Risk Management and Homeowner Stability Act of 2017

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination, H.R. 3556, the Taxpayer Protections for Mortgage Finance Act of 2017; S 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to Qualified Mortgages and mortgage origination; H.R. 4560, GSE Jumpstart Reauthorization Act of 2017, Bipartisan Housing Finance Reform Act of 2018

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

Government targets: Ginnie Mae, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, 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

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination, H.R. 3556, the Taxpayer Protections for Mortgage Finance Act of 2017; S 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to Qualified Mortgages and mortgage origination; H.R. 4560, GSE Jumpstart Reauthorization Act of 2017, Bipartisan Housing Finance Reform Act of 2018

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

Government targets: Ginnie Mae, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Treasury, Dept of

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination, H.R. 3556, the Taxpayer Protections for Mortgage Finance Act of 2017; S 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to Qualified Mortgages and mortgage origination;

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

Government targets: Ginnie Mae, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Treasury, Dept of

H.R. 916; Risk Management and Homeowner Stability Act; the bill would prohibit the use of Fannie Mae and Freddie Mac guarantee fees to offset the budget. H.R. 1694; Fannie and Freddie Open Records Act; the bill would require Fannie Mae and Freddie Mac to be subject to the Freedom of Information Act while in conservatorship. S. 2155; Economic Growth, Regulatory Relief, and Consumer Protection Act; which would make changes to the regulation of Property Assessed Clean Energy Loans, appraisals and qualified mortgages. H.R. 6746; Protecting American Taxpayers and Homeowners Act; the bill would reform the mortgage finance system; including the FHA home loan program and the conventional mortgage market. C.A.R. discussed the "Enterprise Paid Mortgage Insurance" pilot program with Fannie Mae and Freddie Mac.

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)

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.

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.

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination, H.R. 3556, the Taxpayer Protections for Mortgage Finance Act of 2017; S 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to Qualified Mortgages and mortgage origination;

Client expense: $128,000 · Firm income: Not reported

Government targets: Ginnie Mae, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Treasury, Dept of

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination, H.R. 3556, the Taxpayer Protections for Mortgage Finance Act of 2017; S 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to Qualified Mortgages and mortgage origination; H.R. 4560, GSE Jumpstart Reauthorization Act of 2017

Client expense: $128,000 · Firm income: Not reported

Government targets: Ginnie Mae, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Treasury, Dept of

H.R. 916; Risk Management and Homeowner Stability Act; the bill would prohibit the use of Fannie Mae and Freddie Mac guarantee fees to offset the budget. H.R. 1694; Fannie and Freddie Open Records Act; the bill would require Fannie Mae and Freddie Mac to be subject to the Freedom of Information Act while in conservatorship. S. 2155; Economic Growth, Regulatory Relief, and Consumer Protection Act; which would make changes to the regulation of Property Assessed Clean Energy Loans, appraisals and qualified mortgages

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. 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.

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination, H.R. 3556, the Taxpayer Protections for Mortgage Finance Act of 2017; S 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to Qualified Mortgages and mortgage origination.

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

Government targets: Ginnie Mae, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Treasury, Dept of

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination, H.R. 3556, the Taxpayer Protections for Mortgage Finance Act of 2017; S 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to Qualified Mortgages and mortgage origination.

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

Government targets: Ginnie Mae, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, 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 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.

H.R. 916; Risk Management and Homeowner Stability Act; the bill would prohibit the use of Fannie Mae and Freddie Mac guarantee fees to offset the budget. H.R. 1694; Fannie and Freddie Open Records Act; the bill would require Fannie Mae and Freddie Mac to be subject to the Freedom of Information Act while in conservatorship. S. 2155; Economic Growth, Regulatory Relief, and Consumer Protection Act; which would make changes to the regulation of Property Assessed Clean Energy Loans, appraisals and qualified mortgages

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. 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.

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

H.R. 916; Risk Management and Homeowner Stability Act; the bill would prohibit the use of Fannie Mae and Freddie Mac guarantee fees to offset the budget. H.R. 1694; Fannie and Freddie Open Records Act; the bill would require Fannie Mae and Freddie Mac to be subject to the Freedom of Information Act while in conservatorship. S. 2155; Economic Growth, Regulatory Relief, and Consumer Protection Act; which would make changes to the regulation of Property Assessed Clean Energy Loans, appraisals and qualified 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.

Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.

Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - including but not limited to any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; Treasury's report on FinTech and Innovation; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); HR 3978, the TRID Improvement Act; Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; FCC Oversight; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (HR 3758/S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; HR 4545, the Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Debt Collection Quantitative Disclosure Testing (OMB Control Number: 3170-XXXX; Docket No. CFPB-2017-00380); Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; Mortgage Servicing Rules under the Truth in Lending Act; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate Methodology; NCUA proposed 2018 and 2019 budgets; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76); H.R. 4464, the Common Sense Credit Union Capital Relief Act of 2017; HR 1457, the Making Online Banking Initiation Legal and Easy Act of 2017; S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act; HR 3221, the Securing Access to Affordable Mortgages Act; HR 3299, the Protecting Consumers' Access to Credit Act of 2017; HR 4296, related to operational risk capital requirements; Lawsuit abuse related to website access requirements under the Americans with Disabilities Act; More oversight of credit Bureaus including subjecting them to examinations related to data security; HR 2396, the Privacy Notification Technical Clarification Act; HR 2954, the Home Mortgage Disclosure Adjustment Act; HR 3072, the CFPB Examination and Reporting Threshold Act; HR 3299, the Protecting Consumers' Access to Credit Act; HR 3857, the Protecting Advice for Small Savers Act; Comments on Proposed Rule - Capital Planning and Supervisory Stress Testing (RIN: 3133-AE80; Comments on Notice of Proposed Rulemaking Regarding Accuracy of Advertising (RIN: 3133-AE78); Draft Strategic Plan (NCUA 2018-2022); Request for Delay of HMDA Implementation Deadline; CFPB Remittance Rule; NCUA Regulatory Reform Agenda; SBA Reducing Reg Burden RFI (Docket Number SBA-2017-0005); Mortgage Servicing Rules under RESPA (RIN 3170-AA77); NCUA Consideration of HMDA "good faith" compliance efforts in examination process; FCC expand its exigent circumstances exception for data breaches so CUs can contact members without limitation to provide notification and remediation options; IRS Tax Transcript Processing; OCC, FDIC, FRB: proposed Simplified Capital Requirements; FHFA Strategic Plan for fiscal years 2018-2022; Amendments to Federal Mortgage Disclosure Requirements under TILA (RIN 3170-AA61); Deferred Compensation Plans.

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination, H.R. 3556, the Taxpayer Protections for Mortgage Finance Act of 2017; S 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to Qualified Mortgages and mortgage origination.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination, H.R. 3556, the Taxpayer Protections for Mortgage Finance Act of 2017; S 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act, provisions related to Qualified Mortgages and mortgage origination.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 916; Risk Management and Homeowner Stability Act; the bill would prohibit the use of Fannie Mae and Freddie Mac guarantee fees to offset the budget. H.R. 1694; Fannie and Freddie Open Records Act; the bill would require Fannie Mae and Freddie Mac to be subject to the Freedom of Information Act while in conservatorship.

Client expense: $25,130 · 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)

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"

Client expense: $25,130 · Firm income: Not reported

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 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 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 HR3089 - Corporate Transparency Act of 2017 S1454 - TITLE Act S1717 - Corporate Transparency Act of 2017 Discussions with the Consumer Finance Protection Bureau (CFPB) regarding RESPA, TRID, and credit scoring. Discussions with the Federal Housing Finance Agency (FHFA) regarding single family rentals, fees, GSEs, and credit scoring. Discussions with the Department of the Treasury regarding money laundering, regulatory reform, and credit availability. Discussions with the Financial Crimes Enforcement Network (FinCEN) regarding money laundering.

Client expense: $11,140,000 · Firm income: Not reported

Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).

Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); "Development of a Private Flood Insurance Market" title of HR 3823; Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; QM safe harbor for portfolio loans; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; S.J. Res. 47/ H.J. Res. 111; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; thresholds related to open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency and Increased Efficiency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination; Credit Score Competition Act; S. 1717, the Corporate Transparency Act; HR 3971, the Community Institution Mortgage Relief Act of 2017; HR 3978, TRID Improvement Act of 2017; HR 2359, FCRA Liability Harmonization Act; keep NCUA out of the appropriations process; subject non-depository GLBA institutions to regular examinations; require credit reporting agencies to notify depository institutions when one of their accounts is breached; HR 3354 - retain the 3 member board structure at NCUA, CDFI funding, CDRLF full funding, change single director of CFPB to five member Board; support for recommendations in Treasury Report, A Financial System that Creates Economic Opportunities; Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure; Fannie Mae and Freddie Mac's Proposed Underserved Markets Plan; CFPB - 2013 RESPA Servicing Rule (Docket No. - 2017-0012); Dept of Labor - Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82; FHFA- Improving Language Access in Mortgage Lending and Servicing Request for Input; CFPB - Request for Information regarding the Ability-to-repay/QM Rule Assessment (Docket No. CFPB-2017-0014); Dept. of Treasury - Reducing Regulation and Controlling Regulatory Costs; Federal Reserve - Docket No. R-1564: Reg CC - Availability of Funds and Collection of Checks - The Expedited Funds Availability Act, Proposed Rule and Request for Comment - 82 Federal Register 25539 (June 2, 2017); NCUA - proposal to adopt procedures governing appeals to the Board; Voluntary Mergers of Federally Insured Credit Unions; NCUA - 2017 Regulatory Review; NCUA - Publish 2016 Annual Review Report; NCUA-Codify IRPS; NCUA - Standardized publication of Legal Opinion Letters; NCUA - Model Bylaws; NCUA - PAL Improvements; CFPB - Amendments to Rules Concerning Prepaid Accounts, RIN 3170-AA72; NCUA's proposal to close the temporary corporate credit union stabilization fund and set the share insurance fund normal operating level - return all of the money credit unions paid in and do not raise the NOL; FCC - In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17-59); NCUA - Corporate Credit Unions (RIN 3133-AE75); FHFA - FHLB Capital Requirements (RIN 2590-AA70); NCUA - Comments on Requirements for Insurance; NCUSIF Equity Distributions (RIN 3133-AE77); FHFA - 2018-2020 Enterprise Housing Goals (RIN 2590-AA81); CFPB - Small Business Lending (Docket No. CFPB-2017-0011); Dept. of Labor - Overtime Rule (RIN 1235-AA20); NCUA Emergency Mergers - Chartering and Field of Membership (RIN 3133-AE76).

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination, H.R. 3556, the Taxpayer Protections for Mortgage Finance Act of 2017.

Client expense: $160,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination, H.R. 3556, the Taxpayer Protections for Mortgage Finance Act of 2017.

Client expense: $160,000 · 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 S__ - Credit Scoring Competition Act High Volatility Commercial Real Estate (HVCRE) Rules HR2148 - Clarifying Commercial Real Estate Loans Discussions with the Consumer Finance Protection Bureau (CFPB) regarding QM rules, e-closings, and loan originator compensation. Discussions with the Federal Housing Finance Agency (FHFA) regarding single family rentals, fees, GSEs, and Fannie Mae and Freddie Mac capital reserves. Discussions with the Office of the Comptroller of the Currency (OCC) regarding HVCRE rules. Discussions with the Department of the Treasury regarding money laundering, GSE reform, regulatory reform, credit availability, and Fannie Mae and Freddie Mac capital reserves. Discussions with the Securities and Exchange Commission (SEC) regarding crowdfunding regulations and JOBS Act implementation.

Client expense: $10,920,000 · Firm income: Not reported

Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.

Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national data security standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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 and S. 836); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; alternative capital for credit unions; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); TILA/RESPA Integrated Disclosure Rule (TRID); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; do not cut funding for CDFI program; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Examination reform; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA business loan programs including but not limited to 7(a), 504, express and patriot; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Federal Reserve's role in developing an improved payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL and its implementation; National Credit Union Share Insurance Fund (NCUSIF) Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; protecting the NCUSIF; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; debt collection practices; Qualified Mortgages; Ability to Repay; Mortgage Servicing and Mortgage Servicing Assets; CFPB's Consumer Complaint Database; Home Mortgage Disclosure Act (HMDA) Requirements; Payday Lending; small dollar loans (PALs); Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act (TCPA), CG Docket No. 02-278 and CG Docket No. 05-338; TCPA lawsuit abuse; CDFI certification - eliminate redundant required documentation and lessen reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de novo credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws; examiner consistency; Financial Crimes Enforcement Network's (FinCEN) proposed update and revisions to the collection of Suspicious Activities Reports (SARs) required under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules; combat financial crimes; CFPB's rule governing Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z); Section 1071 of the Dodd Frank Act; open- and close-ended loans; Home Equity Lines of Credit (HELOCs); CFPB's remittance transfer rule; call report modernization; Equal Credit Opportunity Act (ECOA) and it's implementing, Regulation B; Alternative Data and Modeling Techniques in the Credit Process; do not bifurcate the credit union industry with arbitrary thresholds; Credit Card Accountability Responsibility and Disclosure Act (CARD Act); Allowable Charges and Fees Assessed Incident to VA-Guaranteed Home Loans; H.R. 1958 and S. 838, the Protecting Americans from Credit Entanglements Act; Property Assessed Clean Energy (PACE) loans; Overhead Transfer Rate; NCUA Budget Transparency; independent appeals process for credit unions; Credit Risk Transfer; Chattel Loans/duty to serve; H.R. 2133 and S. 1002, the Community Lending Enhancement and Regulatory Relief Act; Hold regulators accountable for cost and compliance burden estimates; NCUA exemption authority over CFPB rules as they relate to credit unions; regulatory coordination.

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination.

Client expense: $130,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Housing/GSE reform, mortgage insurance, housing issues; H.R. 916, Risk Management and Homeowner Stability Act of 2017, provisions relating to private mortgage insurance; H.R. 10, the Financial Choice Act of 2017, provisions related to Qualified Mortgages and mortgage origination; H.R. 1694, the Fannie and Freddie Open Records Act of 2017, provisions relating to private mortgage insurance; H.R. 2133, the CLEARR Act of 2017, provisions related to Qualified Mortgages and mortgage origination.

Client expense: $130,000 · Firm income: Not reported

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.

Client expense: $25,130 · Firm income: Not reported

H.R. 916; Risk Management and Homeowner Stability Act; the bill would prohibit the use of Fannie Mae and Freddie Mac guarantee fees to offset the budget. H.R. 1694; Fannie and Freddie Open Records Act; the bill would require Fannie Mae and Freddie Mac to be subject to the Freedom of Information Act while in conservatorship.

Client expense: $25,130 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Veterans Affairs, Dept of (VA)

H.R. 916 The Risk Management and Homeowner Stability Act Alternative Credit Score Models CFPB Ability to Repay Rule, Small Creditors/Rural Mortgages CLEAR Relief Act Community Lender Regulatory Relief and Consumer Protection Act Flood Insurance Reauthorization GSE Guarantee Fees as a Budget Offset GSE Reform Home Mortgage Disclosure Act (HMDA) Property Assessed Clean Energy (PACE) Loans Qualified Mortgages

Client expense: $990,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Congressional Budget Office (CBO), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Farm Credit Administration, Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, White House Office

G-Fees HR916 - Risk Management and Homeowner Stability Act of 2017 Affiliated Business Arrangements HR1153 - Mortgage Choice Act Discussions with House of Representatives offices regarding draft legislation clarifying the Basel III "High Volatility Commercial Real Estate" risk-weight rules for lenders. Discussions with the Consumer Finance Protection Bureau (CFPB) regarding QM rules. Discussions with the Federal Housing Finance Agency (FHFA) regarding single family rentals and guarantee fees. Discussions with the Office of the Comptroller of the Currency (OCC) regarding commercial lending. Discussions with the Financial Crimes Enforcement Network regarding money laundering. Discussions with the Department of the Treasury regarding money laundering, housing finance, and the GSEs. Discussions with the Securities and Exchange Commission (SEC) regarding crowdfunding regulations. Discussions with the Federal Reserve System regarding consumer lending and regulatory issues.

Client expense: $10,140,000 · Firm income: Not reported

Housing/GSE reform, mortgage insurance, housing issues, Dodd-Frank, H.R. 916, Risk Management and Homeowner Stability Act of 2017.

Client expense: $310,000 · Firm income: Not reported

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 deal that guaranteed the securitization of single-family residents owned and rented by a private company. 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.

Client expense: $47,567 · Firm income: Not reported

Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.

Preserving the credit union tax exemption; Repeal of the Durbin Amendment on debit interchange; Regulatory relief for credit unions and other community financial institutions; Exempting credit unions from the CFPB; CFPB should make greater use of its exemption authority granted by section 1022 of the Dodd-Frank Act; Reforms to the structure of the CFPB and its powers; data and cyber security - create a national datasecurity standard for retailers and others in the payments ecosystem not covered by the Gramm-Leach-Bliley Act; Housing Finance Reform - any reforms should ensure 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, 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); field of membership improvements for credit unions; reforms to credit union capital requirements, including creating a true risk-based capital system and allowing credit unions access to supplemental capital; H.R. 1244 - the Capital Access for Small Businesses and Jobs Act; regulation of FinTech companies; E-SIGN; Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA); Bank Secrecy Act; Anti-Money Laundering requirements; underwriting standards for loans; state usury laws; TCPA Reform - do not hinder credit unions their ability to contact members; Patent Reform - provide relief from practices of patent trolls; NFIP - flood insurance reauthorization and ensure that any changes do not negatively impact credit unions; The REINS Act (H.R. 26); Improve small business input on federal regulations; Regulatory Flexibility Act; Improvements to SBREFA panels; Improve or require agency regulatory guidance; the Financial CHOICE Act; requiring cost-benefit analysis; Community Financial Institution Exemption Act; Financial Services for the Underserved Act; NCUA's MBL rule for credit unions; Senior$afe Act (S. 223); Stop scams on Seniors; H.R. 916 - do not use g-fees for any purpose other than risk mitigation; the importance of CDFIs to credit unions; Raise thresholds in Dodd-Frank; Consumer Financial Protection Safety and Soundness Improvement Act; Greater pre-emption authority for the NCUA; Portfolio Lending and Mortgage Access Act; H.R. 1153 - points and fees; Preserving Access to Manufactured Housing Act; Regulatory Relief for Small Businesses; EMV chip technology is what makes the new cards more secure - PIN is a distraction from the real issue that is data security; party responsible for breached data should be liable for costs associated with breach; the TAILOR Act; operational improvements for credit unions; Subjects CFPB to Congressional appropriations process; Financial Institutions Examination Fairness and Reform Act; the FSOC Transparency and Accountability Act; Small Business Administration SBA 7(a) business loan program; Regulatory Accountability Act; Financial Institution Customer Protection Act - ending Operation Choke Point; use the appropriations process for regulatory relief; Loans in Areas Having Special Flood Hazards - Private Flood Insurance (RIN 3133-AE64); Future of the Payments system; Regulation D; Regulation CC; Military Lending Act; Protect responsible overdraft services; CECL implementation; National Credit Union Share Insurance Fund Premium and issues related to the National Credit Union Share Insurance Funds Equity Ratio; Federal Credit Union Loan Interest Rate Ceiling; Asset Securitization (RIN 3133-AE29); Freedom of Information Act; Federal Government Participation in the Automated Clearing House FISCAL-2016-0001; Consumer Access to Financial Records Docket No. CFPB-2016-0048; Executive Order on Core Principles for Regulating the US Financial System; FSOC Review Authority; UDAAP; CFPBs outline on debt collection practices; Qualified Mortgages; Mortgage Servicing and Mortgage Servicing Assets; Consumer Complaint Database; HMDA Requirements; Payday Lending; Prevent arbitration restrictions; TCPA - In the Matter of Rules and Regulations Implementing the Telephone Consumer Protection Act, CG Docket No. 02-278 and CG Docket No. 05-338; CDFI certification - eliminate redundant required documentation and lesses reporting burden; concerns regarding the entrance of Fannie and Freddie into the chattel loan market; DOL's Fiduciary Duty Rule, Conflict of Interest Rule - Retirement Investment (RIN 1210-AB79); DOD should exercise its authority to extend the MLA credit card exemption; Credit Union Small Business Lending Act - exclude SBA loans from the definition of "member business loans"; Issuing, improving, and adhering to guidance or published "best practices" at the SBA; streamline approval process for SBA loans; improve the user friendliness of the SBA One software; temporarily increase the guarantee on SBA loans; make it easier for credit unions to participate in SBA loan programs; provide more services to help credit unions form; streamline and shorten the application process including approval process for services allowed, and improve communication during the chartering process; NCUA should do more to provide structure and flexibility for the unique challenges that new credit unions face; NCUA and its examiners should establish timetables for responses at various stages of the chartering process and have some limited authority to provide flexibility on a case-by-case basis with new credit unions, such as additional time to build capital requirements or meet certain requirements; Congress should work to allow more flexibility in the Federal Credit Union Act when it comes to prompt corrective action capital requirements for de novo credit unions; field-of-membership (FOM) restrictions should be more accommodating for new credit unions; NCUA should ensure its examiners who are in the field and working with new credit unions, are carrying out the mission of OSCUI, have the ability and flexibility to work with new credit unions, and have the experience to understand business plans adopted by new credit unions; NCUA should take steps to ensure that there are not disconnects between headquarters and regional offices, and assign a specific contact at NCUA for the de nov credit union during the chartering process; modernize outdated governance provisions in the Federal Credit Union Act and its rules and regulations, and taking steps to reform its standard credit union bylaws.