vs 9,062 other HR bills in the 116th — cohort avg 39d
Summary
Secure and Fair Enforcement Banking Act of 2019 or the SAFE Banking Act of 2019 This bill generally prohibits a federal banking regulator from penalizing a depository institution for providing banking services to a legitimate marijuana- or hemp-related business. Specifically, the bill prohibits a federal banking regulator from (1) terminating or limiting the deposit insurance or share insurance of a depository institution solely because the institution provides financial services to a legitimate marijuana- or hemp-related business; (2) prohibiting or otherwise discouraging a depository institution from offering financial services to such a business; (3) recommending, incentivizing, or encouraging a depository institution not to offer financial services to an account holder solely because the account holder is affiliated with such a business; (4) taking any adverse or corrective supervisory action on a loan made to a person solely because the person either owns such a business or owns real estate or equipment leased or sold to such a business; or (5) penalizing a depository institution for engaging in a financial service for such a business. As specified by the bill, a depository institution, a Federal Reserve bank, or an insurer shall not, under federal law, be liable or subject to forfeiture for providing a loan or other financial services to a legitimate marijuana- or hemp-related business. The bill specifies that a federal banking agency may not request or order a depository institution to terminate a customer account unless (1) the agency has a valid reason for doing so, and (2) that reason is not based solely on reputation risk. Valid reasons for terminating an account include threats to national security and involvement in terrorist financing, including state sponsorship of terrorism. The Government Accountability Office must report on (1) access to financial services for minority-owned and women-owned marijuana- or hemp-related businesses; and (2) the effectiveness of suspicious-transaction reports at finding engagement with organized criminal activity in jurisdictions that allow the cultivation, sale, or distribution of marijuana.
Lobbying filings that explicitly cite this bill (50)
These links require the bill number to appear in the filing's source-reported specific issue text. Client expenses and lobbying-firm income are separate disclosure fields.
Received in the Senate and Read twice and referred to the Committee on Banking, Housing, and Urban Affairs.
September 25, 2019
Motion to reconsider laid on the table Agreed to without objection.
September 25, 2019
On motion to suspend the rules and pass the bill, as amended Agreed to by the Yeas and Nays: (2/3 required): 321 - 103 (Roll no. 544). (text: CR H7962-7964)
House
September 25, 2019
Passed/agreed to in House: On motion to suspend the rules and pass the bill, as amended Agreed to by the Yeas and Nays: (2/3 required): 321 - 103 (Roll no. 544).(text: CR H7962-7964)
House
September 25, 2019
DEBATE - The House proceeded with forty minutes of debate on H.R. 1595.
September 25, 2019
Considered under suspension of the rules. (consideration: CR H7962-7974)
September 25, 2019
Mr. Perlmutter moved to suspend the rules and pass the bill, as amended.
Cited source text, amounts, lobbyists, and targets
Cryptocurrency, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10- Financial Choice Act of 2017, H.J. Res. 62/72-Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021." H.R. 5045, "Blockchain Certainty Act." H.R. 4741, "Digital Asset Market Structure and Investor Protection Act," S. 3906, "Small Business Broadband and Emerging Information Technology Enhancement Act of 2022," S. 3970, "Stablecoin Transparency Act," H.R. 7231, "ECASH Act," H.R. 5912, "Close the ILC Loophole Act," S. 4356, "Responsible Financial Innovation Act," H.R. 7614, "Digital Commodity Exchange Act of 2022," S. 3970, "Stablecoin Transparency Act, "H.R. 3425, "Saving Gig Economy Taxpayers Act." S. 4946, "Payments Modernization Act of 2022." S. 4760, "Digital Commodities Consumer Protection Act of 2022." H.R. 8874, "Credit Card Competition Act of 2022." S. 4674, "Credit Card Competition Act of 2022." S. 4831, "No CBDC Act."
Client expense: $410,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
Cited source text, amounts, lobbyists, and targets
Cryptocurrency, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10- Financial Choice Act of 2017, H.J. Res. 62/72-Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021." H.R. 5045, "Blockchain Certainty Act." H.R. 4741, "Digital Asset Market Structure and Investor Protection Act," S. 3906, "Small Business Broadband and Emerging Information Technology Enhancement Act of 2022," S. 3970, "Stablecoin Transparency Act," H.R. 7231, "ECASH Act," H.R. 5912, "Close the ILC Loophole Act," S. 4356, "Responsible Financial Innovation Act," H.R. 7614, "Digital Commodity Exchange Act of 2022," S. 3970, "Stablecoin Transparency Act, "H.R. 3425, "Saving Gig Economy Taxpayers Act." S. 4946, "Payments Modernization Act of 2022." S. 4760, "Digital Commodities Consumer Protection Act of 2022." H.R. 8874, "Credit Card Competition Act of 2022." S. 4674, "Credit Card Competition Act of 2022." S. 4831, "No CBDC Act."
Cited source text, amounts, lobbyists, and targets
Cryptocurrency, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10- Financial Choice Act of 2017, H.J. Res. 62/72-Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021." H.R. 5045, "Blockchain Certainty Act." H.R. 4741, "Digital Asset Market Structure and Investor Protection Act," S. 3906, "Small Business Broadband and Emerging Information Technology Enhancement Act of 2022," S. 3970, "Stablecoin Transparency Act," H.R. 7231, "ECASH Act," H.R. 5912, "Close the ILC Loophole Act," S. 4356, "Responsible Financial Innovation Act," H.R. 7614, "Digital Commodity Exchange Act of 2022," S. 3970, "Stablecoin Transparency Act, "H.R. 3425, "Saving Gig Economy Taxpayers Act."
Cited source text, amounts, lobbyists, and targets
Cryptocurrency, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10- Financial Choice Act of 2017, H.J. Res. 62/72-Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021." H.R. 5045, "Blockchain Certainty Act." H.R. 4741, "Digital Asset Market Structure and Investor Protection Act," S. 3906, "Small Business Broadband and Emerging Information Technology Enhancement Act of 2022," S. 3970, "Stablecoin Transparency Act," H.R. 7231, "ECASH Act."
Cited source text, amounts, lobbyists, and targets
Cryptocurrency, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10-Financial Choice Act of 2017, H.J. Res. 62/72-Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021." H.R. 5045, "Blockchain Certainty Act." H.R. 4741, "Digital Asset Market Structure and Investor Protection Act," S. 3906, "Small Business Broadband and Emerging Information Technology Enhancement Act of 2022," S. 3970, "Stablecoin Transparency Act," H.R. 7231, "ECASH Act."
Reported (Amended) by the Committee on Financial Services. H. Rept. 116-104, Part I.
Congress.gov source codes: 5000, H12200
April 8, 2019
Referred to the Subcommittee on Crime, Terrorism, and Homeland Security.
March 28, 2019
Ordered to be Reported (Amended) by the Yeas and Nays: 45 - 15.
March 28, 2019
Committee Consideration and Mark-up Session Held.
March 27, 2019
Committee Consideration and Mark-up Session Held.
March 26, 2019
Committee Consideration and Mark-up Session Held.
March 7, 2019
Referred to the Committee on Financial Services, and in addition to the Committee on the Judiciary, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
Client expense: $410,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
Client expense: $410,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
Client expense: $410,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
Cited source text, amounts, lobbyists, and targets
Cryptocurrency, mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10-Financial Choice Act of 2017, H.J. Res. 62/72-Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021." H.R. 5045, "Blockchain Certainty Act." H.R. 4741, "Digital Asset Market Structure and Investor Protection Act."
Client expense: $410,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
Cited source text, amounts, lobbyists, and targets
Mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10-Financial Choice Act of 2017, H.J. Res. 62/72-Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021." H.R. 5045, "Blockchain Certainty Act."
Client expense: $230,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
Cited source text, amounts, lobbyists, and targets
Mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10-Financial Choice Act of 2017, H.J. Res. 62/72-Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021." H.R. 2561, "Promoting Access to Capital in Underbanked Communities Act of 2021."
Client expense: $230,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
Cited source text, amounts, lobbyists, and targets
Mobile payments, fraud, data security, data storage, open banking, regulatory reform, tax reporting, payments systems, cyber-security, financial services, merchant cash advances, privacy, the Federal Reserve and big data, CFPB prepaid products rule (Prepaid Accounts Under Direct Electronic Transfer Act {Regulation E} and the Truth in Lending Act), Federal Reserve Secure Payments Task Force, Marketplace lending, H.R. 10-Financial Choice Act of 2017, H.J. Res. 62/72-Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, S.J.Res.19 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to prepaid accounts under the Electronic Fund Transfer Act and the Truth in Lending Act, H. R. 1801-To delay the effective date of the final rule of the Bureau of Consumer Financial Protection titled Prepaid Accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)", S. 387-Consumer Financial Protection Bureau Accountability Act of 2017, S. 626-CFPB-IG Act of 2017. CFPB Governance Structure. H.J.Res. 111, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements." S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Bureau of Consumer Financial Protection relating to "Arbitration Agreements". H.R. 4439, Modernizing Credit Opportunities Act of 2017. H.R. 3299, Protecting Consumers' Access to Credit Act of 2017. S. 1642, Protecting Consumers' Access to Credit Act of 2017. H.R. 3354, Make America Secure & Prosperous Appropriations Act. H.R. 6743, Consumer Information Notification Requirement Act. H.R. 6850, Financial Reporting Threshold Modernization Act. "Potential Federal Reserve Actions To Support Interbank Settlement of Faster Payments, Request for Comments" (Docket # OP-1625). OCC ANPR "Reforming the Community Reinvestment Act Regulatory Framework" (Docket # OCC-2018- 0008). H.R. 1595, "SAFE Banking Act of 2019". FDIC Request for Information on Small-Dollar Lending (Docket No. RIN 3064-ZA04). S. 1200, Secure And Fair Enforcement Banking Act of 2019. H.R. 4813, Keep Big Tech Out of Finance Act. S. 2839, Eliminating Corporate Shadow Banking Act of 2019. S. 1951, Designing Accounting Safeguards To Help Broaden Oversight and Regulations on Data. H.R. 5574, "Preserving Small Business Lending Act of 2020." H.R. 6116, "Consumer Financial Protection Commission Act." S. 3548, "CARES Act." H.R. 6379, "Take Responsibility for Workers and Families Act." H.R. 748, "CARES Act." S. 3990, "Financial Product Safety Commission Act of 2020." H.R. 6886, "Paycheck Protection Program Flexibility Act of 2020." H.R. 710, "Paycheck Protection Program Flexibility Act of 2020." S.4116, "Bill to extend Paycheck Protection Program..." H.R. 8087, "Bill to extend Paycheck Protection Program..." H.R. 7777, "Paycheck Protection Small Business Forgiveness Act." H.R. 8265, "To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program and for other purposes..." S. 4614, "Postal Banking Act." H.R. 8406, "HEROS Act." H.R. 7889, "Small Business Lending Disclosure and Broker Regulation Act of 2020." OCC "True Lender." OCC "National Bank and Federal Savings Association Digital Activities." H.R. 8215, "Improving Digital Identity Act of 2020." U.S. House Committee on Financial Services' Task Force on Financial Technology and Task Force on Artificial Intelligence. S. 4999, "Emergency Direct Payments for Families and Workers Act of 2020." H.R. 8893, "Coronavirus Assistance for Americans Families Act." S. 4927, EIDL Forgiveness Act." H.R. 8827, "Stablecoin Classification and Regulation Act of 2020." S. 4800, "The Heroes Act." H.R. 8721, "Public Banking Act of 2020." S.J. Res 15, "True Lender." H.J. Res 35, "True Lender." H.R. 296, "Financial Technology Protection Act." H.R. 1602, "Eliminate Barriers to Innovation Act of 2021." H.R. 1996, "SAFE Banking Act of 2021."
Client expense: $230,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Council of Economic Advisers (CEA), Federal Communications Commission (FCC), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
Cited source text, amounts, lobbyists, and targets
Reforming federal law and policy governing medical research, financial transactions, and tax deductions applicable to cannabis and allowing states and territories to set and enforce their own laws governing cannabis use, including H.R. 1595 and S. 1200, the Secure and Fair Enforcement (SAFE) Banking Act of 2019.
Client expense: Not reported · Firm income: $80,000
Cited source text, amounts, lobbyists, and targets
S. 1200: SAFE Banking Act of 2019Support
S. 1919: Yes In My Backyard ActSupport
H.R. 4860: Crowdfunding Amendments ActSupport
H.R. 1595, The SAFE Banking Act of 2019Support
Client expense: $190,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
CBAI 2020 Federal Policy Priorities -
Community Bank Response to the COVID-19 Crisis
COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.
The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent.
Additional Meaningful Regulatory Relief for Community Banks
Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently.
The Community Bank Position on Credit Unions and Their Expanded Powers
Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve.
Closing the Industrial Loan Company (ILC) Regulatory Loophole
ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed.
The Community Bank Position on the Farm Credit System and its Expanded Powers
The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks.
The Federal Reserves Role in Payments System Improvement
A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis.
Modernizing the Community Reinvestment Act (CRA)
The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham.
Modifying the FDICs Brokered Deposit Rule
The FDIC proposed brokered deposit rule needs to be updated to reflect modern ways of gathering deposits and they should not be viewed unfavorably, and subject to unreasonable restrictions. A properly tailored brokered deposit rule will ensure that it does not place undue limits on the reasonable use of brokered deposits by community banks.
Safe Harbor for Banking Cannabis-Related Businesses
Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor.
De Novo Community Bank Formation, the Dual Banking System and Charter Choice
Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Recent and encouraging signs by the FDIC to approve de novo charter applications must continue and many new banks should be chartered each year to help maintain the vitality of the community banking profession.
The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking.
Sound Principles for GSE Reform
The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress.
The Federal Home Loan Banks
Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members.
Agriculture and Rural America
A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery.
Enhanced Data, Cyber and Payment Card Security (Data Security)
Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards.
Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks
Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model.
In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies.
The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers.
The Community Bank Positions on Emerging Issues
OCC - Special Purpose Fintech National Bank (SPNBs) Fintech Charters
The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations, and liability.
FASB - Current Expected Credit Loss Model (CECL)
Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks.
CFPB - Customer Data Sharing
Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers.
CFPB - Small-Dollar Consumer Lending
Appropriate action will be required, as the revised implementation of the rule unfolds to assure appropriate and responsible access to small dollar loans by consumers and to minimize any negative impact on community banks small-dollar consumer lending.
CFPB - Small Business Data Collection
Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception.
Federal Reserve - Modernize Reg CC
Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud.
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.
(House, Senate, CFPB, OCC, FDIC, Federal Reserve)
Legislation and Regulation -
Beginning Agriculturalist Lifetime Employment Act of 2021 (BALE Act (no bill number yet) (All Sections) Regarding increasing the percentage of USDA loan guarantee for beginning farmers or ranchers or socially disadvantaged farmers or ranchers (House)
H.R. 1799 - PPP Extension Act of 2021 (All Sections) Regarding extending the Paycheck Protection Program through June 30, 2021 (House and Senate)
H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate)
H.R. 1996 - SAFE Act (All Sections) Regarding safe harbor for banks that choose to provide financial services to cannabis related businesses (House)
Letters -
Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Consumer Access to Financial Records - Docket No CFPB-2020-0034 and RIN 3170-AA78 (CFPB)
Comment Letter to the Federal Reserve regarding: Community Reinvestment Act - Advance Notice of Proposed Rulemaking - Docket No. R-1723 and RIN 7100-AF94 (Federal Reserve House, Senate, OCC, FDIC)
Action Alerts -
Action Alert regarding fixes to the Paycheck Protection Program (PPP) including - small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness; small businesses with modest shortfalls in using first draw dollars should be eligible for second draw loans; and self-employed farmers and ranchers should be permitted to use the gross income method so they have access to the PPP (House and Senate)
Action Alert regarding cosponsoring H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) which exempts from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate)
Miscellaneous -
Potential reintroduction of legislation to exempt community banks from taxation on income from small dollar amount small business and agriculture loans to begin to provide parity with Farm Credit lenders and credit unions (Senate)
The OCCs approval of the conversion of Anchorage Trust Company to become Anchorage Digital Bank (OCC)
Paycheck Protection Program (PPP) CBAI member polling results (House, Senate, CFPB, OCC, FDIC, Federal Reserve)
Paycheck Protection Program (PPP) issue with small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness (House, Senate, CFPB, OCC, FDIC, Federal Reserve)
US Postal Service banking, Farm Credit System lending preferential treatment and unfair competition with community banks, and fraud in the Paycheck Protection Program (PPP) lending - SBA IG Report (Number 20-21) and Bloomberg Businessweek headline PPP Scammers Made Fintech Companies Their Lenders of Choice (Senate)
US Postal Service banking (House)
Paycheck Protection Program (PPP) - ramping the reduction in gross receipts (versus all or nothing) to enable more small business borrowers to qualify for the second round of PPP funding (House)
Closing the Industrial Loan Company (ILC) regulatory loophole for consolidated supervision by the Federal Reserve of ILC parent holding companies ((Federal Reserve House, Senate, OCC, FDIC)
Credit Unions - challenging their tax exemption and unfair competition with community banks (House and Senate)
Small-dollar consumer lending - opportunities and challenges (House)
Client expense: $60,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE
Cited source text, amounts, lobbyists, and targets
CBAI 2020 Federal Policy Priorities -
Community Bank Response to the COVID-19 Crisis
COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.
