ECORA Act of 2021

H.R. 1381 Main St Tax Certainty Act. Makes permanent Section 199A of the tax code H.R. 1977 Enhancing Credit Opportunities in Rural America Act (ECORA) H.R. 5586 Prohibiting IRS Financial Surveillance Act H.R. 6732 Small LENDER Act S. 480 Main Street Tax Certainty Act S. 2202 Enhancing Credit Opportunities for Rural America S. 3506 Prohibiting IRS Financial Surveillance Act Bank Account Information Reporting to the IRS Credit Union Tax Exemption ECORA - Tax relief for community banks - Support Mortgage Insurance Premium Tax Deduction Tax Relief for Community Bank Retained Earnings

Client expense: $1,303,790 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1977 Enhancing Credit Opportunities for Rural America Act (ECORA) H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8950 Digital Commodities Consumer Protection Act of 2022 S. 2202 Enhancing Credit Opportunities for Rural America (ECORA) S. 4760 - Digital Commodities Consumer Protection Act of 2022 Digital assets FCS Cyber Security - Favor Transparency & FCS following Bank like regulations Section 1071 & Farm Credit System compliance USDA Guaranteed Loan Programs regarding Beginning Farmer and Rancher (BFR) Enhancements

Client expense: $1,303,790 · Firm income: Not reported

H.R. 1977 Enhancing Credit Opportunities for Rural America Act (ECORA) H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8950 Digital Commodities Consumer Protection Act of 2022 S. 2202 Enhancing Credit Opportunities for Rural America (ECORA) S. 4760 - Digital Commodities Consumer Protection Act of 2022 Digital assets Farm Credit Administration - Favor updating Young, Beginning, Farmer requirements FCS Cyber Security - Favor Transparency & FCS following Bank like regulations Letter to CFPB Urging restrictions of credit union purchases or banks; facilitate community banks purchasing local community bank instead of allowing large banks to purchase local banks Letter to UDSDA with recommendations on Livestock Dealer Trust regulations Section 1071 & Farm Credit System compliance USDA Guaranteed Loan Programs regarding Beginning Farmer and Rancher (BFR) Enhancements

Client expense: $718,825 · Firm income: Not reported

H.R. 1381 Main St Tax Certainty Act. Makes permanent Section 199A of the tax code H.R. 1977 Enhancing Credit Opportunities in Rural America Act (ECORA) H. R. 5376 - Inflation Reduction Act of 2022 (Build Back Better) H.R. 5586 Prohibiting IRS Financial Surveillance Act H.R. 6732 Small LENDER Act H.R. 6802 Preventing Racial Profiling in Lending Act S. 480 Main Street Tax Certainty Act S. 2202 Enhancing Credit Opportunities for Rural America S. 3506 Prohibiting IRS Financial Surveillance Act Administration Proposal to Close the Tax Gap Bank Account Information Reporting to the IRS Credit Union Tax Exemption ECORA - Tax relief for community banks - Support Tax Relief for Community Bank Retained Earnings

Client expense: $718,825 · Firm income: Not reported

HR 2797: Beginning Agriculturist Lifetime Employment Act (BALE Act) H.R. 1977: Enhancing Credit Opportunities in Rural America Act (ECORA) Ag/Inclusiveness Ag. Appropriations Community & Facilities Legislation Climate/Food and Agriculture Climate Alliance (FACA) Farm Bill Renewable Energy Rural Business Investment Company (RBIC) Program Growing Climate Solutions Act B&I Loan leg for small processors Crop insurance S 4954 Farm Credit for Americans Act of 2022 Feed Emergency Enhancement During Disasters with Cover Crops Act

Client expense: $40,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, HOUSE OF REPRESENTATIVES, SENATE

Monitor implementation of P.L. 115-334, the Agriculture Act of 2018. Monitor progress of Livestock Mandatory Reporting Reauthorization. Monitor progress of S. 949, "A bill to amend the Agricultural Marketing Act of 1946 to foster efficient markets and increase competition and transparency among packers that purchase livestock from producers." Monitor progress of H.R. 4103 / S. 2036, "To amend the Packers and Stockyards Act, 1921, to establish the Office of the Special Investigator for Competition Matters, and for other purposes." General engagement on USDA's expected future regulation on Packers & Stockyards Act requirements. General education on the New Swine Inspection System (NSIS) and the impact of the recent court ruling striking down the line speed provisions of the rule. Advocating for USDA to quickly implement its Time Limited Trial of higher line speeds in NSIS plants. General education on the importance of immigrant labor for the agriculture industry workforce. Monitor implementation of P.L. 116-122, Protecting America's Food and Agriculture Act of 2019, all provisions. General education about the severe impact of the COVID-19 pandemic on the U.S. pork industry. Monitor implementation of P.L. 116-123, Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 116-127, Families First Coronavirus Response Act, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 116-136, Coronavirus Aid, Relief, and Economic Security (CARES) Act, provisions related to agriculture, farms, and food production. Coronavirus Food Assistance Program (CFAP), 85 FR 30825. Second round of Coronavirus Food Assistance Program (CFAP2), 85 FR 59380. Coronavirus Food Assistance Program; Additional Assistance, 86 FR 4877. Monitor implementation of P.L. 116-260, the Consolidated Appropriations Act, 2021, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 117-2, the American Rescue Plan Act of 2021, provisions related to agriculture, farms, and food production. Monitor progress of H.R. 1977, "To amend the Internal Revenue Code of 1986 to exclude from gross income interest received on certain loans secured by agricultural real property." General education on agricultural infrastructure priorities. Seeking additional funding for National Animal Health Laboratory Network and veterinary stockpile. Proposed reconciliation bill, provisions related to agriculture, farms, and food production. Coronavirus Food Assistance Program 2; Producers of Sale-Based Commodities and Contract Producers, 86 FR 48013. H.R. 4999, the Exposing Agricultural Trade Suppression Act. Investments and Opportunities for Meat and Poultry Processing Infrastructure, 86 FR 37728. H.R.2471 - Consolidated Appropriations Act, 2022, provisions related to agriculture, farms, and food production. S.3678 - Beagle Brigade Act of 2022, all provisions. H.R.6833 - Making continuing appropriations for fiscal year 2023, and for other purposes, provisions related to agriculture, farms, and food production. H.R.5376 - Inflation Reduction Act of 2022, provisions related to agriculture, farms, and food production. Notice of Funds Availability; Spot Market Hog Pandemic Program, 86 FR 71003. Notice of Funds Availability; Spot Market Hog Pandemic Program (SMHPP), 87 FR 15358. General education on S.3870 - Meat and Poultry Special Investigator Act of 2022, all provisions. General education on the need for Livestock Gross Margin reform. General education about animal health priorities in future Farm Bills. Transparency in Poultry Grower Contracting and Tournaments, 87 FR 34980.

Farm Credit System H.R. 1977, The Enhancing Credit Opportunities in Rural America Act S. 2202, ECORA Act of 2021

Client expense: $2,870,000 · Firm income: Not reported

H.R. 1977 Enhancing Credit Opportunities for Rural America Act (ECORA) H.R. 7768 Farm Credit Administration Independence Authority Act S. 2202 Enhancing Credit Opportunities for Rural America (ECORA) USDA Guaranteed Loan Programs regarding Beginning Farmer and Rancher (BFR) Enhancements

Client expense: $718,825 · Firm income: Not reported

H.R. 1381 Main St Tax Certainty Act. Makes permanent Section 199A of the tax code H.R. 1977 Enhancing Credit Opportunities in Rural America Act (ECORA) H.R. 5376 Build Back Better Act H.R. 5586 Prohibiting IRS Financial Surveillance Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6802 Preventing Racial Profiling in Lending Act S. 480 Main Street Tax Certainty Act S. 2202 Enhancing Credit Opportunities for Rural America S. 2387 Small Business Tax Fairness Act S. 3506 Prohibiting IRS Financial Surveillance Act S. 3715 E-Sign Modernization Act S. 3745 TAILOR Act S. Amend 3099 Amendment to the Senate Budget Resolution to bar new IRS reporting Administration Proposal to Close the Tax Gap Bank Account Information Reporting to the IRS Credit Union Tax Exemption ECORA - Tax relief for community banks - Support IRS Financial Transaction Reporting Proposal in budget reconciliation Taxation of Capital Gains at Death Tax Relief for Community Bank Retained Earnings

Client expense: $718,825 · Firm income: Not reported

HR 2797: Beginning Agriculturist Lifetime Employment Act (BALE Act) H.R. 1977: Enhancing Credit Opportunities in Rural America Act (ECORA) Ag/Inclusiveness Ag. Appropriations Community & Facilities Legislation Climate/Food and Agriculture Climate Alliance (FACA) Growing Climate Solutions Act Farm Bill Renewable Energy Rural Business Investment Company (RBIC) Program Growing Climate Solutions Act B&I Loan leg for small processors Young beginning Small Producers Rule Crop insurance

Client expense: $40,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, HOUSE OF REPRESENTATIVES, SENATE

Farm Credit System H.R. 1977, The Enhancing Credit Opportunities in Rural America Act S. 2202, ECORA Act of 2021

Client expense: $1,740,000 · Firm income: Not reported

Farm Credit System H.R. 1977, The Enhancing Credit Opportunities in Rural America Act S. 2202, ECORA Act of 2021

Client expense: $1,666,000 · Firm income: Not reported

Monitor implementation of P.L. 115-334, the Agriculture Act of 2018. Monitor progress of Livestock Mandatory Reporting Reauthorization. Monitor progress of S. 949, "A bill to amend the Agricultural Marketing Act of 1946 to foster efficient markets and increase competition and transparency among packers that purchase livestock from producers." Monitor progress of H.R. 4103 / S. 2036, "To amend the Packers and Stockyards Act, 1921, to establish the Office of the Special Investigator for Competition Matters, and for other purposes." General engagement on USDA's expected future regulation on Packers & Stockyards Act requirements. General education on the New Swine Inspection System (NSIS) and the impact of the recent court ruling striking down the line speed provisions of the rule. Advocating for USDA to quickly implement its Time Limited Trial of higher line speeds in NSIS plants. General education on the importance of immigrant labor for the agriculture industry workforce. Monitor implementation of P.L. 116-122, Protecting America's Food and Agriculture Act of 2019, all provisions. General education about the severe impact of the COVID-19 pandemic on the U.S. pork industry. Monitor implementation of P.L. 116-123, Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 116-127, Families First Coronavirus Response Act, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 116-136, Coronavirus Aid, Relief, and Economic Security (CARES) Act, provisions related to agriculture, farms, and food production. Coronavirus Food Assistance Program (CFAP), 85 FR 30825. Second round of Coronavirus Food Assistance Program (CFAP2), 85 FR 59380. Coronavirus Food Assistance Program; Additional Assistance, 86 FR 4877. Monitor implementation of P.L. 116-260, the Consolidated Appropriations Act, 2021, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 117-2, the American Rescue Plan Act of 2021, provisions related to agriculture, farms, and food production. Monitor progress of H.R. 1977, "To amend the Internal Revenue Code of 1986 to exclude from gross income interest received on certain loans secured by agricultural real property." General education on agricultural infrastructure priorities. Seeking additional funding for National Animal Health Laboratory Network and veterinary stockpile. Proposed reconciliation bill, provisions related to agriculture, farms, and food production. Coronavirus Food Assistance Program 2; Producers of Sale-Based Commodities and Contract Producers, 86 FR 48013. H.R. 4999, the Exposing Agricultural Trade Suppression Act. Investments and Opportunities for Meat and Poultry Processing Infrastructure, 86 FR 37728. H.R.2471 - Consolidated Appropriations Act, 2022, provisions related to agriculture, farms, and food production. S.3678 - Beagle Brigade Act of 2022, all provisions. Notice of Funds Availability; Spot Market Hog Pandemic Program, 86 FR 71003. Notice of Funds Availability; Spot Market Hog Pandemic Program (SMHPP), 87 FR 15358. General education on S.3870 - Meat and Poultry Special Investigator Act of 2022, all provisions. General education on the need for Livestock Gross Margin reform. General education about animal health priorities in future Farm Bills.

Issues related to H.R. 1977 and S. 2021 (entire bills).

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1381 Main St Tax Certainty Act. Makes permanent Section 199A of the tax code H.R. 1977 Enhancing Credit Opportunities in Rural America Act (ECORA) H.R. 5376 Build Back Better Act H.R. 5586 Prohibiting IRS Financial Surveillance Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6802 Preventing Racial Profiling in Lending Act S. 480 Main Street Tax Certainty Act S. 2202 Enhancing Credit Opportunities for Rural America S. 2387 Small Business Tax Fairness Act S. 3506 Prohibiting IRS Financial Surveillance Act S. 3715 E-Sign Modernization Act S. 3745 TAILOR Act S. Amend 3099 Amendment to the Senate Budget Resolution to bar new IRS reporting Administration Proposal to Close the Tax Gap Bank Account Information Reporting to the IRS Credit Union Tax Exemption ECORA - Tax relief for community banks - Support IRS Financial Transaction Reporting Proposal in budget reconciliation Taxation of Capital Gains at Death Tax Relief for Community Bank Retained Earnings

Client expense: $1,840,000 · Firm income: Not reported

H.R. 1977 Enhancing Credit Opportunities for Rural America Act (ECORA) H.R. 7768 Farm Credit Administration Independence Authority Act S. 2202 Enhancing Credit Opportunities for Rural America (ECORA) USDA Guaranteed Loan Programs regarding Beginning Farmer and Rancher (BFR) Enhancements

Client expense: $1,840,000 · Firm income: Not reported

H.R. 1977 Enhancing Credit Opportunities for Rural America Act (ECORA) S. 2202 Enhancing Credit Opportunities for Rural America (ECORA) Crop Insurance - Protecting Funding USDA Guaranteed Loan Programs regarding Beginning Farmer and Rancher (BFR) Enhancements

Client expense: $690,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

H.R. 1381 Main St Tax Certainty Act. Makes permanent Section 199A of the tax code H.R. 1977 Enhancing Credit Opportunities in Rural America Act (ECORA) H.R. 5376 Build Back Better Act H.R. 5586 Prohibiting IRS Financial Surveillance Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6802 Preventing Racial Profiling in Lending Act S. 480 Main Street Tax Certainty Act S. 2202 Enhancing Credit Opportunities for Rural America S. 2387 Small Business Tax Fairness Act S. 3506 Prohibiting IRS Financial Surveillance Act S. 3715 E-Sign Modernization Act S. 3745 TAILOR Act S. Amend 3099 Amendment to the Senate Budget Resolution to bar new IRS reporting Administration Proposal to Close the Tax Gap Bank Account Information Reporting to the IRS Credit Union Tax Exemption ECORA - Tax relief for community banks - Support IRS Financial Transaction Reporting Proposal in budget reconciliation Taxation of Capital Gains at Death

Client expense: $690,000 · Firm income: Not reported

Farm Credit System H.R. 1977, The Enhancing Credit Opportunities in Rural America Act S. 2202, ECORA Act of 2021

Client expense: $1,666,000 · Firm income: Not reported

Issues related to H.R. 1977 and S. 2021 (entire bills).

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 6700: FEMA Empowering Essential Deliveries Act (FEED Act) HR 2797: Beginning Agriculturist Lifetime Employment Act (BALE Act) H.R. 1977: Enhancing Credit Opportunities in Rural America Act (ECORA) Ag/Inclusiveness Ag. Appropriations Community & Facilities Legislation Climate/Food and Agriculture Climate Alliance (FACA) Business & Industry CARES Act for small producers Growing Climate Solutions Act Farm Bill Renewable Energy Rural Business Investment Company (RBIC) Program

Client expense: $40,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Farm Credit Administration, HOUSE OF REPRESENTATIVES, SENATE

Monitor implementation of P.L. 115-334, the Agriculture Act of 2018. Monitor progress of Livestock Mandatory Reporting Reauthorization. Monitor progress of S. 949, "A bill to amend the Agricultural Marketing Act of 1946 to foster efficient markets and increase competition and transparency among packers that purchase livestock from producers." Monitor progress of H.R. 4103 / S. 2036, "To amend the Packers and Stockyards Act, 1921, to establish the Office of the Special Investigator for Competition Matters, and for other purposes." General engagement on USDA's expected future regulation on Packers & Stockyards Act requirements. General education on the New Swine Inspection System (NSIS) and the impact of the recent court ruling striking down the line speed provisions of the rule. Advocating for USDA to quickly implement its Time Limited Trial of higher line speeds in NSIS plants General education on USDA FSIS Cooperative Interstate Shipment (CIS) Program. General education on the importance of immigrant labor for the agriculture industry workforce. Monitor implementation of P.L. 116-122, Protecting America's Food and Agriculture Act of 2019, all provisions. General education about the severe impact of the COVID-19 pandemic on the U.S. pork industry. Monitor implementation of P.L. 116-123, Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 116-127, Families First Coronavirus Response Act, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 116-136, Coronavirus Aid, Relief, and Economic Security (CARES) Act, provisions related to agriculture, farms, and food production. Coronavirus Food Assistance Program (CFAP), 85 FR 30825. Second round of Coronavirus Food Assistance Program (CFAP2), 85 FR 59380. Coronavirus Food Assistance Program; Additional Assistance, 86 FR 4877. Monitor implementation of P.L. 116-260, the Consolidated Appropriations Act, 2021, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 117-2, the American Rescue Plan Act of 2021, provisions related to agriculture, farms, and food production. Monitor progress of H.R. 1977, "To amend the Internal Revenue Code of 1986 to exclude from gross income interest received on certain loans secured by agricultural real property." General education on agricultural infrastructure priorities. Seeking additional funding for National Animal Health Laboratory Network and veterinary stockpile. Proposed reconciliation bill, provisions related to agriculture, farms, and food production. Coronavirus Food Assistance Program 2; Producers of Sale-Based Commodities and Contract Producers, 86 FR 48013. H.R. 4999, the Exposing Agricultural Trade Suppression Act. Investments and Opportunities for Meat and Poultry Processing Infrastructure, 86 FR 37728. H.R.2471 - Consolidated Appropriations Act, 2022, provisions related to agriculture, farms, and food production. S.3678 - Beagle Brigade Act of 2022, all provisions. Notice of Funds Availability; Spot Market Hog Pandemic Program, 86 FR 71003. Notice of Funds Availability; Spot Market Hog Pandemic Program (SMHPP), 87 FR 15358.

H.R. 1068 -Carried Interest Fairness Act of 2021 H.R. 1321 -NMTC Extension Act of 2021 H.R. 1381 -Mainstreet Tax Certainty Act H.R. 1483 -REHAB Act of 2021 H.R. 1977 -Enhancing Credit Opportunities in Rural America Act H.R. 2143 -Neighborhood Homes Investment Act H.R. 2188 -Reopening America by Supporting Workers and Businesses Act H.R. 2189 -State Tax Freedom Act H.R. 2286 -taxes property transferred by gift or death as sold at market value H.R. 2288 -Investing in Our Communities Act H.R. 2294 -Historic Tax Credit Growth and Opportunity Act H.R. 2439 -SALT Fairness for Working Families Act H.R. 2558 -ALIGN Act H.R. 2573 -Affordable Housing Credit Improvement Act H.R. 2768 -American Housing and Economic Mobility Act of 2021 H.R. 2863 -First Time Homebuyer Act H.R. 3123 -Parity for Non-Traded REITS Act H.R. 3178 -Estate Tax Rate Reduction Act H.R. 3265 -Middle Class Savings Act H.R. 3324 -Incentivize Residential Energy Efficiency Act H.R. 3357 -Rural Jobs Act H.R. 3725 -Relief and Equity Through Small Business Tax Act H.R. 3805 -Millionaires Surtax Act H.R. 3903 -Tax Fairness Act H.R. 4165 -Uplifting First-Time Homebuyers Act of 2021 H.R. 4177 -Expanding Opportunity Zones Act H.R. 4940 -Real Corporate Profits Tax Act of 2021 H.R. 5376 -Build Back Better Act S. 98 -Neighborhood Homes Investment Act S. 456 -New Markets Tax Credit Extension Act of 2021 S. 480-Mainstreet Tax Certainty Act S. 1027-Tax Assistance for Crumbling Foundations Act S. 1136-Affordable Housing Credit Improvement Act S. 1166-Align Act S. 1368-American Housing and Economic Mobility Act S. 1403-Move America Act S. 1479-Home Lead Safety Credit Improvement Act S. 1499-REPAIR Act S. 1519-Save Hotel Jobs Act S. 1598-Carried Interest Fairness Act of 2021 S. 1627-Estate Tax Reduction Act S. 1652-Paying Fair Share Act S. 1653-SMART Act S. 1671-Rural Jobs Act S. 1753-Home Energy Savings Act S. 1768-Hope for HOMES Act S. 1805-SHELTER Act S. 2028-Millionaires Surtax Act S. 2234-Affordable Homes Act S. 2266-Historic Tax Credit Growth and Opportunity Act S. 2680-Real Corporate Profits Tax Act of 2021 S. 2820-DASH Act

H.R. 1068 -Carried Interest Fairness Act of 2021 H.R. 1321 -NMTC Extension Act of 2021 H.R. 1381 -Mainstreet Tax Certainty Act H.R. 1483 -REHAB Act of 2021 H.R. 1977 -Enhancing Credit Opportunities in Rural America Act H.R. 2143 -Neighborhood Homes Investment Act H.R. 2188 -Reopening America by Supporting Workers and Businesses Act H.R. 2189 -State Tax Freedom Act H.R. 2286 -taxes property transferred by gift or death as sold at market value H.R. 2288 -Investing in Our Communities Act H.R. 2294 -Historic Tax Credit Growth and Opportunity Act H.R. 2439 -SALT Fairness for Working Families Act H.R. 2558 -ALIGN Act H.R. 2573 -Affordable Housing Credit Improvement Act H.R. 2768 -American Housing and Economic Mobility Act of 2021 H.R. 2863 -First Time Homebuyer Act H.R. 3123 -Parity for Non-Traded REITS Act H.R. 3178 -Estate Tax Rate Reduction Act H.R. 3265 -Middle Class Savings Act H.R. 3324 -Incentivize Residential Energy Efficiency Act H.R. 3357 -Rural Jobs Act H.R. 3725 -Relief and Equity Through Small Business Tax Act H.R. 3805 -Millionaires Surtax Act H.R. 3903 -Tax Fairness Act H.R. 4165 -Uplifting First-Time Homebuyers Act of 2021 H.R. 4177 -Expanding Opportunity Zones Act H.R. 4940 -Real Corporate Profits Tax Act of 2021 H.R. 5376 -Build Back Better Act S. 98 -Neighborhood Homes Investment Act S. 456 -New Markets Tax Credit Extension Act of 2021 S. 480-Mainstreet Tax Certainty Act S. 1027-Tax Assistance for Crumbling Foundations Act S. 1136-Affordable Housing Credit Improvement Act S. 1166-Align Act S. 1368-American Housing and Economic Mobility Act S. 1403-Move America Act S. 1479-Home Lead Safety Credit Improvement Act S. 1499-REPAIR Act S. 1519-Save Hotel Jobs Act S. 1598-Carried Interest Fairness Act of 2021 S. 1627-Estate Tax Reduction Act S. 1652-Paying Fair Share Act S. 1653-SMART Act S. 1671-Rural Jobs Act S. 1753-Home Energy Savings Act S. 1768-Hope for HOMES Act S. 1805-SHELTER Act S. 2028-Millionaires Surtax Act S. 2234-Affordable Homes Act S. 2266-Historic Tax Credit Growth and Opportunity Act S. 2680-Real Corporate Profits Tax Act of 2021 S. 2820-DASH Act

Monitor implementation of P.L. 115-334, the Agriculture Act of 2018. Monitor progress of Livestock Mandatory Reporting Reauthorization. Monitor progress of S. 949, "A bill to amend the Agricultural Marketing Act of 1946 to foster efficient markets and increase competition and transparency among packers that purchase livestock from producers." Monitor progress of H.R. 4103 / S. 2036, "To amend the Packers and Stockyards Act, 1921, to establish the Office of the Special Investigator for Competition Matters, and for other purposes." General engagement on USDA's expected future regulation on Packers & Stockyards Act requirements. General education on the New Swine Inspection System (NSIS) and the impact of the recent court ruling striking down the line speed provisions of the rule. Advocating for USDA to defend the NSIS rule in light of the recent court ruling striking down the line speed provisions of the rule. General education on USDA FSIS Cooperative Interstate Shipment (CIS) Program. General education on the importance of immigrant labor for the agriculture industry workforce. Monitor implementation of P.L. 116-122, Protecting America's Food and Agriculture Act of 2019, all provisions. General education about the severe impact of the COVID-19 pandemic on the U.S. pork industry. Monitor implementation of P.L. 116-123, Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 116-127, Families First Coronavirus Response Act, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 116-136, Coronavirus Aid, Relief, and Economic Security (CARES) Act, provisions related to agriculture, farms, and food production. Coronavirus Food Assistance Program (CFAP), 85 FR 30825. Second round of Coronavirus Food Assistance Program (CFAP2), 85 FR 59380. Coronavirus Food Assistance Program; Additional Assistance, 86 FR 4877. Monitor implementation of P.L. 116-260, the Consolidated Appropriations Act, 2021, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 117-2, the American Rescue Plan Act of 2021, provisions related to agriculture, farms, and food production. Monitor progress of H.R. 1977, "To amend the Internal Revenue Code of 1986 to exclude from gross income interest received on certain loans secured by agricultural real property." General education on agricultural infrastructure priorities. Seeking additional funding for National Animal Health Laboratory Network and veterinary stockpile. Proposed reconciliation bill, provisions related to agriculture, farms, and food production. Coronavirus Food Assistance Program 2; Producers of Sale-Based Commodities and Contract Producers, 86 FR 48013. H.R. 4999, the Exposing Agricultural Trade Suppression Act. Investments and Opportunities for Meat and Poultry Processing Infrastructure, 86 FR 37728. H.R. 4502, the Labor, Health and Human Services, Education, Agriculture, Rural Development, Energy and Water Development, Financial Services and General Government, Interior, Environment, Military Construction, Veterans Affairs, Transportation, and Housing and Urban Development Appropriations Act, 2022", provisions related to agricultural appropriations.

H.R. 1068 -Carried Interest Fairness Act of 2021 H.R. 1321 -NMTC Extension Act of 2021 H.R. 1381 -Mainstreet Tax Certainty Act H.R. 1483 -REHAB Act of 2021 H.R. 1977 -Enhancing Credit Opportunities in Rural America Act H.R. 2143 -Neighborhood Homes Investment Act H.R. 2188 -Reopening America by Supporting Workers and Businesses Act H.R. 2189 -State Tax Freedom Act H.R. 2286 -taxes property transferred by gift or death as sold at market value H.R. 2288 -Investing in Our Communities Act H.R. 2294 -Historic Tax Credit Growth and Opportunity Act H.R. 2439 -SALT Fairness for Working Families Act H.R. 2558 -ALIGN Act H.R. 2573 -Affordable Housing Credit Improvement Act H.R. 2768 -American Housing and Economic Mobility Act of 2021 H.R. 2863 -First Time Homebuyer Act H.R. 3123 -Parity for Non-Traded REITS Act H.R. 3178 -Estate Tax Rate Reduction Act H.R. 3265 -Middle Class Savings Act H.R. 3324 -Incentivize Residential Energy Efficiency Act H.R. 3357 -Rural Jobs Act H.R. 3725 -Relief and Equity Through Small Business Tax Act H.R. 3805 -Millionaires Surtax Act H.R. 3903 -Tax Fairness Act H.R. 4165 -Uplifting First-Time Homebuyers Act of 2021 H.R. 4177 -Expanding Opportunity Zones Act H.R. 4940 -Real Corporate Profits Tax Act of 2021 H.R. 5376 -Build Back Better Act S. 98 -Neighborhood Homes Investment Act S. 456 -New Markets Tax Credit Extension Act of 2021 S. 480-Mainstreet Tax Certainty Act S. 1027-Tax Assistance for Crumbling Foundations Act S. 1136-Affordable Housing Credit Improvement Act S. 1166-Align Act S. 1368-American Housing and Economic Mobility Act S. 1403-Move America Act S. 1479-Home Lead Safety Credit Improvement Act S. 1499-REPAIR Act S. 1519-Save Hotel Jobs Act S. 1598-Carried Interest Fairness Act of 2021 S. 1627-Estate Tax Reduction Act S. 1652-Paying Fair Share Act S. 1653-SMART Act S. 1671-Rural Jobs Act S. 1753-Home Energy Savings Act S. 1768-Hope for HOMES Act S. 1805-SHELTER Act S. 2028-Millionaires Surtax Act S. 2234-Affordable Homes Act S. 2266-Historic Tax Credit Growth and Opportunity Act S. 2680-Real Corporate Profits Tax Act of 2021 S. 2820-DASH Act

H.R. 1319 American Rescue Plan Act H.R. 1381 Main St Tax Certainty Act. Makes permanent Section 199A of the tax code H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 1977 Enhancing Credit Opportunities in Rural America Act (ECORA) H.R. 5376 Build Back Better Act H.R. 5586 Prohibiting IRS Financial Surveillance Act S. 480 Main Street Tax Certainty Act S. 2202 Enhancing Credit Opportunities for Rural America S. 2387 Small Business Tax Fairness Act S 2857 Protecting Financial Privacy Act S. 3506 Prohibiting IRS Financial Surveillance Act S. Amend 3099 Amendment to the Senate Budget Resolution to bar new IRS reporting Administration Proposal to Close the Tax Gap Bank Account Information Reporting to the IRS Credit Union Tax Exemption ECORA - Tax relief for community banks - Support IRS Financial Transaction Reporting Proposal in budget reconciliation Stepped-Up Basis Tax Proposal (Opposed) Taxation of Capital Gains at Death Taxation of Grantor Trusts and Passive Assets

Client expense: $1,230,000 · Firm income: Not reported

H.R. 1977 Enhancing Credit Opportunities for Rural America Act (ECORA) S. 2202 Enhancing Credit Opportunities for Rural America (ECORA) Farm Credit System - Strategic Planning letter to Farm Credit Administration - Facilitate Young, Beginning, Small (YBS) farmers and ranchers accuracy in counting loans; limit mergers of FCS associations; prohibit non-farm lending and investments outside of Farm Credit Act. USDA Loan Forgiveness

Client expense: $1,230,000 · Firm income: Not reported

Farm Credit System H.R. 1977, The Enhancing Credit Opportunities in Rural America Act S. 2202, ECORA Act of 2021

Client expense: $2,450,000 · Firm income: Not reported

HR 6700: FEMA Empowering Essential Deliveries Act (FEED Act) HR 2797: Beginning Agriculturist Lifetime Employment Act (BALE Act) H.R. 1977: Enhancing Credit Opportunities in Rural America Act (ECORA) Ag/Inclusiveness Community & Facilities Legislation Climate/Food and Agriculture Climate Alliance (FACA) Business & Industry CARES Act for small producers Growing Climate Solutions Act Reconciliation/Build Back Better Bipartisan Infrastructure Package

Client expense: $40,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), HOUSE OF REPRESENTATIVES, SENATE

HR 6700: FEMA Empowering Essential Deliveries Act (FEED Act) HR 2797: Beginning Agriculturist Lifetime Employment Act (BALE Act) H.R. 1977: Enhancing Credit Opportunities in Rural America Act (ECORA) Ag/Inclusiveness Community & Facilities Legislation Climate/Food and Agriculture Climate Alliance (FACA) Business & Industry CARES Act for small producers

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, White House Office

Issues related to HR 1977 and S 2021 (entire bills).

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) Proposal in legislation known as Build Back Better Act (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) H.R. 6037 (all sections) which is legislation to prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program (House and Senate) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Action Alerts - Action Alert regarding proposal in legislation known as Build Back Better Acct (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Fintechs and Special Purpose Fintech National Bank (SPNBs) - OCC Fintechs, including the OCCs SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) - FASB Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) Proposal in legislation known as Build Back Better Act (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies and their parent companies (House) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) H.R. 6037 (all sections) which is legislation to prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program (House and Senate) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Comment Letter to the Federal Reserve, OCC and the FDIC regarding: Proposed Interagency Guidance on Third-Party Relationships - Risk Management (Federal Reserve Docket No. OP-1752, FDIC RIN 3064-ZA26, and OCC Docket No. OCC-2021-0011) (Federal Reserve, OCC and FDIC) Action Alerts - Action Alert regarding proposal in legislation known as Build Back Better Acct (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House) Professor Saule Omarova nomination to be Comptroller of the Currency (OCC) (Senate)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. The Community Bank Positions on Emerging Issues Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Fintechs and Special Purpose Fintech National Bank (SPNBs) - OCC Fintechs, including the OCCs SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) - FASB Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) Proposal in legislation known as Build Back Better Act (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies and their parent companies (House) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) H.R. 6037 (all sections) which is legislation to prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program (House and Senate) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Comment Letter to the Federal Reserve, OCC and the FDIC regarding: Proposed Interagency Guidance on Third-Party Relationships - Risk Management (Federal Reserve Docket No. OP-1752, FDIC RIN 3064-ZA26, and OCC Docket No. OCC-2021-0011) (Federal Reserve, OCC and FDIC) Action Alerts - Action Alert regarding proposal in legislation known as Build Back Better Acct (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House) Professor Saule Omarova nomination to be Comptroller of the Currency (OCC) (Senate)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally-compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. The Community Bank Positions on Emerging Issues Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulations - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House)

H.R. 1977 Enhancing Credit Opportunities for Rural America Act (ECORA) Crop Insurance Coalition Budget Enhancements to Paycheck Protection Program for farmers by allowing gross income calculations. Enhancing USDA loan programs Oppose Farm Credit System (FCS) expansion efforts Oppose Proposal to Change Definition of Metropolitan Statistical Areas USDA Business & Industry (B&I) Loans as part of COVID relief

Client expense: $910,000 · 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, Internal Revenue Service (IRS), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of

H.R. 1319 American Rescue Plan Act H.R. 1381 Main St Tax Certainty Act. Makes permanent Section 199A of the tax code H.R. 1977 Enhancing Credit Opportunities in Rural America Act (ECORA) S. 480 Main Street Tax Certainty Act Credit Union Tax Exemption Deductibility of Expenses Covered by Paycheck Protection Program Loans

Client expense: $910,000 · 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, Internal Revenue Service (IRS), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of

H.R. 1068 -Carried Interest Fairness Act of 2021 H.R. 1321 -NMTC Extension Act of 2021 H.R. 1381 -Mainstreet Tax Certainty Act H.R. 1483 -REHAB Act of 2021 H.R. 1977 -Enhancing Credit Opportunities in Rural America Act H.R. 2143 -Neighborhood Homes Investment Act H.R. 2188 -Reopening America by Supporting Workers and Businesses Act H.R. 2189 -State Tax Freedom Act H.R. 2286 -taxes property transferred by gift or death as sold at market value H.R. 2288 -Investing in Our Communities Act H.R. 2294 -Historic Tax Credit Growth and Opportunity Act H.R. 2439 -SALT Fairness for Working Families Act H.R. 2558 -ALIGN Act H.R. 2573 -Affordable Housing Credit Improvement Act H.R. 2768 -American Housing and Economic Mobility Act of 2021 H.R. 2863 -First Time Homebuyer Act H.R. 3123 -Parity for Non-Traded REITS Act H.R. 3178 -Estate Tax Rate Reduction Act H.R. 3265 -Middle Class Savings Act H.R. 3324 -Incentivize Residential Energy Efficiency Act H.R. 3357 -Rural Jobs Act H.R. 3725 -Relief and Equity Through Small Business Tax Act H.R. 3805 -Millionaires Surtax Act H.R. 3903 -Tax Fairness Act H.R. 4165 -Uplifting First-Time Homebuyers Act of 2021 H.R. 4177 -Expanding Opportunity Zones Act H.R. 4940 -Real Corporate Profits Tax Act of 2021 H.R. 5376 -Build Back Better Act S. 98 -Neighborhood Homes Investment Act S. 456 -New Markets Tax Credit Extension Act of 2021 S. 480-Mainstreet Tax Certainty Act S. 1027-Tax Assistance for Crumbling Foundations Act S. 1136-Affordable Housing Credit Improvement Act S. 1166-Align Act S. 1368-American Housing and Economic Mobility Act S. 1403-Move America Act S. 1479-Home Lead Safety Credit Improvement Act S. 1499-REPAIR Act S. 1519-Save Hotel Jobs Act S. 1598-Carried Interest Fairness Act of 2021 S. 1627-Estate Tax Reduction Act S. 1652-Paying Fair Share Act S. 1653-SMART Act S. 1671-Rural Jobs Act S. 1753-Home Energy Savings Act S. 1768-Hope for HOMES Act S. 1805-SHELTER Act S. 2028-Millionaires Surtax Act S. 2234-Affordable Homes Act S. 2266-Historic Tax Credit Growth and Opportunity Act S. 2680-Real Corporate Profits Tax Act of 2021 S. 2820-DASH Act

Monitor implementation of P.L. 115-334, the Agriculture Act of 2018. Monitor progress of Livestock Mandatory Reporting Reauthorization. Monitor progress of S. 949, "A bill to amend the Agricultural Marketing Act of 1946 to foster efficient markets and increase competition and transparency among packers that purchase livestock from producers." Monitor progress of H.R. 4103 / S. 2036, "To amend the Packers and Stockyards Act, 1921, to establish the Office of the Special Investigator for Competition Matters, and for other purposes." Monitor progress of H.R. 2186, the BALE Act of 2021. General engagement on USDA's expected future regulation on Packers & Stockyards Act requirements. General education on the New Swine Inspection System (NSIS) and the impact of the recent court ruling striking down the line speed provisions of the rule. Advocating for USDA to defend the NSIS rule in light of the recent court ruling striking down the line speed provisions of the rule. General education on USDA FSIS Cooperative Interstate Shipment (CIS) Program. General education on the importance of immigrant labor for the agriculture industry workforce. Monitor implementation of P.L. 116-122, Protecting America's Food and Agriculture Act of 2019, all provisions. General education about the severe impact of the COVID-19 pandemic on the U.S. pork industry. Monitor implementation of P.L. 116-123, Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 116-127, Families First Coronavirus Response Act, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 116-136, Coronavirus Aid, Relief, and Economic Security (CARES) Act, provisions related to agriculture, farms, and food production. Coronavirus Food Assistance Program (CFAP), 85 FR 30825. Second round of Coronavirus Food Assistance Program (CFAP2), 85 FR 59380. Coronavirus Food Assistance Program; Additional Assistance, 86 FR 4877. Monitor implementation of P.L. 116-260, the Consolidated Appropriations Act, 2021, provisions related to agriculture, farms, and food production. Monitor implementation of P.L. 117-2, the American Rescue Plan Act of 2021, provisions related to agriculture, farms, and food production. Monitor progress of H.R. 1977, "To amend the Internal Revenue Code of 1986 to exclude from gross income interest received on certain loans secured by agricultural real property." General education on agricultural infrastructure priorities. Seeking additional funding for National Animal Health Laboratory Network and veterinary stockpile. Proposed reconciliation bill, provisions related to agriculture, farms, and food production. Coronavirus Food Assistance Program 2; Producers of Sale-Based Commodities and Contract Producers, 86 FR 48013. H.R. 4999, the Exposing Agricultural Trade Suppression Act. Investments and Opportunities for Meat and Poultry Processing Infrastructure, 86 FR 37728.

Monitor progress of H.R. 1977, the "Enhancing Credit Opportunities in Rural America Act of 2021." Monitor progress of S. 994, "For the 99.5 Percent Act." Monitor development of the "Sensible Taxation and Equity Promotion Act of 2021." General education on the impact of proposed changes to the tax code on the pork industry.

Client expense: $510,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Environmental Protection Agency (EPA), Federal Highway Administration (FHA), Federal Maritime Commission, Federal Motor Carrier Safety Administration, Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Occupational Safety & Health Administration (OSHA), SENATE, Transportation, Dept of (DOT), U.S. Customs & Border Protection, U.S. Trade Representative (USTR)

Farm Credit System H.R. 1977, The Enhancing Credit Opportunities in Rural America Act S. 2202, ECORA Act of 2021

Client expense: $2,600,000 · Firm income: Not reported

Issues related to HR 1977 and S 2021 (entire bills).

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE