Financial Reporting Threshold Modernization Act

Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal Issues related to credit union coverage under GNMA rules Issues related to Cryptocurrency and digital assets Issues related to the re-nomination of Todd Harper to the NCUA Board Issues related to examining frameworks to address future pandemic risk Issues related to the NDAA rate cap proposals Issues related to the collection of checks and other items by Federal Reserve Banks and Funds Transfers through Fedwire Issues related to the potential modifications to the Federal Reserve policy on payment system risk Issues related to Small Business Bankruptcy Issues related to mortgage-backed securities insurance Issues related to the state of the rural economy Issues related to financial barriers to minority and women-owned businesses' involvement in infrastructure projects Issues related to the President's working group on financial market's report on stablecoins Issues related to economic impact of growing burden of medical debt Issues related to the Credit Union Employee and Member Safety Act in the FY2022 Omnibus Appropriations Act Issues related to the Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) appraisals Issues related to the National Defense Authorization Act FY2023 Issues related to the Administration of the CDFI Fund Issues related to Central Bank Digital Currency Issues related to National Flood Insurance Program Reauthorization Issues related to Reg. II, Dodd Frank, Durbin Amendment, Section 107531 Issues related to G20 Rome Leaders Declaration Issues related to the United States Innovation and Competition Act of 2021 Issues related to Prompt Corrective Action: Earnings Retention Waivers and Net Worth Restoration Plans Issues related to Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking Issues related to the Truth in Savings Act (TISA) and Part 707 of the NCUA Rules and Regulations Issues related to 40 Year Term Loan Modifications Issues related to data security and interchange fees Issues related to credit union loan maturity limits Issues related to credit union business lending caps Issues related to the administration of the CDFI Fund Issues related to the National Defense Authorization Act and Interchange fee issues Issues related to CDFI recertification applications Issues related to Protecting military service members and veterans from Financial scams and fraud Issues related to new consumer financial products and the impacts to workers Issues related to making the CFPB Accountable to Small Business Act Issues related to cyber incident notification requirements for Federally insured credit unions Issues related to ensuring responsible development of digital assets Issues related to the CFPB ensuring data aggregation services market is Fair, transparent and competitive H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2471, the Consolidated Appropriations Act of 2022 H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3684, Infrastructure Investment and Jobs Act, Sec. 90005, Extension of enterprise guarantee fees H.R. 3958, Central Liquidity Facility Enhancement Act H.R. 3962, SECURE Notarization Act of 2021 H.R. 4277, Overdraft protection legislation H.R. 4495, the Down payment Toward Equity Act of 2021 H.R. 4773, the Consumer Financial Protection Commission Act H.R. 4905, Promoting New and Diverse Depository Institutions Act H.R. 5189, Member Business Loan Expansion Act H.R. 5206, Tax Gap Reform and IRS Enforcement Act H.R. 5305, Extending Government Funding and Delivering Emergency Assistance Act H.R. 5451, Protecting Financial Privacy Act of 2021 H.R. 5912, the Close the ILC Loophole Act H.R. 6889, Credit Union Board Modernization Act H.R. 7003, Expanding Financial Access to Underserved Communities Act H.R. 7022, the Strengthening Cyber-Security for the Financial Sector Act H.R. 7733, the CDFI Bond Guarantee Program Improvement Act of 2022 H.R. 7900, SAFE Banking, amendment #983 by Representative Beatty (OH), Amendment #543 offered by Representatives Dean (PA), Armstrong (ND), Perlmutter (CO),Reschenthalter (PA) and Escobar (TX) H.R. 8152, American Data Privacy and Protection Act H.R. 8294, the Transportation, Housing and Urban development, Agriculture, Rural development, Energy and Water Development, Financial Services and General Government, Interior, Environment, Military Construction, and Veterans affairs Appropriations Act of Fiscal Year 2023 H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1625, Securing and Enabling Commerce Using Remote and Electronic Notarization Act S. 1767, the Credit Union Employee and Member Safety Act of 2021 S. 2857, Protection Financial Privacy Act of 2021 S. 3715, E-SIGN Modernization Act of 2022 S. 3813, Veterans Member Business Loan Act S. 4325, Credit Union Board Modernization S. 4356, The Responsible Financial Innovation Act S. 4676, Credit Card Competition Act of 2022 S. 4698, Improving Cybersecurity of Credit Unions Act S. 4879, Expanding Financial Access for Underserved Communities Act S. Amendment 6174, National Defense Authorization Act, Report on Credit and Debit Card

Client expense: $1,070,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA)

Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs. Veterans and Consumers Fair Credit Act (H.R. 5974/S. 2508), provisions relating to regulation of interest rates on financial products.

Client expense: Not reported · Firm income: $50,000

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S.762 and H.R. 5189, to increase the limit on federal credit union loan maturity. MCUL supports H.R. 2311, the Credit Union Governance Modernization Act of 2021 that was signed into law earlier this year. The bill updates how federal credit unions can handle violent members or members that have or seek to commit fraud against the credit union. The bill provides an important update to the FCUA and prioritizes member and credit union staff safety. We support passage of the H.R. 7003, the Expanding Finance Access for Underserved Communities Act, which would allow federal credit unions to add underserved communities to their fields of membership, exempt business loans by FCU's in underserved areas from the member business lending cap and expand the definition of an underserved area to include areas that are more than 10 miles from the nearest financial institution branch. The bill recently passed the House of Representatives as part of a multi-bill financial service related package. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports congressional efforts, including H.R. 2040, to reform bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules. H.R. 2040 would increase the CTR threshold from $10,000 to $30,000 and adjust the SAR threshold from $5,000 to $10,000 for most financial institutions. MCUL is educating members of our congressional delegation on the growing interest among credit union members and credit unions in cryptocurrency. We believe Congress should explore ways to regulate the delivery of financial services using digital currencies to ensure consumers are protected in the same way if they received financial services from a financial institution. We urge Congress to look for ways to enable credit unions and other financial institutions to provide digital assets, so that these services can be properly overseen by federal regulators. Finally, credit unions seek parity with other financial institutions in this area as credit unions must be able to offer digital/crypto products and services directly to their members in the same way that other institutions can to their customers. MCUL stands opposed to a proposal by the U.S. Treasury Department that would require financial institutions to report on an annual basis, the gross inflows and outflows, for member accounts (businesses and individuals). We have been educating our congressional delegation on the issue and urging them to reject including the proposal in legislation. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principle reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal Issues related to credit union coverage under GNMA rules Issues related to Cryptocurrency and digital assets Issues related to the re-nomination of Todd Harper to the NCUA Board Issues related to examining frameworks to address future pandemic risk Issues related to the NDAA rate cap proposals Issues related to the collection of checks and other items by Federal Reserve Banks and Funds Transfers through Fedwire Issues related to the potential modifications to the Federal Reserve policy on payment system risk Issues related to Small Business Bankruptcy Issues related to mortgage-backed securities insurance Issues related to the state of the rural economy Issues related to financial barriers to minority and women-owned businesses' involvement in infrastructure projects Issues related to the President's working group on financial market's report on stablecoins Issues related to economic impact of growing burden of medical debt Issues related to the Credit Union Employee and Member Safety Act in the FY2022 Omnibus Appropriations Act Issues related to the Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) appraisals Issues related to the National Defense Authorization Act FY2023 Issues related to the Administration of the CDFI Fund Issues related to Central Bank Digital Currency Issues related to National Flood Insurance Program Reauthorization Issues related to Reg. II, Dodd Frank, Durbin Amendment, Section 107531 Issues related to G20 Rome Leaders Declaration Issues related to the United States Innovation and Competition Act of 2021 Issues related to Prompt Corrective Action: Earnings Retention Waivers and Net Worth Restoration Plans Issues related to Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking Issues related to the Truth in Savings Act (TISA) and Part 707 of the NCUA Rules and Regulations Issues related to 40 Year Term Loan Modifications H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2471, the Consolidated Appropriations Act of 2022 H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3684, Infrastructure Investment and Jobs Act, Sec. 90005, Extension of enterprise guarantee fees H.R. 3958, Central Liquidity Facility Enhancement Act H.R. 3962, SECURE Notarization Act of 2021 H.R. 4495, the Downpayment Toward Equity Act of 2021 H.R. 4773, the Consumer Financial Protection Commission Act H.R. 4905, Promoting New and Diverse Depository Institutions Act H.R. 5189, Member Business Loan Expansion Act H.R. 5206, Tax Gap Reform and IRS Enforcement Act H.R. 5305, Extending Government Funding and Delivering Emergency Assistance Act H.R. 5451, Protecting Financial Privacy Act of 2021 H.R. 5912, the Close the ILC Loophole Act H.R. 6889, Credit Union Board Modernization Act H.R. 7003, Expanding Financial Access to Underserved Communities Act H.R. 8152, American Data Privacy and Protection Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1625, Securing and Enabling Commerce Using Remote and Electronic Notarization Act S. 1767, the Credit Union Employee and Member Safety Act of 2021 S. 2857, Protection Financial Privacy Act of 2021 S. 3715, E-SIGN Modernization Act of 2022 S. 3813, Veterans Member Business Loan Act S. 4325, Credit Union Board Modernization S. 4356, The Responsible Financial Innovation Act

Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs. Veterans and Consumers Fair Credit Act (H.R. 5974/S. 2508), provisions relating to regulation of interest rates on financial products.

Client expense: Not reported · Firm income: $50,000

Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal Issues related to credit union coverage under GNMA rules Issues related to Cryptocurrency and digital assets Issues related to the re-nomination of Todd Harper to the NCUA Board Issues related to examining frameworks to address future pandemic risk Issues related to the NDAA rate cap proposals Issues related to the collection of checks and other items by Federal Reserve Banks and Funds Transfers through Fedwire Issues related to the potential modifications to the Federal Reserve policy on payment system risk Issues related to Small Business Bankruptcy Issues related to mortgage-backed securities insurance Issues related to the state of the rural economy Issues related to financial barriers to minority and women-owned businesses' involvement in infrastructure projects Issues related to the President's working group on financial market's report on stablecoins Issues related to economic impact of growing burden of medical debt Issues related to the Credit Union Employee and Member Safety Act in the FY2022 Omnibus Appropriations Act Issues related to the Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) appraisals H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2471, the Consolidated Appropriations Act of 2022 H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3684, Infrastructure Investment and Jobs Act, Sec. 90005, Extension of enterprise guarantee fees H.R. 3958, Central Liquidity Facility Enhancement Act H.R. 3962, SECURE Notarization Act of 2021 H.R. 4773, the Consumer Financial Protection Commission Act H.R. 4905, Promoting New and Diverse Depository Institutions Act H.R. 5206, Tax Gap Reform and IRS Enforcement Act H.R. 5305, Extending Government Funding and Delivering Emergency Assistance Act H.R. 5451, Protecting Financial Privacy Act of 2021 H.R. 5189, Member Business Loan Expansion Act H.R. 6889, Credit Union Board Modernization Act H.R. 7003, Expanding Financial Access to Underserved Communities Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1625, Securing and Enabling Commerce Using Remote and Electronic Notarization Act S. 1767, the Credit Union Employee and Member Safety Act of 2021 S. 2857, Protection Financial Privacy Act of 2021 S. 3715, E-SIGN Modernization Act of 2022 S. 3813, Veterans Member Business Loan Act

Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs. Veterans and Consumers Fair Credit Act (H.R. 5974/S. 2508), provisions relating to regulation of interest rates on financial products.

Client expense: Not reported · Firm income: $50,000

Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs. Veterans and Consumers Fair Credit Act (H.R. 5974/S. 2508), provisions relating to regulation of interest rates on financial products.

Client expense: Not reported · Firm income: $50,000

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S.762 and H.R. 5189, to increase the limit on federal credit union loan maturity. Additionally, as a result of the ongoing COVID-19 crisis, Rep. Brad Sherman (D-CA-30) introduced legislation we are supporting, H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act. The bill would exempt credit union loans related to the pandemic from the MBL for a period of three years. MCUL supports H.R. 2311, the Credit Union Governance Modernization Act of 2021 that was recently signed into law. The bill updates how federal credit unions can handle violent members or members that have or seek to commit fraud against the credit union. The bill provides an important update to the FCUA and prioritizes member and credit union staff safety. We support passage of the H.R. 7003, the Expanding Finance Access for Underserved Communities Act, which would allow federal credit unions to add underserved communities to their fields of membership, exempt business loans by FCU's in underserved areas from the member business lending cap and expand the definition of an underserved area to include areas that are more than 10 miles from the nearest financial institution branch. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports congressional efforts, including H.R. 2040, to reform bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules. H.R. 2040 would increase the CTR threshold from $10,000 to $30,000 and adjust the SAR threshold from $5,000 to $10,000 for most financial institutions. MCUL is educating members of our congressional delegation on the growing interest among credit union members and credit unions in cryptocurrency. We believe Congress should explore ways to regulate the delivery of financial services using digital currencies to ensure consumers are protected in the same way if they received financial services from a financial institution. We urge Congress to look for ways to enable credit unions and other financial institutions to provide digital assets, so that these services can be properly overseen by federal regulators. Finally, credit unions seek parity with other financial institutions in this area as credit unions must be able to offer digital/crypto products and services directly to their members in the same way that other institutions can to their customers. MCUL stands opposed to a proposal by the U.S. Treasury Department that would require financial institutions to report on an annual basis, the gross inflows and outflows, for member accounts (businesses and individuals). We have been educating our congressional delegation on the issue and urging them to reject including the proposal in legislation. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principle reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3958, Central Liquidity Facility Enhancement Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1767, the Credit Union Employee and Member Safety Act of 2021

Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs. Veterans and Consumers Fair Credit Act (H.R. 5974/S. 2508), provisions relating to regulation of interest rates on financial products.

Client expense: Not reported · Firm income: $50,000

Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal Issues related to credit union coverage under GNMA rules Issues related to Cryptocurrency and digital assets Issues related to the re-nomination of Todd Harper to the NCUA Board Issues related to examining frameworks to address future pandemic risk Issues related to the NDAA rate cap proposals Issues related to the collection of checks and other items by Federal Reserve Banks and Funds Transfers through Fedwire Issues related to the potential modifications to the Federal Reserve policy on payment system risk H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3684, Infrastructure Investment and Jobs Act, Sec. 90005, Extension of enterprise guarantee fees H.R. 3958, Central Liquidity Facility Enhancement Act H.R. 4773, the Consumer Financial Protection Commission Act H.R. 4905, Promoting New and Diverse Depository Institutions Act H.R. 5305, Extending Government Funding and Delivering Emergency Assistance Act H.R. 5189, Member Business Loan Expansion Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1767, the Credit Union Employee and Member Safety Act of 2021

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S.762, to eliminate the restriction on federal credit union loan maturity. Additionally, as a result of the ongoing COVID-19 crisis, Rep. Brad Sherman (D-CA-30) introduced legislation we are supporting, H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act. The bill would exempt credit union loans related to the pandemic from the MBL for a period of three years. MCUL supports H.R. 2311, the Credit Union Governance Modernization Act of 2021 makes updates to how federal credit unions can handle violent members or members that have or seek to commit fraud against the credit union. The bill provides an important update to the FCUA and prioritizes member and credit union staff safety. We support passage of the Expanding Finance Access for Underserved Communities Act which would allow federal credit unions to add underserved communities to their fields of membership, exempt business loans by FCU's in underserved areas from the member business lending cap and expand the definition of an underserved area to include areas that are more than 10 miles from the nearest financial institution branch. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports congressional efforts, including H.R. 2040, to reform bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules. H.R. 2040 would increase the CTR threshold from $10,000 to $30,000 and adjust the SAR threshold from $5,000 to $10,000 for most financial institutions. MCUL stands opposed to a proposal by the U.S. Treasury Department that would require financial institutions to report on an annual basis, the gross inflows and outflows, for member accounts (businesses and individuals). We have been educating our congressional delegation on the issue and urging them to reject including the proposal in legislation. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principle reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

H.R. 133 Consolidated Appropriations Act, 2021 Economic Impact Payments H.R. 527 CFPB Dual Mandate and Economic Analysis Act H.R. 766 TAILOR Act H.R. 1319 American Rescue Plan Act of 2021 H.R. 1799 The PPP Extension Act H.R. 1996 SAFE Banking Act H.R. 2040 The Financial Reporting Modernization Act H.R. 2211 Central Bank Digital Currency Study Act H.J. Res. 25 Congressional disapproval of OCC True Lender Rule S. 49 No CFPB in PPP Act S. 524 A bill to create a Homeowner Assistance Fund at the Department of Treasury S. 563 Fair Access to Banking Act S. 723 PPP Extension Act S. 823 A bill to amend the American Rescue Plan Act of 2021 to provide for protection of recovery rebates. S. 910 SAFE Banking Act S.J. Res. 15 Congressional disapproval of OCC True Lender Rule Bank Capital and Accounting Relief Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue BitPay National Trust and Paxos National Trust OCC Trust Charter Applications Brokered Deposits Cannabis Banking CARES Act, Economic Impact Payments CARES Act, Paycheck Protection Program Implementation Central Bank Digital Currency/Digital Dollar Climate-Related Financial Regulation Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Consumer Access to Financial Records Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Current Expected Credit Losses (CECL) Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation Economic Impact Payments (EIP) Garnishment Exemption EIP - Recommendations for Improving Delivery of Payments to Americans Eliminating Corporate Shadow Banking Emergency Capital Investment Program Implementation Equal treatment between community banks and credit unions when assessing rent and related charges on military bases. Exclusion of Paycheck Protection Program Loans from Calculation of Bank Asset Thresholds Fed Accounts Figure Bank, NA Charter Application Fintech/Banking Relationships Fintech Regulatory Requirements Financial Data Sharing Safety Act First Blockchain Bank & Trust, N.A. Charter Application Flood Insurance Reauthorization GM Financial Bank Deposit Insurance Application Industrial Loan Corporation Loophole Reforms/ Square (ILC) and Rakuten Deposit Insurance Applications Interest Rate Caps Minority Depository Institutions Issues Mortgage Servicer Liquidity Facility Nomination of Isabel Guzman to serve as the Administrator of the U.S. Small Business Administration (SBA) Nomination of Dr. Janet Yellen to serve as Secretary of the Treasury OCC Interpretive Letter 1176/Protego & Anchorage Conversion Applications OCC Proposed Payments Charter Postal Banking Regulatory Burden Relief for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Loan Program Funding and Terms Troubled Debt Restructuring

Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal Issues related to credit union coverage under GNMA rules Issues related to Cryptocurrency and digital assets Issues related to the re-nomination of Todd Harper to the NCUA Board Issues related to examining frameworks to address future pandemic risk Issues related to the NDAA rate cap proposals Issues related to the collection of checks and other items by Federal Reserve Banks and Funds Transfers through Fedwire Issues related to the potential modifications to the Federal Reserve policy on payment system risk H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3684, Infrastructure Investment and Jobs Act, Sec. 90005, Extension of enterprise guarantee fees H.R. 3958, Central Liquidity Facility Enhancement Act H.R. 4773, the Consumer Financial Protection Commission Act H.R. 4905, Promoting New and Diverse Depository Institutions Act H.R. 5305, Extending Government Funding and Delivering Emergency Assistance Act H.R. 5189, Member Business Loan Expansion Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1767, the Credit Union Employee and Member Safety Act of 2021

Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs.

Client expense: Not reported · Firm income: $50,000

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S.762, to eliminate the restriction on federal credit union loan maturity. Additionally, as a result of the ongoing COVID-19 crisis, Rep. Brad Sherman (D-CA-30) introduced legislation we are supporting, H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act. The bill would exempt credit union loans related to the pandemic from the MBL for a period of three years. MCUL supports H.R. 2311, the Credit Union Governance Modernization Act of 2021 makes updates to how federal credit unions can handle violent members or members that have or seek to commit fraud against the credit union. The bill provides an important update to the FCUA and prioritizes member and credit union staff safety. Lastly, we support passage of the Expanding Finance Access for Underserved Communities Act which would allow federal credit unions to add underserved communities to their fields of membership, exempt business loans by FCU's in underserved areas from the member business lending cap and expand the definition of an underserved area to include areas that are more than 10 miles from the nearest financial institution branch. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports congressional efforts, including H.R. 2040, to reform bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules. H.R. 2040 would increase the CTR threshold from $10,000 to $30,000 and adjust the SAR threshold from $5,000 to $10,000 for most financial institutions. MCUL will educate members of the Michigan congressional delegation on the importance of voluntary overdraft protection services/products for members and member support for the services/products. We will oppose legislative efforts to limit the ability of financial institutions to offer these voluntary/opt in services. MCUL stands opposed to a proposal by the U.S. Treasury Department that would require financial institutions to report on an annual basis, the gross inflows and outflows, for member accounts (businesses and individuals). We have been educating our congressional delegation on the issue and urging them to reject including the proposal in legislation. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principle reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S.762, to eliminate the restriction on federal credit union loan maturity. Additionally, as a result of the ongoing COVID-19 crisis, Rep. Brad Sherman (D-CA-30) introduced legislation we are supporting, H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act. The bill would exempt credit union loans related to the pandemic from the MBL for a period of three years. MCUL supports H.R. 2311, the Credit Union Governance Modernization Act of 2021 makes updates to how federal credit unions can handle violent members or members that have or seek to commit fraud against the credit union. The bill provides an important update to the FCUA and prioritizes member and credit union staff safety. Lastly, we support passage of the Expanding Finance Access for Underserved Communities Act which would allow federal credit unions to add underserved communities to their fields of membership, exempt business loans by FCU's in underserved areas from the member business lending cap and expand the definition of an underserved area to include areas that are more than 10 miles from the nearest financial institution branch. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports congressional efforts, including H.R. 2040, to reform bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules. H.R. 2040 would increase the CTR threshold from $10,000 to $30,000 and adjust the SAR threshold from $5,000 to $10,000 for most financial institutions. MCUL will educate members of the Michigan congressional delegation on the importance of voluntary overdraft protection services/products for members and member support for the services/products. We will oppose legislative efforts to limit the ability of financial institutions to offer these voluntary/opt in services. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principle reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) Issues related to the discussion draft of the Expanding Financial Access for Underserved Communities Act Issues related to the NCUA's Capitalization of Interest in Connection with Loan Workouts and Modifications Rulemaking Issues related to the Federal Reserve's proposed Regulation II Issues related to Capitalizing interest on consumer loans Issues related to Cryptocurrency Issues related to proposed postal banking pilot program Issues related to proposed new tax reporting requirements for financial institutions Issues related to the implementation of consumer financial protection laws Issues related to the safety and soundness regulations of credit unions Issues related to investment authority Issues related to BSA / AML regulation and Cannabis Banking Issues related to rate cap legislation and the Military Lending Act Issues related to credit card interchange fees and routing Issues related to FY22 National Defense Authorization Act Issues related to NCUA Central Liquidity Facility Issues related to Climate and Natural disaster risk management at regulated entities Issues related to PSPA / QM Conflict Issues related to CAMELS proposal H.J. Res 35, providing for Congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" S.J. Res 15, a joint resolution providing for congressional disapproval under Chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders" H.R. 133, the Consolidated Appropriations Act (2020) H.R. 1319, American Rescue Plan Act of 2021 H.R. 1395, the Housing Financial Literacy Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes H.R. 2547, the Comprehensive Debt Collection Improvement Act H.R. 3958, Central Liquidity Facility Enhancement Act S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, SAFE Banking Act of 2021 S. 1368, American Housing and Economic Mobility Act of 2021 S. 1767, the Credit Union Employee and Member Safety Act of 2021

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S.762, to eliminate the restriction on federal credit union loan maturity. Additionally, as a result of the ongoing COVID-19 crisis, Rep. Brad Sherman (D-CA-30) introduced legislation we are supporting, H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act. The bill would exempt credit union loans related to the pandemic from the MBL for a period of three years. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports congressional efforts, including H.R. 2040, to reform bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules. H.R. 2040 would increase the CTR threshold from $10,000 to $30,000 and adjust the SAR threshold from $5,000 to $10,000 for most financial institutions. MCUL supported/supports passage of legislation making reforms to the Paycheck Protection Act, including the PPP Extension Act of 2021 which extends the application period from March 31st to May 31, 2021. MCUL will educate members of the Michigan congressional delegation on the importance of voluntary overdraft protection services/products for members and member support for the services/products. We will oppose legislative efforts to limit the ability of financial institutions to offer these voluntary/opt in services. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principle reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.

H.R. 1319 American Rescue Plan Act of 2021 H.R. 1711 Financial Inclusion in Banking Act of 2021 H.R. 1799 The PPP Extension Act H.R. 1996 SAFE Banking Act H.R. 2040 The Financial Reporting Modernization Act H.R. 2211 Central Bank Digital Currency Study Act H.R. 2547 Comprehensive Debt Collection Improvement Act H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 2570 Climate Risk Disclosure Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing H.R. 3910 To Amend the Gramm Leach Bliley Act to give the CFPB rulemaking and enforcement authority over the safeguards rule with respect to data aggregators H.R. 3911 To Amend the GLBA to establish procedures for disclosures by financial institutions of nonpublic personal information H.R. 3912 To amend the GBLA to require consumers to opt in before a financial institution may share the nonpublic personal information H.R. 3926 Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2021 H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.J. Res. 25 Congressional disapproval of OCC True Lender Rule S. 723 PPP Extension Act S. 910 SAFE Banking Act S. 1625 Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2021 S.J. Res. 15 Congressional disapproval of OCC True Lender Rule Artificial Intelligence--Use by Financial Institutions Bank Capital and Accounting Relief Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Brokered Deposits Cannabis Banking CARES Act, Economic Impact Payments CARES Act, Paycheck Protection Program Implementation Central Bank Digital Currency/Digital Dollar Climate Crisis Financial Stability Act (draft) Climate Crisis Financial Stability Act (draft) Climate-Related Financial Regulation Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Credit Reporting Credit Union Acquisitions of Community Banks/Vystar CU-Heritage Southeast Bank Transaction and Wings Financial CU/Brainerd Savings and Loan Transaction Credit Union Business Lending Powers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Current Expected Credit Losses (CECL) Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation DFA 1071- Small Business Loan Data Collection Durbin Amendment on Interchange; Extension to Credit Cards Economic Impact Payments (EIP) Garnishment Exemption EIP - Recommendations for Improving Delivery of Payments to Americans Emergency Capital Investment Program Implementation Equal treatment between community banks and credit unions when assessing rent and related charges on military bases. Fair Lending Federal Reserve Accounts for Consumers Figure Bank, NA Charter Application Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Interest Rate Caps LIBOR Transition Minority Depository Institutions Issues Mortgage Servicer Liquidity Facility OCC Interpretive Letter 1176/Protego & Anchorage Conversion Applications OCC Proposed Payments Charter Paycheck Protection Program Loans Exclusion from Calculation of Bank Asset Thresholds Postal Banking Regulatory and Tax Relief for Community Banks SBA 7(a) Loan Program Funding and Terms Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Troubled Debt Restructuring

S. 1200: SAFE Banking Act of 2019Support H.R. 1996: SAFE Banking Act of 2021; Support S.J.Res. 15: A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders".Oppose H.R. 2040: Financial Reporting Threshold Modernization ActSupport H.R. 3198: Comprehensive Regulatory Review Act; Support H.R. 3768: Unlocking Capital for Small Businesses Act of 2019Support H.R. 4860: Crowdfunding Amendments ActSupport H.R. 527: CFPB Dual Mandate and Economic Analysis ActSupport S. 910: SAFE Banking Act of 2021Support S.J.Res. 15: A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders".Oppose

Client expense: $320,000 · Firm income: Not reported

Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs.

Client expense: Not reported · Firm income: $50,000

H.R. 133 Consolidated Appropriations Act, 2021 Economic Impact Payments H.R. 527 CFPB Dual Mandate and Economic Analysis Act H.R. 766 TAILOR Act H.R. 1319 American Rescue Plan Act of 2021 H.R. 1799 The PPP Extension Act H.R. 1996 SAFE Banking Act H.R. 2040 The Financial Reporting Modernization Act H.R. 2211 Central Bank Digital Currency Study Act H.J. Res. 25 Congressional disapproval of OCC True Lender Rule S. 49 No CFPB in PPP Act S. 524 A bill to create a Homeowner Assistance Fund at the Department of Treasury S. 563 Fair Access to Banking Act S. 723 PPP Extension Act S. 823 A bill to amend the American Rescue Plan Act of 2021 to provide for protection of recovery rebates. S. 910 SAFE Banking Act S.J. Res. 15 Congressional disapproval of OCC True Lender Rule Bank Capital and Accounting Relief Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue BitPay National Trust and Paxos National Trust OCC Trust Charter Applications Brokered Deposits Cannabis Banking CARES Act, Economic Impact Payments CARES Act, Paycheck Protection Program Implementation Central Bank Digital Currency/Digital Dollar Climate-Related Financial Regulation Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Consumer Access to Financial Records Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Current Expected Credit Losses (CECL) Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation Economic Impact Payments (EIP) Garnishment Exemption EIP - Recommendations for Improving Delivery of Payments to Americans Eliminating Corporate Shadow Banking Emergency Capital Investment Program Implementation Equal treatment between community banks and credit unions when assessing rent and related charges on military bases. Exclusion of Paycheck Protection Program Loans from Calculation of Bank Asset Thresholds Fed Accounts Figure Bank, NA Charter Application Fintech/Banking Relationships Fintech Regulatory Requirements Financial Data Sharing Safety Act First Blockchain Bank & Trust, N.A. Charter Application Flood Insurance Reauthorization GM Financial Bank Deposit Insurance Application Industrial Loan Corporation Loophole Reforms/ Square (ILC) and Rakuten Deposit Insurance Applications Interest Rate Caps Minority Depository Institutions Issues Mortgage Servicer Liquidity Facility Nomination of Isabel Guzman to serve as the Administrator of the U.S. Small Business Administration (SBA) Nomination of Dr. Janet Yellen to serve as Secretary of the Treasury OCC Interpretive Letter 1176/Protego & Anchorage Conversion Applications OCC Proposed Payments Charter Postal Banking Regulatory Burden Relief for Community Banks Regulatory and Tax Relief for Community Banks SBA 7(a) Loan Program Funding and Terms Troubled Debt Restructuring

Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday lending, auto title lending, and regulatory process. Potential legislation to regulate interest rates on financial products. S.J. Res. 15 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by Office of the Comptroller of the Currency relating to "National Banks and Federal Savings Associations as Lenders." Implementation of the CARES Act (PL 116-136), provisions relating to the payroll protection program. Implementation of the American Rescue Plan Act of 2021 (PL-117-2), provisions relating to the payroll protection program. Legislative proposals relating to prohibiting retail businesses from refusing cash payments. H.R. 2040, The Financial Reporting Threshold Modernization Act, provisions relating to updating thresholds for certain currency transaction reports and suspicious activity reports. H.R. 1996, The SAFE Banking Act of 2021, provisions relating to the provision of financial services to cannabis-related businesses and service providers S. 563, The Fair Access to Banking Act, provisions relating to fair access to financial services and discount window lending programs.

Client expense: Not reported · Firm income: $50,000

Issues related to Federal Credit Union Charter Modernization Issues related to credit union operations Issues related to credit union field of membership Issues related to credit union service organization Issues related to NCUA's low income designation regulation Issues related to NCUA examination procedures Issues related to NCUA's regulation regarding liquidity Issues related to NCUA's rulemaking process Issues related to NCUA's regulatory review process Issues related to Federal Credit Union Bylaws Issues related to credit union loan maturity restrictions Issues related to credit union investment authority Issues related to Regulation of Federal Credit Union By-Laws Issues related to credit unions' incidental powers Issues related to credit union service to marijuana businesses Issues related to material loss reports of the NCUA Office of Inspector General Issues related to the regulation of corporate credit unions Issues related to fixed assets Issues related to credit union conversions Issues related to credit union call report modernization Issues related to NCUA's Corporate Credit Union Stabilization Plan Issues related to NCUA's budget and the overhead transfer rate Issues related to Credit Union Service Organizations (CUSO) Issues related to the authority of the CFPB to exempt credit unions from its rulemaking Issues related to the CFPB rule to remittances and international wire transfers Issues related to CFPB's Leadership structure and Installing a Board rather than a Director Issues related to codifying the CFPB's Credit Union Advisory Council Issues related to requiring SBREFA Panels for CFPB Rulemakings Issues related to overdraft protection and check ordering practices Issues related to mortgage servicing Issues related to mortgage loan originator compensation and qualifications Issues related to the CFPB's rule regarding qualified mortgage / ability to repay Issues related to the CFPB's regulation on Home Mortgage Disclosure Act (Regulation C) Issues related to the CFPB's regulation on Truth-In-Lending Act / Real Estate Settlement Procedures Act Integrated Disclosures Issues related to the payday, vehicle title, and similar lending Issues related to short term lending products and advance deposit products Issues related to the CFPB's consumer complaint database Issues related to the CFPB's consumer complaint database Issues related to the Department of Justice's investigation entitled, "Operation Choke Point" Issues related to indirect auto lending Issues related to credit union service to unbanked and underbanked consumers Issues related to the Financial Accounting Standards Board (FASB) Issues related to data and cyber security Issues related to mobile banking and mobile payments Issues related to identity theft and fraud reduction Issues related to secure payments Issues related to merchant data breaches Issues related to the payments system and innovation Issues related to the Fed's implementation of same-day ACH Issues related to the Bank Secrecy Act and Currency Transaction Reporting Requirements Issues related to the oversight of the Federal Housing Administration Issues related to the USDA Rural Development Loan Program Issues related to the Federal Home Loan Bank System Issues related to membership eligibility in the Federal Home Loan Bank System Issues related to financial literacy Issues related to Housing Finance Reform Issues related to student lending Issues related to the Economic Growth and Regulatory Paperwork Reduction Act Process Issues related to retirement security Issues related to flood insurance Issues related to consumer's access to records Issues related to Interchange Fees Issues related to the Equal Credit Opportunity Act Issues related to the Fair Housing Act Issues related to the merger of credit unions Issues related to the Real Estate Settlement Procedures Act Issues related to Community Reinvestment Act Issues related to Regulation Z Issues related to Military Lending Act Issues related to Financial Technology Issues related to Small Business Lending Data Collection requirements Issues related to Involuntary liquidation of Federal Credit Unions and Claims Procedures Issues related to Web-Bases Quantitative Testing of Point of Sale / ATM Overdraft Disclosure Forms Issues related to residential appraisals Issues related to FHA appraisal certification Issues related to FHA and USDA Loan Modifications Issues related to Faster Payments Issues related to the Fair Credit Reporting Act Issues related to cooperative funding sources in federal appropriations legislation Issues related to regulation of debt collection activity Issues related to capital reform for credit unions Issues related to diversity and inclusion in Financial Services Issues related to Section 124 of the Federal Credit Union Act Issues related to the Consumer Financial Protection Bureau's No-Action Letters and the BCFP Product Sandbox Issues related to enterprise validation and approval of credit score models Issues related to the availability of Funds and Collection of Checks (Regulation CC) Issues related to arbitration clauses Issues related to SBA 7(a) loan program Issues related to financial institutions operating on military installations Issues related to postal banking Issues related to Telephone Consumer Protection Act Issues related to financial technology (FINTECH) Issues related to robocalls and the draft Declatory Ruling (the ruling) and Third Further Notice of Proposted Rulemaking (FNPRM) CG Docket No 17-59, WC Docket No. 17 - 97 Issues related to payday and small dollar lending Issues related to leases of non-excess property on military bases Issues related to Opportunity Zones Issues related to minority homeownership Issues related to the ability of Federal Credit unions to establish their own fiscal year Issues related to a requirement that Federal credit unions file certain information regarding loan officers Issues related to enhancing flexibility of Federal Credit Unions to schedule board meetings Issues related to removing certain outdated responsibilites of Federal credit union board of directors Issues related to permitting Federal credit unions to expel disruptive members for just cause without a vote Issues related to permitting balloting for conversions from state to federal charter and from federal to state charter to be conducted electronically Issues related to PACE Loans Issues related to minority depository insitutions Issues related to AI and cloud computing Issues related to the Consumer Online Privacy Rights Act Issues related to COVID-19 crisis response legislation Issues related to the Paycheck Protection Program Issues related to Taxi Medallion loans Issues related to QRM Risk Retection Review Issues related to NCUA's proposed rule on combination transactions Issues related to the regulation of credit unions as employers Issues related to liability protections for businesses Issues related to remote notary Issues related to digital identity legislation Issues related Paid Leave Payroll Tax Credits Issues related to Economic Impact Payments Issues related to Fed Accounts Issues related to the Federal Reserve's Main Street Lending Program Issues related to troubled debt restructuring Issues related to Prompt Corective Action requirements Issues related to NCUA subordinated debt rulemaking Issues related to Uniform Residential Loan Application Issues related to digitalization of money Issues related to electronic signatures on wire transfer documents Issues related to cybercriminal activity during COVID-19 Issues related to lender forebearance Issues related to Paycheck Protection Program forgiveness process Issues related to Agriculture Lending Issues related to OCC payment charters Issues related to the Student Empowerment and Financial Literacy Act Issues related to OCC National Bank and Savings Association Digital Activities Issues related to the treatment of certain COVID-19 Loss Mitigation options under RESPA (Reg X) Issues related to premium assessments by the National Credit Union Share Insurance Issues related to the proposed exclusion of PPP Loans from financial institution asset calculations Issues related to Section 4013 of the CARES Act Issues related to Section 4016 of the CARES Act Issues related tot he oversight of prudential regulators Issues related to PAL 1 Program Issues related to credit union asset size thresholds for regulatory compliance Issues related to NCUA MERIT examination system Issues related to NCUA Derivatives rulemaking Issues related to mortgage servicer assistance Issues related to Section 4022 of the CARES Act Issues related to the ability of NCUA to offer forbearance from Prompt Corrective Action Requirements Issues related to Temporarily Excluding Certain Low-Risk Assets from the Credit Union Net Worth Ratio Issues related to London Inter-Bank Offered Rate (LIBOR) Issues related to the regulation of Federal Employment Laws Issues related to the Office of Comptroller Charter Issues related to the Crypto Charter Issues related to the Solar Winds Data Breach Issues related to PPP Loan Necessity Questionnaires Issues related to SBA Economic Injury Disaster Loan Advances Issues related to Seasoned QM Loan Definitions Issues related to FHFA Strategic Plan for 2021-2024 Issues related to GSE Housing Goals Issues related to Member Business Lending Issues related to interest rate caps Issues related to Federal Housing Finance Agency's (FHFA) recapitalization plans Issues related to rental and mortgage payment assistance Issues related to BSA / AML Regulation Issues related to CECL Accounting requirements Issues related to climate control issues and effect on financial institutions Issues related to UDAAP guidance and requirements Issues related to risk-based capital requirements Issues related to NCUA's Communications and Transparency Issues related to Enterprise liquidity framework (FHFA) H.R. 133, the Consolidated Appropriations Act (2020) H.R. 1319, American Rescue Plan Act of 2021 H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act 0f 2021 H.R. 1996, Secure and Fair Enforcement (SAFE) Banking Act of 2021 H.R. 2040, the Financial Reporting Threshold Modernization Act H.R. 2311, To amend the Federal Credit Union Act to modernize certain processes regarding expulsion of credit union members for cause, and for other purposes S. 254, A bill to establish a Homeowner Assistance Fund at the Department of the Treasury S. 337, Stop Senior Scams Act S. 762, A bill to provide the National Credit Union Administration Board flexibility to increase Federal credit union loan maturities, and for other purposes S. 910, A bill to create protections for financial institutions that provide financial services to cannabis-related legitimate businesses and service providers for such businesses, and for other purposes

Lapses by the retail industry/merchants in securing consumer information continue to be extremely problematic and costly to consumers and financial institutions. MCUL is advocating that Congress hold retailers to the same or similar data security standards as the financial service industry has to abide by and require retailers notify credit unions sooner once a breach occurs. We support legislation that ensures all businesses, institutions and organizations that collect, use or share personal data are subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly change our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting S.762, to eliminate the restriction on federal credit union loan maturity. Additionally, as a result of the ongoing COVID-19 crisis, Rep. Brad Sherman (D-CA-30) introduced legislation we are supporting, H.R. 6550, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act. The bill would exempt credit union loans related to the pandemic from the MBL for a period of three years. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and our members. MCUL supports congressional efforts, including H.R. 2040, to reform bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules. H.R. 2040 would increase the CTR threshold from $10,000 to $30,000 and adjust the SAR threshold from $5,000 to $10,000 for most financial institutions. MCUL supported/supports passage of legislation making reforms to the Paycheck Protection Act, including the PPP Extension Act of 2021 which extends the application period from March 31st to May 31, 2021. MCUL will educate members of the Michigan congressional delegation on the importance of voluntary overdraft protection services/products for members and member support for the services/products. We will oppose legislative efforts to limit the ability of financial institutions to offer these voluntary/opt in services. Lastly, credit unions are not-for-profit member-owned financial institutions, owned by members they service. Credit unions consumer-focused model is self-regulating and a principle reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.