EIDL Forgiveness Act

Protect the credit union tax exemption; supports a transparent, fair and efficient mechanism for funding agency operations; Overhead Transfer Rate (OTR) methodology and operating fee schedule; support of the FCC's efforts to establish and implement exemptions to the TCPAs consent requirement for important information about fraudulent activity, data breaches and available protections, and money transfers; supportive of the FCCs proposal to not limit the number of calls made under the exemption; Comment on Annual Certification and Data Collection Report Form (ACR) and the Certification Transaction Level Report (CTLR), concerned about the reporting burden and cybersecurity risks associated with the proposed ACR and CTRL; support the certainty and regulatory flexibility afforded by many of the new and updated Interagency Questions and Answers regarding flood insurance; express concern the proposed Community Development Financial Institutions Program application creates many such barriers, which ultimately will make it more difficult and unlikely that credit unions will obtain and maintain CDFI-designation; urge the Federal Housing Finance Agency (FHFA) to evaluate top credit union regulatory priorities, Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the National Credit Union Administration (NCUA) to evaluate the priority issues and enact the requested policy modifications re: Reverse the Adverse Market Refinance Fees Policy, Relief for Originating and Servicing Mortgages During the Ongoing Pandemic, Adopt a Strong but Reasonable Regulatory Capital Framework Preserve Access to the Secondary Market for Smaller Lenders; urge the U.S. Department of the Treasury (Treasury) along with the Financial Crimes Enforcement Network (FinCEN) and the Internal Revenue Service (IRS) to evaluate the top credit union priorities; express concern with Section 2885 of S.4049, which would expand access to nominal leases on military installations for banks; support for Division F, the Corporate Transparency Act of 2019 and Division G, the COUNTER Act of 2019, of H.R.6395, which would make critical improvements to our Bank Secrecy Act (BSA)/anti-money laundering (AML)/beneficial ownership regime; support of a simplified loan forgiveness process for PPP loans under a $150,000 threshold, such as proposed in H.R.7777/S.4117, the Paycheck Protection Small Business Forgiveness Act; support a second round of PPP loans to the hardest hit small businesses; extend the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) that were enacted in section 4016 of the CARES Act and to extend the provisions from section 4013 of the CARES Act dealing with Troubled Debt Restructuring (TDR); support H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020; support excluding EIDL advances from the PPP forgiveness calculation, as proposed by bipartisan legislation in the House, HR.8361, the EIDL Forgiveness Act; supports legislation, H.R.6789/S.3676, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act of 2020, which would provide temporary relief from the credit union member business lending (MBL) cap; support increase funding for the CDFI and CDRLF programs. Providing $1 billion in emergency funding for the CDFI Fund would allow more credit unions to access monies for specific programs; support the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act); support the inclusion of S.4159, the E-SIGN Modernization Act of 2020, in the relief package; credit unions, as not-for-profit cooperative institutions, should not be subject to the CECL standard; support a reduction in the level at which credit unions are considered well capitalized from a net-worth ratio of seven percent to six percent and adequately capitalized from six percent to five percent during the pandemic; reject any idea, even if well-meaning, that could place new hardships on credit unions; urges the Bureau of Consumer Financial Protection (Bureau or CFPB) to evaluate top credit union priorities, Delay Section 1071 Rulemaking, Electronic Disclosure Relief and Credit Card Accountability Responsibility and Disclosure Act of 2009 Act (CARD Act) Improvements, Temporarily Halt the Qualified Mortgage (QM) Rulemaking, Revise Home Mortgage Disclosure Act (HMDA) Rule and Reporting, Facilitate the London Interbank Offered Rate (LIBOR) Transition, Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Guidance and Rulemaking; urge NCUA provide relief to credit unions as they serve their members during the pandemic: Expanding Virtual Meetings, Managing Unexpected Share Growth, Additional Investment Opportunities, Capitalizing Interest on Loan Modifications, Adopting Broader Capital Reform, Finalizing an Efficient and Measured Budget; supports FinCEN defining an overall effective and reasonably designed AML program, including the explicit requirement for a risk-assessment; support automatic loan forgiveness for PPP loans under $150,000 and support any legislative efforts; support legislative efforts to amend the CARES Act to exclude Economic Injury Disaster Loans (EIDL) advance amounts from the calculation of loan forgiveness under the PPP; support initial 3508EZ form and the newly created 3508S form for loans under $50,000; support H.R. 8361, the EIDL Forgiveness Act; recommend a comment period of 90 days for all novel charter applications including the recent filings by Figure Bank for a national charter and Anchorage for a trust charter; TRACED Act; urged the Commission (FCC) not to impose additional restrictions on the existing exemption for informational calls placed to residential telephone numbers (Informational Calls Exemption); urges FinCEN to retain the current Recordkeeping and Travel Rule thresholds; supports the definition of money as proposed, which will resolve ambiguities surrounding applicability to convertible virtual currencies (CVCs); Thresholds for the Requirement to Collect, Retain, and Transmit Information Under the Recordkeeping and Travel Rules (Docket No.: FINCEN-2020-0002; RIN No.: 1506-AB41); Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support increase in size standards for North American Industry Classification System (NAICS) sectors related to finance and insurance, specifically NAICS code 522130 for credit unions; inclusion of S.4117, the Paycheck Protection Small Business Forgiveness Act; support the extensions of the changes to the National Credit Union Administrations (NCUA) Central Liquidity Facility (CLF) and Troubled Debt Restructuring (TDR) provisions from the CARES Act; support focused clarification of regulatory expectations re: ECOA and Reg B; support HUDs codifying court rulings for disparate impact; support extension of CARES Act provisions: Section 1102: Paycheck Protection Program, Section 4012: Community Bank Leverage Ratio, Section 4014: Current Expected Credit Loss (CECL), Section 4008: Deposit Insurance, Section 4013: Troubled Debt Restructuring (TDR), Section 4016: NCUAs Central Liquidity Facility (CLF), Section 1110: Economic Injury Disaster Loan (EIDL) Program; Conference Report for H.R. 6395, the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021; express concern re: The Senates version of the FY 2021 NDAA, S.4049; supports efforts to provide additional emergency funding for CDFIs; outlines several recommendations to improve the efficiency of NCUA budget; bipartisan beneficial ownership and BSA/AML reform legislation - the Corporate Transparency Act and the COUNTER Act; Notice of Ex Parte Presentations, Rules & Regulations Implementing the Tel. Consumer Prot. Act of 1991, CG Docket No. 02-278; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; Notice of Ex Parte Meeting, Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59; support the ultimate objectives of section 1071, express concern that the complexity of section 1071 data collection and the accompanying burden of adopting new compliance systems; support $25 billion in rental assistance to the Treasury Department to allocate to state and local governments, as well as extends the eviction moratorium; support NCUA modernizing the agencys derivatives rule, changing from a prescriptive approach to a more flexible, principles-based approach; support appreciates the CFPB clarifying ambiguities in the 2018 Statement Clarifying the Role of Supervisory Guidance ; H.R. 133, the Consolidated Appropriations Act of 2021

Client expense: $810,000 · 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