End Banking for Human Traffickers Act of 2018

Issues related to anti-money laundering and incorporation transparency H.R. 3089 / S. 1717, The Corporate Transparency Act of 2017 H.R. 6068, Counter Terrorism and Illicit Finance Act H.R. 2219, End Banking for Human Traffickers Act S. 3153, Matthew Young Pollard Intelligence Authorization Act for Fiscal Years 2018 and 2019 Issues related to combating global corruption H.R. 5101, Kleptocracy Asset Recovery Rewards Act H.R.4519, To amend the Securities Exchange Act of 1934 to repeal certain disclosure requirements related to resource extraction, and for other purposes

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

Government targets: Federal Bureau of Investigation (FBI), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Office of Natl Drug Control Policy (NDCP), SENATE, State, Dept of (DOS), Treasury, Dept of

Eliminate the trade and travel embargoes against Cuba (Support HR 574 / S 1699) Support Peace in Sudan Support enhanced trade, aid, and development programs in Africa and the Caribbean Establish a Department of Peace (Support HR 1111) Increase stability in Haiti Oppose the confirmation of Mike Pompeo to serve as US Secretary of State Oppose the State Department's notice of its intention to implement further extreme vetting. The Department is proposing to collect from almost all visa applicants - among other things - social media identifiers, telephone numbers, and email addresses used in the past five years. Oppose the policy of separating parents from children apprehended at the U.S. border Support HR 2219, the End Banking for Human Traffickers Act

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

Government targets: Agriculture, Dept of (USDA), Bureau of Citizenship & Immigration Services (BCIS), Bureau of Prisons (BOP), Bureau of the Census, Centers For Disease Control & Prevention (CDC), Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Consumer Financial Protection Bureau (CFPB), Director of National Intelligence (ODNI), Education, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Reserve System, Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Social Security Administration (SSA), State, Dept of (DOS), Treasury, Dept of, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA), White House Office

Oppose any riders to Appropriations bill(s) which would place the Consumer Financial Protection Bureau under the appropriations process Oppose the leaked version of a housing finance proposal from U.S. Senators Bob Corker (TN) and Mark Warner (VA) that would severely harm Americas housing market. Our opposition is mainly rooted in the proposals negative impact on access, affordability, and market stability Oppose H.R. 1153-the Mortgage Choice Act of 2018, which creates a loophole that would allow loans with higher costs to the borrower to improperly meet the Qualified Mortgage (QM) standard Oppose S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act. The bill de-regulates the financial service industry by repealing several portions of the 2010 Dodd-Frank Wall Street Reform Act Oppose Section 104 of S. 2155, which requires tiered reporting of information under the Home Mortgage Disclosure Act (HMDA) and will result in the exemption of 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act Support GSE reform that contains language to: Preserve and Enhance Fair Housing and Anti-Discrimination Protections; Provide Broad Access for Borrowers, Institutions and Regions; Preserve the Systems Affordable Housing Mission, and the Availability of Inclusive Loan Products and Services; and protect taxpayers Oppose any bill or amendment which would cut the salaries of employees of the Consumer Financial Protection Bureau (CFPB) Oppose HR 1116, the TAILOR Act, which imposes hurdles on agencies adopting regulations, and requires them to revisit them, with burdensome requirements that regulations be tailored for different types of institutions, something agencies already take into account. The bill will make it harder to adopt, maintain or defend regulations Oppose HR 3072, the Bureau of Consumer Financial Protection Examination and Reporting Threshold Act of 2017, will eliminate the CFPB's authority to supervise banks from $10 billion to $50 billion, among the largest 2% of banks in the country Clarify and reiterate that we are opposed to S. 2155 and that we do not have a position on an amendment regarding credit scoring to be offered by Senator Scott (SC) to S. 2155 Oppose HR 5266 or any similar bill or amendment which would turn the leadership of the CFPB from a single director into a commission of 5. Oppose mandatory arbitration clauses for investors; support the SEC protecting investors rights to bring securities class action lawsuits Oppose S. J. Res. 57, which disapproves of a CFPB guidance aimed at restricting discrimination in auto lending Support a national cap on interest rates and fees at 36% to eliminate high-cost loans (support HR 3760 / S 1659) Support the amendment offered by Senator Cortez Masto (NV) to S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act to strike section 104 of the legislation. Section 104 is the section which would exempt 85% of depository institutions from full reporting of loan data under the Home Mortgage Disclosure Act (HMDA) Oppose S. 2155, because it does irreparable damage to fair lending protections against racial discrimination; it harms homebuyers; and it contains over two deregulatory provisions of the financial services industry that were put into place after the 2008 global crises Oppose H.R. 5266, the Financial Product Safety Commission Act of 2018 which would change the leadership structure of the CFPB from a single Director to a 5-member commission Oppose requiring the Consumer Financial Protection Bureau (CFPB) to re-evaluate the work of the CFPB Oppose changes to the CFPBs modus operendi that would make it more difficult for the agency to investigate potential violations of law and easier for lawbreakers to hamstring the bureau. Support the regulators preventing high-cost, usurious loans by banks and credit unions-whether short-term, balloon-payment payday loans (which banks sometimes call deposit advance loans) or longer-term high-cost installment loans or lines of credit, and regardless of whether the loans are made by banks directly or through partnerships with non-bank lenders. Oppose banning public access to the CFPB consumer complaint data base Oppose the CFPB revising the rules by which the Bureau brings administrative enforcement actions before Administrative Law Judges. This changes in procedure and the greater application of rules for federal court litigation would likely make it easier for defendants to slow down proceedings and otherwise obstruct the Bureaus enforcement process. Oppose S. 2702, the Business of Insurance Regulatory Reform Act of 2018. The bill limits the Consumer Financial Protection Bureaus (CFPBs) authority to enforce federal consumer financial protection laws against entities that are regulated by a state insurance regulator to the extent such person is engaged in the business of insurance. The bill threatens to have wide-ranging impacts that infringe on the CFPBs core authority to address problems with consumer financial products and services. Support the SEC urging delaying closing the comment period on their Regulation Best Interest regulatory package. Their entire regulatory approach rests on the questionable assumption that their proposed disclosures will enable investors to make an informed choice among different types of providers. Fortunately, they are planning to conduct investor testing of the disclosures, but they are not expected to complete that round of testing until after the comment period is scheduled to close August 7. We therefore support them keeping the comment period open until 90 days after they have completed and published the findings of their disclosure testing. Support the CFPBs current public complaint process Support the retention of the CFPBs inclusive, transparent, evidence-based and comprehensive rulemaking process Oppose riders to the Financial Services / General Government Appropriations bill for 2019 which would deregulate everything from the nations largest banks to high-frequency Wall Street traders to consumer lenders supervised by the Consumer Financial Protection Bureau Support a Community Reinvestment Act (CRA) which retains a local geographical focus; avoids simplistic measures of performance; safeguards vibrant public participation; maintains the importance of bank branches; retains its focus on low- and moderate-individuals and neighborhoods; penalizes, on CRA exams, discrimination and violation of anti-discrimination and pro-consumer laws; takes bank activity to people and communities of color into consideration; does not allow bank mergers after one or both of the banks fail a CRA exam; takes into consideration affiliate activities; recognizes community benefit agreements; and refines CRA rating to be more reflective of a banks activities Oppose the CFPB revisiting or weakening any existing regulations In order to stop abusive debt collection, support the following regulations: limit calls to one a week (with up to three attempted calls); require collectors to obey the consumers oral request to stop calling; ensure that newer communication technologies respect privacy, do not abuse or harass, and comply with the FDCPA; and prohibit the collection of time-barred debt or adopt very strict limits that prohibit suits on revived debt and limit communications to writings that include clear disclosures that the consumer cannot be sued Support the CFPB decision to refrain from revisiting or delaying the prepaid accounts rule (Regulations E and Z) that is scheduled to go into effect in 2019 Support the Consumer Financial Protection Bureaus remittance rule and urge the bureau not to revisit or weaken it. Support the CFPB (1) rescinding the rule permitting high pre-account opening fees on fee harvester cards that evade the CARD Act, (2) rescinding the ability-to-repay rule that permits consumers who do not have income to rely on household income even if they are not legally entitled to access Support that the FHFA (1) direct Fannie and Freddie to develop capital restoration plans, consistent with the capital and leverage standards being developed, and (2) suspend the net worth sweep in order to increase the GSEs capital buffer. Support existing regulations on the Truth in Savings Act, the Expedited Funds Availability Act, and the Fair lending Act and urge the CFPB not to weaken them Support the long-established disparate impact jurisprudence under the Equal Credit Opportunity Act (ECOA). Support the importance of Regulation B and the use of the disparate-impact doctrine in enforcement actions, examinations, and complaint investigations that have ECOA implications The CFPB must not adopt changes to its processes for using civil investigative demands that would hinder or delay its important work addressing potential legal violations. support and vote in favor of amendment #2157 to be offered by Senator Cortez Masto (NV) to S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act to strike section 104 of the legislation. Support HR 2219, the End Banking for Human Traffickers Act

Oppose any riders to Appropriations bill(s) which would place the Consumer Financial Protection Bureau under the appropriations process Oppose the leaked version of a housing finance proposal from U.S. Senators Bob Corker (TN) and Mark Warner (VA) that would severely harm Americas housing market. Our opposition is mainly rooted in the proposals negative impact on access, affordability, and market stability Oppose H.R. 1153-the Mortgage Choice Act of 2018, which creates a loophole that would allow loans with higher costs to the borrower to improperly meet the Qualified Mortgage (QM) standard Oppose S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act. The bill de-regulates the financial service industry by repealing several portions of the 2010 Dodd-Frank Wall Street Reform Act Oppose Section 104 of S. 2155, which requires tiered reporting of information under the Home Mortgage Disclosure Act (HMDA) and will result in the exemption of 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act Support GSE reform that contains language to: Preserve and Enhance Fair Housing and Anti-Discrimination Protections; Provide Broad Access for Borrowers, Institutions and Regions; Preserve the Systems Affordable Housing Mission, and the Availability of Inclusive Loan Products and Services; and protect taxpayers Oppose any bill or amendment which would cut the salaries of employees of the Consumer Financial Protection Bureau (CFPB) Oppose HR 1116, the TAILOR Act, which imposes hurdles on agencies adopting regulations, and requires them to revisit them, with burdensome requirements that regulations be tailored for different types of institutions, something agencies already take into account. The bill will make it harder to adopt, maintain or defend regulations Oppose HR 3072, the Bureau of Consumer Financial Protection Examination and Reporting Threshold Act of 2017, will eliminate the CFPB's authority to supervise banks from $10 billion to $50 billion, among the largest 2% of banks in the country Clarify and reiterate that we are opposed to S. 2155 and that we do not have a position on an amendment regarding credit scoring to be offered by Senator Scott (SC) to S. 2155 Oppose HR 5266 or any similar bill or amendment which would turn the leadership of the CFPB from a single director into a commission of 5. Oppose S. J. Res. 57, which disapproves of a CFPB guidance aimed at restricting discrimination in auto lending. Support a national cap on interest rates and fees at 36% to eliminate high-cost loans (support HR 3760 / S 1659) Support the amendment offered by Senator Cortez Masto (NV) to S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act to strike section 104 of the legislation. Section 104 is the section which would exempt 85% of depository institutions from full reporting of loan data under the Home Mortgage Disclosure Act (HMDA) Oppose S. 2155, because it does irreparable damage to fair lending protections against racial discrimination; it harms homebuyers; and it contains over two deregulatory provisions of the financial services industry that were put into place after the 2008 global crises Oppose H.R. 5266, the Financial Product Safety Commission Act of 2018 which would change the leadership structure of the CFPB from a single Director to a 5-member commission Oppose requiring the Consumer Financial Protection Bureau (CFPB) to re-evaluate the work of the CFPB Oppose changes to the CFPBs modus operendi that would make it more difficult for the agency to investigate potential violations of law and easier for lawbreakers to hamstring the bureau. Support the regulators preventing high-cost, usurious loans by banks and credit unions-whether short-term, balloon-payment payday loans (which banks sometimes call deposit advance loans) or longer-term high-cost installment loans or lines of credit, and regardless of whether the loans are made by banks directly or through partnerships with non-bank lenders. Oppose banning public access to the CFPB consumer complaint data base Oppose the CFPB revising the rules by which the Bureau brings administrative enforcement actions before Administrative Law Judges. This changes in procedure and the greater application of rules for federal court litigation would likely make it easier for defendants to slow down proceedings and otherwise obstruct the Bureaus enforcement process. Oppose S. 2702, the Business of Insurance Regulatory Reform Act of 2018. The bill limits the Consumer Financial Protection Bureaus (CFPBs) authority to enforce federal consumer financial protection laws against entities that are regulated by a state insurance regulator to the extent such person is engaged in the business of insurance. The bill threatens to have wide-ranging impacts that infringe on the CFPBs core authority to address problems with consumer financial products and services. Support the SEC urging delaying closing the comment period on their Regulation Best Interest regulatory package. Their entire regulatory approach rests on the questionable assumption that their proposed disclosures will enable investors to make an informed choice among different types of providers. Fortunately, they are planning to conduct investor testing of the disclosures, but they are not expected to complete that round of testing until after the comment period is scheduled to close August 7. We therefore support them keeping the comment period open until 90 days after they have completed and published the findings of their disclosure testing. Support the CFPBs current public complaint process Support the retention of the CFPBs inclusive, transparent, evidence-based and comprehensive rulemaking process Oppose riders to the Financial Services / General Government Appropriations bill for 2019 which would deregulate everything from the nations largest banks to high-frequency Wall Street traders to consumer lenders supervised by the Consumer Financial Protection Bureau Support a Community Reinvestment Act (CRA) which retains a local geographical focus; avoids simplistic measures of performance; safeguards vibrant public participation; maintains the importance of bank branches; retains its focus on low- and moderate-individuals and neighborhoods; penalizes, on CRA exams, discrimination and violation of anti-discrimination and pro-consumer laws; takes bank activity to people and communities of color into consideration; does not allow bank mergers after one or both of the banks fail a CRA exam; takes into consideration affiliate activities; recognizes community benefit agreements; and refines CRA rating to be more reflective of a banks activities. Oppose the CFPB revisiting or weakening any existing regulations In order to stop abusive debt collection, support the following regulations: limit calls to one a week (with up to three attempted calls); require collectors to obey the consumers oral request to stop calling; ensure that newer communication technologies respect privacy, do not abuse or harass, and comply with the FDCPA; and prohibit the collection of time-barred debt or adopt very strict limits that prohibit suits on revived debt and limit communications to writings that include clear disclosures that the consumer cannot be sued Support the CFPB decision to refrain from revisiting or delaying the prepaid accounts rule (Regulations E and Z) that is scheduled to go into effect in 2019 Support the Consumer Financial Protection Bureaus remittance rule and urge the bureau not to revisit or weaken it. Support the CFPB (1) rescinding the rule permitting high pre-account opening fees on fee harvester cards that evade the CARD Act, (2) rescinding the ability-to-repay rule that permits consumers who do not have income to rely on household income even if they are not legally entitled to access Support that the FHFA (1) direct Fannie and Freddie to develop capital restoration plans, consistent with the capital and leverage standards being developed, and (2) suspend the net worth sweep in order to increase the GSEs capital buffer. Support existing regulations on the Truth in Savings Act, the Expedited Funds Availability Act, and the Fair lending Acct and urge the CFPB not to weaken them Support the long-established disparate impact jurisprudence under the Equal Credit Opportunity Act (ECOA). Support the importance of Regulation B and the use of the disparate-impact doctrine in enforcement actions, examinations, and complaint investigations that have ECOA implications The CFPB must not adopt changes to its processes for using civil investigative demands that would hinder or delay its important work addressing potential legal violations. support and vote in favor of amendment #2157 to be offered by Senator Cortez Masto (NV) to S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act to strike section 104 of the legislation. Support HR 2219, the End Banking for Human Traffickers Act

HR 790-Return to Prudent Banking Act of 2017, S 881- 21st Century Glass-Steagall Act of 2017, Rep. Waters bill on breaking up banks, HR 477-Small Business, Mergers, Acquisitions and Brokerage Simplification Act of 2017, HR 1116-TAILOR Act of 2017, HR 1585-Fair Investment Opportunities for Professional Experts Act, HR 1645-Fostering Innovation Act of 2017, S 82/HR 399-Stop subsidizing Multi-million dollar corporate Business Act, HR 1153-Mortgage choice act of 2017, HR 3093-Investor, clarity and bank Purity Act, HR 3221-Seeing access to Affordable Mortgages Act, S 2155-Economic Growth, Regulatory relief & consumer protection act, HR 2219-End banking for Human Traffickers act of 2017, HR 2319-Consumer Financial Choice and Capital Markets Protection Act of 2017, Protect the CFPB, Dodd Frank, SEC nominee,

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

Government targets: Agriculture, Dept of (USDA), Education, Dept of, Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, Office of Government Ethics (OGE), SENATE, Securities & Exchange Commission (SEC), U.S. Trade Representative (USTR), White House Office