Veterans Members Business Loan Act

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Client expense: $690,000 · Firm income: Not reported

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

Protect the credit union tax exemption; support national data security standard for those who collect and share consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state privacy laws; establish national standards for fintech; support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; simplify the loan forgiveness process and application for smaller PPP loans; support H.R. 2305, the Veterans Members Business Loan Act; support a strong, independent NCUA as the primary regulator of credit unions; support Rules Committee Amendment #1 (Maloney Amendment #499), which would add the text of the Corporate Transparency Act of 2019 and the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 (the COUNTER Act of 2019); support S. 4117, the Paycheck Protection Small Business Forgiveness Act which would simplify the forgiveness process for PPP loans under $150,000; set aside PPP funds for community financial institutions, as well as consider additional set asides specifically for CDFIs and MDIs; defend credit unions against National Taxpayers Union attacks; exempting credit unions from compliance with the current expected credit loss (CECL) standard; support the HEROES Act proposal to set aside PPP funds for community financial institutions, increase guaranteed portion of existing SBA loans, increase CDFI funding; exclude business loans made in response to COVID-19 relief from the credit union MBL cap; extend loan maturity limits; caution against any additional mandated blanket loan forbearance as a response to the pandemic; caution against overly broad restrictions on credit unions ability to collect on consumer debt during the pandemic; discourage the CFPB from pursuing a QM definition that uses the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) as a proxy for underwriting requirements (the APOR approach); support S. 4159, the E-SIGN Modernization Act, which aims to streamline how consumers consent to receiving electronic documents; support changes to Appendix Q to rely on more flexible and dynamic standards for calculating income and debt; provide greater flexibility with respect to investments in natural person credit union service organizations (CUSOs) and matters of internal governance; supports amendments to facilitate future investments in subordinated debt; process for issuing subordinated debt should be simplified and modeled after the existing framework for secondary capital; supports proposed amendments that would permit greater flexibility when determining the composition of a corporate credit unions board; oppose proposed changes to the definitions used through part 704 that alter the existing distinction between a natural person CUSO and corporate CUSO; support for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); support funding the CDFI Fund at a level of at least $300 million (the House-approved level for FY 2020) for FY 2021; opposition to Amendment #209 (Pascrell-Kaptur #3), which would create a pilot program for postal banking; OCC Should Undertake an Open and Transparent Process in Considering New Charters; OCC Should Ensure that Bank Holding Company Oversight is Applied; RESPA should contain an exception to unnecessary and burdensome regulations for disaster-related programs that move delinquent borrowers into current status; transform the structure of the CFPB from a single director to a bipartisan commission, such as under H.R. 6116; NCUA should also detail how it plans to allocate resources to the Office of Credit Union Resources and Expansion for the rest of the year; NCUA should continue to engage in robust cost-benefit analysis to determine how to allocate resources; support changes to the Central Liquidity Fund in section 4016; extend TDR flexibility to at least December 31, 2021; Oppose Any Effort to Extend Interchange Price Caps; Reject Efforts That Could Lead to Elimination of Courtesy Pay Programs; reject efforts aimed at blanket suppression of adverse credit reporting information; provide approval for the use of automated tools in performing pre-funding reviews of appraisals or evaluations; support H.R. 2305 and S. 2834; exempt social media posts and text messages from the requirement to display the official advertising statement or allow one click away; reinterpret Appendix B to address the recapitalization of interest and align with GAAP, which permits the capitalization of interest on loan modifications; requests that NCUA maintain an off-site posture in connection with examinations; reinstate any field of membership (FOM) statements removed in connection with litigation of NCUAs 2016 FOM rule; support the alternative method to satisfy the account signature or membership card requirements; provide credit unions greater relief and flexibility from the member business lending (MBL) cap; protect consumers against illegal calls and ensure that all stakeholders have the incentive to avoid over-blocking time-sensitive, legitimate calls on which consumers rely; provide a call blocking notification to comply with the TRACED Act; increase capital access for minority- and women-owned business enterprises (MWBEs); FHFA should work with lawmakers to ensure certain legislative guarantees are adopted before the GSEs are released from conservatorship; The FHFA should provide capital relief for Fannie Mae and Freddie Mac by reducing the amount of capital that must be reserved against credit union-originated mortgage loans; oppose increased guarantee fees in the GSE capital framework; more virtual examinations in the upcoming years should greater consistency in NCUAs examination process; Virtual Exams Should Prioritize Reducing Exam Burden and Duration; support CFPBs proposed procedural rule on its new Advisory Opinion (AO) Program; support H.R. 7913; oppose GSEs assessing a fee on mortgage refinance loans; Credit unions should be permitted to provide a notice under current section 1024.41(c)(2)(iii) regarding short term payment forbearance programs; CFPB should issue an additional or amended interim final rule that also addresses disaster Flex Modifications offered by the GSEs; support H.R. 7914, the Eliminating CECL Accounting Standard Act; extension of the GSE Patch; asks the IRS to not include fringe benefits in excess of excludable amounts in the definition of excess remuneration; IRS Should Grandfather Certain Employee Remuneration Contracts; support for the Credit Union Governance Modernization Act of 2020; support proposed amendments to Regulation Z to ease the transition from the London Interbank Offered Rate (LIBOR) to replacement indices; Bureau Should Ensure That Time-Barred Debt Notices Do Not Increase Costs and Liability for Creditors; it should be made clear that the supplemental notice of proposed rulemaking regarding debt collection practices pertaining to time-barred debt do not apply to credit unions collecting their own debt; OCC should not pursue new chartering options for fintechs without a full and transparent rulemaking process; HUD should revise the FHA guidelines regarding the student loan debt calculation; support H.R.7777, the Paycheck Protection Small Business Forgiveness Act; support proposed Seasoned QM definition; new ILC deposit insurance applications at this time could severely weaken the stability of the financial system and urge the FDIC to suspend further chartering activity; support legislative initiatives to increase the maximum thresholds for HPML escrow exemptions; support section 108 creating a new exemption category from the HPML escrow requirement; oppose FHFAs proposed adverse market fee on mortgage refinance loans; FY2021 National Defense Authorization Act - H.R. 6395, S. 4049; Military Base Financial Institution leases; The HEROES Act - H.R. 925, H.R. 6800; The Senate HEALS Act; The CARES Act

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. Currently, we are not supporting any specific legislation. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting H.R. 1661, a bill that would provide the NCUA flexibility to increase non-mortgage loan maturity limits for federal credit unions. We are also supporting H.R. 2305 and S.2834, a bill that would exempt business loans to veterans from the member business loan cap. Additionally, we support S. 3233 to allow expulsion for cause of an unruly member; S. 3326, to remove outdated duties for credit union boards and remove the requirement for credit unions to provide NCUA with the names of its loan officers from the FCUA; and the Board Governance Modernization Act, to modify the FCUA requirement that credit union boards meet once a month to not less than six times per year. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports congressional efforts, including H.R. 2514, the COUNTER Act, and S.2563, the ILLICIT CASH Act, to reform bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules. MCUL supported/supports passage of legislation making reforms to the Paycheck Protection Act, including the Paycheck Protection Flexibility Act of 2020 (P.L. 116-142), S. 4116 (extending the authority under PPP until August 8), and the Paycheck Protection Small Business Forgiveness Act (S. 4117). We are also requesting Congress include in any Phase 4 emergency stimulus bill: S. 4117, providing small businesses with PPP loans under $150k with automatic forgiveness; S. 3620, establishing a housing assistance fund; S.4159; a bill to modernize the E-Sign Act to reflect advancements in technology over the past 20 years and streamline how consumers consent to receiving electronic documents and remove barriers that some face to receiving important documents; approve $1 billion in CDFI fund; include language to better effectuate electronic and remote notarizations. Finally, we are educating Congress on provisions in the HEROES Act we believe to be harmful to financial institutions and our members, including moratoriums on foreclosures, evictions, and collections and provisions dealing with negative credit reporting and adverse information on credit reports and urging Congress to taking our concerns into consideration if they proceed with addressing these issues in a Phase 4 bill.

Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUA's low income designation regulations Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding its regulatory emergency liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's Advanced Notice of Proposed Rulemaking on Alternative Capital Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-laws Issues related to credit unions' incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership Structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to the Department of Defenese Poposal regarding Credit Extending to Service Members under MLA Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system Issues related to Federal Reserve Regulation D Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to Fannie Mae Capital Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to economic growth Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims procedures Issues related to Web-Based Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to payments innovation Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to debt collection requirements Issues related to capital reform for credit unions Issues related to procurement reform for private voluntary organizations Issues related to Federal Credit Union Charter Modernization Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to NCUA's Fidelity Bonds Proposed Rule Issues related to the Consumer Financial Protection Bureau's No-Acton Letters and the BCFP Product Sandbox Issues related to the Consumer Financial Protection Bureau's proposal to extend the Payday Rule's compliance daedline Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 79(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to robocalls and the Stopping Bad Robocalls Act Issues related to financial technology (FINTECH) Issues related to the Consumer Financial Protection Bureau Payday Rule Issues related to appraisals Issues related to student lending Issues related to robocalls and the draft Declaratory Ruling (the ruling) and Third Further Notice of Proposed Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17-97 Issues related to FY 2020 Foreign Assistance Budget and Policy Priorities Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to permit Federal Credit Unions to establish their own fiscal year Issues related to striking a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhance flexibility of Federal Credit Unions to schedule board meetings Issues related to remove certain outdated responsibilities of Federal credit union board of directors Issues related to permit Federal credit unions to expel disruptive members for just cause without a vote Issues related to permit balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to the draft bill improving Laundering Laws and Increasing Comprehensive Information Issues related to tracking of Criminal Activity in Shell Holding (ILLICIT CASH Act) Issues related to PACE loans Issues related to Consumer Financial Protection Bureau's HMDA reporting thresholds Issues on NCUA Executive compensation rules Issues related to business access to financial services Issues related to Strengthening Cybersecurity for the Financial Sector Act of 2019 Issues related to minority depository institutions Issues related to the Federal Reserve's Faster Payments Proposal Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to Credit Union Board Meeting Frequency Issues related to COVID-19 crisis response legislation Issues related to the regulation of overtime Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to essential services designation for financial services during COVID-19 Issues related to QRM Risk Retention review Issues related to NCUA's proposed rule on Combination transactions Issues related to the Freezing Assets of Suspected Terrorist and Enemy Recruits Act of 2020 Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to Federal Home Loan Bank liquidity Issues related to digital identity legislation Issues related to Paid Leave Payroll Tax Credits Issues related to the Central Liquidity Facility (CLF) Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to the legislation to temporarily halt the Federal financial regulators from carrying out rulemakings unrelated to the COVID-19 emergency until the end of such emergency Issues related to troubled debt restructuring Issues related to Prompt Corrective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forbearance Issues related to Paycheck Protection Program forgiveness process H.R. 266, Paycheck Protection Program and Healthcare Enhancement Act H.R. 388, the Financial Reporting Threshold Modernization Act H.R. 442, to amend the Consumer Financial Protection Act of 2010 to extend the supervisory authority of the Bureau of Consumer Financial Protection to include assessing compliance with the Military Lending Act H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act, Title I and Secs. 4008, 4012, 4014 of Title IV H.R.1039, to streamline requirements for currency transaction reports and suspicious activity reports and for other purposes H.R. 1158, the FY2020 Consolidated Appropriations Act (funding for the CDFI Fund as well as the Community Development Revolving Loan Fund) H.R. 1500, the Consumers First Act H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking act of 2019 H.R. 1661, to provide the National Credit Union Administration Board flexibility to increase Federal credit Union loan maturities, and for other purposes H.R. 1737, the American Housing and Economic Mobility Act of 2019 H.R. 1865, FY2020 Further Consolidated Appropriations Act (funding for the Cooperative Development Program, tax extenders, repeal of "parking tax") H.R. 1957, the Taxpayers First Act of 2019 H.R. 2093, to amend the Controlled Substances Act to provide for a new rule regarding the application of the Act of marijuana, and for other purposes H.R. 2157, Supplemental Appropriations Act of 2019 H.R. 2162, Housing Financial Literacy Act of 2019 H.R. 2290, Shutdown Guidance for Financial Institutions Act H.R. 2305, Veterans Members Business Loan Act H.R. 2445, Self-Employed Mortgage Access Act H.R. 2500, National Defense Authorization Act for Fiscal Year 2020 H.R. 2513, Corporate Transparency Act of 2019 H.R. 2514, Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 H.R. 2740, the State and Foreign Operations and Related Programs Appropriations Act H.R. 2852, Homebuyer Assistance Act of 2019 H.R. 3111, National Flood Insurance Program Administration Reform Act of 2019 H.R. 3167, National Flood Insurance Program Re-authorization Act of 2019 H.R. 3182, Current Expected Credit Loss Consumer Impact and Study Bill of 2019 H.R. 3198, the Comprehensive Regulatory Review Act H.R. 3300, the Economic Mobility Act of 2019 H.R. 3301, the Taxpayer Certainty and Disaster Tax Relief Act of 2019 H.R. 3351, Financial Services and General Government Appropriations Act of 2020 H.R. 3375, the Stopping Bad Robocalls Act H.R. 4458, Cybersecurity and Financial System Resilience Act H.R. 4464, Monitoring and Curbing Abusive Debt Collection Clarification Act H.R. 4565, the Responsible Accounting Standards Act of 2019 H.R. 5001, Non-Judicial Foreclosure Debt Collection Clarification Act H.R. 5013, Small Business Fair Debt Collection Protection Act H.R. 5050, Veterans and Consumers Fair Credit Act H.R. 5132, Gun Violence Prevention through Financial Intelligence Act H.R. 5315, Expanding Opportunities for Minority Depository Institutions Act H.R. 5322, Ensuring Diversity in Community Banking Act of 2019 H.R. 5332, Protecting your Credit Score Act of 2019 H.R. 5332, Protection your Credit Score Act of 2019, Sec. 5 H.R. 5513, the Expanding Opportunities for Minority Depository Institutions Act H.R. 5981, Credit Union Board Modernization Act H.R. 6074, Coronavirus Preparedness and Response Supplemental Appropriations Act H.R. 6116, the Consumer Financial Protection Commission Act of 2020 H.R. 6201, the Families First Coronavirus Response Act, paid and sick leave provisions H.R. 6321, the Financial Protections and Assistance for America's Consumers, States, Businesses, and Vulnerable Populations Act H.R. 6395, National Defense Authorization Act for Fiscal Year 2021 H.R. 6423, to provide a temporary debt collection moratorium during the COVID-19 emergency period, and for other purposes H.R. 6550, Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020 H.R. 6551, the CARES Act Section 4014, Technical Corrections Act H.R. 6736, the Protect Rural Renters Act of 2020 H.R. 6741, the COVID-19 Mortgage Relief Act H.R. 6789, Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020 H.R. 6790, the Business Borrowers Protection Act H.R. 6800, Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act of 2020 H.R. 6820, the Emergency Rental Assistance and Rental Market Stabilization Act of 2020 H.R. 6873, the Emergency Housing Assistance for Older Adults Act of 2020 H.R. 7084, the Emergency Housing Voucher Act of 2020 H.Res 275, Supporting the goals and ideals of "Financial Literacy Month" H.Res 327, Encouraging greater public-private sector collaboration to promote financial literacy for students and young adults H.Res 328, Supporting the protection of elders through financial literacy H. Res 602, Support of resolution in support of cooperatives S. 151, Telephone Robocall Abuse Criminal Enforcement and Deterrence Act S. 787, the American Housing and Economic Mobility Act of 2019 S. 1028, Strengthening the Tenth Amendment through Entrusting States (STATES Act) S. 1200, Secure and Fair Enforcement Banking Act of 2019 (SAFE Act) S. 1564, Continued Encouragement for Consumer Lending Act S. 2524, the Financial Services and General Government Appropriations Act of Fiscal Year 2020 S. 2563, The Improving Laundering Laws and Increasing Comprehensive Information S. 2583, the State-Foreign Operations and Related Programs Appropriations Act for FY2020 S. 2833, Veterans and Consumers Fair Credit Act of 2019 S. 2834, Veterans member Business Loan Act S. 3003, the Financial Institution Customer Protection Act S. 3032, Strengthening the Tenth Amendment Through Entrusting States S. 3323, Credit Union Governance Modernization Act of 2020 S. 3326, Credit Union Modernization Act of 2019 S. 3389, Expanding Access to Lending Options Act S. 3533, the Securing and Enabling Commerce Using Remote and Electronic (SECURE) S. 3548, Coronavirus Aid, Relief, and Economic Security act, payroll tax provisions S. 3571, the Financial Protections and Assistance for America's Consumers, States, Businesses, and Vulnerable Populations Act S. 3620, A Bill to establish a Housing Assistance Fund at the Department of Treasury S. 3676, Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020 S. 4049, National Defense Authorization Act for Fiscal Year 2021 Sec. 2821 of S. 1790, the National Defense Authorization Act of FY 2020

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; the CARES Act; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements- oppose fee structure increases; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements; GSEs should provide relief for CUs impacted by forbearances; raise 15-year maturity limit on certain CU loans; Establish an emergency flexible QM standard; Expand definition of Community FI in FHLB Act; expanding membership in FHLBs to include conduits should be explicitly prohibited; Limit liability for Essential Businesses; Assist associations in relief efforts related to COVID-19; do not eliminate courtesy pay; no blanket forbearance in COVID-19 relief; Increase PPP funding; Community Reinvestment Act; delay property tax assessments; FCC should issue an interim declaratory ruling or otherwise act on the Petition on an expedited basis related to autodialing; SBA to issue PPP guidance; H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; minimize paper payments of Economic Impact payments; Treasury should ensure that all credit unions will be able to receive a payroll tax credit for providing paid sick leave related to COVID-19; support Chairman Hoods request to make changes to the CLF and PCA flexibility during COVID response; third-party vendor examination authority is unnecessary; examiner flexibility with PPP lending; inaccurate call labeling is harmful - provide effective redress; provide equitable access to small lenders for PPP loans and provide transparency related to pacing of applications; improvements to HEROES Act; Support for S. 3833, the Paycheck Protection Program Extension Act; NAFCU urges the NCUA Board to take up Overdraft Policy and approve; Automatic forgiveness of PPP loans under $150k; supportive of efforts to expand financial inclusion, but we are concerned FedAccounts could cause disruptions; oppose adding provision to NDAA that would give banks parity with CUs on military installations; strengthen and improve BSA/AML system while not overburdening CUs support adding Anti-Money Laundering Act of 2020 to NDAA; oppose H.R. 5332, the Protecting Your Credit Score Act; moving the U.S. currency to a federally-backed digital system will have unintended consequences that could affect the privacy of millions of Americans and erode the competitive viability of the U.S. banking system.

Monitor issues related to credit unions; HR 1595 the SAFE Banking Act; HR 2305 Member Business Lending and Veterans; S. 1564 and HR 3182, legislation related to stop and study of CECL.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; establish national standards for fintech; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; temporary relief from TDR; protect small enders from excessive guarantee fees; reduce burdens from TILA/RESPA and TRID; support use of modified DTI ratio for QM loans and general QM reforms; CFPB should raise the safe harbor threshold for remittance transfers; FHFA should continue to evaluate the consistency of the GSEs pooling requirements to ensure fungibility of the UMBS and support investor confidence; NCUA should set an appraisal threshold that provides parity with banks, offer additional commentary on what constitutes a complex transaction to provide credit unions with greater clarity, and establish a de minimis threshold for transactions that are partially insured or guaranteed; FCC should halt Service Providers aggressive call blocking efforts until the STIR/SHAKEN call authentication framework is fully implemented and ensure there is complete transparency and mitigation of blocking for both callers and called parties; HR 3621, The Comprehensive CREDIT Act, needs reforms to prevent increased cost of credit and unreasonable burdens on community institutions; repeal the Durbin Amendment relating to debit interchange and do not extend interchange to credit; the NCUA Board should adopt a variable interest rate to allow for adequate risk-based pricing, expand lending to underserved, and provide mechanism for adjusting interest rate ceiling; examine questionable banker activities such as astroturfing and ask, what other anti-consumer efforts are bankers secretly funding; fair pricing in liquidation of taxi medallion loans; support equitable application of employee remuneration for not-for-profits; exempt credit unions from CFPBs small business data collection rules; support HR 5931, the Improving FHA Support for Small Dollar Mortgages Act of 2020; support S. 3323, the Credit Union Governance Modernization Act of 2020; support increased funding for CDFI programs and CDRLF; eliminate Regulation Ds transaction limit for savings accounts; oppose using g-fees as a source of funding offset; support 5-person leadership commission for the CFPB; provide association relief in COVID-19 relief packages; FCC should exempt credit unions from, payment of fees for use of reassigned numbers database; NCUA and CFPB should allow broad compliance relief and not take supervisory action for at least 60 days due to COVID-19; FHFA should maintain the current LTV policy allowing GSEs to adjust LTV ratios as necessary, the FHFA should impose LLPAs on those communities that allow PACE financing, and support the FHFAs efforts to provide additional disclosures to consumers if the benefits outweigh the burdens, as well as the creation of a state-run registry of PACE lien information; support non-regulatory approaches for encouraging the use and acceptance of AI technologies and eliminate rules that impair AI related innovation; support mitigating concerns related to PACE loans and FHFA should work with state and local leaders to communicate the risks of PACE programs, require licensing of PACE administrators and contractors, and establish clear regulations pertaining to the subordination of PACE liens to mortgages; relief from MBL cap; capital relief including RBC revisions and leverage ratio adjustments; extend examination cycles, mandatory compliance deadlines, allow virtual board meetings; congress should give credit unions parity in COVID-19 relief; modernize CLF; include credit unions and increase funding for PPP; provide temporary capital flexibility; modernize E-sign Act; enhance SBA 7(a) loan program by waiving fees for small business borrowers and lenders, increase federal guaranty, increase deferment flexibility, increase maximum loan size, increase general 7(a) and secondary market authorization caps, waive real estate appraisal requirement, and suspend income tax verifications requirements; NCUA should provide flexibility in capital restoration and other PCA requirements; expedite subordinated debt proposal; relax rules on stress testing and capital planning; do not subject combination transactions to overly prescriptive regulatory requirements.

Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUA's low income designation regulations Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding its regulatory emergency liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's Advanced Notice of Proposed Rulemaking on Alternative Capital Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-laws Issues related to credit unions' incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership Structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to the Department of Defenese Poposal regarding Credit Extending to Service Members under MLA Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system Issues related to Federal Reserve Regulation D Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to Fannie Mae Capital Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to economic growth Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims procedures Issues related to Web-Based Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to payments innovation Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to debt collection requirements Issues related to capital reform for credit unions Issues related to procurement reform for private voluntary organizations Issues related to Federal Credit Union Charter Modernization Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to NCUA's Fidelity Bonds Proposed Rule Issues related to the Consumer Financial Protection Bureau's No-Acton Letters and the BCFP Product Sandbox Issues related to the Consumer Financial Protection Bureau's proposal to extend the Payday Rule's compliance daedline Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 79(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to robocalls and the Stopping Bad Robocalls Act Issues related to financial technology (FINTECH) Issues related to the Consumer Financial Protection Bureau Payday Rule Issues related to appraisals Issues related to student lending Issues related to robocalls and the draft Declaratory Ruling (the ruling) and Third Further Notice of Proposed Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17-97 Issues related to FY 2020 Foreign Assistance Budget and Policy Priorities Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to permit Federal Credit Unions to establish their own fiscal year Issues related to striking a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhance flexibility of Federal Credit Unions to schedule board meetings Issues related to remove certain outdated responsibilities of Federal credit union board of directors Issues related to permit Federal credit unions to expel disruptive members for just cause without a vote Issues related to permit balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to the draft bill improving Laundering Laws and Increasing Comprehensive Information Issues related to tracking of Criminal Activity in Shell Holding (ILLICIT CASH Act) Issues related to PACE loans Issues related to Consumer Financial Protection Bureau's HMDA reporting thresholds Issues on NCUA Executive compensation rules Issues related to business access to financial services Issues related to Strengthening Cybersecurity for the Financial Sector Act of 2019 Issues related to minority depository institutions Issues related to the Federal Reserve's Faster Payments Proposal Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to Credit Union Board Meeting Frequency Issues related to COVID-19 crisis response legislation Issues related to the regulation of overtime Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to essential services designation for financial services during COVID-19 Issues related to QRM Risk Retention review Issues related to NCUA's proposed rule on Combination transactions Issues related to the Freezing Assets of Suspected Terrorist and Enemy Recruits Act of 2020 H.R. 388, the Financial Reporting Threshold Modernization Act H.R. 442, to amend the Consumer Financial Protection Act of 2010 to extend the supervisory authority of the Bureau of Consumer Financial Protection to include assessing compliance with the Military Lending Act H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act, Title I and Secs. 4008, 4012, 4014 of Title IV H.R.1039, to streamline requirements for currency transaction reports and suspicious activity reports and for other purposes H.R. 1158, the FY2020 Consolidated Appropriations Act (funding for the CDFI Fund as well as the Community Development Revolving Loan Fund) H.R. 1500, the Consumers First Act H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking act of 2019 H.R. 1661, to provide the National Credit Union Administration Board flexibility to increase Federal credit Union loan maturities, and for other purposes H.R. 1737, the American Housing and Economic Mobility Act of 2019 H.R. 1865, FY2020 Further Consolidated Appropriations Act (funding for the Cooperative Development Program, tax extenders, repeal of "parking tax") H.R. 1957, the Taxpayers First Act of 2019 H.R. 2093, to amend the Controlled Substances Act to provide for a new rule regarding the application of the Act of marijuana, and for other purposes H.R. 2157, Supplemental Appropriations Act of 2019 H.R. 2162, Housing Financial Literacy Act of 2019 H.R. 2290, Shutdown Guidance for Financial Institutions Act H.R. 2305, Veterans Members Business Loan Act H.R. 2445, Self-Employed Mortgage Access Act H.R. 2500, National Defense Authorization Act for Fiscal Year 2020 H.R. 2513, Corporate Transparency Act of 2019 H.R. 2514, Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 H.R. 2740, the State and Foreign Operations and Related Programs Appropriations Act H.R. 2852, Homebuyer Assistance Act of 2019 H.R. 3111, National Flood Insurance Program Administration Reform Act of 2019 H.R. 3167, National Flood Insurance Program Re-authorization Act of 2019 H.R. 3182, Current Expected Credit Loss Consumer Impact and Study Bill of 2019 H.R. 3198, the Comprehensive Regulatory Review Act H.R. 3300, the Economic Mobility Act of 2019 H.R. 3301, the Taxpayer Certainty and Disaster Tax Relief Act of 2019 H.R. 3351, Financial Services and General Government Appropriations Act of 2020 H.R. 3375, the Stopping Bad Robocalls Act H.R. 4458, Cybersecurity and Financial System Resilience Act H.R. 4464, Monitoring and Curbing Abusive Debt Collection Clarification Act H.R. 4565, the Responsible Accounting Standards Act of 2019 H.R. 5001, Non-Judicial Foreclosure Debt Collection Clarification Act H.R. 5013, Small Business Fair Debt Collection Protection Act H.R. 5050, Veterans and Consumers Fair Credit Act H.R. 5132, Gun Violence Prevention through Financial Intelligence Act H.R. 5315, Expanding Opportunities for Minority Depository Institutions Act H.R. 5322, Ensuring Diversity in Community Banking Act of 2019 H.R. 5332, Protecting your Credit Score Act of 2019 H.R. 5513, the Expanding Opportunities for Minority Depository Institutions Act H.R. 5981, Credit Union Board Modernization Act H.R. 6201, the Families First Coronavirus Response Act, paid and sick leave provisions H.R. 6116, the Consumer Financial Protection Commission Act of 2020 H.Res 275, Supporting the goals and ideals of "Financial Literacy Month" H.Res 327, Encouraging greater public-private sector collaboration to promote financial literacy for students and young adults H.Res 328, Supporting the protection of elders through financial literacy H. Res 602, Support of resolution in support of cooperatives S. 151, Telephone Robocall Abuse Criminal Enforcement and Deterrence Act S. 787, the American Housing and Economic Mobility Act of 2019 S. 1028, Strengthening the Tenth Amendment through Entrusting States (STATES Act) S. 1200, Secure and Fair Enforcement Banking Act of 2019 (SAFE Act) S. 1564, Continued Encouragement for Consumer Lending Act S. 2524, the Financial Services and General Government Appropriations Act of Fiscal Year 2020 S. 2563, The Improving Laundering Laws and Increasing Comprehensive Information S. 2583, the State-Foreign Operations and Related Programs Appropriations Act for FY2020 S. 2833, Veterans and Consumers Fair Credit Act of 2019 S. 2834, Veterans member Business Loan Act S. 3003, the Financial Institution Customer Protection Act S. 3032, Strengthening the Tenth Amendment Through Entrusting States S. 3323, Credit Union Governance Modernization Act of 2020 S. 3326, Credit Union Modernization Act of 2019 S. 3389, Expanding Access to Lending Options Act S. 3548, Coronavirus Aid, Relief, and Economic Security act, payroll tax provisions Sec. 2821 of S. 1790, the National Defense Authorization Act of FY 2020

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. Currently, we are not supporting any specific legislation. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting H.R. 1661, a bill that would provide the NCUA flexibility to increase non-mortgage loan maturity limits for federal credit unions. We are also supporting H.R. 2305 and S.2834, a bill that would exempt business loans to veterans from the member business loan cap. Additionally, we support S. 3233 to allow expulsion for cause of an unruly member; S. 3326, to remove outdated duties for credit union boards and remove the requirement for credit unions to provide NCUA with the names of its loan officers from the FCUA; and the Board Governance Modernization Act, to modify the FCUA requirement that credit union boards meet once a month to not less than six times per year. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports congressional efforts, including H.R. 2514, the COUNTER Act, and S.2563, the ILLICIT CASH Act, to reform bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules. MCUL supported passage of the CARES Act, H.R. 748 and called for the inclusion of several provisions in the bill, including language to: Exempt credit union business loans made during federally declared disasters and emergencies from the Credit Union Member Business Lending Cap; Exempt fully government-guaranteed loans made through programs at the Small Business Administration, Department of Agriculture and other agencies from the Credit Union Member Business Lending Cap; Ensure that any new small business lending programs created through the Small Business Administration or other government agencies include an opportunity for credit unions to participate; and Increase appropriations for the Community Development Financial Institution Fund (CDFIF), the Community Development Revolving Loan Fund (CDRLF), and the Community Development Financial Institutions (CDFI) Fund.

Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUA's low income designation regulations Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding its regulatory emergency liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's Advanced Notice of Proposed Rulemaking on Alternative Capital Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-laws Issues related to credit unions' incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership Structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to the Department of Defenese Poposal regarding Credit Extending to Service Members under MLA Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system Issues related to Federal Reserve Regulatory D Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to Fannie Mae Capital Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to economic growth Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims procedures Issues related to Web-Based Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to payments innovation Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to debt collection requirements Issues related to capital reform for credit unions Issues related to procurement reform for private voluntary organizations Issues related to Federal Credit Union Charter Modernization Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to NCUA's Fidelity Bonds Proposed Rule Issues related to the Consumer Financial Protection Bureau's No-Acton Letters and the BCFP Product Sandbox Issues related to the Consumer Financial Protection Bureau's proposal to extend the Payday Rule's compliance daedline Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 79(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to robocalls and the Stopping Bad Robocalls Act Issues related to financial technology (FINTECH) Issues related to the Consumer Financial Protection Bureau Payday Rule Issues related to appraisals Issues related to student lending Issues related to robocalls and the draft Declaratory Ruling (the ruling) and Third Further Notice of Proposed Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17-97 Issues related to FY 2020 Foreign Assistance Budget and Policy Priorities Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to permit Federal Credit Unions to establish their own fiscal year Issues related to striking a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhance flexibility of Federal Credit Unions to schedule board meetings Issues related to remove certain outdated responsibilities of Federal credit union board of directors Issues related to permit Federal credit unions to expel disruptive members for just cause without a vote Issues related to permit balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to the draft bill improving Laundering Laws and Increasing Comprehensive Information Issues related to tracking of Criminal Activity in Shell Holding (ILLICIT CASH Act) Issues related to PACE loans Issues related to Consumer Financial Protection Bureau's HMDA reporting thresholds Issues on NCUA Executive compensation rules Issues related to small business cannabis Issues related to Strengthening Cybersecurity for the Financial Sector Act of 2019 Issues related to minority depository institutions Issues related to the Federal Reserve's Faster Payments Proposal Issues related to Credit Union acquisitions of banks Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act H.R. 388, the Financial Reporting Threshold Modernization Act H.R. 442, to amend the Consumer Financial Protection Act of 2010 to extend the supervisory authority of the Bureau of Consumer Financial Protection to include assessing compliance with the Military Lending Act H.R.1039, to streamline requirements for currency transaction reports and suspicious activity reports and for other purposes H.R. 1158, the FY2020 Consolidated Appropriations Act (funding for the CDFI Fund as well as the Community Development Revolving Loan Fund) H.R. 1500, the Consumers First Act H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking act of 2019 H.R. 1661, to provide the National Credit Union Administration Board flexibility to increase Federal credit Union loan maturities, and for other purposes H.R. 1737, the American Housing and Economic Mobility Act of 2019 H.R. 1865, FY2020 Further Consolidated Appropriations Act (funding for the Cooperative Development Program, tax extenders, repeal of "parking tax") H.R. 1957, the Taxpayers First Act of 2019 H.R. 2093, to amend the Controlled Substances Act to provide for a new rule regarding the application of the Act of marijuana, and for other purposes H.R. 2157, Supplemental Appropriations Act of 2019 H.R. 2162, Housing Financial Literacy Act of 2019 H.R. 2290, Shutdown Guidance for Financial Institutions Act H.R. 2305, Veterans Members Business Loan Act H.R. 2445, Self-Employed Mortgage Access Act H.R. 2500, National Defense Authorization Act for Fiscal Year 2020 H.R. 2513, Corporate Transparency Act of 2019 H.R. 2514, Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 H.R. 2740, the State and Foreign Operations and Related Programs Appropriations Act H.R. 2852, Homebuyer Assistance Act of 2019 H.R. 3111, National Flood Insurance Program Administration Reform Act of 2019 H.R. 3167, National Flood Insurance Program Re-authorization Act of 2019 H.R. 3182, CECL Consumer Impact and Study Bill of 2019 H.R. 3198, the Comprehensive Regulatory Review Act H.R. 3300, the Economic Mobility Act of 2019 H.R. 3301, the Taxpayer Certainty and Disaster Tax Relief Act of 2019 H.R. 3351, Financial Services and General Government Appropriations Act of 2020 H.R. 3375, the Stopping Bad Robocalls Act H.R. 4458, Cybersecurity and Financial System Resilience Act H.R. 4464, Monitoring and Curbing Abusive Debt Collection Clarification Act H.R. 4565, the Responsible Accounting Standards Act of 2019 H.R. 5001, Non-Judicial Foreclosure Debt Collection Clarification Act H.R. 5013, Small Business Fair Debt Collection Protection Act H.R. 5050, Veterans and Consumers Fair Credit Act H.R. 5315, Expanding Opportunities for Minority Depository Institutions Act H.R. 5322, Ensuring Diversity in Community Banking Act of 2019 H.R. 5332, Protecting your Credit Score Act of 2019 H.Res 275, Supporting the goals and ideals of "Financial Literacy Month" H.Res 327, Encouraging greater public-private sector collaboration to promote financial literacy for students and young adults H.Res 328, Supporting the protection of elders through financial literacy H. Res 602, Support of resolution in support of cooperatives S. 151, TRACED Act S. 787, the American Housing and Economic Mobility Act of 2019 S. 1028, Strengthening the Tenth Amendment through Entrusting States (STATES Act) S. 1200, Secure and Fair Enforcement Banking Act of 2019 (SAFE Act) S. 1564, Continued Encouragement for Consumer Lending Act S. 2524, the Financial Services and General Government Appropriations Act of Fiscal Year 2020 S. 2563, The Improving Laundering Laws and Increasing Comprehensive Information S. 2583, the State-Foreign Operations and Related Programs Appropriations Act for FY2020 S. 2834, Veterans member Business Loan Act S. 3003, the Financial Institution Customer Protection Act S. 3032, Strengthening the Tenth Amendment Through Entrusting States Sec. 2821 of S. 1790, the National Defense Authorization Act of FY 2020

Monitor issues related to credit unions; HR 1595 the SAFE Banking Act; HR 2305 Member Business Lending and Veterans; S. 1564 and HR 3182, legislation related to stop and study of CECL.

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

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Protect the credit union tax exemption; support a national data security standard for those who collect and store consumer information; support a uniform national consumer data privacy standard as opposed to a patchwork of standards stemming from different state data privacy laws; Support appropriately balancing the benefits and burdens associated with collecting and reporting HMDA data; Support reducing regulatory burdens by eliminating HMDA data points adopted pursuant to the Bureaus discretionary authority; Support the revision or elimination of several HMDA data points, including all free-form text boxes; Support enhancing the structure and operations of the CFPB; support the Committees ongoing work to promote diversity and inclusion in financial services; support legislation such as H.R. 4067, the Financial Inclusion in Banking Act of 2019, which would direct the CFPBs Office of Community Affairs to research how to increase financial inclusion for underserved communities; supports CFPB Director Kathy Kraningers efforts to provide financial institutions with regulatory certainty and targeted relief, while focusing the CFPBs efforts on bad actors; support increased focus on diversity, equity, and inclusion (DEI) within the American economy and the industry; support laws and regulations aimed at detecting and preventing discrimination, as well as the legal mechanisms used to protect fundamental consumer interests; support HUDs objective of updating the Disparate Impact Rule by aligning it more closely with the Supreme Courts decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc., (Inclusive Communities); support housing finance reform of the GSEs because the current conservatorship of the government-sponsored enterprises (GSEs), Fannie Mae and Freddie Mac, is unsustainable; Support permitting the GSEs to retain more capital to better protect taxpayers in the event of a severe economic downturn; support H.R. 2513, the Corporate Transparency Act of 2019 and the COUNTER Act of 2019; support efforts to modernize the Currency Transaction Report (CTR) threshold by indexing it for inflation; support The Business of Insurance Regulatory Reform Act of 2019; support tech sprints; support regulatory efforts to modernize and streamline supervisory processes; support reducing the length of exams and minimizing manual review processes to alleviate operational disruption; support the CFPBs use of machine automated compliance checks; Support Interbank real-time gross settlement of faster payments docket No. OP-1670; support distribution of excess the National Credit Union Share Insurance Fund reserves; support return of the normal operating level to its historical level of 1.30 percent; support appropriate, tailored regulation for credit unions and relief from growing regulatory burdens; support a fair playing field; support government transparency and accountability; support a strong, independent NCUA as the primary regulator for credit unions; support H.R. 1661, legislation to provide the NCUA Board flexibility to increase loan maturities; support Legislation to allow all credit unions to add underserved areas to their fields of membership; support reducing regulatory burdens; advocate against an expanded consumer compliance examination program; supports legislative efforts to direct the FCC to combat illegal robocalls in the House-Senate agreement on S. 151, the TRACED Act; support efforts to distinguish between fraudulent/illegal robocalls and calls from legitimate businesses seeking to communicate with their members and customers; support a safe harbor that would allow credit unions to send text messages to their members to clarify in an opt-out confirmation message the scope of the recipients opt-out request without violating the Telephone Consumer Protection Act (TCPA) or related FCC rules; support H.R. 2305, Veterans Members Business Loan Act; support implementing regulations that clarify that the requirements of the CCPA and its implementing regulations do not apply to organizations that solely collect GLBA-covered information; support a delay in enforcement of the CCPA; support amending NCUAs Chartering Manual to modernize its regulations so credit unions can continue to effectively serve their communities, especially underserved communities; support voluntary, market-based merger transactions that benefit the communities served by credit unions; H.R. 5315, the Expanding Opportunity for MDIs Act, offered by Representative Joyce Beatty (D-OH) and H.R. 5322, the Ensuring Diversity in Community Banking Act of 2019; support keeping legislative reform of the housing finance system as a priority for the Senate Committee on Banking, Housing Committee on Banking, Housing & Urban Affairs and the House Committee on Financial Services; support NCUA developing its own, tailored guidance to clearly communicate examiner expectations in advance of CECLs 2023 compliance date; support relieving credit unions from having to comply with the CECL standard; support S. 2563, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act (ILLICIT CASH Act).

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. Currently, we are not supporting any specific legislation. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting H.R. 1661, a bill that would provide the NCUA flexibility to increase non-mortgage loan maturity limits for federal credit unions. We are also supporting H.R. 2305 and S.2834, a bill that would exempt business loans to veterans from the member business loan cap. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports efforts to curb illegal and harassing robocalls and is monitoring congressional efforts to do so. Credit unions must ensure any legislation to end illegal robocalls takes into consideration the unique interests of our members (each of which is a shareholder of the credit union) and that institutions maintain the ability to contact their members for legitimate reasons, such as when an account is overdrawn. MCUL supported assage of H.R. 3375 and ultimately passage of the Pallone Thune TRACED Act, S. 151. MCUL supports congressional efforts, including H.R. 2514, the COUNTER Act, and S.2563, the ILLICIT CASH Act, to reform bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules.

Monitor issues related to credit unions; HR 1595 the SAFE Banking Act; HR 2305 Member Business Lending and Veterans; S. 1564 and HR 3182, legislation related to stop and study of CECL.

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

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE

Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUA's low income designation regulations Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding its regulatory emergency liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's Advanced Notice of Proposed Rulemaking on Alternative Capital Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-laws Issues related to credit unions' incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership Structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to the Department of Defenese Poposal regarding Credit Extending to Service Members under MLA Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system Issues related to Federal Reserve Regulatory D Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to Fannie Mae Capital Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to economic growth Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims procedures Issues related to Web-Based Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to payments innovation Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to debt collection requirements Issues related to capital reform for credit unions Issues related to procurement reform for private voluntary organizations Issues related to Federal Credit Union Charter Modernization Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to NCUA's Fidelity Bonds Proposed Rule Issues related to the Consumer Financial Protection Bureau's No-Acton Letters and the BCFP Product Sandbox Issues related to the Consumer Financial Protection Bureau's proposal to extend the Payday Rule's compliance daedline Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 79(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to robocalls and the Stopping Bad Robocalls Act Issues related to financial technology (FINTECH) Issues related to the Consumer Financial Protection Bureau Payday Rule Issues related to appraisals Issues related to student lending Issues related to robocalls and the draft Declaratory Ruling (the ruling) and Third Further Notice of Proposed Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17-97 Issues related to FY 2020 Foreign Assistance Budget and Policy Priorities Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to permit Federal Credit Unions to establish their own fiscal year Issues related to striking a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhance flexibility of Federal Credit Unions to schedule board meetings Issues related to remove certain outdated responsibilities of Federal credit union board of directors Issues related to permit Federal credit unions to expel disruptive members for just cause without a vote Issues related to permit balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to the draft bill improving Laundering Laws and Increasing Comprehensive Information Issues related to tracking of Criminal Activity in Shell Holding (ILLICIT CASH Act) Issues related to PACE loans Issues related to Consumer Financial Protection Bureau's HMDA reporting thresholds Issues on NCUA Executive compensation rules Issues related to small business cannabis H.R. 388, the Financial Reporting Threshold Modernization Act H.R. 442, to amend the Consumer Financial Protection Act of 2010 to extend the supervisory authority of the Bureau of Consumer Financial Protection to include assessing compliance with the Military Lending Act H.R.1039, to streamline requirements for currency transaction reports and suspicious activity reports and for other purposes H.R. 1500, the Consumers First Act H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking act of 2019 H.R. 1661, to provide the National Credit Union Administration Board flexibility to increase Federal credit Union loan maturities, and for other purposes H.R. 1737, the American Housing and Economic Mobility Act of 2019 H.R. 1957, the Taxpayers First Act of 2019 H.R. 2093, to amend the Controlled Substances Act to provide for a new rule regarding the application of the Act of marijuana, and for other purposes H.R. 2157, Supplemental Appropriations Act of 2019 H.R. 2162, Housing Financial Literacy Act of 2019 H.R. 2290, Shutdown Guidance for Financial Institutions Act H.R. 2305, Veterans Members Business Loan Act H.R. 2500, National Defense Authorization Act for Fiscal Year 2020 H.R. 2513, Corporate Transparency Act of 2019 H.R. 2514, Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 H.R. 2740, the State and Foreign Operations and Related Programs Appropriations Act H.R. 2852, Homebuyer Assistance Act of 2019 H.R. 3111, National Flood Insurance Program Administration Reform Act of 2019 H.R. 3167, National Flood Insurance Program Re-authorization Act of 2019 H.R. 3182, CECL Consumer Impact and Study Bill of 2019 H.R. 3198, the Comprehensive Regulatory Review Act H.R. 3300, the Economic Mobility Act of 2019 H.R. 3301, the Taxpayer Certainty and Disaster Tax Relief Act of 2019 H.R. 3351, Financial Services and General Government Appropriations Act of 2020 H.R. 3375, the Stopping Bad Robocalls Act H.R. 4565, the Responsible Accounting Standards Act of 2019 H.Res 275, Supporting the goals and ideals of "Financial Literacy Month" H.Res 327, Encouraging greater public-private sector collaboration to promote financial literacy for students and young adults H.Res 328, Supporting the protection of elders through financial literacy H. Res 602, Support of resolution in support of cooperatives S. 151, TRACED Act S. 787, the American Housing and Economic Mobility Act of 2019 S. 1028, Strengthening the Tenth Amendment through Entrusting States (STATES Act) S. 1200, Secure and Fair Enforcement Banking Act of 2019 (SAFE Act) S. 1564, Continued Encouragement for Consumer Lending Act S. 2563, The Improving Laundering Laws and Increasing Comprehensive Information Sec. 2821 of S. 1790, the National Defense Authorization Act of FY 2020

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. Currently, we are not supporting any specific legislation. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting H.R. 1661, a bill that would provide the NCUA flexibility to increase non-mortgage loan maturity limits for federal credit unions. We are also supporting H.R. 2305, a bill that would exempt business loans to veterans from the member business loan cap. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports efforts to curb illegal and harassing robocalls and is monitoring congressional efforts to do so. Credit unions must ensure any legislation to end illegal robocalls takes into consideration the unique interests of our members (each of which is a shareholder of the credit union) and that institutions maintain the ability to contact their members for legitimate reasons, such as when an account is overdrawn. MCUL supported recent passage of H.R. 3375. MCUL supports congressional efforts, including H.R. 2514, the COUNTER Act, to reform bank secrecy act/anti-money laundering reforms.

Monitor issues related to credit unions; HR 1595 the SAFE Banking Act; HR 2305 Member Business Lending and Veterans; S. 1564 and HR 3182, legislation related to stop and study of CECL.

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

Government targets: HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE

Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to vacancies on the National Credit Union Administration (NCUA) Board Issues related to NCUA's low income designation regulations Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding its regulatory emergency liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's Advanced Notice of Proposed Rulemaking on Alternative Capital Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-laws Issues related to credit unions' incidental powers Issues related to credit unions ability to offer prepaid cards Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to the use of Eminent Domain to Seize Performing Mortgage Loans Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership Structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to the Department of Defenese Poposal regarding Credit Extending to Service Members under MLA Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system Issues related to Federal Reserve Regulatory D Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to Fannie Mae Capital Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to economic growth Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims procedures Issues related to Web-Based Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to payments innovation Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to debt collection requirements Issues related to capital reform for credit unions Issues related to procurement reform for private voluntary organizations Issues related to Federal Credit Union Charter Modernization Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to NCUA's Fidelity Bonds Proposed Rule Issues related to the Consumer Financial Protection Bureau's No-Acton Letters and the BCFP Product Sandbox Issues related to the Consumer Financial Protection Bureau's proposal to extend the Payday Rule's compliance daedline Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 79(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to robocalls and the Stopping Bad Robocalls Act Issues related to financial technology (FINTECH) Issues related to the Consumer Financial Protection Bureau Payday Rule Issues related to appraisals Issues related to student lending Issues related to robocalls and the draft Declaratory Ruling (the ruling) and Third Further Notice of Proposed Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17-97 Issues related to FY 2020 Foreign Assistance Budget and Policy Priorities Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to permit Federal Credit Unions to establish their own fiscal year Issues related to striking a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhance flexibility of Federal Credit Unions to schedule board meetings Issues related to remove certain outdated responsibilities of Federal credit union board of directors Issues related to permit Federal credit unions to expel disruptive members for just cause without a vote Issues related to permit balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to the draft bill improving Laundering Laws and Increasing Comprehensive Information Issues related to tracking of Criminal Activity in Shell Holding (ILLICIT CASH Act) Issues related to PACE loans Issues related to Consumer Financial Protection Bureau's HMDA reporting thresholds Issues on NCUA Executive compensation rules Issues related to small business cannabis H.R. 388, the Financial Reporting Threshold Modernization Act H.R. 442, to amend the Consumer Financial Protection Act of 2010 to extend the supervisory authority of the Bureau of Consumer Financial Protection to include assessing compliance with the Military Lending Act H.R.1039, to streamline requirements for currency transaction reports and suspicious activity reports and for other purposes H.R. 1500, the Consumers First Act H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking act of 2019 H.R. 1661, to provide the National Credit Union Administration Board flexibility to increase Federal credit Union loan maturities, and for other purposes H.R. 1737, the American Housing and Economic Mobility Act of 2019 H.R. 1957, the Taxpayers First Act of 2019 H.R. 2093, to amend the Controlled Substances Act to provide for a new rule regarding the application of the Act of marijuana, and for other purposes H.R. 2157, Supplemental Appropriations Act of 2019 H.R. 2162, Housing Financial Literacy Act of 2019 H.R. 2290, Shutdown Guidance for Financial Institutions Act H.R. 2305, Veterans Members Business Loan Act H.R. 2500, National Defense Authorization Act for Fiscal Year 2020 H.R. 2513, Corporate Transparency Act of 2019 H.R. 2514, Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 H.R. 2740, the State and Foreign Operations and Related Programs Appropriations Act H.R. 2852, Homebuyer Assistance Act of 2019 H.R. 3111, National Flood Insurance Program Administration Reform Act of 2019 H.R. 3167, National Flood Insurance Program Re-authorization Act of 2019 H.R. 3182, CECL Consumer Impact and Study Bill of 2019 H.R. 3198, the Comprehensive Regulatory Review Act H.R. 3300, the Economic Mobility Act of 2019 H.R. 3301, the Taxpayer Certainty and Disaster Tax Relief Act of 2019 H.R. 3351, Financial Services and General Government Appropriations Act of 2020 H.Res 275, Supporting the goals and ideals of "Financial Literacy Month" H.Res 327, Encouraging greater public-private sector collaboration to promote financial literacy for students and young adults H.Res 328, Supporting the protection of elders through financial literacy S. 151, TRACED Act S. 787, the American Housing and Economic Mobility Act of 2019 S. 1028, Strengthening the Tenth Amendment through Entrusting States (STATES Act) S. 1200, Secure and Fair Enforcement Banking Act of 2019 (SAFE Act) S. 1564, Continued Encouragement for Consumer Lending Act

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regulations.

Protect the credit union tax exemption; S. 151, the TRACED Act - modernize the Telephone Consumer Protection Act to combat illegal robocalls, while also protecting credit unions ability to freely make legitimate communications with their members - reforms should clarify the intent requirement for a TCPA violation to prevent good-faith communications by legitimate callers from being swept into the provisions of the bill - reforms should require voice service providers to consult with call originators as they implement the STIR/SHAKEN call authentication framework - require FCC to promulgate rules for the safe harbor available to voice service providers that establish a process to give notice to legitimate callers prior to their calls being blocked and, subsequently, correct any unintended blocking; establish a broad definition of automatic telephone dialing system or autodialer under the TCPA that only includes equipment that uses a random or sequential number generator to store or produce numbers and dial those numbers without human intervention - conduct reforms to help credit unions contact their members with important account information - permit callers to establish a reasonable opt-out method for revoking their consent to be contacted - remove language that goes beyond the scope of addressing the illegal actors who make abusive automated calls and in essence harms businesses and consumers by impeding legitimate calls that consumers actually need or want, HR 946 - support creating reassigned numbers database using existing numbering databases, (CG Docket No. 17-59) - provide a comprehensive safe harbor from TCPA liability for callers who use the database regularly but make a call to a reassigned number due to database errors - urge FCC to seek public comment on draft Declaratory Ruling, Advanced Methods to Target and Eliminate Unlawful Robocalls, (CG Docket No. 17-59, WC Docket No. 17-97); financial literacy - Support HR 275 and the goals and ideals of financial literacy month; Department of Defense - oppose an amendment to provide banks with rent-free leases on military bases under the John S. McCain National Defense Authorization Act - exempt loans to veteran-owned businesses from the credit union member business lending cap, HR 2305; Postal Banking - the United States Postal Service should not provide banking services which will be beyond its core competencies, will raise a number of serious regulatory and consumer protection questions, and will present significant competitive issues for private sector entities; Banking regulation and supervision - support the use of formal rulemaking versus informal guidance - agencies should clarify how guidance is treated, as inconsistencies can lead to compliance confusion; ensure that examiners treat regulations and guidance consistently - improve the examination process for financial institutions by passing the Financial Institutions Examination Fairness and Reform Act; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time; Supervisory Committee Audits and Verifications (RIN 3133-AE91) - NCUA should remove the report on examination of internal controls over call reporting alternative audit option - remove the 120-day language in engagement letters to outside, compensated auditors regarding the required written report - support Appendix A to Part 715 alternative audit option - do not include other areas of review in Appendix A - retain Supervisory Committee Guide; Request for Information Regarding Consumer Credit Card Market (Docket No. CFPB-2019-0002) - encourage effective credit card disclosure use, including flexibility to provide required disclosures via mobile banking platforms - support providing fair and transparent credit products and services - support changes to regulations carrying out the Credit Card Accountability Responsibility and Disclosure Act of 2009 as the consumer credit card market evolves - support reporting on the credit card market to ensure practices align with CARD Act - support effective, simple and user friendly credit card disclosures - support allocating resources from Office of Cost-Benefit Analysis toward innovation; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; oppose the Green Amendment (#29) to H.R. 1500 which would reinstate the CFPBs rule on arbitration agreements which Congress voted to disapprove in 2017; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; Property Assessed Clean Energy Loans - support imposing ability-to-repay underwriting requirements for PACE loans - support imposing civil liability on violators of the ATR requirements under section 130 of the Truth In Lending Act - support adopting Truth In Lending - RESPA disclosures for PACE loans; Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) - support rescission of mandatory ability-to-repay (ATR) underwriting requirements - support for delay of compliance date, RIN3170-AA95 - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan (PAL) programs for credit unions - recommend expanding the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees, (RIN 1235-AA20) - supports the Department of Labors (DOL) proposed adjustments to overtime exemption rules under the Fair Labor Standards Act (FLSA) - urge DOL to consider additional options and guidance to reduce burdens for smaller credit unions - support regulatory flexibility for certain bonuses, incentive payments, and commissions - urge DOL to commit to a future formal assessment of the four-year review of the salary levels, in lieu of automatic reviews or increases; Ginnie Mae, Request for Input on Pooling Eligibility Changes - recommend that Ginnie Mae first allow the VA to complete its own evaluation of VA cash-out refinances, then closely evaluate other changes before removing cash out refinance loans made through the U.S. Department of Veterans Affairs from the Ginnie Mae II Multi-Issuer Program (GIIMIP) - Before excluding VA cash-out refinances, Ginnie Mae should complete further review to determine whether there is more than a correlation between the propensity to rapidly prepay VA loans and the different LTV requirements in the VA program compared to those of the Federal Housing Administration (FHA), Fannie Mae, and Freddie Mac - support a de minimis standard restricting inclusion of cash-out refinances for VA loans in the GII MIP; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws (RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; supports a strong independent NCUA; Consideration of the Financial Services and General Government Appropriations Bill - supports the language in the draft bill to keep funding for the NCUA's Community Development Revolving Loan Fund (CDRLF) at a level of $2 million and to fund the Community Development Financial Institutions (CDFI) Fund at a level of $300 million; NCUA should maintain the current regulation requiring annual review by a federal credit union (FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; A Review of the Appraisal Industry - a formal appraisal should not be required for commercial real estate appraisals; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; support amendment to the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act (COUNTER Act), HR 2514; support amendment to the Corporate Transparency Act of 2019, HR 2513; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support reform bill addressing beneficial ownership requirements; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans (RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases; support the SBAs modernizing the requirements for Certified Development Companies who provide vital 504 program loans; support Title IV of H.R. 3300, the Economic Mobility Act of 2019, which would repeal the 21 percent excise tax imposed on certain not-for-profits for providing certain fringe benefits under the Tax Cuts and Jobs Act (TCJA).; support 2019 NCUA Regulatory Review of 1/3 of NCUA regualtions;

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. Currently, we are not supporting any specific legislation. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting H.R. 1661, a bill that would provide the NCUA flexibility to increase non-mortgage loan maturity limits for federal credit unions. We are also supporting H.R. 2305, a bill that would exempt business loans to veterans from the member business loan cap. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports efforts to curb illegal and harassing robocalls and is monitoring congressional efforts to do so. Credit unions must ensure any legislation to end illegal robocalls takes into consideration the unique interests of our members (each of which is a shareholder of the credit union) and that institutions maintain the ability to contact their members for legitimate reasons, such as when an account is overdrawn. We are currently monitoring H.R. 3375.

Protect the credit union tax exemption; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; streamline regulations to allow credit unions to better serve members and cut compliance costs; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time - CRT transactions should be expanded and CSP and single security retained - FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; reforms to the TCPA Act to ensure that credit unions are able to contact their members, S.151; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws(RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; FidelityBonds(RIN3133-AE87) - NCUA should re-evaluate the additional oversight requirements to achieve an operationally efficient and cost-effective solution. NCUA should maintain the current regulation requiring annual review by a federal credit union(FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal.. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; move to confirm NCUA nominees Hood and Harper as soon as possible; move to confirm FHFA Director nominee, Calabria as soon as possible; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; Technical issues with HMDA Platform - CFPB and NCUA should interpret good faith compliance under Regulation C to excuse highly disruptive technical problems that are attributable to the design and programming of the HMDA Platform and clarify how they intend to evaluate errors caused by technical problems on the HMDA Platform that are not the fault of credit unions; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans(RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases.

Protect the credit union tax exemption; data security - create a national standard for data security for any entity that collects sensitive personal financial information similar to the Gramm-Leach-Bliley Act for financial institutions while not adding burdens to entities already regulated under this Act - payment of costs associated with a breach by breached entity - require data security policy disclosure - notify account servicer in case of a breach - require disclosure of breached entity - enforce prohibitions on data retention; Agency transparency; government accountability; create a 5 member commission at the CFPB; push for additional NCUSIF distributions - obtain full refunds of stabilization assessments; exempt credit unions from CFPB authority; streamline regulations to allow credit unions to better serve members and cut compliance costs; level playing field through smart regulation and consumer protections where financial institutions and fintech companies compete; NCUA should follow other financial regulators and reduce their budget; oppose efforts to bring the NCUA under congressional appropriations; housing finance reform - ensure that credit unions maintain unfettered access to the secondary mortgage market and fair pricing based on loan quality - explicit government guarantee - GSEs should be self-funded - FHFA should have board of advisors - GSEs should be allowed to rebuild capital buffers - GSEs should not be privatized at this time - CRT transactions should be expanded and CSP and single security retained - FHFA or its successor should continue strong oversight of GSEs and any new system; expand field of membership flexibility to help credit unions grow; capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; reforms to the TCPA Act to ensure that credit unions are able to contact their members, S.151; modernize the NCUA examination process; oppose NCUA third party vendor authority; support member business lending reforms and relief from maturity limits, HR1661; protect credit unions from frivolous ADA website litigation; create clear guidance for unfair, deceptive, or abusive acts and practices (UDAAP); repeal the Durbin Amendment and remove interchange price fixing; oppose Community Reinvestment Act coverage for credit unions; expand exemption from CFPBs payday lending rule for payday alternative loans (PAL); advocate for variable interest rates; Federal Credit Union Bylaws(RIN 3133-AE86) - support updates to the bylaw amendment process, member meeting and election processes, and amend the bylaws to expedite the process for expelling a member who is abusive, or conducting an illegal act; FidelityBonds(RIN3133-AE87) - NCUA should re-evaluate the additional oversight requirements to achieve an operationally efficient and cost-effective solution. NCUA should maintain the current regulation requiring annual review by a federal credit union(FCU) board of directors (Board), and not require supervisory committee review. NCUA should conduct an impact study on the proposed bond contract requirement to ensure that it does not adversely affect FCUs. NCUA should provide clarification on the process for reapplying for bond form approval upon the expiration of the ten-year term; end the government shutdown; ensure that credit unions continue to be able to participate in the Federal Home Loan Banks (FHLB) AMA programs, particularly in the new small member participation housing goal. Supports the overall simplification of the housing goals regulation, and additional flexibility granted to the FHLBs and the phase-in period that the FHFA has provided in the proposal.. Ensure that the changes do not reduce the FHLBs ability to purchase mortgages. FHFA should set initial housing goal targets so that all FHLBs are in compliance from the start, and then incrementally increase the targets as appropriate. FHFA should provide more data on the overall mortgage market to justify the thresholds in the proposal; support innovative and effective retirement savings initiatives; support financial literacy initiatives; CFPBs TRID Frequently Asked Questions - provide more clarity and assistance to credit unions; supports the use of formal rulemaking versus informal guidance; Availability of Funds and Collection of Checks (RIN3170-AA31) - Agencies should consider ways to mitigate funds availability disclosure costs that will disproportionately impact small credit unions and support clarification of existing regulatory language and the correction of errors in Regulation DD; Policy on No-Action Letters and the BCFP Product Sandbox (DocketNo.CFPB-2018-0042) - support CFPB efforts to promote innovation by advancing policies that would accommodate new financial products or services and help identify burdensome rules and regulations; Cannabis banking/ H.R. 1595 - Congress should examine legislative steps that could be taken to provide greater clarity and legal certainty at the federal level for institutions that choose to provide financial services to state-authorized MRBs and ancillary businesses including providing safe harbor; move to confirm NCUA nominees Hood and Harper as soon as possible; move to confirm FHFA Director nominee, Calabria as soon as possible; provide relief from CECL implementation burdens - credit unions should not be subject to CECL standards; Loan Guaranty: Revisions to VA-Guaranteed or Insured Cash-Out Home Refinance Loans (RIN 2900-AQ42) - support regulations aimed at curbing lending that could jeopardize veterans financial security while not adding burdens or new requirements on credit unions - seek clarification of the timing of the net tangible benefit tests loan comparison disclosure, and guidance on the required standardized form that must be used. The VA should delay the rules compliance date by at least 30 days to ensure credit unions are provided with a reasonable timeframe to adopt the rules changes into their lending practices; HR 2305 exclude business loans made to veterans from the statutory MBL cap; support a strong, robust, and secure credit bureau system; support alternative models that more accurately capture credit worthy borrowers; support full funding for Community Development Financial Institutions Program; allow all types of credit unions to serve underserved areas; Technical issues with HMDA Platform - CFPB and NCUA should interpret good faith compliance under Regulation C to excuse highly disruptive technical problems that are attributable to the design and programming of the HMDA Platform and clarify how they intend to evaluate errors caused by technical problems on the HMDA Platform that are not the fault of credit unions; support long-term solutions to ensure efficient, self-sustaining and affordable US postal system but USPS should not be allowed to offer financial services; support reauthorization of National Flood Insurance Program and ensure there are no lapses; BSA/AML system is in need of improvements and reform - more coordination between law enforcement priorities and credit union examiners is needed - need updated database for SAR and Currency Transaction Report(CTR)filings to streamline the narrative reporting that law enforcement often requests from financial institutions - increase information sharing and allow the sharing of compliance resources; end the misuse of anonymous shell corporations and pass meaningful anti-money laundering reform legislation - modernize the anti-money laundering and counter the financing of terrorism(AML/CFT) regime in the United States and help prevent the use of corporate structures to hide the identities of their beneficial owners from law enforcement; support for DelayofComplianceDate-Payday,VehicleTitle,andCertainHigh-CostInstallmentLoans(RIN3170-AA95) - because it would allow the Bureau ample time to review compliance obstacles not originally anticipated in the final Payday Rule, including additional Payday Alternative Loan(PAL) programs for credit unions - will allow the Bureau time to expand the Payday Rules safe harbor exemption to encompass all future iterations of PALs finalized by the NCUA - Revised Rule must exclude all future PALs programs; Validation and Approval of Credit ScoreModels (RIN 2590-AA98) - FHFA should re-propose this rule as soon as possible to provide a more inclusive, fair process that has the potential to enhance the operations of the GSEs and encourage the providers of credit score models to innovate, cut costs, and help more creditworthy consumers access the financing they need; SBA loan programs including the importance of 7(a) loans - avoid potential fee increases.

Monitor issues related to credit unions; HR 1595 the SAFE Banking Act; HR 2305 Member Business Lending and Veterans

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

Government targets: HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE