Credit Score Competition Act of 2017

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

Providing greater access to protection under the Soldiers and Sailors Civil Relief Act to active duty service members. Exempting nationwide consumer reporting agencies from certain provisions of the Credit Repair Organizations Act. H.R. 435, The Credit Access and Inclusion Act of 2017, all provisions. H.R. 898, Credit Score Competition Act of 2017, all provisions. H.R. 2359, FCRA Liability Harmonization Act, all provisions. Issues relating to the provision of credit monitoring to federal employees were subject to a data breach of the Federal government. S. 2155, Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to credit freezes, active duty military alerts, veterans medical debt, and credit score competition. S. 3040, Credit Access and Inclusion Act of 2018, all provisions. S. 488, JOBS and Investor Confidence Act of 2018, provisions in Title II, Credit Access and Inclusion.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to credit scores, HR 898 - The Credit Score Competition Act and S. 2155.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

1. GSE Reform - General issues related to the preservation of a federal guaranty and the TBA (To-Be-Announced) market; support for increased participation of private capital; discussions/proposals related to credit risk transfer (CRT). Review and provide feedback on draft bipartisan bill to reform Fannie Mae and Freddie Mac 2. General Housing Finance Issues - Issues concerning FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP), including increased risk sharing, transparency, and industry participation. Providing commentary and analysis on the FHFA's proposed capital framework for the GSEs 3. Private-Label Securities (PLS) - General issues related to support for industry agreed-upon solutions arrived at in its RMBS 3.0 project for inclusion as part of any new structure for the return of private-label mortgage-backed securities; issues related to the facilitation of deal agent initiatives (PLS initiatives). 4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice, including lobbying and advocacy around proposed legislative fixes to the FCA.

Client expense: $110,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

G-Fees HR916 - Risk Management and Homeowner Stability Act of 2017 Affiliated Business Arrangements HR1153 - Mortgage Choice Act QRM Rules HR__ - FY2018 Appropriations Credit Scoring HR123 - FHA Alternative Credit Pilot Program Reauthorization Act of 2017 HR435 - The Credit Access and Inclusion Act of 2017 HR898 - Credit Score Competition Act of 2017 HR2262 - Free Credit Score Act of 2017 HR3911 - Risk-Based Credit Examination Act S1685 - Credit Scoring Competition Act Credit Reporting/Data Security HR3755 - Comprehensive Consumer Credit Reporting Reform Act of 2017 HR3766 - Credit Information Protection Act of 2017 HR3878 - Free Credit Freeze Act HR3896 - Secure and Protect Americans' Data Act S1816 - Freedom from Equifax Exploitation Act Student Loans HR795 - Employer Participation in Student Loan Assistance Act HR1635 - Empowering Students Through Enhanced Financial Counseling Act HR2477 - Bank on Students Emergency Loan Refinancing Act HR4508 - PROSPER Act S1162 - Bank on Students Emergency Loan Refinancing Act S1176 - Repay Act of 2017 High Volatility Commercial Real Estate (HVCRE) Rules HR2148 - Clarifying Commercial Real Estate Loans S2405 - Clarifying Commercial Real Estate Loans Beneficial Ownership Disclosure/Anti-Money Laundering HR3089 - Corporate Transparency Act of 2017 S1454 - TITLE Act S1717 - Corporate Transparency Act of 2017 S3336 - Defending American Security from Kremlin Aggression Act of 2018 Financial Regulatory Reform HR10 - Financial CHOICE Act of 2017 HR3971 - Community Institution Mortgage Relief Act of 2017 S2155 - Economic Growth, Regulatory Relief, and Consumer Protection Act Short Sales HR5237 - Fast Help For Homeowners Act CFPB Commission HR5266 - Financial Product Safety Commission Act of 2018 Seller Financing HR5287 - PARITY Act of 2018 Discussions with the Department of the Treasury regarding anti-money laundering, housing finance reform, credit availability, geographic targeting orders, and multifamily risk-sharing. Discussions with the Federal Housing Finance Agency (FHFA) regarding GSE guarantee fees (G-fees), housing finance reform, G-fees LLPAS (overlays), and capital standards. Discussions with the Consumer Financial Protection Bureau (CFPB) regarding the 3% cap. Discussions with the White House regarding GSE reform, agency nominations. Discussions with the National Economic Council (NEC) regarding GSE reform and GSE capital. Discussions with the Financial Crimes Enforcement Network (FinCEN) regarding anti-money laundering. Discussions with the Federal Housing Authority (FHA) within the Department of Housing and Urban Development (HUD) regarding student loan debt.

Client expense: $26,400,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Environmental Protection Agency (EPA), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, U.S. Copyright Office, U.S. Geological Survey (USGS), Veterans Affairs, Dept of (VA), White House Office

H.R. 898 Credit Score Competition Act; S. 1685 Credit Score Competition Act. Issues related to credit scoring. S. 2155, Economic Growth, Regulatory Relief, and Consumer Protection Act.

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

Government targets: HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Natl Economic Council (NEC), SENATE, Small Business Administration (SBA), Treasury, Dept of

H.R. 898 Credit Score Competition Act. S.1685 - Credit Score Competition Act of 2017. Issues related to credit scoring. S.2155 - Economic Growth, Regulatory Relief, and Consumer Protection Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA), Treasury, Dept of

Credit Score Competition Act of 2017 (S. 1685/H.R. 898), a bill to require Fannie Mae and Freddie Mac to establish a process to evaluate credit scoring models to determine whether lenders should have the option of using them in underwriting loans to be sold to either Fannie Mae or Freddie Mac; Implementation of Section 310 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (P.L. 115-174).

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE

Providing greater access to protection under the Soldiers and Sailors Civil Relief Act to active duty service members. Exempting nationwide consumer reporting agencies from certain provisions of the Credit Repair Organizations Act. H.R. 435, The Credit Access and Inclusion Act of 2017, all provisions. H.R. 898, Credit Score Competition Act of 2017, all provisions. H.R. 2359, FCRA Liability Harmonization Act, all provisions. Issues relating to the provision of credit monitoring to federal employees were subject to a data breach of the Federal government. S. 2155, Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to credit freezes, active duty military alerts, veterans medical debt, and credit score competition. S. 3040, Credit Access and Inclusion Act of 2018, all provisions.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 898; Credit Score Competition Act of 2017; To require Fannie Mae and Freddie Mac to establish procedures for considering certain credit scores in making a determination whether to purchase a residential mortgage, and for other purposes. H.R. 916; Risk Management and Homeowners Stability Act of 2017; The bill amends the Congressional Budget Act of 1974 to prohibit the chairs of the congressional budget committees from counting increases to guarantee fees as offsets for budget enforcement purposes. The bill includes an exception for legislation that increases guarantee fees to finance reforms to the secondary mortgage market. C.A.R. advocated the issue of mortgage finance reform with Congress. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac to consider a second manufactured home (that meets the real property definition) to be considered an accessory unit. C.A.R. advocated to the FHA and HUD to reinstate the policy to reduce the FHA mortgage insurance premium. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac to reduce the guarantee fee. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac the issue of doing business with institutional investors on single family residences for rent. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac the issue of assumable loans. C.A.R. advocated the impact of Home Equity Conversion Mortgages on the FHA's Mutual Mortgage Insurance Fund. C.A.R. advocated the issue of fees that are payable by Veterans in a VA financed real estate transaction. C.A.R. submitted comments on Docket ID OCC-2017-0011, Notice of Proposed Rulemaking and Request for Comment "Real Estate Appraisals" C.A.R. submitted comments to the Federal Housing Finance Agency on the Fannie Mae and Freddie Mac proposal to waive appraisals for mortgages. C.A.R. discussed the idea of a fee charged by the FHA to update its technology. C.A.R. advocated on the Federal Housing Finance Agency's Credit Score; Request for Information. C.A.R. advocated on the FHA proposed FHA condo rules. C.A.R. advocated on the current inclusion of FHA home equity conversion mortgages being included in the calculation of the FHA's Mutual Mortgage Insurance Fund's statutory reserve. C.A.R. advocated on the reduction of the guarantee-fees charged by Fannie Mae and Freddie Mac following the passage of H.R. 1.

Client expense: $48,158 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Environmental Protection Agency (EPA), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Veterans Affairs, Dept of (VA)

1. GSE Reform - General issues related to the preservation of a federal guaranty and the TBA (To-Be-Announced) market; support for increased participation of private capital; discussions/proposals related to credit risk transfer (CRT). 2. General Housing Finance Issues - Issues concerning FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP), including increased risk sharing, transparency, and industry participation. Providing commentary and analysis on the FHFA's proposed capital framework for the GSEs 3. Private-Label Securities (PLS) - General issues related to support for industry agreed-upon solutions arrived at in its RMBS 3.0 project for inclusion as part of any new structure for the return of private-label mortgage-backed securities; issues related to the facilitation of deal agent initiatives (PLS initiatives). 4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice, including lobbying and advocacy around proposed legislative fixes to the FCA.

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

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

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); 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.

Client expense: $590,000 · 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

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); 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.

Client expense: $590,000 · 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

Issues related to credit scores, HR 898 - The Credit Score Competition Act and S. 2155.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 898 Credit Score Competition Act; S. 1685 Credit Score Competition Act. Issues related to credit scoring. S. 2155, Economic Growth, Regulatory Relief, and Consumer Protection Act.

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

Government targets: HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Natl Economic Council (NEC), SENATE, Small Business Administration (SBA), Treasury, Dept of

H.R. 898 Credit Score Competition Act. S.1685 - Credit Score Competition Act of 2017. Issues related to credit scoring. S.2155 - Economic Growth, Regulatory Relief, and Consumer Protection Act.

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

Government targets: HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Natl Economic Council (NEC), SENATE, Small Business Administration (SBA), Treasury, Dept of

G-Fees HR916 - Risk Management and Homeowner Stability Act of 2017 Affiliated Business Arrangements HR1153 - Mortgage Choice Act QRM Rules HR__ - FY2018 Appropriations Credit Scoring HR123 - FHA Alternative Credit Pilot Program Reauthorization Act of 2017 HR435 - The Credit Access and Inclusion Act of 2017 HR898 - Credit Score Competition Act of 2017 HR2262 - Free Credit Score Act of 2017 HR3911 - Risk-Based Credit Examination Act S1685 - Credit Scoring Competition Act Credit Reporting/Data Security HR3755 - Comprehensive Consumer Credit Reporting Reform Act of 2017 HR3766 - Credit Information Protection Act of 2017 HR3878 - Free Credit Freeze Act HR3896 - Secure and Protect Americans' Data Act S1816 - Freedom from Equifax Exploitation Act Student Loans HR795 - Employer Participation in Student Loan Assistance Act HR1635 - Empowering Students Through Enhanced Financial Counseling Act HR2477 - Bank on Students Emergency Loan Refinancing Act HR4508 - PROSPER Act S1162 - Bank on Students Emergency Loan Refinancing Act S1176 - Repay Act of 2017 High Volatility Commercial Real Estate (HVCRE) Rules HR2148 - Clarifying Commercial Real Estate Loans S2405 - Clarifying Commercial Real Estate Loans Beneficial Ownership Disclosure/Anti-Money Laundering HR3089 - Corporate Transparency Act of 2017 S1454 - TITLE Act S1717 - Corporate Transparency Act of 2017 Financial Regulatory Reform HR10 - Financial CHOICE Act of 2017 HR3971 - Community Institution Mortgage Relief Act of 2017 S2155 - Economic Growth, Regulatory Relief, and Consumer Protection Act Short Sales HR5237 - Fast Help For Homeowners Act CFPB Commission HR5266 - Financial Product Safety Commission Act of 2018 Seller Financing HR5287 - PARITY Act of 2018 Discussions with the Department of the Treasury regarding anti-money laundering, housing finance reform, and credit availability. Discussions with the Federal Housing Finance Agency (FHFA) regarding GSE guarantee fees (G-fees), housing finance reform, and G-fees LLPAS (overlays). Discussions with the Consumer Financial Protection Bureau (CFPB) regarding Dodd-Frank, 3% cap. Discussions with the White House regarding housing finance reform.

Client expense: $14,200,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Labor, Dept of (DOL), SENATE, Treasury, Dept of, U.S. Agency for International Development (USAID), Veterans Affairs, Dept of (VA), White House Office

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 amendments; FCC Oversight; Patent Reform - provide relief from practices of patent trolls; NFIP - National flood insurance program reauthorization; 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); Common Sense Credit Union Capital Relief Act of 2018 (H.R. 5288); 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, 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 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; 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; suggested 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.

Client expense: $550,000 · 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

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 amendments; FCC Oversight; Patent Reform - provide relief from practices of patent trolls; NFIP - National flood insurance program reauthorization; 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); Common Sense Credit Union Capital Relief Act of 2018 (H.R. 5288); 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, 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 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; 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; suggested 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.

Client expense: $550,000 · 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

Providing greater access to protection under the Soldiers and Sailors Civil Relief Act to active duty service members. Exempting nationwide consumer reporting agencies from certain provisions of the Credit Repair Organizations Act. H.R. 435, The Credit Access and Inclusion Act of 2017, all provisions. H.R. 898, Credit Score Competition Act of 2017, all provisions. H.R. 2359, FCRA Liability Harmonization Act, all provisions. Issues relating to the provision of credit monitoring to federal employees were subject to a data breach of the Federal government. S. 2155, Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to credit freezes, active duty military alerts, veterans medical debt, and credit score competition. S. 3040, Credit Access and Inclusion Act of 2018, all provisions.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Credit Score Competition Act of 2017 (S. 1685/H.R. 898), a bill to require Fannie Mae and Freddie Mac to establish a process to evaluate credit scoring models to determine whether lenders should have the option of using them in underwriting loans to be sold to either Fannie Mae or Freddie Mac; Section 310 of the "Economic Growth, Regulatory Relief, and Consumer Protection Act" (S. 2155).

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE

Issues related to credit scores, HR 898 - The Credit Score Competition Act and S. 2155.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to credit scoring; Credit Repair Organizations Act draft legislation; H.R. 898 / S. 1685, Credit Score Competition Act of 2017; S. 2155, The Economic Growth, Regulatory Relief and Consumer Protection Act

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

Government targets: HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Natl Economic Council (NEC), SENATE, Treasury, Dept of

H.R. 898; Credit Score Competition Act of 2017; To require Fannie Mae and Freddie Mac to establish procedures for considering certain credit scores in making a determination whether to purchase a residential mortgage, and for other purposes. H.R. 916; Risk Management and Homeowners Stability Act of 2017; The bill amends the Congressional Budget Act of 1974 to prohibit the chairs of the congressional budget committees from counting increases to guarantee fees as offsets for budget enforcement purposes. The bill includes an exception for legislation that increases guarantee fees to finance reforms to the secondary mortgage market. C.A.R. advocated the issue of mortgage finance reform with Congress. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac to consider a second manufactured home (that meets the real property definition) to be considered an accessory unit. C.A.R. advocated to the FHA and HUD to reinstate the policy to reduce the FHA mortgage insurance premium. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac to reduce the guarantee fee. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac the issue of doing business with institutional investors on single family residences for rent. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac the issue of assumable loans. C.A.R. advocated the impact of Home Equity Conversion Mortgages on the FHA's Mutual Mortgage Insurance Fund. C.A.R. advocated the issue of fees that are payable by Veterans in a VA financed real estate transaction. C.A.R. submitted comments on Docket ID OCC-2017-0011, Notice of Proposed Rulemaking and Request for Comment "Real Estate Appraisals" C.A.R. submitted comments to the Federal Housing Finance Agency on the Fannie Mae and Freddie Mac proposal to waive appraisals for mortgages. C.A.R. discussed the idea of a fee charged by the FHA to update its technology. C.A.R. advocated on the Federal Housing Finance Agency's Credit Score; Request for Information. C.A.R. advocated on the FHA proposed FHA condo rules. C.A.R. advocated on the current inclusion of FHA home equity conversion mortgages being included in the calculation of the FHA's Mutual Mortgage Insurance Fund's statutory reserve. C.A.R. advocated on the reduction of the guarantee-fees charged by Fannie Mae and Freddie Mac following the passage of H.R. 1.

Client expense: $45,136 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Environmental Protection Agency (EPA), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Veterans Affairs, Dept of (VA)

1. GSE Reform - General issues related to the preservation of a federal guaranty and the TBA (To-Be-Announced) market; support for increased participation of private capital; discussions/proposals related to credit risk transfer (CRT). 2. General Housing Finance Issues - Issues concerning FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP), including increased risk sharing, transparency, and industry participation. Providing commentary and analysis on the FHFA's proposed capital framework for the GSEs 3. Private-Label Securities (PLS) - General issues related to support for industry agreed-upon solutions arrived at in its RMBS 3.0 project for inclusion as part of any new structure for the return of private-label mortgage-backed securities; issues related to the facilitation of deal agent initiatives (PLS initiatives). 4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice, including lobbying and advocacy around proposed legislative fixes to the FCA.

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

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Credit Score Competition Act of 2017 (S. 1685/H.R. 898), a bill to require Fannie Mae and Freddie Mac to establish a process to evaluate credit scoring models to determine whether lenders should have the option of using them in underwriting loans to be sold to either Fannie Mae or Freddie Mac; "Economic Growth, Regulatory Relief, and Consumer Protection Act" (S. 2155).

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE

LEGISLATIVE: 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 amendments; FCC Oversight; Patent Reform - provide relief from practices of patent trolls; NFIP - National flood insurance program reauthorization; 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); Common Sense Credit Union Capital Relief Act of 2018 (H.R. 5288); 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). REGULATORY: 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, qualified mortgage, ATR, mortgage servicing, consumer complaint database, 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 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; 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.

Client expense: $790,000 · 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

LEGISLATIVE: 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 amendments; FCC Oversight; Patent Reform - provide relief from practices of patent trolls; NFIP - National flood insurance program reauthorization; 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); Common Sense Credit Union Capital Relief Act of 2018 (H.R. 5288); 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). REGULATORY: 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, qualified mortgage, ATR, mortgage servicing, consumer complaint database, 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 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; 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.

Client expense: $790,000 · 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

1. GSE Reform - General issues related to the preservation of a federal guaranty and the TBA (To-Be-Announced) market; support for increased participation of private capital; discussions/proposals related to credit risk transfer (CRT). 2. General Housing Finance Issues - Issues concerning FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP), including increased risk sharing, transparency, and industry participation. 3. Private-Label Securities (PLS) - General issues related to support for industry agreed-upon solutions arrived at in its RMBS 3.0 project for inclusion as part of any new structure for the return of private-label mortgage-backed securities; issues related to the facilitation of deal agent initiatives (PLS initiatives). 4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice.

Client expense: $80,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

1. GSE Reform - General issues related to the preservation of a federal guaranty and the TBA (To-Be-Announced) market; support for increased participation of private capital; discussions/proposals related to credit risk transfer (CRT). 2. General Housing Finance Issues - Issues concerning FHFA's efforts to implement both a single-security (SS) and common securitization platform (CSP), including increased risk sharing, transparency, and industry participation. 3. Private-Label Securities (PLS) - General issues related to support for industry agreed-upon solutions arrived at in its RMBS 3.0 project for inclusion as part of any new structure for the return of private-label mortgage-backed securities; issues related to the facilitation of deal agent initiatives (PLS initiatives). 4. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 5. Credit Score Competition Act - (H.R.898), specifically, supporting a free-market approach to the GSE's use of alternative credit models. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice.

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

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 898 Credit Score Competition Act. S.1685 - Credit Score Competition Act of 2017. Issues related to credit scoring. S.2155 - Economic Growth, Regulatory Relief, and Consumer Protection Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA), Treasury, Dept of

H.R. 898 Credit Score Competition Act; S. 1685 Credit Score Competition Act. Issues related to credit scoring

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Small Business Administration (SBA), Treasury, Dept of

Providing greater access to protection under the Soldiers and Sailors Civil Relief Act to active duty service members. Exempting nationwide consumer reporting agencies from certain provisions of the Credit Repair Organizations Act. H.R. 435, The Credit Access and Inclusion Act of 2017, all provisions. H.R. 898, Credit Score Competition Act of 2017, all provisions. H.R. 2359, FCRA Liability Harmonization Act, all provisions. Issues relating to the provision of credit monitoring to federal employees were subject to a data breach of the Federal government. S. 2155, Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to credit freezes, active duty military alerts and veterans medical debt.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to credit scores, HR 898 - The Credit Score Competition Act and S. 2155.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to credit scoring; Credit Repair Organizations Act draft legislation; H.R. 898 / S. 1685, Credit Score Competition Act of 2017; S. 2155, The Economic Growth, Regulatory Relief and Consumer Protection Act

Client expense: $150,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

G-Fees HR916 - Risk Management and Homeowner Stability Act of 2017 Affiliated Business Arrangements HR1153 - Mortgage Choice Act QRM Rules HR__ - FY2018 Appropriations Credit Scoring HR123 - FHA Alternative Credit Pilot Program Reauthorization Act of 2017 HR435 - The Credit Access and Inclusion Act of 2017 HR898 - Credit Score Competition Act of 2017 HR2262 - Free Credit Score Act of 2017 HR3911 - Risk-Based Credit Examination Act S1685 - Credit Scoring Competition Act Credit Reporting/Data Security HR3755 - Comprehensive Consumer Credit Reporting Reform Act of 2017 HR3766 - Credit Information Protection Act of 2017 HR3878 - Free Credit Freeze Act HR3896 - Secure and Protect Americans' Data Act S1816 - Freedom from Equifax Exploitation Act Student Loans HR795 - Employer Participation in Student Loan Assistance Act HR1635 - Empowering Students Through Enhanced Financial Counseling Act HR2477 - Bank on Students Emergency Loan Refinancing Act HR4508 - PROSPER Act S1162 - Bank on Students Emergency Loan Refinancing Act S1176 - Repay Act of 2017 High Volatility Commercial Real Estate (HVCRE) Rules HR2148 - Clarifying Commercial Real Estate Loans S2405 - Clarifying Commercial Real Estate Loans Beneficial Ownership Disclosure/Anti-Money Laundering HR3089 - Corporate Transparency Act of 2017 S1454 - TITLE Act S1717 - Corporate Transparency Act of 2017 Financial Regulatory Reform HR10 - Financial CHOICE Act of 2017 HR3971 - Community Institution Mortgage Relief Act of 2017 S2155 - Economic Growth, Regulatory Relief, and Consumer Protection Act Short Sales HR5237 - Fast Help For Homeowners Act CFPB Commission HR5266 - Financial Product Safety Commission Act of 2018 Discussions with the Senate regarding the nomination of David C. Tryon to be the Chief Counsel of Advocacy to the Small Business Administration (SBA) and GSE reform. Discussions with the House of Representatives regarding anti-money laundering and GSE reform. Discussions with the Department of the Treasury regarding financial institutions regulatory reform, anti-money laundering, and Government Sponsored Entities (GSE) reform. Discussions with the Federal Housing Finance Agency (FHFA) regarding credit scores and GSE guarantee fees (G-fees). Discussions with the Consumer Financial Protection Bureau (CFPB) regarding RESPA.

Client expense: $13,040,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Labor, Dept of (DOL), SENATE, Treasury, Dept of, U.S. Geological Survey (USGS), Veterans Affairs, Dept of (VA)

H.R. 898; Credit Score Competition Act of 2017; To require Fannie Mae and Freddie Mac to establish procedures for considering certain credit scores in making a determination whether to purchase a residential mortgage, and for other purposes. H.R. 916; Risk Management and Homeowners Stability Act of 2017; The bill amends the Congressional Budget Act of 1974 to prohibit the chairs of the congressional budget committees from counting increases to guarantee fees as offsets for budget enforcement purposes. The bill includes an exception for legislation that increases guarantee fees to finance reforms to the secondary mortgage market. C.A.R. advocated the issue of mortgage finance reform with Congress. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac to consider a second manufactured home (that meets the real property definition) to be considered an accessory unit. C.A.R. advocated to the FHA and HUD to reinstate the policy to reduce the FHA mortgage insurance premium. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac to reduce the guarantee fee. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac the issue of doing business with institutional investors on single family residences for rent. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac the issue of assumable loans. C.A.R. advocated the impact of Home Equity Conversion Mortgages on the FHA's Mutual Mortgage Insurance Fund. C.A.R. advocated the issue of fees that are payable by Veterans in a VA financed real estate transaction. C.A.R. submitted comments on Docket ID OCC-2017-0011, Notice of Proposed Rulemaking and Request for Comment "Real Estate Appraisals" C.A.R. submitted comments to the Federal Housing Finance Agency on the Fannie Mae and Freddie Mac proposal to waive appraisals for mortgages. C.A.R. discussed the idea of a fee charged by the FHA to update its technology. C.A.R. advocated on the Federal Housing Finance Agency's Credit Score; Request for Information. C.A.R. advocated on the FHA proposed FHA condo rules. C.A.R. advocated on the current inclusion of FHA home equity conversion mortgages being included in the calculation of the FHA's Mutual Mortgage Insurance Fund's statutory reserve. C.A.R. advocated on the reduction of the guarantee-fees charged by Fannie Mae and Freddie Mac following the passage of H.R. 1.

Client expense: $45,136 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Environmental Protection Agency (EPA), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Veterans Affairs, Dept of (VA)

H.R. 1345, Protect Children from Theft Act of 2017 - as it relates to protecting the credit of minors. H.R. 759, Ability to Repay Verification Enabling Act -as it relates to income and employment. H.R. 898, Credit Score Competition Act of 2017 - as it relates to credit scores and for other purposes. S. 744, Protecting Veterans Credit Act of 2017 - as it relates to credit reports. S. 314, FIX Credit Reporting Errors Act as it relates to FCRA. H.R. 402, the Fair Access to Credit Scores Act - as it relates it relates to credit scores. H.J Res. 111 - Providing for Congressional Disapproval under chapter 8, of title 5, United States code, of the rules submitted by Bureau of Consumer Financial Protection, relating to "Arbitration Agreements" Issues as it pertains to arbitration. S.J.Res.47-A joint resolution providing for Congressional Disapproval under chapter 8, of title 5, United States code, of the rules submitted by Bureau of Consumer Financial Protection, relating to "Arbitration Agreements". Issues as it pertains to arbitration. H.R.2359-FCRA Liability Harmonization Act-issues as it pertains to FCRA Liability Reform H.R.3755,Comprehensive Consumer Credit Reporting Reform Act of 2017, issues as it relates to the FCRA S.1819,Equal Employment for All Act of 2017, issues as it relates to employment screening H.R.3783,Equal Employment for All Act of 2017, issues as it relates to employment screening S.1815,Data Broker Accountability and Transparency Act of 2017, issues as it relates to data brokers S.1810,Free Credit Freeze Act, issues as it relates to credit freeze S.1758,Tenant Protection Act, issues as it relates to residential screening H.R.759, Ability to Repay Verification Enabling Act, issues as it relates to unemployment compensation S.1066,Federal Adjustment in Reporting Student Credit Act of 2017, issues as it relates to student lending S.1816, Freedom from Equifax Exploitation Act, issues as it relates to the FCRA H.R.435, The Credit Access and Inclusion Act of 2017, issues as it relates to alternative data H.R.2262, Free Credit Score of 2017, issues as it relates to credit scores H.R.3766,Credit Information Protection Act of 2017, issues as it relates to credit freeze H.R.3539, Mug Shots Elimination Act of 2017, issues as it relates to mug shots H.R.3878, Free Credit Freeze Act, issues as it relates to credit freeze H.R.4028, PROTECT Act of 2017, Issues as it relates to the FCRA H.R.1982,PROTECT Act of 2017, issues as it relates to the FCRA H.Con. Res.71,Budget Reconciliation, issues as it relates to privacy

Client expense: $170,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE

Ability to Repay Verification Enabling Act (State Unemployment Agencies) - HR 759. Free Annual Credit Report Credit Score Inclusion - HR 402. Veteran medical debt information - S 744. FCRA and Consumer report disputes - S 314. Protect the credit of minors - HR 1345. Credit Score Competition Act of 2017. Fannie Mae and Freddie Mac to establish procedures for considering credit scores in determinating whether to purchase a residential mortgage - HR 898. Positive/alternative Consumer Credit Information from Utilities and telecom companies - HR 435. Alternative Scores for Fannie Mae and Freddie Mac. Credit Repair Organizations Act. CFPB's Consumer complaint database. Data security and breach notification. Data Broker accuracy of collected personal information. Data encryption. Military lending act and Department of Defense - Employment, income and status. CFPB - "Credit invisibles" and the "Unscoreable" - Consumers with a lack of credit history. CFPB - Use of arbitration agreements involving consumer financial products and services. CFPB - Short term, small dollar lending. Alternative credit data - Telecom, utilities reporting consumer payment information to national credit bureaus. Credit access and inclusion. FCC Lifeline Program - HR 1139, HR 1469, HR 1591, S 421. Cybersecurity threat information sharing. Improper benefits (Improper payments). FCRA liability

Client expense: $250,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), SENATE, Social Security Administration (SSA), Treasury, Dept of

H.R. 898; Credit Score Competition Act of 2017; To require Fannie Mae and Freddie Mac to establish procedures for considering certain credit scores in making a determination whether to purchase a residential mortgage, and for other purposes. H.R. 916; Risk Management and Homeowners Stability Act of 2017; The bill amends the Congressional Budget Act of 1974 to prohibit the chairs of the congressional budget committees from counting increases to guarantee fees as offsets for budget enforcement purposes. The bill includes an exception for legislation that increases guarantee fees to finance reforms to the secondary mortgage market. C.A.R. advocated the issue of mortgage finance reform with Congress. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac to consider a second manufactured home (that meets the real property definition) to be considered an accessory unit. C.A.R. advocated to the FHA and HUD to reinstate the policy to reduce the FHA mortgage insurance premium. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac to reduce the guarantee fee. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac the issue of doing business with institutional investors on single family residences for rent. C.A.R. advocated to the FHFA, Fannie Mae and Freddie Mac the issue of assumable loans. C.A.R. advocated the impact of Home Equity Conversion Mortgages on the FHA's Mutual Mortgage Insurance Fund. C.A.R. advocated the issue of fees that are payable by Veterans in a VA financed real estate transaction. C.A.R. submitted comments on Docket ID OCC-2017-0011, Notice of Proposed Rulemaking and Request for Comment "Real Estate Appraisals" C.A.R. submitted comments to the Federal Housing Finance Agency on the Fannie Mae and Freddie Mac proposal to waive appraisals for mortgages.

Client expense: $33,034 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Veterans Affairs, Dept of (VA)

G-Fees HR916 - Risk Management and Homeowner Stability Act of 2017 Affiliated Business Arrangements HR1153 - Mortgage Choice Act QRM Rules HR__ - FY2018 Appropriations Credit Scoring HR123 - FHA Alternative Credit Pilot Program Reauthorization Act of 2017 HR435 - The Credit Access and Inclusion Act of 2017 HR898 - Credit Score Competition Act of 2017 HR2262 - Free Credit Score Act of 2017 HR3911 - Risk-Based Credit Examination Act S1685 - Credit Scoring Competition Act Credit Reporting/Data Security HR3755 - Comprehensive Consumer Credit Reporting Reform Act of 2017 HR3766 - Credit Information Protection Act of 2017 HR3878 - Free Credit Freeze Act HR3896 - Secure and Protect Americans' Data Act S1816 - Freedom from Equifax Exploitation Act Student Loans HR795 - Employer Participation in Student Loan Assistance Act HR1635 - Empowering Students Through Enhanced Financial Counseling Act HR2477 - Bank on Students Emergency Loan Refinancing Act HR4508 - PROSPER Act S1162 - Bank on Students Emergency Loan Refinancing Act S1176 - Repay Act of 2017 High Volatility Commercial Real Estate (HVCRE) Rules HR2148 - Clarifying Commercial Real Estate Loans Beneficial Ownership Disclosure/Anti-Money Laundering HR3089 - Corporate Transparency Act of 2017 S1454 - TITLE Act S1717 - Corporate Transparency Act of 2017 Financial Regulatory Reform HR10 - Financial CHOICE Act of 2017 HR3971 - Community Institution Mortgage Relief Act of 2017 S2155 - Economic Growth, Regulatory Relief, and Consumer Protection Act Discussions with the House of Representatives regarding anti-money laundering. Discussions with the Consumer Finance Protection Bureau (CFPB) regarding RESPA, and TRID. Discussions with the Federal Housing Finance Agency (FHFA) regarding GSE reform, credit scoring, and credit availability. Discussions with the Department of the Treasury regarding money laundering, credit availability, and GSE reform. Discussions with the Financial Crimes Enforcement Network (FinCEN) regarding money laundering. Discussions with the Federal Reserve regarding high volatility acquisition, development, and construction loans for commercial real estate. Discussions with the Office of the Comptroller of the Currency (OCC) regarding high volatility acquisition, development, and construction loans for commercial real estate. Discussions with the Federal Deposit Insurance Corporation (FDIC) regarding high volatility acquisition, development, and construction loans for commercial real estate. Discussions with the Small Business Administration (SBA) regarding small business loans. Discussions with the Securities and Exchange Commission (SEC) regarding crowdfunding rules and small business capital raising.

Client expense: $22,200,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), 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, Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, U.S. Copyright Office, U.S. Geological Survey (USGS), Veterans Affairs, Dept of (VA), White House Office

H.R. 898 Credit Score Competition Act. S.1685 - Credit Score Competition Act of 2017. Issues related to credit scoring

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 898 Credit Score Competition Act; S. 1685 Credit Score Competition Act. Issues related to credit scoring

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to credit scoring; Credit Repair Organizations Act draft legislation; H.R. 898/S. 1685, Credit Score Competition Act of 2017

Client expense: $110,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE