Financial Inclusion in Banking Act of 2019

GSE Reform Discussions with the House and Senate regarding GSE Reform. Anti-Money Laundering/Beneficial Ownership HR2513 - Corporate Transparency Act of 2019 HR2514 - Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 HR __ - (Discussion Draft) To make reforms to the Federal Bank Secrecy Act and anti-money laundering laws, and for other purposes S2563 - ILLICIT Cash Act (Discussion Draft) Discussions with the House Financial Services Committee on Anti-Money Laundering issues. Discussions with the House Financial Services Committee on the Bank Secrecy Act. Discussions with the Senate Banking Committee on Anti-Money Laundering issues. Credit Reporting HR3618 - Free Credit Scores for Consumers Act of 2019 HR3621 - Student Borrower Credit Improvement Act HR3622 - Restoring Unfairly Impaired Credit and Protecting Consumers Act HR4067 - Financial Inclusion in Banking Act of 2019 HR4328 - Protecting Innocent Consumers Affected by a Shutdown Act HR5332 - Protecting Your Credit Score Act of 2019 HR__ - Improving Credit Reporting for All Consumers Act of 2019 HR__ - Clarity in Credit Score Formation Act of 2019 HR__ - Accurate Access to Credit Information Act of 2019 Discussions with the Senate. Financial Education HR4067 - Financial Inclusion in Banking Act of 2019 Student Loan Debt HR4545 - Private Loan Disability Discharge Act of 2019 HR5287 - Fair Student Loan Debt Collection Practices Act HR5294 - Student Borrower Protections Act of 2019 Communications with the House and Senate. Credit Scoring Discussions with the House and Senate. Qualified Mortgage (QM) Rule HR2445 - Self-Employed Mortgage Access Act of 2019 Communications with the Consumer Financial Protection Board (CFPB) regarding TRID. Communications with the Federal Housing Finance Agency (FHFA) regarding GSE reform and the capital rule.

Client expense: $11,080,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Bureau of the Census, Consumer Financial Protection Bureau (CFPB), Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office

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).

HR 123-FHA Additional Credit Pilot Program Act, HR 132-North America Development Bank Improvement Act, HR 4029-Tribal access to Homeless Assistance, HR 4067-Financial interest in banking act, HR 4242-Greater accountability in Pay Act, HR 4300-Fostering stable Housing opportunities act, HR 4302-Homeless Assistance Act, HR 4328-Protecting individual consumers affected by shutdown, HR 4329-ESG Disclosure Simplification Act, HR 4344-Investor Protections and Capital Markets Fairness Act, HR 4335-8-k Trading Gap, HR 4320-Corporate Management Accountability Act, HR 3885-Wall Street Banker Accountability for Misconduct Act, Whistle-blower legislation, Executive Compensation reforms, HR 2513-Corporate Transparency Act, HR 2514-Coordinating Oversight upgrading and innovative technology and examiner reform, Glass Steagall legislation, Facebook Libra, potential short selling legislation, DOL Electronic disclosure, HR 2534-Insider trading protections act, various debt collection bills, Senate Banking committee on shareholder resolutions, House financial services bill on data, SEC meeting with Commissioner Jackson, ESG issues,

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

Government targets: Consumer Product Safety Commission (CPSC), Federal Energy Regulatory Commission (FERC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC)

GSE Reform Discussions with the House and Senate regarding GSE Reform. Anti-Money Laundering/Beneficial Ownership HR2513 - Corporate Transparency Act of 2019 HR __ - (Discussion Draft) To make reforms to the Federal Bank Secrecy Act and anti-money laundering laws, and for other purposes S2563 - ILLICIT Cash Act (Discussion Draft) Discussions with the House Financial Services Committee on Anti-Money Laundering issues. Discussions with the House Financial Services Committee on the Bank Secrecy Act. Discussions with the Senate Banking Committee on Anti-Money Laundering issues. Credit Reporting HR3618 - Free Credit Scores for Consumers Act of 2019 HR3621 - Student Borrower Credit Improvement Act HR3622 - Restoring Unfairly Impaired Credit and Protecting Consumers Act HR4328 - Protecting Innocent Consumers Affected by a Shutdown Act HR__ - Improving Credit Reporting for All Consumers Act of 2019 HR__ - Clarity in Credit Score Formation Act of 2019 HR__ - Accurate Access to Credit Information Act of 2019 Discussions with the Senate. Financial Education HR4067 - Financial Inclusion in Banking Act of 2019 Student Loan Debt Communications with the House and Senate. Credit Scoring Discussions with the House and Senate. Communications with the Consumer Financial Protection Board (CFPB) regarding the QM Patch. Communications with the Federal Housing Finance Agency (FHFA) regarding GSE reform, credit scores. Communications with the White House regarding GSE reform, financing reform. Communications with the Financial Crimes Enforcment Network (FinCEN) regarding anti-money laundering. Communications with the Department of the Treasury regarding GSE reform.

Client expense: $8,240,000 · Firm income: Not reported

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); 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; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.

Protect the credit union tax exemption; Setting the record straight on banker attacks; Examining Regulatory Frameworks for Digital Currencies, Digital Assets and Blockchain; Enrollment Period for Electronic Consent Based Social Security Number Verification Service (Docket No. SSA 2019-0021); Social Security Administrations (SSA) implementation of section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to create a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service; Support proposal to increase deposits from public units and nonmembers (RIN 3133-AF00); capital and risk-based capital reforms to preserve safety and soundness of the credit union industry; Delay of effective date of the risk-based capital rules, RIN 3133-AF01; Third Further Notice of Proposed Rulemaking, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17-97, 84 Fed. Reg. 29,478 (June 24, 2019); 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; Support H.R. 3375, the Stopping Bad Robocalls Act and the requirement for the FCC to prescribe regulations to clarify the definition of an ATDS or autodialer; Support examining the Use of Alternative Data in Underwriting and Credit Scoring to Expand Access to Credit in a responsible way and on a level playing field with credit unions; Support examining the proposed merger of Suntrust and BB&T; Support Congress examining legislative steps to take to provide greater clarity and legal certainty at the federal level for credit unions that choose to provide financial services to state-authorized marijuana related businesses; Challenges for cannabis and Banking: outside perspectives; Support examining and looking at regulatory concerns related to Facebooks proposed cryptocurrency, Libra and its impact on consumers, privacy, investors, and the American financial system; Support Potential Modifications to the Federal Reserve Banks' National Settlement Service and Fedwire Funds Service / Docket No. OP-1664; Support CFPB Review Pursuant to the Regulatory Flexibility Act and CFPBs discretion to review rules not subject to the 610 reviews / Docket No. CFPB-2019-0024; Support for H.R. 3182, the CECL Consumer Impact and Study Bill of 2019; Support H.R. 281, the Ensuring Diverse Leadership Act of 2019: support the amendment in the nature of a substitute to H.R. 2852, the Homebuyer Assistance Act of 2019; Support H.R. 3618, the Free Credit Scores for Consumers Act of 2019; Do not support H.R. 3614, the Restricting Use of Credit Checks for Employment Decisions Act; Support in part H.R. 3642, the Improving Credit Reporting for All Consumers Act; Do not support H.R. 3629, the Clarity in Credit Score Formation Act of 2019; Support for H.R. 2162, the Housing Financial Literacy Act of 2019; Support Renewal without Change of the Requirement for Information Sharing between Government Agencies and Financial Institutions (Docket No.: FINCEN-2018-0017; OMB Control No.: 1506-0049); Support Overdraft Rule Review Pursuant to the Regulatory Flexibility Act Docket No. CFPB-2019-0023; Support Modernization of the Safeguards Rule, 16 CFR part 314, Project No. 145407; Support the credit union difference; Support Housing Finance Reforms, such as guaranteed access for community financial institutions, fair pricing based on quality and not quantity of loans sold, and a level playing field allowing institutions of all sizes to compete; Support extending implementation period for CECL / Topic 326; support using extended implementation period to educated credit unions about the practical application of CECL; Support addressing CECLs negative impact on credit unions; Support revising Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z) RIN 3170-AA98); Support increased funding for NCUAs Community Development Revolving Loan Fund, the Community Development Financial Institutions Fund, and the Small Business Administrations 7(a) and 504 loan programs; Support limiting the scope of the Debt Collection Practices regulation to the scope of the FDCPA (Regulation F) (RIN 3170-AA41); Support H.R. 123, Alternative Data for Additional Credit FHA Pilot Program Reauthorization Act; Support H.R. 4067, Financial Inclusion in Banking Act of 2019; Support in part, H.R. 4328, Protecting Innocent Consumers Affected by a Shutdown Act; Oppose section 2821 of the National Defense Authorization Act (NDAA) for Fiscal Year 2020 (S. 1790); Support Facilitating Faster Payments in the U.S.; support the Federal Reserve developing real-time gross settlement capability, aka the FedNow Service; Support an update to the Exceptions to Employment Restrictions Under Section 205(d) of the Federal Credit Union Act (RIN: 3133-AF02); Support FHFA directive to prohibit GSEs from providing volume-based discounts; oppose full recapitalization and removal of the GSEs from conservatorship without first coordinating with Congress to achieve fair pricing and equal access to the secondary mortgage market.