The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent.
Additional Meaningful Regulatory Relief for Community Banks
Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently.
The Community Bank Position on Credit Unions and Their Expanded Powers
Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve.
The Federal Reserves Role in Payments System Improvement
A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis.
Modernizing the Community Reinvestment Act (CRA)
The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham.
Safe Harbor for Banking Cannabis-Related Businesses
Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor.
Sound Principles for GSE Reform
The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress.
The Federal Home Loan Banks
Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members.
Enhanced Data, Cyber and Payment Card Security (Data Security)
Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards.
Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks
Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model.
In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies.
The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers.
The Community Bank Positions on Emerging Issues
CFPB - Customer Data Sharing
Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers.
CFPB - Small-Dollar Consumer Lending
Appropriate action will be required, as the revised implementation of the rule unfolds to assure appropriate and responsible access to small dollar loans by consumers and to minimize any negative impact on community banks small-dollar consumer lending.
Federal Reserve - Modernize Reg CC
Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud.
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.
(House, Senate, CFPB, OCC, FDIC, Federal Reserve)
Letters -
Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Consumer Access to Financial Records - Docket No CFPB-2020-0034 and RIN 3170-AA78 (CFPB)
Comment Letter to the Federal Reserve regarding: Community Reinvestment Act - Advance Notice of Proposed Rulemaking - Docket No. R-1723 and RIN 7100-AF94 (Federal Reserve House, Senate, OCC, FDIC)
Miscellaneous -
US Postal Service banking (Senate and House)
Credit Unions - challenging their tax exemption and unfair competition with community banks (House and Senate)
Small-dollar consumer lending - opportunities and challenges (House)
Client expense: $60,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE
Cited source text, amounts, lobbyists, and targets
CBAI 2020 Federal Policy Priorities -
Community Bank Response to the COVID-19 Crisis
COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.
The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent.
Additional Meaningful Regulatory Relief for Community Banks
Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently.
The Community Bank Position on Credit Unions and Their Expanded Powers
Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve.
The Community Bank Position on the Farm Credit System and its Expanded Powers
The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks.
The Federal Reserves Role in Payments System Improvement
A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis.
Modernizing the Community Reinvestment Act (CRA)
The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham.
Safe Harbor for Banking Cannabis-Related Businesses
Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor.
Agriculture and Rural America
A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery.
Enhanced Data, Cyber and Payment Card Security (Data Security)
Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards.
Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks
Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model.
In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies.
The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers.
The Community Bank Positions on Emerging Issues
CFPB - Small Business Data Collection
Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception.
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.
(House, Senate, CFPB, OCC, FDIC, Federal Reserve)
Legislation and Regulation -
Beginning Agriculturalist Lifetime Employment Act of 2021 (BALE Act (no bill number yet) (All Sections) Regarding increasing the percentage of USDA loan guarantee for beginning farmers or ranchers or socially disadvantaged farmers or ranchers (House)
H.R. 1799 - PPP Extension Act of 2021 (All Sections) Regarding extending the Paycheck Protection Program through June 30, 2021 (House and Senate)
H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate)
H.R. 1996 - SAFE Act (All Sections) Regarding safe harbor for banks that choose to provide financial services to cannabis related businesses (House)
Letters -
Comment Letter to the Federal Reserve regarding: Community Reinvestment Act - Advance Notice of Proposed Rulemaking - Docket No. R-1723 and RIN 7100-AF94 (Federal Reserve House, Senate, OCC, FDIC)
Action Alerts -
Action Alert regarding fixes to the Paycheck Protection Program (PPP) including - small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness; small businesses with modest shortfalls in using first draw dollars should be eligible for second draw loans; and self-employed farmers and ranchers should be permitted to use the gross income method so they have access to the PPP (House and Senate)
Action Alert regarding cosponsoring H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) which exempts from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate)
Miscellaneous -
Potential reintroduction of legislation to exempt community banks from taxation on income from small dollar amount small business and agriculture loans to begin to provide parity with Farm Credit lenders and credit unions (Senate)
Paycheck Protection Program (PPP) CBAI member polling results (House, Senate, CFPB, OCC, FDIC, Federal Reserve)
Paycheck Protection Program (PPP) issue with small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness (House, Senate, CFPB, OCC, FDIC, Federal Reserve)
Farm Credit System lending (preferential treatment and unfair competition with community banks, fraud in the Paycheck Protection Program (PPP) lending - SBA IG Report (Number 20-21) and Bloomberg Businessweek headline PPP Scammers Made Fintech Companies Their Lenders of Choice (Senate)
Paycheck Protection Program (PPP) - ramping the reduction in gross receipts (versus all or nothing) to enable more small business borrowers to qualify for the second round of PPP funding (House)
Client expense: $60,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE
Cited source text, amounts, lobbyists, and targets
CBAI 2020 Federal Policy Priorities -
Community Bank Response to the COVID-19 Crisis
COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.
The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent.
Additional Meaningful Regulatory Relief for Community Banks
Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently.
The Community Bank Position on Credit Unions and Their Expanded Powers
Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve.
The Community Bank Position on the Farm Credit System and its Expanded Powers
The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks.
The Federal Reserves Role in Payments System Improvement
A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis.
Modernizing the Community Reinvestment Act (CRA)
The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham.
Safe Harbor for Banking Cannabis-Related Businesses
Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor.
Sound Principles for GSE Reform
The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress.
The Federal Home Loan Banks
Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members.
Agriculture and Rural America
A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery.
Enhanced Data, Cyber and Payment Card Security (Data Security)
Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards.
The Community Bank Positions on Emerging Issues
CFPB - Small Business Data Collection
Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception.
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.
(House, Senate, CFPB, OCC, FDIC, Federal Reserve)
Legislation and Regulation -
Beginning Agriculturalist Lifetime Employment Act of 2021 (BALE Act (no bill number yet) (All Sections) Regarding increasing the percentage of USDA loan guarantee for beginning farmers or ranchers or socially disadvantaged farmers or ranchers (House)
H.R. 1799 - PPP Extension Act of 2021 (All Sections) Regarding extending the Paycheck Protection Program through June 30, 2021 (House and Senate)
H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate)
H.R. 1996 - SAFE Act (All Sections) Regarding safe harbor for banks that choose to provide financial services to cannabis related businesses (House)
Letters -
Comment Letter to the Federal Reserve regarding: Community Reinvestment Act - Advance Notice of Proposed Rulemaking - Docket No. R-1723 and RIN 7100-AF94 (Federal Reserve House, Senate, OCC, FDIC)
Action Alerts -
Action Alert regarding fixes to the Paycheck Protection Program (PPP) including - small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness; small businesses with modest shortfalls in using first draw dollars should be eligible for second draw loans; and self-employed farmers and ranchers should be permitted to use the gross income method so they have access to the PPP (House and Senate)
Action Alert regarding cosponsoring H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) which exempts from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate)
Miscellaneous -
Potential reintroduction of legislation to exempt community banks from taxation on income from small dollar amount small business and agriculture loans to begin to provide parity with Farm Credit lenders and credit unions (Senate)
Paycheck Protection Program (PPP) CBAI member polling results (House, Senate, CFPB, OCC, FDIC, Federal Reserve)
Paycheck Protection Program (PPP) issue with small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness (House, Senate, CFPB, OCC, FDIC, Federal Reserve)
US Postal Service banking, Farm Credit System lending (preferential treatment and unfair competition with community banks, and fraud in the Paycheck Protection Program (PPP) lending - SBA IG Report (Number 20-21) and Bloomberg Businessweek headline PPP Scammers Made Fintech Companies Their Lenders of Choice (Senate)
Paycheck Protection Program (PPP) - ramping the reduction in gross receipts (versus all or nothing) to enable more small business borrowers to qualify for the second round of PPP funding (House)
Client expense: $60,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE
Cited source text, amounts, lobbyists, and targets
CBAI 2020 Federal Policy Priorities -
Community Bank Response to the COVID-19 Crisis
COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function.
The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity
CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country.
Completing the Implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155)
The banking regulators have almost completed implementing S. 2155 so community banks can benefit from all of the regulatory relief measures. Community bankers, the associations that represent their interests, and Congress (which represent this vital economic constituency) must diligently insist on the swift completion the rulemaking - consistent with Congressional intent.
Additional Meaningful Regulatory Relief for Community Banks
Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs , SARs, tax exempt interest on agricultural and small business loans, and beneficial ownership reporting) to permit them to serve their customers and communities better and more efficiently.
The Community Bank Position on Credit Unions and Their Expanded Powers
Credit unions have long-since strayed from their founding purposes, blatantly abusing their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve.
Closing the Industrial Loan Company (ILC) Regulatory Loophole
ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed.
The Community Bank Position on the Farm Credit System and its Expanded Powers
The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in and the playing field leveled for community banks.
The Federal Reserves Role in Payments System Improvement
A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis.
Modernizing the Community Reinvestment Act (CRA)
The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham.
Modifying the FDICs Brokered Deposit Rule
The FDIC proposed brokered deposit rule needs to be updated to reflect modern ways of gathering deposits and they should not be viewed unfavorably, and subject to unreasonable restrictions. A properly tailored brokered deposit rule will ensure that it does not place undue limits on the reasonable use of brokered deposits by community banks.
Safe Harbor for Banking Cannabis-Related Businesses
Without taking a position on the legalization of cannabis, it is a matter of public safety to have a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act of 2019 (H.R. 1595) which provides this legal safe harbor.
De Novo Community Bank Formation, the Dual Banking System and Charter Choice
Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Recent and encouraging signs by the FDIC to approve de novo charter applications must continue and many new banks should be chartered each year to help maintain the vitality of the community banking profession.
The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking.
Sound Principles for GSE Reform
The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress.
The Federal Home Loan Banks
Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members.
Agriculture and Rural America
A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery.
Enhanced Data, Cyber and Payment Card Security (Data Security)
Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards.
Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks
Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model.
In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies.
The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers.
The Community Bank Positions on Emerging Issues
OCC - Special Purpose Fintech National Bank (SPNBs) Fintech Charters
The Office of Comptroller of the Currency (OCC) intends to issue special purpose national banking charters to Fintech companies. Fintechs cannot have the advantages of a national bank charter with limited requirements, regulations, and liability.
FASB - Current Expected Credit Loss Model (CECL)
Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks.
CFPB - Customer Data Sharing
Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers.
CFPB - Small-Dollar Consumer Lending
Appropriate action will be required, as the revised implementation of the rule unfolds to assure appropriate and responsible access to small dollar loans by consumers and to minimize any negative impact on community banks small-dollar consumer lending.
CFPB - Small Business Data Collection
Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception.
Federal Reserve - Modernize Reg CC
Fraud losses are increasing at community banks and Reg CC needs to keep pace with the technology. All banks, credit unions, and others who utilize the payments system should be operating on the same level playing field when it comes to return reasons for fraud and acknowledging and communicating about fraud.
Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts
The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.
(House, Senate, CFPB, OCC, FDIC, Federal Reserve)
Legislation and Regulation -
Beginning Agriculturalist Lifetime Employment Act of 2021 (BALE Act (no bill number yet) (All Sections) Regarding increasing the percentage of USDA loan guarantee for beginning farmers or ranchers or socially disadvantaged farmers or ranchers (House)
H.R. 1799 - PPP Extension Act of 2021 (All Sections) Regarding extending the Paycheck Protection Program through June 30, 2021 (House and Senate)
H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) (All Sections) Regarding exempting from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate)
H.R. 1996 - SAFE Act (All Sections) Regarding safe harbor for banks that choose to provide financial services to cannabis related businesses (House)
Letters -
Comment Letter to the Consumer Financial Protection Bureau (CFPB) regarding: Consumer Access to Financial Records - Docket No CFPB-2020-0034 and RIN 3170-AA78 (CFPB)
Comment Letter to the Federal Reserve regarding: Community Reinvestment Act - Advance Notice of Proposed Rulemaking - Docket No. R-1723 and RIN 7100-AF94 (Federal Reserve House, Senate, OCC, FDIC)
Action Alerts -
Action Alert regarding fixes to the Paycheck Protection Program (PPP) including - small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness; small businesses with modest shortfalls in using first draw dollars should be eligible for second draw loans; and self-employed farmers and ranchers should be permitted to use the gross income method so they have access to the PPP (House and Senate)
Action Alert regarding cosponsoring H.R. 1977 - Enhancing Credit Opportunities in Rural America Act (ECORA) which exempts from taxes interest earned on loans from farm real estate and rural mortgage loans (House and Senate)
Miscellaneous -
Potential reintroduction of legislation to exempt community banks from taxation on income from small dollar amount small business and agriculture loans to begin to provide parity with Farm Credit lenders and credit unions (Senate)
The OCCs approval of the conversion of Anchorage Trust Company to become Anchorage Digital Bank (OCC)
Paycheck Protection Program (PPP) CBAI member polling results (House, Senate, CFPB, OCC, FDIC, Federal Reserve)
Paycheck Protection Program (PPP) issue with small businesses not being able to borrow up to the maximum first round draw amount, in spite of a legislative rule change for the second round, because the small business had been granted first round PPP forgiveness (House, Senate, CFPB, OCC, FDIC, Federal Reserve)
US Postal Service banking, Farm Credit System lending preferential treatment and unfair competition with community banks, and fraud in the Paycheck Protection Program (PPP) lending - SBA IG Report (Number 20-21) and Bloomberg Businessweek headline PPP Scammers Made Fintech Companies Their Lenders of Choice (Senate)
US Postal Service banking (House)
Paycheck Protection Program (PPP) - ramping the reduction in gross receipts (versus all or nothing) to enable more small business borrowers to qualify for the second round of PPP funding (House)
Closing the Industrial Loan Company (ILC) regulatory loophole for consolidated supervision by the Federal Reserve of ILC parent holding companies ((Federal Reserve House, Senate, OCC, FDIC)
Credit Unions - challenging their tax exemption and unfair competition with community banks (House and Senate)
Small-dollar consumer lending - opportunities and challenges (House)
Client expense: $60,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE
Cited source text, amounts, lobbyists, and targets
H.R. 1595 - Secure And Fair Enforcement Banking Act of 2019 or the SAFE Banking Act of 2019 H.R. 6395 - William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 - cyber insurance S. 1200 - Secure And Fair Enforcement Banking Act of 2019 or the SAFE Banking Act of 2019 Cyber security, cyber insurance, cyber terrorism insurance, and data breach legislation Dodd-Frank Act legislation
Client expense: $280,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
H.R. 1595 - Secure And Fair Enforcement Banking Act of 2019 or the SAFE Banking Act of 2019 H.R. 6395 - William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 - cyber insurance S. 1200 - Secure And Fair Enforcement Banking Act of 2019 or the SAFE Banking Act of 2019 Cyber security, cyber insurance, and data breach legislation Dodd-Frank Act legislation
Client expense: $250,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
H.R. 1595 - Secure And Fair Enforcement Banking Act of 2019 or the SAFE Banking Act of 2019 S. 1200 - Secure And Fair Enforcement Banking Act of 2019 or the SAFE Banking Act of 2019 Cyber security, cyber insurance, and data breach legislation Dodd-Frank Act legislation
Client expense: $400,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
H.R. 1595 - Secure And Fair Enforcement Banking Act of 2019 or the SAFE Banking Act of 2019 S. 1200 - Secure And Fair Enforcement Banking Act of 2019 or the SAFE Banking Act of 2019 Cyber security, cyber insurance, and data breach legislation Dodd-Frank Act legislation
Client expense: $210,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
HR 469 Using replacement cost value to determine premium rates for flood insurance; HR 470 Repeal mandatory flood insurance for commercial properties; HR 471 The Taxpayer Exposure Mitigation Act, requires the NFIP to purchase reinsurance; HR 472 The Community Mapping Act, allows communities to develop alternative flood insurance rate maps; HR 830 The Flood Insurance for Farmers Act, allows for repair and construction of structures within flood zones; HR 342 & HR 2318, The FIRM IT Act of 2019, seeks to improve mapping for the NFIP; HR 1666, allows for private flood insurance to meet continuous coverage requirements; HR 2578, the NFIP Extension Act of 2019, HR 3111 NFIP Administrative Reform Act of 2019; HR 3146 Fair Flood Insurance Act of 2019, which provides for monthly installment payments; HR 3167 NFIP Re-authorization Act of 2019; HR 3258 Flood Insurance Integrity Act of 2019; HR 3872/S 2187 NFIP Re-authorization and Reform Act of 2019; S 1144 Flood Insurance Rate Map Interagency Technology Act; S 1520 NFIP Extension Act of 2019; and S 1533 NFIP Extension Act . We are monitoring all legislation impacting the National Flood Insurance Program to insure that the program remains available and affordable for our customers.
HR 1595 & S 1200 The SAFE Banking Act; also HR 4074 and S 1200 The CLAIM Act - Monitor efforts to facilitate financial services to legal cannabis-related businesses
HR 1756 - The Preventing Credit Score Discrimination in Auto Insurance Act; S 4755 a bill to prohibit auto insurers from using certain income proxies; Monitoring these bill which could impact insurance underwriting
HR 6494 Business Interruption Insurance Coverage Act of 2020; oppose
HR 6497 Never Again Small Business Protection Act; oppose
HR 7011 Pandemic Risk Insurance Act; concerns with requiring insurance coverage for uninsurable events like pandemics
HR 7412 Business Interruption Relief Act; oppose
S 4325 Business of Insurance Regulatory Reform Act - support this bill which deals with the CFPB authority to regulate insurance
Client expense: $50,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
No Bill # - Federal Agency Regulatory Changes Associated with COVID-19 Relief
No Bill # - SEC Best Interest Standard
S.603, H.R. 3561 - Financial Stability Oversight Council Improvement Act of 2019
S.603, H.R. 1862 - Issues relating to Dodd Frank Implementation and FIO, OFR, Volcker Rule, FSOC, FSB and their associated work on topics like capital standards, non bank SIFI designation, insurance regulation and oversight
No Bill # - International Insurance Capital Standards
H.R.1595, S. 1152 - SAFE Banking Act of 2019
No Bill # - Executive Order on Core Principles for Regulating the United States Financial System (February 3, 2017) and subsequent reports on banking (June 6, 2017), capital markets (October 20, 2017), and insurance and asset management (November 17, 2017) and Fintech report (July 31, 2018).
No Bill # - GSE and FHA Housing Finance Reform; Trump Administration Housing Finance Reform Plan
No Bill # - LIBOR Transition Federal Safe Harbor Draft Legislation
No Bill # - Exemption from Derivatives Clearing Organization Registration (RIN 3038-AE65); Registration with Alternative Compliance for Non-U.S. Derivatives Clearing Organizations (RIN 3038-AE87)
No Bill # - Support Federal agency efforts to allow for greater electronic efficiencies, including e-delivery and e-signature, with customers
H.R. 1018 - Improving Corporate Governance through Diversity Act of 2019
H.R. 3279 - Diversity in Corporate Leadership Act of 2019
No Bill # - Tailored Shareholder Reports, Treatment of Annual Prospectus Updates for Existing Investors, and Improved Fee and Risk Disclosure for Mutual Funds and Exchange-Traded Funds; Fee Information in Investment Company Advertisements File No. S7-09-20, August 5, 2020
Client expense: $580,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Accounting Standards Advisory Board (FASAB), Federal Highway Administration (FHA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
No Bill # - FRB's Market Liquidity Programs: CPPF, SMCCF, PMCCF, and TALF; support adding CMBS and CLOs to TALF and new credit program for mortgage servicers
No Bill # - Federal Agency Regulatory Changes Associated with COVID-19 Relief
No Bill # - SEC Best Interest Standard
S.603, H.R. 3561 - Financial Stability Oversight Council Improvement Act of 2019
S.603, H.R. 1862 - Issues relating to Dodd Frank Implementation and FIO, OFR, Volcker Rule, FSOC, FSB and their associated work on topics like capital standards, non bank SIFI designation, insurance regulation and oversight
No Bill # - International Insurance Capital Standards
H.R.1595, S. 1152 - SAFE Banking Act of 2019
No Bill # - Executive Order on Core Principles for Regulating the United States Financial System (February 3, 2017) and subsequent reports on banking (June 6, 2017), capital markets (October 20, 2017), and insurance and asset management (November 17, 2017) and Fintech report (July 31, 2018).
No Bill # - FED Notes "Nontraditional Life Insurance Liabilities"
No Bill # - FED Notes "Capturing the Illiquid Premium"
No Bill # - GSE and FHA Housing Finance Reform; Trump Administration Housing Finance Reform Plan
No Bill # - Authority to require supervision and regulation of certain nonbank financial companies; final interpretive guidance
H.R. 1018 - Improving Corporate Governance through Diversity Act of 2019
H.R. 3279 - Diversity in Corporate Leadership Act of 2019
No Bill # - Regulatory Capital Rules: Risk based capital requirements for depository institution holding companies signficantly engaged in insurance activities
Client expense: $790,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Accounting Standards Advisory Board (FASAB), Federal Highway Administration (FHA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
H.R.3884/S.2227 - Marijuana Opportunity Reinvestment and Expungement Act of 2019, to remove marijuana from the Controlled Substances Act and to provide programming and funding for communities that have been harmed the most by the disproportionate enforcement of cannabis prohibition. H.R.1595/S.1200 - Secure And Fair Enforcement Banking Act of 2019, to create protections for depository institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses, and for other purposes.
Client expense: $20,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
H.R.3884/S.2227 - Marijuana Opportunity Reinvestment and Expungement Act of 2019, to remove marijuana from the Controlled Substances Act and to provide programming and funding for communities that have been harmed the most by the disproportionate enforcement of cannabis prohibition. H.R.1595/S.1200 - Secure And Fair Enforcement Banking Act of 2019, to create protections for depository institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses, and for other purposes.
Client expense: $20,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
H.R.3884/S.2227 - Marijuana Opportunity Reinvestment and Expungement Act of 2019, to remove marijuana from the Controlled Substances Act and to provide programming and funding for communities that have been harmed the most by the disproportionate enforcement of cannabis prohibition. H.R.1595/S.1200 - Secure And Fair Enforcement Banking Act of 2019, to create protections for depository institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses, and for other purposes.
Client expense: $20,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
H.R.3884/S.2227 - Marijuana Opportunity Reinvestment and Expungement Act of 2019, to remove marijuana from the Controlled Substances Act and to provide programming and funding for communities that have been harmed the most by the disproportionate enforcement of cannabis prohibition. H.R.1595/S.1200 - Secure And Fair Enforcement Banking Act of 2019, to create protections for depository institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses, and for other purposes.
Client expense: $20,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
H.R.3884/S.2227 - Marijuana Opportunity Reinvestment and Expungement Act of 2019, to remove marijuana from the Controlled Substances Act and to provide programming and funding for communities that have been harmed the most by the disproportionate enforcement of cannabis prohibition. H.R.1595/S.1200 - Secure And Fair Enforcement Banking Act of 2019, to create protections for depository institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses, and for other purposes.
Client expense: $20,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
H.R.3884/S.2227 - Marijuana Opportunity Reinvestment and Expungement Act of 2019, to remove marijuana from the Controlled Substances Act and to provide programming and funding for communities that have been harmed the most by the disproportionate enforcement of cannabis prohibition. H.R.1595/S.1200 - Secure And Fair Enforcement Banking Act of 2019, to create protections for depository institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses, and for other purposes.
Client expense: $20,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
H.R.3884/S.2227 - Marijuana Opportunity Reinvestment and Expungement Act of 2019, to remove marijuana from the Controlled Substances Act and to provide programming and funding for communities that have been harmed the most by the disproportionate enforcement of cannabis prohibition. H.R.1595/S.1200 - Secure And Fair Enforcement Banking Act of 2019, to create protections for depository institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses, and for other purposes.
Client expense: $20,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
H.R.3884/S.2227 - Marijuana Opportunity Reinvestment and Expungement Act of 2019, to remove marijuana from the Controlled Substances Act and to provide programming and funding for communities that have been harmed the most by the disproportionate enforcement of cannabis prohibition. H.R.1595/S.1200 - Secure And Fair Enforcement Banking Act of 2019, to create protections for depository institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses, and for other purposes.
Client expense: $20,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
H.R.3884/S.2227 - Marijuana Opportunity Reinvestment and Expungement Act of 2019, to remove marijuana from the Controlled Substances Act and to provide programming and funding for communities that have been harmed the most by the disproportionate enforcement of cannabis prohibition. H.R.1595/S.1200 - Secure And Fair Enforcement Banking Act of 2019, to create protections for depository institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses, and for other purposes.
Client expense: $20,000 · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
No Bill # - Federal Agency Regulatory Changes Associated with COVID-19 Relief
No Bill # - SEC Best Interest Standard
S.603, H.R. 3561 - Financial Stability Oversight Council Improvement Act of 2019
S.603, H.R. 1862 - Issues relating to Dodd Frank Implementation and FIO, OFR, Volcker Rule, FSOC, FSB and their associated work on topics like capital standards, non bank SIFI designation, insurance regulation and oversight
No Bill # - International Insurance Capital Standards
H.R.1595, S. 1152 - SAFE Banking Act of 2019
No Bill # - Executive Order on Core Principles for Regulating the United States Financial System (February 3, 2017) and subsequent reports on banking (June 6, 2017), capital markets (October 20, 2017), and insurance and asset management (November 17, 2017) and Fintech report (July 31, 2018).
No Bill # - GSE and FHA Housing Finance Reform; Trump Administration Housing Finance Reform Plan
No Bill # - LIBOR Transition Federal Safe Harbor Draft Legislation
No Bill # - Exemption from Derivatives Clearing Organization Registration (RIN 3038-AE65); Registration with Alternative Compliance for Non-U.S. Derivatives Clearing Organizations (RIN 3038-AE87)
No Bill # - Support Federal agency efforts to allow for greater electronic efficiencies, including e-delivery and e-signature, with customers
H.R. 1018 - Improving Corporate Governance through Diversity Act of 2019
H.R. 3279 - Diversity in Corporate Leadership Act of 2019
No Bill # - Tailored Shareholder Reports, Treatment of Annual Prospectus Updates for Existing Investors, and Improved Fee and Risk Disclosure for Mutual Funds and Exchange-Traded Funds; Fee Information in Investment Company Advertisements File No. S7-09-20, August 5, 2020
Client expense: $580,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Accounting Standards Advisory Board (FASAB), Federal Highway Administration (FHA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
Cited source text, amounts, lobbyists, and targets
H.R. 342 National Flood Insurance Program Mapping
H.R. 420 Marijuana Products Regulation
H.R. 469 Flood Insurance Coverage Rates
H.R. 470 Mandatory Flood Insurance Coverage Repeal
H.R. 471 Private Capital and Reinsurance Markets Risk Transfer
H.R. 472 Alternative Flood Insurance Rate Maps
H.R. 1402 Flood Maps Preparation Transfer
H.R. 1418 Health Insurance Antitrust laws Application
H.R. 1595 Cannabis Related Businesses Financial Services
H.R. 1666 Private Flood Insurance Coverage
H.R. 1689 Climate Change Advisory Commission Establishment
H.R. 1756 Auto Insurance Consumer Reports Use Prohibition
H.R. 1862 Federal Insurance Office Abolition
S. 350 Health Insurance Federal Antitrust laws Application
S. 420 Marijuana Products Taxation and Regulation
S. 603 Financial Company Supervision Determination
H.R. 2048 Consumer Products and Services Pricing
H.R. 2318 National Flood Insurance Mapping
H.R. 2479 Financial Stability Oversight Council Voting Member
H.R. 2578 National Flood Insurance Program Extension Act of 2019
H.R. 2684 Auto Insurance Cost Disparities Study
H.R. 3111 National Flood Insurance Reforms
H.R. 3167 National Flood Insurance Program Reform
H.R. 3183 Crop Insurance Eligibility
H.R. 3258 Flood Insurance Rates Review
S. 1108 Data Protection Impact Assessments
S. 1144 National Flood Insurance Mapping
S. 1200 Cannabis Related Business Financial Services Protection
S. 1213 Health Insurance Reform Provision
S. 1214 Individual and Collective Privacy Rights Protection
S. 1520 National Flood Insurance Program Reauthorization
S. 1531 Health Insurance Consumer Protections
S. 1533 National Flood Insurance Program Reauthorization
H.R. 3872 National Flood Insurance Program Reauthorization
H.R. 4074 Cannabis Related Business Safe Harbor
H.R. 4523 Risk Retention Groups Commercial Insurance Types
S. 2088 Flood Area Community Accountability
S. 2122 Flood Insurance Program Contract Termination Authority
S. 2171 Flood Insurance Agents Continuing Education Requirement
S. 2187 National Flood Insurance Program Reauthorization
S. 2192 Flood Risk Reduction Funding Assistance
S. 2201 Cannabis Related Business Insurers Safe Harbor
H.R. 4634 Terrorism Risk Insurance Act Reauthorization
H.R. 4652 Individual Market Reinsurance Fund Establishment
S. 2877 Terrorism Risk Insurance Act
S. 2964 Non Premium Aviation Insurance Authority Extension
H.R. 1756 Auto Insurance Consumer Reports Use Prohibition
H.R. 3693 Insurance Rate Income Proxies
H.R. 5776 Flood Damaged Areas Accountability
**Issues lobbied without specific bill number: COVID-19 Related Insurance Legislation, Business Interruption Insurance, Consumer Financial Protection Bureau Oversight of the Insurance Industry, Marijuana Financial Services
H.R. 6494 Insurance Coverage for Business Interruption Losses
H.R. 6497 Insurance Coverage for Business Interruption Losses
H.R. 6800 HEROES Act Workers Compensation Provision
H.R. 7011 Pandemic Risk Reinsurance Program
H.R. 7412 Insurers Support Temporary Voluntary Program
S. 3814 Loan Forgiveness Period Extension
**Issues lobbied without specific bill number: Business Continuity Protection Program, COVID-19 personal and commercial insurance response and role, municipal services liability, judicial insurance antitrust consent decree
Client expense: $1,650,000 · Firm income: Not reported
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Federal Aviation Administration (FAA), Federal Emergency Management Agency (FEMA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Economic Council (NEC), Natl Labor Relations Board (NLRB), SENATE, Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR)
Cited source text, amounts, lobbyists, and targets
H.R. 342 National Flood Insurance Program Mapping
H.R. 420 Marijuana Products Regulation
H.R. 469 Flood Insurance Coverage Rates
H.R. 470 Mandatory Flood Insurance Coverage Repeal
H.R. 471 Private Capital and Reinsurance Markets Risk Transfer
H.R. 472 Alternative Flood Insurance Rate Maps
H.R. 1402 Flood Maps Preparation Transfer
H.R. 1418 Health Insurance Antitrust laws Application
H.R. 1595 Cannabis Related Businesses Financial Services
H.R. 1666 Private Flood Insurance Coverage
H.R. 1689 Climate Change Advisory Commission Establishment
H.R. 1756 Auto Insurance Consumer Reports Use Prohibition
H.R. 1862 Federal Insurance Office Abolition
S. 350 Health Insurance Federal Antitrust laws Application
S. 420 Marijuana Products Taxation and Regulation
S. 603 Financial Company Supervision Determination
H.R. 2048 Consumer Products and Services Pricing
H.R. 2318 National Flood Insurance Mapping
H.R. 2479 Financial Stability Oversight Council Voting Member
H.R. 2578 National Flood Insurance Program Extension Act of 2019
H.R. 2684 Auto Insurance Cost Disparities Study
H.R. 3111 National Flood Insurance Reforms
H.R. 3167 National Flood Insurance Program Reform
H.R. 3183 Crop Insurance Eligibility
H.R. 3258 Flood Insurance Rates Review
S. 1108 Data Protection Impact Assessments
S. 1144 National Flood Insurance Mapping
S. 1200 Cannabis Related Business Financial Services Protection
S. 1213 Health Insurance Reform Provision
S. 1214 Individual and Collective Privacy Rights Protection
S. 1520 National Flood Insurance Program Reauthorization
S. 1531 Health Insurance Consumer Protections
S. 1533 National Flood Insurance Program Reauthorization
H.R. 3872 National Flood Insurance Program Reauthorization
H.R. 4074 Cannabis Related Business Safe Harbor
H.R. 4523 Risk Retention Groups Commercial Insurance Types
S. 2088 Flood Area Community Accountability
S. 2122 Flood Insurance Program Contract Termination Authority
S. 2171 Flood Insurance Agents Continuing Education Requirement
S. 2187 National Flood Insurance Program Reauthorization
S. 2192 Flood Risk Reduction Funding Assistance
S. 2201 Cannabis Related Business Insurers Safe Harbor
H.R. 4634 Terrorism Risk Insurance Act Reauthorization
H.R. 4652 Individual Market Reinsurance Fund Establishment
S. 2877 Terrorism Risk Insurance Act
S. 2964 Non Premium Aviation Insurance Authority Extension
H.R. 1756 Auto Insurance Consumer Reports Use Prohibition
H.R. 3693 Insurance Rate Income Proxies
H.R. 5776 Flood Damaged Areas Accountability
**Issues lobbied without specific bill number: COVID-19 Related Insurance Legislation, Business Interruption Insurance, Consumer Financial Protection Bureau Oversight of the Insurance Industry, Marijuana Financial Services
Client expense: $1,710,000 · Firm income: Not reported
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Federal Aviation Administration (FAA), Federal Emergency Management Agency (FEMA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Economic Council (NEC), Natl Labor Relations Board (NLRB), SENATE, Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR)
Cited source text, amounts, lobbyists, and targets
Private flood insurance; insurance industry safe harbors; NARAB; H.R.1595, S.1200 - Secure and Fair Enforcement Banking Act of 2019; H.R.4074, S.2201 - CLAIM Act; COVID-19 response on insurance impacts including business interruption and recovery fund legislation; H.R. 7011 - Pandemic Risk Insurance Act of 2020
Client expense: Not reported · Firm income: $70,000
Cited source text, amounts, lobbyists, and targets
S.1144: improve mapping under the NFIP
HR 470: Repeal of Mandatory Flood Insurance Coverage for Commercial Properties
H.R.2318: improve mapping under the NFIP, and for other purposes.
HR472: Community Mapping Act
HR 471: Taxpayer Exposure Mitigation Act/Reinsurance
HR 469: To require the use of replacement cost value in determining the premium rates for flood insurance coverage under the NFIP
H.R. 1756: Preventing Credit Score Discrimination in Auto Insurance
S. 1298 Primary Regulators of Insurance Vote Act (PRIVA Act) of 2019
H.R. 3622: Restoring Unfairly Impaired Credit and Protecting Consumers Act
Issues relating to the implementation off the National Association of Registered Agents and Brokers (NARAB)
Issues relating to Diversity & Inclusion, Disparate Impact
Issues relating to U.S. and international insurance capital standards
Issues relating to the Federal Insurance Office
Issues relating to the re-authorization and reform for the NFIP
HR 3623 Climate Risk Disclosure Act of 2019
HR 3624 Outsourcing Accountability Act
HR 3629 Clarify Credit Score Formation Act of 2019
HR 3693 Prohibit Auto Insurance Discrimination Act (Watson-Coleman)
S 2201 Clarifying Law Around Insurance of Marijuana (Claim Act)
HR 1595 Safe Banking Act
HR 4592 International Insurance Standards Act of 2019
HR 3111 National Flood Insurance Program Administrative Reform Act of 2019
HR 3167 National Flood Insurance Program Re-authorization Act of 2019
S 2187 National Flood Insurance Program Re-authorization and Reform Act of 2019
HR 5776 Repeatedly Flooded Communities Preparation Act
H.R.6494 - Business Interruption Insurance Coverage Act of 2020
H.R.7011 - Pandemic Risk Insurance Act of 2020
H.R.6497 Never Again Small Business Protection Act of 2020
H.R. 7412, the Business Interruption Relief Act of 2020
Client expense: $800,000 · Firm income: Not reported
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Consumer Financial Protection Bureau (CFPB), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Highway Traffic Safety Administration (NHTSA), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR)
Cited source text, amounts, lobbyists, and targets
H.R. 99/S. 1508, the "Thin Blue Line Act," which would provide additional aggravating factors for the imposition of the death penalty for targeting and killing a law enforcement officer;
H.R. 207, the Stop the Violence Act, which would establish a pilot program within the U.S. Department of Health and Human Services to provide grants to 10 trauma centers which have existing violence prevention or intervention programs designed to reduce re-admittance and reincarceration rates;
H.R. 295, the End Banking for Human Traffickers Act, which would add the Secretary of the Treasury as a member of the Presidents Interagency Task Force;
H.R. 449, the Pathways to Improving Homeland Security at the Local Level Act, which would direct the Assistant Secretary for State and Local Law Enforcement to produce an accessible annual catalog on the available DHS training, publications, programs, and services for their State, local and tribal partners;
H.R. 489, the Strengthening Homeland Security, Intelligence and Essential Law Enforcement Departments (SHIELD) Act, which would make sure that Federal law enforcement officers required to report for duty even in the event that the Departments or agencies they serve have not been appropriated funds by Congress;
H.R. 724/S. 479, the Preventing Animal Cruelty and Torture Act, which would provide a criminal penalty for those who engage in animal crushing as well as for those who create or distribute such films;
H.R. 816, the "Officer Sean Collier Campus Police Recognition Act," which would include campus police officer within the definition of "public safety officer" for purposes of death, disability, and education benefits under the Public Safety Officers' Benefits Program;
H.R. 838/S.265, the Threat Assessment, Prevention and Safety (TAPS) Act, which would provide resources to create a national strategy to identify, investigate, and mitigate possibly violent behavior through multi-disciplinary behavioral threat assessment and management;
H.R. 1156, the LEOSA Reform Act, which would amend the Law Enforcement Officers Safety Act (LEOSA) and exempt qualified active and retired law enforcement officers from local and State prohibitions on the carriage of concealed firearms, to ensure that these officers are able to carry in the same venues as civilian concealed carry permit holders in areas like schools and national parks, as well as use public transportation and extends the exemption to magazine capacity and would allow active and retired law enforcement officers to access services at U.S. post offices, Social Security Administration offices or Veterans Affairs facilities;
H.R. 1210, the Heroes Lesley Zerebney and Gilbert Vega First Responders Survivors Support Act, which would increase the amount of the death benefit provided by the Public Safety Officers benefits (PSOB) program as well as other benefits administered by the PSOB;
H.R. 1325/S. 4605, the Protect and Serve Act, which would make it a Federal crime to target a law enforcement officer with an assault that results in serious bodily harm or death;
H.R. 1327/S. 546, the Never Forget the Heroes: Permanent Authorization of the September 11th Victim Compensation Fund Act, which would reauthorize the Victim Compensation Fund (VCF) through the Fiscal Year 2090, the same reauthorization Congress provided for the World Trade Center Health Program (WTCHP);
H.R. 1387, the Criminal Organizations Narcotics, Finance, Resources, Operations and Network Targeting (CONFRONT) Act, which would codify an existing Executive Order and direct the Federal government to develop a national strategy to combat transnational criminal organizations;
H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking Act, which would allow U.S. banks and financial institutions to do business with companies trafficking in an illegal substance-marijuana;
H.R. 1865, the National Law Enforcement Museum Commemorative Coin Act, which would direct the U.S. Mint to produce commemorative coins and divert some of the proceeds from their sale to support the National Law Enforcement Officers Memorial Fund;
H.R. 1866, the Probation Officer Protection Act, which would amend section 3606 of Title 18, United States Code, to grant probation officers authority to arrest hostile third parties who obstruct or impede a probation officer in the performance of official duties;
H.R. 2935/S. 1622, the Stopping Overdoses of Fentanyl Analogues (SOFA) Act, which would amend current law to prevent criminal drug traffickers and manufacturers from evading Federal penalties by using analogue drugs which are just as lethal as fentanyl;
H.R. 2070/S.954, the Providing Officers with Electronic Resources (POWER) Act, which would establish a grant program to be administered by the Office of Community Oriented Policing Services (COPS) in order to provide State and local law enforcement agencies with portable chemical screening devices to detect dangerous synthetic opioids and other drugs;
H.R. 2329, the Law Enforcement Immersive Training Act, which would provide grants to State and local law enforcement agencies to access immersive, real-life, scenario-based training;
H.R. 2368/S.998, the Supporting and Treating Officers in Crisis (STOIC) Act, which would revive and expand programs designed to help officers and their families with stress reduction, suicide prevention and the promotion of mental health and wellness;
H.R. 2379/S. 1231, the Bulletproof Vest Partnership Grant Reauthorization Act, which would permanently reauthorizes the Bulletproof Vest Partnership (BVP) program;
H.R. 2560/S.1278, the Putting First Responders First Act, which would codify existing Internal Revenue Code regulations making service-connected disability compensation exempt from Federal income taxes
H.R. 2812/S.1208, the Protecting Americas First Responders Act, which would update the PSOB disability determinations and the definitions making it more consistent with existing Federal law and greatly improve the ability of our injured and disabled officers to have their claims processed more fairly and more quickly;
H.R. 2935/S. 1622, the Stopping Overdoses of Fentanyl Analogues (SOFA) Act, which would amend current law to prevent criminal drug traffickers and manufacturers from evading Federal penalties by using analogue drugs which are just as lethal as fentanyl;
H.R. 3735/S. 2746, the "Law Enforcement Suicide Data Collection Act," which would require the Director of the Federal Bureau of Investigation to provide information on suicide rates in law enforcement;
H.R. 3990/S. 2750, the Operation Stonegarden Reauthorization Act, which would reauthorize grants to State, local and tribal law enforcement agencies to improve border security;
H.R. 4963, the Stop Importation and Manufacturing of Synthetic Analogues (SIMSA) Act, which would update the Controlled Substances Act by adding a Schedule A to allow for the inclusion of analogue and synthetic drugs similar in effect, but chemically different, to existing scheduled substances on a temporary basis;
H.R. 5376/S. 3007, the Eliminated Network Distribution (END) of Child Exploitation Act, which would improve the effectiveness of the CyberTipline, which is administered by the National Center for Missing and Exploited Children;
H.R. 5855, the Bipartisan Solution to Cyclical Violence Act, which would direct the Department of Health and Human Services to establish a grant program for specified trauma centers and nonprofits to establish or expand intervention or prevention programs related to intentional violent trauma, excluding intimate partner violence;
H.R. 6008, the "Traumatic Brain Injury and Post-Traumatic Stress Disorder Law Enforcement Training Act," which would direct the Attorney General to develop crisis intervention training tools for use by law enforcement and other public safety officers when interacting with community members who have traumatic brain injury (TBI), another form of acquired brain injury, or Post-Traumatic Stress Disorder (PTSD);
H.R. 6509, the Public Safety Officer Pandemic Response Act, which would expand and codify the presumption that a death benefit claim for a COVID-19 related death, made through Public Safety Officers Benefits (PSOB) program, will be found by the Bureau of Justice Assistance (BJA) to have contracted the disease in the line of duty in most cases as well as in disability claims;
H.R. 7120, the "Justice in Policing Act," which proposes a series of police reforms;
H.R. 7278/S. 3985, the "Just and Unifying Solutions to Invigorate Communities Everywhere Act," which proposes a series of police reforms;
H.R. 7568, the "Public Safety Officer Support Act," which would expand the eligibility of certain officers or their surviving family for death and disability benefits as provided for by the Public Safety Officers Benefits (PSOB) program;
H.R. 7951, the "Qualified Immunity Act," which would codify the existing qualified immunity doctrine;
H.R. 8772/S. 2174, the "Missing Persons and Unidentified Remains Act," would expand eligibility for grants to State and local governments to identify remains;
H. Res. 1093, which calls on Congress to enact a bill of rights for law enforcement officers;
S. 400, the Blocking Deadly Fentanyl Imports Act, which would modernize the Foreign Assistance Act (FAA) by adding countries that are significant sources of illicit fentanyl and similar synthetic opioids to the annual Majors List";
S. 465, the First Responders Survivors Support Act, which would increase the amount of the death benefit provided by the Public Safety Officers Benefit (PSOB) program as well as other benefits administered by the PSOB;
S. 495, the EAGLES Act, which would reauthorize the National Threat Assessment Center (NTAC) within the U.S. Department of Homeland Security;
S. 820, the Debbie Smith Act, which would reauthorize the Debbie Smith Act;
S. 1208, the "Protecting America's First Responders Act," which would update the PSOB disability determinations and the definitions making it more consistent with existing Federal law and greatly improve the ability of our injured and disabled officers to have their claims processed more fairly and more quickly;
S. 1231, the "A bill to reauthorize the Bulletproof Vest Partnership Grant Program," which would permanently reauthorize the bulletproof vest program;
S. 1464, the "Law Enforcement Training for Mental Health Crisis Response Act," which would address an urgent need to provide our nations law enforcement officers with training to recognize and appropriately respond to behavioral crises caused, not by criminal activity, but by mental illness and substance abuse;
S. 1883, the "Combating Money Laundering, Terrorist Financing, and Counterfeiting Act," which would update various statutes to better fight money laundering and cash smuggling another other illicit finance crimes;
S. 1978, the Corporate Transparency Act, which would require the Federal government to collect beneficial ownership information for corporations and limited liability companies unless the State already collects this information;
S. 2197, the Protecting Rights of Those Exploited by Coercive Trafficking (PROTECT) Act, which would amend existing human trafficking law to specify the use of drugs or illegal substances to cause a person to engage in a commercial sex act or forced labor constitutes a form of coercion;
S. 2264, Erics Law, which would amend current law to allow Federal prosecutors to impanel a second jury for the sentencing phase of capital cases;
S. 2323, the Screening All Fentanyl-Enhanced (SAFE) Mail Act, which would use technology developed by the Opioid Detection Challenge in the U.S. Department of Homeland Security to be deployed within 5 years to scan 100% of all international mail and express cargo for fentanyl and other synthetic opioids;
S. 2701, the Federal Initiative to Guarantee Health by Targeting (FIGHT) Fentanyl Act, which would permanently schedule fentanyl-related substances as Schedule 1 substances;
S. 3398, the "Eliminating Abusive and Rampant Neglect of Interactive Technologies (EARN IT) Act, which would establish a National Commission on Online Child Sexual Exploitation Prevention in an effort to combat the sexual exploitation of children on the Internet;
S. 3607, the Safeguarding Americas First Responders Act, which would establish a presumption that a law enforcement or other public safety officers who dies from COVID-19 or complications related to COVID-19 did so because they sustained a personal injury in the line of duty, provided that the officer engaged in line of duty actions between 1 January 2020 and 31 December 2021;
S. 3987, the "Strong communities Act," which would establish a grant program for local law enforcement agencies to assist in recruiting officers in their own community;
S. 4036, the "Reforming Qualified Immunity Act," which would undermine the existing qualified immunity doctrine;
S. 4186, the Driving for Opportunity Act, which would create a grant program for States to reinstate drivers licenses that were suspended for unpaid fines and fees;
S. 4486, the Achieving Thorough Transparency and Accessibility for Information Navigation on Mental Health Act," which would establish an interactive, internet website-based dashboard that publicizes all Federally funded mental health related grants; and
S. 4491, the "Methamphetamine Response Act," which would designate methamphetamine as an emerging drug threat which would then require the Office of National Drug Control Policy to create an Emerging Threat Response Plan.
Client expense: $55,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Labor, Dept of (DOL), SENATE, White House Office
Cited source text, amounts, lobbyists, and targets
H.R. 2513/H.R. 6395/S. 1976/S. 4049, the Corporate Transparency Act, which would require the Federal government to collect beneficial ownership information for corporations and limited liability companies unless the State already collects this information;
H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking Act, which would allow U.S. banks and financial institutions to do business with companies trafficking in an illegal substance-marijuana;
S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings (ILLICIT CASH) Act, which would provide law enforcement with tools to better combat money laundering, including the collection of beneficial ownership information; and
S. 3865, the "Paycheck Protection Program Second Chance Act," which would make former offenders who on businesses eligible for the Paycheck Protection Program.
Client expense: $55,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Labor, Dept of (DOL), SENATE, White House Office
Cited source text, amounts, lobbyists, and targets
The SAFE Banking Act (HR 1595/S 1200) aims to address the lack of access to banking experienced by lawful cannabis businesses operating in states with existing cannabis regulatory structures. The bill would prevent banking regulators from penalizing banks and their employees for providing financial services to state-legal cannabis businesses, reducing the uncertainty and risk that deters many banks from working with cannabis businesses.
The SAFE Banking Act is a critical next step in achieving the transparency and regulatory compliance required for the long-term health and safety of the cannabis industry.
Client expense: Not reported · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
The Oregon Cannabis Association supports banking reform for cannabis businesses and encourages the US Congress to enact HR 1595/S 1200, the Secure and Fair Enforcement or SAFE Banking Act. This bill, which passed the House in September 2019, would allow cannabis businesses to have the same banking services enjoyed by their non-cannabis peers - eg. checking accounts and lines of credit.
Client expense: Not reported · Firm income: Not reported
Cited source text, amounts, lobbyists, and targets
SAFE Banking (HR 1595/S 1200).
CBAI supports the creation of a safe harbor - as provided by the SAFE Banking Act - so that state legal and compliant cannabis business can access traditional financial services like checking accounts and lines of credit.
Client expense: Not reported · Firm income: Not reported