhanced deduction rules for charitable contributions of inventory; Modify the rules for capitalization and inclusion in inventory costs for certain expenses under 263A; Modify the rules for capitalization and inclusion in inventory costs for certain expenses under section 263A; Section 41(h) Treatment of Credit for Qualified Small Businesses; Section 471 cost definition under section 263A; Revenue Procedure 2004-34 advance payments; Accounting for loyalty points and the scope of Treas. Reg. 1.451-4; Mileage rates for business expense, medical expense, moving expense and charitable contribution purposes; Mobile Workforce State Income Tax Simplification Act of 2015 (H.R. 2315 and S. 386); Multi-State Worker (telecommuter) Tax Fairness Act; Net operating loss deduction; Pass-through Entities; Allow Subchapters K and S to Remain as Separate Subchapters; Retain the Flexibility of the Subchapter K Model (Including Special Allocations and Outside Basis for Partnership Level Debt); Retain the Check-the-Box Rules; Obtain Tax Rate Parity Between Pass-Through Business Entities and C Corporations; Repeal Section 1372: Partnership Rules to Apply for Fringe Benefit Purposes for S Corporations; Make Permanent the Reduced Recognition Period for Built-In Gains for S Corporations; Allow Full Consideration of Net Realized Built-In Loss for S Corporations; Make Remedial Allocations Mandatory for Partnerships with Greater than 5% Nonresident Alien Individuals as Shareholders; Eliminate the Section 751(b) Calculation on Disproportionate Distributions; Oppose Any Proposal for Tax Treatment of "Large" Partnerships as Corporations; Require Mandatory Adjustments to Basis of Partnership Property in Case of Transfer of Partnership Interests and Mandatory Adjustments to Basis of Undistributed Partnership Property; Allow Accumulated Earnings and Profits Withdrawal from S Corporations with Certainty; Reduce Realized Built-In Gains of S Corporations by the Amount of Accrued State Income Tax; Allow Incentive Deductions Permitted by the Internal Revenue Code to Flow Through to Taxpayers Without Basis Limitations; Repeal the Prohibition of Section 179(d)(4) for Estates/Trusts; Alternatively, Allow Pass-Through Entity Allocation and Amortization at the Estate /Trust Level; Charitable Contribution Deduction for Electing Small Business Trusts; Permanent Rule Regarding Basis Adjustment to Stock of S Corporations Making Charitable Contribution of Property; Allow an offset to the built-in gains tax for charitable contribution and foreign tax credit carryforwards from a C year; Add a new 120-day post-termination transition period beginning on the date that a taxpayer files an amended Form 1120S; Allow S corporations to have nonresident aliens as shareholders and potential current beneficiaries of electing small business trusts; Repeal section 1362(d)(3), which terminates an S election due to passive investment income that exceeds a certain threshold, or increase the passive investment income threshold of S corporations under section 1375(a)(2) from 25% to 60%; Extension of time for making S corporation elections; Partnership audits; Allow the transfer of any partnership suspended losses to his/her spouse when spousal transfers under section 1041(a) take place; Clarify that husband and wife partnerships that are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Repeal section 708(b)(1)(B) relating to the technical terminations of partnerships; Retain existing safe harbors for allocation of shared partnership liabilities.; Request for Guidance Regarding Worthless Stock Deductions Under Section 165(g) for S Corporations; Partnership Audit Simplification Act of 2015 (H.R. 2821); Treatment under Section 721(c) of property transfers to partnerships with related foreign partners; Technical corrections to Partnership Audit procedures enacted as part of the Bipartisan Budget Act of 2016; Notice 2016-23, BBA Partnership Audit Regime regulations; Disguised sales rules under Section 707; Allocation of partnership liabilities under Section 752; Management fee waivers; Net Investment Income Tax on disposition of partnership interest; Treatment of partner as an employee for benefit purposes; User Fees Charged for S Corporation Private Letter Ruling Requests; Transfers of Property to Partnerships with Related Foreign Partners and of Certain Interests in Corporations as Stock or Indebtedness (Notice 2015-54); Additional Guidance for AAA Ordering Rules; S Corp Basis Ordering (Section 1367); S Corp guidance on inability to utilize certain suspended passive activity losses upon redemption (Section 469(g)); Update Treas. Reg. 1.1361-5 to reflect the addition of clause (ii) to section 1361(b) (3)(C) made by section 8234 of P.L. 110-28; Issue a revenue ruling incorporating the guidance from PLRs 200308035 and 201017019; Guidance regarding the application of section 302(b)(4) to distributions by an S corporation; Guidance as to when, for AMT purposes, S corporations will have attributes which are different for regular tax and AMT purposes; Provide additional guidance to whether a state tax refund attributable to the S portion of an electing small business trust (ESBT) is allocated to the S portion; Applicability of proposed section 385 regulations to partnerships; Reporting requirements for partnerships under section 6038; Treat the return of an S corporation as the return of any related qualified subchapter S subsidiary for purposes of any relevant period of limitations; Patient Protection and Affordable Care Act (P.L. 111-148) implementation and related issues; Health reimbursement arrangements (HRAs); The Small Business Healthcare Relief Act (H.R. 5447 / S. 1697); Small business health insurance tax credit; Employer information reporting requirements (Form 1095-C); Remote Transactions Parity Act of 2015, Marketplace Fairness Act of 2015 (H.R. 2775 / S. 6998); Savings & Investments; Consolidate and simplify the multiple types of tax-favored retirement plans and the rules governing them; Eliminate Certain Nondiscrimination Tests on Employee Pre-tax and Roth Deferrals for 401(k) Plans, Matching Contributions; Eliminate the Top-Heavy Rules; Create a Uniform Rule Regarding the Determination of Basis in Distributions; Create a Uniform Attribution Rule; Create a Uniform Definition of Owners; Change the Required Minimum Distribution Rules During Life and Remove Half-Year Age References; Create Uniform Rules for Early Withdrawal Penalties; Elimination of Income Limits on Contributions to Roth IRAs; Inflation Adjustments for Roth IRA Contributions; Simplify the small business health insurance tax credit under IRC section 45R; Simplify the tax treatment of Roth individual retirement account contributions; SEPs; SIMPLE 401(k)s; Rules Related to Designated Roth Contributions; Repeal the requirement that benefits become fully vested upon a partial termination of a qualified retirement plan; Section 385 Proposed Regulations - Regarding the treatment of certain interests in corporations as stock or indebtedness (REG-108060-15); Small Business Tax Compliance Relief Act of 2015 (S. 1827); Standardize IRC definitions to avoid multiple meanings for the same term; The Self-Employment Contributions Act (SECA); Determination of net earnings from self-employment; Equalize the tax treatment between employees and self-employed individuals with respect to the deduction for health insurance costs in determining income subject to OASDI and HI taxes; Tax Reform (General); Principles of Good Tax Policy; Tax extenders (H.R. 2029, the Protecting Americans from Tax Hikes Act of 2015 and Consolidated Appropriations Act, 2016); Permanence of tax legislation; Small business compliance burdens; International tax provisions related to the Tax Reform Act of 2014; Tax administration and compliance; Late and amended Forms 1099 - corrected information reporting safe harbor de minimis and reporting rollover to year of change; Amend the section 6051 reporting requirement to permit truncation of employee social security numbers; Clarification of six-year statute of limitations in case of overstatement of basis; Penalties (definition of tax shelters; significant purpose; reasonable cause exceptions; penalty for failure to file; penalty for failure to file correct information returns and provide payee statements; Form 3520 and 3520-A penalties; late filing penalties under sections 6698 and 6699; Form 5471 penalty relief); Pre-populated returns; Private Debt Collection; Repeal the section 7122(c)(1) requirement to provide a 20% partial payment with a lump-sum offer in compromise; Section 9100 relief (administrative relief for missed statutory elections); Tax Administration Integrity Act (H.R. 3167); Tax rates and definitions; Consistent definitions in the Internal Revenue Code; Deduction for adjusted net capital gain; Elimination of surtaxes; Inflation-adjusting thresholds and amounts; Repeal of phase-ins/phase-outs; Simplified Income Tax Rate Structure; Tax return due dates (Public Law 114-41, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015); Form 3520 change technical correction; Taxpayer Bill of Rights; Taxpayer Bill of Rights Act of 2015 (H.R. 1058, S. 949, S. 951); Small Business Taxpayer Bill of Rights Act of 2015 (H.R. 1828, S. 949); Taxpayer Bill of Rights Enhancement Act of 2015 (S. 1578); Treasury/IRS Priority Guidance Plan (Notice 2016-26); United States Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) System; Virtual currency (Bitcoin)

Client expense: $1,320,000 · Firm income: Not reported

Government targets: Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

H.R. 6100/S. 3436: Protect Family Farms and Businesses Act - provisions relating to proposed regulations relating to restrictions on liquidation of an interest with respect to estate, gift, and generation-skipping transfer taxes S860/HR725 Death Tax Repeal Act - provisions relating to estate tax repeal. S698 Marketplace Fairness Act - provisions relating to remittance of sales and use taxes H.R.2775 - Remote Transactions Parity Act of 2015 - provisions relating to remittance of sales and use taxes HR 2050/S 2045 Middle Class Health Benefits Tax Repeal Act - provisions relating to high cost employer sponsored health care plans

Client expense: $82,913 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Urge support for Trans-Pacific Partnership; Urge support for Renewable Fuel Standards; Urge support for crop insurance program; urge co-sponsorship or HR 6100, Protect Family Farms; urge signature of letter on China biotech approvals; urge support for 2018 Farm Bill; Urge support for 2016 Water Resources Development Act; Urge support for repeal of "Waters of the United States;" urge support of December 2016 Grain Inspection, Packers and Stockyards Administration rules;

Client expense: $54,377 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Unnumbered Bill Related to Reform Legislation H.R. 3397 - Disaster Savings and Resilient Construction Act of 2015 Power-Take-Off Tax Correction Reintroduction of The Disaster Savings Accounts Act Multiemployer Pension Plan (MEPPs) Unnumbered Bills to Fix the Highway Trust Fund H.R. 6042 - To nullify certain proposed regulations relating to restrictions on liquidation of an interest with respect to estate, gift, and generation-skipping transfer taxes. H.R. 6100 and S. 3436 - Protect Family Farms and Businesses Act Unnumbered Bills Related to the Airport and Airway Trust Fund Unnumbered Bills Related to Regulatory Reform Unnumbered Bills Related to Valuation Dicounts

Client expense: $410,153 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), Federal Emergency Management Agency (FEMA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Natl Labor Relations Board (NLRB), Occupational Safety & Health Administration (OSHA), SENATE, State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of

- Advocacy in support of Death Tax Repeal Act (HR 2429 / S 1183), which would repeal the estate tax. - Advocacy in support of S. 698 / H.R. 2775 (Marketplace Fairness Act/ Remote Transactions Parity Act) which address online sales tax avoidance. - Advocacy in support of H.R. 2096 / S. 1212 (Promotion & Expansion of Private Employee Ownership Act) which allows for more businesses to consider becoming ESOPs by addressing deficiencies within the tax code - Advocacy in support of the 25D and Section 48 (Geothermal) Tax Credit. - Advocacy in support of HR 6100, which would prevent a proposed change to Section 2704 by Treasury/ IRS from taking effect

Client expense: $40,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Legislative services related to energy tax issues and alternative fuel incentives. - H.R. 6228, Bill to extend and modify the alternative fuel credits - H.R. 6100, Protect Family Farms and Businesses Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to federal tax reform; expired and expiring tax extender provisions slated to expire at the end of 2016 affecting agriculture and farmer cooperatives. Estate Tax legislation, H.R. 6100 the Protect Family Farms and Businesses Act, and S. 3436, Protect Family Farms and Businesses Act, affecting agriculture and farmer cooperatives.

Client expense: $253,743 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Commodity Futures Trading Commission (CFTC), Environmental Protection Agency (EPA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Transportation, Dept of (DOT), U.S. Trade Representative (USTR)

Highway Trust Fund Solvency; S.2606 exempting water and sewer construction from Private Activity Bond volume cap; Individual and corporate tax reform; Financial Accounting Standards Board issues; HR 1105, Permanent reduction or elimination of the estate and gift taxes; Repeal of health insurance tax; Implementation of the Water Resources Reform and Development Act; Like-kind Exchanges (Sec. 1031); Creation of a category for Public Buildings for Private Activity Bond eligibility and exemption of that category from volume cap; H.R. 5008- Clarify Workers Misclassification in the Construction Industry Act; H.R. 5361/S. 3177- Public Buildings Renewal Act 2016; Repeal NPRM on Sec. 385 Debt Equity Rules; American Job Builders Tax Reform Act- POC method accounting;HR 4468 Water Infrastructure Trust Fund Act; Section 199 NPRM; Energy Efficiency Tax Incentives Act(179D); H.R. 6100/ S. 3436- Protect Family Farms and Businesses Act,SEC 2704 Valuation Regulations; H.R. 6042- Nullify Proposed 2704 Regs

Client expense: $159,000 · Firm income: Not reported

Government targets: Education, Dept of, Environmental Protection Agency (EPA), Federal Highway Administration (FHA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Occupational Safety & Health Administration (OSHA), Office of Management & Budget (OMB), SENATE, Transportation, Dept of (DOT), Treasury, Dept of, White House Office

Comprehensive Tax Reform. Pass-Through Rates. Completed Contract Method/ Section 460(e) Reform. Estate tax, generally. The American Job Builders Tax Reform Act. IRS (Reg) Title: Treatment of Certain Interests in Corporations as Stock or Indebtedness (RIN 1545-BN40). House Tax Reform "Blueprint." H.R. 5076: Main Street Fairness Act. IRS (Reg) Title: Estate, Gift, and Generation-skipping Transfer Taxes: Restrictions on Liquidation of an Interest (RIN 1545-BB71). H.R. 6100/ S. 3436: Protect Family Farms and Business Act.

Client expense: $550,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Labor, Dept of (DOL), Occupational Safety & Health Administration (OSHA), Office of Management & Budget (OMB), SENATE

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

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

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

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

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

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

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

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

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

Estate Tax HR 6100 - change IRS intrepretation of deductions; request for Senate support of letter to IRS overall tax reform Implementation of bills passed in December: Permanently extend Section 179 small business expensing (H.R. 636) Permanently repeal the Estate Tax (H.R. 1105) Fifty percent bonus depreciation permanent (S 1660) Fifty percent bonus depreciation extended (S. 1666) All also included in Protecting Americans from Tax Hikes Act of 2015 (PATH) Senate package of two-year extension of tax extenders House Tax Reform Package- proposal to eliminate ability to deduct net business interest

Client expense: $70,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE

Expressed support for H.R. 6100, the Protect Family Farms and Business Act Asked members to sign letters opposing IRS proposed regulation, REG-163113-02, Estate, Gift, and Generation-Skipping Transfer Taxes

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

ARTBA staff have met with congressional offices to urge inclusion of a long-term Highway Trust Fund revenue solution in any tax reform or deficit reduction package or a stand-alone measure. ARTBA urged Congress to address a shortfall to the Highway Trust Fund as a part of any comprehensive tax reform package. ARTBA supported the passage of S. 3436/H.R. 6100, the Protect Family Farms & Businesses Act. The measure would force the withdrawal of an Internal Revenue Service (IRS) proposal that would restrict small businesses from discounting shareholder stock for estate tax purposes for interests including lack of control or lack of marketability.

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

Government targets: Army, Dept of (Corps of Engineers), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Justice, Dept of (DOJ), Office of Management & Budget (OMB), President of the U.S., SENATE, Small Business Administration (SBA), Transportation, Dept of (DOT)

The organization supports replacing the current federal income tax with a system that is simple, transparent, revenue-neutral and equitable. As such, we are closely monitoring discussions in the House Ways and Means Committee and the Senate Finance Committee. We are also supportive of extending certain temporary tax provisions and maintaining the like-kind exchange provision in the Internal Revenue Code. Jobs and Premium Protection Act (S.183/H.R.928): Legislation that would repeal the tax levied on a health insurance company's net premium. The tax was included in the Patient Protection and Affordable Care Act, which Farm Bureau opposed. The organization supports S.183/H.R.928. Death Tax Repeal Act (S.860/H.R.1155): Legislation that would amend the Internal Revenue Code to repeal estate and generation-skipping transfer taxes. The organization opposes the estate tax and therefore supports S.860/H.R.1155. Marketplace Fairness Act of 2015 (S.698): Legislation that would allow each member state under the Streamlined Sales and Use Tax Agreement to require all sellers not qualifying for a small-seller exception to collect and remit sales and use taxes with respect to internet sales. Remote sellers with less than $1 million annual sales are excluded; those who are above the threshold would be provided software for collecting the tax. The organization supports fair competition between local and main street retailers and internet-only sellers. The House companion bill is H.R.2775, the Remote Transactions Parity Act. Farm Equipment Depreciation (S.2202/H.R.4474): Legislation to permanently reinstate five-year depreciation for farm equipment. The organization supports this change since agriculture is an equipment-heavy industry. The Protect Family Farms and Businesses Act (H.R.6100/S.3436): Legislation to prohibit the Internal Revenue Service from finalizing and implementing its proposed regulations on liquidation of an interest with respect to estate, gift, and generation-skipping transfer taxes. The organization opposes the rulemaking because it would make it more difficult for farmers and ranchers who operate family-owned partnerships, LLCs or corporations to transfer their farms and ranches to the next generation. Comments were filed during the public comment period. Biodiesel Tax Incentive Reform and Extension Act of 2016 (H.R.5240): Legislation that would extend the $1-per-gallon tax credit for biodiesel through the end of 2019 and reform the credit from a blenders credit to a producers credit for fuel using U.S. commodities. The organization supports the bill.

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

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

S. 860 - the Death Tax Repeal Act; S. 2595 - the Building Rail Access for Customers and the Economy Act; S. 3188 - the Biodiesel Tax Incentive Reform and Extension Act of 2016; S. 3248 - the Agriculture Environmental Stewardship Act; S. 3436 - the Protect Family Farms and Businesses Act; H.R. 4626 - the Building Rail Access for Customers and the Economy Act; H.R. 5167 - Technologies for Energy Security Act; H.R. 5240 - the Biodiesel Tax Incentive Reform and Extension Act of 2016; H.R. 5489 - the Agriculture Environmental Stewardship Act; H.R. 6100 - the Protect Family Farms and Businesses Act; General tax reform; Capital Gains Taxes; and Cash Accounting.

Client expense: Not reported · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

Estate Tax- H.R. 1105 and H.R. 6100, Pass Through Entity Taxation-H.R. 5076 and H.R. 4377, LIFO- H.R. 4377, Craft Beverage Modernization Act of 2015- S.1562 and H.R. 2903

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Reduction of the maximum federal estate tax rate and ultimate elimination of federal estate, gift and generation-skipping taxes; specific bills include the Death Tax Repeal Act of 2013 (H.R. 1105 and S. 860); Protect Family Farms and Businesses Act (H.R. 6100); General issues on House and Senate regarding comprehensive tax reform.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Maintaining timber tax provisions that allow forest owners to pay capital gains on income from a timber sale, deduct forest management costs, and deduct reforestation costs; estate tax; Protect Family Farms and Business Act-S. 3436/H.R. 6100; H.R.6042 - To nullify certain proposed regulations relating to restrictions on liquidation of an interest with respect to estate, gift, and generation-skipping transfer taxes.

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

Government targets: Agriculture, Dept of (USDA), Council on Environmental Quality (CEQ), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE, U.S. Fish & Wildlife Service (USFWS)

Comprehensive Tax Reform. Pass-Through Rates. Completed Contract Method/ Section 460(e) Reform. Estate tax, generally. The American Job Builders Tax Reform Act. IRS (Reg) Title: Treatment of Certain Interests in Corporations as Stock or Indebtedness (RIN 1545-BN40). House Tax Reform "Blueprint." H.R. 5076: Main Street Fairness Act. IRS (Reg) Title: Estate, Gift, and Generation-skipping Transfer Taxes: Restrictions on Liquidation of an Interest (RIN 1545-BB71). H.R. 6100/ S. 3436: Protect Family Farms and Business Act.

Client expense: $550,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Occupational Safety & Health Administration (OSHA), SENATE

Estate Tax House and Senate Tax Reform Proposals Protect Family Farms and Businesses Act (HR 6100/S 3436)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 5818 Mandated Expenses Tax Relief Act; H.R. 1087 Wireless Telecommunications Tax and Fee Collection Fairness Act; H.R. 1397 Seniors Tax Simplification Act; H.R. 1528 End Discriminatory State Taxes for Automobile Rentals; H.R. 1643 Digital Goods and Services Tax Fairness Act; H.R. 1855/S.987 Small Business Tax Equity Act of 2015 ; H.R. 2315 Mobile Workforce State Income Tax Simplification Act; H.R. 27 Tax Code Termination Act; H.R. 2775 Remote Transactions parity Act ; H.R. 2842 Individual Rate Simplification Act; H.R. 2946 IncentivizeCorporate America Act; H.R. 3017 Invest in America Act; H.R. 3083 Bring Jobs Back to America Act; H.R. 3213 Fixed Asset Relief Act; H.R. 3267 Paycheck Relief Act; H.R. 4377 American Business Competiveness Act; H.R. 4518 Corporate Rate Equality and Trade Empowerment Jobs Act; H.R. 4581 Stop Corporate Earnings Stripping Act; H.R. 6098 Transparent Recognition of Unjustified Tax Hoarding in Government Act; H.R.2584 Buisness Activity Tax Simplification Act; H.R.5076 MainStreetFairnessAct; HR ___ Hybrid Origin Discussion Draft; S. 1261 Wireless Telecommunications Tax and Fee Collection Fairness Act; S. 3436/H.R. 6100 Protect Family Farms and Businesses Act.; S. 698 Marketplace Fairness Act; S.2650/H.R. 5946 United States Appreciation for Olympians and Paralympians Act;

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

Government targets: Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, SENATE

Support Thune letter of estate tax rules; Support HR 6100, estate tax calculation

Client expense: $68,769 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

IRS REG-108060-15IRS 385 Rule/Corp Inversions H.R. 5893o Regulation Without Representation Act of 2016 REG 163113-02/RIN 1545-BB71Section 2709 Gift and Estate Tax Valuation Changes H.R. 2775Remote Transaction Parity Act H.R. 3590Halt Tax Increases on the Middle Class and Seniors Act H.R. 5523Clyde-Hisch-Sowers RESPECT Act (IRS Asset Forfeiture H.R. 2315Mobile Workforce State Income Tax Simplification Act S. 2809IRS Audit Reforms H.R. 5361/S.3177Public Buildings Renewal Act N/AOnline Sales Tax Simplification Act HR 6270/S 3424Foreign Affiliate Reinsurance HR 1828Small Business Taxpayer Bill of Rights HR 6100/S 3436Protect Family Farms and Businesses Act, estate tax rules

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

Government targets: Education, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)

Comprehensive tax reform proposals, provisions with impact on corporations and pass-through entities; H.R. 6100, Protect Family Farms and Businesses Act; Treasury proposed "minority discount" rules.

Client expense: $140,000 · Firm income: Not reported

Government targets: Education, Dept of, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Treasury, Dept of

In support the Protect Family Farms and Businesses Act (S.3436, H.R. 6100), which prevents the implementation of regulations which repeal the use of valuation discounts upon transferring a business to a family member.

Client expense: Not reported · Firm income: Not reported

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

Comprehensive Tax Reform. Pass-Through Rates. Completed Contract Method/ Section 460(e) Reform. Estate tax, generally. The American Job Builders Tax Reform Act. IRS (Reg) Title: Treatment of Certain Interests in Corporations as Stock or Indebtedness (RIN 1545-BN40). House Tax Reform "Blueprint." H.R. 5076: Main Street Fairness Act. IRS (Reg) Title: Estate, Gift, and Generation-skipping Transfer Taxes: Restrictions on Liquidation of an Interest (RIN 1545-BB71). H.R. 6100/ S. 3436: Protect Family Farms and Business Act.

Client expense: $550,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Occupational Safety & Health Administration (OSHA), SENATE

Issues relating to federal tax reform; expired and expiring tax extender provisions slated to expire at the end of 2016 affecting agriculture and farmer cooperatives. Estate Tax legislation, H.R. 6100 the Protect Family Farms and Businesses Act, and S. 3436, Protect Family Farms and Businesses Act, affecting agriculture and farmer cooperatives.

Client expense: $308,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Commodity Futures Trading Commission (CFTC), Environmental Protection Agency (EPA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Transportation, Dept of (DOT), U.S. Trade Representative (USTR)

The organization supports replacing the current federal income tax with a system that is simple, transparent, revenue-neutral and equitable. As such, we are closely monitoring discussions in the House Ways and Means Committee and the Senate Finance Committee. We are also supportive of extending certain temporary tax provisions and maintaining the like-kind exchange provision in the Internal Revenue Code. Jobs and Premium Protection Act (S.183/H.R.928): Legislation that would repeal the tax levied on a health insurance company's net premium. The tax was included in the Patient Protection and Affordable Care Act, which Farm Bureau opposed. The organization supports S.183/H.R.928. Death Tax Repeal Act (S.860/H.R.1155): Legislation that would amend the Internal Revenue Code to repeal estate and generation-skipping transfer taxes. The organization opposes the estate tax and therefore supports S.860/H.R.1155. Marketplace Fairness Act of 2015 (S.698): Legislation that would allow each member state under the Streamlined Sales and Use Tax Agreement to require all sellers not qualifying for a small-seller exception to collect and remit sales and use taxes with respect to internet sales. Remote sellers with less than $1 million annual sales are excluded; those who are above the threshold would be provided software for collecting the tax. The organization supports fair competition between local and main street retailers and internet-only sellers. The House companion bill is H.R.2775, the Remote Transactions Parity Act. Farm Equipment Depreciation (S.2202/H.R.4474): Legislation to permanently reinstate five-year depreciation for farm equipment. The organization supports this change since agriculture is an equipment-heavy industry. The Protect Family Farms and Businesses Act (H.R.6100/S.3436): Legislation to prohibit the Internal Revenue Service from finalizing and implementing its proposed regulations on liquidation of an interest with respect to estate, gift, and generation-skipping transfer taxes. The organization opposes the rulemaking because it would make it more difficult for farmers and ranchers who operate family-owned partnerships, LLCs or corporations to transfer their farms and ranches to the next generation. Biodiesel Tax Incentive Reform and Extension Act of 2016 (H.R.5240): Legislation that would extend the $1-per-gallon tax credit for biodiesel through the end of 2019 and reform the credit from a blenders credit to a producers credit for fuel using U.S. commodities. The organization supports the bill.

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

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

H.R. 6100/S. 3436: Protect Family Farms and Businesses Act - provisions relating to proposed regulations relating to restrictions on liquidation of an interest with respect to estate, gift, and generation-skipping transfer taxes S860/HR725 Death Tax Repeal Act - provisions relating to estate tax repeal. S698 Marketplace Fairness Act - provisions relating to remittance of sales and use taxes H.R.2775 - Remote Transactions Parity Act of 2015 - provisions relating to remittance of sales and use taxes HR 2050/S 2045 Middle Class Health Benefits Tax Repeal Act - provisions relating to high cost employer sponsored health care plans

Client expense: $93,771 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Unnumbered Bill Related to Reform Legislation H.R. 3397 - Disaster Savings and Resilient Construction Act of 2015 Power-Take-Off Tax Correction Reintroduction of The Disaster Savings Accounts Act Multiemployer Pension Plan (MEPPs) Unnumbered Bills to Fix the Highway Trust Fund H.R. 6042 - To nullify certain proposed regulations relating to restrictions on liquidation of an interest with respect to estate, gift, and generation-skipping transfer taxes. H.R. 6100 - Protect Family Farms and Businesses Act Unnumbered Bills Related to the Airport and Airway Trust Fund

Client expense: $410,153 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), Federal Emergency Management Agency (FEMA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Natl Labor Relations Board (NLRB), Occupational Safety & Health Administration (OSHA), SENATE, State, Dept of (DOS), Transportation, Dept of (DOT)

Estate Tax- H.R. 1105 and H.R. 6100, Pass Through Entity Taxation-H.R. 5076 and H.R. 4377, LIFO- H.R. 4377, Craft Beverage Modernization Act of 2015- S.1562 and H.R. 2903

Client expense: $350,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Access to Capital: SBE Council continues to advocate for reforms and solutions to improve capital formation in the U.S. and access to capital for small businesses. Specific bills include: Fix Crowdfunding Act of 2016 (H.R. 4855): Supported House passage. Investment Advisers Modernization Act of 2016 (H.R. 5424): Supported House passage. Accelerating Access to Capital Act of 2015 (H.R. 2357): Supported House passage. Regulatory Reform and Modernization: SBE Council continues to voice support for comprehensive regulatory reform including streamlining regulations, more openness and transparency in the regulatory process, giving small businesses a meaningful voice in rulemakings, cost-benefit analysis, and looks-backs and sunsetting of regulations. Specific bills include: Regulatory Relief for Small Businesses, Schools, and Nonprofits Act (H.R. 6094): Supported House passage. Overtime Reform and Review Act (S. 3464): Support. The Financial CHOICE Act: Support House bill to reform Dodd-Frank and the financial regulatory system. Require Evaluation Before Implementing Executive Wishlists Act (REVIEW Act) of 2015 (H.R. 3438 and S. 1927): Supported House passage and Senate bill. Stop Settlement Slush Funds Act of 2016 (H.R. 5063 and S. 3050): Supported House passage and Senate bill. Regulatory Integrity Act of 2016 (H.R. 5226): Supported House passage. Federal Communications Commission rules on Set-Top-Box: Oppose proposed rulemaking and pushed for changes and a more open process. Postal Service Reform Act (H.R. 5714): Expressed concern to U.S. House about this bill. Protecting Workplace Advancement and Opportunity Act: Support. Overtime Reform and Enhancement Act (H.R. 5813): Support. EPA and the Clean Air Science Advisory Committee (CASAC): Urged the EPA to add diverse and neutral members of this advisory council. ADA Education and Reform Act of 2016 (H.R. 3765): Support Tax Reform and Relief: SBE Council continues to engage with Congress and the Administration on the need for tax system overhaul, fairness and simplicity for small businesses. Specific bills and actions include: Section 385 regulatory changes by U.S. Treasury: Expressed concern and opposed hasty changes. Mobile Workforce State Income Tax and Simplification Act of 2015 (H.R. 2315 and S. 386): Supported House passage and Senate bill. Empowering Employees Through Stock Ownership Act (H.R. 5719 and S. 3152): Supported House passage and Senate bill. U.S. Treasury regulatory changes to Estate, Gift, and Generation-skipping Transfer Taxes: Restrictions on Liquidation of an Interest: Oppose regulatory changes proposed by Treasury. Protect Family Farms and Businesses Act (H.R. 6100 and S. 3436): Support both bills. International Trade, Competitiveness and Tariff Relief, Intellectual Property: SBE Council continues to voice support for trade agreements and efforts to improve and simplify exporting for small businesses, and strengthening IP protections. Affordable Health Coverage and ACA Reform: SBE Council continues to support multiple efforts to fully reform the Affordable Care Act and replace with market-based alternatives and solutions that produce competition and lower costs for small businesses. Specific bills include: Halt Tax Increases on the Middle Class and Seniors Act (H.R. 3950): Supported House passage. CO-OP Consumer Protection Act of 2016 (H.R. 954): Supported House passage. Small Business Health Care Relief Act (S. 3060): Continue to push for Senate passage. Privacy and Cybersecurity: Improving Small Business Cybersecurity Act (H.R. 5064): Supported House passage Improving Small Business Cybersecurity Act (S. 3024): Support Senate bill. OTHER: Expressed support for Section 806 in S. 2943, the Senate version of the 2017 NDAA. Debt Management and Fiscal Responsibility Act of 2016 (S.3182): Support. Clyde-Hirsch-Sowers RESPECT Act (H.R. 5523): Supported House Passage.

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

Government targets: Environmental Protection Agency (EPA), Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

- Advocacy in support of Death Tax Repeal Act (HR 2429 / S 1183), which would repeal the estate tax. - Advocacy in support of S. 698 / H.R. 2775 (Marketplace Fairness Act/ Remote Transactions Parity Act) which address online sales tax avoidance. - Advocacy in support of H.R. 2096 / S. 1212 (Promotion & Expansion of Private Employee Ownership Act) which allows for more businesses to consider becoming ESOPs by addressing deficiencies within the tax code - Advocacy in support of the 25D and Section 48 (Geothermal) Tax Credit. - Advocacy in support of HR 6100, which would prevent a proposed change to Section 2704 by Treasury/ IRS from taking effect

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Legislative services related to energy tax issues and alternative fuel incentives. - H.R. 6228, Bill to extend and modify the alternative fuel credits - H.R. 6100, Protect Family Farms and Businesses Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE