Eliminating CECL Accounting Standard Act

H.R. 133 Consolidated Appropriations Act H.R. 748 CARES Act H.R. 925 Updated HEROES Act H.R. 3182 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard H.R. 6249 Coronavirus Accounting Relief Act H.R. 6385 To provide temporary relief from troubled debt restructuring disclosures, to delay the implementation of certain accounting standards for depository institutions substantially affected by COVID-19, and for other purposes. H.R. 7914 Eliminating CECL Accounting Standards Act S. 1564 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard S. 3502 Community Bank Regulatory Relief Act, Accounting Provisions S. 3548 CARES Act, Accounting Provisions Accounting for Paycheck Protection Program Loan Processing Fees Current Expected Credit Losses (CECL) Standard

Client expense: $960,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, White House Office

Public Law 111-203, H.R. 4173 - Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Implementation and Regulatory reform. Captive Reinsurance Transactions, Insurance Capital Standards and Global Capital Standards. Roles of federal and state agencies at the International Association of Insurance Supervisors and the Financial Stability Board. Implementation of S. 2270 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III Implementation of S. 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act. Issue: Implementation and regulatory reform of the financial services industry. Implementation of H.R. 748 - the Coronavirus Aid, Relief, and Economic Security (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. Issue: CECL, TDR, Remote Online Notarization, SBA loans. H.R. 1815 - SEC Disclosure Effectiveness Test Act. Issue: SEC investor testing. H.R. 1862/S. 1586 - Federal Insurance Office Abolishment Act of 2019. Issue: FIO reform. H.R. 3561/S. 603 - Financial Stability Oversight Council Improvement Act of 2019. Issue: FSOC reform. H.R. 1595/S. 1200 - Secure and Fair Enforcement Banking Act. Issue: Insurance companies working with legitimate marijuana businesses. H.R. 3351- Financial Services and General Government Appropriations Act, 2020. Issue: Making appropriations for financial services and general government for the fiscal year ending September 30, 2020. H.R. 3614 - Restricting Use of Credit Checks for Employment Decisions Act. Issue: ban the use of credit information for most employment decisions. H.R. 2474/S.664 - Protecting Workers Freedom to Organize Act. To amend the National Labor Relations Act, the Labor Management Relations Act, 1947, and the Labor-Management Reporting and Disclosure Act of 1959. Issue: independent contractor status. H.R. 4592 - International Insurance Standards Act of 2019. To preserve the state-based system of insurance regulation and provide greater oversight of and transparency on international insurance standards setting process. Issue: insurance capital standards. H.R. 6994/S. 3795 - Registration for Index-Linked Annuities Act. To direct the SEC to revise any rules necessary to enable issuers of index-linked annuities to use the securities offering forms that are available to other issuers of securities. Issue: index-linked annuities. S. 3533/H.R. 6364 - Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2020. To authorize and establish minimum standards for electronic and remote notarizations that occur in or affect interstate commerce, to require any Federal court located in a State to recognize notarizations performed by a notary public commissioned by another State when the notarization occurs in or affects interstate commerce, and to require any State to recognize notarizations performed by a notary public commissioned by another State when the notarization occurs in or affects interstate commerce or when the notarization was performed under or relates to a public act, record, or judicial proceeding of the State in which the notary public was commissioned. Issue: remote online notarization. S. 4159 - Electronic Signatures in Global and National Commerce Act. To amend the Electronic Signatures in Global and National Commerce Act to accommodate emerging technologies. Issue: electronic signatures H.R. 7809 - Helping Open Properties Endeavor (HOPE) Act of 2020. This bill establishes an equity facility in the Department of the Treasury to assist commercial mortgage borrowers. Specifically, Treasury must guarantee the purchase by financial institutions of certain equity instruments backed by a commercial mortgage. The bill defines commercial mortgage as a mortgage loan secured by an interest in real property owned for rental income. Borrowers with reduced revenues from their commercial property may qualify for an amount not to exceed 10% of the outstanding amount owed on their commercial mortgage. Issue: Commercial mortgages. H.R. 7913 - Financial Institution Forbearance Act. To amend the CARES Act to improve the temporary relief from troubled debt restructurings, and for other purposes. Issue: troubled debt restructurings. H.R. 7914 - Eliminating CECL Accounting Standard Act. This bill provides that no one shall be required to comply with a specified accounting standard applicable to credit losses (i.e., the current expected credit losses standard, also known as the CECL standard). Issue: CECL H.R. 133 - Consolidated Appropriations Act of 2021. Year end funding and COVID relief bill. Issue: The CARES Act temporarily suspends the generally accepted accounting principles (GAAP) requirements for the Troubled Debt Restructuring (TDR) classifications on loans. Extends this provision for an additional year, to January 1, 2022. S. 4325 - Business of Insurance Regulatory Reform Act of 2020. Issue: Clarifying that the CFPB does not regulate the business of insurance. H.R.__ - To deem certain references to the London Interbank Offered Rate (LIBOR) as referring to a replacement benchmark rate in the case of LIBOR no longer being available. Issue: LIBOR H.R.__ - Clarity in Credit Score Formation Act. Issue: Establishing clear federal oversight of the development of credit scoring models. Issue: Commercial mortgage-backed security (CMBS) debt. Not bill number assigned. Issue: Making Diversity and Inclusion Efforts more Intentional. No bill number assigned. Issue: Unclaimed life insurance products. No bill number assigned. Issue: Covered agreement on prudential measures with respect to the business of insurance and reinsurance. No bill number assigned. Issue: Government Sponsored Enterprises (GSE) reform. No bill number assigned.

Public Law 111-203, H.R. 4173 - Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Implementation and Regulatory reform. Captive Reinsurance Transactions, Insurance Capital Standards and Global Capital Standards. Roles of federal and state agencies at the International Association of Insurance Supervisors and the Financial Stability Board. Implementation of S. 2270 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III Implementation of S. 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act. Issue: Implementation and regulatory reform of the financial services industry. Implementation of H.R. 748 - the Coronavirus Aid, Relief, and Economic Security (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. Issue: CECL, TDR, Remote Online Notarization, SBA loans. H.R. 1815 - SEC Disclosure Effectiveness Test Act. Issue: SEC investor testing. H.R. 1862/S. 1586 - Federal Insurance Office Abolishment Act of 2019. Issue: FIO reform. H.R. 3561/S. 603 - Financial Stability Oversight Council Improvement Act of 2019. Issue: FSOC reform. H.R. 1595/S. 1200 - Secure and Fair Enforcement Banking Act. Issue: Insurance companies working with legitimate marijuana businesses. H.R. 3351- Financial Services and General Government Appropriations Act, 2020. Issue: Making appropriations for financial services and general government for the fiscal year ending September 30, 2020. H.R. 3614 - Restricting Use of Credit Checks for Employment Decisions Act. Issue: ban the use of credit information for most employment decisions. H.R. 2474/S.664 - Protecting Workers Freedom to Organize Act. To amend the National Labor Relations Act, the Labor Management Relations Act, 1947, and the Labor-Management Reporting and Disclosure Act of 1959. Issue: independent contractor status. H.R. 4592 - International Insurance Standards Act of 2019. To preserve the state-based system of insurance regulation and provide greater oversight of and transparency on international insurance standards setting process. Issue: insurance capital standards. H.R. 6994/S. 3795 - Registration for Index-Linked Annuities Act. To direct the SEC to revise any rules necessary to enable issuers of index-linked annuities to use the securities offering forms that are available to other issuers of securities. Issue: index-linked annuities. S. 3533/H.R. 6364 - Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2020. To authorize and establish minimum standards for electronic and remote notarizations that occur in or affect interstate commerce, to require any Federal court located in a State to recognize notarizations performed by a notary public commissioned by another State when the notarization occurs in or affects interstate commerce, and to require any State to recognize notarizations performed by a notary public commissioned by another State when the notarization occurs in or affects interstate commerce or when the notarization was performed under or relates to a public act, record, or judicial proceeding of the State in which the notary public was commissioned. Issue: remote online notarization. S. 4159 - Electronic Signatures in Global and National Commerce Act. To amend the Electronic Signatures in Global and National Commerce Act to accommodate emerging technologies. Issue: electronic signatures H.R. 7809 - Helping Open Properties Endeavor (HOPE) Act of 2020. This bill establishes an equity facility in the Department of the Treasury to assist commercial mortgage borrowers. Specifically, Treasury must guarantee the purchase by financial institutions of certain equity instruments backed by a commercial mortgage. The bill defines commercial mortgage as a mortgage loan secured by an interest in real property owned for rental income. Borrowers with reduced revenues from their commercial property may qualify for an amount not to exceed 10% of the outstanding amount owed on their commercial mortgage. Issue: Commercial mortgages. H.R. 7913 - Financial Institution Forbearance Act. To amend the CARES Act to improve the temporary relief from troubled debt restructurings, and for other purposes. Issue: troubled debt restructurings. H.R. 7914 - Eliminating CECL Accounting Standard Act. This bill provides that no one shall be required to comply with a specified accounting standard applicable to credit losses (i.e., the current expected credit losses standard, also known as the CECL standard). Issue: CECL H.R. 133 - Consolidated Appropriations Act of 2021. Year end funding and COVID relief bill. Issue: The CARES Act temporarily suspends the generally accepted accounting principles (GAAP) requirements for the Troubled Debt Restructuring (TDR) classifications on loans. Extends this provision for an additional year, to January 1, 2022. S. 4325 - Business of Insurance Regulatory Reform Act of 2020. Issue: Clarifying that the CFPB does not regulate the business of insurance. H.R.__ - To deem certain references to the London Interbank Offered Rate (LIBOR) as referring to a replacement benchmark rate in the case of LIBOR no longer being available. Issue: LIBOR H.R.__ - Clarity in Credit Score Formation Act. Issue: Establishing clear federal oversight of the development of credit scoring models. Issue: Commercial mortgage-backed security (CMBS) debt. Not bill number assigned. Issue: Making Diversity and Inclusion Efforts more Intentional. No bill number assigned. Issue: Unclaimed life insurance products. No bill number assigned. Issue: Covered agreement on prudential measures with respect to the business of insurance and reinsurance. No bill number assigned. Issue: Government Sponsored Enterprises (GSE) reform. No bill number assigned.

H.R.3885 - To amend the Bank Holding Company Act of 1956 to defer part of the compensation of senior employees of large bank holding companies (and their subsidiaries) for 10 years, to use such deferred amounts to pay any civil or criminal fines that may be levied on the bank holding company (or subsidiary), and for other purposes (Tulsi Gabbard, D-HI-2) H.R.5180 - To amend the Bank Holding Company Act of 1956 to restore the separation between banking and commerce by prohibiting bank holding company ownership of nonfinancial assets, and for other purposes (Jesus Garcia, D-IL-4) H.R.6249 - To temporarily prohibit the Federal financial regulators from requiring compliance with the CECL Rule by persons impacted by Coronavirus, and for other purpose (Blaine Luetkemeyer, R-MO-3) S.3502 - A bill to delay the implementation date of the current expected credit losses methodology for estimating allowances for credit losses, and for other purposes (Kevin Cramer, R-ND) S.4270 - A bill to amend the CARES Act to ensure that the temporary relief from CECL standards does not terminate in the middle of a company's fiscal year (Thom Tillis, R-NC) H.R.7914 - To specify that no person shall be required to comply with the CECL Rule under any Federal statute or regulation (Blaine Luetkemeyer, R-MO-3) S.4835 - A bill to prohibit bank holding companies from facilitating fossil fuel production from new sources or new or expanded fossil infrastructure that would drive such production, and for other purposes (Jeff Merkley, D-OR) S.2563 - ILLICIT CASH Act - To improve laws relating to money laundering, and for other purposes (Mark Warner, D-VA)

Client expense: $470,000 · Firm income: Not reported

H.R. 4565 - Responsible Accounting Standards Act of 2019. Issues relating to the accounting standard-setting process generally - no specific legislation. Issues related to CECL and accounting standards including H.R. 133 (P.L. 116 - 260) - Consolidated Appropriations Act, 2021 - Division N - Additional Coronavirus Response and Relief and H.R. 7914 - Eliminating CECL Accounting Standard Act.

Client expense: Not reported · Firm income: $70,000

Public Law 111-203, H.R. 4173 - Dodd-Frank Wall Street Reform and Consumer Protection Act. Issue: Implementation and Regulatory reform. Captive Reinsurance Transactions, Insurance Capital Standards and Global Capital Standards. Roles of federal and state agencies at the International Association of Insurance Supervisors and the Financial Stability Board. Implementation of S. 2270 - Insurance Capital Standards Clarification Act of 2014. The bill would give the Federal Reserve the authority to tailor capital standards for insurance companies subject to Fed supervision. Issue: Capital Standards, Basel III * Implementation of S. 2155 Economic Growth, Regulatory Relief, and Consumer Protection Act. Issue: Implementation and regulatory reform of the financial services industry. Implementation of H.R. 748 - the Coronavirus Aid, Relief, and Economic Security (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. Issue: CECL, TDR, Remote Online Notarization, SBA loans. H.R. 1815 - SEC Disclosure Effectiveness Test Act. Issue: SEC investor testing. H.R. 1862/S. 1586 - Federal Insurance Office Abolishment Act of 2019. Issue: FIO reform. H.R. 3561/S. 603 - Financial Stability Oversight Council Improvement Act of 2019. Issue: FSOC reform. H.R. 1595/S. 1200 - Secure and Fair Enforcement Banking Act. Issue: Insurance companies working with legitimate marijuana businesses. H.R. 3351- Financial Services and General Government Appropriations Act, 2020. Issue: Making appropriations for financial services and general government for the fiscal year ending September 30, 2020. H.R. 3614 - Restricting Use of Credit Checks for Employment Decisions Act. Issue: ban the use of credit information for most employment decisions. H.R. 2474/S.664 - Protecting Workers Freedom to Organize Act. To amend the National Labor Relations Act, the Labor Management Relations Act, 1947, and the Labor-Management Reporting and Disclosure Act of 1959. Issue: independent contractor status. H.R. 4592 - International Insurance Standards Act of 2019. To preserve the state-based system of insurance regulation and provide greater oversight of and transparency on international insurance standards setting process. Issue: insurance capital standards. * H.R. 6994/S. 3795 - Registration for Index-Linked Annuities Act. To direct the SEC to revise any rules necessary to enable issuers of index-linked annuities to use the securities offering forms that are available to other issuers of securities. Issue: index-linked annuities. S. 3533/H.R. 6364 - Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2020. To authorize and establish minimum standards for electronic and remote notarizations that occur in or affect interstate commerce, to require any Federal court located in a State to recognize notarizations performed by a notary public commissioned by another State when the notarization occurs in or affects interstate commerce, and to require any State to recognize notarizations performed by a notary public commissioned by another State when the notarization occurs in or affects interstate commerce or when the notarization was performed under or relates to a public act, record, or judicial proceeding of the State in which the notary public was commissioned. Issue: remote online notarization. S. 4159 - Electronic Signatures in Global and National Commerce Act. To amend the Electronic Signatures in Global and National Commerce Act to accommodate emerging technologies. Issue: electronic signatures H.R. 7809 - Helping Open Properties Endeavor (HOPE) Act of 2020. This bill establishes an equity facility in the Department of the Treasury to assist commercial mortgage borrowers. Specifically, Treasury must guarantee the purchase by financial institutions of certain equity instruments backed by a commercial mortgage. The bill defines commercial mortgage as a mortgage loan secured by an interest in real property owned for rental income. Borrowers with reduced revenues from their commercial property may qualify for an amount not to exceed 10% of the outstanding amount owed on their commercial mortgage. Issue: Commercial mortgages. H.R. 7913 - Financial Institution Forbearance Act. To amend the CARES Act to improve the temporary relief from troubled debt restructurings, and for other purposes. Issue: troubled debt restructurings. H.R. 7914 - Eliminating CECL Accounting Standard Act. This bill provides that no one shall be required to comply with a specified accounting standard applicable to credit losses (i.e., the current expected credit losses standard, also known as the CECL standard). Issue: CECL H.R.__ - To deem certain references to the London Interbank Offered Rate (LIBOR) as referring to a replacement benchmark rate in the case of LIBOR no longer being available. Issue: LIBOR H.R.__ - Clarity in Credit Score Formation Act. Issue: Establishing clear federal oversight of the development of credit scoring models. S.__ Clarifying that the CFPB does not regulate the business of insurance. Issue: Commercial mortgage-backed security (CMBS) debt. Not bill number assigned. Issue: Making Diversity and Inclusion Efforts more Intentional. No bill number assigned. Issue: Unclaimed life insurance products. No bill number assigned. Issue: Covered agreement on prudential measures with respect to the business of insurance and reinsurance. No bill number assigned. Issue: Government Sponsored Enterprises (GSE) reform. No bill number assigned.

H.R. 748 CARES Act H.R. 3182 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard H.R. 6249 Coronavirus Accounting Relief Act H. R. 6385 To provide temporary relief from troubled debt restructuring disclosures, to delay the implementation of certain accounting standards for depository institutions substantially affected by COVID-19, and for other purposes. H.R. 6551 CARES Act Section 4014 Technical Corrections Act H.R. 7914 Eliminating CECL Accounting Standards Act S. 1564 Requires agency study of Current Expected Credit Loss standard and delays effective date of standard S. 3502 Community Bank Regulatory Relief Act, Accounting Provisions S. 3548 CARES Act, Accounting Provisions Accounting for Paycheck Protection Program Loan Processing Fees Current Expected Credit Losses (CECL) Standard

Client expense: $840,000 · Firm income: Not reported

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

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

H.R.3885 - To amend the Bank Holding Company Act of 1956 to defer part of the compensation of senior employees of large bank holding companies (and their subsidiaries) for 10 years, to use such deferred amounts to pay any civil or criminal fines that may be levied on the bank holding company (or subsidiary), and for other purposes (Tulsi Gabbard, D-HI-2) , ALL PROVISIONS H.R.5180 - To amend the Bank Holding Company Act of 1956 to restore the separation between banking and commerce by prohibiting bank holding company ownership of nonfinancial assets, and for other purposes (Jesus Garcia, D-IL-4) , ALL PROVISIONS H.R.6249 - To temporarily prohibit the Federal financial regulators from requiring compliance with the CECL Rule by persons impacted by Coronavirus, and for other purpose (Blaine Luetkemeyer, R-MO-3) , ALL PROVISIONS S.3502 - A bill to delay the implementation date of the current expected credit losses methodology for estimating allowances for credit losses, and for other purposes (Kevin Cramer, R-ND) , ALL PROVISIONS S.4270 - A bill to amend the CARES Act to ensure that the temporary relief from CECL standards does not terminate in the middle of a company's fiscal year (Thom Tillis, R-NC) , ALL PROVISIONS H.R.7914 - To specify that no person shall be required to comply with the CECL Rule under any Federal statute or regulation (Blaine Luetkemeyer, R-MO-3) , ALL PROVISIONS

Client expense: $550,000 · Firm income: Not reported