Financial Technology Protection Act

Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions; Credit union exemptions from the CFPB; Reforms to the structure of the CFPB and its powers; data and cyber security - creation of a national data security standard; Housing Finance Reform - ensuring that credit unions have unfettered access to the secondary mortgage market based on loan quality rather than quantity; Member Business Lending - raise the arbitrary cap, raise the de minimis exclusion; exempt loans to veterans from the definition of MBL, and exclude non-owner occupied, 1-4-family dwellings from the calculation of the cap on credit union member business loans (H.R. 389/S. 836); Capital Access for Small Businesses and Jobs Act (H.R. 1244); TRID Improvement Act (H.R. 5078/S. 2490); Bank Secrecy Act; FCC Oversight; Patent Reform - provide relief from practices of patent trolls; NFIP - National flood insurance program; The REINS Act (H.R. 26/S. 21); Regulatory Flexibility Act; Improve or require agency regulatory guidance; Financial CHOICE Act (H.R. 10); Community Financial Institution Exemption Act (H.R. 1264); Financial Services for the Underserved Act (H.R. 4665); Senior$afe Act (H.R. 3758/S. 223); Community Mortgage Lender Regulatory Act of 2017 (H.R. 1964); Securing Access to Affordable Mortgage Act of 2017 (H.R. 3221); Greater pre-emption authority for the NCUA; Mortgage Choice Act (H.R. 1153); Preserving Access to Manufactured Housing Act (H.R.1699/S. 1751); Consumer Financial Protection Board Act 2017 (S. 105); Financial Product Safety Commission Act of 2018 (H.R. 5266); TAILOR Act (H.R. 1116/S.366); CFPB Accountability Act of 2017 or the TABS Act of 2017 (H.R. 2553/S.387); Subject CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act (H.R. 4545/S. 2237); Expanding SBA business loan programs; Financial Institution Customer Protection Act (H.R. 2706); Financial services and general government appropriations bill; Home Mortgage Disclosure Adjustment Act (H.R. 2954/S. 1310); Home Mortgage Reporting Relief Act of 2017 (H.R. 4648); QM safe harbor for portfolio loans; Portfolio Lending and Mortgage Access Act (H.R. 2226/S. 2013); the Community Lending Enhancement and Regulatory Relief Act (H.R. 2133/S.1002); Common Sense Credit Union Capital Relief Act of 2017 (H.R. 4464); Risk-Based Capital; Common Sense Credit Union Capital Relief Act of 2018 (H.R. 5288/S.3750); Credit Score Competition Act (H.R. 898/S. 1685); Community Institution Mortgage Relief Act of 2017 (H.R. 3971); Small Business 7(a) Lending Oversight Reform Act (H.R. 4743/S.2283); Business of Insurance Regulatory Reform Act of 2017 (H.R. 3746); Subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; Protecting Americans from Credit Entanglements Act (H.R. 1958/S.838); Making Online Banking Initiation Legal and Easy Act of 2017 (H.R. 1457); Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155); Securing Access to Affordable Mortgages Act (H.R. 3221); Protecting Consumers' Access to Credit Act of 2017 (H.R. 3299); H.R. 4296 - related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; the ADA Education and Reform Act of 2017 (H.R. 620); CFPB Examination and Reporting Threshold Act (H.R. 3072). NCUA - Voluntary mergers; reforms to credit union capital requirements; supplemental capital for credit unions; FOM improvements; FCU interest rate cap; asset securitization authority for credit unions; Call report modernization; NCUSIF issues including NOL ratio and equity distribution; short-term small dollar lending; de novo charter process, approvals, and flexibility; consistent examination expectations; Issuance of clear UDAAP expectations; Exam appeals process; Codify IRPS; Bylaws ANPR; Capital Planning and Supervisory Stress Testing; Accuracy of Advertising; support for NCUA Regulatory Reform Agenda; Extend examination cycle for low-risk, well-run credit unions greater than $1 billion in assets; CFPB - Use of Section 1022 exemption authority; rulemakings related to debt collection, overdraft, qualified mortgage, ATR, mortgage servicing, consumer complaint database (and consumer inquiry handling process), Home Mortgage Disclosure Act (HMDA) requirements and reporting thresholds, implementation and examination, prepaid accounts; Section 1071 small business data collection; remittances rule and review; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); free access to credit scores for consumers; Amendments to TILA/RESPA Integrated Disclosure Rule (TRID); Dept. of Treasury - Executive Order implementation, streamlining CDFI certifications, CDFI and CDRLF funding; cybersecurity interagency coordination; Regulation of FinTech companies; Do not subject credit unions to the Community Reinvestment Act (CRA); FCC - TCPA reform and requirements, interpretations, and litigation, fighting robocalls; FHFA - chattel loans/duty to serve; GSEs use of alternative credit scores; Credit Risk Transfer transactions; implementation of the Common Securitization Platform (CSP) and Single Security; FHLB Capital Requirements; FHLB role in mortgage market; SBA - Expanding CU participation in SBA lending; Dept. of Defense - Military Lending Act (MLA) Final Rule changes, guidance and implementation; IRS - guidance related to the tax reform bill, including executive compensation excise tax; Dept. of Labor - Revocation of Fiduciary Duty rule and Overtime rule; Dept. of Justice - ADA standards and guidance related to website accessibility; FTC - frivolous demand letters in violation of the Federal Trade Commission Act; FinCEN - Burden related to Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules, raising the required SAR reporting threshold; combating financial crimes; Federal Reserve - Regulation CC; acceptance of electronically signed loans as pledged collateral; role in payments system; Electronic Signatures; NIST - framework for Improving Critical Infrastructure Cybersecurity; Dept. of VA - Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; FFIEC - evolution of the Cybersecurity Assessment Tool (CAT); FASB - CECL Accounting Standard implementation; Involuntary Liquidation of FCUs and Claims Procedures; Modernizing data collection for supervision of credit unions; FHFA's Affordable Housing Program; IRS oversight of credit unions; FinCEN's Customer Due Diligence Rule; CFPB Civil Investigative Demands and Associated processes; CFPB's Rules of Practice for Adjudication Proceedings; Collection of Checks and other items by Federal Reserve Banks and Funds Transfers Through Fedwire; CFPB's Enforcement Processes; Federal Credit Union Bylaws; CFPB's Supervision Program; Proposed Suspension and Debarment Procedures; FY'19 FSGG Appropriations Bill; CFPB's RFI regarding external engagements; Regulatory Review; CFPB's Rulemaking Processes; the Give Useful Information to Define Effective Compliance Act (H.R. 5534); the Counter Terrorism and Illicit Finance Act (H.R. 6068); Regulatory Changes in Light of S. 2155; CFPB's Adopted Regulations and New Rulemakings Authorities; Volker Rule; Feedback regarding operating vision for the US Faster Payments Council; CFPB's Inherited Regulations and Inherited Rulemaking Authorities; Title VII of H.R. 5841; CFPB financial education programs; financial literacy; Payday Alternative Loans (PALs); privacy risks regarding data sharing and section 1033 of Dodd-Frank; Disparate Impact Standard; Identity Fraud; Variable Interest Rates; Glass-Steagall Act; Credit Bureaus and the Fair Credit Reporting Act; NDAA - bank operations on military bases; USPS banking services; H.R. 5036, the Financial Technology Protection Act; H.R. 6743 - the Consumer Information Notification Requirement Act, NCUAs proposed rulemaking on loans and lines of credit (RIN 3133-AE88); CFPBs proposed policy to Encourage Trial Disclosure Program; NCUA budget; FHFAs Enterprise Capital Requirements (RIN 2590-AA95); FHFAs Uniform Mortgage-Backed Security (RIN 2590-AA94); NCUAs Real Estate Appraisals (3133-AE79); Potential Federal Reserve Actions to Support Interbank Settlement of Faster Payments, RFC (Docket No. OP-1625); SBAs Express Loan Programs; Affiliation Standards (RIN 3245-AG74); CFPB Data Collection and internal data governance policies RFI.

Client expense: $530,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

H.R. 10, Financial CHOICE Act of 2017 H.R. 21/S. 34, Midnight Rules Relief Act of 2017 H.R. 78, SEC Regulatory Accountability Act H.R. 79/S. 588, Helping Angels Lead Our Startups (HALOS) Act H.R. 238, Commodity End-User Relief Act H.R. 477, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2017 H.R. 1116, Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2017 H.R. 1153, Mortgage Choice Act of 2017 H.R. 1219/S. 444, Supporting America's Innovators Act of 2017 H.R. 1257, Securities and Exchange Commission Overpayment Credit Act H.R. 1312/S. 416, Small Business Capital Formation Enhancement Act H.R. 1343, Encouraging Employee Ownership Act of 2017 H.R. 1457, Making Online Banking Initiation Legal and Easy (MOBILE) Act of 2017 H.R. 1585, Fair Investment Opportunities for Professional Experts Act H.R. 1611, Gender Diversity in Corporate Leadership Act of 2017 H.R. 1645/S. 2126, Fostering Innovation Act of 2017 H.R. 1702, Small Business Development Centers Improvement Act of 2018 H.R. 2128, Due Process Restoration Act of 2017 H.R. 2201, Micro Offering Safe Harbor Act H.R. 2226/S. 2013, Portfolio Lending and Mortgage Access Act H.R. 2319, Consumer Financial Choice and Capital Markets Protection Act of 2018 H.R. 2396, Privacy Notification Technical Clarification Act H.R. 2553, Taking Account of Bureaucrats Spending (TABS) Act of 2017 H.R. 2706, Financial Institution Customer Protection Act of 2017 H.R. 3089, Corporate Transparency Act of 2017 H.R. 3093, Investor Clarity and Bank Parity Act H.R. 3179, Transparency and Accountability for Business Standards Act H.R. 3299, Protecting Consumers' Access to Credit Act of 2017 H.R. 3312/S. 1893, Systemic Risk Designation Improvement Act of 2017 H.R. 3746/S. 2702, Business of Insurance Regulatory Reform Act of 2017 H.R. 3762, International Insurance Standards Act of 2017 H.R. 3857, Protecting Advice for Small Savers (PASS) Act of 2017 H.R. 3860, IRS Data Verification Modernization Act of 2017 H.R. 3903/S. 2347, Encouraging Public Offerings Act of 2017 H.R. 3911, Risk-Based Credit Examination Act H.R. 3948, Protection of Source Code Act H.R. 3972, Family Office Technical Correction Act of 2017 H.R. 3973, Market Data Protection Act of 2017 H.R. 3978, TRID Improvement Act of 2017 H.R. 4015, Corporate Governance Reform and Transparency Act of 2017 H.R. 4061, Financial Stability Oversight Council Improvement Act of 2017 H.R. 4248, To amend the Securities Exchange Act of 1934 to repeal certain disclosure requirements related to conflict minerals, and for other purposes H.R. 4263, Regulation A+ Improvement Act of 2017 H.R. 4267, Small Business Credit Availability Act H.R. 4279, Expanding Investment Opportunities Act H.R. 4281/S. 2953, Expanding Access to Capital for Rural Job Creators Act H.R. 4289, To amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain disclosure requirements related to coal and mine safety H.R. 4292, Financial Institution Living Will Improvement Act of 2017 H.R. 4293, Stress Test Improvement Act of 2017 H.R. 4294, Prevention of Private Information Dissemination Act of 2017 H.R. 4296, To place requirements on operational risk capital requirements for banking organizations established by an appropriate Federal banking agency H.R. 4311, Foreign Investment Risk Review Modernization Act of 2017 H.R. 4519, To amend the Securities Exchange Act of 1934 to repeal certain disclosure requirements related to resource extraction, and for other purposes H.R. 4529, Accelerating Access to Capital Act of 2017 H.R. 4537, International Insurance Standards Act of 2017 H.R. 4545, Financial Institutions Examination Fairness and Reform Act H.R. 4550, Practice of Law Technical Clarification Act of 2017 H.R. 4566, Alleviating Stress Test Burdens to Help Investors Act H.R. 4607, Comprehensive Regulatory Review Act H.R. 4659, To require the appropriate Federal banking agencies to recognize the exposure-reducing nature of client margin for cleared derivatives H.R. 4753, Federal Reserve Supervision Testimony Clarification Act H.R. 4771, Small Bank Holding Company Relief Act of 2018 H.R. 4790, Volcker Rule Regulatory Harmonization Act H.R. 4861, Ensuring Quality Unbiased Access to Loans (EQUAL) Act of 2018 H.R. 5036, Financial Technology Protection Act H.R. 5051, Public Company Registration Threshold Act H.R. 5054, Small Company Disclosure Simplification Act of 2018 H.R. 5059, State Insurance Regulation Preservation Act H.R. 5105/S. 2436, Better Utilization of Investments Leading to Development (BUILD) Act of 2018 H.R. 5266, Financial Product Safety Commission Act of 2018 H.R. 5323, Derivatives Fairness Act H.R. 5534, Give Useful Information to Define Effective (GUIDE) Compliance Act H.R. 5645, Standard Merger and Acquisition Reviews Through Equal Rules Act of 2018 H.R. 5749, Options Markets Stability Act H.R. 5756, To require the Securities and Exchange Commission to adjust certain resubmission thresholds for shareholder proposals H.R. 5783, Cooperate with Law Enforcement Agencies and Watch Act of 2018 H.R. 5877, Main Street Growth Act H.R. 5970, Modernizing Disclosures for Investors Act H.R. 5999, Streamlining Communications for Investors Act H.R. 6021, Small Business Audit Correction Act of 2018 H.R. 6035, Streamlining Communications for Investors Act H.R. 6068, Counter Terrorism and Illicit Finance Act H.R. 6130, Helping Startups Continue to Grow Act H.R. 6139, Improving Investment Research for Small and Emerging Issuers Act H.R. 6158, Brokered Deposit Affiliate-Subsidiary Modernization Act of 2018 H.R. 6177, Developing and Empowering our Aspiring Leaders Act of 2018 H.R. 6319, Expanding Investment in Small Businesses Act H.R. 6320, Promoting Transparent Standards for Corporate Insiders Act H.R. 6321, Investment Adviser Regulatory Flexibility Improvement Act H.R. 6322, Enhancing Multi-Class Stock Disclosures Act H.R. 6324, Middle Market IPO Underwriting Cost Act S. 366, Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2017 S. 462, Securities and Exchange Commission Overpayment Credit Act S. 488, Encouraging Employee Ownership Act S. 488, JOBS and Investor Confidence Act of 2018 (House Amendment) S. 536, Cybersecurity Disclosure Act of 2017 S. 1117, Consumer Financial Choice and Capital Markets Protection Act of 2017 S. 1241, Combating Money Laundering, Terrorist Financing, and Counterfeiting Act of 2017 S. 1454, True Incorporation Transparency for Law Enforcement (TITLE) Act S. 1717, Corporate Transparency Act of 2017 S. 1744, Brokaw Act S. 2098, Foreign Investment Risk Review Modernization Act of 2017 S. 2155, Economic Growth, Regulatory Relief, and Consumer Protection Act S. 2499, A bill to require the Financial Industry Regulatory Authority to establish a relief fund to provide investors with the full value of unpaid arbitration awards issued against brokerage firms or brokers regulated by the Authority S. 2756, Fair Investment Opportunities for Professional Experts Act S. 2765, RBIC Advisers Relief Act of 2018 S. 3004, Small Business Audit Correction Act of 2018 S. 3421, Blue Sky Harmonization Act S. 3577, Financial Stability Oversight Council Improvement Act of 2018 S. 3614, Corporate Governance Fairness Act S. J. Res. 57, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act" Draft legislation titled Credit Services Protection Act of 2017 Draft legislation titled Counter Terrorism and Illicit Finance Act Draft legislation titled Data Acquisition and Technology Accountability and Security Act Draft legislation directing the Securities and Exchange Commission to increase and align the smaller reporting company and nonaccelerated filer financial thresholds Draft legislation to remove the limitation on large accelerated filers qualifying as an emerging growth company Draft legislation to require the Securities and Exchange Commission to revise the definition of a qualifying portfolio company to include an emerging growth company, for purposes of the exemption from registration for venture capital fund advisers under the Investment Advisers Act of 1940 Draft legislation to amend the Investment Company Act of 1940 to increase the percentage of voting shares a diversified company may hold in a single issuer Draft legislation on cryptocurrencies Potential legislation similar to H.R. 1090, Retail Investor Protection Act (114th Cong.) Potential legislation similar to H.R. 4294, Strengthening Access to Valuable Education and Retirement Support (SAVERS) Act of 2015 Proposed regulations on universal proxy (81 Fed. Reg. 79,122-79,186, November 10, 2016) Proposed rule on auditor independence with respect to certain loans or debtor-creditor relationships (83 Fed. Reg. 20,753-20,773, May 8, 2018) Proposed regulation on Regulation Best Interest (83 Fed. Reg. 21,574-21,682, May 9, 2018) Proposed Commission interpretation regarding standard of conduct for investment advisers; request for comment on enhancing investment (83 Fed. Reg. 21,203-21,214, May 9, 2018) Proposed rule on form CRS relationship summary; amendments to form ADV; required disclosures in retail communications and restrictions on the use of certain names or titles (83 Fed. Reg. 21,416-21,575, May 9, 2018) Policy to Encourage Trial Disclosure Programs (83 Fed. Reg. 45,574-45,578, September, 10, 2018) Federal Reserve, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Security Exchange Commission, Commodity Futures Trading Commission: Proposed Revisions to Prohibitions and Restrictions on Proprietary Trading and Certain Interests in, and Relationships with, Hedge Funds and Private Equity Funds - Docket No. OCC-2018-0010 (OCC); Docket No. R-1608 (Federal Reserve); RIN 3064-AE67 (FDIC); File Number S7- 14-18 (SEC); RIN 3038-AE72 (CFTC) Proposed changes to applicability thresholds for regulatory capital and liquidity requirements. Docket IDs: OCC-2018--0037 RIN 1557-AE56; Docket No. R-1628 RIN 7100-AF21 Nomination of Kathleen Kraninger to serve as Director of the Bureau of Consumer Financial Protection Nomination of Elad Roisman to serve as a Commissioner of the Securities and Exchange Commission Nomination of Dr. Dino Falaschetti to serve as Director of the Office of Financial Research Nomination of Jelena McWilliams to be Chair of the Federal Deposit Insurance Corporation Nomination of Kimberly Reed to serve as President of the Export-Import Bank of the United States (Ex-Im) Various issues relating to the implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act (P.L. 111-203); implementation of the Jumpstart Our Business Startups Act (P.L. 112-106); implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act (P.L. 115-174); Executive Order 13772, Core Principles for Regulating the United States Financial System; Presidential Memorandum for the Secretary of the Treasury regarding Orderly Liquidation Authority; Basel III capital standards, bank capital, and liquidity reform; Consumer Financial Protection Bureau (CFPB) transparency and accountability; CFPB regulatory sandbox for disclosures; CFPB reform; anti-money laundering and Bank Secrecy Act (P.L. 91-508) improvements; political spending disclosures; systemic risk regulation and Financial Stability Oversight Council (FSOC) designation of non-bank financial companies; Financial Stability Oversight Council (FSOC) reform; Department of Treasury review of FSOC determination and designation process; Federal Reserve: Enhanced Disclosure of the Models Used in the Federal Reserves Supervisory Stress Test, Docket No. OP-1586; Stress Testing Policy Statement, Docket No. OP-1587; Policy Statement on the Scenario Design Framework for Stress Testing, Docket No. OP-1588; Office of Financial Research transparency and accountability; reform of international standard setting bodies including Financial Stability Board, International Association of Insurance Supervisors and Basel Committee on Banking Supervision; Federal Reserve reform; Federal Reserve proposed guidance on supervisory expectation for boards of directors 2017-16735; proxy voting systems; Security Exchange Commission strategic plan; Security Exchange Commission Rule 701 Form S-8 reforms; Security Exchange Commission conflict mineral rule; Security Exchange Commission pay ratio rule; Security Exchange Commission Advisory Committee on Small and Emerging Companies; Security Exchange Commission request for information regarding standards of conduct for investment advisors and broker-dealers; Security Exchange Commission staff legal bulletin 141 (CF) shareholder proposals; Security Exchange Commission FAST Act (P.L. 114-94) modernization and simplification of regulations S-K file no. S7-08-17; Security Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; Security Exchange Commission auditor independence with respect to certain loans or debtor-creditor relationships file no. S7-10-18; Security Exchange Commission Staff Legal Bulletin 20 Proxy Voting: Proxy Voting Responsibilities of Investment Advisers and Availability of Exemptions from the Proxy Rules for Proxy Advisory Firms; Security Exchange Commission proposal on the use of derivatives by registered investment companies and business development companies; Security Exchange Commission capital, margin, and segregation requirements for security-based swap dealers and major security-based swap participants and capital requirements for broker-dealers (File No. S7-08-12); Consumer Financial Protection Bureau trial disclosures and no action letter process; Public Company Accounting Oversight Board (PCAOB) draft strategic plan for 2018-2022; Federal Trade Commission competition and consumer protection in the 21st century hearings regarding common ownership; disclosure requirements and materiality; JOBS Act 3.0; Accounting standards developed by the Financial Accounting Standards Board, including the current expected credit loss (CECL) standard; potential legislation to create legal framework for venture exchange; potential legislation on anti-money laundering and Bank Secrecy Act reporting improvements; credit bureau issues; financial technology issues; beneficial ownership; reforms to the Committee on Foreign Investment in the United States; modernization of the Community Reinvestment Act (P.L. 95-128); application of Customer Identification Program requirements under anti-money laundering rules to bank-affiliated premium finance companies; application of the May 2016 Customer Due Diligence Rule to routine cash refunds issued by bank-affiliated premium finance companies; proposals to audit the Board of Governors of the Federal Reserve System; small business lending; impact of prudential regulations on lending to small businesses by depository institutions; CFTC Proposed rulemaking on the De Minimis Exception to the Swap Dealer Definition; HUD proposed rulemaking regarding implementation of the Fair Housing Acts Disparate Impact Standard; Federal Trade Commission concerning Common Ownership; SEC proposed amendments to the Commissions Whistleblower Program rules; blockchain and fintech; adoption of the current expected credit loss accounting standard; proxy process, proxy advisory firms, and other related aspects of corporate governance

Client expense: $15,950,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), 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 Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), 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 Labor Relations Board (NLRB), Natl Security Council (NSC), Natl Telecommunications & Information Administration (NTIA), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), Office of the Vice President of the United States, Patent & Trademark Office (PTO), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Social Security Administration (SSA), 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. Trade Representative (USTR), White House Office

H.R. 10, Financial CHOICE Act of 2017 H.R. 21/S. 34, Midnight Rules Relief Act of 2017 H.R. 78, SEC Regulatory Accountability Act H.R. 79/S. 588, Helping Angels Lead Our Startups (HALOS) Act H.R. 238, Commodity End-User Relief Act H.R. 477, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2017 H.R. 1116, Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2017 H.R. 1153, Mortgage Choice Act of 2017 H.R. 1219/S. 444, Supporting America's Innovators Act of 2017 H.R. 1257, Securities and Exchange Commission Overpayment Credit Act H.R. 1312/S. 416, Small Business Capital Formation Enhancement Act H.R. 1343, Encouraging Employee Ownership Act of 2017 H.R. 1457, Making Online Banking Initiation Legal and Easy (MOBILE) Act of 2017 H.R. 1585, Fair Investment Opportunities for Professional Experts Act H.R. 1611, Gender Diversity in Corporate Leadership Act of 2017 H.R. 1645/S. 2126, Fostering Innovation Act of 2017 H.R. 1702, Small Business Development Centers Improvement Act of 2018 H.R. 2128, Due Process Restoration Act of 2017 H.R. 2201, Micro Offering Safe Harbor Act H.R. 2226/S. 2013, Portfolio Lending and Mortgage Access Act H.R. 2396, Privacy Notification Technical Clarification Act H.R. 2553, Taking Account of Bureaucrats Spending (TABS) Act of 2017 H.R. 2706, Financial Institution Customer Protection Act of 2017 H.R. 3089, Corporate Transparency Act of 2017 H.R. 3093, Investor Clarity and Bank Parity Act H.R. 3110, Financial Stability Oversight Council Insurance Member Continuity Act H.R. 3179, Transparency and Accountability for Business Standards Act H.R. 3299, Protecting Consumers' Access to Credit Act of 2017 H.R. 3312/S. 1893, Systemic Risk Designation Improvement Act of 2017 H.R. 3746/S. 2702, Business of Insurance Regulatory Reform Act of 2017 H.R. 3762, International Insurance Standards Act of 2017 H.R. 3857, Protecting Advice for Small Savers (PASS) Act of 2017 H.R. 3860, IRS Data Verification Modernization Act of 2017 H.R. 3903/S. 2347, Encouraging Public Offerings Act of 2017 H.R. 3911, Risk-Based Credit Examination Act H.R. 3948, Protection of Source Code Act H.R. 3972, Family Office Technical Correction Act of 2017 H.R. 3973, Market Data Protection Act of 2017 H.R. 3978, TRID Improvement Act of 2017 H.R. 4015, Corporate Governance Reform and Transparency Act of 2017 H.R. 4061, Financial Stability Oversight Council Improvement Act of 2017 H.R. 4248, To amend the Securities Exchange Act of 1934 to repeal certain disclosure requirements related to conflict minerals, and for other purposes H.R. 4263, Regulation A+ Improvement Act of 2017 H.R. 4267, Small Business Credit Availability Act H.R. 4279, Expanding Investment Opportunities Act H.R. 4281/S. 2953, Expanding Access to Capital for Rural Job Creators Act H.R. 4289, To amend the Dodd-Frank Wall Street Reform and Consumer Protection Act to repeal certain disclosure requirements related to coal and mine safety H.R. 4292, Financial Institution Living Will Improvement Act of 2017 H.R. 4293, Stress Test Improvement Act of 2017 H.R. 4294, Prevention of Private Information Dissemination Act of 2017 H.R. 4296, To place requirements on operational risk capital requirements for banking organizations established by an appropriate Federal banking agency H.R. 4311, Foreign Investment Risk Review Modernization Act of 2017 H.R. 4519, To amend the Securities Exchange Act of 1934 to repeal certain disclosure requirements related to resource extraction, and for other purposes H.R. 4529, Accelerating Access to Capital Act of 2017 H.R. 4537, International Insurance Standards Act of 2017 H.R. 4545, Financial Institutions Examination Fairness and Reform Act H.R. 4550, Practice of Law Technical Clarification Act of 2017 H.R. 4566, Alleviating Stress Test Burdens to Help Investors Act H.R. 4607, Comprehensive Regulatory Review Act H.R. 4659, To require the appropriate Federal banking agencies to recognize the exposure-reducing nature of client margin for cleared derivatives H.R. 4753, Federal Reserve Supervision Testimony Clarification Act H.R. 4771, Small Bank Holding Company Relief Act of 2018 H.R. 4790, Volcker Rule Regulatory Harmonization Act H.R. 4861, Ensuring Quality Unbiased Access to Loans (EQUAL) Act of 2018 H.R. 5036, Financial Technology Protection Act H.R. 5051, Public Company Registration Threshold Act H.R. 5054, Small Company Disclosure Simplification Act of 2018 H.R. 5059, State Insurance Regulation Preservation Act H.R. 5105/S. 2436, Better Utilization of Investments Leading to Development (BUILD) Act of 2018 H.R. 5192/S. 2498, Protecting Children from Identity Theft Act H.R. 5266, Financial Product Safety Commission Act of 2018 H.R. 5323, Derivatives Fairness Act H.R. 5534, Give Useful Information to Define Effective (GUIDE) Compliance Act H.R. 5645, Standard Merger and Acquisition Reviews Through Equal Rules Act of 2018 H.R. 5749, Options Markets Stability Act H.R. 5756, To require the Securities and Exchange Commission to adjust certain resubmission thresholds for shareholder proposals H.R. 5783, Cooperate with Law Enforcement Agencies and Watch Act of 2018 H.R. 5877, Main Street Growth Act H.R. 5970, Simplifying Disclosures for Investors Act H.R. 5999, Streamlining Communications for Investors Act H.R. 6021, Small Business Audit Correction Act of 2018 H.R. 6035, Streamlining Communications for Investors Act H.R. 6068, Counter Terrorism and Illicit Finance Act H.R. 6130, Helping Startups Continue to Grow Act H.R. 6139, Improving Investment Research for Small and Emerging Issuers Act H.R. 6158, Brokered Deposit Affiliate-Subsidiary Modernization Act of 2018 H.R. 6177, Developing and Empowering our Aspiring Leaders Act of 2018 H.R. 6319, Expanding Investment in Small Businesses Act H.R. 6320, Promoting Transparent Standards for Corporate Insiders Act H.R. 6321, Investment Adviser Regulatory Flexibility Improvement Act H.R. 6322, Enhancing Multi-Class Stock Disclosures Act H.R. 6324, Middle Market IPO Underwriting Cost Act S. 366, Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2017 S. 462, Securities and Exchange Commission Overpayment Credit Act S. 488, JOBS and Investor Confidence Act of 2018 S. 536, Cybersecurity Disclosure Act of 2017 S. 1117, Consumer Financial Choice and Capital Markets Protection Act of 2017 S. 1241, Combating Money Laundering, Terrorist Financing, and Counterfeiting Act of 2017 S. 1454, True Incorporation Transparency for Law Enforcement (TITLE) Act S. 1463, Financial Stability Oversight Council Insurance Member Continuity Act S. 1717, Corporate Transparency Act of 2017 S. 1744, Brokaw Act S. 2098, Foreign Investment Risk Review Modernization Act of 2017 S. 2155, Economic Growth, Regulatory Relief, and Consumer Protection Act S. 2499, A bill to require the Financial Industry Regulatory Authority to establish a relief fund to provide investors with the full value of unpaid arbitration awards issued against brokerage firms or brokers regulated by the Authority S. 2756, Fair Investment Opportunities for Professional Experts Act S. 2765, RBIC Advisers Relief Act of 2018 S. 3004, Small Business Audit Correction Act of 2018 S. 3421, Blue Sky Harmonization Act S. J. Res. 57, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act" Draft legislation titled Credit Services Protection Act of 2017 Draft legislation titled Counter Terrorism and Illicit Finance Act Draft legislation titled Data Acquisition and Technology Accountability and Security Act Draft legislation directing the Securities and Exchange Commission to increase and align the smaller reporting company and nonaccelerated filer financial thresholds Draft legislation to remove the limitation on large accelerated filers qualifying as an emerging growth company Draft legislation to require the Securities and Exchange Commission to revise the definition of a qualifying portfolio company to include an emerging growth company, for purposes of the exemption from registration for venture capital fund advisers under the Investment Advisers Act of 1940 Draft legislation to amend the Investment Company Act of 1940 to increase the percentage of voting shares a diversified company may hold in a single issuer Potential legislation similar to H.R. 1090, Retail Investor Protection Act (114th Cong.) Potential legislation similar to H.R. 4294, Strengthening Access to Valuable Education and Retirement Support (SAVERS) Act of 2015 Proposed regulations on universal proxy (81 Fed. Reg. 79,122-79,186, November 10, 2016) Proposed rule on auditor independence with respect to certain loans or debtor-creditor relationships (83 Fed. Reg. 20,753-20,773, May 8, 2018) Proposed regulation on Regulation Best Interest (83 Fed. Reg. 21,574-21,682, May 9, 2018) Proposed Commission interpretation regarding standard of conduct for investment advisers; request for comment on enhancing investment (83 Fed. Reg. 21,203-21,214, May 9, 2018) Proposed rule on form CRS relationship summary; amendments to form ADV; required disclosures in retail communications and restrictions on the use of certain names or titles (83 Fed. Reg. 21,416-21,575, May 9, 2018) Federal Reserve and the Office of the Comptroller of the Currency; Joint Notice of Proposed Rulemaking: Regulatory Capital Rules: Regulatory Capital, Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Important Bank Holding Companies and Certain of Their Subsidiary Insured Depository Institutions; Total Loss-Absorbing Capacity Requirements for U.S. Global Systemically Important Bank Holding Companies; Federal Reserve System Docket No. R-1604 and OCC Docket ID OCC-2018-0002 Nomination of Kathleen Kraninger to serve as Director of the Bureau of Consumer Financial Protection Nomination of Elad Roisman to serve as a Commissioner of the Securities and Exchange Commission Nomination of Dr. Dino Falaschetti to serve as Director of the Office of Financial Research Nomination of Jelena McWilliams to be Chair of the Federal Deposit Insurance Corporation Nomination of Kimberly Reed to serve as President of the Export-Import Bank of the United States (Ex-Im) Various issues relating to the implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act (P.L. 111-203); implementation of the Jumpstart Our Business Startups Act (P.L. 112-106); implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act (P.L. 115-174, section 215); Executive Order 13772, Core Principles for Regulating the United States Financial System; Presidential Memorandum for the Secretary of the Treasury regarding Orderly Liquidation Authority; Basel III capital standards, bank capital, and liquidity reform; Consumer Financial Protection Bureau (CFPB) transparency and accountability; CFPB regulatory sandbox for disclosures; CFPB consumer complaint database; CFPB reform; anti-money laundering and Bank Secrecy Act (P.L. 91-508) improvements; political spending disclosures; systemic risk regulation and Financial Stability Oversight Council (FSOC) designation of non-bank financial companies; Financial Stability Oversight Council (FSOC) reform; Department of Treasury review of FSOC determination and designation process; Federal Reserve: Enhanced Disclosure of the Models Used in the Federal Reserves Supervisory Stress Test, Docket No. OP-1586; Stress Testing Policy Statement, Docket No. OP-1587; Policy Statement on the Scenario Design Framework for Stress Testing, Docket No. OP-1588; Office of Financial Research transparency and accountability; reform of international standard setting bodies including Financial Stability Board, International Association of Insurance Supervisors and Basel Committee on Banking Supervision; Federal Reserve reform; Federal Reserve proposed guidance on supervisory expectation for boards of directors 2017-16735; proxy voting systems; Security Exchange Commission strategic plan; Security Exchange Commission Rule 701 Form S-8 reforms; Security Exchange Commission conflict mineral rule; Security Exchange Commission pay ratio rule; Security Exchange Commission Advisory Committee on Small and Emerging Companies; Security Exchange Commission request for information regarding standards of conduct for investment advisors and broker-dealers; Security Exchange Commission staff legal bulletin 141 (CF) shareholder proposals; Security Exchange Commission FAST Act (P.L. 114-94) modernization and simplification of regulations S-K file no. S7-08-17; Security Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; Security Exchange Commission auditor independence with respect to certain loans or debtor-creditor relationships file no. S7-10-18; Security Exchange Commission Staff Legal Bulletin 20 Proxy Voting: Proxy Voting Responsibilities of Investment Advisers and Availability of Exemptions from the Proxy Rules for Proxy Advisory Firms; Security Exchange Commission proposal on the use of derivatives by registered investment companies and business development companies; Security Exchange Commission standards of conduct for investment advisers and broker-dealers; Public Company Accounting Oversight Board (PCAOB), including draft strategic plan for 2018-2022; Federal Trade Commission competition and consumer protection in the 21st century hearings regarding common ownership; disclosure requirements and materiality; JOBS Act 3.0; potential legislation to create legal framework for venture exchange; credit bureau issues; tailoring bank rules to reduce the burden on small, midsize, and regional banks; beneficial ownership; reforms to the Committee on Foreign Investment in the United States; modernization of the Community Reinvestment Act (P.L. 95-128); application of Customer Identification Program requirements under anti-money laundering rules to bank-affiliated premium finance companies; application of the May 2016 Customer Due Diligence Rule to routine cash refunds issued by bank-affiliated premium finance companies; proposals to audit the Board of Governors of the Federal Reserve System; small business lending; consolidated asset thresholds related to the Advanced Approaches capital framework, the net stable fund ratio rule, and the liquidity coverage ratio rule; impact of prudential regulations on lending to small businesses by depository institutions; testimony by the Vice Chairman for Supervision, Federal Reserve Board, to the House Committee on Financial Services and the Senate Committee on Banking, Housing, and Urban Affairs; CFTC Proposed rulemaking on the De Minimis Exception to the Swap Dealer Definition; HUD proposed rulemaking regarding implementation of the Fair Housing Acts Disparate Impact Standard; Federal Trade Commission concerning Common Ownership; SEC proposed amendments to the Commissions Whistleblower Program rules; blockchain and fintech

Client expense: $17,560,000 · Firm income: Not reported

Government targets: Agency for Toxic Substances & Disease Registry, Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), 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 Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), 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 Labor Relations Board (NLRB), Natl Security Council (NSC), Natl Telecommunications & Information Administration (NTIA), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), Office of the Vice President of the United States, Patent & Trademark Office (PTO), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Social Security Administration (SSA), 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. Trade Representative (USTR), White House Office