Home Loan Quality Transparency Act of 2019

Support S. 331 / HR 963, which restores comprehensive HMDA reporting requirements to 25 for mortgages and 100 for HELOCs with the exclusion for banks and credit unions with fewer than $30 million in assetts Support the H.R. 1500, the Consumer First Act, which reestablishes the vitality of the CFPB Oppose proposal by Senator Crapo to privatize Fannie Mae and Freddie Mac Support H.R. 1018, which instructs companies to disclose the race, ethnicity, gender, Veterans status and disability status of members of their Boards of Directors and C-Suite level executives. Support hr 2684, the FAIR RATES Act, which directs the Federal Insurance Office (FIO) to collect specific loss data from large auto insurance providers, publicly disclose the data, and submit an analysis to Congress on disparate impact along racial lines in automobile insurance Support HR 4254, the Overdraft Protection Act of 2019. This legislation will address the most abusive provisions of todays typical overdraft coverage Support the development of any proposed changes to the Community Reinvestment Act (CRA) are developed carefully and refrain from enacting reforms that would undercut CRAs effectiveness Support the letter drafted by Senator Brown to the CFPB regarding its Notice of Proposed Rulemaking regarding Ability to Repay (ATR) and Qualified Mortgages (QM). Urge the CFPB to consider the letter and intent of the ATR and QM statutory requirements to ensure that: (1) borrowers maintain at least the same level of access to responsible, affordable mortgage credit that they have today; and (2) all mortgage loans are made based on a demonstrated ability to repay analysis that relies on documented and verified income and is itself documented and subject to examination by the Bureau and other regulators Support real-time payments; support efforts by the Federal Reserve to develop a real-time payment plan; support the inclusion of civil right protections in any and all real-time payment plans

Client expense: $72,500 · Firm income: Not reported

Government targets: Alcohol & Tobacco Tax & Trade Bureau (TTB), Army, Dept of (Corps of Engineers), Bureau of Alcohol Tobacco Firearms & Explosives, Bureau of Citizenship & Immigration Services (BCIS), Bureau of the Census, Centers For Disease Control & Prevention (CDC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Economic Development Administration, Education, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Motor Carrier Safety Administration, Federal Reserve System, Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), 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), Office of Management & Budget (OMB), Office of Personnel Management (OPM), Office of Policy Development, Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), State, Dept of (DOS), Treasury, Dept of, U.S. Customs & Border Protection, U.S. Immigration & Customs Enforcement (ICE), White House Office

Support S. 331 / HR 963, which restores comprehensive HMDA reporting requirements to 25 for mortgages and 100 for HELOCs with the exclusion for banks and credit unions with fewer than $30 million in assets Support lifting the austere Budget Control Act federal spending caps and ensuring that affordable housing, community development, and transportation programs receive the highest allocation of discretionary funds possible for FY20. Support S. 787 / HR 1737, the American Housing and Economic Mobility Act, which would: ramp up investments at the federal level to build an estimated 3 million new housing units aimed at lower-income and middle-class families in urban, suburban, and rural areas; establish down-payment assistance programs in communities that were shut out of homeownership by redlining and segregation practices; create hard-to-refuse incentives for local governments to eliminate land use rules that currently drive up costs and reduce the construction of new affordable housing; provide support to underwater borrowers, primarily in suburban and rural communities; modernize the Community Reinvestment Act so it covers more financial institutions and promotes more sustainable investments in LMI communities; update the Fair Housing Act of 1968 to prevent discrimination against people because of sexual orientation, gender identity, marital status, source of income, or veterans status; return the estate tax thresholds to their levels at the end of the Bush Administration - affecting about 10,000 of the wealthiest families in the country - in order to fund the provisions in the bill Support the Disability Integration Act, S.117 / H.R. 555, to ensure that people with disabilities can live in the community rather than be forced into nursing facilities and other institutions. Support increasing resources to fight housing discrimination; support HR 149 Support multi-year funding to repair the Federal Housing Administrations broken IT systems Support FHFAs activities to make their mortgage loan products more accessible to Americans with Limited English Proficiency. Support $5 billion for the National Low Income Trust and $15 billion to rehabilitate the public housing stock and that housing be included in any omnibus infrastructure plan Support s. 2076 / hr 3685 which is a comprehensive reform of eviction and screening policies for federal housing assistance. Oppose the CFPB proposal to raise the threshold for financial institutions to submit Home Mortgage Disclosure (HMDA) data. Support a letter by Chair Waters and Chair Velasquez in opposition to these changes. Support a letter by Ranking Member Brown in opposition to these changes Support HR 3154 / S1929, the Homeownership for Dreamers Act, which would ensure that DACA recipients are eligible for loans backed by FHA. Oppose the decision by the Federal Housing Finance Agency to remove the question about a borrowers language preference from the revised Uniform Residential Loan Application (URLA) FHA mortgages play a crucial role in providing and maintaining access to affordable and sustainable homeownership for LMI families and communities of color. If the Loan Sale Program continues in its current unregulated form, FHA borrowers and their communities remain at risk of further harm from non-compliant servicers and private equity loan purchasers. It is crucial that HUD implement strong protections both before and after loans are sold to prevent needless borrower displacement and neighborhood instability. HUD must develop and enforce robust protections for FHA borrowers and former borrowers affected by loan sales and mandate comprehensive data collection, including on fair housing issues, so that the impact of loan sales can be properly evaluated and problems addressed Support the view that any effort to comprehensively reform Government Sponsored Entities (GSEs)-Fannie Mae and Freddie Mac-must recognize the importance of preserving and strengthening access to stable, affordable, and equitable homeownership opportunities for American families. Oppose the Presidential Memorandum on the issue Support the ATR-QM rule coinciding with the expiration of the GSE Patch; support the elimination Eliminate the debt-to-income (DTI) ratio threshold and the associated Appendix Q; Support maintaining and enhancing the existing ATR regulatory language; and maintaining the existing QM statutory safe product restrictions that prohibit certain risky loan features (e.g., no terms over 30 years, no negative amortization, no interest-only payments, no balloon payments, documented and verified income, etc.) Oppose the Presidential Memorandum on Federal Housing Finance Reform released on 9-5-19 as it will increase the cost of a mortgage for everyone, especially families of color, low- to moderate-income families, and rural families Any effort to comprehensively reform Government Sponsored Entities (GSEs)-Fannie Mae and Freddie Mac-must recognize the importance of preserving and strengthening access to stable, affordable, and equitable homeownership opportunities for all American families Support a letter by Senator Cortez Masto to FHFA Director Mark Calabria opposing his decision to remove the language preference and housing counseling information from the Uniform Residential Loan Application form Support the administration continuing to make contributions to the Housing Trust Fund and Capital Magnet Fund as housing finance reform efforts move forward, including any capital restoration plan.

Client expense: $72,500 · Firm income: Not reported

Government targets: Alcohol & Tobacco Tax & Trade Bureau (TTB), Army, Dept of (Corps of Engineers), Bureau of Alcohol Tobacco Firearms & Explosives, Bureau of Citizenship & Immigration Services (BCIS), Bureau of the Census, Centers For Disease Control & Prevention (CDC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Economic Development Administration, Education, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Motor Carrier Safety Administration, Federal Reserve System, Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), 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), Office of Management & Budget (OMB), Office of Personnel Management (OPM), Office of Policy Development, Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), State, Dept of (DOS), Treasury, Dept of, U.S. Customs & Border Protection, U.S. Immigration & Customs Enforcement (ICE), White House Office

Support S. 331 / HR 963, Introduced by Senator Cortez Masto and Congresswoman Velazquez which restores comprehensive HMDA reporting requirements to 25 for mortgages and 100 for HELOCs with the exclusion for banks and credit unions with fewer than $30 million in assets Support the establishment of a National Task Force on the Impact of the Affordable Housing Crisis Support lifting the austere Budget Control Act federal spending caps and ensuring that affordable housing, community development, and transportation programs receive the highest allocation of discretionary funds possible for FY20. Support the American Housing and Economic Mobility Act, which would: ramp up investments at the federal level to build an estimated 3 million new housing units aimed at lower-income and middle-class families in urban, suburban, and rural areas; establish down-payment assistance programs in communities that were shut out of homeownership by redlining and segregation practices; create hard-to-refuse incentives for local governments to eliminate land use rules that currently drive up costs and reduce the construction of new affordable housing; provide support to underwater borrowers, primarily in suburban and rural communities; modernize the Community Reinvestment Act so it covers more financial institutions and promotes more sustainable investments in LMI communities; update the Fair Housing Act of 1968 to prevent discrimination against people because of sexual orientation, gender identity, marital status, source of income, or veterans status; return the estate tax thresholds to their levels at the end of the Bush Administration - affecting about 10,000 of the wealthiest families in the country - in order to fund the provisions in the bill Support the Disability Integration Act, S.117 / H.R. 555, to ensure that people with disabilities can live in the community rather than be forced into nursing facilities and other institutions. Support increasing resources to fight housing discrimination; support HR 149 Support multi-year funding to repair the Federal Housing Administrations broken IT systems Support FHFAs activities to make their mortgage loan products more accessible to Americans with Limited English Proficiency. Support that the CFPB re-issue the Notice of Proposed Rulemaking (NPRM) and the Advanced Notice of Proposed Rulemaking (ANPR) regarding the Home Mortgage Disclosure Act (HMDA). The CFPB should re-issue the NPRM and ANPR after it has released the Snapshot National Loan Level Dataset for the 2018 HMDA data and the CFPBs analysis and report of the data Support $5 billion for the National Low Income Trust ad $15 billion to rehabilitate the public housing stock and that housing be included in any omnibus infrastructure plan Support s. 2076 / hr 3685 which is a comprehensive reform of eviction and screening policies for federal housing assistance. Support publicly available, broad-based data collection, tracking and disclosure of investment in areas that have been historically under-capitalized through the Opportunity Zone program. This data is essential to helping ensure any community development policy including the Opportunity Zone program can achieve its goals Oppose the CFPB proposal to raise the threshold for financial institutions to submit Home Mortgage Disclosure (HMDA) data. Support a letter by Chair Waters and Chair Velasquez in opposition to these changes. Support a letter by Ranking Member Brown in opposition to these changes Support HR 3154 / S1929, the Homeownership for Dreamers Act, which would ensure that DACA recipients are eligible for loans backed by FHA. Support the US Department of Housing and Urban Affairs carefully assessing the potential risks and benefits of the Opportunity Zone investments and act accordingly to further HUDs mission to ensure there are quality and affordable homes for all people and create sustainable and inclusive communities that are free from discrimination. Oppose any diminishment of the new and enhanced Home Mortgage Disclosure Act (HMDA) variables added by the 2015 final rule issued by the Consumer Financial Protection Bureau earlier this year Oppose the FHA proposed streamlining of the certification language and new details of the Defect Taxonomy on the origination side getting the loan-level certification requirements. Getting the process right is of enormous consequence to consumers, lenders, and the well-being of the FHA program. It will enable more borrowers to have access to safe and affordable mortgage credit, assist FHA to operate a safe and sustainable mortgage insurance program with effective quality control, and provide lenders with the clarity they need about enforcement standards to expand access to FHA-insured mortgage credit.

Client expense: $72,500 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Alcohol & Tobacco Tax & Trade Bureau (TTB), Army, Dept of (Corps of Engineers), Bureau of Alcohol Tobacco Firearms & Explosives, Bureau of Citizenship & Immigration Services (BCIS), Bureau of the Census, Centers For Disease Control & Prevention (CDC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Economic Development Administration, Education, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Motor Carrier Safety Administration, Federal Reserve System, Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), 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 Park Service (NPS), Office of Management & Budget (OMB), Office of Personnel Management (OPM), Office of Policy Development, Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), State, Dept of (DOS), U.S. Customs & Border Protection, U.S. Immigration & Customs Enforcement (ICE), White House Office