Improving FHA Support for Small Dollar Mortgages Act of 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.

Client expense: $680,000 · 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

H.R. 4351: YES IN MY BACKYARD ACT; PROVISIONS RELATED TO HOUSING SUPPLY AND ACCESS H.R. 5931: IMPROVING FHA SUPPORT FOR SMALL DOLLAR MORTGAGES ACT OF 2020; PROVISIONS RELATED TO HOUSING SUPPLY AND ACCESS S. 1919: YES IN MY BACKYARD ACT; PROVISIONS RELATED TO HOUSING SUPPLY AND ACCESS

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

Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Labor, Dept of (DOL), SENATE, Small Business Administration (SBA), Treasury, Dept of

Rural Housing HR3620 - Strategy and Investment in Rural Housing Preservation Act of 2019 Communications with the House Financial Services Committee in support of the Rural Housing Service. Communications with the House and Senate in support of rural housing programs, 502 loans, and rural broadband. Violence Against Women Act HR1585 - Violence Against Women Reauthorization Act of 2019 Veterans Housing Issues HR299 - Blue Water Navy Vietnam Veterans Act of 2019 HR5923 - Fair Access to Co-ops for Veterans Act Communications with the House of Representatives and the Senate opposing the use of VA Home Loan Guarantee Fees to pay for other VA programs. Fair Housing Protections HR5 - Equality Act HR149 - Housing Fairness Act of 2019 HR1865 - Further Consolidated Appropriations Act, 2020 S1246 - Fair and Equal Housing Act of 2019 Communications with the House and Senate regarding HUD FY 2021 appropriations, including support for Fair Housing Initiative Programs (FHIP) and the HUD Office of Fair Housing and Equal Opportunity. FHA Programs HR123 - FHA Additional Credit Pilot Program Reauthorization Act HR1865 - Further Consolidated Appropriations Act, 2020 HR2162 - Housing Financial Literacy Act of 2019 HR2852 - Homebuyer Assistance Act of 2019 HR3141 - FHA Loan Affordability Act of 2019 HR5931 - Improving FHA Support for Small Dollar Mortgages Act of 2020 S1722 - FHA Appraiser Eligibility Expansion Act HUD-Assisted Housing HR1690 - Safe Housing for Families Act of 2019 HR __ - DISCUSSION DRAFT - Housing Infrastructure Act Transportation and Housing HR4307 - Build More Housing Near Transit Act HR4351 - Yes In My Backyard Act S1919 - Yes In My Backyard Act Affordable Housing HR4300 - Fostering Stable Housing Opportunities Act of 2019 S1804 - HUD Manufactured Housing Modernization Act of 2019 S2160 - CO ALERTS Act of 2019 COVID-19 Relief HR748 - CARES Act HR6201 - Families First Coronavirus Response Act Communications with Congress requesting COVID-19 relief for multifamily property owners and tenants. HUD Leadership Communications with the Senate in support of Brian Montgomery's nomination to be Deputy Secretary of HUD, and in support of David Woll's nomination to be Assistant Secretary of HUD, Office of Community Planning and Development. Discussions with the Department of Housing and Urban Development (HUD) regarding, the FHA, barriers to affordable housing, fair housing, Section 8 Multifamily housing, the FHA Single Family loan program, nominations, and the FHA and private flood insurance. Discussions with the Department of Veterans Affairs (VA) regarding the VA home loan guarantee program. Discussions with the U.S. Department of Agriculture (USDA) regarding rural housing loans and multifamily housing. Discussions with the Federal Housing Finance Agency (FHFA) regarding appraisals and real property.

HR 149, The Housing Fairness Act of 2019, To authorize funds to prevent housing discrimination through the use of nationwide testing, to increase funds for the Fair Housing Initiatives Program, and for other purposes H. R. 5934 - To amend the Fair Debt Collection Practices Act to safeguard access to information for consumers and to stop abusive debt litigation, and for other purposes. HR 5931 - Improving FHA Support for Small Dollar Mortgages Act of 2020 - This bill directs the Department of Housing and Urban Development (HUD) to report on barriers to making Federal Housing Administration (FHA) single-family mortgage insurance available for mortgages under $70,000. Specifically, HUD must report H.R.6379 - Take Responsibility for Workers and Families Act S.3566 - Stop Overdraft Profiteering during COVID-19 Emergency Act of 2020 - to prohibit depository institutions from assessing overdraft and non-sufficient fund fees during the novel coronavirus crisis and other disasters, and for other purposes. S.3565 - Small Business and Consumer Debt Collection Emergency Relief Act of 2020 - To amend the Fair Debt Collection Practices Act to provide additional protections for consumers and small business owners from debt collection during a major disaster or emergency. S.3560 - Small Business and Consumer Emergency Credit Act - To amend the Truth in Lending Act to extend the consumer credit protections provided to members of the Armed Forces and their dependents under title 10, United States Code, to all consumers. S 3548 - To provide emergency assistance and health care response for individuals, families, and businesses affected by the 2020 coronavirus pandemic. S.3509 - A bill to provide borrowers the right to request forbearance on mortgage loan payments due to a declared disaster, and for other purposes. H.R.6321 - To provide financial protections and assistance for America's consumers, States, businesses, and vulnerable populations during the COVID-19 emergency and to recover from the emergency. H.R.6363 - Student Debt Emergency Relief Act HR 3182 - To require the Securities and Exchange Commission and certain Federal agencies to carry out a study relating to accounting standards, and for other purposes. HR 748/Public Law No: 116-136 (03/27/2020) Coronavirus Aid, Relief, and Economic Security Act or the CARES Act - This bill responds to the COVID-19 (i.e., coronavirus disease 2019) outbreak and its impact on the economy, public health, state and local governments, individuals, and businesses Transportation, Housing and Urban Development, and Related Agencies Appropriations Act for FY2021 H.R. 3674 the College Affordability Act, a bill to lower the costs of college for students and improve the quality of education H.J.Res.76, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Education relating to "Borrower Defense Institutional Accountability" HR 5050 / s 2833, To amend the Truth in Lending Act to extend the consumer credit protections provided to members of the Armed Forces and their dependents under title 10, United States Code, to all consumers H.R. XXX, amends the Fair Credit Reporting Act to delay the inclusion in consumer credit reports and to establish requirements for debt collectors with respect to medical debt information of veterans due to inappropriate or delayed billing payments or reimbursements from the Department of Veterans Affairs, and for other purposes. H.R. 2750, Justice for Servicemembers Act, To amend title 9 of the United States Code to prohibit predispute arbitration agreements that force arbitration of certain disputes arising from claims of service members and veterans. H.R. XXXX, Protecting Consumers Access to Credit Act (This bill amends the Revised Statutes, the Home Owners' Loan Act, the Federal Credit Union Act, and the Federal Deposit Insurance Act to state that bank loans that are valid when made as to their maximum rate of interest in accordance with federal law shall remain valid with respect to that rate regardless of whether a bank has subsequently sold or assigned the loan to a third party.) H.R. XXXX, the Protecting Consumers from Unreasonable Credit Rates Act (This bill amends the Truth in Lending Act to prohibit a creditor from extending credit to a consumer under an open end consumer credit plan (credit card) for which the fee and interest rate exceeds 36%.) HR 5050 / s 2833, To amend the Truth in Lending Act to extend the consumer credit protections provided to members of the Armed Forces and their dependents under title 10, United States Code, to all consumers H. R. 166, To establish an Office of Fair Lending Testing to test for compliance with the Equal Credit Opportunity Act, to strengthen the Equal Credit Opportunity Act and to provide for criminal penalties for violating such Act, and for other purposes H.R. 5330, Consumer Protections for Medical Debt Collections Act, a bill which would provide relief to those struggling with health problems and medical debt by preventing collection of medical debt for two years from the date of the medical billing. H.R. 5021, The Ending Debt Collection Harassment Act of 2019, a bill to amend the Fair Debt Collection Practices Act (FDCPA) to prohibit a debt collector from contacting a consumer by email or text message without a consumers consent to be contacted electronically, and prohibits the Consumer Financial Protection Bureau (CFPB) from issuing any rules implementing the FDCPA that allow a debt collector to send unlimited email and text messages to a consumer. H.R. 5013, The Small Business Fair Debt Collection Protection Act, a bill that expands the FDCPAs protections to cover small business loans H.R. 5003, The Fair Debt Collection Practices for Servicemembers Act, a bill by that amends the FDCPA to prohibit debt collectors from threatening servicemembers or their families to have a servicemembers rank reduced, have their security clearance revoked, have them prosecuted under the Uniform Code of Military Justice, or communicating with a servicemembers chain of command to locate a servicemember. H.R. 5001, The Non-Judicial Foreclosure Debt Collection Clarification Act, a bill that reverses the recent Supreme Court decision in Obduskey versus McCarthy and Holthus LLP by amending the FDCPA to clarify that entities in non-judicial foreclosure proceedings are covered by the law H.R. 4403, The Stop Debt Collection Abuse Act, a bill that extends the FDCPAs protections as it relates to debt owed to a federal agency, limits the fees debt collectors can charge, and clarifies that debt buyers are subject to FDCPA H.R. 3948, The Debt Collection Practices Harmonization Act, a bill that clarifies that private debt collectors who pursue debts such as municipal utility bills, tolls, traffic tickets, and court debts are subject to the FDCPA H.R. 3490,The Small Business Lending Fairness Act, a bill that would amend the Truth in Lending Act (TILA) to restrict the use of predatory small business loan contract clauses called confessions of judgment.

H.R. 5050Veterans and Consumers Fair Credit Act Interchange Fees H.R.3621Comprehensive CREDIT Act H.R.5931 Improving FHA Support for Small Dollar Mortgages Act H.R.4351 Yes In My Backyard Act

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

Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Federal Communications Commission (FCC), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Office of Management & Budget (OMB), Postal Regulatory Commission, SENATE, Surface Transportation Board (STB), Treasury, Dept of, 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; 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.